United States
Environmental Protection
Agency
Water and Waste Management
Effluent Guidelines Division
WH-552      	
Washington DC 20460
    EPA-440/1-83/019-b
440183019B3
Development
Document for
Effluent  Limitations
Guidelines and
Standards for  the
             Proposed
Nonferrous Metals

Point  Source Category
Volume
Supplemental Development
Documents For:

Primary Tungsten
Primary Columbium - Tantalum
Secondary Silver
Secondary Lead
Secondary Aluminum
Secondary Copper

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                 DEVELOPMENT DOCUMENT

                         for

    EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS

                       for the

NONFERROUS METALS MANUFACTURING POINT SOURCE CATEGORY

             Primary Tungsten Subcategory
        Primary Columbium-Tantalum Subcategory
             Secondary Silver Subcategory
             Secondary Copper Subcategory
              Secondary Lead Subcategory
            Secondary Aluminum Subcategory
              Frederick A. Eidsness, Jr.
          Assistant Administrator for Water
                   Steven Schatzow
                       Director
      Office of Water Regulations and Standards
              Jeffery D. Denit, Director
             Effluent Guidelines Division
              Ernst P. Hall, P.E. , Chief r..,,..^ ... .„,„, pi0tcc!;on Agency
             Metals and Machinery Branch
                                                  -,:T) Street
                James R. Berlow, P.E.Cni
              Technical Project Officer
                      March 1983
         U.S. Environmental Protection Agency
                   Office of Water
      Office of Water Regulations and Standards
             Effluent Guidelines Division
               Washington, D.C.  20460

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    This development document  for  nonferrous  metals  manufacturing
    (phase I) consists of three volumes,  a  general development docu-
    ment and  two volumes of  subcategory-specific  supplements.   The
    Agency intends to modify the General  Development Document, as
    necessary, and produce additional  volumes of  subcategory-specific
    supplements in order to  support  limitations and  standards  for
    additional nonferrous metals manufacturing (phase II)  subcate-
    gories as they are proposed and  promulgated.
U,S. Envircrm—*

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                   PRIMARY TUNGSTEN SUBCATEGORY

                        TABLE OF CONTENTS


Section

I         SUMMARY AND CONCLUSIONS	     1

II        RECOMMENDATIONS	     3

          TUNGSTIC ACID RINSE BPT EFFLUENT LIMITATIONS .  .     3

          ACID LEACH WET AIR POLLUTION CONTROL
          BPT EFFLUENT LIMITATIONS 	     4

          ALKALI LEACH WASH BPT EFFLUENT LIMITATIONS ...     4

          ION-EXCHANGE RAFFINATE BPT EFFLUENT
          LIMITATIONS	     4

          CALCIUM TUNGSTATE PRECIPITATE WASH
          BPT EFFLUENT LIMITATIONS 	     5

          CRYSTALLIZATION AND DRYING OF AMMONIUM
          PARATUNGSTATE BPT EFFLUENT LIMITATIONS 	     5

          AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES
          WET AIR POLLUTION CONTROL BPT EFFLUENT
          LIMITATIONS	     5

          REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL
          BPT EFFLUENT LIMITATIONS 	     6

          REDUCTION TO TUNGSTEN WATER OF FORMATION
          BPT EFFLUENT LIMITATIONS 	     6

          TUNGSTIC ACID RINSE BAT EFFLUENT LIMITATIONS .  .     7

          ACID LEACH WET AIR POLLUTION CONTROL
          BAT EFFLUENT LIMITATIONS 	     7

          ALKALI LEACH WASH BAT EFFLUENT LIMITATIONS ...     7

          ION-EXCHANGE RAFFINATE BAT EFFLUENT
          LIMITATIONS	     8

          CALCIUM TUNGSTATE PRECIPITATE WASH
          BAT EFFLUENT LIMITATIONS 	     8

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                   PRIMARY TUNGSTEN SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section
          CRYSTALLIZATION AND DRYING OF AMMONIUM
          PARATUNGSTATE BAT EFFLUENT LIMITATIONS 	     8

          AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES
          WET AIR POLLUTION CONTROL BAT EFFLUENT
          LIMITATIONS	.'	     9

          REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL
          BAT EFFLUENT LIMITATIONS 	     9

          REDUCTION TO TUNGSTEN WATER OF FORMATION
          BAT EFFLUENT LIMITATIONS 	     9

          TUNGSTIC ACID RINSE NSPS	    10

          ACID LEACH WET AIR POLLUTION CONTROL NSPS. ...    10

          ALKALI LEACH WASH NSPS	    11

          ION-EXCHANGE RAFFINATE NSPS	    11

          CALCIUM TUNGSTATE PRECIPITATE WASH NSPS	    11

          CRYSTALLIZATION AND DRYING OF AMMONIUM
          PARATUNGSTATE NSPS	    12

          AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES
          WET AIR POLLUTION CONTROL NSPS	    12

          REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL
          NSPS	    12

          REDUCTION TO TUNGSTEN WATER OF FORMATION NSPS. .    13

          TUNGSTIC ACID RINSE PSES	    13

          ACID LEACH WET AIR POLLUTION CONTROL PSES. ...    13

          ALKALI LEACH WASH PSES	    14

          ION-EXCHANGE RAFFINATE PSES	    14

          CALCIUM TUNGSTATE PRECIPITATE WASH PSES	    14
                               11

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                   PRIMARY TUNGSTEN SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          CRYSTALLIZATION AND DRYING OF AMMONIUM
          PARATUNGSTATE PSES	    14

          AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES
          WET AIR POLLUTION CONTROL PSES	    15

          REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL
          PSES	    15

          REDUCTION TO TUNGSTEN WATER OF FORMATION PSES.  .    15

          TUNGSTIC ACID RINSE PSNS	    16

          ACID LEACH WET AIR POLLUTION CONTROL PSNS. ...    16

          ALKALI LEACH WASH PSNS	    16

          ION-EXCHANGE RAFFINATE PSNS	    16

          CALCIUM TUNGSTATE PRECIPITATE WASH PSNS	    17

          CRYSTALLIZATION AND DRYING OF AMMONIUM
          PARATUNGSTATE PSNS	    17

          AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES
          WET AIR POLLUTION CONTROL PSNS	    17

          REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL
          PSNS	    18

          REDUCTION TO TUNGSTEN WATER OF FORMATION PSNS.  .    18

          TUNGSTIC ACID RINSE BCT EFFLUENT LIMITATIONS .  .    18

          ACID LEACH WET AIR POLLUTION CONTROL
          BCT EFFLUENT LIMITATIONS 	    19

          ALKALI LEACH WASH BCT EFFLUENT LIMITATIONS ...    19

          ION-EXCHANGE RAFFINATE BCT EFFLUENT
          LIMITATIONS	    19

          CALCIUM TUNGSTATE PRECIPITATE WASH
          BCT EFFLUENT LIMITATIONS 	    19
                               3.11

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                   PRIMARY TUNGSTEN SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          CRYSTALLIZATION AND DRYING OF AMMONIUM
          PARATUNGSTATE BCT EFFLUENT LIMITATIONS  	     20

          AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES
          WET AIR POLLUTION CONTROL BCT EFFLUENT
          LIMITATIONS	     20

          REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL
          BCT EFFLUENT LIMITATIONS 	     20

          REDUCTION TO TUNGSTEN WATER OF FORMATION
          BCT EFFLUENT LIMITATIONS	     20

III       INDUSTRY PROFILE	     21

          DESCRIPTION OF PRIMARY TUNGSTEN PRODUCTION  ...     21

          Raw Materials	     21
          Leaching of Ore Concentrates	,.  .     21
          Purification to Ammonium Paratungstate  	     22
          Reduction to Metal	     22
          Process Wastewater Sources 	     23
          Other Wastewater Sources 	     23

          AGE, PRODUCTION AND PROCESS PROFILE	     23

IV        SUBCATEGORIZATION	     31

          FACTORS CONSIDERED IN SUBCATEGORIZATION	     31

          FACTORS CONSIDERED IN SUBDIVIDING THE PRIMARY
          TUNGSTEN SUBCATEGORY 	     32

          OTHER FACTORS	     33

          PRODUCTION NORMALIZING PARAMETERS	     33

V         WATER USE AND WASTEWATER CHARACTERISTICS  ....     35

          WASTEWATER FLOW RATES	     36
                               IV

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                   PRIMARY TUNGSTEN SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          WASTEWATER CHARACTERISTICS DATA	     37

          Data Collection Portfolios 	     37
          Field Sampling Data	     37

          WASTEWATER CHARACTERISTICS AND FLOWS BY
          SUBDIVISION	     39

          Tungstic Acid Rinse Water	     39
          Acid Leach Wet Air Pollution Control	     39
          Alkali Leach Wash	     40
          Ion-Exchange Raffinate  	     40
          Calcium Tungstate Precipitation Wash 	     40
          Crystallization and Drying of Ammonium
          Paratungstate	     41
          Ammonium Paratungstate  Conversion to Oxides
          Wet Air Pollution Control	     41
          Reduction to Tungsten Wet Air Pollution Control.     42
          Reduction to Tungsten Metal Water of Formation  .     42

VI        SELECTION OF POLLUTANT  PARAMETERS	     81

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS	     81

          Conventional and Nonconventional Pollutant
          Parameters Selected	     81

          TOXIC POLLUTANTS	     82

          Toxic Pollutants Never  Detected	     82
          Toxic Pollutants Never  Found Above Their
          Analytical Quantification Limit	     84
          Toxic Pollutants Present Below Concentrations
          Achievable by Treatment	     85
          Toxic Pollutants Detected in a Small Number
          of Sources	     87
          Toxic Pollutants Selected for Further Considera-
          ation in Establishing Limitations and Standards.     88

VII       CONTROL AND TREATMENT TECHNOLOGIES 	     95

          CURRENT CONTROL AND TREATMENT PRACTICES	     95
                               v

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                   PRIMARY TUNGSTEN SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section
VIII
IX
Tungstic Acid Rinse Water	    95
Acid Leach Wet Air Pollution Control	    96
Alkali Leach Wash	    96
Ion-Exchange Raffinate 	    96
Calcium Tungstate Precipitation Wash  	    96
Crystallization and Drying of Ammonium
Paratungstate	    96
Ammonium Paratungstate Conversion to Oxides
Wet Air Pollution Control	    97
Reduction to Tungsten Wet Air Pollution
Control	    97
Reduction to Tungsten Water of Formation  ....    97

CONTROL AND TREATMENT OPTIONS	    98

Option A	    98
Option B	    98
Option C	    99
Option E	    99
Option F	    99

COSTS, ENERGY, AND NONWATER QUALITY ASPECTS.  .  .    101

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES.  .    102

Option A	    102
Option B	    103
Option C	    103
Option E	    103
Option F	    103

NONWATER QUALITY ASPECTS 	    104

Energy Requirements	    104
Solid Waste	    104
Air Pollution	    105

BEST PRACTICABLE TECHNOLOGY CURRENTLY
AVAILABLE	    113

TECHNICAL APPROACH TO BPT	    113
                               VI

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Section
                   PRIMARY TUNGSTEN SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
          INDUSTRY COST AND POLLUTANT REDUCTION
          BENEFITS	   115

          BPT OPTION SELECTION 	   116

          WASTEWATER DISCHARGE RATES .  :  	   116

          Tungstic Acid Rinse Water	   116
          Acid Leach Wet Air Pollution Control	   117
          Alkali Leach Wash	   117
          Ion-Exchange Raffinate 	   118
          Calcium Tungstate Precipitate Wash 	   118
          Crystallization and Drying of Ammonium
          Paratungstate	   118
          Ammonium Paratungstate Conversion to Oxides
          Wet Air Pollution Control	   118
          Reduction to Tungsten Wet Air Pollution Control.   119
          Reduction to Tungsten Water of Formation ....   119

          REGULATED POLLUTANT PARAMETERS  	   120

          EFFLUENT LIMITATIONS 	   120

          BEST AVAILABLE TECHNOLOGY ECONOMICALLY
          ACHIEVABLE	   127

          TECHNICAL APPROACH TO BAT	   127

          Option A	   129
          Option B	   129
          Option C	   130
          Option E	   130
          Option F	   130

          INDUSTRY COST AND POLLUTANT REDUCTION
          BENEFITS	   130

          Pollutant Reduction Benefits  	   131
          Compliance Costs 	   131

          BAT OPTION SELECTION 	   132

          WASTEWATER DISCHARGE RATES 	   133
                              VII

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                   PRIMARY TUNGSTEN SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          REGULATED POLLUTANT PARAMETERS 	   134

          EFFLUENT LIMITATIONS 	   135

XI        NEW SOURCE PERFORMANCE STANDARDS 	   149

          TECHNICAL APPROACH TO BDT	   149

          Option A	   149
          Option B	   150
          Option C	   150
          Option E	   150
          Option F	   150
          BDT Option Selection 	   150

          REGULATED POLLUTANT PARAMETERS 	   151

          NEW SOURCE PERFORMANCE STANDARDS 	   151

XII       PRETREATMENT STANDARDS 	   157

          TECHNICAL APPROACH TO PRETREATMENT 	   157

          INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS  .   158

          PRETREATMENT STANDARDS FOR EXISTING SOURCES.  .  .   158

          Option A	   158
          Option B	   159
          Option C	   159
          Option E	   159
          Option F	   159

          PSNS AND PSES OPTION SELECTION	   159

          REGULATED POLLUTANT PARAMETERS 	   160

          PRETREATMENT STANDARDS 	   160

XIII      BEST CONVENTIONAL POLLUTANT CONTROL
          TECHNOLOGY	   171
                               Vlll

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                   PRIMARY TUNGSTEN SUBCATEGORY

                          LIST OF TABLES


Number                                                      Page

III-l     INITIAL OPERATING YEAR  (RANGE) SUMMARY OF PLANTS
          IN THE PRIMARY TUNGSTEN SUBCATEGORY BY DISCHARGE
          TYPE	    25

III-2     PRODUCTION RANGES FOR THE PRIMARY TUNGSTEN
          SUBCATEGORY	    26

III-3     SUMMARY OF SUBCATEGORY PROCESSES AND ASSOCIATED
          WASTE STREAMS	    27

V-l       WATER USE AND DISCHARGE RATES FOR TUNGSTIC
          ACID RINSE WATER	    43

V-2       WATER USE AND DISCHARGE RATES FOR ACID LEACH
          WET AIR POLLUTION CONTROL	    44

V-3       WATER USE AND DISCHARGE RATES FOR ALKALI
          LEACH WASH	    45

V-4       WATER USE AND DISCHARGE RATES FOR ION-
          EXCHANGE RAFFINATE	    46

V-5       WATER USE AND DISCHARGE RATES FOR CALCIUM
          TUNGSTATE PRECIPITATE WASH  	    47

V-6       WATER USE AND DISCHARGE RATES FOR AMMONIUM
          PARATUNGSTATE CRYSTALLIZATION AND DRYING ....    48

V-7       WATER USE AND DISCHARGE RATES FOR APT CONVERSION
          TO OXIDES WET AIR POLLUTION CONTROL	    49

V-8       WATER USE AND DISCHARGE RATES FOR REDUCTION TO
          TUNGSTEN WET AIR POLLUTION CONTROL 	    50

V-9       WATER USE AND DISCHARGE RATES FOR REDUCTION
          TO TUNGSTEN WATER OF FORMATION 	    51
                                                       n
V-10      PRIMARY TUNGSTEN SAMPLING DATA TUNGSTIC ACID
          RINSE RAW WASTEWATER	    52

V-ll      PRIMARY TUNGSTEN SAMPLING DATA ION-EXCHANGE
          RAFFINATE RAW WASTEWATER 	    59
                               IX

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                   PRIMARY TUNGSTEN SUBCATEGORY

                    LIST OF TABLES (Continued)


Number                                                      Page

V-12      PRIMARY TUNGSTEN SAMPLING DATA OXIDES REDUCTION
          FURNACE SCRUBBER RAW WASTEWATER	    64

V-13      PRIMARY TUNGSTEN SAMPLING DATA TREATMENT PLANT
          SAMPLES - PLANT B	    65

V-14      PRIMARY TUNGSTEN SAMPLING DATA TREATMENT PLANT
          SAMPLES - PLANT C	    68

VI-1      FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
          PRIMARY TUNGSTEN RAW WASTEWATER	    91

VIII-1    ENERGY REQUIREMENTS	   106

IX-1      BPT WASTEWATER DISCHARGE RATES FOR THE
          PRIMARY TUNGSTEN SUBCATEGORY  	   121

IX-2      BPT EFFLUENT LIMITATIONS FOR  THE PRIMARY
          TUNGSTEN SUBCATEGORY 	   122

X-l       CURRENT RECYCLE PRACTICES WITHIN THE PRIMARY
          TUNGSTEN SUBCATEGORY 	   136

X-2       POLLUTANT REDUCTION BENEFITS  FOR DIRECT
          DISCHARGERS	   137

X-3       COST OF COMPLIANCE FOR THE PRIMARY TUNGSTEN
          SUBCATEGORY DIRECT DISCHARGERS 	   139

X-4       BAT WASTEWATER DISCHARGE RATES FOR THE
          PRIMARY TUNGSTEN SUBCATEGORY  	   140

X-5       BAT EFFLUENT LIMITATIONS FOR  THE PRIMARY
          TUNGSTEN SUBCATEGORY 	   141

XI-1      NSPS WASTEWATER DISCHARGE RATES FOR THE
          PRIMARY TUNGSTEN SUBCATEGORY  	   152

XI-2      NSPS FOR THE PRIMARY TUNGSTEN SUBCATEGORY. ...   153

XII-1     POLLUTANT REDUCTION BENEFITS  FOR INDIRECT
          DISCHARGERS	   161

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PRIMARY TUNGSTEN SUBCATEGORY



 LIST OF TABLES (Continued)
Number
XII-2
XII-3
XII-4
XII-5
XIII-1

COST OF COMPLIANCE FOR THE PRIMARY TUNGSTEN
SUBCATEGORY INDIRECT DISCHARGERS 	
PSES AND PSNS WASTEWATER DISCHARGE RATES FOR
THE PRIMARY TUNGSTEN SUBCATEGORY 	
PSES FOR THE PRIMARY TUNGSTEN SUBCATEGORY. . . .
PSNS FOR THE PRIMARY TUNGSTEN SUBCATEGORY. . . .
BCT EFFLUENT LIMITATIONS FOR THE PRIMARY
TUNGSTEN SUBCATEGORY 	
Page
163
164
165
168
173
           XI

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PRIMARY TUNGSTEN SUBCATEGORY




      LIST OF FIGURES
Number
III-l
III-2
V-l
V-2
V-3
V-4
VIII-
PRIMARY TUNGSTEN PRODUCTION PROCESS 	
GEOGRAPHIC LOCATIONS OF THE PRIMARY TUNGSTEN
SUBCATEGORY PLANTS 	
SAMPLING SITES AT PRIMARY TUNGSTEN PLANT A ...
SAMPLING SITES AT PRIMARY TUNGSTEN PLANT B . . .
SAMPLING SITES AT PRIMARY TUNGSTEN PLANT C . . .
SAMPLING
1
PRIMARY

SITES AT PRIMARY TUNGSTEN PLANT D . . .
TUNGSTEN
(ORE
TO
APT)
Page
28
29
76
77
78
79
COMBINATION 1,
OPTION A 	
VIII-2

VIII-


3

VIII-4

VIII-

5
PRIMARY
OPTION
PRIMARY
OPTION
PRIMARY
OPTION
PRIMARY

C

E

F

TUNGSTEN

TUNGSTEN

TUNGSTEN

TUNGSTEN
(ORE

(ORE

(ORE

(ORE
TO

TO

TO

TO
APT)

APT)

APT)

APT)
107
COMBINATION 1,


107
COMBINATION 1,


108
COMBINATION 1,


108
COMBINATION 2,
OPTION A 	
VIII-6

VIII-


7

VIII-8


VIII-9


VIII-10


PRIMARY
OPTION

C
PRIMARY
OPTION
PRIMARY
OPTION
PRIMARY
OPTION
PRIMARY
OPTION
E

F

A

C
TUNGSTEN

TUNGSTEN

TUNGSTEN

TUNGSTEN

TUNGSTEN

(ORE

(ORE

(ORE

(APT

(APT

TO

TO

TO

TO

TO

APT)

APT)

APT)

109
COMBINATION 2,


109
COMBINATION 2,


110
COMBINATION 2,

METAL)


METAL)



COMBINATION 2,

COMBINATION 2,

110

111

111
           XI1

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Number
VIII-11

VIII-12
IX-1
X-l
X-2
X-3
X-4
X-5
                   PRIMARY TUNGSTEN SUBCATEGORY
                   LIST OF FIGURES (Continued)
PRIMARY TUNGSTEN (APT TO METAL) COMBINATION 2,
OPTION E 	
PRIMARY TUNGSTEN HOLDING TANK COSTS,
BPT TREATMENT SCHEME FOR PRIMARY TUNGSTEN
SUBCATEGORY	
BAT TREATMENT SCHEME FOR OPTION A.
BAT TREATMENT SCHEME FOR OPTION B.
BAT TREATMENT SCHEME FOR OPTION C.
BAT TREATMENT SCHEME FOR OPTION E.
BAT TREATMENT SCHEME FOR OPTION F.
Page

 112
 112

 126
 144
 145
 146
 147
 148
                              Kill

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                        TABLE OF CONTENTS


Section                                                     Page

I         SUMMARY AND CONCLUSIONS.	   177

II        RECOMMENDATIONS	   179

          CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL
          BPT EFFLUENT LIMITATIONS 	   179

          SOLVENT EXTRACTION RAFFINATE BPT EFFLUENT
          LIMITATIONS	   180

          SOLVENT EXTRACTION WET AIR POLLUTION CONTROL
          BPT EFFLUENT LIMITATIONS 	   180

          PRECIPITATION AND FILTRATION OF METAL SALTS
          BPT EFFLUENT LIMITATIONS 	   180

          METAL SALT DRYING WET AIR POLLUTION CONTROL
          BPT EFFLUENT LIMITATIONS 	   181

          REDUCTION OF SALT TO METAL BPT EFFLUENT
          LIMITATIONS	   181

          REDUCTION OF SALT TO METAL WET AIR POLLUTION
          CONTROL BPT EFFLUENT LIMITATIONS 	   181

          CONSOLIDATION AND CASTING CONTACT COOLING
          BPT EFFLUENT LIMITATIONS 	   182

          CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL
          BAT EFFLUENT LIMITATIONS 	   182

          SOLVENT EXTRACTION RAFFINATE BAT EFFLUENT
          LIMITATIONS	   183

          SOLVENT EXTRACTION WET AIR POLLUTION CONTROL
          BAT EFFLUENT LIMITATIONS 	   183

          PRECIPITATION AND FILTRATION OF METAL SALTS
          BAT EFFLUENT LIMITATIONS 	   183

          METAL SALT DRYING WET AIR POLLUTION CONTROL
          BAT EFFLUENT LIMITATIONS 	   184
                               xv

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          REDUCTION OF SALT TO METAL BAT EFFLUENT
          LIMITATIONS	   184

          REDUCTION OF SALT TO METAL WET AIR POLLUTION
          CONTROL BAT EFFLUENT LIMITATIONS 	   184

          CONSOLIDATION AND CASTING CONTACT COOLING
          BAT EFFLUENT LIMITATIONS 	   185

          CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL
          NSPS	   185

          SOLVENT EXTRACTION RAFFINATE NSPS	   186

          SOLVENT EXTRACTION WET AIR POLLUTION CONTROL
          NSPS	   186

          PRECIPITATION AND FILTRATION OF METAL SALTS
          NSPS	 .  .   186

          METAL SALT DRYING WET AIR POLLUTION CONTROL
          NSPS	   187

          REDUCTION OF SALT TO METAL NSPS	   187

          REDUCTION OF SALT TO METAL WET AIR POLLUTION
          CONTROL NSPS	  .   187

          CONSOLIDATION AND CASTING CONTACT COOLING
          NSPS	  .   188

          CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL
          PSES	   188

          SOLVENT EXTRACTION RAFFINATE PSES	   189

          SOLVENT EXTRACTION WET AIR POLLUTION CONTROL
          PSES	   189

          PRECIPITATION AND FILTRATION OF METAL SALTS
          PSES	   189
                               xvi

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          METAL SALT DRYING WET AIR POLLUTION CONTROL
          PSES	   190

          REDUCTION OF SALT TO METAL PSES	   190

          REDUCTION OF SALT TO METAL WET AIR POLLUTION
          CONTROL PSES	   190

          CONSOLIDATION AND CASTING CONTACT COOLING
          PSES	   191

          CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL
          PSNS	   191

          SOLVENT EXTRACTION RAFFINATE PSNS	   191

          SOLVENT EXTRACTION WET AIR POLLUTION CONTROL
          PSNS	   192

          PRECIPITATION AND FILTRATION OF METAL SALTS
          PSNS	   192

          METAL SALT DRYING WET AIR POLLUTION CONTROL
          PSNS	   192

          REDUCTION OF SALT TO METAL PSNS	   193

          REDUCTION OF SALT TO METAL WET AIR POLLUTION
          CONTROL PSNS	   193

          CONSOLIDATION AND CASTING CONTACT COOLING
          PSNS	   193

          CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL
          BCT EFFLUENT LIMITATIONS 	   194

          SOLVENT EXTRACTION RAFFINATE BCT EFFLUENT
          LIMITATIONS	   194

          SOLVENT EXTRACTION WET AIR POLLUTION CONTROL
          BCT EFFLUENT LIMITATIONS 	   194
                              xvii

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section

          PRECIPITATION AND FILTRATION OF METAL SALTS
          BCT EFFLUENT LIMITATIONS 	   195

          METAL SALT DRYING WET AIR POLLUTION CONTROL
          BCT EFFLUENT LIMITATIONS 	   195

          REDUCTION OF SALT TO METAL BCT EFFLUENT
          LIMITATIONS	   195

          REDUCTION OF SALT TO METAL WET AIR POLLUTION
          CONTROL BCT EFFLUENT LIMITATIONS 	   195

          CONSOLIDATION AND CASTING CONTACT COOLING
          BCT EFFLUENT LIMITATIONS 	   196

III       INDUSTRY PROFILE 	   197

          DESCRIPTION OF PRIMARY COLUMBIUM-TANTALUM
          PRODUCTION	   197

          Raw Materials	   197
          Digestion of Ore or Slag	   197
          Separation of Salts	   198
          Reduction of Salt to Metal	   199
          Consolidation and Casting	   199
          Process Wastewater Sources 	   200
          Other Wastewater Sources 	   200

          AGE, PRODUCTION, AND PROCESS PROFILE 	   201

IV        SUBCATEGORIZATION	   207

          FACTORS CONSIDERED IN SUBCATEGORIZATION	   207

          FACTORS CONSIDERED IN SUBDIVIDING THE PRIMARY
          COLUMBIUM-TANTALUM SUBCATEGORY	   208

          Other Factors	   209

          PRODUCTION NORMALIZING PARAMETERS	   209
                               xviii

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                  TABLE OF CONTENTS  (Continued)


Section                                                     Page

V         WATER USE AND WASTEWATER CHARACTERISTICS  ....    211

          WASTEWATER SOURCES, DISCHARGE RATES, AND
          CHARACTERISTICS	    212

          Concentrate Digestion Wet Air Pollution Control.    214
          Solvent Extraction Raffinate 	    215
          Solvent Extraction Wet Air Pollution Control  .  .    215
          Precipitation and Filtration of Metal Salt  .  .  .    215
          Metal Salt Drying Wet Air Pollution Control.  .  .    216
          Reduction of Salt to Metal Wastewater	    216
          Reduction of Salt to Metal Wet Air Pollution
          Control	    216
          Consolidation and Casting Contact Cooling.  .  .  .    216

VI        SELECTION OF POLLUTANT PARAMETERS	    269

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS	    269

          Conventional and Nonconventional Pollutant
          Parameters Selected	    269

          TOXIC POLLUTANTS	    270

          Toxic Pollutants Never Detected	    270
          Toxic Pollutants Never Found Above Their
          Analytical Quantification Limit	    272
          Toxic Pollutants Present Below Concentrations
          Achievable by Treatment	    273
          Toxic Pollutants Detected in a Small Number
          of Sources	    274
          Toxic Pollutants Selected for Consideration
          for Limitations and Standards	    277

VII       CONTROL AND TREATMENT TECHNOLOGIES 	    285

          CURRENT CONTROL AND TREATMENT PRACTICES	    285

          Concentrate Digestion Wet Air Pollution Control.    285
          Solvent Extraction Raffinate 	    286
          Solvent Extraction Wet Air Pollution Control  .  .    286
          Precipitation and Filtration of Metal Salt  .  .  .    286
                               xix

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section
VIII
IX
                                                  Page

Metal Salt Drying Wet Air Pollution Control.  .  .    287
Reduction of Salt to Metal Wastewater	    287
Reduction of Salt to Metal Scrubber	    288
Consolidation and Casting Contact Cooling.  .  .  .    288

CONTROL AND TREATMENT OPTIONS	    288

Option A	    288
Option B	    289
Option C	    289
Option D	    289
Option E	    289
Option F	    289

COSTS, ENERGY, AND NONWATER QUALITY ASPECTS.  .  .    291

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES.  .    292

Option A	    292
Option B	    292
Option C	    293
Option D	    293
Option E	    293
Option F	    293

NONWATER QUALITY ASPECTS 	    294

Energy Requirements	    294
Solid Waste	    294
Air Pollution	    295

BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE	    307

TECHNICAL APPROACH TO BPT	    307

INDUSTRY COST AND POLLUTANT REDUCTION
BENEFITS	  .    309

BPT OPTION SELECTION 	    310

WASTEWATER DISCHARGE RATES	    311
                               xx

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Section
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
          Concentrate Digestion Wet Air Pollution
          Control	   311
          Solvent Extraction Raffinate 	   311
          Solvent Extraction Wet Air Pollution Control .  .   311
          Precipitation and Filtration of Metal Salts. .  .   312
          Metal Salt Drying Wet Air Pollution Control. .  .   312
          Reduction of Salt to Metal	   312
          Reduction of Salt to Metal Wet Air Pollution
          Control	   312
          Consolidation and Casting Contact Cooling.  . .  .   313

          REGULATED POLLUTANT PARAMETERS 	   313

          EFFLUENT LIMITATIONS 	   313

          BEST AVAILABLE TECHNOLOGY ECONOMICALLY
          ACHIEVABLE	   321

          TECHNICAL APPROACH TO BAT	   321

          Option A	   323
          Option B	   323

            Recycle of Water Used in Wet Air Pollution
            Control	   323

          Option C	   324
          Option D	   324
          Option E	   324
          Option F	   324

          INDUSTRY COST AND POLLUTANT REDUCTION
          BENEFITS	   325

          Pollutant Reduction Benefits 	   325
          Compliance Cost	   325

          BAT OPTION SELECTION 	   326

          WASTEWATER DISCHARGE RATES 	   326

          Concentrate Digestion Wet Air Pollution Control.   327
          Solvent Extraction Wet  Air Pollution Control .  .   327
          Metal Salt Drying Wet Air Pollution Control. .  .   327
                               xxi

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          REGULATED POLLUTANT PARAMETERS 	   327

          EFFLUENT LIMITATIONS 	   329

XI        NEW SOURCE PERFORMANCE STANDARDS 	   345

          TECHNICAL APPROACH TO BDT	   345

          Option A	   345
          Option B	   345
          Option C	   345
          Option D	   346
          Option E	   346
          Option F	   346

          BDT OPTION SELECTION 	   346

          REGULATED POLLUTANT PARAMETERS 	   347

          NEW SOURCE PERFORMANCE STANDARDS 	   347

XII       PRETREATMENT STANDARDS 	   353

          TECHNICAL APPROACH TO PRETREATMENT  	   353

          PRETREATMENT STANDARDS FOR EXISTING SOURCES.  .  .   354

          Option A	   354
          Option B	   354
          Option C	   354
          Option D	   355
          Option E	   355
          Option F	   355

          INDUSTRY COST AND ENVIRONMENTAL BENEFITS ....   355

          PSES AND PSNS OPTION SELECTION	   355

          REGULATED POLLUTANT PARAMETERS 	   356

          PRETREATMENT STANDARDS 	   356

XIII      BEST CONVENTIONAL POLLUTANT CONTROL
          TECHNOLOGY	   367
                              xxii

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              PRIMARY COLUMBIUM-TANTALUM  SUBCATEGORY

                          LIST OF TABLES
Number

III-l     INITIAL OPERATING YEAR  (RANGE) SUMMARY OF  PLANTS
          IN THE PRIMARY COLUMBIUM-TANTALUM  SUBCATEGORY  BY
          DISCHARGE	    202

III-2     PRODUCTION RANGES FOR THE PRIMARY  COLUMBIUM-
          TANTALUM SUBCATEGORY  	    203

III-3     PRODUCTION PROCESSES UTILIZED BY THE COLUMBIUM-
          TANTALUM SUBCATEGORY  	    204

V-l       WATER USE AND DISCHARGE RATES FOR  CONCENTRATE
          DIGESTION WET AIR POLLUTION CONTROL	    217

V-2       PRIMARY COLUMBIUM-TANTALUM SAMPLING DATA
          CONCENTRATE DIGESTION SCRUBBER RAW WASTEWATER.  .    218

V-3       WATER USE AND DISCHARGE RATES FOR  SOLVENT
          EXTRACTION RAFFINATE  	    223

V-4       PRIMARY COLUMBIUM-TANTALUM SAMPLING DATA
          SOLVENT EXTRACTION RAFFINATE RAW WASTEWATER. .  .    224

V-5       WATER USE AND DISCHARGE RATES FOR  SOLVENT
          EXTRACTION WET AIR POLLUTION CONTROL 	    228

V-6       PRIMARY COLUMBIUM-TANTALUM SAMPLING DATA
          SOLVENT EXTRACTION SCRUBBER RAW WASTEWATER  ...    229

V-7       WATER USE AND DISCHARGE RATES FOR  PRECIPITATION
          AND FILTRATION OF COLUMBIUM-TANTALUM SALT.  ...    232

V-8       PRIMARY COLUMBIUM-TANTALUM SAMPLING DATA
          PRECIPITATION AND FILTRATION RAW WASTEWATER. .  .    233

V-9       WATER USE AND DISCHARGE RATES FOR METAL SALT
          DRYING WET AIR POLLUTION CONTROL 	    236

V-10      PRIMARY COLUMBIUM-TANTALUM SAMPLING DATA METAL
          SALT DRYING SCRUBBER, REDUCTION OF SALT TO
          METAL, AND REDUCTION OF SALT TO METAL SCRUBBER
          RAW WASTEWATER	    237
                              xxi 11

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PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY



      LIST OF TABLES (Continued)
Number
V-ll
V-12
V-13
V-14
V-15
V-16
V-17
V-18
VI-1
vni-i
IX-1
IX-2
X-l
X-2

WATER USE AND DISCHARGE RATES FOR REDUCTION OF
SALT TO METAL 	
WATER USE AND DISCHARGE RATES FOR REDUCTION OF
SALT TO METAL WET AIR POLLUTION CONTROL 	
PRIMARY COLUMBIUM -TANTALUM - SAMPLING DATA
MISCELLANEOUS - RAW WASTEWATER - PLANT A ....
PRIMARY COLUMBIUM -TANTALUM - SAMPLING DATA
MISCELLANEOUS - RAW WASTEWATER - PLANT B . . . .
PRIMARY COLUMBIUM -TANTALUM SAMPLING DATA
MISCELLANEOUS - RAW WASTEWATER - PLANT C .....
PRIMARY COLUMBIUM -TANTALUM - SAMPLING DATA
MISCELLANEOUS - TREATMENT PLANT SAMPLES PLANT A.
PRIMARY COLUMBIUM -TANTALUM - SAMPLING DATA
MISCELLANEOUS - TREATMENT PLANT SAMPLES PLANT B.
PRIMARY COLUMBIUM -TANTALUM - SAMPLING DATA
MISCELLANEOUS - TREATMENT PLANT SAMPLES PLANT D.
FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
PRIMARY COLUMBIUM -TANTALUM SUBCATEGORY RAW
WASTEWATER 	
ENERGY REQUIREMENTS 	
BPT WASTEWATER DISCHARGE RATES FOR THE PRIMARY
COLUMBIUM -TANTALUM SUBCATEGORY 	
BPT EFFLUENT LIMITATIONS FOR THE PRIMARY
COLUMBIUM-TANTALUM SUBCATEGORY 	
CURRENT RECYCLE PRACTICES WITHIN THE PRIMARY
COLUMBIUM-TANTALUM SUBCATEGORY 	
POLLUTANT REDUCTION BENEFITS FOR DIRECT
DISCHARGERS 	
Page
243
244
245
248
251
255
258
261
280
296
314
315
330
331
                 XXIV

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                    LIST OF TABLES  (Continued)


Number                                                      Page

X-3       COST OF COMPLIANCE FOR THE PRIMARY COLUMBIUM-
          TANTALUM SUBCATEGORY 	    333

X-4       BAT WASTEWATER DISCHARGE RATES FOR THE PRIMARY
          COLUMBIUM-TANTALUM SUBCATEGORY 	    334

X-5       BAT EFFLUENT LIMITATIONS FOR THE PRIMARY
          COLUMBIUM-TANTALUM SUBCATEGORY 	    335

XI-1      NSPS FOR THE PRIMARY COLUMBIUM-TANTALUM
          SUBCATEGORY	    348

XII-1     POLLUTANT REDUCTION BENEFITS FOR INDIRECT
          DISCHARGERS	    357

XII-2     COST OF COMPLIANCE FOR THE PRIMARY COLUMBIUM-
          TANTALUM SUBCATEGORY 	    359

XII-3     PSES AND PSNS WASTEWATER DISCHARGE RATES FOR
          THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY  ...    360

XII-4     PSES FOR THE PRIMARY COLUMBIUM-TANTALUM
          SUBCATEGORY	    361

XII-5     PSNS FOR THE PRIMARY COLUMBIUM-TANTALUM
          SUBCATEGORY	    364

XIII-1    BCT EFFLUENT LIMITATIONS FOR THE PRIMARY
          COLUMBIUM-TANTALUM SUBCATEGORY 	    369
                               XXV

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PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY




           LIST OF FIGURES
Number
III-l
III-2

V-l
V-2
V-3
V-4
V-5
VIII-1

VIII-2

VIII-3

VIII-4

VIII-5

VIII-6

VIII-7

VIII-8

VIII-9


COLUMBIUM -TANTALUM MANUFACTURING PROCESS ....
GEOGRAPHIC LOCATIONS OF THE COLUMBIUM-TANTALUM
METAL PRODUCTION PLANTS 	
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT A . .
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT A . .
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT B . .
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT C . .
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT D . .
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 1, OPTION C 	
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 1, OPTION D 	
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 1, OPTION E 	
COLUMBIUM-TANTALUM (ORE TO SALT /METAL) COMBINA-
TION 1, OPTION F 	
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 2, OPTION A 	
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 2, OPTION C 	
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 2, OPTION D 	
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 2, OPTION E 	
COLUMBIUM-TANTALUM (ORE TO SALT/METAL) COMBINA-
TION 2, OPTION F 	
Page
205

206
264
265
266
267
268

297

298

299

300

301

301

302

302

303
                 XXVI

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PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY



     LIST OF FIGURES (Continued)
Number
VIII-10

VIII-11

VIII-12

VIII-13

VIII-14

VIII-15
IX-1

X-l
X-2
X-3
X-4
X-5
X-6

COLUMBIUM -TANTALUM (SALT
1, OPTION A 	
COLUMBIUM -TANTALUM (SALT
1, OPTION C 	
COLUMBIUM -TANTALUM (SALT
1, OPTION D 	
COLUMBIUM -TANTALUM (SALT
1, OPTION E 	
COLUMBIUM-TANTALUM (SALT
1, OPTION F 	
HOLDING TANK COSTS . . .
BPT TREATMENT SCHEME FOR
TANTALUM SUBCATEGORY . .
BAT TREATMENT SCHEME FOR
BAT TREATMENT SCHEME FOR
BAT TREATMENT SCHEME FOR
BAT TREATMENT SCHEME FOR
BAT TREATMENT SCHEME FOR
BAT TREATMENT SCHEME FOR

TO METAL)

TO METAL)

TO METAL)

TO METAL)

TO METAL)



COMBINATION

COMBINATION

COMBINATION

COMBINATION

COMBINATION


Page

303

304

304

305

305
306
PRIMARY COLUMBIUM -

OPTION A.
OPTION B.
OPTION C.
OPTION D.
OPTION E.
OPTION F.







319
338
339
340
341
342
343
                xxvii

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                   SECONDARY SILVER SUBCATEGORY

                        TABLE OF CONTENTS


Section                                                      Page

I         SUMMARY AND CONCLUSIONS 	     373

II        RECOMMENDATIONS	     377

          FILM STRIPPING BPT EFFLUENT LIMITATIONS ....     377

          FILM STRIPPING WET AIR POLLUTION CONTROL
          BPT EFFLUENT LIMITATIONS	     378

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS BPT EFFLUENT LIMITATIONS	     378

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS WET AIR POLLUTION CONTROL 	     378

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS BPT EFFLUENT LIMITATIONS	     379

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BPT
          EFFLUENT LIMITATIONS	     379

          ELECTROLYTIC REFINING BPT EFFLUENT LIMITATIONS.     379

          FURNACE WET AIR POLLUTION CONTROL BPT EFFLUENT
          LIMITATIONS	     380

          CASTING CONTACT COOLING BPT EFFLUENT
          LIMITATIONS	     380

          CASTING WET AIR POLLUTION CONTROL BPT EFFLUENT
          LIMITATIONS	     380

          LEACHING BPT EFFLUENT LIMITATIONS 	     381

          LEACHING WET AIR POLLUTION CONTROL BPT EFFLUENT
          LIMITATIONS	     381

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS BPT EFFLUENT LIMITATIONS	     381
                              xxix

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Section
                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BPT
          EFFLUENT LIMITATIONS	     382

          FILM STRIPPING BAT EFFLUENT LIMITATIONS ....     382

          FILM STRIPPING WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     383

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS BAT EFFLUENT LIMITATIONS	     383

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     383

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS BAT EFFLUENT LIMITATIONS	     384

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     384

          ELECTROLYTIC REFINING BAT EFFLUENT LIMITATIONS.     384

          FURNACE WET AIR POLLUTION CONTROL BAT EFFLUENT
          LIMITATIONS	     385

          CASTING CONTACT COOLING BAT EFFLUENT
          LIMITATIONS	     385

          CASTING WET AIR POLLUTION CONTROL BAT EFFLUENT
          LIMITATIONS	"     385

          LEACHING BAT EFFLUENT LIMITATIONS 	     386

          LEACHING WET AIR POLLUTION CONTROL BAT EFFLUENT
          LIMITATIONS	     386

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS BAT EFFLUENT LIMITATIONS	     386
                               XXX

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     387

          FILM STRIPPING BAT EFFLUENT LIMITATIONS ....     387

          FILM STRIPPING WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     387

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS BAT EFFLUENT LIMITATIONS	     388

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     388

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS BAT EFFLUENT LIMITATIONS	     388

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     389

          ELECTROLYTIC REFINING BAT EFFLUENT LIMITATIONS.     389

          FURNACE WET AIR POLLUTION CONTROL BAT EFFLUENT
          LIMITATIONS	     389

          CASTING CONTACT COOLING BAT EFFLUENT
          LIMITATIONS	     390

          CASTING WET AIR POLLUTION CONTROL BAT EFFLUENT
          LIMITATIONS	     390

          LEACHING BAT EFFLUENT LIMITATIONS 	     390

          LEACHING WET AIR POLLUTION CONTROL BAT EFFLUENT
          LIMITATIONS	     391

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS BAT EFFLUENT LIMITATIONS	     391
                               XXXI

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page


          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS	     391

          FILM STRIPPING NSPS	     392

          FILM STRIPPING WET AIR POLLUTION CONTROL NSPS  .     392

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS NSPS	     392

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS WET AIR POLLUTION CONTROL NSPS. ...     393

          PRECPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS NSPS	     393

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL NSPS. ...     393

          ELECTROLYTIC REFINING NSPS	     394

          FURNACE WET AIR POLLUTION CONTROL NSPS	     394

          CASTING CONTACT COOLING NSPS	     394

          CASTING WET AIR POLLUTION CONTROL NSPS	     395

          LEACHING NSPS	     395

          LEACHING WET AIR POLLUTION CONTROL NSPS  ....     395

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS NSPS	     396

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL NSPS. ...     396

          FILM STRIPPING PSES	     396

          FILM STRIPPING WET AIR POLLUTION CONTROL PSES  .     397
                              xxxii

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                   SECONDARY SILVER SUBCATEGORY

                   TABLE OF CONTENTS (Continued)


Section                                                      Page
          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS PSES	     397

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL PSES. .  .   .     397

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS PSES	'.     397

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL PSES. ...     398

          ELECTROLYTIC REFINING PSES	     398

          FURNACE WET AIR POLLUTION CONTROL PSES	     398

          CASTING CONTACT COOLING PSES	     398

          CASTING WET AIR POLLUTION CONTROL PSES	     399

          LEACHING PSES	     399

          LEACHING WET AIR POLLUTION CONTROL PSES  ....     399

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS PSES	     399

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL PSES. .  .   .     400

          FILM STRIPPING PSES	     400

          FILM STRIPPING WET AIR POLLUTION CONTROL PSES  .     400

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS PSES	     401

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS WET AIR POLLUTION CONTROL PSES. .  .   .     401
                             xxxiii

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS PSES	     401

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL PSES. ...     401

          ELECTROLYTIC REFINING PSES	     402

          FURNACE WET AIR POLLUTION CONTROL PSES	     402

          CASTING CONTACT COOLING PSES	     402

          CASTING WET AIR POLLUTION CONTROL PSES	     402

          LEACHING PSES	     403

          LEACHING WET AIR POLLUTION CONTROL PSES  ....     403

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPH1C
          SOLUTIONS PSES	     403

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPH1C
          SOLUTIONS WET AIR POLLUTION CONTROL PSES. .  .  .     403

          FILM STRIPPING PSNS	     404

          FILM STRIPPING WET AIR POLLUTION CONTROL PSNS  .     404

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS PSNS	     404

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS WET AIR POLLUTION CONTROL PSNS. .  .  .     405

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS PSNS	     405

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL PSNS. ...     405

          ELECTROLYTIC REFINING PSNS	     405
                              XXXIV

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page

          FURNACE WET AIR POLLUTION CONTROL PSNS	     406

          CASTING CONTACT COOLING PSNS	     406

          CASTING WET AIR POLLUTION CONTROL PSNS	     406

          LEACHING PSNS	     406

          LEACHING WET AIR POLLUTION CONTROL PSNS ....     407

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUITONS PSNS	     407

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL PSNS.  .  .   .     407

          FILM STRIPPING BCT EFFLUENT LIMITATIONS ....     408

          FILM STRIPPING WET AIR POLLUTION CONTROL BCT
          EFFLUENT LIMITATIONS	     408

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS BCT EFFLUENT LIMITATIONS	     408

          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS WET AIR POLLUTION CONTROL BCT
          EFFLUENT LIMITATIONS	     409

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS BCT EFFLUENT LIMITATIONS	     409

          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BCT
          EFFLUENT LIMITATIONS	     409

          ELECTROLYTIC REFINING BCT EFFLUENT LIMITATIONS.     410

          FURNACE WET AIR POLLUTION CONTROL BCT EFFLUENT
          LIMITATIONS	     410

          CASTING CONTACT COOLING BCT EFFLUENT
          LIMITATIONS	     410

          CASTING WET AIR POLLUTION CONTROL BCT EFFLUENT
          LIMITATIONS	     410

                              XXXV

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                  TABLE OF CONTENTS (Continued)


Section                                                      Page

          LEACHING BCT EFFLUENT LIMITATIONS 	     411

          LEACHING WET AIR POLLUTION CONTROL BCT EFFLUENT
          LIMITATIONS	     411

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS BCT EFFLUENT LIMITATIONS	     411

          PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC
          SOLUTIONS WET AIR POLLUTION CONTROL BCT
          EFFLUENT LIMITATIONS	     411

III       INDUSTRY PROFILE	     413

          DESCRIPTION OF SECONDARY SILVER PRODUCTION. .  .     413

          Raw Materials	     413
          Photographic Materials	     413

            Discarded Film	     413
            Film Processing Solutions 	     415

          Nonphotographic Materials 	     416

            Waste Plating Solutions 	     416
            Sterling-Silver Industry Scraps 	     417
            Electrical Component Scrap	     417
            Silver-Rich Sludge	     418

          Process Wastewater Sources	     418
          Other Wastewater Sources	     419

          AGE, PRODUCTION, AND PROCESS FILE	     419

IV        SUBCATEGORIZATION 	     429

          FACTORS CONSIDERED IN SUBCATEGORIZATION ....     429

          FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY
          SILVER SUBCATEGORY	     430

          OTHER FACTORS	     430
                              xxxvo.

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page

          Plant Size	     431
          Plant Age	     431

          PRODUCTION NORMALIZING PARAMETERS 	     431

V         WATER USE AND WASTEWATER CHARACTERISTICS. ...     433

          WASTEWATER SOURCES, DISCHARGE RATES, AND
          CHARACTERISTICS 	     434

          Film Stripping	     437
          Film Stripping Wet Air Pollution Control. . .  .     437
          Precipitation and Filtration of Film Stripping
          Solutions	     437
          Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control  	     438
          Precipitation and Filtration of Photographic
          Solutions	     438
          Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution Control  	     438
          Electrolytic Refining 	     439
          Furnace Wet Air Pollution Control 	     439
          Casting Contact Cooling Water 	     439
          Casting Wet Air Pollution Control 	     440
          Leaching	     440
          Leaching Wet Air Pollution Control	     440
          Precipitation and Filtration of Nonphotographic
          Solutions	     441
          Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control  	     441

VI        SELECTION OF POLLUTANT PARAMETERS 	     479

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS	     479

          Conventional and Nonconventional Pollutant
          Parameters Selected 	 .....     479

          TOXIC POLLUTANTS	     480

          Toxic Pollutants Never Detected 	     481
                              xxxvii

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page

          Toxic Pollutants Never Found Above Their
          Analytical Quantification Limit 	     482
          Toxic Pollutants Present Below Concentrations
          Achievable by Treatment 	     483
          Toxic Pollutants Detected in a Small Number
          of Sources	     484
          Toxic Pollutants Selected for Consideration
          In Establishing Limitations 	     488

VII       CONTROL AND TREATMENT TECHNOLOGIES	     495

          CURRENT CONTROL AND TREATMENT PRACTICES ....     495

          Film Stripping	     495
          Film Stripping Wet Air Pollution Control.  . . .     496
          Precipitation and Filtration of Film Stripping
          Solutions	     496
          Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control  	     496
          Precipitation and Filtration of Photographic
          Solutions	     496
          Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution Control  	     497
          Electrolytic Refining 	     497
          Furnace Wet Air Pollution Control 	     497
          Casting Contact Cooling Water  	     498
          Casting Wet Air Pollution Control 	     498
          Leaching	     498
          Leaching Wet Air Pollution Control	     499
          Precipitation and Filtration of Nonphotographic
          Solutions	     499
          Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control  	     499

          CONTROL AND TREATMENT OPTIONS CONSIDERED.   .  .  .     500

          Option A	     500
          Option B	     500
          Option C	     500
          Option E	     501
                             xxxviii

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section
VIII
IX
COSTS, ENERGY, AND NONWATER QUALITY ASPECTS . ,

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES ,

Option A	 .
Option B	
Option C	'	,
Option E	

NONWATER QUALITY ASPECTS	,

Energy Requirements 	

SOLID WASTE 	

Air Pollution 	

BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE 	 ,

TECHNICAL APPROACH TO BPT 	

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS,

BDT OPTION SELECTION	,

WASTEWATER DISCHARGE RATES	,

Film Stripping	
Film Stripping Wet Air Pollution Control. . . ,
Precipitation and Filtration of Film Stripping
Solutions 	
Precipitation and Filtration of Film Stripping
Solutions Wet Air Pollution Control 	 ,
Precipitation and Filtration of Photographic
Solutions 	
Precipitation and Filtration of Photographic
Solutions Wet Air Pollution Control 	
Electrolytic Refining 	
Furnace Wet Air Pollution Control  	
Casting Contact Cooling Water 	
Casting Wet Air Pollution Control  	
Leaching	
Leaching Wet Air Pollution Control	,
Page

 503

 504

 504
 504
 505
 505

 505

 505

 506

 507


 513

 513

 515

 516

 517

 517
 517

 517

 518

 518

 518
 519
 519
 520
 520
 520
 520
                              XXXIX

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page

          Precipitation and Filtration of Nonphotographic
          Solutions	     521
          Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control  	     521

          REGULATED POLLUTANT PARAMETERS	     521

          EFFLUENT LIMITATIONS	     522

X         BEST AVAILABLE TECHNOLOGY ECONOMICALLY
          ACHIEVABLE	     531

          TECHNICAL APPROACH TO BAT	     531

          Option A	     532
          Option B	     533

            Recycle of Casting Contact Cooling Water
            Through Cooling Towers	     534
            Recycle of Water Used In Wet Air Pollution
            Control	     534

          Option C	     534
          Option E	     535

          INDUSTRY COST AND ENVIRONMENTAL BENEFITS.  ...     535

          Pollutant Reduction Benefits	  .     535
          Compliance Costs	  .     536

          BAT OPTION SELECTION	     536

          WASTEWATER DISCHARGE RATES	     537

          Furnace Wet Air Pollution Control  	     537
          Casting Contact Cooling Water 	     538

          REGULATED POLLUTANT PARAMETERS	     538

          EFFLUENT LIMITATIONS	     540
                               xl

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                   SECONDARY SILVER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                      Page

XI        NEW SOURCE PERFORMANCE STANDARDS	     561

          TECHNICAL APPROACH TO BDT	     561

          BDT OPTION SELECTION	     562

          REGULATED POLLUTANT PARAMETERS	     563

          NEW SOURCE PERFORMANCE STANDARDS	     563

XII       PRETREATMENT STANDARDS	     571

          TECHNICAL APPROACH TO PRETREATMENT	     571

          Pretreatment Standards for Existing and New
          Sources	     572

          INDUSTRY COST AND ENVIRONMENTAL BENEFITS.  ...     573

          PSES OPTION SELECTION 	     573

          PSNS OPTION SELECTION 	     574

          REGULATED POLLUTANT PARAMETERS	     574

          PRETREATMENT STANDARDS	     574

XIII      BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY.     597
                               xli

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                   SECONDARY SILVER SUBCATEGORY

                          LIST OF TABLES
Table
III-l     INITIAL OPERATING YEAR (RANGE) SUMMARY OF
          PLANTS IN THE SECONDARY SILVER SUBCATEGORY BY
          DISCHARGE TYPE	     421

III-2     PRODUCTION RANGES FOR THE SECONDARY SILVER
          SUBCATEGORY	     422

III-3     SUMMARY OF SECONDARY SILVER SUBCATEGORY
          PROCESSES AND ASSOCIATED WASTE STREAMS	     423

V-l       WATER USE AND DISCHARGE RATES FOR FILM
          STRIPPING	     442

V-2       SECONDARY SILVER SAMPLING DATA PHOTO-
          MISCELLANEOUS RAW WASTEWATER	     443

V-3       WATER USE AND DISCHARGE RATES FOR
          PRECIPITATION AND FILTRATION OF FILM STRIPPING
          SOLUTIONS	     450

V-4       WATER USE AND DISCHARGE RATES FOR
          PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC
          SOLUTIONS	     451

V-5       SECONDARY SILVER SAMPLING DATA PHOTO-
          MISCELLANEOUS RAW WASTEWATER	     452

V-6       WATER USE AND DISCHARGE RATES FPR PRECIPITATION
          AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS WET
          AIR POLLUTION CONTROL 	     454

V-7       WATER USE AND DISCHARGE RATES FOR ELECTROLYTIC
          REFINING	     455

V-8       SECONDARY SILVER SAMPLING DATA NONPHOTO-
          MISCELLANEOUS RAW WASTEWATER	     456

V-9       WATER USE AND DISCHARGE RATES FOR FURNACE WET
          AIR POLLUTION CONTROL	  .     460

V-10      WATER USE AND DISCHARGE RATES FOR CASTING
          CONTACT COOLING WATER 	     461
                               xlii

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                   SECONDARY SILVER SUBCATEGORY

                    LIST OF TABLES (Continued)


Table                                                        Page

V-ll      WATER USE AND DISCHARGE RATES FOR CASTING
          WET AIR POLLUTION CONTROL	     462

V-12      WATER USE AND DISCHARGE RATES FOR LEACHING.  .  .     463

V-13      WATER USE AND DISCHARGE RATES FOR LEACHING
          WET AIR POLLUTION CONTROL	     464

V-14      WATER USE AND DISCHARGE RATES FOR PRECIPITATION
          AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS  .  .     465

V-15      WATER USE AND DISCHARGE RATES FOR PRECIPITATION
          AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS WET
          AIR POLLUTION CONTROL  	     466

V-16      SECONDARY SILVER SAMPLING DATA NONPHOTO-
          TREATMENT PLANT SAMPLES - PLANT A 	     467

V-17      SECONDARY SILVER SAMPLING DATA NONPHOTO-
          TREATMENT PLANT SAMPLES - PLANT B 	     469

V-18      SECONDARY SILVER SAMPLING DATA PHOTO-
          TREATMENT PLANT SAMPLE - PLANT C	     471

VI-1      FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
          SECONDARY SILVER RAW WASTEWATER 	     491

VIII-1    ENERGY REQUIREMENTS 	     508

IX-1      BPT WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY SILVER SUBCATEGORY	     523

IX-2      BPT EFFLUENT LIMITATIONS FOR THE SECONDARY
          SILVER SUBCATEGORY	     525

X-l       CURRENT RECYCLE PRACTICES WITHIN THE SECONDARY
          SILVER SUBCATEGORY	     541

X-2       POLLUTANT REDUCTION BENEFITS FOR DIRECT
          DISCHARGERS	     542

X-3       COST OF COMPLIANCE FOR DIRECT DISCHARGERS IN
          THE SECONDARY SILVER SUBCATEGORY	     544
                              xliii

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                   SECONDARY SILVER SUBCATEGORY

                    LIST OF TABLES (Continued)


Table                                                        Page

X-4       BAT WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY SILVER SUBCATEGORY	      545

X-5       BAT EFFLUENT LIMITATIONS FOR THE SECONDARY
          SILVER SUBCATEGORY (BASED ON OPTION B)	      547

X-6       BAT EFFLUENT LIMITATIONS FOR THE SECONDARY
          SILVER SUBCATEGORY (BASED ON OPTION C)	      552

XI-1      NSPS WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY SILVER SUBCATEGORY	      564

XI-2      NSPS FOR THE SECONDARY SILVER SUBCATEGORY ...      566

XII-1     POLLUTANT REDUCTION BENEFITS FOR INDIRECT
          DISCHARGERS	      576

XII-2     COST OF COMPLIANCE FOR INDIRECT DISCHARGERS  IN
          THE SECONDARY SILVER SUBCATEGORY	      578

XII-3     PSES AND PSNS WASTEWATER DISCHARGE RATES FOR
          THE SECONDARY SILVER SUBCATEGORY	      579

XII-4     PSES FOR THE SECONDARY SILVER SUBCATEGORY
          (BASED ON OPTION B)	      581

XII-5     PSES FOR THE SECONDARY SILVER SUBCATEGORY
          (BASED ON OPTION C)	      586

XII-6     PSNS FOR THE SECONDARY SILVER SUBCATEGORY
          (BASED ON OPTION C)	      591

XIII-1    BCT EFFLUENT LIMITATIONS FOR THE SECONDARY
          SILVER SUBCATEGORY	      599
                               xliv

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         SECONDARY SILVER SUBCATEGORY

               LIST OF FIGURES
SILVER REFINING FROM PHOTOGRAPHIC MATERIALS .  .

SILVER REFINING FROM WASTE PLATING SOLUTIONS.  .
Figure

III-l

III-2

III-3     SECONDARY SILVER PRODUCTION PROCESS FROM
          NONPHOTOGRAPHIC SCRAP  .  .  .	

III-4     GEOGRAPHIC LOCATIONS OF THE SECONDARY SILVER
          INDUSTRY	

V-l       SAMPLING SITES AT SECONDARY SILVER PLANT A. .  .

V-2       SAMPLING SITES AT SECONDARY SILVER PLANT B. .  .

V-3       SAMPLING SITES AT SECONDARY SILVER PLANT C. .  .

V-4       SAMPLING SITES AT SECONDARY SILVER PLANT D. .  .

VIII-1    SECONDARY SILVER (PHOTOGRAPHIC) COMBINATION 1,
          OPTION A	

VIII-2    SECONDARY SILVER (PHOTOGRAPHIC) COMBINATION 1,
          OPTION C	

VIII-3    SECONDARY SILVER (PHOTOGRAPHIC) COMBINATION 1,
          OPTION E	

VIII-4    SECONDARY SILVER (NON-PHOTOGRAPHIC) COMBINATION
          1, OPTION A 	

VIII-5    SECONDARY SILVER (NON-PHOTOGRAPHIC) COMBINATION
          1, OPTION C 	

VIII-6    SECONDARY SILVER (NON-PHOTOGRAPHIC) COMBINATION
          1, OPTION E 	

VIII-7    SECONDARY SILVER HOLDING TANK COSTS 	

VIII-8    SECONDARY SILVER COOLING TOWER COSTS CASTING
          CONTACT COOLING 	
Page

 424

 425


 426


 427

 475

 476

 477

 478


 509


 509


 510


 510


 511


 511

 512


 512
                     xlv

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                   SECONDARY SILVER SUBCATEGORY

                         LIST OF FIGURES


Figure                                                       Page

IX-1      BPT TREATMENT SCHEME FOR THE SECONDARY SILVER
          SUBCATEGORY	     530

X-l       BAT TREATMENT SCHEME FOR OPTION A	     557

X-2       BAT TREATMENT SCHEME FOR OPTION B	     558

X-3       BAT TREATMENT SCHEME FOR OPTION C	     559

X-4       BAT TREATMENT SCHEME FOR OPTION E	     560
                               xlvi

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                   SECONDARY COPPER SUBCATEGORY

                        TABLE OF CONTENTS


Section                                                     Page

I         SUMMARY AND CONCLUSIONS	    605

II        RECOMMENDATIONS	    609

          BPT EFFLUENT LIMITATIONS 	    609

          BAT EFFLUENT LIMITATIONS 	    610

          NSPS	    610

          PSES	    610

          PSNS	    610

          BCT	    610

III       INDUSTRY PROFILE 	    611

          DESCRIPTION OF SECONDARY COPPER PRODUCTION ...    611

          Raw Materials	    611

          PRETREATMENT OF SCRAP	    612

          Stripping	    612
          Briquetting	    612
          Size Reduction	    612
          Crushing	    613
          Residue Concentration	    613
          Residue Pelletizing and Roll Briquetting ....    613
          Drying	    614
          Burning	    614
          Sweating	    614

          SMELTING OF LOW-GRADE SCRAP AND RESIDUES ....    615

          MELTING,  REFINING,  AND ALLOYING INTERMEDIATE-
          GRADE COPPER-BASED SCRAP 	    617

          REFINING HIGH-GRADE COPPER SCRAP 	    618

          Fire Refining	    619
          Skimming	    619
          Electrolytic Refining	    620
          Postelectrolytic Melting and Refining	    620
                             xlvii

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                   SECONDARY COPPER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          CASTING	   620

          Brass and Bronze Ingot	   621
          Black and Blister Copper	   621
          Anodes	   622
          Refined Copper 	   622
          Copper Shot	   622

          PROCESS WASTEWATER SOURCES 	   623

          OTHER WASTEWATER SOURCES 	   623

          AGE, PRODUCTION, AND PROCESS PROFILE 	   623

IV        SUBCATEGORIZATION	   629

          FACTORS CONSIDERED IN SUBCATEGORIZATION	   629

          FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY
          COPPER SUBCATEGORY 	   630

          Other Factors	   631

          PRODUCTION NORMALIZING PARAMETERS	   631

V         WATER USE AND WASTEWATER CHARACTERISTICS ....   633

          WASTEWATER SOURCES, DISCHARGE RATES, AND
          CHARACTERISTICS	   634

          SECONDARY COPPER WASTEWATER SOURCES AND
          CHARACTERISTICS	   637

          Residue Concentration	   637
          Slag Granulation	   637
          Reverberatory and Rotary Furnace Wet Air
          Pollution Control	   637
          Spent Electrolyte	   638
          Scrap and Anode Rinsing	   638
          Contact Cooling Water	   638
          Casting Wet Air Pollution Control	   639
                              xlviii

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                   SECONDARY COPPER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

VI        SELECTION OF POLLUTANT PARAMETERS	    673

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS	    673

          Conventional Pollutant Parameters Selected .  .  .    673

          TOXIC POLLUTANTS	    674

          Toxic Pollutants Never Detected	    674
          Toxic Pollutants Never Found Above Their
          Analytical Quantification Concentration	    676
          Toxic Pollutants Present Below Concentrations
          Achievable by Treatment	    677
          Toxic Pollutants Detected in a Small Number
          of Sources	    678
          Toxic Pollutants Selected for Further Consid-
          eration for Limitation	    682

VII       CONTROL AND TREATMENT TECHNOLOGIES 	    689

          TECHNICAL BASIS OF PROMULGATED BPT 	    689

          CURRENT CONTROL AND TREATMENT PRACTICES	    690

          Residue Concentration	    691
          Slag Granulation	    692
          Reverberatory and Rotary Furnace Wet Air
          Pollution Control	    692
          Scrap Anode Rinsing	    693
          Spent Electrolyte	    693
          Casting Contact Cooling	    694

          CONTROL AND TREATMENT OPTIONS	    695

          Option A	    695
          Option C	    695
          Option G	    696
                               xlix

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                   SECONDARY COPPER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section

VIII

IX


X


XI

XII
COSTS, ENERGY, AND NONWATER QUALITY ASPECTS.  .
Page

 697
BEST PRACTICABLE TECHNOLOGY CURRENTLY
AVAILABLE	   699

BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE	   701

NEW SOURCE PERFORMANCE STANDARDS 	   703

PRETREATMENT STANDARDS 	   705

INTRODUCTION 	   705

TECHNICAL APPROACH TO PRETREATMENT 	   705

PRETREATMENT STANDARDS FOR EXISTING SOURCES. .   .   706

Option A	   707
Option C	   707
Option G	   707

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS  .   707

POLLUTANT REDUCTION BENEFITS 	   707

COMPLIANCE COSTS 	   708

PSES OPTION SELECTION	   709

PSNS OPTION SELECTION	   709

WASTEWATER DISCHARGE RATES 	   709

Residue Concentration	   709
Slag Granulation	   709
Reverberatory and Rotary Furnace Wet Air
Pollution Control	   710
Spent Electrolyte	   710
Scrap Anode Rinsing	   710
Casting Contact Cooling	   710
Casting Wet Air Pollution Control	   711

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                   SECONDARY COPPER SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          STORMWATER AND PRECIPITATION ALLOWANCES	   711

          PRETREATMENT STANDARDS FOR EXISTING AND NEW
          SOURCES	   711

XIII      BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY  .   713
                               li

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                   SECONDARY COPPER SUBCATEGORY

                          LIST OF TABLES


Number                                                      Page

III-l     INITIAL OPERATING YEAR (RANGE) SUMMARY OF PLANTS
          IN THE SECONDARY COPPER SUBCATEGORY BY DISCHARGE
          TYPE	   624

III-2     PRODUCTION RANGES FOR PROCESSING PLANTS OF THE
          SECONDARY COPPER SUBCATEGORY  	   625

III-3     PRODUCTION PROCESSES UTILIZED BY THE SECONDARY
          COPPER SUBCATEGORY 	   626

V-l       WATER USE AND DISCHARGE RATES FOR RESIDUE
          CONCENTRATION	   640

V-2       WATER USE AND DISCHARGE RATES FOR SLAG
          GRANULATION	   641

V-3       WATER USE AND DISCHARGE RATES FOR REVERBERATORY
          AND ROTARY FURNACE WET AIR POLLUTION CONTROL  .  .   642

V-4       ELECTROLYTE USE AND DISCHARGE RATES	   643

V-5       WATER USE AND DISCHARGE RATES FOR SCRAP ANODE
          RINSING	   644

V-6       WATER USE AND DISCHARGE RATES FOR CASTING
          CONTACT COOLING	   645

V-7       WATER USE AND DISCHARGE RATES FOR CASTING
          WET AIR POLLUTION CONTROL	   646

V-8       SECONDARY COPPER SAMPLING DATA RESIDUE CONCEN-
          TRATION RAW WASTEWATER	   647

V-9       SECONDARY COPPER SAMPLING DATA WET AIR POLLUTION
          CONTROL RAW WASTEWATER 	   651

V-10      SECONDARY COPPER SAMPLING DATA SPENT ELECTRO-
          LYTE RAW WASTEWATER	   653

V-ll      SECONDARY COPPER SAMPLING DATA CASTING CONTACT
          COOLING RAW WASTEWATER	   655

V-l2      SECONDARY COPPER SAMPLING DATA MISCELLANEOUS
          RAW WASTEWATER	   657
                               lii

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SECONDARY COPPER SUBCATEGORY



 LIST OF TABLES (Continued)
Number
V-13
V-14
V-15
V-16
VI-1
XII-1

SECONDARY COPPER SAMPLING DATA TREATMENT PLANT
SAMPLES - PLANT A 	
SECONDARY COPPER SAMPLING DATA TREATMENT PLANT
SAMPLES - PLANT B 	
SECONDARY COPPER SAMPLING TREATMENT PLANT
SAMPLES - PLANT C 	
SECONDARY COPPER SAMPLING DATA TREATMENT PLANT
SAMPLES - PLANT E 	
FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
SECONDARY LEAD RAW WASTEWATER 	
POLLUTANT REDUCTION BENEFITS FOR INDIRECT
DISCHARGERS 	
Page
662
663
664
666
685
712
           liii

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SECONDARY COPPER SUBCATEGORY




      LIST OF FIGURES
Number
III-l
III-2
V-l
V
V
V
V
-2
-3
-4
-5
SECONDARY
GEOGRAPH1
SUBCATEGC
SAMPLING
SAMPLING
SAMPLING
SAMPLING
SAMPLING
f COPPER PRODUCTION
EC LOCATIONS OF THE
)RY 	 	
SITES
SITES
SITES
SITES
SITES
AT
AT
AT
AT
AT
SECONDARY
SECONDARY
SECONDARY
SECONDARY
SECONDARY
PROCESS
SECOND/
COPPER
COPPER
COPPER
COPPER
COPPER
i

JIY COPPER
PLANT
PLANT
PLANT
PLANT
PLANT
A ...
D • • •
\j • • *
D . . .
Hi • • •
Page
627
628
668
669
670
671
672
           liv

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                  SECONDARY ALUMINUM SUBCATEGORY

                        TABLE OF CONTENTS


Section                                                     Page

I         SUMMARY AND CONCLUSIONS	   715

II        RECOMMENDATIONS	   718

          BPT EFFLUENT LIMITATIONS 	   718

          SCRAP DRYING WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS 	   720

          SCRAP SCREENING AND MILLING BAT EFFLUENT
          LIMITATIONS	   720

          DROSS WASHING BAT EFFLUENT LIMITATIONS 	   720

          DEMAGGING WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS 	   721

          DIRECT CHILL CASTING CONTACT COOLING BAT
          EFFLUENT LIMITATIONS 	   721

          STATIONARY CASTING CONTACT COOLING BAT
          EFFLUENT LIMITATIONS 	   721

          SHOT CASTING CONTACT COOLING BAT EFFLUENT
          LIMITATIONS	   722

          SCRAP DRYING WET AIR POLLUTION CONTROL NSPS.  .  .   722

          SCRAP SCREENING AND MILLING NSPS	   723

          DROSS WASHING NSPS	   723

          DEMAGGING WET AIR POLLUTION CONTROL NSPS ....   723

          DIRECT CHILL CASTING CONTACT COOLING NSPS.  ...   724

          STATIONARY CASTING CONTACT COOLING NSPS	   724

          SHOT CASTING CONTACT COOLING NSPS	   725
                               lv

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                  SECONDARY ALUMINUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          SCRAP DRYING WET AIR POLLUTION CONTROL PSES.  .  .   725

          SCRAP SCREENING AND MILLING PSES	   725

          DROSS WASHING PSES	   726

          DEMAGGING WET AIR POLLUTION CONTROL PSES ....   726

          DIRECT CHILL CASTING CONTACT COOLING PSES.   ...   726

          STATIONARY CASTING CONTACT COOLING PSES	   726

          SHOT CASTING CONTACT COOLING PSES	   727

          SCRAP DRYING WET AIR POLLUTION CONTROL PSNS.  .  .   728

          SCRAP SCREENING AND MILLING PSNS	   728

          DROSS WASHING PSNS	   728

          DEMAGGING WET AIR POLLUTION CONTROL PSNS ....   728

          DIRECT CHILL CASTING CONTACT COOLING PSNS.   ...   729

          STATIONARY CASTING CONTACT COOLING PSNS	   729

          SHOT CASTING CONTACT COOLING PSNS	   729

          SCRAP DRYING WET AIR POLLUTION CONTROL BCT
          EFFLUENT LIMITATIONS 	   730

          SCRAP SCREENING AND MILLING BCT EFFLUENT
          LIMITATIONS	   730

          DROSS WASHING BCT EFFLUENT LIMITATIONS 	   730

          DEMAGGING WET AIR POLLUTION CONTROL BCT
          EFFLUENT LIMITATIONS	   731

          DIRECT CHILL CASTING CONTACT COOLING BCT
          EFFLUENT LIMITATIONS 	   731
                               Ivi

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                  SECONDARY ALUMINUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          STATIONARY CASTING CONTACT COOLING BCT
          EFFLUENT LIMITATIONS  	   731

          SHOT CASTING CONTACT COOLING BCT EFFLUENT
          LIMITATIONS	   732

III       INDUSTRY PROFILE 	   733

          DESCRIPTION OF SECONDARY ALUMINUM PRODUCTION .   .   733

          Raw Materials	   733
          Pretreatment 	   733
          Smelting and Refining	   734
          Process Wastewater Sources 	   737
          Other Wastewater Sources 	   737
          Age, Production and Process Profile	   738

IV        SUBCATEGORIZATION	   745

          FACTORS CONSIDERED IN SUBCATEGORIZATION	   745

          FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY
          ALUMINUM SUBCATEGORY 	   746

          Other Factors	   747

          PRODUCTION NORMALIZING PARAMETERS	   748

V         WATER USE AND WASTEWATER CHARACTERISTICS ....   749

          WASTEWATER SOURCES, DISCHARGE RATES,  AND
          CHARACTERISTICS	   750

          Scrap Drying Wet Air Pollution Control	   753
          Scrap Screening and Milling	   753
          Dross Washing Wastewater 	   753
          Demagging Wet Air Pollution Control	   753
          Direct Chill Casting Contact Cooling 	   754
          Stationary Casting Cooling 	   754
          Shot Casting Contact Cooling 	   755
                               Ivii

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                  SECONDARY ALUMINUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section
VI
VII
VIII
                                                  Page

SELECTION OF POLLUTANTS	    787

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
PARAMETERS	    787

Conventional and Nonconventional Pollutant
Parameters Selected	    787

TOXIC POLLUTANTS	    789

Toxic Pollutants Never Detected	    789
Toxic Pollutants Never Found Above Their
Analytical Quantification Concentration	    791
Toxic Pollutants Present Below Concentrations
Achievable by Treatment	    791
Toxic Pollutants Detected in a Small Number
of Sources	    793
Toxic Pollutants Selected for Consideration in
Establishing Limitations 	    797

CONTROL AND TREATMENT TECHNOLOGIES 	    803

TECHNICAL BASIS OF BPT	    803

CURRENT CONTROL AND TREATMENT PRACTICES	    804

Scrap Drying Wet Air Pollution Control	    804
Scrap Screening and Milling Wastewater 	    804
Dross Washing Wastewater 	    804
Demagging Wet Air Pollution Control	    805
Casting Contact Cooling	    806

CONTROL AND TREATMENT OPTIONS CONSIDERED ....    806

Option A	    807
Option C	    807
Option F	    807

COSTS, ENERGY, AND NONWATER QUALITY ASPECTS. .  .    809

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES.  .    810

Option A	    810
Option C	    811
Option F	    811
                             Iviii

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                  SECONDARY ALUMINUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          NONWATER QU/LITY ASPECTS 	    811

          Energy Requirements	    812
          Solid Waste	    812
          Air Pollution	    813

IX        BEST PRACTICABLE TECHNOLOGY CURRENTLY
          AVAILABLE	    821

X         BEST AVAILABLE TECHNOLOGY ECONOMICALLY
          ACHIEVABLE	    823

          TECHNICAL APPROACH TO BAT	    823

          Option A	    824

            Recycle of Casting Contact Cooling Water
            Through Cooling Towers 	    825
            Recycle of Water Used in Wet Air Pollution
            Control	    825

          Option C	    826
          Option F	    826

          INDUSTRY COST AND POLLUTANT REDUCTION
          BENEFITS	    826

          Pollutant Reduction Benefits 	    827
          Compliance Costs 	    827

          BAT OPTION SELECTION 	    828

          WASTEWATER DISCHARGE RATES 	    829

          Scrap Drying Wet Air Pollution Control
          Wastewater	    829
          Scrap Screening and Milling	    829
          Dross Washing Wastewater 	    830
          Demagging Wet Air Pollution Control	    830
          Direct Chill Casting Contact Cooling 	    830
          Stationary Casting Contact Cooling Water ....    831
          Shot Casting Contact Cooling Water 	    831
                              lix

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Section
XI
XII
XIII
        SECONDARY ALUMINUM SUBCATEGORY

        TABLE OF CONTENTS (Continued)


                                                  Page

REGULATED POLLUTANT PARAMETERS .... 	   831

EFFLUENT LIMITATIONS 	   832

NEW SOURCE PERFORMANCE STANDARDS 	   845

TECHNICAL APPROACH TO BDT	   845

Option A	   845
Option C	   845
Option F	   846

BDT OPTION SELECTION 	   846

REGULATED POLLUTANT PARAMETERS 	   847

NEW SOURCE PERFORMANCE STANDARDS 	   847

PRETREATMENT STANDARDS 	   853

TECHNICAL APPROACH TO PRETREATMENT 	   853

PRETREATMENT STANDARDS FOR EXISTING SOURCES. .  .   854

Option A	   854
Option C	   854
Option F	   855

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS  .   855

PSES AND PSNS OPTION SELECTION	   855

REGULATED POLLUTANT PARAMETERS 	   855

PRETREATMENT STANDARDS 	   856

BEST CONVENTIONAL POLLUTANT CONTROL
TECHNOLOGY	   867
                               Ix

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                  SECONDARY ALUMINUM  SUBCATEGORY

                          LIST OF TABLES
Number

III-l     INITIAL OPERATING YEAR  (RANGE) SUMMARY OF PLANTS
          IN THE SECONDARY ALUMINUM  SUBCATEGORY BY DIS-
          CHARGE TYPE	    739

III-2     PRODUCTION RANGES FOR SMELTERS AND REFINERS OF
          THE SECONDARY ALUMINUM  SUBCATEGORY  	    740

III-3     SUMMARY OF SUBCATEGORY  PROCESSES AND ASSOCIATED
          WASTE STREAMS	    741

V-l       WATER USE AND DISCHARGE RATES FOR SCRAP DRYING
          WET AIR POLLUTION CONTROL	    756

V-2       WATER USE AND DISCHARGE RATES FOR SCRAP
          SCREENING AND MILLING	    757

V-3       WATER USE AND DISCHARGE RATES FOR DROSS
          WASHING	    758

V-4       SECONDARY ALUMINUM SAMPLING DATA DROSS WASHING
          RAW WASTEWATER	    759

V-5       WATER USE AND DISCHARGE RATES FOR DEMAGGING
          WET AIR POLLUTION CONTROL	    762

V-6       SECONDARY ALUMINUM SAMPLING DATA DEMAGGING
          SCRUBBER LIQUOR RAW WASTEWATER 	    763

V-7       WATER USE AND DISCHARGE RATES FOR DIRECT
          CHILL CASTING CONTACT COOLING (ALUMINUM
          FORMING CATEGORY)	    767

V-8       WATER USE AND DISCHARGE RATES FOR DIRECT
          CHILL CASTING CONTACT COOLING WATER (PRIMARY
          ALUMINUM SUBCATEGORY)	    769

V-9       SECONDARY ALUMINUM SAMPLING DATA CASTING
          CONTACT COOLING WATER RAW  WASTEWATER 	    770

V-10      SECONDARY ALUMINUM SAMPLING DATA DEMAGGING
          WET AIR POLLUTION CONTROL  AND CASTING CONTACT
          COOLING COMBINED RAW WASTEWATER	    771
                               Ixi

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                  SECONDARY ALUMINUM SUBCATEGORY

                    LIST OF TABLES (Continued)
Number
V-ll      SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT A	  .   773

V-12      SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT B	   775

V-13 ,     SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT D	   778

V-14      SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT E	   780

VI-1      FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
          SECONDARY ALUMINUM RAW WASTEWATER	   798

VIII-1    ENERGY REQUIREMENTS	   814

X-l       CURRENT RECYCLE PRACTICES WITHIN THE SECONDARY
          ALUMINUM SUBCATEGORY 	   834

X-2       POLLUTANT REDUCTION BENEFITS FOR DIRECT
          DISCHARGERS	   835

X-3       COST OF COMPLIANCE FOR THE SECONDARY ALUMINUM
          SUBCATEGORY DIRECT DISCHARGERS 	   836

X-4       BAT WASTEWATER DISCHARGE RATES FOR THE SECONDARY
          ALUMINUM SUBCATEGORY 	   837

X-5       BAT EFFLUENT LIMITATIONS FOR THE SECONDARY
          ALUMINUM SUBCATEGORY 	   838

XI-1      NSPS WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY ALUMINUM SUBCATEGORY 	   848

XI-1      NSPS FOR THE SECONDARY ALUMINUM SUBCATEGORY.  .  .   849

XII-1     POLLUTANT REDUCTION BENEFITS FOR INDIRECT
          DISCHARGERS	   857

XII-2     COST OF COMPLIANCE FOR THE SECONDARY ALUMINUM
          SUBCATEGORY INDIRECT DISCHARGERS 	   858
                               Ixii,

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                  SECONDARY ALUMINUM  SUBCATEGORY

                    LIST OF TABLES  (Continued)


Number                                                      Page

V-ll      SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT A	    773

V-12      SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT B	    775

V-13      SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT D	    778

V-14      SECONDARY ALUMINUM SAMPLING DATA TREATMENT
          PLANT SAMPLES PLANT E	    780

VI-1      FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
          SECONDARY ALUMINUM RAW WASTEWATER	    798

VIII-1    ENERGY REQUIREMENTS	    814

X-l       CURRENT RECYCLE PRACTICES WITHIN THE SECONDARY
          ALUMINUM SUBCATEGORY  	    834

X-2       POLLUTANT REDUCTION BENEFITS FOR DIRECT
          DISCHARGERS	    835

X-3       COST OF COMPLIANCE FOR THE  SECONDARY ALUMINUM
          SUBCATEGORY DIRECT DISCHARGERS 	    836

X-4       BAT WASTEWATER DISCHARGE RATES FOR THE SECONDARY
          ALUMINUM SUBCATEGORY  	    837

X-5       BAT EFFLUENT LIMITATIONS FOR THE SECONDARY
          ALUMINUM SUBCATEGORY  	    838

XI-1      NSPS WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY ALUMINUM SUBCATEGORY 	    848

XI-1      NSPS FOR THE SECONDARY ALUMINUM SUBCATEGORY.  .  .    849

XII-1     POLLUTANT REDUCTION BENEFITS FOR INDIRECT
          DISCHARGERS	    857

XII-2     COST OF COMPLIANCE FOR THE SECONDARY ALUMINUM
          SUBCATEGORY INDIRECT DISCHARGERS 	    858
                              Ixiii

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SECONDARY ALUMINUM SUBCATEGORY



  LIST OF TABLES (Continued)
Number
XII-3
XII-4
XII-5
XII-6
XIII-1

PSES AND PSNS WASTEWATER DISCHARGE RATES FOR
THE SECONDARY ALUMINUM SUBCATEGORY 	
PSES FOR THE SECONDARY ALUMINUM SUBCATEGORY
(MASS -BASED) 	
PSES FOR THE SECONDARY ALUMINUM SUBCATEGORY
(CONCENTRATION -BASED) 	
PSNS FOR THE SECONDARY ALUMINUM SUBCATEGORY. . .
BCT EFFLUENT LIMITATIONS FOR THE SECONDARY
ALUMINUM SUBCATEGORY 	
Page
859
860
863
865
869
           Ixiv

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                  SECONDARY ALUMINUM  SUBCATEGORY
                         LIST OF FIGURES
Number
III-l
III-2

V-l
V-2
V-3
V-4
V-5
VIII-1
VIII-2
VIII-3
VIII-4
VIII-5
VIII-6
VIII-7
VIII-8
VIII-9
VIII-10
VIII-11
X-l
X-2
X-3
SECONDARY ALUMINUM SMELTING PROCESS.
GEOGRAPHIC LOCATIONS OF SECONDARY ALUMINUM
SUBCATEGORY PLANTS  	
SAMPLING SITES AT SECONDARY ALUMINUM PLANT A  .  .
SAMPLING SITES AT SECONDARY ALUMINUM PLANT B  .  .
SAMPLING SITES AT SECONDARY ALUMINUM PLANT C  .  .
SAMPLING SITES AT SECONDARY ALUMINUM PLANT D  .  .
SAMPLING SITES AT SECONDARY ALUMINUM PLANT E  .  .
SECONDARY ALUMINUM COMBINATIONS 1&4, OPTION A.  .
SECONDARY ALUMINUM COMBINATIONS !Sc4, OPTION C.  .
SECONDARY ALUMINUM COMBINATIONS 1&4, OPTION F.  .
SECONDARY ALUMINUM COMBINATIONS 2&5, OPTION A.  .
SECONDARY ALUMINUM COMBINATIONS 28t5, OPTION C.  .
SECONDARY ALUMINUM COMBINATIONS 2&5, OPTION F.  .
SECONDARY ALUMINUM COMBINATION 3, OPTION A ...
SECONDARY ALUMINUM COMBINATION 3, OPTION C .  .  .
SECONDARY ALUMINUM COMBINATION 3, OPTION F .  .  .
COOLING TOWER COSTS (CASTING CONTACT COOLING).  .
HOLDING TANK COSTS 	
BAT TREATMENT SCHEME FOR OPTION A	
BAT TREATMENT SCHEME FOR OPTION C	
BAT TREATMENT SCHEME FOR OPTION F	
Page
 742

 743
 782
 783
 784
 785
 786
 815
 815
 816
 816
 817
 817
 818
 818
 819
 819
 820
 841
 842
 843
                              Ixv

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                    SECONDARY LEAD SUBCATEGORY

                        TABLE OF CONTENTS


Section                                                     Page

I         SUMMARY AND CONCLUSIONS	873

II        RECOMMENDATIONS	877

          BATTERY CRACKING BPT EFFLUENT
          LIMITATIONS	877

          BLAST AND REVERBERATORY FURNACE WET AIR
          POLLUTION CONTROL BPT EFFLUENT LIMITATIONS ...  878

          KETTLE WET AIR POLLUTION CONTROL BPT EFFLUENT
          LIMITATIONS	878

          CASTING CONTACT COOLING BPT EFFLUENT
          LIMITATIONS	879

          BATTERY CRACKING BAT EFFLUENT
          LIMITATIONS	879

          BLAST AND REVERBERATORY FURNACE WET AIR
          POLLUTION CONTROL BAT EFFLUENT LIMITATIONS ...  880

          KETTLE WET AIR POLLUTION CONTROL
          BAT EFFLUENT LIMITATIONS 	  880

          CASTING CONTACT COOLING BAT EFFLUENT
          LIMITATIONS	880

          BATTERY CRACKING BAT EFFLUENT
          LIMITATION   	881

          BLAST AND REVERBERATORY FURNACE WET AIR
          POLLUTION CONTROL BAT EFFLUENT LIMITATIONS ...  881

          KETTLE WET AIR POLLUTION CONTROL BAT
          EFFLUENT LIMITATIONS   	  881

          CASTING CONTACT COOLING
          BAT EFFLUENT LIMITATIONS 	  882

          BATTERY CRACKING
          NSPS	882

          BLAST AND REVERBERATORY FURNACE WET
          AIR POLLUTION CONTROL NSPS	883

                              Ixvii

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                    SECONDARY LEAD SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          KETTLE WET AIR POLLUTION CONTROL
          NSPS	883

          CASTING CONTACT COOLING
          NSPS	883

          BATTERY CRACKING
          PSES	884

          BLAST AND REVERBERATORY FURNACE WET AIR POLLU-
          TION CONTROL PSES	884

          KETTLE WET AIR POLLUTION CONTROL
          PSES	884

          CASTING CONTACT COOLING
          PSES   	885

          BATTERY CRACKING
          PSES   	885

          BLAST AND REVERBERATORY FURNACE WET AIR
          POLLUTION CONTROL PSES 	  885

          KETTLE WET AIR POLLUTION CONTROL
          PSES   	886

          CASTING CONTACT COOLING
          PSES   	886


          BATTERY CRACKING PSNS	886

          BLAST AND REVERBERATORY FURNACE WET AIR
          POLLUTION CONTROL PSNS 	  887

          KETTLE WET AIR POLLUTION CONTROL PSNS	887

          CASTING CONTACT COOLING PSNS 	  887

          BATTERY CRACKING BCT EFFLUENT LIMITATIONS  ...  888
                              Ixviii

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                    SECONDARY LEAD SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          BLAST AND REVERBERATORY FURNACE WET AIR
          POLLUTION CONTROL BCT EFFLUENT LIMITATION  .  .     888

          KETTLE WET AIR POLLUTION CONTROL BCT
          EFFLUENT LIMITATIONS 	     888

          CASTING CONTACT COOLING
          BCT EFFLUENT LIMITATIONS 	     889

III       INDUSTRY PROFILE 	  891

          DESCRIPTION OF SECONDARY LEAD PRODUCTION ....  891

          Raw Materials	  891
          Scrap Pretreatment	891
          Battery Breaking by Shear or Saw	892
          Hammer-Mill Battery-Breaking 	  892
          Flotation-Type Separators	892
          Low-Energy Shredders 	  892
          Whole Battery Charging 	  892
          Smelting Operations  	  893
          Refining and Casting	893
          Process Wastewater Sources 	  894
          Other Wastewater Sources 	  895
          Age, Production and Process Profile	895

IV        SUBCATEGORIZATION	901

          FACTORS CONSIDERED IN SUBCATEGORIZATION	901

          FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY
          LEAD SUBCATEGORY	902

          Other Factors	902

          PRODUCTION NORMALIZING PARAMETERS	903
                               Ixix

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                    SECONDARY LEAD SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

V         WATER USE AND WASTEWATER CHARACTERISTICS ....  905

          WASTEWATER SOURCES, DISCHARGE RATES, AND
          CHARACTERISTICS	906

          Battery Cracking	'.	908
          Blast and Reverberatory Furnace Wet Air
          Pollution Control  	  909
          Kettle Wet Air Pollution Control 	  909
          Casting Contact Cooling Water	909

VI        SELECTION OF POLLUTANTS	939

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS	939

          Conventional and Nonconventional Pollutant
          Parameters Selected	939

          TOXIC POLLUTANTS	940

          Toxic Pollutants Never Detected	940
          Toxic Pollutants Never Found Above Their
          Analytical Quantification Concentration	942
          Toxic Pollutants Present Below Concentrations
          Achievable by Treatment	943
          Toxic Pollutants Detected in a Small Number
          of Sources	944
          Toxic Pollutants Selected for Consideration in
          Establishing Limitations 	  946

VII       CONTROL AND TREATMENT TECHNOLOGIES 	  953

          CURRENT CONTROL AND TREATMENT PRACTICES	953

          Batter Cracking  	  953
          Blast and Reverberatory Furnace Wet Air
          Pollution Control  	  954
          Kettle Wet Air Pollution Control 	  954
          Casting Contact Cooling  	  955
                               Ixx

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                    SECONDARY LEAD SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section
VIII
IX
                                                  Page
CONTROL AND TREATMENT OPTIONS	955

Option A	955
Option B	955
Option C	956
Option D	956
Option F	956

COSTS, ENERGY, AND NONWATER QUALITY ASPECTS. .  .  957

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES.  .  957

Option A	958
Option B	958
Option C	958
Option D	958
Option F	959

NONWATER QUALITY ASPECTS 	  959

Energy Requirements	959
Solid Waste	960
Air Pollution	961

BEST PRACTICABLE TECHNOLOGY CURRENTLY
AVAILABLE	969

TECHNICAL APPROACH TO BPT	  969

INDUSTRY COST AND POLLUTANT REDUCTION
BENEFITS	971

BPT OPTION SELECTION 	  972

WASTEWATER DISCHARGE RATES 	  972

Battery Cracking 	  972
Blast and Reverberatory Furnace Wet Air
Pollution Control  	  973
Kettle Wet Air Pollution Control 	  973
Casting Contact Cooling Water  	  973
                               Ixxi

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                    SECONDARY LEAD SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

          REGULATED POLLUTANT PARAMETERS 	  974

          EFFLUENT LIMITATIONS 	  974

X         BEST AVAILABLE TECHNOLOGY ECONOMICALLY
          ACHIEVABLE	979

          TECHNICAL APPROACH TO BAT	979

          Option A	981
          Option B	981

            Recycle of Casting Contact Cooling Water
            Through Cooling Towers 	  981
            Recycle or Reuse of Dross Reverberatory
            Recycle of Water Used in Wet Air
            Pollution Control  	  982

          Option C	982
          Option D	982
          Option F	982

          INDUSTRY COST AND POLLUTANT REDUCTION
          BENEFITS	983

          Pollutant Reduction Benefits 	  983
          Compliance Costs 	  984

          BAT OPTION SELECTION 	  984

          WASTEWATER DISCHARGE RATES 	  985

          Battery Cracking 	  985
          Blast and Reverberatory Furnace Wet Air
          Pollution Control  	  986
          Casting Contact Cooling  	  986
                              Ixxii

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                    SECONDARY LEAD SUBCATEGORY

                  TABLE OF CONTENTS  (Continued)


Section                                                     Page

          REGULATED POLLUTANT PARAMETERS  	  986

          EFFLUENT LIMITATIONS  	  987

XI        NEW SOURCE PERFORMANCE STANDARDS  	  1003

          TECHNICAL APPROACH TO BDT	1003

          BDT OPTION SELECTION  	  1005

          REGULATED POLLUTANT PARAMETERS  	  1005

          NEW SOURCE PERFORMANCE STANDARDS  	  1006

XII       PRETREATMENT STANDARDS 	  1011

          TECHNICAL APPROACH TO PRETREATMENT  	  1011

          PRETREATMENT STANDARDS FOR  EXISTING SOURCES.  .  .  1012

          INDUSTRY COST AND POLLUTANT REDUCTION
          BENEFITS	1013

          PSES OPTION SELECTION  	  1013

          PSNS OPTION SELECTION  	  1014

          REGULATED POLLUTANT PARAMETERS  	  1015

          PRETREATMENT STANDARDS 	  1015

XIII      BEST CONVENTIONAL POLLUTANT CONTROL
          TECHNOLOGY	1027
                              Ixxiii

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                    SECONDARY LEAD SUBCATEGORY

                          LIST OF TABLES


Number                                                      Page

III-l     INITIAL OPERATING YEAR SUMMARY OF PLANTS IN
          THE SECONDARY LEAD SUBCATEGORY BY DISCHARGE
          TYPE	896

III-2     PRODUCTION RANGES FOR THE SECONDARY LEAD
          SUBCATEGORY	897

III-3     SUMMARY OF SECONDARY LEAD SUBCATEGORY PROCESSES
          AND ASSOCIATED WASTE STREAMS 	  898

V-l       WATER USE AND DISCHARGE RATES FOR BATTERY
          CRACKING OPERATIONS  	  910

V-2       SECONDARY LEAD SAMPLING DATA BATTERY
          CRACKING RAW WASTEWATER	911

V-3       WATER USE AND DISCHARGE RATES FOR BLAST
          REVERBERATORY FURNACE WET AIR POLLUTION
          CONTROL	915

V-4       SECONDARY LEAD SAMPLING DATA BLAST AND
          REVERBERATORY FURNACE SCRUBBER LIQUOR RAW
          WASTEWATER   	916

V-5       WATER USE AND DISCHARGE RATES FOR KETTLE
          WET AIR POLLUTION CONTROL	917

V-6       SECONDARY LEAD SAMPLING DATA KETTLE SCRUBBER
          LIQUOR RAW WASTEWATER	918

V-7       WATER USE AND DISCHARGE RATES FOR CASTING
          CONTACT COOLING  	  919

V-8       SECONDARY LEAD SAMPLING DATA MISCELLANEOUS
          RAW WASTEWATER	920

V-9       SECONDARY LEAD SAMPLING DATA TREATMENT PLANT
          SAMPLES - PLANT A	923

V-10      SECONDARY LEAD SAMPLING DATA TREATMENT PLANT
          SAMPLES - PLANT B	925

V-ll      SECONDARY LEAD SAMPLING DATA TREATMENT PLANT
          SAMPLES - PLANT C	926
                              Ixxiv

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SECONDARY LEAD SUBCATEGORY



LIST OF TABLES (Continued)
Number
V-12

V-13

VI-1

VIII-1
IX-1

IX-2

X-l

X-2

X-3

X-4

X-5

X-6

XI-1

XI-2

SECONDARY LEAD SAMPLING DATA TREATMENT
PLANT SAMPLES - PLANT D 	
SECONDARY LEAD SAMPLING DATA TREATMENT
PLANT SAMPLES - PLANT E 	
FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
SECONDARY LEAD RAW WASTEWATER 	
ENERGY REQUIREMENTS 	
BPT WASTEWATER DISCHARGE RATES FOR THE
SECONDARY LEAD SUBCATEGORY 	
BPT EFFLUENT LIMITATIONS FOR THE SECONDARY
LEAD SUBCATEGORY 	
CURRENT RECYCLE PRACTICES WITHIN THE
SECONDARY LEAD SUBCATEGORY 	
TREATMENT PERFORMANCE SECONDARY LEAD
SUBCATEGORY DIRECT DISCHARGERS 	
COST OF COMPLIANCE FOR THE SECONDARY LEAD
SUBCATEGORY 	
BAT WASTEWATER DISCHARGE RATES FOR THE
SECONDARY LEAD SUBCATEGORY 	
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD
SUBCATEGORY 	
BAT EFFLUENT LIMITATIONS FOR THE SECONDARY
LEAD SUBCATEGORY 	
NSPS WASTEWATER DISCHARGE RATES FOR THE
SECONDARY LEAD SUBCATEGORY 	
NSPS FOR THE SECONDARY LEAD SUBCATEGORY ....
Page

928

930

948
962

975

976

989

990

992

993

994

996

1007
1008
          Ixxv

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                    SECONDARY LEAD SUBCATEGORY



                    LIST OF TABLES (Continued)





Number                                                      Page
XII-1
XII-2
XII-3
XII-4
XII-5
XII-6
XIII-1
TREATMENT PERFORMANCE SECONDARY LEAD
SUBCATEGORY INDIRECT DISCHARGERS 	
COST OF COMPLIANCE FOR THE SECONDARY
LEAD SUBCATEGORY 	
PSES AND PSNS WASTEWATER DISCHARGE RATES
FOR THE SECONDARY LEAD SUBCATEGORY 	
PSES FOR THE SECONDARY LEAD SUBCATEGORY . . .
PSES FOR THE SECONDARY LEAD SUBCATEGORY. . . .
PSNS FOR THE SECONDARY LEAD SUBCATEGORY . . .
BCT EFFLUENT LIMITATIONS FOR THE SECONDARY
LEAD SUBCATEGORY 	
1016
1018
1019
1020
1022
1024
1029
                              Ixxvi

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SECONDARY LEAD SUBCATEGORY




     LIST OF FIGURES
Number
III-l
-L. JL J_ -*-
III-2
V-l
V-2
V-3
V-4
V-5
V-6
VIII-1
VIII-2
VIII-3
VIII-4
VIII-5
VIII-6
VIII-7
VIII-8
VIII-9
VIII-10
IX-1
X-l
X-2
X-3

SECONDARY LEAD SMELTING PROCESS 	
GEOGRAPHIC LOCATIONS OF SECONDARY LEAD
SUBCATEGORY PLANTS 	
SAMPLING SITES AT SECONDARY LEAD PLANT A ....
SAMPLING SITES AT SECONDARY LEAD PLANT B . . . .
SAMPLING SITES AT SECONDARY LEAD PLANT C . . . .
SAMPLING SITES AT SECONDARY LEAD PLANT D . . . .
SAMPLING SITES AT SECONDARY LEAD PLANT E . . . .
SAMPLING SITES AT SECONDARY LEAD PLANT F . . . .
SECONDARY LEAD COMBINATION 1, OPTION A 	
SECONDARY LEAD COMBINATION 1, OPTION C 	
SECONDARY LEAD COMBINATION 1, OPTION D 	
SECONDARY LEAD COMBINATION 1, OPTION F 	
SECONDARY LEAD COMBINATION 2Sc3, OPTION A ....
SECONDARY LEAD COMBINATION 2&3, OPTION C . . . .
SECONDARY LEAD COMBINATION 2&3, OPTION D . . .
SECONDARY LEAD COMBINATION 2&3, OPTION F . . .
HOLDING TANK COSTS 	
COOLING TOWER COSTS CASTING CONTACT COOLING . .
BPT TREATMENT SCHEME FOR THE SECONDARY
LEAD SUBCATEGORY 	
BAT TREATMENT SCHEME FOR OPTION A 	
BAT TREATMENT SCHEME FOR OPTION B 	
BAT TREATMENT SCHEME FOR OPTION C 	
Page
899
900
932
933
934
935
936
937
963
963
964
964
965
965
966
966
967
967
978
998
999
1000
         Ixxvii

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                    SECONDARY LEAD SUBCATEGORY



                         LIST OF FIGURES






Number                                                      Page



X-4       BAT TREATMENT SCHEME FOR OPTION D	1001



X-5       BAT TREATMENT SCHEME FOR OPTION F	1002
                              Ixxviii

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                   PRIMARY TUNGSTEN  SUBCATEGORY

                             SECTION  I

                      SUMMARY AND  CONCLUSIONS


Pursuant to Sections  301,  304,  306,  307,  and  501  of  the  Clean
Water Act and the provisions of the  Settlement  Agreement in
Natural Resources Defense  Council v. Train, 8 ERG 2120  (D.D.C.
1976) modified, 12 ERG  1833 (D.D.C.  1979),  EPA  has collected  and
analyzed data for plants in the primary tungsten  subcategory.
EPA has never proposed  or  promulgated  effluent  limitations or
standards for this subcategory.   This  document  and the admini-
strative record provide the technical  basis for proposing
effluent limitations  based on best practicable  technology (BPT)
and best available technology  (BAT)  for existing  direct
dischargers, pretreatment  standards  for existing  indirect
dischargers (PSES), pretreatment  standards  for  new indirect
dischargers (PSNS), and standards of performance  for new source
direct dischargers (NSPS).

The primary tungsten  subcategory  is  comprised of  eight plants.
Of the eight plants,  two discharge directly to  rivers, lakes, or
streams; three discharge to publicly owned  treatment works
(POTW); and three achieve  zero  discharge  of process  wastewater.

EPA first studied the primary tungsten subcategory to determine
whether differences in  raw materials,  final products, manufactur-
ing processes, equipment,  age and size of plants, 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 waste-
waters, including toxic pollutants.

EPA also identified several  distinct control  and  treatment
technologies (both in-plant  and end-of-pipe)  applicable  to the
primary tungsten subcategory.   The Agency analyzed both  histori-
cal and newly generated data on the  performance of these technol-
ogies, 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 imple-
menting the various options  on  the subcategory.   For each control
and treatment option that  the Agency found to be  most effective

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and technically feasible in controlling the discharge of pollu-
tants, the number of potential closures, number of employees
affected, and impact on price were estimated.  These results are
reported in a separate document entitled "The Economic Impact
Analysis of Proposed Effluent Standards and Limitations Guide-
lines and Standards for the Nonferrous Smelting and Refining
Industry."

Based on consideration of the above factors, EPA identified
various control and treatment technologies which formed the basis
for BPT and selected control and treatment appropriate for each
set of standards and limitations.  The mass limitations and
standards for BPT, BAT, NSPS, PSES, PSNS, and BCT are presented
in Section II.

After examining the various treatment technologies, the Agency
has identified BPT to represent the average of the best existing
technology.  Metals removal based on lime precipitation and
sedimentation technology is the basis for the BPT limitations.
Steam stripping was selected as the technology basis for ammonia
limitations.  To meet the BPT effluent limitations based on this
technology, the primary tungsten subcategory is not expected to
incur any costs.

For BAT, the Agency has built upon the BPT technology basis by
adding in-process control technologies which include recycle of
process water from air pollution control waste streams.  Filtra-
tion is added as an effluent polishing step to the end-of-pipe
treatment scheme.  To meet the BAT effluent limitations based on
this technology, the primary tungsten subcategory is estimated to
incur a capital cost of $0.447 million and an annual cost of
$0.193 million.

BDT, which is the technical basis of NSPS, is equivalent to BAT.
In selecting BDT, EPA recognizes that new plants have the oppor-
tunity 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 tech-
nology.

The technology basis for PSES is equivalent to BAT.  To meet the
pretreatment standards for existing sources, the primary tungsten
subcategory is estimated to incur a capital cost of $0.396
million and an annual cost of $0.329 million.  For PSNS, the
Agency selected end-of-pipe treatment and in-process flow reduc-
tion control techniques equivalent to NSPS.

The best conventional technology (BCT) replaces BAT for the con-
trol of conventional pollutants.  The technology basis of BCT is
the BPT treatment of lime precipitation and sedimentation.

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                   PRIMARY TUNGSTEN SUBCATEGORY

                            SECTION II

                         RECOMMENDATIONS
1.  EPA has divided the primary tungsten subcategory  into nine
    subdividisions for the purpose of effluent  limitations and
    standards.  These subdivisions are:

    (a)  Tungstic acid rinse water,
    (b)  Acid leach wet air pollution control,
    (c)  Alkali leach wash,
    (d)  Ion-exchange raffinate,
    (e)  Calcium tungstate precipitate wash,
    (f)  Crystallization and drying of ammonium paratungstate,
    (g)  Ammonium paratungstate conversion to oxides wet air
         pollution control,
    (h)  Reduction to tungsten wet air pollution control, and
    (i)  Reduction to tungsten water of formation.

2.  BPT is proposed based on the performance achievable by the
    application of chemical precipitation and sedimentation (lime
    and settle) technology, along with preliminary treatment
    consisting of ammonia steam stripping for selected waste
    streams.  The following BPT effluent limitations  are
    proposed:


     (a)  Tungstic Acid Rinse
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   7,140.0         6,188.0
Selenium                              58,548.0        26,180.0
Zinc                                  63,308.0        26,656.0
Ammonia (as N)                     6,330,800.0     2,789,360.0
TSS                                1,951,600.0        952,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

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     (b)  Acid Leach Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   5,655.0         4,901.0
Selenium                              46,371.0        20,735.0
Zinc                                  50,141.0        21,112.0
Ammonia (as N)                     5,014,100.0     2,209,220.0
TSS                                1,545,700.0       754,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (c)  Alkali Leach Wash
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   7,005.0         6,071.0
Selenium                              57,441.0        25,685.0
Zinc                                  62,111.0        26,152.0
Ammonia (as N)                     6,211,100.0     2,736,620.0
TSS                                1,914,700.0       934,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (d)  Ion-Exchange Raffinate
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   7,680.0         6,656.0
Selenium                              62,976.0        28,160.0
Zinc                                  68,096.0        28,672.0
Ammonia (as N)                     6,809,600.0     3,000,320.0
TSS                                2,099,200.0     1,024,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

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      (e)  Calcium Tungstate Precipitate Wash
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   5,580.0         4,836.0
Selenium                              45,756.0        20,460.0
Zinc                                  49,476.0        20,832.0
Ammonia (as N)                     4,947,600.0     2,179,920.0
TSS                                1,525,200.0       744,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

      (f)  Crystallization and Drying of Ammonium Paratungstate
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00
TSS                                        0               0
pH                                Within the range of 7.5 to 10.0
                                           at all times

      (g)  Ammonium Paratungstate Conversion to Oxides Wet Air
          Pollution Control
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide (W03) produced
English Units - Ibs/billion Ibs of "blue" oxide (W03) produced

Lead                                   3,135.0         2,717.0
Selenium                              25,707.0        11,495.0
Zinc                                  27,797.0        11,704.0
Ammonia (as N)                     2,779,700.0     1,224,740.0
TSS                                  856,900.0       418,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

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     (h)  Reduction to Tungsten Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                  10,980.0         9,516.0
Selenium                              90,036.0        40,260.0
Zinc                                  97,356.0        40,992.0
Ammonia (as N)                     9,735,600.0     4,289,520.0
TSS                                3,001,200.0     1,464,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (i)  Reduction to Tungsten Water of Formation
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   2,910.0         2,522.0
Selenium                              23,862.0        10,670.0
Zinc                                  25,802.0        10,864.0
Ammonia (as N)                     2,580,200.0     1,136,840.0
TSS                                  795,400.0       388,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

3.  BAT is proposed based on the performance achievable by the
    application of chemical precipitation, sedimentation, and
    multimedia filtration (lime, settle, and filter) technology
    and in-process flow reduction methods, along with preliminary
    treatment consisting of ammonia steam stripping for selected
    waste streams.  The following BAT effluent limitations are
    proposed:

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      (a)  Tungstic Acid Rinse
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0        17,612.0
Zinc                                  48,552.0        19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0

      (b)  Acid Leach Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,091.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0

      (c)  Alkali Leach Wash
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0

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     (d)  Ion-Exchange Raffinate
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0

     (e)  Calcium Tungstate Precipitate Wash
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0

     (f)  Crystallization and Drying of Ammonium Paratungstate
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00

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     (g)  Ammonium Paratungstate Conversion to Oxides Wet Air
          Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide  (VKH) produced
English Units - Ibs/billion Ibs of "blue" oxide  (W03) produced

Lead                                   2,090.0         1,881.0
Selenium                              17,138.0         7,733.0
Zinc                                  21,318.0         8,778.0
Ammonia (as N)                     2,779,700.0     1,224,740.0

     (h)  Reduction to Tungsten Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0         3,478.0
Zinc                                   9,588.0         3,948.0
Ammonia (as N)                     1,250,200.0       550,840.0

     (i)  Reduction to Tungsten Water of Formation
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0         1,746.0
Selenium                              15,908.0         7,178.0
Zinc                                  19,788.0         8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0

-------
4.  NSPS are proposed based on the performance achievable by the
    application of chemical precipitation, sedimentation, and
    multimedia filtration (lime, settle, and filter) technology,
    and in-process flow reduction control methods, along with
    preliminary treatment consisting of ammonia steam stripping
    for selected waste streams.  The following effluent standards
    are proposed for new sources:


     (a)  Tungstic Acid Rinse NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0        17,612.0
Zinc                                  48,552.0        19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0
TSS                                  714,000.0       571,200.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


     (b)  Acid Leach Wet Air Pollution Control NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,091.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0
TSS                                   56,550.0        45,240.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               10

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      (c)  Alkali Leach Wash NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0
TSS                                  700,500.0       560,400.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

      (d)  Ion-Exchange Raffinate NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0
TSS                                  768,000.0       614,400.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

      (e)  Calcium Tungstate Precipitate Wash NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0
TSS                                  558,000.0       446,400.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               11

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     (f)  Crystallization and Drying of Ammonium Paratungstate
          NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00
TSS                                        0               0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (g)  Ammonium Paratungstate Conversion to Oxides Wet Air
          Pollution Control NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

       Metric Units - mg/kkg of "blue" oxide (WCH) produced
English Units - Ibs/billion Ibs of "blue" oxide (W03> produced

Lead                                   2,090.0         1,881.0
Selenium                              17,138.0         7,733.0
Zinc                                  21,318.0         8,778.0
Ammonia (as N)                     2,779,700.0     1,224,740.0
TSS                                  313,500.0       250,800.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (h)  Reduction to Tungsten Wet Air Pollution Control NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0         3,478.0
Zinc                                   9,588.0         3,948.0
Ammonia (as N)                     1,250,200.0       550,840.0
TSS                                  141,000.0       112,800.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                                12

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      (i)  Reduction to Tungsten Water of Formation NSPS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0         1,746.0
Selenium                              15,908.0         7,178.0
Zinc                                  19,788.0         8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0
TSS                                  291,000.0       232,800.0
pH                                Within the range of  7.5 to  10.0
                                           at all times

5.  PSES are proposed based on the performance achievable by  the
    application of chemical precipitation, sedimentation, and
    multimedia filtration  (lime, settle, and filter) technology,
    and in-process flow reduction control methods, along with
    preliminary treatment consisting of ammonia steam  stripping
    for selected waste streams.  The following pretreatment
    standards are proposed for existing sources:


    (a)  Tungstic Acid Rinse PSES

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0         17,612.0
Zinc                                  48,552.0         19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0

      (b)  Acid Leach Wet Air Pollution Control PSES

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,901.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0
                               13

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      (c)  Alkali Leach Wash PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0

      (d)  Ion-Exchange Raffinate PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0

      (e)  Calcium Tungstate Precipitate Wash PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0

      (f)  Crystallization and Drying of Ammonium Paratungstate
          PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00
                               14

-------
     (g)  Ammonium Paratungstate Conversion to Oxides Wet Air
          Pollution Control PSES

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide  (WCK) produced
English Units - Ibs/billion Ibs of "blue" oxide  (W03> produced

Lead                                   2,090.0          1,881.0
Selenium                              17,138.0          7,733.0
Zinc                                  21,318.0          8,778.0
Ammonia (as N)                     2,779,700.0     1,224,740.0

     (h)  Reduction to Tungsten Wet Air Pollution Control PSES

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    A.ny One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0          3,478.0
Zinc                                   9,588.0          3,948.0
Ammonia (as N)                     1,250,200.0       112,800.0

     (i)  Reduction to Tungsten Water of Formation PSES

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0          1,746.0
Selenium                              15,908.0          7,178.0
Zinc                                  19,788.0          8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0


6.  PSNS are proposed based on the performance achievable by the
    application of chemical precipitation, sedimentation, and
    multimedia filtration (lime, settle, and filter) technology,
    and in-process flow reduction control methods, along with
    preliminary treatment consisting of ammonia steam stripping
    for selected waste streams.  The following pretreatment
    standard are proposed for new sources:
                                15

-------
     (a)  Tungstic Acid Rinse PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0        17,612.0
Zinc                                  48,552.0        19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0

     (b)  Acid Leach Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,091.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0

     (c)  Alkali Leach Wash PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0

     (d)  Ion-Exchange Raffinate PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0
                               16

-------
      (e)  Calcium Tungstate Precipitate Wash PSNS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0

      (f)  Crystallization and Drying of Ammonium Paratungstate
          PSNS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00

      (g)  Ammonium Paratungstate Conversion to Oxides Wet Air
          Pollution Control PSNS

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property	Any One Day	Monthly Average

       Metric Units - mg/kkg of "blue" oxide (WO^) produced
English Units - Ibs/billion Ibs of "blue" oxide (W03) produced

Lead                                   2,090.0         1,881.0
Selenium                              17,138.0         7,733.0
Zinc                                  21,318.0         8,778.0
Ammonia (as N)                     2,779,700.0     1,224,740.0
                               17

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     (h)  Reduction to Tungsten Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0         3,478.0
Zinc                                   9,588.0         3,948.0
Ammonia (as N)                     1,250,200.0       550,840.0

     (i)  Reduction to Tungsten Water of Formation PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0         1,746.0
Selenium                              15,908.0         7,178.0
Zinc                                  19,788.0         8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0


7.  BCT is proposed based on the performance achievable by the
    application of chemical precipitation and sedimentation (lime
    and settle) technology, along with preliminary treatment
    consisting of ammonia steam stripping for selected waste
    streams.  The following BCT effluent limitations are proposed
    for existing direct dischargers:

     (a)  Tungstic Acid Rinse
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

TSS                                1,951,600.0       952,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times
                               18

-------
      (b)  Acid Leach Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units  - Ibs/billion Ibs of tungstic acid produced

TSS                                1,545,700.0       754,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times

      (c)  Alkali Leach Wash
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

TSS                                1,914,700.0       934,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times

      (d)  Ion-Exchange Raffinate
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

TSS                                2,099,200.0     1,024,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times

      (e)  Calcium Tungstate Precipitate Wash
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

TSS                                1,525,200.0       744,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times
                               19

-------
     (f)  Crystallization and Drying of Ammonium Paratungstate
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

TSS                                        0               0
pH                               Within the range of 7.. 5 to 10.0
                                          at all times

     (g)  Ammonium Paratungstate Conversion to Oxides
          Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide (WO;*) produced
English Units - Ibs/billion Ibs of "blue" oxide (WOs) produced

TSS                                  856,900.0       418,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times

     (h)  Reduction to Tungsten Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

TSS                                3,001,200.0     1,464,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times

     (i)  Reduction to Tungsten Water of Formation
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

TSS                                  795,400.0       388,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times
                               20

-------
                   PRIMARY TUNGSTEN SUBCATEGORY

                           SECTION III

                         INDUSTRY PROFILE
This section of the primary tungsten supplement describes the raw
materials and processes used in producing primary tungsten and
presents a profile of the primary tungsten plants identified in
this study.  For discussion of the purpose, authority, and meth-
odology for this study, and a general description of the nonfer-
rous metals manufacturing category, refer to Section III of the
General Development Document.

In the early 1780's, tungstic acid was first isolated from
scheelite and wolframite and, shortly thereafter, tungsten was
obtained by both carbon and hydrogen reduction of wolframite
[(Fe,Mn)W04].  Hydrogen reduction is still a key step in the
production of tungsten powder from which other finished products
are derived.  From the mid-nineteenth century through the first
third of this century, tungsten was used chiefly as an alloying
agent in steel.  During the last 30 years, however, tungsten uses
have increased to include production of carbides and alloys.  The
1974 production use breakdown was 68 percent carbide, 15 percent
pure metal, and 15 percent alloy.  Another two percent was used
to manufacture various metal compounds (2).

DESCRIPTION OF PRIMARY TUNGSTEN PRODUCTION

The production of tungsten metal can be divided into three dis-
tinct stages - leaching of ore concentrates, purification to
ammonium paratungstate (APT), and the reduction of APT to metal.
The actual processes used in each stage vary with the type and
purity of the raw material used.  The primary tungsten production
process is presented schematically in Figure III-l and described
below.

