United States         Effluent Guidelines Division      EPA-440/1-84/019-5
        Environmental Protection     WH-552            Jujy 198'
        Agency           Washington, D.C. 20460
        Water and Waste Management
440184019B5 -
&EPA   Development          Proposed
        Document for
        Effluent Limitations
        Guidelines and
        Standards for the
        Nonferrous  Metals

        Point Source Category
        Phase II
        Supplemental Development
        Document For:

        Primary Antimony

-------
                  DEVELOPMENT DOCUMENT

                          for

    EFFLUENT  LIMITATIONS GUIDELINES AND STANDARDS

                        for the
                                   •i

NONFERROUS METALS MANUFACTURING POINT  SOURCE CATEGORY

                        PHASE II

              Primary Antimony Supplement
                     Jack E. Ravan
          Assistant Administrator for Water
                    Edwin L. Johnson
                        Director
      Office  of  Water Regulations and  Standards
                                   i. ..":  r vironrnental Protection Agency
                                   R-.;;.--!!! V, L.brary
                                   230 SJ'!t-i Dearborn 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

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                        TABLE OF CONTENTS


Section                                                     Page

I         SUMMARY AND CONCLUSIONS	      1

II        RECOMMENDATIONS	      3

          BPT LIMITATIONS FOR THE PRIMARY ANTIMONY
          SUBCATEGORY	      3
          BAT LIMITATIONS FOR THE PRIMARY ANTIMONY
          SUBCATEGORY	      4
          NSPS FOR THE PRIMARY ANTIMONY SUBCATEGORY.  ...      5
          PSNS FOR THE PRIMARY ANTIMONY SUBCATEGORY.  ...      6

III       INDUSTRY PROFILE 	      9

          DESCRIPTION OF PRIMARY ANTIMONY PRODUCTION ...      9
          RAW MATERIALS	     10
          PYROMETALLURGICAL PROCESSES	     10
          LEACHING	     10
          AUTOCLAVING	     11
          ELECTROW INNING	     11
          CONVERSION TO ANTIMONY TRIOXIDE	     11
          PROCESS WASTEWATER SOURCES 	     12
          OTHER WASTEWATER SOURCES 	     12
          AGE, PRODUCTION, AND PROCESS PROFILE 	     12

IV        SUBCATEGORIZATION	     19

          FACTORS CONSIDERED IN SUBCATEGORIZATION	     19
          FACTORS CONSIDERED IN SUBDIVIDING THE PRIMARY
          ANTIMONY SUBCATEGORY 	     20
          OTHER FACTORS	     20
          PRODUCTION NORMALIZING PARAMETERS.  .	     21

V         WATER USE AND WASTEWATER CHARACTERISTICS ....     23

          WASTEWATER FLOW RATES	     24
          WASTEWATER CHARACTERISTICS DATA	     24
          DATA COLLECTION PORTFOLIOS 	     24
          FIELD SAMPLING DATA	     25
          WASTEWATER CHARACTERISTICS AND FLOWS BY
          SUBDIVISION	     26
          SODIUM ANTIMONATE AUTOCLAVE WASTEWATER 	     26
          FOULED ANOLYTE 	     27

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

VI        SELECTION OF POLLUTANT PARAMETERS	    31

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS	    31
          CONVENTIONAL POLLUTANT PARAMETERS SELECTED ...    31
          TOXIC POLLUTANTS	    32
          TOXIC POLLUTANTS NEVER DETECTED	    32
          TOXIC POLLUTANTS SELECTED FOR FURTHER
          CONSIDERATION IN ESTABLISHING LIMITATIONS
          AND STANDARDS.	    35

VII       CONTROL AND TREATMENT TECHNOLOGIES 	    39

          CURRENT CONTROL AND TREATMENT PRACTICES	    39
          SODIUM ANTIMONATE AUTOCLAVE WASTEWATER 	    39
          FOULED ANOLYTE 	    40
          CONTROL AND TREATMENT OPTIONS	    40
          OPTION A	    40
          OPTION C .  . . . '.	    40

VIII   .   COSTS, ENERGY, AND NONWATER QUALITY ASPECTS. .  .    41

          TREATMENT OPTIONS FOR EXISTING SOURCES 	    41
          OPTION A	    41
          OPTION C ........ 	    41
          COST METHODOLOGY	    41
          NONWATER QUALITY ASPECTS 	    42
          ENERGY REQUIREMENTS	    42
          SOLID WASTE	    42
          AIR POLLUTION	    43

IX        BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
          AVAILABLE	    45

          TECHNICAL APPROACH TO BPT	    45
          INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES.  .    47
          BPT OPTION SELECTION 	    47
          WASTEWATER DISCHARGE RATES 	    48
          SODIUM ANTIMONATE AUTOCLAVE WASTEWATER 	    48
          FOULED ANOLYTE  	    49
          REGULATED POLLUTANT PARAMETERS 	    49
          EFFLUENT LIMITATIONS 	    49
                               ii

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section
XI
XII
BEST AVAILABLE TECHNOLOGY ECONOMICALLY
ACHIEVABLE	     53

TECHNICAL APPROACH TO BAT	     53
OPTION A	     54
OPTION C	     54
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES.  .     55
POLLUTANT REMOVAL ESTIMATES	     55
COMPLIANCE COSTS	     55
BAT OPTION SELECTION 	     56
WASTEWATER DISCHARGE RATES 	     56
REGULATED POLLUTANT PARAMATERS 	     57
EFFLUENT LIMITATIONS 	     58

NEW SOURCE PERFORMANCE STANDARDS 	     65

TECHNICAL APPROACH TO NSPS	     65
OPTION A	     65
OPTION C	     66
NSPS OPTION SELECTION	     66
REGULATED POLLUTANT PARAMETERS 	     66
NEW SOURCE PERFORMANCE STANDARDS 	     66

PRETREATMENT STANDARDS 	     69

TECHNICAL APPROACH TO PRETREATMENT 	     69
PRETREATMENT STANDARDS FOR NEW SOURCES 	     70
OPTION A	     70
OPTION C	     70
PSNS OPTION SELECTION	     70
REGULATED POLLUTANT PARAMETERS 	     71
PRETREATMENT STANDARDS FOR NEW SOURCES 	     71
XIII
BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
75
                              iii

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                          LIST OF TABLES
Number
Page
III-1     INITIAL OPERATING YEAR (RANGE) SUMMARY OF
          PLANTS IN THE PRIMARY ANTIMONY SUBCATEGORY
          BY DISCHARGE TYPE	    13

III-2     PRODUCTION RANGES FOR THE PRIMARY ANTIMONY
          SUBCATEGORY	    14

III-3     SUMMARY OF PRIMARY ANTIMONY SUBCATEGORY
          PROCESSES AND ASSOCIATED WASTE STREAMS 	    14

V-1       WATER USE AND DISCHARGE RATE FOR SODIUM
          ANTIMONATE AUTOCLAVE WASTEWATER	    28

V-2       WATER USE AND DISCHARGE RATE FOR FOULED ANOLYTE.    29

V-3       PRIMARY ANTIMONY SAMPLING DATA FOULED ANOLYTE
          AUTOCLAVE DISCHARGE RAW WASTEWATER 	    30

VI-1      FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
          PRIMARY ANTIMONY RAW WASTEWATER	    37

VI11-1    COST OF COMPLIANCE FOR THE PRIMARY ANTIMONY
          SUBCATEGORY DIRECT DISCHARGERS 	    44

IX-1      BPT WASTEWATER DISCHARGE RATES FOR THE
          PRIMARY ANTIMONY SUBCATEGORY 	    50

IX-2      BPT MASS LIMITATIONS FOR THE PRIMARY ANTIMONY
          SUBCATEGORY	    51

X-1       POLLUTANT REMOVAL ESTIMATES FOR DIRECT
          DISCHARGERS IN THE PRIMARY ANTIMONY
          SUBCATEGORY	    59

X-2       COST OF COMPLIANCE FOR THE PRIMARY ANTIMONY
          SUBCATEGORY DIRECT DISCHARGERS 	    60

X-3       BAT WASTEWATER DISCHARGE RATES FOR THE
          PRIMARY ANTIMONY SUBCATEGORY 	   61

X-4       BAT MASS LIMITATIONS FOR THE PRIMARY
          ANTIMONY SUBCATEGORY 	   62
                               v

-------
                   PRIMARY ANTIMONY SUBCATEGORY



                    LIST OF TABLES (Continued)





Number                                                      Page



XI-1      NSPS WASTEWATER DISCHARGE RATES FOR THE

XI-2
XII-1
XII-2
PRIMARY ANTIMONY SUBCATEGORY 	 	
NSPS FOR THE PRIMARY ANTIMONY SUBCATEGORY. . . .
PSNS WASTEWATER DISCHARGE RATES FOR THE
PRIMARY ANTIMONY SUBCATEGORY 	
PSNS FOR THE PRIMARY ANTIMONY SUBCATEGORY. . . .
67
68
72
73
                               vi

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                         LIST OF FIGURES


Number                                                      Page

III-1     PRIMARY ANTIMONY PRODUCTION PROCESS
          (PYROMETALLURGICAL)	    16

III-2     PRIMARY ANTIMONY PRODUCTION PROCESS
          (HYDRO-METALLURGICAL)	    17

III-3     GEOGRAPHIC LOCATIONS OF THE PRIMARY ANTIMONY
          SUBCATEGORY PLANTS	    18

IX-1      BPT TREATMENT SCHEME FOR THE PRIMARY ANTIMONY
          SUBCATEGORY	    52

X-1       BAT TREATMENT SCHEME FOR OPTION A	    63

X-1       BAT TREATMENT SCHEME FOR OPTION C	    64
                              Vll

-------
viii

-------
                    PRIMARY ANTIMONY  SUBCATEGORY

                             SECTION  I

                     SUMMARY AND  CONCLUSIONS
Pursuant to Sections 301, 304,  306,  307,  and  501  of  the  Clean
Water Act and the provisions  of the  Settlement Agreement in
Natural Resources Defense Council v.  Train, 8 ERG 2120  (D.D.C.
1976) modified, 12 ERG 1833 (D.D.C.  1979), EPA has collected and
analyzed data for plants in the primary antimony  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 effluent
limitations based on best practicable technology  (BPT) and best
available technology (BAT) for  existing direct dischargers, pre-
treatment standards for new indirect  dischargers  (PSNS),  and
standards of performance for  new source direct dischargers
(NSPS).

The primary antimony subcategory is comprised of  eight plants.
Of the eight plants, one discharges directly  to a river,  four
plants achieve zero discharge of process  wastewater, and  three
plants generate no process wastewater.

EPA first studied the primary antimony subcategory to determine
whether differences in raw materials,  final products, manufac-
turing 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,  two subdivi-
sions have been identified for  this subcategory that warrant
separate effluent limitations.   These  include:

     •  Sodium antimonate autoclave wastewater, and
     •  Fouled anolyte.

EPA also identified several distinct  control and  treatment tech-
nologies (both in-plant and end-of-pipe)  applicable to the pri-
mary antimony subcategory.  The  Agency analyzed both historical
and newly generated data on the  performance of these technolo-
gies,  including their nonwater  quality environmental impacts and
air quality, solid waste generation,  and  energy requirements.
EPA also studied various flow reduction techniques reported in
the data collection portfolios  (dcp)  and  plant visits.

-------
Engineering costs were prepared for each of the control and
treatment options considered for the 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."

