United States Effluent Guidelines Division EPA-440/l-84/Ol9-b
Environmental Protection WH-552 July 1984
Agency Washington, D.C. 20460
Water and Waste Management T'T'U I O4U I \J D I (J
>EPA Development Proposed
Document for
Effluent Limitations
Guidelines and
Standards for the
Nonferrous Metals
Point Source Category
Phase II
Supplemental Development
Document For:
Secondary Nickel
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DEVELOPMENT DOCUMENT
for
EFFLUENT LIMITATIONS GUIDELINES AND STANDARDS
for the
NONFERROUS METALS MANUFACTURING POINT SOURCE CATEGORY
PHASE II
Secondary Nickel Supplement
Jack E. Ravan
Assistant Administrator for Water
Edwin L. Johnson
Director
Office of Water Regulations and Standards
f-r ' U.S. Environmental Protection Agency
* Region V, Library
230 South D^j.uorn Street
Chicago, Illinois 60604
Jeffery D. Denit, Director
Effluent Guidelines Division
Ernst P. Hall, P.E., Chief
Metals and Machinery Branch
James R. Berlow, P.E.
Technical Project Officer
July 1984
U.S. Environmental Protection Agency
Office of Water
Office of Water Regulations and Standards
Effluent Guidelines Division
Washington, D.C. 20460
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U5
.
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SECONDARY NICKEL SUBCATEGORY
TABLE OF CONTENTS
Section Page
I SUMMARY AND CONCLUSIONS 1
II RECOMMENDATIONS 3
NSPS FOR THE SECONDARY NICKEL SUCBATEGORY. ... 3
PSES FOR THE SECONDARY NICKEL SUBCATEGORY. ... 4
PSNS FOR THE SECONDARY NICKEL SUBCATEGORY. ... 5
III INDUSTRY PROFILE 7
DESCRIPTION OF SECONDARY NICKEL PRODUCTION ... 7
RAW MATERIALS 7
SLAG RECLAMATION 7
ACID RECLAMATION 8
SCRAP RECLAMATION 8
PROCESS WASTEWATER SOURCES 8
OTHER WASTEWATER SOURCES 9
AGE, PRODUCTION, AND PROCESS PROFILE 9
IV SUBCATEGORIZATION 15
FACTORS CONSIDERED IN SUBCATEGORIZATION 15
FACTORS CONSIDERED IN SUBDIVIDING THE
SECONDARY NICKEL SUBCATEGORY 16
OTHER FACTORS 17
PRODUCTION NORMALIZING PARAMATERS 17
V WATER USE AND WASTEWATER CHARACTERISTICS .... 19
WASTEWATER FLOW RATES 20
WASTEWATER CHARACTERISTICS DATA 20
DATA COLLECTION PORTFOLIOS 20
FIELD SAMPLING DATA 21
WASTEWATER CHARACTERISTICS AND FLOWS BY
SUBDIVISION 22
SLAG RECLAIM TAILINGS 22
ACID RECLAIM LEACHING FILTRATE 22
ACID RECLAIM LEACHING BELT FILTER BACKWASH ... 23
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SECONDARY NICKEL SUBCATEGORY
TABLE OF CONTENTS (Continued)
Section
VI
VII
VIII
IX
X
Page
SELECTION OF POLLUTANTS . 37
CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
PARAMETERS 37
CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
PARAMETERS SELECTED 37
TOXIC POLLUTANTS 38
TOXIC POLLUTANTS NEVER DETECTED 38
TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR
ANALYTICAL QUANTIFICATION CONCENTRATION 41
TOXIC POLLUTANTS SELECTED FOR FURTHER
CONSIDERATION IN ESTABLISHING LIMITATIONS
AND STANDARDS 41
CONTROL AND TREATMENT TECHNOLOGIES 45
CURRENT CONTROL AND TREATMENT PRACTICES 45
SLAG RECLAIM TAILINGS 45
ACID RECLAIM LEACHING FILTRATE 46
ACID RECLAIM LEACHING BELT FILTER BACKWASH ... 46
CONTROL AND TREATMENT OPTIONS 46
OPTION A 46
OPTION C 47
COSTS, ENERGY, AND NONWATER QUALITY ASPECTS. . . 49
TREATMENT OPTIONS FOR EXISTING SOURCES 49
OPTION A 49
OPTION C 49
COST METHODOLOGY 49
NONWATER QUALITY ASPECTS 50
ENERGY REQUIREMENTS °. . 50
SOLID WASTE 51
AIR POLLUTION 52
BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
AVAILABLE 55
BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE 57
ii
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SECONDARY NICKEL SUBCATEGORY
TABLE OF CONTENTS (Continued)
Section
XI
XII
NEW SOURCE PERFORMANCE STANDARDS 59
TECHNICAL APPROACH TO NSPS 59
OPTION A 59
OPTION C 59
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES. . 61
POLLUTANT REMOVAL ESTIMATES 61
COMPLIANCE COSTS 62
NSPS OPTION SELECTION 62
WASTEWATER DISCHARGE RATES 63
SLAG RECLAIM TAILINGS 63
ACID RECLAIM LEACHING FILTRATE 63
ACID RECLAIM LEACHING BELT FILTER BACKWASH ... 63
REGULATED POLLUTANT PARAMETERS 64
NEW SOURCE PERFORMANCE STANDARDS 65
PRETREATMENT STANDARDS 71
TECHNICAL APPROACH TO PRETREATMENT 71
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES. . 72
PRETREATMENT STANDARDS FOR EXISTING AND NEW
SOURCES 72
OPTION A 72
OPTION C 73
PSES OPTION SELECTION 73
PSNS OPTION SELECTION 73
PRETREATMENT STANDARDS 73
XIII
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
79
iii
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IV
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SECONDARY NICKEL SUBCATEGORY
LIST OF TABLES
Number
III-1 INITIAL OPERATING YEAR SUMMARY OF PLANTS IN
THE SECONDARY NICKEL SUBCATEGORY BY
DISCHARGE TYPE 10
III-2 PRODUCTION RANGES FOR THE SECONDARY NICKEL
SUBCATEGORY 11
III-3 SUMMARY OF SECONDARY NICKEL SUBCATEGORY
PROCESSES AND ASSOCIATED WASTE STREAMS 12
V-1 WATER USE AND DISCHARGE RATES FOR
SLAG RECLAIM TAILINGS 24
V-2 WATER USE AND DISCHARGE RATES FOR
ACID RECLAIM LEACHING FILTRATE 25
V-3 WATER USE AND DISCHARGE RATES FOR ACID RECLAIM
LEACHING BELT FILTER BACKWASH 26
V-4 SECONDARY NICKEL SAMPLING DATA SLAG RECLAIM
TAILINGS POND INFLUENT RAW WASTEWATER
SAMPLING DATA 27
V-5 SECONDARY NICKEL SAMPLING DATA SLAG RECLAIM
TAILINGS POND EFFLUENT RAW WASTEWATER
SAMPLING DATA 29
V-6 SECONDARY NICKEL SAMPLING DATA ACID RECLAIM
LEACHING FILTRATE RAW WASTEWATER SAMPLING DATA . 31
V-7 SECONDARY NICKEL SAMPLING DATA ACID RECLAIM
LEACHING BELT FILTER BACKWASH RAW WASTEWATER
SAMPLING DATA 33
VI-1 FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
SECONDARY NICKEL SUBCATEGORY RAW WASTEWATER. . . 43
VI11-1 COST OF COMPLIANCE FOR THE SECONDARY NICKEL
SUBCATEGORY INDIRECT DISCHARGERS 53
XI-1 NSPS WASTEWATER DISCHARGE RATES FOR THE
SECONDARY NICKEL SUBCATEGORY 66
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SECONDARY NICKEL SUBCATEGORY
LIST OF TABLES (Continued)
Number Page
XI-2 NSPS FOR THE SECONDARY NICKEL SUBCATEGORY. ... 67
XII-1 POLLUTANT REMOVAL ESTIMATES FOR INDIRECT
DISCHARGERS IN THE SECONDARY NICKEL
SUBCATEGORY 75
XII-2 COST OF COMPLIANCE FOR THE SECONDARY NICKEL
SUBCATEGORY INDIRECT DISCHARGERS 76
XII-3 PSES AND PSNS WASTEWATER DISCHARGE RATES FOR
THE SECONDARY NICKEL SUBCATEGORY 77
XII-4 PSES AND PSNS FOR THE SECONDARY NICKEL
SUBCATEGORY 78
VI
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SECONDARY NICKEL SUBCATEGORY
LIST OF FIGURES
Number Page
III-1 SECONDARY NICKEL MANUFACTURING PROCESSES .... 13
III-2 GEOGRAPHIC LOCATIONS OF SECONDARY NICKEL
SUBCATEGORY PLANTS 14
V-1 SAMPLING SITES AT SECONDARY NICKEL PLANT A ... 35
XI-1 NSPS TREATMENT SCHEME FOR OPTION A 68
XI-2 NSPS TREATMENT SCHEME FOR OPTION C 69
XI-3 NSPS TREATMENT SELECTED FOR THE SECONDARY
NICKEL SUBCATEGORY 70
vii
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SECONDARY NICKEL SUBCATEGORY
SECTION I
SUMMARY AND CONCLUSIONS
Pursuant to Sections 301, 304, 306, 307, and 501 of the Clean
Water Act and the provisions of the Settlement Agreement in
Natural Resources Defense Council v. Train. 8 ERG 2120 (D.D.C.
1976) modified. 12 ERG 1833 (D.D.C. 1979), EPA has collected and
analyzed data for plants in the secondary nickel subcategory.
EPA has never proposed or promulgated effluent limitations or
standards for this subcategory. This document and the adminis-
trative record provide the technical basis for proposing pre-
treatment standards for existing indirect dischargers (PSES),
pretreatment standards for new indirect dischargers (PSNS), and
standards of performance for new source direct dischargers
(NSPS).