RAW MATERIALS

The principal domestic ores used to produce ammonium paratung-
state and tungsten metal powder are ferberite (FeW04) and
scheelite (CaW04).  Both of these ores are mined principally in
California and Colorado.

LEACHING OF ORE CONCENTRATES

Scheelite ores of high quality (i.e., low concentrations of
molybdenum and complexing elements such as phosphorus, arsenic,
and silicon) are usually leached with hot hydrocholoric acid
(HC1).  An insoluble tungstic acid intermediate (H2W04) is
                               21

-------
formed.  The acidic tungstic acid rinse water and HC1  fume  con-
trol scrubber water are wastewater sources.

Lower quality scheelite ores and some wolframite ores,
(Fe,Mn)W04, may be digested using a soda-autoclave leach
process that uses high temperatures and soda ash in quantities
greater than stoichiometric amounts to produce a sodium tungstate
intermediate (Na2W04).  If molybdenum impurities are present,
the ore concentrates are reacted with sodium hydrosulfide  (NaHS)
to precipitate molybdenum trisulfide (MoS3).

Higher quality wolframite ores are processed using an  alkaline
leaching method.  This method, which also produces a sodium
tungstate intermediate, involves digestion with a strong caustic
solution, usually sodium hydroxide (NaOH).  The sodium tungstate
solution is filtered to remove soluble impurities.  Sodium
tungstate is crystallized from the filtrate, and the remaining
caustic solution is recycled or wasted.

PURIFICATION TO AMMONIUM PARATUNGSTATE

Purification of the tungstic acid intermediate (H2W04) is
more direct than that for sodium tungstate.  After filtering and
washing to remove soluble calcium chloride  (CaCl2)> the tung-
stic acid is dissolved in ammonium hydroxide (NH40H).  APT  is
obtained from the crystallization of the resulting ammonia  tung-
state (AT) solution.  Wet air pollution control wastewater
associated with the drying of the APT crystals generally has
treatable concentrations of ammonia.

The purification of the sodium tungstate intermediate  can follow
two basic routes.  The classical approach is to precipitate cal-
cium tungstate (synthetic scheelite) from the sodium tungstate
solution by adding calcium chloride; a waste supernatant solution
which is high in sodium chloride results.  The calcium tungstate
(CaW04) can then be digested with hydrochloric acid (HC1).
From this point, the purification is the same as described  above
for the purification of tungstic acid intermediate - dissolution
with ammonia followed by crystallization.

The second approach for purifying the sodium tungstate interme-
diate is a newer extraction method.  The sodium tungstate solu-
tion is converted to ammonia tungstate solution in a liquid
ion-exchange system.  After equilibration with ammonium hydrox-
ide, APT is recovered by filtration and crystallization.  The
raffinate from the ion exchange process is a wastewater source.

REDUCTION TO METAL

Dried APT is calcined in indirectly heated rotary furnaces  to
drive off ammonia and produce tungsten oxides (WOX).   The type
                                22

-------
of oxide produced is a  function  of  furnace  atmosphere  (N2,
H2, etc.) and temperature.  The  calciners are  often  equipped
with wet scrubbers whose wastewaters  contain treatable  concen-
trations of ammonia.

Tungsten oxides are reduced to metal  powder in high  temperature
(>700°C) furnaces.  The reducing agent  is typically  hydrogen
(H2).  Powders of various particle  sizes are produced by  vary-
ing furnace reaction time, temperature  gradient, hydrogen flow,
and layer thickness.  Water of formation and scrubber wastewater
may be associated with  this step.

PROCESS WASTEWATER SOURCES

Although a variety of processes  are involved in primary tungsten
production, the process wastewater  sources  can be  subdivided as
follows:

     1.  Tungstic acid  rinses,
     2.  Acid leaching wet air pollution control,
     3.  Alkali leach wash,
     4.  Ion-exchange raffinate,
     5.  Calcium tungstate precipitate  wash,
     6.  Crystallization and drying of  ammonium paratungstate,
     7.  Ammonium paratungstate  conversion  to  oxides wet  air
         pollution control,
     8.  Reduction to tungsten wet  air  pollution control,  and
     9.  Reduction to tungsten water  of formation.

OTHER WASTEWATER SOURCES

There are other waste streams associated with  the  primary
tungsten subcategory.  These waste  streams  include, but are  not
limited to:

     1.  Stormwater runoff, and
     2.  Maintenance and cleanup water.

These waste streams are not considered  as a part of  this  rulemak-
ing.  EPA believes that the flows and pollutant loadings  associ-
ated with these waste streams are insignificant relative  to  the
waste streams selected, or are best handled by the appropriate
permit authority on a case-by-case  basis under authority  of
Section 403 of the CWA.

AGE, PRODUCTION, AND PROCESS PROFILE

Figure III-2 shows the location  of  the  eight primary tungsten
plants operating in the United States.  Six of the eight  plants
are located in states around the Great  Lakes while one  is  located
in California and the other in Alabama.  All but the one  in
California are in net precipitation areas.
                                23

-------
Table III-l shows the relative age and discharge status* of the
tungsten plants and illustrates that many plants were built
around the time of World War II.  The average plant age is
between 25 and 35 years.  From Table III-2, it can be seen that
four plants produce over 1,000 tons/yr of metal, while three
others produce less than 250 tons/yr.  Mean production is about
1,000 tons/yr.

Table III-3 provides a summary of the number of plants generating
wastewater for the waste streams associated with various proces-
ses and the number of plants with the process.
                               24

-------
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-------
                                  Table III-2

             PRODUCTION RANGES FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                      Tungsten Production Range for 1976

                      0-250      251-1,000     1,001-5,000     Total Number
   Type of Plant     tons/yr      tons/yr        tons/yr        of Plants

   Direct               Oil                2


   Indirect             201                3


   Zero                 102*               3_


                                                                     8
*0ne plant here produces APT, not tungsten metal.
                                     26

-------
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   Wolframite Ore Concentrates
          (Fe.Mn)WO.
         Sch«tlit« Ore Concentrates
                 C.HO,.
                                                        HC1
Liquid Ion-
 Exchange
 Synthetic
 Scheelite
Precipitation
                                 CaWO.
                                          HC1 Leach
                      W Metal
                  Figure  III-l

 PRIMARY TUNGSTEN  PRODUCTION PROCESS
                        28

-------
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                   PRIMARY TUNGSTEN  SUBCATEGORY

                            SECTION  IV

                        SUBCATEGORIZATION
As discussed in Section IV of the General Development  Document,
the nonferrous metals manufacturing category has been  subcate-
gorized to take into account pertinent  industry characteristics,
manufacturing process variations, and a number of other  factors
which affect the ability of the  facilities to achieve  effluent
limitations.  This section summarizes the factors considered
during the designation of the primary tungsten subcategory  and
its related subdivisions.  Production normalizing parameters  for
each subdivision will also be discussed.

FACTORS CONSIDERED IN SUBCATEGORIZATION

The following factors were evaluated for use in subcategorizing
the nonferrous metals manufacturing category:

      1.  Metal products, co-products,  and by-products;
      2.  Raw materials;
      3.  Manufacturing processes;
      4.  Product form;
      5.  Plant location;
      6.  Plant age;
      7.  Plant size;
      8.  Air pollution control  methods;
      9.  Meteorological conditions;
     10.  Treatment costs;
     11.  Nonwater quality aspects;
     12.  Number of employees;
     13.  Total energy requirements; and
     14.  Unique plant characteristics.

Evaluation of all factors that could warrant subcategorization
resulted in the designation of the primary tungsten subcategory.
Three factors were particularly  important in establishing these
classifications:  the type of metal produced, the nature of the
raw material used, and the manufacturing processes involved.

In Section IV of the General Development Document, each of these
factors is described, and the rationale for selecting  metal
product, manufacturing process,  and raw materials as the princi-
pal factors used for subcategorization  is discussed.   On this
basis, the nonferrous metals manufacturing category (phase I) was
divided into 12 subcategories, one of them being primary
tungsten.
                                31

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FACTORS CONSIDERED IN SUBDIVIDING THE PRIMARY TUNGSTEN
SUBCATEGORY

The factors listed previously were each evaluated when consider-
ing subdivision of the primary tungsten subcategory.  In the
discussion that follows, the factors will be described as they
pertain to this particular subcategory.

The rationale for considering further subdivision of the primary
tungsten subcategory is based primarily on differences in the
production processes and raw materials used.  Within this sub-
category, 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 tungsten 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 subdivisions:

     1.  Tungstic acid rinse,
     2.  Acid leach wet air pollution control,
     3.  Alkali leach wash,
     4.  Ion-exchange raffinate,
     5.  Calcium tungstate precipitate wash,
     6.  Crystallization and drying of ammonium paraturigstate,
     7.  Ammonium paratungstate conversion to oxides wet air
         pollution control,
     8.  Reduction to tungsten wet air pollution control, and
     9.  Reduction to tungsten water of formation.

These subdivisions follow directly from differences within the
three distinct production stages of primary tungsten; leaching of
ore concentrates, purification to APT, and reduction to metal.
Generally, a specific plant will either process ore to APT,
reduce APT to metal, or utilize all three stages of production
and process ore concentrate all the way to tungsten metal.

Leaching of ore concentrates gives rise to the first three sub-
divisions.  The acidic rinses of insoluble tungstic acid are a
major source of wastewater directly attributable to leaching with
HCl.  Wastewaters from scrubbers which are used to control HC1
fumes may also be significant sources of pollutants.  If the
alkali leaching process is used, the decantation of sodium
tungstate may produce a waste stream unless it is recycled in
some way.
                               32

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Differences in methods of purifying  the  two  intermediates--
sodium tungstate and tungstic acid--into APT resulted  in  the
fourth, fifth, and sixth subdivisions.   If sodium  tungstate is
the intermediate from leaching, calcium  tungstate  (synthetic
scheelite) may be precipitated by adding calcium chloride,
CaCl2'  The filtrate from this process is a  wastewater which
contains sodium chloride, NaCl.  If  the  liquid  ion-exchange route
is chosen to convert sodium tungstate to APT, a raffinate  stream
is a potential discharge.

Plants which produce APT crystallize it  from solution.  Conse-
quently the spent mother liquor may  create another discharge
situation.  Some plants use a combination of recycle or evapora-
tion if it is feasible for this process.  An ammonia recovery
system is commonly economically viable for this waste  stream.

The final production stage, reduction of APT to metal, also has
three subdivisions associated with it.   The  decomposition  of APT
to tungsten oxides drives off ammonia which  is  usually contained
with some type of wet scrubbing system.  The reduction of  oxides
to tungsten metal in reduction furnaces  will also  require  a wet
scrubber to clean the reduction furnace  offgases.   The reduction
of WC>3 to tungsten metal in a hydrogen atmosphere  will produce
a "water of formation."  This water may  pass in a  vapor phase
through the scrubber system or may be condensed separately;
consequently, a separate subdivision has been included to  account
for this potential discharge.

OTHER FACTORS

The other factors considered in this evaluation either support
the establishment of the nine subdivisions or were shown  to be
inappropriate bases for subdivision.  Air pollution control
methods, treatment costs, and total energy requirements are
functions of the selected subcategorization  factors--metal
product, raw materials, and production processes.   Therefore,
they are not independent factors and do  not  affect the subcate-
gorization which has been applied.  As discussed in Section IV of
the General Development Document, 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 metal plants.

PRODUCTION NORMALIZING PARAMETERS

As discussed previously, the effluent limitations  and  standards
developed in this document establish mass limitations  on  the dis-
charge of specific pollutant parameters.  To allow these  regula-
tions to be applied to plants with various production  capacities,
                               33

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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 actual mass of tungsten product or  inter-
mediate produced will be used as the PNP.  Thus, the PNPs for the
nine subdivisions are as follows:
         Subdivision

1.  Tungstic acid rinse
2.  Acid leach wet air pollution
      control
3.  Alkali wash leach

4.  Ion-exchange raffinate

5.  Calcium tungstate precipitate
      wash
6.  Crystallization and drying
      of ammonium paratungstate
7.  Ammonium paratungstate con-
      version to oxides wet air
      pollution control
8.  Reduction to tungsten wet
      air pollution control
9.  Reduction to tungsten water
      of formation
        PNP

kkg of tungstic acid produced
kkg of tungstic acid produced

kkg of sodium tungstate pro-
  duced
kkg of ammonium tungstate
  produced
kkg of calcium tungstate
  produced
kkg of ammonium paratungstate
  produced
kkg of "blue" oxide (W03>
  produced

kkg of tungsten produced

kkg of tungsten produced
Other PNPs were considered.  The use of production capacity
instead of actual production was eliminated from consideration
because the mass of the pollutant produced is more a function of
true production than of installed capacity.  The use of some com-
mon intermediate (i.e., ammonium paratungstate or tungsten metal)
as a basis for PNPs for all processes was rejected since not all
plants follow the same production path to get to the specific
end-product.  Additionally, some plants divert part of their
intermediate products (e.g., sodium tungstate and tungsten acid)
and sell them as by-products instead of processing all input raw
materials to one final product.  If an "end-product" were chosen
as the PNP, plants that had these upstream diversions would be
allowed to discharge more per mass of product than their
competitors who did not.
                               34

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                   PRIMARY TUNGSTEN  SUBCATEGORY

                            SECTION  V

             WATER USE AND WASTEWATER  CHARACTERISTICS
This section describes the characteristics  of  the wastewaters
associated with the primary  tungsten  subcategory.  Water  use and
discharge rates are explained and  then  summarized in  tables at
the end of this section.  Data used to  characterize the waste-
waters are presented.  Finally, the specific source,  water use
and discharge flows, and wastewater characteristics for each
separate wastewater source are discussed.

Section V of the General Development  Document  contains a  detailed
description of the data sources and methods of analysis used to
characterize wastewater from the nonferrous metals manufacturing
category.  To summarize this information briefly, 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 quantify the pollutant discharge from primary tung-
sten plants, a field sampling program was conducted.  A complete
list of the pollutants considered  and a summary of the techniques
used in sampling and laboratory analyses are included in  Section
V of the General Development Document.  Wastewater samples were
collected in two phases:  screening and verification.  The first
phase, screen sampling, was  to identify which  toxic pollutants
were present in the wastewaters from  production of the various
metals.  Screening samples were analyzed for 128 of the 129 toxic
pollutants and other pollutants deemed  appropriate.   (Because the
analytical standard for TCDD was judged to be  too hazardous to be
made generally available, samples  were  never analyzed for this
pollutant.  There is no reason to  expect that  TCDD would  be
present in nonferrous metals manufacturing wastewater.)   A total
of four plants were selected for sampling in the primary  tungsten
subcategory; one for screening, three for verification.   In
general, the samples were analyzed for  three classes  of pollu-
tants:  toxic organic pollutants,  toxic metal  pollutants, and
criteria pollutants (which includes both conventional and
nonconventional pollu- tants).

As described in Section IV of this supplement, the primary
tungsten subcategory has been split into nine  subdivisions or
wastewater sources, so that  the proposed regulation contains mass
discharge limitations and standards for nine unit processes
discharging process wastewater.  Differences in the wastewater
characteristics associated with these subdivisions are to be
expected.   For this reason, wastewater  streams corresponding to
                               35

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each subdivision are addressed separately in the discussions  that
follow.  These wastewater sources are:

     1.  Tungstic acid rinse water,
     2.  Acid leach wet air pollution control,
     3.  Alkali leach wash,
     4.  Ion-exchange raffinate,
     5.  Calcium tungstate precipitate wash,
     6.  Crystallization and drying of ammonium paratungstate,
     7.  Ammonium paratungstate conversion to oxides
         wet air pollution control,
     8.  Reduction to tungsten wet air pollution control, and
     9.  Reduction to tungsten water of formation.

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 tungsten product and is therefore based on the  sum of
recycle and make-up 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 treat-
ment, disposal, or discharge per mass of tungsten produced.
Differences between the water use and wastewater flows  associated
with a given stream result from recycle, evaporation, and carry-
over 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, acid
leaching scrubber water flow is related to the production of  the
tungstic acid intermediate.  As such, the discharge rate is
expressed in liters of scrubber water per metric ton of tungstic
acid produced (gallons of scrubber water per ton of tungstic
acid).

The production normalized discharge flows were compiled and sta-
tistically analyzed by stream type.  These production normalized
water use and discharge flows are presented by subdivision in
Tables V-l through V-9 at the end of this section.  Where appro-
priate, 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 by subdivision.  A
similar analysis of factors affecting the wastewater flows is
presented in Sections X, XI, and XII where representative BAT,
BPT, 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.
                                36

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WASTEWATER CHARACTERISTICS DATA

Data used to characterize the various wastewaters  associated with
primary tungsten production come  from two sources--data  collec-
tion portfolios and analytical data  from field  sampling  trips.

DATA COLLECTION PORTFOLIOS

In the data collection portfolios, the  tungsten plants that dis-
charge wastewater were asked to specify the presence or  absence
of toxic pollutants in their wastewater.  In all cases,  the
plants indicated that the toxic organic pollutants were  believed
to be absent.  However, nearly all of the plants stated  that they
either knew the metals to be present or they believed the metals
to be absent.  The responses for  the metals are summarized
below:*

               Known       Believed     Believed     Known
Pollutant     Present      Present       Absent     Absent

Antimony         1141
Arsenic          3031
Asbestos         0061
Beryllium        0061
Cadmium          2041
Chromium         3121
Copper           4120
Cyanide          1051
Lead             3031
Mercury          2131
Nickel           1231
Selenium         0061
Silver           3130
Thallium         0070
Zinc             4120

FIELD SAMPLING DATA

In order to quantify the concentrations of pollutants present in
wastewater from primary tungsten plants, wastewater samples were
collected at four plants, which represents half of the primary
tungsten plants in the United States.  Diagrams indicating the
sampling sites and contributing production processes are shown in
Figures V-l through V-4 (at the end of this section).
*Two plants which produce tungsten metal have been omitted due
 to lack of data.
                                37

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Raw wastewater data are summarized in Tables V-10 through V-15
(at the end of this section).  Analytical results for  tungstic
acid rinse water, ion-exchange raffinate, and oxides reduction
furnace scrubber water are given in Tables V-10, V-ll,  and V-12,
respectively.  Table V-13 presents data on tungstic acid rinse
water after lime and settle treatment.  Analytical results at
various points in the treatment scheme of plant C are  summarized
in Table V-15.  Note that the stream numbers listed in  the tables
correspond to those given in individual plant sampling  site
diagrams, Figures V-l through V-5.  Where no data is listed  for a
specific day of sampling, the wastewater samples for the stream
were not collectd.  If the analyses did not detect a pollutant in
a wastestream, the pollutant was omitted from the table.

The field sampling data for raw wastewater and source  water  indi-
cate that the concentrations of bis(2-ethylhexyl) phthalate,
chloroform, di-n-octyl phthalate, and zinc in the source water
were, in some cases, equal to or greater than their concentra-
tions in the raw wastewater.  This may imply that the  presence of
these materials in the raw wastewater is the result of  source
water composition rather than the processes used.

The data tables include some samples measured at concentrations
considered not quantifiable.  The base-neutral extractable,  acid
extractable, and volatile organics generally are considered  not
quantifiable at concentrations equal to or less than 0.010 tog/1.
Below this concentration, organic analytical results are not
quantitatively accurate; however, the analyses are useful to
indicate the presence of a particular pollutant.  The  pesticide
fraction is considered not quantifiable at concentrations equal
to or less than 0.005 mg/1.  Nonquantifiable results are
designated in the tables with an asterisk (double asterisk for
pesticides).

These detection limits shown on the data tables are not the  same
in all cases as the published detection limits for these pollu-
tants by the same analytical methods.  The detection limits  used
were reported with the analytical data and hence are the appro-
priate 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  calibra-
tion, variation in stock solutions, and variation in operators.

The statistical analysis of data includes some samples  measured
at concentrations considered not quantifiable.  Data reported as
an asterisk are considered as detected but below quantifiable
concentrations, and a value of zero is used for averaging.   Toxic
organic, nonconventional, and conventional pollutant data
reported with a "less than" sign are considered as detected, but
not further quantifiable.  A value of zero is also used for
                                38

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averaging.  If a pollutant is reported as not detected,  it  is
excluded in calculating the average.  Finally,  toxic metal  values
reported as less than a certain value were considered  as not
detected, and consequently were not used in the calculation of
the average.  For example, three  samples reported  as ND, *, and
0.021 mg/1 have an average value  of 0.010 mg/1.

Appropriate tubing or background  blank and source  water  concen-
trations are presented with the summaries of the sampling data.
The method by which each sample was collected is indicated  by
number, as follows:

     1     one-time grab
     2     24-hour manual composite
     3     24-hour automatic composite
     4     48-hour manual composite
     5     48-hour automatic composite
     6     72-hour manual composite
     7     72-hour automatic composite

WASTEWATER CHARACTERISTICS AND FLOWS BY SUBDIVISION

Since primary tungsten production involves nine principal sources
of wastewater and each has potentially different 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.

TUNGSTIC ACID RINSE WATER

Both plants that leach scheelite  ores or calcium tungstate
(synthetic scheelite) with hydrochloric acid to produce  tungstic
acid (H2W04) also use water to rinse the insoluble H2W04.
The spent rinse water is discharged.  The production normalized
water use and discharge rates for tungsten acid rinses are  given
in Table V-l in liters per metric ton of tungstic  acid produced.

Table V-10 summarizes the field sampling data on spent tungsten
acid rinse water from two plants.  From this data, it  can be seen
that tungsten acid rinses can be  characterized by  acidic pH;
treatable concentrations of many  metals including  lead and  zinc;
and treatable concentrations of suspended solids.

ACID LEACH WET AIR POLLUTION CONTROL

Plants that acid leach use wet scrubbing systems for the control
of HCl fumes.  One plant recycled this water and the other  dis-
charged all of it.  Table V-2 presents the production  normalized
water use and discharge flows for acid leach scrubber  water in
liters per metric ton of tungstic acid produced.
                               39

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The Agency did not specifically sample this wastestream, but  the
stream's major characteristics should be very similar to the  raw
wastewater data from tungstic acid rinse water, Table V-10.   That
is, the scrubber water is expected to be acidic (pH of approxi-
mately 2) .

ALKALI LEACH WASH

Four plants reported using water for an alkali leaching step  in
which wolframite type ores, (Fe,Mn)W04, are digested in a
caustic environment to produce sodium tungstate, Na£W04.
Na£W04 is filtered from the digestion-wash liquor and the
filtrate may be evaporated, recycled, or discharged.  Table V-3
presents the production normalized water use and discharge flows
for alkali leach wash water in liters per metric ton of sodium
tungstate produced.

Although this waste stream was not sampled, it is assumed that
many of the impurities that were leached away in the acid leach-
ing process will also be present in the alkali leach wash since
both start from ore concentrates.  Consequently, treatable con-
centrations of metals and suspended solids are expected.  Waste-
water characteristics for acid leaching are shown in Table V-10.

ION-EXCHANGE RAFFINATE

Two plants use a liquid ion-exchange method for producing
ammonium tungstate (AT) from sodium tungstate.  A raffinate
stream will be discharged.  Table V-4 presents the production
normalized water use and discharge flows for this waste stream.
These flows are given in liters per metric ton of AT produced.
Differences between the normalized flows can be attributed to
slight differences in the processes themselves.

Table V-ll presents field sampling data for an ion-exchange
raffinate stream at one of the plants.  This stream has measura-
ble concentrations of organics such as acenaphthene, naphthalene,
acenaphthylene and fluorene, since an organic resin may be used
in the ion-exchange process.  The sampling data also indicate
that the stream is acidic (pH of approximately 2.5) and contains
metals, suspended solids, and ammonia.

CALCIUM TUNGSTATE PRECIPITATION WASH

Four plants report a flow associated with calcium tungstate
(synthetic scheelite) precipitation.  In this intermediate step,
sodium tungstate is converted to calcium tungstate by mixing  with
a calcium chloride solution.  No plants reported recycling this
wastewater.  The production normalized water use and discharge
flows are reported in Table V-5 as liters per metric ton of
calcium tungstate produced.
                               40

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The Agency did not collect any raw wastewater  samples  from  this
operation during the field sampling program.   It  is expected  that
the waste filtrate will contain the same metals resulting from
ore concentrate impurities which were found in other primary
tungsten process waste streams.  The sampling  data  for  tungstic
acid rinse water, Table V-10, is assumed to be fairly representa-
tive of the metals and conventional pollutants found in the
calcium tungstate wash water.  Calcium tungstate  wash water is
not expected to be as acidic, however.

CRYSTALLIZATION AND DRYING OF AMMONIUM PARATUNGSTATE

All four plants which produce ammonium paratungstate (APT)  report
that wastewater is associated with the crystallization  and  drying
step.  APT crystals are precipitated and filtered from  an aqueous
mother liquor.  This mother liquor is usually  recycled  or evapo-
rated after ammonia recovery.  The drying of crystals may require
a wet scrubber to control the ammonia which is driven off in  the
drying process.  This scrubber water is usually stripped of
ammonia and then recycled or discharged.  Table V-6 presents  the
production normalized water use and discharge  flows for this
subdivision in liters per metric ton of APT produced.

The most significant pollutant characteristic  associated with
this stream is the concentration of ammonia.  Although  the Agency
did not specifically sample APT drying scrubber water or mother
liquor, the metal constituents present should  be  similar to those
given in the sampling data in Table V-12.  This table gives data
for scrubber water from a reduction furnace.   The major differ-
ence between this data and APT drying scrubber water would be the
concentrations of ammonia associated with APT drying.

AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES WET AIR POLLUTION
CONTROL

Six plants report using water in converting APT to tungsten
oxides (WOX).   In all cases a wet scrubbing system is used  to
control the ammonia which is driven off when APT  is calcined  to
oxides in rotary furnaces.  Two of the six plants evaporate or
recycle this scrubber water.  To calculate production normaliza-
tion factors,  all oxides were assumed to be the common  "blue"
oxide, W03.  Thus, production normalized water use and  dis-
charge flows are presented as liters of water per metric ton  of
"blue" oxide (W03) in Table V-7.

Table V-12 summarizes the field sampling data  for the pollutants
detected in a stream which should be representative of  APT reduc-
tion scrubber  water with regard to toxic pollutants.  Addition-
ally, treatable concentrations of ammonia and  suspended solids,
and an alkaline pH are expected.  The ammonia will be present in
                               41

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the wastewater from this scrubber because it evolves as  the APT
is converted to an oxide.  The presence of ammonia causes the pH
to be elevated.

REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL

Five plants that reduce tungsten oxides to tungsten metal report
using water in a wet scrubbing system.  The scrubbing system is
used to control particulates from the furnace operation, although
some plants use a hydrogen recovery system, too.  Table  V-8 gives
production normalized water use and discharge flows in liters per
metric ton of tungsten metal for the five plants which use water.
As shown in Table V-8, two plants use a total recycle of this
stream.

Particulates and soluble salts from fluxes used in the reduction
furnaces will characterize this waste stream.  Treatable concen-
 trations of ammonia and an alkaline pH may also be found.  Table
V-12 presents field sampling data for samples taken from two
different reduction furnace scrubber waters.

REDUCTION TO TUNGSTEN METAL WATER OF FORMATION

Plants that reduce oxides to tungsten metal in a hydrogen atmo-
sphere may generate a water of formation as generalized  by the
following reaction:

                  WOX + H2 •	^ W + H20

In some plants this water may be recondensed in the reduction
furnace scrubber system.  Production normalized water use and
discharge flows for this subdivision are presented in Table V-9
in liters per metric ton of tungsten metal.  It should be noted
that since this is a water of formation, no water will actually
be used in this process.

The wastewater characteristics of this stream should be  very
similar to those for the scrubber waters from reduction  to metal
furnaces as described above.  Table V-12 is the field sampling
data that is associated with this stream.
                               42

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                     Table V-l

  WATER USE AND DISCHARGE RATES FOR TUNGSTIC ACID
                    RINSE WATER
        (103 1/kkg of Tungstic Acid Produced)
                                          Production
                           Production     Normalized
               Percent     Normalized     Discharge
Plant Code     Recycle     Water Use         Flow

   9011           0           57.6           57.6

   9014           0           37.6           37.6
                        43

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                     Table V-2

    WATER USE AND DISCHARGE RATES FOR ACID LEACH
             WET AIR POLLUTION CONTROL
        (103 1/kkg of Tungstic Acid Produced)
                                          Production
                           Production     Normalized
               Percent     Normalized     Discharge
Plant Code     Recycle     Water Use         Flow

   9011           0           37.7           37.7

   9014         100           15.0            0
                        44

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                            Table V-3

       WATER USE AND DISCHARGE RATES FOR ALKALI LEACH WASH
             (103 1/kkg of Sodium Tungstate Produced)
                                  Production
NR - Present but data not reported in dcp.
Production
Normalized
Plant Code
9011
9012
9014
9017
Percent
Recycle
(100%
Evapora-
tion)
0
NR
0
Normalized
Water Use
24.4
10.7
NR
82.6
Discharge
Flow
0
10.7
0
82.6
                               45

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                            Table V-4

          WATER USE AND DISCHARGE RATES FOR ION-EXCHANGE
                            RAFFINATE
                1/kkg of Ammonium Tungstate Produced)
       Plant Code

          9012

          9017
Percent
Recycle

  NR

   0
Production
Normalized
Water Use

    NR.

   29.8
Production
Normalized
Discharge
   Flow

   72.5

   29.8
NR - Present but data not reported in dcp.
                               46

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                            Table V-5

        WATER USE AND DISCHARGE RATES FOR CALCIUM TUNGSTATE
                         PRECIPITATE WASH
                1/kkg of Calcium Tungstate Produced)
                                  Production
NR - Present but data not reported in dcp.
Production
Normalized
Plant Code
9011
9012
9014
9017
Percent
Recycle
0
NR
0
0
Normalized
Water Use
21.0
NR
65.8
24.7
Discharge
Flow
21.0
NR
65.8
24.7
                               47

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                            Table V-6

     WATER USE AND DISCHARGE RATES FOR AMMONIUM PARATUNGSTATE
                    CRYSTALLIZATION AND DRYING
          (1(P 1/kkg of Ammonium Paratungstate Produced)
Plant Code
9011
9012
9014
9017
Percent
Recycle
(100%
Evapora-
tion)
NR
100
NR
Production
Normalized
Water Use
.098
NR
NR
NR
                                                 Production
                                                 Normalized
                                                 Discharge
                                                 	Flow

                                                     0'
                                                     0

                                                     0

                                                    68.6
NR - Present but data not reported in dcp.
                               48

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                            Table V-7

         WATER USE AND DISCHARGE RATES FOR APT CONVERSION
               TO OXIDES WET AIR POLLUTION CONTROL
           (103 1/kkg of "blue" Oxide  (W03>Produced)
                                  Production
Production
Normalized
Plant Code
9010
9011
9012
9014
9015
9018
Percent
Recycle
0
(100%
Evapora-
tion)
0
0
100
0
Normalized
Water Use
11.0
.05
36.8
7.43
NR
28.4
Discharge
Flow
11.0
0
36.8
7.43
0
28.4
NR - Present but data not reported in dcp.
                               49

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                            Table V-8

          WATER USE AND DISCHARGE RATES FOR REDUCTION TO
                TUNGSTEN WET AIR POLLUTION CONTROL
                     1/kkg of Tungsten Produced)
                                  Production
NR - Present but data not reported in dcp,
Production
Normalized
Plant Code
9012
9014
9015
9016
9018
Percent
Recycle
0
33
100
100
0
Normalized
Water Use
426.0
120.6
NR
NR
65.9
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                               50

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                            Table V-9

          WATER USE AND DISCHARGE RATES FOR REDUCTION TO
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                 Figure V-4



SAMPLING SITES AT  PRIMARY TUNGSTEN PLANT  D
                     79

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                   PRIMARY TUNGSTEN SUBCATEGORY

                            SECTION VI

                SELECTION OF POLLUTANT PARAMETERS
Section V of this supplement presented data from primary tungsten
plant sampling visits and subsequent chemical analyses.  This
section examines that data and discusses the selection or exclu-
sion of pollutants for potential limitation.  The  legal basis  for
the exclusion of toxic pollutants under Paragraph  8(a) of the
Settlement Agreement is presented in Section VI of the General
Development Document.

Each pollutant selected for potential limitation is discussed  in
Section VI of the General Development Document.  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 describes the analysis  that was per-
formed to select or exclude pollutants for further  consideration
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 concen-
trations used for the toxic metals were the long-term performance
values achievable by lime precipitation, sedimentation, and fil-
tration;  The treatable concentrations used for the toxic organ-
ics were the long-term performance values achievable by carbon
adsorption (see Section VII of the General Development Document -
Combined Metals Data Base).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS

This study examined samples from the primary tungsten subcategory
for three conventional pollutant parameters (oil and grease, to-
tal suspended solids, and pH) and four nonconventional pollutant
parameters•(ammonia, chemical oxygen demand, total  organic car-
bon, and total phenols).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS SELECTED

The conventional and nonconventional pollutants or  pollutant
parameters selected for limitation in this subcategory are:

     ammonia
     total suspended solids (TSS)
     pH
                                81

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Ammonia is the only nonconventional pollutant parameter  selected
for consideration in establishing limitations for this subcate-
gory.  Ammonia was found in all seven raw waste samples  analyzed
for this subcategory in concentrations ranging from 0.0435  to
1,790 mg/1.  Three of the values recorded are well above the 32.2
mg/1 concentration attainable by the available treatment technol-
ogy.  Additionally, ammonia concentrations above the treatable
concentration (up to 2,250 mg/1) were found in three partially
treated wastewaters where there was no raw waste data available.
Consequently, ammonia is selected for limitation in this
subcategory.

TSS concentrations ranging from 43 to 209 mg/1 were observed in
the three raw waste samples analyzed for this study.  All three
concentrations are well above the 2.6 mg/1 treatable concentra-
tion.  In one partially treated sample, TSS was measur€sd at 6,714
mg/1.  Furthermore, most of the specific methods used to remove
toxic metals do so by converting these metals to precipitates,
and these toxic-metal-containing precipitates should not be
discharged.  Meeting a limitation on total suspended solids helps
ensure that removal of these precipitated toxic metals has been
effective.  For these reasons, total suspended solids are
selected for limitation in this subcategory.

The nine pH values observed during this study ranged from 0.6 to
12.0.  Eight of the nine values were equal to or less than  2.5,
and the other was above the 7.5 to 10.0 range considered desira-
ble for discharge to receiving waters.  Many deleterious effects
are caused by extreme pH values or rapid changes in pH.  Also,
effective removal of toxic metals by precipitation requires
careful control of pH.  Since pH control within the desirable
limits is readily attainable by available treatment, pH  is
selected for limitation in this subcategory.

TOXIC POLLUTANTS

The frequency of occurrence of the toxic pollutants in the raw
wastewater samples taken is presented in Table VI-1.  Table VI-1
is based on the raw wastewater data from streams 9, 64,  130, and
219 (see Section V).  These data provide the basis for the cate-
gorization of specific pollutants, as discussed below.   Treatment
plant samples were not considered in the frequency count.

TOXIC POLLUTANTS NEVER DETECTED

Paragraph 8(a)(iii) of the Revised Settlement Agreement  allows
the Administrator to exclude from limitation those toxic pollu-
tants not detectable by Section 304(h) analytical methods or
other state-of-the-art methods.  The toxic pollutants listed
below were not detected in any raw wastewater samples from this
subcategory; therefore, they are not selected for consideration
in establishing limitations:
                                82

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 2.  acrolein
 3.  acrylonitrile
 5.  benzidine
 6.  carbon tetrachloride
 7.  chlorobenzene
 8.  1,2,4-trichlorobenzene
 9.  hexachlorobenzene
11.  1,1,1-trichloroethane
12.  hexachloroethane
13.  1,1-dichloroethane
14.  1,1,2-trichloroethane
16.  chloroethane
17.  bis(chloromethyl) ether
18.  bis(2-chloroethyl) ether
19.  2-chloroethyl vinyl ether
20.  2-chloronaphthalene
21.  2,4,6-trichlorophenol
22.  parachlorometa cresol
24.  2-chlorophenol
25.  1,2-dichlorobenzene
26.  1,3-dichlorobenzene
27.  1,4-dichlorobenzene
28.  3,3'-dichlorobenzidine
30.  1,2-trans-dichloroethylene
31.  2,4-dichlorophenol
32.  1,2-dichloropropane
33.  1,3-dichloropropylene
34.  2,4-dimethylphenol
35.  2,4-dinitrotoluene
36.  2,6-dinitrotoluene
37.  1,2-diphenylhydrazine
40.  4-chlorophenyl phenyl ether
41.  4-bromophenyl phenyl ether
42.  bis(2-chloroisopropyl)ether
43.  bis(2-chloroethoxy)methane
44.  methylene chloride
45.  methyl chloride (chloromethane)
46.  methyl bromide (bromomethane)
48.  dichlorobromomethane
49.  trichlorofluoromethane
50.  dichlorodifluoromethane
52.  hexachlorobutadiene
53.  hexachlorocyclopentadiene
54.  isophorone
56.  nitrobenzene
57.  2-nitrophenol
58.  4-nitrophenol
59.  2,4-dinitrophenol
60.  4,6-dinitro-o-cresol
61.  N-nitrosodimethylamine
                         83

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      62.  N-nitrosodiphenylamine
      63.  N-nitrosodi-n-propylamine
      64.  pentachlorophenol
      65.  phenol
      67.  butyl benzyl phthalate
      70.  diethyl phthalate
      71.  dimethyl phthalate
      72.  benzo(a)anthracene
      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
      88.  vinyl chloride
      89.  aldrin
      90.  dieldrin
      91.  chlordane
      92.  4,4'-DDT
      93.  4,4'-DDE
      94.  4,4'-ODD
      96.  beta-endosulfan
      97.  endosulfan sulfate
      98.  endrin
      99.  endrin aldehyde
     100.  heptachlor
     101.  heptachlor epoxide
     102.  alpha-BHC
     103.  beta-BHC
     104.  gamma-BHC
     105.  delta-BHC
     113.  toxaphene
     114.  antimony
     116.  asbestos
     129.  2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD)

TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION CONCENTRATION

The provision of Paragraph 8(a)(iii) of the Revised Settlement
Agreement excluding from limitation those toxic pollutants which
are not detectable includes those pollutants whose concentrations
fall below EPA's nominal detection limit.  The  toxic pollutants
listed below were never found above their analytical quantifica-
tion concentration in any raw wastewater samples from this
subcategory; therefore, they are not selected for consideration
in establishing limitations.

       4.  benzene
      10.  1,2-dichloroethane
                                84

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      15.  1,1,2,2-tetrachloroethane
      39.  fluoranthene
      78.  anthracene        (a)
      81.  phenanthrene      (a)
      84.  pyrene
      87.  trichloroethylene
      95.  alpha endosulfan
     106.  PCB-1242            (b)
     107.  PCB-1254            (b)
     108.  PCB-1221            (b)
     109.  PCB-1232            (c)
     110.  PCB-1248            (c)
     111.  PCB-1260            (c)
     112.  PCB-1016            (c)

(a), (b),  (c)  Reported together.

TOXIC POLLUTANTS PRESENT BELOW CONCENTRATIONS ACHIEVABLE  BY
TREATMENT

Paragraph  8(a)(iii) of the Revised Settlement Agreement also
allows the exclusion of toxic pollutants which were  detected  in
quantities too small to be effectively reduced by  technologies
known to the Administrator.  The pollutants  listed below  are  not
selected for consideration in establishing limitations because
they were not found in any raw wastewater samples  from this sub-
category above concentrations considered achievable  by existing
or available treatment technologies.  These  pollutants are  dis-
cussed individually following the list.

      23.  chloroform
      29.  1,1-dichloroethylene
      38.  ethylbenzene
      51.  chlorodibromomethane
      85.  tetrachloroethylene
      86.  toluene
     117.  beryllium
     121.  cyanide
     123.  mercury

Chloroform was detected in six of eight raw  waste  samples for
which it was analyzed at concentrations ranging  from 0.014  to
0.036 mg/1.  Since available treatment methods specific for
chloroform can reduce its concentration only to  0.1  mg/1, this
pollutant should not be considered for limitations.  Chloroform
was found at a high concentration (1.933 mg/1) in  one of  the
several treated wastewater samples taken.  However,  chloroform is
a common laboratory solvent, and this elevated reading may  be due
to sample contamination.  The presence of chloroform in the blank
taken attests to this possibility.
                                85

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Regardless, this result alone cannot be generalized as character-
istic of the entire subcategory, since it is not used or  formed
during processing.  Therefore, chloroform is not selected  for
limitation.

1,1-Dichloroethylene was detected in only one of the eight raw
wastewater samples for which it was analyzed.  This one concen-
tration of 0.019 mg/1 is well below the 0.10 mg/1 concentration
considered achievable by identified treatment technology.  There-
fore, 1,1-dichloroethylene is not selected for limitation.

Ethylbenzene was detected in two of the eight raw wastewater sam-
ples.  Only one of these samples (0.011 mg/1) contained ethylben-
zene above its analytical quantification concentration. (0.01
mg/1).  Because this concentration is below that attainable by
identified treatment technology, (0.05 mg/1), ethylbenzene is not
selected for limitation.

Chlorodibromomethane was detected in only one of the eight raw
waste samples.  This one concentration of 0.038 mg/1 is below the
0.10 mg/1 concentration considered achievable by identified
treatment technology.  Therefore, Chlorodibromomethane is not
selected for limitation.

Tetrachloroethylene was detected in all eight of the raw waste
samples for which it was analyzed.  Of the three detections which
could be quantified, the highest concentration observed was  .037
mg/1.  Since this concentration is below the 0.05 mg/1 concentra-
tion achievable by identified treatment technology, tetrachloro-
ethylene is not selected for limitation.

Toluene was detected in five of the eight samples.  Only two of
these were above toluene's analytical quantification concentra-
tion (0.01 mg/1), and both were below this pollutant's treatable
concentration (0.05 mg/1).  Thus, toluene was not selected for
limitation.

Beryllium was detected in only one of the five raw waste samples.
This one concentration of 0.03 mg/1 is below the 0.20 mg/1 con-
centration considered achievable by available treatment.  There-
fore, beryllium is not selected for limitation.

Cyanide was detected in six of nine raw waste samples.  Of the
three detections which could be quantified, the highest concen-
tration observed was 0.02 mg/1.  Since this concentration  is
below the 0.047 mg/1 concentration considered achievable by
identified treatment technology, cyanide is not selected  for
limitation.

Mercury was found in all five samples analyzed, at concentrations
ranging from 0.0002 mg/1 to 0.004 mg/1.  Since all of these are
below treatability (of 0.036 mg/1), mercury is not selected for
limitation.
                               86

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TOXIC POLLUTANTS DETECTED IN A SMALL NUMBER  OF  SOURCES

Paragraph 8(a)(iii) allows for the exclusion of a  toxic  pollutant
if it is detectable in the effluent from only a small number  of
sources within the subcategory and it  is uniquely  related  to  only
those sources.  The following pollutants were not  selected  for
limitation on this basis.

      47.  bromoform
      66.  bis(2-ethylhexyl) phthalate
      68.  di-n-butyl phthalate
      69.  di-n-octyl phthalate
      76.  chrysene
     115.  arsenic
     120.  copper
     124.  nickel
     126.  silver

Although these pollutants were not selected  for limitation  in
establishing nationwide regulations, it may  be  appropriate, on a
case-by-case basis, for the local permitter  to  specify effluent
limitations.

Bromoform was detected in two of eight raw wastewater samples.
The only concentration above the treatability of 0.05 mg/1  was
0.053 mg/1.  Since this is just slightly higher than could  be
achieved by treatment and such a small number of sources indicate
that bromoform is present, bromoform is not  selected for
limitation.

Bis(2-ethylhexyl) phthalate was found  above  its treatability
(0.01 mg/1) in two of three samples analyzed for it.  This
compound is a plasticizer commonly used in laboratory and  field
sampling equipment, and is not used or formed as a by-product in
this subcategory.  Also, in the dcp the responding primary
tungsten plants indicated that this pollutant was believed  to be
absent.  Therefore, bis(2-ethylhexyl) phthalate is not selected
for limitation.

Di-n-butyl phthalate was detected above its  treatability (0.025
mg/1) in only one of five samples analyzed.   This  compound  is a
plasticizer commonly used in laboratory and  field  sampling
equipment, and is not considered a pollutant specific to this
subcategory.  Also, in the dcp the responding primary tungsten
plants indicated that this pollutant was believed  to be  absent.
Therefore, di-n-butyl phthalate is not selected for limitation.

Di-n-octyl phthalate occurred above its treatability (0.01  mg/1)
in one of five samples.  This compound is a  plastizicer used  in
many products and is not considered a pollutant specific to this
subcategory.  Also, in the dcp the responding primary tungsten
                                87

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plants indicated that this pollutant was believed  to be  absent.
Therefore, di-n-octyl phthalate is not selected  for limitation.

Chrysene concentrations were above treatability  (0.01 mg/1)  in
only one of five samples analyzed.  The sample measured  0.024
mg/1.  This site-specific result cannot be generalized as
characteristic of the entire subcategory, therefore, chrysene is
not selected for limitation.

Arsenic was detected above its treatability  (0.34  mg/1)  in only
one of the five raw waste streams for which  it was sampled.  The
Agency has no reason to believe that treatable arsenic concentra-
tions should be present in primary tungsten  wastewaters, and it
believes that this one value found at one plant  is not represen-
tative of the subcategory.  For these reasons arsenic is not
selected for limitation.

Copper was found at 5 mg/1 in one sample, but the  other  six
samples analyzed contained copper at 0.2 mg/1 or less, which is
below its treatability of 0.39 mg/1.  The Agency has no  reason to
believe that treatable copper concentrations should be present in
primary tungsten wastewaters, and it believes that this  one  value
found at one plant is not representative of  the  subcategory.
Thus, copper is not selected for limitation.

Nickel was detected above its treatability of 0.22 mg/1  in only
one of the five raw waste streams for which  it was sampled.  The
Agency has no reason to believe that treatable nickel concentra-
tions should be present in primary tungsten  wastewaters, and it
believes that this one value found at one plant  is not represen-
tative of the subcategory.  Therefore, nickel is not selected for
limitation.

Silver was detected above its treatability (0.07 mg/1) in only
two of the five streams for which it was analyzed.  The  Agency
has no reason to believe that treatable silver concentrations
should be present in primary tungsten wastewaters, and it
believes that these two values are not representative of the
subcategory.  Therefore, silver is not selected  for limitation.

TOXIC POLLUTANTS SELECTED FOR FURTHER CONSIDERATION IN
ESTABLISHING LIMITATIONS AND STANDARDS

The toxic pollutants listed below are selected for further con-
sideration in establishing limitations and standards for this
subcategory.  The toxic pollutants selected  for  further  consider-
ation for limitation are each discussed following  the list.

     1.  acenaphthene
    55.  naphthalene
    77.  acenaphthylene
                                88

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    80.  fluorene
   118.  cadmium
   119.  chromium
   122.  lead
   125.  selenium
   127.  thallium
   128.  zinc

Acenaphthene was detected  in  one  of  the  three  raw wastewater
streams for which  it was analyzed.   That  sample,  the  ion-exchange
raffinate, exhibited a  concentration of  0.111  mg/1 which is  above
the concentration  attainable  by treatment (0.01  mg/1).   Since
this is the only sampling  data for ion exchange  raffinate,  and
since this stream  may contain toxic  organic  pollutants,   acenaph-
thene is selected  for further consideration  for  limitation.

Naphthalene was detected above its treatability  (0.05 mg/1)  in
one of three raw wastewater streams  for which  it  was  analyzed.
That sample, ion-exchange  raffinate,  exhibited a concentration of
1.078 mg/1.  Since this is the only  sampling data for ion
exchange raffinate, and since this stream may  contain toxic
organic pollutants, naphthalene is selected  for  further  consider-
ation for limitation.

Acenaphthylene was detected in one of three  raw  wastewater
streams.  That sample exhibited a concentration  of 0.112 mg/1
which is above the concentration  attainable  by treatment (0.01
mg/1).  Since this is the  only sampling data for  ion  exchange
raffinate, and since this  stream  may contain toxic organic
pollutants, acenaphthylene is selected for further consideration
for limitation.

Fluorene was detected in one  of three raw wastewater  streams.
That sample exhibited a concentration of  0.06  mg/1 which is  above
treatability (0.01 mg/1).  Since  this is  the only sampling  data
for ion exchange raffinate, and since this stream may contain
toxic organic pollutants,  fluorene is selected for further
consideration for  limitation.

Cadmium was detected above treatability  (0.049 mg/1)  in  one  of
seven raw wastewater streams  sampled.  The treatable  concentra-
tion was detected  in tungstic acid rinse  water, which may contain
cadmium from the ore concentrates.   Therefore, cadmium is
selected for further consideration for limitation.

Chromium was detected above its treatability of  0.07  mg/1 in both
tungstic acid rinse water  samples before  treatment.   The highest
concentration was  2.0 mg/1.   One  sample from a third  stream  indi-
cated that chromium was present at a concentration quantifiable
but below treatability.  Therefore,  chromium is  selected for
further consideration for  limitation.
                                89

-------
Lead was detected in one raw waste stream at a concentration  of
20.0 mg/1 which is well above the .08 mg/1 attainable  by  identi-
fied treatment technology.  This concentration was observed in
tungstic acid rinse water which may contain toxic metals  from ore
concentrates. Although no raw waste data is available,  sampling
data at a second plant indicated that lead concentrations  above
the treatability concentration were present in the treated waste-
water.  For these reasons, lead is selected for further con-
sideration for limitation.

Selenium was detected but could not be quantified other than  as
being less than 0.01 mg/1 in two of five raw waste streams for
which it was sampled.  However, at another plant for which there
was no raw wastewater data, a partially treated wastewater stream
exhibited a selenium concentration of 1.0 mg/1 which is above
selenium's treatability of 0.20 mg/1.  Since selenium  impurities
may be present in ore concentrates and because selenium was
present at 1.0 mg/1 in a partially treated sample, it  is  selected
for further consideration for limitation.

Thallium was detected in one of the five raw wastewater samples
at a concentration above its treatability of 0.34 mg/1,,   The
treatable concentration was observed in raw tungstic acid rinse
water at 0.70 mg/1.  Therefore, thallium is selected for  further
consideration for limitation.

Zinc was detected in two of the five samples for which it  was
analyzed above its treatability of 0.23 mg/1.  The highest con-
centration found was 2.0 mg/1.  Treated wastewater sampling data
from one plant also indicated that concentrations above treat-
ability remained even after lime and settle treatment  had been
applied to a stream.  Accordingly, zinc is selected for further
consideration for limitation.
                                90

-------
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                         91

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                   PRIMARY  TUNGSTEN  SUBCATEGORY

                            SECTION VII

                CONTROL AND TREATMENT TECHNOLOGIES
The preceding sections of this  supplement discussed  the  sources,
flows, and characteristics of the wastewaters  from primary tung-
sten plants.  This section summarizes  the description  of these
wastewaters and indicates the treatment  technologies which are
currently practiced in the primary tungsten  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  tungsten subcategory.

CURRENT CONTROL AND TREATMENT PRACTICES

Control and treatment technologies are discussed in  general in
Section VII of the General Development Document.   The  basic prin-
ciples of these technologies and the applicability to  wastewater
similar to that found in this subcategory are presented  there.
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 tungsten
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.  Gener-
ally, 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
economic scale and in some instances to  combine streams  of
different alkalinity to reduce  treatment chemical  requirements.
One plant in this subcategory currently  has  combined wastewater
treatment systems, none have lime precipitation and  sedimenta-
tion, but three have lime precipitation, sedimentation and fil-
tration.  As such, five options have been selected for consider-
ation for BPT, BAT, BDT, BCT, and pretreatment  based on  combined
treatment of these compatible waste streams.

TUNGSTIC ACID RINSE WATER

Tungstic acid is prepared by leaching  ore concentrates with
hydrochloric acid and then rinsing the soluble  tungsten  acid with
water.   The two plants using this process practice lime  and set-
tle treatment to precipitate metals before discharging the rinse
water.   A third plant which produces a tungsten acid intermediate
                                95

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by reacting HCl with sodium tungstate neutralizes the rinse water
along with other wastes and then coagulates with polymers and
practices sedimentation.

ACID LEACH WET AIR POLLUTION CONTROL

Plants that acid leach use wet scrubbing systems for the control
of hydrochloric acid fumes.  One plant discharges this acidic
wastewater after lime and settle treatment while a second
recycles the entire stream for use as tungsten acid rinse water.

ALKALI LEACH WASH

The four plants which use an alkali ore leaching process, such as
caustic digestion or a soda autoclave, generate a waste from the
decant washing of the sodium tungstate intermediate.  Two plants
have reduced this flow to zero by filtering the insoluble impuri-
ties and using a combination of evaporation and recycle.  A third
plant discharges this and all its other wastes to a settling pond
where the water either evaporates or percolates into the ground.
Only one plant discharges this wastewater, although it does
pretreat this stream by chemical oxidation.

ION-EXCHANGE RAFFINATE

When a liquid ion-exchange process is used to convert sodium
tungstate to ammonium tungstate, a raffinate stream is generated.
Of the two plants which utilize this process, one is a zero dis-
charge plant because it pumps all of its wastes, including the
ion-exchange raffinate, to a settling pond where the water evapo-
rates.  The second plant, a direct discharger, treats this waste-
water with a lime and settle process and then coagulates with
polymers and practices sedimentation before discharge.

CALCIUM TUNGSTATE PRECIPITATION WASH

Calcium tungstate, synthetic scheelite, is precipitated when
sodium tungstate crystals are dissolved and then reacted with
calcium chloride solution.  The precipitated crystals are allowed
to settle, and the waste sodium chloride supernatant can be
decanted.  Of the four plants which precipitate calcium tungstate
only one has achieved zero discharge status.  This plant dis-
charges all of its wastes to a settling pond.  Two plants treat
this wash water.  One uses lime and settle, and the second adds
coagulation with polymers to a lime and settle pretreatment.  The
fourth plant discharges this briny waste without treatment.

CRYSTALLIZATION AND DRYING OF AMMONIUM PARATUNGSTATE

Ammonium paratungstate crystals are precipitated from a mother
liquor which will contain ammonia and possibly tungsten.  For
                                96

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this reason, three plants  completely  recycle  and reprocess  the
filtrate after recovering  the  ammonia for  reuse.   If heating is
used to dry the crystals,  a wet  scrubber system is used to  con-
tain ammonia fumes, and again, an  ammonia  recovery system may be
used.  The fourth plant recycles and  reuses  some of this scrubber
water, but discharges the  majority of it to a settling pond.

AMMONIUM PARATUNGSTATE CONVERSION  TO  OXIDES WET AIR POLLUTION
CONTROL

When ammonium paratungstate  (APT)  is  converted to tungsten  oxides
(WOX), ammonia is evolved.  Most plants use a wet scrubbing
system to contain the fumes, and some use  an  ammonia recovery
system.  Of the six plants which reported  using this process  and
generating a waste stream, two have reduced the flow to zero.
One of these accomplished  this by  recycle  to  a cooling tower  and
reuse, and the other by a  combination of evaporation,  ammonia
recovery, and reuse.  The  following treatment schemes  are
currently in place in the  rest of  the subcategory:

     1.  No treatment of scrubber  water; direct discharge - one
         plant.

     2.  Lime and settle treatment of scrubber water,  ammonia
         recovery; direct  discharge - one  plant.

     3.  Primary and secondary settling; indirect discharge -
         one plant.

     4.  Off-gases run through bubbling tank,  fine  particles
         of tungsten material  settle  out,  overflow from settling
         tanks is indirectly discharged -  one plant.

REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL

Tungsten oxides (WOX) are reduced  to  tungsten metal in rotary
reduction furnaces, usually under  a hydrogen  atmosphere.  Of  the
seven plants which produce tungsten metal  in  this manner, five
report using a wet scrubbing system to control particulate  emis-
sions.   Two of these plants have achieved  zero discharge  for  this
stream through 100 percent recycle and reuse.   One  plant  recycles
one third of its scrubber water  and recovers  hydrogen  for reuse
before discharging the remaining water directly.   The  two remain-
ing plants do not treat this water before  discharge.

REDUCTION TO TUNGSTEN WATER OF FORMATION

Plants  that reduce oxides to tungsten metal in a  hydrogen atmo-
sphere may generate a water of formation as generalized by  the
following reaction:

                 WOX + H2	*• W  + H20


                               97

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One plant uses primary and secondary settling on this waste
stream.  A second reported evaporating all of the water of forma-
tion.  Many plants, however, did not quantify this waste  flow
because the water is recondensed in the wet scrubbing system of
the reduction furnace.  In these cases the treatment applied to
reduction to tungsten scrubber water would also apply to  the
water of formation.

CONTROL AND TREATMENT OPTIONS

The Agency examined five control and treatment technology options
that are applicable to the primary tungsten subcategory.  The
options selected for evaluation represent a combination of
in-process flow reduction, preliminary treatment technologies
applicable to individual waste streams, and end-of-pipe treatment
technologies.

Examination of the raw wastewater data does not show any  arsenic
or selenium at or above treatable concentrations.  Also,  these
pollutants are not characteristic of the raw materials and
processing agents used in this subcategory.  Therefore, Option D,
which includes activated aluminum adsorption, was not considered
as an appropriate treatment technology.

OPTION A

Option A for the primary tungsten subcategory requires control
and treatment technologies to reduce the discharge of wastewater
volume and pollutant mass.

The Option A treatment scheme consists of chemical precipitation
and sedimentation technology.  Specifically, lime or some other
alkaline compound is used to precipitate toxic metal ions as
metal hydroxides.  The metal hydroxides and suspended solids
settle out and the sludge is collected.  Vacuum filtration is
used to dewater sludge.

Preliminary treatment consisting of ammonia steam stripping for
waste streams containing treatable concentrations of ammonia is
also included in Option A.  Steam stripping is an efficient
method for reducing the ammonia concentrations, as well as
recovering ammonia as a by-product.  Steam stripping also
prevents the transfer of ammonia to the air.

OPTION B

Option B for the primary tungsten subcategory consists of the
Option A (ammonia steam stripping, lime precipitation and sedi-
mentation) treatment scheme plus flow reduction techniques to
reduce the discharge of wastewater volume.  In-process changes
which allow for water recycle and reuse are the principal control
mechanisms for flow reduction.
                               98

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OPTION C

Option C for the primary tungsten subcategory consists of all
control and treatment requirements of Option B  (in-process flow
reduction, ammonia steam stripping, lime precipitation and sedi-
mentation) plus multimedia filtration technology added at the end
of the Option B treatment scheme.  Multimedia filtration is used
to remove suspended solids, including precipitates of metals,
beyond 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 consistent removal during periods of time
in which there are rapid increases in flows or  loadings of pollu-
tants to the treatment system.

OPTION E

Option E for the primary tungsten subcategory consists of Option
C (in-process flow reduction, ammonia steam stripping, lime
precipitation and sedimentation) with the addition of granular
activated carbon technology at the end of the Option C treatment
scheme.  The activated carbon process is utilized to control the
discharge of toxic organics.

OPTION F

Option F for the primary tungsten subcategory consists of all of
the control and treatment requirements of Option C (in-process
flow reduction, ammonia steam stripping, lime precipitation and
sedimentation) plus reverse osmosis and multiple-effect evapora-
tion technology added at the end of the Option C treatment
scheme.  Reverse osmosis is provided for the complete recycle of
the treated water by controlling the concentration of dissolved
solids concentrations.  Multiple-effect evaporation is used to
dewater brines rejected from reverse osmosis.
                               99

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                   PRIMARY TUNGSTEN SUBCATEGORY

                           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  suggested
in Section VII for wastewaters from primary tungsten plants.
The energy requirements of the considered options as well  as
solid waste, and air pollution aspects are also discussed.
Section VIII of the General Development Document provides  back-
ground on the capital and annual costs for each of the  technol-
ogies discussed herein.

The various sources of wastewater that have been discussed
throughout this document are combined into two separate groups.
These groups are based on the two basic steps of primary
tungsten production - the conversion of ore concentrates to
ammonium paratungstate (APT) and the reduction of APT to metal.
These groups are selected for the purpose of cost estimation
because the combination of waste streams in each is representa-
tive of the processing that occurs in most primary tungsten
plants.  In addition, the waste streams associated with each
group also require varying degrees of preliminary treatment with
ammonia steam stripping.  This will be discussed further below.
Since all the plants in the subcategory can be classified  as
performing one or the other or both of the two basic steps in
primary tungsten production, a division of the waste streams
along these lines is appropriate.  Accordingly, the wastewater
sources in the primary tungsten subcategory have been divided,
for the purpose of cost estimation, as follows:

Group A - Ore to APT

     1.  Tungstic acid rinse water;
     2.  Acid leach wet air pollution control;
     3.  Alkali leach wash;
     4.  Ion-exchange raffinate;
     5.  Calcium tungstate precipitate wash; and
     6.  Crystallization and drying of ammonium paratungstate.

Group B - APT to metal

     1.  Ammonium paratungstate conversion to oxides wet air
         pollution control;
     2.  Reduction to tungsten metal wet air pollution control;
         and
     3.  Reduction to tungsten metal water of formation.
                               101

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The wastewater characteristics of both ore to metal and  ore  to
APT plants are similar since it is the ore to APT step which
encompasses most of the unique waste streams.  Therefore, plants
which do both steps (i.e., process ore concentrates all  the  way
to tungsten metal) are included in group A, the ore to APT
group.

The two wastewater groupings have been further divided into  two
combinations.  The APT to metal group streams and ion-exchange
raffinate contain treatable concentrations of ammonia, and will
require ammonia steam stripping preliminary treatment.   Ore  to
APT waste streams with the possible exception of ion-exhcnage
raffinate will not contain treatable concentrations of ammonia.
Therefore ammonia steam stripping preliminary treatment  will not
be costed for plants having only these streams or for plants
which already have ammonia steam stripping in-place.  Thus,  for
existing sources in the primary tungsten subcategory, the fol-
lowing situations are selected for cost analysis.

                                  Ore to APT      APT to Metal
                                 Waste Streams   Waste Streams

Combination 1.  (no ammonia            X
  steam stripping preliminary
  treatment included)

Combination 2.  (ammonium steam        X               X
  stripping preliminary treat-
  ment included)

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES

Five treatment options have been developed for both combinations
in existing primary tungsten sources.  The only difference in
the options for the two different combinations is that ammonia
steam stripping is added to each option for combination.  The
options are summarized below and schematically presented in
Figures X-l through X-5.

OPTION A

Option A consists of preliminary ammonia steam stripping treat-
ment and lime precipitation and sedimentation end-of-pipe tech-
nology.  For combination 2, ammonia steam is added as prelimi-
nary treatment for 20 percent of the ore to APT wastewaters  and
70 percent of the APT to metal wastewaters.  Ammonia steam
stripping is not included in the costs for combination 1.
                               102

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OPTION B

Option B consists of  in-process  flow reduction  measures,  pre-
liminary ammonia steam  stripping treatment,  and lime  precipita-
tion and sedimentation  end-of-pipe  technology.   The  in-process
flow reduction measure  consists  of  the  recycle  of  acid  leach
scrubber water and reduction  to  tungsten  scrubber  water through
holding tanks.  A separate  cost  curve was  developed  to  estimate
holding tank costs.   This curve  is  based  on  a retention time of
one day for the scrubber water which is to be recycled.   To
determine  the cost of Option  B,  the holding  tank cost is  added
to the cost of Option A.

OPTION C

Option C requires the in-process  flow reduction measures  of
Option B,  preliminary ammonia steam stripping treatment,  and
end-of-pipe treatment technology  consisting  of  lime precipita-
tion, sedimentation,  and multimedia filtration.  As with  Options
A and B, only the costs for combination 2  are based on  ammonia
steam stripping preliminary treatment.  Also, the  cost  curves
developed  for Option  C  do not consider  in-process  flow  reduc-
tion.  Therefore, the total cost  of Option C is  determined  by
adding the cost for holding tanks to the  costs  obtained from the
Option C cost curves.

OPTION E

Option E requires the in-process  flow measures  of  Options B and
C, preliminary ammonia  steam  stripping  treatment,  and end-of-
pipe treatment technology consisting of lime precipitation,
sedimentation, multimedia filtration, and  activated carbon
adsorption.  As with  Options  A,  B,  and  C,  only  the costs  for
combination 2 wastewaters are based  on preliminary ammonia  steam
stripping  treatment.  Also, the  cost curves  developed for Option
E do not consider in-process  flow reduction.  Therefore,  the
total cost of Option  E  is determined by adding  the cost obtained
from the Option E cost  curves.

OPTION F

Option F requires the in-process  flow reduction  measures  of
Options B, C, and E,  preliminary  ammonia  steam  stripping  treat-
ment, and end-of-pipe treatment technology consisting of  lime
precipitation, sedimentation, multimedia  filtration,  reverse
osmosis,  and multiple-effect  evaporation.  As with Options  A, B,
C, and E,  only the costs for  combination 2 are based  on ammonia
steam stripping preliminary treatment.  In addition,  the  cost
curves developed for  Option F do not include the cost associated
with in-process flow  reduction.  Therefore,  the  total cost  of
Option F is determined by adding the cost  for holding tanks  to
                               103

-------
the cost obtained from the Option F cost curves.  An Option  F
cost curve was not developed for the APT to metal group because
this group does not have pollutant characteristics that warrant
the addition of reverse osmosis technology.

The cost curves for the options summarized above are presented
in the figures listed below.  The respective options which the
curves are based on are also shown.

     Combination         Figures VIII-       Options Posted

     1 (ore to APT)          1-4           A, C, E, F
     2 (ore to APT)          5-8           A, C, E, F
     3 (APT to metal)        9-11          A, C, E

The holding tank cost curve is presented in Figure VIII-12.
This curve is used to determine the cost of flow reduction.

NONWATER QUALITY ASPECTS

A general discussion of the nonwater quality aspects of the  con-
trol and treatment options considered for the nonferrous metals
category is contained in Section VIII of the General Development
Document.  Nonwater quality impacts specific to the primary
tungsten subcategory, including energy requirements, solid waste
and air pollution are discussed below.

ENERGY REQUIREMENTS

The methodology used for determining the energy requirements for
the various options is discussed in Section VIII of the General
Development Document.  Briefly, the energy usage of the various
options is determined for the primary tungsten plant with the
median wastewater flow.  The energy usage of the options is  then
compared to the energy usage of the median primary tungsten
energy consumption plant.  As shown in Table VIII-1, the most
energy intensive option is reverse osmosis, which increases  the
median primary tungsten energy consumption by 2.03 percent.  The
remaining four options would increase the median energy consump-
tion by less than 1 percent.

SOLID WASTE

Sludges associated with the primary tungsten subcategory will
necessarily contain additional quantities (and concentrations)
of toxic metal pollutants.  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).  Consequently, sludges generated from treating
primary industries' wastewater are not presently subject to
regulation as hazardous wastes.
                               104

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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  non-
ferrous 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), 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 dump-
ing 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.  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 ammonia steam
stripping, chemical precipitation, sedimentation, multimedia
filtration, activated carbon, and reverse osmosis.  These  tech-
nologies transfer pollutants to solid waste and do  not involve
air stripping or any other physical process likely  to transfer
pollutants to air.
                               105

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   106
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       SLUDGE REMOVAL
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                     PRIMARY TUNGSTEN  (ORE TO APT)
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                     PRIMARY TUNGSTEN  (ORE TO APT)
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                                      107

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                      PRIMARY TUNGSTEN  (ORE TO APT)
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                    10,000
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                      PRIMARY TUNGSTEN  (ORE TO  APT)
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                                      108

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10,000
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  107
                     PRIMARY TUNGSTEN (ORE TO APT)
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                  °-01
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           i  i i i 111	i   i i  i i i 111	i   iii
           10
  100            1,000
           FLOW, cu m/day

         Figure VIII-6
10,000
100,000
                     PRIMARY  TUNGSTEN (ORE  TO APT)
                        COMBINATION 2,  OPTION C
                                     109

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  107
  JO6
in
8
_i
a
•5
o
                       SLUDGE REMOVAL
                       CHEMICALS
                       ENERGY
                       MATERIALS
                                                   LABOR
                                                   DEPRECIATION
                                                   CAPITAL
              '	
                                                           ii'i	1—i—i  11 i ii
                  0.01
      i i  i ml    i  I
        OJ FLOW,  mod  L°
        ' ' i i i nl	J	1—i Mini
                                                            10.0
           10
  10'
  106  -
 M
 O
 O
 £
 o
100           1,000
         FLOW, cu m/doy

       Figure  VIII-7
10,000
100,000
                     PRIMARY TUNGSTEN  (ORE TO APT)
                       COMBINATION 2, OPTION E
  10'
                         100
                                      1,000
                                  FLOW, cu m/doy

                               Figure VIII-8
                           10,000
             100,000
                     PRIMARY TUNGSTEN  (ORE TO APT)
                       COMBINATION 2,  OPTION F
                                     110

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  107
  I06
o
o
z
z
  104
                       SLUDGE REMOVAL,
                       CHEMICALS & ENERGY
                       MATERIALS 	
                           LABOR
                           DEPRECIATION
                           CAPITAL
                  0.01
        0>l
                                                            10.0
      li' i i i ni    i  t—i i, i i ill	1	1—i  M
           FLOW,  mgd
        i I  I I I I ll	l_  i I  I I i J i I	1	1	1 1  | !,ll	1	1_
           10
100            1,000
         FLOW, cu m/doy
      Figure VIII-9
10,000
                                                                100,000
                     PRIMARY TUNGSTEN (APT TO METAL)
                       COMBINATION  2, OPTION A
                        CHEMICALS 8 ENERGY
                I—i—i i Mill	1	1—' '
                         100
             1,000
         FLOW, cu m/day
      Figure VIII-10
10,000
100,000
                     PRIMARY  TUNGSTEN (APT  TO METAL)
                       COMBINATION  2,  OPTION C
                                     111

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     107
     I06
   o
   u
   Z
     I04
                          SLUDGE REMOVAL
                          CHEMICALS
                          ENERGY
                          MATERIALS
                                                     LABOR
                                                     DEPRECIATION
                                                     CAPITAL
                     0.01

                     !  .1,1111
        OJ  FLOW,  mgd   L0
10 6 p
              10
100           1,000
         FLOW, cu m/day
      Figure VIII-11
                                                     10,000
10.0

	i I	L
    100,000
                       PRIMARY  TUNGSTEN (APT TO METAL)
                         COMBINATION 2,  OPTION E
                                                       DEPRECIATION

                                                       CAPITAL
                                 Figure  VIII-12

                     PRIMARY  TUNGSTEN HOLDING TANK COSTS
                                      112

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                   PRIMARY TUNGSTEN SUBCATEGORY

                            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 primary tungsten 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 facili-
ties 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 charac-
teristics.  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, transfera-
ble, 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 industry
practice.

TECHNICAL APPROACH TO BPT

The Agency studied the nonferrous metals category to identify the
processes used, the wastewaters generated, and the treatment pro-
cesses installed.  Information was collected from industry using
data collection portfolios, and specific plants were sampled and
the wastewaters analyzed.  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.
                               113

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As explained in Section IV, the primary tungsten subcategory has
been subdivided into nine potential wastewater sources.  Since
the water use, discharge rates, and pollutant characteristics of
each of these wastewaters is potentially unique, effluent limita-
tions will be developed for each of the nine subdivisions.

For each of the subdivisions, 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 deter-
mined 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 ana-
lyzed to determine (1) whether or not operations included gener-
ated 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 waste-
water 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 dis-
charge flow) reflects the water use controls which are common
practices within the industry.  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 loadings were
calculated for each wastewater source or subdivision.  This cal-
culation 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 loadings  (milligrams of pollu-
tant per metric ton of production unit - mg/kkg) were calculated
by multiplying the BPT normalized flow (1/kkg) by the treatabil-
ity concentration using the BPT treatment system (mg/1) for each
pollutant parameter to be limited under BPT.

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
                               114

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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  dis-
charge flow rates for each source; consequently,  the  treatment
technologies which are  currently used by the  lowest dischargers
will be the treatment technologies most  likely  required to meet
BPT guidelines.  Section VII discusses the  various treatment
technologies which are  currently in  place for each wastewater
source.  In most cases, the  current  treatment technologies
consist of chemical precipitation and sedimentation (lime and
settle technology) and  a combination of  reuse and recycle to
reduce flow.  Ammonia steam  stripping is added  to streams con-
taining treatable concentrations of  ammonia.  Consequently,  the
typical BPT treatment scheme will consist of  ammonia  steam
stripping  (if needed),  chemical precipitation,  and sedimentation.
This BPT treatment scheme is presented schematically  in Figure
IX-1.

The overall effectiveness of end-of-pipe treatment for the
removal of wastewater pollutants is  improved by the applica-
tion 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  REDUCTION BENEFITS

In balancing costs in relation  to effluent  reduction benefits,
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 BPT.   See Weyerhaeuser
Company v.  Costle, 590 F.2d  1011 (D.C. Cir. 1978).
                               115

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The methodology for calculating pollutant reduction benefits  and
plant compliance costs is discussed in Section X.  Tables X-2 and
X-3 show the pollutant reduction benefits for each treatment
option.  The current pollutant discharge and removal estimates
for the primary tungsten industry are shown in Table X-4.   Com-
pliance costs are presented in Table X-5.

BPT OPTION SELECTION

The technology basis for the BPT limitations is, Option A,
chemical precipitation and sedimentation technology to remove
metals and solids from combined wastewaters and to control  pH,
and ammonia steam stripping preliminary treatment to remove
ammonia.  These technologies are demonstrated and economically
achievable since they are already in place at both of the direct
dischargers in this subcategory.  The BPT treatment scheme  is
presented in Figure IX-1.

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 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
for each of the nine wastewater sources are discussed below and
summarized in Table IX-1.  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, or PNPs, are also listed in
Table IX-1.

Section V of this document 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-9.

TUNGSTIC ACID RINSE WATER

The BPT wastewater discharge rate for tungstic acid rinse water
is 47,600 1/kkg (11,400 gal/ton) of tungstic acid prodxaced.
This rate is allocated only for those plants which acid leach
ore concentrates and then rinse the insoluble tungstic acid with
water.  Water use and wastewater discharge rates are presented  in
Table V-l.  Two plants leach ore concentrates in this manner  and
generate 57,600 and 37,600 1/kkg.

A third plant generates a tungstic acid rinse water from an acid
leaching step, but this production normalized flow is much  larger
than the other flows in this subdivision and was not included in
                               116

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the calculations.  This stream  is  considered  unique  because  an
alkali leaching product, not ore concentrates,  are leached,  and
the tungstic acid produced is more thoroughly rinsed and  dryed  in
preparation for sale as a by-product.   Consequently,  the  BPT
flows were based on data from the  first two plants while  streams
like the third one mentioned above should be  considered unique
and regulated on a case-by-case basis.

ACID LEACH WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate  for acid leach  scrubber water
is 37,700 1/kkg (9,040 gal/ton) of tungstic acid  produced.   This
rate is allocated only for those plants which acid leach  ore con-
centrates and use a wet scrubbing  system to control  the fumes.
Two plants which treat ore concentrates in this manner use water
for emission control.  Water use and wastewater discharge rates
are presented in Table V-2.  One reports a once-through flow of
37,700 1/kkg while the second reports no generation  of wastewater
due to total recycle.  Extensive recycle may  be possible  for this
stream, but zero discharge may  not be technically feasible unless
(1) a recycycle system controls dissolved solids  build-up;  (2)
the wastewater is evaporated; or (3) there is a production opera-
tion which can accept the quality  of treated  wastewater.   Some of
these zero discharge possibilities are  site specific  and,  hence,
may not apply to all plants.  For  this  reason BPT flow is based
on the non-zero discharger flows only,  and in this case,  there is
only one non-zero discharger.

ALKALI LEACH WASH

The BPT wastewater discharge rate  for alkali  leach wash is 46,700
1/kkg (11,200 gal/ton) of sodium tungstate produced.  It  is  the
average of two plants generating wastewater.   This rate is allo-
cated only for those plants which  use an alkaline leaching step
to process ore concentrates followed by a filtering  or wash/
decant step.  Of the four plants which  alkali leach,  only two
report generating a wastewater, at rates of 10,700 1/kkg  and
82,600 1/kkg.  Water use and wastewater discharge rates are
presented in Table V-3.  The plant that generates 82,600  1/kkg
has achieved zero discharge status by pumping all its wastes to a
settling pond where the water can  evaporate or percolate  into the
ground.  Since this is feasible only because  the  plant is in a
net evaporation area, its flow  generation rate is still used in
the calculation of the regulatory  flow.  The  two  plants which
report zero discharge from the  alkali leaching step  are not  con-
sidered in the regulatory flow  since zero is  discharge feasible
in only a few site-specific applications as explained in  the
previous paragraph.
                               117

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ION-EXCHANGE RAFFINATE

The BPT wastewater discharge rate  for  ion-exchange  raffinate  is
51,200 1/kkg (12,300 gal/ton) of ammonium tungstate produced.
This rate is allocated only to those plants which use  a  liquid
ion-exchange process.  The two plants which do this generate
raffinate streams at flows of 29,800 1/kkg and 72,500  1/kkg.
Water use and wastewater discharge rates are presented in  Table
V-4.  These values were averaged to calculate the regulatory
flow.  The plant which generates the 72,500 1/kkg of wastewater
is a zero discharge plant, but this flow is still included in the
calculation since its ability to achieve zero discharge  through
an end-of-pipe treatment (evaporation and percolation  from a
settling pond) is site-specific.

CALCIUM TUNGSTATE PRECIPITATE WASH

The BPT wastewater discharge rate  for calcium tungstate  precipi-
tate washes is 37,200 1/kkg (8,920 gal/ton) of calcium tungstate
produced. This rate is allocated only to those plants which pre-
cipitate calcium tungstate from a  sodium tungstate  solution by
adding calcium chloride.  The filtrate or rinses of the  precipi-
tate make up this wastewater.  All four plants which precipitate
calcium tungstate report generating a wastewater, although the
data was insufficient to quantify  the flow from one plant.  Water
use and wastewater discharge rates are presented in Table  V-5.
The BPT flow rate is the average of the remaining three  flows,
which ranged from 21,000 1/kkg to  65,800 1/kkg.  The plant  inside
this range is actually a zero discharge plant, but  its flow
generation rate is still used in calculation since  its ability to
achieve zero discharge status is site-specific.

CRYSTALLIZATION AND DRYING OF AMMONIUM PARATUNGSTATE

No BPT wastewater discharge rate is provided for the crystalliza-
tion and drying of ammonium paratungstate.  Of the  four  plants
which crystallize and then dry ammonium paratungstate, three are
direct dischargers which have reduced the flow of this wastewater
to zero through a combination of reuse and recycle. The  fourth
plant is a zero discharge plant which pumps its wastes to  a
settling pond.   Water use and wastewater discharge  rates are
presented in Table V-6.  Since the plants in this category have
demonstrated the ability to reduce the flow of this stream to
zero, it is appropriate that the BPT regulatory flow should be
zero.

AMMONIUM PARATUNGSTATE CONVERSION TO OXIDES WET AIR POLLUTION
CONTROL

The BPT wastewater discharge rate  for the APT conversion to
oxides step is 20,900 1/kkg (5,010 gal/ton) of "blue" oxide
(W03) produced.  This rate is allocated only to those plants
                               118

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which calcine APT to  drive  off  ammonia  and  produce tungsten
oxides  (assumed  to be W03-)   Most  plants  use  a wet scrubbing
system  to contain the fumes,  and some use an  ammonia recovery
system.  Of the  six plants  which reported using this process and
generating a waste stream,  two  have  reduced this flow to zero
through combinations  of recycle, reuse, and evaporation.  These
two plants are not figured  into BPT  flow  calculations since zero
discharge is feasible in .only a few  site  specific applications.
Water use and wastewater discharge rates  are  presented in Table
V-7.  The flow rates  from the four direct and indirect dis-
chargers which were averaged  to develop the production normalized
BPT flow allowance range from 7,430  1/kkg to  36,800 1/kkg.

REDUCTION TO TUNGSTEN WET AIR POLLUTION CONTROL

The BPT wastewater discharge  rate  for reduction to tungsten metal
scrubber water is 73,200 1/kkg  (17,500 gal/ton) of tungsten pro-
duced.  This rate is  allocated  only  to those  plants which use a
wet air pollution control system to  control particulate emissions
from furnaces used to reduce  tungsten oxides  (WOX) to tungsten
metal.  Five of  the seven reporting  plants  that produce tungsten
metal in this manner use a  wet  scrubbing  system.   Water use and
wastewater discharge  rates  are  presented  in Table V-8.   Two of
these five claim to have reduced this flow  to zero through 100
percent recycle.  Extensive recycle  is demonstrated for this
stream, but a zero discharge  may not be technically feasible
unless  (1) a recycle  system controls dissolved solids build-up;
(2) the waste- water  is evaporated;  or  (3)  there is a production
operation which  can accept  the  quality of the treated wastewater.
Some of these zero discharge  possibilities  are site-specific and,
hence, are not applicable on  a  nationwide basis.   For this
reason, BPT flow is based on  the non-zero discharger flows  only.
Of the three dischargers, one had  a  flow  which was six times
greater than the others and,  since there  is no technical basis
for this, it was not  considered when the  two  other flows,  at
80,500 1/kkg and 65,900 1/kkg,  were  averaged.

REDUCTION TO TUNGSTEN WATER OF  FORMATION

The BPT wastewater discharge  rate  for water of formation from the
reduction of tungsten oxides  is 19,400 1/kkg  (4,650 gal/ton) of
tungsten produced.  Of the  seven plants which reduce tungsten
oxides to tungsten metal, only  two report wastewaters that  are
not associated with wet air pollution control devices or non-
contact cooling.  Water use and wastewater  discharge rates  are
presented in Table V-9.   Water  of  formation is generated when
WOX is reduced to tungsten metal in  a hydrogen atmosphere.   The
BPT wastewater discharge rate is based on the discharge rate of
one of the plants.  The other plant  does  not  discharge this
wastewater and was not considered  in calculating  the discharge
allowance.
                               119

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In plants which use wet scrubbing systems, this water of forma-
tion is most likely vaporized upon formation and then recondensed
in the scrubber system.  Consequently, plants with wet scrubbing
systems on their reduction furnaces do not report a separate
water of formation waste stream.  For this reason, this BPT flow
rate should be allocated only to those plants which reduce oxides
to metal, but do not use a wet air pollution control system.

REGULATED POLLUTANT PARAMETERS

The raw wastewater concentrations from individual operations and
the subcategory as a whole were examined to select certain pollu-
tant parameters for limitation.  This examination and evaluation
was presented in Section VI.  A total of six pollutants or pollu-
tant parameters are selected for limitation under BPT and are
listed below:

     122.  lead
     125.  selenium
     128.  zinc
           ammonia
           TSS
           PH

EFFLUENT LIMITATIONS

The treatable concentrations achievable by application of the
proposed BPT are discussed in Section VII of the General Develop-
ment Document and summarized there in Table VII-19.  These treat-
able 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 metric ton of
product represent the BPT effluent limitations and are presented
in Table IX-2 for each individual waste stream.
                               120

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                            Table  IX-1

              BPT WASTEWATER  DISCHARGE RATES  FOR  THE
                   PRIMARY TUNGSTEN  SUBCATEGORY
Wastewater Stream
 BPT Normalized
 Discharge Rate
1/kkggal/ton
          Production
         Normalization
           Parameter
Tungstic Acid
  Rinse Water
47,600   11,400
         Tungstic acid
         produced
Acid Leach Wet Air
  Pollution Control    37,700     9,040
                       Tungstic acid
                       produced
Alkali Leach
  Wash
46,700   11,200
         Sodium tungstate
         produced
Ion-Exchange
  Raffinate
51,200   12,300
         Ammonium tungstate
         produced
Calcium Tungstate
  Precipitate Wash
37,200    8,920
         Calcium tungstate
         produced
Crystallization
  and Drying of
  Ammonium Para-
  tungstate

Ammonium Paratung-
  state Conversion
  to Oxides Wet
  Air Pollution
  Control

Reduction to
  Tungsten
  Air Pollu-
  tion Control

Reduction to
  Tungsten
  Water of
  Formation
     0
0
20,900    5,010
73,200   17,500
         "Blue" oxide
          produced
         Tungsten metal
         produced
                       Tungsten metal
                       produced
19,400    4,650
                               121

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                            Table IX-2

                 BPT EFFLUENT LIMITATIONS FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
                       Tungstic Acid Rinse

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   7,140.0         6,188.0
Selenium                              58,548.0        26,180.0
Zinc                                  63,308.0        26,656.0
Ammonia (as N)                     6,330,800.0     2,789,360.0
TSS                                1,951,600.0       952,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
               Acid Leach Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   5,655.0         4,901.0
Selenium                              46,371.0        20,735.0
Zinc                                  50,141.0        21,112.0
Ammonia (as N)                     5,014,100.0     2,209,220.0
TSS                                1,545,700.0       754,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                        Alkali Leach Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   7,005.0         6,071.0
Selenium                              57,441.0        25,685.0
Zinc                                  62,111.0        26,152.0
Ammonia (as N)                     6,211,100.0     2,736,620.0
TSS                                1,914,700.0       934,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

                               122

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                      Table IX-2 (Continued)

                 BPT EFFLUENT LIMITATIONS FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
                      Ion-Exchange Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   7,680.0         6,656.0
Selenium                              62,976.0        28,160.0
Zinc                                  68,096.0        28,672.0
Ammonia (as N)                     6,809,600.0     3,000,320.0
TSS                                2,099,200.0     1,024,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                Calcium Tungstate Precipitate Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   5,580.0         4,836.0
Selenium                              45,756.0        20,460.0
Zinc                                  49,476.0        20,832.0
Ammonia (as N)                     4,947,600.0     2,179,920.0
TSS                                1,525,200.0       744,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               123

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                      Table IX-2 (Continued)

                 BPT EFFLUENT LIMITATIONS FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY


       Crystallization and Drying of Ammonium Paratungstate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             DO
TSS                                        0               0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                Ammonium Paratungstate Conversion to
                  Oxides Wet Air Pollution Control
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide (WOO produced
English Units - Ibs/billion Ibs of "blue" oxide (W03> produced

Lead                                   3,135.0         2,717.0
Selenium                              25,707.0        11,495.0
Zinc                                  27,797.0        11,704.0
Ammonia (as N)                     2,779,700.0     1,224,740.0
TSS                                  856,900.0       418,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               124

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                      Table IX-2  (Continued)

                 BPT EFFLUENT LIMITATIONS FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
         Reduction to Tungsten Vet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                  10,980.0         9,516.0
Selenium                              90,036.0        40,260.0
Zinc                                  97,356.0        40,992.0
Ammonia (as N)                     9,735,600.0     4,289,520.0
TSS                                3,001,200.0     1,464,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
             Reduction to Tungsten Water of Formation

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   2,910.0         2,522.0
Selenium                              23,862.0        10,670.0
Zinc                                  25,802.0        10,864.0
Ammonia (as N)                     2,580,200.0     1,136,840.0
TSS                                  795,400.0       388,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               L25

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                    PRIMARY TUNGSTEN SUBCATEGORY

                             SECTION X

        BEST AVAILABLE  TECHNOLOGY  ECONOMICALLY ACHIEVABLE


The effluent limitations which  must be  achieved by July 1,  1984
are based  on the best control and  treatment  technology used by a
specific point  source within the industrial  category  or subcate-
gory, or by another industry where it is  readily 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).  At a minimum,  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 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  effluent  reduction benefits
(see Weyerhaeuser v. Costie, 11 ERG 2149  (D.C.  Cir. 1978)).
However,in assessing the  proposed BAT, the  Agency has given
substantial weight  to the  economic achievability  of the
technology.

TECHNICAL  APPROACH  TO BAT

In pursuing this second round of effluent limitations,  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 five technology
options which could be applied  to  the primary  tungsten subcate-
gory 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
                               127

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effectiveness achievable with the more sophisticated BAT
treatment technology and reductions in the effluent flows
allocated to various waste streams.

The treatment technologies considered for BAT are summarized
below:

Option A (Figure X-l) is based on:

o  Preliminary treatment with ammonia steam stripping
   (where required)
o  Lime precipitation and sedimentation

Option B (Figure X-2) is based on:

o  Preliminary treatment with ammonia steam stripping
   (where required)
o  Lime precipitation and sedimentation
o  In-process flow reduction of acid leach and reduction
   to tungsten scrubber liquor

Option C (Figure X-3) is based on:

o  Preliminary treatment with ammonia steam stripping
   (where required)
o  Lime precipitation and sedimentation
o  In-process flow reduction of acid leach and reduction
   to tungsten scrubber liquor
o  Multimedia filtration

Option E (Figure X-4) is based on:

o  Preliminary treatment with ammonia steam stripping
   (where required)
o  Lime precipitation and sedimentation
o  In-process flow reduction of acid leach and reduction
   to tungsten scrubber liquor
o  Multimedia filtration
o  Activated carbon adsorption

Option F (Figure X-5) is based on:

o  Preliminary treatment with ammonia steam stripping
   (where required)
o  Lime precipitation and sedimentation
o  In-process flow reduction of acid leach and reduction
   to tungsten scrubber liquor
o  Multimedia filtration
o  Reverse osmosis in conjunction with multiple-effect
   evaporation
                               128

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The five options examined for BAT are discussed  in  greater  detail
on the following pages.  The first option considered  (Option A)
is the same as the BPT treatment and control  technology which was
presented in the previous section.  The last  four options each
represent substantial progress toward the reduction of pollutant
discharges above and beyond the progress achievable by BPT.

OPTION A

Option A for the primary tungsten subcategory is equivalent to
the control and treatment technologies which  were analyzed  for
BPT in Section IX  (see Figure X-l).  The BPT  end-of-pipe treat-
ment scheme includes lime precipitation and sedimentation,  with
ammonia steam stripping  preliminary treatment of wastewaters
containing treatable concentrations of ammonia  (see Figure  IX-1).
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 primary tungsten subcategory achieves lower
pollutant discharge by building upon the Option A end-of-pipe
treatment technology.  Flow reduction measures are  added to the
Option A treatment scheme which consists of lime precipitation
and sedimentation, with ammonia steam stripping  preliminary
treatment of the wastewaters containing treatable concentrations
of ammonia (see Figure X-2).  These flow reduction  measures,
including in-process changes, result in the elimination of  some
wastewater streams and the concentration of pollutants in other
effluents.  As explained in Section VII of the General
Development Document, treatment of a more concentrated effluent
allows achievement of a greater net pollutant removal and intro-
duces the possible economic benefits associated with  treating a
lower volume of wastewater.

The method used in Option B to reduce process wastewater genera-
tion and discharge rates is recycle of water  used in  wet air
pollution control.  There are two wet air pollution control
wastewater sources regulated under these effluent limitations for
which recycle is considered feasible:

        Acid leach wet air pollution control, and
        Reduction to metal wet air pollution  control.

Table X-l presents the number of plants reporting wastewater use
with these sources, the number of plants practicing recycle of
scrubber liquor, and the range of recycle values being used.
Although three plants report total recycle of their scrubber
water, some blowdown or periodic cleaning is  likely to be needed
to prevent the buildup of dissolved and suspended solids since
the water picks up particulates and fumes from the  air.
                               129

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Reduction of flow through recycle or reuse represents  the  best
available technology economically achievable  for these  streams.
Acid leaching scrubber water may be reused in the  scrubber with
periodic blowdown or as rinse water for insoluble  tungstic acid.
Scrubber water from wet air pollution control systems  on furnaces
which reduce tungsten oxides to metal may also be  recycled
through the scrubber with periodic blowdown as several  plants
have demonstrated.

OPTION C

Option C for the primary tungsten subcategory consists  of  all
control and treatment requirements of Option  B (flow reduction,
ammonia steam stripping, lime precipitation and sedimentation)
plus multimedia filtration technology added at the end  of  the
Option B treatment scheme (see Figure X-3).   Multimedia filtra-
tion is used to remove suspended solids, including precipitates
of toxic metals, beyond the concentrations 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.

OPTION E

Option E for the primary tungsten subcategory consists  of  all the
control and treatment requirements of Option  C (flow reduction,
ammonia steam stripping, lime precipitation,  sedimentation,  and
multimedia filtration) with the addition of granular activated
carbon technology at the end of the Option C  treatment  scheme
(see Figure X-4).  The activated carbon process is provided  to
control the discharge of toxic organics.

OPTION F

Option F for the primary tungsten subcategory consists  of  reverse
osmosis and multiple-effect evaporation technology and  complete
recycle added at the end of the Option C (flow reduction,  ammonia
steam stripping, lime precipitation, sedimentation, and multi-
media filtration) treatment scheme (see Figure X-5).  Reverse
osmosis controls dissolved solids to the point where total
recycle, and thus zero discharge, is feasible.  The multiple-
effect evaporation technology is used to dewater the brines
rejected from reverse osmosis.

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

As one means of evaluating each technology option, EPA  developed
estimates of the pollutant reduction benefits  and  the compliance
costs associated with each option.  The methodologies are
described below.
                               130

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POLLUTANT REDUCTION BENEFITS

A complete description of  the methodology used  to  calculate  the
estimated pollutant reduction, or benefit,  achieved  by  the appli-
cation of the various treatment  options  is  presented in Section  X
of the General Development Document.   In short,  sampling data
collected during the field sampling program were used to charac-
terize the major waste streams considered for regulation.  At
each sampled facility, the sampling data was production normal-
ized 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  tungsten  subcategory.   By  multiply-
ing the total subcategory  production for a  unit  operation times
the corresponding raw waste value, the mass of pollutant gener-
ated for that unit operation was estimated.

The volume of wastewater discharged after the application of each
treatment option was estimated by multiplying the  regulatory flow
determined for each unit process by the total subcategory produc-
tion.  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  dis-
charged by the subcategory.  The mass  of pollutant removed,
referred to as the benefit, is simply  the difference between the
estimated mass of pollutant generated within the subcategory and
the mass of pollutant discharged after application of the treat-
ment option.

The Agency varied this procedure slightly in computing  estimated
BPT discharge in a subcategory where there  is an existing BPT
limitation.  In this case, EPA took the mass limits  from the BPT
limitations (for all pollutants  limited at  BPT)  and  multiplied
these limits by the total subcategory production (from  dcp).
(The assumption is that plants are discharging a volume equal to
their BPT allowance times their production.) Where  pollutants
are not controlled by existing BPT, EPA used the achievable  con-
centration for the associated technology proposed today,  and
multiplied these concentrations by the total end-of-pipe dis-
charge of process wastewater for the subcategory (from  dcp).  The
total of both these calculations represents estimated mass load-
ings for the subcategory.  The pollutant reduction benefit esti-
mates for direct discharges in the primary  tungsten  subcategory
are presented in Table X-2.  Pollutant reduction benefit esti-
mates for indirect dischargers are shown in Section  XII.

COMPLIANCE COSTS

In estimating subcategory-wide compliance costs, the  first step
was to develop uniformly applicable cost curves, relating the
                               131

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total costs associated with installation and operation of waste-
water treatment technologies to plant process wastewater dis-
charge.  EPA applied these curves on a per plant basis, a plant's
costs—both capital, and operating and maintenance—being deter-
mined 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 cost
of compliance for the subcategory.  The compliance costs asso-
ciated with the various options are presented in Table X-3 for
direct discharges in the primary tungsten subcategory.  Compli-
ance cost for indirect discharges are shown in Section XII. These
costs were used in assessing economic achievability.

BAT OPTION SELECTION

EPA has selected Option C which includes flow reduction, lime
precipitation, sedimentation, and multimedia filtration, with
ammonia steam stripping preliminary treatment of wastewaters
containing treatable concentrations of ammonia.  The estimated
capital cost of proposed BAT is 447,000 dollars (1978 dollars)
and the annual cost is 193,000 dollars (1978 dollars).  The
end-of-pipe treatment configuration for Option C is presented in
Figure X-3.

EPA is proposing multimedia filtration as part of the BAT techno-
logy because this technology is demonstrated in the subcategory
(three of eight plants, and both direct dischargers presently
have filters) and results in additional removal of toxic metals.
In addition, filtration adds reliability to the treatment system
by making it less susceptible to operator error and to sudden
changes in raw wastewater flow and concentrations.

Ammonia steam stripping is demonstrated in the nonferrous metals
manufacturing category.  Four plants in the primary tungsten
subcategory have steam stripping in-place.  EPA believes that
performance data from the iron and steel manufacturing category
provide a valid measure of this technology's performance on non-
ferrous metals manufacturing category wastewater because raw
wastewater concentrations of ammonia are of the same order of
magnitude in the respective raw wastewater matrices.

Chemical analysis data were collected of raw waste (treatment
influent) and treated waste (treatment effluent) from one coke
plant of the iron and steel manufacturing category.  A contractor
for EPA, using EPA sampling and chemical analysis protocols,
collected six paired samples in a two-month period.  These data
are the data base for determining the effectiveness of ammonia
steam strippinng technology and are contained within the public
record supporting this document.  Ammonia treatment at this coke
plant consisted of two steam stripping columns in series with
                               132

-------
steam injected countercurrently  to  the  flow  of  the  wastewater.   A
lime reactor for pH adjustment separated  the two  stripping
columns.

The raw untreated wastewater  samples  from the coke  facility
contained ammonia concentrations of 599,  226, 819,  502,  984,  and
797 mg/1.  Raw untreated wastewater samples  from  the  primary
tungsten subcategory contained ammonia  concentrations  of 695  and
1,610 mg/1.

Implementation of the control and treatment  technologyies of
Option C would remove annually an estimated  3,689 kilograms of
toxic metal pollutants, which is 127 kilograms  of toxic  metal
pollutants over the estimated BPT removal.   The ammonia  steam
stripping technology of Option C would  remove annually an
estimated 741,470 kilograms of ammonia.

Activated carbon technology (Option E)  was also considered,
however this technology is not necessary  since  toxic  organic
pollutants are not limited in this  subcategory  (see discussion  on
Regulated Pollutant Parameters at the end of this section).

Reverse osmosis and multiple-effect evaporation (Option  F) was
considered for the purpose of achieving zero discharge of process
wastewater; however, the Agency ultimately rejected this technol-
ogy because it was determined that  its  performance  for this
specific purpose was not adequately demonstrated  in this category
nor was it clearly transferable  from another category.

WASTEWATER DISCHARGE RATES

A BAT discharge rate was calculated for each subdivision based
upon the flows of the existing plants,  as determined  from analy-
sis of the data collection portfolios.  The  discharge  rate is
used with the achievable treatment  concentrations to  determine
BAT effluent limitations.  Since the discharge  rate may  be
different for each wastewater source, separate  production normal-
ized discharge rates for each of the nine wastewater  sources  were
determined and are summarized in Table  X-4.   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, or PNPs,
are also listed in Table X-4.

The BAT discharge rates reflect the flow  reduction  requirements
of the selected BAT option.  For this reason, the two  scrubber
waters which were targeted for flow reduction through  recycle for
BAT have lower flow rates than the  corresponding  BPT  flows.
Since several plants have demonstrated  sufficient ability to
achieve substantial recycle of these two  wastewaters,  lower flow
                               133

-------
allowances for these streams represent the best available  tech-
nolgy economically achievable.

The BAT discharge rate for both acid leach scrubber water  and
reduction to metal scrubber water is based on 90 percent recycle
of the scrubber effluent (refer to Section VII of the General
Development Document).  Consequently, the BAT production normal-
ized discharge flow for acid leach wet air pollution control is
3,770 1/kkg (904 gal/ton) of tungstic acid produced.  This rate
should be allocated only to those plants which acid leach  ore
concentrates and use a wet air pollution control system to con-
trol fumes.  Similarly, the BAT discharge flow for reduction to
tungsten metal wet air pollution control is 9,400 1/kkg (2,253
gal/ton) of tungsten produced.  This rate is allocated only to
those plants which use a wet air pollution control system  to con-
trol particulate emissions from furnaces used to reduce tungsten
oxides (WOX) to tungsten metal.

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) (197677 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 limitation.  This examination and
evaluation was presented in Section VI.  The Agency, however, has
chosen not to regulate all 10 toxic pollutants selected in this
analysis.

The primary tungsten subcategory generates an estimated 8,340
kg/yr of toxic pollutants, of which only 70 kg/yr are toxic
organic pollutants.  The Agency believes that the toxic organic
pollutants in the primary tungsten subcategory are present only
in trace (deminimus quantities) and are neither causing nor
likely to cause toxic effects.  Therefore, the following toxic
organic pollutants are excluded from regulation:

       1.  acenaphthene
      55.  naphthalene
      77.  acenaphthylene
      80.  fluorene

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 proposing effluent mass
limitations only for those pollutants generated in the greatest
                               134

-------
quantities as shown by the pollutant reduction benefit  analysis.
The pollutants selected for specific limitation are  listed below:

     122.  lead
     125.  selenium
     128.  zinc
           ammonia  (as N)

Be establishing limitations and standards  for certain toxic  metal
pollutants, discharges 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 technically justified since the treatable con-
centrations used for lime precipitation and sedimentation tech-
nology are based on optimized treatment for concommitant  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 tech-
nology removes metals non-preferentially.

The toxic metal pollutants selected for specific limitation  in
the primary tungsten subcategory to control the discharges of
toxic metal pollutants are lead, selenium, and zinc.  Ammonia is
also selected for limitation since the methods used  to  control
lead, selenium, and zinc are not effective in the control of
ammonia.  The following toxic metal pollutants are excluded  from
limitation on the basis that they are effectively controlled by
the limitations developed for lead, selenium, and zinc:

     118.  cadmium
     119.  chromium (Total)
     127.  thallium

The conventional pollutant parameters TSS  and pH will be  limited
by the best conventional technology (BCT)  effluent limitations.
These effluent limitations and a discussion of BCT are presented
in Section XIII of this supplment.

EFFLUENT LIMITATIONS

The concentrations achievable by application of BAT  are discussed
in Section VII of the General Development  Document and  summarized
there in Table VII-19.  The treatable concentrations both one day
maximum and monthly average values are multiplied by the  BAT
normalized discharge flows summarized in Table X~4 to calculate
the mass of pollutants allowed to be discharged per  mass  of
product.  The results of these calculations in milligrams of
pollutant per metric ton of product represent the BAT effluent
limitations and are presented in Table X-5 for each waste stream.
                               135

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-------
                          Table X-3

                      COST OF COMPLIANCE
                           FOR THE
                 PRIMARY TUNGSTEN SUBCATEGORY

                      Direct Dischargers
                      Capital Cost             Annual Cost
Option               (1978 Dollars)           (1978 Dollars)

  A                            00

  B                      337,000                   55,000

  C                      447,000                  193,000

  E                    3,715,000                1,214,000

  F                    1,260,000                  389,000
                             139

-------
                            TABLE X-4

              BAT WASTEWATER DISCHARGE RATES FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
Wastewater Stream
                       BAT Normalized
                       Discharge Rate
1/kkj
gal/ton
  Production
 Normalization
   Parameter
Tungstic Acid
  Rinse Water
47,600   11,410
              Tungstic acid
              produced
Acid Leach Wet Air
  Pollution Control

Alkali Leach
  Wash
 3,770
   904
46,700   11,200
 Tungstic acid
 produced

 Sodium tungstate
 produced
Ion-exchange
  Raffinate
51,200   12,300
              Ammonium tungstate
              produced
Calcium Tungstate
  Precipitate Wash
37,200    8,920
              Calcium tungstate
              produced
Crystallization
  and Drying of
  Ammonium
  Paratungstate

Ammonium Paratung-
  state Conversion
  to Oxides Wet Air

Reduction to Tung-
  sten Wet Air
  Pollution Control

Reduction to
  Tungsten
  Water of
  Formation
     0



20,900



 9,400
     0



 5,010



 2,253
"Blue" oxide
 produced
 Tungsten metal
 produced
                       Tungsten metal
                       produced
19,400    4,650
                               140

-------
                            Table X-5

                 BAT EFFLUENT LIMITATIONS FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
                       Tungstic Acid Rinse

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0        17,612.0
Zinc                                  48,552.0        19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0


               Acid Leach Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,019.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0


                        Alkali Leach Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0
                               141

-------
                      Table X-5 (Continued)

                 BAT EFFLUENT LIMITATIONS FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
                      Ion Exchange Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0


                Calcium Tungstate Precipitate Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0


       Crystallization and Drying of Ammonium Paratungstate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00
                               142

-------
                      Table X-5  (Continued)

                 BAT EFFLUENT LIMITATIONS FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY


       Ammonium Paratungstate Conversion to Oxides Wet Air
       	Pollution Control	

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of  "blue" oxide (WOO produced
English Units - Ibs/billion Ibs  of "blue" oxide  (W03> produced

Lead                                   2,090.0         1,881.0
Selenium                              17,138.0         7,733.0
Zinc                                  21,318.0         8,778.0
Ammonia (as N)                     2,779,700.0     1,224,740.0


         Reduction to Tungsten Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0         3,478.0
Zinc                                   9,588.0         3,948.0
Ammonia (as N)                     1,250,200.0       550,840.0


             Reduction to Tungsten Water of Formation

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0         1,746.0
Selenium                              15,908.0         7,178.0
Zinc                                  19,788.0         8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0
                               143

-------
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-------
                   PRIMARY TUNGSTEN SUBCATEGORY

                            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  tech-
nology (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 techno-
logies which reduce pollution to the maximum extent feasible.

This section describes the technologies for treatment of waste-
water from new sources and presents mass discharge standards for
regulatory pollutants for NSPS in the primary tungsten  subcate-
gory, based on the selected treatment technology.

TECHNICAL APPROACH TO BDT

The best available demonstrated technology (BDT) for new source
performance standards is equivalent to the best available  tech-
nology (BAT) selected for currently existing primary tungsten
plants.  This result is a consequence of careful review by the
Agency of a wide range of technical options for new source treat-
ment systems which is discussed in Section XI of the General
Development Document.  This review of the primary tungsten
subcategory found no new, economically feasible, demonstrated
technologies which could be considered an improvement over those
chosen for consideration for BAT.  Additionally, there was
nothing found to indicate that the wastewater flows and char-
acteristics of new plants would not be similar to those from
existing plants, since the processes used by new sources are not
expected to differ from those used at existing sources.  Conse-
quently, BAT production normalized discharge rates, which  are
based on the best existing practices of the subcategory, can also
be applied to new sources.  These rates are presented in Table
XI-1.

Treatment technologies considered for the BDT options are
identical to the treatment technologies considered for  the BAT
options.   These options are:
OPTION A
        Preliminary treatment with ammonia steam stripping
        (where required)
        Lime precipitation and sedimentation
                               149

-------
OPTION B
     o
     o
Preliminary treatment with ammonia steam stripping
(where required)
Lime precipitation and sedimentation
In-process flow reduction of acid leach and reduction
to tungsten scrubber liquor
OPTION C
     o  Preliminary treatment with ammonia steam  stripping
        (where required)
     o  Lime precipitation and sedimentation
     o  In-process flow reduction of acid leach and reduction
        to tungsten scrubber liquor
     o  Multimedia filtration
OPTION E
     o  Preliminary treatment with ammonia steam stripping
        (where required)
     o  Lime precipitation and sedimentation
     o  In-process flow reduction of acid leach and reduction
        to tungsten scrubber liquor
     o  Multimedia filtration
     o  Activated carbon adsorption
OPTION F
     o  Preliminary treatment with ammonia steam stripping
        (where required)
     o  Lime precipitation and sedimentation
     o  In-process flow reduction of acid leach and reduction
        to tungsten scrubber liquor
     o  Multimedia filtration
     o  Reverse osmosis in conjunction with multiple-effect
        evaporation

BDT OPTION SELECTION

EPA is proposing that the best available demonstrated technology
for the primary tungsten subcategory be equivalent to Option C
(flow reduction, ammonia steam stripping, lime precipitation,
sedimentation, and multimedia filtration).  This technology is
demonstrated by three plants in the subcategory.

The wastewater flow rates for BDT are the same as the BAT flow
rates.  Further flow reduction measures for BDT are not  feasible,
because dry scrubbing is not demonstrated for controlling emis-
sions from acid leaching, APT conversion to oxides, and  tungsten
                               150

-------
reduction furnaces.  The nature  of  these  emissions  (acid fumes,
hot particulate matter) technically precludes  the use  of dry
scrubbers.  Therefore, EPA  is  including an  allowance  from this
source at BDT equivalent to  that proposed for  BAT.  EPA also does
not believe that new plants  could achieve any  additional flow
reduction beyond the 90 percent  scrubber  effluent recycle
proposed for BAT.

Activated carbon technology  (Option E) was  also  considered,  how-
ever this technology is not  necessary since toxic organic pollu-
tants are not limited in this  subcategory.   Reverse osmosis  in
conjunction with multiple-effect evaporation (Option F)  was
considered for the purpose  of  achieving zero discharge of process
wastewater; however, the Agency ultimately  rejected this technol-
ogy because it was determined  that  its performance  for this
specific purpose was not adequately demonstrated in this category
nor was it clearly transferable  from another category.

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
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 and  are shown in  Table  XI-1.   The
mass of pollutant allowed to be discharged  per mass of product is
calculated by multiplying the appropriate treatable concentration
(mg/1) by the production normalized wastewater discharge flows
(1/kkg).   The treatable concentrations are  listed in Table VII-19
of the General Development Document.  The results of these calcu-
lations are the production-based new source  performance  stand-
ards.   These standards are presented in Tables XI-2.
                               151

-------
                            TABLE XI-1

             NSPS WASTEWATER DISCHARGE RATES FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
Wastewater Stream
 BAT Normalized
 Discharge Rate
1/kkggal/ton
          Production
         Normalization
           Parameter
Tungstic Acid
  Rinse Water
47,600   11,410
         Tungstic acid
         produced
Acid Leach Wet Air
  Pollution Control    3,770      904
Alkali Leach
  Wash
46,700   11,200
         Tungstic acid
         produced

         Sodium tungstate
         produced
Ion-exchange
  Raffinate
51,200   12,300
         Ammonium tungstate
         produced
Calcium Tungstate
  Precipitate Wash
37,200    8,920
         Calcium tungstate
         produced
Crystallization
  and Drying of
  Ammonium
  Paratungstate

Ammonium Paratung-
  state Conversion
  to Oxides Wet Air

Reduction to Tung-
  sten Wet Air
  Pollution Control

Reduction to
  Tungsten
  Water of
  Formation
     0
0
20,900    5,010
 9,400    2,253
        "Blue" oxide
         produced
         Tungsten metal
         produced
                       Tungsten metal
                       produced
19,400    4,650
                               152

-------
                            Table XI-2

            NSPS FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                       Tungstic Acid Rinse

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0        17,612.0
Zinc                                  48,552.0        19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0
TSS                                  714,000.0       571,200.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


               Acid Leach Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,091.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0
TSS                                   56,550.0        45,240.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


                        Alkali Leach Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0
TSS                                  700,500.0       560,400.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

                               153

-------
                      Table XI-2 (Continued)

            NSPS FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                      Ion-Exchange Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0
TSS                                  768,000.0       614,400.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


                Calcium Tungstate Precipitate Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0
TSS                                  558,000.0       446,400.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


      Crystallization and Drying of Ammonium Paratungstate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00
TSS                                        0               0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               154

-------
                      Table XI-2  (Continued)

            NSPS FOR THE PRIMARY  TUNGSTEN SUBCATEGORY
                Ammonium Paratungstate Conversion
                   to Wet Air Pollution Control

                                   Maximum  for      Maximum  for
Pollutant or Pollutant Property    Any One  Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide  (WOO produced
English Units - Ibs/billion Ibs of "blue" oxide  (W03> produced

Lead                                   2,090.0          1,881.0
Selenium                              17,138.0          7,733.0
Zinc                                  21,318.0          8,778.0
Ammonia (as N)                     2,779,700.0     1,224,740.0
TSS                                  313,500.0       250,800.0
pH                                Within the  range of 7.5 to 10.0
                                            at all times
         Reduction to Tungsten Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0         3,478.0
Zinc                                   9,588.0         3,948.0
Ammonia (as N)                     1,250,200.0       550,840.0
TSS                                  141,000.0       112,800.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
             Reduction to Tungsten Water of Formation

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0         1,746.0
Selenium                              15,908.0         7,178.0
Zinc                                  19,788.0         8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0
TSS                                  291,000.0       232,800.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               155

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                   PRIMARY TUNGSTEN SUBCATEGORY

                           SECTION XII

                      PRETREATMENT STANDARDS


Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources  (PSES), which must be achieved
within three years of promulgation.  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 heavy 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 facili-
ties, 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 instal-
lation.  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 primary tungsten subcategory.  Pretreatment
standards for regulated pollutants are presented based on the
selected control and treatment  technology.

TECHNICAL APPROACH TO PRETREATMENT

Before proposing 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 percentage
removed nationwide by well-operated POTW meeting secondary
treatment requirements, is less than the percentage removed by
direct dischargers complying with BAT effluent limitations
guidelines for that pollutant.  (See generally, 46 FR at 9415-16
(January 28,  1981)).
                               157

-------
This definition of pass through satisfies two competing  objec-
tives set by Congress:  (1) that standards for indirect:  dis-
chargers be equivalent to standards for direct dischargers while
at the same time, (2) that the treatment capability and  perfor-
mance of the POTW be recognized and taken into account in regu-
lating 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 or the dilution of the
pollutants in the POTW effluent to lower concentrations  due to
the addition of large amounts of non-industrial wastewater.

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

The industry cost and pollutant reduction benefits of each treat-
ment option were used to determine the most cost-effective
option.  The methodology applied in calculating pollutant reduc-
tion benefits and plant compliance costs is discussed in Section
X.  Table XII-1 shows the estimated pollutant reduction  benefits
for indirect dischargers.   Compliance costs for indirect dis-
chargers are presented in Table XII-2.

PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES

Options for pretreatment of wastewaters from both existing and
new sources are based on increasing the effectiveness of end-of-
pipe treatment technologies.  All in-plant changes and applicable
end-of-pipe treatment processes have been discussed previously in
Sections X and XI.  The options for PSNS and PSES, therefore, are
the same as the BAT options discussed in Section X.

A description of each option is presented in Section X,  while a
more detailed discussion,  including pollutants controlled by each
treatment process is presented in Section VII of the General
Development Document.

Treatment technologies considered for the PSNS and PSES  options
are:

OPTION A

     o  Preliminary treatment with ammonia steam stripping
        (where required)
     o  Lime precipitation and sedimentation
                               158

-------
OPTION B
     o  Preliminary treatment with  ammonia  steam  stripping
        (where required)
     o  Lime precipitation and  sedimentation
     o  In-process flow reduction of  acid leach and  reduction
        to tungsten scrubber liquor
OPTION C

     o

     o
     o
Preliminary treatment with ammonia steam stripping
(where required)
Lime precipitation and sedimentation
In-process flow reduction of acid leach and reduction
to tungsten scrubber liquor
Multimedia filtration
OPTION E
     o  Preliminary treatment with ammonia  steam  stripping
        (where required)
     o  Lime precipitation and sedimentation
     o  In-process flow reduction of acid leach and  reduction
        to tungsten scrubber liquor
     o  Multimedia filtration
     o  Activated carbon adsorption
OPTION F
     o  Preliminary treatment with ammonia steam stripping
        (where required)
     o  Lime precipitation and sedimentation
     o  In-process flow reduction of acid leach and reduction
        to tungsten scrubber liquor
     o  Multimedia filtration
     o  Reverse osmosis in conjunction with multiple-effect
        evaporation

PSNS AND PSES OPTION SELECTION

Option C (flow reduction, ammonia steam stripping, lime precipi-
tation, sedimentation, and multimedia filtration) has been
selected as the regulatory approach for pretreatment standards
for new and existing sources (PSNS and PSES) on the basis that it
achieves effective removal of toxic pollutants at a reasonable
cost.  In addition, filtration is demonstrated in the subcategory
(including one of three indirect dischargers), and will not
result in adverse economic impacts.  The estimated capital cost
of proposed PSES is 396,000 dollars (1978 dollars) and the annual
cost is 329,000 dollars (1978 dollars).
                               159

-------
The wastewater discharge rates for both PSES and PSNS are  iden-
tical to the BAT discharge rates for each waste stream.  The PSES
and PSNS discharge rates are shown in Table XII-3.  No additional
flow reduction measures for PSNS are feasible because the  only
other flow reduction technology, reverse osmosis in conjunction
with multiple-effect evaporation, is not demonstrated, nor is it
clearly transferable for this subcategory.  Activated carbon
technology (Option E) was also considered however, this technol-
ogy is not necessary since toxic organic pollutants are not
limited in this subcategory.

Implementation of the proposed PSES will result in an estimated
annual removal of 4,075 kilograms of toxic pollutants.  Imple-
mentation of Option C will result in an estimated annual removal
of 79,500 kilograms of ammonia.

REGULATED POLLUTANT PARAMETERS

Pollutants selected for limitation, in accordance with the
rationale of Sections VI and X, are identical to those selected
for limitation for BAT.  It is necessary to propose PSES and PSNS
to prevent the pass-through of lead, selenium, zinc, and ammonia,
which are the limited pollutants.