After examining the various treatment technologies, the Agency
has identified BPT to represent the average of the best existing
technology.  Metals removal based on chemical precipitation and
sedimentation technology is the basis for the BPT limitations.
To meet the BPT effluent limitations based on this technology,
the primary antimony subcategory is expected to incur an esti-
mated capital cost of $34,200 and an annual cost of $17,300.

For BAT, filtration is added an an effluent polishing step to the
BPT end-of-pipe treatment scheme.  To meet the BAT effluent limi-
tations based on this technology, the primary antimony subcate-
gory is estimated to incur a capital cost of $41 ,250 and an
annual cost of $21,183.

NSPS is equivalent to BAT.  In selecting NSPS, EPA recognized
that new plants have the opportunity to implement the best and
most efficient manufacturing processes and treatment technology.
As such, the technology basis of BAT has been determined as the
best demonstrated technology.

PSES is not being proposed for this subcategory because there are
no existing indirect dischargers in the primary antimony subcate-
gory.  For PSNS, the Agency selected end-of-pipe treatment tech-
nology equivalent to BAT.

The best conventional technology (BCT) replaces BAT for the con-
trol of conventional pollutants.  BCT is not being proposed at
this time because the methodology for BCT has not yet been
finalized.

The mass limitations and standards for BPT, BAT, NSPS, and PSNS
are presented in Section II.

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                            SECTION II

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

    (a)  Sodium antimonate autoclave wastewater, and
    (b)  Fouled anolyte.

2.  BPT is proposed based on the performance achievable by the
    application of chemical precipitation and sedimentation
    technology.  The following BPT effluent limitations are
    proposed:


BPT LIMITATIONS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(a)  Sodium Antimonate Autoclave Wastewater

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

    mg/kg (Ib/million Ibs) of antimony contained in
               sodium antimonate product

Antimony                 20.360             9.079
Arsenic                  14.820             6.596
Lead                      2.979             1.419
Mercury                   1.773             0.709
Total suspended         290.800           138.300
  solids
pH                     Within the range of 7.5 to 10.0
                                at all times

-------
BPT LIMITATIONS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(b)  Fouled Anolyte

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

   mg/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                 20.360             9.079
Arsenic                  14.820             6.596
Lead                      2.979             1.419
Mercury        •           1.773             0.709
Total suspended         290.800           138.300
  solids
pH                     Within the range of 7.5 to 10.0
                                at all times


3.  BAT is proposed based on the performance achievable by the
    application of chemical precipitation, sedimentation, and
    multimedia filtration technology.  The following BAT effluent
    limitations are proposed:


BAT LIMITATIONS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(a)  Sodium Antimonate Autoclave Wastewater

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

    mg/kg (Ib/million Ibs) of antimony contained in
               sodium antimonate product

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426

-------
BAT LIMITATIONS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(b)  Fouled Anolyte

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

   mg/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                 13.690             6.100
Arsenic   -                9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426


4.  NSPS are proposed based on the performance achievable by the
    application of chemical precipitation, sedimentation, and
    multimedia filtration technology.  The following effluent
    standards are proposed for new sources:


NSPS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(a)  Sodium Antimonate Autoclave Wastewater

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

    mg/kg (Ib/million Ibs)  of antimony contained in
               sodium antimonate product

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
Total suspended         106.400            85.120
  solids
pH                     Within the range of 7.5 to 10.0
                                at all times

-------
NSPS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(b)  Fouled Anolyte

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

   rag/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
Total suspended         106.400            85.120
  solids
pH                     Within the range of 7.5 to 10.0
                                at all times


5.  PSES is not being proposed for the primary antimony sub-
    category at this time because there are no existing indirect
    dischargers in the primary antimony subcategory.

6.  PSNS are proposed based on the performance achievable by the
    application of chemical precipitation, sedimentation, and
    multimedia filtration technology.  The following pretreatment
    standards are proposed for new sources:


PSNS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(a)  Sodium Antimonate Autoclave Wastewater

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

    mg/kg (Ib/million Ibs) of antimony contained in
               sodium antimonate product

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426

-------
PSNS FOR THE PRIMARY ANTIMONY SUBCATEGORY

(b)  Fouled Anolyte

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

   mg/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
7.  EPA is not proposing BCT at this time for the primary
    antimony subcategory.

-------
8

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                           SECTION III

                         INDUSTRY PROFILE


This section of the primary antimony supplement describes  the  raw
materials and processes used in producing primary antimony and
presents a profile of the primary antimony plants identified in
this study.  For a discussion of the purpose, authority, and
methodology for this study and for a general description of the
nonferrous metals manufacturing category, refer to Section III of
the General Development Document.

Although there are about 112 minerals of antimony, the principal
ore mineral is stibnite, the sulfide of antimony.  Antimony also
occurs in other metal ores, including gold-quartz deposits and
copper-lead-zinc deposits.  The major use of antimony metal is as
an alloying constituent which increases the strength and inhibits
the corrosion of lead and other metals.

Industrial applications of antimony are primarily as an alloying
agent and include use as a hardener in lead storage batteries,
tank linings, and chemical pumps and pipes.  Of the many antimony
compounds available commercially, the most important is antimony
trioxide (Sb203).  Antimony trioxide is used for flameproof-
ing plastics, paints, vinyls, fabrics, and chemicals.  It  is also
used in the ceramics industry to impart hardness and acid
resistance to enamel coverings.

DESCRIPTION OF PRIMARY ANTIMONY PRODUCTION

There are two general types of methods of manufacturing antimony
and its compounds:  hydrometallurgical methods and pyrometallurg-
ical methods.  Antimony metal is produced from antimony minerals
or ore by smelting.  Antimony trioxide is produced from antimony
metal or ore concentrates by roasting or burning.  These pyro-
metallurgical processes, practiced at five of the eight antimony
plants identified in this subcategory, generate no process
wastewater.

Hydrometallurgical processing, practiced at the remaining  three
antimony plants, can be used to produce antimony metal, antimony
trioxide, and sodium antimonate (NaSb03).  Hydrometallurgical
processing can be divided into four distinct stages:  leaching,
autoclaving, electrowinning, and conversion to antimony trioxide.
The actual processes used at each plant vary with the type and
purity of the raw materials used as well as with the type  of
antimony product manufactured.  The primary antimony production
processes, both pyrometallurgical and hydrometallurgical,  are
presented in Figures III-1 and III-2 and described below.

-------
RAW MATERIALS

The principal source of antimony is the sulfide ore mineral
stibnite.  Stibnite, the sulfide of antimony together with its
oxidized equivalents, is mined in several countries including
Mexico, China, Peru, Yugoslavia, and Algeria.  Virtually all
domestic production of primary antimony metal is a by-product of
the refining of base metal and silver ores.  Antimony trioxide  is
produced from imported ores, antimony metal, and crude antimony
oxide from South Africa.

PYROMETALLURGICAL PROCESSES

Antimony metal can be produced by smelting antimony minerals or
ore with appropriate fluxes.  Metal of 99 percent purity can be
manufactured by this process with no generation of wastewater.

Antimony trioxide can be produced by burning or roasting ore con-
centrates or antimony metal.  Burning converts the sulfide ore  to
volatile antimony trioxide.  Evaporation separates the slag from
the trioxide which two plants reported is collected in a baghouse
and packaged for sale.  One plant practices wet air pollution
control to recover antimony from the gases leaving the baghouse.
Because the scrubber liquor from this product recovery step is
completely recycled in order to recovery antimony, the final
emissions scrubber is-not considered to be a wastewater source  in
this subcategory.  No plants in this subcategory reported sulfur
dioxide (S02) emissions from the trioxide production process.

LEACHING

A variety of antimony compounds can be produced from ore concen-
trates by hydrometallurgical processes.  Leaching of the concen-
trate is conducted batchwise in a heated, pressurized vat.  Some
concentrates are blended with coke, sodium sulfate, and sodium
carbonate and melted in a furnace before leaching with sodium
hydroxide.  Other concentrates are combined with sodium sulfide
and sulfur and leached with sodium hydroxide without prior
melting.  In either case, the leaching process produces soluble
Na3SbS3 and Na3AsS3«  Because of the coke used as a raw
material in the furnace, EPA is considering the possibility that
several organic pollutants are present in the wastewater

Solids are separated from the leaching solution by thickening and
filtration.  The residue, which contains compounds such as
pyrite, silica, stibnite, soluble arsenic, and NaAsS3, is
either disposed of or further processed to recover other mecals.
Antimony is recovered from the leaching solution either by auto-
claving or by electrowinning, depending on the product desired.
                               10

-------
AUTOCIAVING

Sodium antimonate  (NaSb03>  is produced by  autoclaving the
antimony-bearing solution from the leaching process  with oxygen.
Autoclaving consists of heating the  solution  under pressure  in
the presence of oxygen.  The elevated temperature and pressure
drive the oxidation reaction resulting in  the formation of
insoluble sodium antimonate which is separated  from  the remaining
liquid.  After drying, the  product is packaged  and sold.   The
autoclave discharge is the  only wastewater generated by this
process.

ELECTROWINNING

Antimony metal is  recovered from the pregnant solution from  the
leaching process by electrowinning.  Antimony is deposited on  the
cathode as a brittle, non-adherent layer which  is periodically
stripped and washed.  It is then either sold  or further processed
to antimony trioxide.  The  wash water is not  discharged.

Because the products of oxidation at the anode  interfere with  the
deposition of antimony at the cathode, two different and physi-
cally separated solutions are used.  The catholyte,  which  in this
case is the pregnant solution from the leaching process, sur-
rounds the cathode and the  anolyte surrounds  the anode.  Inter-
mingling of the two solutions is minimized by a canvas barrier.
Small pores in the canvas allow the  solutions to contact;  this
maintains the integrity of  the electrical  circuit and permits
current to flow.

After the antimony has been removed, the barren catholyte  is
recycled to the process using one of two methods.  At the  plant
which reports melting of the ore before leaching, spent electro-
lyte is spray dried.  The dried salts are  captured in a baghouse
and recycled to the blending step.  At the two  plants which  leach
concentrates without first melting them, barren catholyte  solu-
tion is recycled directly to the leaching  process.   One of those
two plants removes the fouled anolyte and  treats it  by autoclav-
ing to recover sodium antimonate for recycle  to the  leaching pro-
cess.  The fouled anolyte discharge  is the only wastewater gener-
ated by the electrowinning  process.  The subsequent  autoclaving
of this stream is considered to be a preliminary wastewater
treatment process and is distinguished from autoclaving to
produce sodium antimonate as a final product.

CONVERSION TO ANTIMONY TRIOXIDE

Antimony metal produced by  electrowinning  or  purchased antimony
metal can be converted to antimony trioxide in  a fuming furnace.
The product of this process is captured in a  baghouse and  sold.
There is no generation of wastewater during this conversion
process.
                               11

-------
PROCESS WASTEWATER SOURCES

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

     1.  Sodium antimonate autoclave wastewater, and
     2.  Fouled anolyte.

OTHER WASTEWATER SOURCES

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

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

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

AGE, PRODUCTION, AND PROCESS PROFILE

Figure II1-3 shows the location of the eight primary antimony
plants operating in the United States.  The plants are geograph-
ically scattered, located in seven states across the country.