The secondary nickel subcategory consists of two plants. One of
the two plants discharges to a publicly-owned treatment works,
and one achieves zero discharge of process wastewater. There are
no plants discharging directly to rivers, streams, or lakes.
EPA first studied the secondary nickel subcategory to determine
whether differences in raw materials, final products, manufactur-
ing processes, equipment, age and size of plants; or water usage,
required the development of separate effluent limitations and
standards for different segments of the subcategory. This
involved a detailed analysis of wastewater discharge and treated
effluent characteristics, including (1) the sources and volume of
water used, the processes used, and the sources of pollutants and
wastewaters in the plant; and (2) the constituents of waste-
waters, including toxic pollutants. As a result, three subdivi-
sions have been identified for this subcategory that warrant
separate effluent limitations. These include:
• Slag reclaim tailings,
• Acid reclaim leaching filtrate, and
• Acid reclaim leaching belt filter backwash.
EPA also identified several distinct control and treatment tech-
nologies (both in-plant and end-of-pipe) applicable to the sec-
ondary nickel subcategory. The Agency analyzed both historical
and newly generated data on the performance of these technolo-
gies, including their nonwater quality environmental impacts and
air quality, solid waste generation, and energy requirements.
EPA also studied various flow reduction techniques reported in
the data collection portfolios (dcp) and plant visits.
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Engineering costs were prepared for each of the control and
treatment options considered for the subcategory. These costs
were then used by the Agency to estimate the impact of implement-
ing the various options on the subcategory. For each control and
treatment option that the Agency found to be most effective and
technically feasible in controlling the discharge of pollutants,
we estimated the number of potential closures, number of employ-
ees affected, and impact on price. These results are reported in
a separate document entitled "The Economic Impact Analysis of
Proposed Effluent Limitations Guidelines and Standards for the
Nonferrous Smelting and Refining Industry."
Because there are no direct dischargers in the secondary nickel
subcategory, EPA is not proposing BPT, BAT or BCT.
After examining the various treatment technologies, the Agency
selected PSES to consist of metals removal based on chemical
precipitation and sedimentation technology, with filtration added
as an effluent polishing step. However, filtration is not
required for slag reclaim tailings. Chemical precipitation and
sedimentation technology represents the best exisiting technology
in this subcategory. Filtration is transferred to this subcate-
gory because existing treatment is inadequate, and because fil-
tration is demonstrated at 25 facilities in nonferrous metals
manufacturing. To meet the pretreatment standards for existing
sources, the secondary nickel subcategory is estimated to incur a
capital cost of $287,000 and an annual cost of $120,000.
NSPS is equivalent to PSES technology. In selecting NSPS, EPA
recognizes that new plants have the opportunity to implement the
best and most efficient manufacturing processes and treatment
technology. Review of the industry indicates that no new
demonstrated technologies that improve on PSES technology exist.
As such, the technology basis of PSES has been determined as the
best demonstrated technology.
For PSNS, the Agency selected end-of-pipe treatment equivalent to
NSPS.
The best conventional technology (BCT) replaces BAT for the con-
trol of conventional pollutants. Although the methodology for
BCT has not yet been finalized, BCT is not proposed for this
subcategory because there are no direct dischargers.
The mass limitations and standards for NSPS, PSES, and PSNS are
presented in Section II.
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SECONDARY NICKEL SUBCATEGORY
SECTION II
RECOMMENDATIONS
EPA has divided the secondary nickel subcategory into three
subdivisions for the purpose of effluent limitations and
standards. These subdivisions are:
(a) Slag reclaim tailings,
(b) Acid reclaim leaching filtrate, and
(c) Acid reclaim leaching belt filter backwash.
BPT is not proposed because there are no direct dischargers.
BAT is not proposed because there are no direct dischargers.
NSPS are proposed based on the performance achievable by the
application of chemical precipitation and sedimentation
technology (lime and settle), along with end-of-pipe
filtration. Filtration is not required for the slag reclaim
tailings system. The following new source performance
standards are proposed:
SPS FOR THE SECONDARY NICKEL SUBCATEGORY
a) Slag Reclaim Tailings
Dllutant or Maximum for Maximum for
allutant Property Any One Day Monthly Average
g/kg (Ib/million Ibs) of slag reclaim nickel produced
iromium (total) 37.670 15.410
Dpper 168.700 85.600
ickel 164.400 108.700
Dtal suspended 3,510.000 1,669.000
solids
3 Within the range of 7.5 to 10.0
at all times
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NSPS FOR THE SECONDARY NICKEL SUBCATEGORY
(b) Acid Reclaim Leaching Filtrate
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
mg/kg (Ib/million Ibs) of acid reclaim nickel produced
Chromium (total) 1.848 0.749
Copper 6.394 3.047
Nickel 2.747 1.848
Total suspended 74.930 59.940
solids
pH Within the range of 7.5 to 10.0
at all times
NSPS FOR THE SECONDARY NICKEL SUBCATEGORY
(c) Acid Reclaim Leaching Belt Filter Backwash
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
mg/kg (Ib/million Ibs) of acid reclaim nickel produced
Chromium (total) 0.444 0.180
Copper ' 1.535 0.731
Nickel 0.660 0.444
Total suspended 17.990 14.390
solids
pH Within the range of 7.5 to 10.0
at all times
5. PSES are proposed based on the performance achievable by the
application of chemical precipitation and sedimentation
technology (lime and settle), along with end-of-pipe
filtration. Filtration is not required for the slag reclaim
tailings system. The following pretreatment standards for
existing sources are proposed:
PSES FOR THE SECONDARY NICKEL SUBCATEGORY
(a) Slag Reclaim Tailings
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
mg/kg (Ib/million Ibs) of slag reclaim nickel produced
Chromium (total) 37.670 15.410
Copper 162.700 85.600
Nickel 164.400 108.700
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'SES FOR THE SECONDARY NICKEL SUBCATEGORY
b) Acid Reclaim Leaching Filtrate
'ollutant or Maximum for Maximum for
'ollutant Property Any One Day Monthly Average
g/kg (Ib/million Ibs) of acid reclaim nickel produced
Ihromium (total) 1.848 0.749
!opper 6.394 3.047
ickel 2.747 1.848
'SES FOR THE SECONDARY NICKEL SUBCATEGORY
c) Acid Reclaim Leaching Belt Filter Backwash
ollutant or Maximum for Maximum for
ollutant Property Any One Day Monthly Average
g/kg (Ib/million Ibs) of acid reclaim nickel produced
hromium (total) 0.444 0.180
opper 1.535 0.731
ickel 0.660 0.444
PSNS are proposed based on the performance achievable by the
application of chemical precipitation and sedimentation
technology (lime and settle), along with end-of-pipe
filtration. Filtration is not required for the slag reclaim
tailings system. The following pretreatment standards for
new sources are proposed:
SNS FOR THE SECONDARY NICKEL SUBCATEGORY
a) Slag Reclaim Tailings
ollutant or Maximum for Maximum for
ollutant Property Any One Day Monthly Average
g/kg (Ib/million Ibs) of slag reclaim nickel produced
hromium (total) 37.670 15.410
opper 168.700 85.600
ickel 164.400 108.700
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PSNS FOR THE SECONDARY NICKEL SUBCATEGORY
(b) Acid Reclaim Leaching Filtrate
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
mg/kg (Ib/million Ibs) of acid reclaim nickel produced
Chromium (total) 1.848 0.749
Copper 6.394 3.047
Nickel 2.747 1.848
PSNS FOR THE SECONDARY NICKEL SUBCATEGORY
(c) Acid Reclaim Leaching Belt Filter Backwash
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
mg/kg (Ib/million Ibs) of acid reclaim nickel produced
Chromium (total) 0.444 0.180
Copper 1.535 0.731
Nickel 0.660 0.444
7. BCT is not proposed for this subcategory at this time,
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SECONDARY NICKEL SUBCATEGORY
SECTION III
INDUSTRY PROFILE
This section of the secondary nickel supplement describes the raw
materials and processes used in smelting and refining secondary
nickel and presents a profile of the secondary nickel plants
identified in this study. 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 NICKEL PRODUCTION
Secondary nickel production can be divided into three distinct
operations--slag reclamation, acid reclamation, and scrap recla-
mation. Slag reclamation is a wet mechanical granulation opera-
tion. Acid reclamation and scrap reclamation are hydrometallurg-
ical refining processes. One plant in the U.S. reclaims nickel
from slag and pickling acids, and a second plant reclaims nickel
from scrap. Secondary nickel production processes are presented
schematically in Figure III-1 and described below.
RAW MATERIALS
Secondary nickel is reclaimed from three raw materials: nickel
melt furnace slag, nickel carbonate produced from waste pickling
acids and wastewater treatment sludges from nickel forming oper-
ations, and solid nickel scrap from other manufacturing opera-
tions. Nickel alloy scrap generated at steel mills may also be
recycled within the mill; however, no refining of the nickel
scrap takes place prior to recycle and therefore, is not con-
sidered within this subcategory.
SLAG RECLAMATION
The objective of slag reclamation is to recover the nickel values
from the dross or slag produced in nickel melt furnaces. When
the nickel ingots are smelted in the presence of fluxing agents,
the oxidized metals and impurities rise to the surface of the
liquid metal and are removed from the furnace. This slag is
approximately 10 percent metallics.
The dross or slag is first air cooled and solidified, and then
mechanically granulated with a jaw crusher and a wet rod mill.
It is then fed onto a wet mineral jig, which uses specific grav-
ity differences to recover the nickel concentrate product. The
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mineral jig is a shaking table. Large volumes of water wash over
the crushed slag on the table, carrying away the lighter (less
dense) non-metallics. The denser, nickel-containing solids are
the product. A large volume of tailings wastewater is produced.