PRETREATMENT STANDARDS

Pretreatment standards are based on the treatable concentrations
from the selected treatment technology, (Option C), and the
discharge rates determined in Section X for BAT.  A mass of
pollutant per mass of product (mg/kkg) allocation is given for
each subdivision within the subcategory.  This pollutant alloca-
tion is based on the product of the treatable concentration from
the proposed treatment (mg/1) and the production normalized
wastewater discharge rate (1/kkg).  The achievable treatment
concentrations for BAT are identical to those for PSES and PSNS.
These concentrations are listed in Tables XII-19 of the General
Development Document.  PSES and PSNS are presented in Tables
XII-4 and XII-5.
                               160

-------
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-------
                         Table XII-2

                      COST OF COMPLIANCE
                           FOR THE
                 PRIMARY TUNGSTEN SUBCATEGORY

                     Indirect Dischargers
                      Capital Cost             Annual Cost
Option               (1978 Dollars)           (1978 Dollars)

  A                      423,000                  200,000

  B                      572,000                  222,000

  C                      396,000                  329,000

  E                    1,290,000                1,270,000

  F                      498,000                  726,000
                            163

-------
                           TABLE XII-3

         PSES AND PSNS WASTEWATER DISCHARGE RATES FOR THE
                   PRIMARY TUNGSTEN SUBCATEGORY
Wastewater Stream
 BAT Normalized
 Discharge Rate
1/kkggal/ton
          Production
         Normalization
           Parameter
Tungstic Acid
  Rinse Water
47,600   11,410
         Tungstic acid
         produced
Acid Leach Wet Air
  Pollution Control    3,770      904

Alkali Leach
  Wash                46,700   11,200
                       Tungstic acid
                       produced

                       Sodium tungstate
                       produced
Ion-exchange
  Raffinate
51,200   12,300
         Ammonium tungstate
         produced
Calcium Tungstate
  Precipitate Wash
37,200    8,920
         Calcium tungstate
         produced
Crystallization
  and Drying of
  Ammonium
  Paratungstate

Ammonium Paratung-
  state Conversion
  to Oxides Wet Air

Reduction to Tung-
  sten Wet Air
  Pollution Control

Reduction to
  Tungsten
  Water of
  Formation
     0
0
20,900    5,010
 9,400    2,253
        "Blue" oxide
         produced
         Tungsten metal
         produced
                       Tungsten metal
                       produced
19,400    4,650
                               164

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                           Table XII-4

            PSES FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                       Tungstic Acid Rinse

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0        17,612.0
Zinc                                  48,552.0        19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0


               Acid Leach Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,901.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0


                        Alkali Leach Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0
                               165

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                     Table XII-4 (Continued)

            PSES FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                      Ion-Exchange Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0


                Calcium Tungstate Precipitate Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0


       Crystallization and Drying of Ammonium Paratungstate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             0               0
                               166

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                     Table XII-4  (Continued)

            PSES FOR THE PRIMARY  TUNGSTEN SUBCATEGORY
       Ammonium Paratungstate Conversion to Oxides Wet Air
       _ Pollution Control _

                                   Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide  (WCH) produced
English Units - Ibs/billion Ibs of "blue" oxide  (WOa) produced
Lead                                   2,090.0          1,881.0
Selenium                              17,138.0          7,733.0
Zinc                                  21,318.0          8,778.0
Ammonia  (as N)                     2,779,700.0     1,224,740.0


         Reduction to Tungsten Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0          3,478.0
Zinc                                   9,588.0          3,948.0
Ammonia  (as N)                     1,250,200.0       112,800.0


             Reduction to Tungsten Water of Formation

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0          1,746.0
Selenium                              15,908.0          7,178.0
Zinc                                  19,788.0          8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0
                               167

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                           Table XII-5

            PSNS FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                       Tungstic Acid Rinse

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                   4,760.0         4,284.0
Selenium                              39,032.0        17,612.0
Zinc                                  48,552.0        19,992.0
Ammonia (as N)                     6,330,800.0     2,789,360.0


               Acid Leach Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

Lead                                     377.0           339.30
Selenium                               3,091.40        1,394.90
Zinc                                   3,845.40        1,583.40
Ammonia (as N)                       501,410.0       220,922.0


                        Alkali Leach Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

Lead                                   4,670.0         4,203.0
Selenium                              38,294.0        17,279.0
Zinc                                  47,634.0        19,614.0
Ammonia (as N)                     6,211,100.0     2,736,620.0
                               168

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                     Table XII-5  (Continued)

            PSNS FOR THE PRIMARY  TUNGSTEN SUBCATEGORY


                      Ion-Exchange Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

Lead                                   5,120.0         4,608.0
Selenium                              41,984.0        18,944.0
Zinc                                  52,224.0        21,504.0
Ammonia (as N)                     6,809,600.0     3,000,320.0


                Calcium Tungstate Precipitate Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate produced

Lead                                   3,720.0         3,348.0
Selenium                              30,504.0        13,764.0
Zinc                                  37,944.0        15,624.0
Ammonia (as N)                     4,947,600.0     2,179,920.0


       Crystallization and Drying of Ammonium Paratungstate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

Lead                                       0               0
Selenium                                   0               0
Zinc                                       0               0
Ammonia (as N)                             00
                               169

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                     Table XII-5 (Continued)

            PSNS FOR THE PRIMARY TUNGSTEN SUBCATEGORY
                Ammonium Paratungstate Conversion
               To Oxides Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide (WOO produced
English Units - Ibs/billion Ibs of "blue" oxide (W03) produced

Lead                                   2,090.0         1,881.0
Selenium                              17,138.0         7,733.0
Zinc                                  21,318.0         8,778.0
Ammonia (as N)                     2,779,700.0     1,224,740.0


          Reduction to Tungsten Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

Lead                                     940.0           846.0
Selenium                               7,708.0         3,478.0
Zinc                                   9,588.0         3,948.0
Ammonia (as N)                     1,250,200.0       550,840.0


             Reduction to Tungsten Water of Formation

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

Lead                                   1,940.0         1,746.0
Selenium                              15,908.0         7,178.0
Zinc                                  19,788.0         8,148.0
Ammonia (as N)                     2,580,200.0     1,136,840.0
                               170

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                   PRIMARY TUNGSTEN  SUBCATEGORY

                           SECTION XIII

         BEST CONVENTIONAL POLLUTANT CONTROL  TECHNOLOGY


The 1977 amendments to the Clean Water Act  added  Section  301  (b)
(2)(E), establishing  "best conventional pollutant  control  tech-
nology" (BCT) for discharge of conventional pollutants from
existing industrial point sources.   Biochemical oxygen-demanding
pollutants  (8005), total suspended solids  (TSS),  fecal coli-
form, oil and grease  (OScG) , and pH have been  designated as
conventional pollutants  (see 44 FR 44501).

BCT is not  an additional limitation,  but replaces  BAT for  the
control of  conventional pollutants.   In addition  to  the other
factors specified in  Section 304(b)(4)(B),  the  Act requires that
limitations for conventional pollutants be  assessed  in light of a
two-part cost-reasonableness test.   On October  29, 1982,  the
Agency proposed a revised methodology for  carrying out BCT
analyses (47 FR 49176).  The purpose  of the proposal was  to
correct errors in the BCT methodology originally  established in
1977.

Part 1 of the proposed BCT test requires that the  cost and  level
of reduction of conventional pollutants by  industrial dischargers
be compared with the  cost and level  of reduction  to  remove  the
same type of pollutants by publicly-owned  treatment  works  (POTW).
The POTW comparison figure has been  calculated  by  evaluating the
change in costs and removals between  secondary  treatment  (30 mg/1
BOD and 30 mg/1 TSS)  and advanced secondary treatment (10 mg/1
BOD and 10 mg/1 TSS).  The difference in cost is  divided by the
difference  in pounds  of conventional  pollutants removed, resul-
ting in an estimate of the "dollars  per pound"  of  pollutant
removed, that is used as a benchmark  value.   The proposed POTW
test benchmark is $0.30 per pound (1978 dollars).

Part 2 of the BCT test requires that  the cost and  level of  reduc-
tion of conventional pollutants by industrial dischargers be
evaluated internally  to the industry.  In  order to develop  a
benchmark that assesses a reasonable  relationship  between cost
and removal, EPA has  developed an industry  cost ratio which
compares the dollar per pound of conventional pollutant removed
in going from primary to secondary treatment  levels with that of
going from secondary to more advanced treatment levels.  The
basis of costs for the calculation of this  ratio are the costs
incurred by a POTW.   EPA used these costs because:   they reflect
the treatment technologies most commonly used to remove conven-
tional pollutants from wastewater; the treatment levels associ-
ated with them compare readily to the  levels  considered for
                               171

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industrial dischargers; and the costs are the most reliable  for
the treatment levels under consideration.  The proposed industry
subcategory benchmark is 1.42.  If the industry figure for a
subcategory is lower than 1.43, the subcategory passes the BCT
test.

The Agency usually considers two conventional pollutants in  the
cost test, TSS and an oxygen-demanding pollutant.  Although both
oil and grease and BOD5 are considered to be oxygen-demanding
substances by EPA (see 44 FR 50733), only one can be selected in
the cost analysis to conform to procedures used to develop POTW
costs.  Oil and grease is used rather than BOD5 in the cost
analysis performed for nonferrous metals manufacturing waste
streams due to the common use of oils in casting operations  in
this industry.

BPT is the base for evaluating limitations on conventional
pollutants (i.e., it is assumed that BPT is already in place).
The test evaluates the cost and removals associated with
treatment and controls in addition to that specified as BPT.

If the conventional pollutant removal cost of the candidate BCT
is less than the POTW cost, Part 1 of the cost-reasonableness
test is passed and Part 2 (the internal industry test) of the
cost-reasonableness test must be performed.  If the internal
industry test is passed, then a BCT limitation is promulgated
equivalent to the candidate BCT level.  If all candidate BCT
technologies fail both parts of the cost-reasonableness test, the
BCT requirements for conventional pollutants are equal to BPT.

The BCT test was performed for the proposed BAT basis of ammonia
steam stripping, lime precipitation, sedimentation, in-process
flow reduction, and multimedia filtration.  The primary tungsten
subcategory failed Part 1 of the test with a calculated cost of
$15.04 per pound (1978 dollars) of removal of conventional pollu-
tants using BAT technology.  The intermediate flow reduction
option was also examined, but it too failed with a cost of $19.73
per pound (1978 dollars) of conventional removal.
                               172

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                           Table XIII-1

   BCT EFFLUENT LIMITATIONS FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                       Tungstic Acid Rinse

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

TSS                                1,951,600.0       952,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times


               Acid Leach Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of tungstic acid produced
    English Units - Ibs/billion Ibs of tungstic acid produced

TSS                                1,545,700.0       754,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times


                        Alkali Leach Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

        Metric Units - mg/kkg of sodium tungstate produced
   English Units - Ibs/billion Ibs of sodium tungstate produced

TSS                                1,914,700.0       934,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times
                               173

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                     Table XIII-1 (Continued)

   BCT EFFLUENT LIMITATIONS FOR THE PRIMARY TUNGSTEN SUBCATEGORY


                      Ion-Exchange Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of ammonium tungstate produced
  English Units - Ibs/billion Ibs of ammonium tungstate produced

TSS                                2,099,200.0     1,024,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all  times


                Calcium Tungstate Precipitate Wash

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of calcium tungstate produced
  English Units - Ibs/billion Ibs of calcium tungstate  produced

TSS                                1,525,200.0       744,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all  times


       Crystallization and Drying of Ammonium Paratungstate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

     Metric Units - mg/kkg of ammonium paratungstate produced
    English Units - Ibs/billion Ibs of ammonium paratungstate
                             produced

TSS                                        0               0
pH                               Within the range of 7.5 to 10.0
                                          at all  times
                               174

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                     Table XIII-l (Continued)

  BCT EFFLUENT LIMITATIONS FOR THE PRIMARY TUNGSTEN SUBCATEGORY
               Ammonium Paratungstate Conversion to
                 Oxides Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of "blue" oxide (W03> produced
English Units - Ibs/billion Ibs of "blue" oxide (W03> produced

TSS                                  856,900.0       418,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times
         Reduction to Tungsten Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten produced
       English Units - Ibs/billion Ibs of tungsten produced

TSS                                3,001,200.0     1,464,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times
             Reduction to Tungsten Water of Formation

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of tungsten reduced
       English Units - Ibs/billion Ibs of tungsten reduced

TSS                                  795,400.0       388,000.0
pH                               Within the range of 7.5 to 10.0
                                          at all times
                               175

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              PRIMARY COLUMBIUM-TANTALUM  SUBCATEGORY

                            SECTION  I

                     SUMMARY AND CONCLUSIONS


Pursuant to Sections 301, 304, 306,  307,  and  501 of the  Clean
Water Act and the provisions of the  Settlement Agreement in
Natural Resources Defense Council v. Train, 8 ERC  2120  (D.D.C.
1976) modified, 12 ERG 1833 (D.D.C.  1979), EPA has collected and
analyzed data for plants in the primary columbium-tantalum sub-
category.  EPA has never proposed or promulgated effluent limita-
tions or standards for this subcategory.  This document  and the
administrative record provide the technical basis  for proposing
effluent limitations based on best practicable technology (BPT)
and best available technology (BAT)  for direct dischargers,
pretreatment standards for indirect  dischargers  (PSES),  pretreat-
ment standards for new indirect dischargers (PSNS), and  standards
of performance for new source direct dischargers (NSPS).

The primary columbium-tantalum subcategory is comprised  of five
plants.  Of the five plants, three discharge  directly to rivers,
lakes, or streams; two discharge to  publicly  owned treatment
works (POTW); and none achieve zero  discharge of process
wastewater.

EPA first studied the primary columbium-tantalum subcategory to
determine whether differences in raw materials,  final products,
manufacturing processes, equipment,  age and size of plants, and
water usage, required the development of  separate  effluent limi-
tations 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  employed, and  the sources of
pollutants and wastewaters in the plant;  and  (2) the constituents
of wastewaters, including toxic pollutants.

EPA also identified several distinct control  and treatment tech-
nologies (both in-plant and end-of-pipe)  applicable to the pri-
mary columbium-tantalum subcategory.  The Agency analyzed both
historical and newly generated data  on the performance of these
technologies, including their nonwater quality environmental
impacts (air quality and 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 imple-
menting the various options on the industry.  For each control
                               177

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and treatment option that the Agency found to be most effective
and technically feasible in controlling the discharge of pollu-
tants, the number of potential closures, number of 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 Nonfer-
rous Smelting and Refining Industry.

Based on consideration of the above factors, EPA identified vari-
ous control and treatment technologies which formed the basis for
BPT and selected control and treatment appropriate for each set
of standards and limitations.  The mass limitations and standards
for BPT, BAT, NSPS, PSES, PSNS, and BCT are presented in Section
II.

After examining the various treatment technologies, the Agency
has identified BPT to represent the average of the best existing
technology.  Metals removal based on lime precipitation and
sedimentation technology is the basis for the BPT limitations.
Steam stripping is selected as the technology basis for ammonia
limitations.  To meet the BPT effluent limitations based on this
technology, the primary columbium-tantalum subcategory is not
expected to incur any costs.

For BAT, the Agency has built upon the BPT basis by adding
in-process control technologies which include recycle of process
water from air pollution control and metal contact cooling waste
streams.  Filtration is added as an effluent polishing step to
the end-of-pipe treatment scheme.  To meet the BAT effluent
limitations based on this technology, the primary columbium-
tantalum subcategory is estimated to incur a capital cost of
$0.797 million and an annual cost of $0.396 million.

The best demonstrated technology (BDT), which is the technical
basis of NSPS, is equivalent to BAT.  In selecting BDT, EPA
recognizes 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.

The Agency selected the same technology as BAT for PSES.  To meet
the pretreatment standards for existing sources, the primary
columbium-tantalum subcategory is estimated to incur a capital
cost of $2.47 million and an annual cost of $1.41 million.  For
PSNS, the Agency selected end-of-pipe treatment and in-process
flow reduction control techniques equivalent to NSPS.

The best conventional technology (BCT) replaces BAT for the
control of conventional pollutants.  The technology basis of BCT
is the BPT treatment of lime precipitation and sedimentation.
                               178

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 1.
 2.
         PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                       SECTION II

                    RECOMMENDATIONS

EPA has divided the primary columbium-tantalum subcategory
into eight subdivisions for the purpose of effluent limi-
tations and standards.  These subdivisions are:
     (a)
     (b)

     IS!
     (e)
     (f)
     (g)

     (h)
     Concentrate digestion wet air pollution control,
     Solvent extraction raffinate,
     Solvent extraction wet air pollution control,
     Precipitation and filtration of metal salts,
     Metal salt drying wet air pollution control,
     Reduction of salt to metal,
     Reduction of salt to metal wet air pollution control,
     and
     Consolidation and casting contact cooling.
BPT is proposed based on the effluent concentrations
achievable by the application of chemical precipitation and
sedimentation (lime and settle) technology, along with pre-
liminary treatment consisting of ammonia steam stripping for
selected waste streams.  The following BPT effluent limita-
tions are proposed:

(a)  Concentrate Digestion Wet Air Pollution Control
     BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
                              Maximum for
                              Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of columbium-tantalum salt produced
                          from digestion
    English Units - Ibs/billion Ibs of columbium-tantalum salt
                     produced from digestion
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
                                 1,637.25
                                14,516.95
                             1,451,695.0
                               649,442.50
                               447,515.0
    1,418.95
    6,112.40
  639,619.0
  288,156.0
  218,300.0
                             Within the range of 7.5 to 10.0
                                      at all times
                               179

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     (b)  Solvent Extraction Raffinate
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
     4,037.40
    35,798.28
 3,579,828.0
 1,601,502.0
 1,103,556.0
     3,499.08
    15,072.96
 1,577,277.60
   710,582.40
   538,320.0
 Within the range of 7.5 to 10.0
          at all times
     (c)  Solvent Extraction Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
       645.21
     5,720.86
   572,086.20
   255,933.30
   176,357.40
       559.18
     2,408.78
   252,062.04
   113,556.96
    86,028.0
 Within the range of 7.5 to 10.0
          at all times
     (d)  Precipitation and Filtration of Metal Salts
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    37,083.45
   328,806.59
32,880,659.0
14,709,768.50
10,136,143.0
    32,138.99
   138,444.88
14,487,267.80
 6,526,687.20
 4,944,460.0
 Within the range of 7.5 to 10.0
          at all times
                               180

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     (e)  Metal Salt Drying Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
  Maximum for      Maximum for
  Any One Day    Monthly Average
    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    12,546.45
   111,245.19
11,124,519.0
 4,976,758.50
 3,429,363.0
    10,873.59
    46,840.08
 4,901,479.80
 2,208,175.20
 1,672,860.0
 Within the range of 7.5 to 10.0
          at all times
     (f)  Reduction of Salt to Metal
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    52,899.45
   469,041.79
46,904,179.0
20,983,448.50
14,459,183.0
    45,846.19
   197,491.28
20,666,051.80
 9,310,303.20
 7,053,260.0
 Within the range of 7.5 to 10.0
          at all times
     (g)  Reduction of Salt to Metal Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
     3,228.15
    28,622.93
 2,862,293.0
 1,280,499.50
   882,361.0
     2,797.73
    12,051.76
 1,261,130.60
   568,154.40
   430,420.0
 Within the range of 7.5 to 10.0
          at all times
                               181

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     (h)  Consolidation and Casting Contact Cooling
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
        0
        0
        0
        0
        0
         0
         0
         0
         0
         0
Within the range of 7.5 to 10.0
         at all times
 3.  BAT is proposed based on the treatability concentrations
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle, and
     filter) technology and in-process flow reduction control
     methods, along with preliminary treatment consisting of
     ammonia steam stripping for selected waste streams.  The
     following BAT effluent limitations are proposed:

     (a)  Concentrate Digestion Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
       Metric Units - mg/kkg of columbium or tantalum salt
                     produced from digestion
     English Units - Ibs/billion Ibs of columbium or tantalum
                   salt produced from digestion
Lead
Zinc
Ammonia (as N)
Fluoride
      515.63
    5,259.43
  685,787.90
  204,705.11
       464.07
     2,165.65
   302,159.18
    90,750.88
                              182

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      (b)  Solvent Extraction Raffinate
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                  2,691.60         2,422.44
Zinc                                 27,454.32        11,304.72
Ammonia (as N)                    3,579,828.0      1,577,277.60
Fluoride                          1,068,565.2        473,721.60

      (c)  Solvent Extraction Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                     43.01            38.71
Zinc                                    438.70           180.64
Ammonia (as N)                       57,203.30        25,203.86
Fluoride                             17,074.97         7,569.76

      (d)  Precipitation and Filtration of Metal Salts
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated

Lead                                 24,722.30        22,250.07
Zinc                                252,167.46       103,833.66
Ammonia (as N)                   32,880,659.0     14,487,267.80
Fluoride                          9,814,753.10     4,351,124.80
                              183

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     (e)  Metal Salt Drying Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Lead                                  1,647.90         1,483.11
Zinc                                 16,808.58         6,921.18
Ammonia (as N)                    2,191,707.0        965,669.40
Fluoride                            654,216.30       290,030.40

     (f)  Reduction of Salt to Metal
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                 35,266.30        31,739.67
Zinc                                359,716.26       148,118.46
Ammonia (as N)                   46,904,179.0     20,666,051.80
Fluoride                         14,000,721.10     6,206,868.80

     (g)  Reduction of Salt to Metal Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                  2,152.10         1,936.89
Zinc                                 21,951.42         9,038.82
Ammonia (as N)                    2,862,293.0      1,261,130.60
Fluoride                            854,383.7        378,769.6
                              184

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      (h)  Consolidation and Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated
Lead
Zinc
Ammonia  (as N)
Fluoride
        0
        0
        0
        0
         0
         0
         0
         0
     NSPS are proposed based on the treatability concentrations
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle, and
     filter) technology and in-process flow reduction control
     methods, along with preliminary treatment consisting of
     ammonia steam stripping for selected waste streams.  The
     following effluent standards are proposed for new sources:

     (a)  Concentrate Digestion Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
       Metric Units - mg/kkg of columbium or tantalum salt
                     produced from digestion
     English Units - Ibs/billion Ibs of columbium or tantalum
                   salt produced from digestion
Lead
Zinc
Ammonia
Fluoride
Total Suspended Solids
pH
      515.63
    5,259.43
  685,787.90
  204,705.11
   77,344.50
       464.07
     2,165.65
   302,159.18
    90,750.88
    61,875.60
Within the range of 7.5 to 10.0
         at all times
                              185

-------
     (b)  Solvent Extraction Raffinate NSPS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
     2,691.60
    27,454.32
 3,579,828.0
 1,068,565.2
   403,740.0
 Within the range of 7.5 to 10.0
          at all times
     2,422.44
    11,304.72
 1,577,277.60
   473,721.60
   322,992.0
     (c)  Solvent Extraction Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
        43.01            38.71
       438.70           180.64
    57,203.30        25,203.86
    17,074.97         7,569.76
     6,451.50         5,161.20
 Within the range of 7.5 to 10.0
          at all times
     (d)  Precipitation and Filtration of Metal Salts NSPS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
    24,722.30
   252,167.46
32,880,659.0
 9,814,753.10
 3,708,345.0
    22,250.07
   103,833.66
14,487,267.80
 4,351,124.80
 2,966,676.0
 Within the range of 7.5 to 10.0
          at all times
                               186

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      (e)  Metal Salt Drying Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried
Lead
Zinc
Ammonia  (as N)
Fluoride
Total Suspended Solids
     1,647.90
    16,808.58
 2,191,707.0
   654,216.30
   247,185.0
     1,483.11
     6,921.18
   965,669.40
   290,030.40
   197,748.0
                                  Within the range of 7.5 to 10.0
                                           at all times
     (f)  Reduction of Salt to Metal NSPS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
    35,266.30
   359,716.26
46,904,179.0
14,000,721.10
 5,289,945.0
    31,739.67
   148,118.46
20,666,051.80
 6,206,868.80
 4,231,956.0
 Within the range of 7.5 to 10.0
          at all times
     (g)  Reduction of Salt to Metal Wet Air Pollution Control
          NSPS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
     2,152.10
    21,951.42
 2,862,293.0
   854,383.7
   322,815.0
     1,936.89
     9,038.82
 1,261,130.60
   378,769.6
   258,252.0
 Within the range of 7.5 to 10.0
          at all times
                              187

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     (h)  Consolidation and Casting Contact Cooling NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Lead                                      0                0
Zinc                                      0                0
Ammonia (as N)                            00
Fluoride                                  0                0
TSS                                       0                0
pH                                Within the range of 7.5 to 10.0
                                            at all times

 5.  PSES are proposed based on the effluent concentrations
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle, and
     filter) technology and in-process flow reduction control
     methods, along with preliminary treatment consisting of
     ammonia steam stripping for selected waste streams.  The
     following effluent standards are proposed:

     (a)  Concentrate Digestion Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium-tantalum salt produced
                          from digestion
    English Units - Ibs/billion Ibs of columbium-tantalum salt
                     produced from digestion

Lead                                    515.63          464.07
Zinc                                  5,259.43        2,165.65
Ammonia (as N)                      685,787.90      302,159.18
Fluoride                            204,705.11        90,750.88
                              188

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     (b)  Solvent Extraction Raffinate PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                  2,691.60         2,422.44
Zinc                                 27,454.32        11,304.72
Ammonia (as N)                    3,579,828.0      1,577,277.60
Fluoride                          1,068,565.2        473,721.60

     (c)  Solvent Extraction Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                     43.01            38.71
Zinc                                    438.70           180.64
Ammonia (as N)                       57,203.30        25,203.86
Fluoride                             17,074.97         7,569.76

     (d)  Precipitation and Filtration of Metal Salts PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated

Lead                                 24,722.30        22,250.07
Zinc                                252,167.46       103,833.66
Ammonia (as N)                   32,880,659.0     14,487,267.80
Fluoride                          9,814,753.10     4,351,124.80
                              189

-------
     (e)  Metal Salt Drying Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt  dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Lead                                  1,647.90         1,483.11
Zinc                                 16,808.58         6,921.18
Ammonia (as N)                    2,191,707.0        965,669.40
Fluoride                            654,216.30       290,030.40

     (f)  Reduction of Salt to Metal PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                 35,266.30        31,739.67
Zinc                                359,716.26       148,118.46
Ammonia (as N)                   46,904,179.0     20,666,051.80
Fluoride                         14,000,721.10     6,206,868.80

     (g)  Reduction of Salt to Metal Wet Air Pollution Control
          PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                  2,152.10         1,936.89
Zinc                                 21,951.42         9,038.82
Ammonia (as N)                    2,862,293.0      1,261,130.60
Fluoride                            854,383.7        378,769.6
                              190

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      (h)  Consolidation and Casting Contact Cooling PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Lead                                      0                0
Zinc                                      0                0
Ammonia  (as N)                           '0                0
Fluoride                                  0                0

 4.  PSNS are proposed based on the effluent concentrations
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle, and
     filter) technology and in-process flow reduction control
     methods, along with preliminary treatment consisting of
     ammonia steam stripping for selected waste streams.  The
     following effluent standards are proposed for new sources:

     (a)  Concentrate Digestion Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of columbium or tantalum salt
                     produced from digestion
     English Units - Ibs/billion Ibs of columbium or tantalum
                   salt produced from digestion

Lead                                    515.63           464.07
Zinc                                  5,259.43         2,165.65
Ammonia  (as N)                      685,787.90       302,159.18
Fluoride                            204,705.11        90,750.88

     (b)  Solvent Extraction Raffinate PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                  2,691.60         2,422.44
Zinc                                 27,454.32        11,304.72
Ammonia  (as N)                    3,579,828.0      1,577,277.60
Fluoride                          1,068,565.2        473,721.60


                              191

-------
     (c)  Solvent Extraction Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                     43.01            38.71
Zinc                                    438.70           180.64
Ammonia (as N)                       57,203.30        25,203.86
Fluoride                             17,074.97         7,569.76

     (d)  Precipitation and Filtration of Metal Salts PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated

Lead                                 24,722.30        22,250.07
Zinc                                252,167.46       103,833.66
Ammonia (as N)                   32,880,659.0     14,487,267.80
Fluoride                          9,814,753.10     4,351,124.80

     (e)  Metal Salt Drying Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Lead                                  1,647.90         1,483.11
Zinc                                 16,808.58         6,921.18
Ammonia (as N)                    2,191,707.0        965,669.40
Fluoride                            654,216.30       290,030.40
                              192

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      (f)  Reduction of Salt to Metal PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                 35,266.30        31,739.67
Zinc                                359,716.26       148,118.46
Ammonia (as N)                   46,904,179.0     20,666,051.80
Fluoride                         14,000,721.10     6,206,868.80

      (g)  Reduction of Salt to Metal Wet Air Pollution Control
          PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                  2,152.10         1,936.89
Zinc                                 21,951.42         9,038.82
Ammonia (as N)                    2,862,293.0      1,261,130.60
Fluoride                            854,383.7        378,769.6

      (h)  Consolidation and Casting Contact Cooling PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Lead                                      0                0
Zinc                                      0                0
Ammonia (as N)                            00
Fluoride                                  0                0
                              193

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 7.  BCT is proposed based on the effluent concentrations
     achievable by the application of chemical precipitation and
     sedimentation (lime and settle) technology and in-process
     flow reduction control methods, along with preliminary
     treatment consisting of ammonia steam stripping for selected
     waste streams.  The following BPT effluent limitations are
     proposed:

     (a)  Concentrate Digestion Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

    Metric Units - mg/kkg of columbium-tantalum salt produced
                          from digestion
    English Units - Ibs/billion Ibs of columbium-tantalum salt
                     produced from digestion

Total Suspended Solids              447,515.0       218,300.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (b)  Solvent Extraction Raffinate
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any OneDay    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Total Suspended Solids            1,103,556.0        538,320.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (c)  Solvent Extraction Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Total Suspended Solids              176,357.40        86,028.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               194

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     (d)  Precipitation and Filtration of Metal Salts
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated

Total Suspended Solids           10,136,143.0      4,944,460.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (e)  Metal Salt Drying Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Total Suspended Solids            3,429,363.0      1,672,860.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (f)  Reduction of Salt to Metal
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
English Units - Ibs/billion Ibs of columbium or tantalum reduced

Total Suspended Solids           14,459,183.0      7,053,260.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (g)  Reduction of Salt to Metal Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
English Units - Ibs/billion Ibs of columbium or tantalum reduced

Total Suspended Solids              882,361.0        430,420.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

                               195

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     (h)  Consolidation and Casting Contact Cooling
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Total Suspended Solids                    0                0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               196

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              PRIMARY COLUMBIUM-TANTALUM  SUBCATEGORY

                           SECTION  III

                         INDUSTRY PROFILE
This section of the primary columbium-tantalum  supplement
describes the raw materials and  processes  used  in  manufacturing
primary columbium and tantalum salts  and in  subsequent  production
of the respective metals.  It also  presents  a profile  of the  col-
umbium and tantalum plants identified in this study.  Refer to
Section III of the General Development Document for  discussion  of
the purpose, authority, and methodology of this study  and  a gen-
eral description of the nonferrous  metals  manufacturing category.

While chemists refer to periodic table element  number 41 as
niobium, in American metallurgy  it  is known  as  columbium,  and
this name will be used in this report.

DESCRIPTION OF PRIMARY COLUMBIUM AND  TANTALUM PRODUCTION

The processes used at a columbium and tantalum  production  facil-
ity depend largely upon the raw  material used and  the plant's
final product.  Four basic operations from ore  or  slag  to  metal
must be performed:  physical and chemical  breakup  of the ore  or
slag to form columbium and tantalum salts  (digestion);  separation
of the columbium and tantalum salts from each other  and from  the
various impurities present; reduction of the salt  to the respec-
tive metal; and fabrication of the  metals  into  some  consistent
form, e.g., ingots, bars, or plates.   Some plants  perform  the
first two operations, and some the  last two;  some  perform  all
four operations.  A typical plant in  the first  category is shown
in Figure III-l.

RAW MATERIALS

Ore concentrates and slags are the  chief raw materials  for the
production of columbium and tantalum.  Ore concentrates are
derived principally from the minerals columbite, tantalite,
pyrochlore, and ferroniobium, these minerals  having  a relatively
high concentration of the desired metals.  Slags from  foreign tin
production have also been found  to  be a reliable source.   Colum-
bium and tantalum are usually found together, and  are somewhat
difficult to separate.

DIGESTION OF ORE OR SLAG

The ore or slag is first pulverized to approximately the con-
sistency of talcum powder.  Then, columbium  and tantalum (along
with some impurities) are leached from the powder  by either
hydrofluoric acid or by chlorine  gas.
                               197

-------
Treatment of the ore or slag powder with chlorine gas  at  500  to
1,000°C evolves the volatile pentachlorides of columbium  and  tan-
talum, as well as the chlorides of various other substances.
These are removed by selective condensation and the columbium and
tantalum chlorides are separated by distillation.  This process
is completely anhydrous and generates no wastewater streams.   The
process has been used in the past, but is not now in use  on a
commercial scale due to the difficulty in separating the  tantalum
chloride and columbium chloride by distillation.

In the leaching process, aqueous hydrofluoric acid dissolves
columbium, tantalum, and impurity metals from the powder  forming
the fluoride salts of these metals.  Leaching is a more advanta-
geous method for digesting the ore or slag because of  the ease
with which the columbium and tantalum fluorides can be separated
by solvent extraction.  Acid mist generated in the leaching
process may be controlled by wet scrubbers.  The scrubber liquor
produced is a source of wastewater.

SEPARATION OF SALTS

Separation and purification of the columbium and tantalum fluor-
ides is most economically achieved using solvent extraction.
Methyl isobutyl ketone (MIBK) is the most commonly used solvent.
Separation of columbium and tantalum by this method hinges on the
different solubilities that the fluoride salts of the  two metals
exhibit in MIBK as a function of hydrofluoric acid normality  in
the feed.  For instance, tantalum shows a great affinity  for  the
organic (MIBK) phase at low normalities, while the normality  must
be substantially increased for columbium to show a similar affin-
ity.  Usually, then, a low normality feed stream is contacted
with MIBK, whereupon tantalum salt of high purity is extracted.
Additional hydrofluoric acid is then added to increase the
normality of the aqueous phase, (the columbium-laden stream)
which is then contacted with fresh MIBK, extracting the columbium
salt.

The raffinate from this step is a source of wastewater.   The
columbium and tantalum are next extracted from MIBK by deionized
water.  Following extraction, the MIBK raffinate strea.m is
recycled.  Wet air pollution control used to control solvent
extraction air fumes is a source of wastewater.  Columbium and
tantalum salts are precipitated from the deionized water, usually
by the addition of ammonia (to precipitate columbium)  and
potassium fluoride (to precipitate tantalum).  The crystal
precipitates are filtered from the aqueous mother liquor, which
is then discarded.  The crystals are then washed with  water and
dried.
                               198

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REDUCTION OF SALT TO METAL

A number of methods exist for the reduction of columbium and
tantalum salts to metal.  They include sodium reduction,
aluminothermic reduction, carbon reduction, and electrolysis.

Sodium reduction is a popular method for producing both columbium
and tantalum from their salts.  In this process, sodium reduces
the columbium or tantalum to  metal.  Layers of the salt are
alternated with layers of sodium in a reaction vessel, then
capped with sodium chloride to prevent oxidation of the reduced
metal.  The reaction mixture is often ignited electrically, but
once ignited, the exothermic reaction is self-sustaining.  Wet
scrubbers are often used to control the gaseous emissions  from
the reaction vessel.  After cooling, the columbium or tantalum
metal containing material is crushed, and any iron picked  up  from
the reaction vessel is removed magnetically.  The remaining metal
powder is further purified by leaching with water, followed by
nitric or hydrochloric acid.

The aluminothermic reaction also may be used on both columbium
and tantalum salts.  This method also may be used on certain
ferrocolumbium ores which do not require digestion and separation
of columbium and tantalum salts.  The salt (or ore) is mixed  with
aluminum powder.  Potassium chlorate is added to provide
additional reaction heat, and magnesium is added to properly
ignite the mixture.  Columbium and tantalum are reduced to metal
while aluminum is oxidized.

Carbon reduction takes place through a two-step route known as
the Balke process and can be used on both columbium and tantalum
salts.  Its predominant use, however, is the reduction of  the
metal oxides.  The metal oxide is first mixed with fine carbon
and heated under vacuum to 1,800°C, where a metal carbide  and
carbon monoxide are formed.  The carbide is then mixed with more
oxide and reacts to form the pure metal and more carbon monoxide.

Electrolytic reduction of tantalum is sometimes practiced  using
fused salt techniques.  Potassium fluotantalate (iJ^TaFy),  the
crystal which was precipitated by potassium fluoride in the sepa-
ration of salts step, is electrolyzed to yield the pure tantalum
metal, which is then separated from the cathode by pulverizing
both metal and cathode acid, leaching out the cathode material
(usually carbon).

CONSOLIDATION AND CASTING

Both columbium and tantalum show a tendency to lose their
metallic characteristics, particularly malleability and ductil-
ity, when even small amounts of impurities are present in  the
                              199

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metal matrix.  Therefore, special  techniques must be used  to
further purify the metals and work them  into their  desired form.
Some of the more popular processes include electron beam melting,
cold-crucible arc melting, and simultaneous compacting  and
resistance heating.

Electron beam melting is currently the most common  method  of  con-
solidation.  A beam of high voltage, low current electrons is
focused onto the crude metal and the top of a  retractable  ingot
contained in a water-cooled copper cylinder.   The beam  melts  the
crude metal, and the falling molten globules form a pool on top
of the ingot.  The process is continuous, with the  ingot being
lowered as the molten metal solidifies.  Most  impurities boil out
of the pool into the high vacuum environment required by the
electron beam and are removed.

Arc melting occurs in much the same way  as electron beam melting,
except that a low voltage, high current  arc of electricity melts
the crude metal.

Simultaneous compaction and direct resistance  heating is the  old-
est process used and is somewhat undesirable,  as the metal must
be processed two or three times to reach sufficient purity.   The
metal is typically compacted at about 6,900 atmospheres (0.7 GPa)
and heated to 1,400 to 1,500°C for several hours.   It is then
rolled and sintered at 2,300°C.  Several rolling and sintering
steps may be required.

PROCESS WASTEWATER SOURCES

In summary, the major uses of water in primary columbium and  tan-
talum processing are:

    1. Concentrate digestion wet air pollution control,
    2. Solvent extraction,
    3. Solvent extraction wet air  pollution control,
    4. Precipitation and filtration of metal salt,
    5. Metal salt drying wet air pollution control,
    6. Reduction of salt to metal,
    7. Reduction of salt to metal  wet air pollution control,  and
    8. Consolidation and casting contact cooling.

OTHER WASTEWATER SOURCES

There are other waste streams associated with  the production  of
primary columbium-tantalum.  The principal waste stream is main-
tenance and cleanup water.  This waste stream  is not considered
as part of this rulemaking.  EPA believes that the  flows and  pol-
lutant loadings associated with this waste stream are insignifi-
cant relative to the waste streams selected, or it  is best
                               200

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handled by the appropriate permit authority on a case-by-case
basis under the authority of Section 403(a) of the Clean Water
Act.

AGE, PRODUCTION, AND PROCESS PROFILE

All five of the columbium-tantalum plants identified in this
study were built in the 20-year period just after World War II
(Table III-l).  Average plant production is approximately 450
tons per year, as shown in Table III-2.

Figure III-2 depicts the geographic locations of the plants
comprising the columbium-tantalum subcategory of the nonferrous
category.  The plants are scattered, with half the plants located
in the New England area and the rest in the Midwest or the West.

Table III-3 lists the major production processes presently used
in the columbium-tantalum subcategory.  Also shown is the number
of plants discharging from these processes.
                              201

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                 Table III-2

          PRODUCTION RANGES FOR THE
        COLUMBIUM-TANTALUM SUBCATEGORY
Production Ranges
    for 1976
   (tons/year)                 No.  of Plants

  Less than 450                      3

  More than 450                      2

  TOTAL                              5
                    203

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                           TABLE III-3

               PRODUCTION PROCESSES UTILIZED BY THE
                  COLUMBIUM-TANTALUM SUBCATEGORY
     Process

Digestion

Extraction

Precipitation and
 Filtration

Drying Salts

Reduction

Consolidation and
 Casting
 Number of
Plants With
 Process

    3

    3

    3


    3

    3

    4
   Number of
Plants Reporting
  Generation of
   Wastewater

      3

      3

      3
      3

      3

      1
                              204

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                            SECTION  IV

                        SUBCATEGORIZATTON
As discussed in Section IV of the General Development Document,
the nonferrous metals manufacturing  category has been subcatego-
rized to take into account pertinent industry characteristics,
manufacturing process variations, wastewater characteristics  and
a number of other factors that might affect the ability of the
facilities to achieve effluent limitations.  This section summa-
rizes the factors considered during  the designation of the pri-
mary columbium-tantalum subcategory  and its related subdivisions,

FACTORS CONSIDERED IN SUBCATEGORIZATION

The following factors were evaluated for use in determining
appropriate subcategories for the nonferrous metals category:

     1.  Metal products, co-products, and by-products;
     2.  Raw materials;
     3.  Manufacturing processes;
     4.  Product form;
     5.  Plant location;
     6.  Plant age;
     7.  Plant size;
     8.  Air pollution control methods;
     9.  Meteorological conditions;
    10.  Treatment costs;
    11.  Nonwater quality aspects;
    12.  Number of employees;
    13.  Total energy requirements; and
    14.  Unique plant characteristics.

Evaluation of all factors that could warrant subcategorization
resulted in the designation of the primary columbium-tantalum
subcategory.  Three factors were particularly important in estab-
lishing these classifications:  the type of metal produced, the
nature of raw materials used, and the manufacturing processes
involved.

In Section IV of the General Development Document, each of these
factors is described and the rationale for selecting metal prod-
uct, manufacturing processes and raw materials as the principal
factors used for subcategorization is discussed.  On this basis
the nonferrous metals manufacturing category was divided into 12
subcategories (phase I), one of them being primary
columbium-tantalum.
                              207

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The primary columbium-tantalum subcategory has not been con-
sidered during previous rulemaking.  The purpose of this rulemak-
ing is to establish BPT, BAT, and BCT effluent limitations, and
NSPS, PSES, and PSNS for the primary columbium-tantalum
subcategory.

FACTORS CONSIDERED IN SUBDIVIDING THE PRIMARY COLUMBIUM-TANTALUM
SUBCATEGORY

The factors listed previously were each evaluated when establish-
ing the primary columbium-tantalum subcategory and its subdivi-
sions.  In the discussion that follows, the factors will be
described as they pertain to this particular subcategory.

The rationale for considering further subdivision of the primary
columbium-tantalum subcategory is based primarily on the produc-
tion process used.  Within this subcategory, a number of differ-
ent operations are performed, which may or may not have a water
use or discharge, and which may require the establishment of
separate effluent limitations and standards.  While primary
columbium-tantalum is still considered a single subcategory, a
more thorough examination of the production processes, water use
and discharge practices, and pollutant generation rates has
illustrated the need for limitations and standards based on a
specific set of waste streams.  Limitations and standards will be
based on specific flow allowances for the following subdivisions:

     1.  Concentrate digestion wet air pollution control,
     2.  Solvent extraction raffinate,
     3.  Solvent extraction wet air pollution control,
     4.  Precipitation and filtration of metal salt,
     5.  Metal salt drying wet air pollution control,
     6.  Reduction of salt to metal,
     7.  Reduction of salt to metal wet air pollution control,
         and
     8.  Consolidation and casting contact cooling.

These subdivisions follow directly from differences within the
two distinct production stages of primary columbium and tantalum:
production of salts from ore concentrates and slags, and the
reduction of salts to produce the metals.  Plants processing
primary columbium and tantalum fall into three categories:
plants which perform the ore-to-salt operation, plants which
perform the salt-to-metal operation, and plants which perform
both operations.  A review of the sampling data shows that
significantly different wastewater volumes and characteristics
are produced by the two manufacturing processes.  Therefore,
eight subdivisions of the primary columbium-tantalum subcategory
are necessary.
                              208

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Other Factors
The other factors considered in this evaluation either  supported
the establishment of the primary columbium-tantalum subcate-
gory and its subdivisions, or were shown to be inappropriate
bases for subcategorization.  Air pollution control methods,
treatment costs, nonwater quality aspects and total energy
requirements are functions of the selected subcategorization
factors--metal product, raw materials, and production processes.
Therefore, they are not independent factors and will not affect
the method of subcategorization.  As discussed in Section IV of
the General Development Document, certain other factors such as
plant age, plant size, and the number of employees were also
evaluated and were determined to be inappropriate for use as
bases for subcategorization of this subcategory.

PRODUCTION NORMALIZING PARAMETERS

The effluent limitations and standards developed in this document
establish mass limitations on the discharge of pollutants.  To
allow these regulations to be applied to plants with various
production capacities, the mass of pollutant discharge must be
related to a unit of production.  This factor is known  as the
production normalizing parameter (PNP).  In general, the amount
of product or intermediate produced by a particular manufacturing
process is used as the PNP.  This is based on the principle that
the amount of water generated is proportional to the amount of
product made.  The PNPs for the eight primary columbium-tantalum
subdivisions are shown below:
           Subdivision

1.  Concentrate digestion wet air
     pollution control
2.  Solvent extraction raffinate
3.  Solvent extraction wet air
     pollution control

4.  Precipitation and filtration
     of metal salt

5.  Metal salt drying wet air
     pollution control
            PNP

kkg of columbium or tanta-
 lum salt produced from
 digestion

kkg of columbium or
 tantalum salt extracted

kkg of columbium or
 tantalum salt extracted

kkg of columbium or
 tantalum salt precipitated

kkg of columbium or
 tantalum salt dried
                               209

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           Subdivision                            PNP

6.  Reduction of salt to metal        kkg of columbium or
                                       tantalum reduced

7.  Reduction of salt to metal wet    kkg of columbium or
     air pollution control             tantalum reduced

8.  Consolidation and casting         kkg of columbium or
     contact cooling                   tantalum consolidated or
                                       cast
                               210

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                            SECTION V

             WATER USE AND WASTEWATER CHARACTERISTICS
This section describes the characteristics of wastewater associ-
ated with the primary columbium-tantalum subcategory.  Data used
to quantify wastewater flow and pollutant concentrations are
presented, summarized, and discussed.  The contribution of
specific production processes to the overall wastewater discharge
from primary columbium-tantalum plants is identified whenever
possible.

Section V of the General Development Document contains a detailed
description of the data sources and methods of analysis used to
characterize wastewater from the nonferrous metals category.  To
summarize this information briefly, two principal data sources
were used:  data collection portfolios (dcp) and field sampling
results.  Data collection portfolios contained information
regarding wastewater flows.

In order to quantify the pollutant discharge from primary
columbium-tantalum plants, a field sampling program was
conducted.  Wastewater samples were collected in two phases:
screening and verification.  The first phase, screen sampling,
was to identify which toxic pollutants were present in the
wastewaters from production of the various metals.  Screening
samples were analyzed for 128 of the 129 toxic pollutants and
other pollutants deemed appropriate.  (Because the analytical
standard for TCDD was judged to be too hazardous to be made
generally available, samples were never analyzed for this pollu-
tant.  There is no reason to expect that TCDD would be present in
columbium-tantalum wastewater).  A total of 10 plants were
selected for screen sampling in the nonferrous metals manufactur-
ing category with one of those plants in the primary columbium-
tantalum subcategory .  A complete list of the pollutants
considered and a summary of the techniques used in sampling and
laboratory analyses are included in Section V of the General
Development Document.  In general, the samples were analyzed for
three classes of pollutants:  toxic organic pollutants, toxic
metal pollutants, and criteria pollutants (which includes both
conventional and nonconventional pollutants).

As described in Section IV of this supplement, the primary
columbium-tantalum subcategory has been further categorized into
eight subdivisions, each representing a major source of waste-
water in the subcategory.  Differences in the wastewater charac-
teristics associated with these subdivisions are to be expected.
For this reason, wastewater streams corresponding to each subdi-
vision are addressed separately in the discussions that follow.
                               211

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WASTEWATER SOURCES, DISCHARGE RATES, AND CHARACTERISTICS

The wastewater data presented in this section were evaluated  in
light of production process information compiled during this
study.  As a result, it was possible to identify the principal
wastewater sources in the primary columbium-tantalum subcategory.
They are:

     1.  Concentrate digestion wet air pollution control,
     2.  Solvent extraction raffinate,
     3.  Solvent extraction wet air pollution control,,
     4.  Precipitation and filtration of metal salt,
     5.  Metal salt drying wet air pollution control,
     6.  Reduction of salt to metal,
     7.  Reduction of salt to metal wet air pollution control,
         and
     8.  Consolidation and casting contact cooling.

Data supplied by dcp responses were evaluated, and two flow-to-
production ratios were calculated for each stream.  The two
ratios, water use and wastewater discharge flow, are differenti-
ated by the flow value used in calculation.  Water use is defined
as the volume of water or other fluid (e.g., spent leachate)
required for a given process per mass of product and is therefore
based on the sum of recycle and make-up flows to a given process.
Wastewater flow discharged after pretreatment or recycle (if
these are present) is used in calculating the production normal-
ized flow--the volume of wastewater discharged from a given
process to further treatment, disposal, or discharge per mass of
columbium or tantalum 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 produc-
tion normalizing parameter, PNP, assigned to each stream, as
outlined in Section IV.  The production normalized flows were
compiled and statistically analyzed by stream type.  Where appro-
priate, an attempt was made to identify factors that could
account for variations in water use.  This information is summa-
rized in this section.  A similar analysis of factors affecting
the wastewater values is presented in Sections X, XI, and XII
where representative BAT, BDT, and pretreatment discharge flows
are selected for use in calculating the effluent limitations  and
standards.  As an example, reduction of salt to metal air scrub-
bing flow is related to the reduction production.  As such, the
discharge rate is expressed in liters of scrubber wastewater  per
metric ton of metal reduced.

In order to quantify the concentrations of pollutants present in
wastewater from primary columbium-tantalum plants, wastewater
samples were collected at five plants, representing 100 percent
                               212

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of the discharging primary columbium-tantalum plants.  Diagrams
indicating the sampling sites and contributing production
processes are shown in Figures V-l through V-5.

The raw wastewater sampling data for the primary columbium-
tantalum subcategory are presented in Tables V-2, V-4, V-6, V-8,
and V-10, (at the end of this section).  Treated wastewater
sampling data are shown in Tables V-16 through V-18  (at the end
of this section).  Tables V-13 through V-15 show miscellaneous

raw wastewater for plants A, B, and C.  These data were not used
for the .wastewater characterizations discussed below.  Where no
data are listed for a specific day of sampling, the  wastewater
samples for the stream were omitted.  If the analysis did not
detect a pollutant in a waste stream, the pollutant  was omitted
from the table.

The data tables include some wastewater samples measured at con-
centrations not considered quantifiable.  The base neutral
extractables, acid fraction extractables, and volatile organics
are generally considered not quantifiable at concentations at or
below 0.010 mg/1.  Below this concentration, the data is
considered too susceptible to random error to be quantitatively
accurate.  However, these data are useful in that they indicate
the presence of a particular pollutant.  The pesticide fraction
is considered nonquantifiable at concentrations equal to or less
than 0.005 mg/1.  Nonquantifiable results are designated in the
tables with an asterisk (double asterisk for less than or equal
to 0.005 mg/1).

These detection limits shown on the data tables are  not the same
in all cases as the published detection limits for these pollu-
tants by the same analytical methods.  The detection limits used
were reported with the analytical data and hence are the appro-
priate 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 calibra-
tion, variation in stock solutions, and variation in operators.

The statistical analysis of data includes some samples measured
at concentrations considered not quantifiable.  Data reported as
an asterisk are considered as detected but below quantifiable
concentrations, and a value of zero is used for averaging.  Toxic
organic, nonconventional, and conventional pollutant data
reported with a "less than" sign are considered as detected, but
not further quantifiable.  A value of zero is also used for
averaging.   If a pollutant is reported as not detected, it is
excluded in calculating the average.  Finally, toxic metal values
reported as less than a certain value were considered as not
                               213

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detected, and consequently, were not used in the calculation of
the average.  For example, three samples reported as ND, *, and
0.021 mg/1 have an average value of 0.010 mg/1.

The method by which each sample was collected  is indicated by
number, as follows.

     1     one-time grab
     2     24-hour manual composite
     3     24-hour automatic composite
     4     48-hour manual composite
     5     48-hour automatic composite
     6     72-hour manual composite
     7     72-hour automatic composite

In the data collection portfolios, all of the  columbium-tantalum
plants indicated that the toxic organic pollutants were known or
believed to be absent from their wastewater.   The majority of the
metals were believed to be absent as summarized below:

                Known      Believed     Believed     Known
Pollutant      Present      Present      Absent      Absent

Antimony          1            -            21
Arsenic           1            -            21
Beryllium         -            -            31
Cadmium           -            -            22
Chromium          1            1            11
Copper            -            1            21
Lead              -            -            22
Mercury           -            1            12
Nickel            1            1            11
Selenium          -            -            41
Silver            -            -            22
Zinc              -            -            31
CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL

The first step in the production of primary columbium and tan-
talum is the digestion of ore concentrates and slags with hydro-
fluoric acid.  The process solubilizes columbium and tantalum,
along with various other metals which require removal.  Three of
the five columbium-tantalum plants use wet scrubbers on their
concentrate digestion process.  Water use and discharge rates are
shown in liters per metric ton of columbium-tantalum salt
produced from digestion in Table V-l.

Table V-2 summarizes the raw wastewater sampling data for the
toxic and selected conventional and nonconventional pollutants.
                               214

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The wet scrubber  liquor  is  strongly  acidic  (pH  of  approximately
2.0), containing  suspended  solids, fluorides, and  some metals  at
treatable concentrations  (see Table  V-2).   Insoluble  gangue
impurities are removed by filtration.  On-site  disposal  of gangue
impurities is required because  it  is radioactive.  The waste
gangue slurry is  typically  contained in a holding  pond,  the over-
flow from which is acidic and contains quantifiable concentra-
tions of metals,  fluorides, and suspended solids.

SOLVENT EXTRACTION RAFFINATE

The digested solution containing columbium  and  tantalum  is
contacted with an organic solvent  such as methyl isobutyl ketone
(MIBK) in a two step multistage extract'ion  process, resulting  in
the extraction and separation of columbium  and  tantalum.  Three
plants discharge  this wastewater as  shown in Table V-3.  The
impurities from digestion remaining  in the  raffinate  typically
include treatable concentrations of  organics, fluorides, metals,
suspended solids, and oil and grease.  The  sampling data from  an
extraction raffinate waste  stream  are presented in Table V-4.

SOLVENT EXTRACTION WET AIR  POLLUTION CONTROL

After extraction, the organic streams bearing columbium  and
tantalum are often contacted with  deionized water  to  strip the
columbium and tantalum from the organic phase.  The organic
solvent is then recycled to the first extraction process.  Two
plants use wet scrubbers to control  air emissions  from extraction
operations.  One  of these plants uses the same  scrubber  for air
pollution control of concentrate digestion  and  solvent extrac-
tion.  The water  use and discharge rates for the two  plants are
presented in Table V-5 in liters per metric ton of columbium or
tantalum salt extracted.  This wastewater is acidic and  contains
concentrations of toxic organics and metals, fluorides,  and
suspended solids  as shown in Table V-6.

PRECIPITATION AND FILTRATION OF METAL SALT

Precipitation of  pure metal salts  from the  aqueous phase may be
accomplished by ammonia addition to  form columbium and tantalum
oxides.  All three plants reporting  this waste  stream discharge
it as shown in Table V-7.   The filtrate wastewater typically
contains treatable concentrations  of ammonia, fluoride,  metals,
and suspended solids.   Ammonia stripping is frequently practiced
to recover ammonia from the filtrate prior  to discharge  of the
waste stream.  Tantalum may also be  recovered by treatment of  the
solubilized tantalum salt with hydrofluoric acid and  potassium
fluoride to precipitate potassium  fluotantalate (K^TaFy).
This precipitate  also requires filtration and washing, leaving a
filtrate effluent stream containing  measurable  concentrations  of
potassium, fluorides,  and chlorides  (see Table  V-8).
                               215

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METAL SALT DRYING WET AIR POLLUTION CONTROL

Following filtration, the precipitates are usually dried and
calcined to yield purified salts.  Four of the five columbium-
tantalum plants use wet scrubbers in drying operations.  Water
use and discharge rates are shown in Table V-9.  Wet scrubber
waste streams associated with this process reflect the precipi-
tation process used.  For example, treatable concentrations of
ammonia are present when ammonia is used as the reagent for pre-
cipitation, as can be seen in Table V-10.  Table V-10 shows data
from combined wastewater from the metal salt drying scrubber,
reduction of salt to metal, and reduction of salt to metal
scrubber waste streams.

REDUCTION OF SALT TO METAL WASTEWATER

Reduction processes vary somewhat in the columbium-tantalum
subcategory.  Of the several reduction techniques discussed in
Section III, only two were reported in practice by plants in the
columbium-tantalum subcategory.  The first of these, sodium
reduction, appears to be the dominant technique.  The process
requires extensive washing of the product metal with water or a
combination of water and acid.  The production normalized
discharge rates are shown in Table V-ll.  This waste stream
typically contains treatable concentrations of fluoride (see
Table V-10), as well as toxic metals, chloride, and oil and
grease.  The other reduction process used, aluminothermic
reduction, is reported to generate no wastewater.  The waste
streams are sometimes passed through a cyclone to recover
valuable columbium and tantalum solids.  In addition, water is
used for sizing at one of the plants surveyed.  However, this
waste stream is combined with washing operations and is not
further considered as a separate waste stream.

REDUCTION OF SALT TO METAL WET AIR POLLUTION CONTROL

Reduction process emissions are frequently controlled with wet
scrubbers.  The resulting discharge is similar to the reduction
washing streams.  This waste stream may also be passed through a
cyclone to recover columbium and tantalum solids, if present.
Water use and discharge rates are presented in Table V-12 in
liters per metric ton of columbium-tantalum metal reduced.
Sampling data for this waste stream are contained in Table V-10.
This wastewater contains many of the same pollutants found in
reduction of salt to metal wastewater.

CONSOLIDATION AND CASTING CONTACT COOLING

Only one of the plants surveyed practiced direct contact cooling
of metal castings.  This plant recycles 100 percent of the water
used for this operation, resulting in zero discharge.  No sam-
pling data were available for this waste stream.


                               216

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                            Table V-l

     WATER USE AND DISCHARGE RATES FOR CONCENTRATE DIGESTION
                    WET AIR POLLUTION CONTROL

    (1/kkg of columbium-tantalum salt produced from digestion)
   Plant Code

      507

      509

      519
Percent
Recycle

   7

   0

  86
Production
Normalized
Water Use

   9,344

    NR

  93,800
  Production
  Normalized
Discharge Rate

     8,690

     NR

    13,132
NR = Present, but data not reported in dcp
                              217

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                              223

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-------
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       WATER USE AND DISCHARGE RATES FOR SOLVENT EXTRACTION
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                              228

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       WATER USE AND DISCHARGE RATES FOR PRECIPITATION AND
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                              232

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       WATER USE AND DISCHARGE RATES FOR METAL SALT DRYING
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                              236

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                            Table V-ll

       WATER USE AND DISCHARGE RATES FOR REDUCTION OF SALT
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  Plant Code

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                              243

-------
                            Table V-12

       WATER USE AND DISCHARGE RATES FOR REDUCTION OF SALT
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  40,697

   2,168
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     2,168
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                              244

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Source
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Mixing HCL
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 Laboratory
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                         Figure  V-l

   SAMPLING  SITES  AT  COLUMBIUM-TANTALUM PLANT A
                              264

-------
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-------
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0.082 MGD'
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                                   116
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                                                                 0.11 MGD
                                                            Discharge
                                   Figute  V-3

           SAMPLING  SITES  AT COLUMBIUM-TANTALUM  PLANT  B
                                         266

-------
 Vaste Solid Slurry
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  Waste Raffinate
    From Solvent
    Extraction
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Control on Digestion,
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   Miscellaneous
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                                                           Equalization Pond
                                                              Discharge

                              Figure V-4

     SAMPLING SITES  AT COLUMBIUM-TANTALUM PLANT  C
                                   267

-------
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                             Figure  V-5

     SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT  D
                                   268

-------
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                            SECTION VI

                SELECTION OF POLLUTANT PARAMETERS


Section V of this supplement presented data from primary
columbium-tantalum plant sampling visits and subsequent chemical
analyses.  This section examines that data and discusses the
selection or exclusion of pollutants for potential limitation.
The legal basis for tta exclusion of toxic pollutants under Para-
graph 8(a) of the Settlement Agreement is presented in Section VI
of the General Development Document.

Each pollutant selected for potential limitation is discussed in
Section VI of the General Development Document.  That discussion
provides information concerning where the pollutant originates
(i.e., whether it is a naturally occurring substance, processed
metal, or a manufactured compound); the general physical proper-
ties and the form of the pollutant; toxic effects of the pollu-
tant in humans and other animals; and the behavior of the pollu-
tant in POTW at concentrations expected in industrial discharges.

The discussion that follows describes the analysis that was per-
formed to select or exclude pollutants for further consideration
for limitations and standards.  Pollutants will be considered for
limitations and standards if they are present in concentrations
treatable by the technologies identified in this analysis.  The
treatability concentrations used for the toxic metals were the
long-term performance values achievable by lime precipitation,
sedimentation, and filtration.  The treatability concentrations
used for the toxic organics were the long-term performance values
achievable by carbon adsorption (see Section VII of the General
Development Document - Combined Metals Data Base).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS

This study examined samples from the primary columbium-tantalum
subcategory for three conventional pollutant parameters (oil and
grease, total suspended solids, and pH) and six nonconventional
pollutant parameters (ammonia, chemical oxygen demand, chloride,
fluoride, total organic carbon, and total phenols).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS SELECTED

The following conventional and nonconventional pollutants or
pollutant parameters are selected for consideration in estab-
lishing limitations for the columbium-tantalum subcategory:

     ammonia
     total suspended solids (TSS)
     fluoride
     pH
                              269

-------
Five of eight samples analyzed for ammonia exhibited concentra-
tions in excess of 40 mg/1 (above the treatability concentration)
with values reported as high as 3,210 mg/1.  Since five of eight
samples are above the 32 mg/1 concentration attainable with steam
stripping, ammonia is selected for further consideration.

The concentration of suspended solids in the 11 samples for which
it was analyzed ranged from 1 mg/1 to 27,890 mg/1.  Furthermore,
most of the treatment used to remove toxic metals does so by
precipitating the metals or their salts, and these toxic metal
precipitates should not be discharged.  A limitation on total
suspended solids then, would help ensure that the toxic metals
are removed.  Thus, total suspended solids is selected for
consideration for limitation.

Fluoride ions in low concentration (approximately 1.0 ing/1) are
beneficial in drinking water supplies.  However, higher concen-
trations (above 10 mg/1) can be harmful and even fatal to humans
and animals.  All six samples analyzed  for fluoride contained
very high concentrations of this pollutant (ranging from 2,800 to
24,000 mg/1).  Consequently, fluoride is selected for considera-
tion for limitation.

The pH range measured was 1.87 to 11.0.  Many deleterious effects
are caused by either extreme pH values, or rapid changes in pH.
Effective removal of toxic metals requires careful control of pH.
Therefore, pH is considered for specific regulation in this
subcategory.

TOXIC POLLUTANTS

The frequency of occurrence of toxic pollutants in the wastewater
samples taken is presented in Table VI-1.  These data provide the
basis for the categorization of specific pollutants as discussed
below.  Table VI-1 is based on raw wastewater data from streams
22, 23, 25, 113, 114, and 117 shown in Figures V-l through V-5
and presented in Tables V-2, V-4, V-6, V-8, and V-10.  Treatment
plant samples were not considered in the frequency count.
Streams 48, 49, 50, 51, 52, 115, and 116 were not used because
they contain either treated wastewater or wastewater from
processes not considered for regulation in this rulemaking.

TOXIC POLLUTANTS NEVER DETECTED

Paragraph 8(a)(iii) of the Revised Settlement Agreement allows
the Administrator to exclude from regulation those toxic pollu-
tants not detectable by Section 304(h) analytical methods or
other state-of-the-art methods.  The toxic pollutants listed
below were not detected in any wastewater samples from this sub-
category; therefore,  they are not selected for consideration in
establishing limitations:
                               270

-------
 2.  acrolein
 3.  acrylonitrile
 5.  benzidine
 9.  hexachlorobenzene
11.  1,1,1-trichloroethane
13.  1,1-dichloroethane
16.  chloroethane
17.  DELETED
18.  bis(2-chloroethyl) ether
19.  2-chloroethyl vinyl ether
21.  2,4,6-trichlorophenol
22.  parachlorometa cresol
24.  2-chlorophenol
25.  1,2-dichlorobenzene
26.  1,3-dichlorobenzene
27.  1,4-dichlorobenzene
28.  3,3'-dichlorobenzidtne
29.  1,1-dichloroethylene
31.  2,4-dichlorophenol
32.  1,2-dichloropropane
33.  1,3-dichloropropylene
34.  2,4-dimethylphenol
37,  1,2-diphenylhydrazine
40.  4-chlorophenyl phenyl ether
41.  4-bromophenyl phenyl ether
42.  bis(2-chloroisopropyl) ether
43.  bis(2-chloroethoxy) methane
45.  methyl chloride
46.  methyl bromide
49.  DELETED
50.  DELETED
52.  hexachlorobutadiene
53.  hexachlorocyclopentadiene
55.  naphthalene
57.  2-nitrophenol
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
65.  phenol
69.  di-n-octyl phthalate
72.  benzo(a)anthracene
74.  3,4-benzofluoranthene
75.  benzo(k)fluoranthene
76.  chrysene
77.  acenaphthylene
79.  benzo(ghi)perylene
                        271

-------
      82.  dibenzo(a,h)anthracene
      83.  indeno(l, 2,3-cd)pyrene
      84.  pyrene
      86.  toluene
      88.  vinyl chloride
      89.  aldrin
      90.  dieldrin
      91.  chlordane
      92.  4,4'-DDT
      93.  4,4'-DDE
      94.  4,4'-ODD
      95.  alpha-endosulfan
      96.  beta-endosulfan
      97.  endosulfan sulfate
      98.  endrin
      99.  endrin aldehyde
     100.  heptachlor
     101.  heptachlor epoxide
     102.  alpha-BHC
     103.  beta-BHC
     104.  gamma-BHC
     105.  delta-BHC
     129.  2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD)

TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION LIMIT

The provision of Paragraph 8(a)(iii) of the Revised Settlement
Agreement excluding from regulation those toxic pollutants which
are not detectable includes those pollutants whose concentrations
fall below EPA's nominal detection limit.  The  toxic p>ollutants
listed below were never found above their analytical quantifica-
tion concentration in any wastewater samples from this subcate-
gory; therefore, they are not selected for consideration in
establishing limitations.

      14.  1,1,2-trichloroethane
      15.  1,1,2,2-tetrachloroethylene
      20.  2-chloronaphthalene
      35.  2,4-dinitrotoluene
      36.  2,6-dinitrotoluene
      39.  fluoranthene
      67.  butyl benzyl phthalate
      73.. benzo(a)pyrene
      78.  anthracene     (a)
      80.  fluorene
      81.  phenanthrene   (a)
     113.  toxaphene
     121.  cyanide

(a)  Reported together.


                              272

-------
TOXIC POLLUTANTS PRESENT BELOW CONCENTRATIONS ACHIEVABLE BY
TREATMENT

Paragraph 8(a)(ill) of the Revised Settlement Agreement also
allows the exclusion of toxic pollutants which were detected  in
quantities too small to be effectively reduced by any technolo-
gies known to the Administrator.  The pollutants listed below are
not selected for consideration in establishing limitations
because they were not found in any wastewater samples from this
subcategory above concentrations considered achievable by exist-
ing or available treatment technologies.  These pollutants are
discussed individually following the list.

       4.  benzene
      48.  dichlorobromomethane
      54.  isophorone
      70.  diethyl phthalate
     117.  beryllium
     126.  silver

Benzene was detected above its analytical quantification limit in
one of 14 samples.  The detected value was less than 0.05 mg/1,
the concentration achievable by available treatment.  Therefore,
benzene is not selected for consideration for limitation.

Dichlorobromomethane was detected above its analytical quantifi-
cation limit in only one of 14 samples, at a concentration of
0.038 mg/1.  Available treatment can reduce the dichlorobromo-
methane concentration to only 0.1 mg/1, so it is not selected for
consideration for limitation.

Isophorone occurred above its analytical quantification limit in
just one of seven samples; the reported value was 0.029 mg/1,
which is below the concentration to which available treatment can
reduce this pollutant (0.05 mg/1).  Therefore, isophorone is  not
selected for consideration for limitation.

Diethyl phthalate was detected in four of eight samples with  one
value above the analytical quantification concentration of 0.010
mg/1.   The concentration of diethyl phthalate in the sample was
0.017 mg/1, which is below the treatable concentration of 0.025
mg/1.   Therefore, diethyl phthalate was not selected for
consideration.

Beryllium was detected in five of six samples analyzed.  However,
it was found above its quantification limit in only two samples,
both at concentrations below the treatable concentration of 0.20
mg/1 for this pollutant.   The concentrations of beryllium in  the
two samples were 0.18 and 0.02 mg/1.  Therefore, beryllium is not
selected for consideration for limitation.
                               273

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Silver was detected in two of six samples analyzed, at values  of
0.06 and 0.07 mg/1.  However, treatment technology available
cannot bring the silver concentration below 0.07 mg/1, so  silver
is not selected for consideration for limitation.

TOXIC POLLUTANTS DETECTED IN A SMALL NUMBER OF SOURCES

Paragraph 8(a)(iii) allows for the exclusion of a toxic pollutant
if it is detectable in the effluent from only a small number of
sources within the subcategory and it is uniquely related  to only
those sources.  The following pollutants were not selected for
regulation on this basis.

       1.  acenaphthene
       6.  carbon tetrachloride
      12.  hexachloroethane
      23.  chloroform
      30.  1,2-trans-dichloroethylene
      44.  methylene chloride
      47.  bromoform
      56.  nitrobenzene
      66.  bis(2-ethylhexyl) phthalate
      68.  di-n-butyl phthalate
      71.  dimethyl phthalate
      85.  tetrachloroethylene
     106.  PCB-1242       (a)
     107.  PCB-1254       (a)
     108.  PCB-1221       (a)
     109.  PCB-1232       (a)
     110.  PCB-1248       (b)
     111.  PCB-1260       (b)
     112.  PCB-1016       (b)
     123.  mercury

(a),(b)  Reported together

Acenaphthene was detected in one of eight samples, with the one
detected value above the 0.01 mg/1 concentration considered
attainable with the identified treatment technology.  The  value
detected in the sample was 0.017 mg/1.  From the waste stream  in
which acenaphthene was detected, two other samples of this waste
stream reported acenaphthene as a not detected.  Therefore, acen-
aphthene is not considered characteristic of columbium-tantalum
wastewaters and is not considered for limitation.

Carbon tetrachloride was found above its analytical quantifica-
tion limit in two of 14 samples, with concentrations of 0.017  and
0.074 mg/1.  It was found below the analytical quantification
limit in 12 other samples, in all but one of which it was  not
                              274

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detected at all.  Carbon  tetrachloride  is  a  common laboratory
solvent.  Since no carbon tetrachloride was  detected  in  either  of
the source water  samples  taken,  and  since  it is  not used in the
columbium-tantalum subcategory nor is it a likely  by-product of
any chemical that is used,  the values recorded  can be ascribed  to
sample contamination.  Therefore, carbon tetrachloride is  not
selected for consideration  for limitation.

Hexachloroethane was present  in  only one out of  seven samples
taken, at 0.023 mg/1.  Concentrations above  0.01 mg/1 are
considered treatable by the identified  treatment technology.
Also, in the dcp, all of  the  columbium-tantalum  plants indicated
that this pollutant was either known or believed to be absent.
Therefore, hexachloroethane is not selected  for  consideration for
limitation.

Chloroform, a common laboratory  solvent, was detected in 10 of  14
samples, ranging from below the  analytical quantification  limit
to 0.24 mg/1.  Concentrations above  the analytical quantification
limit in two of the three blanks  (0.052 mg/1 and 0.015 mg/1)  ana-
lyzed raise the likelihood  of sample contamination.   Also,  in the
dcp, all of the columbium-tantalum plants  indicated that this
pollutant was either known  or believed  to  be absent.   Chloroform,
therefore, is not selected  for consideration for limitation.

1,2-trans-dichloroethylene  was detected in two of  17  samples,
with both of the concentrations  above the  0.1 mg/1 concentration
considered attainable with  the identified  treatment technology.
The values detected above treatability were  0.484  and 0.26  mg/1.
These two values were taken from  two different waste  streams  that
were sampled three times  each.   The  remaining six  samples  were
reported as not detected; therefore, 1,2-trans-dichloroethylene
is not considered to be characteristic  of  raw wastewaters  from
columbium-tantalum plants.

One very high value of methylene  chloride, 88.4 mg/1,  was  found
in one of 14 samples; methylene  chloride was not detected  in the
remaining 13 samples.  But  this  solvent is so pervasive  in  labor-
atories that this one case  of detection (out of 14) is probably
due to sample contamination.  The presence of methylene  chloride
in one of the blanks attests  to  this.  Also,  in  the dcp, all  of
the columbium-tantalum plants indicated that this  pollutant was
either known or believed  to be absent.  Therefore, methylene
chloride is not selected  for consideration for limitation.

Nitrobenzene was detected in one  of  eight  samples, and above  the
0.05 concentration considered attainable with the  identified
treatment technology.  The  value  detected was 0.1  mg/1.  This
value was obtained from a sample  of  solvent  extraction raffinate
in which two other samples  were reported as  not detected.   Nitro-
benzene, therefore, is not  considered for  limitation.
                               275

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Bis(2-ethylhexyl) phthalate was reported present above its ana-
lytical quantification limit in five of seven samples; the
reported concentrations ranged from 0.02 mg/1 to 1.2 mg/1.  This
compound is a plasticizer found in many plastic materials used in
manufacturing plants, thus it is not considered attributable to
specific materials or processing in this subcategory.  Also, in
the dcp, all of the columbium-tantalum plants indicated that this
pollutant was either known or believed to be absent.  Therefore,
bis(2-ethylhexyl) phthalate is not selected for consideration for
limitation.

Di-n-butyl phthalate was measured above its analytical quantifi-
cation limit in three of 11 samples; the measured concentrations
ranged from 0.012 mg/1 to 0.08 mg/1.  This substance is a plasti-
cizer found in many products used in manufacturing plants; it is
not considered a pollutant specific to this point source.  Also,
in the dcp, all of the columbium-tantalum plants indicated that
this pollutant was either known or believed to be absent.  There-
fore, di-n-butyl phthalate is not selected for consideration for
limitation.

Dimethyl phthalate was reported present above its analytical
quantification limit in two of 11 samples; the reported concen-
trations were 0.012 mg/1 and 0.02 mg/1.  This compound is a
plasticizer found in many plastic materials used in manufacturing
plants, and is not considered a point source specific pollutant.
Also, in the dcp, all of the columbium-tantalum plants indicated
that this pollutant was either known or believed to be absent.
Therefore, dimethyl phthalate is not selected for consideration
for limitation.

Tetrachloroethylene was detected in three of 17 samples, with one
of the values above the 0.05 mg/1 concentration considered
attainable with the identified treatment technology.  The value
detected was 0.157 mg/1.  The process waste stream from which
this sample was taken also produced six samples in which tetra-
chloroethylene was not detected.  Therefore, tetrachloroethylene
is not considered for further limitation.

PCB-1242, PCB-1254, and PCB-1221 were measured above their ana-
lytical quantification limit in only one of seven samples.  The
observed concentration was 0.0516 mg/1.  Since PCBs were found in
just one plant, and since in the dcp, all of the columbium-
tantalum plants indicated that this pollutant was either known or
believed to be absent, they are not selected for consideration
for limitation.
                              276

-------
PCB-1232, PCB-1248, PCB-1260, and PCB-1016 were measured above
their analytical quantification limit in one of seven samples.
The observed concentration was 0.336 mg/1.  Since PCB's were
found in only one plant, and since in the dcp, all of the
columbium-tantalum plants indicated that this pollutant was
either known or believed to be absent, they are not selected for
consideration for limitation.

Mercury was found above the concentration achievable by treatment
in one of six samples.  Only one sample at 0.063 mg/1 was detec-
ed above the treatable concentration of 0.036 mg/1.  Since the
five other samples were below treatability, Mercury is not
selected for consideration for limitation.

TOXIC POLLUTANTS SELECTED FOR FURTHER CONSIDERATION FOR LIMITA-
TIONS AND STANDARDS

The toxic pollutants listed below were selected for further
consideration in establishing limitations and standards for this
subcategory.  The toxic pollutants selected are each discussed
following the list.

       7.  chlorobenzene
       8.  1,2,4-trichlorobenzene
      10.  1,2-dichloroethane
      38.  ethylbenzene
      51.  chlorodibromomethane
      87.  trichloroethylene
     114.  antimony
     115.  arsenic
     116.  asbestos
     118.  cadmium
     119.  chromium
     120.  copper
     122.  lead
     124.  nickel
     125.  selenium
     127.  thallium
     128.  zinc

Chlorobenzene was detected in three of 17 samples, with two of
the concentrations above the 0.025 mg/1 concentration considered
attainable with the identified treatment technology.  The values
detected above treatability were 1.00 and 0.034 mg/1.  Both of
these values are from the same waste stream and represent two of
the six samples analyzed from solvent extraction raffinate-

1,2,4-Trichloroethylene was detected in two of eight samples,
with one of the values above the 0.01 mg/1 concentration consid-
ered attainable with the identified treatment technology.  The
                               277

-------
value detected above treatability was 0.051 mg/1.  Both samples
in which 1,2,4-trichloroethylene was detected are from solvent
extraction raffinate.  Since the waste stream is from a solvent
extraction process using an organic solvent, and 1,2,4-trichloro-
ethylene was found above a treatable concentration, it is
selected for further consideration for limitation.

1,2-Dichloroethane was detected in 11 of 17 samples, with two of
the concentrations above the 0.1 mg/1 concentration considered
attainable with the identified treatment technology.  The values
detected above the quantification concentration ranged from 0.016
mg/1 to 0.156 mg/1.  1,2-Dichloroethane was detected above quan-
tification in five different process waste streams representing
two different plants.  Therefore, 1,2-dichloroethane is not
site-specific, and it is considered for further limitation.

Ethylbenzene was detected in six of 17 samples, with one of the
concentrations above the 0.05 mg/1 concentration considered
attainable with the identified treatment technology.  The values
detected above the quantification concentration ranged from 0.04
mg/1 to 0.057 mg/1.  Ethylbenzene was detected in five different
process waste streams representing two plants.  Therefore,
ethylbenzene is considered for further limitation.

Chlorodibromomethane was detected in five of 17 samples, with one
of the concentrations above the 0.10 mg/1 concentration consid-
ered attainable with the identified treatment technology.  The
values detected above the quantification concentration ranged
from 0.02 to 7.08 mg/1.   The detection of Chlorodibromomethane
was not site-specific as it was detected in three different pro-
cess wastewater streams representing two plants.  Therefore,
Chlorodibromomethane is considered for further limitation.

Trichloroethylene was detected in 13 of 17 samples, with one of
the concentrations above the 0.01 mg/1 concentration considered
attainable with the identified treatment technology.  Twelve of
these samples were below the quantification concentration.  The
value detected above the treatable concentration was 0.235 mg/1.
Trichloroethylene was detected in four different process waste
streams representing two plants.  Trichloroethylene cannot be
considered site-specific and is therefore considered for further
limitation.

Antimony was found in four of six samples analyzed; in all four
of these, it was measured above its treatable concentration
(0.047 mg/1) at concentrations ranging up to 30 mg/1.  Therefore,
antimony is selected for further consideration.
                               278

-------
Arsenic was found in all six samples analyzed; three  samples
contained concentrations above its treatable concentration of
0.34 mg/1.  Values were as high as 45 mg/1.  Therefore, arsenic
is selected for further consideration.

Analyses were made for asbestos at only one plant.  The raw
wastewater sample contained 980 million fibers per  liter  (MFL),
while the plant influent contained less than 9 MFL.   Since
asbestos was detected and is above the treatable  concentration of
10 MFL in the only sample analyzed, it is considered  for  further
limitation.

Cadmium was detected in four of six samples, and  was  found above
its treatable concentration of 0.049 mg/1.  The concentration of
cadmium in the sample was 40 mg/1.  Cadmium, therefore, is
selected for further consideration.

Five of six samples analyzed for chromium showed  concentrations
in excess of its treatable concentration  (0.07 mg/1).  Wastewater
at one sampling site was found to contain 1,000 mg/1  on each of
three days sampled.  Therefore, chromium is selected  for  further
consideration.

Copper was found in all six samples analyzed, and occurred at
concentrations above its treatable concentration  of 0.39  mg/1 in
five of these.  Values ranged from 0.8 to 300 mg/1.   Therefore,
copper is selected for further consideration.

Lead occurred far above its treatable concentration of 0.08 mg/1
in five of six samples.  Concentrations ranged from 1.0 to 1,000
mg/1.  Lead, therefore, is selected for further consideration.

Eight out of 10 samples analyzed for nickel yielded values above
the treatable concentration of 0.22 mg/1.   The reported concen-
trations were generally around 0.5 mg/1, but ran  as high  as 10
mg/1.  Therefore, nickel is selected for further  consideration.

Selenium was found in three of six samples analyzed,  all  three
above its treatable concentration (0.20 mg/1).  Values were as
high as 70 mg/1.   Therefore, selenium is selected for further
consideration.

Thallium was found above its treatable concentration  of 0.34 mg/1
in three of six samples, with concentrations of 0.83, 1.14, and
1.18 mg/1.  Therefore, thallium is selected for further
consideration.

Four of six samples analyzed contained zinc at concentrations
above the treatability concentration of 0.23 mg/1.  Values ranged
from less than 400 mg/1tto 1,000 mg/1.   Zinc is thus  selected for
further consideration.
                               279

-------
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              PRIMARY COLUMBIUM-TANTALUM  SUBCATEGORY

                           SECTION VII

                CONTROL AND TREATMENT TECHNOLOGIES
The preceding sections of this supplement discussed  the  sources,
flows, and characteristics  of the wastewaters  generated  in  the
primary columbium-tantalum  subcategory.  This  section summarizes
the description of these wastewaters  and indicates the level  of
treatment which is currently practiced  for each waste stream.

CURRENT CONTROL AND TREATMENT PRACTICES

Control and treatment technologies are  discussed in  general in
Section VII of the General  Development  Document.  The basic
principles of these technologies and  the applicability to waste-
water similar to that found in this subcategory are  presented
there.  This section presents a summary of the control and  treat-
ment technologies that are  currently  applied to each of  the
sources generating wastewater in this subcategory.   As discussed
in Section V, wastewater associated with the primary columbium-
tantalum subcategory is characterized by the presence of the
toxic metal pollutants, ammonia, 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 waste-
water 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 chem-
ical requirements.  Three plants in this subcategory currently
have combined wastewater treatment systems, three have lime
precipitation and sedimentation, and  one has lime precipitation,
sedimentation and filtration.  As such, six options  have been
selected for considereation for BPT,  BAT, BDT, BCT,  and  pretreat-
ment in this subcategory, based on combined treatment of these
compatible waste streams.

CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL

All three plants which practice digestion use hydrofluoric  acid
to leach the columbium and  tantalum ore concentrates.  The  leach-
ate goes to solvent extraction.  Wet  scrubbers are used  at  all
three plants, two with recycle (7 and 86 percent) and a  bleed
stream,  and one with once-through water usage.  Wet  scrubbers are
necessary due to the acidic nature of the emissions  and  the
presence of gaseous fluoride.  The scrubber liquor has treatable
concentrations of suspended solids, fluoride and metals.   One
                              285

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plant also reports a gangue slurry of unreacted ore which has
similar concentrations.  The addition of alkali is used in all
cases to reduce these high concentrations.  Existing wastewater
treatment schemes for this waste stream are as follows:

     1.  Lime addition and sedimentation (partial recycle);
     2.  Lime addition, sedimentation, and filtration
         (no recycle); and
     3.  Equalization pond (no recycle).

SOLVENT EXTRACTION RAFFINATE

After methyl isobutyl ketone extraction the barren raffinate must
be treated.  One plant of the three plants with this wastewater
recycles a portion of the raffinate to the leaching process to
utilize the acidic nature of this waste stream.  The raffinate
has characteristics similar to the concentrate digestion scrubber
liquor.  This stream is treated as follows:

     1.  Lime addition and sedimentation (partial recycle);
     2.  Lime addition, sedimentation, and filtration
         (no recycle); and
     3.  Neutralization and equalization pond  (no recycle).

SOLVENT EXTRACTION WET AIR POLLUTION CONTROL

This waste stream is generated by wet air pollution control
equipment located over the solvent extraction process.  Two
plants use wet scrubbers to control solvent extraction air emis-
sions.  One plant does not recycle the scrubber effluent; the
other plant uses the same scrubber for solvent extraction and
concentrate digestion, practicing 86 percent recycle.  Waste
characteristics are very similar to those found in the solvent
extraction raffinate and concentrate digester scrubber waste
streams; treatment similar to these two waste streams is indi-
cated.  Indeed, the established treatment techniques are iden-
tical:

     1.  Lime addition and sedimentation (partial recycle); and
     2.  Lime addition, sedimentation, and filtration (no
         recycle).

PRECIPITATION AND FILTRATION OF METAL SALT

The metal salts in the pregnant extraction solutions are precipi-
tated either by oxide precipitation with ammonia or by potassium
fluoride precipitation of potassium fluotantalate (I^TaFy) .
The barren solutions must subsequently be treated.  Three plants
produce this wastewater; one is a once-through discharger.  Two
plants did not report their discharge practices.  The wastewater
                               286

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contains treatable concentrations of ammonia,  fluoride, metals,
and suspended solids.  The following wastewater treatment  schemes
are practiced for this stream:

     1.  Ammonia stripping, lime addition, and sedimentation
         (partial recycle);
     2.  Ammonia stripping, lime addition, sedimentation,  and
         filtration  (no recycle); and
     3.  Neutralization and equalization pond  (no  recycle).

METAL SALT DRYING WET AIR POLLUTION CONTROL

Four of the five plants surveyed practice  salt drying  or calcin-
ing prior to further processing.  Wet scrubbers are necessary to
control fluoride emissions during this process.  Three plants
practice partial recycle, ranging from 67  to 93 percent.   The
fourth plant discharges without recycle.   This wastewater  con-
tains treatable concentrations of ammonia  when ammonia is  used in
precipitation.  Precipitation with hydrofluoric acid results in
wastewater containing treatable concentrations of  fluoride.
Suspended solids, metals are also present.  The treatment  schemes
used to treat salt drying scrubber liquor  by the four  plants
which practice salt drying are as follows:

     1.  Lime addition and sedimentation (partial  recycle);
     2.  Ammonia stripping, lime addition, sedimentation,  and
         filtration  (no recycle);
     3.  Lime addition, caustic addition,  polymer  addition,
         and sedimentation (partial recycle); and
     4.  Neutralization and equalization pond  (no  recycle).

REDUCTION OF SALT TO METAL WASTEWATER

Four plants reduce columbium or tantalum salts to  the  metal.  One
plant practices aluminothermic reduction,  which produces no
wastewater.  The other three plants practice sodium reduction.
Leaching after sodium reduction, a common  practice for tantalum
production, is a major source of wastewater.  After completion of
the reduction reaction and subsequent cooling, the tantalum
exists as small particles of metal in a matrix of  potassium and
sodium salts.  The salts are removed by successive leaches in
water and acid to produce a pure metal powder.  The resulting
wastewater contains  fluoride at treatable  concentrations,  as well
as toxic metals and oil and grease.  The wastewater treatment
schemes used for this waste stream are as  follows:

     1.  Lime addition and sedimentation (partial  recycle);
     2.  Lime addition, sedimentation, and filtration
         (no recycle); and
     3.  Caustic addition and centrifugation (no recycle).
                              287

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REDUCTION OF SALT TO METAL SCRUBBER

Wet scrubbers are used to control emissions during the reduction
reaction.  Two plants use wet scrubbers, neither practicing
recycle of the scrubber liquor.  This wastewater is similar  in
characteristic to the reduction wastewater.  It contains toxic
metals and fluoride and chloride in treatable concentrations.
Treatment for the waste stream consists of:

     1.  Lime addition and sedimentation (partial recycle);  and
     2.  Lime addition, sedimentation, and filtration
         (no recycle)

CONSOLIDATION AND CASTING CONTACT COOLING

Four plants reported consolidation and casting operations.   One
plant generates no wastewater.  Two plants use noncontact cooling
water.  The fourth plant generates contact cooling water but
recycles 100 percent through a cooling tower.  Therefore no
wastewater is discharged for this waste stream.

CONTROL AND TREATMENT OPTIONS

The Agency examined six control and treatment technology alterna-
tives that are applicable to the primary columbium-tantalum
subcategory.  The options selected for evaluation represent  a
combination of in-process flow reduction, pretreatment technology
applicable to individual waste streams, and end-of-pipe treatment
technologies.

OPTION A

Option A for the primary columbium-tantalum subcategory requires
treatment technologies to reduce pollutant mass.  The Option A
treatment schemes consists of ammonia steam stripping preliminary
treatment applied to the combined streams of precipitation and
filtration of metal salts wastewater, solvent extraction air
pollution scrubber wastewater, and concentrate digestion scrubber
wastewater.  Preliminary treatment is followed by lime precipi-
tation and sedimentation applied to the combined stream of steam
stripper effluent, solvent extraction raffinate wastewater,
reduction of salt to metal wastewater and reduction of salt  to
metal air pollution scrubbing wastewater.  Chemical precipitation
is used to remove metals and fluoride by the addition of lime
followed by gravity sedimentation.  Suspended solids are also
removed from the process.
                               288

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OPTION B

Option B for the primary columbium-tantalum  subcategory  consists
of all treatment requirements of Option A  (ammonia steam strip-
ping, lime precipitation, and sedimentation) plus control
technologies to reduce the discharge of wastewater volume.  Water
recycle and reuse are the principal control  mechanisms for  flow
reduction.

OPTION C

Option C for the primary columbium-tantalum  subcategory  consists
of all control and treatment requirements  of Option B  (ammonia
steam stripping, in-process flow reduction,  lime precipitation,
and sedimentation) plus multimedia filtration  technology added at
the end of the Option B treatment scheme.  Multimedia  filtration
is used to remove suspended solids, including  precipitates  of
metals and fluoride, beyond 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 as well.   The
addition of filters also provides consistent removal during
periods in which there are rapid increases in  flows or loadings
of pollutants to the treatment system.

OPTION D

Option D for the primary columbium-tantalum  subcategory  consists
of Option C (ammonia steam stripping, in-process flow  reduction,
lime precipitation, sedimentation, and multimedia filtration)
with the addition of activated alumina technology at the end of
the Option C treatment scheme.  The activated  alumina process is
used to remove dissolved arsenic which remains after lime
precipitation.

OPTION E

Option E for the primary columbium-tantalum  subcategory  consists
of Option C (ammonia steam stripping, in-process flow reduction,
lime precipitation, sedimentation, and multimedia filtration)
with the addition of granular activated carbon technology at the
end of the Option C treatment scheme.  The activated carbon
process is utilized to control the discharge of toxic organics.

OPTION F

Option F for the primary columbium-tantalum  subcategory  consists
of Option C (ammonia steam stripping, in-process flow reduction,
lime precipitation, sedimentation, and multimedia filtration)
                               289

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                           SECTION VIII

            COSTS, ENERGY AND NONWATER QUALITY ASPECTS


This section describes the method used to develop the costs asso-
ciated with the control and treatment technologies suggested in
Section VII for wastewaters from primary columbium-tantalum
plants.  Cost curves are presented showing the total annual cost
of each treatment and control technology as a function of waste-
water flow rate.  The energy consumption of each technology as
well as solid waste and air pollution aspects are also discussed.
A discussion concerning the costing methodology is contained in
Section VIII of the General Development Document.

For costing purposes, the primary columbium-tantalum subcategory
has been divided into two groups:  ore to salt or metal and salt
to metal.  Costs are determined for each of the two types of
plants currently in existence by using the annual cost curves
developed for each of these two groups.

The ore to salt or metal group contains plants which have pre-
liminary ammonia steam stripping followed by lime precipitation
and sedimentation technology in place, and plants which do not
have these technologies in place.  Therefore, costs have been
developed for each of those two combinations of wastewater treat-
ment.  Combination 1 represents the plants which practice pre-
liminary ammonia steam stripping followed by lime precipitation
and sedimentation technology.  Combination 2 represents the
plants which do not have preliminary ammonia steam stripping
followed by lime precipitation and sedimentation technology in
place.  Each combination consists of the following wastewaters:

     1.   Concentrate digestion wet air pollution control
         wastewater,
     2.   Solvent extraction raffinate,
     3.   Solvent extraction wet air pollution control wastewater,
     4.   Precipitation and filtration of metal salt wastewater,
     5.   Metal salt drying wet air pollution control wastewater,
     6.   Reduction of salt to metal wastewater, and
     7.   Reduction of salt to metal wet air pollution control
         wastewater.

The salt to metal group contains the following wastewaters:

     1.   Metal salt drying wet air pollution control wastewater,
     2.   Reduction of salt to metal wastewater, and
     3.   Reduction of salt to metal wet air pollution control
         wastewater.
                              291

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Ammonia steam stripping is not considered in the costs developed
for the combined salt to metal group wastewaters since ammonia is
not present in those waste streams.

TREATMENT OPTIONS POSTED FOR EXISTING SOURCES

Six control and treatment options are considered for treating
wastewater from the primary columbium-tantalum subcategory.  Cost
estimates in the form of annual cost curves have been developed
for each of the control and treatment options.  The options are
summarized below and presented schematically in Figures X-l
through X-6.

OPTION A

Option A for the primary columbium-tantalum subcategory consists
of lime precipitation and sedimentation end-of-pipe technology,
with ammonia steam stripping preliminary treatment for waste
streams containing treatable concentrations of ammonia.  Streams
with treatable concentrations of ammonia include precipitation
and filtration of metal salts wastewater, concentration digestion
scrubber water, and solvent extraction scrubber water.  Cost
curves for Option A are not presented for the ore to salt or
metal group combination 1 plants, since these plants already have
Option A technology in place.  Also, as mentioned previously, the
cost curves for the salt to metal group do not consider ammonia
steam stripping since ammonia is not present in this group's
wastewaters.  The curves for the ore to salt or metal group com-
bination 2 plants assume that 11 percent of the wastewaters
receive ammonia steam stripping preliminary treatment.

OPTION B

Option B for the primary columbium-tantalum subcategory requires
control and treatment technologies to reduce the discharge of
wastewater volume and pollutant mass.  The recycle of metal salt
drying scrubber water, concentrate digestion scrubber, and sol-
vent extraction scrubber water through holding tanks is the con-
trol mechanism for flow reduction.  The Option B treatment scheme
consists of ammonia steam stripping preliminary treatment for
streams containing treatable concentrations of ammonia, and
end-of-pipe treatment technology consists of lime precipitation
and sedimentation.  The cost of Option B is the cost of holding
tanks for the ore to salt or metal combination 1 plants.  For the
ore to salt or metal combination 2 plants and the salt to metal
plants, holding tank costs are added to the Option A cost to
determine the cost of Option B.
                               292

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OPTION C

Option C consists of all the control and  treatment technologies
of Option B (flow reduction, ammonia steam stripping, lime pre-
cipitation, and sedimentation) with the addition of multimedia
filtration to the end-of-pipe treatment scheme.  The holding
tanks used for flow reduction are not  included  in the cost curves
developed for Option C.  Therefore, the total cost of Option C is
determined by adding holding tank costs to the  costs obtained
from the Option C cost curves.  For the ore to  salt or metal com-
bination 1 group plants, the cost curves  for Option C and the
options which follow represent the incremental  cost associated
with adding the various end-of-pipe technologies to existing
treatment.

OPTION D

Option D consists of all the control and  treatment technologies
of Option C (flow reduction, ammonia steam stripping, lime pre-
cipitation, sedimentation, and multimedia filtration) with the
addition of activated alumina adsorption  to the end-of-pipe
treatment scheme.  As with Option C, the  total  cost of Option D
is determined by adding holding tank costs to the costs obtained
from the Option D cost curves.

OPTION E

Option E consists of all the control and  treatment technologies
of Option C (flow reduction, ammonia steam stripping, lime pre-
cipitation, sedimentation, and multimedia filtration) with the
addition of activated carbon adsorption to the  end-of-pipe treat-
ment scheme.   Holding tank costs must  also be added to the costs
obtained from the Option E cost curves to determine the total
cost of Option E.

OPTION F

Option F consists of all the control and  treatment technologies
of Option C (flow reduction, ammonia steam stripping, lime pre-
cipitation, sedimentation, and multimedia filtration) with the
addition of reverse osmosis and multiple-effect evaporation
followed by complete recycle to the end-of-pipe treatment scheme.
The total cost of Option F is determined by adding holding tank
costs to the costs obtained from the Option F cost curves.

The cost curves for the options summarized above are presented in
the figures listed below.  The respective options which the
curves are based on are also shown.
                              293

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       Group           Combination   Figure VIII-   Option Posted

Ore to Salt or Metal        1           1-4       C,D,E,F

Ore to Salt or Metal        2           5-9       A, C, D, E, F

Salt to Metal               1          10-14      A, C, D, E, F

The holding tank cost curves are presented in Figure VIII-15.

NONWATER QUALITY ASPECTS

A general discussion of the nonwater quality aspects of the con-
trol and treatment options considered for the nonferrous metals
category is contained in Section VIII of the General Development
Document.  Nonwater quality impacts specific to the primary
columbium-tantalum subcategory, including energy requirements,
solid waste and air pollution are discussed below.

ENERGY REQUIREMENTS

The methodology used for determining the energy requirements for
the various options is discussed in Section VIII of the General
Development Document.  Briefly, the energy usage of the various
options is determined for the primary columbium-tantalum plant
with the median wastewater flow.  The energy usage of the options
is then compared to the energy usage of the median primary
columbium-tantalum energy consumption plant.  As shown in Table
VIII-1, the most energy intensive option is reverse osmosis,
which increases the usage of the median primary columbium-
tantalum energy consumption by 0.42 percent.

SOLID WASTE

Sludges associated with the primary columbium-tantalum subcate-
gory will necessarily contain additional quantities (and concen-
trations) of toxic metal pollutants.  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). Consequently, sludges generated from treating
primary industries1 wastewater are not presently subject to
regulation as hazardous wastes.

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).
                               294

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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 genera-
tor 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  treat-
ment, 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.  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  chemical precipita-
tion, sedimentation, multimedia filtration and reverse osmosis.
These technologies transfer pollutants to solid waste and do not
involve air stripping or any other physical process likely to
transfer pollutants to air.
                               295

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                COLUMBIUM-TANTALUM  (ORE TO SALT/METAL)
                        COMBINATION  1,  OPTION C
                                   297

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                        SLUDGE REMOVAL
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                COLUMBIUM-TANTALUM (ORE TO  SALT/METAL)
                        COMBINATION 1,  OPTION  D
                                   298

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                 COLUMBIUM-TANTALUM (ORE  TO SALT/METAL)
                         COMBINATION 1, OPTION E
                                     299

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 10'
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                              SLUDGE REMOVAL

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                              MATERIAL
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                               Figure  VIII-4


                 COLUMBIUM-TANTALUM  (ORE TO  SALT/METAL)
                         COMBINATION  1,  OPTION F
                                    300

-------
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-------
                            SLUDGE REMOVAL
                            CHEMICALS
                            ENERGY
                            MATERIALS
                                                LABOR
                                                DEPRECIATION
                                                CAPITAL
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      Figure  VIII-7
10,000
100,000
               COLUMBIUM-TANTALUM  (ORE TO SALT/METAL)
                       COMBINATION  2,  OPTION  D
                T
                          i i i i il   i  i   i i i i MI
100
                                   1,000
                               FLOW, cu m/day

                             Figure  VIII-8
10,000
                                      100,000
                COLUMBIUM-TANTALUM (ORE TO  SALT/METAL)
                       COMBINATION 2,  OPTION E
                                   302

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                       Figure VIII-9
                       10,000
100,000
                   COLUMBIUM-TANTALUM  (ORE TO SALT/METAL)
                            COMBINATION  2, OPTION F
  10
  I06
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                       Figure VIII-10
                                                    10,000
                                    100,000
                   COLUMBIUM-TANTALUM  (SALT TO METAL)
                            COMBINATION  1,  OPTION A
                                      303

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                               Figure VIII-11
                    COLUMBIUM-TANTALUM (SALT TO METAL)
                          COMBINATION  1,  OPTION  C
 10
  10
           10
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                FLOW, cu m/day
              Figure VI11-12
                                             10,000
100,000
                  COLUMBIUM-TANTALUM  (SALT TO  METAL)
                          COMBINATION  1,  OPTION D
                                    304

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                                 SLUDGE REMOVAL-
                                 CHEMICALS-
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                                                        LABOR
                                                        DEPRECIATION
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  107
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            Figure  VIII-13

COLUMBIUM-TANTALUM (SALT TO METAL)
      COMBINATION  1, OPTION E
                                       100,000
  10"
o
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                                 SLUDGE REMOVAL-
                                 CHEMICALS
                                 ENERGY
      r
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                                                        LABOR
                                                        DEPRECIATION
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       Figure  VIII-14
                                10,000
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                  COLUMBIUM-TANTALUM (SALT TO METAL)
                          COMBINATION 1, OPTION F
                                    305

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  106
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                             Figure VIII-15
                           HOLDING  TANK COSTS
                                                            iao
                                    306

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                            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 primary columbium-tantalum
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 facili-
ties 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 charac-
teristics.  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, transfera-
ble, 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. llTF)~.  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 the category
using data collection portfolios, and specific plants were
sampled and the wastewaters analyzed.  Some of the factors which
must be considered in establishing effluent limitations based on
BPT have already been discussed.  The age of equipment and facil-
ities, 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.
                               307

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As explained in Section IV, the primary columbium-tantalum
subcategory has been subdivided into eight 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
eight subdivisions.

For each of the subdivisions, 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  deter-
mined 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 ana-
lyzed to determine (1) whether or not operations included gener-
ated 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 waste-
water such as rainfall runoff and noncontact cooling water is not
considered in the analysis.

Normalized flqws 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 dis-
charge rate) reflects the water use controls which are common
practices within the category.  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.

For the development of effluent limitations, mass loadings were
calculated for each wastewater source or subdivision.  This cal-
culation was made on a stream-by-stream basis, primarily  because
plants in this subcategory may perform one or more of the opera-
tions in various combinations.  The mass loadings (milligrams of
pollutant per metric ton of production unit - mg/kkg) 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 loadings which are allowed under BPT for each plant will
be the sum of the individual mass loadings for the various waste-
water 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 efflu-
ent limitations for these combined wastewaters are based  on the
various wastewater sources which actually contribute to the com-
bined flow.  This method accounts for the variety of combinations
of wastewater sources and production processes which may  be found
at columbium-tantalum plants.
                               303

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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 subcategory.

BPT effluent limitations are based on the average of the  dis-
charge flow rates for each source; consequently, the treatment
technologies which are currently used by the lowest dischargers
will be the treatment technologies most likely required to meet
BPT effluent limitations.  Section VII discusses the various
treatment technologies which are currently in place for each
wastewater source.  In most cases, the current treatment  technol-
ogies consist of chemical precipitation and sedimentation (lime
and settle technology) and a combination of reuse and recycle to
reduce flow.  Ammonia steam stripping is added to streams with
treatable concentrations of ammonia.

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 REDUCTION BENEFITS

In balancing costs in relation to  effluent reduction benefits,
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 BPT.  See Weyerhaeuser
Company v. Costle, 590 F. 2d 1011  (D.C. Cir. 1978).
                               309

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The methodology for calculating pollutant reduction benefits and
plant compliance costs is discussed in Section X.  Table X-2
shows the estimated pollutant reduction benefits for each treat-
ment option for direct dischargers.  Compliance costs are pre-
sented in Table X-3.

BPT OPTION SELECTION

The BPT selected consists of chemical precipitation and sedimen-
tation (lime and settle technology) with ammonia steam stripping
preliminary treatment of wastewaters containing treatable concen-
trations of ammonia.  The best practicable technology is pre-
sented in Figure IX-1.  The BPT treatment is equivalent to Option
A described in Section VII.

Ammonia steam stripping is demonstrated in the nonferrous metals
manufacturing category and at two primary columbium-tantalum
facilities.  EPA believes that performance data from the iron and
steel manufacturing category provide a valid measure of this
technology's performance on nonferrous metals manufacturing
category wastewater because raw wastewater concentrations of
ammonia are generally of the same order of magnitude in the
respective raw wastewater matrices.

Chemical analysis data were collected of raw waste (treatment
influent) and treated waste (treatment effluent) from one coke
plant of the iron and steel manufacturing category.  A contractor
for EPA, using EPA sampling and chemical analysis protocols, col-
lected six paired samples in a two-month period.  These data are
the data base for determining the effectiveness of ammonia steam
stripping technology and are contained within the public record
supporting this document.  Ammonia treatment at this coke plant
consisted of two steam stripping columns in series with steam
injected countercurrently to the flow of the wastewater.  A lime
reactor for pH adjustment separated the two stripping columns.

The raw untreated wastewater samples from the coke facility con-
tained ammonia concentrations of 599, 226, 819, 502, 984, and 797
mg/1.  Raw untreated wastewater samples from the primary
columbium-tantalum subcategory contained ammonia concentrations
of 53.1 , 496.1, 25,700, 18,500, and 16,900 mg/1.  These latter
three concentrations represent three days of sampling from a
metal salt drying scrubber.  Although these concentrations are
much larger than the data used to develop the ammonia steam
stripping performance values, the Agency believes that these
performance values are still achievable.
                               310

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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 dcp.  The discharge rate  is used with the
achievable treatment concentration  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 eight wastewater sources are discussed below and
summarized in Table IX-1.  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,  or PNP's, are listed in  Table
IX-1.

Section V of this document further  describes the discharge  flow
rates and presents the water use and discharge flow rates for
each plant by subdivision.

CONCENTRATE DIGESTION WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for concentrate digestion wet
air pollution control is 10,915 1/kkg (2,618 gal/ton) of
columbium-tantalum salt produced from digestion.  This rate is
allocated only for plants practicing wet air pollution control
for concentrate digestion.  Three plants reported wastewater dis-
charges from concentrate digestion  wet air pollution control,  but
dcp information provided by one plant was  insufficient to calcu-
late a discharge rate.  Therefore,  the BPT discharge rate is
based on the average of two plants  which discharge 8,692.4  and
13,135.5 1/kkg (2,084.5 and 3,150 gal/ton).  Water use and
discharge rates are presented in Table V-l.

SOLVENT EXTRACTION RAFFINATE

The BPT wastewater discharge rate for solvent extraction raffi-
nate is 26,916 1/kkg (6,470.4 gal/ton) of  columbium or tantalum
salt extracted.  This rate is based on the average discharge rate
of two plants, which discharge 19,268 and  34,694 1/kkg (4,620  and
8,320 gal/ton).  A third plant reported insufficient data to
calculate a discharge rate.  Water  use and discharge rates  are
presented in Table V-3.

SOLVENT EXTRACTION WET AIR POLLUTION CONTROL

The BPT discharge rate for solvent  extraction wet air pollution
control is 4,301 1/kkg (1,034 gal/ton) of  columbium or tantalum
salt extracted.  This rate is allocated only for plants practic-
ing wet air pollution control for solvent  extraction.  Two  plants
reported this wastewater, however,  one plant uses the same  scrub-
ber for both solvent extraction and concentrate digestion wet  air
pollution control.  This plant should not  receive a discharge
                               311

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allowance for solvent extraction wet air pollution control
because the entire flow for this scrubber was allocated to con-
centrate digestion scrubbing and would result in double counting.
The BPT discharge rate is based on the discharge rate of the
single plant which will receive an allowance for solvent
extraction wet air pollution control.  Water use and discharge
rates are presented in Table V-5.

PRECIPITATION AND FILTRATION OF METAL SALTS

The BPT wastewater discharge rate for precipitation and filtra-
tion waste streams is 247,223 1/kkg  (59,428 gal/ton) of colum-
bium or tantalum salt precipitated.  Three plants reported pro-
ducing this waste stream.  The BPT discharge rate is based on the
discharge rate of one of the plants.  The two other plants
reported insufficient data to calculate a discharge rate.  Water
use and discharge rates are presented in Table V-7.

METAL SALT DRYING WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for metal salt drying wet air
pollution control is 83,643 1/kkg (20,106 gal/ton) of columbium
or tantalum salt dried.  This rate is allocated only for plants
practicing wet air pollution control for metal salt drying emis-
sions.  Four plants discharge a metal salt drying wet air pollu-
tion control waste stream.  Two plants discharging this waste
stream reported sufficient dcp information to calculate a
discharge rate.  The two plants generate 11,563 and 156,125 1/kkg
(2,773 and 37,440 gal/ton) respectively, of metal salt drying wet
air pollution wastewater.  The BPT discharge is the average
discharge rate of these two plants.  Water use and discharge
rates are presented in Table V-9.

REDUCTION OF SALT TO METAL

The BPT wastewater discharge rate for reduction of salt to metal
is 352,663 1/kkg (84,775 gal/ton) of columbium or tantalum
reduced.  This rate is based on the average discharge rate of two
plants, which discharge 170,740 and 536,282 1/kkg  (40,945 and
128,605 gal/ton).  A third plant reported insufficient dcp
information to calculate a discharge rate.  Water use and
discharge rates are presented in Table V-ll.

REDUCTION OF SALT TO METAL WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for reduction of salt to metal
wet air pollution control is 21,521  1/kkg (5,173 gal/ton) of
columbium or tantalum reduced.  This rate is allocated only for
those plants practicing wet air pollution control  for reduction
emissions.  The BPT discharge rate is based on the average dis-
charge rate of the two plants reporting this wastewater.  The two
                               312

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plants generate 2,168 and 40,978 1/kkg  (520 and 9,827 gal/ton)
respectively, of this wastewater.  Water use and discharge rates
are presented in Table V-12.

CONSOLIDATION AND CASTING CONTACT COOLING

No BPT wastewater discharge allowance is provided  for consolida-
tion and casting contact cooling.  Only one plant  in this sub-
category reported a consolidation and casting contact cooling
waste stream.  This plant does not discharge this  wastewater.
BPT is based on this plant.

REGULATED POLLUTANT PARAMETERS

The raw wastewater concentrations from  individual  operations and
the subcategory as a whole were examined to select certain pollu-
tant parameters for limitation.  This examination  and evaluation
was presented in Section VI.  A total of six pollutants or pollu-
tant parameters were selected for limitation and are listed
below:

     122.  lead
     128.  zinc
           ammonia
           fluoride
           total suspended solids
           pH

EFFLUENT LIMITATIONS

The treatability concentrations achievable by application of the
proposed BPT treatment are explained in Section VII of General
Development Document and summarized there in Table VII-19.  The
achievable treatment 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
metric ton of product represent the BPT effluent limitations and
are presented in Table IX-2 for each individual waste stream.
                              313

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                            Table IX-2

                 BPT EFFLUENT LIMITATIONS FOR THE
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
         Concentrate Digestion Vet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of columbium-tantalum salt produced
                          from digestion
    English Units - Ibs/billion Ibs of columbium-tantalum salt
                     produced from digestion
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    1,637.25
   14,516.95
1,451,695.0
  649,442.50
  447,515.0
    1,418.95
    6,112.40
  639,619.0
  288,156.0
  218,300.0
Within the range of 7.5 to 10.0
         at all times
                   Solvent Extraction Raffinate

                                   Maximum for
Pollutant or Pollutant Property    Any One Day
                  Maximum for
                Monthly Average
  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    4,037.40
   35,798.28
3,579,828.0
1,601,502.0
1,103,556.0
Within the range of 7.5 to 10.0
         at all times
     3,499.08
    15,072.96
 1,577,277.60
   710,582.40
   538,320.0
                               315

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                      Table IX-2 (Continued)

                 BPT EFFLUENT LIMITATIONS FOR THE
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
           Solvent Extraction Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
       645.21
     5,720.86
   572,086.20
   255,933.30
   176,357.40
       559.18
     2,408.78
   252,062.04
   113,556.96
    86,028.0
 Within the range of 7.5 to 10.0
          at all times
           Precipitation and Filtration of Metal Salts


Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    37,083.45
   328,806.59
32,880,659.0
14,709,768.50
10,136,143.0
    32,138.99
   138,444.88
14,487,267.80
 6,526,687.20
 4,944,460.0
 Within the range of 7.5 to 10.0
          at all times
                               316

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                      Table IX-2 (Continued)

                 BPT EFFLUENT LIMITATIONS FOR THE
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
           Metal Salt Drying Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    12,546.45
   111,245.19
11,124,519.0
 4,976,758.50
 3,429,363.0
    10,873.59
    46,840.08
 4,901,479.80
 2,208,175.20
 1,672,860.0
 Within the range of 7.5 to 10.0
          at all times
                    Reduction of Salt to Metal
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
    52,899.45
   469,041.79
46,904,179.0
20,983,448.50
14,459,183.0
    45,846.19
   197,491.28
20,666,051.80
 9,310,303.20
 7,053,260.0
                                  Within the range of 7.5 to 10.0
                                           at all times
                               317

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                      Table IX-2 (Continued)

                 BPT EFFLUENT LIMITATIONS FOR THE
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
       Reduction of Salt to Metal Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
    3,228.15
   28,622.93
2,862,293.0
1,280,499.50
  882,361.0
     2,797.73
    12,051.76
 1,261,130.60
   568,154.40
   430,420.0
Within the range of 7.5 to 10.0
         at all times
            Consolidation and Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
        0
        0
        0
        0
        0
         0
         0
         0
         0
         0
Within the range of 7.5 to 10.0
         at all times
                               318

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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                            SECTION X

        BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE


The effluent limitations which must be achieved by July  1, 1984
are based on the best control and treatment technology used by a
specific point source within the industrial category or  subcate-
gory, or by another industry where it is readily 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).  At a minimum BAT technology
represents the best available technology at plants of various
ages, sizes, processes, or other characteristics.  As with BPT,
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 feasible process
changes or internal controls, even when not in common industry
practice.

The statutory assessment of BAT considers costs, but does not
require a balancing of costs against effluent reduction  benefits
(see Weyerhaeuser v. Costle, 11 ERG 2149 (D.C. Cir. 1978)).
However, in assessing the proposed BAT, the Agency has given
substantial weight to the economic achievability of the  selected
technology.

TECHNICAL APPROACH TO BAT

In pursuing this second round of effluent limitations, 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 six technology
options which could be applied to the primary columbium-tantalum
subcategory as treatment options for the basis of BAT effluent
limitations.
                               321

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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 treat-
ment technology and reductions in the effluent flows allocated to
various waste streams.

In summary, the treatment technologies considered for BAT are
presented below:

Option A (Figure X-l) is based on

     o  Preliminary treatment with ammonia steam stripping
     o  Chemical precipitation and sedimentation

Option B (Figure X-2) is based on

     o  Preliminary treatment with ammonia steam stripping
     o  Chemical precipitation and sedimentation
     o  In-process flow reduction

Option C (Figure X-3) is based on

     o  Preliminary treatment with ammonia steam stripping
     o  Chemical precipitation and sedimentation
     o  In-process flow reduction
     o  Multimedia filtration

Option D (Figure X-4) is based on

     o  Preliminary treatment with ammonia steam stripping
     o  Chemical precipitation and sedimentation
     o  In-process flow reduction
     o  Multimedia filtration
     o  Activated alumina adsorption for fluoride removal

Option E (Figure X-5) is based on

     o  Preliminary treatment with ammonia steam stripping
     o  Chemical precipitation and sedimentation
     o  In-process flow reduction
     o  Multimedia filtration
     o  Preliminary treatment with activated carbon adsorption

Option F (Figure X-6) is based on

     o  Preliminary treatment with ammonia steam stripping
     o  Chemical precipitation and sedimentation
     o  In-process flow reduction
     o  Multimedia filtration
     o  Reverse osmosis in conjunction with multiple-effect
        evaporation


                               322

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The six options examined  for BAT are  discussed  in  greater  detail
below.  The first option  considered is the same as the BPT treat-
ment which was presented  in the previous  section.  The last five
options each represent substantial progress  toward the prevention
of polluting the environment above and beyond the  progress
achievable by BPT.

OPTION A

Option A for the primary  columbium-tantalum  subcategory  is equiv-
alent to the control and  treatment technologies which were
analyzed for BPT in Section IX.  The  BPT  end-of-pipe treatment
scheme includes lime precipitation, sedimentation, with  ammonia
steam stripping preliminary treatment (see Figure X-l).  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 primary  columbium-tantalum  subcategory  achieves
lower pollutant discharge by building upon the Option A  end-of-
pipe treatment technology, which consists of ammonia steam
stripping, lime precipitation, and sedimentation.  Flow  reduction
measures are added to Option A treatment  (see Figure X-2).  These
flow reduction measures,  including in-process changes, result  in
the elimination of some wastewater streams and the concentration
of pollutants in other effluents.  Treatment of a more concen-
trated effluent allows achievement of a greater net pollutant
removal and introduces the possible economic benefits associated
with treating a lower volume of wastewater.

Methods used in Option B  to reduce process wastewater generation
or discharge rates are presented below:

Recycle of Water Used in Wet Air Pollution Control

There are four wastewater sources associated with wet air
pollution control which are regulated under  these effluent
limitations:

     --Concentrate digestion scrubber,
     --Solvent extraction scrubber,
     --Metal salt drying  scrubber, and
     --Reduction of salt to metal scrubber.

Table X-l presents the number of plants reporting wastewater use
with these sources, the number of plants  practicing recycle of
scrubber liquor, and the range of recycle values being used.
Although some plants report total recycle of their scrubber
                               323

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water, some blowdown or periodic cleaning is likely to be needed
to prevent the buildup of dissolved and suspended solids since
the water picks up particulates and fumes from the air.

OPTION C

Option C for the primary columbium-tantalum subcategC'ry consists
of all control and treatment requirements of Option B (ammonia
steam stripping, in-process flow reduction, lime precipitation,
and sedimentation) plus multimedia filtration technology added at
the end of the Option B treatment scheme (see Figure X-3).
Multimedia filtration is used to remove suspended solids,
including precipitates of toxic metals, beyond the concentrations
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 as well.

OPTION D

Option D for the primary columbium-tantalum subcategory consists
of Option C (ammonia steam stripping, in-process flow reduction,
lime precipitation, sedimentation, and multimedia filtration)
with the addition of activated alumina technology at the end of
the Option C treatment scheme (see Figure X-4).   The activated
alumina process will provide further improvement in the effluent
quality by removing fluoride from the effluent.

OPTION E

Option E for the primary columbium-tantalum subcategory consists
of Option C (ammonia steam stripping, in-process flow reduction,
lime precipitation, sedimentation, and multimedia filtration)
with the addition of granular activated carbon technology at the
end of the Option C treatment scheme (see Figure X-5).  The
activated carbon process is utilized to control the discharge of
toxic organics.

OPTION F

Option F for the primary columbium-tantalum subcategory consists
of Option C (ammonia steam stripping, in-process flow reduction,
lime precipitation, sedimentation, and multimedia filtration)
with the addition of reverse osmosis and multiple-effect evapora-
tion technologies at the end of the Option C treatment scheme
(see Figure X-6).  Option F is used for complete recycle of the
treated water by controlling the concentration of dissolved
solids.
                               324

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INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

As one means of evaluating each technology option, EPA developed
estimates of the pollutant reduction benefits and the compliance
costs associated with each option.  The methodologies are
described below.

POLLUTANT REDUCTION BENEFITS

A complete description of the methodology used to calculate the
estimated pollutant reduction, or benefit, achieved by the appli-
cation of the various treatment options is presented in Section X
of the General Development Document.  In short, sampling data
collected during the field sampling program were used to charac-
terize the major waste streams considered for regulation.  At
each sampled facility, the sampling data was production normal-
ized 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 columbium-tantalum subcategory.  By multi-
plying 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 by multiplying the regulatory flow
determined for each unit process by the total subcategory produc-
tion.  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 dis-
charged by the subcategory.   The mass of pollutant removed,
referred to as the benefit, is simply the difference between the
estimated mass of pollutant generated within the subcategory and
the mass of pollutant discharged after application of the treat-
ment option.