Table II1-1 shows the relative age and discharge status  of the
antimony plants.  The oldest plant was built in the 1880's, and
three others are more than 30 years old.  Two new plants have
been built within the last 10 years.  From Table III-2,  it can be
seen that six of the seven plants that provided production infor-
mation produced less than 300 kkg/yr of antimony and antimony
compounds.  The one remaining plant produced more than 2,000
kkg/yr of antimony in the form of antimony trioxide.

Table III-3 provides a summary of the number of plants using
specific manufacturing processes and the number of plants gener-
ating wastewater for the streams associated with those processes.
                               12

-------




























r-»
i
H- 1
M
M

Ol
r-l
n
cd
E_ |
































w
PM
coS
H
2 W
H Q
C*
<5 >"
§PQ

05«
W 05
O
^O
W W
O H
z<:
..
W Z
>. o
s
O rH
Z EH
HH Z
H <
H
W OS
P-. <
o s
rH
rJ 03
<3 P-l
rH
H W
rH 3-
23 EH
Lj
z
rH




CO
4-1
O
EH







CO
1-1
cO
01

C
.H

01
01

CO
j-i
Ol
o.
o

f^
CO
•H
*•>
M




O)
>-l CO x-v
O CM +
<4-< ON O
0) i— vO
PQ ^-^


s-^
1 O
CM CO vO
CO CM 1
ON ON *—
T— T— in
V_/



^-^
1 O
CM co m
>tf CO 1
ON ON ,—
'— *~ -4
**^



X-N
1 O
CM CO >d-
LT) -^- |
ON ON »•—
t- i— CO
v_x



x-^.
1 O
CM CO CO
v£> un i
ON ON ^
T- T— CM
•^^



x^,
1 O
CM CO CM
r^ vo i
ON ON T-
'-'-'—

1 x~\
CM CO O
JQ P^H ^mm
ON ON 1
"---O
»—    CO    CO|
O 4J


01 CO
CXr-l
                o    .-I    i-
         «-    O    0|    i-
                o    ^l    -
                r-    0|   ,-
                      0|
               ^    0|   ^
         o    »-
4J
o
01     O

•H     01
                      ^-    CN
                   EH
                   O
                   H
                                                                                           C
                                                                                           O
                                                                                          •H
                                                                                          4-1
                                                                                           CO
                                                                                 O
                                                                                M-t
                                                                                 C
                                                                                          CO
                                                                                          0)
                                                                                 00
                                                                                 C
                                                                                •r-l

                                                                                4-1
                                                                                 CO
                                                                                 S-i
                                                                                 01
                                                                                 co
                                                                                •H
                                                                                 4J
                                                                                          0)
                                                                                          T3
                                                                                 O

                                                                                 a

                                                                                 4-1
                                                                                 o
                                                                                 C

                                                                                TJ
                                                                                •H
                                                                                T3
                                                                                 1-1
                                                                                 o
                                                                                 00
                                                                                 Ol
                                                                                4J
                                                                                 CO
                                                                                 o
                                                                                          CO


                                                                                          CO
                                                                                C
                                                                                •H


                                                                                4J
                                                                                C
                                                                                cO
                                                                                i— I
                                                                                a.
                                                                                          c
                                                                                         o
                                 13

-------
Total Number
of Plants*
t—  on







,










CM
1
M
1— 1
M

r-t
^1
CO
H






















O
O
W
H

U
pa
J3
CO

25
o
s
H
25
^j

^H
q^
^j
|g
i— i
(V,
PJ
W
PS
H

Oi
S

CO
w
o
^
OS

z
0
I— 1
E-i
U
S3
(Q
O
S















CM
00
^

J_l
O
M-l

0)
or
c
cfl
OS
c
o
•1-1
4->
CJ
TJ
O
S-J
CM

C
o
s
•iH
4J
c
»x


^^
)_i
^
•~^
or
^
•*~s



^^N
V4
^.
~^
or
<*>.
y
•>-x



o-
>•
•^.
or
VX
^
    -   0|  ,-
         o|
         -I   on
     o   <-!   «-
O   T-
         -   CM
0 4->
C
CU (0
CXrH
^Pn
E-i
4-1
O
CU
i-l
•r-|
Q


O
l-i
CU
M



^>
V-i
Q

, •)

o

CX

4J
o
c
-a
T3

^
V4
O
00
0)
4-1
CO
o
"3
to
CO
•H
4J

C

4J
C
CO
rH
CX

QJ
O
*









.
T3
(1)
0
'O
O
J_i
CX
en
O

CO
cO
25

-o
CO
en
O
CM

CO

CO
0)
"O
^J
1— ^
O
C

(U
rH
CO
>
C
O
•H
4J
O
3
T3
O
P-4
*
*

















•
T3
0)
O
p
TJ
0
CX
CO
O
CM
o
CO

CO

C
O
•H
4J
O
3
TJ
O
p-1
-1-

                     14

-------
                           Table  III-3

        SUMMARY OF PRIMARY ANTIMONY SUBCATEGORY  PROCESSES
                   AND ASSOCIATED WASTE STREAMS
   Process or Waste Stream

Pyrometallurgical processes

Leaching

Autoclaving

     Sodium antimonate autoclave
     wastewater

Electrowinning

     Fouled anolyte

Conversion to antimony trioxide
 Number of
Plants With
 Process or
Waste Stream

      5

      3

      2

      2


      3

      3

      2
    Number
  of Plants
  Reporting
  Generation
of Wastewater*
*Through reuse or evaporation practices, a plant may "generate" a
 wastewater from a particular process but not discharge it.
                              15

-------
u
3
•O
o
                                                                                       0>
                                                                                       >-i

                                                                                       3)
cs
tf
D
n4
nJ
<:
H

g
o
                                                                                             CO
                                                                                             en
                                                                                             W
                                                                                             CJ
                                                                                             o
                                                                                             P£5
                                                                                             eu
O
M

H
                                                                                             0

                                                                                             O
                                                                                             03
                                                                                             i
                                                                                             CM
                                     16

-------
      i -o
      v.  e

      z a.
     ^ g
.:    '•
us	
 Jj-»

 I

I
X

1
                                                                 
-------
                                                    cu
                                                    o
                                                    O
                                                    U
                                                    1
                                               bC
                                               •1-1
                                                    os
                                                    33
                                                    H
                                                     2
                                                     O
                                                     o
                                                     U
                                                     a
18

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                            SECTION IV

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

FACTORS CONSIDERED IN SUBCATEGORIZATION

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

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

Evaluation of all factors that could warrant subcategorization
resulted in the designation of the primary antimony 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 primary
antimony.
                              19

-------
FACTORS CONSIDERED IN SUBDIVIDING THE PRIMARY ANTIMONY  SUB-
(JATEGUK?

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

The rationale for considering further subdivision of  the  primary
antimony subcategory is based primarily on differences  in  the
producton processes and raw materials used.  Within this  subcate-
gory, 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 pri-
mary antimony is still considered a single subcategory, a more
thorough examination of the production processes has  illustrated
the need for limitations and standards based on a specific set of
waste streams.  Limitations will be based on specific flow
allowances for the following subdivisions:

     1.  Sodium antimonate autoclave wastewater, and
     2.  Fouled anolyte.

These subdivisions represent the only reported sources  of waste-
water in this subcategory and follow directly from differerces in
the production stages of primary antimony.

The plant which manufactures sodium antimonate autoclaves  the
antimony bearing solution from the leaching process.  The  first
subdivision is associated with the wastewater discharged  from
this autoclaving operation.

When fouled anolyte is removed from the electrowinning  operation
and autoclaved for sodium antimonate recovery, a wastewater
stream is produced at one plant.  Other plants recycle  the elec-
trolyte with no reported wastewater discharge.  Thus, the second
subdivision accounts for operational differences in the electro-
winning stage of antimony production.

OTHER FACTORS

The other factors considered in this evaluation either  support
the establishment of the two 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,  namely metal
product, raw materials, and production processes.  Therefore,
they are not independent factors and do not affect the  subcatego-
rization which has been applied.  As discussed in Section IV of
the General Development Document, certain other factors,  such as
                               20

-------
plant age, plant size, and the number of employees, were  also
evaluated and determined to be inappropriate for use  as bases  for
subdivision of nonferrous metals plants.

PRODUCTION NORMALIZING PARAMETERS

As discussed previously, the effluent limitations  and standards
developed in this document establish mass limitations 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).

In general, for each production process which has  a wastewater
associated with it, the mass of antimony contained in the product
will be used as the PNP.  Thus, the PNPs for the two  subdivisions
are as follows:

          Subdivision                           PNP

1.  Sodium antimonate autoclave    antimony contained in  sodium
    wastewater                     antimonate product

2.  Fouled anolyte                 antimony metal  produced  by
                                   electrowinning
                               21

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                            SECTION V

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

Section V of the General Development Document contains a detailed
description of the data sources and methods of analysis used to
characterize wastewater from the nonferrous metals manufacturing
category.  To summarize this information briefly, two principal
data sources were used:  data collection portfolios (dcp) and
field sampling results.  Data collection portfolios contain
information regarding wastewater flows and production levels.

In order to conduct an analysis of the primary antimony subcate-
gory waste streams and quantify the pollutant discharge from
plants in this subcategory, the levels of toxic pollutants in the
wastewaters must be known.  Although data were not obtained by
sampling a primary antimony plant, one plant submitted sampling
data of their wastewater in the dcp.  The data consist of analy-
ses for two classes of pollutants:  toxic metal pollutants, and
conventional pollutants.  Samples were not analyzed for toxic
organic pollutants because there was no reason to believe that
organic pollutants would be present in wastewaters generated by
the primary antimony subcategory.  (Because the analytical stan-
dard for TCDD was judged to be too hazardous to be made generally
available, samples were never analyzed for this pollutant.
Samples were also not analyzed for asbestos or cyanide.  There is
no reason to expect that TCDD,  asbestos,  or cyanide would be
present in primary antimony wastewater.)

As described in Section- IV of this supplement, the primary anti-
mony subcategory has been split into two subdivisions or waste-
water sources, so that the proposed regulation contains mass
discharge limitations and standards for two 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.  These wastewater sources are:

     1.  Sodium antimonate autoclave wastewater, and
     2.  Fouled anolyte.

                               23

-------
WASTEWATER FLOW RATES

Data supplied by dcp responses were evaluated, and  two  flow-to-
production ratios, water use and wastewater discharge flow, were
calculated for each stream.  The two ratios are differentiated by
the flow value used in calculation.  Water use is defined  as  the
volume of water or other fluid required for a given process per
mass of antimony produced and is therefore based on the  sum of
recycle and makeup flows to a given process.  Wastewater flow
discharged after pretreatment or recycle  (if these  are  present)
is used in calculating the production normalized flow—the volume
of wastewater discharged from a given process to further treat-
ment, disposal, or discharge per mass of  antimony produced.   Dif-
ferences between the water use and wastewater flows associated
with a given stream result from recycle,  evaporation, and  carry-
over on the product.  The production values used in calculation
correspond to the production normalizing  parameter, PNP, assigned
to each stream, as outlined in Section IV.  As an example, sodium
antimonate autoclave wastewater is related to the production  of
antimony contained in the sodium antimonate product.  As such,
the discharge rate is expressed in liters of autoclave  wastewater
per metric ton of antimony contained in the sodium  antimonate
product (gallons of wastewater per ton of antimony  contained  in
the sodium antimonate product).