The nickel product is returned to the melt furnace and the
wastewater is discharged.
ACID RECLAMATION
In the acid reclamation process, spent pickling acids and waste-
water treatment sludges from nickel forming operations are intro-
duced into a vessel with soda ash (Na2C03) which precipitates
the nickel as nickel carbonate. The impure nickel carbonate,
which is separated from the liquid phase by filtration, is the
raw material for the acid reclaim process.
Impure nickel carbonate is slurried with water to produce a homo-
geneous solution, and then roasted in an open hearth furnace to
produce nickel oxide. The nickel oxide produced by roasting is
then leached with water to remove impurities, and filtered. The
leaching filtrate may be discharged as a waste stream. After
filtering, the filter is backwashed and the backwash water may
also be discharged as a waste stream. The nickel oxide product
is approximately 35 percent nickel, and is returned to the nickel
melting furnaces.
SCRAP RECLAMATION
Scrap resulting from the manufacture of nickel products may be
recycled to recover the nickel values. The scrap is fed into a
digestion unit with nitric acid and water. The acid removes
silver and other impurities, and a 95 percent nickel product is
either sold or returned to the manufacturing facility. The
resultant solution containing significant silver values is routed
to a silver recovery process and is covered by the regulations
for secondary silver refining in nonferrous phase II. There are
no waste streams associated with nickel scrap reclamation.
PROCESS WASTEWATER SOURCES
Although a variety of processes are involved in secondary nickel
production, the significant wastewater sources that are asso-
ciated with the secondary nickel subcategory can be subdivided as
follows:
1. Slag reclaim tailings,
2. Acid reclaim leaching filtrate, and
3. Acid reclaim leaching belt filter backwash.
8
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OTHER WASTEWATER SOURCES
There are other waste streams associated with the secondary
nickel subcategory. These waste streams include but are not
limited to:
1. Stormwater runoff,
2. Maintenance and cleanup water, and
3. Noncontact cooling water.
These waste streams are not considered as a part of this rulemak-
ing. EPA believes that the flows and pollutant loadings associ-
ated with these waste streams are insignificant relative to waste
streams selected, or are best handled by the appropriate permit
authority on a case-by-case basis under authority of Section 403
of the Clean Water Act.
AGE, PRODUCTION, AND PROCESS PROFILE
Figure III-2 shows the locations of the two secondary nickel
plants operating in the United States. Both are located east of
the Mississippi River, near the industrial centers of western
Pennsylvania.
Table III-1 illustrates the relative age and discharge status of
the secondary nickel plants in the United States. One plant was
built in 1923, and the other was built in 1976.
From Table III-2, it can be seen that of the two facilities which
reclaim nickel, one plant reclaims between 500 and 1,000 tons per
year, and the other less than 50 tons per year.
Table III-3 provides a summary of the number of plants generating
wastewater for the waste streams associated with the various pro-
cesses and the number of plants with the process.
9
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Table III-1
INITIAL OPERATING YEAR SUMMARY OF PLANTS IN THE
SECONDARY NICKEL SUBCATEGORY BY DISCHARGE TYPE
Initial Operating Year
(Plant Age in Years)
Type of
Plant
Direct
Indirect
Zero
Total
1982-
1966
(0-15)
0
0
1
1
1965-
1946
(15-35)
0
0
0
0
1945-
1926
(35-55)
0
0
0
0
1925-
1906
(55-75)
0
1
0
1
Total
0
. 1
1
2
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Table III-2
PRODUCTION RANGES FOR THE SECONDARY NICKEL SUBCATEGORY
Production Ranges for 1982
(Tons/Year)a Number of Plants
0-50 1
50 - 100 0
500 - 1 ,000 1
Total 2
Based on production of reclaimed nickel
11
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i) Slag Reclaim
Slag or Dross
from Nickel
Smelting
Furnace
Tailings
to Pond
Nickel Concentrate
' Product
ii) Acid Reclaim
Spent Acids
Waste Treatment
Sludge
Pickling Wastes
Evaporate
pH
Adjustment
Nickel .
Carbonate j
Filter
t
H20
Open
Hearth
Furnace
NickeJ
Oxide
L .
Leaching
Soda Ash
Nickel Forming
Wastewater
Leaching
Filtrate
Solids
Process
Belt
Filter
Backwash
iii) Scrap Reclaim
Manufacturing _^
Scrap
Digestion
Separation
HNO.. H_0
Nickel Product Sold
•or Recycled to Process
Silver-Rich Stream
to Silver Recovery
Figure III-1
SECONDARY NICKEL MANUFACTURING PROCESSES
13
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SECONDARY NICKEL SUBCATEGORY
SECTION IV
SUBCATEGORIZATION
As discussed in Section IV of the General Development Document,
the nonferrous metals category has been subcategorized to take
into account pertinent industry characteristics, manufacturing
process variations, and a number of other factors which affect
the ability of the facilities to achieve effluent limitations.
This section summarizes the factors considered during the desig-
nation of the secondary nickel subcategory and its related subdi-
visions. Production normalizing parameters for each subdivision
will also be discussed.
FACTORS CONSIDERED IN SUBCATEGORIZATION
The following factors were evaluated for use in subcategorizing
the nonferrous metals manufacturing category:
1. Metal products, co-products, and by-products;
2. Raw materials;
3. Manufacturing processes;
4. Product form;
5. Plant location;
6. Plant age;
7. Plant size;
8. Air pollution control methods;
9. Meteorological conditions;
10. Treatment costs;
11. Nonwater quality aspects;
12. Number of employees;
13. Total energy requirements; and
14. Unique plant characteristics.
Evaluation of all factors that could warrant subcategorization
resulted in the designation of the secondary nickel 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 prod-
uct, manufacturing process, and raw materials as the principal
factors used for subcategorization is discussed. On this basis,
the nonferrous metals manufacturing category (phase II) was
divided into 21 subcategories, one of them being secondary
nickel.
15
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FACTORS CONSIDERED IN SUBDIVIDING THE SECONDARY NICKEL
SUBCATEGQRY
The factors listed previously were each evaluated when consider-
ing subdivision of the secondary nickel subcategory. In the dis-
cussion that follows, the factors will be described as they per-
tain to this particular subcategory.
The rationale for considering further subdivision of the second-
ary nickel 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 nickel is still considered a single subcategory,
a more thorough examination of the production processes has
illustrated the need for limitations and standards based on a
specific set of waste streams. Limitations will be based on
specific flow allowances for the following subdivisions:
1. Slag reclaim tailings,
2. Acid reclaim leaching filtrate, and
3. Acid reclaim leaching belt filter backwash.
These subdivisions follow directly from differences between the
processing steps of secondary nickel production. Slag reclaim
and acid reclaim both have various steps which generate
wastewater.
Slag reclamation establishes the need for the first subdivision-
slag reclaim tailings. After crushing and milling the nickel-
rich slag, a nickel concentrate is separated from impurities with
a wet mineral jig. This produces a tailings waste stream which
is discharged.
Acid reclamation establishes the need for the second and third
subdivisions—acid reclaim leaching filtrate, and acid reclaim
leaching belt filter backwash. Spent pickling acids and waste-
water treatment sludges are added to a tank containing soda ash
in order to precipitate nickel as nickel carbonate. After fil-
tration, the precipitate is slurried with water and roasted in an
open hearth furnace in order to oxidize the nickel. The nickel
oxide is leached with water to remove impurities and then fil-
tered on a belt filter. The acid reclaim leaching filtrate is
discharged as a waste stream. The belt filter is backwashed with
water, and the backwash water is also discharged as a waste
stream.
16
-------
OTHER FACTORS
The other factors considered .in this evaluation either support
the establishment of the three subdivisions or were shown to be
inappropriate bases for subdivision. Air pollution control
methods, treatment costs, and total energy requirements are func-
tions of the selected subcategorization factors—metal product,
raw materials, and production processes. As discussed in Section
IV of the General Development Document, certain other factors,
such as plant age, plant size, and the number of employees, were
also evaluated and determined to be inappropriate for use as
bases for subdivision of the nonferrous metals subcategory.
PRODUCTION NORMALIZING PARAMETERS
As discussed previously, the effluent limitations and standards
developed in this document establish mass limitations on the dis-
charge of specific pollutant parameters. To allow these regula-
tions to be applied to plants with various production capacities,
the mass of pollutant discharged must be related to a unit of
production. This factor is known as the production normalizing
parameter (PNP). The PNPs for the three subdivisions are as
follows:
Subdivision PNP
1. Slag reclaim tailings slag reclaim nickel
produced
2. Acid reclaim leaching filtrate acid reclaim nickel
produced
3. Acid reclaim leaching belt filter acid reclaim nickel
backwash produced
17
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SECONDARY NICKEL SUBCATEGORY
SECTION V
WATER USE AND WASTEWATER CHARACTERISTICS
This section describes the characteristics of the wastewaters
associated with the secondary nickel subcategory. Water use and
discharge rates are explained and then summarized in tables at
the end of this section. Data used to characterize the waste-
waters are presented. Finally, the specific source, water use
and discharge flows, and wastewater characteristics for each
separate wastewater source are discussed.
Section V of the General Development Document contains a detailed
description of the data sources and methods of analysis used to
characterize wastewater from the nonferrous metals manufacturing
category. To summarize this information briefly, two principal
data sources were used: data collection portfolios and field
sampling results. Data collection portfolios contain information
regarding wastewater flows and production levels.