The pollutant reduction benefit estimates for the primary
columbium-tantalum subcategory are presented in Table X-2.

COMPLIANCE COST

In estimating subcategory-wide compliance costs, the first step
was to develop uniformly-applicable cost curves, relating 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 annual-
ized capital costs, and the operating and maintenance costs,


                               325

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yielding the cost of compliance for the subcategory  (See Table
X-3).  These costs were used in assessing economic achievabil-
ity.

BAT OPTION SELECTION

EPA has selected Option C as the basis for BAT in this subcate-
gory.  The combination of in-process controls and end-of-pipe
technologies increases the removal of toxic pollutants by an
estimated 285 kg/yr and nonconventionals by 2,424 kg/yr over
estimated BPT discharges.  Removals from the raw waste generated
are estimated at 145,735 kg/yr of toxic metals and 1,286,679
kg/yr of nonconventional pollutants.  The end-of-pipe treatment
configuration for Option C was presented in Figure X-3.

Activated alumina (Option D) was considered; however, this
technology was rejected because it was not demonstrated in  this
category nor was it clearly transferable to nonferrous waste-
water.  Activated carbon (Option E) was also considered; however,
this technology was eliminated because it is not necessary  since
toxic organic pollutants are not selected for limitation in this
subcategory.  Reverse osmosis (Option F) was considered for the
purpose of achieving zero discharge of process wastewater;  how-
ever, the Agency ultimately rejected this technology because it
was determined that its performance for this specific purpose was
not adequately demonstrated in this category nor was it clearly
transferable from another category.

WASTEWATER DISCHARGE RATES

A BAT discharge rate was calculated for each subdivision based
upon the flows of the existing plants, as determined from analy-
sis of dcp.  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 eight wastewater sources were determined and  are summa-
rized in Table X-4.  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-4.

The BAT wastewater discharge rate equals the BPT wastewater dis-
charge rate for five of the eight waste streams in the primary
columbium-tantalum subcategory.  Based on the available data, the
Agency did not find that further flow reduction would be feasible
for these wastewater sources.  The rationale for determining
these regulatory flows is presented in Section IX.  Wastewater
streams for which BAT discharge rates differ from BPT are
discussed below.
                                326

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CONCENTRATE DIGESTION WET AIR POLLUTION  CONTROL

The BAT wastewater discharge rate  for  concentrate  digestion wet
air pollution control is 5,156  1/kkg  (1,237  gal/ton)  of
columbium-tantalum salt produced from  digestion.   This rate is
allocated only to those plants  with concentrate digestion  wet air
pollution control.  The BAT discharge  rate  is  based  on 90  percent
recycle of the average water use of two  plants.  A third plant
reported insufficient dcp information  to calculate a discharge
rate.  Water use and discharge  rates are presented in Table V-l.

SOLVENT EXTRACTION WET AIR POLLUTION CONTROL

The BAT wastewater discharge rate  for  solvent  extraction wet air
pollution control is 430 1/kkg  (103 gal/ton) of columbium  or
tantalum salt extracted.  This  rate is allocated only to those
plants with concentrate digestion  wet  air pollution  control.  The
BAT discharge rate is based on  90  percent recycle  of the water
use at one of the two plants which generate  this waste stream.
One plant uses the same scrubber for both solvent  extraction and
concentrate digestion wet air pollution  control.   This plant is
regulated under concentrate digestion wet air  pollution control
and should not receive a discharge allowance for solvent extrac-
tion wet air pollution control  in  order  to prevent double
counting of this flow.  Water use  and  discharge rates are
presented in Table V-3.

METAL SALT DRYING WET AIR POLLUTION CONTROL

The BAT wastewater discharge rate  for metal  salt drying wet air
pollution control is 16,479.4 1/kkg (3,961.4 gal/ton) of colum-
bium or tantalum salt dried.  This rate  is allocated  only  to
those plants with metal salt drying wet  air  pollution control.
Four plants generate this waste stream.   The BAT discharge rate
is based on 90 percent recycle  of  the water  use at one of  these
plants.  Two plants reported insufficient dcp  information  to
calculate water usage, and the  water usage of  one  plant was
extremely high.   These plants were not considered  in  calculating
the BAT discharge rate.  Water  use and discharge rates are
presented in Table V-9.

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) (1976T7 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 limitation.  This examination and
evaluation was presented in Section VI.   The Agency,   however, has
chosen not to regulate all 19 toxic pollutants selected in this
analysis.
                               327

-------
The columbium-tantalum subcategory generates an estimated 211,000
kg/yr of toxic pollutants, of which only 170 kg/yr are toxic
organic pollutants.  The Agency believes that the toxic organic
pollutants in the columbium-tantalum subcategory are present only
in trace (deminimus quantities) and are neither causing nor
likely to cause toxic effects.  Therefore, the following toxic
organic pollutants are excluded from regulation:

      7.  chlorobenzene
      8.  1,2,4-trichlorobenzene
     10.  1,2-dichloroethane
     30.  1,2-trans-dichloroethylene
     38.  ethylbenzene
     51.  chlorodibromomethane
     87.  trichloroethylene

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 proposing effluent mass
limitations only for those pollutants generated in the greatest
quantities as shown by the pollutant reduction benefit analysis.
The pollutants selected for specific limitation are listed below:

     122.  lead
     128.  zinc
           ammonia (as N)
           fluoride

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 technically justified since the treatable con-
centrations used for lime precipitation and sedimentation tech-
nology are based on optimized treatment for concommitant 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 tech-
nology removes metals non-preferentially.

The toxic metal pollutants selected for specific limitation in
the columbium-tantalum subcategory to control the discharges of
toxic metal pollutants are lead and zinc.  Ammonia is also
                               328

-------
selected for limitation since the methods used  to control  lead
and zinc are not effective in the control of ammonia.  The  fol-
lowing toxic pollutants are excluded  from limitation on  the basis
that they are effectively controlled  by the limitations  developed
for lead and zinc:

     114.  antimony
     115.  arsenic
     116.  asbestos
     118.  cadmium
     119.  chromium  (Total)
     120.  copper
     124.  nickel
     125.  selenium
     127.  thallium

The conventional pollutant parameters pH and TSS will be limited
by the best conventional technology (BCT) effluent limitations.
These effluent limitations and a discussion of  BCT are presented
in Section XIII of this supplement.

EFFLUENT LIMITATIONS

The concentrations achievable by application of BAT are  discussed
in Section VII of the General Development Document and summarized
there in Table  VII-19.  The treatability concentrations both one
day maximum and monthly average values are multiplied by the BAT
normalized discharge flows summarized in Table X-4 to calculate
the mass of pollutants allowed to be  discharged per mass of
product.  The results of these calculations in milligrams of
pollutant per metric ton of product represent the BAT effluent
limitations and are presented in Table X-5 for each waste stream.
                              329

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                          Table X-l

             CURRENT RECYCLE PRACTICES WITHIN THE
            PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
Concentrate Digestion

Solvent Extraction

Metal Salt Drying

Reduction of Salt to
 Metal
 Number of
Plants With
Wastewater

     3

     2

     4

     2
  Number
of Plants
Practicing
 Recycle

    2

    1

    3

    0
 Range of
 Recycle
Values (7,)

  7-86

  0-86

 67 - 89
                             330

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                 Table X-3

         COST OF COMPLIANCE FOR THE
   PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
            Capital Cost       Annual Cost
Option     (1978 Dollars)     (1978 Dollars)

  AGO

  B             86,000            13,000

  C            797,000           396,000

  D            872,000           439,000

  E          1,270,000           571,000

  F            986,000           504,000
                    333

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                            Table X-5

                 BAT EFFLUENT LIMITATIONS FOR THE
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
         Concentrate Digestion Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of columbium or tantalum salt
                     produced from digestion
     English Units - Ibs/billion Ibs of columbium or tantalum
                   salt produced from digestion

Lead                                    515.63           464.07
Zinc                                  5,259.43         2,165.65
Ammonia (as N)                      685,787.90       302,159.18
Fluoride                            204,705.11        90,750.88


                   Solvent Extraction Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day	MonthlyAverage

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                  2,691.60         2,422.44
Zinc                                 27,454.32        11,304.72
Ammonia (as N)                    3,579,828.0      1,577,277.60
Fluoride                          1,068,565.2        473,721.60


           Solvent Extraction Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                     43.01            38.71
Zinc                                    438.70           180.64
Ammonia (as N)                       57,203.30        25,203.86
Fluoride                             17,074.97         7,569.76
                               335

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                      Table X-5 (Continued)

                 BAT EFFLUENT LIMITATIONS FOR THE
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
           Precipitation and Filtration of Metal Salts

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt  precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated

Lead                                 24,722.30        22,250.07
Zinc                                252,167.46       103,833.66
Ammonia (as N)                   32,880,659.0     14,487,267.80
Fluoride                          9,814,753.10     4,351,124.80


           Metal Salt Drying Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Lead                                  1,647.90         1,483.11
Zinc                                 16,808.58         6,921.18
Ammonia (as N)                    2,191,707.0        965,669.40
Fluoride                            654,216.30       290,030.40


                    Reduction of Salt to Metal

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                 35,266.30        31,739.67
Zinc                                359,716.26       148,118.46
Ammonia (as N)                   46,904,179.0     20,666,051.80
Fluoride                         14,000,721.10     6,206,868.80
                              336

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                      Table X-5 (Continued)

                 BAT EFFLUENT LIMITATIONS FOR THE
              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
       Reduction of Salt to Metal Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                  2,152.10         1,936.89
Zinc                                 21,951.42         9,038.82
Ammonia (as N)                    2,862,293.0      1,261,130.60
Fluoride                            854,383.7        378,769.6


            Consolidation and Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Lead                                      0                0
Zinc                                      0                0
Ammonia (as N)                            00
Fluoride                                  0                0
                              337

-------
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              PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY

                            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 tech-
nology (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 technolo-
gies 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 limita-
tions of regulated pollutants for NSPS in the primary columbium-
tantalum subcategory, based on the described control technology.

TECHNICAL APPROACH TO BDT

As discussed in the General Development Document, all of the
treatment technology options applicable to a new source were
previously considered for the BAT options.  For this reason, six
options were considered for BDT, all identical  to BAT Options A,
B, C, D, E, and F, which are discussed in Section X.  Briefly,
the treatment technologies used for the six options are as
follows:

OPTION A

     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping preliminary treatment of
        wastewaters containing treatable concentrations of
        ammonia

OPTION B

     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping preliminary treatment of
        wastewaters containing treatable concentrations of
        ammonia
     o  In-process flow reduction

OPTION C

     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping preliminary treatment of
        wastewaters containing treatable concentrations of
        ammonia
     o  In-process flow reduction
     o  Multimedia filtration


                              345

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OPTION D
     o
     o
     o
Chemical precipitation and sedimentation
Ammonia steam stripping preliminary treatment of
wastewaters containing treatable concentrations of
ammonia
In-process flow reduction
Multimedia filtration
Activated alumina adsorption for fluoride removal
OPTION E
     o
     o
     o
     o
     o
Chemical precipitation and sedimentation
Ammonia steam stripping preliminary treatment of
wastewaters containing treatable concentrations of
ammonia
In-process flow reduction
Multimedia filtration
Activated carbon adsorption
OPTION F
     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping preliminary treatment of
        wastewaters containing treatable concentrations of
        ammonia
     o  In-process flow reduction
     o  Multimedia filtration
     o  Reverse osmosis and multiple-effect evaporation

Partial or complete recycle and reuse of wastewater  is an essen-
tial part of the last four options.  Recycle and reuse can pre-
cede or follow end-of-pipe treatment.  A more detailed discussion
of the treatment options is presented in Section X.

BDT OPTION SELECTION

EPA is proposing that the best available demonstrated technology
for the primary columbium-tantalum subcategory be equal to BAT
(Option C).   Review of the subcategory indicates that no new
demonstrated technologies that improve on BAT technology exist.

Dry scrubbing is not demonstrated for controlling emmissions  from
concentrate digestion, metal salt drying and salt to metal reduc-
tion.  The nature of these emissions (acidic fumes,  hot particu-
late matter) technically precludes the use of dry scrubbers.
Therefore, EPA is including an allowance for these sources at
NSPS equivalent to that proposed for BAT.  The Agency also does
not believe that new plants could achieve any additional flow
reduction beyond that proposed for BAT.
                               346

-------
Activated alumina (Option D) was considered; however, this
technology was rejected because it too was not demonstrated  in
this category, nor was it clearly transferable to nonferrous
wastewater.  Activated carbon  (Option E) was also considered;
however, this technology was eliminated because  it  is not
necessary, since toxic organic pollutants are not selected for
limitation in this subcategory.

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 category nor was it clearly
transferable from another category.

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
limitation in Section X are also selected for limitation in
NSPS.

NEW SOURCE PERFORMANCE STANDARDS

The NSPS discharge flows for each wastewater source are the  same
as the BAT discharge rates listed in Section X.  The mass of
pollutant allowed to be discharged per mass of product is
calculated by multiplying the appropriate achievable treatment
concentration by the production normalized wastewater discharge
flows (1/kkg).  These treatment concentrations are listed in
Table VII-19 of the General Development Document.  The results of
these calculations are the production-based new  source perfor-
mance standards, and are presented in Table XI-1.  Since both the
discharge flows and the achievable treatment concentrations are
the same for new sources and BAT, the NSPS are identical to the
BAT mass limitations.
                               347

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                            Table XI-1

       NSPS FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
         Concentrate Digestion Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
       Metric Units - mg/kkg of columbium or tantalum salt
                     produced from digestion
     English Units - Ibs/billion Ibs of columbium or tantalum
                   salt produced from digestion
Lead
Zinc
Ammonia
Fluoride
Total Suspended Solids
pH
      515.63
    5,259.43
  685,787.90
  204,705.11
   77,344.50
       464.07
     2,165.65
   302,159.18
    90,750.88
    61,875.60
Within the range of 7.5 to 10.0
         at all times
                   Solvent Extraction Raffinate
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
    2,691.60
   27,454.32
3,579,828.0
1,068,565.2
  403,740.0
     2,422.44
    11,304.72
 1,577,277.60
   473,721.60
   322,992.0
Within the range of 7.5 to 10.0
         at all times
                              348

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                      Table XI-1 (Continued)

       NSPS FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
           Solvent Extraction Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
        43.01            38.71
       438.70           180.64
    57,203.30        25,203.86
    17,074.97         7,569.76
     6,451.50         5,161.20
 Within the range of 7.5 to 10.0
          at all times
           Precipitation and Filtration of Metal Salts
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
pH
    24,722.30
   252,167.46
32,880,659.0
 9,814,753.10
 3,708,345.0
    22,250.07
   103,833.66
14,487,267.80
 4,351,124.80
 2,966,676.0
 Within the range of 7.5 to 10.0
          at all times
                               349

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                      Table XI-1 (Continued)

       NSPS FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
           Metal Salt Drying Wet Air Pollution Control


Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
     1,647.90
    16,808.58
 2,191,707.0
   654,216.30
   247,185.0
     1,483.11
     6,921.18
   965,669.40
   290,030.40
   197,748.0
 Within the range of 7.5 to 10.0
          at all times
                    Reduction of Salt to Metal
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    35,266.30
   359,716.26
46,904,179.0
14,000,721.10
 5,289,945.0
    31,739.67
   148,118.46
20,666,051.80
 6,206,868.80
 4,231,956.0
 Within the range of 7.5 to 10.0
          at all times
                               350

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                      Table XI-1 (Continued)

       NSPS FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
       Reduction of Salt to Metal Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced
Lead
Zinc
Ammonia (as N)
Fluoride
Total Suspended Solids
PH
    2,152.10
   21,951.42
2,862,293.0
  854,383.7
  322,815.0
Within the range of 7.5 to 10.0
         at all times
     1,936.89
     9,038.82
 1,261,130.60
   378,769.6
   258,252.0
            Consolidation and Casting Contact Cooling
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated
Lead
Zinc
Ammonia (as N)
Fluoride
TSS
PH
        0
        0
        0
        0
        0
         0
         0
         0
         0
         0
Within the range of 7.5 to 10.0
          at all times
                              351

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              PRIMARY COLUMBIUM-TANTALUM  SUBCATEGORY

                           SECTION XII

                      PRETREATMENT STANDARDS


Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for exisitng  sources  (PSES), which must be achieved
within three years of promulgation.  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 heavy 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 facili-
ties, 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 instal-
lation.  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 primary  columbium-tantalum subcategory.  Pretreat-
ment standards for regulated pollutants are presented based on
the selected control and treatment technology.

TECHNICAL APPROACH TO PRETREATMENT

Before proposing 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 percentage
removed nationwide by well-operated POTW meeting secondary treat-
ment requirements, is less than the percentage removed by direct
dischargers complying with BAT  effluent limitations guidelines
for that pollutant.  (See generally, 46 FR at 9415-16 (January
28, 1981).)

This definition of pass through satisfies two competing
objectives set by Congress:   (1) that standards for indirect dis-
chargers be equivalent  to standards for direct dischargers, while
                               353

-------
at the same time, (2) that the treatment capability and perfor-
mance of the POTW be recognized and taken into account: in regu-
lating 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 pollu-
tants in the POTW effluent to lower concentrations due to the
addition of large amounts of non-industrial wastewater.

PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES

Options for pretreatment of wastewaters are based on increasing
the effectiveness of end-of-pipe treatment technologies.  All
in-plant changes and applicable end-of-pipe treatment processes
have been discussed previously in Sections X and XI.  The options
for PSES and PSNS, therefore, are the same as the BAT options
discussed in Section X.

A description of each option is presented in Section X, while a
more detailed discussion, including pollutants controlled by each
treatment process and achievable treatment concentrations are
presented in Section VII of the General Development Document.

The treatment technology options for the PSES and PSNS are:

Option A

     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping of wastewaters containing
        treatable concentrations of ammonia

Option B

     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping of wastewaters containing
        treatable concentrations of ammonia
     o  In-process flow reduction

Option C

     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping of wastewaters containing
        treatable concentrations of ammonia
     o  In-process flow reduction
     o  Multimedia filtration
                               354

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Option D
     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping of wastewaters containing
        treatable concentrations of ammonia
     o  In-process flow reduction
     o  Multimedia filtration
     o  Activated alumina for fluoride removal
Option E
     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping of wastewaters containing
        treatable concentrations of ammonia
     o  In-process flow reduction
     o  Multimedia filtration
     o  Activated carbon adsorption

Option F

     o  Chemical precipitation and sedimentation
     o  Ammonia steam stripping of wastewaters containing
        treatable concentrations of ammonia
     o  In-process flow reduction
     o  Multimedia filtration
     o  Reverse osmosis and multiple-effect evaporation

INDUSTRY COST AND ENVIRONMENTAL BENEFITS

The industry cost and environmental benefits of each treatment
option were used to determine the most cost-effective option.
The methodology applied in calculating pollutant reduction
benefits and plant compliance costs is discussed in Section X.
Table XII-1 shows the estimated pollutant reduction benefits for
direct and indirect dischargers, while compliance costs are
presented in Table XII-2.

PSES AND PSNS OPTION SELECTION

The technology basis for proposed PSES and PSNS is identical to
NSPS and BAT (Option C).  EPA knows of no demonstrated technology
that provides more efficient pollutant removal than NSPS and BAT
technology.

Activated alumina (Option D) was considered; however, this
technology was rejected because it was not demonstrated in this
category, nor was it clearly transferable to nonferrous
wastewater.  Activated carbon (Option E) was also considered;
however, this technology was eliminated because it is not
necessary since toxic organic pollutants are not selected for
limitation in this subcategory.
                               355

-------
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 category nor was it clearly
transferable from another category.

REGULATED POLLUTANT PARAMETERS

The pollutants and pollutant parameters selected for limitation,
in accordance with the rationale of Section X, are identical to
those selected for limitation for BAT.  PSES and PSNS prevent the
pass-through of lead, zinc, fluoride, and ammonia.

PRETREATMENT STANDARDS

The PSES and PSNS discharge flows are identical to the BAT
discharge flows for all processes.  These discharge flows are
listed in Table XII-3.  The mass of pollutant allowed to be dis-
charged 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-19 of the General
Development Document.  Pretreatment standards for existing and
new sources, as determined from the above procedure, are shown in
Tables XII-4 and XII-5 for each waste stream.

Mass-based standards are proposed for the columbium-tantalum
subcategory to ensure that the standards are achieved by means of
pollutant removal rather than by dilution.  They are particularly
important since the standards are based upon flow reduction;
pollutant limitations associated with flow reduction cannot be
measured any other way but as a reduction of mass discharged.
The flow reduction over estimated current flow for the
columbium-tantalum subcategory is 16.1 percent.
                               356

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-------
                Table XII-2

         COST OF COMPLIANCE FOR THE
   PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY
            Capital Cost       Annual Cost
Option     (1978 Dollars)     (1978 Dollars)

  A            300,000            152,000

  B            461,000            175,000

  C          2,190,000      '    1,350,000

  D          2,470,000          1,410,000

  E          3,670,000          1,690,000

  F          2,890,000          1,500,000
                   359

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-------
                           Table XII-4

       PSES FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY


         Concentrate Digestion Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium-tantalum salt produced
                          from digestion
    English Units - Ibs/billion Ibs of columbium-tantalum salt
                     produced from digestion

Lead                                    515.63          464.07
Zinc                                  5,259.43        2,165.65
Ammonia (as N)                      685,787.90      302,159.18
Fluoride                            204,705.11       90,750.88


                   Solvent Extraction Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                  2,691.60         2,422.44
Zinc                                 27,454.32        11,304.72
Ammonia (as N)                    3,579,828.0      1,577,277.60
Fluoride                          1,068,565.2        473,721.60


           Solvent Extraction Vet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                     43.01            38.71
Zinc                                    438.70           180.64
Ammonia (as N)                       57,203.30        25,203.86
Fluoride                             17,074.97         7,569.76
                              361

-------
                     Table XII-4 (Continued)

       PSES FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY


           Precipitation and Filtration of Metal Salts

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated

Lead                                 24,722.30        22,250.07
Zinc                                252,167.46       103,833.66
Ammonia (as N)                   32,880,659.0     14,487,267.80
Fluoride                          9,814,753.10     4,351,124.80


           Metal Salt Drying Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Lead                                  1,647.90         1,483.11
Zinc                                 16,808.58         6,921.18
Ammonia (as N)                    2,191,707.0        965,669.40
Fluoride                            654,216.30       290,030.40


                    Reduction of Salt to Metal

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                 35,266.30        31,739.67
Zinc                                359,716.26       148,118.46
Ammonia (as N)                   46,904,179.0     20,666,051.80
Fluoride                         14,000,721.10     6,206,868.80
                               362

-------
                     Table XII-4 (Continued)

       PSES FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY


       Reduction of Salt to Metal Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                  2,152.10         1,936.89
Zinc                                 21,951.42         9,038.82
Ammonia (as N)                    2,862,293.0      1,261,130.60
Fluoride                            854,383.7        378,769.6


            Consolidation and Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Lead                                      0                0
Zinc                                      0                0
Ammonia (as N)                            00
Fluoride                                  0                0
                              363

-------
                           Table XII-5

       PSNS FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGOR*


         Concentrate Digestion Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of columbium or tantalum salt
                     produced from digestion
     English Units - Ibs/billion Ibs of columbium or tantalum
                   salt produced from digestion

Lead                                    515.63           464.07
Zinc                                  5,259.43         2,165.65
Ammonia (as N)                      685,787.90       302,159.18
Fluoride                            204,705.11        90,750.88


                   Solvent Extraction Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                  2,691.60         2,422.44
Zinc                                 27,454.32        11,304.72
Ammonia (as N)                    3,579,828.0      1,577,277.60
Fluoride                          1,068,565.2        473,721.60


           Solvent Extraction Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Lead                                     43.01            38.71
Zinc                                    438.70           180.64
Ammonia (as N)                       57,203.30        25,203.86
Fluoride                             17,074.97         7,569.76
                              364

-------
                     Table XII-5 (Continued)

       PSNS FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY


           Precipitation and Filtration of Metal Salts

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated'

Lead                                 24,722.30        22,250.07
Zinc                                252,167.46       103,833.66
Ammonia (as N)                   32,880,659.0     14,487,267.80
Fluoride                          9,814,753.10     4,351,124.80


           Metal Salt Drying Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any OneDay    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Lead                                  1,647.90         1,483.11
Zinc                                 16,808.58         6,921.18
Ammonia (as N)                    2,191,707.0        965,669.40
Fluoride                            654,216.30       290,030.40


                    Reduction of Salt to Metal

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                 35,266.30        31,739.67
Zinc                                359,716.26       148,118.46
Ammonia (as N)                   46,904,179.0     20,666,051.80
Fluoride                         14,000,721.10     6,206,868.80
                               365

-------
                     Table XII-5 (Continued)

       PSNS FOR THE PRIMARY COLUMBIUM-TANTALUM SUBCATEGORY


       Reduction o.f Salt to Metal Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
     English Units - Ibs/billion Ibs of columbium or tantalum
                             reduced

Lead                                  2,152.10         1,936.89
Zinc                                 21,951.42         9,038.82
Ammonia (as N)                    2,862,293.0      1,261,130.60
Fluoride                            854,383.7        378,769.6


            Consolidation and Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Lead                                      0                0
Zinc                                      0                0
Ammonia (as N)                            00
Fluoride                                  0                0
                              366

-------
              PRIMARY COLUMBIUM-TANTALIM SUBCATEGORY

                           SECTION XIII

          BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY


The 1977 amendments to the Clean Water Act added Section 301(b)
(2)(E), establishing "best conventional pollutant control  tech-
nology" (BCT) for discharge of conventional pollutants from
existing industrial point sources.  Biochemical oxygen-demanding
pollutants (8005), total suspended solids  (TSS), fecal coli-
form, oil and grease (O&G), and pH have been designated as con-
ventional pollutants (see 44 FR 44501).

BCT is not an additional limitation, but replaces BAT for  the
control of conventional pollutants.  In addition to the other
factors specified in Section 304(b)(4)(B), the Act requires  that
limitations for conventional pollutants be assessed in light of a
two-part cost-reasonableness test.  On October 29, 1982, the
Agency proposed a revised methodology for  carrying out BCT analy-
ses (47 FR 39176).  The purpose of the proposal was to correct
errors in the BCT methodology originally established in 1977.

Part 1 of the proposed BCT test requires that the cost and level
of reduction of conventional pollutants by industrial dischargers
be compared with the cost and level or reduction to remove the
same type of pollutants by publicly-owned  treatment works  (POTW).
The POTW comparison figure has been calculated by evaluating the
change in costs and removals between secondary treatment (30 mg/1
BOD and 30 mg/1 TSS) and advanced secondary treatment (10 mg/1
BOD and 10 mg/1 TSS).   The difference in cost is divided by  the
difference in pounds of conventional pollutants removed, result-
ing in an estimate of the "dollars per pound" of pollutant
removed, that is used as a benchmark value.  The proposed POTW
test benchmark is $0.30 per pound (1978 dollars).

Part 2 of the BCT test required that the cost and level of reduc-
tion of conventional pollutants by industrial dischargers be
evaluated internally to the industry.  In order to develop a
benchmark that assesses a reasonable relationship between  cost
and removal,  EPA has developed an industry cost ratio which com-
pares the dollar per pound of conventional pollutant removed in
going from primary to secondary treatment levels with that of
going from secondary to more advanced treatment levels.  The
basis of costs for the calculation of this ratio are the costs
incurred by a POTW.  EPA used these costs because:  they reflect
the treatment technologies most commonly used to remove conven-
tional pollutants from wastewater; the treatment levels associ-
ated with them compare readily to the levels considered for
industrial dischargers; and the costs are the most reliable  for
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the treatment levels under consideration.  The proposed   industry
subcategory benchmark is 1.42.  If the industry figure for a
subcategory is lower than 1.43, the subcategory passes the BCT
test.

The Agency usually considers two conventional pollutants  in the
cost test, TSS and an oxygen-demanding pollutant.  Although both
oil and grease and BOD5 are considered to be oxygen-demanding
substances by EPA (see 44 FR 50733), only one can be selected in
the cost analysis to conform to procedures used to develop POTW
costs.  Oil and grease is used rather than BOD5 in the cost
analysis performed for nonferrous metals manufacturing waste
streams due to the common use of oils in casting operations in
this industry.

BPT is the base for evaluating limitations on conventional
pollutants (i.e., it is assumed that BPT is already in place).
The test evaluates the cost and removals associated with
treatment and controls in addition to that specified as BPT.

If the conventional pollutant removal cost of the candidate BCT
is less than the POTW cost, Part 1 of the cost-reasonableness
test is passed and Part 2 (the internal industry test) of the
cost-reasonableness test must be performed.  If the internal
industry test is passed, then a BCT limitation is promulgated
equivalent to the candidate BCT level.  If all candidate  BCT
technologies fail both parts of the cost-reasonableness test, the
BCT requirements for conventional pollutants are equal to BPT.

The BCT test was performed for the proposed basis of lime precip-
itation, sedimentation, in-process flow reduction, and multimedia
filtration.  The columbium-tantalum subcategory failed Part 1 of
the test with a calculated cost of $76.16 per pound (1978 dol-
lars) of removal of conventional pollutants using BAT technology.
The intermediate flow reduction option was also examined, but it
too failed with a cost of $8.73 per pound (1978 dollars)  of
conventional removal.
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                           Table XIII-1

   BCT EFFLUENT LIMITATIONS FOR THE PRIMARY COLUMBIUM-TANTALUM
                           SUBCATEGORY
         Concentrate Digestion Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium-tantalum salt produced
                          from digestion
    English Units - Ibs/billion Ibs of columbium-tantalum salt
                     produced from digestion

Total Suspended Solids              447,515.0       218,300.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                   Solvent Extraction Raffinate

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Total Suspended Solids            1,103,556.0        538,320.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
           Solvent Extraction Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

  Metric Units - mg/kkg of columbium or tantalum salt extracted
     English Units - Ibs/billion Ibs of columbium or tantalum
                          salt extracted

Total Suspended Solids              176,357.40        86,028.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               369

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                     Table XIII-1  (Continued)

   BCT EFFLUENT LIMITATIONS FOR THE PRIMARY COLUMBIUM-TANTALUM
                           SUBCATEGORY
           Precipitation and Filtration of Metal Salts

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

Metric Units - mg/kkg of columbium or tantalum salt  precipitated
     English Units - Ibs/billion Ibs of columbium or tantalum
                        salt precipitated

Total Suspended Solids           10,136,143.0     4,944,460.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
           Metal Salt Drying Vet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of columbium or tantalum salt dried
     English Units - Ibs/billion Ibs of columbium or tantalum
                            salt dried

Total Suspended Solids            3,429,363.0      1,672,860.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                    Reduction of Salt to Metal

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
English Units - Ibs/billion Ibs of columbium or tantalum reduced

Total Suspended Solids           14,459,183.0      7,053,260.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               370

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                     Table XIII-1 (Continued)

   BCT EFFLUENT LIMITATIONS FOR THE PRIMARY COLUMBIUM-TANTALUM
                           SUBCATEGORY
       Reduction of Salt to Metal Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum reduced
English Units - Ibs/billion Ibs of columbium or tantalum reduced

Total Suspended Solids              882,361.0        430,420.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
            Consolidation and Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of columbium or tantalum cast or
                           consolidated
     English Units - Ibs/billion Ibs of columbium or tantalum
                       cast or consolidated

Total Suspended Solids                    0                0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               371

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                   SECONDARY SILVER SUBCATEGORY

                            SECTION I

                     SUMMARY AND CONCLUSIONS


Pursuant to Sections 301, 304, 306, 307, and 501 of the Clean
Water Act and the provisions of the Settlement Agreement in
Natural Resources Defense Council v. Train, 8 EFC 2120 (D.D.C.
1976) modified, 12 ERG 1833 (D.D.C. 1979), EPA has collected and
analyzed data for plants ih the secondary silver subcategory.
EPA has never proposed or promulgated effluent limitations or
standards for this subcategory.  This document and the admini-
strative record provide the technical basis for proposing
effluent limitations based on best practicable technology (BPT)
and best available technology (BAT) for existing direct
dischargers, pretreatment standards for existing indirect
dischargers (PSES), pretreatment standards for new indirect
dischargers (PSNS), and standards of performance for new source
direct dischargers (MSPS).

The secondary silver subcategory is comprised of 44 plants.  Of
the 44 plants, four discharge directly to rivers, lakes, or
streams; 17 discharge to publicly owned treatment works (POTW);
and 23 achieve zero discharge of process wastewater.

EPA first studied the secondary silver subcategory to determine
whether differences in raw materials, final products, manufactur-
ing processes, equipment, age and size of plants, 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 waste-
waters, including toxic pollutants.

EPA also identified several distinct control and treatment tech-
nologies (both in-plant and end-of-pipe) applicable to the
secondary silver subcategory.  The Agency analyzed both histori-
cal and newly generated data on the performance of these tech-
nologies, including their nonwater quality environmental impacts
(such as air quality impacts and 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 category.  These costs were
then used by the Agency to estimate the impact of implementing
the various options on the subcategory.  For each control and
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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 employees affected,
and impact on price were estimated.  These results are reported
in a separate document entitled Economic Impact Analysis of Pro-
posed Effluent Limitations and Standards for the Nonferrous
Smelting and Refining Industry.

Based on consideration of the above factors, EPA identified vari-
ous control and treatment technologies which formed the basis for
BPT and selected control and treatment appropriate for each set
of standards and limitations.  The mass limitations and standards
for BPT, BAT, NSPS, PSES, PSNS, and BCT are presented in Section
II.

After examining the various treatment technologies, the Agency
has identified BPT to represent the average of the best existing
technology.  Metals removal based on lime precipitation and sedi-
mentation technology is the basis for the BPT limitations.  Steam
stripping was selected as the technology basis for ammonia limi-
tations.  To meet the BPT effluent limitations, the secondary
silver subcategory will incur an estimated  capital cost of
$0.124 million (1978 dollars) and an annual cost of $0.263 mil-
lion (1978 dollars).

Due to current adverse structural economic changes that are not
reflected in EPA's current economic analysis, the Agency has
identified alternative technologies as a basis for BAT effluent
limitations.  For Alternative A, the Agency has built upon the
BPT basis of steam stripping for ammonia limitation and lime
precipitation and sedimentation for metals removed by adding
in-process control technologies which include recycle of process
water from air pollution control and metal contact cooling waste
streams.  To meet the Alternative A BAT effluent limitations, the
secondary silver subcategory will incur an estimated capital cost
of $0.184 million (1978 dollars) and an annual cost of $0.278
million (1978 dollars).  For Alternative B, filtration is added
as an effluent polishing step to the in-process flow reduction,
steam stripping, lime precipitation, and sedimentation technology
considered in Alternative A.  To meet the Alternative B BAT
effluent limitations, the secondary silver subcategory will incur
an estimated capital cost of $0.206 million (1978 dollars) and an
annual cost of $0.345 million  (1978 dollars).

The best demonstrated technology, BDT, which is the technical
basis of NSPS, is equivalent to BAT. In selecting BDT, EPA recog-
nizes that new plants have the opportunity to implement the best
and most efficient manufacturing processes and treatment  techno-
logy.  However, the technology basis of BAT has been determined
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as the best demonstrated technology because no additional process
modifications or treatment technologies have been identified that
substantially improve BAT performance.

The Agency selected the same alternative technologies as BAT for
PSES.  To meet the Alternative A pretreatment standards for exis-
ting sources, the secondary silver subcategory will incur an
estimated capital cost of $1.03 million (1978 dollars) and an
annual cost of $0.958 million (1978 dollars).

Alternative B pretreatment standards for existing sources are
estimated to result in a capital cost of $1.14 million (1978
dollars) and an annual cost of $1.07 million (1978 dollars).  For
pretreatment standards for new sources (PSNS), the Agency selec-
ted preliminary treatment, end-of-pipe treatment, and in-process
flow reduction control techniques equivalent to BDT.  As such,
the PSNS are identical to the NSPS for all waste streams.

The best conventional technology (BCT) replaces BAT for the con-
trol of conventional pollutants.  The technology basis of BCT is
the BPT treatment of lime precipitation and sedimentation, with
ammonia steam stripping preliminary treatment for selected waste
streams.
                              375

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                   SECONDARY SILVER SUBCATEGORY

                            SECTION II

                         RECOMMENDATIONS
 1.
 2.
EPA has divided the secondary silver subcategory into 14
subdivisions for the purpose of effluent limitations and
standards.  These subdivisions are:

(a)  Film Stripping,
(b)  Film Stripping Wet Air Pollution Control,
(c)  Precipitation and Filtration of Film Stripping
     Solutions,
(d)  Precipitation and Filtration of Film Stripping
     Solutions Wet Air Pollution Control,
(e)  Precipitation and Filtration of Photographic Solutions,
(f)  Precipitation and Filtration of Photographic Solutions
     Wet Air Pollution Control,
(g)  Electrolytic Refining,
(h)  Furnace Wet Air Pollution Control,
(i)  Casting Contact Cooling,
(j)  Casting Wet Air Pollution Control,
(k)  Leaching,
(1)  Leaching Wet Air Pollution Control,
(m)  Precipitation and Filtration of Nonphotographic
     Solutions, and
(n)  Precipitation and Filtration of Nonphotographic
     Solutions Wet Air Pollution Control.

BPT is proposed based on the performance achievable by the
application of chemical precipitation and sedimentation
(lime and settle) technology, along with preliminary treat-
ment consisting of ammonia steam stripping for selected
waste streams.  The following BPT effluent limitations are
proposed for existing sources:
     (a)  Film Stripping
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
                              Maximum for
                              Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
                             3,076,100.0      1,619,000.0
                             2,153,270.0        906,640.0
                           215,327,000.0     94,873,400.0
                            66,379,000.0     32,380,000.0
                             Within the range of 7.5 to 10.0
                                      at all times
                               377

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     (b)  Film Stripping Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
     29,602.0         15,580.0
     20,721.40         8,724.80
  2,072,140.0        912,988.0
    638,780.0        311,600.0
  Within the range of 7.5 to 10.0
           at all times
     (c)  Precipitation and Filtration of Film Stripping
          Solutions
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
  3,516,900.0      1,851,000.0
  2,461,830.0      1,036,560.0
246,183,000.0    108,468,600.0
 75,891,000.0     37,020,000.0
  Within the range of 7.5 to 10.0
           at all times
     (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
     29,602.0         15,580.0
     20,721.40         8,724.80
  2,072,140.0        912,988.0
    638,780.0        311,600.0
  Within the range of 7.5 to 10.0
           at all times
                               378

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      (e)  Precipitation and Filtration of Photographic
          Solutions
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
  1,622,600.0        854,000.0
  1,135,820.0        478,240.0
113,582,000.0     50,044,400.0
 35,014,000.0     17,080,000.0
  Within the range of 7.5 to 10.0
           at all times
     (f)  Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    741,570.0        390,300.0
    519,099.0        218,568.0
 51,909,900.0     22,871,580.0
 16,002,300.0      7,806,000.0
  Within the range of 7.5  to  10.0
           at all times
     (g)  Electrolytic Refining
          BPT EFFLUENT LIMITATIONS

                                   Maximum for
Pollutant or Pollutant Property    Any One Day
                    Maximum for
                  Monthly Average
             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
     46,200.40         24,316.0
     32,340.28         13,616.96
  3,234,028.0       1,424,917.60
    996,956.0         486,320.0
  Within the range  of 7.5  to  10.0
           at all times
                               379

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     (h)  Furnace Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of silver roasted,  smelted,  or dried
   English Units - Ibs/billion Ibs of silver  roasted,  smelted,
                             or dried
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
   40,886.10        21,519.0
   28,620.27        12,050.64
2,862,027.0      1,261,013.40
  882,279.0        430,380.0
Within the range of 7.5 to 10.0
         at all times
     (i)  Casting Contact Cooling
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs  of silver cast
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
   22,866.50        12,035.0
   16,006.55         6,739.60
1,600,655.0        705,251.0
  493,435.0        240,700.0
Within the range of 7,5 to 10.0
         at all times
     (j)  Casting Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    9,007.90         4,741.0
    6,305.53         2,654.96
  630,553.0        277,822.60
  194,381.0         94,820.0
Within the range of 7.5 to 10.0
         at all times
                               380

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     (k)  Leaching
          BPT EFFLUENT LIMITATIONS
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
     5,282.0          2,780.0
     3,697.4          1,556.8
   369,740.0        162,908.0
   113,980.0         55,600.0
 Within the range of 7.5 to 10.0
          at all times
     (1)  Leaching Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
   270,539.10       142,389.0
   189,377.37        79,737.84
18,937,737.0      8,343,995.40
 5,837,949.0      2,847,780.0
 Within the range of 7.5 to 10.0
          at all times
     (m)  Precipitation and Filtration of Nonphotographic
          Solutions
          BPT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
   187,296.30        98,577.0
   131,107.41        55,203.12
13,110,741.0      5,776,612.20
 4,041,657.0      1,971,540.0
 Within the range of 7.5 to 10.0
          at all times
                               381

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     (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    151,868.90        79,931.0
    106,308.23        44,761.36
 10,630,823.0      4,683,956.60
  3,277,171.0      1,598,620.0
  Within the range of 7.5 to 10.0
           at all times
 3.  EPA is proposing two technology alternatives for BAT for the
     secondary silver subcategory.  BAT Alternative A is proposed
     based on the performance achievable by the application of
     chemical precipitation and sedimentation (lime and settle)
     technology and in-process flow reduction control methods,
     along with preliminary treatment consisting of ammonia steam
     stripping for selected waste streams.  The following BAT
     effluent limitations are proposed for existing sources:

     (a)  Film Stripping
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia(as N)
  3,076,100.0
  2,153,270.0
215,327,000.0
 1,619,000.0
   906,640.0
94,873,400.0
                               382

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     (b)  Film Stripping Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0

     (c)  Precipitation and Filtration of Film Stripping
          Solutions
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            3,516,900.0      1,851,000.0
Zinc                              2,461,830.0      1,036,560.0
Ammonia (as N)                  246,183,000.0    108,468,600.0

     (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0
                              383

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     (e)  Precipitation and Filtration of Photographic  Solutions
          BAT EFFLUENT LIMITATIONS

                                   Maximum for       Maximum for
Pollutant or Pollutant Property    Any One Day     Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs  of silver  precipitated

Copper                            1,622,600.0        854,000.0
Zinc                              1,135,820.0        478,240.0
Ammonia (as N)                  113,582,000.0     50,044,400.0

     (f)  Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution  Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for       Maximum for
Pollutant or Pollutant Property    Any One Day     Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs  of silver  precipitated

Copper                              741,570.0        390,300.0
Zinc                                519,099.0        218,568.0
Ammonia (as N)                   51,909,900.0     22,871,580.0
                                           at all times

     (g)  Electrolytic Refining
          BAT EFFLUENT LIMITATIONS

                                   Maximum for       Maximum for
Pollutant or Pollutant Property    Any One Day     Monthly Average

             Metric Units - mg/kkg of  silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                              46,200.4        24,316.0
Zinc                                 32,340.28        13,616.96
Ammonia (as N)                    3,234,028.0      1,424,917.60
                               384

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     (h)  Furnace Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted,  or dryed
  English Units - Ibs/billion Ibs of silver roasted, smelted,  or
                              dryed

Copper                                    0                0
Zinc                                   .   0                0
Ammonia (as N)                            00

     (i)  Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                2,287.6          1,204.0
Zinc                                  1,601.32           674.24
Ammonia (as N)                      160,132.0         70,554.40

     (j)  Casting Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                9,007.8          4,741.0
Zinc                                  6,305.53         2,654.96
Ammonia (as N)                      630,553.0        277,822.60
                              385

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     (k)  Leaching
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                5,282.0          2,780.0
Zinc                                  3,697.4          1,556.8
Ammonia (as N)                      369,740.0        165,662.20

     (1)  Leaching Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              270,539.1        142,389.0
Zinc                                189,377.37        79,737.84
Ammonia (as N)                   18,937,737.0      8,343,995.40

     (m)  Precipitation and Filtration of Nonphotographic
          Solutions
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              187,296.30        98,577.0
Zinc                                131,107.41        55,203.12
Ammonia (as N)                   13,110,741.0      5,776,612.20
                               386

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     (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              151,868.9         79,931.0
Zinc                                106,308.23        44,761.36
Ammonia (as N)                   10,630,823.0      4,683,956.60

     BAT Alternative B is proposed based on the performance
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle, and
     filter) technology and in-process flow reduction control
     methods; along with preliminary treatment consisting of
     ammonia steam stripping for selected waste streams.  The
     following BAT effluent limitations are proposed for existing
     sources:

     (a)  Film Stripping
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                            2,072,320.0        987,590.0
Zinc                              1,651,380.0        679,980.0
Ammonia(as N)                   215,327,000.0     94,873,400.0

     (b)  Film Stripping Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0
                               387

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     (c)  Precipitation and Filtration of Film Stripping
          Solutions
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            2,369,280.0      1,129,110.0
Zinc                              1,888,020.0        777,420.0
Ammonia (as N)                  246,183,000.0    108,468,600.0

     (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any OneDay    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0

     (e)  Precipitation and Filtration of Photographic
          Solutions
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,093,120.0        520,940.0
Zinc                                871,080.0        358,680.0
Ammonia (as N)                  113,582,000.0     50,044,400.0
                              388

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     (f)  Precipitation and Filtration of Photographic Solutions
          Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              499,584.0        238,083.0
Zinc                                398,106.0        163,926.0
Ammonia (as N)                   51,909,900.0     22,871,580.0

     (g)  Electrolytic Refining
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               31,124.48        14,832.76
Zinc                                 24,802.32        10,212.72
Ammonia (as N)                    3,234,028.0      1,424,917.60

     (h)  Furnace Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted,  or dried
  English Units - Ibs/billion Ibs of silver roasted, smelted,  or
                              dried

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            00
                              389

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     (i)  Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs  of silver cast

Copper                                1,541.12           734.44
Zinc                                  1,228.08           505.68
Ammonia (as N)                      160,132.0         70,554.40

     (j)  Casting Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs  of silver cast

Copper                                6,068.48         2,892.01
Zinc                                  4,835.82         1,991.22
Ammonia (as N)                      630,553.0        277,822.60

     (k)  Leaching
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver  produced from leaching

Copper                                3,558.4          1,695.8
Zinc                                  2,835.6          1,167.6
Ammonia (as N)                      369,740.0        162,908.0
                               390

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     (1)  Leaching Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              182,257.92        86,857.29
Zinc                                145,236.78        59,803.38
Ammonia (as N)                   18,937,737.0      8,343,995.40

     (m)  Precipitation and Filtration of Nonphotographic
          Solutions
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              126,178.56        60,131.97
Zinc                                100,548.54        41,402.34
Ammonia (as N)                   13,110,741.0      5,776,612.20

     (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              102,311.68        48,757.91
Zinc                                 81,529.62        33,571.02
Ammonia (as N)            ^      10,630,823.0      4,683,956.60

 4.  NSPS are proposed based on the performance achievable by
     the application of chemical precipitation, sedimentation,
     and multimedia filtration (lime, settle, and filter) tech-
     nology and in-process flow reduction control methods, along
     with preliminary treatment consisting of ammonia steam
     stripping for selected waste streams.  The following efflu-
     ent standards are proposed for new sources:
                               391

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     (a)  Film Stripping NSPS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
  2,072,320.0        987,590.0
  1,651,380.0        679,980.0
215,327,000.0     94,873,400.0
 24,285,000.0     19,428,000.0
    Within range of 7.5 to 10.0
         at all times.
     (b)  Film Stripping Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
     19,942.40         9,503.80
     15,891.60         6,543.60
  2,072,140.0        912,988.0
     233,700.0       186,960.0
  Within the range of 7.5 to 10.0
          at all times
     (c)  Precipitation and Filtration of Film Stripping
          Solutions NSPS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia(as N)
Total Suspended Solids
pH
  2,369,280.0      1,129,110.0
  1,888,020.0        777,420.0
246,183,000.0    108,468,600.0
 27,765,000.0     22,212,000.0
   Within the range of 7.5 to
    10,0 at all times.
                              392

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     (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control NSPS
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total  Suspended Solids
pH
     19,942.40         9,503.80
     15,891.60         6,543.60
  2,072,140.0        912,988.0
    233,700.0        186,960.0
      Within the range of 7.5 to
         10.0 at all times.
     (e)  Precipitation and Filtration of Photographic
          Solutions NSPS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
  1,093,120.0        520,940.0
    871,080.0        358,680.0
113,582,000.0     50,044,400.0
 12,810,000.0     10,248,000.0
      Within the range of 7.5  to
           10.0 at all times.
     (f)  Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total  Suspended Solids
pH
    499,584.0        238,083.0
    398,106.0        163,926.0
 51,909,900.0     22,871,580.0
  5,854,500.0      4,683,600.0
     Within the range of 7.5  to
       10.0 at all times.
                              393

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     (g)  Electrolytic Refining NSPS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
   31,124.48        14,832.76
   24,802.32        10,212.72
3,234,028.0      1,424,917.60
  364,740.0        291,792.0
    Within the range of 7.5 to
      10.0 at all times.
     (h)  Furnace Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of silver roasted,  smelted,  or dried
  English Units - Ibs/billion Ibs of silver roasted,  smelted,  or
                              dried
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
     (i)  Casting Contact Cooling NSPS
        0
        0
        0
        0
         0
         0
         0
         0
     Within the range of 7.5 to
        10.0 at all times.
                                   Maximum for
Pollutant or Pollutant Property    Any One Day
                  Maximum for
                Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    1,541.12           734.44
    1,228.08           505.68
  160,132.0         70,554.40
   18,060.0         14,448.0
     Within the range of 7.5 to
      10.0 at all times.
                              394

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      (j)  Casting Wet Air Pollution Control NSPS
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia (as N)
Total  Suspended
PH
Solids
  6,068.48         2,892.01
  4,835.82         1,991.22
630,553.0        277,822.60
 71,115.0         56,892.0
    Within the range of 7.5
    to 10.0 at all times.
     (k)  Leaching NSPS
Pollutant or Pollutant Property
                 Maximum for
                 Any One Day
                Maximum for
              Monthly Average
      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
                    3,558.4          1,695.8
                    2,835.6          1,167.6
                  369,740.0        162,908.0
                   41,700.0         33,360.0
                      Within the range of 7.5
                      to 10.0 at all times.
     (1)  Leaching Wet Air Pollution Control NSPS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
                  182,257.92        86,857.29
                  145,236.78        59,803.38
               18,937,737.0      8,343,995.40
                2,135,835.0      1,708,668.0
                Within the range of 7.5  to  10.0
                         at all  times
                              395

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     (m)  Precipitation and Filtration of Nonphotographic
          Solutions NSPS
Pollutant or Pollutant Property
   Maximum  for
   Any  One  Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    126,178.56         60,131.97
    100,548.54         41,402.34
 13,110,741.0       5,776,612.20
  1,478,655.0       1,182,924.0
  Within  the range  of 7.5  to 10.0
           at all  times
     (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia(as N)
Total Suspended Solids
pH
    102,311.68        48,757.91
     81,529.62        33,571.02
 10,630,823.0      4,683,956.60
  1,198,965.0        959,172.0
  Within the range of 7.5 to 10»0
           at all times
 5.  EPA is proposing two technology alternatives for PSES for
     the secondary silver subcategory.  PSES Alternative A is
     proposed based on the performance achievable by the appli-
     cation of chemical precipitation and sedimentation (lime and
     settle) technology and in-process flow reduction control
     methods, along with preliminary treatment consisting of
     ammonia steam stripping for selected waste streams.  The
     following pretreatment standards are proposed for existing
     sources:

     (a)  Film Stripping PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia(as N)
  3,076,100.0
  2,153,270.0
215,327,000.0
  1,619,000.0
    906,640.0
94,873,400.0
                               396

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      (b)  Film Stripping Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Pay    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0

      (c)  Precipitation and Filtration of Film Stripping
          Solutions PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            3,516,900.0      1,851,000.0
Zinc                              2,461,830.0      1,036,560.0
Ammonia (as N)                  246,183,000.0    108,468,600.0

      (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0

      (e)  Precipitation and Filtration of Photographic
          Solutions PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    AnyOne Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,622,600.0        854,000.0
Zinc                              1,135,820.0        478,240.0
Ammonia (as N)                  113,582,000.0     50,044,400.0
                              397

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     (f)  Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              741,570.0        390,300.0
Zinc                                519,099.0        218,568.0
Ammonia (as N)                   51,909,900.0     22,871,580.0

     (g)  Electrolytic Refining PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               46,200.4         24,316.0
Zinc                                 32,340.28        13,616.96
Ammonia (as N)                    3,234,028.0      1,424,917.60

     (h)  Furnace Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted, or dryed
  English Units - Ibs/billion Ibs of silver roasted, smelted,  or
                              dryed

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            0                0

     (i)  Casting Contact Cooling PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                2,287.6          1,204.0
Zinc                                  1,601.32           674.24
Ammonia (as N)                      160,132.0         70,554.40
                              398

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     (j)  Casting Wet Air Pollution Control PSES
Pollutant or Pollutant Property
  Maximum for      Maximum for
  Any One Day    Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia (as N)
     (k)  Leaching PSES
Pollutant or Pollutant Property
     9,007.8
     6,305.53
   630,553.0
  Maximum for
  Any One Day
     4,741.0
     2,654.96
   277,822.60
  Maximum for
Monthly Average
      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
     5,282.0
     3,697.4
   369,740.0
     2,780.0
     1,556.8
   165,662.20
     (1)  Leaching Wet Air Pollution Control PSES
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
   270,539.1
   189,377.37
18,937,737.0
   142,389.0
    79,737.84
 8,343,995.40
     (m)  Precipitation and Filtration of Nonphotographic
          Solutions PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
   187,296.30
   131,107.41
13,110,741.0
    98,577.0
    55,203.12
 5,776,612.20
                               399

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     (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              151,868.9         79,931.0
Zinc                                106,308.23        44,761.36
Ammonia (as N)                   10,630,823.0      4,683,956.60

     PSES Alternative B is proposed based on the performance
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle, and
     filter) technology and in-process flow reduction control
     methods, along with preliminary treatment of ammonia steam
     stripping for selected waste streams.  The following pre-
     treatment standards are proposed for existing sources:

     (a)  Film Stripping PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                            2,072,320.0        987,590.0
Zinc                              1,651,380.0        679,980.0
Ammonia (as N)                  215,327,000.0     94,873,400.0

     (b)  Film Stripping Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0
                              400

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     (c)  Precipitation and Filtration of Film Stripping
          Solutions PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            2,369,280.0      1,129,110.0
Zinc                              1,888,020.0        777,420.0
Ammonia (as N)                  246,183,000.0    108,468,600.0

     (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0

     (e)  Precipitation and Filtration of Photographic
          Solutions PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,093,120.0        520,940.0
Zinc                                871,080.0        358,680.0
Ammonia (as N)                  113,582,000.0     50,044,400.0

     (f)  Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              499,584.0        238,083.0
Zinc                                398,106.0        163,926.0
Ammonia (as N)                   51,909,900.0     22,871,580.0

-------
     (g)  Electrolytic Refining PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver  refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               31,124.48        14,832.76
Zinc                                 24,802.32        10,212.72
Ammonia (as N)                    3,234,028.0      1,424,917.60

     (h)  Furnace Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

    Metric Units - mg/kkg of silver roasted,  smelted,  or  dried
  English Units - Ibs/billion Ibs of silver roasted, smelted or
                              dried

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            00

     (i)  Casting Contact Cooling PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of  silver cast

Copper                                1,541.12           734.44
Zinc                                  1,228.08           505.68
Ammonia (as N)                      160,132.0         70,554.40

     (j)  Casting Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of  silver cast

Copper                                6,068.48         2,892.01
Zinc                                  4,835.82         1,991.22
Ammonia (as N)                      630,553.0        277,822.60
                               402

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      (k)  Leaching PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                3,558.40         1,695.80
Zinc                                  2,835.60         1,167.60
Ammonia (as N)                      369,740.0        162,908.0

      (1)  Leaching Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              182,257.92        86,857.29
Zinc                                145,236.78        59,803.38
Ammonia (as N)                   18,937,737.0      8,343,995.40

      (m)  Precipitation and Filtration of Nonphotographic
          Solutions PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              126,178.56        60,131.97
Zinc                                100,548.54        41,402.34
Ammonia (as N)                   13,110,741.0      5,776,612.20

      (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              102,311.68        48,757.91
Zinc                                 81,529.62        33,571.02
Ammonia(as N)                    10,630,823.0      4,683,956.60
                              403

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 6.  PSNS are proposed based on the performance achievable by
     the application of chemical precipitation, sedimentation,
     and multimedia filtration (lime, settle, and filter) tech-
     nology and in-process flow reduction control methods, along
     with preliminary treatment consisting of ammonia steam
     stripping for selected waste streams.  The following pre-
     treatment standards are proposed for new sources:

     (a)  Film Stripping PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                            2,072,320.0        987,590.0
Zinc                              1,651,380.0        679,980.0
Ammonia (as N)                  215,327,000.0     94,873,400.0

     (b)  Film Stripping Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0

     (c)  Precipitation and Filtration of Film Stripping
          Solutions PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            2,369,280.0      1,129,110.0
Zinc                              1,888,020.0        777,420.0
Ammonia (as N)                  246,183,000.0    108,468,600.0
                              404

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     (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0

     (e)  Precipitation and Filtration of Photographic
          Solutions PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,093,120.0        520,940.0
Zinc                                871,080.0        358,680.0
Ammonia  (as N)                 113,582,000.0     50,044,400.0

     (f)  Precipitation and Filtration of Photographic
          Solutions Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              499,584.0        238,083.0
Zinc                                398,106.0        163,926.0
Ammonia (as N)                   51,909,900.0     22,871,580.0

     (g)  Electrolytic Refining PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               31,124.48        14,832.76
Zinc                                 24,802.32        10,212.72
Ammonia (as N)                    3,234,028.0      1,424,917.60
                              405

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     (h)  Furnace Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted,  smelted,  or dried
    English Units - Ibs/billion of silver roasted,  smelted,  or
                              dried

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            0                0

     (i)  Casting Contact Cooling PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                1,541.12           734.44
Zinc                                  1,228.08           505.68
Ammonia (as N)                      160,132.0         70,554.40

     (j)  Casting Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any^ One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                6,068.48         2,892.01
Zinc                                  4,835.82         1,991.22
Ammonia (as N)                      630,553.0        277,822.60

     (k)  Leaching PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                3,558.40         1,695.80
Zinc                                  2,835.60         1,167.60
Ammonia (as N)                      369,740.0        162,908.0
                              406

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     (1)  Leaching Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              182,257.92        86,857.29
Zinc                                145,236.78        59,803.38
Ammonia (as N)                   18,937,737.0      8,343,995.40

     (m)  Precipitation and Filtration of Nonphotographic
          Solutions PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              126,178.56        60,131.97
Zinc                                100,548.54        41,402.34
Ammonia (as N)                   13,110,741.0      5,776,612.20

     (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              102,311.68        48,757.91
Zinc                                 81,529.62        33,571.02
Ammonia (as N)                   10,630,823.0      4,683,956.60

 7.  BCT is proposed based on performance achievable by the
     application of chemical precipitation and sedimentation
     (lime and settle) technology and in-process flow reduction
     control methods, along with preliminary treatment consisting
     of ammonia steam stripping for selected waste streams.  The
     following BCT effluent limitations are proposed for existing
     direct dischargers:
                              407

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     (a)  Film Stripping
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly  Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Total Suspended Solids           66,379,000.0     32,380,000.0
pH                                Within the range of 7.5  to 10.0
                                           at all times

     (b)  Film Stripping Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly  Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Total Suspended Solids              638,780.0        311,600.0
pH                                Within the range of 7.5  to 10.0
                                           at all times

     (c)  Precipitation and Filtration of Film Stripping
          Solutions
          BCT EFFLUENT LIMITATIONS

                                 Maximum for      Maximum  for
Pollutant or Pollutant Property    Any One Day    Monthly  Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids           75,891,000.0     37,020,000.0
pH                                Within the range of 7.5  to 10.0
                                           at all times
                              408

-------
     (d)  Precipitation and Filtration of Film Stripping
          Solutions Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids              638,7£0.0        311,600.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (e)  Precipitation and Filtration of Photographic Solutions
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids           35,014,000.0     17,080,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (f)  Precipitation and Filtration of Photographic Solutions
          Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids           16,002,300.0      7,806,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                              409

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     (g)  Electrolytic Refining
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Total Suspended Solids              996,956.0        486,320.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (h)  Furnace Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted,  smelted, or dried
    English Units - Ibs/billion Ibs of silver roasted,  smelted
                             or dried

Total Suspended Solids              882,279.0        430,380.0
pH                                Within the range of 7.5 to 10.0
                                           at all time£5

     (i)  Casting Contact Cooling
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Total Suspended Solids              493,435.0        240,700.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (j)  Casting Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Total Suspended Solids              194,381.0         94,820.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                              410

-------
      (k)  Leaching
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Total Suspended Solids              113,980.0         55,600.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

      (1)  Leaching Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Total Suspended Solids            5,837,949.0      2,847,780.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

      (m)  Precipitation and Filtration of Nonphotographic
          Solutions
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids            4,041,657.0      1,971,540.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

      (n)  Precipitation and Filtration of Nonphotographic
          Solutions Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids            3,277,171.0      1,598,620.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

                              411

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                   SECONDARY SILVER SUBCATEGORY

                           SECTION III

                         INDUSTRY PROFILE
This section of the secondary silver supplement describes the raw
materials and processes used in refining secondary silver and
presents a profile of the secondary silver plants identified in
this study.  For a discussion of the purpose, authority and
methodology for this study and a general description of the
nonferrous metals category, refer to Section III of the General
Development Document.

DESCRIPTION OF SECONDARY SILVER PRODUCTION

The production of secondary silver can be divided into two subdi-
visions based on the source of raw materials:  photographic and
nonphotographic.  Photographic processes for recovering silver
include film stripping and precipitation, film incineration,
chemical precipitation from solution, metallic replacement in
solution, and direct electrolytic refining.  Nonphotographic
manufacturing involves precipitation of silver from waste plating
solutions, melting and casting of sterling-silver scrap, and
processing electrical component scrap.

RAW MATERIALS

The principal raw materials used by plants recovering silver from
photographic materials are discarded photographic film (both
color and black and white) and silver-rich sludges and solutions
from photographic processing.  Waste plating solutions, sterling
ware scrap, and electrical component scrap are the principal raw
materials used in the nonphotographic category.

PHOTOGRAPHIC MATERIALS

Photographic raw materials silver recovery can be divided into
two primary sources, discarded film and film processing solu-
tions.

Discarded Film

The silver in emulsion on discarded film can be recovered by two
methods:  stripping, precipitation and drying, and incineration.
Figure III-l represents a general flow diagram of photographic
film scrap processes.  The primary steps are:

     1.  Granulation,
     2.  Stripping,
     3.  Sedimentation and filtration,
     4.  Precipitation,


                              413

-------
     5.  Roasting,
     6.  Casting,
     7.  Purification, and
     8.  Melting and casting.

Stripping Method.  Photographic film can be stripped directly or
first shredded and granulated.  Dust generated by granulation is
collected with a baghouse and recycled to the precipitation step
further along in the process.  The film can be stripped of the
silver-bearing emulsion by a number of ways.  In one method, the
film is stripped using nitric acid, resulting in a silver nitrate
solution.  The reaction of emulsion with nitric acid produces
nitrogen-containing air emissions (NOX), which are removed with
a scrubber, resulting in a wastewater stream.  Another method
uses wet oxidation with a catalyst at high temperature and
pressure to produce a silver liquor.  A third stripping process
converts silver in the film to silver chloride using ferric
chloride solution containing hydrochloric acid.

A silver-rich solution is usually separated from the granulated
film residue by sedimentation, decantation, and filtration.  The
residue is discarded as solid waste, usually in a landfill.

Silver in solution can be precipitated by various precipitating
agents.  Caustic soda, soda ash (Na2C03), and proteolytic
enzymes are commonly used.  Alum is used as a flocculating agent
in some processes.  The addition of chloride ion will precipitate
silver chloride which can be reduced to silver by hydrogen reduc-
tion.  Thiosulfate solution also converts silver chloride to a
soluble silver complex, silver thiosulfate.  Recovered baghouse
dust from the granulation step may also be added during the
precipitation step.

The silver-free supernatent is decanted and sent to waste
treatment.  Silver sludge is dewatered by gravity or filter
thickening, vacuum filtration, centrifuging, or drying.  The
water removed is sent to waste treatment or recycled.  Alkaline
or acidic fumes emitted from the precipitation step are scrubbed,
resulting in a wastewater stream.  Silver sludge filtration
produces another silver-free wastewater stream.

The dried cake is roasted in a reverberatory furnace.  Most pro-
cesses have baghouses for pollution control of particulates in
furnace off-gases. Some use scrubbers and electrostatic precipi-
tators.  The impure silver is then cast into ingots or Dore
plates.  The furnace slag is crushed and classified, and the
silver concentrate recycled as furnace feed, while the tailings
are landfilled.
                               414

-------
Dore plates are electrolytically refined on-site or shipped to
other facilities.  The electrolytic purification is carried out
in either Balbach-Thum cells (horizontal electrodes) or Moebius
cells (vertical electrodes).  A typical electrolyte solution con-
sists of silver nitrate and a small amount of nitric acid.  The
electrolyte is kept slightly to mildly acidic, a pH range of
approximately 2 to 6.  In addition to refined silver, electroly-
sis produces a waste stream of spent electrolyte and a slime
containing precious metals such as gold and platinum.  The slime
is further refined for precious metal recovery.

The refined silver is melted in a melting furnace and cast as
ingots.  Pollution control of furnace off-gases is handled with a
baghouse, scrubber, or electrostatic precipitator.  Contact
cooling water is used in the casting steps, as well as casting
scrubbers which produce wastewater streams.

Incineration.  Photographic film may be incinerated, rather than
processed by granulation, stripping, and precipitation. The
temperature and rate of burning must be carefully controlled if
high efficiency is to be maintained.  Air emissions include
organic vapors from the volatilization and decomposition of
organic scrap contaminants, as well as combustion gases and dust.
The emissions are usually controlled by afterburners in series
with a baghouse or scrubber.  Scrubbing techniques produce a
wastewater discharge.  Silver-bearing ash is then fed directly to
roasting and the process proceeds as described above.  Some
refineries buy silver-bearing ash from scrap dealers.

Film Processing Solutions

There are three basic methods for recovering silver from photo-
graphic processing solutions:  chemical precipitation, metallic
replacement, and direct electrolytic refining.  Silver recovery
from baths has also been successful by adsorption from solution
by ion exchange.  Reverse osmosis has been used on dilute
solutions.

Chemical Precipitation.  Silver-rich solutions from photographic
film developing and manufacturing undergo precipitation and puri-
fication as described above.  One alternate method uses sulfide
compounds, particularly sodium sulfide as the precipitating
agent.  Emission gases, such as hydrogen sulfide, are control-
led with a wet scrubber, resulting in a wastewater stream.  The
subsequent process for silver recovery is identical to other
precipitation methods.

Metallic Replacement.  Silver ions can be effectively reduced
from solution to a solid state by a replacement reaction.  Any
metal more active than silver will go into solution as an ion,
while the silver ion becomes solid metal.  Zinc, aluminum,
                               415

-------
copper, and iron are commonly used to recover silver by replace-
ment from photographic fixing solutions.  The silver sludge
produced can be filtered, roasted and cast as described previ-
ously.

Direct Electrolytic Refining.  Although used as a purification
step in other recovery processes, electrolytic refining is also a
direct means of silver recovery.  In the electrolytic method, a
current is passed between an anode and a cathode which are sus-
pended in a solution which contains greater than one mg/1 of
silver.  Solutions containing silver below this concentration are
difficult to refine electrolytically.  Silver, about 99 percent
pure, collects on the cathode.  The cathode is periodically
stripped to recover the silver.  If the current density is too
high for the amount of silver in the solution, thiosulfate in
solution will decompose, forming silver sulfide.  This reduces
current efficiency and will render the regenerated solution
unsuitable for reuse.  Spent electrolyte solution is discarded or
further refined for other precious metals.  If the thiosulfate in
solution is allwed to decompose, gaseous sulfur emissions
(SOX), must be removed with a scrubber.

NONPHOTOGRAPHIC MATERIALS

Based on the source of raw materials, the nonphotographic mate-
rials category can be divided into three basic processes for the
recovery of silver:  precipitation of waste plating solutions,
melting of sterling-silver industry scraps, and refining of
electrical components scrap.

Waste Plating Solutions

Silver-plated tableware is produced by electroplating silver from
cyanide solutions onto preformed shapes made of tin, iron, zinc,
or copper.  Silver wastes generated are spills of silver-rich
electrolyte, dilute wash solutions, and spent electrolyte.
Cyanide plating solutions are treated to precipitate the silver
and oxidize the cyanide.  As shown in Figure III-2, the process
consists of precipitation, filtration and washing, drying or
roasting, casting, refining, and recasting.  Some processors cast
the silver before refining and sell the ingots to other refiners.

Precipitation is usually accomplished by addition of sodium hypo-
chlorite, resulting in silver chloride.  After settling, the sil-
ver chloride is washed, filtered, and dried to be sold as product
or further processed with methods similar to those used for
photographic silver precipitates.  The cyanide left in solution
may be oxidized with sodium hypochlorite and lime to form a waste
stream.  Wastewater streams also result from waste washing water
and the filtrate and dewatering wastes.  Wet scrubbers are used
                               416

-------
to control fumes from the precipitation and filtration steps.
Roasting and melting furnaces may also require air pollution con-
trol to remove particulates.

An alternate silver recovery method is precipitation of silver as
the metal, using zinc metal with sodium chloride solution.  The
subsequent steps are identical to other precipitation processes.

Sterling-Silver Industry Scraps

The solid waste products from the sterling-silver industry
include defective tableware, trimmings, turnings, punchings,
fumes, spillage, drosses from melting and casting, and dusts.
The different wastes vary in impurity and the relatively pure
materials are melted, assayed, and reused.  Lower quality wastes
are combined, melted and cast, and the bullions are electrolyti-
cally refined as described above.

Electrical Component Scrap

Silver scrap from electrical components includes electrical con-
tacts, wire, silver-bearing batteries, condensers and solders.
Figure III-3 shows typical production processes followed if elec-
trical scrap is not suitable for electrolytic refining.

After careful sorting and sampling, the scrap is smelted in a
reverberatory furnace to produce lead bullion, copper matte, and
slag.  The slag is smelted in a blast furnace to separate the
lead and copper portions, which are recycled.  Blast furnace slag
is discarded.  Dust and fumes from both the reverberatory and
blast furnaces are collected and recycled.

The copper matte is crushed, ground, roasted, and leached.  A wet
scrubber may be used to control particulate air emissions from
the roasting furnace, producing a wastewater stream.  Leaching
may be effected with nitric, sulfuric, or hydrochloric acid,
using two methods.  In one process, the leaching agent dissolves
the base metals, leaving silver as a residue which can be fil-
tered and washed for further processing.  This leaching operation
usually produces two wastewater streams:  a silver-free leachate,
which may be discharged or recycled, and a scrubber discharge
stream.

In the second leaching process, silver is dissolved by the  leach-
ing agent and later precipitated from solution.  This leaching
also results in two wastewater streams:  a lead-iron residue and
a scrubber discharge stream, resulting from the control of acid
fume s.
                               417

-------
Electrical component parts may also be stripped directly with
cyanide or nitric acid solutions to produce solutions from which
silver can be precipitated.

Silver in solution from leaching or direct stripping is precipi-
tated by metallic replacement with copper and then filtered.
Copper sulfate composes most of the supernatant and filtrate and
is either purified for copper recovery or discarded. Wet scrub-
bers may provide control of acidic fumes emitted during the
precipitation step, producing an additional wastewater stream.

The recovered silver is melted in a furnace and cast as refined
ingots.  Silver of insufficient purity may undergo electrolytic
refining.  Particulate emissions from the melting furnace are
controlled with a baghouse or scrubber.  Venturi scrubbers are
commonly used and a wastewater stream is discharged.

The lead bullion from the reverberatory smelting furnace and lead
from the blast furnace is fed to a reverberatory-type cupola
furnace.  The cupellation produces litharge and precious metal
layers.  The litharge is sent to a lead refinery or reduced for
recycle to the reverberatory smelting unit.  The cupola furnace
requires a baghouse or scrubber to remove emission gas pollu-
tants.

The precious metal layer is cast into anodes (Dore plates) for
electrolytic refining.  The silver collects on the cathodes,
which are melted and cast as refined ingots.  The slime residue,
containing gold and platinum, is further refined.  The spent
electrolyte solution may be discarded as waste.  Wastewater
streams may also be generated by contact cooling water used in
casting, and melting furnace and casting scrubbers, which remove
particulates emitted from these operations.

Silver-Rich Sludges

Silver-rich sludges from waste plating solutions, stripping
solutions, and photographic solutions are leached and the silver
recovered, resulting in a silver-rich solution.  Leaching agents
used are hydrochloric acid, sulfuric acid, or nitric acid.  The
silver-rich solution is put through precipitation, filtration,
roasting, melting, and casting steps to produce refined silver
ingots.

PROCESS WASTEWATER SOURCES

The principal uses of water in secondary silver plants are:

      1.  Film stripping,
      2.  Film stripping wet air pollution control,
                               418

-------
      3.  Precipitation and filtration of film stripping
          solutions,
      4.  Precipitation and filtration of film stripping
          solutions wet air pollution control,
      5.  Precipitation and filtration of photographic solutions,
      6.  Precipitation and filtration of photographic solutions
          wet air pollution control,
      7.  Electrolytic refining,
      8.  Furnace wet air pollution control,
      9.  Casting contact cooling water,
     10.  Casting wet air pollution control,
     11.  Leaching,
     12.  Leaching wet air pollution control,
     13.  Precipitation and filtration of nonphotographic
          solutions, and
     14.  Precipitation and filtration of nonphotographic
          solutions wet air pollution control.

OTHER WASTEWATER SOURCES

There are other waste streams associated with the production of
secondary silver.  These waste streams include but are not
limited to:

      1.  Maintenance and cleanup water, and
      2.  Direct electrolytic refining wet air pollution control
          wastewater

These waste streams are not considered as part of this rulemak-
ing.  EPA believes that the flows and pollutant loadings associ-
ated with these waste streams are insignificant relative to the
waste streams selected, or are best handled by the appropriate
permit authority on a case-by-case basis under the authority of
Section 403(a) of the Clean Water Act.

AGE, PRODUCTION, AND PROCESS PROFILE

Of the 44 plants recovering silver (from photographic and non-
photographic materials), Figure III-4 shows that the plants are
concentrated in the Northeast and California, with plants also
located in Idaho, Utah, Louisiana, Florida, and Texas.

Table III-l summarizes the general type and shows the relative
ages of the secondary silver plants.  Four plants discharge
directly, 17 are indirect dischargers, and 23 are zero dis-
chargers.  Fourteen plants process only photographic materials,
14 process only nonphotographic materials, and 16 plants process
both types of materials.  The average plant age is between 15 and
24 years.
                              419

-------
Table III-2 shows the production ranges for the 44 secondary
silver plants.  Over half of the plants that reported production
data produce in excess of 100,000 troy ounces per year.  Twelve
of these plants produce over 1,000,000 troy ounces of silver per
year.  Only five plants reported producing less than 50,000 troy
ounces per year.

Table III-3 provides a summary of the plants having the various
secondary silver processes.  The number of plants generating
wastewater from the processes is also shown.
                               420

-------
























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-------
        Waste
     To Landfill  *•
      Silver Free
        Water     •*-
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        Water     *-
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          Ball mill
            Jig
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           cells
          Classifier    j-1
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                                 i
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                           Granulation
                              Stripping
Sedimentation
& Filtration
Precipitation
Silver Sludge
  Filtration
                              Roasting
                                 i
                              Casting
                                  i
                           Electrolysis
  Melting
  & Casting
                                                          Baghouse
                                                    -Nitric Acid
                                                      Recovered Dust
                                                   Waste Photographic
                                                     Solutions
                        Silver-Bearing Photographic
                           Film Ash
                     •*•  Electrolysis  Slimes
                         to Au & Pt Recovery
                              Silver Ingots
                          coarse silver concentrate
                             (to Roasting)
           Fine silver
           concentrate
Tailings to (to Precipitation)
  waste
                             Figure  III-l
       SILVER  REFINING FROM PHOTOGRAPHIC  MATERIALS

                                    424

-------
                    Silver Waste
                    Plating Solution
                  Precipitation
Sodium hypochlorite
  & line
                     Settling
         To Waste
'Sodium hypochlorite
Drying
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                                                            __   Silver
                                                            Chloride sold
                                                            as  product
                                                    Waste Stream
                                                  Slimes to Au & Ft
                                                     Recovery
                              Silver ingots
                          Figure  III-2
      SILVER REFINING FROM WASTE PLATING SOLUTIONS
                                   425

-------
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                   SECONDARY SILVER SUBCATEGORY

                            SECTION IV

                        SUBCATEGORIZATION
As discussed in Section IV of the General Development Document,
the nonferrous metals manufacturing category has been subcate-
gorized to take into account pertinent category characteristics,
manufacturing process variations, wastewater characteristics, and
a number of other factors which affect the ability of the facili-
ties to achieve effluent limitations.  This section summarizes
the factors considered during the designation of the secondary
silver subcategory and its related subdivisions.

FACTORS CONSIDERED IN SUBCATEGORIZATION

The following factors were evaluated for use in determining
appropriate subcategories for the nonferrous metals industry:

      1.  Metal products, co-products, and by-products;
      2.  Raw materials;
      3.  Manufacturing processes;
      4.  Product form;
      5.  Plant location;
      6.  Plant age;
      7.  Plant size;
      8.  Air pollution control methods;
      9.  Meteorological conditions;
     10.  Treatment costs;
     11.  Nonwater quality aspects;
     12.  Number of employees;
     13.  Total energy requirements; and
     14.  Unique plant characteristics.

Evaluation of all factors that could warrant subcategorization
resulted in the designation of the secondary silver subcategory.
Three factors were particularly important in establishing these
classifications:  the type of metal produced, the nature of raw
materials used, and the manufacturing processes involved.

In Section IV of the General Development Document, each of these
factors is described, and the rationale for selecting metal prod-
ucts, manufacturing processes and raw materials as the principal
factors used for subcategorization is discussed.  On the basis of
these factors, the nonferrous metals manufacturing category
(phase I) was divided into 12 subcategories, one of them being
secondary silver.

The secondary silver subcategory has not been considered during
previous rulemaking.  The purpose of this rulemaking is to estab-
lish BPT and BAT effluent limitations, and NSPS, PSES, and PSNS
for the secondary silver subcategory.

                               429

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FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY SILVER SUBCATE-
GORY

The factors listed previously were each evaluated when, consider-
ing subdivision o£ the secondary silver subcategory.  In the
discussion that follows, the factors will be described as they
pertain to this particular subcategory.

The rationale for considering further subdivision of the second-
ary silver subcategory is based primarily on the production pro-
cesses used.  Within the subcategory, a number of different oper-
ations are performed, which may or may not have a water use or
discharge, and which may require the establishment of separate
effluent limitations and standards.  While the secondary silver
industry is still considered a single subcategory, a more
thorough examination of the production processes, water use and
discharge practices, and pollutant generation rates has illus-
trated the need for limitations and standards based on a specific
set of waste streams.  Limitations and standards will be based on
specific flow allowances for the following subdivisions:

      1.  Film stripping,
      2.  Film stripping wet air pollution control,
      3.  Precipitation and filtration of film stripping
          solutions,
      4.  Precipitation and filtration of film stripping
          solutions wet air pollution control,
      5.  Precipitation and filtration of photographic solutions,
      6.  Precipitation and filtration of photographic solutions
          wet air pollution control,
      7.  Electrolytic refining,
      8.  Furnace wet air pollution control,
      9.  Casting contact cooling water,
     10.  Casting wet air pollution control,
     11.  Leaching,
     12.  Leaching wet air pollution control,
     13.  Precipitation and filtration of nonphotographic
          solutions, and
     14.  Precipitation and filtration of nonphotographic
          solutions wet air pollution control.

OTHER FACTORS

A number of other factors considered in this evaluation either
supported the establishment of the secondary silver subcategory
and its subdivisions or were shown to be inappropriate bases for
subcategorization.  Air pollution control methods, treatment
costs, nonwater quality aspects, and total energy requirements
are functions of the selected subcategorization factors—raw
materials and production processes.  As such, they support the
                               430

-------
method of subcategorization which has been applied.  Factors
determined to be inappropriate for use as bases for subcategori-
zation are discussed briefly below.

PLANT SIZE

It is difficult to categorize secondary silver plants on the
basis of size.  The individual processes involved in silver
production often process different amounts of silver-bearing
material.  Therefore, it is more appropriate to categorize silver
plants on the basis of process production, e.g., precipitation
production.

PLANT AGE

Plants within the secondary silver subcategory differ in age, in
terms of initial operating year.  However, to remain competitive,
plants are constantly modernized.  Modifications to process oper-
ations have been made, resulting in greater production efficiency
and reduced air pollution emissions.  As a result, neither the
concentration of constituents in wastewater nor the capability to
meet the limitations is related to plant age.

PRODUCTION NORMALIZING PARAMETERS

The effluent limitations and standards developed in this document
establish mass limitations on the discharge of specific pollutant
parameters.  To allow these limitations to be applied to plants
with various production capacities, the mass pollutant discharged
must be related to a unit of production.  This factor is kn*own as
the production normalizing parameter (PNP).  In general, the
actual silver production from the respective manufacturing pro-
cess is used as the PNP.  This is based on the principle that the
amount of water generated is proportional to the amount of prod-
uct made.  Therefore, the PNP's for the 14 secondary silver
subdivisions are as follows:

          Subdivision                                 PNP

      1.  Film stripping                          kkg of silver
                                                  produced from
                                                  film stripping

      2.  Film stripping wet air pollution        kkg of silver
          control                                 produced from
                                                  film stripping

      3.  Precipitation and filtration of         kkg of silver
          film stripping                          precipitated
                              431

-------
     Subdivision

 4.  Precipitation and filtration of film
     stripping solutions wet air pollu-
     tion control

 5.  Precipitation and filtration of
     photographic solutions

 6.  Precipitation and filtration of
     photographic solutions wet air
     pollution control

 7.  Electrolytic refining
 8.  Furnace wet air pollution control
 9.  Casting contact cooling water
10.  Casting wet air pollution control
11.  Leaching
12.  Leaching wet air pollution control
13.  Precipitation and filtration of
     nonphotographic solutions

14.  Precipitation and filtration of
     nonphotographic solution wet air
     pollution control
    PNP

kkg of silver
precipitated
kkg of silver
precipitated

kkg of silver
precipitated
kkg of silver
refined

kkg of silver
smelted,
roasted, or
dried

kkg of silver
cast

kkg of silver
cast

kkg of silver
produced from
leaching

kkg of silver
produced from
leaching

kkg of silver
precipitated

kkg of silver
precipitated
                          432

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                   SECONDARY SILVER SUBCATEGORY

                            SECTION V

             WATER USE AND WASTEWATER CHARACTERISTICS
This section describes the characteristics of wastewater associ-
ated with the secondary silver subcategory.  Data used to quan-
tify wastewater flow and pollutant concentrations are presented,
summarized, and discussed.  The contribution of specific produc-
tion processes to the overall wastewater discharge from secondary
silver plants is identified whenever possible.

Section V of the General Development Document contains a detailed
description of the data sources and methods of analysis used to
characterize wastewater from the nonferrous metals manufacturing
category.  To summarize this information briefly, 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 quantify the pollutant discharge from secondary
silver plants, a field sampling program was conducted.  A com-
plete list of the pollutants considered and a summary of the
techniques used in sampling and laboratory analyses are included
in Section V of the General Development Document.  Wastewater
samples were collected in two phases:  screening and verifica-
tion.  The first phase, screen sampling, was to identify which
toxic pollutants were present in the wastewaters from production
of the various metals.  Screening samples were analyzed for 128
of the 129 toxic pollutants and other pollutants deemed appropri-
ate.  (Because the analytical standard for TCDD was judged to be
too hazardous to be made generally available, samples were never
analyzed for this pollutant.  There is no reason to expect that
TCDD would be present in secondary silver wastewater).  A total
of 10 plants were selected for screen sampling in the nonferrous
metals manufacturing category, one of these being a secondary
silver plant.  Of the 36 plants selected for verification
sampling, three were from the secondary silver subcategory.  In
general, the samples were analyzed for three classes of pollu-
tants:  toxic organic pollutants, toxic metal pollutants, and
criteria pollutants (which includes both conventional and
nonconventional pollutants).

As described in Section IV of this supplement, the secondary
silver subcategory has been further categorized into 14 subdivi-
sions, so that the proposed regulation contains mass discharge
limitations and standards for 14 unit processes discharging
process wastewater.  Differences in the wastewater characteris-
tics associated with these subdivisions are to be expected.  For
this reason, wastewater streams corresponding to each subdivision
are addressed separately in the discussions that follow.
                              433

-------
WASTEWATER SOURCES, DISCHARGE RATES, AMD CHARACTERISTICS

The wastewater data presented in this section were evaluated in
light of production process information compiled during this
study.  As a result, it was possible to identify the principal
wastewater sources in the secondary silver subcategory.  They
are:

     1.  Film stripping,
     2.  Film stripping wet air pollution control,
     3.  Precipitation and filtration of film stripping
         solutions,

      4.  Precipitation and filtration of film stripping
          solutions wet air pollution control,
      5.  Precipitation and filtration of photographic solutions,
      6.  Precipitation and filtration of photographic solutions
          wet air pollution control,
      7.  Electrolytic refining,
      8.  Furnace wet air pollution control,
      9.  Casting contact cooling water,
     10.  Casting wet air pollution control,
     11.  Leaching,
     12.  Leaching wet air pollution control,
     13.  Precipitation and filtration of nonphotographic
          solutions, and
     14.  Precipitation and filtration of nonphotographic
          solutions wet air pollution control.

Data supplied by dcp responses were evaluated, and two flow-to-
production ratios were calculated for each stream.  The two
ratios, water use and wastewater discharge flow, are differenti-
ated by the flow value used in calculation.  Water use is defined
as the volume of water or other fluid (e.g., emulsions, lubri-
cants) required for a given process per mass of silver product
and is therefore based on the sum of recycle and make-up flows to
a given process.  Wastewater flow discharged after pretreatment
or recycle (if these are present) is used in calculating the pro-
duction normalized flow--the volume of wastewater discharged from
a given process to further treatment, disposal, or discharge per
mass of silver produced.  Differences between the water use and
wastewater flows associated with a given stream result from recy-
cle, evaporation, and carryover on the product.  The production
values used in calculation correspond to the production normaliz-
ing parameter, PNP, assigned to each stream, as outlined in
Section IV.  The production normalized flows were compiled and
statistically analyzed by stream type.  Where appropriate, an
attempt was made to identify factors that could account for vari-
ations in water use.  This information is summarized in this
section.  A similar analysis of factors affecting the wastewater
                               434

-------
values is presented in Sections X, XI, and XII where representa-
tive BAT, BDT, and pretreatment discharge flows are selected for
use in calculating the effluent limitations and standards.  As an
example, silver precipitation and filtration scrubbing wastewater
flow is related to precipitate production.  As such, the dis-
charge rate is expressed in liters of scrubber wastewater
discharged per metric ton of silver produced by precipitation.

In order to quantify the concentrations of pollutants present in
wastewater from secondary silver plants, wastewater samples were
collected at four plants.  Diagrams indicating the sampling sites
and contributing production processes are shown in Figures V-l
through V-4 (at the end of this section) ..

The raw wastewater sampling data for the secondary silver sub-
category are presented in Tables V-2, V-5, and V-8 (at the end of
this section).  Treated wastewater sampling data are shown in
Tables V-16 through V-18.  The stream codes presented in the
tables may be used to identify the location of each of the
samples on the process flow diagrams in Figures V-l through V-4.
Where no data are listed for a specific day of sampling, the
wastewater samples for the stream were not collected.  If the
analysis did not detect a pollutant in a waste stream, the
pollutant was omitted from the table.

The data tables include some samples measured at concentrations
considered not quantifiable.  The base-neutral extractable, acid
fraction extractable, and volatile organics are generally
considered not quantifiable at concentrations equal to or less
than 0.010 mg/1.  Below this concentration, organic analytical
results are not quantitatively accurate; however, the analyses
are useful to indicate the presence of a particular pollutant.
The pesticide fraction is considered not quantifiable at concen-
trations equal to or less than 0.005 mg/1.  Nonquantifiable
results are designated in the tables with an asterisk (double
asterisk for pesticides).

These detection limits shown on the data tables are not the same
in all cases as the published detection limits for these pollu-
tants by the same analytical methods.  The detection limits used
were reported with the analytical data and hence are the appro-
priate 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 calibra-
tion, variation in stock solutions, and variation in operators.

The statistical analysis of data includes some samples measured
at concentrations considered not quantifiable.  Data reported as
an asterisk are considered as detected but below quantifiable
                               435

-------
concentrations, and a value of zero is used for averaging.  Toxic
organic, nonconventional, and conventional pollutant data
reported with a "less than" sign are considered as detected, but
not further quantifiable.  A value of zero is also used for
averaging.  If a pollutant is reported as not detected, it is
excluded in calculating the average.  Finally, toxic metal values
reported as less than a certain value were considered as not
detected and a value of zero is used in the calculation of the
average.  For example, three samples reported as ND, *, and 0.021
mg/1 have an average value of 0.010 mg/1.

The method by which each sample was collected is indicated by
number, as follows:

     1     one-time grab
     2     24-hour manual composite
     3     24-hour automatic composite
     4     48-hour manual composite
     5     48-hour automatic composite
     6     72-hour manual composite
     7     72-hour automatic composite

In the data collection portfolios, the secondary silver plants
which discharge wastewater were asked to specify the presence or
absence of the toxic pollutants in their effluent.  Of the 44
secondary silver plants, 19 did not respond to this portion of
the questionnaire.  All plants responding to the organic com-
pounds portion of the questionnaire reported that all toxic
organic pollutants were known to be absent or believed to be
absent from their wastewater.

The responses for the toxic metals and cyanide are summarized
below:

               Known      Believed     Believed     Known
Pollutant     Present     Present       Absent      Absent

Antimony         2            4           14           5
Arsenic          1            2           16           6
Beryllium        0            2           16           7
Cadmium          4            5           10           6
Chromium         5            4           10           6
Copper          10            4            6           5
Cyanide          4            1           13           7
Lead             7486
Mercury          1            2           16           6
Nickel           8395
Selenium         1            2           15           7
Silver          13            5            3           4
Thallium         0            1           16           8
Zinc            10            4            7           4


                              436

-------
FILM STRIPPING

Photographic film may be stripped of emulsion and the silver pre-
cipitated.  The emulsion can be screened and rinsed, producing
wastewater.  Water discharge rates are presented in Table V-l in
liters per metric ton of silver produced from film stripping.
Table V-2 (stream 14) shows combined raw wastewater data from
film stripping and wet air pollution control on film stripping
and film stripping precipitation.  Data are not available for
separate waste streams because discrete points in each stream
were not accessible.  However, based on the combined wastewater
data and the raw materials and process used, film stripping
wastewater should contain toxic organics and metals, cyanide,
and suspended solids above treatable concentrations, as well as
phenolics at a quantifiable concentration.

FILM STRIPPING WET AIR POLLUTION CONTROL

One plant engaged in film stripping uses a wet scrubber to con-
trol air emissions.  This plant uses the same scrubber to control
emissions from film stripping and film stripping precipitation.
A 99+ percent recycle of the scrubber water is maintained and the
discharge rate is 2,152 liters per metric ton (516 gal/ton) of
silver produced from film stripping.  Table V-2 (stream 14) shows
combined raw wastewater data from film stripping and wet air pol-
lution control on film stripping and film stripping precipita-
tion.  Data are not available for separate waste streams because
discrete points in each stream were not accessible.  However,
based on the combined wastewater data and the raw materials and
process used, film stripping wet air pollution control wastewater
should contain toxic organics and metals, cyanide, phenolics, and
suspended solids.

PRECIPITATION AND FILTRATION OF FILM STRIPPING SOLUTIONS

In film stripping processes, the solution resulting from washing
granulated film is treated to precipitate the silver.  After
settling or filtration, the silver-free solution may be discarded
as wastewater.  Four of the six photographic plants that use this
process discharge a waste stream.  The water discharge rates,
reported in liters per metric ton of silver precipitated, are
shown in Table V-3.  Sampling data for film stripping solutions
precipitation are summarized in Table V-2 (Stream 12).  Raw
wastewater from this process contains toxic organics and metals,
cyanide, and suspended solids at treatable concentrations, as
well as measurable concentrations of phenolics.
                               437

-------
PRECIPITATION AND FILTRATION OF FILM STRIPPING SOLUTIONS WET AIR
POLLUTION CONTROL

One plant uses a wet scrubber on its film stripping precipitation
process, producing a waste stream.  This plant uses the same
scrubber to control air emissions from film stripping and film
stripping precipitation, therefore the water discharge rates and
stream characteristics are identical for both subdivisions.  This
wastewater should be characterized by the presence of toxic
organics and metals above treatable concentrations, as well as
suspended solids, and cyanide.

PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS

Silver can be precipitated from discarded hypo solutions.  After
filtration, the silver-free solution constitutes a waste stream.
Fifteen of the 30 photographic silver recovery plants have pre-
cipitation processes, nine of these discharging process waste-
water.  The discharge rates from these plants, presented in
liters per metric ton of silver precipitated, are shown in Table
V-4.  The Agency did not sample the raw wastewater from silver
solution precipitation directly; however, wastewater samples were
collected after filtering with sawdust (which is part of the
process).  This wastewater contains 1,2-dichloroethane, chloro-
form, phthalates, and tetrachloroethylene, all above treatable
concentrations (0.025 to 0.132 mg/1).  Toxic metals are also
found, including a high concentration of zinc (200 mg/1).  Ammo-
nia (4,630 mg/1;, and chloride (734 mg/1) are also present.
Suspended solids are evident, but most solids in the raw waste-
water were probably removed by the filter. Raw wastewater
sampling data are given in Table V-5.

PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS WET AIR
POLLUTION CONTROL

Of the 15 photographic silver plants precipitating silver solu-
tions, four use wet air pollution control, three discharging
wastewater from wet scrubbers.  The water discharge flow rates
are shown in Table V-6.  Although wastewater samples were not
collected from precipitation of photographic solutions wet air
pollution control, raw wastewater data are available from a film
stripping precipitation scrubber.  The wastewater characteristics
for the two scrubbers are expected to be similar because of the
similarities in the raw materials and processes used.  Wastewater
samples collected from the analogous wet scrubber stream contain
toxic organics and metals, cyanide, and suspended solids above
treatable concentrations, as well as phenolics at quantifiable
concentrations.
                               438

-------
ELECTROLYTIC REFINING

Twenty plants use electrolytic refining as a purification step in
secondary silver processing.  Thirteen plants generate waste
streams consisting of spent electrolyte; 12 of those discharge
the wastewater.  Table V-7 shows the water discharge rates in
liters per metric ton of silver refined.

Electrolytic refining is similar for photographic and nonphoto-
graphic plants, therefore wastewater from each may have similar
characteristics.  Table V-8 summarizes the raw wastewater
sampling data for the toxic and selected conventional and
nonconventional pollutants.

The samples were collected at a nonphotographic plant from a com-
bined waste stream comprised of raw wastewater from electrolytic
refining, as well as metal-depleted solutions.  This raw waste-
water contains toxic organics and metals, ammonia, fluoride,
cyanide, and suspended solids above treatable concentrations, as
well as quantifiable concentrations of phenolics.

FURNACE WET AIR POLLUTION CONTROL

Of the secondary silver plants with furnaces or incinerators, 19
control off-gas emissions.  Eleven plants use wet scrubbers, four
of these discharging wastewater, as shown in Table V-9.  Although
the Agency did not collect samples from furnace scrubber waste
streams, the furnace scrubber wastewater is analogous to scrubber
wastewater from other secondary silver processes because of the
similarity in raw materials used.  Therefore, furnace scrubber
wastewater should contain toxic organics and metals, cyanide, and
suspended solids.  Increased suspended solids may be present in
wastewater from furnace scrubbers not preceded by baghouse ash
collectors.

CASTING CONTACT COOLING WATER

Contact cooling water may be used for casting.  Of the 28 second-
ary silver plants reporting casting operations, 11 use, and 10
discharge contact cooling water.  The water discharge rates are
presented in liters per metric ton of silver cast in Table V-10.

Since casting operations are similar in photographic and non-
photographic plants, wastewater from both should exhibit similar
characteristics.  Table V-8 (stream 44) summarizes field sampling
data from combined raw wastewater, of which casting contact
cooling water is a constituent.  Data are not available for
separate waste streams because discrete points in each stream
were not accessible.  However, based on the combined wastewater
data and the raw materials and process used, casting contact
                               439

-------
cooling wastewater should contain treatable concentrations of
toxic organics and metals, ammonia, cyanide, fluoride, and
suspended solids.

CASTING WET AIR POLLUTION CONTROL

Four of the 28 silver plants with casting operations use either
baghouses or scrubbers to control air emissions from casting.
One plant with a wet scrubber discharges water, as shown in Table
V-ll.

Although the Agency did not collect samples from casting scrubber
waste streams, this wastewater is analogous to scrubber waste-
water from other secondary silver processes because of the
similarity in raw materials used.  Casting scrubber water should
contain toxic organics and metals above treatable concentrations.
The wastewater may also contain cyanide, phenolics, and suspended
solids.

LEACHING

In nonphotographic materials plants, leaching is used to recover
silver from silver sludges and copper matte associated with the
melting of electrical component parts.  Of the 15 nonphotographic
plants that leach, 12 discharge wastewater, consisting of either
silver-free leachate or lead-iron residue.  Water discharge rates
are given in Table V-12 in liters per metric ton of silver
produced from leaching.

Table V-8 (stream 40) shows combined raw wastewater data from
nonphotographic solutions precipitation and electrolytic refin-
ing.  Leaching wastewaters have similar characteristics as
precipitation wastewater because of the nature of the nonphoto-
graphic materials processed.  Data are not available for separate
waste streams because discrete points in each stream were not
accessible.  However, based on the combined wastewater data and
the raw materials and process used, raw wastewater from leaching
should contain toxic organics and metals, ammonia, fluoride,
cyanide, and suspended solids above treatable concentrations.

LEACHING WET AIR POLLUTION CONTROL

For leaching emissions, discharge rates are shown in Table V-13.
Of the 12 plants with leaching emissions control, eight discharge
wastewater.  This wastewater is analogous to scrubber wastewater
from other secondary silver processes and should be similarly
characterized.  Toxic organics and metals, cyanide, and suspended
solids should be present above treatable concentrations.
                               440

-------
PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS

Silver may be recovered by precipitation from leachates, waste
silver-plating solutions or melted silver scrap.  Nine nonphoto-
graphic plants report this process, seven discharging wastewater.
Depleted solutions may be discarded as wastewater, along with
washwater and silver-free filtrates.  Discharge water rates are
presented in Table V-15.

Table V-8 (stream 40) shows combined raw wastewater data from
nonphotographic solutions precipitation and electrolytic refin-
ing.  Data are not available for separate waste streams because
discrete points in each stream were not- accessible.  However,
based on the combined wastewater data and the raw materials and
process used, precipitation of nonphotographic solutions waste-
water should be characterized by the presence of toxic organics
and metals, ammonia, cyanide, chloride, fluoride, and suspended
solids above treatable concentrations.

PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS WET AIR
POLLUTION CONTROL

Air emissions control may be applied to precipitation and filtra-
tion processes.  Of the four plants using emission control, three
discharge water, as shown in Table V-15.  Toxic organics and
metals, phenolics, cyanide, and suspended solids characterize
wastewater from scrubbers on similar silver processes.  Raw
wastewater sampling data are presented in Table V-2.
                               441

-------
                            Table V-l

         WATER USE AND DISCHARGE RATES FOR FILM STRIPPING

            1/kkg of silver produced from film stripping)
    Plant
    Code

    30927

    566

    596
Percent
Recycle

   0

   NR

   NR
  Production
  Normalized
   Water Use

1,617.0

      NR

      NR
   Production
   Normalized
Discharge Flow

1,617.0

      NR

      NR
NR = Present but data not reported in dcp
                               442

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-------
Table V-2 (Continued)
ONDARY SILVER SAMPLING DATA
PHOTO - MISCELLANEOUS
RAW WASTEWATER
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-------
                            Table V-3

         WATER USE AND DISCHARGE RATES FOR PRECIPITATION
            AND FILTRATION OF FILM STRIPPING SOLUTIONS
            1/kkg of silver produced from film stripping)
Plant
Code
30927
541
74
566
602
Percent
Recycle
0
0
0
NR

Production
Normalized
Water Use
3,623.0
74.17
23.71
NR
No Wastewater
Production
Normalized
Discharge Flow
3,623.0
74.17
23.71
NR
Produced
NR
Present but data not reported in dcp
                              450

-------
                            Table V-4
         WATER USE AND DISCHARGE RATES FOR PRECIPITATION
             AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS

                (1Q3 1/kkg of silver precipitated)
Plant
Code
30927
538
9022
437
615
563
567
4301
74
Percent
Recycle
0
0
0
0
0
0
0
0
0
                            Production
                            Normalized
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                          2,890.0

                            680.0

                            433.0

                            217.0

                             50.6

                                NR

                                NR

                                NR

                                NR
                                            Production
                                            Normalized
                                         Discharge Flow

                                         2,890.0

                                           680.0

                                           433.0

                                           217.0

                                            50.6

                                               NR

                                               NR

                                               NR

                                               NR
NR
Present but data not reported in dcp
                               451

-------
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-------
                            Table V-6

         WATER USE AND DISCHARGE RATES FOR PRECIPITATION
         AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS WET AIR
                        POLLUTION CONTROL

              (10-* 1/kkg of silver precipitated)
    Plant
    Code

    553

    74

    459

    567
Percent
Recycle

  99+

  99

 100

  68
Production
Normalized
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39,021.1

   NR

   NR

   NR
  Production
  Normalized
Discharge Flow

      18.76

      NR

       0

      NR
NR = Present but data not reported in dcp
                              454

-------
                  Table V-7

WATER USE AND DISCHARGE RATES FOR ELECTROLYTIC
                   REFINING

       (103 1/kkg of silver refined)
                  Production
Production
Plant
Code
567
457
553
615
460
65
4301
Percent
Recycle
0
0
0
0
0
0
0
Normalized
Water Use
63.22
52.64
20.3
15.81
9.85
8.96
2.19
Normalized
Discharge Flow
63.22
52.64
20.3
15.81
9.85
8.96
2.19
                    455

-------
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-------
                            Table V-9
        WATER USE AND DISCHARGE RATES FOR FURNACE WET AIR
                        POLLUTION CONTROL

                 (103 1/kkg of silver produced)
Plant
Code
78
553
65
549
437
9020
596
441
62
459
4567
Percent
Recycle
99.9
99.7
100
100
100
0
100
100
100
100
NR
                            Production
                            Normalized
                             Water Use

                              4,620.0

                              1,580.5

                                638.3

                                373.1

                                303.5

                                252.9

                                NR

                                NR

                                NR

                                NR

                                NR
                                           Production
                                           Normalized
                                         Discharge Flow

                                                4.62

                                                4.74

                                                0

                                                0

                                                0

                                              252.9

                                                0

                                                0

                                                0

                                                0

                                                NR
NR
Present but data not reported in dcp,
                              460

-------
                            Table V-10

            WATER USE AND DISCHARGE RATES FOR CASTING
                      CONTACT COOLING WATER

                  (103 1/kkg of silver cast)
Plant
Code
460
553
9020
25
564
448
459
567
578
456
Percent
Recycle
0
0
0
0
0
0
*
0
0
NR
                            Production
                            Normalized
                             Water Use

                               47.4

                                6.32

                                3.53

                                1.58

                                1.34

                                NR

                                NR

                                NR

                                NR

                                NR
   Production
   Normalized
Discharge Flow

     47.4

      6.32

      3.53

      1.58

      1.34

      NR

      0

      NR

      NR

      NR
NR = Present but data not reported in dcp,

^Evaporated.
                              461

-------
                            Table V-ll

            WATER USE AND DISCHARGE RATES FOR CASTING
                    WET AIR POLLUTION CONTROL

                  (103 1/kkg of silver cast)
                            Production           Production
    Plant     Percent       Normalized           Normalized
    Code      Recycle        Water Use        Discharge Flow

    553        99.7           1,580.0               4.74

    459       100               NR                   NR
NR = Present but data not reported in dcp
                               462

-------
                            Table V-12



            WATER USE AND DISCHARGE RATES FOR LEACHING



                1/kkg of silver produced from leaching)






                            Production           Production
Plant
Code
9022
9020
549
615
78
553
25
82
448
567
459
664
74
Percent
Recycle
0
0
0
0
0
0
NR
NR
NR
0
NR
NR

Normalized
Water Use
20,425.2
3,161.0
86.7
3.61
2.54
2.19
NR
NR
NR
NR
NR
NR
No Wastewater
Normalized
Discharge Flow
20,425.2
3,161.0
86.7
3.61
2.54
2.19
NR
NR
NR
NR
NR
NR
Produced
NR = Present but data not reported in dcp,
                              463

-------
                            Table V-13

            WATER USE AND DISCHARGE RATES FOR LEACHING
                    WET AIR POLLUTION CONTROL
               1/kkg of silver produced from leaching)
Plant
Code
9020
74
549
83
553
78
82
459
664
448
567
Percent
Recycle
99
99+
99
79.2
99+
100
97.4
100
100
NR
65
                            Production
                            Normalized
                             Water Use

                             15,805.0

                              7,021.5

                              2,894.0

                              1,753.4

                                225.0

                                  2.5

                                NR

                                NR

                                NR

                                NR

                                NR
  Production
  Normalized
Discharge Flow

      158.05

        4.01

       28.9

      364.7

        0.45

        0

       NR

        0

        0

       NR

       NR
NR * Present but data not reported in dcp
                               464

-------
                            Table V-14
         WATER USE AND DISCHARGE RATES FOR PRECIPITATION
           AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS

                    1/kkg of silver precipitated)
    Plant
    Code

    9020

    615

    74

    460

    82

    9023

    578
         Percent
         Recycle

            0

            0

            0

            0

            0

            0

           NR
Production
Normalized
 Water Use

 2,528.8

   252.9

    29.06

    13.37

    NR

    NR

    NR
   Production
   Normalized
Discharge Flow

   2,528.8

     252.9

      29.06

      13.37

       NR

       NR

       NR
NR
Present but data not reported in dcp.
                               465

-------
                            Table V-15

         WATER USE AND DISCHARGE RATES FOR PRECIPITATION
           AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS
                    WET AIR POLLUTION CONTROL
                    1/kkg of silver precipitated)
    Plant
    Code

    9020

    74

    578
Percent
Recycle

  99

  99+

  NR
Production
Normalized
 Water Use
15,805.0

 7,021.5

    NR
  Production
  Normalized
Discharge Flow

      158.05

        1.62

       NR
NR = Present but data not reported in dcp.
                              466

-------


























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                             475

-------
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                              476

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                               478

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                   SECONDARY SILVER SUBCATEGORY

                            SECTION VI

                SELECTION OF POLLUTANT PARAMETERS
Section V of this supplement presented data from secondary silver
plant sampling visits and subsequent chemical analyses.  This
section examines that data and discusses the selection or exclu-
sion of pollutants for potential limitation.  The legal basis for
the exclusion of toxic pollutants under Paragraph 8(a) of the
Settlement Agreement is presented in Section VI of the General
Development Document.

Each pollutant selected for potential limitation is discussed in
Section VI of the General Development Document.  That discussion
provides information concerning where the pollutant originates
(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 describes the analysis that was per-
formed to select or exclude pollutants for further consideration
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 concen-
trations used for the toxic metals were the long-term performance
values achievable by lime precipitation, sedimentation, and
filtration.  The treatable concentrations used for the toxic
organics were the long-term values achievable by carbon adsorp-
tion (see Section VII of the General Development Document -
Combined Metals Data Base).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS

This study examined samples from the secondary silver subcategory
for three conventional pollutant parameters (oil and grease,
total suspended solids, and pH) and six nonconventional pollutant
parameters (ammonia, chemical oxygen demand, chloride, fluoride,
total organic carbon, and total phenols).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS SELECTED

The conventional and nonconventional pollutants and pollutant
parameters selected for consideration for limitation in this
subcategory are:

     ammonia
     phenols (total; by 4-AAP method)
                               479

-------
     total suspended solids (TSS)
     PH

Ammonia was found in all four samples analyzed in concentrations
ranging from 675 to 4,630 mg/1.  All of the values recorded are
well above the treatable concentration of 32.2 mg/1, attainable
by the available treatment technology.  Therefore, ammonia is
selected for consideration for limitation.

Total phenols are detected in all eight samples analyzed.  Four
samples contained phenols in concentrations above the treatable
concentration of 0.25 m/gl.  Concentrations for all samples
ranged from 0.012 to 62.5 mg/1.  Therefore, total phenols are
also selected for consideration for limitation.

Total suspended solids (TSS) concentrations ranging from 92 to
3,664 mg/1 were observed in the five samples analyzed for this
study.  All five samples exhibited concentrations above the
treatable concentration attainable by the identified treatment
technology.  Furthermore, most of the specific methods for
removing toxic metals do so by precipitation, and the result-
ing toxic metals precipitates should not be discharged..  Meeting
a limitation on TSS also aids in removal of precipitated toxic
metals.  For these reasons, total suspended solids is considered
for limitation in this subcategory.

The pH values observed in four of seven samples were outside the
6.0 to 10.0 range considered desirable for discharge to receiving
waters.  Four pH values ranged from 1.1 to 2.95.  The remaining
three samples ranged from 5.9 to 8.4.  Effective removal of toxic
metals by chemical precipitation requires careful control of pH.
Therefore, pH is considered for limitation in this subcategory.

TOXIC POLLUTANTS

The frequency of occurrence of the toxic pollutants in the waste-
water samples taken is presented in Table VI-1.  These data pro-
vide the basis for the categorization of specific pollutants, as
discussed below.  Table VI-1 is based on the raw wastewater data
from streams 12, 14, 16, 40, 61, and 230 (see Section V).  Treat-
ment plant.samples were not considered in the frequency count.
Raw waste stream 44 was not used in the count because it con-
tained gold, platinum, and palladium processing wastewater in
addition to silver processing wastewater.
                               480

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TOXIC POLLUTANTS NEVER DETECTED

Paragraph 8(a)(iii) of the Revised Settlement Agreement allows
the Administrator to exclude from regulation those toxic pollu-
tants not detectable by Section 304(h) analytical methods or
other state-of-the-art methods.  The toxic pollutants listed
below were not detected in any wastewater samples from this
subcategory; therefore, they are not selected for consideration
in establishing limitations:

      2.  acrolein
      3.  acrylonitrile
      5.  benzidine
      8.  1,2,4-trichlorobenzene
      9.  hexachlorobenzene
     12.  hexachloroethane
     13.  1,1-dichloroethane
     14.  1,1,2-trichloroethane
     16.  chloroethane
     17.  DELETED
     18.  bis(2-chloroethyl) ether
     19.  2-chloroethyl vinyl ether
     20.  2-chloronaphthalene
     21.  2,4,6-trichlorophenol
     22.  parachlorometa cresol
     24.  2-chlorophenol
     25.  1,2-dichlorobenzene
     26.  1,3-dichlorobenzene
     27.  1,4-dichlorobenzene
     28.  3,3'-dichlorobenzidine
     31.  2,4-dichlorophenol
     32.  1,2-dichloropropane
     33.  1,3-dichloropropylene
     34.  2,4-dimethylphenol
     35.  2,4-dinitrotoluene
     36.  2,6-dinitrotoluene
     37.  1,2-diphenylhydrazine
     39.  fluoranthene
     40.  4-chlorophenyl phenyl ether
     41.  4-bromophenyl phenyl ether
     42.  bis(2-chloroisopropyl) ether
     43.  bis(2-chloroethoxy) methane
     45.  methyl chloride
     46.  methyl bromide
     48.  dichlorobromomethane
     49.  DELETED
     50.  DELETED
     52.  hexachlorobutadiene
     53.  hexachlorocyclopentadiene
     54.  isophorone
                               481

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     55.  naphthalene
     56.  nitrobenzene
     57.  2-nitrophenol
     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
     65.  phenol
     71.  dimethyl phthalate
     72.  benzo(a)anthracene
     73.  benzo(a)pyrene
     74.  3,4-benzofluoranthene
     75.  benzo(k)fluoranthene
     76.  chrysene
     77.  acenaphthylene
     79.  benzo(ghi)perylene
     80.  fluorene
     82.  dibenzo(a,h)anthracene
     83.  indeno(l,2,3-cd)pyrene
     88.  vinyl chloride
     89.  aldrin
     94.  4,4'-DDD
     95.  alpha-endosulfan
     96.  beta-endosulfan
     97.  endosulfan sulfate
    101.  heptachlor epoxide
    105.  delta-BHC
    117.  beryllium
    129.  2,3,7,8-tetrachlorodibenzo-p-dioxin

TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION LIMIT

The provision of Paragraph 8(a)(iii) of the Revised Settlement
Agreement excluding from regulation those toxic pollutants which
are not detectable includes those pollutants whose concentrations
fall below EPA's nominal detection limit.  The toxic pollutants
listed below were never found above their analytical quantifica-
tion concentration in any wastewater samples from this subcate-
gory; therefore, they are not selected for consideration in
establishing limitations.

        7.  chlorobenzene
      15.  1,1,2,2-tetrachloroethane
      51.  chlorodibromomethane
      78.  anthracene      (a)
                               482

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      81.   phenanthrene   (a)
      90.   dieldrin
      91.   chlordane
      92.   4,4'-DDT
      93.   4,4'-DDE
      98.   endrin
      99.   endrin aldehyde
     100.   heptachlor
     102.   alpha-BHC
     103.   beta-BHC
     104.   gamma-BHC
     113.   toxaphene
     116.   asbestos

(a)  Reported together.

TOXIC POLLUTANTS PRESENT BELOW CONCENTRATIONS ACHIEVABLE BY
TREATMENT

Paragraph 8(a)(iii) of the Revised Settlement Agreement also
allows the exclusion of toxic pollutants which were detected in
quantities too small to be effectively reduced by technologies
known to the Administrator.  The pollutants listed below are not
selected for consideration in establishing limitations because
they were not found in any wastewater samples from this subcate-
gory above concentrations considered achievable by existing or
available treatment technologies.  These pollutants are dis-
cussed individually following the list.

      1.  acenaphthene
     30.  1,2-trans-dichloroethylene
     38.  ethylbenzene

Acenaphthene was detected in only one of nine samples analyzed.
That sample contained 0.010 mg/1, which is the treatable
concentration.  Since the pollutant was not detected above the
concentration attainable by identified treatment technology,
acenaphthene is not considered for limitation.

1,2-trans-dichloroethylene was found in only one sample above its
quantification limit.  The reported concentration was 0.049 mg/1.
which is below the treatable concentration of 0.1 mg/1.  There-
fore, 1,2-trans-dichloroethylene is not considered for limita-
tion.

Ethylbenzene was detected in five of nine samples analyzed.
Three samples contained this pollutant above its quantification
limit, but below its treatable concentration of 0.05 mg/1.
Ethylbenzene concentrations were 0.021, 0,017, and 0.016 mg/1.
Therefore, ethylbenzene is not considered for limitation.
                               483

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TOXIC POLLUTANTS DETECTED IN A SMALL NUMBER OF SOURCES

Paragraph 8(a)(iii) allows for the exclusion of a toxic pollutant
if it is detectable in the effluent from only a small number of
sources within the subcategory and it is uniquely related to only
those sources.  The following pollutants were not selected for
limitation on this basis.

     11.  1,1,1-trichloroethane
     23.  chloroform
     44.  methylene chloride
     47.  bromoform
     66.  bis(2-ethylhexyl) phthalate
     67.  butyl benzyl phthalate
     68.  di-n-butyl phthalate
     69.  di-n-octyl phthalate
     70.  diethyl phthalate
     84.  pyrene
     85.  tetrachloroethylene
     86.  toluene
    106.  PCB-1242     (b)
    107.  PCB-1254     (b)
    108.  PCB-1221     (b)
    109.  PCB-1232     (c)
    110.  PCB-1248     (c)
    111.  PCB-1260     (c)
    112.  PCB-1016     (c)
    123.  mercury

(b),(c)  Reported together.

Although these pollutants were not selected for consideration- in
establishing nationwide limitations, it may be appropriate, on a
case-by-case basis, for the local permitter to specify effluent
limitations.

1,1,1-Trichloroethane was detected at two plants in two of nine
samples, both at concentrations of 0.022 mg/1.  The treatability
concentration is 0.01 mg/1 for this pollutant.  Since it was not
detected in seven other samples, the measurements may be regarded
as specific to the site and not characteristic of the subcategory
as a whole. Also, 1,1,1-trichloroethane cannot be attributed to
specific materials and processes used in the secondary silver
subcategory.  All 25 of the secondary silver plants reporting the
presence or absence of toxic pollutants indicated in the dcp that
this pollutant was either known or believed to be absent from
their wastewater.  Therefore, 1,1,1-trichloroethane is not
considered for limitation.

Chloroform was found at concentrations ranging from 0.109 to 1.31
mg/1 in five  of nine samples.  The achievable concentration
treatment for chloroform is 0.1 mg/1.  Chloroform cannot be
traced  to specific materials or processes associated with the


                               484

-------
secondary silver subcategory; however, it is a common laboratory
solvent and the high concentrations found could be   attributed
to sample contamination.  The presence of chloroform in the blank
samples taken attest to this possibility, particularly since the
pollutant was not detected in four samples.  The results cannot
be generalized as characteristic of the subcategory.  All 25 of
the secondary silver plants reporting the presence or absence of
toxic pollutants indicated in the dcp that this pollutant was
either known or believed to be absent from their wastewater.
Therefore, chloroform is not considered for limitation.

Methylene chloride was measured at a concentration above its
treatable concentration in three of nine samples in one plant,
with values of 0.67, 3.10, and 3.32 mg/1.  The treatable con-
centration is 0.1 mg/1.  This pollutant is not attributable to
specific materials or processes associated with the secondary
silver subcategory, but is a common solvent used in analytical
laboratories.  All 25 of the secondary silver plants reporting
the presence or absence of toxic pollutants indicated in the dcp
that this pollutant was either known or believed to be absent
from their wastewater.  Because methylene chloride was not
detected in six of nine samples, as well as the high probability
of sample contamination, this pollutant is not considered for
limitation.