The production normalized discharge flows were compiled  by stream
type.  These production normalized water  use and discharge flows
are presented by subdivision in Tables V-1 and V-2  at the  end of
this section.  Where appropriate, an attempt was made to identify
factors that could account for variations in water  use  and dis-
charge rates.  These variations are discussed later in  this  sec-
tion by subdivision.  A similar analysis  of factors affecting the
wastewater flows is presented in Sections X, XI, and XII where
representative BAT, NSPS, and pretreatment flows are selected for
use in calculating the effluent limitations.

The water use and discharge rates shown do not include  nonprocess
wastewater, such as rainfall runoff and noncontact  cooling water.

WASTEWATER CHARACTERISTICS DATA

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

DATA COLLECTION PORTFOLIOS

In the data collection portfolios, the antimony  plants  that  gen-
erate wastewater were asked to specify the presence of  toxic pol-
lutants in their wastewater.  Of the five primary antimony plants
                                24

-------
that generate wastewater, three responded  to  this  portion  of the
questionnaire.  No plant responding to the questionnaire reported
the presence of any toxic organic pollutants.   The responses for
the toxic metals and cyanide are summarized below.
Pollutant
Known Present
Antimony              2
Arsenic               2
Beryllium             0
Cadmium               1
Chromium              0
Copper                0
Cyanide               0
Lead                  1
Mercury               1
Nickel                0
Selenium              1
Silver                0
Thallium              1
Zinc                  1

FIELD SAMPLING DATA
      Believed Present
(Based on'Raw Materials and
  Process Chemicals Used)
                                  0
                                  1
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
                                  0
Sampling data for the primary antimony  subcategory  were  provided
by one company in its dcp.  No other field  sampling programs  were
conducted.

Raw wastewater data are summarized  in Table V-3 at  the end  of
this section.  Analytical results for eight samples of the  fouled
anolyte autoclave discharge were provided  in  one  dcp.  The  data
included results for several toxic metals  and two conventional
pollutant parameters.  No toxic organic, cyanide  or source  water
data were provided.

Several points regarding the data tables should be  noted.   First,
Table V-3 includes some samples measured at concentrations  con-
sidered not quantifiable.  The detection limits shown on the  data
tables are not the same in all cases as the published detection
limits for these pollutants by the same analytical  methods.   The
detection limits used were reported with the  analytical  data  and
hence are the appropriate limits to apply  to  the  data.   Detection
limit variation can occur as a result of a  number of laboratory-
specific, equipment-specific, and daily operator-specific
factors.  These factors can include day-to-day differences  in
machine calibration, variation in stock solutions,  and variation
in operators.
                                25

-------
Second, the analysis of data includes some samples measured  at
concentrations considered not quantifiable.   If a pollutant  is
reported as not detected, a value of zero is  used in  calculating
the average.  Toxic metal values reported as  less than a  certain
value are considered as not quantifiable and  a value  of  zero is
used in the calculation of the average.

WASTEWATER CHARACTERISTICS AND FLOWS BY SUBDIVISION

Since primary antimony production involves two principal  sources
of wastewater and each has potentially different characteristics
and flows, the wastewater characteristics and discharge -rates
corresponding to each subdivision will be described separately.
A brief description of why the associated production  processes
generate a wastewater and explanations for variations of  water
use within each subdivision will also be discussed.

SODIUM ANTIMONATE AUTOCLAVE WASTEWATER

Sodium antimonate (NaSb03) is produced by autoclaving the
antimony-bearing solution from the leaching process with  oxygen.
The autoclave wastewater is discharged.  The  production normal-
ized water use and discharge rates for sodium antimonate  auto-
clave wastewater are given in Table V-1 in liters per metric ton
of antimony contained in sodium antimonate product.

The one company which reports this wastewater stream  did  not pro-
vide flow rate information.  It is assumed that the amount of
wastewater generated by autoclaving the leaching solution is the
same as the amount of wastewater generated by electrowinning a
solution containing the same amount of antimony.  Therefore, the
production normalized discharge flow for sodium antimonate
autoclave discharge water is assumed to be equal to that  for the
fouled anolyte using the antimony content of  the product  as  the
production normalizing parameter.

No sampling data are available for this stream, but it  is
expected to be similar in composition to the  fouled anolyte  auto-
clave discharge for which data are present in Table V-3.   The
fouled anolyte wastewater is essentially the  same as  the  sodium
antimonate autoclave wastewater except that the influent  to  the
fouled anolyte autoclave has had much of the  antimony removed.
The sodium antimonate autoclave wastewater is therefore  expected
to contain treatable concentrations of suspended solids  and  toxic
metals, including antimony, arsenic, and mercury.  Also,  EPA is
Considering the possibility that toxic organic pollutants are
present in the wastewater, because of the coke used as  a  raw
material in the smelting furnace.
                                26

-------
FOULED ANOLYTE

Antimony metal is produced by electrowinning  the  pregnant  solu-
tion from the leaching process.  Barren  electrowinning  solution
is recycled to the process by various means at  three  plants.   One
of those plants removes a portion of the barren electrolyte,
referred to as the fouled anolyte, and treats it  by autoclaving
with oxygen to recover sodium antimonate.  The  production  normal-
ized water use and discharge rates for the fouled anolyte  are
given in Table V-2 in liters per metric  ton of  antimony metal
produced by electrowinning.

No sampling data are available for this  stream, but it  is
expected to be similar in composition to the  fouled anolyte
autoclave discharge for which data are presented  in Table  V-3.
Autoclaving is used as a treatment process to remove  antimony as
sodium antimonate from the fouled anolyte, but  it is  not expected
to greatly affect other components of the wastewater.   The fouled
anolyte stream is therefore expected to  be characterized by
treatable concentrations of suspended solids  and  toxic  metals,
including antimony, arsenic, and mercury.  Also,  EPA  is con-
sidering the possibility that toxic organic pollutants  are
present in the wastewater, because of the coke  used as  a raw
material in the smelting furnace.
                               27

-------
                            Table V-1

                 WATER USE AND DISCHARGE RATE FOR
              SODIUM ANTIMONATE AUTOCLAVE WASTEWATER

    (1/kkg of antimony contained in sodium antimonate product)
                                                 Production
                                  Production     Normalized
                      Percent     Normalized     Discharge
       Plant Code     Recycle     Water Use         Flow

          1157          NR            NR           7,093*
NR = Data not reported in dcp.

*Assumed value (see Text).
                               28

-------
                            Table V-2

                 WATER USE AND DISCHARGE RATE FOR
                          FOULED ANOLYTE

       (1/kkg of antimony metal produced by electrowinning)
                                                 Production
                                  Production     Normalized
                      Percent     Normalized     Discharge
       Plant Code     Recycle     Water Use         Flow

          1159          NR           • NR           7,093
NR = Data net reported in dcp.
                              29

-------




























en
i
>

eg
rH
X>
CO
EH


























<
H
<
P

O
t-r
f-*
r- 1
rJ

^
H
z
0
S
M
EH
^^
<
OS
 W
H 
cO
rl
11
4«J
C
01
o
C
o
u
















^o

r*
cO
a


in

>
cO
Q



cO
P




cn
>
cO
Q




CM

>•
CO
P




T-.

>
cO
P



o m
CM ^~
00
CM



O CM
CM 00
*- oo


m r-
CM en O O
<- 00
r*- 1—
* «
en en


^t in
m -



o
,- v£>
• •
O CM
V r-

in
o o i—
1- r- O O
O o r^ o
W




O o o en
«— t- cr> CM
O O CM r-
V V




o
"- O
• •
O vO
V




1— •
o
•
0
V

r^
CM
•
O




,—
•
o
V


0 O
»— 1—
o o
V V




0 0

o o
V V




o
^_
•
o





r—
0
•
o





^o
m
CM
r-*



00

P^






o
m
o
o
o
•
en



O
,—
•
en
^_


in m
0 0
en en
r— ,_




in o
CM-t
en en
T™" T™




m
o
•
CM
t__




in
00
•
CM
T—






4J
C
cfl
4-1
3 co
rH 4->
^H C
O CO
CM 4-»
3
rH
rH
O
OH

O
•iH
X
O
H


>>
C
O
B
•r-l
4-1
C
CO


•
-tf
r—
T—












O
iH
C

T3 pu cO
CO O >
S-l
3
0
5-1

3
rH
rH
O
O-i

rH
cO
0 C
C 0
•iH -iH
N 4-)
C
0)
>
oo C
CM O
r- U

CO
T5
•r-l
rH
O
CO

T5
CD
TJ
C

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                            SECTION VI

                SELECTION OF POLLUTANT  PARAMETERS


Section V of this supplement presented  data from primary  antimony
sampling analyses.  This section examines  that data  and discusses
the selection or exclusion of pollutants for potential limita-
tion.

Each pollutant selected for potential limitation is  discussed in
Section VI of the General Development Document.  That discussion
provides information concerning the nature of the pollutant
(i.e., whether it is a naturally occurring substance, processed
metal, or a manufactured compound); general physical properties
and the form of the pollutant; toxic effects of the  pollutant in
humans and other animals; and behavior  of  the pollutant in POTW
at the concentrations expected in industrial discharges.

The discussion that follows presents and briefly discusses the
selection of conventional pollutants and pollutant parameters for
effluent limitations.  Also described is the analysis that was
performed to select or exclude toxic 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 concentrations used for the toxic metals were the  long-
term performance values achievable by chemical precipitation,
sedimentation, and filtration.  The treatable concentrations used
for the toxic organics were the long-term performance values
achievable by carbon adsorption (see Section VII of  the General
Development Document - Combined Metals  Data Base).

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS

This study examined samples from the primary antimony subcategory
for two conventional pollutant parameters  (total suspended solids
and pH).

CONVENTIONAL POLLUTANT PARAMETERS SELECTED

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

     total suspended solids (TSS)
     pH
                               31

-------
Nonconventional pollutant parameters were not selected for
limitation in this subcategory.

TSS concentrations ranging from 348 to 1 ,256 mg/1 were observed
in the five raw waste samples analyzed for TSS in this study.
All five concentrations were well above  the 2.6 mg/1 treatability
concentration.  Most of the specific methods used to remove  toxic
metals from a wastewater do so by converting them to precipi-
tates.  Meeting a limit on total suspended solids ensures that
removal of these precipitated toxic metals has been effective.
For this reason, total suspended solids  are selected for
limitation in this subcategory.

The'eight pH values observed during this study ranged from 12.85
to 13.40, all outs\de the 7.5 to 10.0 range considered desirable
for discharge to receiving waters.  Effective removal of toxic
metals by chemical precipitation requires careful control of pH.
Therefore, pH is selected for limitation in this subcategory.

TOXIC POLLUTANTS

The frequency of occurrence of the toxic pollutants in the raw
wastewater samples is presented in Table VI-1.  Table VI-1 is
based on the raw wastewater data provided for the fouled anolyte
autoclave discharge (see Section V).  These data provide the
basis for the categorization of specific pollutants, as discussed
below.