In order to quantify the pollutant discharge from secondary
nickel plants, a field sampling program was conducted. A com-
plete list of the pollutants considered and a summary of the
techniques used in the sampling and laboratory analyses are
included in Section V of the General Development Document. Sam-
ples were analyzed for 124 of the 126 toxic pollutants and other
pollutants deemed appropriate. (Because the analytical standard
for TCDD was judged to be too hazardous to be made generally
available, samples were never analyzed for this pollutant. Sam-
ples were also not analyzed for asbestos. There is no reason to
expect that TCDD or asbestos would be present in nonferrous
metals manufacturing wastewater.) One plant was selected for
sampling in the secondary nickel subcategory. 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
nickel subcategory has been categorized into three subdivisions,
so that the proposed regulation contains mass discharge limita-
tions and standards for three unit processes discharging process
wastewater. Differences in the wastewater characteristics asso-
ciated with these subdivisions are to be expected. For this
reason, wastewater streams corresponding to each subdivision are
addressed separately in the discussions that follow. These
wastewater sources are:
19
-------
1. Slag reclaim tailings,
2. Acid reclaim leaching filtrate, and
3. Acid reclaim leaching belt filter backwash.
WASTEWATER FLOW RATES
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 required for a given process per mass of
nickel 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 waste-
water discharged from a given process to further treatment, dis-
posal, or discharge per mass of nickel produced. Differences
between the water use and wastewater flows associated with a
given stream result from recycle, evaporation, and carryover on
the product. The production values used in calculation corre-
spond to the production normalizing parameter, PNP, assigned to
each stream, as outlined in Section IV. As an example, slag
reclaim tailings wastewater flow is related to slag reclaim
nickel production. As such, the discharge rate is expressed in
liters of tailings wastewater discharged per metric ton of slag
reclaim nickel production.
The production normalized flows were compiled and statistically
analyzed by stream type. These production normalized water use
and discharge flows are presented by subdivision in Tables V-1
through V-3 at the end of this section. Where appropriate, an
attempt was made to identify factors that could account for vari-
ations in water use. This information is summarized in this sec-
tion. A similar analysis of factors affecting the wastewater
values is presented in Sections XI and XII where representative
NSPS and pretreatment discharge flows are. selected for use in
calculating the effluent limitations and standards.
WASTEWATER CHARACTERISTICS DATA
Data used to characterize the various wastewaters associated with
~econdary nickel production come from two sources—data collec-
t-ion portfolios and analytical data from field sampling trips.
DATA COLLECTION PORTFOLIOS
In the data collection portfolios, plants were asked to indicate
whether or not any of the toxic pollutants were present in their
effluent. The one discharging plant indicated that most toxic
20
-------
organic pollutants were believed to be absent from their efflu-
ent. The plant indicated that a few of the toxic organic pollu-
tants are believed to be present in its effluent. The plant
stated that some of the toxic metals were known to be present in
their effluent. The responses for the toxic metals are summa-
rized below.
Pollutant Known Present Believed Present
Antimony 0 0
Arsenic 0 0
Beryllium 0 0
Cadmium 0 0
Chromium 1 1
Copper 1 1
Lead 0 0
Mercury 0 0
Nickel 1 1
Selenium 0 0
Silver 0 0
Thallium 0 0
Zinc 1 1
FIELD SAMPLING DATA
In order to quantify the concentrations of pollutants present in
wastewater from secondary nickel plants, wastewater samples were
collected at one plant. A diagram indicating the sampling sites
and contributing production processes is shown in Figure V-1 (at
the end of this section.)
The sampling data for the secondary nickel subcategory are pre-
sented in Tables V-4 through V-7 (at the end of this section).
The stream codes displayed in Tables V-4 through V-7 may be used
to identify the location of each of the samples on process flow
diagrams in Figure V-1. Where no data are listed for a specific
day of sampling, the wastewater samples for the stream were not
collected.
The detection limits shown on the data tables are not the same in
all cases as the published detection limits for these pollutants
by the same analytical methods. The detection limits used were
reported with the analytical data and hence are the appropriate
limits to apply to the data. Detection limit variation can occur
as a result of a number of laboratory-specific, equipment-speci-
fic, and daily operator-specific factors. These factors can
include day-to-day differences in machine calibration, variation
in stock solutions, and variation in operators.
21
-------
The statistical analysis of data includes some samples measured
at concentrations considered not quantifiable. Toxic metal and
conventional and nonconventional pollutant values reported as
less than a certain value were considered as not quantifiable and
a value of zero is used in the calculation of the average.
Appropriate source water concentrations are presented with the
summaries of the sampling data.
The method by which each sample was collected is indicated by
number, as follows:
1 - One-time grab
2 - Manual composite during intermittent process operation
3 - 8-hour manual composite
4 - 8-hour automatic composite
5 - 24-hour manual composite
6-24 hour automatic composite
WASTEWATER CHARACTERISTICS AND FLOWS BY SUBDIVISION
Since secondary nickel production involves three principal
sources of wastewater and each has potentially different charac-
teristics and flows, the wastewater characteristics and discharge
rates corresponding to each subdivision will be described sepa-
rately. A brief description of why the associated production
processes generate a wastewater and explanations for variations
of water use within each subdivision will also be discussed.
SLAG RECLAIM TAILINGS
Nickel is recovered from dross or slag generated in nickel smelt-
ing furnaces by a wet granulation operation. . After recovering
the nickel values from the granulated slag, the wet residue is
discharged to a tailings pond and the overflow from the tailings
pond is discharged as a waste stream. One plant reported
generating this waste stream, and its water use and discharge
rates are presented in Table V-1.
Sampling data for slag reclaim tailings is presented in Table
V-4. This waste stream is characterized by the presence of
treatable concentrations of arsenic, chromium, copper, nickel,
suspended solids, and pH. Sampling data for tailings pond efflu-
ent is presented in Table V-5.
ACID RECLAIM LEACHING FILTRATE
After nickel is precipitated from waste pickling acids with
sodium carbonate and roasted to produce nickel oxide, the nickel
oxide is leached with water to remove impurities. The nickel
oxide is recovered on a belt filter and the leaching filtrate is
22
-------
discarded. One plant reported generating this waste stream, and
its water use and discharge rates are presented in Table V-2.
Sampling data for acid reclaim leaching belt filtrate is pre-
sented in Table V-6. This waste stream is characterized by the
presence of treatable concentrations of chromium, copper, nickel,
and suspended solids.
ACID RECLAIM LEACHING BELT FILTER BACKWASH
In the acid reclaim process, after the leached nickel oxide is
scraped from the belt filter, the filter is backwashed with water
and the backwash water may be discharged. One plant reported
generating this waste stream, and its water use and discharge
rates are presented in Table V-3.
Sampling data for acid reclaim leaching belt filter backwash is
presented in Table V-7. This waste stream is characterized by
the presence of treatable concentrations of chromium, copper,
nickel, and suspended solids.
23
-------
Table V-1
WATER USE AND DISCHARGE RATES FOR SLAG RECLAIM TAILINGS
(1/kkg of slag reclaim nickel produced)
Production Production
Plant Percent Recycle Normalized Normalized
Code or Reuse Water Use Flow Discharge Flow
1169 0 85,600 85,600
24
-------
Table V-2
WATER USE AND DISCHARGE RATES FOR
ACID RECLAIM LEACHING FILTRATE
(1/kkg of acid reclaim nickel produced)
Production Production
Plant Percent Recycle Normalized Normalized
Code or Reuse Water Use Flow Discharge Flow
1169 0 5,000 5,000
25
-------
Table V-3
WATER USE AND DISCHARGE RATES FOR
ACID RECLAIM LEACHING BELT FILTER BACKWASH
(1/kkg of acid reclaim nickel produced)
Production Production
Plant Percent Recycle Normalized Normalized
Code or Reuse Water Use Flow Discharge Flow
1169 0 1,200 1,200
26
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SAMPLING SITES AT SECONDARY NICKEL PLANT A
35
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36
-------
SECONDARY NICKEL SUBCATEGORY
SECTION VI
SELECTION OF POLLUTANTS
Section V of this supplement presented data from secondary nickel
plant sampling visits and subsequent chemical analyses. This
section examines those data and discusses the selection or exclu-
sion of toxic pollutants for potential limitation. Conventional
and nonconventional pollutants are selected or excluded for
regulation in this section.
Each toxic pollutant selected for potential limitation is dis-
cussed in Section VI of the General Development Document. That
discussion provides information about the nature of the pollutant
(i.e., whether it is a naturally occurring substance, processed
metal, or a manufactured compound); general physical properties
and the form of the pollutant; toxic effects of the pollutants in
humans and other animals; and behavior of the pollutant in POTW
at t" e concentrations expected in industrial discharges.
The discussion that follows describes the analysis that was per-
formed to select or exclude toxic pollutants for further con-
sideration for limitations and standards. The data from three
wastewater samples collected at one nickel plant were considered
in this analysis. All samples are raw wastewater samples col-
lected on one day at one of the plants. Pollutants will be
selected for further consideration if they are present in concen-
trations treatable by the technologies considered in this analy-
sis. In Sections IX through XII, a final selection of the pollu-
tants to be limited will be made, based on relative factors.
CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS
This study examined samples from secondary nickel plants for
three conventional pollutant parameters (oil and grease, total
suspended solids, and pH) and one nonconventional pollutant para-
meter (ammonia).
CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS SELECTED
The conventional and nonconventional pollutants or pollutant
parameters selected for limitation in this subcategory are:
total suspended solids (TSS)
pH
37
-------
Total suspended solids (TSS) concentrations in the three samples
ranged from 350 mg/1 to 16,000 mg/1. All of the observed concen-
trations are above the 2.6 mg/1 concentration considered achiev-
able by identified treatment technology. Furthermore, most of
the technologies used to remove toxic metals do so by converting
these metals to precipitates. A limitation on total suspended
solids ensures that sedimentation to remove precipitated toxic
metals is effectively operating. For these reasons, total sus-
pended solids is a pollutant parameter selected for limitation in
this subcategory.
The pH values observed ranged from 6.6 to 11.4. Effective
removal of toxic metals by precipitation requires careful control
of pH. Therefore, pH is selected for limitation in this subcate-
gory.