Bromoform was not detected in eight of nine samples, but was
found above its treatable concentration in one sample.  The 0.065
mg/1 found is only slightly higher than the 0.05 mg/1 treatable
concentration.  All 25 of the secondary silver plants reporting
the presence or absence of toxic pollutants indicated in the dcp
that this pollutant was either known or believed to be absent
from their wastewater.  Since bromoform is present at only one
source, bromoform is assumed to be unique to that source and not
considered for limitation.

Bis(2-ethylhexyl) phthalate was found above its treatable con-
centration of 0.01 mg/1 in four of five samples.  The concentra-
tions ranged from 0.011 to 0.119 mg/1.  This pollutant is not
associated with specific processes used in the secondary silver
subcategory, but is commonly used as a plasticizer in laboratory
and field sampling equipment.  All 25 of the secondary silver
plants reporting the presence or absence of toxic pollutants
indicated in the dcp that this pollutant was either known or
believed to be absent from their wastewater.  Since the presence
of this pollutant may be attributed to sample contamination,
bis(2-ethylhexyl) phthalate is not considered for limitation.

Butyl benzyl phthalate was measured in two of five samples at
concentrations of 0.052 and 0.054 mg/1.  The treatable concen-
tration for this pollutant ranges from 0.001 to 0.01 mg/1.
                               485

-------
This pollutant is used as a plasticizer in laboratory and field
sampling equipment.  Since it was not detected in three of five
samples, the measurements may be regarded as specific to the site
and not characteristic of the subcategory as a whole.  All 25 of
the secondary silver plants reporting the presence or absence of
toxic pollutants indicated in the dcp that this pollutant was
either known or believed to be absent from their wastewater.
Therefore, butyl benzyl phthalate is not considered for
limitation.

Di-n-butyl phthalate was found above its treatable concentration
(0.025 mg/1) in two of five samples analyzed.  However> this
compound is a plasticizer used in many products found in manufac-
turing plants; it is not associated with specific processes used
in this subcategory.  All 25 of the secondary silver plants
reporting the presence or absence of toxic pollutants indicated
in the dcp that this pollutant was either known or believed to be
absent from their wastewater.  Therefore, di-n-butyl phthalate is
not considered for limitation.

Di-n-octyl phthalate was measured above its treatable concentra-
tion (0.01 mg/1) in three of five samples analyzed.  However,
this compound is a plasticizer used in many products found in
manufacturing plants; it is not associated with specific
processes in this subcategory.  All 25 of the secondary silver
plants reporting the presence or absence of toxic pollxitants
indicated in the dcp that this pollutant was either known or
believed to be absent from their wastewater.  Therefore,
di-n-ocytl phthalate is not considered for limitation.

Diethyl phthalate was detected above its treatable concentration
(0.025 mg/1) in one of five samples analyzed.  However, this
compound is a plasticizer used in many products found in manufac-
turing plants; it is not associated with specific processes in
this subcategory.  All 25 of the secondary silver plants report-
ing the presence or absence of toxic pollutants indicated in the
dcp that this pollutant was either known or believed to be absent
from their wastewater.  Because of the site-specificity of the
one result, diethyl phthalate is not considered for limitation.

Pyrene was found in one of five samples at a concentration of
2.15 mg/1.  The treatable concentration for this pollutant ranges
from 0.001.to 0.01 mg/1.  Pyrene was not detected in four other
samples, including two samples from the same plant at the treat-
able value.  All 25 of the secondary silver plants reporting the
presence or absence of toxic pollutants indicated in the dcp that
this pollutant was either known or believed to be absent from
their wastewater.  This site-specific result cannot be general-
ized as characteristic of the whole subcategory, so pyrene is not
considered for limitation.
                               486

-------
Tetrachloroethylene was detected above its treatable concentra-
tion (0.05 mg/1) in two of nine samples.  The concentrations
found were 0.087 and 0.123 mg/1.  Tetrachloroethylene was also
found in plant source water and sample blanks. This pollutant is
not attributable to the materials and processes in this subcate-
gory and the results cannot be generalized as characteristic of
the subcategory as a whole.  All 25 of the secondary silver
plants reporting the presence or absence of toxic pollutants
indicated in the dcp that this pollutant was either known or
believed to be absent from their wastewater.  Therefore, tetra-
chloroethylene is not considered for limitation.

Toluene was found above its treatable concentration (0.05 mg/1)
in one of nine samples, at 0.057 mg/1.  This pollutant is not
attributable to specific materials and processes in this sub-
category.  All 25 of the secondary silver plants reporting the
presence or absence of toxic pollutants indicated in the dcp that
this pollutant was either known or believed to be absent from
their wastewater.  Therefore, toluene is not considered for
limitation.

The seven toxic pollutant PCB's (polychlorinated biphenyls) are
not clearly separated by the analytical protocol used in this
study; thus, they are reported in two groups.  The first group
contains PCB-1242, PCB-1254, and PCB-1221; the second PCB-1232,
PCB-1248, PCB-1260, and PCB-1016.  Both groups were found in one
of five samples at the same plant.  The concentration for each
group was 0.012 mg/1, which exceeds the treatable concentration
of 0.001 mg/1.  All 25 of the secondary silver plants reporting
the presence or absence of toxic pollutants indicated in the dcp
that this pollutant was either known or believed to be absent
from their wastewater.  Since these pollutants were found in only
one plant, they are assumed to unique to that source and are not
considered for limitation.

Mercury was measured above its treatable concentration (0.036
mg/1) in one of four samples.  Even though found at 1.0 mg/1,
this pollutant is not attributable to specific materials and pro-
cesses in this subcategory.  Also, 22 of the 25 secondary silver
plants reporting the presence or absence of toxic pollutants
indicated in the dcp that mercury was known to be absent or
believed to be absent from their wastewater.  Since it was found
in only one plant, mercury is not considered for limitation.
                               487

-------
TOXIC POLLUTANTS SELECTED FOR CONSIDERATION IN ESTABLISHING
LIMITATIONS

       4.  benzene
       6.  carbon tetrachloride
      10.  1,2-dichloroethane
      29.  1,1-dichloroethylene
      87.  trichloroethylene
     114.  antimony
     115.  arsenic
     118.  cadmium
     119.  chromium
     120.  copper
     121.  cyanide
     122.  lead
     124.  nickel
     125.  selenium
     126.  silver
     127.  thallium
     128.  zinc

Benzene was detected above its treatable concentration (0.05 to
0.010 mg/1) in six of nine samples.  The concentrations ranged
from 0.054 to 2.05 mg/1.  Since benzene was present in concentra-
tions exceeding the concentration achievable by identified treat-
ment technology, it is selected for consideration for limitation.

Carbon tetrachloride was found above its treatable concentration
(0.05 mg/1) in three of nine samples.  Concentrations ranged from
0.07 to 2.3 mg/1.  Since carbon tetrachloride was present in
concentrations exceeding the concentration achievable by identi-
ified treatment technology, it is selected for consideration for
limitation.

1,2-Dichloroethane was detected above its quantification limit in
four of nine samples in two plants.  Two samples, with concentra-
tions of 0.58 and 0.156 mg/1, were above the concentration con-
sidered attainable by treatment (0.1 mg/1).  Since 1,2-dichloro-
ethane was present in concentrations exceeding the concentra-
tion achievable by identified treatment technology, it is
selected for consideration for limitation.

1,1-Dichloroethylene was measured above its quantification limit
in three of nine samples in two plants.  Two samples were above
the treatable concentration (0.1 mg/1) for this pollutant with
concentrations of 0.33 and 6.1 mg/1.  Since 1,1-dichloroethylene
was present in concentrations exceeding the concentration achiev-
able by identified treatment technology, it is selected for
consideration for limitation.
                               488

-------
Trichloroethylene was detected above its treatable concentration
(0.01 mg/1) in three of nine samples.  The concentrations ranged
from 0.473 to 0.93 mg/1.  Since trichloroethylene was present in
concentrations exceeding the concentration achievable by identi-
fied treatment technology, it is selected for consideration for
limitation.

Antimony was found above its treatable concentration (0.47 mg/1)
in three of five samples.  The concentrations ranged from 0.7 to
12.0 mg/1.  Since antimony was present in concentrations exceed-
ing the concentration achievable by identified treatment techno-
logy, it is selected for consideration for limitation.

Arsenic was measured above its quantification limit in all five
samples analyzed.  Two of the five samples contained this
pollutant above the treatable concentration (0.34 mg/1), with
concentrations of 1.9 and 2.2 mg/1.  Since arsenic was present in
concentrations exceeding the concentration achievable by identi-
fied treatment technology, it is selected for consideration for
limitation.

Chromium was found above its treatable concentration (0.07 mg/1)
in all five samples analyzed.  The concentrations ranged from 0.3
to 100 mg/1.  Since chromium was present in concentrations
exceeding the concentration achievable by identified treatment
technology, it is selected for consideration for limitation.

Copper was detected above its treatable concentration (0.39 mg/1)
in all five samples analyzed.  The concentrations ranged from
0.72 to 70.0 mg/1.  Since copper was present in concentrations
exceeding the concentration achievable by identified treatment
technology, it is selected for consideration for limitation.

Cyanide was measured above its treatable concentration (0.047
mg/1) in six of nine samples from four of the five waste streams.
The concentrations ranged from 0.132 to 5.95 mg/1, in two plants
(one photographic and one nonphotographic).  Since cyanide was
present in concentrations exceeding the concentration achievable
by identified treatment technology, it is selected for considera-
tion for limitation.

Lead was found above its treatable concentration (0.08 mg/1) in
all five samples analyzed.  The concentrations ranged from 0.5 to
9.0 mg/1.  Since lead was present in concentrations exceeding the
concentration achievable by identified treatment technology, it
is selected for consideration for limitation.

Nickel was measured above its treatable concentration (0.22 mg/1)
in four of five samples.  The concentrations ranged from 0.4 to
30.0 mg/1.  Since nickel was present in concentrations exceeding
the concentration achievable by identified treatment technology,
it is selected for consideration for limitation.
                               489

-------
Selenium was found above its treatable concentration (0.20mg/l)
in three of five samples.  The concentrations ranged from 0.25 to
0.9 mg/1.  Since selenium was present in concentrations exceeding
the concentration achievable by identified treatment technology,
it is selected for consideration for limitation.

Silver was detected above its quantification limit in three of
five samples analyzed.  Concentrations ranged from 0.07 to 5.0
mg/1.  Three samples contained silver at concentrations above the
concentration considered attainable by treatment (0.07 mg/1).
Since silver was present in concentrations exceeding the
concentration achievable by identified treatment technology, it
is selected for consideration for limitation.

Thallium was found above its quantification limit in two of the
five samples analyzed for this pollutant.  One of the five
samples contained thallium at a concentration of 0.4 mg/1, above
the treatable concentration (0.34 mg/1) for this pollutant.
Since thallium was present in concentrations exceeding the con-
centration achievable by identified treatment technology, it is
selected for consideration for limitation.

Zinc was measured above its treatable concentration (0.23 mg/1)
in all five samples analyzed.  The concentrations ranged from 4.0
to 2,000 mg/1.  Since zinc was present in concentrations
exceeding the concentration attainable by identified treatment
technology, it is selected for for consideration for limitation.
                               490

-------
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                   SECONDARY SILVER SUBCATEGORY

                           SECTION VII

                CONTROL AND TREATMENT TECHNOLOGIES
The preceding sections of this supplement discussed the sources,
flows, and characteristics of the wastewaters from secondary
silver plants.  This section summarizes the description of these
wastewaters and indicates the level of treatment which is cur-
rently practiced by the secondary silver subcategory for each
waste stream.

CURRENT CONTROL AND TREATMENT PRACTICES

Control and treatment technologies are discussed in general in
Section VII of the General Development Document.  The basic prin-
ciples of these technologies and the applicability of wastewater
similar to that found in this subcategory are presented there.
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 secondary silver
subcategory is characterized by the presence of the toxic metal
pollutants and suspended solids.  (The raw (untreated) wastewater
data for specific sources as well as combined waste streams are
presented in Section V).  Generally, these pollutants are present
in each of the waste streams at concentrations above treatabil-
ity, 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.  Seven plants in this subcate-
gory currently have combined wastewater treatment systems, five
have lime precipitation and sedimentation, and three have lime
precipitation, sedimentation and filtration.  As such, four
options have been selected for consideration for BPT, BAT, BDT,
BCT, and pretreatment in this subcategory, based on combined
treatment of these compatible waste streams.

FILM STRIPPING

The emulsion resulting from the stripping of photographic film
can be screened and rinsed, producing wastewater.  Three of the
eight plants with this process reported an effluent, none of
which is recycled.  As discussed in Section V, this wastewater
should contain treatable concentrations of toxic metals, oil and
grease, cyanide, and suspended solids.  One plant treats film
stripping wastewater in an activated sludge system.  Two plants
reported no wastewater treatment.
                               495

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FILM STRIPPING WET AIR POLLUTION CONTROL

One of the eight plants engaged in film stripping uses a wet
scrubber to control air emissions.  Toxic organics, toxic metals,
phenolics, suspended solids, and cyanide should be present at
treatable concentrations.  This plant practices 99+ pesrcent
recycle of film stripping scrubber water.  Treatment of the
wastewater consists of neutralization, flocculation, and
sedimentation.

PRECIPITATION AND FILTRATION OF FILM STRIPPING SOLUTIONS

Depleted silver solutions from film stripping must be discarded
after precipitation.  Four of six plants discharge this waste-
water.  Toxic organics, toxic metals, suspended solids, phenol-
ics, and cyanide should be present at treatable concentrations.
No plants reported recycling this wastewater.  Treatment at one
plant consists of an activated sludge system.  Another plant
treats by neutralization with caustic soda or acid, flocculation
by polymer addition, and settling.  Two plants discharge into
municipal sewer lines without treatment.

PRECIPITATION AND FILTRATION OF FILM STRIPPING SOLUTIONS WET AIR
POLLUTION CONTROL

One plant uses a wet scrubber to control air emissions from a
precipitation process.  Toxic organics, toxic metals, cyanide,
phenolics, and suspended solids should be found at treatable con-
centrations in the scrubber wastewater.  The scrubber wastewater
recycle is 99 percent. Treatment before discharge consists of
neutralization, flocculation (with a polymer agent), and set-
tling.

PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS

Silver-free solutions are usually discarded after precipitation.
Nine of the 15 plants precipitating photographic solutions pro-
duce wastewater from this process.   Treatable concentrations of
ammonia and toxic metals characterize this wastewater.  Most sus-
pended solids will have been removed with the silver precipitate
during filtration.  There are no plants that recycle this waste-
water.  A number of treatment methods are applied before this
wastewater is discharged.  They are:

     1.  Neutralization - two plants,
     2.  Neutralization and sedimentation - one plant,
     3.  Neutralization, sedimentation, and filtration - two
         plants, and
     4.  Activated sludge system - one plant.
                               496

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PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS WET AIR
POLLUTION CONTROL

Four plants use wet scrubbers on precipitation and filtration
processes.  The wastewater characteristics are similar to scrub-
ber wastewater from film stripping precipitation because of the
similar materials and processes used.  Toxic organics, metals,
phenolics, cyanide, and suspended solids should be present in
this wastewater at treatable  concentrations.  One plant prac-
tices complete recycle of silver solution scrubber water.  The
three others practice partial recycle of the scrubber liquor
(from 68 to >99+ percent).  The following treatment schemes are
currently in use in the subcategory:

     1.  100 percent evaporation - one plant,
     2.  Neutralization - one plant,
     3.  Contractor disposal - one plant, and
     4.  No treatment - one plant.

ELECTROLYTIC REFINING

Wastewater discharges from electrolytic refining consist of spent
electrolyte solution.  Of the 20 plants having an electrolytic
refining process, 12 discharge wastewater.  This wastewater
should contain treatable concentrations of carbon tetrachloride,
pyrene, brotnoform, benzene, and tetrachloroethylene.  Toxic
metals, ammonia, cyanide, and suspended solids are present above
treatable concentrations.  One plant reported recycling the spent
electrolyte to a precipitation process.  The following treatment
methods are currently practiced:

     1.  No treatment - seven plants,
     2.  Neutralization - one plant,
     3.  Precipitation with sodium chloride and sedimentation -
         one plant,
     4.  Contractor disposal - one plant,
     5.  Chemical reduction, neutralization, and sedimentation -
         one plant, and
     6.  Flocculation and sedimentation - one plant.

FURNACE WET AIR POLLUTION CONTROL

Air emission sources in secondary silver furnace operations are
incinerators, roasting and drying furnaces, and melting furnaces.
Nineteen secondary silver producers control air emissions, using
various methods.  These are:

     1.  Baghouse - seven plants,
     2.  Dry electrostatic precipitator (ESP) - one plant,

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     3.  Wet electrostatic precipttator - one plant,
     4.  Wet scrubber - five plants,
     5.  Baghouse and wet scrubber - three plants,
     6.  Scrubber and ESP - one plant, and
     7.  Afterburners (for incinerators).

Toxic organics, metals, phenolics, cyanide, and suspended solids
should be present at treatable concentrations in the wastewater
produced by wet air pollution control.  Seven plants producing
this wastewater practice complete recycle.  Four others practice
partial recycle (>99 percent).  Treatment methods used are:

     1.  No treatment - one plant,
     2.  100 percent evaporation - one plant,
     3.  Neutralization, flocculation with polymer, and sedimen-
         tation - one plant, and
     4.  Contractor disposal - one plant.

CASTING CONTACT COOLING WATER

Of the 44 secondary silver plants, 28 have casting operations, 11
using contact cooling water.  One plant achieves zero discharge
through evaporation and no plants practice recycle.  Casting con-
tact cooling water should contain dissolved and suspended solids,
and metals.  Current treatment methods used are:

     1.  Neutralization - two plants,
     2.  Neutralization, flocculation with polymer, and
         filtration - one plant,
     3.  Neutralization and sedimentation - one plant, and
     4.  No treatment - seven plants.

CASTING WET AIR POLLUTION CONTROL

Air emissions from casting operations are controlled in four
plants.  Two plants use baghouses, one plant uses a wet scrubber,
and another reported a scrubber and a baghouse.  Water from
scrubbers should contain treatable concentrations of toxic
metals, suspended solids, and organics and must be treated before
recycling.  One plant practices complete recycle of the scrubber
water, the other plant recycles 99+ percent.  No treatment of
this wastewater was reported.

LEACHING

Of the 15 nonphotographic silver plants that leach, 12 discharge
wastewater.  This wastewater should contain treatable concentra-
tions of toxic organics and metals, ammonia, cyanide, phenolics,
and suspended solids.  One plant practices complete recycle of
the wastewater.  The other plants do not recycle.  One plant
                               •498

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recovers precious metals from the waste by electrolysis.
Wastewater treatment methods used are:

     1.  Neutralization - one plant,
     2.  Neutralization, sedimentation, and filtration - two
         plants, and
     3.  Contractor disposal - two plants.


LEACHING WET AIR POLLUTION CONTROL

Twelve plants that leach nonphotographic materials reported air
emissions controls.  Devices commonly used are packed bed, spray
tower, and venturi scrubbers.  Eight plants discharge wastewater,
which should contain treatable concentrations of toxic organics,
toxic metals, ammonia, cyanide, and suspended solids.  Three
plants practice complete recycle of the scrubber water.  Seven
other plants recycle from 65 to 99+ percent.  Treatment methods
used consist of:

     1.  Neutralization - one plant,
     2.  Neutralization, sedimentation, and filtration - two
         plants, and
     3.  No treatment - five plants.

PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS

Seven of the nine nonphotographic silver plants with this process
produce wastewater.  This wastewater should contain toxic organ-
ics, toxic metals, ammonia, cyanide, phenolics, and suspended
solids.  No plants reported recycling this waste stream.  Treat-
ment methods for this wastewater consist of:

     1.  Neutralization and sedimentation - two plants,
     2.  Neutralization, sedimentation, and filtration - two
         plants,
     3.  Contractor disposal - one plant, and
     4.  No treatment - two plants.

PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS WET AIR
POLLUTION CONTROL

Scrubbers are used in four plants to control fumes from precipi-
tation and filtration processes.  This wastewater should contain
treatable concentrations of toxic organics, toxic metals, pheno-
lics, cyanide, and suspended solids.  Three plants discharge this
wastewater while two plants practice 99+ percent recycle.  Scrub-
ber water is commonly combined with other process wastewater and
treated in a central plant facility.  Treatment methods used
are:

     1.  Neutralization - one plant, and
     2.  Neutralization, sedimentation, and filtration - two
         plants.


                               499

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CONTROL AND TREATMENT OPTIONS CONSIDERED

Based on an examination of the wastewater sampling data, four
control and treatment technologies that effectively control the
pollutants found in secondary silver wastewaters were selected
for evaluation.  These technology options are discussed below.

Other treatment technologies included activated alumina adsor-
ption (Option D) and reverse osmosis (Option F).  Although these
technologies are theoretically applicable to wastewaters gener-
ated in the secondary silver subcategory, they were not selected
for evaluation because they are not demonstrated in the nonfer-
rous metals manufacturing category, nor are they clearly
transferable.

OPTION A

Option A for the secondary silver subcategory requires treatment
technologies to reduce pollutant mass.  The Option A treatment
scheme consists of ammonia steam stripping preliminary treatment
applied to the combined stream of precipitation and filtration of
photographic and nonphotographic solutions.  Preliminary treat-
ment is followed by lime and settle (chemical precipitation and
sedimentation) applied to the combined stream steam stripper
effluent and the combined stream of all other wastewater.  Chemi-
cal precipitation is used to remove metals and fluoride by the
addition of lime followed by gravity sedimentation.  Suspended
solids are also removed from the process.

OPTION B

Option B for the secondary silver subcategory consists of the
ammonia steam stripping, lime precipitation, and sedimentation
technology considered in Option A plus control technologies to
reduce the discharge of wastewater volume.  Water recj^cle and
reuse of scrubber water and casting contact cooling water are the
principal control mechanisms for flow reduction.

OPTION C

Option C for the secondary silver subcategory consists of the
ammonia steam stripping, in-process flow reduction, lime pre-
cipitation, and sedimentation technology considered in Option B
plus multimedia filtration technology added at the end of the
Option B treatment scheme.  Multimedia filtration is used to
remove suspended solids, including precipitates of metals and
fluoride, beyond 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 consistent removal during
periods in which there are rapid increases in  flows or loadings
of pollutants to the treatment system.


                               500

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OPTION E

Option E for the secondary silver subcategory consists of the
ammonia steam stripping, in-process flow reduction, lime pre-
cipitation, sedimentation, and multimedia filtration technology
considered in Option C with the addition of granular activated
carbon technology at the end of the Option C treatment scheme.
The activated carbon process is utilized to control the discharge
of toxic organics.
                               501

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                   SECONDARY SILVER SUBCATEGORY

                           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 silver plants.  The
energy requirements of the considered options as well as solid
waste and air pollution aspects are also discussed.  Section VIII
of the General Development Document provides background on the
capital and annual costs for each of the technologies discussed
herein.

The various sources of wastewater that have been discussed
throughout this document are combined into two groups.  These
groups are based on the source of raw materials in the secondary
silver subcategory:  photographic and nonphotographic.  These
groups are selected because the combinations of wastestreams in
each is representative of the processing that occurs in most
plants.  In addition, the wastestreams associated with each group
also require varying degrees of preliminary treatment with
ammonia steam stripping.  This will be discussed further below.
Since all the plants in the subcategory can be classified in one
or the other or both of these groups, a division of the waste
streams along these lines is appropriate.  The wastewater sources
in the secondary silver subcategory have been divided for the
purposes of cost estimation as follows:

     Photographic Group

      1.  Film stripping
      2.  Film stripping wet air pollution control
      3.  Precipitation and filtration of film stripping
          solutions
      4.  Precipitation and filtration of film stripping
          solutions
          wet air pollution control
      5.  Precipitation and filtration of photographic solutions
      6.  Precipitation and filtration of photographic solutions
      7   wet air pollution control
      8.  Electrolytic refining
      9.  Furnace wet air pollution control
     10.  Casting contact cooling water
     11.  Casting wet air pollution control.

     Nonphotographic Group

      1.  Leaching
      2.  Leaching wet air pollution control
                               503

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      3.  Precipitation and filtration of nonphotographic
          solutions
      4.  Precipitation and filtration of nonphotographic
          solutions wet air pollution control
      5.  Furnace wet air pollution control
      6.  Electrolytic refining
      7.  Casting contact cooling water
      8.  Casting wet air pollution control.

Plants which process both photographic and nonphotographic mate-
rials are included in the photographic group, since the processes
in both groups are similar and the photographic group encompasses
the waste streams requiring preliminary treatment for the second-
ary silver subcategory.

Section VI indicated that significant pollutants or pollutant
parameters in the secondary silver subcategory are copper, zinc,
TSS, ammonia, and pH.  As explained in Section VI of the General
Development Document, metals are most economically removed by
chemical precipitation, sedimentation, and filtration.  Ammonia
may be removed from waste streams by steam stripping, and
activated carbon is a technology for removing organics.

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES

As discussed in Section VII, four control and treatment options
have been developed for both the photographic group and the non-
photographic group.  Cost estimates in the form of annual cost
curves were developed for each of these control and treatment
options.  The options are summarized below and schematically pre-
sented in Figures X-l through X-4.

OPTION A

Option A requires preliminary ammonia steam stripping treatment,
and end-of-pipe technology consisting of lime precipitation and
sedimentation.  The cost curves for the photographic group assume
that 94 percent of the combined wastewaters undergo preliminary
ammonia steam stripping treatment, while the nonphotographic
group cost curves assume 25 percent.  Specific streams that will
require ammonia steam stripping preliminary treatment include
precipitation and filtration of photographic solutions waste-
water, and precipitation and filtration of nonphotographic
solutions wastewater.

OPTION B

Option B requires in-process flow reduction measures, preliminary
ammonia steam stripping treatment, and end-of-pipe treatment
technology consisting of lime precipitation and sedimentation.
The in-process flow reduction measures consist of the recycle of
wet air pollution control water, through holding tanks, and the
                               504

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recycle of casting contact cooling water through cooling towers.
The holding tank cost curve is based on a retention time of one
day for the scrubber water which is to be recycled.  To determine
the cost of Option B, the holding tank and cooling tower costs
are added to the cost of Option A.

OPTION C

Option C requires the in-process flow reduction measures of
Option B, preliminary ammonia steam stripping treatment, and
end-of-pipe treatment technology consisting of lime precipita-
tion, sedimentation, and multimedia filtration.  The cost curves
developed for Option C do not include the cost of in-process flow
reduction.  Therefore, the total cost of Option C is determined
by adding the holding tank and cooling tower costs to the costs
determined from the Option C cost curves.

OPTION E

Option E requires the in-process flow reduction measures of
Option B and C, preliminary ammonia steam stripping treatment,
and end-of-pipe treatment technology consisting of lime precipi-
tation, sedimentation, multimedia filtration, and activated
carbon adsorption.  The cost curves developed for Option E do not
include the cost of in-process flow reduction.  Therefore, the
total cost of Option E is determined by adding holding tank and
cooling tower costs to the costs determined from the Option E
cost curves.

The cost curves for the options summarized above are presented in
the figures listed below the respective options which the curves
are based on are also shown.

     Group            Figure VIII-          Option Costed

   Photographic            1-3                   A, C, E
   Nonphotographic         4-6                   A, C, E

The holding tank and cooling tower cost curves are presented in
Figures VIII-7 and VIII-8, respectively.

NONWATER QUALITY ASPECTS

A general discussion of the nonwater quality aspects of the con-
trol and treatment options considered for the nonferrous metals
category is contained in Section VIII of the General Development
Document.  Nonwater quality impacts specific to the secondary
silver subcategory including energy requirements, solid waste,
and air pollution are discussed below.

ENERGY REQUIREMENTS

The methodology used for determining the energy requirements for
the various options is discussed in Section VIII of the General
Development Document.  Briefly, the energy usage of the various

                               505

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options is determined for the secondary silver plant with the
median wastewater flow.  The energy usage of the options is then
compared to the energy usage of the median secondary silver
energy consumption plant.  As shown in Table VIII-1, the most
energy intensive option is reverse osmosis, which increases the
median secondary silver energy consumption by 0.25 percent.  The
remaining three options would increase this plant's energy con-
sumption by less than 0.25 percent.

SOLID WASTE

Sludges associated with the secondary silver subcategory will
necessarily contain additional quantities (and concentrations) of
toxic metal pollutants.  Wastes generated by secondary metals
industries can be regulated as hazardous.  However, the Agency
examined the solid wastes that would be generated at secondary
nonferrous metals manufacturing plants by the suggested treatment
technologies and believes they are not hazardous wastes under the
Agency's regulations implementing Section 3001 of the Resource
Conservation and Recovery Act.  None of these wastes is 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, sedimenta-
tion, and filtration.  By the addition of excess lime during
treatment, similar sludges, specifically toxic metal bearing
sludges, generated by other industries such as the iron and steel
industry, passed the Extraction Procedure (EP) toxicity test.
See 40 CFR 8261.24.  Thus, the Agency believes that the
wastewater sludges will similarly not be EP toxic if the
recommended technology is applied.

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 non-
ferrous 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 trans-
porter 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).


                               506

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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 were not identified as hazardous, they still
must be disposed of in compliance with the Subtitle D open dump-
ing 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.  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 ammonia steam strip-
ping chemical precipitation, sedimentation, multimedia filtration
and activated carbon adsorption.  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 the cooling tower systems which are used as the
basis for flow reduction in the secondary silver subcategory.
However, the Agency does not consider this impact to be
significant.
                               507

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                                     511

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                    SECONDARY SILVER HOLDING TANK COSTS
                                                          iao
                      •  I  • t  • t ••!    ff  •  •»•«•»!    t  f  »tflf4«
                               Figure VIII-8

        SECONDARY  SILVER COOLING TOWER COSTS CASTING CONTACT  COOLING
                                   512

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                   SECONDARY SILVER SUBCATEGORY

                            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 silver 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 facili-
ties involved, the manufacturing processes employed, 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 predictipn
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 within the subcategory.

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.  Some of the
factors which must be considered in establishing effluent limi-
tations 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.
                               513

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As explained in Section IV, the secondary silver subcategory has
been subdivided into 14 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 14 subdivisions.

For each of the subdivisions, 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 deter-
mined 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 ana-
lyzed to determine (1) whether or not operations included gener-
ated 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 waste-
water, 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 normal-
ized 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 loadings were
calculated for each wastewater source or subdivision.  This cal-
culation 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 loadings (milligrams of pollu-
tant per metric ton of production unit - mg/kkg) were calculated
by multiplying the BPT normalized flow (1/kkg) by the achievable
treatment concentrations using the BPT treatment system (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 various waste-
water 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 efflu-
ent limitations for these combined wastewaters are based on the
                               514

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various wastewater sources which actually contribute to the com-
bined flow.  This method accounts for the variety of combinations
of wastewater sources and production processes which may be found
at secondary silver 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 subcategory.

BPT effluent limitations are based on the average of the dis-
charge flow rates for each source; consequently, the treatment
technologies which are currently used by the lowest dischargers
will be the treatment technologies most likely required to meet
BPT guidelines.  Section VII discusses the various treatment
technologies which are currently in place for each wastewater
source.  In most cases, the current treatment technologies
consist of chemical precipitation and sedimentation (lime and
settle technology) and a combination of reuse and recycle to
reduce flow.  Ammonia steam stripping is added to streams
containing treatable concentrations of ammonia.

The overall effectiveness of end-of-pipe treatment for the
removal of wastewater pollutants is improved by the applica-
tion 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.

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

In balancing costs in relation to effluent reduction benefits,
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 BPT.  See Weyerhauser
Company v. Costle, 590 F.2d 1011 (D.C. Cir. 1978).
                               515

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The methodology for calculating pollutant reduction benefits and
plant compliance costs is discussed in Section X.  Tables X-2 and
XII-1 show the estimated pollutant reduction benefits for each
treatment option for direct and indirect dischargers.  Compliance
costs are presented in Table X-3.

BPT OPTION SELECTION

The best practicable tecnology consists of chemical precipita-
tion and sedimentation (lime and settle technology) with ammonia
steam stripping preliminary treatment of wastewaters containing
treatable concentrations of ammonia.  The best practicable
technology is presented schematically in Figure IX-1.  BPT is
equivalent to Option A described in Section X.

Ammonia steam stripping is demonstrated in the nonferrous metals
manufacturing category.  One plant in the secondary aluminum
subcategory, one plant in the secondary lead subcategory, two
plants in the primary columbium-tantlaum subcategory, and four
plants in the primary tungsten subcategory reported steam
stripping in-place.

EPA believes that performance data from the iron and steel
manufacturing category provide a valid measure of this techno-
logy's performance on nonferrous metals manufacturing category
wastewater because raw wastewater concentrations of ammonia are
of the same order of magnitude in the respective raw wastewater
matrices.

Chemical analysis data were collected of raw waste (treatment
influent) and treated waste (treatment effluent) from one coke
plant of the iron and steel mnufacturing category.  A contractor
for EPA, using EPA sampling and chemical analysis protocols,
collected data paired samples in a two-month period.  These data
are the data base for determining the effectiveness of ammonia
steam stripping technology and are contained within the public
record supporting this document.  Ammonia treatment at this coke
plant consisted of two steam stripping columns in series with
steam injected countercurrently to the flow of the wastewater.
A lime reactor for pH adjustment separated the two stripping
columns.

The raw untreated wastewater samples from the coke facility
contained ammonia concentrations of 599, 226, 819, 502, 984, and
797 mg/1.  Raw untreated wastewater samples from the secondary
slver subcategory contained ammonia concentrations of 1,202 and
4,630 mg/1.

The proposed BPT will result in the removal of approximately
27,070 kg/yr of toxic pollutants and 578,350 kg/yr of ammonia
from the estimated raw discharge.  The estimated capital cost of
BPT is $124,000 (1978 dollars) and the estimated annual cost is
$263,000 (1978 dollars).


                               516

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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 concentration .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 14 wastewater sources are discussed below and
summarized in Table IX-1.  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 pro-
duction normalizing parameters, or PNP's, 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.

FILM STRIPPING

The BPT wastewater discharge rate for film stripping is 1,619,000
1/kkg (388,300 gal/ton) of silver produced from film stripping.
Three plants reported wastewater discharges from film stripping,
but the dcp data provided by two plants were insufficient to
calculate discharge rates.  Therefore, the discharge rate from
one plant was used.

FILM STRIPPING WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for film stripping wet air
pollution control is 15,580 1/kkg (3,737 gal/ton) of silver
produced from film stripping, based on 99 percent recycle.  This
rate is allocated only for plants practicing wet air pollution
control for  film stripping.  One plant reported this wastewater,
recycling 99+ percent.  This plant uses the same scrubber to
control air emissions from film stripping and film stripping
precipitation.  Since the BPT limitation is based on 99 percent
recycle, this plant meets the BPT discharge rate.

PRECIPITATION AND FILTRATION OF FILM STRIPPING SOLUTIONS

The BPT wastewater discharge rate for film stripping precipita-
tion and filtration waste streams is 1,851,000 1/kkg (444,000
gal/ton) of silver precipitated.  Of the six plants with this
process, four reported producing wastewater.  The BPT rate is
based on the average discharge rate of two plants, which generate
3,623,000 and 74,170 1/kkg (869,000 and 17,790 gal/ton).  A third
plant reported insufficient data to calculate the discharge rate.
Another plant reported this waste stream as a combination of pho-
tographic and nonphotographic wastewater, therefore this plant
also was omitted from the calculation.  The distribution of
wastewater rates for this waste stream is presented in Section V
(Table V-3).

                               517

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PRECIPITATION AND FILTRATION OF FILM STRIPPING SOLUTIONS WET AIR
POLLUTION CONTROL

The BPT wastewater discharge rate for film stripping precipita-
tion and filtration wet scrubbing is 15,580 1/kkg (3,737 gal/ton)
of silver precipitated, based on 99 percent recycle.  This rate
is allocated only for plants which use wet air pollution control
on  precipitation or filtration processes for film stripping
solutions.  One plant reported this wastewater, recycling 994-
percent.  This plant uses the same scrubber to control air emis-
sions from film stripping and film stripping precipitation.
Since the BPT rate is based on 99 percent recycle, this plant
currently meets the BPT discharge rate.

PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS

The BPT wastewater discharge rate for the precipitation and
filtration of photographic solutions is 854,000 1/kkg (204,850
gal/ton) of silver precipitated.  Of the 15 plants reporting this
process, nine discharge wastewater.  Four plants did not provide
sufficient data to calculate discharge rates.  The discharge
rates for the five other plants range from 50,600 1/kkg (12,100
gal/ton) to 2,890,000 1/kkg (693,000 gal/ton).  Wastewater dis-
charge rates are presented in Table V-4.  The BPT rate is based
on the average of the discharge rates of these five plants. Four
of the five plants reporting this discharge meet the BPT dis-
charge rate.

PRECIPITATION AND FILTRATION OF PHOTOGRAPHIC SOLUTIONS WET AIR
POLLUTION CONTROL

The BPT wastewater discharge rate for precipitation and filtra-
tion of photographic solutions wet air pollution control is
390,000 1/kkg (93,600 gal/ton) of silver precipitated.  This rate
is allocated only to plants having wet air pollution control for
precipitation and filtration of photographic solutions.  Of the
15 plants that have this process, four use wet air pollution con-
trol devices.  Three of the four plants did not report sufficient
production data to calculate a discharge rate for this waste
stream, although sufficient data was reported to determine recy-
cle practices.  One of the four plants achieves zero discharge of
this waste stream through complete recycle, while two plants
practice 99 percent recycle or greater.  The fourth plant recy-
cles 68 percent of its precipitation and filtration of photo-
graphic solutions wet air pollution control water.  Thus,
extensive recycle is possible for this wastewater stream.
However, zero discharge may not be technically feasible unless
(1) a recycle system controls dissolved solids buildup; (2) the
wastewater is evaporated; or (3) this wastewater can be reused in
another production operation that can accept water of this qual-
ity.  Some of these zero-discharge possibilities are site-
specific and, therefore, are not applicable to all secondary
                               518

-------
silver pollutants that generate this wastewater.  Therefore, a
BPT wastewater discharge rate is allocated for precipitation and
filtration of photographic solutions wet air pollution control.
This discharge rate is based on 99 percent recycle of the water
used for precipitation and filtration of photographic solutions
wet air pollution control at the only plant for which a discharge
rate could be determined.  The Agency's general policy is 90 per-
cent recycle, however, the plant that the discharge rate is based
on recycles 99.9 percent of this wastewater, and two other plants
practice 99 and 100 percent recycle.  Thus 99 percent recycle
represents current subcategory practices for precipitation and
filtration of photographic solutions wet air pollution control
water.

ELECTROLYTIC REFINING

The BPT wastewater discharge rate for electrolytic refining is
24,316 1/kkg (5,833 gal/ton) of silver refined.  Of the 20 plants
reporting electrolytic refining operations, 12 produce waste-
water.  Four plants reported insufficient data to calculate dis-
charge rates.  Data from seven plants, with discharge rates rang-
ing from 2,190 1/kkg (525 gal/ton) to 63,221 1/kkg (15,165 gal/
ton), were used to calculate the BPT rate.  Only one plant prac-
tices recycle of this wastewater and achieves zero discharge by
100 percent reuse.  The distribution of wastewater rates for
electrolytic refining is presented in Table V-7.  Five of the
seven discharging plants meet the BPT discharge rate.

FURNACE WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for the furnace air wet scrub-
bing stream is 21,519 1/kkg (5,162 gal/ton) of silver smelted,
roasted, or dried.  This rate is allocated only for plants
practicing wet air pollution control for furnace emissions.
Emissions from furnace operations are controlled by dry or wet
control devices.  Common dry methods involve baghouses or dry
electrostatic precipitators.  Wet devices include packed bed,
spray, and Venturi scrubbers, and wet electrostatic precipi-
tators.  Of the 19 plants reporting furnace air pollution
control, 11 produce waste streams.  Seven of the eleven plants
achieve zero discharge through 100 percent recycle.  Two of the
four plants that discharge this waste stream practice 99 percent
recycle or greater, while one plant uses a once-through opera-
tion.  The remaining plant did not report production or waste-
water flow data for this waste stream.  Water use and discharge
rates are presented in Table V-9.  The BPT discharge rate is
based on 99 percent recycle of the average water use at the three
plants for which discharge rates were determined.  The 99 percent
recycle basis represents current subcategory practices since nine
of the eleven plants that produce this waste stream recycle 99
percent or greater.  Each of those nine plants meets the BPT
discharge rate.
                               519

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CASTING CONTACT COOLING WATER

The BPT wastewater discharge rate for casting contact cooling
water is 12,035 1/kkg (2,887 gal/ton) of silver cast.  Casting is
done in 28 secondary silver plants, 11 plants using contact
cooling water.  One of the ten plants achieves zero discharge of
this waste stream through evaporation.  None of the remaining
nine plants practice recycle or reuse.  Five of the nine plants
reported sufficient data to calculate a discharge rate,.  The
discharge rates from the five reporting plants range from 1,340
1/kkg (320 gal/ton) to 47,416 1/kkg (11,374 gal/ton).  Wastewater
rates are presented in Table V-10.  The BPT discharge rate is the
average discharge rate of these five plants.  Only one of the
five plants does not meet the BPT rate.

CASTING WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for the casting wet scrubber
waste stream is 4,741 1/kkg (1,137 gal/ton) of silver cast.  This
rate is allocated only for plants practicing wet air pollution
control for casting.  Only four plants of the 28 with casting
operations use air pollution control.  Two plants use dry systems
and one recycles 100 percent.  One plant, using 99.7 percent
recycle, reported a discharge rate of 4,741 1/kkg (1,137 gal/ton)
for processing photographic and nonphotographic materials.  The
BPT rate is based on this plant.

LEACHING

The BPT discharge rate for plants with nonphotographic leaching
processes is 2,780 1/kkg (667 gal/ton) of silver produced from
leaching.  Of the 15 plants using this process, 12 discharge
wastewater.  Six plants supplied sufficient information to calcu-
late discharge rates.  Three plants with once-through discharge
had rates ranging from 2,190 1/kkg (525 gal/ton) to 3,611 1/kkg
(866 gal/ton).  The BPT rate is an average of the discharge from
these three plants.  Three other once-through dischargers report-
ed rates ranging from 86,690 1/kkg (20,800 gal/ton) to 20,425,200
1/kkg (4,899,400 gal/ton).  The rates from these three plants
were omitted from the BPT rate calculation because there is no
reason to believe that water is needed in these amounts, in light
of rates from the other plants.  Table V-12 shows the distribu-
tion of wastewater rates for leaching.

LEACHING WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for nonphotographic leaching
wet scrubbing is 142,389 1/kkg  (35,155 gal/ton) of silver
produced from leaching.  This rate is allocated only for plants
using wet air pollution control on leaching processes.  Three
                                520

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plants achieve zero discharge through 100 percent recycle or
reuse.  The recycle in seven additional plants ranges from 65 to
99+ percent, four of those using at least 99 percent.  Some of
the zero discharge possibilities are site-specific and are not
applicable on a nationwide basis.  The BPT discharge rate is
based on the average of five plants with discharge rates ranging
from 450 to 364,700 1/kkg (110 to 37,900 gal/ton).  Insufficient
data to calculate a discharge rate was reported from three of the
eight discharging plants.  Three of the eight discharging plants
meet the BPT rate.  Water use and discharge rates are shown in
Table V-13.

PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS

The BPT wastewater discharge rate for nonphotographic precipita-
tion and filtration is 98,577 1/kkg (23,650 gal/ton) of silver
precipitated.  Of the nine plants using this process, two produce
no wastewater.  Three plants supplied insufficient information to
calculate discharge rates.  Four plants are once-through dis-
chargers with rates ranging from 13,374 1/kkg (3,208 gal/ton) to
2,528,800 1/kkg (606,600 gal/ton).  Table V-14 presents the
wastewater rates for this waste stream.  The BPT discharge rate
is based on the average discharge rate of three of these plants.
The plant with the 2,528,800 1/kkg (606,600 gal/ton) rate was not
considered in the average because this discharge rate is nearly
ten times that of the next highest plant.  Two of the discharging
plants meet the BPT rate.

PRECIPITATION AND FILTRATION OF NONPHOTOGRAPHIC SOLUTIONS WET AIR
POLLUTION CONTROL

The BPT wastewater discharge rate for nonphotographic precipita-
tion and filtration wet scrubbing is 79,931 1/kkg (19,173  gal/
ton) of silver precipitated.  Three plants produce this waste-
stream.  The BPT discharge rate is the average discharge rate of
two of these plants.  One plant did not report sufficient data to
determine its discharge rate.  Wastewater rates are presented in
Table V-15.

REGULATED POLLUTANT PARAMETERS

The raw wastewater concentrations from individual operations and
the subcategory as a whole were examined to select certain pol-
lutant parameters for limitation.  This examination and evalu-
ation was presented in Section VI.  Five pollutants are selected
for limitation under BPT and are listed below:

     120.  copper
     128.  zinc
           ammonia (N)
           total suspended solids (TSS)
           PH
                               521

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EFFLUENT LIMITATIONS

The concentrations achievable by application of the proposed BPT
treatment are explained in Section VII of the General Development
Document and summarized there in Table VII-19.  The achievable
treatment concentrations (both one-day maximum and monthly aver-
age 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 metric ton of
product represent the BPT effluent limitations and are presented
in Table IX-2 for each individual waste stream.
                               522

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                            Table IX-2

  BPT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                          Film Stripping
Pollutant or Pollutant Property
     Maximum  for
     Any  One  Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    3,076,100.0       1,619,000.0
    2,153,270.0        906,640.0
  215,327,000.0      94,873,400.0
   66,379,000.0      32,380,000.0
    Within  the range of  7.5  to 10.0
             at  all  times
             Film Stripping Wet Air Pollution Control
Pollutant or Pollutant Property
    Maximum  for
    Any One  Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
      29,602.0         15,580.0
      20,721.40         8,724.80
    2,072,140.0        912,988.0
      638,780.0        311,600.0
    Within the range of 7.5 to 10.0
             at all times
     Precipitation and Filtration of Film Stripping Solutions
Pollutant or Pollutant Property
    Maximum  for
    Any One  Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
   3,516,900.0      1,851,000.0
   2,461,830.0      1,036,560.0
 246,183,000.0    108,468,600.0
   75,891,000.0     37,020,000.0
   Within the range of 7.5 to 10.0
             at all times
525

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                      Table IX-2 (Continued)

  BPT EFFLUENT LIMITATIONS FOR THE SECONDARY  SILVER SUBCATEGORY
     Precipitation and Filtration of Film Stripping Solutions
                    Wet Air Pollution Control
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
     29,602.0         15,580.0
     20,721.40         8,724.80
  2,072,140.0        912,988.0
    638,780.0        311,600.0
  Within the range of 7.5 to 10.0
           at all times
      Precipitation and Filtration of Photographic Solutions
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
  1,622,600.0        854,000.0
  1,135,820.0        478,240.0
113,582,000.0     50,044,400.0
 35,014,000.0     17,080,000.0
  Within the range of 7.5 to 10.0
           at all times
      Precipitation and Filtration of Photographic Solutions
                    Wet Air Pollution Control
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    741,570.0        390,300.0
    519,099.0        218,568.0
 51,909,900.0     22,871,580.0
 16,002,300.0      7,806,000.0
  Within the range of 7.5 to 10.0
           at all times
                              526

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                      Table IX-2 (Continued)

  BPT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                      Electrolytic Refining
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined
Copper
Zinc
Ammonia  (as N)
Total Suspended Solids
pH
   46,200.40        24,316.0
   32,340.28        13,616.96
3,234,028.0      1,424,917.60
  996,956.0        486,320.0
Within the range of 7.5 to 10.0
         at all times
                Furnace Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of silver roasted, smelted, or dried
   English Units - Ibs/billion Ibs of silver roasted, smelted,
                             or dried
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
   40,886.10        21,519.0
   28,620.27        12,050.64
2,862,027.0      1,261,013.40
  882,279.0        430,380.0
Within the range of 7.5 to 10.0
         at all times
                     Casting Contact Cooling
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
   22,866.50        12,035.0
   16,006.55         6,739.60
1,600,655.0        705,251.0
  493,435.0        240,700.0
Within the range of 7.5 to 10.0
         at all times
                              527

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                      Table IX-2 (Continued)

  BPT EFFLUENT LIMITATIONS FOR THE SECONDARY  SILVER SUBCATEGORY
                Casting Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
     9,007.90         4,741.0
     6,305.53         2,654.96
   630,553.0        277,822.60
   194,381.0         94,820.0
 Within the range of 7.5 to 10.0
          at all times
                             Leaching
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
     5,282.0          2,780.0
     3,697.4          1,556.8
   369,740.0        162,908.0
   113,980.0         55,600.0
 Within the range of 7.5 to 10.0
          at all times
                Leaching Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
   270,539.10       142,389.0
   189,377.37        79,737.84
18,937,737.0      8,343,995.40
 5,837,949.0      2,847,780.0
 Within the range of 7.5 to 10.0
          at all times
                              528

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                      Table IX-2 (Continued)

  BPT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
    Precipitation and Filtration of Nonphotographic Solutions
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
   187,296.30        98,577.0
   131,107.41        55,203.12
13,110,741.0      5,776,612.20
 4,041,657.0      1,971,540.0
 Within the range of 7.5 to 10.0
          at all times
    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
   151,868.90        79,931.0
   106,308.23        44,761.36
10,630,823.0      4,683,956.60
 3,277,171.0      1,598,620.0
 Within the range of 7.5 to 10.0
          at all times
                               529

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                   SECONDARY SILVER SUBCATEGORY

                            SECTION X

        BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE


The effluent limitations which must be achieved by July 1, 1984
are based on the best control and treatment technology used by a
specific point source within the industrial category or subcate-
gory, or by another category where it is readily 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).   At a minimum, 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 feasible process changes or inter-
nal controls, even when not in common practice.

The statutory assessment of BAT considers costs, but does not
require a balancing of costs against effluent reduction benefits
(see Weyerhaeuser v. Costle, 11 ERC 2149 (D.C. Cir. 1978)).
However, in assessing the proposed BAT, the Agency has given
substantial weight to the economic achievability of the tech-
nology.

TECHNICAL APPROACH TO BAT

In pursuing this second round of effluent regulations, 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 four technology
options which could be applied to the secondary silver subcate-
gory 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
                               531

-------
effectiveness achievable with the more sophisticated BAT treat-
ment technology and reductions in the effluent flows allocated to
various waste streams.

In summary, the treatment technologies considered for the second-
ary silver subcategory are:

Option A (Figure X-l) is based on

     o  Ammonia steam stripping preliminary treatment for streams
        containing ammonia at treatable concentrations
     o  Chemical precipitation and sedimentation

Option B (Figure X-2) is based on

     o  In-process flow reduction of casting contact cooling
        water and wet air pollution control water
     o  Ammonia steam stripping preliminary treatment for streams
        containing ammonia at treatable concentrations
     o  Chemical precipitation and sedimentation

Option C (Figure X-3) is based on

     o  In-process flow reduction of casting contact cooling
        water and wet air pollution control water
     o  Ammonia steam stripping preliminary treatment for streams
        containing ammonia at treatable concentrations
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration

Option E (Figure X-4) is based on

     o  In-process flow reduction of casting contact cooling
        water and wet air pollution control water
     o  Ammonia steam stripping preliminary treatment for streams
        containing ammonia at treatable concentrations
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration
     o  Activated carbon adsorption end-of-pipe technology

The four options examined for BAT are discussed in greater detail
below.  The first option considered is the same as the BPT
treatment technology which was presented in the previous section.

OPTION A

Option A for the secondary silver subcategory is equivalent to
the control and treatment technologies which were analyzed for
BPT in Section IX.  The BPT end-of-pipe treatment scheme includes
chemical precipitation, and sedimentation  (lime and settle), with
                                 532

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ammonia steam stripping preliminary treatment of wastewaters
containing treatable concentrations of ammonia (see Figure X-l).
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 silver subcategory achieves lower
pollutant discharge by building upon the Option A (ammonia steam
stripping, chemical precipitation, and sedimentation) treatment
technology.  Flow reduction measures are added to the Option A
treatment scheme (see Figure X-2).  These flow reduction mea-
sures, including in-process changes, result in the elimination of
some wastewater streams and the concentration of pollutants in
other effluents.  As explained in Section VII of the General
Development Document, treatment of a more concentrated effluent
allows achievement of a greater net pollutant removal and intro-
duces the possible economic benefits associated with treating a
lower volume of wastewater.

Option B flow reduction measures are reflected in the BAT waste-
water discharge rates.  Flow reduction has been included in
determining the BAT discharge rates for furnace wet air pollution
control, and casting contact cooling water.  Based on available
data, the Agency did not feel that further flow reduction over
BPT would be feasible for the remaining 12 waste streams in the
secondary silver subcategory.  These waste streams are:

     1.  Film stripping,
     2.  Film stripping wet air pollution control,
     3.  Precipitation and filtration of film stripping solu-
         tions,
     4.  Precipitation and filtration of film stripping solutions
         wet air pollution control,
     5.  Precipitation and filtration of photographic solutions,
     6.  Precipitation and filtration of photographic solutions
         wet air pollution control,
     7.  Electrolytic refining,
     8.  Casting wet air pollution control,
     9.  Leaching,
    10.  Leaching wet air pollution control,
    11.  Precipitation and filtration of nonphotographic solu-
         tions, and
    12.  Precipitation and filtration of nonphotographic solu-
         tions wet air pollution control.

Flow reduction measures used in Option B to reduce process
wastewater generation or discharge rates include the following:
                               533

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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 silver 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
similar wastewaters to assure the success of this technology
using cooling towers or heat exchangers (refer to Section VII of
the General Development Document).  A blowdown or periodic clean-
ing is likely to be needed to prevent a build-up of dissolved and
suspended solids.  EPA has determined that a blowdown of 10 per-
cent of the water applied in a process is adequate.  The BAT
discharge rate allowance (discussed below) provides for this by
requiring a partial recycle of 90 percent (refer to Section VII
of the General Development Document).

Recycle of Water Used in Vet Air Pollution Control

There are seven wastewater sources associated with wet air pollu-
tion control which are regulated under these effluent limita-
tions :

     1.  Film stripping scrubber,
     2.  Precipitation and filtration of film stripping solutions
         scrubber,
     3.  Precipitation and filtration of photographic solutions
         scrubber,
     4.  Furnace scrubber,
     5.  Casting scrubber,
     6.  Leaching scrubber, and
     7.  Precipitation and filtration of nonphotographic
         solutions scrubber.

Table X-l presents the number of plants reporting wastewater with
the wet air pollution control sources listed bove, the number of
plants practicing recycle, and the range of recycle values being
listed.  Complete recycle of furnace scrubber water will be
required for BAT.  The Agency is not requiring  further flow
reduction at BAT for the remaining wet air pollution control
waste streams.

OPTION C

Option C for the secondary silver subcategory consists of all
control and treatment requirements of Option B  (in-process  flow
reduction, ammonia steam stripping, chemical precipitation, and
sedimentation) plus multimedia filtration technology added  at the
end of the Option B treatment scheme (see Figure X-3).  Multi-
media filtration is used to remove suspended solids, including
                               534

-------
precipitates of toxic metals, beyond the concentration attainable
by gravity sedimentation.  The filter suggested is of the grav-
ity, mixed media type, although other filters, such as rapid sand
filters or pressure filters, would perform satisfactorily.

OPTION E

Option E for the secondary silver subcategory consists of all of
the control and treatment technologies of Option C (in-process
flow reduction, ammonia steam stripping, chemical precipitation,
sedimentation, and multimedia filtration) with the addition of
granular activated carbon technology at the end of the Option C
treatment scheme (see Figure X-4).  The activated carbon process
is provided to control the discharge of toxic organics.

INDUSTRY COST AND ENVIRONMENTAL BENEFITS

As one means of evaluating each technology option, EPA developed
estimates of the pollutant reduction benefits and the compliance
costs associated with each option.  The methodologies are
described below.

POLLUTANT REDUCTION BENEFITS

A complete description of the methodology used to calculate the
estimated pollutant reduction, or benefit, achieved by the
application of the various treatment options is presented in Sec-
tion X of the General Development Document.  In short, 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 norm-
alized 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 secondary silver subcategory.  By multi-
plying the total subcategory production for a unit operation by
the corresponding raw waste value, the mass of pollutant gener-
ated for that unit operation was estimated.

The volume of wastewater discharged after the application of each
treatment option was estimated by multiplying the regulatory flow
determined for each unit process by the total subcategory produc-
tion.  The mass of pollutant discharged was then estimated by
multiplyuing 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,
referred to as the benefit, is simply the difference between the
estimated mass of pollutant generated within the subcategory and
the mass of pollutant discharged after application of the treat-
ment option.
                               535

-------
The Agency varied this procedure slightly in computing estimated
BPT discharge in a subcategory where there is an existing BPT
limitation.  In this case, EPA took the mass limits from the BPT
guidelines (for all pollutants limited at BPT) and multiplied
these limits by the total subcategory production (from dcp).
(The assumption is that plants are discharging a volume equal to
their BPT allowance times their production.)  Where pollutants
are not controlled by existing BPT, EPA used the achievable
concentration for the associated technology proposed today, and
multiplied these concentrations by the total end-of-pipe dis-
charge of process wastewater for the subcategory (from dcp).  The
total of both these calculations represents estimated mass load-
ings for the subcategory.

The pollutant reduction benefit estimates for direct dischargers
in the secondary silver subcategory are presented in Table X-2.

COMPLIANCE COSTS

In estimating subcategory-wide compliance costs, the first step
was to develop uniformly-applicable cost curves, relating the
total costs associated with installation and operation of waste-
water treatment technologies to plant process wastewater dis-
charge.  EPA applied these curves on a per plant basis, a plant's
costs (both capital, and operating and maintenance) being deter-
mined 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 cost
of compliance for the subcategory.  These costs were used in
assessing economic achievability.  Table X-3 shows the compliance
costs of the various options for direct dischargers in the
secondary silver subcategory.  Compliance costs for indirect
dischargers are presented in Table XII-2.

BAT OPTION SELECTION

EPA has selected both Option B and Option C as the basis for
alternative BAT effluent limitations for the secondary silver
subcategory due to current adverse structural economic changes
that are not reflected in the Agency's current economic analysis.
These alternative limitations are based on ammonia steam strip-
ping preliminary treatment, lime precipitation and sedimentation,
end-of-pipe technology, and in-process control technologies to
reduce the volume of process wastewater discharged for Option B,
and the addition of multimedia filtration to the end-of-pipe
technology for Option C.  Significant economic changes in the
secondary silver subcategory have occurred due to the tremendous
fluctuation of silver prices over the past few years.  A more
detailed explanation concerning this economic analysis can be
found in Economic Impact Analysis of Proposed Effluent Standards
and Limitations for the Nonferrous Smelting and Refining
Industry, EPA 440/2-82-002.


                               536

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The proposed BAT Alternative A (Option B) increases the removal
of toxic pollutants by approximately 13 kg/yr over the estimated
BPT discharge.  The estimated capital cost of proposed Alter-
native A is $0.184 million (1978 dollars) and the annual cost is
$0.278 million (1978 dollars).  The proposed BAT Alternative B
(Option C) would remove approximately 27,163 kg/yr of toxic
metals and 578,429 kg/yr of ammonia above the raw discharge.
This proposed alternative will result in the removal of an
estimated 92 kg/yr of toxic pollutants above the estimated BPT
discharge.  The estimated capital cost of Alternative B is $0.206
million (1978 dollars) and the annual cost is an estimated $0.345
million (1978 dollars).

Option E was eliminated because the addition of activated carbon
technology is not necessary since toxic organic pollutants are
not selected for limitation in this subcategory.  (Refer to the
end of this section for a discussion on the exclusion of toxic
organic pollutants.)

WASTEWATER DISCHARGE RATES

A BAT discharge rate was calculated for each subdivision based
upon the flows of the existing plants, as determined from analy-
sis 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 differ-
ent for each wastewater source, separate production normalized
discharge rates for each of the 14 wastewater sources were deter-
mined and are summarized in Table X-4.  The discharge rates are
normalized on a production basis by relating the amount of waste-
water generated to the mass of the intermediate product which is
produced by the process associated with the waste stream in ques-
tion.  These production normalizing parameters (PNP) are also
listed in Table X-4.

As discussed previously, the BAT wastewater discharge rate equals
the BPT wastewater discharge rate for 12 of the 14 waste streams
in the secondary silver subcategory.  Based on the available
data, the Agency did not feel that further flow reduction would
be feasible for these wastewater sources.  Wastewater streams for
which BAT discharge rates differ from BPT are discussed below.

FURNACE WET AIR POLLUTION CONTROL

No BAT wastewater discharge rate is allocated for furnace wet air
pollution control.  This rate applies to all air pollution
control of furnace operations and is based on complete recycle of
wastewater.  Since 15 of the 19 plants with furnace air pollution
control do not currently discharge water, the Agency believes
that zero discharge is feasible for all secondary silver furnace
air pollution control.
                               537

-------
CASTING CONTACT COOLING WATER

The BAT wastewater discharge rate is 1,204 1/kkg (289 gal/ton) of
silver cast.  This rate is based on 90 percent recycle of the BPT
disharge rate.  Ten of the 28 plants using casting contact cool-
ing water are once-through dischargers.  Data were available from
five plants to calculate discharge rates.  One other plant
achieves zero discharge by evaporation.  Available discharge
rates range from 1,340 1/kkg (320 gal/ton) to 47,416 1/kkg
(11,374 gal/ton).  The distribution of wastewater rates is pre-
sented in Section V (Table-10).   One of five plants reporting
sufficient dcp information meet the BAT rate.

REGULATED POLLUTANT PARAMETERS

In implementing the terms of the Consent Agreement in NRDC v.
Train, Op. Git., and 33 U.S.C. §1314(b)(2)(A and B) (1975J, 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 pollutant
parameters for consideration for limitation.  This examination
and evaluation, presented in Section VI, concluded that 20
pollutants and pollutant parameters are present in secondary
silver wastewaters at concentrations than can be effectively
reduced by identified treatment technologies.  (Refer to Section
VI, p. 488 )•

However, 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 waste-
waters from a given subcategory, the Agency is proposing effluent
mass limitations only for those pollutants generated in the
greatest quantities as shown by the pollutant reduction benefit
analysis.  The pollutants selected for specific limitation are
listed below:

     120.  copper
     128.  zinc
           ammonia

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 technically justified since the treatable con-
centrations used for lime precipitation and sedimentation tech-
nology are based on optimized tratment for concommitant multiple
                               538

-------
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 tech-
nology removes metals non-preferentially.

The toxic metal pollutants selected for specific limitation in
the secondary silver subcategory to control the discharges of
toxic metal pollutants are copper and zinc.  Ammonia is also
selected for limitation since the methods used to control copper
and zinc are not effective in the control of ammonia.

The following toxic pollutants are excluded from limitation on
the basis that they are effectively controlled by the limitations
developed for lead and zinc:

     114,  antimony
     115.  arsenic
     118.  cadmium
     119.  chromium
     122.  lead
     124.  nickel
     125.  selenium
     126.  silver
     127.  thallium

The secondary silver subcategory generates an estimated 37,800
kg/yr of toxic pollutants, of which only 33 kkg/yr are toxic
organic pollutants.  The Agency believes that the toxic organic
pollutants in this subcategory are present only in trace (demin-
imus quantities) and are neither causing nor likely to cause
toxic effects.  Therefore, the following toxic organic pollutants
are excluded from limitation:

       4.  benzene
       6.  carbon tetrachloride
      10.  1,2-dichloroethane
      29.  1,1-dichloroethylene
      87.  trichloroethylene

Cyanide was present in the secondary silver subcategory in cer-
tain waste streams at concentrations that can be effectively
reduced by identified treatment technologies.  Treatable con-
centrations of cyanide were found in one photographic materials
plant and one nonphotographic materials plant.  Five different
process waste streams were sampled; four contained cyanide at
treatable concentrations, in six of nine samples.  However, when
waste streams were combined for treatment, cyanide was found at a
concentration below that achievable by identified treatment tech-
nology.  This determination was made by comparing the raw
                               539

-------
the raw (untreated) wasteload and treated discharge estimates
presented in the pollutant reduction benefits.  Cyanide is thus
excluded from limitation.

The conventional pollutant parameters TSS and pH will be limited
by the best conventional technology (BCT) effluent limitations.
These effluent limitations and a discussion of BCT are presented
in Section XIII of this supplement.

EFFLUENT LIMITATIONS

The treatable concentrations, achievable by application of the
two BAT technologies (Options B and C) are summarized in Table
VII-19 of the General Development Document.  These treatable con-
centrations (both one day maximum and monthly average) are
multiplied by the BAT normalized discharge flows summarized in
Table X-4 to calculate the mass of pollutants allowed to be dis-
charged per mass of product.  The results of these calculations
in milligrams of pollutant per metric ton of product represent
the BAT effluent limitations for the secondary silver subcate-
gory.  Two sets of BAT effluent limitations, each based on one of
the two alternative BAT options, have been developed for the
secondary silver subcategory.  BAT effluent limitations based on
Option B (ammonia steam stripping, lime precipitation, sedimenta-
tion, and in-process flow reduction) are presented in Table X-5,
while limitations based on Option C (ammonia steam stripping,
lime precipitation, sedimentation, in-process flow redxiction, and
multimedia filtration) are presented in Table X-6.
                               540

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                            Table X-3

            COST OF COMPLIANCE FOR DIRECT DISCHARGERS IN THE
                      SECONDARY SILVER SUBCATEGORY
                         Capital Cost              Annual Cost
Option                  (1978 Dollars)            (1978 Dollars)

  A                         124,000                   263,000

  B                         184,000                   278,000

  C                         206,000                   345,000
                               544

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-------
                            Table X-5

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)


                          Film Stripping

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping  •

Copper                            3,076,100.0      1,619,000.0
Zinc                              2,153,270.0        906,640.0
Ammonia(as N)                   215,327,000.0     94,873,400.0


             Film Stripping Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    AnyOne Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0


     Precipitation and Filtration of Film Stripping Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            3,516,900.0      1,851,000.0
Zinc                              2,461,830.0      1,036,560.0
Ammonia (as N)                  246,183,000.0    108,468,600.0
                               547

-------
                      Table X-5 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)


     Precipitation and Filtration of Film Stripping Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitatcid
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0


      Precipitation and Filtration of Photographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,622,600.0        854,000.0
Zinc                              1,135,820.0        478,240.0
Ammonia (as N)                  113,582,000.0     50,044,400.0


      Precipitation and Filtration of Photographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              741,570.0        390,300.0
Zinc                                519,099.0        218,568.0
Ammonia (as N)                   51,909,900.0     22,871,580.0
                                           at all times
                              548

-------
                      Table X-5 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)


                      Electrolytic Refining

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               46,200.4         24,316.0
Zinc                                 32,340.28        13,616.96
Ammonia (as N)                    3,234,028.0      1,424,917.60


                Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted, or dryed
  English Units - Ibs/billion Ibs of silver roasted, smelted, or
                              dryed

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            0                0


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                2,287.6          1,204.0
Zinc                                  1,601.32           674.24
Ammonia (as N)                      160,132.0         70,554.40
                               549

-------
                      Table X-5 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)


                Casting Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                9,007.8          4,741.0
Zinc                                  6,305.53         2,654.96
Ammonia (as N)                      630,553.0        277,822.60


                             Leaching

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                5,282.0          2,780.0
Zinc                                  3,697.4          1,556.8
Ammonia (as N)                      369,740.0        165,662.20


                Leaching Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              270,539.1        142,389.0
Zinc                                189,377.37        79,737.84
Ammonia (as N)                   18,937,737.0      8,343,995.40
                               550

-------
                      Table X-5 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)


    Precipitation and Filtration of Nonphotographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              187,296.30        98,577.0
Zinc                                131,107.41        55,203.12
Ammonia (as N)                   13,110,741.0      5,776,612.20


    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              151,868.9         79,931.0
Zinc                                106,308.23        44,761.36
Ammonia (as N)                   10,630,823.0      4,683,956.60
                               551

-------
                            Table X-6

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


                          Film Stripping

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                            2,072,320.0        987,590.0
Zinc                              1,651,380.0        679,980.0
Ammonia(as N)                   215,327,000.0     94,873,400.0


             Film Stripping Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0


     Precipitation and Filtration of Film Stripping Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            2,369,280.0      1,129,110.0
Zinc                              1,888,020.0        777,420.0
Ammonia (as N)                  246,183,000.0    108,468,600.0
                               552

-------
                      Table X-6 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


     Precipitation and Filtration of Film Stripping Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0


      Precipitation and Filtration of Photographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property _ Any One Day _ Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,093,120.0        520,940.0
Zinc                                871,080.0        358,680.0
Ammonia (as N)                  113,582,000.0     50,044,400.0


      Precipitation and Filtration of Photographic Solutions
                        Air Pollution Control
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              499,584.0        238,083.0
Zinc                                398,106.0        163,926.0
Ammonia (as N)                   51,909,900.0     22,871,580.0
                              553

-------
                      Table X-6 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


                      Electrolytic Refining

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               31,124.48        14,832.76
Zinc                                 24,802.32        10,212.72
Ammonia (as N)                    3,234,028.0      1,424,917.60


                Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted, or dried
  English Units - Ibs/billion Ibs of silver roasted, smelted, or
                              dried

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            00


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                1,541.12           734.44
Zinc                                  1,228.08           505.68
Ammonia (as N)                      160,132.0         70,554.40
                               554

-------
                      Table X-6 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


                Casting Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                6,068.48         2,892.01
Zinc                                  4,835.82         1,991.22
Ammonia (as N)                      630,553.0        277,822.60


                             Leaching

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                3,558.4          1,695.8
Zinc                                  2,835.6          1,167.6
Ammonia (as N)                      369,740.0        162,908.0


                Leaching Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              182,257.92        86,857.29
Zinc                                145,236.78        59,803.38
Ammonia (as N)                   18,937,737.0      8,343,995.40
                               555

-------
                      Table X-6 (Continued)

  BAT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


    Precipitation and Filtration of Nonphotographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              126,178.56        60,131.97
Zinc                                100,548.54        41,402.34
Ammonia (as N)                   13,110,741.0      5,776,612.20


    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              102,311.68        48,757.91
Zinc                                 81,529.62        33,571.02
Ammonia (as N)                   10,630,823.0      4,683,956.60
                               556

-------
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                   SECONDARY SILVER SUBCATEGORY

                            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  tech-
nology (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-place controls, and end-of-pipe treatment technolo-
gies 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 limita-
tions of regulatory pollutants for NSPS in the secondary silver
subcategory based on the described control technology.

TECHNICAL APPROACH TO BDT

As discussed in the General Development Document, all of the
treatment technology options applicable to a new source were
previously considered for the BAT options.  For this reason, four
options were considered for BDT, all identical to the BAT  options
discussed in Section X.

Treatment and control technologies used for the BDT options are:

OPTION A

     o  Ammonia steam stripping preliminary treatment for  streams
        containing ammonia at treatable concentrations
     o  Chemical pecipitation and sedimentation
OPTION B
        In-process flow reduction of casting contact cooling
        water and wet air pollution control water
        Ammonia steam stripping preliminary treatment for streams
        containing ammonia at treatable concentrations
        Chemical pecipitation and sedimentation
                               561

-------
OPTION C
     o  In-process flow reduction of casting contact cooling
        water and wet air pollution control water
     o  Ammonia steam stripping preliminary treatment for  streams
        containing ammonia at treatable concentrations
     o  Chemical pecipitation and sedimentation
     o  Multimedia-filtration

OPTION E

     o  In-process flow reduction of casting contact cooling
        water and wet air pollution control water
     o  Ammonia steam stripping preliminary treatment for  streams
        containing ammonia at treatable concentrations
     o  Chemical pecipitation and sedimentation
     o  Multimedia-filtration
     o  Activated carbon adsorption end-of-pipe technology

Partial or complete recycle and reuse of wastewater is an  essen-
tial part of the last three options.  Recycle and reuse can
precede or follow end-of-pipe treatment.  A more detailed  dis-
cussion of the treatment options is presented in Section X.

BDT OPTION SELECTION

EPA is proposing that the best available demonstrated technology
for the secondary silver technology be equal to Option C
(in-process flow reduction, ammonia steam stripping preliminary
treatment, lime precipitation, sedimentation, and multimedia
filtration end-of-pipe treatment).  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.  Therefore, NSPS will be based on the Option C technology
only, rather than considering two alternatives (Option B and C;
as in BAT.  Review of the subcategory indicates that no new
demonstrated technologies that improve on BAT exist.

Activated carbon adsorption technology (Option E) was eliminated
because it is not necessary since toxic organic pollutants are
not selected for limitation in this subcategory.  (Refer to the
discussion of exclusion of toxic organic pollutants in Sections
VI and X.)

Dry scrubbing is not demonstrated for controlling emissions from
film stripping, precipitation and filtration of film stripping
solutions, precipitation and filtration of photographic solu-
tions, reduction furnaces, leaching and precipitation and  filtra-
tion.  The nature of these emissions (acidic fumes, hot particu-
late matter) technically precludes the use of dry scrubbers.
                              562

-------
Therefore, EPA is including an allowance  for  these  sources  at
NSPS equivalent to that proposed  for BAT  Option C.   The  Agency
also does not believe that new plants could achieve any  addi-
tional flow reduction beyond that proposed for BAT.

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
limitation under NSPS, in accordance with the rationale  of
Section 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 and are listed in Table XI-1.  The
mass of pollutant allowed to be discharged per mass  of product is
calculated by multiplying the appropriate  effluent  concentration
by the production normalized wastewater discharge flows  (1/kkg).
The treatment concentrations are listed in Table VII-19  of the
General Development Document.  New source performance standards
are presented in Table XI-2.
                               563

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-------
                            Table XI-2

            NSPS FOR THE SECONDARY SILVER SUBCATEGORY
                          Film Stripping
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
  2,072,320.0        987,590.0
  1,651,380.0        679,980.0
215,327,000.0     94,873,400.0
 24,285,000.0     19,428,000.0
    Within range of 7.5 to 10.0
         at all times.
             Film Stripping Wet Air Pollution Control
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
     19,942.40         9,503.80
     15,891.60         6,543.60
  2,072,140.0        912,988.0
     233,700.0       186,960.0
  Within the range of 7.5 to 10.0
          at all times
     Precipitation and Filtration of Film Stripping Solutions
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           .Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia(as N)
Total Suspended Solids
PH
  2,369,280.0      1,129,110.0
  1,888,020.0        777,420.0
246,183,000.0    108,468,600.0
 27,765,000.0     22,212,000.0
   Within the range of 7.5 to
    10.0 at all times.
                               566

-------
                      Table XI-2  (Continued)

            NSPS FOR THE SECONDARY SILVER SUBCATEGORY
     Precipitation and Filtration of Film Stripping Solutions
                    Wet Air Pollution Control
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia  (as N)
Total  Suspended Solids
pH
     19,942.40         9,503.80
     15,891.60         6,543.60
  2,072,140.0        912,988.0
    233,700.0        186,960.0
      Within the range of 7.5 to
         10.0 at all times.
      Precipitation and Filtration of Photographic Solutions
Pollutant or PollutantProperty
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
  1,093,120.0        520,940.0
    871,080.0        358,680.0
113,582,000.0     50,044,400.0
 12,810,000.0     10,248,000.0
      Within the range of 7.5 to
           10.0 at all times.
      Precipitation and Filtration of Photographic Solutions
                    Wet Air Pollution Control
Pollutant or Pollutant Property
   Maximum for
   Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total  Suspended Solids
PH
    499,584.0        238,083.0
    398,106.0        163,926.0
 51,909,900.0     22,871,580.0
  5,854,500.0      4,683,600.0
     Within the range of 7.5 to
       10.0 at all times.
                               567

-------
                      Table XI-2 (Continued)

            NSPS FOR THE SECONDARY SILVER SUBCATEGORY
                      Electrolytic Refining
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
   31,124.48        14,832.76
   24,802.32        10,212.72
3,234,028.0      1,424,917.60
  364,740.0        291,792.0
    Within the range of 7.5 to
      10.0 at all times.
                Furnace Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
    Metric Units - mg/kkg of silver roasted, smelted, or dried
  English Units - Ibs/billion Ibs of silver roasted, smelted, or
                              dried
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
        0
        0
        0
        0
         0
         0
         0
         0
     Within the range of 7,
        10.0 at all times.
           5 to
                     Casting Contact Cooling
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
    1,541.12           734.44
    1,228.08           505.68
  160,132.0         70,554.40
   18,060.0         14,448.0
     Within the range of 7.5 to
      10.0 at all times.
                               568

-------
                      Table XI-2  (Continued)

            NSPS FOR THE SECONDARY SILVER SUBCATEGORY
                Casting Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast
Copper
Zinc
Ammonia  (as N)
Total  Suspended  Solids
pH
     6,068.48         2,892.01
     4,835.82         1,991.22
   630,553.0        277,822.60
    71,115.0         56,892.0
       Within the range of 7.5
       to 10.0 at all times.
                             Leaching
Pollutant or Pollutant Property
  Maximum for
  AnyOne Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
     3,558.4          1,695.8
     2,835.6          1,167.6
   369,740.0        162,908.0
    41,700.0         33,360.0
       Within the range of 7.5
       to 10.0 at all times.
                Leaching Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
pH
   182,257.92        86,857.29
   145,236.78        59,803.38
18,937,737.0      8,343,995.40
 2,135,835.0      1,708,668.0
 Within the range of 7.5 to 10.0
          at all times
                               569

-------
                      Table XI-2 (Continued)

            NSPS FOR THE SECONDARY SILVER SUBCATEGORY
    Precipitation and Filtration of Nonphotographlc Solutions
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia (as N)
Total Suspended Solids
PH
   126,178.56        60,131.97
   100,548.54        41,402.34
13,110,741.0      5,776,612.20
 1,478,655.0      1,182,924.0
 Within the range of 7.5 to 10.0
          at all times
    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control
Pollutant or Pollutant Property
  Maximum for
  Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated
Copper
Zinc
Ammonia(as N)
Total Suspended Solids
PH
   102,311.68        48,757.91
    81,529.62        33,571.02
10,630,823.0      4,683,956.60
 1,198,965.0        959,172.0
 Within the range of 7.5 to 10.0
          at all times
                               570

-------
                   SECONDARY SILVER SUBCATEGORY

                           SECTION XII

                      PRETREATMENT STANDARDS


Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources (PSES), which roust be achieved
within three years of promulgation.  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 heavy 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 facili-
ties, 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 instal-
lation.  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 silver subcategory.  Pretreatment
standards for regulated pollutants are presented based on the
selected control and treatment technologies.

TECHNICAL APPROACH TO PRETREATMENT

Before proposing 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 percentage
removed nationwide by well-operated POTW meeting secondary
treatment requirements, is less than the percentage removed by
direct dischargers complying with BAT effluent limitations
guidelines for that pollutant.  (See generally, 46 FR at 9415-16
(January 28, 1981).)

This definition of pass through satisfies two competing objec-
tives set by Congress:  (1) that standards for indirect dis-
chargers be equivalent to standards for direct dischargers, while


                               571

-------
at the same time, (2) that the treatment capability and perfor-
mance of the POTW be recognized and taken into account in regu-
lating 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 pollu-
tants in the POTW effluent to lower concentrations due to the
addition of large amounts of non-industrial wastewater.

PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES

Options for pretreatmen,t of wastewaters are based on increasing
the effectiveness of end-of-pipe treatment technologies.  All
in-plant changes and applicable end-of-pipe treatment processes
have been discussed previously in Sections X and XI.  The options
for PSES and PSNS, therefore, are the same as the BAT options
discussed in Section X.

A description of each option is presented in Section X, while a
more detailed discussion, including pollutants controlled by each
treatment process and achievable treatment concentration for each
option, is presented in Section VII of the General Development
Document.

Treatment technology used for the PSES and PSNS options are:

OPTION A

     o  Ammonia steam stripping preliminary treatment for streams
        containing ammonia at treatable concentrations
     o  Chemical pecipitation and sedimentation
OPTION B
        In-process flow reduction of casting contact cooling
        water and wet air pollution control water
        Ammonia steam stripping preliminary treatment for streams
        containing ammonia at treatable concentrations
        Chemical pecipitation and sedimentation
OPTION C
     o  In-process flow reduction of casting contact cooling
        water and wet air pollution control water
     o  Ammonia steam stripping preliminary treatment for  streams
        containing ammonia at treatable concentrations
     o  Chemical pecipitation and sedimentation
     o  Multimedia-filtration
                               572

-------
OPTION E

     o  In-process  flow reduction  of  casting  contact  cooling
        water and wet air pollution control water
     o  Ammonia steam stripping  preliminary treatment for  streams
        containing  ammonia at  treatable  concentrations
     o  Chemical pecipitation  and  sedimentation
     o  Multimedia-filtration
     o  Activated carbon adsorption end-of-pipe  technology

INDUSTRY COST AND ENVIRONMENTAL  BENEFITS

The industry cost and environmental benefits  of  each  treatment
option were used to determine  the  most cost-effective option.
The methodology applied in calculating pollutant reduction
benefits and plant  compliance  costs is discussed in Section  X.
Table XII-1 shows the estimated  pollutant  reduction benefits for
direct and indirect dischargers, while compliance  costs  for
indirect discharges are presented  in  Table XII-2.

PSES OPTION SELECTION

EPA has selected in-process  flow reduction, ammonia steam  strip-
ping preliminary treatment,  lime precipitation,  and sedimentation
(Option B) and in-process flow reduction,  ammonia  steam  stripping
preliminary treatment, chemical  precipitation, sedimentation, and
multimedia filtration (Option  C) as alternative  pretreatment
standards for existing sources for this  subcategory.   This selec-
tion follows from the rationale  used  in  selecting  alternative
options as the basis for BAT.  (Refer to Section X.)

The proposed PSES Alternative  A  (Option  B) would remove  approxi-
mately 9,731 kg/yr  of toxic  pollutants over the  estimated  raw
discharge and an estimated 149,300 kg/yr of ammonia.   The  esti-
mated capital cost  of proposed Alternative A  is  $1.03 million
(1978 dollars) and  the annual  cost is $0.958  million  (1978
dollars).  The proposed PSES Alternative B (Option C) would
remove approximately 9,792 kg/yr of toxic  pollutants  and 149,300
kg/yr of ammonia above the estimated  raw discharge.   The esti-
mated capital cost of Alternative  B is $1.14  million  (1978
dollars) and the annual cost is  an estimated  $1.07 million (1978
dollars).

Activated carbon adsorption  technology (Option E) was  eliminated
because it is not necessary  since  toxic  organic  pollutants are
not selected for limitation  in this subcategory.   (Refer to  the
discussion of selection of pollutants for  limitation  in  Section
X.)
                               573

-------
PSNS OPTION SELECTION

EPA has selected in-process flow reduction, ammonia steam  strip-
ping preliminary treatment, lime precipitation, sedimentation,
and multimedia filtration  (Option C) as the technology basis  for
PSNS.  The Agency recognizes that new sources have the opportu-
nity 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.  Therefore, PSNS will be based
on the Option C technology only, rather than considering two
alternatives (Option B and C) as in PSES.

EPA has not identified any demonstrated technology that provides
more efficient pollutant removal than PSNS technology.  No addi-
tional flow reduction for new sources is feasible because dry
scrubbing is not demonstrated for controlling emissions from  film
stripping, precipitation and filtration of photographic solu-
tions, reduction furnaces, leaching and precipitation and  filtra-
tion.  The nature of these emissions (acidic fumes, hot particu-
late matter) technically precludes the use of dry scrubbers.
Activated carbon adsorption technology (Option E) was eliminated
because it is not necessary since toxic organic pollutants are
not selected for limitation in this subcategorgy (see Section X).
Since PSNS does not include any additional costs compared to
NSPS, the Agency does not believe PSNS will be a barrier to entry
for new facilities.

REGULATED POLLUTANT PARAMETERS

Pollutants and pollutant parameters selected for limitation for
PSES and PSNS, in accordance with the rationale of Section VI and
X, are identical to those selected for limitation for BAT.  EPA
is proposing PSNS for copper, zinc, and ammonia to prevent pass-
through.  The conventional pollutants, TSS and pH, are not
limited under PSES and PSNS because they are effectively con-
trolled by POTW.

PRETREATMENT STANDARDS

The PSES and PSNS discharge flows are identical to the BAT dis-
charge flows for all processes.  These discharge flows are listed
in Table XII-3.  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-19 of the General Development Docu-
ment.  Pretreatment standards for existing and new sources, as
determined from the above procedure, are shown in Tables XII-4
through XII-6 for each waste stream.
                                574

-------
Mass-based standards are proposed for the secondary silver  sub-
category to ensure that the standards are achieved by means of
pollutant removal rather than by dilution.  They are particularly
important since the standards are based upon flow reduction.
Pollutant limitations associated with flow reduction cannot be
measured any way but as a reduction of mass discharged.  Mass-
based PSES without alternative concentration-based standards are
proposed in this subcategory, although the flow reduction for the
entire subcategory is not great.  However, several plants grossly
exceed the flow basis of PSES.  Mass-based standards are needed
to ensure that these plants reduce their water usage.  Mass-based
PSNS are proposed in this subcategory because PSNS for secondary
silver is based on 90 percent flow reduction of raw wastewater by
recycle, and new plants would lack incentive to achieve these
reductions without a mass-based standard.
                               575

-------
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-------
                         Table XII-2

         COST OF COMPLIANCE FOR INDIRECT DISCHARGERS
             IN THE SECONDARY SILVER SUBCATEGORY
                       Capital Cost            Annual Cost
Option                (1978 Dollars)          (1978 Dollars)

  A                        784,000                 907,000

  B                      1,030,000                 958,000

  C                      1,140,000               1,070,000
                             578

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-------
                           Table XII-4

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                        (BASED ON OPTION B)


                          Film Stripping

                                   Maximum  for      Maximum  for
Pollutant or Pollutant  Property    Any One  Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                            3,076,100.0      1,619,000.0
Zinc                              2,153,270.0        906,640.0
Ammonia(as N)                   215,327,000.0     94,873,400.0


             Film Stripping Wet Air Pollution Control

                                   Maximum  for      Maximum  for
Pollutant or Pollutant  Property    Any One  Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0


     Precipitation and  Filtration of Film Stripping Solutions

                                   Maximum  for      Maximum  for
Pollutant or Pollutant  Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            3,516,900.0      1,851,000.0
Zinc                              2,461,830.0      1,036,560.0
Ammonia (as N)                  246,183,000.0    108,468,600.0
                               581

-------
                     Table XII-4 (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)
     Precipitation and Filtration of Film Stripping Solutions
                        Air Pollution Control
                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               29,602.0         15,580.0
Zinc                                 20,721.0          8,724.8
Ammonia (as N)                    2,072,140.0        912,988.0


      Precipitation and Filtration of Photographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,622,600.0        854,000.0
Zinc                              1,135,820.0        478,240.0
Ammonia (as N)                  113,582,000.0     50,044,400.0


      Precipitation and Filtration of Photographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property _ Any One Day _ Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              741,570.0        390,300.0
Zinc                                519,099.0        218,568.0
Ammonia (as N)                   51,909,900.0     22,871,580.0
                               582

-------
                     Table XII-4  (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                        (BASED ON  OPTION B)
                      Electrolytic Refining

                                   Maximum for      Maximum  ifor
Pollutant or Pollutant Property    Any One Day    Monthly Avera \

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               46,200.4         24,316.0
Zinc                                 32,340.28        13,616.96
Ammonia (as N)                    3,234,028.0      1,424,917.£C


                Furnace Wet Air Pollution Control

                                   Maximum for      Maximum  £o,
Pollutant or Pollutant Property    Any One Day    Monthly Averas

    Metric Units - mg/kkg of silver roasted, smelted, or dryed
  English Units - Ibs/billion Ibs of silver roasted, smelted, c_-
                              dryed

Copper                                    0                C
Zinc                                      0                G
Ammonia (as N)                            0                0
                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Aver ?

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                2,287.6          1,204-0
Zinc                                  1,601.32           674.24
Ammonia (as N)                      160,132.0         70,554.40
                               583

-------
                     Table XII-4 (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)


                Casting Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                9,007.8          4,741.0
Zinc                                  6,305.53         2,654.96
Ammonia (as N)                      630,553.0        2:77,822.60


                             Leaching

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                5,282.0          2,780.0
Zinc                                  3,697.4          1,556.8
Ammonia (as N)                      369,740.0        165,662.20


                Leaching Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              270,539.1        142,389.0
Zinc                                189,377.37 ,       79,737.84
Ammonia (as N)                   18,937,737.0      8,343,995.40
                               584

-------
                     Table XII-4 (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION B)


    Precipitation and Filtration of Nonphotographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              187,296.30        98,577.0
Zinc                                131,107.41        55,203.12
Ammonia (as N)                   13,110,741.0      5,776,612.20


    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              151,868.9         79,931.0
Zinc                                106,308.23        44,761.36
Ammonia (as N)                   10,630,823.0      4,683,956.60
                               585

-------
                           Table XII-5

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


                          Film Stripping

                                   Maximum  for      Maximum  for
reViLitafit or Pollutant Property    Any One  Day    Monthly Average

   Matric Units - mg/kkg of silver produced  from  film  stripping
     English Units - Ibs/billion Ibs of silver produced  from
                          film stripping

.cooer                            2,072,320.0        987,590.0
T.Yc                              1,651,380.0        679,980.0
.-iLffioriia  (as N)                  215,327,000.0     94,873,400.0


             Film Stripping Wet Air Pollution Control

                                   Maximum  for      Maximum  for
 ' 'JM^A1"1?—°~Pollutant Property    Any One  Day    Monthly Average

   Metric Units - rcg/kkg of silver produced  from  film  stripping
     Eaglish Units - Ibs/billion Ibs of silver produced  from
                          film stripping

0.- nver                               19,942.40         9,503.80
:: -c                                 15,891.60         6,543.60
Auffioala  (as N)                    2,072,140.0        912,988.0


     Prf.cipltatlon and Filtration of Film Stripping Solutions

                                   Maximum  for      Maximum  for
l'£-l^tartt or Pollutant Property	Any One  Day	Monthly Average

           Metric Units - mg/kkg of silver  precipitated
      English Units - Ibs/billion Ibs of silver precipitated

.'Jcwer                            2,369,280.0      1,129,110.0
Zinc                              1,888,020.0        777,420.0
    aia  (as N)                  246,183,000.0     108,468,600.0
                                586

-------
                     Table XII-5  (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                        (BASED ON OPTION C)


     Precipitation and Filtration of Film Stripping Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia  (as N)                    2,072,140.0        912,988.0


      Precipitation and Filtration of Photographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,093,120.0        520,940.0
Zinc                                871,080.0        358,680.0
Ammonia  (as N)                  113,582,000.0     50,044,400.0


      Precipitation and Filtration of Photographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              499,584.0        238,083.0
Zinc                                398,106.0        163,926.0
Ammonia  (as N)                   51,909,900.0     22,871,580.0
                               587

-------
                     Table XII-5 (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


                      Electrolytic Refining

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               31,124.48        14,832.76
Zinc                                 24,802.32        10,212.72
Ammonia (as N)                    3,234,028.0      1,424,917.60


                Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted, or dried
  English Units - Ibs/billion Ibs of silver roasted, smelted or
                              dried

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            00


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                1,541.12           734.44
Zinc                                  1,228.08           505.68
Ammonia (as N)                      160,132.0         70,554.40
                               588

-------
                     Table XI1-5  (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                        (BASED ON  OPTION C)


                Casting Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                6,068.48         2,892.01
Zinc                                  4,835.82         1,991.22
Ammonia (as N)                      630,553.0        277,822.60


                             Leaching

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                3,558.40         1,695.80
Zinc                                  2,835.60         1,167.60
Ammonia (as N)                      369,740.0        162,908.0


                Leaching Wet Air  Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              182,257.92        86,857.29
Zinc                                145,236.78        59,803.38
Ammonia (as N)                    18,937,737.0      8,343,995.40
                                589

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                     Table XII-5 (Continued)

            PSES FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


    Precipitation and Filtration of Nonphotographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              126,178.56        60,131.97
Zinc                                100,548.54        41,402.34
Ammonia (as N)                   13,110,741.0      5,776,612.20


    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              102,311.68        48,757.91
Zinc                                 81,529.62        33,571.02
Ammonia(as N)                    10,630,823.0      4,683,956.60
                               590

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                           Table XII-6

            PSNS FOR THE SECONDARY SILVER SUBCATEGORY
                        (BASED ON OPTION C)


                          Film Stripping

                                   Maximum for      Maximum for
Pollutant or Pollutant  Property	Any One Day	Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                            2,072,320.0        987,590.0
Zinc                              1,651,380.0        679,980.0
Ammonia  (as N)                  215,327,000.0     94,873,400.0


             Film Stripping Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant  Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia  (as N)                    2,072,140.0        912,988.0


     Precipitation and Filtration of Film Stripping Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            2,369,280.0      1,129,110.0
Zinc                              1,888,020.0        777,420.0
Ammonia  (as N)                  246,183,000.0    108,468,600.0
                               591

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                     Table XII-6 (Continued)

            PSNS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)
     Precipitation and Filtration of Film Stripping Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                               19,942.40         9,503.80
Zinc                                 15,891.60         6,543.60
Ammonia (as N)                    2,072,140.0        912,988.0


      Precipitation and Filtration of Photographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                            1,093,120.0        520,940.0
Zinc                                871,080.0        358,680.0
Ammonia  (as N)                 113,582,000.0     50,044,400.0


      Precipitation and Filtration of Photographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              499,584.0        238,083.0
Zinc                                398,106.0        163,926.0
Ammonia (as N)                   51,909,900.0     22,871,580.0
                               592

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                     Table XII-6  (Continued)

            PSNS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


                      Electrolytic Refining

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - Ibs/billion Ibs of silver refined

Copper                               31,124.48        14,832.76
Zinc                                 24,802.32        10,212.72
Ammonia (as N)                    3,234,028.0      1,424,917.60

                Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted, or dried
    English Units - Ibs/billion of silver roasted, smelted, or
                              dried

Copper                                    0                0
Zinc                                      0                0
Ammonia (as N)                            00

                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                1,541.12           734.44
Zinc                                  1,228.08           505.68
Ammonia (as N)                      160,132.0         70,554.40
                               593

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                     Table XII-6 (Continued)

            PSNS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


                Casting Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Copper                                6,068.48         2,892.01
Zinc                                  4,835.82         1,991.22
Ammonia (as N)                      630,553.0        277,822.60


                             Leaching

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                                3,558.40         1,695.80
Zinc                                  2,835.60         1,167.60
Ammonia (as N)                      369,740.0        162,908.0


                Leaching Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from leaching

Copper                              182,257.92        86,857.29
Zinc                                145,236.78        59,803.38
Ammonia (as N)                   18,937,737.0      8,343,995.40
                               594

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                     Table XII-6 (Continued)

            PSNS FOR THE SECONDARY SILVER SUBCATEGORY
                       (BASED ON OPTION C)


    Precipitation and Filtration of Nonphotographlc Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              126,178.56        60,131.97
Zinc                                100,548.54        41,402.34
Ammonia (as N)                   13,110,741.0      5,776,612.20


    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or PollutantProperty    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Copper                              102,311.68        48,757.91
Zinc                                 81,529.62        33,571.02
Ammonia (as N)                   10,630,823.0      4,683,956.60
                               595

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                   SECONDARY SILVER SUBCATEGORY

                           SECTION XIII

          BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
The 1977 amendments to the Clean Water Act added Section
301(b)(2)(E), establishing "best conventional pollutant control
technology" (BCT) for discharge of conventional pollutants from
existing industrial point sources.  Biochemical oxygen-demanding
pollutants (BODs),  total suspended solids (TSS), fecal coli-
form, oil and grease (O&G), and pH have been designated as
conventional pollutants (see 44 FR 44501).

BCT is not an additional limitation, but replaces BAT for the
control of conventional pollutants.  In addition to the other
factors specified in Section 304(b)(4)(B), the Act requires that
limitations for conventional pollutants be assessed in light of a
two-part cost-reasonableness test.  On October 29, 1982, the
Agency proposed a revised methodology for carrying out BCT analy-
ses (47 FR 49176).   The purpose of the proposal was to correct
errors in the BCT methodology originally established in 1977.

Part 1 of the proposed BCT test requires that the cost and level
of reduction of conventional pollutants by industrial dischargers
be compared with the cost and level of reduction to remove the
same type of pollutants by publicly-owned treatment works (POTW).
The POTW comparison figure has been calculated by evaluating the
change in costs and removals between secondary treatment (30 mg/1
BOD and 30 mg/1 TSS) and advanced secondary treatment (10 mg/1
BOD and 10 mg/1 TSS).  The difference in cost is divided by the
difference in pounds of conventional pollutants removed, result-
ing in an estimate of the "dollars per pound" of pollutant
removed, that is used as a benchmark value.  The proposed POTW
test benchmark is $0.30 per pound (1978 dollars).

Part 2 of the BCT test requires that the cost and level of reduc-
tion of conventional pollutants by industrial dischargers be
evaluated internally to the industry.  In order to develop a
benchmark that assesses a reasonable relationship between cost
and removal, EPA has developed an industry cost ratio which
compares the dollar per pound of conventional po.llutant removed
in going from primary to secondary treatment levels with that of
going from secondary to more advanced treatment levels.  The
basis of costs for the calculation of this ratio are the costs
incurred by a POTW.  EPA used these costs because:  they reflect
the treatment technologies most commonly used to remove conven-
tional pollutants from wastewater; the treatment levels associ-
ated with them compare readily to the levels considered for
industrial dischargers; and the costs are the most reliable for
the treatment levels under consideration.  The proposed industry
                               597

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subcategory benchmark is 1.42.  If the industry figure for a sub-
category is lower than 1.43, the subcategory passes the BCT test.

The Agency usually considers two conventional pollutants in the
cost test, TSS and an oxygen-demanding pollutant.  Although both
oil and grease and BOD5 are considered to be oxygen-demanding
substances by EPA (see 44 FR 50733),  only one can be selected in
the cost analysis to conform to procedures used to develop POTW
costs.  Oil and grease is used rather than BOD5 in the cost an-
alysis performed for nonferrous metals manufacturing waste
streams due to the common use of oils in casting operations in
this industry.

BPT is the base for evaluating limitations on conventional
pollutants (i.e., it is assumed that BPT is already in place).
The test evaluates the cost and removals associated with treat-
ment and controls in addition to that specified as BPT.

If the conventional pollutant removal cost of the candidate BCT
is less than the POTW cost, Part 1 of the cost-reasonableness
test is passed and Part 2 (the internal industry test) of the
cost-reasonableness test must be performed.  If the internal
industry test is passed, then a BCT limitation is promulgated
equivalent to the candidate BCT level.  If all candidate BCT
technologies fail both parts of the cost-reasonableness test, the
BCT requirements for conventional pollutants are equal to BPT.

The BCT test was performed for the proposed BAT technology basis
of in-process flow reduction, ammonia steam stripping preliminary
treatment, and lime precipitation, sedimentation, and multimedia
filtration end-of-pipe technology.  The secondary silver subcate-
gory failed Part 1 of the test with a calculated cost of $4.09
per pound (1978 dollars) of removal of conventional pollutants
using BAT technology.  The intermediate flow reduction option
(in-process flow reduction, ammonia steam stripping preliminary
treatment, and lime precipitation and sedimentation end-of-pipe
treatment) was also examined, but it too failed with a cost of
$1,700 per pound (1978 dollars) of conventional pollutants
removal.
                                598

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                           Table XIII-1

  BCT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGOR?


                          Film Stripping

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Total Suspended Solids           66,379,000.0     32,380,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


             Film Stripping Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of silver produced from film stripping
     English Units - Ibs/billion Ibs of silver produced from
                          film stripping

Total Suspended Solids              638,780.0        311,600.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


     Precipitation and Filtration of Film Stripping Solutions

                                 Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids           75,891,000.0     37,020,000.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                              599

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                     Table XIII-1  (Continued)

  BCT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY
     Precipitation and Filtration of Film Stripping Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day   Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids              638,780.0         311,600.0
pH                                Within the range  of 7.5 to 10.0
                                           at  all times
      Precipitation and Filtration of Photographic  Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day   Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids           35,014,000.0     17,080,000.0
pH                                Within the range  of 7.5 to  10.0
                                           at  all times
      Precipitation and Filtration of Photographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids           16,002,300.0      7,806,000.0
pH                                Within the range of 7.5 to  10.0
                                           at all times
                              600

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                     Table XIII-1 (Continued)

  BCT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY


                      Electrolytic Refining

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

             Metric Units - mg/kkg of silver refined
        English Units - H^s/billion Ibs of silver refined

Total Suspended Solids              996,956.0        486,320.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


                Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of silver roasted, smelted, or dried
    English Units - Ibs/billion Ibs of silver roasted,  smelted
                             or dried

Total Suspended Solids              882,279.0        430,380.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Total Suspended Solids              493,435.0        240,700.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                              601

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                     Table XIII-1  (Continued)

  BCT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY


                Casting Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

               Metric Units - mg/kkg of silver cast
          English Units - Ibs/billion Ibs of silver cast

Total Suspended Solids              194,381.0          94,820.0
pH                                Within the range of 7.5 to 10.0
                                           at  all times


                             Leaching

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from  leaching

Total Suspended Solids              113,980.0          55,600.0
pH                                Within the range of 7.5 to 10.0
                                           at  all times


                Leaching Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of silver produced from leaching
English Units - Ibs/billion Ibs of silver produced from  leaching

Total Suspended Solids            5,837,949.0       2,847,780.0
pH                                Within the range of 7.5 to 10.0
                                           at  all times
                              602

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                     Table XIII-1 (Continued)

  BCT EFFLUENT LIMITATIONS FOR THE SECONDARY SILVER SUBCATEGORY


    Precipitation and Filtration of Nonphotographic Solutions

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids            4,041,657.0      1,971,540.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
    Precipitation and Filtration of Nonphotographic Solutions
                    Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of silver precipitated
      English Units - Ibs/billion Ibs of silver precipitated

Total Suspended Solids            3,277,171.0      1,598,620.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                              603

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                   SECONDARY COPPER SUBCATEGORY

                            SECTION I

                     SUMMARY AND CONCLUSIONS
On February 27, 1975, EPA promulgated technology-based effluent
limitations guidelines for the secondary copper subcategory of
the Nonferrous Metals Manufacturing Point Source category.  Best
practicable control technology currently available  (BPT) and best
available technology economically achievable  (BAT)  effluent limi-
tations were established.  Under these limitations, the discharge
of process wastewater pollutants into navigable waters was
prohibited with the following exceptions.  For the  BPT effluent
limitations, discharge without limitation was allowed for a vol-
ume of process wastewater equivalent to the volume  of stormwater
in excess of that attributable to a 10-year,  24-hour rainfall
event falling on a wastewater cooling impoundment.  The BAT
effluent limitations also contain the stormwater exemption except
the storm is a 25-year, 24-hour rainfall event.  For both the BPT
and BAT effluent limitations, discharge, subject to concentra-
tion-based limitations, was allowed for a volume of process
wastewater equal to the net monthly precipitation on the waste-
water cooling impoundment.

On December 15, 1976, EPA promulgated pretreatment  standards for
existing sources (PSES) for the secondary copper subcategory.
These standards allowed a continuous discharge of process waste-
water to publicly owned treatment works (POTW) subject to concen-
tration-based standards for oil and grease, copper, and cadmium.
PSES is based on lime precipitation and sedimentation treatment
technology.

Since 1974, implementation of the technology-based  effluent limi-
tations and standards has been guided by a series of settlement
agreements into which EPA entered with several environmental
groups, the latest of which occurred in 1979.  NRDC v. Costie, 12
ERG 1833 (D.D.C. 1979), aff'd and remd'd, EOF v. Costle, 14 ERG
2161 (1980).  Under the settlement agreements, EPA was required
to develop BAT limitations and pretreatment and new source per-
formance standards for 65 classes of pollutants discharged from
specific industrial point source categories,  including primary
copper smelting and electrolytic copper refining.  The list of 65
classes was subsequently expanded to a list of 129  specific toxic
pollutants.

Congress amended the Clean Water Act in 1977  to encompass many of
the provisions of the earlier settlement agreements, including
the list of 65 classes of pollutants.  As a result of the settle-
ment agreements and the Clean Water Act Amendments, EPA undertook
                               605

-------
an extensive effort to develop technology-based BAT limitations
and pretreatment and new source performance standards for the
toxic pollutants.

EPA is proposing modifications to BAT, and PSES for the secondary
copper subcategory pursuant to the provisions of the Settlement
Agreement and Sections 301, 304, 306, and 307 of the Clean Water
Act and its amendments.  In addition, EPA is proposing NSPS and
PSNS for this subcategory.  This supplement provides a compila-
tion and analysis of the background material used to develop
these effluent limitations and standards.

The secondary copper subcategory is comprised of 31 plants.  Of
the 31 plants, five discharge directly to rivers, lakes, or
streams; six discharge to publicly owned treatment works (POTW);
and 20 achieve zero discharge of process wastewater pollutants.

EPA first studied the secondary copper subcategory to determine
whether differences in raw materials, final products, manufac-
turing processes, equipment, age and size of plants, and 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 waste-
waters, including toxic pollutants.

EPA also identified several distinct control and treatment
technologies (both in-plant and end-of-pipe) applicable to the
secondary copper subcategory.  The Agency analyzed both histori-
cal and newly generated data on the performance of these tech-
nologies.  EPA also studied various flow reduction and complete
recycle techniques reported in the data collection portfolios
(dcp) and plant visits.

Based on consideration of the above factors, EPA identified vari-
ous control and treatment technologies which formed the basis for
BAT and selected control and treatment appropriate for each set
of standards and limitations.  The mass limitations and standards
for BPT, BAT, NSPS, PSNS, and BCT are presented in Section II.

For BAT, the Agency is proposing to eliminate the discharge
allowance for net monthly precipitation on cooling impoundments.
The BAT effluent limitations will still allow a discharge for
stormwater resulting from the 25-year, 24-hour rainfall event.
EPA is eliminating the net precipitation dishcarge for BAT
because these guidelines are based on cooling impoundments rather
than settling and evaporative impoundments.  Cooling impoundments
require much smaller surface areas than the settling and evapora-
tive impoundments for which the net precipitation discharge was
                               606

-------
allowed.  Cooling towers were  costed  for  BAT  in  the  1975  rulemak-
ing when a plant had insufficient existing  cooling impoundment
capacity or cooling impoundments were  not feasible due  to space
limitations.  EPA believes that secondary copper plants can
accommodate the small volume of water  resulting  from net  precip-
itation on cooling impoundments.  There is  no cost associated
with the proposed BAT effluent limitations.

For NSPS, EPA is proposing zero discharge of  process  wastewater
pollutants.  In selecting NSPS, EPA recognizes that  new plants
have the opportunity to implement the  best  and most  efficient
manufacturing processes and treatment  technology.  EPA believes
that new sources can be constructed with  cooling towers exclu-
sively rather than cooling impoundments.  The Agency  is thus
eliminating the allowance for  catastrophic  stormwater discharge
provided at BAT.

For PSES, EPA is proposing zero discharge of  process  wastewater
pollutants to POTW.  The technology bases for the proposed PSES
is lime precipitation and sedimentation with  cooling  towers and
holding tanks to achieve zero  discharge of  process wastewater
pollutants.  EPA believes that the costs associated  installation
and operation of cooling towers and holding tanks for indirect
dischargers will be insignificant.  In addition, costs for cool-
ing towers and holding tanks were considered  during  the 1976 PSES
rulemaking.  At that time EPA concluded that  the additional cost
was not significant.

For PSNS, EPA is also proposing zero discharge of process waste-
water pollutants.
                               607

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                   SECONDARY COPPER  SUBCATEGORY

                            SECTION  II

                         RECOMMENDATIONS
1.   The secondary copper subcategory has been divided  into
     seven subdivisions for the purpose of effluent  limitations
     and standards.  These subdivisions are:

     (a)  Residue concentration,
     (b)  Slag granulation,
     (c)  Reverberatory and rotary furnace wet air pollution
          control,
     (d)  Spent electrolyte,
     (e)  Scrap anode rinsing,
     (f)  Casting contact cooling, and
     (g)  Casting wet air pollution control.

2.   EPA promulgated BPT effluent limitations for the secondary
     copper subcategory on February 27, 1975 as Subpart F of 40
     CFR Part 421.  No modificaitons are proposed for BPT for  the
     secondary copper subcategory.  Promulgated BPT  for the
     secondary copper subcategory is zero discharge  of  all pro-
     cess wastewater pollutants, subject to discharge allowances
     for catastrophic stormwater and net precipitation.  Facili-
     ties in the secondary copper subcategory may discharge,
     regardless of effluent quality, a volume of water  falling
     within a cooling impoundment in excess of the 10-year, 24-
     hour storm, when a storm of at least that magnitude occurs.
     Further, they can discharge once per month, subject to con-
     centration-based effluent limitations, a volume of water
     equal to the difference between precipitation and evapora-
     tion on the cooling impoundment in that month.  Process
     wastewater discharged pursuant to the net precipitation
     allowance must comply with the following concentration-
     based effluent limitations:

                                   Effluent Limitations
                                          Average of Daily Values
   Effluent              Maximum for        for 30 Consecutive
Characteristic           Any One Day      Days Shall Not Exceed-

                                 Metric Units (mg/1)
                                 English Units (ppm)

Total Suspended Solids      50                    25
Copper                       0.5                   0.25
Zinc                        10                     5
Oil and Grease              20                    10
pH                         Within the range of 6.0 to 9.0
                               609

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3.   EPA is proposing to modify BAT effluent limitations for the
     secondary copper subcategory.  EPA is proposing that BAT
     for the secondary copper subcategory be zero discharge of
     all process wastewater pollutants, subject to a discharge
     allowance for catastrophic stormwater.  Facilities in the
     secondary copper subcategory may discharge, regardless of
     effluent cooling impoundment in excess of the 25-year, 24-
     hour storm when a storm of at least that magnitude occurs.

4.   EPA is proposing that NSPS for the secondary copper subcate-
     gory be zero discharge of all process wastewater pollutants.

5.   EPA is proposing to modify PSES for the secondary copper
     subcategory.  EPA is proposing that PSES for the secondary
     copper subcategory be zero discharge of all process waste-
     water pollutants.

6.   EPA is proposing that PSNS for the secondary copper subcate-
     gory be zero discharge of all process wastewater pollutants.

7.   EPA is not proposing BCT effluent limitations for the
     secondary copper subcategory at this time.
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                    SECONDARY COPPER  SUBCATEGORY

                           SECTION III

                          INDUSTRY PROFILE
This section of the  secondary  copper  supplement  describes  the  raw
materials and processes used in  smelting  and  refining  secondary
copper and copper-base alloys, and presents a profile  of  the
secondary copper  subcategory.  For a  discussion  of  the purpose,
authority, and methodology  for this study and a  general descrip-
tion of the nonferrous metals  manufacturing category,  refer to
Section III of the General  Development  Document.

DESCRIPTION OF SECONDARY COPPER  PRODUCTION

There are a variety  of manufacturing  processes (as  shown  in
Figure III-l) involved in the  production  of secondary  copper or
copper-base alloys.  The raw materials  and desired  end product
play an important role in determining the manufacturing process
of a particular plant.  The principal steps involved in the
production of secondary copper and copper-base alloys  are  as
follows:

     1.  Pretreatment of scrap;
     2.  Smelting of low-grade scrap  and  residues;
     3.  Melting, refining, and  alloying  intermediate-grade
         copper-base scrap
         and residues;
     4.  Refining high-grade copper scrap; and
     5.  Casting.

Each of these production steps,  along with raw materials,  is dis-
cussed in detail below.

RAW MATERIALS

Discarded consumer products, industrial copper-bearing scrap
metal (solids) and melting wastes (slags  and  residues)  are the
basic raw materials used in secondary copper  facilities.  About
two-thirds of the recycled copper tonnage is  in  the form of brass
and bronze, with the remaining one-third  in the,form of copper.
Additional copper values are recovererd from  copper-bearing
wastes, such as skimmings, grindings, ashes,  irony brass and
copper residues and slags.  The  United States  Department of
Interior has estimated that 60 percent of all  copper-base metal
is reclaimed as old metal and comes back  into  production again.
The cycle between its original use and recovery  is approximately
40 years.
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The segregation and classification of scrap metal are important
steps in the production of alloyed ingots or pure copper.  Segre-
gation of copper-base scrap is done in a preliminary way by the
scrap dealer (old scrap) or by the fabrication plant as the scrap
is generated (new scrap).  The copper-bearing scrap sold to the
smelters contains metallic and nonmetallic impurities.  Included
among these are lead, zinc, tin, antimony, iron, manganese,
nickel, chromium, precious metals, and organic-base constituents,
such as insulation (plastic and other types), oil, grease, paint,
rubber, and antifreeze.

PRETREATMENT OF SCRAP

Before scrap, in the form of solids (metal) and residues, is used
by the smelter, various types of pretreatment are performed.  The
materials are usually presorted by secondary material dealers or
shipped directly by foundries and metal shops; however, addi-
tional sorting is often done by the smelter to attain tighter
control of the alloy constituents and the copper content.  The
steps used in the pretreatment of scrap depend on the type of
scrap being processed.  These pretreatment steps are discussed
below in the context of the type of scrap being processed.

Stripping

Insulation and lead sheathing are removed from electrical conduc-
tors, such as cables, by specially designed stripping machines or
by hand.  Water is not used or generated during stripping and
atmospheric emissions are not generated by this process.  The
lead is sold, reclaimed, or used in producing copper-base alloys.
The organic solid wastes are reclaimed or disposed by burning or
landfill.

Briquetting

Compressing bulky scrap, such as borings, turnings, tubing, thin
plate, wire screen, and wire, into small bales compacts the
scrap, allows for less storage area, and makes for easier han-
dling and faster melting.  The problem of oxidation of the metal
is also diminished.  Briquetting is carried out by compacting the
scrap with hydraulic presses.  Water is not used or generated
during briquetting and atmospheric emissions are not generated by
this process.

Size Reduction

Size reduction is used for all types of scrap materials.  Large
thin pieces of scrap metal are reduced in size by pneumatic
cutters, electric shears, and manual shearing.  Tramp iron liber-
ated from the scrap by size reduction is removed from the
shredded product magnetically.  The iron-free products are
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usually briquetted for easy handling.  Shredding  is also used  in
the separation of insulation on copper wire.  The  insulation is
broken loose from metal by shearing action and removed  from the
metal by air classification.

When treating bulky metal items, the process produces small quan-
tities of atmospheric emissions, consisting of dusts of approxi-
mately the same composition as the metal.  Collection of the dust
via dry cyclones or baghouses permits recovery of  the metal
value.

Crushing

Previously dried, brittle, spongy turnings, borings, and long
chips are processed in hammer mills or ball mills.  After  crush-
ing, tramp iron is removed magnetically.  Dust particles consist-
ing of dirt, organic compounds, and finely divided metal are
generally collected using dry cyclones.

Residue Concentration

Some secondary copper plants concentrate the copper values in
slags and other residues, such as drosses, skimmings, spills,  and
sweepings, before charging the concentrates into rotary or rever-
beratory furnaces.  Slags may be crushed, screened through a
coarse screen to remove trash and lumps of copper, pulverized
with a ball mill, and concentrated on a table classifier.  The
concentrate usually contains 70 to 90 percent copper or copper
alloy, and the gangue, or depleted slag, contains  4 or  5 percent
copper alloy.  The depleted slag is usually retained at the plant
site as landfill.  Lower grade residues are wet milled  and con-
centrated by gravity and table classifiers.

The concentration of residues is usually done by wet grinding  and
classifying.  The water associated with this processing contains
some milling fines as suspended solids and dissolved solids from
the soluble components of the residue and metals.  To limit water
consumption, the water used for milling is recycled from holding
tanks or ponds.

Residue Pelletizing and Roll Briquetting

Most small brass and bronze ingot makers (facilities) do not
process residues, but actually sell their copper bearing residues
to the larger refineries for processing to recover the  copper
values.  Some of the large refineries charge the residues  into
their cupola or blast furnaces for the recovery of the  copper
content in the slag or residues.

The fine slags or residues must be agglomerated before  charging
to prevent them from being blown out of the stacks.  The fine
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portions of the copper rich slags or other residues are pellet-
ized by adding water and a binder, if necessary, and rolling the
material in a disk or drum pelletizer until most of the fines are
in the form of small marble size pellets.  Although water is used
in pelletizing, it is completely consumed during processing and
wastewater is not discharged.

Drying

Borings, turnings, and chips from machining are covered with cut-
ting fluids, oils, and greases.  These contaminants are removed
in the drying process.  The scrap is generally heated in a rotary
kiln to vaporize and burn the contaminants.

Drying results in the evolution of considerable quantities of
hydrocarbons, depending on the amount present in the scrap.  The
oils, greases, and cutting fluids contain sulfonated and chlori-
nated hydrocarbons.  Therefore, gaseous emissions evolve and are
composed of the oxidation products that include sulfur oxides,
hydrogen chloride, hydrocarbons, and other combustion products.

The atmospheric emissions are controlled by burning the vaporized
fumes in afterburners, which oxidize the hydrocarbons to carbon
dioxide and water.  Inorganic particulates settle out in the
afterburner section.  Sulfur oxides and chloride emissions are
usually uncontrolled.  As such, water is not used or generated
during drying.

Burning

Scrap may be covered with paper and organic polymer insulation,
such as rubber, polyethylene, polypropylene, or polyvinyl chlor-
ide.  These materials are usually not removed by stripping.  They
are most effectively removed from the scrap by the burning pro-
cess using furnaces, such as rotary kilns.

The burning process generates the combustion products such as
carbon dioxide and water, the emissions may contain such gases as
phthalic anhydride and hydrogen chloride from the burning of
polyvinyl chloride.  Fluorocarbon insulation releases hydrogen
fluoride when burned.  Many of these gases are highly toxic and
corrosive.  These gases may be controlled through the use of wet
scrubbers, however, no plants in this subcategory report the use
of wet scrubbers for controlling burning furnace emissions.

Sweating

Scrap containing low melting point materials, such as radiators,
journal bearings, and lead sheathed cables, can be sweated to
remove babbitt, lead, and solder as valuable by-products, which
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would otherwise contaminate  a  melt.   Scrap  may be  added directly
to a melt without sweating if  the  melt  requires substantial
amounts of the sweatable  constituents.   Sweating is  done by  heat-
ing in an oil- or a gas-fired  muffle  type furnace  with  a sloped
hearth, so that the charge can be  kept  on the  high side and  away
from the fluid low melting components.   The molten metal is  col-
lected in pots, and the sweated  scrap is raked until most of the
low melting metals have been freed.   The process can be a contin-
uous or a batch operation.   Sweating  is also done  in pots by
dumping the scrap into molten  alloy,  which  absorbs the  sweated
babbitt, lead, or solder.  Rotary  kilns have been  used  on small
size scrap.  The tumbling action aids in removing  the molten
metals.  For items which  are difficult  to sweat, a reverberatory
furnace equipped with a shaking  grate is used.   Continuous sweat-
ing is done in tunnel furnaces that have provisions  for solder,
lead, and babbitt recovery.