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*
       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*
                               32

-------
 17.  bis  (chloromethyl) ether  (DELETED)*
 18.  bis  (2-chloroethyl) ether*
 19.  2-chloroethyl vinyl ether (mixed)*
 20.  2-chloronaphthalene*
 21.  2,4,6-trichlorophenol*
 22.  parachlorometa cresol*
 23.  chloroform  (trichlorpmethane)*
 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-d ichlorophenol*
 32.  1 ,2-dichloropropane*
 33.  1,2-dichloropropylene (1,3-dichloropropene)*
 34.  2,4-dimethylphenol*
 35.  2,4-dinitrotoluene*
 36.  2,6-dinitrotoluene*
 37.  1,2-diphenylhydrazine*
 38.  ethylbenzene*
 3 9.  fluoranthene*
 40.  4-chlorophenyl phenyl ether*
 41.  4-bromophenyl phenyl ether*
 42.  bis  (2-chloroisopropyl) ether*
 43.  bis  (2-choroethoxy) methane*
 44.  methylene chloride (dichloromethane)*
 45.  methyl chloride (chloromethane)*
 46.  methyl bromide (bromomethane)*
 47.  bromoform (tribromomethane)*
 48.  dichlorobromomethane*
 49.  trichlorofluoromethane (DELETED)*
 50.  dichlorofluoromethane (DELETED)*
 51.  chlorodibromomethane*
 52.  hexachlorobutadiene*
 53.  hexachlorocyclopentadiene*
 54.  isophorone*
 55.  naphthalene*
 56.  nitrobenzene*
 57.  2-nitrophenol*
 58.  4-nitrophenol*
 59.  2,4-dinitrophenol*
 60.  4,6-dinitro-o-cresol*
 61.  N-nitrosodimethylamine*
62.  N-nitrosodiphenylamine*
 63.  N-nitrosodi-n-propylamine*
64.  pentachlorophenol*
65.  phenol*
66.  bis(2-ethylhexyl)  phthalate*
                        33

-------
 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)fluoranthane (11,12-benzofluoranthene)*
 76.   chrysene*
 77.   acenaphthylene*
 78.   anthracene*
 79.   benzo(ghi)perylene (1,11-benzoperylene)*
 80.   fluorene*
 81.   phenanthrene*
 82.   dibenzo (a,h)anthracene (1,2,5,6-dibenzanthracene)*
 83.   indeno (1,2,3-cd)pyrene (w,e,-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.   PGB-1254 (Arochlor 1254)*
108.   PCB-1221 (Arochlor 1221)*
109.   PCB-1232 (Arochlor 1232)*
110.   PCB-1248 (Arochlor 1248)*
111.   PCB-1260 (Arochlor 1260)*
112.   PCB-1016 (Arochlor 1016)*
113.   toxaphene*
116.   asbestos (Fibrous)
11 7.   beryllium*
119.   chromium (Total)*
                          34

-------
      121.  cyanide  (Total)*
      124.  nickel*
      125.  selenium*
      126.  silver*
      127.  thallium*
      129.  2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD)

*We did not analyze for these pollutants  in samples  of raw
 wastewater from this subcategory.  These pollutants are not
 believed to be present based on the Agency's best engineering
 judgement which includes consideration of raw materials and
 process operations.

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 for further consider-
ation for limitation are each discussed following the list.
     114.  antimony
     115.  arsenic
     118.  cadmium
     120.  copper
     122.  lead
     123.  mercury
     128.  zinc

Antimony was found in eight samples at concentrations ranging
from 3.7 to 120 mg/1.  All eight concentrations were above the
0.47 mg/1 concentration considered achievable by identified
treatment technology.  Therefore, antimony is selected for fur-
ther consideration for limitation in this subcategory.

Arsenic was detected in eight samples at concentrations ranging
from 260 to 3,700 mg/1.  All eight concentrations were above the
0.34 mg/1 treatability concentration.  Therefore, arsenic is
selected for further consideration for limitation.

Cadmium was detected in quantifiable concentrations in two of
eight samples (0.21  and 0.30 mg/1).  Both of these samples were
above the 0.049 mg/1 treatability concentration.  Therefore,
cadmium is selected  for further consideration for limitation.

Copper was detected  in eight samples at concentrations ranging
from 0.20 to 0.8 mg/1.  Three of those samples were above the
0.39 mg/1 treatability concentration.  Therefore, copper is
selected for further consideration for limitation.
                               35

-------
Lead was found in one of eight samples above quantification, at a
concentration of 3.05 mg/1.  That sample was above the 0.08 mg/1
treatability concentration.  Furthermore, antimony is often
recovered from lead-copper-zinc ores.  Therefore, lead is
selected for further consideration for limitation.

Mercury was detected in seven samples at concentrations ranging
from 0.015 to 12.6 mg/1.  Six of those samples were above the
0.036 mg/1 treatability concentration.  Therefore, mercury is
selected for further consideration for limitation.

Zinc was found in two of eight samples at quantifiable concentra-
tions (0.10 and 0.27 mg/1).  One of those samples was above the
0.23 mg/1 concentration considered achievable by identified
treatment technology. Furthermore, antimony is often recovered
from copper-lead-zinc ores.  Therefore, zinc is selected for
further consideration for limitation in this subcategory.
                               36

-------
                                     OOOO   CM   PI   ,- v£>
                                                                                             c
                                                                                             esi
                                                                                             O
                                                                                              i
                         "S
                                                                                        2
                                                                                        u
                                                                                             1
                                                                                             °
                                                                                             •8
                                                                    r-




                                                                    I





                                                                    1
(1)
      2
      o
H a CK!
   o w
fe SH
O M H ^
                 3   £
                •** E s    o)
                '-I 3 — I  lJ T3

                'X'P o  Q.'C
                   -
                                                           -

                                                            S !>
                                                                              co   ii    co r
                                                                              o-i    oc
                                                                             •H   ^    -^ »•

                                                                             ft   S    ^
                                                         37

-------
38

-------
                   PRIMARY ANTIMONY  SUBCATEGORY

                           SECTION VII

                CONTROL AND TREATMENT TECHNOLOGIES


The preceding sections of this supplement discussed  the  sources,
flows, and characteristics of the wastewaters  from primary anti-
mony plants.  This section summarizes the description  of these
wastewaters and indicates the treatment  technologies which are
currently practiced in the primary antimony  subcategory  for each
waste stream.  Secondly, this section presents  the control and
treatment technology options which were  examined by  the  Agency
for possible application to the primary  antimony subcategory.

CURRENT CONTROL AND TREATMENT PRACTICES

Control and treatment technologies are discussed in  general in
Section VII of the General Development Document.  The  basic prin-
ciples of these technologies and the applicability to  wastewater
similar to that found in this subcategory are  presented  there.
This section presents a summary of the control  and treatment
technologies that are currently being applied  to each  of the
sources generating wastewater in this subcategory.   As discussed
in Section V, wastewater associated with the primary antimony
subcategory is characterized by the  presence of the  toxic metal
pollutants and suspended solids.  Generally, these pollutants  are
present at concentrations above treatability.   This  analysis is
supported by the raw (untreated) wastewater  presented  in Section
V.  These wastewater streams may be  combined to allow  plants to
take advantage of economies of scale.  The options selected for
consideration for BPT, BAT, BDT, and pretreatment based  on com-
bined treatment of these compatible waste streams will be summa-
rized toward the end of this section.

SODIUM ANTIMONATE AUTOCLAVE WASTEWATER

Sodium antimonate (NaSb03> is manufactured by  autoclaving the
antimony-bearing solution from the leaching  process  with oxygen.
The autoclave wastewater is expected to  contain treatable
concentrations of suspended solids and toxic metals, and it may
also contain toxic organic pollutants.   One  plant which  manu-
factures sodium antimonate achieves  zero discharge of  this stream
using evaporation ponds.

Another plant recovers sodium antimonate for recycle to  leaching
from spent electrowinning solution by autoclaving.   That process
for product recovery is considered to be a wastewater  treatment
step and is distinguished from autoclaving to  produce  sodium
antimonate as a product.
                               39

-------
FOULED ANOLYTE

Antimony metal is produced by electrowinning the pregnant  solu-
tion from the leaching process.  All three of the plants which
practice electrowinning recycle barren electrolyte  to  leaching.
One plant reports total recycle of the spent electrowinning  solu-
tion.  The second plant spray dries the solution and recycles the
dried salts.  The third plant recycles some of the  electrolyte
but discharges the fouled anolyte portion.  That fouled anolyte
contains toxic metals and suspended solids.  Sodium antimonate  is
recovered from the stream by autoclaving, and the autoclave
wastewater is discharged to a tailings pond  where  settling
occurs before discharge to a river.

CONTROL AND TREATMENT OPTIONS

The Agency examined two control and treatment technology options
that are applicable to the primary antimony subcategory.   The
options selected for evaluation represent applicable end-of-pipe
treatment technologies.

OPTION A

The Option A treatment scheme for the primary antimony subcate-
gory consists of chemical precipitation and sedimentation  of both
waste streams.  Chemical precipitation and sedimentation consists
of lime addition to precipitate metals followed by  gravity
sedimentation for the removal of suspended solids,  including the
metal precipitates.  Vacuum filtration is used to dewater  the
sludge.

OPTION C

Option C for the primary antimony subcategory consists of  all
control and treatment requirements of Option A  (chemical precipi-
tation and sedimentation) plus multimedia filtration technology
added at the end of the Option A treatment scheme.  Multimedia
filtration is used to remove suspended solids, including precipi-
tates of toxic metals, beyond the concentration attainable by
gravity sedimentation.  The filter suggested is of  the gravity,
mixed-media type, although other filters, such as rapid  sand
filters, would perform satisfactorily.

Also, the Agency is considering the need to incorporate  some
measure of toxic organic pollutant removal under both  Options A
and C, such as activated carbon adsorption, if further investi-
gation shows a need for such measure.
                                40

-------
                   PRIMARY ANTIMONY  SUBCATEGORY

                           SECTION VIII

           COSTS, ENERGY, AND NONWATER QUALITY ASPECTS


This section presents a summary of compliance  costs  for  the
primary antimony subcategory and a description of  the  treatment
options and subcategory-specific assumptions used  to develop
these estimates.  Together with the  estimated  pollutant  removal
performance presented in Sections X  and XII of this  supplement,
these cost estimates provide a basis  for  evaluating  each 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
primary antimony subcategory.

TREATMENT OPTIONS FOR EXISTING SOURCES

As discussed in Section VII, two treatment options have  been
developed and considered in proposing limitations  and  standards
for the primary antimony subcategory.  These options are summa-
rized below and schematically presented in Figures X-1 and X-2.

OPTION A

The Option A treatment scheme consists of chemical precipitation
and sedimentation technology.

OPTION C

Option C for the primary antimony subcategory  consists of all
control and treatment requirements of Option A (chemical precipi-
tation and sedimentation) plus multimedia filtration technology
added at the end of the Option A treatment scheme.

Also, the Agency is considering the need  to incorporate  some
measure of toxic organic pollutant removal under both Options A
and C, such as activated carbon adsorption, if further investi-
gation shows a need for such measure.

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.  Plant-by-plant compliance costs have been  esti-
mated for the nonferrous metals manufacturing  category and are

-------
presented in the administrative record supporting this regula-
tion.  The costs developed for the proposed regulation are pre-
sented in Table VIII-1 for the direct dischargers in this
subcategory.

Each of the general assumptions used to develop compliance costs
is presented in Section VIII of the General Development  Document.
No subcategory-specific assumptions were used in developing  com-
pliance costs for the primary antimony subcategory.

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  anti-
mony 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 Option A  are  esti-
mated at 11,900 kWh/yr, and for Option C the estimated require-
ment is 14,600 kWh/yr.  Option C energy requirements increase
over those for Option A because filtration is being added  as an
end-of-pipe treatment technology.  The energy requirements of
both options represent less than one percent of the total  energy
presently consumed at the discharging plant.  It is, therefore,
concluded that the energy requirements of the treatment  options
considered will have no significant impact on total plant  energy
consumption.

