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Table V-5
WATER USE AND DISCHARGE RATES FOR SOLVENT EXTRACTION
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507
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0
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228
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WATER USE AND DISCHARGE RATES FOR PRECIPITATION AND
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519
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WATER USE AND DISCHARGE RATES FOR METAL SALT DRYING
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519
507
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WATER USE AND DISCHARGE RATES FOR REDUCTION OF SALT
TO METAL
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Plant Code
519
513
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Percent
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NR
NR
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170,696
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243
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Table V-12
WATER USE AND DISCHARGE RATES FOR REDUCTION OF SALT
TO METAL WET AIR POLLUTION CONTROL
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Plant Code
513
519
Percent
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0
0
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2,168
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40,697
2,168
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047
046 VGA Blank
Ball Mill
and Sizing
Wastewater
Mixing HCL
Addition
Scrap
Cleaning
Degreasing
20 GPD
Noncontact
Cooling Water
Laboratory
Wastes
Centrifuge
1,380 GPD
048
Discharge
Figure V-l
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT A
264
-------
Reduced Co
Leaching Wastes
Sizing
RoCoclone
Scrubber
052
Mixing NaOH
Addition
Centrifuge
36,480 GPD
Condensate from
Drying Furnaces
Noncontact
Cooling Water
^OGPD
050
/o t
-------
Source Water
Digester
Scrubber and
Extraction
Raffinace
Gangue Slurry
Pond Overflow
Steam Eductor
of K2TaF7
Dryer, Reduction
Leaching
Scrubber
Liquors
Cb/Ta
Precipitation
Supernatant
Ammonia Stripper
Noncontact
Cooling Water
0.096 MGD
0.014 MGD
0.082 MGD'
0.02 MGD
116
117
HO VOA Blank
Mix Tanks
Lime Addition
0.26 MGD
Lagoons
Recycle to Processes
Using Water
0.11 MGD
Discharge
Figute V-3
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT B
266
-------
Vaste Solid Slurry
From Digestion
Waste Raffinate
From Solvent
Extraction
Spent Filtrate
From Salt
Precipitation
Floor Wash Water
NaOH
Mixing Tank
Vet Air Pollution
Control on Digestion,
Salt Precipitation,
and Calcining Oven
Noncontact Cooling
Water
Miscellaneous
Wastewater
Equalization Pond
Discharge
Figure V-4
SAMPLING SITES AT COLUMBIUM-TANTALUM PLANT C
267
-------
Cb Filtrate,
Cb Salt
Drying Scrubber
0.0353 MGD
MH3 Stripping
Lime
Addition
Extraction
Raffinate
.0134 MGD
Ta Filtrate
Ta Reduction
Leach Wastes
Foundry
Extraction Scrub-
ber, Wash Down,
Digester
Scrubber
0.0276 MGD
Other Metal
Refining
Mix Tanks
Lime Addition
i
Holding Tank
/\
022
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
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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
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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
-------
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
-------
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
-------
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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297
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302
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303
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304
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Figure VIII-13
COLUMBIUM-TANTALUM (SALT TO METAL)
COMBINATION 1, OPTION E
100,000
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CHEMICALS
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COLUMBIUM-TANTALUM (SALT TO METAL)
COMBINATION 1, OPTION F
305
-------
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
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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
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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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334
-------
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
-------
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
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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
-------
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
-------
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
-------
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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358
-------
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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360
-------
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
367
-------
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.
368
-------
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
-------
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
373
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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
374
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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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
(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
-------
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
-------
(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
-------
(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
-------
(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
-------
(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
-------
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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Classifier j-1
Photographic Film Scrap
i
Dust
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
(
Ch
as
<
__ 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
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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
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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
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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
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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
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0
0
0
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Normalized
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No Wastewater
Production
Normalized
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3,623.0
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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
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0
0
0
0
0
0
0
0
0
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Normalized
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680.0
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2,890.0
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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
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99+
99
100
68
Production
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39,021.1
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NR
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Normalized
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18.76
NR
0
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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
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0
0
0
0
0
0
0
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63.22
52.64
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15.81
9.85
8.96
2.19
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63.22
52.64
20.3
15.81
9.85
8.96
2.19
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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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SOURCE
WATER
TAP IN
LAB
VOA BLANK
METAL
DEPLETED
SOLUTION
SPENT
ELECTROLYTE
j
\ *
GPD
TANKS
WITH
PIG IRON
SETTLING
TANKS
NaOH
ADDITION
398 GPD
DISCHARGE
Figure V-l
SAMPLING SITES AT SECONDARY SILVER PLANT A
475
-------
SOURCE
TAP IN
LAB
042 VOA BLANK
SPENT
HYDROMETAL-
LUSGICAL
PLANT
LIQUORS
CONTACT
COOLING
WATER
3600 6PD
DISCHARGE
Figure V-2
SAMPLING SITES AT SECONDARY SILVER PLANT B
476
-------
EMULSION
RECOVERY
PROCESS
FILM
WASTE
SCRUBBER
SOLUTIONS
SLUDGE
SYSTEM
>
12 ]
•
-------
060 VOA BLANK
STEEL WOOL
SPENT
HYPO
SOLUTION
SETTLING
TANK
SAWDUST
FILTER
174.7 GPD
DISCHARGE
Figure V-4
SAMPLING SITES AT SECONDARY SILVER PLANT D
478
-------
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
-------
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
-------
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
-------
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
-------
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,
-------
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
-------
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
-------
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
-------
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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510
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511
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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
-------
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
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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
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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
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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
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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
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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.
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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
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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
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580
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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
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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
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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
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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.
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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
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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.
619
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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
620
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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
621
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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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EmXETS. CAKE. NODS. ETC
Figure III-l
SECONDARY COPPER PRODUCTION PROCESS
627
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CM
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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
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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
-------
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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PLANT A
668
-------
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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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