Atmospheric emissions consist  of fumes  and  combustion products
originating from antifreeze  residues, soldering fluxes, rubber
hose remains, and the fuel used  to heat the sweat  furnace.   None
of the plants in this subcategory  use wet scrubbing  for sweating
furnaces.

SMELTING OF LOW-GRADE SCRAP  AND  RESIDUES

Drosses, slags, skimmings, and low-grade copper and  brass scrap
are processed in blast furnaces  or cupola furnaces.   These low-
grade, copper-bearing materials  are melted  to  separate  the copper
values from slags or residues  and  to  produce molten  metal that
can be processed further  immediately  after  recovery,  or after
being cast into ingots or shot for later use or sale.

The product of cupola or blast furnace  melting is  known as black
copper or cupola melt.  It generally  consists  of a mixture of
copper and variable amounts  of most of  the  common  alloying ele-
ments such as tin, lead, zinc, nickel,  iron, phosphorus,  and to a
lesser extent arsenic, antimony, aluminum,  beryllium, chromium,
manganese, silicon, and precious metals.  A matte  is  also formed
when sufficient sulfur is present  to  form a complex  copper-iron-
nickel-lead sulfide.  Other  specialty furnaces,  such as crucible
or induction furnaces, are sometimes  used for  special alloy
production or precious metal recovery.

The charge to the blast or cupola  furnace may  be in  the form of
irony brass and copper, fine insulated  wire, motor armatures,
foundry sweepings, slags, drosses, and  many other  low-grade
materials.  Fine materials are pretreated by pelletizing or
briquetting to reduce losses in  the stack gas.   Limestone and
millscale are added as fluxes  to produce iron  silicate  slags
(depleted slag).   Low sulfur coke  is  used in cupolas  or blast
furnaces to reduce matte  (copper sulfide) formation.
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During the cupola and blast  furnace processes,  the  metallic  con-
stituents melt, while the limestone aluminum, silicon  and  iron
oxides fuse in the smelting  zone and  form a molten  slag, which
mixes with the metals.  The  copper compounds are reduced by  the
coke.  The molten materials  flow downward through the  coke bed
and are collected in a crucible below.  After a period of
quiescence, the metal and slag form separate layers  and are
tapped.  The slag, containing less than 1 percent copper value,
is granulated with a high pressure water spray  or by directing it
into a quench pit while still in its  molten state.   The granu-
lated slag is then sent to a slag pile.

Cupola and blast furnace operations produce large quantities  of
particulate matter from dusty charge  materials, such as fine
slags, fine fluxes, and coke ash, as  well as metal  oxide fumes.
These particulates and fumes are controlled through  the use  of
air pollution control devices.  Dry air pollution control  devices
such as baghouse filters and cyclones are currently  used to
contain these particulates and fumes.

The process of conversion in the secondary copper subcategory can
be done in furnaces called converters or in other types of
furnaces in which molten metal is contained.  The operation  is
derived from primary copper  operation in which  the  sulfide matte
is converted to an oxide-rich copper  melt by oxidation with  air
or oxygen-enriched air.  In  secondary copper operations, however,
only small amounts of sulfide are present in the black copper,
but it is heavily contaminated with alloy metals, such as  zinc,
lead, nickel, iron, manganese, aluminum, tin, antimony,, silicon,
silver, or other metals and  nonmetals contained in  the scrap  or
residues.  Since the sulfur  content is low in secondary black
copper, fuel is required for converting operations ;  unlike
primary copper where the sulfur serves as the fuel.

With the use of converters or converter-oriented operations,  the
copper value in mixed alloys is reclaimed by oxidizing most  of
the alloying elements and removing the oxides as a  slag.   Molten
metal is sometimes oxidized  in a converter by blowing  air  through
ports in the bottom of the furnace until most of the oxidizable
alloying elements and some of the copper are oxidized  (blister
copper).  More commonly, the molten metal in reverberatory or
rotary furnaces is oxidized  by inserting water  cooled  lances  into
the bath and blowing the bath with air or oxygen under a silicate
slag cover until the alloy impourities are reduced  to  the  desired
level.  The slag containing  the alloy metal oxides  and some  cop-
per is removed, and the oxygen in the remaining copper is  reduced
with charcoal and green wood inserted in the bath.   Depending on
the extent of reduction, various grades of refined  copper  are
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produced.  Generally, after conversion,  a blister  copper  is
produced that is subsequently refined  in the  same  plant or sold
or transported to other plants.

Air emissions from converter furnaces  are currently  contained
through the use of dry air pollution control  devices.  The con-
trol of reverberatory and rotary  furnace air  emission will be
discussed later in this section.

MELTING, REFINING, AND ALLOYING INTERMEDIATE-GRADE COPPER-BASED
SCRAP

Copper-based scrap metals, intermediate-grade copper metal scrap,
black and blister copper, and residues with known  origin  or  com-
position are melted, refined, and alloyed, if necessary,  to  pro-
duce either brass or bronze ingots of  specific composition.
These same materials are refined  further to produce  fire  refined
copper suited for end use or for  casting anodes  for  electrolytic
refining.  Direct fired reverberatory  and rotary furnaces are
used to produce the product metals, brass and bronze, and fire
refined copper.

In the production of brass and bronze  ingots,  the  extent  of
refining is usually small, if the scrap  is well  sorted.   If  the
residues are of known origin (usually  a  toll  recovery operation),
refining is also kept to a minimum.  In  the production of copper,
the extent of refining is greater.  The  chemical principles  of
refining are applicable to both brass  and bronze ingot manufac-
ture and the preparation of fire  refined copper.

In the refining step, impurities  and other consitutents of the
charge, present in excess of specifications,  are oxidized.
Elements, such as iron, manganese, silicon, and  aluminum, are
normally considered to be contaminants in copper base alloys and
must be removed by refining.  In  the preparation of  refined  cop-
per, the alloying elements common to brass and bronze must also
be removed.  The methods used in  refining vary with  the type of
furnace, the types of scrap in the charge, as  well as the type of
product being produced.

The reverberatory or rotary furnace is charged with  scrap metal
at the start of the heat and at intervals during the melt down
period.  Air is blown into the molten  metal bath with lances in
order to oxidize metals in near accordance with  their position in
the electromotive series.  Thus,  iron, manganese,  aluminum,  and
silicon are oxidized, and in the refining of  zinc-rich copper
alloy scrap, the loss of zinc is unavoidable.  In  the production
of refined copper, the blowing is for a  longer duration,  since
most of the metal elements must be removed.
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The oxidized metals form a slag layer on the  surface  of  the  melt,
since the oxides have a lower density than the molten metal.
These oxides combine with the slag cover, which  is usually added
to aid in the removal of the oxidized impurities.  Borax, slaked
lime or hydrated lime, glass or silica, soda  ash, and caustic
soda are all used as fluxes to modify the characteristics of the
slag cover.  The most common material used by the brass  and
bronze smelters is anhydrous rasorite, a sodium  borate flux
(Na2B40y), which has a great affinity for metal  oxides and
siliceous materials.  The slag cover protects the molten metal
surface from unwanted oxidation and reduces volatilization of
2 nc.

To oxidize or degasify, as well as to alloy,  a brass  or  bronze
melt, metal fluxing agents are added to the melt.  In almost all
cases, these melt modifiers are binary alloys of copper  with
silicon, phosphorus, manganese, magnesium, lithium, or cadmium.
The highly oxidized, refined copper melt, containing  an  apprecia-
ble amount of Cu20 can be cast from the reverberatory or rotary
furnace into blister copper shapes and used in the subsequent
preparation of fire refined copper.  More typically,  however, the
molten oxidized melt is reduced in the reverberatory  or  rotary
furnace in which it was formed, by using carbon-based reducing
agents and then poling.  These operations are discussed  in detail
in the section on refining of high grade copper  scrap.

Once a melt meets specifications, principally chemical analysis,
the brass or bronze is cast into ingots, cooled, and  then pack-
aged for shipping.  Refined copper, that has  been analyzed and
found to meet specification, is either cast into blister copper
ingots or is subsequently reduced in the furnace as a continua-
tion of the fire refining operation.

Fumes of metal oxides are produced when the molten metal is  blown
with air or oxygen to remove metallic impurities, or  when green
wooden poles are inserted into the bath to reduce the heat.  Dust
is produced during the charging of fine slags and fine flux
materials.  The dusts and fumes are controlled through the use of
baghouse filters or wet scrubbers.  The wet scrubbers on the
reverberatory and rotary furnaces are the sole source of
wastewater.

REFINING HIGH-GRADE COPPER SCRAP

Black copper produced from smelting of low-grade scrap,  slags,
drosses, and sludges, and blister copper prepared from
intermediate-grade scrap, are eventually brought together with
high quality copper scrap (usually No. 2 copper  wire, No. 1  heavy
copper, No. 2 copper-, and light copper) for full fire refining.
Full fire refining is required to produce specification  copper
billets, slabs, cakes, and wire bars.  Copper ingots  and shot are
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also produced for making  copper base  alloys.   Fire  refined copper
may be even further refined by casting  the metal  into  anodes  for
electrolytic refining.  The extent  of refining is governed in
part by the amount and type of metal  impurities and the  need  for
or difficulty of their removal  (by  fire refining) to meet
specifications for the product.

Fire Refining

Fire refining is used to  remove excess  zinc,  lead,  iron  and tin.
Fire refinin involves blowing air or  oxygen  through the  molten
metal in a reverberatory  or rotary  furnace.   In the production  of
pure copper products, the blowing is  continued until the con-
tained zinc, lead, iron,  tin, and other impurities,  along  with
about 3 percent of the copper, are  removed by oxidation.   Most  of
the oxides are trapped in the slag  cover.  After  the contaminated
slag is removed, the refined copper is  deoxidized with green  wood
poles under a charcoal or coke cover.   Once  the oxygen content
meets specifications, the copper is cast  into anodes for electro-
lytic refining or into billets, wire  bars, etc. Selected types  of
flux materials are generally added  to assist  in the removal of
the impurities before poling.

The slags may contain various proportions of  the  fluxes, silica,
iron oxide, phosphorus pentoxide, soda  ash,  rasorite (a  borax
type flux), and limestone depending on  impurities needed to be
removed to obtain the desired composition.   Copper-rich  slags are
reprocessed or sold for that purpose.   Copper-poor  slags are
discarded or sold.

Skimming

After a copper alloy has been refined in  a reverberatory or
rotary furnace, it is analyzed and  adjusted  in composition if
necessary.  The temperature is adjusted and  slags are  skimmed
from the furnace.  These  slags are  generally  reprocessed to
remove copper values trapped in the slag.  The slag may  be pro-
cessed by the smelter or  sold to larger smelters  for processing.

The slags are either crushed wet or dry and wet screened or
tabled to concentrate the copper content, or  the  entire  copper-
rich slag may also be charged into  a  blast furnace  or  cupola  for
remelting and separation of the copper  from  the other  ingredi-
ents.  If the metal content of the  slag is 45 percent  or above,
some facilities will charge the slag  directly into  a rotary or
reverberatory furnace.  Wastewater  is generated in  plants  that
use wet crushing and concentrating.
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Electrolytic Refining

High-purity cathode copper is produced through electrolytic
refining.  Anode copper, often containing precious metals and
impurities such as nickel, are placed into the cells in an
alternating fashion with thin copper starter sheets, which after
electrolytic deposition become cathodes of refined copper.

The cathodes are removed periodically from the electrolytic
cells, melted, and cast into fine-shape castings, such as wire
bar and billets.  Used anodes are removed from the cells, rinsed
to remove adhering acid, and remelted into new anodes.  If nickel
is present in the anodes, the nickel content of the electrolyte,
as well as the copper content, will build up and a bleed from the
circuit must occur.  This bleed is often subjected to electro-
winning for copper removal, wherein a lead cathode is used, and
cementation.

The spent electrolyte, depleted in copper content, may be parti-
ally evaporated by open or barometric condensers in order to
produce nickel sulfate as a by-product.  Precious metals are
recovered as a slime in the bottom of the electrolytic cells and
are usually dried and sold to other facilities for precious metal
value recovery.

Postelectrolytic Melting and Refining

Refined copper in the form of cathodes along with No. 1 copper
wire scrap are melted in reverberatory furnaces or shaft furnaces
and cast into desired product shapes such as cakes, billets, and
wire bars, as well as ingots.  The melting process in the rever-
beratory furnace may be followed by a blowing step, skimming of
the melt, and then poling, followed by preparation for pouring
and casting.

The shaft furnace, which uses natural gas as a fuel and operates
on the principle of a cupola furnace, continuously melts cath-
odes, home scrap, and No. 1 copper wire scrap, with "refining" by
poling or charcoal reduction being done in a small reverberatory
holding furnace just before casting.  The molten copper is con-
tinuously cast into billets and cakes.  Water is used principally
for noncontact cooling in the two types of melting furnaces.
Particulate air emissions from the operation are usually con-
trolled by means of baghouses.  Wet air pollution control may
also be used to control air emissions.  In such cases a waste-
water is generated.

CASTING

Molten metal from the smelting operations described above is cast
into various shapes suitable for shipping, handling, or use in
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subsequent operations.   Copper-base  alloys  are  usually cast into
ingots.  Black copper, blister  copper,  and  anode  copper are also
cast in molds and shapes  suited for  the specific  product.
Refined copper is cast into  shapes suitable for subsequent
fabrication steps, taking the  form of billets,  cakes,  wire bars,
wire rod, and ingots, or  it  may be quenched into  shot.   Casting
operations for the various products  are described below.

Brass and Bronze Ingo*

The melt, which has been  analyzed and found to  meet  specifica-
tions, is adjusted to the proper temperature before pouring.
Rotary and reverberatory  furnaces containing the  molten metal are
tapped, and the metal is  poured into various ingot filling sys-
tems.  The metal may pour directly into a moving,  automatically
controlled mold line, in  which  one or more  molds  are  filled at
once; then the flow shuts off while  a new set of  molds moves  into
position on an endless conveyor.  In another variation,  the metal
from the furnace is tapped into a ladle and then  moved to  a mold
line, which may be stationary or movable.   Molds  are  sprayed  with
a mold wash and then dried thoroughly before the  ingot is  cast.
Automatic devices are often  used to  sprinkle ground charcoal  in
the molds or onto the molten metal in the molds to provide a
special smooth top on the ingots.

The molds are cooled by a water spray or partial  immersion of the
mold in a tank of water.   Once  the molten metal has solidified,
the ingots are quenched in a pit from which they  are  removed  by a
drag conveyor.  After drying, they are  packed for shipment.

Generally, only steam is  discharged  during  the  operation,  and
water is recycled after cooling and  storage in  tanks  or ponds.
The wastewater is discharged periodically to permit the storage
tanks to be cleaned of charcoal  and  mold wash sludges  containing
some metals or their oxides.

Black and Blister Copper

Black copper (or cupola melt) produced  from blast  or  cupola
furnace operations is usually transported or transferred to a
converter or a reverberatory or rotary  furnace  in the  molten
state to conserve heating requirements.  In some  cases  where  the
conversion-oriented operation is backlogged or  out of  synchroni-
zation with black copper  production, the black  copper  might be
cast into convenient shapes  for later use.   These  shapes take the
form of shot, pigs, sows, or any convenient mold  shape  available.
Crude molds formed in sand are  often used to cast  pigs,  sows,  or
other shapes.  Blister copper production may also  be out of phase
with subsequent reduction operations due to a furnace  failure or
plant shutdown.   In such  cases,  the  blister copper is  cast into
almost any available mold shape  for  subsequent  use.  These molds
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may be contact or noncontact cooled with water, or they  can be
air cooled.  In those cases where the blister copper  is  an end
product of the smelter, the molds are made of graphite and are
air cooled.

Anodes

Partially fire refined copper, that is to be electrolytically
refined to remove impurities that are not removed by  fire
refining or to recover impurities of value, is cast into anodes.
The molten metal from the anode furnace is cast in a  circular
mold conveying system (known as a casting wheel) or a conveyor.
The molds may be cooled indirectly, or spray cooled,  or both,
after the metal has been cast.  Once the molten metal has solidi-
fied, it is removed from the mold and quenched in a tank of
water.  The mold is treated with a mold coating or "wash," com-
monly synthetic bone ash (calcium phosphate), before  receiving
the next charge of molten anode copper.  Much of the  spray water
is converted to steam.  Wastewater containing residual mold wash
and some metal oxide scale is generated.

Refined Copper

Fully fire refined copper and melted cathode copper are  cast into
various shapes suitable for fabrication end use.  These  shapes
are billets, cakes, slabs, wire bar, wire rod, and ingots.  Wire
bar and ingots are cast into permanent smolds on a casting wheel
that is internally cooled with water.  Once solidified),  the wire
bar or ingots are removed from the mold and quenched  in  tanks.
The molds are treated with a mold wash and dried before  reuse.

Billets, cakes, and wire rod are usually continuously cast or
directly chill cast, and the metal is cooled within dies using
noncontact and contact cooling water that is recirculated after
passing through cooling towers.  Wire-rod casting uses exclu-
sively noncontact cooling water as the cast rod is reduced in
diameter through a series of water cooled rolls.

Copper Shot

Copper for alloying purposes is sometimes produced in the form of
shot to facilitate handling and remelting.  In some cases, the
copper is alloyed with phosphorus to increase hardness.  Copper
shotting operations consist of pouring the molten refined copper
directly into a quench pit.  Wastewater is generated  when the
quench pit is periodically discharged for cleaning, and  by wet
air pollution control devices operating on gas streams generated
by the melting furnace.
                               622

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PROCESS WASTEWATER SOURCES

The principal sources of wastewater  in  the  secondary  copper  sub-
category are:

     1.  Residue concentration,
     2.  Slag granulation,
     3.  Reverberatory and rotary  furnace wet air pollution
         control,
     4.  Spent electrolyte,
     5.  Scrap anode rinse water,
     6.  Casting contact cooling water, and
     7.  Casting wet air pollution control.

OTHER WASTEWATER SOURCES

There are other wastewater streams associated with  the  manufac-
ture of secondary copper.  These wastewater streams include  but
are not limited to:

     1.  Stormwater runoff, and
     2.  Maintenance and cleanup water.

These waste streams are not considered  as a part of this rulemak-
ing.  EPA believes that the flows  and pollutant loadings associ-
ated with these waste streams are  either insignificant  relative
to the waste streams selected or are best handled by  the appro-
priate permit authority on a case-by-case basis under authority
of Section 403 of the Clean Water  Act.

AGE, PRODUCTION, AND PROCESS PROFILE

A distribution of the secondary copper  plants in the  United
States is shown in Figure III-2.   Figure III-2 shows  that most of
the secondary copper plants are located around the Great Lakes
and New England states.

Table III-l shows that the average plant age is about 20 to  30
years, and that there are five direct,  six  indirect,  and 20  zero
discharge plants in the secondary  copper subcategory.   Table
III-2 summarizes the distribution  of secondary copper plants for
1976 production levels.  Table III-3 provides a summary of the
number of secondary copper plants  that  generate the various  pro-
cess wastewaters identified previously  in this section.
                               623

-------























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-------
                     Table III-2

       PRODUCTION RANGES FOR PROCESSING PLANTS
         OF THE SECONDARY COPPER SUBCATEGORY
   Production Ranges for 1976
	(tons/year)	     Number of Plants

             0 -  5,000                     11

         5,001 - 10,000                      3

        10,001 - 20,000                      6

        20,001 - 30,000                      4

        30,001 +                             4

    No Data Reported in dcp                  3

Total Number of Plants in Survey            31
                         625

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                           Table III-3

               PRODUCTION PROCESSES UTILIZED BY THE
                   SECONDARY COPPER SUBCATEGORY
                        Number of Plants      Number of Plants
Production Process        with Process     Generating Wastewater*

Residue Concentration           7                     7

Slag Granulation                5                     5

Reverberatory and              18                     5
Rotary Furnace Air
Pollution Control

Electrolytic Refining           6                     6

Casting                        29                    22

Casting Air Pollution           8                     3
Control**
 *Due to in-process flow reduction measures, a plant may generate
  a wastewater but not discharge it.

**Reverberatory and rotary furnace air pollution control plants
  are not included in the count for casting air pollution
  control.  An attempt was made to distinguish the reverberatory
  and rotary furnace wet air pollution control systems and  the
  casting wet air pollution control systems that do not use
  reverberatory and rotary furnaces for casting.
                               626

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            Figure  III-l




SECONDARY COPPER PRODUCTION PROCESS
                627

-------
                                  CM
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                                  0)
628

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                   SECONDARY COPPER SUBCATEGORY

                            SECTION IV

                        SUBCATEGORIZATION
As discussed in Section IV of the General Development Document,
the nonferrous metals manufacturing category has been subcategor-
ized to take into account pertinent industry characteristics,
manufacturing process variations1, and a number of other factors
which affect the ability of the facilities to achieve effluent
limitations.  This section summarizes the factors considered
during the designation of the secondary copper subcategory and
its related subdivisions.

FACTORS CONSIDERED IN SUBCATEGORIZATION

The following factors were evaluated for use in subcategorizing
the nonferrous metals manufacturing category:

     1.  Metal products, co-products, and by-products;
     2.  Raw materials;
     3.  Manufacturing processes;
     4.  Product form;
     5.  Plant location;
     6.  Plant age;
     7.  Plant size;
     8.  Air pollution control methods;
     9.  Meteorological conditions;
    10.  Treatment costs;
    11.  Nonwater quality aspects;
    12.  Number of employees;
    13.  Total energy requirements; and
    14.  Unique plant characteristics.

Evaluation of all factors that could warrant subcategorization
resulted in the designation of the secondary copper subcategory.
Three factors were particularly important in establishing these
classifications:   the type of metal produced, the nature of the
raw material used, and the manufacturing processes involved.

In Section IV of the General Development Document, each of these
factors is described, and the rationale for selecting metal pro-
duct, manufacturing processes, and raw materials as the principal
factors used for subcategorization is discussed.  On this basis,
the nonferrous metals manufacturing category (phase I) was divid-
ed into 12 subcategories, one of them being secondary copper.
                               629

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FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY COPPER
SUBCATEGORY

The factors listed previously were each evaluated when consider-
ing subdivision of the secondary copper subcategory.  In the
discussion the follows, the factors will be described as they
pertain to this particular subcategory.

The rationale for considering further subdivision of the second-
ary copper subcategory is based primarily on differences in the
production processes and raw materials used.  Within this sub-
category, 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 secondary copper 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 subdivisions.

Each subdivision is discussed following the list.

     1.  Residue concentration,
     2.  Slag granulation,
     3.  Reverberatory and rotary furnace wet air pollution
         control
     4.  Spent electrolyte
     5.  Scrap anode rinsing,
     6.  Casting contact cooling,
     7.  Casting wet air pollution control.

Two subdivisions have been established for wastewater generated
in the processing of slags and residues.  Slag covers on rever-
beratory and rotary furnaces are generally raked off before the
furnace is tapped.  The copper content of the slag can be recov-
ered by melting the slag (along with scrap copper, coke, and
fluxes) in a cupola or blast furnace, or by milling and classify-
ing the slag into a waste gangue material and a copper rich con-
centrate.  Wastewater is generated in the concentration of slags
or other residues such as drosses, skimming, spills, and sweep-
ings through wet milling and classifying.  When slags are melted
with scrap copper, coke, and fluxes in blast or cupola furnaces,
two products are tapped, a waste or depleted slag, and black
copper.  The waste slag is granulated in a quench pit or with a
high pressure water stream, producing slag granulation waste-
water.

Wet scrubbers are used to remove particulates and metal oxide
fumes from reverberatory and rotary furnace off-gases. There-
fore, a subdivision for reverberatory and rotary furnace wet air
pollution control wastewater is necessary.
                               630

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A subdivision has not been established  for blast, cupola,  or  con-
verter furnace wet air pollution control, since no plants  in  the
subcategory use wet air pollution  control devices in  conjunction
with these furnaces.

Two subdivisions are established for wastewater associated with
electrolytic refining.  These subdivisions are established for
spent electrolyte wastewaters and  scrap anode rinse water.  Spent
electrolyte is sometimes bled to prevent the build up of copper
and nickel in the electrolyte.  Depleted anodes are removed from
the electrolytic cells and rinsed  with water to remove adhering
electrolyte.

Contact cooling water is used for  metal cooling at 22 plants.
Therefore a casting contact cooling subdivision is necessary.  A
subdivision has also been established for casting wet air  pollu-
tion control, since three plants use wet scrubbers to remove
fumes and particulates from casting operations.

OTHER FACTORS

The other factors considered in this evaluation either support
the establishment of the seven subdivisions or were shown  to  be
inappropriate bases for subdivision.  Air pollution control
methods, treatment costs, and total energy requirements are
functions of the selected subcategorization factors--metal prod-
uct, raw materials, and production processes.  Therefore,  they
are not independent factors and do affect the subcategorization
which has been applied.  As discussed in Section IV of the
General Development Document, certain other factors,  such  as
plant age, plant size, and the number of employees, were also
evaluated and determined to be inapproprite for use as  bases  for
subdivision of nonferrous metal plants.

PRODUCTION NORMALIZING PARAMETERS

The effluent limitations and standards developed in this document
establish mass limitations on the  discharge of specific pollutant
parameters.  To allow these regulations to be applied to plants
with various production capcities, the mass of pollutant dis-
charged must be related to a unit  of production.  This  factor is
known as the production normalizing parameter (PNP).

The PNPs for the six subdivisions  in the secondary copper  sub-
category are:

     Subdivision                          PNP

1.   Residue concentration     kkg  of slag or residue  processed
                               631

-------
2.  Slag granulation


3.  Reverberatory and
    furnace wet air
    pollution control

4.  Spent electrolyte

5.  Scrap and rinse water

6.  Casting contact cooling

7.  Casting wet air
    pollution control
kkg of blast and cupola furnace
copper production

kkg of reverberatory and rotary
furnace copper produced


kkg of cathode copper produced

kkg of cathode copper produced

kkg of copper cast

kkg of copper cast
                               632

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                   SECONDARY COPPER SUBCATEGORY

                            SECTION V

             WATER USE AND WASTEWATER CHARACTERISTICS
This section describes the characteristics of wastewater associ-
ated with the secondary copper subcategory.  Data used to quan-
tify wastewater flow and pollutant concentrations are presented,
summarized, and discussed.  The contribution of specific produc-
tion processes to the overall wastewater discharge from secondary
copper plants is identified whenever possible.

Section V of the General Development Document contains a detailed
description of the data sources and methods of analysis used to
characterize wastewater from the nonferrous metals manufacturing
category.  To summarize this information briefly, two principal
data sources were used:  data collection portfolios and field
sampling results.  Data collection portfolios, completed for the
secondary copper subcategory, contain information regarding
wastewater flows and production levels.

In order to quantify the pollutant discharge from secondary cop-
per plants, a field sampling program was conducted.  Wastewater
samples were collected in two phases:  screening and verifica-
tion.  The first phase, screen sampling, was to identify which
toxic pollutants were present in the wastewaters from production
of the various metals.  Screening samples were analyzed for 128
of the 129 toxic pollutants and other pollutants deemed appropri-
ate.  (Because the analytical standard for TCDD was judged to be
too hazardous to be made generally available, samples were never
analyzed for this pollutant.  There is no reason to expect that
TCDD would be present in primary copper smelting and electrolytic
refining wastewater.)  A total of 10 plants were selected for
screen sampling in the nonferrous metals manufacturing category.
A complete list of the pollutants considered and a summary of the
techniques used in sampling and laboratory analyses are included
in Section V of the General Development Document.  In general,
the samples were analyzed for three classes of pollutants:  toxic
organic pollutants, toxic metal pollutants, and criteria pollu-
tants (which includes both conventional and nonconventional
pollutants).

As described in Section IV of this supplement, the secondary
copper subcategory has been further categorized into seven
subdivisions.  As such, the proposed regulation contains mass
discharge limitations and standards for seven unit processes
discharging process wastewater.  Differences in the wastewater
characteristics associated with these subdivisions are to be
expected.  For this reason, wastewater streams corresponding to
each subdivision are addressed separately in the discussions that
follow.
                               633

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WASTEWATER SOURCES, DISCHARGE RATES, AND CHARACTERISTICS

The wastewater data presented in this section were evaluated  in
light of production process information compiled during this
study.  As a result, it was possible to identify the principal
wastewater sources in the secondary copper subcategory.  These
include:

     1.  Residue concentration,
     2.  Slag granulation,
     3.  Reverberatory and rotary furnace wet air pollution
         control,
     4.  Spent electrolyte,
     5.  Scrap anode rinsing,
     6.  Casting contact cooling, and
     7.  Casting wet air pollution control.

Data supplied by dcp responses were used to calculate the amount
of water used and discharged per metric ton of production.  The
two ratios calculated are differentiated by the flow rate used in
the calculation.  Water use is defined as the volume of water or
other fluid (e.g., electrolyte) required for a given process  per
mass of copper product and is therefore based on the sum of
recycle and make-up 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 treat-
ment, disposal, or discharge per mass of copper produced.
Differences between the water use and wastewater flows associated
with a given stream result from recycle, evaporation, and carry-
over on the product.  The production values used in calculations
correspond to the production normalizing parameter, PNP, assigned
to each stream, as outlined in Section IV.   The production nor-
malized flows were compiled and statistically analyzed by stream
type.  Where appropriate, an attempt was made to identify factors
that could account for variations in water use.  This information
is summarized in this section.  As an example, scrap anode rinse
wastewater flow is related to the cathode copper production.  As
such, the discharge rate is expressed in liters of rinse waste-
water per metric ton of cathode copper production (gallons of
rinse water per ton of cathode copper production).

Characteristics of wastewater from the previously listed proces-
ses were determined from sampling data collected at secondary
copper plants.  This data was used in two ways.  From the sam-
pling data, pollutants selected for regulation were determined.
Secondly, the sampling data was used to estimate the yearly mass
of pollutant generated by each waste stream for the entire sub-
category.  There were a total of five site visits, which repre-
sents 11 percent of the secondary copper subcategory.  Diagrams
                               634

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indicating the sampling  sites  and  contributing production
processes are shown  in Figures V-l to  V-5  (at  the  end  of this
section).

In the data collection portfolios, plants  were asked to  indicate
whether  or not any of the  toxic pollutants were believed to  be
present  in their wastewater.   The  responses  for the toxic metals
are summarized below:

                   Known      Believed    Believed      Known
    Pollutant     Present      Present        Absent      Absent

    Antimony         21            7           -
    Arsenic          1                         81
    Beryllium        1           -            9
    Cadmium          3                         7           -
    Chromium         21            7           -
    Copper           71            2           -
    Lead             61            3           -
    Mercury          21            61
    Nickel           415-
    Selenium         -                         91
    Silver           118-
    Zinc             711-

All plants responding to the portion of the  dcp concerning the
presence of the toxic organic pollutants indicated that  they all
were either known or believed to be absent with the exception  of
fluorene.  Two plants reported that fluorene was known to be
present while one plant  reported that  fluorene was believed  to be
present.  However, as reported in  Section VI,  fluorene was not
detected in 12 samples from five waste streams collected during
the Agency's sampling and  analysis program.

The raw wastewater sampling data for the secondary copper sub-
category are presented in  Tables V-8 through V-12  (at  the end  of
this section).  Treated  wastewater sampling  data are shown in
Tables V-13 through V-16 (at the end of this section).   The
stream codes displayed in  Tables V-8 through V-16  may  be used  to
identify the location of each of the samples on the process  flow
diagrams in Figures V-l  through V-5.   Where  no data is listed  for
a specific day of sampling, the wastewater samples for the stream
were not collected.  If  the analyses did not detect a  pollutant
in a waste stream, the pollutant was omitted from  the  table.

The data tables included some samples  measured at  concentrations
considered not quantifiable.  The  base neutral extractable,  acid
extractable,  and volatile  toxic organics generally are considered
not quantifiable at concentrations equal to  or less than 0.010
mg/1.   Below this concentration, organic analytical results  are
not quantitatively accurate; however,  the analyses are useful  to
                               635

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indicate the presence of a particular pollutant.  The pesticide
fraction is considered not quantifiable at concentrations equal
to or less than 0.005 mg/1.  Nonquantifiable results are
designated in the tables with an asterisk (double asterisk  for
pesticides).

These detection limits shown on the data tables are not the  same
in all cases as the published detection limits for these pollu-
tants by the same analytical methods.  The detection limits  used
were reported with the analytical data and hence are the appro-
priate 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 calibra-
tion, variation in stock solutions, and variation in operators.

The statistical analysis of data includes some samples measured
at concentrations considered not quantifiable.  Data reported as
an asterisk are considered as detected but below quantifiable
concentrations, and a value of zero is used for averaging.   Toxic
organic, nonconventional, and conventional pollutant data
reported with a "less than" sign are considered as detected  but
not further quantifiable.  A value of zero is also used for
averaging.  If a pollutant is reported as not detected, it  is
excluded in calculating the average.  Finally, toxic metal  values
reported as less than a certain value were considered as not
detected and a value of zero is used in the calculation of  the
average.  For example, three samples reported as ND, *, and  0.021
mg/1 have an average value of 0.010 mg/1.  The averages calcu-
lated are presented with the sampling data.  These values were
not used in the selection of pollutant parameters.

In the following discussion, water use and field sampling data
are presented for each operation.  Appropriate tubing or back-
ground blank and source water concentrations are pesented with
the summaries of the sampling data.  Figures V-l through V-5 show
the location of wastewater sampling sites at each facility.  The
method by which each sample was collected is indicated by number,
as follows:

     1    one-time grab
     2    24-hour manual composite
     3    24-hour automatic composite
     4    48-hour manual composite
     5    48-hour automatic composite
     6    72-hour manual composite
     7    72-hour automatic composite
                               636

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SECONDARY COPPER WASTEWATER SOURCES AND CHARACTERISTICS

Presented below is a discussion of the characteristics of  the
significant wastewater sources attributable to the processing of
secondary copper.

Residue Concentration

The copper content can be concentrated in slags and other  resi-
dues, such as drosses, skimmings, spills, and sweepings, before
charging the concentrates into rotary or reverberatory furnaces.
The residues are sometimes concentrated by wet milling and
classifying, producing a residue concentration waste stream.  The
water use and discharge rates for residue concentration in liters
of water per metric ton of slag or residue processed are shown  in
Table V-l.

Raw wastewater data for residue concentration are presented in
Table V-8.  This waste stream is characterized by treatable
concentrations of dissolved toxic metal pollutants and suspended
solids.  The toxic metals are soluble components of the slags and
residues, and the suspended solids are from milling fines  that
end up in the water.

Slag Granulation

Five plants report the use of water for blast or cupola furnace
slag granulation.  This wastewater is generated when slag  is
granulated with high pressure water jets, or in quench pits prior
to disposal.  The water use and discharge rates for slag granula-
tion in liters of water per meric ton of blast or cupola furnace
production are shown in Table V-2.

The Agency did not collect any raw wastewater sampling data from
slag granulation operations at secondary copper plants.  However,
the characteristics of this wastewater are generally comparable
to those of residue concentration wastewater, since materials
from nearly identical sources are being treated in either  case.
Thus, slag granulation wastewater contains treatable concentra-
tions of dissolved toxic metal pollutants and suspended solids.

Reverberatory and Rotary Furnace Wet Air Pollution Control

Five plants report the use of wet air pollution control devices
to contain metal oxide fumes and dust from reverberatory and
rotary furnace operations.  Fumes of metal oxides are produced
when the molten metal is blown with air or oxygen to remove
metallic impurities, or when green wooden poles are inserted into
the bath to deoxidize the heat.  Dust will be produced during the
charging of fine slags or fine flux materials.  When wet air
pollution control is used, the metal oxides and dust will  be
                               637

-------
contained in the water as suspended solids and dissolved  toxic
metals.  Raw wastewater data for reverberatory and rotary furnace
wet air pollution control are shown in Table V-9.  As  expected,
toxic metal pollutants and suspended solids are present in treat-
able concentrations.  Table V-9 also shows that this wastewater
is acidic (pH of 1.6 to 2.5).

The water use and discharge rates for reverberatory and rotary
furnace wet air pollution control are presented in Table  V-3.

Spent Electrolyte

Normally, electrolyte is continuously circulated through  thick-
eners and filters to remove solids, and recycled back  through the
electrolytic cells.  It is necessary to blowdown a fraction of
the electrolyte to prevent the buildup of copper and nickel.
This slip stream is treated to recover nickel and copper,  and
recycled or discharged.  Table V-4 presents the electrolyte use
and discharge rates for spent electrolyte in liters per metric
ton of cathode copper produced.

Raw wastewater sampling data for spent electrolyte are shown in
Table V-10.   This waste stream is characterized by treatable con-
centrations of toxic metal pollutants (particularly copper,  lead,
and zinc) and suspended solids.  The pH of the spent electrolyte
in the wastewater samples ranged from 1.48 to 3.45.

Scrap Anode Rinsing

Anodes removed from electrolytic cells are sometimes rinsed
before further processing.  As shown in Table V-5, only two
plants reported the use of rinse water for scrap anode cleaning,
and both of those plants practice 100 percent recycle  of  the
rinse water.  The Agency did not collect any raw wastewater
samples from anode rinsing operations.  Wastewater from this
operation should contain treatable concentrations of total
suspended solids and dissolved toxic metal pollutants, which are
a result of impurities in the modes that are released  into the
rinse water.

Contact Cooling Water

Twenty-two plants report the use of contact cooling water to cool
molten metal cast into ingots, shot, and anodes.  Anodes  and
rough brass or bronze ingots are generally water spray-cooled to
rapidly solidify the casting, and the casting is then  quenched in
a tank of water.  Smooth brass or bronze ingots must be slowly
cooled in the mold under a layer of charcoal to produce the
smooth surface requested by certain customers.  Ingot  mold lines
are quite long for the production of smooth ingots.  The  ingots
                               638

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are permitted to air cool  in  the  mold  during  the  first  portion of
the conveyor travel, the bottom of  the ingot  mold is  submerged in
a tank of water during the  second portion  of  the  conveyor  travel,
and finally the solidified  ingot  is discharged  into a quenching
tank of water.  Part of the charcoal burns  during the ingots'
travel period on the conveyor.  The unburned  charcoal and  char-
coal ash all go into the ingot cooling water.   These  residues
settle as a sludge and are  periodically cleaned out of  the
quenching tanks and subsequent settling tanks or  ponds.  The
water may or may not be recycled.   In  addition  to the charcoal
and charcoal ash, the wastewater  pollutants associated  with con-
tact cooling are metal oxides from  the ingot  surface, refractory
mold wash (calcium phosphate), and  flour dust.  Charcoal is not
used when casting copper anodes,  but the mold wash is used and
the wash ends up in the contact cooling water.  The raw waste-
water data for casting contact cooling water  is presented  in
Table V-ll.  Copper, lead,  zinc,  and total  suspended  solids are
all present in treatable concentrations.

The water use and discharge rates for  casting contact cooling  in
liters of water per metric  ton of copper cast are shown in Table
V-6.

Casting Wet Air Pollution Control

Wet air pollution control devices are  used  to control fumes pro-
duced from casting operations at  three plants.  Two of  these
plants use scrubbers to contain fumes  produced  from alloying
copper with phosphor in induction furnaces.  The  third  plant did
not report why it uses a scrubber for  casting,  however, this
plant casts brass and bronze  ingots which produce metal oxide
fumes when poured.  These fumes can be controlled by  a  scrubber.

The water use and discharge rates for  casting wet  air pollution
control in liters of water  per metric  ton of copper cast are
shown in Table V-7.

Raw wastewater samples were not collected for this stream.  How-
ever, since both casting, and reverberatory and rotary  furnace
water pollution control devices control metal oxide fumes,  their
wastewaters will be similar.  Therefore, casting  wet  air pollu-
tion water contains toxic metal pollutants and  suspended solids.
                               639

-------
                            Table V-l

     WATER USE AND DISCHARGE RATES FOR RESIDUE CONCENTRATION

               (1/kkg of slag or residue processed)
                                  Production
Production
Normalized
Plant Code
15
23
49
50
55
220
4507
Percent
Recycle
0
100
100
100
100
NR
100
Normalized
Water Use
6,702
NR
6,680
NR
NR
NR
NR
Discharge
Flow
6,702
0
0
0
0
677
0
NR - Present, but data not reported in dcp.
                              640

-------
                            Table V-2
        WATER USE AND DISCHARGE RATES FOR SLAG GRANULATION
           (1/kkg of blast and cupola furnace production)
       Plant Code
            26*
            35
            36
            49
            62
Percent
Recycle
  NR
  100
  100
  100
  100
Production
Normalized
Water Use
   NR
   NR
 17,210
 40,900
 65,800
Production
Normalized
Discharge
_  Flow	
      0
      0
      0
      0
      0
*Wastewater is evaporated.
NR - Present, but data not reported in dcp,
                              641

-------
                            Table V-3

       WATER USE AND DISCHARGE RATES FOR REVERBERATORY AND
             ROTARY FURNACE WET AIR POLLUTION CONTROL

   (1/kkg of reverberatory and rotary furnace copper produced)
       Plant Code

            22

            46

            50

            52

           207
Percent
Recycle

  100

    0

  100

  100

   81
Production
Normalized
Water Use

 274,200

   7,226

   NR

   NR

  25,000
Production
Normalized
Discharge
	Flow

      0

  7,226

      0

      0

  4,695
NR - Present, but data not reported in dcp.
                               642

-------
                            Table V-4

               ELECTROLYTE USE AND DISCHARGE RATES

                (1/kkg of cathode copper produced)
                                  Production
*Spent elecrolyte is contract hauled.

NR - Present, but data not reported in dcp
Production
Normalized
Plant Code
22*
62
78*
207
220
670
Percent
Recycle
0
100
NR
NR
100
0
Normalized
Water Use
263.2
NR
NR
NR
NR
10,023
Discharge
Flow
263.2
0
1,499
1,124
0
10,023
                               643

-------
                            Table V-5

      WATER USE AND DISCHARGE RATES FOR SCRAP ANODE RINSING

                (1/kkg of cathode copper produced)
       Plant Code

            78

           670
Percent
Recycle

  100

  100
Production
Normalized
Water Use

    NR.

    NR
Production
Normalized
Discharge
   Flow

     0

     0
NR - Present, but data not reported in dcp
                               644

-------
                            Table V-6

    WATER USE AND DISCHARGE RATES FOR CASTING CONTACT COOLING

                       (1/kkg of copper cast)
                                  Production
*Contact cooling water is dry well injected

NR - Present, but data not reported in dcp.
Production
Normalized
Plant Code
15
16
17
18
21
22
23
26
35
36
37
49
50
52
55
58*
62
207
220
662
4508
9050
Percent
Recycle
0
0
0
100
100
0
100
100
100
100
NR
100
NR
100
100
0
100
0
99
0
0
0
Normalized
Water Use
148
925
1.45
NR
NR
21,586
NR
NR
NR
14,720
NR
6,070
NR
NR
NR
109
NR
12,614
23,700
4,100
917
109
Discharge
Flow
148
925
1.45
0
0
21,586
0
0
0
0
1,406
0
NR
0
0
109
0
12,614
237
4,100
917
109
                               645

-------
                            Table V-7

        WATER USE AND DISCHARGE RATES FOR CASTING WET AIR
                        POLLUTION CONTROL

                      (1/kkg of copper cast)
            36

            37

            78
Percent
Recycle

  100

  NR

    0
Production
Normalized
Water Use_

   NR

   NR

    337
Production
Normalized
Discharge
   Flow

      0

    281

    337
NR - Present, but data not reported in dcp.
                               646

-------


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                                       SETTLING
                                         DISCHARGE
                                                   59
                                           DISCHARGE
                                                 Q.105 MGD
 FIGURE  v-l  -SAMPLING SITES AT SECONDARY COPPER
               PLANT A
                        668

-------
 RUNOFF
   SLAG
  MILLING
 8 RUNOFF
   SLAG

GRANULATION
 CONTACT
 COOLING
  WATER
NON-CONTACT
 COOLING
  WATER
  SOURCE
   CITY
   WATER
             /\
              104
O.OI3MGD
                              GRIT
                              BASIN
               102
                    ,
                             HOLDING
                              LAGOON
                                             DISCHARGE
                                   LIME  ADDITION
                                  MIXING- SETTLING
                                     TRI-MEDIA
                                     FILTRATION
                                       ACID-
                                  NEUTRALIZATION
             101
                               POSSIBLE RECYCLE
                                     HOLDING
                                       TANK
                                                      0.071 MGD
                                                DISCHARGE
   FIGURE v-
     SAMPLING SITES AT SECONDARY COPPER
     PLANT B
                          669

-------
              BALL MILL
                WASTE
                WATER
SOURCE
  CITY
 WATER
               CONTACT
               COOLING
                WATER
      SETTLING
                                           /\
                                           120
DISCHARGE
               0.005 MGD
                            /\
                             121
                       DISCHARGE
O.OI5MGD
 FIGURE  v-3  -SAMPLING  SITES AT SECONDARY COPPER
              PLANT C
                      670

-------
  CITY
 WATER
MAKE-UP
               FURNACE
               SCRUBBER
                 INGOT
                COOLING
               CONTACT
                 BALL
                MILLING
SETTLING
  POND
  NO. i
     0.019 MGO
SETTLING
  POND
  NO. 2
                                     0.027 MGD
                                                v
                                             SETTLING
                                               POND
                                               NO. 3
                                  RECYCLE
  FIGURE v-4  -SAMPLING SITES AT SECONDARY COPPER
               PLANT D
                       671

-------
 WASTE  HaO
   FROM
ELECTROLYTIC
  PROCESS
  GENERAL

 CLEANING
   STORM

   RUNOFF
                        COPPER PRECIPITATE
                                t
                     019
                  —0—H
                  0.029 MGD
CEMENTATION

   TANK
             018
           0.029 MGD
                              SCRAP
                               IRON
DISCHARGE
   FIGURE  v-5  - SAMPLING SITES  AT SECONDARY COPPER
                  PLANT E
                         672

-------
                   SECONDARY COPPER SUBCATEGORY

                            SECTION VI

                SELECTION OF POLLUTANT PARAMETERS
Section V of this supplement presented data from secondary copper
plant sampling visits and subsequent chemical analyses.  This
section examines that data and discusses the selection or exclu-
sion of pollutants for potential limitation.  The legal basis for
the exclusion of toxic pollutants under Paragraph 8(a) of the
Settlement Agreement is presented in Section VI of the General
Development Document.

Each pollutant selected for potential limitation is discussed in
Section VI of the General Development Document.  That discussion
provides information concerning where the pollutant originates
(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 describes the analysis that was
performed to select or exclude pollutants for further considera-
tion for limitations and standards.  Pollutants will be selected
for further consideration if they are present in concentrations
treatable by the technologies considered in this analysis.  The
treatable concentrations used for the toxic metals were the
long-term performance values achievable by lime precipitation,
sedimentation, and filtration.  The treatable concentrations for
the toxic organics were the long-term performance values
achievable by carbon adsorption (see Section VII of the General
Development Document - Combined Metals Data Base).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS

This study considered samples from the secondary copper subcate-
gory for three conventional pollutant paramters (oil and grease,
total suspended solids, and pH) and six nonconventional pollutant
parameters (aluminum, ammonia, chemical oxygen demand, chloride,
fluoride, total organic carbon, and total phenols).

CONVENTIONAL POLLUTANT PARAMETERS SELECTED

The conventional pollutants and pollutant parameters selected for
consideration for limitation in this subcategory are:
                               673

-------
     total suspended solids (TSS)
     oil and grease
     pH

Total suspended solids ranged from 3 to 8,790 mg/1.  Twelve of 12
samples had concentrations above that achievable by identified
treatment technology (2.6 mg/1).  Furthermore, most of the tech-
nologies used to remove toxic metals do so by precipitating the
metals.  A limitation on total suspended solids ensures that
sedimentation to remove precipitated toxic metals is effectively
operating.  Therefore, total suspended solids is selected for
consideration for limitation.

Oil and grease concentrations in the wastewaters sampled ranged
from 2 to 180 mg/1 in 10 samples.  Residue concentration is the
principal source of these pollutants.  The concentration in 2 of
the 10 samples exceeded the treatable concentration (10 mg/1).
Thus, this pollutant is selected for consideration for
limitation.

The pH values observed ranged from 1.5 to 7.0.  Effective removal
of toxic metals by precipitation requires careful control of pH.
Therefore, pH is considered for limitation in this subcategory.

TOXIC POLLUTANTS

The frequency of occurrence of the toxic pollutants in the
wastewater samples taken is presented in Table VI-1.  These data
provide the basis for the categorization of specific pollutants,
as discussed below.  Table VI-1 is based on the raw wastewater
data from streams 2, 104, 58, 19, and 121 (see Section V).  Mis-
cellaneous wastewater and treatment plant samples were not con-
sidered in the frequency count.

TOXIC POLLUTANTS NEVER DETECTED

Paragraph 8(a)(iii) of the Revised Settlement Agreement allows
the Administrator to exclude from regulation those toxic
pollutants not detectable by Section 304(h) analytical methods or
other state-of-the-art methods.  The toxic pollutants listed
below were not detected in any wastewater samples from this sub-
category; therefore, they are not selected for consideration in
establishing regulations:

       2.  acrolein
       3.  acrylonitrile
       5.  benzidine
       7.  chlorobenzene
                               674

-------
 8.  1,2,4-trichlorobenzene
 9.  hexachlorobenzene
11.  1,1,1-trichloroethane
12.  hexachloroethane
13.  1,1-dichloroethane
14.  1,1,2-trichloroethane
16.  chloroethane
17.  DELETED
18.  bis(2-chloroethyl) ether
19.  2-chloroethyl vinyl ether
20.  2-chloronaphthalene
21.  2,4,6-trichlorophenol
22.  parachlorometa cresol
24.  2-chlorophenol
28.  3,3'-dichlorobenzidiene
31.  2,4-dichlorophenol
32.  1,2-dichloropropane
33.  1,3-dichloropropylene
34.  2,4-dimethylphenol
35.  2,4-dinitrotoluene
36.  2,6-dinitrotoluene
37.  1,2-diphenylhydrazine
38.  ethylbenzene
40.  4-chlorophenyl phenyl ether
41.  4-bromophenyl phenyl ether
42.  bis(2-chloroisopropyl) ether
43.  bis(2-chloroethoxy) methane
45.  methyl chloride
46.  methyl bromide
47.  bromoform
48.  dichlorobromomethane
49.  DELETED
50.  DELETED
51.  chlorodibromomethane
52.  hexachlorobutadiene
53.  hexachlorocyclopentadiene
54.  isophorone
56.  nitrobenzene
57.  2-nitrophenol
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
65.  phenol
72.  benzo(a)anthracene
73.  benzo(a)pyrene
79.  benzo(ghi)perylene
                         675

-------
      80.  fluorene
      82.  dibenzo(a,h)anthracene
      83.  ideno(l,2,3-cd)pyrene
      88.  vinyl chloride
      89.  aldrin
      90.  dieldrin
      91.  chlordane
      92.  4-4'-DDT
      93.  4-4'-DDE
      94.  4-4'-ODD
      95.  alpha-endosulfan
      96.  beta-endosulfan
      97.  endosulfan sulfate
      98.  endrin
      99.  endrin aldehyde
     100.  heptachlor
     101.  heptachlor epoxide
     102.  alpha-BHC
     103.  beta-BHC
     104.  gamma-BBC
     105.  delta-BHC
     106.  PCB-1242  (a)
     107.  PCB-1254  (a)
     108.  PCB-1221  (a)
     113.  toxaphene
     127.  thallium
     129.  2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)

(a) Reported together

TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION LEVEL

The provision of Paragraph 8(a)(iii) of the Revised Settlement
Agreement excluding from regulation those toxic pollutants which
are not detectable includes those pollutants whose concentrations
fall below EPA's nominal detection limit.  The toxic pollutants
listed below were never found above their analytical quantifica-
tion concentration in any wastewater samples from this subcate-
gory; therefore, they are not selected for consideration in
establishing regulations.

      15.  1,1,2,2-tetrachloroethane
      71.  dimethyl phthalate
      74.  benzo(b)fluoranthene (a)
      75.  benzo(k)fluoranthene (a)
     109.  PCB-1232 (b)
     110.  PCB-1248 (b)
     111.  PCB-1260 (b)
     112.  PCB-1016 (b)
     116.  asbestos

(a), (b) Reported together


                               676

-------
TOXIC POLLUTANTS PRESENT BELOW CONCENTRATIONS ACHIEVABLE  BY
TREATMENT

Paragraph 8(a)(iti) of the Revised Settlement Agreement also
allows the exclusion of toxic pollutants which were  detected  in
quantities too small to be effectively reduced by  technologies
known to the Administrator.  The pollutants  listed below  are  not
selected for consideration in establishing limitations because
they were not found in any wastewater samples from this subcate-
gory above concentrations considered achievable by existing or
available treatment technologies.  These pollutants  are discussed
individually following the list.

       4.  benzene
      10.  1,2-dichloroethane
      86.  toluene
     114.  antimony
     117.  beryllium
     121.  cyanide
     123.  mercury
     126.  silver

Benzene was detected above its analytical quantification  limit in
one of ten samples from five plants; however, this sample  concen-
tration  was below the concentration achievable by identified
treatment technology (0.05 mg/1).  Therefore, benzene is  not
considered for limitation.

1,2-Dichloroethane was detected above its analytical quantifica-
tion limit in two of ten samples from five plants; however, these
sample concentrations were below that attainable by  treatment.
Therefore, 1,2-dichloroethane is not selected for  limitation.

Toluene was detected above its analytical quantification  limit in
two of ten samples from five plants; however, these  sample  con-
centrations were below that attainable by treatment.  Therefore,
toluene is not selected for limitation.

Antimony was detected above its analytical quantification  limit
in three of thirteen samples from five plants; however, these
sample concentrations were below that attainable by  treatment.
Therefore, antimony is not selected for limitation.

Beryllium was detected above its analytical quantifaction  limit
in eight of thirteen samples from five plants; however, these
sample concentrations were below that attainable by  treatment.
Therefore, beryllium is not selected for limitation.

Cyanide was detected above its analytical quantification  limit in
six of eleven samples from four plants; however, these sample
                               677

-------
concentrations were below that attainable by treatment.  There-
fore, cyanide is not selected for limitation.

Mercury was detected at, or above, its 0.0001 mg/1 analytical
quantification limit in thirteen of thirteen samples from  five
plants.  All of the values are below the 0.026 mg/1 concentration
considered achievable by identified treatment technology.
Therefore, mercury is not considered for limitation.

Silver was detected above its analytical quantification limit in
three of ten samples from four plants; however, these sample con-
centrations were below that attainable by treatment.  Therefore,
silver is not selected for limitation.

TOXIC POLLUTANTS DETECTED IN A SMALL NUMBER OF SOURCES

Paragraph 8(a)(iii) allows for the exclusion of a toxic pollutant
if it is detectable in the effluent from only a small number of
sources within the subcategory and it is uniquely related  to only
those sources.  The following pollutants were not selected  for
limitation on this basis.

       1.  acenapthene
       6.  carbon tetrachloride
      23.  chloroform
      25.  1,2-dichlorobenzene (a)
      26.  1,3-dichlorobenzene (a)
      27.  1,4-dichlorobenzene (a)
      29.  1,1-dichloroethylene
      30.  1,2-trans-dichloroethylene
      39.  fluoranthene
      44.  methylene chloride
      66.  bis(2-ethylhexyl) phthalate
      67.  butyl benzyl phthalate
      68.  di-n-butyl phthalate
      69.  di-n-octyl phthalate
      70.  diethyl phthalate
      76.  chrysene
      78.  anthracene (b)
      81.  phenanthrene (b)
      84.  pyrene
      85.  tetrachloroethylene
     115.  arsenic
     125.  selenium

(a), (b) Reported together

Although these pollutants were not selected for consideration in
establishing nationwide limitations, it may be appropriate, on a
case-by-case basis, for the local permitter to specify effluent
limitations.
                               678

-------
Acenapthene was found above its analytical quantification limit
in two of twelve samples from five plants.  The detected con-
centrations were 0.019 mg/1 and 0.036 mg/1 in the spent elec-
trolyte wastewater sample.  Both of these values are above the
concentration considered achievable by identified technology.
However, since the third sampling date at the plant showed a "not
detected" value, acenapthene is not considered for limitation
because it is believed to be unique to that particular plant and
is not expected to be a common pollutant in spent electrolyte
wastewater.

Carbon tetrachloride was found above its analytical quantifica-
tion limit in just one of ten samples from four plants.  The
reported value was 0.116 mg/1; this pollutant was not detected in
any of the other nine samples.  Because it was found in just one
sample, carbon tetrachloride is not considered for limitation.

Chloroform, a common laboratory solvent, was detected above its
analytical quantification limit in all ten samples from four
plants.  However, it was only found above the concentration con-
sidered achievable by identified technology in five of the ten
samples, ranging from 1.11 mg/1 to 1.19 mg/1.  Concentrations
above the analytical concentration limit in four blanks (0.070
mg/1, 0.181 mg/1, 0.127 mg/1, and 0.043 mg/1) analyzed raise the
likelihood of sample contamination.  Also, in the dcp, all of the
secondary copper plants indicated that this pollutant was either
known or believed to be absent.  Chloroform, therefore, is not
selected for consideration for limitation.

The toxic pollutants 1,2-dichlorobenzene, 1,3-dichlorobenzene,
and 1,4-dichlorobenzene are not clearly separated by the analyt-
ical protocol used in this study; thus, they are reported
together.  The sum of these pollutants was found above its ana-
lytical quantification limit in two of twelve samples from five
plants.  The detected concentrations were 0.117 mg/1 and 0.113
mg/1 in the spent electrolyte wastewater sample.  Both of these
values are above the cncentration considered achievable by iden-
tified technology.  However, since the third sampling day at the
plant showed a  not detected" value, 1,2-dichlorobenzene, 1,3-di-
chlorobenzene, and 1,4-dichlorobenzene are not considered for
limitation because they are believed to be unique to that parti-
cular plant and are not expected to be common pollutants in spent
electrolyte wastewater.

1,1-dichloroethylene was found in concentrations above its ana-
lytical quantification limit in two of ten samples from four
plants.  The values were 0.038 mg/1 and 0.667 mg/1.  Only one of
these samples had a concentration above the 0.1 mg/1 concentra-
tion considered achievable by identified treatment technology.
Because it was found above a treatable concentration in only one
sample, 1,1-dichloroethylene is not considered for limitation.
                               679

-------
1,2-trans-dichloroethylene was found in concentrations above its
analytical quantification limit in three of ten samples from four
plants, with values ranging from 0.012 mg/1 to 0.157 mg/1.  Only
one of the three samples had a concentration above the 0.1 mg/1
concentration considered achievable by identified treatment tech-
nology.  Because it was found above a treatable concentration in
only one sample, 1,2-trans-dichloroethylene is not considered for
limitation.

Fluoranthene was found above its analytical quantification limit
in two of twelve samples from five plants.  The detected concen-
trations were 0.069 mg/1 and 0.258 mg/1 in the spent electrolyte
wastewater sample.  One of these values is above the concentra-
tion considered achievable by identified technology.  However,
since the third sampling day at the plant showed a "not detected"
value, fluoranthene is not considered for limitation because it
is believed to be unique to that particular plant and is not
expected to be a common pollutant in spent electrolyte
wastewater.

Methylene chloride was found above its analytical quantification
limit in two of ten samples from four plants.  The detected con-
centrations were 0.64 mg/1 and 0.58 mg/1.  Since it was found
above the concentration considered achievable by identified tech-
nology in only two samples, methylene chloride is not considered
for limitation.

Bis(2-ethylhexyl) phthalate was found above its analytical quan-
tification limit in 11 of 12 samples from five plants.  The con-
centrations observed ranged from 0.019 to 0.4 mg/1.  The presence
of this pollutant is not attributable to materials or processes
associated with the secondary copper subcategory.  It is commonly
used as a plasticizer in laboratory and field sampling equipment.
EPA suspects sample contamination as the source of this pollu-
tant.  Therefore, bis(2-ethylhexyl) phthalate is not considered
for limitation.

Butyl benzyl phthalate was found above its analytical quantifica-
tion limit in two of 12 samples from five plants.  The concentra-
tions ranged from 0.011 to one mg/1.  The presence of this pol-
lutant is not attributable to materials or processes associated
with the secondary copper subcategory.  It is commonly used as a
plasticizer in laboratory and field sampling equipment.  EPA
suspects sample contamination as the source of this pollutant.
Therefore, butyl benzyl phthalate is not considered for
limitation.
                               680

-------
Di-n-butyl phthalate was found above its analytical quantifica-
tion limit in six of 12 samples from five plants.  The concentra-
tions observed ranged from 0.012 to 0.4 mg/1.  Three of the  six
samples showed concentrations above the 0.025 mg/1 treatability
concentration.  The presence of this pollutant is not attributa-
ble to materials or processes associated with the secondary
copper subcategory.  It is commonly used as a plasticizer  in
laboratory and field sampling equipment.  EPA suspects sample
contamination as the source of this pollutant.  Therefore,
di-n-butyl phthalate is not considered for limitation.

Di-n-octyl phthalate was found above ts analytical quantification
limit in one of 12 samples from five plants.  The concentration
observed was 0.067 mg/1.  The presence of this pollutant is  not
attributable to materials or processes associated with the
secondary copper subcategory.  It is commonly used as a plasti-
cizer in laboratory and field sampling equipment.  EPA suspects
sample contamination as the source of this pollutant.  Therefore,
di-n-octyl phthalate is not considered for limitation.

Diethyl phthalate was found above its analytical quantification
limit in two of 12 samples from five plants.  The concentrations
observed were 0.042 mg/1 and 0.083 mg/1.  The presence of  this
pollutant is not attributable to materials or processes associ-
ated with the secondary copper subcategory.  It is commonly  used
as a plasticizer in laboratory and field sampling equipment.  EPA
suspects sample contamination as the source of this pollutant.
Therefore, diethyl phthalate is not considered for limitation.

Chrysene was detected above its analytical quantification  limit
in just one of 12 samples from five plants.  Since it was  found
in only one sample, chrysene is not considered for limitation.

The toxic pollutants anthracene and phenanthrene are not clearly
separated by the analytical protocol used in this study; thus,
they are reported together.  The sum of these pollutants was
measured at a concentration greater than the analytical quantifi-
cation limit in one of 12 samples from five plants.  The detected
concentration was 0.1 mg/1, which is greater than the concentra-
tion considered attainable by identified technology.  Because
they were found at a treatable concentration in only one sample,
anthracene and phenanthrene are not considered for limitation.

Pyrene was found above its analytical quantification limit in two
of 12 samples from five plants.  The detected concentrations were
0.159 mg/1 and 0.204 mg/1 in the spent electrolyte wastewater
sample.   Both of these values are above the concentration
considered achievable by identified technology.  However, since
the third sampling day at the plant showed a "not detected"
                               681

-------
value, pyrene is not considered for limitation because it is
believed to be unique to that particular plant and is not
expected to be a common pollutant in spent electrolyte
wastewater.

Tetrachloroethylene was found above its analytical quantification
limit in one of 10 samples from four plants.  The detected
concentration was 0.072 mg/1, which is greater than the
concentration considered attainable by identified technology.
Because it was found at a treatable concentration in only one
sample, tetrachloroethylene is not considered for limitation.

Arsenic was found above its analytical quantification limit in
seven of 13 samples taken from five plants.  Concentrations
ranged from 0.01 to one mg/1.  Only one sample contained a
concentration above the 0.34 mg/1 considered attainable by
identified technology.  Because it was found at a treatable
concentration in only one sample, arsenic is not considered for
limitation.

Selenium was found above its analytical quantification limit in
seven of 10 samples taken from four plants.  Concentrations
ranged from 0.005 to 0.5 mg/1.  Only two samples contained a
concentration above the 0.20 mg/1 considered attainable by
identified technology.  Because it was found at a treatable
concentration in only two samples, selenium is not considered for
limitation.

TOXIC POLLUTANTS SELECTED FOR FURTHER CONSIDERATION FOR
LIMITATION

The toxic pollutants listed below are selected for further con-
sideration in establishing limitations for this subcategory.  The
toxic pollutants selected are each discussed following the list.

      55.  naphthalene
      77.  acenaphthylene
      87.  trichlorethylene
     118.  cadmium
     119.  chromium
     120.  copper
     122.  lead
     124.  nickel
     128.  zinc

Naphthalene was found above its analytical quantification limit
in three of 12 samples  from five plants.  The concentrations
measured in the spent electrolyte were 0.042 mg/1, 5.0 mg/1, and
1.6 mg/1.  Two of those values are above the 0.05 mg/1 concentra-
tion attainable by identified treatment technology.  Because it
                               682

-------
is present at treatable concentrations in this spent electrolyte
stream, naphthalene is selected for further consideration for
regulation.

Acenaphthylene was found above its analytical quantification
limit in three of 12 samples from five plants.  The concentra-
tions measured in the spent electrolyte were 0.042 mg/1, 0.117
mg/1, and 0.113 mg/1.  All of these values are above the 0.01
mg/1 concentration available by identified treatment technology.
Because it is present at treatable concentrations in this spent
electrolyte stream, acenaphthylene is selected for further
consideration for regulation.

Trichloroethylene was found above its analytical quantification
limit in four of 10 samples from four plants.  The concentrations
measured in the residue concentration wastewater were 0.023 mg/1
and 0.058 mg/1.  Both of those values are above the 0.01 mg/1
concentration attainable by identified treatment technology.
Because it is present at treatable concentrations in this residue
concentration stream, trichloroethylene is selected for further
consideration for regulation.

Cadmium was measured above its analytical quantification limit in
10 of 13 samples, taken from five plants, with concentrations
ranging from 0.006 to 2.0 mg/1.  Seven samples were above the
0.049 mg/1 concentration attainable by identified treatment
technology.  Therefore, cadmium is selected for further consider-
tion for limitation.

Chromium was found above its analytical quantification limit in
11 of 13 samples, taken from five plants, with concentrations
ranging from 0.008 to 5.0 mg/1.  Eleven samples were above the
0.07 mg/1 concentration attainable by identified treatment
technology.  Therefore, chromium is selected for further
consideration for limitation.

Copper was measured above its analytical quantification limit in
all 13 samples, taken from five plants, with concentrations rang-
ing from 0.3 to 3,630 mg/1.  Twelve samples were above the 0.39
mg/1 concentration attainable by identified treatment technology.
Therefore, copper is selected for further consideration for
limitation.

Lead was found in concentrations above its analytical quantifica-
tion limit in all 13 samples taken from five plants, with
concentrations ranging from 0.2 to 40 mg/1.  All 13 samples
were above the 0.08 mg/1 concentration attainable by identified
treatment technology.  Therefore, lead is selected for further
consideration for limitation.
                               633

-------
Nickel was measured above its analytical quantification limit in
all 13 samples, taken from five plants, with concentrations
ranging from 0.007 to 530 mg/1.  Since nine samples were also
above the 0.22 mg/1 concentration attainable by identified
treatment technology, nickel is selected for further considera-
tion for limitation.

Zinc was measured above its analytical quantification concentra-
tion in all 12 samples taken from five plants, with concentra-
tions ranging from 0.7 to 300 mg/1.  All 12 samples were above
the 0.23 mg/1 concentration attainable by the identified treat-
ment technology.  Therefore, zinc is selected for further consid-
eration for limitation.
                               684

-------
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                   SECONDARY COPPER  SUBCATEGORY

                           SECTION VII

                CONTROL AND TREATMENT TECHNOLOGIES


The preceding sections of this supplement discussed  the waste-
water sources, flows, and characteristics of the wastewaters  from
secondary copper plants.  This section summarizes the description
of these wastewaters and indicates the treatment technologies
which are currently practiced by the secondary copper subcategory
for each waste stream.

TECHNICAL BASIS OF PROMULGATED BPT

EPA promulgated BPT effluent limitations for the secondary copper
subcategory on February 27, 1975 under Subpart F of  40 CFR Part
421.  These effluent limitations prohibit the discharge of pro-
cess wastewater pollutants into navigable waters, and are based
on control technologies for specific waste streams.  The best
practicable control technology for process wastewater generated
during the contact cooling of copper ingots, anodes, billets, or
shot is the elimination of this discharge through recycle and
reuse of all contact cooling water.  With the reuse  and recycle
of casting contact cooling water, the needs for solids and oil
removal would be dictated by plant operational procedures.
Removal of solids such as charcoal used to cover copper alloy
ingots and the oxide scale and mold wash from anode  casting
requires sedimentation and filtration before the water is reused.
The pond used for sedimentation will also provide cooling.
Alternately, a cooling tower can provide settling and cooling
capacity.

The best practicable control technology for process  wastewater
generated from the quenching and granulation of copper-rich slags
is the elimination of this discharge by the recycle  and reuse of
all slag granulation wastewater.  Suspended solids are removed by
sedimentation and filtration prior to recycle and reuse.  Alter-
nately, the molten slag may be air cooled after it has been cast
into slag pots for subsequent metal recovery by dry  methods.
When quenching and granulating depleted (waste) slags, the best
practicable control technology is the total recycle  and reuse of
this wastewater after treatment to reduce suspended  solids by
sedimentation and filtration.

The best practicable control technology for process  wastewater
generated during copper-rich slag milling and classifying
(residue concentration) is the elimination of this discharge by
either total recycle and reuse of this wastewater, or by melt-
agglomerating the metal in a blast, cupola, or rotary furnace.
                               689

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Prior to recycle and reuse, solids are removed by lime precipi-
tation, if necessary, sedimentation, and filtration.

The best practicable control technology for process wastewater
produced from furnace exhaust scrubbing is the elimination of
wastewater discharge by recycling all of the furnace scrubber
water.  Before recycling, the scrubber water is treated by
sedimentation and filtration or centrifugation.  Another alterna-
tive to the elimination of this waste stream is conversion to dry
air pollution control equipment.

The best practicable control technology for wastewater from elec-
trolytic refining is the elimination of this wastewater discharge
by treating the bleed stream from electrolytic cell operations,
so that it is suitable for reuse in other plant processes.  The
treatment consists of removal of copper by cementation with iron
metal, lime precipitation, and sand filtering this stream to
remove solids.  The resulting water is then discharged to a com-
bined process wastewater reservoir serving other plant water
needs.

The BPT effluent limitations contain a catastrophic stormwater
allowance.  This stormwater exemption states that a volume of
process wastewater in excess of the 10-year, 24-hour storm event
falling on a wastewater impoundment may be discharged.  This dis-
charge is not subject to effluent limitations.

The BPT effluent limitations also contain a net precipitation
exemption.  This exemption allows facilities to discharge once
per month, subject to concentation-based effluent limitations, a
volume of water equal to the difference between precipitation and
evaporation falling on an impoundment in that month.

CURRENT CONTROL AND TREATMENT PRACTICES

Control and treatment technologies are also discussed in general
in Section VII of the General Development Document.  The basic
principles of these technoloies and the applicability to waste-
water similar to that found in this subcategory are presented
there.  This section presents a summary of the control and treat-
ment 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 copper
subcategory is characterized by the presence pf the toxic metal
pollutants and suspended solids.  This analysis is supported by
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 treatable
concentrations, so these waste streams are commonly combined for
treatment to reduce the concentrations of these pollutants.
                               690

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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.

Six plants in this subcategory treat combined wastewater.  At
three of these plants, combined waste streams are settled in one
or more settling ponds and then completely recycled.  One plant
treats combined wastewater by screening, sedimentation in ponds,
and filtration, and combined wastewater is neutralized with
caustic prior to discharge at another plant.  At the remaining
plant, combined waste streams are treated by lime precipitation,
sedimentation, and filtration prior to discharge.

RESIDUE CONCENTRATION

Residue concentration wastewater is generated when the copper
value is recovered from reverberatory and rotary furnace slags,
and other residues such as drosses, skimmings, spills, and
sweepings, through wet milling and classifying.  Seven plants
generate this waste stream.  Five of these plants achieve zero
discharge of residue concentration wastewater through 100 percent
recycle.  One discharging plant does not recycle this waste
stream and the other discharging plant did not report its recycle
practices.

The residue concentration wastewater is treated by six of the
seven plants prior to recycle or discharge.  The treatment
schemes include the following:

     1.  Preliminary treatment consisting of acid neutralization,
         polymer flocculation, and sedimentation for residue
         concentration wastewater only.  Following preliminary
         treatment, the residue concentration wastewater is
         combined with other process wastewater and settled in
         lagoons, screened, filtered, and then completely
         recycled.

     2.  Sedimentation with lagoons, total recycle (combined
         treatment).

     3.  Filtration,  total recycle (no combined treatment).

     4.  Sedimentation with classifiers and jigs, screening,
         sedimentation with lagoons, total recycle (no combined
         treatment).

     5.  Sedimentation in lagoons, discharge (no recycle, or
         combined treatment).
                               691

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     6.  Grit removal for residue concentration wastewater,  and
         combined treatment consisting of lime precipitation,
         sedimentation, and filtration, followed by discharge
         (recycle practices not reported).

The seventh plant recycles 100 percent of this waste stream, but
did not report if the stream is treated prior to recycle.

Residue concentration wastewater is characterized by treatable
concentrations of suspended solids, and dissolved toxic metal
pollutants.

SLAG GRANULATION

This wastewater is generated when blast or cupola furnace  slag
is granulated with high pressure water jets, or in quench  pits.
Five plants generate a slag granulation waste stream.  Four  of
these plants practice complete recycle, and the remaining  plant
evaporates its slag granulation wastewater.  Prior to recycle,
the slag granulation wastewater is treated by one or more  of the
following steps:

     1.  Screening,
     2.  Settling ponds or basins, and
     3.  Filtration.

At two of the total recycle plants, the slag granulation water is
combined with other process wastewater when treated.

Slag granulation wastewater contains treatable concentrations of
dissolved metals and suspended solids.

REVERBERATORY AND ROTARY FURNACE WET AIR POLLUTION CONTROL

Wet air pollution control devices are used by five secondary
copper plants to contain metal oxide fumes and dust produced from
rotary and reverberatory furnace operations.  Three of the five
plants completely recycle this waste stream, and one plant recy-
cles 81 percent.  The remaining plant does not recycle this  waste
stream.  The control and treatment practices of the five plants
are as follows:

     1.  Settling ponds, total recycle;

     2.  Settling ponds (combined with other process wastewater),
         total recycle;

     3.  Settling tanks, centrifuge, total recycle;

     4.  Holding tank, 81 percent recycle, settling tanks,
         discharge; and
                               692

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     5.  Lime and caustic neutralization, flocculation with  iron
         salts and polymers, clarification, and filtration
         followed by discharge.

As shown above, only one of the five plants combines it  furnace
wet air pollution control water with other process wastewater  for
treatment.

Reverberatory and rotary furnace wet air pollution control water
is characterized by treatable concentrations of suspended solids
and dissolved toxic metals.

SCRAP ANODE RINSING

This wastewater is generated when anodes are removed from elec-
trolytic cells and rinsed before further processing.  Two plants
rinse scrap anodes.  Both plants recycle or reuse 100 percent  of
their scrap anode rinse water.  This wastewater is characterized
by treatable concentrations of suspended solids and dissolved
toxic metal pollutants.

SPENT ELECTROLYTE

Electrolyte is continuously circulated through thickeners and
filters to remove anode mud slimes, and recycled back through  the
electrolytic cells.  A bleed stream is necessary to prevent  the
build-up of nickel and copper in the electrolyte.  Usually,  nic-
kel or copper is recovered from the electrolyte bleed before
recycle or discharge.  Copper is recovered from the electrolyte
by cementation with iron.  In this process, scrap iron is added
to the spent electrolyte and the solution is heated to about
180°F, where copper precipitates from solution.  An alternate
method for recovering copper from solution is electrowinning.
Nickel is recovered by evaporating the electrolyte bleed to
produce nickel sulfate crystals and sulfuric acid.  Six plants in
the secondary copper subcategory have an electrolytic refining
process.  Two of those plants discharge spent electrolyte without
treatment.  One of those two plants contract hauls the spent
electrolyte.  At two plants, copper is cemented from an electro-
lytic bleed stream with iron, and the resulting solution is
either discharged (at one plant) or contract hauled (at the  other
plant).  The remaining two plants each achieve zero discharge of
spent electrolyte through the following treatment schemes:

     1.  An electrolyte bleed stream is electrowinned to recover
         copper and evaporated to recover nickel sulfate crystals
         and sulfuric acid.

     2.  An electrolyte bleed stream is evaporated to recover
         nickel sulfate and sulfuric acid.
                               693

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Spent electrolyte is acidic and contains treatable concentrations
of dissolved metals (particularly copper).

CASTING CONTACT COOLING

Contact cooling water is used by 22 plants in the secondary cop-
per subcategory.  As discussed in Section III, there are a
variety of methods for cooling the various types of castings.
In the case of ingots, anodes, and billets, the molten metal is
solidified by spray cooling, and then quenched in tanks.  Fin-
ished refined copper shapes are usually prepared by cooling the
molten metal by non-contact cooling techniques, and then quench-
ing the solidified metal.  Shot is manufactured by directing a
small stream of molten copper directly into a quench pit.

Eleven of the 22 plants which produce casting contact cooling
water achieve zero discharge through total recycle.  One achieves
zero discharge through dry well injection.  There are a variety
of control and treatment practices utilized by both zero dis-
charge and discharging plants.  These control and treatment
practices are as follows:

      1.  No recycle, discharge without treatment (five plants);

      2.  Partial recycle, caustic neutralization, discharge
         (one plant);

      3.  Cooling pond, partial recycle, settling pond, discharge
          (one plant);

      4.  Partial recycle through cooling towers (two plants);

      5.  99 percent recycle with a blowdown stream treated by
          lime precipitation, sedimentation, and filtration prior
          to discharge (one plant);

      6.  No treatment, total recycle (three plants);

      7.  Screening, total recycle (one plant);

      8.  Settling, total recycle (four plants);

      9.  Screening, settling, filtration, total recycle
          (one plant);

     10.  Settling pits, holding tanks, cooling tower, centri-
          fuge, total recycle (one plant);

     11.  Neutralization with lime, flocculation with polymers,
          settling, total recycle (one plant); and

     12.  No recycle, dry well injection (one plant).


                               694

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At five of the above plants,  casting  contact  cooling water  is
combined with other process wastewater when treated.

Casting contact cooling water is characterized  by  treatable con-
centrations of lead, zinc, copper,  and total  suspended  solids.

CASTING WET AIR POLLUTION CONTROL

Three plants control fumes from casting  operations  with wet air
pollution control devices.  One plant completely recycles casting
scrubber water after neutralization with caustic and settling,
and one plant contract hauls  a. casting scrubber water bleed
stream.  The remaining plant  discharges  a casting  scrubber  water
bleed stream after neutralization with caustic.

CONTROL AND TREATMENT OPTIONS CONSIDERED

Based on an examination of the wastewater sampling  data, three
control and treatment options that  effectively  control  the  pollu-
tants found in secondary copper wastewaters were selected for
evaluation.  These technology options are discussed below.

Reverse osmosis (Option F) is theoretically applicable  to waste-
waters generated in the secondary silver subcategory; however, it
is not demonstrated in the nonferrous metals  manufacturing  cate-
gory, nor is it clearly transferable.  Activated alumina adsorp-
tion (Option D) and activated carbon adsorption (Option E)  were
not considered for secondary  copper because pollutants  (arsenic,
flouride and the toxic organics) generally treatable  by these
technologies are not present  at treatable concentrations or in
quantities warranting control.

OPTION A

Option A for the secondary copper subcategory is equivalent to
the technology basis for the  promulgated pretreatment standards
for existing sources.  The Option A treatment scheme  consists of
chemical precipitation and sedimentation (lime  and  settle)
applied to combined 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.

OPTION C

Option C for the secondary copper subcategory consists  of all the
requirements of Option A (chemical precipitation and  sedimenta-
tion) plus multimedia filtration added to  the end of  the Option C
treatment scheme.   Multimedia  filtration  is used to  remove  sus-
pended solids,  including precipitates of  metals, beyond the con-
centration attainable by gravity sedimentation.  The  filter
                               695

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suggested is the gravity, mixed-media type, although other  forms
of filters such as rapid sand filters or pressure filters would
perform satisfactorily.

OPTION G

Option G for the secondary copper subcategory is based on total
recycle of all process wastewater through cooling towers and
holding tanks with lime precipitation and sedimentation treat-
ment.  The water obtained from the above treatment is of
sufficient quality for reuse in secondary copper operations.
                               696

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                   SECONDARY COPPER  SUBCATEGORY

                           SECTION VIII

            COSTS, ENERGY AND NONWATER QUALITY ASPECTS


As discussed in Section VII, EPA considered  three control  and
treatment technology options for the  secondary copper subcate-
gory.  The Agency considered costs in regard to  it's review  of
the promulgated PSES.  The first option, Option  A,  is equiva-
lent to the technology basis used for the promulgated PSES.
Option A is based on lime precipitation and  sedimentation  of
combined process wastewater.  The second option  considered,
Option C, includes lime precipitation and sedimentation  followed
by end-of-pipe polishing filtration.  The third  option con-
sidered, Option G, is equivalent to  the technology  basis used for
the promulgated BPT and BAT.

There are no costs associated with Option A  for  indirect dis-
chargers since these costs were included in  development  of the
promulgated PSES.  The costs associated with Option G, cooling
towers and holding tanks to achieve  zero discharge  of wastewater
pollutants were considered during the 1976 rulemaking.   These
costs are presented in, Supplemental  for Pretreatment to the
Interim Final Development Document for the Secondary Copper~Seg-
ment of the Nonferrous Metals Manufacturing  Point Source
Category, U.S. EPA, EPA 440/l-77/081d.The  Agency  concluded at
that time that the additional costs  associated with cooling
towers and holding tanks were not significant when  compared  to
the costs of implementing lime precipitation and sedimentation.

Wastes generated by secondary copper  can be  regulated as hazard-
ous.  However, the Agency examined the solid wastes that would be
generated at secondary copper plants  by the  suggested treatment
technologies and believes they are not hazardous wastes under the
Agency's regulations implementing Section 3001 of the Resource
Conservation and Recovery Act.  None  of these wastes are listed
specifically as hazardous.  Nor are  they likely  to  exhibit a
characteristic of hazardous wastes.   This judgment  is made based
on the recommended technology of lime precipitation, sedimenta-
tion and filtration.  By the addition of excess  lime during
treatment, similar sludges, specifically toxic metal bearing
sludges, generated by other industries such  as the  iron  and  steel
industry passed the Extraction Procedure (EP) toxicity test.  See
40 CFR 261.24.  Thus, the Agency believes that the  wastewater
sludges will similarly not be EP toxic if the recommended  tech-
nology is applied.
                               697

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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 genera-
tor standards would require generators of hazardous nonferrous
metals manufacturing wastes to meet conta.inerization, labeling,
recordkeeping, and reporting requirements; if plants dispose  of
hazardous wastes off-site, they would have to prepare a mani-
fest which would track the movement of the wastes from the gener-
ator'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 CRF 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),
47 FR 32274 (July 26, 1982).

Even if these wastes are not identified as hazardous, they still
must be disposed of in compliance with 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.  For more details, see Section VIII of the General
Development Document.

The proposed PSES technology should not substantially increase
the energy requirements of the existing PSES because of the addi-
tional pumping requirements for complete recycle.  To achieve the
proposed PSES, a typical indirect discharger will increase total
energy consumption by less than 1 percent of the energy consumed
for production purposes.

The Agency estimates that the NSPS and PSNS technology will,  in
general, require as much energy as the existing source limita-
tions .
                               698

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                   SECONDARY COPPER  SUBCATEGORY

                            SECTION  IX

     BEST PRACTICABLE CONTROL TECHNOLOGY  CURRENTLY AVAILABLE


EPA promulgated BPT effluent limitations  for  the  secondary  copper
subcategory on February 27, 1975 as  Subpart F of  40  CFR  Part  421.
EPA is not proposing any modifications to these limitations.
Under the BPT effluent limitations,  existing  point sources  may
not dishcarge process wastewater pollutants to  U.S.  waters.   The
zero discharge of process wastewater pollutants is achieved by
the application of lime precipitation, sedimentation,  and  filtra-
tion technology followed by the total recycle and reuse  of
treated water.  The BPT effluent limitations  include net precipi-
tation and catastrophic storm allowances.  A  process wastewater
impoundment which is designed, constructed and  operated  so  as to
contain the precipitation from the 10-year, 24-hour  rainfall
event as established by the National Climatic Center,  National
Oceanic and Atmospheric Admnistration, for the  area  in which  such
impoundment is located may discharge that volume  of  process
wastewater which is equivalent to the volume  of precipitation
that falls within the impoundment in excess of  that  attributable
to the 10-year, 24-hour rainfall event, when  such event  occurs.
Also, during any calendar month there may be  discharged  from  a
process wastewater impoundment either a volume  of process waste-
water equal to the difference between the precipitation  for that
month that falls within the impoundment and either the evapora-
tion from the pond water surface area for that  month,  or a  volume
of process wastewater equal to the difference between  the mean
precipitation for that month that falls within  the impoundment
and the mean evaporation from the pond water  surface area as
established by the National Climatic Center,  National  Oceanic and
Atmospheric Administration, for the  area  in which such impound is
located (or as otherwise determined  if no monthly data have been
established by the National Climatic Center), whichever  is
greater.

Process wastewater discharge pursuant to  the  net  precipitation
allowance shall comply with the following concentration-based
effluent limitations:
                               699

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                                   Effluent Limitations
   Effluent
Characteristic
Maximum for
Any One Day
Average of Daily Values
  for 30 Consecutive
Days Shall Not Exceed-
Total Suspended Solids
Copper
Zinc
Oil and Grease
pH
        Metric Units (mg/1)
        English Units (ppm)

   50                    25
    0.5                   0.25
   10                     5
   20                    10
  Within the range of 6.0 to 9.0
                               700

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                   SECONDARY COPPER SUBCATEGORY

                            SECTION X

        BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE


EPA promulgated BAT effluent limitations for the secondary copper
subcategory on February 27, 1975 as Subpart F of 40 CFR Part 421.
These BAT effluent limitations prohibit the discharge of process
wastewater pollutants into U.S. waters.  The zero discharge of
process wastewater pollutants is achieved by the application of
lime precipitaiton, sedimentation, filtration technology followed
by the total recycle and reuse of treated water.  The BAT efflu-
ent limitations include the same net precipitation and cata-
strophic storm allowances as the existing BPT effluent limita-
tions except the catastrophic storm is a 25-year, 24-hour rain-
fall event.

As discussed in Section IX of the General Development Document,
the Agency is modifying its approach to stormwater.  EPA is pro-
posing to modify the existing BAT effluent limitations for the
secondary copper subcategory to eliminate the existing net pre-
cipitation allowance.  The impoundments used for cooling and set-
tling process wastewater prior to recycle and reuse require much
smaller surface areas than the settling evaporative impoundments
for which the net precipitation discharge was allowed.  Since
cooling and settling impoundments have a much smaller surface
area than evaporative impoundments, the net precipitation on
these impoundments is small enough for secondary copper plants to
accommodate.  Cooling towers were costed for BAT in the 1975
rulemaking when a plant had insufficient existing cooling
impoundment capacity or cooling impoundments were not feasible
due to space limitations.   Thus, EPA is requiring that net
precipitation on cooling and settling impoundments be used in
secondary copper processes instead of being discharged.  The
proposed BAT effluent limitations are, therefore, zero discharge
of process wastewater pollutants to U.S. waters with allowances
for the 25-year, 24-hour storm.
                               701

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                   SECONDARY COPPER SUBCATEGORY

                            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 tech-
nology (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 technol-
ogies which reduce pollution to the maximum extent feasible.

EPA is proposing that NSPS for the secondary copper subcategory
be equal to zero discharge of process wastewater pollutants.  EPA
is also eliminating the allowance for catastrophic stormwater
discharge provided at BAT.  The Agency believes that new sources
can be constructed with cooling towers exclusively, and that the
cost of cooling towers instead of cooling impoundments is mini-
mal.  Some existing plants already use cooling  towers rather than
cooling impoundments.  Therefore, EPA believes  that NSPS, as
defined, does not constitute a barrier to entry for new plants.
                               703

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                   SECONDARY COPPER  SUBCATEGORY

                           SECTION XII

                      PRETREATMENT STANDARDS
INTRODUCTION

Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources  (PSES), which must be achieved
within three years of promulgation.   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 heavy 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 facili-
ties , 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 instal-
lation.  Pretreatment standards are to be technology-based,
analogous to the best available technology for removal of toxic
pollutants.

EPA promulgated PSES for the secondary copper subcategory on
December 15, 1976 as Subpart F  of 40  CFR Part 421.  The promul-
gated PSES allows a continuous  discharge of process wastewater
subject to specific limitations based on treatment with lime
precipitation and sedimentation.  Proposed BAT (and promulgated
BPT) for this subcategory require the zero discharge of process
wastewater pollutants to U.S. waters.  EPA is proposing to modify
PSES to eliminate the disparity between BAT and  PSES.  Accord-
ingly, EPA is proposing that PSES for the secondary copper sub-
category be zero discharge of process wastewater pollutants to
POTW.

This section describes the control and treatment technologies for
pretreatment of process wastewaters from existing sources and new
sources in the primary electrolytic copper refining subcategory.
Pretreatment standards for regulated  pollutants  are presented
based on the selected treatment technology.

TECHNICAL APPROACH TO PRETREATMENT

Before proposing pretreatment standards, the agency examines
whether the pollutants discharged by  the industry pass through
the POTW or interfere with the  POTW operations or its chosen
                               705

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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 percentage
removed nationwide by well-operated POTW meeting secondary
treatment requirements, is less than the percentage removed by
direct dischargers complying with BAT effluent limitations  guide-
lines for that pollutant.  (See generally, 46 FR at 9415-16
(January 28, 1981).)

This definition of pass through satisfies- two competing objec-
tives set by Congress:  (1) that standards for indirect dis-
chargers be equivalent to standards for direct dischargers, while
at the same time, (2) that the treatment capability and perfor-
mance of the POTW be recognized and taken into account in regu-
lating 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
the addition of large amounts of non-industrial wastewater.

PRETREATMENT STANDARDS FOR EXISTING SOURCES

In summary form, the treatment technologies considered for
secondary copper plants discharging to POTW are:

Option A is based on:

     o  Lime precipitation and sedmentation

Option C is based on:

     o  Lime precipitation and sedimentation
     o  Multimedia filtration

Option G is based on:

     o  Lime precipitation and sedimentation
     o  Multimedia filtration
     o  In-process flow reduction with cooling towers and
        holding tanks
     o  Total recycle and reuse of treated water

These three technology options for PSES are discussed in greater
detail below.  The first option considered (Option A) is identi-
cal to the technology basis for the existing PSES.  The remaining
                               706

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two options provide additional pollutant removal beyond that
achieved by Option A.

Option A

Option A for the secondary copper subcategory  is lime precipita-
tion and sedimentation  (lime and settle).  Lime precipitation  and
sedimentation removes metals and suspended solids  from process
wastewater by the addition of lime followed by sedimentation.

Option C

Option C for the secondary copper subcategory  consists of multi-
media filtration technology added to the end of the time precipi-
tation and sedimenation technology of Option A.  Multimedia fil-
tration is used to remove suspended solids, including precipi-
tates of metals, beyond 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 filers, would perform satisfactorily.

Option G

Option G consists of the lime precipitation and sedimentation
technology of Option A, followed by complete recycle and reuse of
the treated water.  In-process flow reduction  measures consisting
of the recycle of process wastewater through cooling towers or
holding tanks is also added for Option G.

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

As one means of evaluating each technology option, EPA developed
estimates of the pollutant reduction benefits  and  the compliance
costs associated with each option.  The methodologies are
described on the following pages.

POLLUTANT REDUCTION BENEFITS

A complete description of the methodology used to  calculate the
estimated pollutant reduction, or benefit, achieved by the appli-
cation of the various treatment options is presenteed in Section
X of the General Development Document.  In short,  sampling data
collected during the field sampling program were used to charac-
terize the major waste streams considered for  regulation.  At
each sampled facility, the sampling data was production normal-
ized 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 secondary copper subcategory.  By multiply-
ing 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.
                               707

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The volume of wastewater discharged after the application of each
treatment option was estimated by multiplying the regxilatory flow
determined for each unit process by the total subcategory produc-
tion.  The mass of pollutant discharged was then estimated by
multipylying 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,
referred to as the benefit, is simply the difference between the
estimated mass of pollutant generated within the subcategory and
the mass of pollutant discharged after application of the treat-
ment option.

The Agency varied this procedure slightly in computing estimated
BPT discharge in a subcategory where there is an existing BPT
limitation.  In this case, EPA took the mass limits from the BPT
limitations (for all pollutants limited at BPT) and multiplied
these limits by the total subcategory production (from dcp).
(The assumption is that plants are discharging a volume equal to
their BPT allowance times their production).  Where pollutants
are not controlled by existing BPT, EPA used the achievable
concentration for the associated technology proposed today, and
multiplied these concentrations by the total end-of-pipe dis-
charge of process wastewater for the subcategory (from dcp).  The
total of both these calculations represents estimated mass  load-
ings for the subcategory.  The pollutant reduction benefit  esti-
mates for the segment of the secondary copper subcategory
discharging to POTW are shown in Table XII-1.

COMPLIANCE COSTS

In estimating subcategory-wide compliance costs, the first  step
was to develop uniformly-applicable cost curves, relating the
total costs associated with installation and operation of waste-
water treatment technologies to plant process wastewater dis-
charge.  EPA applied these curves on a per plant basis, a plant's
costs—both capital, and operating and maintenance—being deter-
mined 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 cost, yielding the cost
of compliance for the subcategory.  These costs were used in
assessing economic achievability.  Option A represents no cost
since it is the technology basis for the existing PSES.  The
costs for cooling towers and hold tanks were considered for the
existing PSES rulemaking.  At that time, EPA concluded that the
additional cost was not significant.  Thus, Option G represents
no significant cost.  Costs were not determined for Option  C.
                               708

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PSES OPTION SELECTION

EPA has selected Option G as  the basis  for  PSES.   Option  G con-
sists of chemical precipitation and  sedimentation, with cooling
towers and holding tanks to achieve  zero  discharge of  process
wastewater pollutants.  Implementation  of Option  G would  remove
an estimated 4,837 kg of toxic pollutants over  estimated  current
discharge.  EPA believes that the  costs associated with instal-
ling cooling towers and holding tanks will  be insignificant.   In
addition, costs for cooling towers and  holding  tanks were con-
sidered during the 1976 PSES  rulemaking.

PSNS OPTION SELECTION

The technology basis for proposed  PSNS  is identical to NSPS and
BAT, which is zero discharge  of all  process wastewater pollutants
(including no allowance for catastrophic  stormwater discharges).
PSNS does not increase costs  compared to  PSES or  BAT,  and EPA
does not believe that PSNS will prevent the entry of new  plants.

VASTEWATER DISCHARGE RATES

Specific wastewater streams associated  with the secondary copper
subcategory are residue concentration wastewater,  slag granula-
tion, wastewater, reverberatory and  rotary  furnace wet air pollu-
tion control wastewater, spent electrolyte, scape anode rinsing
wastewater, casting contact cooling  wastewater  and casting wet
air pollution control wastewater.  None of  these  wastewater
streams will be allocated a discharge allowance for the proposed
PSES.  The zero discharge requirement will eliminate the  dispar-
ity between the existing PSES and  the promulgated and  proposed
BAT effluent limitations.  Each wastewater  stream is discussed
individually below.

RESIDUE CONCENTRATION

No discharge alowance is provided  for residue concentration for
proposed PSES.  Seven plants  in the  secondary copper subcategory
generate residue concentration wastewater.  The water  use and
discharge rates for residue concentration at these plants  are
shown in Table V-l.  As shown in Table V-l, five  of the seven
plants practice total recycle and reuse of this waste  stream,
while only two plants discharge the  residue concentration waste-
water.  The zero discharge of residue concentration wastewater is
based on the five plants who do not  discharge this wastewater.

SLAG GRANULATION

No discharge allowance is provided for  slag granulation for pro-
posed PSES.   Five plants in the secondary copper  subcategory
generate this waste stream.  The water use and discharge  rates
                               709

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for slag granulation at these plants are shown in Table V-2.  As
shown by Table V-2, all five plants practice total recycle and
reuse of this waste stream.  Accordingly, no discharge allowance
is provided for slag granulation.

REVERBERATORY AND ROTARY FURNACE WET AIR POLLUTION CONTROL

No discharge allowance is provided for reverberatory and rotary
furnace wet air pollution control for proposed PSES.  Five plants
in the secondary copper subcategory use wet air pollution control
on their rotary and reverberatory furnaces.  The production nor-
malized water use and discharge rates for reverberatory and
rotary furnace wet air pollution control of these plants are
shown in Table V-3.  Three of the five plants completely recycle
and reuse this waste stream.  In addition, 13 plants control
reverberatory and rotary furnace fumes and dust with dry air
pollution control devices.  Therefore, based on total recycle or
dry air pollution control, no discharge allowance is provided for
reverberatory and rotary furnace wet air pollution control for
proposed PSES.

SPENT ELECTROLYTE

No discharge allowance is provided for spent electrolyte for the
proposed PSES.  Six plants in the secondary copper subcategory
have an electrolyte refining process.  The production normalized
electrolyte use and discharge rates at these plants are shown in
Table V-4.  Four plants achieve zero discharge of spent electro-
lyte by either complete recycle (two plants) or by contract
hauling (two plants).  EPA believes that spent electrolyte is
suitable for reuse in other plant operations after treatment con-
sisting of cementation with iron (for copper recovery), lime pre-
cipitation, and sedimentation.  For this reason, and since four
of the six plants already achieve zero discharge for spent elec-
trolyte, a discharge allowance is not provided.

SCRAP ANODE RINSING

No discharge allowance is provided for scrap anode rinsing for
proposed PSES.  Two plants reported this waste stream.  The water
use and discharge rates for scrap anode rinsing at these plants
are shown in Table V-5.  Table V-5 shows that both of the plants
with scrap anode rinsing practice 100 percent recycle.  Accord-
ingly, a discharge allowance is not provided for scrap anode
rinsing.

CASTING CONTACT COOLING

No discharge allowance is provided for casting contact cooling
water.  Twenty-two plants use casting contact cooling water.  The
water use and discharge rates for casting contact cooling at
                               710

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these plants is shown in Table V-6.  As shown in Table V-6,  10 of
the 22 plants achieve zero discharge of this wastewater,  EPA
believes that the 12 plants which discharge this wastewater  can
also achieve zero discharge through recycle and reuse with cool-
ing towers and holding tanks.  Therefore, no discharge allowance
is provided for casting contact cooling water.

CASTING WET AIR POLLUTION CONTROL

No discharge allowance is provided for casting wet air pollution
control.  Three plants in the secondary copper subcategory use
wet air pollution control devices to control fumes from casting
melting furnaces or pouring.  The water use and discharge rates
for casting wet air pollution control are shown in Table V-7.
Table V-7 shows that one of the three plants completely recycle
and reuses this waste stream.  In addition, five plants use  dry
air pollution control devices to control fumes from casting  oper-
ations.  Therefore, based on total recycle or dry air pollution
control, no discharge allowance is provided for casting wet  air
pollution control.

STORMWATER AND PRECIPITATION ALLOWANCES

No discharge allowance is provided for catastrophic and net  pre-
cipitation stormwater for the proposed PSES and PSNS.  These
standards are based on the use of cooling towers and holding
tanks rather than cooling impoundments.

PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES

EPA is proposing zero discharge of process wastewater polluants
(with no net precipitation and catastrophic storm allowances) for
both PSES and PSNS for the secondary copper subcategory.
                               711

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                   SECONDARY COPPER SUBCATEGORY

                           SECTION XIII

          BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY


The 1977 amendments to the Clean Water Act added  Section  301(b)
(2)(E), establishing "best conventional pollutant  control  tech-
nology" (BCT) for discharge of conventional pollutants  from
existing industrial point sources.  Biochemical oxygen-demanding
pollutants  (8005), total suspended solids  (TSS),  fecal  coli-
form,  oil and grease (O&G), and pH have been designated as
conventional pollutants  (see 44 FR 44501).

BCT is not an additional limitation, but replaces  BAT for  the
control of conventional pollutants.  In addition  to the other
factors specified in Section 304(b)(4)(B), the Act requires that
limitations for conventional pollutants be assessed in  light of a
two-part cost-reasonableness test.  On October 29, 1982, the
Agency proposed a revised methodology for carrying out  BCT analy-
ses (47 FR 49176).  The purpose of the proposal was to  correct
errors in the BCT methodology originally established in 1977.

Part 1 of the proposed BCT test requires that the  cost  and level
of reduction of conventional pollutants by industrial dischargers
be compared with the cost and level of reduction  to remove the
same type of pollutants by publicly-owned treatment works  (POTW).
The POTW comparison figure has been calculated by  evaluating the
change in costs and removals between secondary treatment  (30 mg/1
BOD and 30 mg/1 TSS) and advanced secondary treatment (10 mg/1
BOD and 10 mg/1 TSS).  The difference in cost is divided by the
difference in pounds of conventional pollutants removed, result-
ing in an estimate of the "dollars per pound" of pollutant
removed; that is used as a benchmark value.  The proposed POTW
test benchmark is $0.30 per pound (1978 dollars).

Part 2 of the BCT test requires that the cost and  level of reduc-
tion of conventional pollutants by industrial dischargers be
evaluated internally to the industry.  In order to develop a
benchmark that assesses a reasonable relationship between cost
and removal, EPA has developed an industry cost ratio which
compares the dollar per pound of conventional pollutant removed
in going from primary to secondary treatment levels with that of
going from secondary to more advanced treatment levels.  The
basis of costs for the calculation of this ratio are the costs
incurred by a POTW.  EPA used these costs because:  they reflect
the treatment technologies most commonly used to remove conven-
tional pollutants from wastewater; the treatment  levels associ-
ated wth them compare readily to the levels considered  for
industrial dischargers, and the costs are the most reliable for
                               713

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the treatment levels under consideration.  The proposed industry
subcategory benchmark is 1.42.  If the industry figure for a sub-
category is lower than 1.43, the subcategory passes the BCT test.

The Agency usually considers two conventional pollutants in the
cost test, TSS and an oxygen-demanding pollutant.  Although both
oil and grease and BOD5 are considered to be oxygen-demanding
substances by EPA (see 44 FR 50733), only one can be selected in
the cost analysis to conform to procedures used to develop POTW
costs.  Oil and grease is used rather than BOD5 in the cost
analysis performed for nonferrous metals manufacturing waste
streams due to the common use of oils in casting operations in
this industry.

BPT is the base for evaluating limitations on conventional
pollutants (i.e., it is assumed that BPT is already in place).
The test evaluates the costs and removals associated with treat-
ment and controls in addition to that specified as BPT.

If the conventional pollutant removal cost of the candidate BCT
is less than the POTW cost, Part 1 of the cost-reasonableness
test is passed and Part 2 (the internal industry test) of the
cost-reasonableness test must be performed.  If the internal
industry test is passed, then a BCT limitation is promulgated
equivalent to the candidate BCT level.  If all candidate BCT
technologies fail both parts of the cost-reasonableness test, the
BCT requirements for conventional pollutants are equal to BPT.

BPT and BAT effluent limitations for secondary copper smelting
are zero discharge of process wastewater pollutants.  These
effluent limitations control the discharge of toxic and non-
conventional pollutants.  Likewise, they incidentally provide
adequate control of conventional pollutants.  Consequently, EPA
is not proposing BCT effluent limitations for secondary copper
smelting.
                               714

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                  SECONDARY ALUMINUM SUBCATEGORY

                            SECTION I

                     SUMMARY AND CONCLUSIONS


On April 8, 1974, EPA promulgated technology-based effluent limi-
tations guidelines and performance standards  for  the  secondary
aluminum smelting subcategory of the nonferrous metals manufac-
turing point source category.  Those regulations  included BPT,
BAT, NSPS, and PSNS limitations.  The main purpose of these
effluent guidelines and standards was to  limit the quantities of
total suspended solids, chemical oxygen demand, fluoride,
ammonia, aluminum, and copper, and the range  of pH found in
secondary aluminum smelting wastewater discharges.  On December
15, 1976, EPA promulgated technology-based pretreatment standards
for existing sources (PSES) in the secondary  aluminum subcate-
gory.  The main purpose of these standards was to limit the
quantities of ammonia, oil and grease, and the range of pH found
in secondary aluminum smelting wastewater discharges.

Since 1974, implementation of the technology-based effluent limi-
tations and standards has been guided by a series of settlement
agreements into which EPA entered with several environmental
groups, the latest of which occurred in 1979.  NRDC v. Costle, 12
ERG 1833 (D.D.C. 1979), aff'd and remd'd, EOF v. Costle, 14 ERG
2161 (1980).  Under the settlement agreements, EPA was required
to develop BAT limitations and pretreatment and new source per-
formance standards for 65 classes of pollutants discharged from
specific industrial point source categories,  including secondary
aluminum smelting.  The list of 65 classes was subsequently
expanded to a list of 129 specific toxic pollutants, and now
consists of 126 toxics.

Congress amended the Clean Water Act in 1977  to encompass many of
the provisions of the earlier settlement agreements, including
the list of 65 classes of pollutants.  As a result of the settle-
ment agreements and the Clean Water Act Amendments, EPA undertook
an extensive effort to develop technology-based BAT limitations
and pretreatment and new source performance standards for the
toxic pollutants.

EPA is proposing modifications to BAT, NSPS,  PSES and PSNS and
the establishment of BCT for this subcategory pursuant to the
provisions of the Settlement Agreement and Sections 301, 304,
306, and 307 of the Clean Water Act and its amendments.  Con-
sideration will be given to incorporation of  limits on priority
pollutant levels in discharges in these modified standards.  This
supplement provides a compilation and analysis of the background
material used to develop these effluent guidelines.
                               715

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The secondary aluminum subcategory is comprised of 55 plants.
Of the 55 plants, eight discharge directly to rivers, lakes, or
streams; 13 discharge to publicly owned treatment works (POTW);
and 34 achieve zero discharge of process wastewater.

EPA first studied the secondary aluminum subcategory to determine
whether differences in raw materials, final products, manufactur-
ing processes, equipment, age and size of plants, 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 waste-
waters, including toxic pollutants.

EPA also identified several distinct control and treatment
technologies (both in-plant and end-of-pipe) applicable to the
secondary aluminum subcategory.  The Agency analyzed both
historical and newly generated data on the performance of these
technologies, including their nonwater quality environmental
impacts (air quality impacts and 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 category.  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 employees affected,
and impact on price were estimated.  These results are reported
in a separate document entitled Economic Impact Analysis of
Proposed Effluent Limitations and Standards for the Nonferrous
Smelting and Refining Industry.

Based on consideration of the above factors, EPA identified vari-
ous control and treatment technologies which formed the basis  for
BPT and selected control and treatment appropriate for each set
of standards and limitations.  The mass limitations and standards
for BPT, BAT, NSPS, PSES, PSNS, and BCT are presented in Section
II.

For BAT, the Agency has built upon the BPT basis of lime precipi-
tation and sedimentation by adding in-process control technolo-
gies, preliminary treatment(of ammonia by steam stripping, and
multimedia filtration.  In-process control technologies include
recycle or reuse of process water from wet air pollution control
and metal contact cooling.  Filtration is added as an effluent
                               716

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polishing step to further reduce metals and suspended  solids  con-
centrations.  To meet the BAT effluent limitations based on this
technology, the secondary aluminum subcategory is estimated to
incur a capital cost of $1.6 million  (1978 dollars) and an annual
cost of $1.35 million (1978 dollars).

The best demonstrated technology (BDT), which is the technical
basis of NSPS, is equivalent to BAT.   In modifying BDT, EPA
recognizes 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 deter-
mined as the best demonstrated technology.  Treatment  of toxic
metals is based upon lime precipitation, sedimentation, and
filtration.  Oil skimming is included  for the control  of oil and
grease.

Pretreatment standards for existing sources are based  on the  same
technology as BAT.  The technology basis is in-process flow
reduction, ammonia steam stripping preliminary treatment, lime
precipitation, sedimentation, and multimedia filtration.  To meet
PSES, the secondary aluminum subcategory is estimated  to incur a
capital cost of $2.4 million (1978 dollars) and an annual cost of
$1.6 million (1978 dollars).  The Agency is proposing  alternative
concentration-based and mass-based PSES for this subcategory.
Mass-based standards ensure that dilution is not used  as a means
of achieving effluent limitations.  They are particulary impor-
tant when a limitation is based on flow reduction since flow
reduction must be measured as a reduction of mass discharged.
However, in the secondary aluminum subcategory flow reduction
over current discharge rates is minimal (0.2 percent).

For pretreatment standards for new sources, the technology basis
of in-process flow reduction, preliminary treatment, and end-of-
pipe technology is equivalent to NSPS.  As such, PSNS  are iden-
tical to NSPS for all waste streams.   Alternative mass-based  and
concentration-based PSNS are not proposed, since PSNS  includes
significant flow reduction (90 percent flow reduction  of direct
chill casting wastewater).

The best conventional technology (BCT) replaces BAT for the con-
trol of conventional pollutants.  The  technology basis of BCT is
preliminary treatment of selected waste streams by ammonia steam
stripping and oil skimming, and lime precipitation and sedimenta-
tion end-of-pipe technology.
                               717

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                  SECONDARY ALUMINUM SUBCATEGORY

                            SECTION II

                         RECOMMENDATIONS
1.   EPA has divided the secondary aluminum subcategory into
     seven subdivisions for the purpose of effluent limitations
     and standards.   These subdivisions are:

     (a)  Scrap drying wet air pollution control,
     (b)  Scrap screening and milling,
     (c)  Dross washing,
     (d)  Demagging wet air pollution control,
     (e)  Direct chill casting contact cooling,
     (f)  Stationary casting contact cooling, and
     (g)  Shot casting contact cooling.

2.   EPA promulgated BPT effluent limitations for the secondary
     aluminum subcategory on April 8, 1974, as Subpart C of 40
     CFR Part 421.  At this time, EPA is not proposing any modi-
     fications to BPT effluent limitations.  The BPT effluent
     limitations apply to discharges resulting from magnesium
     removal processes (demagging using either chlorine or
     aluminum fluoride) and wet residue processes.  BPT was
     promulgated based on the performance achievable by the
     application of chemical precipitation and sedimentation
     (lime and settle) technology.  The following BPT effluent
     limitations were promulgated for existing sources:

     (a)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties, which
          may be discharged by a point source subject to the
          provisions of this subpart and which uses water for
          metal cooling, after application of the best practi-
          cable control technology currently available:  There
          shall be no discharge of process wastewater pollutants
          to navigable waters.

     (b)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties which may
          be discharged by a point source subject to the provi-
          sions of this subpart and which uses aluminum fluoride
          in its magnesium removal process  ("demagging process"),
          after application of the best practicable control
          technology currently available:  There  shall be no
          discharge of process wastewater pollutants to navi-
          gable waters.
                               718

-------
      (c)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties con-
          trolled by this section, which may be discharged by
          a point source subject to the provisions of this
          subpart and which uses chlorine in its magnesium
          removal process, after application of the best
          practicable control technology currently available:
                   	Effluent Limitations	

   Effluent        Average of daily values for 30 consecutive
Characteristic	days shall not exceed	

                   Metric units  (kilograms per 1,000 kg
                             magnesium removed)
                   English units (Ibs per 1,000 Ibs
                   	magnesium removed)	

TSS                                  175
COD                                    6.5
pH                        Within the range of 7.5 to 9.0


     (d)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties which
          may be discharged by a point source subject to the
          provisions of this subpart and which processes resi-
          dues by wet methods, after application of the best
          practical control technology currently available:
                   	Effluent Limitations	

   Effluent        Average of daily values for 30 consecutive
Characteristic	days shall not exceed	

                   Metric units (kilograms per 1,000 kg
                             magnesium removed)
                   English units (Ibs per 1,000 Ibs
                   	magnesium removed)	

TSS                                    1.5
Fluoride                               0.4
Ammonia (as N)                         0.01
Aluminum                               1.0
Copper                                 0.003
COD                                    1.0
pH                       Within the range of 7.5 to 9.0
                               719

-------
3.   EPA is proposing to modify BAT based on the performance
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle,
     and filter) technology, along with preliminary treatment
     consisting of ammonia steam stripping for selected waste
     streams.  The following BAT effluent limitations are
     proposed for existing sources:

     (a)  Scrap Drying Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Lead                                    0             0
Zinc                                    0             0
Aluminum                                0             0
Ammonia (as N)                          00


     (b)  Scrap Screening and Milling
          BAT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0             0
Zinc                                    0             0
Aluminum                                0             0
Ammonia (as N)                          0             0


     (c)  Dross Washing
          BAT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80      978.12
Zinc                               11,085.36    4,564.56
Aluminum                           32,930.04   13,476.32
Ammonia (as N)                  1,445,444.0   636,864.80
                               720

-------
      (d)  Demagging Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Lead                                  80.0         72.0
Zinc                                 816.0        336.0
Aluminum                           2,424.0        992.0
Ammonia (as N)                   106,400.0     46,880.0


      (e)  Direct Chill Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

      Metric Units - mg/kkg of aluminum product from direct
                          chill casting
     English Units - Ibs/billion Ibs of aluminum product from
                       direct chill casting

Lead                                 199.90       179.91
Zinc                               2,038.98       839.58
Aluminum                           6,056.97     2,478.76
Ammonia (as N)                   265,867.0    117,141.40


      (f)  Stationary Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

    Metric Units - mg/kkg of aluminum produced from stationary
                             casting
    English Units - Ibs/billion Ibs of aluminum produced from
                        stationary casting

Lead                                   0            0
Zinc                                   0            0
Aluminum                               0            0
Ammonia (as N)                         00
                               721

-------
     (g)  Shot Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

   Metric Units - mg/kkg of aluminum produced from shot casting
    English Units - Ibs/billion Ibs of aluminum produced from
                           shot casting

Lead                                    0             0
Zinc                                    0             0
Aluminum                                0             0
Ammonia (as N)                          0             0


4.   EPA is proposing to modify NSPS based on the performance
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle, and
     filter) technology, along with preliminary treatment
     consisting of ammonia steam stripping and oil skimming for
     selected waste streams.   The following effluent standards
     are proposed for new sources:


     (a)  Scrap Drying Wet Air Pollution Control NSPS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Lead                                    0             0
Zinc                                    0             0
Aluminum                                0             0
Ammonia (as N)                          0             0
Oil and Grease                          0             0
TSS                                     0             0
pH                               Within the range of 7., 5 to 10.0
                                    at all times
                               722

-------
      (b)  Scrap Screening and Milling NSPS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0             0
Zinc                                    0             0
Aluminum                                0             0
Ammonia (as N)                          00
Oil and Grease                          0             0
TSS                                     0             0
pH                               Within the range of 7.5 to 10.0
                                    at all times


      (c)  Dross Washing NSPS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80        978.12
Zinc                               11,085.36      4,564.56
Aluminum                           32,930.04     13,476.32
Ammonia (as N)                  1,445,444.0     636,864.80
Oil and Grease                    108,680.0     108,680.0
TSS                               163,020.0     130,416.0
pH                              Within the range of 7.5 to
                                  10.0 at all times


      (d)  Demagging Wet Air Pollution Control NSPS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Lead                                   80.0          72.0
Zinc                                  816.0         336.0
Aluminum                            2,424.0         992.0
Ammonia (as N)                    106,400.0      46,880.0
Oil and Grease                      8,000.0       8,000.0
TSS                                12,000.0       9,600.0
pH                               Within the range of 7.5 to 10.0
                                    at all times
                               723

-------
     (e)  Direct Chill Casting Contact Cooling NSPS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Lead                                  199.90        179.91
Zinc                                2,038.98        839.58
Aluminum                            6,0.56.97      2,478.76
Ammonia (as N)                    265,867.0     117,141.40
Oil and Grease                     19,990.0      19,990.0
TSS                                29,985.0      23,988.0
pH                               Within the range of 7.5 to 10.0
                                    at all times


     (f)  Stationary Casting Contact Cooling NSPS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

    Metric Units - mg/kkg of aluminum produced from stationary
                             casting
    English Units - Ibs/million Ibs of aluminum produced from
                        stationary casting

Lead                                    0             0
Zinc                                    0             0
Aluminum                                0             0
Ammonia (as N)                          00
Oil and Grease                          0             0
TSS                                     0             0
pH                               Within the range of 7.5 to 10.0
                                    at all times
                               724

-------
     (g)  Shot Casting Contact Cooling NSPS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

   Metric Units - mg/kkg of aluminum produced from shot casting
       English Units - Ibs/billion Ibs of aluminum produced
                        from shot casting

Lead                                    0             0
Zinc                                    0             0
Aluminum                                0             0
Ammonia (as N)                          00
Oil and Grease                          0             0
TSS                                     0             0
pH                               Within the range of 7.5 to 10.0
                                    at all times
5.   EPA is proposing to modify PSES based on the performance
     acheivable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle,
     and filter) technology, along with preliminary treatment
     consisting of ammonia steam stripping for selected waste
     streams.  The following mass-based pretreatment standards
     are proposed for existing sources:

     (a)  Scrap Drying Wet Air Pollution Control PSES

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Lead                                    0             0
Zinc                                    0             0
Ammonia (as N)                          00

     (b)  Scrap Screening and Milling PSES

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0             0
Zinc                                    0             0
Ammonia (as N)                          0             0


                               725

-------
     (c)  Dross Washing PSES

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80        978.12
Zinc                               11,085.36      4,564.56
Ammonia (as N)                  1,445,444.0     636,864.80

     (d)  Demagging Wet Air Pollution Control PSES

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Untis - Ibs/billion Ibs of aluminum demagged

Lead                                   80.0          72.0
Zinc                                  816.0         336.0
Ammonia (as N)                    106,400.0      46,880.0

     (e)  Direct Chill Casting Contact Cooling PSES

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Lead                                  199.90        179.91
Zinc                                2,038.98        839.58
Ammonia (as N)                    265,867.0     117,141.40

     (f)  Stationary Casting Contact Cooling PSES

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                        stationary casting
       English Units - Ibs/billion Ibs of aluminum produced
                     from stationary casting

Lead                                    0             0
Zinc                                    0             0
Ammonia (as N)                          0             0
                               726

-------
    (g)  Shot Casting Contact Cooling PSES

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

   Metric Units - mg/kkg of aluminum produced from shot casting
    English Units - Ibs/billion Ibs of aluminum produced from
                           shot casting

Lead                                    0             0
Zinc                                    0             0
Ammonia (as N)                          00


6.   Alternatively, concentration-based standards are proposed
     for the modifications to PSES based on the same end-of-pipe
     technologies used for the proposed mass-based standards.
     The concentrations presented below apply to all process
     wastewater streams for which allowances were given under
     the mass-based standards proposed above.  The following
     concentration-based pretreatment standards are proposed for
     existing sources:


                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

                       Metric Units - mg/1
                       English Units - ppm

Lead                                    0.10          0.09
Zinc                                    1.02          0.42
Ammonia (as N)                        133            58.6


7.   EPA is proposing to modify PSNS based on the performance
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime,  settle,
     and filter) technology, along with preliminary treatment
     consisting of ammonia steam stripping for selected waste
     streams.  The following mass-based pretreatment standards
     are proposed for new sources:
                              727

-------
     (a)  Scrap Drying Wet Air Pollution Control PSNS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

                       Metric Units - mg/1
                       English Units - ppm

Lead                                    0             0
Zinc                                    0             0
Ammonia (as N)                          0             0


     (b)  Scrap Screening and Milling PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          0               0


     (c)  Dross Washing PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80          978.12
Zinc                               11,085.36        4,564.56
Ammonia (as N)                  1,445,444.0       636,864.80


     (d)  Demagging Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Lead                                   80.0            72.0
Zinc                                  816.0           336.0
Ammonia (as N)                    106,400.0        46,880.0
                              728

-------
     (e)  Direct Chill Casting Contact Cooling PSNS

                                   Maximunft for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Lead                                  199.90          179.91
Zinc                                2,038.98          839.58
Ammonia (as N)                    265,867.0       117,141.40


     (f)  Stationary Casting Contact Cooling PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of aluminum produced from stationary
                             casting
    English Units - Ibs/billion Ibs of aluminum produced from
                        stationary casting

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00


     (g)  Shot Casting Contact Cooling PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of aluminum produced from shot casting
    English Units - Ibs/billion Ibs of aluminum produced from
                           shot casting

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          0               0

8.   BCT is proposed based on the performance achievable by the
     application of chemical precipitation and sedimentation
     (lime and settle) technology, along with preliminary treat-
     ment consisting of ammonia steam stripping and oil skimming
     for selected waste streams.  The following BCT limitations
     are proposed for existing direct dischargers:
                               729

-------
     (a)  Scrap Drying Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Oil and Grease                          0             0
TSS                                     0             0
pH                               Within-the range of 7.5 to 10.0
                                    at all times
     (b)  Scrap Screening and Milling
          BCT EFFLUENT LIMITATIONS

                                     Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Oil and Grease                          0             0
TSS                                     0             0
pH                               Within the range of 7.5 to 10.0
                                    at all times
     (c)  Dross Washing
          BCT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Oil and Grease                     217,360.0    130,416.0
TSS                                445,588.0    217,360.0
pH                               Within the range of 7.5 to 10.0
                                    at all times
                              730

-------
     (d)  Demagging Wet Air Pollution control
          BCT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Oil and Grease                     16,000.0      9,600.0
TSS                                32,800.0     16,000.0
pH                               Within the range of 7.5 to 10.0
                                    at all times


     (e)  Direct Chill Casting Contact Cooling
          BCT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Oil and Grease                     39,980.0     23,988.0
TSS                                81,959.0     39,980.0
pH                               Within the range of 7.5 to 10.0
                                    at all times


     (f)  Stationary Casting Contact Cooling
          BCT EFFLUENT LIMITATIONS

                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                        stationary casting
       English Units - Ibs/billion Ibs of aluminum produced
                     from stationary casting

Oil and Grease                          0            0
TSS                                     0            0
pH                                      00
                                 Within the range of 7.5 to 10.0
                                    at all times
                               731

-------
      (g)  Shot Casting Contact Cooling
           BCT EFFLUENT LIMITATIONS
                                    Maximum for  Maximum for
Pollutant or Pollutant Property	Any One Day  Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                        shot casting
       English Units - Ibs/billion Ibs of aluminum produced from
                       shot casting

Oil and Grease                          0             0
TSS                                     0             0
pH                               Within the range of 7.5 to 10.0
                                    at all times
                              732

-------
                  SECONDARY ALUMINUM SUBCATEGORY

                           SECTION  III

                         INDUSTRY PROFILE
This section of the Secondary Aluminum Supplement describes  the
raw materials and processes used  in reducing  recycling  aluminum
and presents a profile of the secondary aluminum plants  identi-
fied in this study.  For a discussion of  the  purpose, authority,
and methodology for this study and a general  description of  the
nonferrous metals manufacturing category, refer to Section III of
the General Development Document.