SOLID WASTE

Sludge generated in the primary antimony subcategory is  due  to
the precipitiaton of metal hydroxides and carbonates using lime.
Sludges associated with the primary antimony subcategory will
necessarily contain quantities of toxic metal pollutants.  These
sludges are not subject to regulation as hazardous wastes  since
wastes generated by primary smelters and refiners are currently
exempt from regulation by Act of Congress (Resource Conservation
and Recovery Act (RCRA), Section 3001 (b)), as interpreted by
EPA.  If a small excess of lime is added during treatment, the
Agency does not believe these sludges would be identified  as haz-
ardous under RCRA in any case.  (Compliance costs include  this
amount of lime.)  This judgement is based on the results of
Extraction Procedure  (EP) toxicity tests performed on similar
sludges  (toxic metal-bearing sludges) generated by other indus-
tries such as the iron and steel industry.  A small amount of
                                42

-------
excess lime was added during treatment, and  the  sludges  subse-
quently generated passed the toxicty test.   See  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 Agency's view that solid  wastes generated  as a
result of these guidelines are not expected  to be hazardous,  gen-
erators 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" haz-
ardous 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 CRF 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).

It is estimated that the primary antimony subcategory  will
generate 33 .metric tons of sludge per year when  implementing  the
proposed BPT treatment technology.  The Agency has calculated as
part of the costs for wastewater treatment the cost  of hauling
and disposing of these wastes.  For more details, see  Section
VIII of the General Development Document.

AIR POLLUTION

There is no reason to believe that any substantial air pollution
problems will result from implementation of  chemical precipita-
tion, sedimentation, and multimedia filtration.  These technolo-
gies transfer pollutants to solid waste and  are not  likely  to
transfer pollutants to air.
                               43

-------
                       Table VIII-1

 COST OF COMPLIANCE FOR THE PRIMARY  ANTIMONY SUBCATEGORY

                    DIRECT DISCHARGERS

                  (March, 1982 Dollars)


                  Total Required               Total
Option             Capj-tal Cost             Annual Cost

  A                   $34,200                 $17,300

  C                   $41,250                 $21,183
                           44

-------
                   PRIMARY ANTIMONY 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 antimony  subcategory,
as well as the established performance of the  recommended BPT
systems.  Particular consideration is given to the treatment
already in place at plants within the data base.

The factors considered in identifying BPT include the total cost
of applying the technology in relation to the  effluent reduction
benefits from such application, the age of equipment and facili-
ties involved, the manufacturing processes used, nonwater quality
environmental impacts (including energy requirements), and  other
factors the Administrator considers appropriate.  In general, the
BPT level represents ,the average of the existing performances of
plants of various ages, sizes, processes, or other common charac-
teristics.  Where existing performance is uniformly  inadequate,
BPT may be transferred from a different subcategory  or category.
Limitations based on transfer of technology are supported by a
rationale concluding that the technology is, indeed, transfera-
ble, and a reasonable prediction that it will  be capable of
achieving the prescribed effluent limits (see Tanner's Council
of America v. Train. 540 F.2d 1188 (4th Cir. 1176).BPT focuses
on end-of-pipe treatment rather than process changes or internal
controls,  except where such practices are common industry
practice.

TECHNICAL APPROACH TO BPT

The Agency studied the nonferrous metals category to identify the
processes  used,  the wastewater's generated,  and the treatment pro-
cesses installed.  Information was collected from industry using
data collection portfolios,  and specific plants were sampled and
the wastewaters  analyzed.   In making technical assessments of
data,  reviewing manufacturing processes, and assessing wastewater
treatment  technology options,  both indirect and direct dis-
chargers 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.
                              45

-------
As explained in Section IV, the primary antimony subcategory has
been subdivided into two 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 two subdivisions.

For each of the subdivisions, a specific approach was  followed
for the development of BPT mass limitations.  The first  require-
ment to calculate these limitations is to account for  production
and flow variability from plant to plant.  Therefore,  a  unit of
production or production normalizing parameter  (PNP) was 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 plant within the subcategory was  then  analyzed
to determine (1) which subdivisions were present, (2)  the  spe-
cific flow rates generated for each subdivision, and  (3) the
specific production normalized flows for each subdivision.   This
analysis is discussed in detail in Section V.  Nonprocess  waste-
waters such as rainfall runoff and noncontact cooling  water are
not considered in the analysis.

Production normalized flows for each subdivision were  then ana-
lyzed to determine the flow to be used as part of the  basis for
BPT mass limitations.  The selected flow (sometimes referred to
as the BPT regulatory flow or BPT discharge rate) reflects the
water use controls which are common practices within the cate-
gory.  The BPT regulatory flow is based on the average of  all
applicable data.  Plants with normalized flows above the average
may have to implement some method of flow reduction to achieve
the BPT limitations.

The second requirement to calculate mass limitations is  the set
of concentrations that are achievable by application of  the BPT
level of treatment technology.  Section VII discusses  the  various
control and treatment technologies which are currently in  place
for each wastewater source.  In most cases throughout  the  nonfer-
rous metals manufacturing industry, 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
production - mg/kkg) were calculated by multiplying the  BPT
regulatory flow (1/kkg) by the concentration achievable  by the
BPT level of treatment technology  (mg/1) for each pollutant
parameter to be limited under BPT.  These mass  loadings  are
                                46

-------
published in the Federal Register and  in CFR Part 400 as the
effluent limitations guidelines.

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
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 combina-
tions of wastewater sources and production processes which may be
found at primary antimony plants.

The Agency usually establishes wastewater limitations in terms of
mass rather than concentration.  This  approach prevents the use
of dilution as a treatment method (except for controlling pH).
The production normalized wastewater flow (1/kkg) is a link
between the production operations and  the effluent limitations.
The pollutant discharge attributable to each operation can be
calculated from the normalized flow and effluent concentration
achievable by the treatment technology and summed to derive an
appropriate limitation for each plant.

INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES

In balancing costs in relation to pollutant removal estimates,
EPA considers the volume and nature of existing discharges, the
volume and nature of discharges expected after application of
BPT,  the general environmental effects of the pollutants, and the
cost and economic impacts of the required pollution control
level.  The Act does not require or permit consideration of water
quality problems attributable to particular point sources or
industries,  or water quality improvements in particular water
quality bodies.  Accordingly, water quality considerations were
not the basis for selecting the proposed BPT.  See Weyerhaeuser
Company v. Costle. 590 F.2d 1011 (D.C. Cir. 1978).

The methodology for calculating pollutant removal estimates and
plant compliance costs is discussed in Section X.  Table X-1
shows the pollutant removal estimates  for each treatment option
for direct dischargers.  Compliance costs for direct dischargers
are presented in Table X-2.

BPT OPTION SELECTION

The technology basis for the BPT limitations is Option A, chemi-
cal precipitation and sedimentation technology to remove metals
and solids from combined wastewaters and to control pH.  These
technologies are not in-place at the one discharger in this
                               47

-------
subcategory.  The BPT treatment scheme  is presented  in  Figure
IX-1.  The Agency is also considering the possibility of  requir-
ing activated carbon adsorption as an effluent polishing  step  to
control the discharge of toxic organic  pollutants.   Toxic organic
pollutants may be present due to the coke used as  a  raw material
in the smelting furnace.

Implementation of the proposed BPT limitations will  remove
annually an estimated 2,642 kg of toxic metals and 965  kg of TSS
over estimated current discharge, which is equal to  the raw waste
generated because no treatment is in-place.  The Agency projects
a capital cost of approximately $34,200 and an annualized cost of
approximately $17,300 for achieving proposed BPT.

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 data collection portfolios.  The  discharge rate
is used with the achievable treatment concentrations to determine
BPT effluent limitations.  Since the discharge rate  may be dif-
ferent for each wastewater source, separate production  normalized
discharge rates for each of the two wastewater sources  are dis-
cussed 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 product which  is produced  by
the process associated with the waste stream in question.  These
production normalizing parameters, or PNPs, are also listed in
Table IX-1.

Section V of this document further describes the discharge flow
rates and presents the water use and discharge flow  rates for
each plant by subdivision in Tables V-1 and V-2.

SODIUM ANTIMONATE AUTOCLAVE WASTEWATER

The BPT wastewater discharge allowance  for sodium  antimonate
autoclave wastewater is 7,093 1/kkg  (1,704 gal/ton)  of  antimony
contained in sodium antimonate product. This rate is allocated
to any plant which produces sodium antimonate from a pregnant
leaching solution by an autoclaving operation.  No allowance is
given when sodium antimonate is recovered for recycling by
autoclaving fouled anolyte because in that case, autoclaving is
considered to be a wastewater treatment step for product
recovery.

No recycle or reuse of this wastewater  is reported at the one
plant that generates this stream.  Because that plant did not
provide flow rate information in the dcp, the BPT  discharge
allowance for sodium antimonate autoclave wastewater was  assumed
                                48

-------
to be equal to the BPT discharge allowance  for  fouled  anolyte
using the antimony content of the product as  the  production  nor-
malizing parameter.

FOULED ANOLYTE

The BPT wastewater discharge allowance  for  fouled anolyte  is
7,093 1/kkg (1,704 gal/ton) of antimony metal produced by  elec-
trowinning.  This rate is allocated  to  any  plant  which recovers
antimony by electrowinning it from a pregnant leaching solution.
The BPT allowance is based on the discharge rate  at  the only
plant that reported this stream.  That  plant  recycles  some of  the
spent electrowinnning solution, but  did not provide  flow rate
information for the recycled stream.  That  plant  also  recovers
and recycles sodium antimonate from  the fouled  anolyte before
disposal.

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
is presented in Sections VI and X.   A total of  six pollutants  or
pollutant parameters are selected for limitation  under BPT and
are listed below:

     114.  antimony
     115.  arsenic
     122.  lead
     123.  mercury
           TSS
           pH

EFFLUENT LIMITATIONS

The treatable concentrations achievable by  application of  the
proposed BPT are discussed in Section VII of  the  General Develop-
ment Document and summarized there in Table VII-19.  These treat-
able concentrations (both one-day maximum and monthly  average
values) are multiplied by the BPT normalized discharge flows
summarized in Table IX-1 to calculate the mass  of pollutants
allowed to be discharged per mass of product.   The results of
these calculations in milligrams of  pollutant per kilogram of
product represent the BPT effluent limitations  and are presented
in Table IX-2 for each individual waste stream.
                               49

-------
                            Table IX-1

              BPT WASTEWATER DISCHARGE RATES FOR THE
                   PRIMARY ANTIMONY SUBCATEGORY
   Wastewater Stream

Sodium antimonate auto-
clave wastewater
Fouled anolyte
 BPT Normalized
 Discharge Rate
1/kkg    gal/ton
7,093
7,093
1 ,704
1 ,704
    Production
    Normalized
    Parameter

Antimony contained
in sodium antimon-
ate product

Antimony metal
produced by elec-
trowinning
                               50

-------
                            Table  IX-2

                   BPT MASS LIMITATIONS FOR THE
                   PRIMARY ANTIMONY SUBCATEGORY
(a)  Sodium Antimonate Autoclave Wastewater

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

    mg/kg (Ib/million Ibs) of antimony contained in
               sodium antimonate product

Antimony                 20.360             9.079
Arsenic                  14.820             6.596
Lead                      2.979             1.419
Mercury                   1.773             0.709
Total suspended         290.800           138.300
  solids
pH                     Within the range of 7.5 to 10.0
                                at all times
(b)  Fouled Anolyte

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

   tug/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                 20.360             9.079
Arsenic                  14.820             6.596
Lead                      2.979             1.419
Mercury                   1.773             0.709
Total suspended         290.800           138.300
  solids
pH              •       Within the range of 7.5 to 10.0
                                at all times
                               51

-------
                                                     o
                                                     o
                                                     td

                                                     S
                                                     u
                                                     CQ
                                                     a
                                                     CO
                                                     55

                                                     i
                                                     I— I
                                                     H
                                                     w
                                                     PC
                                                     oi
                                                     W

                                                     35
                                                     w


                                                     I
                                                     w
                                                     Pi
                                                     H

                                                     H
                                                     CU
                                                     PQ
52

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                            SECTION X

        BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE


The effluent limitations which must be achieved by July 1, 1984
are based on the best control and treatment technology used by a
specific point source within the industrial category or subcate-
gory, or by another industry where it is readily transferable.
Emphasis is placed on additional treatment techniques applied at
the end of the treatment systems currently used, as well as
reduction of the amount of water used and discharged, process
control, and treatment technology optimization.