Both oil and grease and ammonia are not selected for limitation
in this subcategory. Oil and grease was measured above its quan-
tifiable concentration (5 mg/1) in all three samples, however it
was not measured above its treatable concentration in any of the
samples (10 mg/1). Therefore, oil and grease is not selected for
limitation. Although ammonia was not analyzed for in any of the
samples, it is not expected to be present in the wastewater based
on the raw materials and production processes used. Therefore,
ammonia is not selected for limitation in this subcategory.
TOXIC POLLUTANTS
The frequency of occurrence of the toxic pollutants in the waste-
water samples considered in this analysis 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 sampling data from streams 986, 004, and 005.
Stream 987 was sampled after settling and was not used in the
frequency count.
TOXIC POLLUTANTS NEVER DETECTED
The toxic pollutants listed below were not detected in any raw
wastewater samples from this subcategory; therefore, they are not
selected for consideration in establishing limitations:
1. acenaphthene*
2. acrolein*
3. acrylonitrile*
4. benzene*
5. benzidine*
6. carbon tetrachloride (tetrachloromethane)*
7. chlorobenzene*
8. 1 ,2,4-trichlorobenzene*
38
-------
9. hexachlorobenzene*
10. 1,2-dichloroethane*
11. 1,1,1-trichloroethane*
12. hexachloroethane*
13. 1,1-dichloroethane*
14. 1 ,1,2-trichloroethane*
15. 1,1,2,2-tetrachloroethane*
16. chloroethane*
17. bis (chloromethyl) ether (deleted)*
18. bis (2-chloroethyl) ether*
19. 2-chloroethyl vinyl ether (mixed)*
20. 2-chloronaphthalene*
21. 2,4,6-trichlorophenol*
22. para-chloro meta-cresol*
23. chloroform (trichloromethane)*
24. 2-chlorophenol*
25. 1,2-dichlorobenzene*
26. 1 ,3-dichlorobenzene*
27. 1,4-dichlorobenzene*
28. 3,3-dichlorobenzidine*
29. 1,1-dichloroethylene*
30. 1,2-trans-dichloroethylene*
31. 2,4-dichlorophenol*
32. 1 ,2-dichloropropane*
33. 1,3-dichloropropylene (1,3-dichloropropene)*
34. 2,4-dimethylphenol*
35. 2,4-dinitrotoluene*
36. 2,6-dinitrotoluene*
37. 1,2-diphenylhydrazine*
38. ethylbenzene*
39. fluoranthene*
40. 4-chlorophenyl phenyl ether*
41. 4-bromophenyl phenyl ether*
42. bis (2-chloroisopropyl) ether*
43. bis (2-chloroethoxy) methane*
44. methylene chloride (dichloromethane)*
45. methyl chloride (chloromethane)*
46. methyl bromide (bromomethane)*
47. b'romoform (tribromome1 thane)*
48. dichlorobromomethane*
49. trichlorofluoromethane (deleted)*
50. dichlorodifluoromethane (deleted)*
51. chlorodibromomethane*
52. hexachlorobutadiene*
53. hexachlorocyclopentadiene*
54. isophorone*
55. naphthalene*
56. nitrobenzene*
57. 2-nitrophenol*
58. 4-nitrophenol*
39
-------
59. 2,4-dinitrophenol*
60. 4,5-dinitro-o-cresol*
61. N-nitrosodimethylamine*
62. N-nitrosodiphenylamine*
63. N-nitrosodi-n-propylamine*
64. pentachlorophenol*
65. phenol*
66. bis (2-ethylhexyl) phthalate*
67. butyl benzyl phthalate*
68. di-n-butyl phthalate*
69. di-n-octyl phthalate*
70. diethyl phthalate*
71. dimethyl phthalate*
72. benzo (a) anthracene (1,2-benzanthracene)*
73. benzo (a) pyrene (3,4-benzopyrene)*
74. 3,4-benzofluoranthene*
75. benzo (k) fluoranthene*
76. chrysene*
77. acenaphthylene*
78. anthracene*
79. benzo (ghi) perylene (1,12-benzoperylene)*
80. fluorene*
81. phenanthrene*
82. dibenzo (a,h) anthracene (1,2,5,6-dibenzanthracene)*
83. ideno (1,2,3-cd) pyrene (2,3,-o-phenylenepyrene)*
84. pyrene*
85. tetrachloroethylene*
86. toluene*
87. trichloroethylene*
88. vinyl chloride (chloroethylene)*
89. aldrin*
90. dieldrin*
91. chlordane (technical mixture and metabolites)*
92. 4,4'-DDT*
93. 4, 4'-DDE (p.p'DDX)*
94. 4,4'-DDD (p.p'TDE)*
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 (lindane)*
105. Delta-BHC*
106. PCB-1242 (Arochlor 1242)*
107. PCB-1254 (Arochlor 1254)*
108. PCB-1221 (Arochlor 1221)*
40
-------
109. PCB-1232 (Arochlor 1232)*
110. PCB-1248 (Arochlor 1248)*
111. PCB-1260 (Arochlor 1260)*
112. PCB-1016 (Arochlor 1016)*
113. toxaphene*
116. asbestos
129. 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD)
*We did not analyze for these pollutants in samples of raw
wastewater from this subcategory. These pollutants are not
believed to be present based on the Agency's best engineering
judgement which includes consideration of raw materials and
process operations.
TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION CONCENTRATION
The toxic pollutants listed below were never found above their
analytical quantification concentration in any wastewater samples
from this subcategory; therefore, they are not selected for con-
sideration in establishing effluent limitations and standards.
114. antimony
117. beryllium
118. cadmium
121. cyanide
122. lead
123. mercury
125. selenium
126. silver
127. thallium
TOXIC POLLUTANTS SELECTED FOR FURTHER CONSIDERATION IN ESTABLISH-
ING LIMITATIONS AND STANDARDS
The toxic pollutants listed below are selected for further con-
sideration in establishing limitations and standards for this
subcategory. The toxic pollutants selected are each discussed
following the list.
115. arsenic
119. chromium
120. copper
124. nickel
128. zinc
Arsenic was detected above its treatable concentration (0.34
mg/1) in one of three samples. The quantifiable concentrations
ranged from 0.013 mg/1 to 0.93 mg/1. Since arsenic was present
-------
in concentrations exceeding the concentration achievable by iden-
tified treatment technology, it is selected for consideration for
limitation.
Chromium was detected above its treatable concentration (0.07
mg/1) in three of three samples. The quantifiable concentrations
ranged from 0.88 mg/1 to 5.35 mg/1. Since chromium was present
in concentrations exceeding the concentration achievable by iden-
tified treatment technology, it is selected for consideration for
limitation.
Copper was detected above its treatable concentration (0.39 mg/1)
in three of three samples. The quantifiable concentrations
ranged from 0.59 mg/1 to 60 mg/1. Since copper was present in
concentrations exceeding the concentration achievable by identi-
fied treatment technology, it is selected for consideration for
limitation.
Nickel was detected above its treatable concentration (0.22 mg/1)
in three of three samples. The quantifiable concentrations
ranged from 7.5 mg/1 to 96 mg/1. Since nickel was present in
concentrations exceeding the concentration achievable by identi-
fied treatment technology, it is selected for consideration for
limitation.
Zinc was detected above its treatable concentration (0.23 mg/1)
in one of three samples. The quantifiable concentrations ranged
from 0.12 mg/1 to 0.26 mg/1. Since zinc was present in concen-
trations exceeding the concentration achievable by identified
treatment technology, it is selected for consideration for
limitation.
42
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SECONDARY NICKEL SUBCATEGORY
SECTION VII
CONTROL AND TREATMENT TECHNOLOGIES
The preceding sections of this supplement discussed the sources,
flows, and characteristics of the wastewaters from secondary
nickel plants. This section summarizes the description of these
wastewaters and indicates the treatment technologies which are
currently practiced in the secondary nickel subcategory for each
waste stream. Secondly, this section presents the control and
treatment technology options which were examined by the Agency
for possible application to the secondary nickel subcategory.
CURRENT CONTROL AND TREATMENT PRACTICES
Control and treatment technologies are discussed in general in
Section VII of the General Development Document. The basic prin-
ciples of these technologies and the applicability to wastewater
similar to that found in this subcategory are presented there.
This section presents a summary of the control and treatment
technologies that are currently being applied to each of the
sources generating wastewater in this subcategory. As discussed
in Section V, wastewater associated with the secondary nickel
subcategory is characterized by the presence of the toxic metal
pollutants and suspended solids. This analysis is supported by
the raw (untreated) wastewater data presented for specific
sources as well as combined waste streams in Section V. Gener-
ally, these pollutants are present in each of the waste streams
at concentrations above treatability, and these waste streams are
commonly combined for treatment. Construction of one wastewater
treatment system for combined treatment allows plants to take
advantage of economic scale and in some instances to combine
streams of different alkalinity to reduce treatment chemical
requirements. The one discharging plant in this subcategory
currently has a combined wastewater treatment system treating
nickel forming and acid reclaim wastewater, consisting of lime
precipitation and sedimentation. Two options have been selected
for consideration for NSPS and pretreatment based on combined
treatment of these compatible waste streams.
SLAG RECLAIM TAILINGS
Slag or dross from a nickel smelting furnace may be reclaimed for
its nickel values with a wet granulation type of operation. The
tailings generated by this operation are discharged to a tailings
pond where solids are settled. The tailings pond is allowed to
overflow and be discharged to a POTW. It is a primary settling
45
-------
unit, and no additional treatment is performed on this waste-
water. One plant has this waste stream and treatment. The raw
waste is characterized by toxic metals and suspended solids.
ACID RECIAIM LEACHING FILTRATE
After the acid reclaim nickel is precipitated with sodium car-
bonate and roasted to produce nickel oxide, it is leached with
water to remove impurities. The nickel oxide is recovered on a
belt filter. One plant discharges leaching filtrate without
treatment to a POTW.
