United States         Effluent Guidelines Division     EPA-440/1-84/019-b
Environmental Protection     WH-552           July 1984
Agency           Washington, D.C. 20460  A Af\A r\ A r\
Water and Waste Management             ^T^fU I O^rU I b/DO

Development          Proposed
Document for
Effluent Limitations
Guidelines and
Standards for the

Nonferrous Metals

Point Source Category
Phase II
Supplemental Development
Document For:

Secondary Uranium

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                  DEVELOPMENT DOCUMENT

                          for

    EFFLUENT LIMITATIONS  GUIDELINES AND STANDARDS

                        for  the
                                -*.

NONFERROUS METALS MANUFACTURING POINT SOURCE CATEGORY

                        PHASE II

             Secondary  Uranium  Supplement
                     Jack  E.  Ravan
          Assistant  Administrator for Water
                    Edwin  L.  Johnson
                        Director
      Office of Water  Regulations and Standards
                                     US. Fr-ylronrrenta! Protection Agency
              Jeffery  D.  Denit,  Director
             Effluent  Guidelines Division
              Ernst  P.  Hall,  P.E.,  Chief
             Metals  and Machinery Branch
                James  R.  Berlow,  P.E.
              Technical  Project Officer
                       July  1984
         U.S. Environmental  Protection Agency
                    Office  of Water
      Office of Water  Regulations and Standards
             Effluent  Guidelines Division
               Washington,  D.C.   20460

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U,S. EwfeonmciTts! Protection Agency

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                  SECONDARY URANIUM SUBCATEGORY

                        TABLE OF CONTENTS


Section                                                     Page

I         SUMMARY AND CONCLUSIONS	      1

II        RECOMMENDATIONS	      3

          BPT MASS LIMITATIONS FOR THE SECONDARY
          URANIUM SUBCATEGORY	      3
          BAT MASS LIMITATIONS FOR THE SECONDARY
          URANIUM SUBCATEGORY	      7
          NSPS FOR THE SECONDARY URANIUM SUBCATEGORY ...     10
          PSNS FOR THE SECONDARY URANIUM SUBCATEGORY ...     13

III       INDUSTRY PROFILE 	     17

          DESCRIPTION OF SECONDARY URANIUM PRODUCTION.  .  .     17
          RAW MATERIALS	     17
          URANIUM TETRAFLUORIDE PRODUCTION 	     18
          MAGNESIUM REDUCTION PROCESS	     18
          PROCESS WASTEWATER SOURCES 	     19
          OTHER WASTEWATER SOURCES 	     19
          AGE, PRODUCTION, AND PROCESS PROFILE 	     19

IV        SUBCATEGORIZATION	     27

          FACTORS CONSIDERED IN SUBCATEGORIZATION	     27
          FACTORS CONSIDERED IN SUBDIVIDING THE
          SECONDARY URANIUM SUBCATEGORY	     28
          OTHER FACTORS	     29
          PRODUCTION NORMALIZING PARAMETERS	     29

V         WATER USE AND WASTEWATER CHARACTERISTICS ....     31

          WASTEWATER FLOW RATES	     32
          WASTEWATER CHARACTERISTICS DATA	     33
          DATA COLLECTION PORTFOLIOS 	     33
          FIELD SAMPLING DATA	     33
          WASTEWATER CHARACTERISTICS AND FLOWS BY
          SUBDIVISION	     34
          REFINERY FILTRATE	     34
          SLAG LEACH SLURRY	     35
          SOLVENT EXTRACTION RAFFINATE 	     35
          DIGESTION OPERATION WET AIR POLLUTION CONTROL.  .     36
          EVAPORATION AND CALCINATION WET AIR POLLUTION
          CONTROL	     36
          HYDROGEN REDUCTION AND HYDROFLUORINATION KOH
          WET AIR POLLUTION CONTROL	     37
          HYDROFLUORINATION WET AIR POLLUTION CONTROL.  .  .     37

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                  SECONDARY URANIUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)