DESCRIPTION OF SECONDARY ALUMINUM PRODUCTION

Secondary aluminum production involves two basic process steps:
pretreatment and smelting and refining.   A pretreatment  step is
required before smelting and refining operations can be  under-
taken because this industry uses  essentially  scraps  (much of
which is contaminated) for its raw material.  The two processes,
their components, and variations  are discussed below.   Figure
III-l represents a general flow diagram of the two process steps.

RAW MATERIALS

The secondary aluminum subcategory uses aluminum-bearing scrap to
produce metallic aluminum and aluminum alloys.  Much of  the  scrap
used is purchased from scrap dealers of industrial plants.   There
are five primary classifications  of scrap processed:  old sheet
and castings, new clippings and forgings, borings and turnings,
residues, and high iron.

New scrap is produced during the  manufacture  of a finished prod-
uct and originates from the aircraft industry, aluminum  formers,
and other manufacturing plants.   Old scrap (sheet and castings)
is comprised of worn out, damaged or obsolete articles  and
includes automobile parts, household items, and airplane parts.
Borings and turnings are by-products of the machining of cast-
ings, rods, and forgings by the aircraft  and  automobile  industry.
Residues consist of drosses, skimmings, and slags which  are
obtained from primary reduction plants, secondary smelting
plants, casting plants, and foundries.  Foil  from discarded
packaging constitutes a minor source of raw material for this
industry.  High iron aluminum scraps which are to be reused  in
the secondary aluminum subcategory require more extensive treat-
ment before smelting than other sources of scrap aluminum.

PRETREATMENT

Scrap pretreatment involves preparing the material for  further
processing and removing contaminants.  As Figure III-l  indicates,
                               733

-------
the scrap pretreatment process varies depending on the source  and
type of raw material being handled.  There is also variation in
the degree to which scrap is pretreated among facilities.  There
are three general methods of pretreating:  mechanical, hydro-
metallurgical, and pyrometallurgical, with the method used being
dependent on the type of scrap.  The mechanical method involves
shredding and classifying, baling, and milling and screening.
Hydrometallurgical treatment involves leaching with water, and
pyrometallurgical processing involves burning and drying and
sweating.  Depending on the type of raw material, pretreatment
may consist of a combination of these methods before smelting  and
refining is effected.

Old sheet, castings, and clippings preparation is a dry process
that can vary from no pretreatment to crushing and screening that
compacts the scrap.  New clippings and forgings usually require
little preparation other than sorting; however, they may be con-
taminated with cutting oils, and may require crushing and drying
to remove the oils.  Cable, which is not considered a major
source for the secondary aluminum subcategory, requires shredding
and classifying to remove the insulation and ferrous portions
from the aluminum.  The borings and burnings are also often
contaminated by cutting oils and require burning or drying to
remove that contaminant.  The entire procedure consists of
(1) crushing the borings and turnings to compact the scrap,
(2) heating the scrap in an oil or gas-fired rotary dryer to
remove organic material and water, (3) screening to remove
aluminum fines, and (4) magnetically removing the tramp iron.

Residues, such as drosses, skimmings, and slags, contain 10 to 30
percent aluminum, as well as oxides, carbides, nitrides, fluxing
salts, and other contaminants.  Metallic aluminum can be liber-
ated from the impurities using either dry or wet processes.  The
dry process consists of milling, screening, and magnetic separa-
tion for iron removal.  The wet process involves milling and
leaching with water to remove the contaminants.  The washed
material is then screened, dried, and passed through a magnetic
separator.  Heavy metallic skims, a minor source of aluminum,
require little pretreatment.

Foil, which is another minor source of raw material for the
subcategory, is usually pretreated by roasting to remove paper or
wax backings.  High iron content scrap often is subjected to
sweating treatment to remove impurities.  This process involves
placing the iron-contaminated aluminum in a sweating furnace.
This furnace has sloped sides and the molten aluminum flows down
the slope, leaving the higher melting point materials such as
iron behind.  Alternately, the high iron scrap also can be
purified by crushing it and removing the iron magnetically.
                               734

-------
SMELTING AND REFINING

The second step of the manufacturing  process  for  the  secondary
aluminum subcategory is smelting and  refining.  This  step  actu-
ally consists of five substeps:  charging  scrap to  the  furnace;
addition of fluxing agents; addition  of alloying  agents;
demagging or degassing; and skimming.

Charging of scrap into the furnace  can be  a batch process  or a
continuous process.  Each cycle, called a  "heat", will  vary  in
length depending on the process.  Charging wells  are  often
designed to permit the introduction of chips  and  scrap  below the
surface of a previously melted  charge called  a "heel.   This
design not only minimizes oxidation,  but provides for more
efficient application of pollution  control systems.

The next step is fluxing the molten charge.   There  are  two
general types of fluxes:  cover fluxes that are used  to reduce
oxidation of the melt by air, and solvent  fluxes  that react  with
contaminants such as nonmetallics, residues from  burned coatings,
and dirt to form insolubles which float on the surface  of  the
melt as slag.

Next, alloying agents are added to the melt in varying  amounts
according to production specifications.  Copper,  silicon,  man-
ganese, or zinc are typical alloys added.  Mixing the furnace
contents is necessary to assure uniform composition.  Nitrogen or
other inert gases may be injected to  aid in the mixing.  Magne-
sium is another alloying agent used.  However, scrap  aluminum,
received by the secondary aluminum smelters averages  about 0.3 to
0.5 percent magnesium, while the product line of  alloys produced
averages about 0.1 percent.  Therefore, after the furnace  is
fully charged and the melt brought up to the  desired  chemical
specification, it is usually necessary to  remove  the  excess
magnesium (known as "demagging").

Demagging is accomplished with  chlorine or chlorinating agents,
such as anyhdrous aluminum chloride or chlorinated  organics,  or
with aluminum fluoride.  Magnesium chloride or magnesium fluoride
is formed and collected in the  fluxing agents on  top  of the
molten melt.  As the magnesium  is depleted, chlorine  will  consume
aluminum and the excess aluminum chloride  or  aluminum fluoride
present volatilizes into the surrounding air  and  is a source of
air pollution.

Magnesium is the only metal removable from the alloy  in this
manner.  Other metal alloy levels must be  adjusted  by the
addition of either more aluminum (dilution) or more of  the metal.

Chlorination is performed at temperatures  between 760 and  815°C.
As a rule of thumb, the reaction requires  3.5 kilograms of
                               735

-------
chlorine per kilogram of magnesium removed.  Elemental  chlorine
gas is fed under pressure through tubes or lances to the bottom
of the melt.  As it bubbles through the melt, it reacts with
magnesium and aluminum to form chlorides, which float to the melt
surface where they combine with the fluxing agents and  are
skimmed off.  Because magnesium is above aluminum in the electro-
motive series, aluminum chloride will be reduced by any available
magnesium in the melt.  At the beginning of the demagging cycle,
the principal reaction product is magnesium chloride.  As magne-
sium is removed and there is less available for reaction with
chlorine, the reaction of chlorine with aluminum becomes more
significant, the reduction of the aluminum chloride by magnesium
becomes less likely, and the production of aluminum chloride,  a
volatile compound, becomes significant.  The aluminum chloride
escapes and considerable fuming results from the chlorination,
making ventilation and air pollution equipment necessary.  Con-
trol of fumes is frequently accomplished by wet scrubbing and,
thus, is a source of water contamination.

Aluminum fluoride as a demagging agent reacts with the magnesium
to form magnesium fluoride, which in turn combines with the flux
on top of the melt, where it is skimmed off.  In practice, about
4.3 kilograms of aluminum fluoride are required per kilogram of
magnesium removed.  The air contaminants exist as gaseous fluor-
ides or as fluoride dusts and are a source of air pollution.   The
fluorides are controlled by either dry or wet methods.  When dry
scrubbing is used, a solid waste is generated.  When wet scrub-
bing is used, both water pollution and solid waste are generated.

Some facilities in the secondary aluminum subcategory are not
limited by a magnesium content in their product, particularly  the
deoxidant manufacturers, and they make no attempt to remove
magnesium.  Therefore, these plants do not contend with the
magnitude of fumes produced by demagging, and as a result, do  not
require extensive air pollution control equipment and related
water usage.

In the skimming step, the dross or slag, with its associated
impurities, is skimmed from the molten aluminum.  The cooled slag
is stored for shipment to a residue processor, recycled, or dis-
carded.

The product line(s) of each smelter can be categorized  as
specification alloy ingots, billets, hot metal, notched bar,
shot, and hardeners.  Specification alloy ingots, used  by
foundries for casting, are the most important products of the
secondary aluminum subcategory.  Cooling can be done with either
contact or noncontact cooling water, and air cooling is also
used.
                               736

-------
Plants using contact cooling water  recycle  systems  generate
intermittent discharges  (accompanied with sludge  removal).   Bil-
lets, manufactured  for use  in  extrusion  plants, are cooled with
noncontact water that is recycled.  Sometimes  the molten  metal  is
poured directly into preheated crucibles, then shipped  while
still in a molten form.  No water is used.  Notched bar molds may
be air or water cooled with either  contact  or  noncontact  water.

Direct chill casting is  characterized  by continuous solidifica-
tion of the metal while  it  is  being poured.  The  length  of  an
ingot cast using this method is  determined  by  the vertical dis-
tance it is allowed to drop rather  than  by  mold dimensions.  Mol-
ten aluminum is tapped from the  melting  furnace and flows through
a distributor channel into a shallow mold.  Noncontact  cooling
water circulates within  this mold,  causing  solidification of the
aluminum.  The base of the mold  is  attached to a  hydraulic cylin-
der which is gradually lowered as pouring continues.  As  the
solidified aluminum leaves the mold, it  is  sprayed  with contact
cooling water to reduce  the temperature  of  the forming  ingot.
The cylinder continues to descend into a tank  of  water, causing
further cooling of  the ingot as  it  is  immersed.   When the cylin-
der has reached its lowest position, pouring stops  and  the ingot
is lifted from the  pit.  The hydraulic cylinder is  then raised
and positioned for  another casting  cycle.

Aluminum shot is also used as  a  deoxidant in the  steel  industry.
Molten metal is poured into a  vibrating  feeder, where droplets  of
molten metal are formed  through  perforated  openings.  The drop-
lets are cooled in  a quench tank.  Water is generally recycled,
and periodic sludge removal is required.

PROCESS WASTEWATER SOURCES

The primary areas of water use and wastewater  production  in  the
secondary aluminum subcategory are  as  follows:

  1.  Scrap drying wet air pollution control,
  2.  Scrap screening and milling,
  3.  Dross washing,
  4.  Demagging wet air pollution control,  and
  5.  Direct chill casting contact  cooling  water,
  6.  Stationary casting contact cooling water,
  7.  Shot casting contact cooling water.

OTHER WASTEWATER SOURCES

There are other waste streams  associated with  the production of
secondary aluminum.   These waste streams include  but are not
limited to:
                               737

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  1.  Maintenance and cleanup water, and
  2.  Stormwater runoff.

These wastes are not considered as 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, or are best handled by the appropriate permit
authority on a case-by-case basis under the authority of Section
403(a) of the CWA.

AGE, PRODUCTION, AND PROCESS PROFILE

Figure III-2 shows the location of 55 secondary aluminum
reduction plants.  Most of the plants are located in the eastern
United States, and most are in urban areas near raw materials and
markets.  The notations within the states indicated the type of
discharge the facilities use, direct (D), indirect (I), or zero
(Z).

The data in Table III-l indicate that the majority of facilities
(30) are less than 25 years old, reflecting relative recent
development of this industry.

In addition, most facilities practice zero discharge with only 15
percent (eight facilities) discharging directly.

The data in Table III-2 indicate that the majority of facilities
produce between 5,000 and 20,000 tons per year of secondary alum-
inum.  Table III-3 provides a summary of the plants having the
various secondary aluminum processes; the number of plants
generating wastewater from the processes is also shown.
                               738

-------
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                                               739

-------
                 Table III-2

 PRODUCTION RANGES FOR SMELTERS AND REFINERS
    OF THE SECONDARY ALUMINUM SUBCATEGORY
 Production Ranges
for 1976 (Tons/Year)          Number of Plants

       0 -  2,500                     5

   2,501 -  5,000                     8

   5,001 - 10,000                    19

  10,001 - 20,000                    13

  20,001 - 30,000                     4

      30,000 +                        4

      No Data                        __2

Total Number of                      55
Plants in Survey
                    740

-------
                           Table III-3

  SUMMARY OF SUBCATEGORY PROCESSES AND ASSOCIATED WASTE STREAMS
           Process

Scrap Drying Air Pollution
Control

Scrap Screening and Milling

Dross Classification

Dust Air Pollution Control

Demagging Air Pollution
Control

Casting
 Number of
Plants With
  Process

    28
    21

     5

    16

    34


    54
    Number of
Plants Reporting
   Generating
   Wastewater
       2

       4

       0

      19


      38
*Through reuse or evaporative practices, a plant may "generate"
 a wastewater from a particular process but not discharge it.
                               741

-------
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          SECONDARY ALUMINU1-1 SMELTING PROCESS
                                742

-------
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743

-------
                  SECONDARY ALUMINUM SUBCATEGORY

                            SECTION IV

                        SUBCATEGORIZATION
As discussed in Section IV of the General Development Document,
the nonferrous metals manufacturing category has been subcate-
gorized to take into account pertinent industry characteristics,
manufacturing process variations, wastewater characteristics, and
a number of other factors which affect the ability of the facili-
ties to achieve effluent limitations.  This section summarizes
the factors considered during the designation of the secondary
aluminum subcategory and its related subdivisions.

FACTORS CONSIDERED IN SUBCATEGORIZATION

The following factors were evaluated for use in determining
appropriate subcategories for the nonferrous metals subcategory:

      1.  Metal products, co-products, and by-poducts;
      2.  Raw materials;
      3.  Manufacturing processes;
      4.  Product form
      5.  Plant location
      6.  Plant age;
      7.  Plant size;
      8.  Air pollution control methods;
      9.  Meterological conditions;
     10.  Treatment costs;
     11.  Nonwater quality aspects;
     12.  Number of employees;
     13.  Total energy requirements; and
     14.  Unique plant characteristics.

Evaluation of all factors that could warrant subcategorization
resulted in the designation of the secondary aluminum subcate-
gory.  Three factors were particularly important in establishing
these classifications:  the type of metal produced, the nature of
raw materials used, and the manufacturing processes involved.

In Section IV of the General Development Document, each of these
factors is described, and the rationale for selecting metal prod-
uct, manufacturing processes, and raw materials as the principal
factors used for subcategorization is discussed.  On this basis,
the nonferrous metals manufacturing category (phase I) was
divided into 12 subcategories, one of them being secondary
aluminum.
                                745

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Secondary aluminum was identified as a subcategory in  a  final
regulation promulgated in 1974 and BPT, BAT, NSPS, and PSNS
effluent limitations and standards were established  for  the
secondary aluminum subcategory. The purpose of this  study is to
support proposed modifications to the BAT, NSPS, and PSNS
regulations.

FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY ALUMINUM SUBCATE-
GORY

The factors listed above were each evaluated when establishing
the secondary aluminum subcategory and its subdivisions.  In the
discussion that follows, the factors will be described as they
pertain to this particular subcategory.  Subcategorization of the
entire nonferrous metals industry and evaluation of  the  factors
used in this process are discussed in Section IV of  the  General
Development Document.

The rationale for subdividing the secondary aluminum sxibcategory
considers the diversity in source of raw materials,  the  use of
certain manufacturing processes by only a few facilities, and the
differences in available technologies for final product:  process-
ing (i.e., contact cooling water, air cooling, and noncontact
cooling water).

The raw materials used by secondary aluminum plants  are  either
solid scraps (clippings and forgings, borings and turnings, and
old sheet and castings) or residues from aluminum reduction and
smelting.  Since all secondary smelters use the various?  types of
scraps at one time or another, the type of scrap cannot  be used
as a basis for Subcategorization.  However, many plants  have
scrap drying operations.  Most of these plants use air pollution
control devices in this process.  A few plants use wet scrubbers
which produce wastewater.  Some facilities also use  water in
scrap screening and milling, generating wastewater.  Therefore,
scrap drying wet air pollution control and scrap screening and
milling should be considered subdivisions.

Furnace residue processing to recover aluminum can produce a
wastewater stream with treatable pollutant concentrations.  Five
facilities process furnace residues, and four of these use water
for the processing.  Since this process produces a potemtially
contaminated waste stream it has been identified as  a  subdivi-
sion.

Plants practicing magnesium removal (demagging), use either a
chlorine or aluminum fluoride process.  The demagging process
requires air pollution control devices to minimize fuming.  Wet
scrubbing can be practiced with both types of demagging  and the
resulting scrubber water is usually treated by pH adjustment and
settling.
                                746

-------
Thirty-four plants demag, 19 generate wastewater  from  fume  scrub-
bing.  Because the demagging process can produce  a contaminated
wastewater, it has been  identified  as a subdivision within  the
secondary aluminum subcategory.

The final secondary aluminum process step is casting.  The  tech-
nique for cooling the aluminum  into various shapes varies within
the subcategory and with the product.  Air cooling, water contact
cooling, and water noncontact cooling are all used.  When water
contact cooling is used, the cooling water is frequently recy-
cled.  However, a blowdown stream may be necessary to  dissipate
the buildup of dissolved solids.  This blowdown stream may  have,
in addition to treatable dissolved  solids, oil and grease and
phenolics, depending on whether lubricants are used in casting.
This manufacturing process with has also been considered for
subdivision within the secondary aluminum subcategory.

Within the secondary aluminum subcategory the processes that
produce the wastewaters discussed previously, residue  processing
wastewater, demagging fume scrubber liquors, and  contact cooling
water, are not all present at all facilities.  Some facilities
may have one, others combinations of two, and still others  all
three.  The building block approach used in this  regulation
accommodates these differences by establishing limitations  and
standards for each waste stream.

Limitations will be based on specific flow allowances  for the
following subdivisions:

     1.   Scrap drying wet air pollution control,
     2.   Scrap screening and milling,
     3.   Dross washing,
     4.   Demagging wet air pollution control,
     5.   Direct chill casting contact cooling,
     6.   Stationary casting contact cooling, and
     7.   Shot casting contact cooling.

Other Factors

The other factors considered in this evaluation either supported
the establishment of the secondary  aluminum subcategory and its
subdivisions or were shown to be inappropriate bases for subcate-
gorization.  Air pollution control  methods, treatment  costs,
nonwater quality aspects, and total energy requirements were each
shown to be functions of the selected subcategorization factors--
metal product, raw materials, and production processes.  As such,
they support the method of subcategorization which has been
applied.   As discussed in Section IV of the General Development
Document, certain other factors, such as plant age, plant size,
and the  number of employees, were also evaluated  and determined
to be inappropriate as bases for subcategorization of  nonferrous
metal plants.
                                747

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PRODUCTION NORMALIZING PARAMETERS

The effluent limitations and standards developed in this document
establish mass limitations on the discharge of specific pollutant
parameters.  To allow these regulations to be applied to plants
with various production capacities, the mass of pollutant dis-
charged must be related to a unit of production.  This factor,
the production normalizing parameter (PNP), is developed in
conjunction with subcategorization.

In general, the amount of aluminum produced by the respective
manufacturing process is used as the PNP.  The PNP's for the
seven secondary aluminum subdivisions are:
            Subdivision

    Scrap drying wet air pollution
    control

    Scrap screening and milling
3.  Dross washing

4.  Demagging wet air pollution
    control

5.  Direct chill casting contact
    cooling

6.  Stationary casting contact
    cooling

7.  Shot casting contact cooling
           PNP

kkg of aluminum scrap
dried

kkg of scrap screened or
milled

kkg of dross washed

kkg of aluminum demagged


kkg of aluminum cast


kkg of aluminum cast


kkg of aluminum cast
                                748

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                  SECONDARY ALUMINUM  SUBCATEGORY

                            SECTION V

             WATER USE AND WASTEWATER CHARACTERISTICS
This section describes the characteristics of wastewater  associ-
ated with the  secondary aluminum  subcategory.   Data used  to  quan-
tify wastewater flow and pollutant concentrations are presented,
summarized, and discussed.  The contribution of specific  produc-
tion processes to the overall wastewater discharge from secondary
aluminum plants is identified whenever possible.

Section V of the General Development Document contains a  detailed
description of the data sources and methods of  analysis used  to
characterize wastewater from the  nonferrous metals category.  To
summarize this information briefly, two principal data sources
were used:  data collection portfolios (dcp) and field sampling
results.  Data collection portfolios, completed for each  of  the
secondary aluminum plants, contained information regarding waste-
water flows and production levels.

In order to quantify the pollutant discharge from secondary  alum-
inum plants, a field sampling program was conducted.  A complete
list of the pollutants considered and a summary of the techniques
used in sampling and laboratory analyses are included in  Section
V of the General Development Document.  Wastewater samples were
collected in two phases:  screening and verification.  The first
phase, screen sampling, was to identify which toxic pollutants
were present in the wastewaters from production of the various
metals.  Screening samples were analyzed for 128 of the 129  toxic
pollutants and other pollutants deemed appropriate.  (Because the
analytical standard for TCDD was  judged to be too hazardous  to be
made generally available, samples were never analyzed for this
pollutant.  There is no reason to expect that TCDD would  be  pres-
ent in secondary aluminum wastewater.)  A total of 10 plants were
selected for screening sampling in the nonferrous metals  manufac-
turing category, one of those being a secondary aluminum  plant.
In general, the samples were analyzed for three classes of pollu-
tants:  toxic organic pollutants, toxic metal pollutants, and
criteria pollutants (which includes conventional and
nonconventional pollutants).

As described in Section IV of this supplement,  secondary  aluminum
plants have been categorized into seven subdivisions.  Differ-
ences in the wastewater characteristics associated with these
subdivisions are to be expected.  For this reason, wastewater
streams corresponding to each subdivision are addressed
separately in the discussions that follow.
                               749

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WASTEWATER SOURCES. DISCHARGE RATES, AND CHARACTERISTICS

The wastewater data presented in this section were evaluated  in
light of production process information compiled during this
study.  As a result, it was possible to identify the principal
wastewater sources in the secondary aluminum subcategory.  The
result of this analysis is summarized in the following,
discussion.

Sources of process wastewater within the secondary aluminum
subcategory include:

     1.  Scrap drying wet air pollution control,
     2.  Scrap screening and milling,
     3.  Dross washing,
     4.  Demagging wet air pollution control,
     5.  Direct chill casting contact cooling water,
     6.  Stationary casting contact cooling, and
     7.  Shot casting contact cooling.

Data supplied by data collection portfolio responses were evalu-
ated, and two flow-to-production ratios were calculated for each
stream.  The two ratios, water use and wastewater discharge flow,
are differentiated by the flow value used in calculation.  Water
use is defined as the volume of water or other  fluid (e.g., emul-
sions, lubricants) required for a given process per mass of
aluminum product and is therefore based on the  sum of recycle and
make-up flows to a given process.  Wastewater flow discharged
after pretreatment or recycle (if these are used) is used in
calculating the production normalized flow—the volume of waste-
water discharged from a given process to further treatment,
disposal, or discharge per mass of aluminum produced.  Differ-
ences between the water use and wastewater flows associated with
a given stream result from recycle, evaporation, and carryover on
the product.  The production values in calculation correspond to
the production normalizing parameter, PNP, assigned to each
stream, as outlined in Section IV.  The production normalized
flows were compiled by stream type.  Where appropriate, an
attempt was made to identify factors that could account for
variations in water use.  This information is summarized in this
section.  A similar analysis of factors affecting the wastewater
values is presented in Sections X, XI, and XII, where representa-
tive BAT, BDT, and pretreatment discharge flows are selected  for
use in calculating the effluent limitations and standards.  As an
example, casting cooling water wastewater flow  is related to  the
casting production.  As such, the discharge rate is expressed in
liters of cooling water per metric ton of casting production
(gallons of cooling water wastewater per ton of aluminum
reduction production).
                               750

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In order to quantify the concentrations  of pollutants  present  in
wastewater from secondary aluminum plants, wastewater  samples
were collected at five plants.  Diagrams  indicating  the  sampling
sites and contributing production processes are  shown  in Figures
V-l to V-5.

The reported water use and discharge rates for the seven
identified secondary aluminum wet operations are given in Tables
V-l, 2, 3, 5, 7, and 8.  The raw wastewater sampling data for  the
facilities sampled are presented in Tables V-4, V-6, and V-9.
Table V-lO shows combined raw wastewater  data from demagging
scrubbing and casting contact cooling.

The treated wastewater data are shown in  Tables V-ll through
V-14.  The locations and stream codes of  the samples taken  are
identified on the process flow diagrams  in Figures V-l through
V-5.  Where no data is listed for a specific day of  sampling,  the
wastewater samples for the stream were not collected.  If the
analysis did not detect a pollutant in a  waste stream, the
pollutant was omitted from the table.

The data tables include some samples measured at concentrations
considered not quantifiable.  The base neutral extractable, acid
extractable, and volatile organics are considered not  quantifia-
ble at concentrations equal to or less than 0.010 mg/1.  Below
this concentration, organic analytical results are not quanti-
tatively accurate; however, the analyses  are useful  to indicate
the presence of a particular pollutant.   The pesticide fraction
is considered not quantifiable at concentrations equal to or less
than 0.005 mg/1.  Nonquantifiable results are designated in the
tables with an asterisk (double asterisk  for pesticides).

These detection limits shown on the data  tables  are  not  the same
as 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.

The statistical analysis of data includes some samples measured
at concentrations considered not quantifiable.  Data reported  as
an asterisk are considered as detected but below quantifiable
concentrations, and a value of zero is used for averaging.  Toxic
organic, nonconventional and conventional pollutant  data reported
with a "less than" sign are considered as detected,  but  not fur-
ther quantifiable.  A value of zero is also used for averaging.
If a pollutant is reported as not detected, it is excluded  in
                               751

-------
calculating the average.  Finally, toxic metal values reported as
less than a certain value were considered at not detected, and a
value of zero is used in the calculation of the average.  For
example, three samples reported as ND, *, and 0.021 mg/1 have an
average value of 0.010 mg/1.

In the following discussion, water use and field sampling data
are presented for each operation.  Appropriate tubing or back-
ground blank and source water concentrations are presented with
the summaries of the sampling data.  Figures V-l through V-5 show
the location of wastewater sampling sites at each facility.  The
method by which each sample was collected is indicated by number,
as follows:

     1     one-time grab
     2     24-hour manual composite
     3     24-hour automatic composite
     4     48-hour manual composite
     5     48-hour automatic composite
     6     72-hour manual composite
     1     72-hour automatic composite

In the data collection portfolios, plants were asked to specify
the presence or absence of any of the toxic pollutants in their
effluent.  All of the plants that responded to this portion of
the questionnaire indicated that they believed the toxic organic
pollutants to be absent.  One exception, hexachloroethane, was
reported believed to be present by two plants.  This compound was
not detected in any sample taken in the subcategory.

Although most of the plants indicated that the toxic metals were
believed absent from their effluent, some plants did report that
specific pollutants were known present or believed present.  The
responses for the toxic metals are shown below.

                    Known     Believed   Believed     Known
     Pollutant     Present     Present    Absent      Absent

     Antimony         -           -        23
     Arsenic          -           1        22
     Beryllium        1           -        22
     Cadmium          5           1        17
     Chromium        11           5         7
     Copper           1                    21            1
     Lead             7           6        10
     Mercury          2           2        18            1
     Nickel           5           2        16
     Selenium         -           -        22            1
     Thallium         -                    22            1
     Zinc             968
                               752

-------
SCRAP DRYING WET AIR POLLUTION CONTROL

Some scrap may require drying to  remove  cutting  oils  and water.
The scrap drying procedure consists of crushing  the scrap  and
heating in an oil or gas-fired rotary drier.  Twenty-nine  secon-
dary aluminum plants control air  emissions  from  scrap drying
operations.  Three use scrubbers, while  26  use baghouses.   Scrap
drying wet air pollution control  water use  and discharge rates
are shown in Table V-l in liters  per metric ton  (gal/ton)  of
aluminum scrap dried.

The Agency did not sample raw wastewater  from scrap drying scrub-
bers, however, this wastewater should contain total suspended
solids and treatable concentrations of aluminum.  Toxic organic
pollutants should not be present  at measurable concentrations.

SCRAP SCREENING AND MILLING

Only two plants reported using water in  scrap screening and
milling.  The discharge rates from these  plants  is presented in
Table V-2 in liters per metric ton of aluminum scrap  screened or
milled.  The Agency did not sample scrap  screening and milling
wastewater but this waste stream  should  contain  total suspended
solids and treatable concentrations of aluminum, as well as toxic
metals.

DROSS WASHING WASTEWATER

Sources of aluminum for the secondary aluminum subcategory are
residues such as drosses, skimmings, and  slags.  These residues
must be pretreated before charging them  into the smelters.  Both
wet and dry processes are available for  this pretreatment.  Of
the facilities surveyed, four used the wet  process to prepare
their residues for smelting.  The quantities of  water used and
discharged, expressed as a function of dross processed, are
presented in Table V-3.

The data in Table V-4 indicate that this  wastewater contains
treatable concentrations of suspended solids (aluminum oxide and
hydrated alumina), ammonia, and metals such as aluminum, copper,
and lead.

DEMAGGING WET AIR POLLUTION CONTROL

As discussed in Section III, demagging consists  of injecting
chlorine or aluminum fluoride into the molten aluminum to  remove
magnesium.  During this process,  heavy fuming can result.   Of the
26 facilities supplying data, 17 use a wet  process to control
emissions from this process,, while nine use a dry process.  The
flow rates used and discharged, expressed in liters/metric ton of
aluminum demagged, for those plants with  wet air pollution
control are shown in Table V-5.
                               753

-------
The wastewaters associated with this scrubbing operation may  con-
tain treatable concentrations of suspended solids and chlorides
or fluorides, and of heavy metals.  Table V-6 summarizes the
wastewater sampling data associated with demagging scrubber
wastes.

DIRECT CHILL CASTING CONTACT COOLING WATER

The usual final step in the secondary aluminum subcategory
process is often the casting of molten aluminum into ingots,
bars, billets, shot, etc.  Air cooling, noncontact water cooling,
and contact water cooling are used to cool the molten metal.  The
contact cooling water is often recycled, but a blowdown stream is
often required.  There is a trend in the secondary aluminum sub-
category toward converting to direct chill casting.  However,
limited data were available for direct chill casting from the dcp
survey.  Wastewater use and discharge data were taken from both
the aluminum forming and the primary aluminum subcategories
because information does not indicate a significant difference in
the amount of water required for direct chill casting cooling in
a secondary aluminum, primary aluminum, and aluminum forming
plant.  Tables V-7 and V-8 present the production normalized
water use and discharge rates expressed in liters per metric  ton
of aluminum cast.  In all, 27 primary aluminum plants and 61
aluminum forming plants have direct chill casting operations.
Recycle of the contact cooling water is practiced at 30 aluminum
forming and 18 primary aluminum plants.  Of these, 12 plants
indicated that total recycle of this stream made it possible  to
avoid any discharge of wastewater; however, the majority of the
plants discharge a bleed stream.

In direct chill casting, lubrication of the mold is required  to
ensure proper ingot quality.  Lard or castor oil is usually
applied before casting begins and may be reapplied during the
drop.  Much of the lubricant volatilizes on contact with the
molten aluminum, but contamination of the contact cooling water
with oil and oil residues does occur.  Oil and grease, and chlor-
ides are usually present, along with a measurable concentration
of suspended solids.  Table V-9 presents casting contact cooling
water sampling data from a secondary aluminum plant.  The type of
casting operation sampled was not reported with the data.  How-
ever, the types of casting considered in this subcategory will
have similar wastewater pollutant characteristics because the raw
material, aluminum, is the same in each operation.

STATIONARY CASTING COOLING

In the stationary casting method, molten aluminum is poured into
cast iron molds and the generally allowed to air cool.  The
Agency is aware of the use of spray quenching to quickly cool the
surface of the molten aluminum once it is cast into the molds;
                               754

-------
however, this water evaporates on contact with the molten alumi-
num.  This operation is similar throughout the secondary aluminum
and primary aluminum subcategories, and the aluminum forming
category, and no discharge of process water has been reported.

SHOT CASTING CONTACT COOLING

Contact cooling water is used for rapid quenching of molten metal
in deoxidizer shot production.  Specific casting methods used  in
the secondary aluminum subcategory were not differentiated in  the
data collection portfolios.  Therefore, specific water use and
wastewater characterization data were not available.  However,
the dcp survey showed that recycle and reuse of casting contact
cooling water is widely practiced in the secondary aluminum
subcategory.  Thirty-five plants reported generating casting
contact cooling water, 22 of those achieving zero discharge
through complete recycle or evaporation.  Suspended solids and
aluminum should be present in this water.
                               755

-------
                      Table V-l

    WATER USE AND DISCHARGE RATES FOR SCRAP DRYING
              WET AIR POLLUTION CONTROL

           (1/kkg of aluminum scrap dried)

                         Production      Production
              Percent    Normalized      Normalized
Plant Code    Recycle    Water Use     Discharge Rate
  00427           0        1,057           1,057

  04102         100        5,111               0

  00640         100          567.6             0
                         756

-------
                            Table V-2

        WATER USE AND DISCHARGE RATES FOR SCRAP SCREENING
                           AND MILLING

                 (1/kkg of aluminum scrap dried)
      Plant Code

        00296

        00301
Percent
Recycle

  100

  100
Production
Normalized
Water Use

  13,827

    NR
  Production
  Normalized
Discharge Rate

      0

      0
NR - Present, but data not reported in dcp.
                               757

-------
                            Table V-3

         WATER USE AND DISCHARGE RATES FOR DROSS WASHING

                     (1/kkg of dross washed)
      Plant Code

        04104

        04101

        04102

        04103
Percent
Recycle

   67

  100

  100

    0*
Production
Normalized
Water Use

  32,933

  78,840

  58,408

    NR
  Production
  Normalized
Discharge Rate

    10,868

         0

         0

         0
*Wastewater is 100 percent evaporated.

NR - Present, but data not reported in dcp
                              758

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-------
                            Table V-5

           WATER USE AND DISCHARGE RATES FOR DEMAGGING
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                   (1/kkg of aluminum demagged)
                               Production
Production
Plant Code
4104
0332
0037
0427
0333
0048
0018
0628
0326
0313
0296
0301
0319
0320
0329
0330
0532
0625
4209
Percent
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0
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0
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0
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0
100
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100
100
100
100
100
100
100
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1,956.24
1,867
1,370.2
476
577
339.6
326.0
283.5
223.3
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30,728
NR
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553.7
172.7
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Discharge Rate
1,956.24
1,867
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476
346
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0
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0
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0
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NR - Present, but data not reported in dcp.
                               762

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-------
                       Table V-7

           WASTER USE AND DISCHARGE RATES FOR
          DIRECT CHILL CASTING CONTACT COOLING
              (ALUMINUM FORMING CATEGORY)

                (1/kkg of aluminum cast)
Plant Code*

    1
    2
    3
    4
    5
    6
    7
    8
    9
   10
   11
   12
   13
   14
   15
   16
   17
   18
   19
   20
   21
   22
   23
   24
   25
   26
   27
   28
   29
   30
   31
   32
   33
   34
   35
   36
   37
Percent
Recycle

  100
  100
   50
   97
  100
  100
  100
  100
  100
   99
   99
  100
   99
    0
   98
   97
   99
    0
   NR
   NR
   97
   98
    0
   93
   94
   97
   99
   96
   96
   94
   92
    0
   NR
    0
   NR
    0
    0
Production
Normalized
Water Use

   NR
   NR
  2,743
   NR
   NR
   NR
   NR
   NR
      8.339
 82,050
105,000
 86,430
 82,640
    908.9
 30,670
 37,530
 31,340
    392.8
   NR
   NR
 73,800
 31,440
  3,819
 14,090
 35,320
 36,980
177,900
 70,880
 62,960
 72,130
 43,360
  3,394
   NR
  5,041
   NR
  9,089
  9,506
  Production
  Normalized
Discharge Rate

      0
      0
      0
      0
      0
      0
      0
      0
      0
      0.2989
      0.3252
      0.4169
      0.4169
    120.9
    150.1
    250.2
    313.4
    392.8
    496.2
    514.5
    612.9
    629.6
    779.7
    963.1
  1,113
  1,167
  1,483
  1,534
  1,955
  2,397
  2,753
  3,002
  4,003
  5,041
  5,337
  9,089
  9,506
                          767

-------
                      Table V-7 (Continued)

                WATER USE AND DISCHARGE RATES FOR
               DIRECT CHILL CASTING CONTACT COOLING
                   (ALUMINUM FORMING CATEGORY)

                     (1/kkg of aluminum cast)
      Plant Code*

         38
         39
         40
         41
         42
         43
         44
         45
         46
         47
         48
         49
         50
         51
         52
         53
         54
         55
         56
         57
         58
         59
         60
         61
Percent
Recycle

   0
   0
   0
   0
   0
   0
  98
  96
  NR
  NR
   0
   0
  NR
   0
  NR
   0
  NR
  NR
 100
  NR
  NR
   0
  90
  NR
Production
Normalized
Water Use

  23,060
  28,390
  35,500
  52,540
  58,370
  91,310
    NR
    NR
    NR
    NR
    NR
    NR
    NR
    NR
    NR
    NR
    NR
    NR
  50,030
    NR
    NR
    NR
    NR
    NR
  Production
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Discharge Rate

    16,590
    28,390
    35,500
    52,540
    58,370
    91,310
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
      NR
NR - Present, but data not reported in dcp.

*Some plants use more than one type of direct chill casting
 process.
                               768

-------
                            Table V-8

                WATER USE AND DISCHARGE RATES FOR
            DIRECT CHILL CASTING CONTACT COOLING WATER
                  (PRIMARY ALUMINUM SUBCATEGORY)

                     (1/kkg of aluminum cast)
      Plant Code*

        368
        348
        346
        355
        362
        367
        355
        345
        357
        363
        350
        353
        340
        371
        366
        342
        365
        349
        370
        348
        369
        365
        352
        360
        347
        370
        343
Percent
Recycle

 100
 100
 100
  97
  99
   0
  99
  82
  98
  95
  98
  94
  98
   0
   1
  93
  53
   0
   0
   0
   0
  53
  20
   0
   0
   0
   2
Production
Normalized
Water Use

   NR
   NR
   NR
  1,113
 54,790
    254.3
 34,120
  2,535
 24,350
 28,440
142,700
 46,910
138,300
  6,504
  7,088
117,000
 18,260
 10,330
 12,080
 12,180
 12,530
 30,440
 20,580
 20,700
 31,700
 52,490
 60,460
  Production
  Normalized
Discharge Rate

       0
       0
       0
      33.36
     125.1
     254.3
     437.8
     446.1
     487.8
   1,422
   2,218
   3,040
   3,319
   6,504
   7,021
   8,118
   8,635
  10,320
  12,080
  12,180
  12,530
  14,360
  16,470
  20,700
  31,700
  52,490
  52,290
NR - Present, but data not reported in dcp.

*Some plants have more than one type of direct chill casting
 process.
                               769

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                             078  VOA BLANK
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SAMPLING SITES  AT SECONDARY ALUMINUM PLANT A
                      782

-------
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SAMPLING SITES AT  SECONDARY ALUMINUM PLANT B
                       783

-------
SOURCE
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   SAMPLING SITES  AT SECONDARY ALUMINUM PLANT  C
                          784

-------
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  SAMPLING  SITES AT SECONDARY  ALUMINUM PLANT D
                           785

-------
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SAMPLING SITES  AT SECONDARY ALUMINUM PLANT E
                       786

-------
                  SECONDARY ALUMINUM SUBCATEGORY

                            SECTION VI

                     SELECTION OF POLLUTANTS
Section V of this supplement presented data  from secondary
aluminum plant sampling visits and  subsequent chemical analyses.
This section examines those data and discusses the selection or
exclusion of pollutants for potential limitation.  The legal
basis for the exclusion of toxic pollutants  under Paragraph 8(a)
of the Settlement Agreement is presented  in  Section VI of the
General Development Document.

Each pollutant selected for potential limitation is discussed  in
Section VI of the General Development Document.  That discussion
provides information about where the pollutant originates (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 describes the analysis that was performed to select
or exclude pollutants for limitation in this subcategory.

The discussion that follows describes the analysis that was per-
formed to select or exclude pollutants for further consideration
for limitations and standards.  Pollutants will be considered  if
they are present in concentrations  treatable by the technologies
considered in this analysis.  The treatable  concentration used
for the toxic metals were the long-term performance values
achievable by lime precipitation, sedimentation, and filtration.
The treatable concentrations used for the toxic organics were  the
long-term performance values achievable by carbon adsorption (see
Section VII of the General Development Document - Combined Metals
Data Base).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS

This study examined samples from the secondary aluminum subcate-
gory for three conventional pollutant parameters (oil and grease,
total suspended solids, and pH) and seven nonconventional pollu-
tant parameters (ammonia, chemical  oxygen demand, chloride,
fluoride, aluminum, total organic carbon, and total phenols).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS SELECTED

The conventional and nonconventional pollutants or pollutant
parameters selected for consideration for limitation in this
subcategory are:
                               787

-------
     aluminum
     ammonia
     total suspended solids (TSS)
     oil and grease
     pH

Aluminum was found above the 0.74 mg/1 concentration attainable
by identified treatment technology in three of six samples in two
plants.  Because it is the major product of plants in this sub-
category and was found at treatable concentrations, alximinum is
selected for consideration for limitation.

Ammonia was measured at three sites at two plants.  The concen-
tration of ammonia in these samples varied widely, depending on
the stage and type of manufacturing process.  Those plants that
produce treatable concentrations of ammonia will be considered
for limitation for that pollutant.

Total suspended solids ranged from 60 to 20,140 mg/1 in six
samples.  All of the measured concentrations are well above the
concentration achievable by identified treatment technology.
Furthermore, most of the technologies used to remove toxic metals
do so by converting these metals to precipitates, and these
toxic-metal-containing precipitates should not be discharged.
Meeting a limitation on total suspended solids also ensures that
sedimentation to remove precipitated toxic metals has been effec-
tive.  For these reasons, total suspended solids is considered
for limitation in this subcategory.

Oil and grease was found above treatability (10 mg/1) in six of
seven samples with concentrations ranging from 16 to 157 mg/1.
Many secondary aluminum plants have converted to direct chill
casting processes since the sampling data was collected.  Sam-
pling data from direct chill casting raw wastewater taken at
aluminum forming plants show oil and grease present at treatable
concentrations in 15 of 23 samples.  The treatable concentrations
range from 15 to 226 mg/1.  (For a further discussion, refer to
Section V of the Development Document for Proposed Effluent
Limitations Guidelines and Standards for the Aluminum Forming
Point Source Category).  Therefore, oil and grease is selected
for consideration for limitation.

The pH of a wastewater measures its relative acidity or alkalin-
ity.  In this study, the pH values observed in raw wastewater
ranged from 2.8  to 9.6.  Effective removal of toxic metals by
precipitation requires careful control at pH.  Therefore, pH is
considered for limitation in this subcategory.
                               788

-------
TOXIC POLLUTANTS

The frequency of occurrence of the toxic pollutants in the waste-
water samples taken is presented in Table VI-1.  These data
provide the basis for the categorization of specific pollutants,
as discussed below.  Table Vl-1 is based on the raw wastewater
data from streams 3, 68, 70, 80, and 84 (see Section V).  Treat-
ment plant sampling data were not considered in the frequency
count.

TOXIC POLLUTANTS NEVER DETECTED

Paragraph 8(a)(iii) of the Revised Settlement Agreement allows
the Administrator to exclude from regulation those toxic pollu-
tants not detectable by Section 304(h) analytical methods or
other state-of-the-art methods.  The toxic pollutants listed
below were not detected in any wastewater samples from this
subcategory; therefore, they are not selected for consideration
in establishing limitations:

       1.  acenaphthene
       2.  acrolein
       3.  acrylonitrlle
       5.  benzidine
       6.  carbon tetrachloride
       7.  chlorobenzene
       8.  1,2,4-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.  DELETED
      18.  bis(2-chloroethyl) ether
      19.  2-chloroethyl vinyl ether
      20.  chloronaphthalene
      21.  2,4,6-trichlorophenol
      22.  parachlorometa cresol
      24.  2-chlorophenol
      25.  1,2-dichlorobenzene
      26.  1,3-dichlorobenzene
      28.  3,3'-dichlorobenzidine
      31.  2,4-dichlorophenol
      32.  1,2-dichloropropane
      33.  1,3-dichloropropylene
                              789

-------
 34.  2,4-dimethylphenol
 35.  2,4-dinitrotoluene
 36.  2,6-dinitrotoluene
 37.  1,2-diphenylhydrazine
 38.  ethylbenzene
 40.  4-chlorophenyl phenyl ether
 41.  4-bromophenyl phenyl ether
 42.  bis(2-chloroisopropyl) ether
 43.  bis(2-chloroethoxy)  methane
 45.  methyl chloride
 46.  methyl bromide
 47.  bromoform
 49.  DELETED
 50.  DELETED
 51.  chlorodibromomethane
 52.  hexachlorobutadiene
 53.  hexachlorocyclopentadiene
 54.  isophorone
 55.  naphthalene
 56.  nitrobenzene
 57.  2-nitrophenol
 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
 65.  phenol
 70.  diethyl phthalate
 72.  benzo(a)anthracene
 74.  3,4-benzofluoranthene
 75.  benzo(k)fluoranthene
 78.  anthracene (a)
 79.  benzo(ghi)perylene
 80.  fluorene
 81.  phenanthene (a)
 82.  dibenzo(a,h)anthracene
 83.  indeno (1,2,3-cd)pyrene
 86.  toluene
 88.  vinyl chloride
 89.  aldrin
 90.  dieldrin
 94.  4,4'-DDD
 95.  alpha-endosulfan
 96.  beta-endosulfan
 97.  endosulfan sulfate
105.  delta-BHC
116.  asbestos
129.  2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)

 (a)   Reported together
                          790

-------
TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION LIMIT

The provision of Paragraph 8(a)(iii) of the Revised Settlement
Agreement excluding from regulation  those  toxic pollutants which
are not detectable includes those pollutants whose concentrations
fall below EPA's nominal detection limit.  The toxic pollutants
listed below were never found above  their  analytical quantifica-
tion level in any wastewater samples from  this subcategory;
therefore, they are not selected for consideration in establish-
ing limitations.

      91.  chlordane
      92.  4,4'-DDT
      93.  4,4'-DDE
      98.  endrin
      99.  endrin aldehyde
     100.  heptachlor
     101.  heptachlor epoxide
     102.  alpha-BHC
     103.  beta-BHC
     104.  gamma-BHC
     106.  PCB-1242      (a)
     107.  PBC-1254      (a)
     108.  PCB-1221      (a)
     109.  PCB-1232      (b)
     110.  PCB-1248      (b)
     111.  PCB-1260      (b)
     112.  PCB-1016      (b)
     113.  toxaphene
     121.  cyanide

     (a),(b)  Reported together.

TOXIC POLLUTANTS PRESENT BELOW CONCENTRATIONS ACHIEVABLE BY
TREATMENT

Paragraph 8(a)(iii) of the Revised Settlement Agreement also
allows the exclusion of toxic pollutants which were detected  in
quantities too small to be effectively reduced by technologies
known to the Administrator.  The pollutants listed below are  not
selected for consideration in establishing limitations because
they were not found in any wastewater samples from this subcate-
gory above concentrations considered achievable by existing or
available treatment technologies.  These pollutants are discussed
individually following the list.

      29.  1,1-dichloroethylene
      30.  1,2-trans-dichloroethylene
      48.  dichlorobromomethane
     114.  antimony


                              791

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     117.  beryllium
     123.  mercury
     125.  selenium
     126.  silver

1,1-Dichloroethylene was found above its analytical quantifica-
tion limit in one of 12 samples, at 0.099 mg/1.  The measured
concentration is below the treatable concentration of 0.1 mg/1.
Therefore, 1,1-dichloroethylene is not considered for limita-
tion.

1,2-trans-Dichloroethylene was found above its analytical quanti-
fication limit in five of 12 samples, with values ranging from
0.019 to 0.070 mg/1.  All of the values are below the treatable
concentration of 0.1 mg/1.  Therefore, 1,2-trans-dichloro-
ethylene is not considered for limitation.

Dichlorobromomethane was found above its analytical quantifica-
tion limit in one of 12 samples.  The measured value was 0.019
mg/1, which is below 0.1 mg/1, the concentration achievable by
identified treatment technology.  Therefore, dichlorobromomethane
is not considered for specific limitation.

Antimony was found above its analytical quantification limit in
one of six samples collected at four plants.  The concentration
found was 0.3 mg/1, which is below that achievable by identified
technology.  Therefore, antimony is not considered for
limitation.

Beryllium was found above its analytical quantification limit in
three of four samples.  The maximum concentration measxired was
0.20 mg/1.  The concentration achievable by identified treatment
technology is 0.20 mg/1.  Therefore, beryllium is not considered
for limitation.

Mercury was detected above its analytical quantification limit in
all five samples of this subcategory, ranging from 0.0002 to
0.0064 mg/1.  All of the values are below the 0.036 mg/1 concen-
tration achievable by identified treatment technology.  There-
fore, mercury is not considered for limitation.

Selenium was found above its quantification concentration in one
of three samples collected at three plants.  The concentration
found was 0.20 mg/1, which is the concentration achievable by
identified treatment technology.  Therefore, selenium is not
considered for limitation.

Silver was found above its analytical quantification limit in one
of three samples with a value of 0.07 mg/1.  This concentration
is equal to that achievable by identified treatment technology.
Therefore, silver is not considered for limitation.
                               792

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TOXIC POLLUTANTS DETECTED IN A SMALL NUMBER OF SOURCES

Paragraph 8(a)(iii) allows for the exclusion of a  toxic pollutant
if it is detectable in the effluent from only a small number of
sources within the subcategory and it  is uniquely  related  to only
those sources.  The following pollutants were not  selected  for
consideration for limitation on this basis.

       4.  benzene
      23.  chloroform
      27.  1,4-dichlorobenzene
      39.  fluoranthene
      44.  methylene chloride
      66.  bis(2-ethylhexyl) phthalate
      67.  butyl benzyl phthalate
      68.  di-n-butyl phthalate
      69.  di-n-octyl phthalate
      71.  dimethyl phthalate
      73.  benzo(a)pyrene
      76.  chrysene
      77.  acenaphthylene
      84.  pyrene
      85.  tetrachloroethylene
      87.  trichloroethylene
     115.  arsenic
     119.  chromium
     120.  copper
     124.  nickel
     127.  thallium

Although these pollutants were not selected for consideration in
establishing nationwide limitations, it may be appropriate, on a
case-by-case basis, for the local permitter to specify effluent
limitations.

Benzene was found above its analytical quantification limit in
one of 12 samples collected at four plants. The concentration of
0.136 mg/1 is above the concentration achievable by identified
treatment technology.  Also, all secondary aluminum plants
indicated in the dcp that this pollutant was known to be absent
or believed to be absent from their wastewater.  Because it was
found above a treatable concentration at only one  plant, benzene
is not considered for limitation.

Chloroform was found above its analytical quantification limit in
11 of 12 samples collected at four plants.  The 11 samples ranged
from values of 0.019 to 0.410 mg/1; however, 10 of the 11 samples
were at concentrations below that achievable by treatment.  Also,
all secondary aluminum plants indicated in the dcp that this
pollutant was known to be absent or believed to be absent from
their wastewater.  Because the possibility of sample contamina-
tion is likely,  chloroform is not considered for limitation.
                               793

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1,4-Dichlorobenzene was found above its analytical quantification
concentration in only one of six samples collected from three
plants with a concentration of 0.026 mg/1, which is treatable by
identified technology.  However, all secondary aluminum plants
indicated in the dcp that this pollutant was known to be absent
or believed to be absent from their wastewater.  Since it was
detected in only one plant, 1,4-dichlorobenzene is not considered
for limitation.

Fluoranthene was detected above its analytical quantification
limit in only one of six samples collected at three plants.  The
reported fluoranthene concentration, 0.020 mg/1, is above the
concentration achievable by available treatment.  However, all
secondary aluminum plants indicated in the dcp that this pollu-
tant was known to be absent or believed to be absent from their
wastewater.  Because it was found at only one plant, indicating
the pollutant is site-specific, fluoranthene is not considered
for limitation.

Methylene chloride was found above its analytical quantification
limit in one of 12 samples.  The measurable concentration was
0.370 mg/1.  This pollutant is not attributable to specific
materials or processes associated with the secondary aluminum
subcategory; however, it is a common solvent used in analytical
laboratories.  Also, all secondary aluminum plants indicated in
the dcp that this pollutant was known to be absent or believed to
be absent from their wastewater.  Since the possibility of sample
contamination is likely, methylene chloride is not considered for
limitation.

Bis(2-ethylhexyl) phthalate was found above its analytical quan-
tification limit in three of six samples.  The concentrations
measured were 0.075, 0.28, and 2.03 mg/1.  The presence of this
pollutant is not attributable to materials or processes associ-
ated with the secondary aluminum subcategory.  It is commonly
used as a plasticizer in laboratory and field sampling equipment.
EPA suspects sample contamination as the source of this pollu-
tant.  Also, all secondary aluminum plants indicated in the dcp
that this pollutant was known to be absent or believed to be
absent from their wastewater.  Therefore, bis(2-ethylhexyl)
phthalate is not considered for limitation.

Butyl benzyl phthalate was found above its analytical quantifica-
tion limit in two of six samples collected from three plants.
The measured values were 0.014 and 0.098 mg/1.  The presence of
this pollutant is not attributable to materials or processes
associated with the secondary aluminum subcategory.  It is
commonly used as a plasticizer in laboratory and field sampling
equipment.  EPA suspects sample contamination as the source of
this pollutant.  Also, all secondary aluminum plants indicated in
                               794

-------
the dcp that this pollutant was known  to  be  absent  or  believed to
be absent from their wastewater.  For  these  reasons, butyl  benzyl
phthalate is not considered for limitation.

Di-n-butyl phthalate was  found above its  analytical quantifica-
tion limit in two of six  samples, with concentrations  of  0.022
and 0.045 mg/1.  The presence of  this  pollutant  is  not attribu-
table to materials or processes associated with  the secondary
aluminum subcategory.  It  is commonly  used as  a  plasticizer in
laboratory and field sampling equipment.  EPA  suspects sample
contamination as the source of this pollutant.   Also,  all second-
ary aluminum plants indicated in  the dcp  that  this  pollutant was
known to be absent or believed to be absent  from their waste-
water.  Therefore, di-n-butyl phthalate is not considered for
limitation.

Di-n-octyl phthalate was  found above its  analytical quantifica-
tion limit in only one of  six samples  collected  at  three  plants,
at a concentration of 0.036 mg/1.  The presence  of  this pollu-
tant is not attributable  to materials  or  processes  associated
with the secondary aluminum subcategory.  It is  commonly  used  as
a plasticizer in laboratory and field  sampling equipment.   EPA
suspects sample contamination as  the source  of this pollutant.
Also, all secondary aluminum plants indicated  in the dcp  that
this pollutant was known  to be absent  or  believed to be absent
from their wastewater.  For these reasons, di-n-octyl  phthalate
is not considered for limitation.

Dimethyl phthalate was detected at a concentration  greater  than
its analytical quantification limit in only  one  of  six samples
collected at three plants.  The measured  concentration of this
toxic pollutant was 0.056  mg/1.   Also, all secondary aluminum
plants indicated in the dcp that  this  pollutant  was known to be
absent or believed to be absent from their wastewater.  Because
it was found at just one plant, dimethyl  phthalate  is  not
considered for limitation.

Benzo(a)pyrene was detected at a  concentration above its  analyti-
cal quantification limit  in only  one of six  samples collected  at
three plants.   The 0.012 mg/1 concentration measured is above  the
concentration achievable by identified treatment technology.
However, all secondary aluminum plants indicated in the dcp that
this pollutant was known to be absent  or  believed to be absent
from their wastewater.  Because it was found at  only one  plant,
benzo(a)pyrene is not considered  for limitation.

Chrysene was detected at a concentration  above its  analytical
quantification limit in only one  of six samples  collected at
three plants.   The 0.017 mg/1 concentration measured is above  the
concentration achievable by identified treatment  technology.
However, all secondary aluminum plants indicated in the dcp that
                               795

-------
this pollutant was known to be absent or believed to be absent
from their wastewater.  Because it was found only at one plant,
chrysene is not considered for limitation.

Acenaphthylene was detected at a concentration above its analyti-
cal quantification limit in only one of six samples collected at
three plants.  The 0.017 mg/1 concentration measured is above the
concentration achievable by identified treatment technology.
Also, all secondary aluminum plants indicated in the dcp that
this pollutant was known to be absent or believed to be absent
from their wastewater.  Because it as found at only one plant,
acenaphthylene is not considered for limitation.

Pyrene was measured at a concentration greater than its analyti-
cal quantification limit in only one of six samples collected at
three plants.  The concentration of this toxic pollutant was
0.024 mg/1.  Also, all secondary aluminum plants indicated  in the
dcp that this pollutant was known to be absent or believed  to be
absent from their wastewater.  Because it was found at just one
plant, pyrene is not considered for limitation.

Tetrachloroethylene was found above its analytical quantification
limit and above the concentration attainable by available
treatment in only one of 12 samples collected from four plants,
indicating the pollutant is site-specific.  The measured
concentration was 0.378 mg/1.  Also, all secondary aluminum
plants indicated in the dcp that this pollutant was known to be
absent or believed to be absent from their wastewater.  There-
fore, tetrachloroethylene is not considered for limitation.

Trichloroethylene was found above its analytical quantification
limit and treatable concentration in one of 12 samples collected
from four plants.  The sample concentration was 0.787 mg/1.
Also, all secondary aluminum plants indicated in the dcp that
this pollutant was known to be absent or believed to be absent
from their wastewater.  Since this pollutant was found at only
one plant, trichloroethylene is not considered for limitation.

Arsenic was found above its treatable concentration in one  of
three samples collected at four plants.  The concentration  of
arsenic was 4.0 mg/1. Since it was found at a treatable
concentration only one plant, arsenic is not considered for
limitation.

Chromium was found above its treatable concentration in one of
three samples collected at two plants.  This sample contained 2.0
mg/1 of chromium.  Since a treatable concentration of chromium
was collected at only one plant, chromium is not considered for
limitation.
                               796

-------
Copper was found above  its treatable  concentration  in  one  of four
samples, with a value of 10.0 mg/1.   Since  copper was  found  at
only one plant, it  is considered  specific to  that site and is not
considered for limitation.

Nickel was detected above its treatable  concentration  in one of
three samples (1.0 mg/1).  Since  it was  found in only  one  plant,
nickel is not considered for limitation.

Thallium was detected above its treatable concentration in one  of
three samples collected at three  plants.  Because it was found  at
only one plant, thallium is not considered  for  limitation.

TOXIC POLLUTANTS SELECTED FOR CONSIDERATION FOR ESTABLISHING
LIMITATIONS

The pollutants listed below were  selected for further  considera-
tion in establishing limitations  and  standards  for  this subcate-
gory.  The toxic pollutants selected  are each discussed following
the list.

     118.  cadmium
     122.  lead
     128.  zinc

Cadmium was detected above its analytical quantification limit  in
four samples collected at two plants.  The  values ranged from
0.020 to 0.500 mg/1.  Three of the concentrations are  above  the
concentration of 0.049 mg/1, which is achievable by identified
treatment technology.  Therefore, cadmium is  selected  for
consideration for limitation.

Lead was detected present above its analytical  quantification
limit in all four samples collected at two  plants.  The reported
lead concentrations ranged from 0.060 to 8.0  mg/1.  A  lead con-
centration of 0.08 mg/1 is achievable by identified treatment
technology.  Therefore, lead is selected for  consideration for
limitation.

Zinc was detected above its analytical quantification  limit  in
all four samples collected at two plants.   The  concentrations of
zinc reported ranged from 2.0 to 8.0 mg/1.  The concentration of
zinc achievable by identified treatment  technology  is  0.23 mg/1.
Therefore, zinc is selected for consideration  for limitation.
                               797

-------
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                                                 801

-------
                  SECONDARY ALUMINUM SUBCATEGORY

                            SECTION VII

                CONTROL AND TREATMENT TECHNOLOGIES

The preceding sections of this supplement discussed the waste-
water sources, flows, and characteristics of the wastewaters from
secondary aluminum plants.  This section summarizes the descrip-
tion of these wastewaters and indicates the level of treatment
which is currently practiced by in secondary aluminum subcategory
for each waste stream.

TECHNICAL BASIS OF BPT

As mentioned in Section III, EPA promulgated BPT effluent limita-
tions guidelines for the secondary aluminum smelting subcategory
on April 8, 1974.  In order to put the treatment practices cur-
rently in place and the technologies selected for BAT options
into the proper perspective, it is necessary to describe the
technologies selected by EPA for BPT.  The BPT regulations
established by EPA limited the discharge of aluminum, copper,
ammonia, chemical oxygen demand, fluoride, and total suspended
solids and required the control of pH (refer to Section IX).

Control and treatment technologies are also discussed in general
in Section VII of the General Development Document.  The basic
principles of these technologies and the applicability to waste-
water similar to that found in this subcategory are presented
there. This section presents a summary of the control and treat-
ment 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 secondary aluminum
subcategory is characterized by the presence of the toxic metal
pollutants and suspended solids.  The raw (untreated) wastewater
data are 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.  Three plants in this subcate-
gory currently have combined wastewater treatment systems, one
has lime precipitation and sedimentation, and no plants have lime
precipitation, sedimentation and filtration.  As such, three
options have been selected for consideration for BAT, BDT, BCT,
and pretreatment in this subcategory, based on combined treatment
of these compatible waste streams.
                              803

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CURRENT CONTROL AND TREATMENT PRACTICES

Control and treatment technologies are discussed in general  in
Section VII of the General Development Document.  The basic
principles of these technologies ard the applicability to waste-
water similar to that found in this industry are presented there.
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 and then
identifies three options which are considered as the basis for
BAT, BDT, and pretreatment for existing and new sources.

SCRAP DRYING WET AIR POLLUTION CONTROL

Wet and dry control devices are used to control air emissions
from scrap drying operations.  Three plants use scrubbers; 26
plants use baghouses.  Two plants practice 100 percent recycle,
resulting in zero discharge.  One plant discharges this waste-
water, which may contain suspended solids and aluminum.

Alkali addition and sedimentation can be used to remove suspended
solids and some metals.  The one plant producing this wastewater
reported no treatment before discharging to a municipal sewer
system.

SCRAP SCREENING AND MILLING WASTEWATER

Two plants use scrubbers to control air emissions from scrap
screening and milling operations.  Both plants practice 100 per-
cent reycle of this wastewater, which may contain total suspended
solids, toxic metals, and aluminum at treatable concentrations.
Alkali addition and sedimentation may be used to reduce suspended
solids and some metals.

DROSS WASHING WASTEWATER

Of the four plants that practice wet dross processing, two prac-
tice 100 percent recycle and one attains zero discharge by solar
evaporation.  One plant recycles 67 percent of this wastewater,
which contains organics, toxic metals, aluminum, ammonia, phenol-
ics, and suspended solids.

The only currently practiced reduction of primary aluminum
residues and secondary aluminum slags uses wet milling with  a
countercurrent flow process to reduce or possibly eliminate  salt
impregnation of runoff and ground water from discarded solid
waste.  Such salt recovery installations are operating in England
and Switzerland, and the salts recovered assist in paying for the
                               804

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operation since they are reusable as  fluxing  salts  in  the  second-
ary aluminum subcategory.  By using a countercurrent milling and
washing approach, two advantages are  realized.  The final  recov-
ered metal is washed with clean water, providing a  low-salt feed
to the melting furnaces.  The wastewater, with the  insolubles
removed, would be of a concentration  suitable for economical salt
recovery by evaporation and crystallization.  Heat  for evapora-
tion could be supplied by the waste heat from the furnaces.  The
process would have to contend with the ultimate disposal of dirt,
trace metals, and insoluble salts not removed from  the  dross
during milling.  Sedimentation with recycle is the  treatment
method currently used at the one discharging  facility.

DEMAGGING WET AIR POLLUTION CONTROL

During the smelting process it is often necessary to remove mag-
nesium from the molten aluminum.  This process of demagging can
be performed with chlorine or aluminum fluoride.  Most  facilities
(25 of the 37 that demag) use chlorine to accomplish the demag-
ging.  Aluminum fluoride is more expensive than chlorine and is
not regarded as effective in removing magnesium.  In addition,
the furnace refractory lining life is shorter when  aluminum
fluoride is used since residues resulting from its  use  in  the
demagging process are more corrosive  than chlorine  generated
residues.

However, demagging with chlorine complicates emissions  control
because of the formation of hydrochloric acid in the smelting
emissions, due to the hydrolysis of aluminum and magnesium
chloride when wet scrubbing is used.  Emissions from aluminum
fluoride demagging are usually controlled with dry  processes.

Demagging scrubbing wastewater contains organics, toxic metals,
cyanide, aluminum, ammonia, chloride, phenolics, total  suspended
solids, and oil and grease.

Of the 55 facilities surveyed, 20 use some form of wet  process
control of demagging air emissions.  Seven of the 20 practice 100
percent recycle, while two others use a closed system  incorporat-
ing evaporation ponds.   Four of the facilities discharge (either
directly or to a POTW)  with no prior  treatment, and one facility
only settles the waste stream before discharging it.  The  six
facilities that treat this waste stream all neutralize  the stream
(often with soda ash) before discharge.  This neutralization step
is usually followed by a settling procedure since pH adjustment
to 5.0 to 7.0 will precipitate most of the aluminum and magnes-
ium.
                               805

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.CASTING  CONTACT COOLING

Different  product  cooling  techniques  are  used  in  the  secondary
aluminum subcategory  depending on  the product  being produced.
Air  cooling, contact  water cooling, and noncontact water cooling
are  all  used.  Also,  there is a  trend toward converting  to  direct
chill  casting  in the  secondary aluminum subcategory  (refer  to
Section  V, p.754   ).  The  use of contact  water itself varies with
the  type of product being  manufactured.   Ingot molds  are often
sprayed  with water to cool them, whereas  the production  of
deoxidizer shot involves allowing  molten  aluminum to  flow through
the  mesh of a  screen  and fall  (forming a  spherical shot  product)
into a quenching tank.

Oil  and  grease, used  to  lubricate  mold conveyor systems, is
washed from the equipment  as the product  is sprayed with water.
The  quantity of this  form  of wastewater can be reduced by recycle
or the adoption of systems that  allow total evaporation  through
regulated  flow.

Casting  contact cooling water  contains treatable  concentrations
of aluminum, oil and  grease, and suspended solids.

Of the 55  facilities  surveyed, 35  produced a wastewater  associ-
ated with  cooling water.   Twenty-two  of the 35 facilities utilize
recycle  or evaporation to  the extent  that no discharge of contact
cooling  water  occurs.  Eleven  of the  facilities discharge (either
directly or indirectly) with no  treatment other than  some volume
reduction  due  to evaporation or  partial recycle.  Two facilities
treat  the  wastewater  before discharge.  One uses  flotation  to
remove oil and grease followed by  grit removal before discharge.
The  other  facility uses equalization  and  neutralization  before
discharge.

CONTROL  AND TREATMENT OPTIONS CONSIDERED

Based  on an examination of the wastewater sampling data, three
treatment  technologies that effectively control the polluants
found  in secondary aluminum wastewaters were selected for eval-
uation.  These technology  options  are discussed bleow.   Other
treatment  technologies included  additional in-process flow
reduction  (Option B), activated  alumina adsorption  (Option  D),
and  activated  carbon  adsorption  (Option E).  These technologies
were not selected  for evaluation because  they  are not applicable
to the secondary aluminum  subcategory.  Option B  does not apply
since  in-process wastewater flow reduction is  part of the Option
A technology.  EPA believes that no additional in-process waste-
water  flow reduction  is achievable by this subcategory.   Since
arsenic  was not selected for consideration for limitation in the
secondary  aluminum subcategory,  activated alumina technology
(Option  D) was not selected for  evaluation because  it is not
                                806

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applicable.   (For pollutant  selection,  refer  to Section VI,
p. 787  ).  Since no toxic organic pollutants  were  selected  for
consideration for limitation in  this  subcategory,  activated
carbon technology (Option E)  also is  not  applicable.

OPTION A

Option A for  the secondary aluminum subcategory is equivalent to
BPT treatment.  Option A requires control and treatment technol-
ogies to reduce the discharge of wastewater volume and pollutant
mass.  Recycle of casting contact cooling water is the control
mechanism for  flow reduction.

The Option A  treatment scheme consists  of ammonia  stream  strip-
ping preliminary treatment applied to the dross washing waste-
water stream, preliminary treatment of  casting cooling water with
oil skimming,  and lime and settle technology  (chemical precipita-
tion and sedimentation) applied  to the  combined stream of steam
stripper effluent, demagging air pollution scrubbing wastewater,
and casting contact cooling  wastewater.   Chemical precipitation
is used to remove metals and fluoride by  the  addition of  lime
followed by gravity sedimentation.  Suspended solids are  also
reroved from  the process.

OPTION C

Option C for  the secondary aluminum subcategory consists  of pre-
liminary treatment with ammonia  steam stripping and oil skimming
in-process flow reduction, and the chemical precipitation and
sedimentation technology considered in  Option A plus multimedia
filtration end-of-pipe technology.  Multimedia filtration is used
to remove suspended solids,  including precipitates of metals,
beyond the concentration attainable by  gravity sedimentation.
The filter suggested is of the 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 consistent removal  during periods in which there are
rapid increases in flows or  loadings  of pollutants to the
treatment scheme.

OPTION F

Option F for  the secondary aluminum subcategory consists  of pre-
liminary treatment with ammonia steam stripping and oil skimming
in-process flow reduction, chemical precipitation, sedimentation,
and multimedia filtration technology  considered in Option C with
the addition  of reverse osmosis and evaporation end-of-pipe tech-
nology.   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 the brines
rejected from reverse osmosis.
                               807

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                  SECONDARY ALUMINUM SUBCATEGORY

                           SECTION VIII

           COSTS, ENERGY, AND NONWATER QUALITY ASPECTS


This section describes the method used to develop the costs asso-
ciated with the control and treatment technologies discussed  in
Section VII for wastewaters from secondary aluminum plants.   The
energy requirements of the considered options, as well as  solid
waste and air pollution aspects, are also discussed in this sec-
tion.  Section VIII of the General Development Document provides
background on the capital and annual costs for each of the
technologies discussed herein.

The wastewater streams associated with the secondary aluminum
subcategory are combined into three groups for the purposes of
this section.  These three groups have been selected because  the
combinations of waste streams is representative of the processing
that occurs in secondary aluminum plants.  The three groups are
as follows:

     1.  Dross washing, scrap drying wet air pollution control,
         and scrap screening and milling wastewaters;
     2.  Demagging wet air pollution control wastewater; and
     3.  Direct chill casting contact cooling.

These three groups are found in existing plants in the five dif-
ferent combinations shown below.  These five combinations are
selected for the purpose of cost estimation because they repre-
sent the wastewater combinations that occur most frequently in
plants in the secondary aluminum subcategory.

                        Dross                           Direct
                Washing,  Scrap Drying     Demagging      Chill
                  Wet Air Pollution        Wet Air      Casting
                  Control and Scrap       Pollution     Contact
Combination     Screening and Milling      Control      Cooling

     1                    X                   X
     2                                        XX
     3                                                     X
     4                    X
     5                                        X

The wastewater of combination 4 is so similar to that of combina-
tion 1 that they are considered to gether for the cost estimates.
Similarly, combination 5 is considered with combination 2.  Thus,
three combinations of wastewater are considered for the purpose
of cost estimates.
                               809

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Section VI indicated that significant pollutants and pollutant
parameters in the secondary aluminum subcategory are cadmium,
lead, zinc, aluminum, ammonia, oil and grease, total suspended
solids, and pH.  As explained in Section VII of the General
Development Document, metals are most economically remov  1 by
lime precipitation, sedimentation, and filtration techn-'ogy.
Reverse osmosis, in conjunction with multiple-effect evaporation,
is a technology used for the removal of organics and  Dissolved
metals.  Ammonia is removed from streams in which it is present
in treatable concentrations by preliminary steam stripping treat-
ment, and oil and grease is removed by oil skimming.

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES

As discussed in Section VII, three control and treatment options
are considered for treating wastewater from the secondary alumi-
num subcategory.  Cost estimates, in the form of annual cost
curves, have been developed for each of these control and treat-
ment options.  The control and treatment options are presented
schematically in Figures X-l through X-3 and summarized below.

OPTION A

Option A for the secondary aluminum subcategory requires control
and treatment technologies to reduce the discharge of wastewater
volume and pollutant mass.  The recycle of direct chill casting
contact cooling water through cooling towers and the total recy-
cle of scrap drying scrubber water through holding tanks are the
control mechanisms for flow reduction.  The Option A treatment
technology consists of ammonia steam stripping preliminary treat-
ment applied to the dross washing wastewater stream, and oil
skimming preliminary treatment applied to the direct chill
casting contact cooling water stream; preliminary treatment  is
followed by lime precipitation and sedimentation applied to  the
combined stream of steam stripper effluent, scrap screening  and
milling wastewater, demagging scrubber water, and direct chill
casting contact cooling water.  The annual cost curves developed
for the various options for wastewater combinations 1 and 4  are
based on ammonia steam stripping preliminary treatment for 85
percent of the wastewater stream, while the curves developed for
combinations 2, 3, and 5 do not consider ammonia steam stripping
preliminary treatment since these combinations do not contain
dross washing wastewater.  The annual cost curves developed  for
Option A do not consider the recycle of direct chill casting con-
tact cooling water through cooling towers or the recycle of  scrap
drying scrubber water through holding tanks.  Therefore, separate
cost curves have been developed to estimate holding tank and
cooling tower costs.  The total cost of Option A is determined by
adding the holding tank and cooling tower costs to the cost
determined from the appropriate Option A cost curve.
                               810

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OPTION C

Option C for the  secondary  aluminum  subcategory  consists  of all
the control and treatment technologies of Option A  (in-process
flow reduction through holding  tanks  and cooling towers,  ammonia
steam stripping and oil skimming preliminary  treatment, and lime
precipitation and sedimentation end-of-pipe treatment) with the
addition of multimedia filtration to  the end-of-pipe  treatment
scheme.  The cost curves for Option C do not  consider the recycle
of direct chill casting contact cooling water through cooling
towers or the recycle of scrap  drying scrubber water  through
holding tanks.  Therefore,  the  total  cost of  Option C is  deter-
mined by adding the cooling tower and holding tank  costs  to the
cost determined from the appropriate  Option C cost  curve.

OPTION F

Option F for the secondary  aluminum subcategory  consists  of all
the control and treatment technologies of Option C  (in-process
flow reduction through holding  tanks  and cooling towers,  ammonia
steam stripping and oil skimming preliminary  treatment, and lime
precipitation, sedimentation, and multimedia  filtration
end-of-pipe treatment) with the addition of reverse osmosis and
multiple-effect evaporation technology, followed by total  recycle
to the end-of-pipe treatment scheme.  The cost curves developed
for the five wastewater combinations  do not consider  the  recycle
of direct chill casting contact cooling water through cooling
towers or the recycle of scrap  drying scrubber water  through
holding tanks.  Therefore,  the  total  cost of  Option F is  deter-
mined by adding the cooling tower and holding tank costs  to the
cost determined from the appropriate  Option F cost  curve.

The cost curves for the options summarized above are  presented in
the figures listed below.   The  respective options which the
curves are based on are also shown.

         Combination     Figure VIII-    Options Costed

            1 & 4           1-3             A,  C, F
            2 Sc 5           4-6             A,  C, F
              3             7-9             A,  C, F

The cooling tower and holding tank cost curves are shown  in
Figures VIII-10 and VIII-11, respectively.

NONWATER QUALITY ASPECTS

A general discussion of the nonwater  quality  aspects  of the con-
trol and treatment options  considered for the nonferrous  metals
category is contained in Section VIII of the  General  Development
                               811

-------
Document.  Nonwater quality impacts specific to the secondary
aluminum subcategory including energy requirements, solid waste,
and air pollution are discussed below.

ENERGY REQUIREMENTS

The methodology used for determining the energy requirements for
the various options is discussed in Section VIII of the General
Development Document.  Briefly, the energy usage of the various
options is determined for secondary aluminum using the median
plant wastewater flow.  The energy usage of the options is then
compared to the energy usage of the median secondary aluminum
energy consumption plant.  As shown in Table VIII-1, the most
energy intensive option is reverse osmosis, which increases the
median secondary aluminum energy consumption by 0.065 percent.
The remaining two options would increase the median energy
consumption by less than 0.065 percent.

SOLID WASTE

Sludges associated with the secondary aluminum subcategory will
necessarily contain toxic 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 nonferrous metals manufacturing
plants by the suggested treatment technologies and believes they
are not hazardous wastes under the Agency's regulations imple-
menting Section 3001 of the Resource Conservation and Recovery
Act.  None of these wastes is 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 preicipitation, sedimentation and filtration.  By the
addition of excess lime during treatment, similar sludges,
specifically toxic metal bearing sludges, generated by other
industries such as the iron and steel industry, passed the
Extraction Procedure (EP) toxicity test.  See 40 CFR §261.24.
Thus, the Agency believes that the wastewater sludges will
similarly not be EP toxic if the recommended technology is
applied.

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
                               812

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point of generation to point of  final disposition.  EPA's
generator standards would require generators of hazardous non-
ferrous 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  trans-
porter 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),
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  dump-
ing 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  dis-
posing  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 ammonia steam strip-
ping, oil skimming, chemical precipitation, sedimentation, multi-
media filtration, and reverse osmosis.  These technologies trans-
fer 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 the cooling tower systems which are  used as the
basis for flow reduction in the secondary aluminum subcategory.
However, the Agency does not consider this impact to be
significant.
                               813

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                      SLUDGE REMOVAL

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                      ENERGY

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                                             CAPITAL
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                SECONDARY ALUMINUM  COMBINATIONS  1&4, OPTION A
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-------
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SECONDARY  ALUMINUM COMBINATIONS 1&4, OPTION  F
  10'
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 MATERIALS
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                                  Figure VIII-4

               SECONDARY ALUMINUM  COMBINATIONS  2&5,  OPTION A

                                        816

-------
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                                 Figure  VIII-5

              SECONDARY ALUMINUM COMBINATIONS 2&5,  OPTION  C
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               SECONDARY ALUMINUM COMBINATIONS 2&5,  OPTION F
                                        317

-------
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               SECONDARY ALUMINUM COMBINATION  3,  OPTION  F
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                                 Figure  VIII-10

               COOLING TOWER  COSTS  (CASTING CONTACT COOLING)

                                      819

-------
                          DEPRECIATION
                          CAPITAL
    Figure VIII-11
HOLDING TANK COSTS
         820

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                  SECONDARY ALUMINUM SUBCATEGORY

                            SECTION IX

     BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
EPA promulgated best practicable control technology currently
available (BPT) effluent limitations standards for the secondary
aluminum industry on April 8, 1974 as Subpart C of 40 CFR Part
421.  Pollutants regulated by these standards are aluminum,
copper, chemical oxygen demand, ammonia, fluoride, TSS, and pH.
Unlike the current rulemaking, the BPT standards were developed
on the basis of two subdivisions of the secondary aluminum
process, not on the basis of individual wastewater streams.  BPT
standards were established for magnesium removal processes
(demagging using either chlorine or aluminum fluoride) and wet
residue processes. The effluent limitations established by the
BPT standards are as listed below:

     (a)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties, which
          may be discharged by a point source subject to the
          provisions of this subpart and which uses water for
          metal cooling, after application of the best practi-
          cable control technology currently available:  There
          shall be no discharge of process wastewater pollutants
          to navigable waters.

     (b)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties which may
          be discharged by a point source subject to the provi-
          sions of this subpart and which uses aluminum fluoride
          in its magnesium removal process ("demagging process"),
          after application of the best practicable control
          technology currently available:  There shall be no
          discharge of process wastewater pollutants to navi-
          gable waters.

     (c)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties con-
          trolled by this section, which may be discharged by
          a point source subject to the provisions of this
          subpart and which uses chlorine in its magnesium
          removal process, after application of the best
          practicable control technology currently available:
                               821

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                               Effluent Limitations
   Effluent        Average of daily values for 30 consecutive
Characteristic	days shall not exceed	

                   Metric units (kilograms per 1,000 kg
                             magnesium removed)
                   English units (Ibs per 1,000 Ibs
                   	magnesium removed)	

TSS                                  175
COD                                    6.5
pH                        Within the range of 7.5 to 9,0

     (d)  The following limitations establish the quantity or
          quality of pollutants or pollutant properties which
          may be discharged by a point source subject to the
          provisions of this subpart and which processes resi-
          dues by wet methods, after application of the best
          practical control technology currently available:

                   	Effluent Limitations	

   Effluent        Average of daily values for 30 consecutive
Characteristic	days shall not exceed	

                   Metric units (kilograms per 1,000 kg
                             magnesium removed)
                   English units (Ibs per 1,000 Ibs
                   	magnesium removed)	

TSS                                    1.5
Fluoride                               0.4
Ammonia (as N)                         0.01
Aluminum                               1.0
Copper                                 0.003
COD                                    1.0
pH                       Within the range of 7.5 to 9.0
                               822

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                  SECONDARY ALUMINUM SUBCATEGORY

                            SECTION X

        BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE


The effluent limitations which must be achieved by July  1,  1984
are based on cne b^st control and treatment  technology used by a
specific point source within the industrial  category or  sub-
category, or by another industry where it is readily transfera-
ble.  Emphasis is placed on additional treatment techniques
applied at the end of the treatment systems  currently used  for
BPT, as well as reduction of the amount of water used and dis-
charged, 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).  At a minimum, 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 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 effluent reduction  benefits
(see Weyerhaeuser v. Costle, 11 ERG 2149 (D.C. Cir. 1978)).
However, in assessing the proposed BAT, the Agency has given
substantial weight to the economic achievability of the
technology.

TECHNICAL APPROACH TO BAT

In pursuing this second round of effuent regulations, EPA
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 three technology
alternatives which could be applied to the secondary aluminum
subcategory as BAT options.

In  summary, the treatment technologies considered for BAT are
presented below:
                              823

-------
Option A (Figure X-l) is based on

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing wastewater with
        ammonia steam stripping
     o  In-process flow reduction of direct chill casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation

Option C (Figure X-2) is based on

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing wastewater with
        ammonia steam stripping
     o  In-process flow reduction of direct chill casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration

Option F (Figure X-3) is based on

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing wastewater with
        ammonia steam stripping
     o  In-process flow reduction of direct chill casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration
     o  Reverse osmosis and multiple-effect evaporation for
        complete recycle of treated water

The three options for BAT are discussed in greater detail below.
The first option considered is the same at the BPT treatment and
control technology.

OPTION A

Option A for the secondary aluminum subcategory is equivalent to
BPT treatment.  Option A requires control and treatment techolo-
gies to reduce the discharge of wastewater volume and pollutant
mass.   These measures include in-process changes, resulting in
the elimination of some wastewater streams and the concentration
of pollutants in other effluents.  As explained in Section VII of
the General Development Document, treatment of a more concen-
trated effluent allows achievement of a greater net pollutant
                               824

-------
removal and introduces the possible economic benefits associated
with treating a lower volume of wastewater.  Methods used  in
Option A to reduce process wastewater generation or discharge
rates include the following:

Recycle of Casting Contact Cooling Water Through Cooling Towers

The cooling and recycle of contact cooling water is practiced by
25 of the 38 plants reporting this wastewater.  The function of
casting contact cooling water is to quickly remove heat from the
newly formed ingot or bar.  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 category experience with
casting contact cooling wastewaters to assure the success  of this
technology using cooling towers or heat exchangers (refer  to
Section VII of the General Development Document).  Although 22
plants have reported that they do not discharge any quench water
by reason of 100 percent recycle, a blowdown or periodic cleaning
is likely to be needed to prevent a buildup of dissolved and
suspended solids.  (EPA has determined that a blowdown of  10
percent of the water applied in a process is adequate.)

Recycle of Water Used in Wet Air Pollution Control

There are two wastewater sources associated with wet air
pollution control which are regulated under these effluent
limitations:

     1.  Scrap drying, and
     2.  Demagging.

Table X-l presents the number of plants reporting wastewater use
with these sources, the number of plants practicing recycle of
scrubber liquor, and the range of recycle values being used.

The Option A treatment scheme includes in-process flow reduction,
steam stripping preliminary treatment of wastewaters containing
ammonia at treatable concentrations and oil skimming, where
required.   Preliminary treatment is followed by chemical precipi-
tation and sedimentation (see Figure X-l).  Although oil and
grease is a conventional pollutant limited under best conven-
tional technology (BCT), oil skimming is needed for BAT to ensure
proper metals removal.  Oil and grease interferes with the chemi-
cal addition and mixing required for chemical precipitation
treatment.   Chemical precipitation is used to remove metals by
the addition of lime followed by gravity sedimentation.
Suspended solids are also removed from the process.
                               825

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OPTION C

Option C for the secondary aluminum subcategory builds upon  the
Option A control and treatment technology of in-process flow
reduction, oil skimming  (where required), ammonia steam strip-
ping, chemical precipitation, and sedimentation by adding multi-
media filtration technology at the end of the Option A treatment
scheme (see Figure X-2).  Multimedia filtration is used to remove
suspended solids, including precipitates of metals, beyond 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.

OPTION F

Option F for the secondary aluminum subcategory builds upon  the
Option C control and treatment technology of in-process flow
reduction, oil skimming  (where required), ammonia steam strip-
ping, chemical precipitation, sedimentation, and multimedia
filtration with the addition of reverse osmosis and evaporation
technology at the end of the Option C treatment train (see Figure
X-3).  Option F is used  for complete recycle of the treated
wastewater by controlling the concentration of dissolved solids.
Multiple-effect evaporation is used to dewater brines rejected
from reverse osmosis.

Other treatment technologies included additional in-process  flow
reduction (Option B), activated alumina adsorption (Option D),
and activated carbon adsorption (Option E).   These technologies
were not considered because they are not applicable to the
secondary aluminum subcategory.  Option B does not apply since
in-process wastewater flow reduction is part of the Option A
technology.   EPA believes that no additional in-process waste-
water flow reduction is  achievable for this subcategory.  Since
arsenic was not selected for consideration for limitation in the
secondary aluminum subcategory, activated alumina technology
(Option D) was not considered because it is not applicable.   (For
pollutant selection refer to Section VI, p.  787 .)  Since no
toxic organic pollutants were selected for consideration for
limitation in this subcategory, activated carbon technology
(Option E) also is not applicable.

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

As a means of evaluating each technology option, EPA developed
estimates of the pollutant reduction benefits and the compliance
costs associated with each option.  The methodologies are
described below.
                               826

-------
POLLUTANT REDUCTION BENEFITS

A complete description of the methodology used  to  calculate  the
estimated pollutant reduction, or benefit, achieved by  the appli-
cation of the various treatment  options  is presented  in Section X
of the General Development Document.   In short, sampling data
collected during the field sampling program were used to charac-
terize the major waste streams considered for regulation.  At
each sampled facility, the sampling data was production normal-
ized 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 secondary aluminum  subcategory.  By multi-
plying 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 by multiplying the  regulatory flow
determined for each unit process by the  total subcategory produc-
tion.  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  dis-
charged by the subcategory.  The mass  of pollutant removed,
referred to as the benefit, is simply  the difference  between the
estimated mass of pollutant generated  within the subcategory and
the mass of pollutant discharged after application of the treat-
ment option.

The Agency varied this procedure slightly in computing  estimated
BPT discharge in a subcategory where there is an existing BPT
limitation.  In this case, EPA took the  mass limits from the BPT
limitations (for all pollutants  limited  at BPT) and multiplied
these limits by the total subcategory  production (from  dcp).
(The assumption is that plants are discharging a volume equal to
their BPT allowance times their production.)  Where pollutants
are not controlled by existing BPT, EPA  used the achievable
concentration for the associated technology proposed  in this
document, and multiplied these concentrations by the  total
end-of-pipe discharge of process wastewater for the subcategory
(from dcp).  The total of both these calculations represents
estimated mass loadings for the subcategory.  The pollutant
reduction benefit estimates for direct dischargers in the
secondary aluminum subcategory are presented in Table X-2.

COMPLIANCE COSTS

In estimating subcategory-wide compliance costs, the  first step
was to develop uniformly-applicable cost curves, relating the
total costs associated with installation and operation  of waste-
water treatment technologies to plant  process wastewater dis-
charge.   EPA applied these curves on a per plant basis,  a plant's
                               827

-------
costs (both capital, and operating and maintenance) being deter-
mined 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 cost
of compliance for the subcategory (see Table X-3).  These costs
were used in assessing economic achievability.

BAT OPTION SELECTION

EPA has selected Option C as the basis of BAT in this subcate-
gory.  The BAT treatment scheme proposed consists of flow reduc-
tion, oil skimming (where required), preliminary treatment of
ammonia steam stripping, lime precipitation, sedimentation, and
filtration for control of toxic metals.  The selected option
increases the removal of toxic pollutants from raw wastewater by
approximately 903 kg/yr and nonconventional pollutants by approx-
imately 541 kg/yr.  This option also removes approximately 17
kg/yr of toxic pollutants and 46 kg/yr of nonconventional pollu-
tants over the estimated BPT discharge.  The estimated capital
cost of proposed BAT is $1.6 million (1978 dollars) and the
annual cost is $1.35 million (1978 dollars).

Ammonia steam stripping is demonstrated in the nonferrous metals
manufacturing category.  One plant in the secondary aluminum sub-
category, one plant in the secondary lead subcategory, two plants
in the primary columbium-tantalum subcategory, and four plants in
the primary tungsten subcategory reported steam stripping in
place.

EPA believes that performance data from the iron and steel manu-
facturing category provide a valid measure of this technology's
performance on nonferrous metals manufacturing category waste-
water because raw wastewater concentrations of ammonia are of the
same order of magnitude in the respective raw wastewater
matrices.

Chemical analysis data were collected of raw waste (treatment
influent) and treated waste (treated effluent) from one coke
plant of the iron and steel manufacturing category.  A contractor
for EPA, using EPA sampling and chemical analysis protocols, col-
lected six paired samples in a two-month period.  These data are
the data base for determining the effectiveness of ammonia steam
stripping technology and are contained within the public record
supporting this document.  Ammonia treatment at this coke plant
consisted of two steam stripping columns in series with steam
injected countercurrently to the flow of the wastewater.  A lime
reactor for pH adjustment separated the two stripping columns.
                               828

-------
                    stewater samples  from the coke  facility  con-
                    ntrations of 599, 226, 819, 502, 984, and  797
                     wstewater samples  from the secondary alumi-
                    ained an ammonia  concentration  of 195 mg/1.

                    oves additional toxic and nonconventional
                    conomically achievable, it is included as
     v±. pvwpw^v- ~^~.  Filtration also  adds to the  treatment
system reliability by making it less  susceptible to operator
error and to sudden changes in raw wastewater flows and
concentrations.

Reverse osmosis (Option F) was considered for the purpose of
achieving zero discharge of process wastewater pollutants;
however, it was rejected because it is  not adequately demon-
strated in this subcategory nor is it clearly transferable from
another category.

WASTEWATER DISCHARGE RATES

Specific wastewater streams associated  with the secondary alumi-
num subcategory are generated from scrap drying air pollution
control, scrap screening and milling, dross washing, demagging
air pollution control, direct chill casting contact cooling, and
shot casting contact cooling.

Table X-4 lists the production normalized wastewater discharge
rates allocated at BAT for these wastewater streams.  The values
represent the best existing practices of the industry, as deter-
mined from the analysis of dcps.  Individual discharge rates from
the plants surveyed are presented in  Section V of this supplement
for each wastewater stream.

SCRAP DRYING WET AIR POLLUTION CONTROL  WASTEWATER

No BAT wastewater discharge allowance is provided for scrap
drying air pollution control.  Only three of 29 plants use
scrubbers to control emissions; the remaining 26 plants use
baghouses.  Two of the three plants with scrubbers  achieve zero
discharge by 100 percent recycle.  One  plant is a once-through
discharger with a rate of 1,057 1/kkg (253.5 gal/ton) of aluminum
scrap produced.  Wastewater rates are presented in  Section V
(Table V-l).  The BAT allowance is zero discharge of wastewater
pollutants based on the attainment of no discharge  by 28 of 29
plants including two of the three operations using wet air
pollution control.

SCRAP SCREENING AND MILLING

No BAT wastewater discharge rate is provided for scrap screening
and milling.  Both plants reporting this wastewater are zero
                               829

-------
dischargers because of 100 percent recycle or reuse.  Therefore,
the Agency believes that zero discharge is possible for all
secondary aluminum scrap screening and milling processes.

DROSS WASHING WASTEWATER

The BAT wastewater discharge rate is 10,868 1/kkg  (2,607 gal/ton)
of dross processed.  Four plants reported producing this waste-
water.  One plant discharges after 67 percent recycle and the BAT
rate is the discharge from this plant.  Two plants recycle 100
percent of the wastewater and the fourth plant evaporates 100
percent.  EPA considers the zero discharge practices for this
waste stream to be site-specific and not applicable on a nation-
wide basis.  Wastewater rates for dross washing are presented in
Section V (Table V-3).

DEMAGGING WET AIR POLLUTION CONTROL

The BAT wastewater discharge rate is 800 1/kkg (192 gal/ton) of
aluminum demagged.  This rate is allocated only for plants prac-
ticing wet air pollution control of demagging operations.  Of the
37 demagging operations reported, 19 use water for emissions con-
trol.  Nine plants using water reported no wastewater discharge,
achieved by recycle or reuse.  Eight of the nine plants com-
pletely recycle the wastewater, while one plant did not report a
recycle percentage.  Another plant practices a partial recycle of
40 percent.  Nine plants have once-through operations, eight of
these discharging 223.3 to 1,956.24 1/kkg (54.5 to 469.2 gal/
ton).  No flow data were provided by one of the discharging
plants.  A distribution of wastewater rates is presented in Table
V-5.  Industry comments on a draft of this document asserted that
the use of recirculation systems using treated water reduces
demagging scrubber efficiency.  Therefore, recycle of scrubber
liquor was not used as a basis for the BAT discharge rate for
demagging wet air pollution control.  The BAT discharge rate is
based on the average of the nine discharging plants.  Fifteen of
the 19 plants with demagging wet air pollution control meet the
BAT rate.

DIRECT CHILL CASTING CONTACT COOLING WATER

The BAT wastewater discharge rate for direct chill casting
contact cooling water is 1,999 1/kkg  (479.4 gal/ton) of aluminum
cast.  There is a trend in the secondary aluminum subcategory
toward converting to direct chill casting.  Direct chill casting
practices and the wastewater discharge from this operation are
similar in aluminum forming, primary aluminum reduction and
secondary aluminum plants.  The information available does not
indicate any significant difference in the amount of water
required for direct chill casting in a primary aluminum, second-
ary aluminum and aluminum forming plants.  For this reason,
                               830

-------
available wastewater data  from aluminum  forming  and  primary
aluminum plants were considered together in establishing BPT
effluent limitations.  No  data for  direct  chill  casting water  use
were provided by secondary aluminum plants

In all, 27 primary aluminum plants  and 61  aluminum forming plants
have direct chill casting  operations.  Recycle of the  contact
cooling water is practiced at 30 aluminum  forming and  18 primary
aluminum plants.  Of these, 12 plants indicated  that total recy-
cle of this stream made it possible to avoid any discharge of
wastewater; however, the majority of the plants  discharge a bleed
stream.  The discharge flow for this operation is based on the
average of the best, which is the average  normalized discharge
flow of the 29 plants that practice recycle.

STATIONARY CASTING CONTACT COOLING  WATER

No BAT wastewater discharge allowance is  provided for  stationary
casting cooling.  In the stationary casting method, molten alumi-
num is poured into cast iron molds  and then generally  allowed  to
air cool.  The Agency is aware of the use  of spray quenching to
quickly cool the surface of the molten aluminum  once it is cast
into the molds; however, this water evaporates on contact with
the molten aluminum.  As such, the  Agency  believes that there  is
no basis for a pollutant discharge  allowance.

SHOT CASTING CONTACT COOLING WATER

No BAT wastewater discharge allowance is provided for  shot
casting contact cooling.   In the secondary aluminum dcp summary,
22 of 35 plants reporting  casting contact  cooling water achieve
zero discharge through complete recycle  or evaporation.  EPA
believes zero discharge is feasible for  all secondary  aluminum
shot casting processes.

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)  (19T6J, 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 eight pollutants and pollutant parameters are present in
secondary aluminum wastewaters at concentrations that  can be
effectively reduced by identified treatment technologies.  (Refer
to Section VI, p. 797).

However, the high cost associated with analysis  for toxic metal
pollutants has prompted EPA to develop an  alternative  method for
                               831

-------
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 waste-
waters from a given subcategory, the Agency is proposing effluent
mass limitations only for those pollutants generated in the
greatest quantities as shown by the pollutant reduction benefit
analysis.  The pollutants selected for specific limitation are
listed below:

     122.  lead
     128.  zinc
           aluminum
           ammonia

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 technically justified since the treatable con-
centrations used for lime precipitation and sedimentation tech-
nology are based on optimized treatment for concommitant 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 tech-
nology removes metals non-preferentially.

The toxic metal pollutants selected for specific limitation in
the secondary aluminum subcategory to control the discharges of
toxic metal pollutants are lead and zinc.  Ammonia is also
selected for limitation since the methods used to control lead
and zinc are not effective in the control of ammonia.

The following toxic pollutant is excluded from limitation on the
basis that it is effectively controlled by the limitations
developed for lead and zinc:

     118.  cadmium

The conventional pollutant parameters oil and grease, TSS, and pH
will be limited by the best conventional technology (BCT) efflu-
ent limitations.  These effluent limitations and a discussion of
BCT are presented in Section XIII of this supplement.

EFFLUENT LIMITATIONS

The treatable concentrations achievable by application of the BAT
treatment are discussed in Section VII of the General Development
                               832

-------
Document and summarized there in Table VII-19.  The treatable
concentrations (both one day maximum and monthly average values)
are multiplied by the BAT normalized discharge flows summarized
in Table X-4 to calculate the mass of pollutants allowed to be
discharged per mass of product.  The results of these calcula-
tions in milligrams of pollutant per metric ton of product repre-
sent the BAT effluent limitations and are presented in Table X-5
for each waste stream.
                              833

-------
                           Table X-l

    CURRENT RECYCLE PRACTICES WITHIN  THE SECONDARY .ALUMINUM
                          SUBCATEGORY
                                       Number of
                         Number of       Plants        Range of
                        Plants With    Practicing     Recycle
    Waste Stream        Wastewater      Recycle       Values (%)

Scrap Drying Wet Air         3              2            100
 Pollution Control

Demagging Wet Air           19              9         40 -  100
 Pollution Control
                              834

-------
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                        Table X-3

COST OF COMPLIANCE FOR THE SECONDARY ALUMINUM SUBCATEGORY
                    DIRECT DISCHARGERS
                   Capital Cost       Annual Cost
       Option     (1978 Dollars)     (1978 Dollars)

         A          1,510,000          1,310,000

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-------
                            Table X-5

 BAT EFFLUENT LIMITATIONS FOR THE SECONDARY ALUMINUM SUBCATEGORY


              Scrap Drying Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          00


                   Scrap Screening and Milling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          00


                          Dross Washing

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80          978.12
Zinc                               11,085.36        4,564.56
Aluminum                           32,930.04       13,476.32
Ammonia (as N)                  1,445,444.0       636,864.80
                               338

-------
                      Table X-5 (Continued)

 BAT EFFLUENT LIMITATIONS FOR THE SECONDARY ALUMINUM SUBCATEGORY


               Demagging Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Lead                                   80.0            72.0
Zinc                                  816.0           336.0
Aluminum                            2,424.0           992.0
Ammonia (as N)                    106,400.0        46,880.0


               Direct Chill Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

      Metric Units - mg/kkg of aluminum product from direct
                          chill casting
     English Units - Ibs/billion Ibs of aluminum product from
                       direct chill casting

Lead                                  199.90          179.91
Zinc                                2,038.98          839.58
Aluminum                            6,056.97        2,478.76
Ammonia (as N)                    265,867.0       117,141.40


                Stationary Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of aluminum produced from stationary
                             casting
    English Units - Ibs/billion Ibs of aluminum produced from
                        stationary casting

Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          0               0
                              839

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                      Table X-5 (Continued)

 BAT EFFLUENT LIMITATIONS FOR THE SECONDARY ALUMINUM SUBCATEGORY


                   Shot Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of aluminum produced from shot casting
    English Units - Ibs/billion Ibs of aluminum produced from
                           shot casting


Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          0               0
                              840

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                  SECONDARY ALUMINUM  SUBCATEGORY

                            SECTION XI

                 NEW SOURCE PERFORMANCE STANDARDS
INTRODUCTION
The basts for new source performance  standards  (NSPS) under Sec-
tion 306 of the Act if the best available demonstrated  technol-
ogy (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, Con-
gress directed EPA to consider the best demonstrated process
changes, in-plant controls, and end-of-pipe treatment technolo-
gies 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  limita-
tions of regulatory pollutants for NSPS in the  secondary aluminum
subcategory, based on the described control technology.

TECHNICAL APPROACH TO BDT

As discussed in the General Development Document,  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, all identical to the BAT
options discussed in Section X.  The  treatment  technologies used
for the three BDT options are:

OPTION A

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing  wastewater with
        ammonia steam stripping
     o  In-process flow reduction of  direct chill  casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation

OPTION C

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing  wastewater with
        ammonia steam stripping
     o  In-process flow reduction of  direct chill  casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration
                              84.S

-------
OPTION F

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing wastewater with
        ammonia steam stripping
     o  In-process flow reduction of direct chill casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration
     o  Reverse osmosis and multiple-effect evaporation for
        complete recycle of treated water

Partial or complete reuse and recycle of wastewater is an essen-
tial 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 promulgated the best available demonstrated technology for
the secondary aluminum subcategory on April 8, 1974 as Subpart C
of 40 CFR Part 421.  The promulgated NSPS prohibits the discharge
of process wastewater except for an allowance, if determined to
be necessary, which allows the discharge of process wastewater
from chlorine demagging.  In this respect, promulgated NSPS was
less stringent than promulgated BAT.  The Agency did this recog-
nizing that NSPS became effective on the data of promulgation and
did not believe that the dry chlorine demagging processes were
immediately available.  The Agency believes that they were
appropriate for BAT with its compliance date being 10 years
later.

EPA is proposing to modify the promulgated NSPS to allow for a
discharge from chlorine demagging and direct chill casting.  The
discharge allowances are identical to those proposed for BAT.
The technology basis is also identical to that of the proposed
BAT treatment consisting of in-process flow reduction, prelimi-
nary treatment by oil skimming and ammonia steam stripping, lime
precipitation, sedimentation and filtration (Option C).

Reverse osmosis is not demonstrated and is not clearly transfer-
able to nonferrous metals manufacturing wastewater.  The Agency
also does not believe that new plants could achieve any addi-
ional flow reduction for chlorine demagging and direct chill
casting beyond that proposed for BAT.
                               846

-------
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
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, oil and grease, 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 all the BAT options and are presented
in Table XI-1.  The mass of pollutant allowed to be discharged
per mass of product is calculated by multiplying the appropriate
achievable treatment concentration by the production normalized
wastewater discharge flows (1/kkg).  The treatable concentrations
are listed in Tables VII-19 of the General Development Document.
New source performance standards for the secondary aluminum
subcategory waste streams are presented in Table XI-2.
                              847

-------
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-------
                            Table XI-2

           NSPS FOR THE SECONDARY ALUMINUM SUBCATEGORY


              Scrap Drying Wet Air Pollution Control.

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          00
Oil and grease                          0               0
TSS                                     0               0
pH                                Within the range 7.5 to 10.0
                                          at all times


                   ScrapScreening and Milling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          00
Oil and grease                          0               0
TSS                                     0               0
pH                                    Within the range of 7.5
                                      to 10.0 at all times
                               849

-------
                      Table XI-2 (Continued)

           NSPS FOR THE SECONDARY ALUMINUM SUBCATEGORY


                          Dross Washing

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80          978.12
Zinc                               11,085.36        4,564.56
Aluminum                           32,930.04       13,476.32
Ammonia (as N)                  1,445,444.0       636,864.80
Oil and grease                    108,680.0       108,680.0
TSS                               163,020.0       130,416.0
pH                                Within the range of 7.5 to 10.0
                                         at all times


               Demagging Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Lead                                   80.0            72.0
Zinc                                  816.0           336.0
Aluminum                            2,424.0           992.0
Ammonia (as N)                    106,400.0        46,880.0
Oil and grease                      8,000.0         8,000.0
TSS                                12,000.0         9,600.0
pH                                 Within the range of 7.5 to
                                      10.0 at all times
                              850

-------
                      Table XI-2  (Continued)

           NSPS FOR THE SECONDARY ALUMINUM SUBCATEGORY


               Direct Chill Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Lead                                  199.90          179.91
Zinc                                2,038.98          839.58
Aluminum                            6,056.97        2,478.76
Ammonia (as N)                    265,867.0       117,141.40
Oil and grease                     19,990.0        19,990.0
TSS                                29,985.0        23,988.0
pH                                 Within the range of 7.5 to
                                    10.0 at all times


                Stationary Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of aluminum produced from stationary
                             casting
    English Units - Ibs/billion Ibs of aluminum produced from
                        stationary casting

Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          00
Oil and grease                          0               0
TSS                                     0               0
pH                                 Within the range of 7.5 to
                                    10.0 at all times
                              851

-------
                      Table XI-2 (Continued)

           NSPS FOR THE SECONDARY ALUMINUM SUBCATEGORY


                   Shot Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of aluminum produced from stationary
                             casting
    English Units - Ibs/billion Ibs of aluminum produced from
                        stationary casting

Lead                                    0               0
Zinc                                    0               0
Aluminum                                0               0
Ammonia (as N)                          00
Oil and grease                          0               0
TSS                                     0               0
pH                                 Within the range of 7.5 to
                                    10.0 at all times
                               852

-------
                  SECONDARY ALUMINUM SUBCATEGORY

                           SECTION XII

                      PRETREATMENT STANDARDS


Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources (PSES), which must be achieved
within three years of promulgation.  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 heavy 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 facili-
ties, 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 instal-
lation.  Pretreatment standards are to be technology based,
analogous to the best available technology for removal of toxic
pollutants.

This section describes the control technology for pretreatment of
process wastewaters from existing sources and new sources in the
secondary aluminum subcategory.  Pretreatment standards for regu-
lated pollutants are presented based on the described control
technology.

TECHNICAL APPROACH TO PRETREATMENT

Before proposing pretreatment standards, the Agency examines
whether the pollutants discharged by the subcategory pass through
the POTW of 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 percentage
removed nationwide by well-operated POTW meeting secondary
treatment requirements, is less than the percentage removed by
direct dischargers complying with BAT effluent limitations
guidelines for that pollutant.  (see generally, 46 FR at 9415-16
(January 28, 1981).

This definition of pass through satisfies two competing objec-
tives set by Congress:  (1) that standards for indirect dis-
chargers be equivalent to standards for direct dischargers, while
                               853

-------
at the same time, (2) that the treatment capability and perfor-
mance of the POTW be recognized and taken into account in regula-
ting 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 pollu-
tants in the POTW effluent to lower concentrations due to the
addition of large amounts of non-industrial wastewater.

PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES

Options for pretreatment of wastewaters from both existing and
new sources are based on increasing the effectiveness of end-of-
pipe treatment technologies.  All in-plant changes and applicable
end-of-pipe treatment processes have been discussed previously in
Sections X and XI.  The options for PSNS and PSES, therefore, are
the same as the BAT options discussed in Section X.  Although oil
and grease is a conventional pollutant compatible with treatment
provided by POTW, oil skimming is needed for the PSNS treatment
technology to ensure proper removal.  Oil and grease interferes
with the chemical addition and mixing required for chemical
precipitation and treatment.

A description of each option is presented in Section X, while a
more detailed discussion, including pollutants controlled by each
treatment process and achievable treatment concentrations is
presented in Section VII of the General Development Document.

Treatment technology options for the PSES and PSNS are:

OPTION A

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing wastewater with
        ammonia steam stripping
     o  In-process flow reduction of direct chill casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation

OPTION C

     o  Preliminary treatment with oil skimming (where required)
     o  Preliminary treatment of dross washing wastewater with
        ammonia steam stripping
     o  In-process flow reduction of direct chill casting contact
        cooling water and scrubber liquor resulting from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration
                               854

-------
OPTION F

     o  Preliminary treatment with oil skimming  (where required)
     o  Preliminary treatment of dross washing wastewater with
        ammonia steam stripping
     o  In-process flow reduction of direct chill casting contact
        cooling water and scrubber liquor resulting  from scrap
        drying wet air pollution control
     o  Chemical precipitation and sedimentation
     o  Multimedia filtration
     o  Reverse osmosis and multiple-effect evaporation for
        complete recycle of treated water

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

The industry cost and environmental benefits of each treatment
option were used to determine the most cost-effective option.
The methodology applied in calculating pollutant reduction
benefits and plant compliance costs is discussed in Section X.

Table XII-1 shows the estimated pollutant reduction benefits  for
indirect dischargers.  Compliance costs are presented in Table
XII-2.

FSES AND PSNS OPTION SELECTION

The technology basis for proposed PSES and PSNS is identical  to
BAT (Option C).  The treatment scheme consists of in-process  flow
reduction, preliminary treatment with ammonia steam stripping and
oil skimming (where required), followed by lime precipitation,
sedimentation, and filtration.  EPA knows of no demonstrated
technology that provides more efficient pollutant removal than
BAT technology.  No additional flow reduction for new sources is
feasible because the only other available flow reduction technol-
ogy, reverse osmosis (Option F) is not adequately demonstrated
nor is it clearly transferable for this subcategory.

Since the proposed PSNS does not increase costs compared to PSES
of BAT, it is not expected to prevent the entry of new plants
into the subcategory.  The selected option for proposed PSES
increases the removal of approximately 1,214 kg/yr of toxic
pollutants over the estimated raw discharge.  The estimated
capital cost of proposed PSES is $2.4 million (1978 dollars)  and
the annual cost is $1.6 million (1978 dollars).

REGULATED POLLUTANT PARAMETERS

Pollutants selected for regulation under PSES and PSNS are
identical to those selected for regulation for BAT.  The conven-
tional pollutants oil and grease, TSS, and pH are not limited
under PSES and PSNS because they are effectively controlled by
                               855

-------
POTW.  PSES and PSNS prevent the pass-through of lead, zinc, and
ammonia.  Aluminum is not limited because in its hydroxide form
it is used by POTW as a flocculant aid in the settling and
removal of suspended solids.  As such, aluminum in limited
quantities does not pass through or interfere with POTW; rather
it is a necessary aid to its operation.

PRETREATMENT STANDARDS

In proposing PSES and PSNS, the Agency considered whether to
propose exclusively mass-based standards, or to allow a POTW the
alternative of concentration or mass-based standards.  Mass-based
standards ensure that limitations are achieved by means of pollu-
tant removal rather than by dilution.  They are particularly
important when a limitation is based upon flow reduction because
pollutant limitations associated with the flow reduction cannot
be measured any way but as a reduction of mass discharged.
Mass-based standards, however, are harder to implement because a
POTW faces increased difficulties in monitoring.  A POTW also
must develop specific limits for each plant based on the unit
operations present and the production occurring in each opera-
tion.

EPA resolved these competing considerations by proposing mass-
based standards exclusively where the PSES and PSNS treatment
options include significant flow reductions or where significant
pollutant removals are attibutable to flow reductions.  Flow
reduction over current discharge rates is minimal (0.2 percent)
in the secondary aluminum subcategory.  For secondary aluminum,
EPA has concluded that the proposed PSES should provide alterna-
tive mass-based and concentration-based standards.

The Agency is not proposing alternative mass- and concentra-
tion-based PSNS for the secondary aluminum subcategory, since
PSNS include significant flow reduction (90 percent flow
reduction of direct chill casting).

The PSES and PSNS discharge flows for mass-based standards are
identical to the BAT discharge flows for all processes.  These
discharge flows are listed in Table XII-3.  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-19 of the
General Development Document.  Concentration-based PSES are iden-
tical to the achievable treatment concentrations.  Mass and con-
centration-based PSES are presented in Tables XII-4 and XII-5,
respectively.  PSNS are shown in Table XII-6.
                               856

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-------
                       Table XII-2

COST OF COMPLIANCE FOR THE SECONDARY ALUMINUM SUBCATEGORY
                   INDIRECT DISCHARGERS
                   Capital Cost       Annual Cost
       Option     (1978 Dollars)     (1978 Dollars)

         A          2,200,000          1,500,000

         C          2,400,000          1,600,000

         F          3,080,000          1,900,000
                           858

-------
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-------
                           Table XII-4

           PSES FOR THE SECONDARY ALUMINUM SUBCATEGORY
                           (MASS-BASED)


              Scrap Drying Vet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          0               0


                   Scrap Screening and Milling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00


                          Dross Washing

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80          978.12
Zinc                               11,085.36        4,564.56
Ammonia (as N)                  1,445,444.0       636,864.80
                              860

-------
                     Table XII-4 (Continued)

           PSES FOR THE SECONDARY ALUMINUM SUBCATEGORY
                           (MASS-BASED)


               Demagglng Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Lead                                   80.0            72.0
Zinc                                  816.0           336.0
Ammonia (as N)                    106,400.0        46,880.0


               Direct ChillCasting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Lead                                  199.90          179.91
Zinc                                2,038.98          839.58
Ammonia (as N)                    265,867.0       117,141.40


                Stationary Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                        stationary casting
       English Units - Ibs/billion Ibs of aluminum produced
                     from stationary casting

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00
                              861

-------
                     Table XII-4 (Continued)

           PSES FOR THE SECONDARY ALUMINUM SUBCATEGORY
                           (MASS-BASED)


                   Shot Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of aluminum produced from shot casting
    English Units - Ibs/billion Ibs of aluminum produced from
                           shot casting

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00
                               862

-------
                           Table XII-5

           PSES FOR THE SECONDARY ALUMINUM SUBCATEGORY
                      (CONCENTRATION-BASED)


                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                       Metric Units - mg/1
                       English  Units -. ppm

Lead                                    0.10            0.09
Zinc                                    1.02            0.42
Ammonia (as N)                        133              58.6
                              863

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                           Table XII-6

           PSNS FOR THE SECONDARY ALUMINUM SUBCATEGORY


              Scrap Drying Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00


                   Scrap Screening and Milling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00


                          Dross Washing

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Lead                                1,086.80          978.12
Zinc                               11,085.36        4,564.56
Ammonia (as N)                  1,445,444.0       636,864.80
                               864

-------
                     Table XII-6 (Continued)

           PSNS FOR THE SECONDARY ALUMINUM SUBCATEGORY


               Demagging Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

            Metric Units - mg/kkg of aluminum demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Lead                                   80.0            72.0
Zinc                                  816.0           336.0
Ammonia (as N)                    106,400.0        46,880.0


               Direct Chill Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Lead                                  199.90          179.91
Zinc                                2,038.98          839.58
Ammonia (as N)                    265,867.0       117,141.40


                Stationary Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

    Metric Units - mg/kkg of aluminum produced from stationary
                             casting
    English Units - Ibs/billion Ibs of aluminum produced from
                        stationary casting

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00
                               365

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                     Table XII-6 (Continued)

           PSNS FOR THE SECONDARY ALUMINUM SUBCATEGORY


                   Shot Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kke of aluminum produced from shot casting
    English Units - Ibs/billion Ibs of aluminum produced from
                           shot casting

Lead                                    0               0
Zinc                                    0               0
Ammonia (as N)                          00
                               866

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                  SECONDARY ALUMINUM SUBCATEGORY

                           SECTION XIII

          BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
The 1977 amendments to the Clean Water Act added Section
301(b)(2)(E), establishing  "best conventional pollutant control
technology" (BCT) for discharge of conventional pollutants  from
existing industrial point sources.  Biochemical oxygen-demanding
pollutants  (BOD5), total suspended solids (TSS), fecal coli-
form, oil and grease (0&G), and pH have been designated as
conventional pollutants (see 44 FR 44501).