ACID RECLAIM LEACHING BELT FILTER BACKWASH
In the acid reclaim process, after the leached nickel oxide is
scraped off the belt filter, the filter is backwashed with water.
This cleans the filter. Backwash water is treated as a combined
waste stream along with nickel forming wastewaters in a lime pre-
cipitation and sedimentation system prior to discharge.
Recycle is not practiced on these three waste streams and all are
indirectly discharged. All have toxic metals and suspended
solids above treatable concentrations.
CONTROL AND TREATMENT OPTIONS
The Agency examined two control and treatment technology
options that are applicable to the secondary nickel subcategory.
The options selected for evaluation represent a combination of
preliminary treatment technologies applicable to individual waste
streams and end-of-pipe treatment technologies.
OPTION A
Option A for the secondary nickel subcategory requires control
and treatment technologies to reduce the discharge of wastewater
pollutant mass.
The Option A treatment scheme consists of chemical precipitation
and sedimentation technology. Specifically, lime or some other
chemical is used to precipitate toxic metal ions as metal hydrox-
ides. The metal hydroxides and suspended solids settle out and
the sludge is collected. Vacuum filtration is used to dewater
sludge.
Slag reclaim and acid reclaim wastewaters are treated separately
because of economic considerations.
46
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OPTION C
Option C for the secondary nickel subcategory consists of all
control and treatment requirements of Option A (chemical precipi-
tation and sedimentation, separate treatment of slag and acid
reclaim wastewater) plus multimedia filtration technology added
at the end of the Option A treatment scheme. Multimedia filtra-
tion is used to remove suspended solids, including precipitates
of metals, beyond the concentration attainable by gravity sedi-
mentation. The filter suggested is of the gravity, mixed-media
type, although other forms of filters, such as rapid sand filters
or pressure filters would perform satisfactorily. The addition
of filters also provides consistent removal during periods of
time in which there are rapid increases in flows or loadings of
pollutants to the treatment system.
47
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48
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SECONDARY NICKEL SUBCATEGORY
SECTION VIII
COSTS, ENERGY, AND NONWATER QUALITY ASPECTS
This section presents a summary of compliance costs for the
secondary nickel subcategory and a description of the treatment
options and subcategory-specific assumptions used to develop
these estimates. Together with the estimated pollutant reduction
performance presented in Sections XI and XII of this supplement,
these cost estimates provide a basis for evaluating each regula-
tory option. These cost estimates are also used in determining
the probable economic impact of regulation on the subcategory at
different pollutant discharge levels. In addition, this section
addresses nonwater quality environmental impacts of wastewater
treatment and control alternatives, including air pollution,
solid wastes, and energy requirements, which are specific to the
secondary nickel subcategory.
TREATMENT OPTIONS FOR EXISTING SOURCES
As discussed in Section VII, two treatment options have been
developed for existing secondary nickel sources. The treatment
schemes for each option are summarized below and schematically
presented in Figures XI-1 and XI-2.
OPTION A
Option A consists of chemical precipitation and sedimentation
end-of-pipe technology. Slag reclaim tailings is treated sepa-
rately from acid reclaim wastewater.
OPTION C
Option C consists of Option A (chemical precipitation and sedi-
mentation, and separate^ treatment of slag and acid reclaim waste-
water) with the addition of multime'dia filtration to the end of
the Option A treatment scheme.
COST METHODOLOGY
A detailed discussion of the methodology used to develop the com-
pliance costs is presented in Section VIII of the General Devel-
opment Document. Plaut-by-plant compliance costs have been
estimated for the nonferrous metals manufacturing category and
are presented in the administrative record supporting this regu-
lation. The costs developed for the proposed regulation are
presented in Table VIII-1 for the one indirect discharger in the
secondary nickel subcategory.
49
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Each of the general assumptions used to develop compliance costs
is presented in Section VIII of the General Development Document.
Each subcategory contains a unique set of waste streams requiring
certain subcategory-specific assumptions to develop compliance
costs. The major assumptions relevant to cost estimates for the
secondary nickel subcategory are discussed briefly below.
(1) There is only one discharging plant in this subcate-
gory. This plant also has operations covered by the
nonferrous metals forming regulation. Compliance
costs are based on integrated treatment of the two
acid reclaim waste streams (with forming streams) and
separate treatment of the slag reclaim tailings
stream. Costs attributable to treating the streams
associated with acid reclaim operations at this plant
are based on flow weighting the integrated treatment
costs.
(2) The slag reclaim tailings stream is not recycled at
BAT since recycling is not demonstrated on this waste
stream. Plant operation shows that numerous attempts
have been made to recycle this stream without success.
(3) Costs of treating the slag reclaim tailings stream are
based on primary settling and removal of the majority
of settleable solids in the existing lagoon prior to
entering chemical precipitation. Chemical precipita-
tion is accomplished using sulfuric acid as the preci-
pitant rather than lime due to the high pH of the
influent (pH 11).
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
nickel 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. Energy requirements for the two options
considered are estimated at 63,000 kWh/yr and 82,000 kWh/yr for
Options A and C, respectively. Option C represents less than one
percent of a typical plant's electrical energy usage. It is
therefore concluded that the energy requirements of the treatment
options considered will not have a significant impact on total
plant energy consumption.
50
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SOLID WASTE
Sludge generated in the secondary nickel subcategory is due to
the precipitation of metal hydroxides and carbonates using lime
or sulfuric acid. Sludges associated with the secondary nickel
subcategory will necessarily contain quantities of toxic metal
pollutants. Wastes generated by secondary metal industries can
be regulated as hazardous. However, the Agency examined the
solid wastes that would be generated at secondary nonferrous
metals manufacturing plants by the suggested treatment tech-
nologies and believes they are not hazardous wastes under the
Agency1s regulations implementing Section 3001 of the Resource
Conservation and Recovery Act. The one exception to this is
solid wastes generated by cyanide precipitation. These sludges
are expected to be hazardous and this judgment was included in
this study. None of the non-cyanide wastes are listed specific-
ally as hazardous. Nor are they likely to exhibit a characteris-
tic of hazardous waste. This judgment is made based on the rec-
ommended technology of lime precipitation and filtration. By the
addition of a small excess of lime during treatment, similar
sludges, specifically toxic metal bearing sludges, generated by
other industries such as the iron and steel industry passed the
Extraction Procedure (EP) toxicity test. See 40 CFR §261 .24.
Thus, the Agency believes that the wastewater sludges will simi-
larly not be EP toxic if the recommended technology is applied.
Although it is the Agency1s 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 identified should be or are listed as hazardous,
they will come within the scope of RCRA1s "cradle to grave"
hazardous waste management program, requiring regulation from the
point of generation to point of final disposition. EPA"s gener-
ator 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 waste 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
51
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treatment, storage, and disposal facilities allowed to receive
such wastes. See 40 CFR Part 464 [46 FR 2802 (January 12, 1981),
47 FR 32274 (July 26, 1982)].
Even if these wastes are not identified as hazardous, they still
must be disposed of in compliance with the Subtitle D open dump-
ing standards, implementing §4004 of RCRA. See 44 FR 53438
(September 13, 1979). The Agency has calculated as part of the
costs for wastewater treatment the cost of hauling and disposing
of these wastes. Fbr more details, see Section VIII of the
General Development Document.
The Agency estimates that the proposed PSES regulation for
secondary nickel manufacturing facilities will generate 281
metric tons of solid wastes (wet basis) in 1982 as a result of
wastewater treatment.
AIR POLLUTION
There is no reason to believe that any substantial air pollution
problems will result from implementation of chemical precipita-
tion, sedimentation, and multimedia filtration. These technolo-
gies transfer pollutants to solid waste and are not likely to
transfer pollutants to air.
52
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Table VIII-1
COST OF COMPLIANCE FOR THE SECONDARY
NICKEL SUBCATEGORY
INDIRECT DISCHARGERS
(March, 1982 Dollars)
Total Required Total
Option Capital Cost Annual Cost
A 286,000 119,000
C 341,000 148,000
(287,000)* (120,000)*
*These costs represent Option C without filtration for slag
reclaim tailings.
53
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SECONDARY NICKEL SUBCATEGORY
SECTION IX
BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY AVAILABLE
The plants within the secondary nickel subcategory were studied
as to their wastewater disposal practices and it was determined
that BPT and BAT are not applicable to this subcategory. This is
because there are no direct dischargers of process wastewater.
The secondary nickel subcategory is regulated under New Source
Performance Standards in Section XI and Pretreatment Standards in
Section XII.
55
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SECONDARY NICKEL SUBCATEGORY
SECTION X
BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
As described in Section IX, BAT is not applicable to the second-^
ary nickel subcategory because none of the plants in the subcate-
gory directly discharge any wastewater to surface waters. Regu-
lation of the secondary nickel subcategory is covered in Section
XI under New Source Performance Standards and Section XII under
Pretreatment Standards.
57
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SECONDARY NICKEL 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 technologies for treatment of waste-
water from new sources and presents mass discharge standards for
regulated pollutants for NSPS in the secondary nickel subcate-
gory, based on the selected treatment technology.
TECHNICAL APPROACH TO NSPS
New source performance standards are based on the most effective
and beneficial technologies currently available. The Agency
reviewed and evaluated a wide range of technology options. The
Agency elected to examine two technology options, applied to
combined wastewater streams, which could be applied to the
secondary nickel subcategory as alternatives for the basis of
NSPS.