Section                                                     Page

VI        SELECTION OF POLLUTANT PARAMETERS	    49

          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS	    49
          CONVENTIONAL AND NONCONVENTIONAL POLLUTANT
          PARAMETERS SELECTED	    49
          TOXIC POLLUTANTS	    51
          TOXIC POLLUTANTS NEVER DETECTED	    51
          TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR
          ANALYTICAL QUANTIFICATION CONCENTRATION	    54
          TOXIC POLLUTANTS PRESENT BELOW CONCENTRATIONS
          ACHIEVABLE BY TREATMENT	    54
          TOXIC POLLUTANTS SELECTED FOR FURTHER
          CONSIDERATION IN ESTABLISHING LIMITATIONS
          AND STANDARDS	    54

VII       CONTROL AND TREATMENT TECHNOLOGIES 	    57

          CURRENT CONTROL AND TREATMENT PRACTICES	    57
          REFINERY FILTRATE	    57
          SLAG LEACH SLURRY	    58
          SOLVENT EXTRACTION RAFFINATE 	    58
          DIGESTION OPERATION WET AIR POLLUTION CONTROL.  .    58
          EVAPORATION AND CALCINATION WET AIR  POLLUTION
          CONTROL	    58
          HYDROGEN REDUCTION AND HYDROFLUORINATION KOH
          WET AIR POLLUTION CONTROL	    59
          HYDROFLUORINATION WET AIR POLLUTION  CONTROL.  .  .    59
          CONTROL AND TREATMENT OPTIONS	    59
          OPTION A	    59
          OPTION C	    60

VIII      COSTS, ENERGY, AND NONWATER QUALITY  ASPECTS.  .  .    61

          TREATMENT OPTIONS FOR EXISTING SOURCES 	    61
          OPTION A	    61
          OPTION C	    61
          COST METHODOLOGY	    61
          NONWATER QUALITY ASPECTS 	    62
          ENERGY REQUIREMENTS	    62
          SOLID WASTE	    62
          AIR POLLUTION	    64
                                ii

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Section
                  SECONDARY URANIUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
IX        BEST PRACTICABLE CONTROL TECHNOLOGY CURRENTLY
          AVAILABLE	     67

          TECHNICAL APPROACH TO BPT	     67
          INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES.  .     69
          BPT OPTION SELECTION 	     69
          WASTEWATER DISCHARGE RATES 	     71
          REFINERY FILTRATE	     71
          SLAG LEACH SLURRY	     71
          SOLVENT EXTRACTION RAFFINATE  	     71
          DIGESTION OPERATION WET AIR POLLUTION CONTROL.  .     72
          EVAPORATION AND CALCINATION WET AIR POLLUTION
          CONTROL	     72
          HYDROGEN REDUCTION AND HYDROFLUORINATION KOH
          WET AIR POLLUTION CONTROL	     72
          HYDROFLUORINATION WET AIR POLLUTION CONTROL. .  .     73
          REGULATED POLLUTANT PARAMETERS 	     73
          EFFLUENT LIMITATIONS 	     73

X         BEST AVAILABLE TECHNOLOGY ECONOMICALLY
          ACHIEVABLE	     81

          TECHNICAL APPROACH TO BAT	     81
          OPTION A	     82
          OPTION C	     82
          INDUSTRY COST AND POLLUTANT REMOVAL ESTIMATES.  .     83
          POLLUTANT REMOVAL ESTIMATES	     83
          COMPLIANCE COSTS 	     83
          BAT OPTION SELECTION 	     84
          WASTEWATER DISCHARGE RATES 	     84
          REGULATED POLLUTANT PARAMETERS 	     85
          EFFLUENT LIMITATIONS 	     86

XI        NEW SOURCE PERFORMANCE STANDARDS 	     95

          TECHNICAL APPROACH TO NSPS	     95
          OPTION A	     96
          OPTION C	     96
          NSPS OPTION SELECTION	     96
          REGULATED POLLUTANT PARAMETERS 	     96
          NEW SOURCE PERFORMANCE STANDARDS 	     97
                               iii

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                  SECONDARY URANIUM SUBCATEGORY

                  TABLE OF CONTENTS (Continued)
Section

XII       PRETREATMENT STANDARDS
          TECHNICAL APPROACH TO PRETREATMENT . .
          PRETREATMENT STANDARDS FOR NEW SOURCES
          OPTION A 	
          OPTION C 	
          PSNS OPTION SECTION	
          REGULATED POLLUTANT PARAMETERS ....
          PRETREATMENT STANDARDS FOR NEW SOURCES
XIII      BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY .   111
                                iv