BCT is not an additional limitation, but replaces BAT for the
control of conventional pollutants.  In addition to the other
factors specified in SEction 304(b)(4)(B), the Act requires that
limitations for conventional pollutants be assessed in light of a
two-part cost-reasonableness test.  On October 29, 1982, the
Agency proposed a revised methodology for carrying out BCT  analy-
ses (47 FR 49176).  The purpose of the proposal was to correct
errors in the BCT methodology originally established in 1977.

Part 1 of the proposed BCT test requires that the cost and  level
of reduction of conventional pollutants by industrial discharges
be compared with the cost and level of reduction to remove  the
same type of pollutants by publicly-owned treatment works (POTW).
The POTW comparison figure has been calculated by evaluating the
change in costs and removals between secondary treatment (30 mg/1
BOD and 30 mg/1 TSS) and advanced secondary treatement (10  mg/1
BOD and 10 mg/1 TSS).  The difference in cost is divided by the
difference in pounds of conventional pollutants removed, result-
ing in an estimate of the "dollars per pound" of pollutant
removed, that is used as a benchmark value.  The proposed POTW
test benchmark is $0.30 per pound (1978 dollars).

Part 2 of the BCT test requires that the cost and level of
reduction of conventional pollutants by industrial dischargers be
evaluated internally to the industry.  In order to develop  a
benchmark that assesses a reasonable relationship between cost
and removal,  EPA has developed an industry cost ratio which
compares the dollar per pound of conventional pollutant removed
in going from primary to seondary treatment levels with that of
going from primary to secondary treatment levels with that  of
going from secondary to more advanced treatment levels.  The
basis of costs for the calculation of this ratio are the costs
incurred by a POTW.   EPA used these costs because: they reflect
the treatment technologies most commonly used to remove
conventional pollutants from wastewater; the treatment levels
associated with them compare readily to the levels considered for
                               867

-------
industral dischargers; and the costs are the most reliable for
the treatment levels under consideration.  The proposed industry
subcategory benchmark is 1.42.  If the industry figure for a
subcategory is lower than 1.43, the subcategory passes the BCT
test.

The Agency usually considers two conventional pollutants in the
cost test, TSS and an oxygen-demanding pollutant.  Although both
oil and grease and BOD5 are considered to be oxygen-demanding
substances by EPA (see 44 FR 50733), only one can be selected in
the cost analysis to conform to procedures used to develop POTW
costs.  Oil and grease is used rather than BOD5 in the cost
analysis performed for nonferrous metals manufacturing waste
streams due to the common use of oils in casting operations in
this industry.

BPT is the base for evaluating limitations on conventional
pollutants (i.e., it is assumed that BPT is already in place).
The test evaluates the cost and removals associated with
treatment and controls in addition to that specified as BPT.

If the conventional pollutant removal cost of the candidate BCT
is less than the POTW cost, Part 1 of the cost-reasonableness
test is passed and Part 2 (the internal industry test) of the
cost-reasonableness test must be performed.  If the internal
industry test is passed, then a BCT limitation is promulgated
equivalent to the candidate BCT level.  If all candidate BCT
technologies fail both parts of the cost-reasonableness test, the
BCT requirements for conventional pollutants are equal to BPT.

The BCT test was performed for the proposed BAT basis of lime
precipitation, sedimentation, in-process flow reduction, and
multimedia filtration.  The secondary aluminum subcategory failed
Part 1 of the test with a calculated cost of $15.68 per pound
(1978 dollars) of removal of conventional pollutants using BAT
technology.
                               868

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                           Table XIII-1

 BCT EFFLUENT LIMITATIONS FOR THE SECONDARY ALUMINUM SUBCATEGORY


              Scrap Drying Wet Air Pollution Control

                                  Maximum for      Maximum for
Pollutant or Pollutant Property   Any One Day	Monthly Average

          Metric Units - mg/kkg of aluminum scrap dried
     English Units - Ibs/billion Ibs of aluminum scrap dried

Oil and grease                         0                0
TSS                                    0                0
pH                                Within the range of 7.5 to 10.0
                                          all times


                   Scrap Screening and Milling

                                 Maximum for      Maximum for
Pollutant or Pollutant Property   Any One Day	Monthly Average

   Metric Units - mg/kkg of aluminum scrap screened and milled
    English Units - Ibs/billion Ibs of aluminum scrap screened
                            and milled

Oil and grease                         0                0
TSS                                    0                0
pH                                Within the range of 7.5 to 10.0
                                          all times


                          Dross Washing

                                  Maximum for      Maximum for
Pollutant or Pollutant Property   Any One Day	Monthly Average

              Metric Units - mg/kkg of dross washed
         English Units - Ibs/billion Ibs of dross washed

Oil and grease                   217,360.0        130,416.0
TSS                              445,588.0        217,360.0
pH                                Within the range of 7.5 to 10.0
                                          all times
                               869

-------
                     Table XIII-1 (Continued)

 BCT EFFLUENT LIMITATIONS FOR THE SECONDARY ALUMINUM SUBCATEGORY


               Demagging Wet Air Pollution Control

                                  Maximum for       Maximum for
Pollutant or Pollutant Property   Any One Day	Monthly Average

            Metric Units - mg/kkg of aluminum  demagged
       English Units - Ibs/billion Ibs of aluminum demagged

Oil and grease                    16,000.0          9,600.0
TSS                               32,800.0         16,000.0
pH                                Within the range of 7.5 to 10.0
                                          all  times


               Direct Chill Casting Contact Cooling

                                  Maximum for       Maximum for
Pollutant or Pollutant Property   Any One Day	Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                       direct chill casting
    English Units - Ibs/billion Ibs of aluminum produced from
                       direct chill casting

Oil and grease                    39,980.0         23,988.0
TSS                               81,959.0         39,980.0
pH                                Within the range of 7.5 to 10.0
                                          all  times


                Stationary Casting Contact Cooling

                                  Maximum for       Maximum for
Pollutant or Pollutant Property   Any One Day	Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                        stationary casting
       English Units - Ibs/billion Ibs of aluminum produced
                     from stationary casting

Oil and grease                         0                0
TSS                                    0                0
pH                                Within the range of 7.5 to 10.0
                                          all  times
                               870

-------
                     Table XIII-1 (Continued)

 BCT EFFLUENT LIMITATIONS FOR THE SECONDARY ALUMINUM SUBCATEGORY


                   Shot Casting Contact Cooling

                                  Maximum for      Maximum for
Pollutant or Pollutant Property   Any One Day	Monthly Average

         Metric Units - mg/kkg of aluminum produced from
                           shot casting
    English Units - Ibs/billion Ibs of aluminum produced from
                           shot casting

Oil and grease                         0                0
TSS                                    0                0
pH                                Within the range of 7.5 to 10.0
                                          all times
                               871

-------
                    SECONDARY LEAD SUBCATEGORY

                            SECTION I

                     SUMMARY AND CONCLUSIONS
On April 8, 1974, EPA promulgated technology-based effluent
limitations guidelines and performance standards for several sub-
categories of the Nonferrous Metals Manufacturing Point Source
Category.  These regulations included BPT, BAT, NSPS, and PSNS
limitations.  The main purpose of these effluent guidelines and
standards was to limit the quantities of total suspended solids,
arsenic, zinc, selenium, copper, cadmium, and oil and grease.
The allowable pH ranges for discharges was also limited.

Since 1974, implementation of the technology-based effluent limi-
tations and standards has been guided by a series of settlement
agreements into which EPA entered with several environmental
groups, the latest of which occurred in 1979.  NRDC v. Costie, 12
ERG 1833 (D.D.C. 1979), aff'd and remd'd, EOF v. Costle, 14 ERG
2161 (1980).  Under the settlement agreements, EPA was required
to develop BAT limitations and pretreatment and new source per-
formance standards for 65 classes of pollutants discharged from
specific industrial point source categories.  The list of 65
classes was subsequently expanded to a list of 129 specific toxic
pollutants, and now consists of 126 toxics.

Congress amended the Clean Water Act in 1977 to encompass many of
the provisions of the earlier settlement agreements, including
the list of 65 classes of pollutants.  As a result of the settle-
ment agreements and the Clean Water Act Amendments, EPA undertook
an extensive effort to develop technology-based BAT limitations
and pretreatment and new source performance standards for the
toxic pollutants.

The purpose of this proposed rulemaking is to create the secon-
dary lead subcategory and establish BPT, BAT, and BCT effluent
limitations and NSPS, and pretreatment standards for this sub-
category.  This is done pursuant to the provisions of the
Settlement Agreement and Sections 301, 304, 306, and 307 of the
Clean Water Act and its amendments.  This supplement provides a
compilation and analysis of the background material used to deve-
lop these effluent limitations and standards.

The secondary lead subcategory is comprised of 69 plants.  Of the
69 plants,  seven discharge directly to rivers, lakes,  or streams;
16 discharge to publicly owned treatment works (POTW); and 46 do
not discharge process wastewater.
                               873

-------
EPA first studied the secondary lead subcategory to determine
whether differences in raw materials, final products, manufactur-
ing processes, equipment, age and size of plants, and 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 processes used (2)
the sources and volume of water used, (3) the sources of
pollutants and wastewaters in the plant; and (4) the constituents
(including toxic pollutants) and volume of wastewaters.

EPA also identified several distinct control and treatmemt tech-
nologies (both in-plant and end-of-pipe) applicable to the
secondary lead subcategory.  The Agency analyzed both historical
and newly generated data on the performance of these technolo-
gies, 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 category.  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 employees affected,
and impact on price were estimated.  These results are reported
in a separate document entitled Economic Impact Analysis of
Proposed Effluent Standards and Limitations for the Nonferrous
Smelting and Refining Industry.

Based on consideration of the above factors, EPA identified vari-
ous control and treatment technologies which formed the basis for
BPT and selected control and treatment appropriate for each set
of standards and limitations.  The mass limitations and standards
for BPT, BAT, NSPS, PSES, PSNS, and BCT are presented in Section
II.

After examining the various treatment technologies, the Agency
has identified BPT to represent the average of the best existing
technology.  Metals removal based on lime precipitation and
sedimentation is the basis for the BPT limitations.  Wastewater
discharge rates used in developing BPT effluent limitations
represent the average of the subcategory discharge and usage for
process wastewater.  To meet the BPT effluent limitations based
on this technology, the secondary lead subcategory is estimated
to incur a capital cost of $0.470 million (1978 dollars) and an
annual cost of $0.228 million (1978 dollars).
                               874

-------
Due to current adverse structural economic changes that are not
reflected in EPA's current economic analysis, the Agency has
identified alternative technologies as a basis for BAT effluent
limitations.  For Alternative A, the Agency has built upon the
BPT basis of lime precipitation and sedimentation for metals
removed by adding in-process control technologies which include
recycle of process water from air pollution control and metal
contact cooling waste streams.  To meet the Alternative A BAT
effluent limitations, the secondary lead subcategory will incur
an estimated capital cost of $0.470 million (1978 dollars) and an
annual cost of $0.228 million (1978 dollars).  For Alternative B,
filtration is added as an effluent polishing step to the in-pro-
cess flow reduction, lime precipitation, and sedimentation tech-
nology considered in Alternative A.  To meet the Alternative B
BAT effluent limitations, the secondary lead subcategory will
incur an estimated capital cost of $2.12 million (1978 dollars)
and an annual cost of $1.36 million (1978 dollars).

The best demonstrated technology, BDT, which is the technical
basis of NSPS, is equivalent to BAT.  In selected BDT, EPA
recognizes that new plants have the opportunity to implement the
best and most efficient manufacturing processes and treatment
technology.  However, the technology basis of BAT has been
determined as the best demonstrated technology because no
additional process modifications or treatment technologies have
been identified that substantially improve BAT performance.

The Agency selected the same alternative technologies as BAT for
PSES.  To meet the Alternative A pretreatment standards for
existing sources, the secondary lead subcategory will incur an
estimated capital cost of $1.49 million (1978 dollars) and an
annual cost of $0.559 million (1978 dollars).

Alternative B pretreatment standards for existing sources are
estimated to result in a capital cost of $3.04 million (1978
dollars) and an annual cost of $1.94 million (1978 dollars).  For
pretreatment standards for new sources (PSNS), the Agency
selected end-of-pipe treatment and in-process flow reduction
control techniques equivalent to BDT.  As such, the PSNS are
identical to the NSPS for all waste streams.

The Agency is also proposing BCT effluent limitations at this
time.  The best conventional technology (BCT) replaces BAT for
the control of conventional pollutants.  The technology basis of
BCT is the BPT treatment of lime precipitation and sedimentation.
                               875

-------
                    SECONDARY LEAD SUBCATEGORY

                            SECTION II

                         RECOMMENDATIONS
 1.  EPA has divided the secondary lead subcategory into four
     subdivisions for the purpose of effluent limitations and
     standards.  These subdivisions are:

     (a)  Battery Cracking,
     (b)  Blast and Reverberatory Furnace Wet Air Pollution
          Control,
     (c)  Kettle Wet Air Pollution Control, and
     (d)  Casting Contact Cooling.

 2.  BPT is proposed based on the performance achievable by
     the application of chemical precipitation and sedimenta-
     tion (lime and settle) technology.  The following
     BPT effluent limitations are proposed:
     (a)  Battery Cracking
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum  for
jlonthly Average
           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    2,697.80        1,193.80
    1,964.60          808.40
      141.0           122.20
    1,250.20          526.40
        0.0             0.0
   38,540.0        18,800.0
Within the range of 7.5 to 10.0
         at all times
                                877

-------
     (b)  Blast and Reverberatory Furnace Wet Air Pollution
          Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
MonthlyAverage
       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
PH
    9,700.60
    7,064.20
      507.0
    4,495.40
        0.0
  138,580.0
    4,292.60
    2,906.80
      439.40
    1,892.80
        0.0
   67,600.0
Within the range of 7.5 to 10.0
         at all times
     (c)  Kettle Wet Air Pollution Control
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
Within the range of 7.5 to 10.0
         at all times
                               878

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     (d)  Casting Contact Cooling
          BPT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
      634.84          280.92
      462.31          190.23
       33.18           28.76
      294.20          123.87
        0.0             0.0
    9,069.20        4,424.0
Within the range of 7.5 to 10.0
         at all times
 3.  EPA is proposing two technology alternatives for BAT for the
     secondary lead subcategory.

     BAT Alternative A is proposed based on the performance
     achievable by the application of chemical precipitation
     and sedimentation (lime and settle) technology and in-
     process flow reduction control methods.  The follow-
     ing BAT effluent limitations are proposed for existing
     sources:
     (a)  Battery Cracking
          BAT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
    1,931.51
    1,406.57
      100.95
      895.09
        0.0
      854.71
      578.78
       87.49
      376.88
        0.0
                               379

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     (b)   Blast and Reverberatory Furnace Wet Air Pollution
           Control
           BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              7,490.7         3,314.7
Arsenic                               5,454.9         2,244.6
Lead                                    391.5           339.3
Zinc                                  3,471.30        1,461.6
Ammonia (as N)                            0.0             0.0

     (c)  Kettle Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            00

     (d)  Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 63.43           28.07
Arsenic                                  46.19           19.01
Lead                                      3.32            2.87
Zinc                                     29.39           12.38
Ammonia (as N)                            0.0             0.0
                               880

-------
     BAT Alternative B is proposed based on the performance
     achievable by the! application of chemical precipitation
     sedimentation, an|d multimedia filtration  (lime, settle,
     and filter) technology and in-process flow reduction
     control methods.  The following BAT effluent  limitations
     are proposed for existing sources:

     (a)  Battery Cracking
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                               1298.89          578.78
Arsenic                                 935.47          383.61
Lead                                     67.30           60.57
Zinc                                    686.46          282.66
Ammonia (as N)                            0.0             0.0

     (b)  Blast and Reverberatory Furnace Wet Air
          Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              5,037.30        2,244.60
Arsenic                               3,627.90        1,487.70
Lead                                    261.0           234.90
Zinc                                  2,662.20        1,096.20
Ammonia (as N)                            0.0             0.0

     (c)  Kettle Wet Air Pollution Control
          BAT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            00

                               881

-------
     (d)  Casting Contact Cooling
          BAT EFFLUENT LIMITATIONS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
       42.65
       30.72
        2.21
       22.54
        0.0
       19.01
       12.60
        1.99
        9.28
        0.0
 4.  NSPS are proposed based on the performance achievable
     by the application of chemical precipitation, sedimentation
     and multimedia filtration (lime, settle, and filter)
     technology and in-process flow reduction control methods.
     The following effluent standards are proposed for new
     sources:
     (a)  Battery Cracking NSPS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    1,298.89          578.78
      935.47          383.61
       67.30           60.57
      686.46          282.66
        0.0             0.0
   10,095.0         8,076.0
Within the range of 7.5 to 10.0
         at all times
                               882

-------
      (b)  Blast and Reverberatory Furnace Wet Air Pollution
          Control NSPS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
PH
    5,037.30
    3,627.90
      261.0
    2,662.0
        0
   39,150.0
    2,244.60
    1,487.70
      234.90
    1,096.20
        0
   31,320.0
Within the range of 7.5 to 10.0
         at all times
      (c)  Kettle Wet Air Pollution Control NSPS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
PH
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
Within the range of 7.5 to 10.0
         at all times
     (d)  Casting Contact Cooling NSPS
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
PH
       42.65           19.01
       30.72           12.60
        2.21            1.99
       22.54            9.28
        0.0             0.0
      331.50          265.20
Within the range of 7.5 to 10.0
         at all times
                               883

-------
 5.  EPA is proposing two technology alternatives for PSES for
     the secondary lead subcategory.

     PSES Alternative A is proposed based on the performance
     achievable by the application of chemical precipitation
     and sedimentation (lime and settle) technology and in-
     process flow reduction control methods.  The follow-
     ing pretreatment standards are proposed:

     (a)  Battery Cracking PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                              1,931.51          854.71
Arsenic                               1,406.57          578.78
Lead                                    100.95           87.49
Zinc                                    895.09          376.88
Ammonia (as N)                            0.0             0.0

     (b)  Blast and Reverberatory Furnace Wet Air Pollution
          Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              7,490.7    -     3,314.7
Arsenic                               5,454.9         2,244.6
Lead                                    391.5           339.3
Zinc                                  3,471.30        1,461.6
Ammonia (as N)                            0.0             0.0

     (c)  Kettle Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            00


                               884

-------
     (d)  Casting Contact Cooling PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 63.43           28.07
Arsenic                                  46.19           19.01
Lead                                      3.32            2.87
Zinc                                     29.39           12.38
Ammonia (as N)                            0.0             0.0

     PSES Alternative B is proposed based on the performance
     achievable by the application of chemical precipitation,
     sedimentation, and multimedia filtration (lime, settle,
     and filter) technology and in-process flow reduction
     control methods.  The following pretreatment standards
     are proposed:

     (a)  Battery Cracking PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                              1,298.89          578.78
Arsenic                                 935.47          383.61
Lead                                     67.30           60.57
Zinc                                    686.46          282.66
Ammonia (as N)                            0.0             0.0

     (b)  Blast and Reverberatory Furnace Wet Air Pollution
          Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              5,037.30        2,244.60
Arsenic                               3,627.90        1,487.70
Lead                                    261.0           234.90
Zinc                                  2,662.20        1,096.20
Ammonia (as N)                            0.0             0.0
                               885

-------
     (c)  Kettle Wet Air Pollution Control PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units '- Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            0               0

     (d)  Casting Contact Cooling PSES

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 42.65           19.01
Arsenic                                  30.72           12.60
Lead                                      2.21            1.99
Zinc                                     22.54            9.28
Ammonia (as N)                            0.0             0.0

 6.  PSNS are proposed based on the performance achievable
     by the application of chemical precipitation, sedimentation
     and multimedia filtration (lime, settle, and filter)
     technology and in-process flow reduction control methods.
     The following pretreatment standards are proposed:

     (a)  Battery Cracking PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                              1,298.89          578.78
Arsenic                                 935.47          383.61
Lead                                     67.30           60.57
Zinc                                    686.46          282.66
Ammonia (as N)                            0.0             0.0
                               886

-------
     (b)  Blast and Reverberatory Furnace Wet Air Pollution
          Control PSNS'

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              5,037.3         2,244.6
Arsenic                               3,627.9         1,487.7
Lead                                    261.0           234.9
Zinc                                  2,662.2         1,096.2
Ammonia (as N)                            0               0

     (c)  Kettle Wet Air Pollution Control PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            00

     (d)  Casting Contact Cooling PSNS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 42.65           19.01
Arsenic                                  30.72           12.60
Lead                                      2.21            1.99
Zinc                                     22.54            9.28
Ammonia (as N)                            0.0             0.0
                              887

-------
 7.  BCT is proposed based on the performance achievable by the
     application of chemical precipitation and sedimentation
     (lime and settle) technology. BCT is not an additional set
     of effluent limitations, but replaces BAT in the control
     of conventional pollutants. The following BCT effluent
     limitations are proposed:

     (a)  Battery Cracking
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Total Suspended Solids               38,540.0        18,800.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (b)  Blast and Reverberatory Furnace Wet Air Pollution
          Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Total Suspended Solids              138,580.0        67,600.0
pH                                Within the range of 7.5 to 10.0
                                           at all times

     (c)  Kettle Wet Air Pollution Control
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Total Suspended Solids                    0               0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               888

-------
     (d)  Casting Contact Cooling
          BCT EFFLUENT LIMITATIONS

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Total Suspended Solids                9,069.20        4,424.0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                               839

-------
                    SECONDARY LEAD SUBCATEGORY

                           SECTION III

                         INDUSTRY PROFILE
This section of the secondary lead supplement describes  the  raw
materials and processes used in converting  lead-bearing  scrap  to
metallic lead and lead-based alloys and presents a profile of  the
secondary lead plants  identified  in this  study.  For  a discussion
of the purpose, authority, and methodology  for this study and  a
general description of the nonferrous metals manufacturing cate-
gory, refer to Section III of the General Development Document.

DESCRIPTION OF SECONDARY LEAD PRODUCTION

There are three major  phases involved in  the secondary lead  sub-
category scrap pretreatment, smelting, and  refining and  casting.
Figure III-l is a block flow diagram depicting the various pro-
cess steps involved in secondary  lead manufacture.  The  following
discussion summarizes  the raw materials used and the processes
with emphasis on the steps where water may  be used. It should  be
pointed out that not all secondary lead plants perform all of  the
process steps described.

RAW MATERIALS

The principal raw materials used  in the secondary lead subcate-
gory are battery storage plates and other scrap reclaimed from
discarded products containing lead.  Minor  amounts of solder,
babbitt, cable coverings, type metal, soft  lead, and antimonial
lead, as well as drosses and residues generated as a result  of
operations within the  secondary lead plant, are also utilized.

SCRAP PRETREATMENT

The scrap pretreatment phase may involve crushing or cutting used
batteries to allow separation of the lead from the battery case,
crushing of drosses and oversize scrap, and sweating of  lead
scrap containing other metals.  The general crushing operations
reduce the layer pieces of scrap to a suitable size using machin-
ery such as jaw crushers.  Sweating involves charging scrap  to a
furnace where the lead value is separated by selective melting.
The molten lead is collected and cast and the residue is removed
from the furnace.   Reverberatory furnaces are used for this
operation.  Particulate emissions can be controlled with a
baghouse, a scrubber,   or both.

There are a number of  different approaches used in battery break-
ing.  Each method of battery breaking is described below.
                              891

-------
Battery Breaking by Shear or Saw

Many smelters dismantle batteries in a hand operation in which
employees (1) separate plastic and rubber batteries, (2) cut the
top of the battery off, and (3) empty the contents of the battery
onto a pile.  Typically, front-end loaders then move the battery
parts to storage and disposal.

Hammer-Mill Battery-Breaking

In order to speed up the process, remove employees from exposure
and utilize plastic battery cases for fuel or resale, some plants
use hammer mills to break batteries.  Unfortunately, this
approach continues to require hand separation of plastic and
rubber cased batteries and manual handling of rubber cased
batteries.

Flotation-Type Separators

A number of flotation-type battery-breakers are currently used in
today's smelters.  The technique uses a combination of shears,
saws, and hammer mills to reduce battery scrap to small pieces.
The separator produces output streams of hard lead (grids and
posts), oxide and sulfate sludge, plastic, and rubber. The
advantages of this system are (1) positive control of furnace
feed enables use of more sophisticated furnaces, e.g., rotary,
and (2) separate recycling of plastic case material.

Low-Energy Shredders

At least five secondary smelters have (or, have had) low-energy
shredders installed for breaking batteries.  This system uses a
low-rpm, low-energy shredding device to slowly shred batteries
into chargeable or separable pieces.

Whole Battery Charging

This technique, developed by the Bergsoe smelter in Denmark,
purposely utilizes as little battery breaking as possible (only
about 20 percent of the battery mass needs to be broken).  The
acid is drained from the battery before charging.  The unbroken
batteries are mixed with other charge materials on concrete beds
using a rubber-tired front end loader.  After the charge is
prepared, it is loaded into the furnace with a front-end loader.

The battery cracking operation may be performed either on- or
off-site.  Spent electrolyte, along with saw or shredder cooling
water and wash water, constitutes a major source of wastewater at
plants where battery cracking is performed.
                              892

-------
SMELTING OPERATIONS

The smelting operation takes place  in either  a  reverberatory  or  a
blast furnace.  In the reverberatory furnace, heat  is  radiated
from the burner flame and the furnace roof  and  walls onto  the
melt.  It is usually one of the least expensive furnaces to oper-
ate because the flame and hot combustion products come in  direct
contact with the melt.

Reverberatory smelting partially purifies and compacts lead
scrap.  The charge to the furnace can be untreated  scrap (where
the sweating and smelting operations are combined), treated
scrap, or a mixture of both.  The process steps for this opera-
tion are:  (1) charging the scrap to the furnace, (2)  melting the
scrap, (3) allowing the slag to rise to the surface of the metal,
(4) tapping the slag as feed for the blast  furnace, and (5) tap-
ping the molten lead.  The product  lead can then be sent either
to the refining and casting operation, cast into semisoft  or  hard
lead ingots, or converted to various forms  of lead  oxide using
kettle (Barton pot) or reverberatory oxidation  methods.

The secondary lead blast furnace is a refractory-lined steel  cyl-
inder with air ports known as tuyeres located at the bottom,
through which air is supplied by a  blower.  Coke, used as  fuel,
is placed in the shaft in alternating layers  along  with scrap,
slag, and limestone (a flux).  One  of the most  important control
variables is the addition rate of combustion  air through the
tuyeres.  Preheating the combustion air may increase the
efficiency of the furnace.

The product of the blast furnace is semisoft  or hard (antimonial)
lead produced from pretreated scrap, reverberatory  slag, and
recycled blast furnace slag (rerun  slag).   A  typical charge for
the blast furnace is composed of 4.5 percent  rerun  slag, 4.5
percent scrap cast iron, 3.0 percent limestone,  5.5 percent coke,
which serves both as a fuel and as  a reducing agent, and 82.5
percent lead oxides, drosses, scrap, and reverberatory slags
obtained from other smelting and refining operations.

Emissions from reverberatory and blast furnaces are usually con-
trolled with baghouses, although wet scrubbers  may  be  used.   Most
secondary lead plants which practice wet scrubbing  of  furnace
emissions utilize some degree of recycle of the scrubbing  liquor.

REFINING AND CASTING

Softening, alloying, and refining processes take place in  kettle
furnaces which are larger versions  of pot furnaces.  Kettles  may
be cylindrical or rectangular in shape and  are  normally used  to
melt metals with melting points below 760°C.  They  are usually
                              893

-------
poured by tilting, dipping, or pumping.  These large pot or ket-
tle furnaces may have many small burners along all sides.  They
are usually natural gas or oil fired.

The product of the kettle softening and refining process is soft,
high purity lead.  The process steps involved are (a) charging
the preheated kettle furnace with an intermediate semisoft or
hard lead obtained from the smelting operation, (b) melting the
charge, (c) fluxing and agitating the molten charge, (d) skimming
the slag, and (e) pouring and casting the soft lead into ingots.

Fluxes which may be used include sodium hydroxide, sodium
nitrate, aluminum, aluminum chloride, sawdust, sulfur, and air.
Sodium hydroxide, sodium nitrate, or air may be used to reduce
the antimony content.  Aluminum reacts preferentially with anti-
mony, copper, and nickel to form drosses, as does sulfur with
copper.  Adding sawdust to the molten metal forms carbon which
produces elemental lead by the reduction of lead oxide.  This
process is known as dry dressing.

The operating temperatures of refining kettles range between 371°
to 482°C.  Emissions are normally collected by using a hood over
the kettle and are usually sent to a baghouse, although wet
scrubbing also may be used.  Solid wastes, consisting of drosses
and skimmings along with baghouse dust, are generally recycled to
the blast furnace.

The alloying and refining process utilizes the same types furnace
as the kettle softening and refining operation and involves
treatment and adjustment of the composition of the lead to
produce the desired alloy.  Antimony, arsenic, copper, silver,
and tin are commonly used for lead alloys.

Cooling of lead or lead alloy castings is usually done with
indirect (noncontact) cooling water in closed loop recirculating
systems.  Contact cooling may also produce a small volume dis-
charge stream.

PROCESS WASTEWATER SOURCES

In summary, the principal uses of wastewater in secondary lead
production are:

    (1).  Battery cracking,
    (2).  Wet air pollution control of blast and reverberatory
          furnaces,
    (3).  Wet air pollution control of refining (kettle)
          furnaces, and
    (4).  Casting contact cooling water.
                               894

-------
OTHER WASTEWATER SOURCES

There are other waste streams associated with the production of
secondary lead. The principal wastewater source is maintenace and
cleanup water.

This waste stream is not considered as part of this rulemaking.
EPA believes that the flows and pollutant loadings associated
with this waste stream is insignificant relative to the waste
streams selected, or is best handled by the appropriate permit
authority on a case-by-case basis under the authority of Section
403(a) of the Clean Water Act.

AGE. PRODUCTION, AND PROCESS PROFILE

Figure III-2 shows the location of the 69 secondary lead plants
operating in the United States.  These plants are predominantly
located in or near major urban centers where most of the raw
materials are readily available.  Of the 69 secondary plants
shown, 21 plants (30 percent) are located west of the Mississippi
River.  The remaining 48 plants are located in two bands east of
the Mississippi, around the Great Lakes and in the South.

As seen from Figure III-2, plants discharging indirectly to POTW
(indirect dischargers) and zero discharge plants (zero dis-
chargers) are found in all areas, while plants discharging
directly to receiving waters are found in the East and South.

Table III-l shows that the median age of secondary lead plants is
within a span of 25 to 44 years.  Table III-2 shows that, for the
58 plants providing lead production data, only nine produced over
20,000 tons in 1976.  Most secondary lead plants are relatively
small operations; roughly two-thirds produced under 15,000 tons
per year in 1976.

Table III-3 provides a summary of the number of plants in the
secondary lead industry which utilize the various process
operations discussed previously, and the number of plants which
generate wastewater associated with each process.  All plants
practicing battery cracking generate wastewater.  For the other
processes, most plants avoid producing wastewater by utilizing
dry air pollution control methods (e.g., baghouses) where con-
trols are implemented.
                               895

-------























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-------
                    Table III-2
PRODUCTION RANGES FOR THE SECONDARY LEAD SUBCATEGORY

    Production Ranges
   for 1976 (Tons/Year)          Number of Plants
        0 -  2,500                      16
    2,501 -  5,000                       4
    5,001 - 10,000                       8
   10,001 - 15,000                      11
   15,001 - 20,000                      10
   20,001 - 30,000                       5
   30,001 +                              4
   Not Reported                         1JL
   Total Number of                      69
   Plants in Survey
                        897

-------
                           Table III-3

         SUMMARY OF SECONDARY LEAD SUBCATEGORY PROCESSES
                   AND ASSOCIATED WASTE STREAMS
         Process

  Battery Cracking

  Lead Dross Preparation

  Smelting

  Lead Oxide Production

  Refining and Alloying

  Casting
Number of
 Plants
  With
 Process

   32

    5

   47

   12

   67

   66
  Number of Plants
Generating Wastewater*

         32

          0

          6

          1

          9

         11
*Through reuse or evaporation practices, a plant may "generate"
 a wastewater from a particular process but not discharge it.
                               898

-------







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                    SECONDARY LEAD SUBCATEGORY

                            SECTION IV

                        SUBCATEGORIZATION
As discussed in Section IV of the General Development Document,
the nonferrous metals manufacturing category has been subcatego-
rized to take into account pertinent industry characteristics,
manufacturing process variations, wastewater characteristics, and
a number of other factors which affect the ability of the facili-
ties to achieve effluent limitations.  This section summarizes
the factors considered during the designation of the secondary
lead subcategory and its related subdivisions.

FACTORS CONSIDERED IN SUBCATEGORIZATION

The following factors were evaluated for use in determining
appropriate subcategories for the nonferrous metals industry:

      1.  Metal products, co-products, and by-products;
      2.  Raw materials;
      3.  Manufacturing processes;
      4.  Product form;
      5.  Plant location;
      6.  Plant age;
      7.  Plant size;
      8.  Air pollution control methods;
      9.  Meteorological conditions;
     10.  Treatment costs;
     11.  Nonwater quality aspects;
     12.  Number of employees;
     13.  Total energy requirements; and
     14.  Unique plant characteristics.

Evaluation of all factors that could warrant subcategorization
resulted in the designation of the secondary lead subcategory.
Three factors were particularly important in establishing these
classifications:  the type of metal produced, the nature of raw
materials used, and the manufacturing processes involved.

In Section IV of the General Development Document, each of these
factors is described, and the rationale for selecting metal prod-
ucts, manufacturing processes, and raw materials as the principal
factors used for subcategorization is discussed.  On the basis of
these factors, the nonferrous metals manufacturing category
(phase I) was divided into 12 subcategories, one of them being
secondary lead.
                               901

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The purpose of this rulemaking is to propose the creation of the
secondary lead subcategory and the establishment of BPT and BAT
effluent limitations, and NSPS, PSES, and PSNS for this subcate-
gory.

FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY LEAD SUBCATEGORY

The factors listed previously were each evaluated when consider-
ing subdivision of the secondary lead subcategory.   In the
discussion that follows, the factors will be described as they
pertain to this particular subcategory.

The rationale for considering further subdivision of the second-
ary lead subcategory is based primarily on the production process
used.   Within this subcategory, a number of different operations
are performed, which may or may not have a water use or dis-
charge, and which may require the establishment of separate
effluent limitations and standards.  While secondary lead produc-
tion is still considered a single subcategory, a more thorough
examination of the production processes, water use and discharge
practices, and pollutant generation rates has illustrated the
need for limitations and standards based on a specific set of
waste streams, in accord with the building block approach adopted
for all nonferrous metal subcategories.  Limitations and
standards will be based on specific flow allowances for the
following subdivisions:

     1.  Battery cracking,
     2.  Blast and reverberatory furnace wet air pollution
         control,
     3.  Kettle wet air pollution control, and
     4.  Casting contact cooling.

OTHER FACTORS

The other factors considered in this evaluation either supported
the establishment of the secondary lead subcategory and its sub-
divisions or were shown to be inappropriate bases for subcatego-
rization.  Air pollution control methods, treatment costs,
nonwater quality aspects, and total energy requirements were each
shown to be functions of the selected subcategorization factors--
metal product, raw materials, and production processes.  As such,
they support the method of subcategorization which has been
applied.  As discussed in Section IV of the General Development
Document, such other factors as plant age, plant size, and the
number of employees were also evaluated and determined to be
inappropriate for use as bases for subcategorization of
nonferrous metal plants.
                               902

-------
PRODUCTION NORMALIZING PARAMETERS

The effluent limitations and standards developed in this document
establish mass limitations on the discharge of specific pollutant
parameters.  To allow these regulations to be applied to plants
with various production capacities, the mass of pollutant dis-
charged must be related to a unit of production.  This factor is
known as the production normalizing parameter (PNP).  In general,
the amount of lead produced by the respective manufacturing pro-
cess is used as the PNP.  This is based on the premise that the
amount of water generated is proportional to the amount of prod-
uct made.  Variations in the association between the amount of
water generated and the amount of product made are not felt to be
significant enough to prevent the establishment of effluent limi-
tations and standards.  The PNP's for the secondary lead subdivi-
sion are as follows:
        Subdivision

1.  Battery cracking

2.  Blast and reverberatory
     furnace wet air pollu-
     tion control

3.  Kettle wet air pollution
     control

4.  Casting contact cooling
     water
           PNP

kkg of lead scrap produced

kkg of lead produced from
 blast and reverberatory
 furnace smelting

kkg of lead produced from
 kettle furnaces

kkg of lead cast
                               903

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                    SECONDARY LEAD SUBCATEGORY

                            SECTION V

             WATER USE AND WASTEWATER CHARACTERISTICS
This section describes the characteristics of wastewater associ-
ated with the secondary lead subcategory.  Data used to quantify
wastewater flow and pollutant concentrations are presented, sum-
marized, and discussed.  The contribution of specific production
processes to the overall wastewater discharge from secondary lead
plants is identified whenever possible.

Section V of the General Development Document contains a detailed
description of the data sources and methods of analysis used to
characterize wastewater from the nonferrous metals category.  To
summarize this information briefly, two principle 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 quantify the pollutant discharge from secondary lead
plants, a field sampling program was conducted.  A complete list
of the pollutants considered and a summary of the techniques used
in sampling and laboratory analyses are included in Section V of
the General Development Document.  Wastewater samples were col-
lected in two phases: screening and verification.  The first
phase, screen sampling, was to identify which toxic pollutants
were present in the wastewaters from production of the various
metals.  Screening samples were analyzed for 128 of the 129 toxic
pollutants and other pollutants deemed appropriate.  (Because the
analytical standard for TCDD was judged to be too hazardous to be
made generally available, samples were never analyzed for this
pollutant.  There is no reason to expect that TCDD would be pre-
sent in nonferrous metals manufacturing wastewater.)  A total of
10 plants were selected for screen sampling in the nonferrous
metals manufacturing category, one of them being a secondary lead
facility.  In general, the samples were analyzed for three
classes of pollutants:  toxic organic pollutants, toxic metal
pollutants, and criteria pollutants (which includes both
conventional and nonconventional pollutants).

As described in Section IV of this supplement, the secondary lead
subcategory has been furthet categorized into four subdivisions,
so that the proposed regulation contains mass discharge limita-
tions and standards for four unit processes discharging process
wastewater.  Differences in the wastewater characteristics asso-
ciated with these subdivisions are to be expected.  For this
reason, wastewater streams corresponding to each subdivision are
addressed separately in the discussions that follow.
                              905

-------
WASTEWATER SOURCES, DISCHARGE RATES, AND CHARACTERISTICS

The wastewater data presented in this section were evaluated in
light of production process information compiled during this
analysis.  From this information it was possible to identify the
principal wastewater sources in the secondary lead subcategory.
These are:

     1.  Battery cracking,
     2.  Blast and reverberatory furnace wet air pollution
         control,
     3.  Kettle wet air pollution control, and
     4.  Casting contact cooling water.

Data supplied by dcp responses were evaluated and two flow-to-
production ratios were calculated for each stream.  These two
ratios, normalized water use and normalized wastewater discharge
flow rate, differ by the water flow rates used in their calcula-
tion.  Water use is defined as the volume of water or other fluid
(e.g., battery electrolyte) required for or generated in a given
process per mass of lead produced by the process and is therefore
based on the sum of recycle and makeup flows to a given process.
The production normalized discharge flow rate is defined as the
volume of wastewater actually discharged from a given process for
further treatment, disposal, or discharge per mass of lead pro-
duced.  Differences between the water use and discharge flows
associated with a given stream may result from combinations of
recycle, evaporation, and carryover on the product.  The pro-
duction values used in calculating these ratios correspond to the
production normalizing parameter (PNP) assigned to each stream,
as discussed in Section IV of this supplement.  The production
normalized flows were compiled by stream type.  An attempt was
made to identify factors that could account for variations in the
water use from plant to plant.  This information is summarized in
this section.  A similar analysis of factors affecting the
normalized wastewater flow rates is presented in Sections X, XI,
and XII where representative BAT, BDT, and pretreatment discharge
flows are selected for use in calculating effluent limitations.

In order to quantify the concentrations of pollutants present in
wastewaters from secondary lead plants, wastewater samples were
collected at six plants, representing 26 percent of the dis-
charging secondary lead plants.  Block diagrams indicating the
locations of sampling points and the production processes
involved for each of these six plants are given in Figures V-l
through V-6 (at the end of this section).

Raw wastewater sampling data for the secondary lead industry are
presented in Tables V-2, V-4, V-6, and V-8 (at the end of this
section).  Treated wastewater sampling data are shown in Tables
V-9 through V-13 (at the end of this section).  The stream codes
                              906

-------
displayed in the tables may be used to identify the  location  of
each of the samples on the process flow diagrams  in  Figures V-l
through V-6.  Where no data are listed for a specific day of  sam-
pling, the wastewater samples for the stream were not collected.
If the analysis did not detect a pollutant in a waste stream, the
pollutant was omitted from the table.

The data tables include some samples measured at  concentrations
considered not quantifiable.  The base neutral extractables,  acid
extractables, and volatile organics are considered not
quantifiable at concentrations equal to or less than 0.010 mg/1.
Below this concentration, organic analytical results are not
quantitatively accurate; however, the analyses are useful to
indicate the presence of a particular pollutant.  The pesticide
fraction is not considered quantifiable below concentrations  of
0.005 mg/1. Nonquantifiable results are designated in the tables
with an asterisk (double asterisk for pesticides).

These detection limits shown on the data tables are  not the same
in all cases as the published detection limits for these pollu-
tants by the same analytical methods.  The detection limits used
were reported with the analytical data and hence  are the appro-
priate 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 calibra-
tion, variation in stock solutions, and variation in operators.

The statistical analysis of data includes some samples measured
at concentrations considered not quantifiable.  Data reported as
an asterisk are considered as detected but below  quantifiable
concentrations, and a value of zero is used for averaging.  Toxic
organic, nonconventional, and conventional data reported with a
"less than" sign are considered as detected, but not further
quantifiable.  A value of zero is also used for averaging.  If a
pollutant is reported as not detected, it is excluded in calcu-
lating the average.  Finally, toxic metal values reported as  less
than a certain value were considered as not detected, and a value
of zero was used in the calculation of the average.  For example,
three samples reported as ND, *, and 0.021 mg/1 have an average
value of 0.010 mg/1.  In selecting pollutants and pollutant
parameters for specific regulation, individual samples were used
rather than average values.

The method by which each sample was collected and composited  is
indicated on the data tables by a code number, as follows:
                               907

-------
     1     one-time grab
     2     24-hour manual composite
     3     24-hour automatic composite
     4     48-hour manual composite
     5     48-hour automatic composite
     6     72-hour manual composite
     7     72-hour automatic composite

In the data collection portfolios, the secondary lead plants
which discharge were asked to specify the presence or absence of
the toxic pollutants in their effluent.  Of the 69 secondary lead
plants, 22 responded to this portion of the questionnaire.  All
plants responding to the organic compounds portion reported that
all toxic organic pollutants were known to be absent or believed
to be absent from their wastewater.

The responses for the toxic metals are summarized below.

                   Known      Believed     Believed     Known
    Pollutant     Present     Present       Absent      Absent

    Antimony        13           5             4
    Arsenic          97             6          -
    Cadmium          76             63
    Chromium         3           5            10          4
    Copper          12           2             71
    Lead            17           4             -          -
    Mercury          2           4            13          3
    Nickel           64            11          1
    Silver           23            17          -
    Thallium         1           6            18          3
    Zinc            10           6             6          -

BATTERY CRACKING

Plants utilizing lead-acid batteries as a source of process raw
materials produce a wastewater stream associated with the battery
cracking operation.  Battery cracking involves the breaking of
battery cases by any of a number of methods described in Section
III.  Wastewater may be generated in the form of electrolyte
drained from the battery cases, by the use of saw or breaker
cooling water, and by area wash water.  All 32 plants having
battery cracking operations generate wastewater.  Table V-l
summarizes the normalized electrolyte, blowdown, and ultimate
discharge flows for these plants in terms of liters per metric
ton of lead scrap produced (recovered) from battery cracking
operations.  Differences from plant to plant in the specific
method and equipment used for battery cracking may be responsible
for variations in these flow rates.
                              903

-------
Table V-2 summarizes the field sampling data  for  the  toxic,  con-
ventional, and nonconventional pollutants detected.   This waste
stream contains quantifiable concentrations of  toxic  organics.
The metals antimony, arsenic, cadmium, copper,  lead,  and zinc  are
generally present in concentrations  from 1 to 100 mg/1.  Treat-
able concentrations of total suspended solids,  and oil and
grease, and low pH  (less than 2) also characterize this stream.

BLAST AND REVERBERATOR/ FURNACE WET  AIR POLLUTION CONTROL

Blast and reverberatory furnaces used in the  smelting operation
in secondary lead plants generally require some type  of air
pollution control to limit emissions, especially  of particulates
and sulfur oxide compounds.  Out of  47'plants having  smelting
operations, six use wet air pollution control;  41 use dry air
pollution control.  Table V-3 summarizes the  water use and
discharge rates for these plants.  Limited sampling and analy-
tical data were obtained on furnace  scrubbing liquor.  As shown
in Table V-4, treatable concentrations of lead  and total
suspended solids were found for the  single sample analyzed.

KETTLE WET AIR POLLUTION CONTROL

Kettles used in the refining and alloying operations  in secondary
lead plants may also produce air pollutants,  especially particu-
late matter, which may require control.  Nine of  the  67 plants
reporting the use of refining and alloying kettles use wet air
pollution control.  Table V-5 shows  the production normalized
water use and discharge rates for these plants.   Data obtained on
the kettle scrubber liquor at one of these plants (presented in
Table V-6) contained measurable concentrations  of ammonia and
treatable concentrations of total suspended solids, arsenic, and
lead (50 to 380 mg/1) with measurable concentrations  of other
metals.

CASTING CONTACT COOLING WATER

Contact cooling water may be used in the casting  operation.  The
cooling water is frequently recycled and may  be totally evapo-
rated,  but a small stream may be blown down to  limit  the buildup
of dissolved solids, which may cause surface  imperfections on the
cast metal.   Eleven plants, of the 66 reporting the use of a
casting operation, use direct contact cooling.  The normalized
water use and discharge data for these plants are summarized in
Table V-7.  No sampling data are available for  secondary lead
plant casting cooling water.  It is  expected  that this operation
may be similar to analogous operations in other nonferrous metals
manufacturing subcategories.  Organics, in the  form of oil and
grease, may be found when lubricants are used.  Total suspended
solids  may also be present in treatable concentrations.
                              909

-------
                          Table V-l

WATER USE AND DISCHARGE RATES FOR BATTERY CRACKING OPERATIONS
                (1/kkg of lead scrap produced)
 Plant Code

   222
   224
   223
   225
   227
   234
   236
   239
   244
   246
   248
   249
   250
   254
   263
   264
   265
   266
   271
   272
   273
   392
   391
   428
   652
   655
  4210
  4211
  9001
  9002
 26001
 26003
Percent
Recycle

   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
   0
Production
Normalized
Water Use

    139
    834
    775
    763
    384
    437
    142
    154
    306
    315
  1,618
    442
  1,984
    796
  1,046
  1,647
  1,084
  4,669
     81
  5,086
    286
    369
    922
    244
    429
    905
    671
    377
  1,063
    638
    705
    600
  Production
  Normalized
Discharge Rate

     139
     834
     775
     763
     384
     437
     142
     154
     306
     315
   1,618
     442
   1,984
     796
   1,046
   1,647
   1,084
   4,669
      81
   5,086
     286
     369
     922
     244
     429
     905
     671
     377
   1,063
     638
     705
     600
                             910

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                            Table V-3

            WATER USE AND DISCHARGE RATES FOR BLAST AND
         REVERBERATORY FURNACE WET AIR POLLUTION CONTROL
               (1/kkg of  lead produced from smelting)
  Plant Code

     266
   26001
     272
     265  (a)
     265
     234
     222
 Percent
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    0
  100
   83.7
   83.3
   93.3
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   97.8
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 40,411
 11,433
 25,507
    942
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   3,252
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   1,909
   1,776
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(a) Plant 265 controls air emissions on two furnaces with two
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NR = Present but data not reported in dcp.
                               915

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                            Table V-5

         WATER USE AND DISCHARGE RATES FOR KETTLE WET AIR
                        POLLUTION CONTROL
          (1/kkg of lead produced from kettle furnaces)


                                Production          Production
                 Percent        Normalized          Normalized
  Plant Code     Recycle        Water Use         Discharge Rate

  26001            100         151,050                   0
    655            100           3,071                   0
    391            100             361                   0
    273             91.7        21,900               1,818
    264             96           1,845                  74
    250              -           1,718                   0*
    225            100          11,373                   0
    224            100           5,724                   0
    223            100           7,089                   0
*100 percent of the wastewater is recycled to decasing washing.
                               917

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-------
                            Table V-7

    WATER USE AND DISCHARGE RATES FOR CASTING CONTACT  COOLING
                        (1/kkg of lead cast)
     Plant Code

      4211
      26001
       427
       422
       248
       244
       234
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  504
  120
  963
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NR  - Not reported in dcp.
                               919

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                          932

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-------
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-------
                    SECONDARY LEAD SUBCATEGORY

                            SECTION VI

                     SELECTION OF POLLUTANTS  .
Section V of this supplement presented data from secondary lead
plant sampling visits and subsequent chemical analyses.  This
section examines that data and discusses the selection or exclu-
sion of pollutants for potential limitation.  The legal basis for
the exclusion of toxic pollutants under Paragraph 8(a) of the
Settlement Agreement is presented in Section VI of the General
Development Document.

Each pollutant selected for potential limitation is discussed in
Section VI of the General Development Document.  That discussion
provides information about where the pollutant originates (i.e.,
whether it is a naturally occurring substance, process 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 describes the analysis that was per-
formed to select or exclude pollutants for further consideration
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 concentrations
used for the toxic metals were the long-term performance values
achievable by lime precipitation, sedimentation, and filtration.
The concentrations used for the toxic organics were the long-term
performance values achievable by carbon adsorption (see Section
VII of the General Development Document - Combined Metals Data
Base).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANTS

This study examined samples from the secondary lead subcategory
for three conventional pollutant parameters (oil and grease,
total suspended solids, and pH) and four nonconventional
pollutant parameters (ammonia, chemical oxygen demand, total
organic carbon, and total phenols).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS SELECTED

The following conventional pollutant parameters were selected for
limitation in this subcategory:

     ammonia
     total suspended solids (TSS)
     pH


                               939

-------
Ammonia was found in all six samples analyzed in concentrations
ranging from 0.2 to 29 mg/1.  The values recorded are not above
the treatable concentration of 32 mg/1. Although none of the
concentrations are above the 32 mg/1 considered achievable with
ammonia steam stripping, ammonia is selected for limitation.
Only one kettle scrubber wastestream was sampled, and ammonia is
known to be present in this stream with concentrations of 22, 25,
and 29 mg/1.  Ammonia is selected for limitation because it is
known to be present in this wastestream and it may occur at
treatable concentrations in this wastestream at other facilities.

Total suspended solids ranged from 240 to 28,000 mg/1 in 14
samples.  All but two of the observed.concentrations are above
that considered achievable by treatment.  Further, most of the
methods used to remove toxic metals do so by converting these
metals to precipitates.  Meeting a limitation on total suspended
solids also helps ensure that removal of these precipitated toxic
metals has been effective.  For these reasons, total suspended
solids is considered for limitation in this subcategory.

The pH of a wastewater measures its relative acidity or alkalin-
ity.  In this study, the pH values observed ranged from 0.6 to
8.1.  Many harmful effects may be caused by extreme pH values or
by rapid changes in pH.  Therefore, pH is considered for limita-
tion in this subcategory.

TOXIC POLLUTANTS

The frequency of occurrence of the toxic pollutants in the waste-
water samples taken is presented in Table VI-1.  These data
provide the basis for the selection or exclusion of specific
pollutants, as discussed below.  Table VI-1 is based on the raw
wastewater data from streams 73, 75, 208, 106, 108, 151, 152, and
176 (see Section V).  Treatment plant sampling data were not used
in the frequency count.

TOXIC POLLUTANTS NEVER DETECTED

Paragraph 8(a)(iii) of the Revised Settlement Agreement allows
the Administrator to exclude from regulation those toxic pollu-
tants not detectable by Section 304(h) analytical methods or
other state-of-the-art methods.  The toxic pollutants listed
below were not detected in any wastewater samples from this sub-
category; therefore, they are not selected for consideration in
establishing limitations:

       1.  acenaphthene
       2.  acrolein
       3.  acrylonitrile
       4.  benzene
                               940

-------
 5.  benzidine
 6.  carbon tetrachloride
 8.  1,2,4-trichlorobenzene
 9.  hexachlorobenzene
10.  1,2-dtchloroethane
11.  1,1,1-trichloroethane
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
20.  2-chloronaphthalene
21.  2,4,6-trichlorophenol
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
31.  2,4-dichlorophenol
32.  1,2-dichloropropane
33.  1,3-dichloropropylene
34.  2,4-dimethylphenol
35.  2,4-dinitrotoluene
36.  2,6-dinitrotoluene
37.  1,2-diphenylhydrazine
38.  ethylbenzene
41.  4-bromophenyl phenyl ether
42.  bts(2-chloroisopropyl) ether
43.  bis(2-chloroethoxy) methane
44.  methylene chloride
45.  methyl chloride
46.  methyl bromide
48.  dichlorobromomethane
49.  DELETED
50.  DELETED
51.  chlorodibromomethane
52.  hexachlorobutadiene
53.  hexachlorocyclopentadiene
54.  isophorone
55.  naphthalene
57.  2-nitrophenol
58.  4-nitrophenol
59.  2,4-dinitrophenol
60.  4,6-dinitro-o-cresol
61.  N-nitrosodimethylamine
                        941

-------
      62.  N-nitrosodiphenylamine
      63.  N-nitrosodi-n-propylamine
      64.  pentachlorophenol
      65.  phenol
      67.  butyl benzyl phthalate
      72.  benzo(a)anthracene
      73.  benzo(a)pyrene
      74.  3,4-benzofluoranthene
      7 5.  benzo(k)fluoranthene
      79.  benzo(ghi)perylene
      80.  fluorene
      82.  dibenzo(a,h)anthracene
      83.  indeno(l,2,3-cd)pyrene
      85.  tetrachloroethylene
      86.  toluene
      87.  trichloroethylene
      88.  vinyl chloride
      89.  aldrin
      95.  alpha-endosulfan
      97.  endosulfan sulfate
     105.  delta-BHC
     113.  toxaphene
     116.  asbestos
     125.  selenium
     129.  2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)

TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION LIMIT

The provision of Paragraph 8(a)(iii) of the Revised Settlement
Agreement excluding from regulation those toxic pollutants which
are not detectable includes those pollutants whose concentrations
fall below EPA's nominal detection limit.  The toxic pollutants
listed below were never found above their analytical quantifica-
tion concentration in any wastewater samples from this subcate-
gory; therefore, they are not selected for consideration in
establishing limitations.

       7.  chlorobenzene
      40.  4-chlorophenyl phenyl ether
      70.  diethyl phthalate
      78.  anthracene     (a)
      81.  phenanthrene   (a)
      90.  dieldrin
      91.  chlordane
      92.  4,4'-DDT
      93.  4,4'-DDE
      94.  4,4'-DDD
      96.  beta-endosulfan
      98.  endrin
      99.  endrin aldehyde
     100.  heptachlor


                               942

-------
     101.  heptachlor epoxide
     102.  alpha-BHC
     103.  beta-BHC
     104.  gamma-BHC
     106.  PCB-1242       (b)
     107.  PCB-1254       (b)
     108.  PCB 1221       (b)
     109.  PCB-1232       (c)
     110.  PCB-1248       (c)
     111.  PCB-1260       (c)
     112.  PCB-1016       (c)

     (a),  (b), (c)  Reported together

TOXIC POLLUTANTS PRESENT  BELOW CONCENTRATIONS ACHIEVABLE  BY
TREATMENT

Paragraph  8(a)(ill) of the Revised Settlement Agreement also
allows the exclusion of toxic pollutants which were detected  in
quantities too small to be effectively reduced by  technologies
known to the Administrator.  The pollutants  listed below  are  not
selected for consideration in establishing limitations because
they were  not found in any wastewater samples from this subcate-
gory above concentrations considered achievable by existing or
identified treatment technologies.  These pollutants are
discussed  individually following the list.

      23.  chloroform
      47.  bromoform
      56.  nitrobenzene
      71.  dimethyl phthalate
     117.  beryllium
     123.  mercury

Chloroform was found above its analytical quantification  limit in
five of 10 samples analyzed, but the highest concentration
reported was 0.026 mg/1,  and identified treatment  can reduce  its
concentration only to 0.1 mg/1.  Chloroform  is thus not selected
for further consideration in establishing limitations.

Bromoform  was detected in only one of 10 samples,  and that one
was below  the concentration to which identified treatment can
reduce its concentration  (0.05 mg/1).  Bromoform is thus  not
selected for consideration for limitation.

Nitrobenzene concentrations exceeded the analytical quantifica-
tion limit in only one of eight samples, and that  one was 0.016
mg/1.  This value is below the 0.05 mg/1 concentration acheivable
by treatment. Therefore, nitrobenzene is not selected for
consideration for limitation.
                              943

-------
Dimethyl phthalate was not detected in seven of eight samples.
The one exception showed a concentration of 0.013 mg/1. This
value is below the 0.05 mg/1 concentration achievable by treat-
ment. Dimethyl phenol is thus not selected for consideration for
limitation.

Beryllium exceeded its analytical quantification limit in only
one of 11 samples, with a concentration of 0.03 mg/1.  This is
below the concentration to which available treatment can reduce
beryllium concentrations (0.20 mg/1), so beryllium is not
selected for consideration for limitation.

Mercury was detected in 11 of 13 samples; with all of these
values below the 0.036 mg/1 concentration achievable by treat-
ment.  Therefore, mercury is not selected for consideration for
limitation.

TOXIC POLLUTANTS DETECTED IN A SMALL NUMBER OF SOURCES

Paragraph 8(a)(iii) allows for the exclusion of a toxic pollutant
if it is detectable in the effluent from only a small number of
sources within the subcategory and it is uniquely related to only
those sources.  The following pollutants were not selected for
limitation on this basis.

      39.  fluoranthene
      66.  bis(2-ethylhexyl) phthalate
      68.  di-n-butyl phthalate
      69.  di-n-octyl phthalate
      76.  chrysene
      77.  ac enaphthy1ene
      84.  pyrene
     121.  cyanide

Although these pollutants were not selected for consideration in
establishing nationwide limitations, it may be appropriate, on a
case-by-case basis, for the local permitter to specify effluent
limitations.

Fluoranthene was detected in one of five samples analyzed, with a
concentration of 0.027 mg/1.  The concentration to which treat-
ment is effective is 0.01 mg/1.  Since fluoranthene was found in
only one waste stream, and since in the dcp all responding plants
indicated that this pollutant was known to be absent or believed
to be absent, it is not selected for consideration for
limitation.

Bis(2-ethylhexyl) phthalate was found above both its analytical
quantification limit and its treatable concentration (0.01 mg/1)
in five of eight samples, with a maximum concentration of 0.585
mg/1.  The presence of this pollutant is not attributable to
                                944

-------
materials or processes associated with the  secondary  lead
subcategory.  It is commonly used as a plasticizer  in laboratory
and field sampling equipment.  EPA suspects  sample  contamination
as the source of this pollutant.  Also, in  the dcp  all responding
plants indicated that this pollutant was known to be  absent  or
believed to be absent.  Therefore, bis(2-ethylhexyl)  phthalate  is
not selected for consideration for limitation.

Two of eight samples analyzed for di-n-butyl phthalate were  found
to contain concentrations above  its analytical quantification
limit, one of these above the 0.025 mg/1 concentration considered
achievable with treatment. The presence of  this pollutant  is not
attributable to materials or processes associated with the
secondary lead  subcategory.  It is commonly used as  a
plasticizer in laboratory and field sampling equipment. EPA
suspects sample contamination as the source of this pollutant.
Also, in the dcp all responding  plants indicated that this
pollutant was known to be absent or believed to be  absent.   It  is
thus not selected for consideration for limitation.

Di-n-octyl phthalate was found above its analytical quantifica-
tion limit (0.01 mg/1) in two of eight samples.  The  presence of
this pollutant is not attributable to materials or  processes
associated with the secondary lead subcategory.  It is commonly
used as a plasticizer in laboratory and field sampling equipment.
EPA suspects sample contamination as the source of  this pollu-
tant.  Also, in the dcp all responding plants indicated that this
pollutant was known to be absent or believed to be  absent.
Therefore, di-n-octyl phthalate  is not selected for consideration
for limitation.

Chrysene was reported present above its analytical  quantification
limit in two of eight samples.   The two reported concentrations
of chrysene were 0.139 and 0.545 mg/1, which are above the 0.001
mg/1 concentration considered attainable with treatment.   The
process waste stream that produced the 0.545 mg/1 value, also
produced five not detected values at two other facilities.
Chrysene is not considered characteristic of the subcategory
because it was found in only two samples from two different
process wastestreams, Therefore, chrysene is not selected  for
consideration for limitation.

Acenaphthylene occurred above its treatable concentration  (0.01
mg/1) in only one of eight samples, where it measured 0.035 mg/1.
Two other samples of this waste  stream at two different plants
were reported as not detected.  This site-specific  result  is not
sufficient to characterize the whole subcategory, so
acenaphthylene is not selected for consideration for  limitations.
                               945

-------
Pyrene exceeded its analytical quantification limit  (0.01 mg/1)
in only two of eight samples.  The two reported concentrations of
pyrene were 0.013 mg/1 and 0.038 mg/1.  These two values are  from
two different process wastestreams.  This site-specific result is
not sufficient to characterize the whole subcategory.  Also,  in
the dcp all responding plants indicated that this pollutant was
known to be absent or believed to be absent.  Therefore, pyrene
is not selected for consideration for limitation.

Cyanide was found at a treatable concentration in three of 11
samples, all at the same plant.  All three concentrations (3.0,
4.0, and 6.0 mg/1) that were reported above the 0.047 mg/1
concentration considered attainable are from the same plant.
Because of the site-specificity of this result, cyanide not
selected for consideration for limitation.

TOXIC POLLUTANTS SELECTED FOR FURTHER CONSIDERATION  FOR
LIMITATIONS

The toxic pollutants listed below were selected for  establishing
limitations and standards for this subcategory.  The toxic
pollutants selected are each discussed following the list.

     114.  antimony
     115.  arsenic
     118.  cadmium
     119.  chromium
     120.  copper
     122.  lead
     124.  nickel
     126.  silver
     127.  thallium
     128.  zinc

Eight of 11 samples analyzed for antimony exhibited  concentra-
tions over the treatable concentration (0.47 mg/1).  Most of
these were above 10 mg/1, with a maximum of 95 mg/1.  Antimony is
thus selected for further consideration for limitation.

Arsenic was found above its treatable concentration  (0.34 mg/1)
in all 10 samples analyzed.  Treatable concentrations ranged  from
0.6 to 16.0 mg/1.  Arsenic is thus selected for further consi-
deration for limitation.

Twelve of 13 samples analyzed for cadmium were found to have
concentrations in excess of the treatable concentration (0.049
mg/1).  Treatable concentrations ranged from 0.41 to 4.8 mg/1.
Therefore, cadmium is selected for further consideration for
limitation.
                               946

-------
Chromium was found to exceed its treatable concentration  (0.07
mg/1) in eight of 13 samples, with a maximum of 1 mg/1. There-
fore, chromium is selected for further consideration  for  limita-
tion.

Copper was found above its treatable concentration  (0.39  mg/1)  in
12 of 13 samples analyzed, with a maximum of 10 mg/1.  Therefore,
copper is selected for further consideration for limitation.

Lead was detected above its treatable concentration  (0.08 mg/1)
in 13 of 14 samples analyzed.  Treatable concentrations ranged
from 4.6 to 95.0 mg/1, with the majority above 10 mg/1.   Lead is
thus selected for further consideration for limitation.

Nine of 13 samples analyzed for nickel exhibited concentrations
exceeding its treatable concentration (0.22 mg/1).  Two sam-
ples had concentrations of 2 mg/1. Therefore, nickel  is selected
for further consideration for limitation.

Eleven samples were analyzed for silver.  Reported results
included concentrations of 0.16, 0.32, and 0.34 mg/1, all three
above the 0.07 mg/1 treatable concentration.  Therefore,  silver
is selected for further consideration for limitation.

Thallium, for which treatment is effective above 0.34 mg/1, was
found in three of 11 samples at 0.5, 0.8, and 1.0 mg/1.   There-
fore, thallium is selected for further consideration  for  limita-
tion.

Zinc was found above its treatable concentration (0.23 mg/1) in
10 of 13 samples analyzed.  Six of these were above 5 mg/1, with
a high of 20 mg/1.  Zinc is thus selected for further
consideration for limitation.
                               947

-------
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                                                          952

-------
                    SECONDARY LEAD SUBCATEGORY

                           SECTION VII

                CONTROL AND TREATMENT TECHNOLOGIES


The preceding sections of this supplement discussed the waste-
water 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

Control and treatment technologies are discussed in general in
Section VII of the General Development Document.  The basic
principles of these technologies and the applicability to waste-
water similar to that found in this subcategory are presented
there.  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.  Fourteen plants in this subcategory
currently have combined wastewater treatment systems, 10 have
lime precipitation and sedimentation, and seven have lime
precipitation, sedimentation and filtration.  As such, five
options have been selected for consideration for BPT, BAT, BDT,
BCT, and pretreatment in this subcategory, based on combined
treatment o£ 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 cooiing water, and
     3.  Area washdown.

The combined wastewater from these sources has the characteris-
tics of the battery electrolyte; pollutant concentrations are


                               953

-------
dependent on the amount of dilution from the other water sources.
In general, this wastewater is characterized by treatable concen-
trations of suspended and dissolved solids, heavy metals, and
arsenic.  Of the 32 plants with battery cracking surveyed, four
do not currently have any control on this stream; they either
discharge it or use contract disposal.  The majority neutralize
the spent acid; 14 use ammonia, nine use lime, and two use
caustic to raise the wastewater pH.  Alkaline pH also favors the
precipitation of heavy metal salts.  Twenty plants provide for
settling of these solids and other suspended solids in sedi-
mentation equipment (e.g., clarifiers).  Six plants filter the
treated wastewater; in five of these plants the filtration step
occurs after sedimentation and in the other filtration is used
alone to remove suspended solids.  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 AND REVERBERATORY FURNACE WET AIR POLLUTION CONTROL

Air emissions from the blast and reverberatory furnaces may
contain particulate matter which must be removed to meet air
emissions standards.  Either dry or wet methods may be used for
particulate control; of the 47 plants surveyed which have blast
reverberatory furnaces, 41 utilize baghouses or dry scrubbers,
while six plants have wet scrubbers to control furnace emissions.
The scrubbing solution contains treatable concentrations of
suspended solids and lead.  Five of the six plants with wet
scrubbers recycle a portion of the scrubber water; the average
recycle ratio is 93 percent.  Two plants indicate they recycle
100 percent of the scrubber water.  The four plants not using 100
percent recycle neutralize this wastewater using either ammonia
(three plants) or caustic (one plant).  Two follow this with
sedimentation or filtration.  The plant that does not recycle any
of this stream combines it with wastewater from other streams and
sends it to a pond.  Treated wastewater is discharged to a POTW
in the other 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, 39 do not control
                               954

-------
kettle emissions, 19 use dry  controls  (baghouses),  and  the
remaining nine use wet  scrubbers.  Kettle  scrubber  effluent
contains lead, arsenic, other alloying metals,  and  suspended
solids at treatable concentrations.  Eight of the nine  plants
with wet scrubbers recycle  the scrubber water;  the  average
recycle ratio is over 98 percent, with six plants reporting 100
percent recycle.  The remaining plant  utilizes  the  scrubber
wastewater in the battery cracking operation.   Of the two plants
not using total 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.

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 11 use
direct contact cooling.  Three plants  use  total recycle of the
cooling water, four rely on evaporation to eliminate the waste-
water, and the remainder discharge wastewater with  no treatment.

CONTROL AND TREATMENT OPTIONS  CONSIDERED

As the sampling and analytical data  in Section  V indicate, the
wastewaters from the secondary lead  subcategory 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  five control and
treatment technology options  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  precipita-
tion and sedimentation) applied to the combined streams of
battery cracking wastewater,  furnace smelting air pollution
scrubbing wastewater, and casting contact cooling water.  Chemi-
cal precipitation is used to remove metals by the addition of
lime, followed by gravity sedimentation.  Suspended solids are
also removed in the process.   This option also requires dry
control methods to control  air emissions from kettle refining  or
alternately,  100 percent recycle of kettle scrubber liquor.

OPTION B

Option B for the secondary  lead subcategory requires control and
treatment to reduce the discharge of wastewater volume  and pollu-
tant mass.   Option B includes  chemical precipitation and sedimen-
                               955

-------
tation requirements, 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, lime precipitation, and sedimenta-
tion) 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.

OPTION D

Option D for the secondary lead subcategory consists 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.

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.

In Section VI of this supplement, none of the toxic organic
pollutants were selected for further consideration in establish-
ing limitations for the secondary lead subcategory.  Therefore,
Option E, which includes activated carbon adsorption for organic
removal, is not applicable to this subcategory.
                               956

-------
                    SECONDARY LEAD SUBCATEGORY

                           SECTION VIII

           COSTS, ENERGY, AND NONWATER QUALITY ASPECTS
This section describes the method used to develop the  costs  asso-
ciated 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.  Section VIII of the General Development Document pro-
vides background on the capital and annual  costs for each of the
technologies discussed herein.

The wastewater streams associated with the  secondary lead sub-
category are combined into three groups for the purposes  of  this
section.  These three groups are as follows:

     1.  Battery cracking wastewater  (electrolyte and  saw water),
     2.  Smelting furnace and kettle wet air pollution control
         wastewaters, and
     3.  Casting contact cooling water.

These three groups are found in existing plants in  the three com-
binations shown below.  These three combinations are selected for
the purpose of cost estimation because they represent  the waste-
water combinations that occur most frequently in plants in the
secondary lead subcategory.
     Combination

          1
          2
          3
Battery
Cracking

     X
     X
     X
Casting
Contact
Cooling
     X
    Casting
Contact Cooling
or Wet Air Pol-
lution Control
Since the wastewater characteristics of combinations  2 and  3 are
similar, these two combinations are considered together  in  the
cost estimates.

TREATMENT OPTIONS COSTED FOR EXISTING SOURCES

As discussed in Section VII, five control and treatment  options
are considered for treating wastewater from the secondary lead
subcategory.  Cost estimates, in the form of annual cost curves,
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-5, and summarized below.
                               957

-------
OPTION A

Option A for the secondary lead subcategory consists of  lime
preciptiation and sedimentation end-of-pipe technology.  Total
recycle of kettle wet air pollution control water is also
required for Option A.  The cost curves developed for Option A  do
not consider the cost for recycling kettle wet air pollution
control water.  Therefore, holding tank costs must be added to
the cost obtained from the Option A cost curves to determine the
total cost of 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 cool-
ing water through cooling towers and the recycle of wet  air pol-
lution control water through holding tanks are the control
mechanisms for flow reduction.  The Option B end-of-pipe treat-
ment technology consists of lime precipitation and sedimentation.
The cost of Option B is determined by adding cooling tower and
holding tank costs (the holding tanks costs for Option B are only
for blast and reverberatory furnace scrubber water) to the cost
of Option A.

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; and  lime pre-
cipitation and sedimentation end-of-pipe treatment) with, the
addition of multimedia filtration to the end-of-pipe treatment
scheme.  The cost curves developed for Option C do not include
the cost of flow reduction.  Therefore, the total cost of Option
C is determined by adding cooling tower and holding tank costs  to
the costs obtained from the Option C cost curves.

OPTION D

Option D for the secondary lead subcategory consists of  all the
control and treatment technologies of Option C (in-process flow
reduction through cooling towers and holding tanks; and  lime pre-
cipitation, sedimentation, and multimedia filtration end-of-pipe
treatment) with the addition of activated alumina adsorption to
the end-of-pipe treatment scheme.  Flow reduction is not included
in the cost curves developed for Option D.  Therefore, holding
tank and cooling tower costs must be added to the costs  obtained
from the Option D cost curves to determine the total cost of
Option D.
                                958

-------
OPTION F

Option F for the secondary lead  subcategory  consists  of  all  the
control and treatment technologies of Option C  (in-process  flow
reduction through holding tanks  and  cooling  towers; and  lime pre-
cipitation, sedimentation, and multimedia  filtration  end-of-pipe
treatment) with the addition of  reverse  osmosis  and multiple-
effect evaporation followed by complete  recycle  to the end-of-
pipe treatment scheme.  Flow reduction is  not included in the
cost curves developed for Option F.  Therefore,  holding  tank and
cooling tower costs must be added to the costs  obtained  from the
Option F cost curves to determine the total  cost of Option  F.

The cost curves for the five options summarized  above are pre-
sented in the figures listed below.  The respective options  which
the curves are based on are also shown.

     Combination         Figure  VIII-         Options  Costed

          1                 1-4             A,  C, D, F

       2 and 3              5-8             A,  C, D, F

The holding tank and cooling tower cost  curves used to determine
flow reduction costs are presented in Figures VIII-9  and VIII-10,
respectively.

NONWATER QUALITY ASPECTS

A general discussion of nonwater quality aspects of the  control
and treatment alternatives considered for  the nonferrous metals
manufacturing category is contained  in Section VIII of the
General Development Document.  Nonwater  quality  impacts  specific
to the secondary lead subcategory including  energy requirements,
solid waste and air pollution are discussed  below.

ENERGY REQUIREMENTS

The methodology used for determining the energy  requirements  for
the various options is discussed in  Section  VIII of the  General
Development Document.  Briefly,  the  energy usage of the  options
is determined using the median wastewater  flow in the subcate-
gory.  The energy usage of the options is  then compared  to the
energy usage of the median secondary lead energy consumption
plant.  As shown in Table VIII-1, the most energy intensive
option is Option F with reverse  osmosis  and  multiple-effect
evaporation, which increases the median  energy consumption by
0.27 percent.
                               959

-------
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
Resource 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, sedimenta-
tion and filtration.  By the addition of excess lime during
treatment, similar sludges, specifically toxic metal bearing
sludges, generated by other industries such as the iron and steel
industry passed the Extraction Procedure (EP) toxicity test.  See
40 CFR 261.24.  Thus, the Agency believes that the wastewater
sludges will similarly not be EP toxic if the recommended tech-
nology is applied.

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 genera-
tor 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 treat-
ment, 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).
                                960

-------
Even if these wastes are not identified as hazardous, they  still
must be disposed of in compliance with the Subtitle  D open  dump-
ing 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.  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 chemical precipita-
tion, sedimentation, multimedia filtration, activated alumina
adsorption, and reverse osmosis.  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.
                               961

-------
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                   SECONDARY LEAD  COMBINATION  1,  OPTION A
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                                                        LABOR
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                    SECONDARY LEAD COMBINATION 1,  OPTION  C
                                       963

-------
                   SLUDGE  REMOVAL
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        SECONDARY LEAD COMBINATION 1,  OPTION D
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         11 111	i  i i  i i i 111	i   i i  i i i 111	i   i  i i i i
                                                   10.0
           10
               100            1,000
                        FLOW, cu m/doy
                      Figure VIII-4
IO.CJO
.00,000
                  SECONDARY  LEAD  COMBINATION  1, OPTION F
                                     964

-------
 10
 10  -
                                   SLUDGE' REMOVAL
                                   CHEMICALS
                                   ENERGY
                                                          LASCrt
                                                          DEPRECIATION
                                                          CAPITOL
                                   FLOW, mgd
                 i i  i t i ill	1—i  i j . i .. i    i  i  i .• i. 11
  10
                                      1,000
                                 FLOW, cu m/day
                                Figure VIII-5
                 SECONDARY  LEAD COMBINATION 2&3, OPTION A
  io6 t,
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  10
                                SLUDGE REMOVAL
                                CHEMICALS
                                ENERGY
                                MATERIALS
                                                          LABOR
                                                          DEPRECIATION
                                                          CAPITAL
                  0.01
         •'  FLOW, mgd  ''
           10
100            1,000
         FLOW, cum/day
        Figure  VIII-6
10,000
,00,000
                 SECONDARY LEAD  COMBINATION  2&3, OPTION C
                                     965

-------
  10
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                              I I I llf'    I  I   I I I I IIJ
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                                CHEMICALS
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                                                     i  i  i i i  i i
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                                                          DEPRECIATION
                                                          CAPITAL
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                                Figure VIII-7
                           10,000
100,000
                SECONDARY LEAD COMBINATIONS  2&3,  OPTION  D
  10   r
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                                SLUDGE REMOVAL
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                                ENERGY
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                                 Figure  VIII-8

                SECONDARY  LEAD COMBINATIONS 2&3,  OPTION F
                                      966

-------
   10

   10
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                                                        DEPRECIATION


                                                        CAPITAL
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                                  Figure VIII-9


                                HOLDING  TANK COSTS
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                                                      t  »
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                                  Figure  VIII-10


                  COOLING TOWER COSTS CASTING CONTACT  COOLING
                                       967

-------
                    SECONDARY LEAD SUBCATEGORY

                            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 facili-
ties 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 (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.  Some of the
factors which must be considered in establishing effluent limi-
tations 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.
                               969

-------
As explained in Section IV, the secondary lead subcategory has
been subdivided into four potential wastewater sources.  Since
the water use, discharge rates, and pollutant characteristics of
each of these wastewaters is potentially unique, effluent limita-
tions will be developed for each of the four subdivisions.

For each of the subdivisions, 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 deter-
mined 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 ana-
lyzed to determine (1) whether or not operations included gener-
ated 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 waste-
water 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 normal-
ized 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 main-
tenance 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 loadings were
calculated for each wastewater source or subdivision.  This cal-
culation 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 loadings (milligrams of pollu-
tant per metric ton of production unit - mg/kkg) were calculated
by multiplying the BPT normalized flow (1/kkg) by the concentra-
tion achievable using the BPT treatment system (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 various waste-
water 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 efflu-
ent limitations for these combined wastewaters are based on the
                              970

-------
various wastewater sources which actually  contribute  to  the  com-
bined 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
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 dis-
charge flow rates for each source; consequently, the  treatment
levels which are currently used by the lowest dischargers will  be
the treatment technologies most likely required to  meet  BPT
guidelines.  Section VII discusses the various treatment tech-
nologies 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 applica-
tion 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 REDUCTION BENEFITS

In balancing costs in relation to effluent  reduction benefits,
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
                               971

-------
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 BPT.  See Weyerhaeuser
Company v. Costle, 590 F.2d 1011 (D.C. Cir. 1978).

The methodology for calculating pollutant reduction benefits and
plant compliance costs is discussed in Section X.  Tables X-2 and
XII-1 show the estimated pollutant reduction benefits for each
treatment option for direct and indirect dischargers.  Compliance
costs are presented in Table X-3.

BPT OPTION SELECTION

The BPT treatment scheme (Figure IX-1) selected consists of
complete recycle of kettle scrubber liquor, and chemical
precipitation and sedimentation (lime and settle) end-of-pipe
technology.  Dry air pollution control of air emissions from
kettle refining is required; or alternately, complete recycle of
kettle scrubber liquor may be used to achieve zero discharge of
wastewater pollutants.  The BPT treatment is equivalent to Option
A described in Section X. The proposed BPT will result in the
removal of approximately 14,350 kg/yr of toxic metal pollutants
and 5,398,900 kg/yr of conventional pollutants from the estimated
raw discharge.  The estimated capital cost of BPT is $470,000
(1978 dollars) and the estimated annual cost is $228,000 (1978
dollars).

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
for each of the four wastewater sources are discussed below and
summarized in Table IX-1.  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 pro-
duction normalizing parameters, or PNP's, are also listed in
Table IX-1.

BATTERY CRACKING

The BPT wastewater discharge rate for battery cracking is 940
1/kkg (225 gal/ton) of lead produced.  All 32 of the plants with
this process discharge this wastewater at rates ranging from 80.5
to 5,086 1/kkg (19.3 to 1,220 gal/ton).  A distribution of waste-
water rates for battery cracking wastewater is presented in
                               972

-------
Section V  (Table V-l).   None  of  the  plants  practice  recycle of
this wastewater, therefore  the BPT rate  is  the  average  discharge
rate of 32 plants.  Twenty-three plants  meet  the  BPT discharge
rate.

BLAST AND REVERBERATORY  FURNACE  WET  AIR  POLLUTION CONTROL

The BPT wastewater discharge  rate for blast and reverberatory
furnace wet air pollution control is 3,380  1/kkg  (811 gal/ton)  of
lead produced.  This rate is  allocated only for those plants
having wet air pollution control for smelting operations.   Of the
47 plants with this process,  seven use 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 discharges with  no recycle.   Three  plants
practice partial recycle, ranging from 83.3 to  93.3  percent.   Two
of the seven plants achieve zero discharge by 100 percent
recycle.  Extensive recycling is possible for this wastewater
stream, but a zero discharge  may not be  technically  feasible
unless (1) a recycle system controls dissolved  solids buildup;
(2) the wastewater is evaporated;  or (3) 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 plants
range from 1,776 to 6,587 1/kkg  (426 to  1,580 gal/ton).   The
average of these four discharges is  the basis for the BPT  rate.
Five of six plants meet  the BPT  rate.  Wastewater rates  for blast
and reverberatory furnace wet air pollution control  are  presented
in Table V-3.

KETTLE WET AIR POLLUTION CONTROL

No BPT wastewater discharge allowance is provided for kettle
scrubbing wastewater.  Twenty-eight  plants control kettle  air
emissions; 19 use dry controls (baghouses), and nine use
scrubbers.  Six plants practice  complete recycle  of  the  scrubber
liquor and one plant uses the liquor in the battery  cracking  and
decasing operation.  The remaining two plants practice  recycle  of
91.7 and 96 percent. Since complete  recycle of kettle scrubber
wastewater is so widely  demonstrated in this  subcategory,  the
Agency believes that zero discharge  of wastewater pollutants  is
feasible for all secondary lead  kettle wet air  pollution control.

CASTING CONTACT COOLING  WATER

The BPT wastewater discharge  rate  for casting contact cooling
water is 221 1/kkg (53.1 gal/ton)  of lead cast.   Of  the  66
secondary lead plants with casting operations,  11  generate
wastewater from the process.  Three  plants practice  total  recycle
and two plants reported  discharging  insignificant"  amounts of
                               973

-------
wastewater. Six plants are 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.
The BPT discharge rate is based on the average of the six dis-
charging plants.  Ten of the 11 plants using casting contact
cooling water meet the BPT discharge rate.

REGULATED POLLUTANT PARAMETERS

The raw wastewater concentrations  from individual operations and
the subcategory as a whole were examined to select certain pollu-
tants 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 General
Development Document and summarized there in Table VII-22.  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 kilograms of pollutant per
metric ton of product represent the BPT effluent limitations and
are presented in Table IX-2 for each individual waste stream.
                               974

-------


































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-------
                            Table IX-2

   BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
                         Battery Cracking

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs. of lead scrap produced
Ant imony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    2,697.80
    1,964.60
      141.0
    1,250.20
        0.0
   38,540.0
    1,193.80
      808.40
      122.20
      526.40
        0.0
   18,800.0
Within the range of 7.5 to 10.0
         at all times
    Blast and Reverberatory Furnace Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting
Ant imony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    9,700.60
    7,064.20
      507.0
    4,495.40
        0.0
  138,580.0
    4,292.60
    2,906.80
      439.40
    1,892.80
        0.0
   67,600.0
Within the range of 7.5 to 10.0
         at all times
                                976

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                      Table IX-2 (Continued)

   BPT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
                 Kettle Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
PH
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
Within the range of 7.5 to 10.0
         at all times
                     Casting Contact Cooling
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
PH
      634.84          280.92
      462.31          190.23
       33.18           28.76
      294.20          123.87
        0.0             0.0
    9,069.20        4,424.0
Within the range of 7.5 to 10.0
         at all times
                               977

-------
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-------
                     SECONDARY LEAD  SUBCATEGORY

                             SECTION X

        BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE


The effluent limitations which must be  achieved by  July  1,  1984,
are based on the best control and treatment  technology used by  a
specific point source within the industrial  category  or  subcate-
gory, or by another  category where  it is  readily  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).  At a minimum, 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 feasible  process changes or
internal controls, even when not in commom 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, 11 ERG 2149  (D.C. Cir. 1978)).
However, in assessing the proposed  BAT, the  Agency has given
substantial weight to the economic  achievability  of the
technology.

TECHNICAL APPROACH TO BAT

In pursuing this second round of effluent regulations, 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 five 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:
                                979

-------
Option A is based on:

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining or alterna-
        tively, complete recycle of kettle scrubber liquor

Option B is based on:

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining or alterna-
        tively, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater

Option C is based on:

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining or alterna-
        tively, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration

Option D is based on:

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining or alterna-
        tively, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration
     o  Activated alumina adsorption

Option F is based on:

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining or alterna-
        tively, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration
     o  Reverse osmosis in conjunction with multiple-effect
        evaporation for complete recycle of treated water

The five 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.
                               980

-------
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
complete recycle of kettle scrubber liquor,  and chemical precipi-
tation and sedimentation  (lime and settle) end-of-pipe  technology
(see Figure X-l).  The discharge rates  for Option  A are equal to
the discharge rates allocated to each stream as a  BPT discharge
flow.  Dry air pollution  control of kettle refining air emissions
is required to achieve zero discharge of wastewater pollutants,
or alternatively, complete recycle of kettle scrubber liquor  may
be used.

OPTION B

Option B for the secondary lead subcategory  achieves lower
pollutant discharge by building upon the Option A  end-of-pipe
treatment technology.  Flow reduction measures  are added to
Option A treatment, chemical precipitation and  sedimentation  (see
Figure X-2).  These flow  reduction measures, including  in-process
changes, result in the elimination of some wastewater streams and
the concentration of pollutants in other effluents.  As explained
in Section VII of the General Development Document, treatment of
a more concentrated effluent allows achievement of a greater  net
pollutant removal and introduces the possible economic benefits
associated with treating  a lower volume of wastewater.

Methods used in Option B  to reduce process wastewater generation
and discharge rates include the following:

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 (refer  to
Section VII of the General Development  Document).  A blowdown or
periodic cleaning is likely to be needed 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.)
                               981

-------
Recycle of Water Used in Wet Air Pollution Control

There are two wastewater sources associated with wet air
pollution control which are regulated under these effluent
limitations:

     --Blast and reverberatory furnace scrubber, and
     --Kettle scrubber.

Table X-l presents the number of plants reporting wastewater use
with these sources, the number of plants practicing recycle of
scrubber liquor, and the range of recycle values being used.
Although some plants report total recycle of their scrubber
water, a blowdown or periodic cleaning may be needed to prevent
the buildup of dissolved and suspended solids since the water
picks up particulates and fumes from the air.  Since the BPT
discharge rate for the kettle scrubber is zero, no further flow
reduction can be achieved at BAT.

OPTION C

Option C for the secondary lead subcategory consists of in-
process flow reduction, chemical precipitation, and sedimentation
treatment of Option B plus multimedia filtration technology added
at the end of Option B treatment (see Figure X-3).  Multimedia
filtration is used to remove suspended solids, including precipi-
tates 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.

OPTION D

Option D for the secondary lead subcategory consists of in-
process flow reduction, chemical precipitation, sedimentation,
and multimedia filtration treatment of Option C with the addition
of activated alumina technology at the end of the Option C treat-
ment.  The activated alumina process is used to remove dissolved
arsenic which remains after lime precipitation.

OPTION F

Option F for the secondary lead subcategory consists of in-
process flow reduction, chemical precipitation, sedimentation,
and multimedia filtration treatment of Option C with the addition
of reverse osmosis and multiple-effect evaporation technology at
the end of the Option C treatment (see Figure X-4).  Option F is
used for complete recycle of the treated water by controlling the
concentration of dissolved solids.  Multiple-effect evaporation
is used in dewater brines rejected by reverse osmosis.
                               982

-------
Another treatment technology, activated  carbon  adsorption  (Option
E) was not considered for this subcategory.   In Section  VI of
this supplement, 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,  is not
applicable.

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

As a means of evaluating each technology option, EPA developed
estimates of the pollutant reduction benefits and the compliance
costs associated with each option.  The  methodologies are
described below.

POLLUTANT REDUCTION BENEFITS

A complete description of the methodology used  to calculate the
estimated pollutant reduction, or benefit, achieved by the appli-
cation of the various treatment options  is presented in  Section X
of the General Development Document.  In short,  sampling data
collected during the field sampling program were used to charac-
terize the major waste streams considered for regulation.  At
each sampled facility, the sampling data was production  normal-
ized 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 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 by multiplying the regulatory flow
determined for each unit process by the total subcategory  produc-
tion.   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 dis-
charged by the subcategory.  The mass of pollutant removed,
referred to as the benefit, is simply the difference between the
estimated mass of pollutant generated within the subcategory and
the mass of pollutant discharged after application of the  treat-
ment option.

The Agency varied this procedure slightly in computing estimated
BPT discharge in a subcategory where there is an existing  BPT
limitation.  In this case, EPA took the mass limits from the BPT
limitations (for all pollutants limited at BPT)  and multiplied
these limits by the total subcategory production (from dcp).
                               983

-------
(The assumption is that plants are discharging a volume equal to
their BPT allowance times their production.)  Where pollutants
are not controlled by existing BPT, EPA used the achievable
concentration for the associated technology proposed in this
document, and multiplied these concentrations by the total
end-of-pipe discharge of process wastewater for the subcategory
(from dcp).  The total of both these calculations represents
estimated mass loadings for the subcategory.  The pollutant
reduction benefit estimates for direct discharges in the second-
ary lead subcategory are presented in Table X-2.

COMPLIANCE COSTS

In estimating subcategory-wide compliance costs, the first step
was to develop uniformly-applicable cost curves, relating the
total costs associated with installation and operation of waste-
water treatment technologies to plant process wastewater dis-
charge.  EPA applied these curves on a per plant basis, a plant's
costs (both capital, and operating and maintenance) being deter-
mined 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 cost
of compliance for the subcategory (see Table X-3) .  These costs
were used in assessing economic achievability.

BAT OPTION SELECTION

EPA has selected both Option B and Option C as the basis for
alternative BAT effluent limitations for the secondary lead sub-
category due to current adverse structural economic changes that
are not reflected in the Agency's current economic analysis.
These alternative limitations are 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.  The major
changes affecting the secondary lead market are an overall
stagnant demand, and a major shift by battery manufacturers to
low-antimony maintenance free (MF) batteries. A more detailed
explanation regarding this economic analysis can be found in the
Economic Impact Analysis of Proposed Effluent Standards and
Limitations for the Nonferrous Smelting and Refining Industry,
EPA 440/2-82-002.

The selected BAT Alternative A (Option B) increases the removal
of toxic metals by an estimated 132 kg/yr over the estimated BPT
discharge.  The estimated capital cost of proposed Alternative A
is $0.470 million (1978 dollars), and the annualized cost is
$0.228 million (1978 dollars).  The selected BAT Alternative B
(Option C) would remove approximately 14,602 kg/yr of toxic
metals and 495 kg/yr of ammonia from raw discharge and increases
                               984

-------
the removal of toxic metals by  an  estimated  189  kg/yr  over the
estimated BPT discharge.  The estimated  capital  cost of the
proposed Alternative B  is $2.12 million  (1978  dollars), and the
annualized cost is  $1.36 million  (1978 dollars).

Activated alumina  (Option D) was considered; however,  this tech-
nology 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; how-
ever, 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.

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 four  wastewater
sources were determined and are summarized in  Table X-4.   The
discharge rates are normalized  on  a production basis by relating
the amount of wastewater generated to the  mass of the  interme-
diate 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-4.

The BAT wastewater  discharge rate  equals the BPT wastewater
discharge rate for  kettle wet air  pollution  control.   Since the
kettle scrubber regulatory discharge  rate  is zero, no  further
flow reduction is feasible.  Wastewater  streams  for which  BAT
discharge rates differ from BPT are discussed  below.

BATTERY CRACKING

The BAT wastewater  discharge rate  for battery  cracking is  673
1/kkg (162 gal/ton) of lead produced  from  battery cracking.   All
32 of the secondary lead plants with  this  process  discharge this
wastewater; none practice recycle.  The  BAT  rate  is predicated  on
the average of discharge rates  from 30 plants  with flow rates
ranging from 80.5 to 1,984 1/kkg (19.3 to  476  gal/ton).  Two
plants use significantly larger volumes  of wash water  than the
other facilities and thus were  excluded  from the  BAT flow
calculation.   Wastewater rates  for  battery cracking are  presented
in Section V (Table V-l).  Seventeen  of  the  32 plants  meet the
BAT discharge rate.
                                985

-------
BLAST AND REVERBERATORY FURNACE WET AIR POLLUTION CONTROL

The BAT wastewater discharge rate for smelting 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
scrubber water used at four plants that discharge from this
process and is allocated only for those plants having wet air
pollution control for smelting operations.  (Refer to Section VII
of the General Development Document.)  Of the 47 plants with
smelting processes, seven use wet scrubbing devices.  One of the
seven did not provide sufficient production information in the
dcp to calculate a discharge rate but reported a recycle rate of
97.8 percent.  One plant is a once-through discharger, practicing
no recycle.  The recycle in three other plants ranges from 83.3
to 93.3 percent.  Two plants achieve zero discharge by 100
percent recycle.  Some zero discharge possibilities are
site-specific and thus, are not applicable on a nationwide basis.
The distribution of wastewater rates for this waste stream is
presented in Table V-3.  Four of the six plants reporting flow
data for this waste stream meet the BAT discharge rate.

CASTING CONTACT COOLING WATER

The BAT wastewater discharge rate is 22 1/kkg (5.3 gal/ton),
based on 90 percent recycle of the BPT discharge allowance (refer
to Section VII of the General Development Document).  Eleven of
the 66 plants with casting operations use contact cooling water.
Three 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).  Seven
of the 11 plants using casting contact cooling water meet the BAT
discharge rate.

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) (197677 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 second-
ary 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
                               986

-------
from a given  subcategory,  the Agency  is  proposing  effluent  mass
limitations only  for those pollutants  generated  in the  greatest
quantities as shown by the pollutant  reduction benefit  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  technically justified since the treatable  con-
centrations used  for lime  precipitation  and sedimentation tech-
nology are based  on optimized treatment  for concommitant  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  tech-
nology removes metals non-preferentially.

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
following toxic pollutants are excluded  from limitation on  the
basis that they are effectively  controlled by the  limitations
developed for the selected toxic metals:

     118.  cadmium
     119.  chromium (Total)
     120.  copper
     124.  nickel
     126.  silver
     127.  thallium

The conventional pollutant parameters  TSS  and pH will be  limited
by the best conventional technology (BCT)  effluent  limitations.
These effluent limitations and a discussion of BCT  are  presented
in Section XIII of this  supplement.

EFFLUENT LIMITATIONS

The treatable concentrations, achievable by application of  the
two BAT technologies (Options B and C) are summarized in Table
VII-19 of the General Development Document.  These  treatable con-
centrations (both one day maximum and  monthly average) are  multi-
plied by the BAT normalized discharge  flows summarized  in Table


                               987

-------
X-4 to calculate the mass of pollutants allowed to be discharged
per mass of product.  The results of these calculations in milli-
grams of pollutant per metric ton of product represent the BAT
effluent limitations for the secondary lead subcategory.  Two
sets of BAT effluent limitations, each based on one of the two
alternative BAT options, have been developed for the secondary
lead subcategory.  BAT effluent limitations based on Option B
(lime precipitation, sedimentation, and in-process flow reduc-
tion) are presented in Table X-5, while limitations based on
Option C (lime precipitation, sedimentation, in-process flow
reduction, and multimedia filtration) are presented in Table X-6,
                               988

-------
                            Table X-l
               CURRENT RECYCLE PRACTICES WITHIN THE
                    SECONDARY LEAD SUBCATEGORY
                         Number of      Number of
                         Plants         Plants         Range of
                         With           Practicing     Recycle
Waste Stream             Wastewater     Recycle        Values (%)

Blast and Reverberatory
 Furnace Wet Atr
 Pollution Control           7              6          83.7-100

Kettle Wet Air
 Pollution Control           9              8          91.7-100
                               989

-------

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-------
                      Table X-3

      COST OF COMPLIANCE FOR THE SECONDARY LEAD
                     SUBCATEGORY
                             Direct Dischargers

                         Capital Cost    Annual Cost
Option                   (1978 Dollars)  (1978 Dollars)

   A                     470,000           288,000
   B                     470,000           228,000
   C                   2,116,000         1,358,000
   D                   2,486,000         1,642,000
                         992

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-------
                            Table X-5

   BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION B)
                         Battery Cracking

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of' lead scrap produced

Antimony                              1,931.51          854.71
Arsenic                               1,406.57          578.78
Lead                                    100.95           87.49
Zinc                                    895.09          376.88
Ammonia (as N)                            0.0             0.0


    Blast and Reverberatory Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              7,490.7         3,314.7
Arsenic                               5,454.9         2,244.6
Lead                                    391.5           339.3
Zinc                                  3,471.30        1,461.6
Ammonia (as N)                            0.0             0.0


                 Kettle Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammpnia (as N)                            00
                              994

-------
                      Table X-5 (Continued)

   BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION B)


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 63.43           28.07
Arsenic                                  46.19           19.01
Lead                                      3.32            2.87
Zinc                                     29.39           12.38
Ammonia (as N)                            0.0             0.0
                              995

-------
                            Table X-6

   BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION C)


                         Battery Cracking

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                              1,298.89          578.78
Arsenic                                 935.47          383.61
Lead                                     67.30           60.57
Zinc                                    686.46          282.66
Ammonia (as N)                            0.0             0.0


    Blast and Reverberatory Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              5,037.30        2,244.60
Arsenic                               3,627.90        1,487.70
Lead                                    261.0           234.90
Zinc                                  2,662.20        1,096.20
Ammonia (as N)                            0.0             0.0


                 Kettle Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            0               0
                               996

-------
                      Table X-6 (Continued)

   BAT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION C)


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 42.65           19.01
Arsenic                                  30.72           12.60
Lead                                      2.21            1.99
Zinc                                     22.54            9.28
Ammonia (as N)                            0.0             0.0
                               997

-------
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                     SECONDARY LEAD SUBCATEGORY

                             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  tech-
nology (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,  Con-
gress directed EPA to consider the best  demonstrated process
changes, in-plant  controls,  and end-of-pipe treatment  technolo-
gies 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

As discussed in the  General  Development  Document,  all  of the
treatment technology options  applicable  to a  new source were
previously considered for  the BAT options.  For this reason,  five
options were considered for  BDT,  all identical, with one
exception, to the BAT options discussed  in Section X.   It  is
proposed that the kettle wet  air  pollution control waste stream
be eliminated under  BDT through the  use  of dry air pollution
control.   Dry scrubbing is widely demonstrated  for controlling
emissions from kettle smelting.   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 hot  particu-  late
matter, as well as sulfur  dioxide fumes, which requires wet air
pollution scrubbing.

The treatment technologies used for  the five  BDT options are:

OPTION A

     o  Chemical precipitation  and  sedimentation
     o  Dry air pollution  control  of kettle refining,  or alter-
        nately,  complete recycle  of  kettle scrubber liquor
                               1003

-------
OPTION B

     o
     o
Chemical precipitation and sedimentation
Dry air pollution control of kettle refining, or alter-
nately, complete recycle of kettle scrubber liquor
In-process flow reduction of casting contact cooling
water, blast and reverberatory furnace scrubber liquor,
and battery cracking wastewater
OPTION C
        Chemical precipitation and sedimentation
        Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber liquor
        In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
        Multimedia filtration
OPTION D
     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration
     o  Activated alumina adsorption
OPTION F

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration
     o  Reverse osmosis in conjunction with multiple-effect
        evaporation for complete recycle of treated water

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.
                               1004

-------
BDT OPTION SELECTION

EPA is proposing that the best available demonstrated technology
for the secondary lead subcategory be equivalent to BAT technol-
ogy Alternative B (Option C).  The selected option consists of
dry kettle air pollution control methods (or alternately, com-
plete recycle of kettle scrubber liquor), in-process flow reduc-
tion, chemical precipitation, sedimentation, and multimedia fil-
tration.

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.

Water conservation and advanced wastewater treatment are demon-
strated in the secondary lead subcategory, and they form the
technical basis of BAT.  Therefore, new source performance stan-
dards are equivalent to BAT Alternative B (Option C).  Control of
particulate matter from kettle smelting has been demonstrated
with dry methods, but emissions from blast and reverberatory fur-
naces may not be controlled with a dry method.  Emissions from
these latter two furnaces contain varying concentrations of sul-
fur dioxide which is removed most efficiently with a wet scrub-
ber.  Review of the subcategory indicates that no additional flow
reduction over and above BAT is achievable with currently demon-
strated technology.  Activated alumina and reverse osmosis are
not demonstrated in this subcategory, and are not clearly trans-
ferable to nonferrous metals manufacturing wastewater.

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
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.
                               1005

-------
NEW SOURCE PERFORMANCE STANDARDS

The NSPS discharge flows for each wastewater source are the same
as the discharge rates for BAT and are presented in Table XI-1.
The mass of pollutant allowed to be discharged per mass of
product is calculated by multiplying the appropriate achievable
treatment concentration by the production normalized wastewater
discharge flows (1/kkg).  These concentrations are listed in
Table VII-19 of the General Development Document. New source
performance standards are presented in Table XI-2.
                               1006

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                            Table XI-2

             NSPS FOR THE SECONDARY LEAD SUBCATEGORY
                         Battery Cracking
Pollutant or Pollutant Property
 Maxinmm for
 Any One Day
  Maximum for
Monthly Average
           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
PH
    1,298.89          578.78
      935.47          383.61
       67.30           60.57
      686.46          282.66
        0.0             0.0
   10,095.0         8,076.0
Within the range of 7.5 to 10.0
         at all times
    Blast and Reverberatory Furnace Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
    5,037.30
    3,627.90
      261.0
    2,662.0
        0
   39,150.0
    2,244.60
    1,487.70
      234.90
    1,096.20
        0
   31,320.0
Within the range of 7.5 to 10.0
         at all times
                            1008

-------
                      Table XI-2  (Continued)

             NSPS FOR THE SECONDARY LEAD SUBCATEGORY
                 Kettle Wet Air Pollution Control
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
        0
Within the range of 7.5 to 10.0
         at all times
                     Casting Contact Cooling
Pollutant or Pollutant Property
 Maximum for
 Any One Day
  Maximum for
Monthly Average
                  Metric Units - mg/kkg of cast
           English Units - Ibs/billion Ibs of lead cast
Antimony
Arsenic
Lead
Zinc
Ammonia (as N)
Total Suspended Solids
pH
       42.65
       30.72
        2.21
       22.54
        0.0
      331.50
Within the range of 7.5 to 10.0
         at all times
       19.01
       12.60
        1.99
        9.28
        0.0
      265.20
                             1009

-------
                    SECONDARY LEAD SUBCATEGORY

                           SECTION XII

                      PRETREATMENT STANDARDS


Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources  (PSES), which must be achieved
within three years of promulgation.  PSES are designed to prevent
the discharge of pollutants which pass through, interfere with,
or are otherwise inco^palible with the operation of publicly
owned treatment works '(POxW) .  The Clean Water Act of 1977
requires pretreatment for pollutants, such as heavy 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 facili-
ties, 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 instal-
lation.  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.  Pretreatment
standards for regulated pollutants are presented based on the
selected control and treatment technologies.

TECHNICAL APPROACH TO PRETREATMENT

Before proposing 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 percentage
removed nationwide by well-operated POTW meeting secondary
treatment requirements, is less than the percentage removed by
direct dischargers complying with BAT effluent limitations
guidelines for that pollutant.  (See generally, 46 FR 9415-16
(January 28,  1981).)

This definition of pass through satisfies two competing objec-
tives set by Congress:  (1) that standards for indirect dis-
chargers be equivalent to standards for direct dischargers, while

                              1011

-------
at the same time, (2) that the treatment capability and perfor-
mance of the POTW be recognized and taken into account in regu-
lating 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 pollu-
tants in the POTW effluent to lower concentrations due to 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.  It is proposed for
PSNS 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 the General Development
Document.

Treatment technologies considered for PSES and PSNS:

OPTION A

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber liquor

OPTION B

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater

OPTION C

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration
                               1012

-------
OPTION D
     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber  liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration
     o  Activated alumina adsorption

OPTION F

     o  Chemical precipitation and sedimentation
     o  Dry air pollution control of kettle refining, or alter-
        nately, complete recycle of kettle scrubber  liquor
     o  In-process flow reduction of casting contact cooling
        water, blast and reverberatory furnace scrubber liquor,
        and battery cracking wastewater
     o  Multimedia filtration
     o  Reverse osmosis in conjunction with multiple-effect
        evaporation for complete recycle of treated water

INDUSTRY COST AND POLLUTANT REDUCTION BENEFITS

The industry cost and pollutant reduction benefits of each treat-
ment option were used to determine the most cost-effective
option.  The methodology applied in calculating pollutant
reduction benefits and plant compliance costs is discussed in
Section X.  Table XII-1 shows the estimated pollutant reduction
benefits for indirect dischargers.  Compliance costs are
presented in Table XII-2.

PSES OPTION SELECTION

EPA has selected both Option B and Option C as the basis for
alternative PSES for the secondary lead subcategory.  This selec-
tion follows the rationale used in reflecting the alternative
options as the basis for BAT.  (Refer to Section X.)  The Option
B treatment consists of in-process flow reduction, chemical pre-
cipitation, and sedimentation.  The Option C treatment consists
of dry kettle air pollution control, in-process flow reduction,
chemical precipitation, sedimentation, and multimedia filtration.
This selection flows the rationale used in selected the alterna-
tive options as the basis for BAT.  (Refer to Section X.)
                               1013

-------
The proposed PSES Alternative A (Option B) would remove approxi-
mately 17,130 kg/yr of toxic metal pollutants over the raw dis-
charge and approximately 11,527 kg/yr of ammonia.  The estimated
capital cost of proposed Alternative A is $1.49 million (1978
dollars) and the estimated annual cost is $0.559 million  (1978
dollars).  The proposed PSES Alternative B (Option C) would
remove approximately 17,290 kg/yr of toxic metal pollutants over
raw discharge and approximately 1,527 kg/yr of ammonia.   The
estimated capital cost Alternative B is $3.04 million  (1978
dollars) and the annual cost is $1.94 million (1978 dollars).

Activated alumina (Option D) was considered; however, this tech-
nology was rejected because it was not demonstrated in this
subcategory nor was it clearly transferable to nonferrous waste-
water.  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 deter-
mined that its performance for this specific purpose was  not
adequately demonstrated in this subcategory nor was it clearly
transferable from another subcategory.

PSNS OPTION SELECTION

The technology basis for proposed PSNS is identical to NSPS.
The PSNS treatment consists of in-process flow reduction, chemi-
cal 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 shut-
down necessary for installation of the new equipment that exist-
ing plants should have.  Therefore, PSNS will be based on the
Option C technology only, rather than considering two alterna-
tives (Options B and C) as in PSES.

EPA knows of no demonstrated technology that provides more
efficient pollutant removal than NSPS technology.  Activated
alumina was considered; however, this technology was rejected
because it was not demonstrated in this subcategory nor was it
clearly transferable to nonferrous wastewater.  No additional
flow reduction for new sources is feasible because the only other
available flow reduction technology, reverse osmosis (Option F) ,
is not demonstrated in the subcategory nor is it clearly
transferable to nonferrous wastewater.
                               1014

-------
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 proposing  PSES
and PSNS for ammonia, antimony, arsenic, lead, and zinc  to pre-
vent pass-through.  The conventional pollutants are not  limited
under PSES and PSNS because they are effectively  controlled  by
POTW.

PRETREATMENT STANDARDS

The PSES and PSNS discharge flows are identical to the BAT dis-
charge flows for all processes.  These discharge  flows are listed
in Table XII-3.  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  dis-
charge flow (1/kkg).  The achievable treatment concentrations are
presented in Table VII-19 of the General Development Document.
Pretreatment standards for existing and new sources, as  de-
termined from the above procedure, are shown  in Tables XII-4
through XII-6 for each waste stream.
                              1015

-------
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-------
                          Table XII-2

                   COST OF COMPLIANCE FOR THE
                  SECONDARY LEAD SUBCATEGORY
                               Indirect Dischargers

                            Capital Cost       Annual Cost
Option                      (1978 Dollars)     (1978 Dollars)
  A                            1,240,000          558,000
  B                            1,485,000          559,000
  C                            3,037,000        1,944,000
  D                   -         3,910,000        2,310,000
                             1018

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                           Table XII-4

             PSES FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION B)


                         Battery Cracking

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                              1,931.51          854.71
Arsenic                               1,406.57          578.78
Lead                                    100.95           87.49
Zinc                                    895.09          376.88
Ammonia (as N)                            0.0             0.0


Blast and Reverberatory Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              7,490.7         3,314.7
Arsenic                               5,454.9         2,244.6
Lead                                    391.5           339.3
Zinc                                  3,471.30        1,461.6
Ammonia (as N)                            0.0             0.0


                 Kettle Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            00
                             1020

-------
                     Table XII-4 (Continued)

             PSES FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION B)


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 63.43           28.07
Arsenic                                  46.19           19.01
Lead                                      3.32            2.87
Zinc                                     29.39           12.38
Ammonia (as N)                            0.0             0.0
                             1021

-------
                           Table XII-5

             PSES FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION C)


                         Battery Cracking

                                   Maximum for      Maximum for
Pollutant or Pollutant Property	Any One Day	Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                              1,298.89          578.78
Arsenic                                 935.47          383.61
Lead                                     67.30           60.57
Zinc                                    686.46          282.66
Ammonia (as N)                            0.0             0.0


    Blast and Reverberatory Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              5,037.30        2,244.60
Arsenic                               3,627.90        1,487.70
Lead                                    261.0           234.90
Zinc                                  2,662.20        1,096.20
Ammonia (as N)                            0.0             0.0


                 Kettle Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            00
                             1022

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                     Table XII-5 (Continued)

             PSES FOR THE SECONDARY LEAD SUBCATEGORY
                       (BASED ON OPTION C)


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Pay    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 42.65           19.01
Arsenic                                  30.72           12.60
Lead                                      2.21            1.99
Zinc                                     22.54            9.28
Ammonia (as N)                            0.0             0.0
                             1023

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                           Table XII-6

             PSNS FOR THE SECONDARY LEAD SUBCATEGORY


                         Battery Cracking

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Antimony                              1,298.89          578.78
Arsenic                                 935.47          383.61
Lead                                     67.30           60.57
Zinc                                    686.46          282.66
Ammonia (as N)                            0.0             0.0


    Blast and Reverberatory Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutantor Pollutant Property    Any One Day    Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Antimony                              5,037.30        2,244.60
Arsenic                               3,627.9         1,487.7
Lead                                    261.0           234.9
Zinc                                  2,662.2         1,096.2
Ammonia (as N)                            0               0


                 Kettle Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Antimony                                  0               0
Arsenic                                   0               0
Lead                                      0               0
Zinc                                      0               0
Ammonia (as N)                            0               0
                              1024

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                     Table XII-6 (Continued)

             PSNS FOR THE SECONDARY LEAD SUBCATEGORY


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of lead cast

Antimony                                 42.65           19.01
Arsenic                                  30.72           12.60
Lead                                      2.21            1.99
Zinc                                     22.54            9.28
Ammonia (as N)                            0.0             0.0
                             1025

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                    SECONDARY LEAD SUBCATEGORY

                           Section XIII

            Best Conventional Pollutant Control Technology


The 1977 amendments to the Clean Water Act added Section
301(b)(2)(E), establishing "best conventional pollutant control
technology" (BCT) for discharge of conventional pollutants  from
existing industrial point sources.  Biochemical oxygen-demanding
pollutants (6005), total suspended solids  (TSS), fecal coli-
form, oil and grease (OScG), and pH have been designated as
conventional pollutants  (see 44 FR 44501).

BCT is not an additional limitation, but replaces BAT for the
control of conventional pollutants.  In addition to the other
factors specified in Section 304(b)(4)(B), the Act requires that
limitations for conventional pollutants be assessed in light of a
two-part cost-reasonableness test.  On October 29, 1982, the
Agency proposed a revised methodology for carrying out BCT  analy-
ses (47 FR 49176).  The purpose of the proposal was to correct
errors in the BCT methodology originally established in 1977.

Part 1 of the proposed BCT test requires that the cost and  level
of reduction of conventional pollutants by industrial dischargers
be compared with the cost and level of reduction to remove  the
same type of pollutants by publicly-owned treatment works (POTW).
The POTW comparison figure has been calculated by evaluating the
change in costs and removals between secondary treatment (30 mg/1
BOD and 30 mg/1 TSS) and advanced secondary treatment (10 mg/1
BOD and 10 mg/1 TSS).  The difference in cost is divided by the
difference in pounds of conventional pollutants removed, result-
ing in an estimate of the "dollars per pound" of pollutant
removed, that is used as a benchmark value.  The proposed POTW
test benchmark is $0.30 per pound (1978 dollars).

Part 2 of the BCT test requires that the cost and level of  reduc-
tion of conventional pollutants by industrial dischargers be
evaluated internally to the industry.  In order to develop  a
benchmark that assesses a reasonable relationship between cost
and removal,  EPA has developed an industry cost ratio which
compares the dollar per pound of conventional pollutant removed
in going from primary to secondary treatment levels with that of
going from secondary to more advanced treatment levels.  The
basis of costs for the calculation of this ratio are the costs
incurred by a POTW.  EPA used these costs because:  they reflect
the treatment technologies most commonly used to remove conven-
tional pollutants from wastewater; the treatment levels associ-
ated with them compare readily to the levels considered for
industrial dischargers; and the costs are the most reliable for
the treatment levels under consideration.  The proposed industry


                              1027

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subcategory benchmark is 1.42.  If the industry figure for a
subcategory is lower than 1.43, the subcategory passes the BCT
test.

The Agency usually considers two conventional pollutants in the
cost test, TSS and an oxygen-demanding pollutant.  Although both
oil and grease and BOD5 are considered to be oxygen-demanding
substances by EPA (see 44 FR 50733), only one can be selected in
the cost analysis to conform to procedures used to develop POTW
costs.  Oil and grease is used rather than BOD5 in the cost
analysis performed for nonferrous metals manufacturing waste
streams due to the common use of oils in casting operations in
this industry.

BPT is the base for evaluating limitations on conventional
pollutants (i.e., it is assumed that BPT is already in place).
The test evaluates the cost and removals associated with treat-
ment and controls in addition to that specified as BPT.

If the conventional pollutant removal cost of the candidate BCT
is less than the POTW cost, Part 1 of the cost-reasonableness
test is passed and Part 2 (the internal industry test) of the
cost-reasonableness test must be performed.  If the internal
industry test is passed, then a BCT limitation is promulgated
equivalent to the candidate BCT level.  If all candidate BCT
technologies fail both parts of the cost-reasonableness test, the
BCT requirements for conventional pollutants are equal to BPT.

The BCT test was performed for the proposed BAT basis of lime
precipitation, sedimentation, in-process flow reduction, and
multimedia filtration.  The secondary lead subcategory failed
Part 1 of the test with a calculated cost of $179.94 per pound
(1978 dollars) of removal of conventional pollutants using BAT
technology.  The intermediate flow reduction option was also
examined, but it too failed with a cost of $15.34 per pound (1978
dollars) of conventional removal.
                               1028

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                           Table XIII-1

   BCT EFFLUENT LIMITATIONS FOR THE SECONDARY LEAD SUBCATEGORY


                         Battery Cracking

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

           Metric Units - mg/kkg of lead scrap produced
      English Units - Ibs/billion Ibs of lead scrap produced

Total Suspended Solids               38,540.0        18,800.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


    Blast and Reverberatory Furnace Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day	Monthly Average

       Metric Units - mg/kkg of lead produced from smelting
  English Units - Ibs/billion Ibs of lead produced from smelting

Total Suspended Solids              138,580.0        67,600.0
pH                                Within the range of 7.5 to 10.0
                                           at all times


                 Kettle Wet Air Pollution Control

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

   Metric Units - mg/kkg of lead produced from kettle furnaces
   English Units - Ibs/billion Ibs of lead produced from kettle
                             furnaces

Total Suspended Solids                    0               0
pH                                Within the range of 7.5 to 10.0
                                           at all times
                              1029

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                     Table XIII-1 (Continued)

   BCT EFFLUENT LIMITATIONS FOR THE SECONDARY  LEAD SUBCATEGORY


                     Casting Contact Cooling

                                   Maximum for      Maximum for
Pollutant or Pollutant Property    Any One Day    Monthly Average

                  Metric Units - mg/kkg of lead cast
           English Units - Ibs/billion Ibs of  lead cast

Total Suspended Solids                9,069.20        4,424.0
pH                                Within the range of 7.5 to 10.0
                                           at  all times
                               1030

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