Treatment technologies considered for the NSPS options are summa-
rized below:
OPTION A (Figure XI-1) is based on:
• Chemical precipitation and sedimentation
„• Separate treatment of slag reclaim tailings wastewater
OPTION C (Figure XI-2) is based on:
• Chemical precipitation and sedimentation
• Multimedia filtration
• Separate treatment of slag reclaim tailings wastewater
As explained in Section IV, the secondary nickel subcategory has
been subdivided into three potential wastewater sources. Since
the water use, discharge rates, and pollutant characteristics of
each of these wastewaters is potentially unique, effluent limita-
tions will be developed for each of the three subdivisions.
59
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For each of the subdivisions, a specific approach was followed
for the development of NSPS. The first requirement to calculate
these limitations is to account for production and flow variabil-
ity from plant to plant. Therefore, a unit of production or
production normalizing parameter (PNP) was determined for each
waste stream which could then be related to the flow from the
process to determine a production normalized flow. Selection of
the PNP for each process element is discussed in Section IV.
Each plant within the subcategory was then analyzed to determine
(1) which subdivisions were present, (2) specific flow rates
generated for each subdivision, and (3) the specific production
normalized flows for each subdivision. This analysis is dis-
cussed in detail in Section V. Nonprocess wastewater such as
rainfall runoff and noncontact cooling water is not considered in
the analysis.
Production normalized flows for each subdivision were analyzed to
determine which flow was to be used as part of the basis for
NSPS. The selected flow (sometimes referred to as a NSPS regula-
tory flow or NSPS discharge flow) reflects the water use controls
which are common practices within the industry. The NSPS nor-
malized flow is based on the average of all applicable data.
Nothing was found to indicate that the wastewater flows and
characteristics of new plants would not be similar to those from
existing plants, since the processes used by new sources are not
expected to differ from those used at existing sources.
The second requirement to calculate new source performance
standards is the set of concentrations that are achievable by
application of the NSPS level of treatment technology. Section
VII discusses the various control and treatment technologies
which are currently in place for each wastewater source. In most
cases, the current control and treatment technologies consist of
chemical precipitation and sedimentation (lime and settle)
technology.
Using these regulatory flows and the achievable concentrations,
the next step is to calculate mass loadings for each wastewater
source or subdivision. This calculation was made on a stream-by-
stream basis, primarily because plants in this subcategory may
perform one or more of the operations in various combinations.
The mass loadings (milligrams of pollutant per metric ton of pro-
duction - mg/kkg) were calculated by multiplying the NSPS regula-
tory flow (1/kkg) by the concentration achievable by the NSPS
level of treatment technology (mg/1) for each pollutant parameter
to be limited under NSPS. These mass loadings are published in
the Federal Register and in CFR Part 400 as the effluent limita-
tions guidelines.
60
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The mass loadings which are allowed under NSPS for each plant
will be the sum of the individual mass loadings for the various
wastewater sources which are found at particular plants. Accord-
ingly, all the wastewater generated within a plant may be com-
bined for treatment in a single or common treatment system, but
the effluent limitations for these combined wastewaters are based
on the various wastewater sources which actually contribute to
the combined flow. This method accounts for the variety of com-
binations of wastewater sources and production processes which
may be found at secondary nickel 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.
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES
As one means of evaluating each technology option, EPA developed
estimates of the pollutant removal and the compliance costs
associated with each option. The methodologies are described
below.
POLLUTANT REMOVAL ESTIMATES
Since there are no existing direct dischargers in the secondary
nickel subcategory, the estimated pollutant removal analysis was
only carried out for indirect dischargers.
A complete description of the methodology used to calculate the
estimated pollutant removal, or benefit, achieved by the appli-
cation of the various treatment options is presented in Section X
of the General Development Document. In short, sampling data
collected during the field sampling program were used to charac-
terize the major waste streams considered for regulation. At
each sampled facility, the sampling data was production normal-
ized for each unit operation (i.e., mass of pollutant generated
per mass of product manufactured). This value, referred to as
the raw waste, was used to estimate the mass of toxic pollutants
generated within the secondary nickel subcategory. The pollutant
removal estimates were calculated for each plant by first estima-
ting the total mass of each pollutant in the untreated waste-
water. This was calculated by first multiplying the raw waste
values by, the corresponding production value for that stream and
then summing these values for each pollutant for every stream
generated by the plant.
-------
The volume of wastewater discharged after the application of each
treatment option was estimated for each operation at each plant
by comparing the actual discharge to the regulatory flow. The
smaller of the two values was selected and summed with the other
plant flows. The mass of pollutant discharged was then estimated
by multiplying the achievable concentration values attainable
with the option (mg/1) by the estimated volume of process waste-
water discharged by the subcategory. The mass of pollutant
removed is the difference between the estimated mass of pollutant
generated within the subcategory and the mass of pollutant dis-
charged after application of the treatment option. The pollutant
removal estimates for indirect dischargers in the secondary
nickel subcategory are presented in Table XI1-1.
COMPLIANCE COSTS
In estimating subcategory-wide compliance costs, the first step
was to develop a cost estimation model, relating the total costs
associated with installation and operation of wastewater treat-
ment technologies to plant process wastewater discharge. EPA
applied the model to each plant. The plant's investment and
operating costs are determined by what treatment it has in place
and by its individual process wastewater discharge flow. As dis-
cussed above, this flow is either the actual or the NSPS regula-
tory flow, whichever is lesser. The final step was to annualize
the capital costs, and to sum the annualized capital costs, and
the operating and maintenance costs for each plant, yielding the
cost of compliance for the subcategory (see Table XII-2). These
costs were used in assessing economic achievability.
NSPS OPTION SELECTION
We are proposing that NSPS for the secondary nickel subcategory
be based on Option C, chemical precipitation, sedimentation, and
filtration (filtration is proposed for acid reclaim leaching fil-
trate and acid reclaim leaching belt filter backwash, but not for
slag reclaim tailings). The end-of-pipe treatment configuration
for the NSPS option selected is presented in Figure XI-3. It was
determined that filtration for slag reclaim tailings is not cost
effective. As such, this waste stream is treated in a separate
treatment system with chemical precipitation and sedimentation,
as shown in Figure XI-3. The pollutants and pollutant parameters
specifically limited under NSPS are chromium, copper, nickel,
total suspended solids and pH. The toxic pollutants arsenic and
zinc were also considered for regulation because they are present
at treatable concentrations in the raw wastewaters from this sub-
category. These pollutants were not selected for specific regu-
lation because they will be effectively controlled when the regu-
lated toxic metals are treated to the levels achievable by the
model technology.
62
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NSPS technology and discharge rates are equivalent to PSES
technology and discharge rates. Because NSPS is equal to PSES,
we believe that the proposed NSPS will not have a detrimental
impact on the entry of new plants into this subcategory.
WASTEWATER DISCHARGE RATES
A NSPS discharge rate is calculated for each subdivision based on
the average of the flows of the existing plants, as determined
from analysis of dcp. The discharge rate is used with the
achievable treatment concentrations to determine NSPS effluent
limitations. Since the discharge rate may be different for each
wastewater source, separate production normalized discharge rates
for each of the three wastewater sources are discussed below and
summarized in Table XI-1. The discharge rates are normalized on
a production basis by relating the amount of wastewater generated
to the mass of the product which is produced by the process asso-
ciated with the waste stream in question. These production nor-
malizing parameters, or PNPs, are also listed in Table XI-1.
Section V of this document further describes the discharge flow
rates and presents water use and discharge flow rates for each
plant by subdivision in Tables V-1 through V-3.
SLAG RECLAIM TAILINGS
The NSPS wastewater discharge rate for slag reclaim tailings is
85,600 1/kkg of slag reclaim nickel produced. This rate is allo-
cated only for those plants which reclaim nickel from slag gener-
ated in melt furnaces with a wet granulation type of process.
The water use and wastewater discharge rates are presented in
Table V-1. The NSPS flow is based on the rate reported by the
only discharging plant (85,600 1/kkg).
ACID RECLAIM LEACHING FILTRATE
The NSPS wastewater discharge rate for acid reclaim leaching fil-
trate is 5,000 1/kkg of acid reclaim nickel produced. This rate
is allocated only for those plants which reclaim nickel from
spent acids, pickling wastes, and wastewater treatment sludges by
roasting the nickel carbonate to nickel oxide and then leaching
away impurities with water. The water use and wastewater dis-
charge rates are presented in Table V-2. The NSPS flow is based
on the rate reported by the only discharging plant (5,000 1/kkg).
ACID RECLAIM LEACHING BELT FILTER BACKWASH
The NSPS wastewater discharge rate for acid reclaim leaching belt
filter backwash is 1,200 1/kkg of acid reclaim nickel produced.
This rate is allocated only for those plants which reclaim nickel
63
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from spent acids, pickling wastes, and wastewater treatment
sludges as explained above, and clean the belt filter with water.
The water use and wastewater discharge rates are presented in
Table V-3. The NSPS flow is based on the rate reported by the
only discharging plant (1,200 1/kkg).
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 five pollutants or pol-
lutant parameters are selected for limitation under NSPS and are
listed below:
119. chromium
120. copper
124. nickel
TSS
pH
The Agency has chosen not to regulate all five toxic pollutants
selected in Section VI for further consideration.
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 above 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 removal analysis.
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 chemical-precipitation and sedimentation
technology are based on optimized treatment for concomitant mul-
tiple metals removal. Thus, even though metals have somewhat
different theoretical solubilities, they will be removed at very
nearly the same rate in a chemical precipitation and sedimenta-
tion treatment system operated for multiple metals removal.
64
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NEW SOURCE PERFORMANCE STANDARDS
The treatable concentrations achievable by application of the
proposed NSPS are discussed in Section VII of the General Devel-
opment Document and summarized there in Table VII-19. These
treatable concentrations (both one day maximum and monthly
average values) are multiplied by the NSPS normalized discharge
flows summarized in Table XI-1 to calculate the mass of pollu-
tants allowed to be discharged per mass of product. The results
of these calculations in milligrams of pollutant per kilogram of
product represent the new source performance standards and are
presented in Table XI-2 for each individual waste stream.