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                  SECONDARY URANIUM SUBCATEGORY

                          LIST OF TABLES


Number                                                      Page

III-1     INITIAL OPERATING YEAR (RANGE) SUMMARY OF
          PLANTS IN THE SECONDARY URANIUM SUBCATEGORY
          BY DISCHARGE TYPE	    21

III-2     PRODUCTION RANGES FOR THE SECONDARY URANIUM
          SUBCATEGORY	    22

II1-3  .   SUMMARY OF SECONDARY URANIUM SUBCATEGORY
          PROCESS AND ASSOCIATED WASTE STREAMS 	    23

V-1       WATER USE AND DISCHARGE RATES FOR
          REFINERY FILTRATE	    38

V-2       WATER USE AND DISCHARGE RATES FOR
          SLAG LEACH SLURRY	    39

V-3       WATER USE AND DISCHARGE RATES FOR
          SOLVENT EXTRACTION RAFFINATE 	    40

V-4       WATER USE AND DISCHARGE RATES FOR DIGESTION
          OPERATION WET AIR POLLUTION CONTROL	    41

V-5       WATER USE AND DISCHARGE RATES FOR EVAPORATION
          AND CALCINATION WET AIR POLLUTION CONTROL. ...    42

V-6       WATER USE AND DISCHARGE RATES FOR HYDROGEN
          REDUCTION AND HYDROFLUORINATION KOH WET AIR
          POLLUTION CONTROL	    43

V-7       WATER USE AND DISCHARGE RATES FOR HYDROFLUORINA-
          TION WET AIR POLLUTION CONTROL	    44

V-8       SECONDARY URANIUM SUBCATEGORY TREATMENT PLANT
          INFLUENT RAW WASTEWATER SAMPLING DATA	    45

V-9       SECONDARY URANIUM SUBCATEGORY TREATMENT PLANT
          EFFLUENT SAMPLING DATA 	    47

VI-1       FREQUENCY OF OCCURRENCE OF TOXIC POLLUTANTS
          SECONDARY URANIUM SUBCATEGORY RAW WASTEWATER .  .    56

VII1-1    COST OF COMPLIANCE FOR THE SECONDARY URANIUM
          SUBCATEGORY DIRECT DISCHARGERS 	    65

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                  SECONDARY URANIUM SUBCATEGORY

                    LIST OF TABLES (Continued)


Number                                                      Page

IX-1      BPT WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY URANIUM SUBCATEGORY	    74

IX-2      BPT MASS LIMITATIONS FOR THE SECONDARY
          URANIUM SUBCATEGORY	    75

X-1       POLLUTANT REMOVAL ESTIMATES FOR DIRECT
          DISCHARGERS	    87

X-2       COST OF COMPLIANCE FOR THE SECONDARY URANIUM
          SUBCATEGORY	    88

X-3       BAT WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY URANIUM SUBCATEGORY	    89

X-4       BAT MASS LIMITATIONS FOR THE SECONDARY
          URANIUM SUBCATEGORY. . 	    90

XI-1      NSPS WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY URANIUM SUBCATEGORY	    98

XI-2      NSPS FOR THE SECONDARY URANIUM SUBCATEGORY ...    99

XII-1     PSNS WASTEWATER DISCHARGE RATES FOR THE
          SECONDARY URANIUM SUBCATEGORY	   106

XII-2     PSNS FOR THE SECONDARY URANIUM SUBCATEGORY ...   107
                               vi

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                  SECONDARY URANIUM SUBCATEGORY

                         LIST OF FIGURES


Number                                                      Page

III-1     URANIUM TETRAFLUORIDE PRODUCTION PROCESS
          IN THE SECONDARY URANIUM SUBCATEGORY	    24

II1-2     MAGNESIUM REDUCTION PROCESS IN THE SECONDARY
          URANIUM SUBCATEGORY	    25

III-3     GEOGRAPHIC LOCATIONS OF THE SECONDARY URANIUM
          SUBCATEGORY PLANTS	    26

V-1       SAMPLING SITES AT URANIUM ORE MILL	    48

IX-1      BPT TREATMENT SCHEME FOR THE SECONDARY
          URANIUM SUBCATEGORY	    79

X-1       BAT TREATMENT SCHEME FOR OPTION A	    93

X-2       BAT TREATMENT SCHEME FOR OPTION C	    94
                              Vii

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V3-1X

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                   SECONDARY URANIUM SUBCATEGORY