The factors considered in assessing best available technology
economically achievable (BAT) include the age of equipment and
facilities involved, the process used, process changes, nonwater
quality environmental impacts (including energy requirements),
and the costs of application of such technology (Section 304(b)
(2)(B) of the Clean Water Act).  At a minimum, BAT represents the
best available technology economically achievable at plants of
various ages, sizes, processes, or other characteristics.  Where
the Agency has found the existing performance to be uniformly
inadequate, BAT may be transferred from a different subcategory
or category.  BAT may include feasible process changes or
internal controls, even when not in common industry practice.

The required assessment of BAT considers costs, but does not
require a balancing of costs against pollutant removals (see
Weyerhaeuser v. Costle. 11  ERG 2149 (D.C. Cir. 1978)).  However,
in assessing the proposed BAT, the Agency has given substantial
weight to the economic achievability of the technology.

TECHNICAL APPROACH TO BAT

The Agency reviewed a wide range of technology options and evalu-
ated the available possibilities to ensure that the most effec-
tive and beneficial technologies were used as the basis of BAT.
To accomplish this, the Agency elected to examine two technology
options which could be applied to the primary antimony 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
                              53

-------
effectiveness achievable with the more sophisticated BAT  treat-
ment technology.

The treatment technologies considered for BAT are summarized
below:

Option A (Figure X-1):

     •  Chemical precipitation and sedimentation

Option C (Figure X-2):

     •  Chemical precipitation and sedimentation
     •  Multimedia filtration

The two options examined for BAT are discussed  in greater detail
below.   The first option considered (Option A) is  the  same as
the BPT treatment and control technology which  was  presented  in
the previous section.  The second option represents substantial
progress toward the reduction of pollutant discharges above and
beyond the progress achievable by BPT.

OPTION A

Option A for the primary antimony subcategory is equivalent to
the control and treatment technologies^ which were analyzed for
BPT in Section IX (see Figure X-1).  The BPT end-of-pipe  treat-
ment scheme includes chemical precipitation .and sedimentation
(see Figure IX-1).  The discharge rates for Option  A are  equal to
the discharge rates allocated to each stream as a BPT discharge
flow.  As discussed earlier, EPA is also considering the  possi-
bility of activated carbon adsorption for controlling toxic
organic pollutants.

OPTION C

Option C for the primary antimony subcategory consists  of all
control and treatment requirements of Option A  (chemical  precipi-
tation and sedimentation) plus multimedia filtration technology
added at the end of the Option A treatment scheme  (see  Figure
X-2).  Multimedia filtration is used to remove  suspended  solids,
including precipitates of toxic metals, beyond  the  concentrations
attainable 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.  As discussed earlier, EPA is also  considering
the possibility of activated carbon adsorption  for  controlling
toxic organic pollutants.
                                54

-------
INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES

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

POLLUTANT REMOVAL ESTIMATES

A complete description of the methodology used to  calculate the
estimated pollutant removal achieved by the  application of the
various treatment options is presented in Section  X of the
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 normalized  for  each
unit operation (i.e., mass of pollutant generated  per  mass of
product manufactured).  This value, referred to  as  the raw waste,
was used to estimate the mass of toxic pollutants  generated
within the primary antimony subcategory.  The pollutant removal
estimates were calculated for each plant by  first  estimating  the
total mass of each pollutant in the untreated wastewater.   This
was calculated by first multiplying the raw  waste  values by the
corresponding production value for that stream and  them summing
these values for each pollutant for every stream generated by the
plant.

Next, the volume of wastewater discharged after  the application
of each treatment option was estimated for each  operation  at  each
plant by comparing the actual discharge to the regulatory  flow.
The smaller of the two values was selected and summed  with the
other plant flows.  The mass of pollutant discharged was then
estimated by multiplying the achievable concentration  values
attainable with the option (mg/1) by the estimated  volume  of
process wastewater discharged by the subcategory.   The mass of
pollutant removed is the difference between  the  estimated  mass  of
pollutant generated within the subcategory and the  mass of pollu-
tant discharged after application of the treatment  option.  The
pollutant removal estimates for direct dischargers  in  the  primary
antimony subcategory are presented in Table  X-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
                                55

-------
discussed above, this flow is either the actual or the BAT regu-
latory flow, whichever is lesser.  The final step was to annual-
ize the capital costs, and to sum the annual!zed capital costs,
and the operating and maintenance costs for each plant, yielding
the cost of compliance for the subcategory.  The compliance  costs
associated with the various options are presented in Table X-2
for direct discharges in the primary antimony subcategory.   These
costs were used in assessing economic achievability.

BAT OPTION SELECTION

EPA has selected Option C which includes chemical precipitation,
sedimentation, and multimedia filtration.  The estimated capital
cost of proposed BAT is 41,250 dollars (1982 dollars) and the
annual cost is 21,183 dollars (1982 dollars).  The end-of-pipe
treatment configuration for Option C is presented in Figure  X-2.
As discussed earlier, EPA is also considering the possibility of
activated carbon adsorption for controlling toxic organic
pollutants.

EPA is proposing multimedia filtration as part of the BAT techno-
logy because this technology results in additional removal of
toxic metals.  Filtration is also presently demonstrated at  25
plants throughout the nonferrous metals manufacturing category.
Filtration adds reliability to the treatment system by making it
less susceptible to operator error and to sudden changes in  raw
wastewater flow and concentrations.

Implementation of the control and treatment technologies of
Option C would remove annually an estimated 2,644 kilograms  of
toxic metal pollutants, which is 1.3 kilograms of toxic metal
pollutants over the estimated BPT removal.

WASTEWATER DISCHARGE RATES

A BAT discharge rate was calculated for each subdivision based
upon the flows of the existing plants, as determined from analy-
sis of the data collection portfolios.  The discharge rate is
used with the achievable treatment concentrations to determine
BAT effluent limitations.  Since the discharge rate may be dif-
ferent for each wastewater source, separate production normalized
discharge rates for each of the two wastewater sources were
determined and are summarized in Table X-3.  The discharge rates
are normalized on a production basis by relating the amount  of
wastewater generated to the mass of product which is produced by
the process associated with the waste stream in question.  These
production normalizing parameters, or PNPs, are also listed  in
Table X-3.
                               56

-------
The BAT discharge rates reflect no flow reduction  requirements  as
compared to the BPT option flows.  In-process  flow reduction  was
not considered achievable for any waste streams  in this  subcate-
gory.  Consequently, the BAT and BPT production  normalized
discharge flows are identical.

REGULATED POLLUTANT PARAMETERS

In implementing the terms of the Consent Agreement in  NRDC  v.
Train, Op. Cit., and 33 U. S.C. 1314(b)(2)(A and  B)  (197577  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 seven toxic pollutants  selected  for
further consideration in this analysis.

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 removal analysis.  The
pollutants selected for specific limitation are  listed below:

     11 4.  antimony
     11 5.  arsenic
     122.  lead
     123.  mercury

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
multiple metals removal.  Thus, even though metals have  somewhat
different theoretical solubilities, they will  be removed at very
nearly the same rate in a chemical precipitation and sedimenta-
tion treatment system operated for multiple metals removal.
Filtration as part of the technology basis is  likewise justified
because this technology removes metals non-preferentially.
                               57

-------
The toxic metal pollutants selected for specific limitation  in
the primary antimony subcategory to control the discharges of
toxic metal pollutants are antimony, arsenic, lead, and mercury.
The following toxic metal pollutants are excluded from limitation
on the basis that they are effectively controlled by the  limita-
tions developed for antimony, arsenic, lead, and mercury;

     118.  cadmium
     120.  copper
     128.  zinc

EFFLUENT LIMITATIONS

The concentrations, achievable by application of BAT are discussed
in Section VII of the General Development Document and summarized
there in Table VII-19.  The treatable concentrations both one day
maximum and monthly average values are multiplied by the  BAT nor-
malized discharge flows summarized in Table X-3 to calculate the
mass of pollutants allowed to be discharged per mass of product.
The results of these calculations in milligrams of pollutant per
kilogram of product represent the BAT effluent limitations and
are presented in Table X-4 for each waste stream.
                                58

-------
        < PM
 e 

U £ 01
 Cu SI
O «
                                          GO ON
                                          r-~ oo
                                          in PO
                                so rs|
                                i— ro
                                CM oo
-*    p-
in    •—
co    r-
                                                             -a-
                                                             vO
                                                             CO
                  so
                  co
oo
in
            CMvOOOOCMOCOsOOOOO'-
            m vo         <—
               m
                                                                                           O
                                                                                           oo
                                                                   0
                                                                   oo
                                                                                                       CM
                                                                                                       so
 O J=-
-I  O
 u  in,

(§"0'
      o
      m
                                                             o
                                                             m
                                                                   o
                                                                   m
                                                                                                       o
                                                                                                       oo
                                          O O O
                                                                             o O
 O. SI ^
O OS ^"^
                                          -a- oo
                                          00 OS
                                          .- 0
                    vO
                    O
                          in
                          vO
                          CM    r- P-.
en    in

^-    fi
                                                                        CM
                                                                        m
                                          m to
                                             m
                                                              m vo o o O o —
                                                                                           -a-
                                                                                           vO
                                                                   -s-
                                                                   vO
                                                                         O
                                                                         vO
X

 0)
                                  01
                              <  OO
                                  I-
                               c      O o
                    —    (T.    CM ^
in
vO
m
           •-ooooooooooooo
CM


O


•*'
                                                             vO
                                                             C1
                                                             in
                 vO
                 m
                 in
oo
o
vO
                                                             o
                                                             CM
                                                                   o
                                                                   CM
        d
        o
        P-.