65
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Table XI-1
NSPS WASTEWATER DISCHARGE RATES FOR THE
SECONDARY NICKEL SUBCATEGORY
Wastewater Stream
Slag Reclaim Tailings
Acid Reclaim Leaching
Filtrate
Acid Reclaim Leaching
Belt Filter Backwash
NSPS Normalized
Discharge Rate
(1/kkg) (gal/ton)
85,600
5,000
1,200
21,000
1,200
300
Production
Normalizing
Parameter
slag reclaim
nickel produced
acid reclaim
nickel produced
acid reclaim
nickel produced
66
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TABLE XI-2
NSPS FOR THE SECONDARY NICKEL SUBCATEGORY
a) Slag Reclaim Tailings
ollutant or Maximum for Maximum for
jllutant Property Any One Day Monthly Average
3/kg (Ib/million Ibs) of slag reclaim nickel produced
iromium (total) 37.670 15.410
apper 168.700 85.600
ickel 164.400 108.700
Dtal suspended 3,510.000 1,669.000
solids
i Within the range of 7.5 to 10.0
at all times
3) Acid Reclaim Leaching Filtrate
Dllutant or Maximum for Maximum for
allutant Property Any One Day Monthly Average
3/kg (Ib/million Ibs) of acid reclaim nickel produced
iromium (total) 1.848 0.749
spper 6.394 3.047
.ckel 2.747 1.848
3tal-suspended 74.930 59.940
solids
I Within the range of 7.5 to 10.0
at all times
:) Acid Reclaim Leaching Belt Filter Backwash
>llutant or Maximum for Maximum for
>llutant Property Any One Day Monthly Average
/kg (Ib/million Ibs) of acid reclaim nickel produced
romium (total) 0.444 0.180
pper 1.535 0.731
Ckel 0.660 0.444
>tal suspended 17.990 14.390
solids
Within the range of 7.5 to 10.0
at all times
67
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SECONDARY NICKEL SUBCATEGORY
SECTION XII
PRETREATMENT STANDARDS
Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources (PSES) , which must be achieved
within three years of promulgation. PSES are designed to prevent
the discharge of pollutants which pass through, interfere with,
or are otherwise incompatible with the operation of publicly
owned treatment works (POTW). The Clean Water Act of 1977
requires pretreatment for pollutants, such as heavy metals, that
limit POTW sludge management alternatives. Section 307 (c) of the
Act requires EPA to promulgate pretreatment standards for new
sources (PSNS) at the same time that it promulgates NSPS. New
indirect discharge facilities, like new direct discharge facili-
ties, have the opportunity to incorporate the best available
demonstrated technologies, including process changes, in-plant
controls, and end-of-pipe treatment technologies, and to use
plant site selection to ensure adequate treatment system instal-
lation. Pretreatment standards are to be technology based,
analogous- to the best available technology for removal of toxic
pollutants.
This section describes the control and treatment technologies for
pretreatment of process wastewaters from existing sources and new
sources in the secondary nickel subcategory. Pretreatment
standards for regulated pollutants are presented based on the
selected control and treatment technology.
TECHNICAL APPROACH TO PRETREATMENT
Before proposing pretreatment standards, the Agency examines
whether the pollutants discharged by the industry pass through
the POTW or interfere with the POTW operation or its chosen
sludge disposal practices. In determining whether pollutants
pass through a well-operated POTW achieving secondary treatment,
the Agency compares the percentage of a pollutant removed by POTW
with the percentage removed by direct dischargers applying the
best available technology economically achievable. A pollutant
is deemed to pass through the POTW when the average percentage
removed nationwide by well-operated POTW meeting secondary 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) .)
71
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This definition of pass through satisfies two competing objec-
tives set by Congress: (1) that standards for indirect dis-
chargers be equivalent to standards for direct dischargers while
at the same time, (2) that the treatment capability and perfor-
mance of the POTW be recognized and taken into account in regu-
lating the discharge of pollutants from indirect dischargers.
The Agency compares percentage removal rather than the mass or
concentration of pollutants discharged because the latter would
not take into account the mass of pollutants discharged to the
POTW from non-industrial sources or the dilution of the pollu-
tants in the POTW effluent to lower concentrations due to the
addition of large amounts of non-industrial wastewater.
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES
The industry cost and pollutant removal estimates of each treat-
ment option were used to determine the most cost-effective
option. The methodology applied in calculating pollutant removal
estimates and plant compliance costs is discussed in Section XI.
Table XII-1 shows the estimated pollutant removal estimates for
indirect dischargers. Compliance costs for indirect dischargers
are presented in Table XII-2.
PRETREATMENT STANDARDS FOR EXISTING AND NEW SOURCES
Options for pretreatment of wastewaters from both existing and
new sources are based on increasing the effectiveness of end-of-
pipe treatment technologies. All in-plant changes and applicable
end-of-pipe treatment processes have been discussed previously in
Section XI. The options for PSNS and PSES, therefore, are the
same as the NSPS options discussed in Section XI.
A description of each option is presented in Section XI, while a
more detailed discussion, including pollutants controlled by each
treatment process is presented in Section VII of the General
Development Document.
Treatment technologies considered for the PSNS and PSES options
are:
OPTION A
Chemical precipitation and sedimentation
Separate treatment of slag reclaim tailings wastewater
72
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OPTION C
• Chemical precipitation and sedimentation
• Multimedia filtration
• Separate treatment of slag reclaim tailings wastewater
PSES OPTION SELECTION
We are proposing PSES for this subcategory based on Option C,
chemical precipitation, sedimentation, and filtration (filtration
is proposed for acid reclaim leaching filtrate and acid reclaim
leaching filter backwash, but not for slag reclaim tailings).
The pollutants specifically regulated under PSES are chromium,
copper, and nickel. The toxic pollutants arsenic and zinc were
also considered for regulation because they are present at treat-
able concentrations in the raw wastewaters from this subcategory.
These pollutants were not selected for specific regulation
because they will be effectively controlled when the regulated
toxic metals are treated to the levels achievable by the model
technology. We are proposing PSES to prevent pass-through of
chromium, copper, and nickel. These toxic pollutants are removed
by a well-operated POTW at an average of 32 percent while PSES
technology removes approximately 84 percent.
Implementation of the proposed PSES limitations would remove
annually an estimated 1,113 kg of toxic metals. We estimate a
capital cost of $287,000 and an annualized cost of 8120,000 to
achieve the proposed PSES. The proposed PSES will not result in
adverse economic impacts.
PSNS OPTION SELECTION
We are proposing PSNS equivalent NSPS and PSES. The same pollu-
tants pass through at PSNS as at PSES, for the same reasons. We
know of no economically feasible, demonstrated technology that is
better than PSES technology. The PSES flow allowances are based
on minimization of process wastewater wherever possible.
We believe that the proposed PSNS are achievable, and that they
are not a barrier to entry of new plants into this subcategory.
The wastewater discharge rates for both PSES and PSNS are iden-
tical to the NSPS discharge rates for each waste stream. The
PSES and PSNS discharge rates are shown in Table XII-3.
PRETREATMENT STANDARDS
Pretreatment standards are based on the treatable concentrations
from the selected treatment technology, (Option C), and the
discharge rates determined in Section XI for NSPS and shown in
73
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Table XII-3. A mass of pollutant per mass of product (mg/kg)
allocation is given for each subdivision within the subcategory.
This pollutant allocation is based on the product of the
treatable concentration from the proposed treatment (mg/1) and
the production normalized wastewater discharge rate (1/kkg). The
achievable treatment concentrations for NSPS are identical to
those for PSES and PSNS. These concentrations are listed in Table
VII-19 of the General Development Document. PSES and PSNS are
presented in Table XII-4.
74
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Table XII-2
COST OF COMPLIANCE FOR THE SECONDARY
NICKEL SUBCATEGORY
INDIRECT DISCHARGERS
(March, 1982 Dollars)
Total Required Total
Option Capital Cost Annual Cost
A 286,000 119,000
C 341,000 148,000
(287,000)* (120,000)*
*These costs represent Option C without filtration for cl?g
reclaim tailings.
76
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Table XI1-3
PSES AND PSNS WASTEWATER DISCHARGE RATES FOR THE
SECONDARY NICKEL SUBCATEGORY
Wastewater Stream
Slag Reclaim Tailings
Acid Reclaim Leaching
Filtrate
Acid Reclaim Leaching
Belt Filter Backwash
PSES and PSNS
Normalized
Discharge Rate
(1/kkg) (gal/ton)
85,600
5,000
1,200
21,000
1,200
300
Production
Normalizing
Parameter
slag reclaim
nickel produced
acid reclaim
nickel produced
acid reclaim
nickel produced
77
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TABLE XI1-4
PSES AND PSNS FOR THE SECONDARY NICKEL SUBCATEGORY
(a) Slag Reclaim Tailings
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
nag/kg (Ib/million Ibs) of slag reclaim nickel produced
Chromium (total) 37.670 15.410
Copper 162.700 85.600
Nickel 164.400 108.700
(b) Acid Reclaim Leaching Filtrate
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
Big/kg (Ib/million Ibs) of acid reclaim nickel produced
Chromium (total) 1.848 0.749
Copper 6.394 3.047
Nickel 2.747 1.848
(c) Acid Reclaim Leaching Belt Filter Backwash
Pollutant or Maximum for Maximum for
Pollutant Property Any One Day Monthly Average
mg/kg (Ib/million Ibs) of acid reclaim nickel produced
Chromium (total) 0.444 0.180
Copper 1.535 0.731
Nickel 0.660 0.444
78
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SECONDARY NICKEL SUBCATEGORY
SECTION XIII
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
EPA is not proposing best conventional pollutant control tech-
nology (BCT) for the secondary nickel subcategory at this time.
79
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