                             SECTION I

                      SUMMARY AND CONCLUSIONS


Pursuant  to  Sections  301,  304,  306,  307,  and 501  of the Clean
Water Act and  the  provisions of the  Settlement  Agreement in
Natural Resources  Defense  Council v. Train,  8 ERG 2120  (D.D.C.
1976) modified,  12 ERG  1833 (D.D.C.  1979),  EPA  has collected  and
analyzed  data  for  plants in the secondary uranium 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,
pretreatment standards  for new  indirect dischargers (PSNS), and
standards of performance for new source direct  dischargers
(NSPS).

The secondary  uranium subcategory is comprised  of three plants.
Of the three plants,  one discharges directly to a stream, and two
operate dry  processes.

EPA first studied  the secondary uranium subcategory to  determine
whether differences in  raw materials,  final  products, manufactur-
ing processes, equipment,  age and size of plants,  or water  usage
required  the development of separate effluent limitations and
standards  for  different segments  of the subcategory.  This
involved  a detailed analysis of wastewater discharge and treated
effluent  characteristics,  including  (1) the  sources and volume of
water used,  the  processes  used,  and the sources of pollutants and
wastewaters  in the plant;  and (2) the constituents  of waste-
waters, including  toxic pollutants.  As a result,  seven subdivi-
sions have been  identified  for  this subcategory that warrant
separate  effluent  limitations.   These  include:

        Refinery filtrate,
        Slag leach slurry,
        Solvent  extraction  raffinate,
        Digestion  operation wet  air pollution control,
        Evaporation and calcination wet air  pollution control,
        Hydrogen reduction  and hydrofluorination  KOH wet air
        pollution  control,  and
     •  Hydrofluorination wet air pollution  control.

EPA also  identified several distinct control  and  treatment  tech-
nologies  (both in-plant and end-of-pipe)  applicable  to  the  sec-
ondary uranium subcategory.  The Agency analyzed  both historical

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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 a.r
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.
Steam stripping was selected as the technology basis for ammonia
limitations.  To meet the BPT effluent limitations based on this
technology, the secondary uranium subcategory is expected to
incur an estimated capital cost of $28,600 and an annual cost of
$73,644.

For BAT, filtration is added as an effluent polishing step to the
BPT end-of-pipe treatment scheme.  To meet the BAT effluent limi-
tations based on this technology, the secondary uranium subcate-
gory is estimated to incur a capital cost of $54,312 and an
annual cost of $86,452.

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

PSES is not being proposed for this subcategory because there are
no existing indirect dischargers in the secondary uranium subcat-
egory.  For PSNS, the Agency selected pretreatment and end-of-
pipe treatment techniques 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.

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              SECONDARY URANIUM  SUBCATEGORY

                       SECTION  II

                    RECOMMENDATIONS
1.  EPA has divided the secondary uranium  subcategory
    into  seven subdivisions  for  the  purpose  of  effluent
    limitations and standards.   These  subdivisions  are:

    (a)   Refinery filtrate,
    (b)   Slag leach slurry,
    (c)   Solvent extraction  raffinate,
    (d)   Digestion operation wet air pollution  control,
    (e)   Evaporation and calcination wet air pollution
          control,
    (f)   Hydrogen reduction  and  hydrofluorination KOH
          wet air pollution control,  and
    (g)   Hydrofluorination wet air pollution control.

2.  BPT is proposed based on the performance achievable
    by the application of ammonia steam stripping pre-
    treatment for removal of ammonia,  followed  by
    chemical precipitation and sedimentation technol-
    ogy.  The following BPT  effluent limitations are
    proposed:

BPT MASS  LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(a)  Refinery Filtrate

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

  mg/kg (Ib/million Ibs) of  uranium  trioxide produced

Chromium  (total)          15.310              6.264
Copper                   66.120            34.800
Nickel                   66.820            44.200
Ammonia (as N)         4,639.000         2,039.000
Fluoride              1,218.000            696.000
Uranium                 139.200            78.300
Total Suspended       1,427.000            678.600
 Solids
pH                     Within the range of 7.5  to 10.0
                                 at all times

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BPT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(b)  Slag Leach Slurry