4-)
C
18
4J
3
r-H
i— 1
O
OH














C
O
E
.**
.u
C
<











U
•«H
B
,'e
l-i T3
01 0)
CO U




t— (
m
4J
o
•U
N^*

E
*v>4
E
O
Id
j:
u




/— s.
1—\
*B
U
O
4J
s^x-
SI
u -o
01 •-<
D. C "O
O. CO CO
0X4)
O OiJ











^
in r-l
3 0)
U J4
lJ U
0) -H
zz











1
1-1 >J
C 01
01 >
rH i-<
01 1H
CO CO











E
lp^
r-l
r-l U
CO C
H N







CO
o

X
o
H

t ^
^
H
O
H
CO
-J
<
z
0

H
Z
w
^
z
s

J

CO H
CO O
H H



CO
H

<3
H
3

J
O
OH

^
^
s
H
                                                                        59

-------
                        Table X-2

 COST OF COMPLIANCE FOR THE PRIMARY  ANTIMONY  SUBCATEGORY

                    DIRECT DISCHARGERS


                   Total Required                 Total
                    Capital Cost              Annual Cost
Option             (1982 Dollars)             (1982  Dollars)

  A                   $34,200                   $17,300

  C                   $41,250                   $21,183
                          60

-------
                            Table X-3

              BAT WASTEWATER DISCHARGE RATES FOR THE
                   PRIMARY ANTIMONY SUBCATEGORY
   Wastewater Stream

Sodium antimonate auto-
clave wastewater
Fouled anolyte
 BAT Normalized
 Discharge Rate
1/kkg    gal/ton
7,093
7,093
1 ,704
1 ,704
    Production
    Normalized
    Parameter

Antimony contained
in sodium antimon-
ate product

Antimony metal
produced by elec-
trowinning
                               61

-------
                            Table X-4

                   BAT MASS LIMITATIONS FOR THE
                   PRIMARY ANTIMONY SUBCATEGORY
(a)  Sodium Antimonate Autoclave Wastewater

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

    mg/kg (Ib/million Ibs) of antimony contained in
               sodium antimonate product

Antimony                  13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
(b)  Fouled Anolyte

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

   mg/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                  13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
                                62

-------
n
                                                                   X

                                                                    
-------
O-
                                                    CM
                                                     I
                                                    X

                                                     01
                                                     S-i
                                                     3
                                                     oc
                                                         z
                                                         a
                                                         t-t
                                                         H
                                                         eu
                                                         o
W .
                                                         H
                                                         a
                                                         w
                                                         PQ
           64

-------
                    PRIMARY ANTIMONY SUBCATEGORY

                             SECTION XI

                 NEW  SOURCE  PERFORMANCE  STANDARDS


The basis  for new source performance standards  (NSPS)  under Sec-
tion 306 of  the Act is  the best  available  demonstrated technology
(BDT).  New  plants  have the  opportunity  to design  the  best  and
most efficient production processes and  wastewater treatment
technologies without  facing  the  added costs  and restrictions
encountered  in retrofitting  an existing  plant.   Therefore,  Con-
gress directed EPA  to consider the  best  demonstrated process
changes, in-plant controls,  and  end-of-pipe  treatment  technolo-
gies which reduce pollution  to the  maximum extent  feasible.

This section describes  the technologies  for  treatment  of waste-
water from new sources  and presents mass discharge standards for
regulatory pollutants for NSPS in the primary antimony subcate-
gory, based  on the  selected  treatment technology.

TECHNICAL APPROACH  TO NSPS

New source performance  standards are equivalent to the best
available technology  (BAT) selected for  currently  existing  pri-
mary antimony plants.   This  result  is a  consequence of careful
review by the Agency of a wide range of  technology options  for
new source treatment  systems which  is discussed in Section  IX of
the General Development Document.   This  review  of  the  primary
antimony subcategory found no new,  economically feasible, demon-
strated technologies which could be considered  an  improvement
over those chosen for consideration for  BAT.  Additionally,  there
was nothing found to indicate that  the wastewater  flows and  char-
acteristics of new  plants would not be similar  to  those from
existing plants, since the processes used  by new sources are not
expected to differ  from those used  at existing  sources.  Conse-
quently, BAT production normalized  discharge rates, which are
based on the best existing practices of  the  subcategory, can also
be applied to new sources.  These rates  are presented  in Table
XI-1.

Treatment technologies considered for the  NSPS  options  are  iden-
tical to the treatment technologies  considered  for the  BAT
options.  These options are:

OPTION A

     •  Chemical precipitation and  sedimentation
                               65

-------
OPTION C

     •  Chemical precipitation and sedimentation
     •  Multimedia filtration

NSPS OPTION SELECTION

EPA is proposing that the best available demonstrated  technology
for the primary antimony subcategory be equivalent  to  Option  C
(chemical precipitation, sedimentation, and multimedia filtra-
tion) .  This technology is demonstrated by 25 plants in  the
nonferrous metals manufacturing category.  As discussed  earlier,
EPA is also considering the possibility of activated carbon
adsorption as an effluent polishing step to control the  discharge
of toxic organic pollutants.

The wastewater flow rates for NSPS are the same as  the BAT flow
rates.  A review of the industry indicates that no new demon-
strated technologies that improve on BAT technology exist.  EPA
does not believe that new plants could achieve any  flow reduction
beyond the allowances proposed for BAT, therefore,  the NSPS
allowances are equal to those for BAT.

REGULATED POLLUTANT PARAMETERS

The Agency has no reason to believe that the pollutants  that  will
be found in treatable concentrations in proceses 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 Sec-
tions VI and X, are identical to those selected for BAT.   The
conventional pollutant parameters TSS and pH are also  selected
for limitation.

NEW SOURCE PERFORMANCE STANDARDS

The NSPS discharge flows for each wastewater source are the same
as the discharge rates for BAT and are shown in Table  XI-1.   The
mass of pollutant allowed to be discharged per mass of product is
based on the product of the appropriate treatable concentration
(mg/1) and the production normalized wastewater discharge  flows
(1/kkg).  The treatable concentrations are listed in Table VII-19
of the General Development Document.  The results of these cal-
culations are the production-based new source performance  stan-
dards.  These standards are presented in Table XI-2, in
milligrams of pollutant per kilogram of product.
                                66

-------
                            Table XI-1

             NSPS WASTEWATER DISCHARGE RATES FOR THE
                   PRIMARY ANTIMONY SUBCATEGORY
   Wastewater Stream

Sodium antimonate auto-
clave wastewater
Fouled anolyte
NSPS Normalized
 Discharge Rate
1/kkg    gal/ton
7,093
7,093
1 ,704
1 ,704
    Production
    Normalized
    Parameter

Antimony contained
in sodium antimon-
ate product

Antimony metal
produced by elec-
trowinning
                              67

-------
                            Table XI-2

            NSPS FOR THE PRIMARY ANTIMONY SUBCATEGORY


(a)  Sodium Antimonate Autoclave Wastewater

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

    rag/kg (Ib/million Ibs) of antimony contained in
               sodium antimonate product

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
Total suspended         106.400            85.120
  solids
pH                     Within the range of 7.5 to 10.0
                                at all times


(b)  Fouled Anolyte

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

   mg/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
Total suspended         106.400            85.120
  solids
pH                     Within the range of 7.5 to 10.0
                                at all times
                               68

-------
                   PRIMARY ANTIMONY 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, inlcuding 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.

Pretreatment standards for existing sources (PSES) will not be
proposed for the primary antimony subcategory because there are
no existing indirect dischargers in this subcategory.  However,
pretreatment standards for new sources (PSNS) will be proposed.

This section describes the control and treatment technologies for
pretreatment of process wastewaters from new sources in the pri-
mary antimony subcategory.  Pretreatment standards for regulated
pollutants are presented based on the selected control and treat-
ment 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
                               69

-------
treatment requirements, is less than  the percentage removed  by
direct dischargers complying with BAT effluent limitations guide-
lines for that pollutant.  (See generally, 46 FR at 9415-16
(January 28, 1981)).

This definition of pass through satisfies two competing objec-
tives set by Congress:  (1) that standards for indirect dis-
chargers be equivalent to standards for direct dischargers while
at the same time, (2) that the treatment capability and perfor-
mance of the POTW be recognized and taken into account in regu-
lating the discharge of pollutants from indirect dischargers.

The Agency compares percentage removal rather than the mass  or
concentration of pollutants discharged because the latter would
not take into account the mass of pollutants discharged to the
POTW from non-industrial sources 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.

PRETREATMENT STANDARDS FOR NEW SOURCES

Options for pretreatment of wastewaters from new sources are
based on increasing the effectiveness of end-of-pipe treatment
technologies.  All in-plant changes and applicable end-of-pipe
treatment processes have been discussed previously in Sections X
and XI.  The options for PSNS, therefore, are the same as the BAT
options discussed in Section X.

A description of each option is presented in Section X, while a
more detailed discussion, including pollutants controlled by each
treatment process is presented in Section VII of the General
Development Document.

Treatment technologies considered for the PSNS options are:

OPTION A

     •  Chemical precipitation and sedimentation

OPTION C

     •  Chemical precipitation and sedimentation
     •  Multimedia filtration

PSNS OPTION SELECTION

Option C (chemical precipitation, sedimentation, and multimedia
filtration) has been selected as the  regulatory approach for
pretreatment standards for new sources on the basis that it
                               70

-------
achieves effective removal of toxic pollutants  and  is  demon-
strated by 25 plants throughout the nonferrous  metals  manufac-
turing category.  As discussed earlier,  EPA  is  considering the
possible addition of activated carbon adsorption  for the  control
of toxic organic pollutants.

The wastewater discharge rates for PSNS  are  identical  to  the BAT
discharge rates for each waste stream.   The  PSNS  discharge rates
are shown in Table XII-1.  No additional flow reduction measures
for PSNS are feasible; EPA does not believe  that  new plants could
achieve flow reduction beyond the allowances  proposed  for BAT.

REGULATED POLLUTANT PARAMETERS

Pollutants selected for limitation, in accordance with the ratio-
nale of Sections VI and X, are identical to  those selected for
limitation for BAT.  It is necessary to  propose PSNS to prevent
the pass-through of antimony, arsenic, lead,  and  mercury,  which
are the limited pollutants.

PRETREATMENT STANDARDS FOR NEW SOURCES

Pretreatment standards for new sources are based  on the treatable
concentrations from the selected treatment technology, (Option
C), and the discharge rates determined in Section X for BAT.   A
mass of pollutant per mass of product (mg/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 BAT are identical to  those for PSNS.   These
concentrations are listed in Table VII-19 of  the  General
Development Document.  PSNS is presented in  Table XII-2.
                               71

-------
                           Table XII-1

             PSNS WASTEWATER DISCHARGE RATES FOR THE
                   PRIMARY ANTIMONY SUBCATEGORY
   Wastewater Stream

Sodium antimonate auto-
clave wastewater
Fouled anolyte
PSNS Normalized
 Discharge Rate
1/kkggal/ton
7,093
7,093
1 ,704
1 ,704
    Production
    Normalized
    Parameter

Antimony contained
in sodium antimon-
ate product

Antimony metal
produced by elec-
trowinning
                               72

-------
                           Table XII-2

            PSNS FOR THE PRIMARY ANTIMONY SUBCATEGORY


(a)  Sodium Antimonate Autoclave Wastewater

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

    mg/kg (Ib/million Ibs) of antimony contained in
               sodium antimonate product

Antimony                 13.690    •         6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426


(b)  Fouled Anolyte

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

   mg/kg (Ib/million Ibs) of antimony metal produced
                   by electrowinning

Antimony                 13.690             6.100
Arsenic                   9.859             4.398
Lead                      1.986             0.922
Mercury                   1.064             0.426
                               73

-------
74

-------
                   PRIMARY ANTIMONY SUBCATEGORY

                           SECTION XIII

          BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY
EPA is not proposing best conventional pollutant control technol-
ogy (BCT) for the primary antimony subcategory at this time.
                               75

-------