   Pollutant or        Maximum for       Maximum for
Pollutant Property _ Any One Day _ Monthly Average
mg/kg (Ib/million
Chromium (total)
Copper
Nickel
Ammonia (as N)
Fluoride
Uranium
Total Suspended
Solids
pH
Ibs) of uranium trioxide produced
1.672
7.220
7.296
506.500
133.000
15.200
155.800

Within the
0.684
3.800
4.826
222.700
76.000
8.550
74.100

range of 7.5 to 10.0
                                at all times
BPT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(c)  Solvent Extraction Raffinate

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          2.332             0.954
Copper                   10.070             5.300
Nickel                   10.180             6.731
Ammonia (as N)          706.500           310.600
Fluoride                185.500         .  106.000
Uranium                  21.200            11.930
Total Suspended         217.300           103.400
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times

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BPT MASS LIMITATIONS  FOR THE  SECONDARY URANIUM
SUBCATEGORY

(d)  Digestion Operation Wet  Air Pollution Control

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

  rag/kg (Ib/million Ibs)  of uranium  trioxide produced

Chromium (total)          0.013             0.005
Copper                    0.057             0.030
Nickel                    0.058             0.038
Ammonia (as N)            3.900             1.758
Fluoride                  1.050             0.600
Uranium                   0.120             0.068
Total Suspended           1.230             0.585
 Solids
pH                     Within the range of 7.5 to 10.0
                                 at all  times
BPT MASS- LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(e)  Evaporation and Calcination Wet Air  Pollution
     Control

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

  mg/kg  (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000  •
Ammonia  (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
Total Suspended           0.000             0.000
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times

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BPT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(f)  Hydrogen Reduction and Hydrofluorination KOH Wet
     Air Pollution Control

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

           mg/kg (Ib/million Ibs) of uranium
                 tetrafluoride produced

Chromium (total)          0.009             0.004
Copper                    0.038             0.020
Nickel                    0.038             0.025
Ammonia (as N)            2.666             1.172
Fluoride                  0.700             0.400
Uranium                   0.080             0.045
Total Suspended           0.820             0.390
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
BPT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(g)  Hydrofluorination Wet Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium tetrafluoride
                        produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
Total Suspended           0.000             0.000
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times

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     BAT  is  proposed based  on  the  performance  achievable
     by the  application  of  ammonia steam  stripping  pre-
     treatment  for ammonia  removal,  followed by chemical
     precipitation, sedimentation,  and multimedia fil-
     tration technology.  The  following BAT effluent
     limitations are proposed:
BAT MASS LIMITATIONS FOR THE  SECONDARY  URANIUM
SUBCATEGORY

(a)  Refinery Filtrate

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

  mg/kg (Ib/million Ibs) of uranium  trioxide  produced

Chromium (total)         12.880            5.220
Copper                   44.550           21.230
Nickel                   19.140           12.880
Ammonia (as N)        1,439.000        2,039.000
Fluoride              1,218.000           696.000
Uranium                  93.260           52.550
BAT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(b)  Slag Leach Slurry

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.406             0.570
Copper                    4.864             2.318
Nickel                    2.090             1.406
Ammonia (as N)          506.500           222.500
Fluoride                133.000            76.000
Uranium                  10.180             5.738

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BAT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(c)  Solvent Extraction Raffinate

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.961             0.795
Copper                    6.784             3.233
Nickel                    2.915             1.961
Ammonia (as N)          706.500           310.600
Fluoride                185.500           106.000
Uranium                  14.200             8.003
BAT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(d)  Digestion Operation Wet Air Pollution Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.011             0.005
Copper                    0.038             0.018
Nickel                    0.017             0.011
Ammonia (as N)            3.999             1.758
Fluoride                  1.050             0.600
Uranium                   0.080             0.045
BAT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(e)  Evaporation and Calcination Wet Air Pollution
     Control

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

  rog/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000

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BAT MASS LIMITATIONS FOR THE  SECONDARY  URANIUM
SUBCATEGORY

(f)  Hydrogen Reduction and Hydrofluorination  KOH  Wet
     Air Pollution Control

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

    rog/kg (Ib/million Ibs) of uranium tetrafluoride
                        produced

Chromium (total)          0.007              0.003
Copper                    0.026              0.012
Nickel                    0.011              0.007
Ammonia (as N)            2.666              1.172
Fluoride                  0.700              0.400
Uranium                   0.054              0.030
BAT MASS LIMITATIONS FOR THE SECONDARY URANIUM
SUBCATEGORY

(g)  Hydrofluorination Wet Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium tetrafluoride
                        produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
4.  NSPS are proposed based on the performance achiev-
    able by the application of ammonia steam stripping
    pretreatment for removal of ammonia, followed by
    chemical precipitation, sedimentation, and multi-
    media filtration technology.  The following efflu-
    ent standards are proposed for new sources:

-------
NSPS FOR THE SECONDARY URANIUM SUBCATEGORY

(a)  Refinery Filtrate

   Pollutant or        Maximum for       Maximum for
Pollutant Property _ Any One Day _ Monthly Average
rag/kg (Ib/million
Chromium (total)
Copper
Nickel
Ammonia (as N)
Fluoride
Uranium
Total Suspended
Solids
pH
Ibs) of uranium trioxide produced
12.880
44. 550
19.140
4,639.000
1,218.000
93.260
522.000

Within the
5.220
21.230
12.880
2,039.000
696.000
52.550
417.600

range of 7.5 to 10.0
                                at all times


NSPS FOR THE SECONDARY URANIUM SUBCATEGORY

(b)  Slag Leach Slurry

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1 . 406             0. 570
Copper                    4.864             2.318
Nickel                    2.090             1.406
Ammonia (as N)          506.500           222.700
Fluoride                133.000             76.000
Uranium                  1 0. 1 80             5. 738
Total Suspended          57.000             45.600
 Solids
pH                     Within the range of  7.5 to  10.0
                                at all times
                                10

-------
NSPS FOR THE SECONDARY URANIUM SUBCATEGORY

(c)  Solvent Extraction Raffinate

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

  fflg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.961             0.795
Copper                    6.784             3.233
Nickel                    2.915             1.961
Ammonia (as N)          706.500            310.600
Fluoride                185.500            106.000
Uranium                  14.200             8.003
Total Suspended          79.500             63.600
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times


NSPS FOR THE SECONDARY URANIUM SUBCATEGORY

(d)  Digestion Operation Wet Air Pollution Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.011             0.005
Copper                    0.038             0.018
Nickel                    0.017             0.011
Ammonia (as N)            3.999             1.758
Fluoride                  1.050             0.600
Uranium                   0.080             0.045
Total Suspended  •         0.450             0.360
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
                               11

-------
NSPS FOR THE SECONDARY URANIUM SUBCATEGORY

(e)  Evaporation and Calcination Wet Air Pollution
     Control

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

  rog/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0.000
Fluoride               ,   0.000             0.000
Uranium                   0.000             0.000
Total Suspended           0.000             0.000
 Solids
pH                     Within the range of  7.5 to 10.0
                                at all times
NSPS FOR THE SECONDARY URANIUM SUBCATEGORY

(f)  Hydrogen Reduction and Hydrofluorination  KOH Wet
     Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium  tetrafluoride
                        produced

Chromium (total)          0.007              0.003
Copper                    0.026              0.012
Nickel                    0.011              0.007
Ammonia (as N)            2.666              1.172
Fluoride                  0.700              0.400
Uranium                   0.054              0.030
Total Suspended           0.300              0.240
 Solids
pH                     Within the range  of  7.5 to 10.0
                                at  all times
                                12

-------
NSPS FOR THE SECONDARY  URANIUM  SUBCATEGORY

(g)  Hydrofluorination  Wet Air  Pollution  Control

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

    mg/kg (Ib/million Ibs) of uranium  tetrafluoride
                        produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
Total Suspended           0.000             0.000
 Solids
pH                      Within the range of 7.5 to 10.0
                                at  all times
5.  PSES is not being proposed  for  this  subcategory at
    this time because there are no  existing  indirect
    dischargers in the secondary uranium subcategory.

6.  PSNS are proposed based on  the  performance  achiev-
    able by the application of  ammonia steam stripping
    pretreatment for removal of ammonia,  followed  by
    chemical precipitation, sedimentation, and  multi-
    media filtration technology.  The following pre-
    treatment standards are proposed for new sources:
PSNS FOR THE SECONDARY URANIUM  SUBCATEGORY

(a)  Refinery Filtrate

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

  mg/kg (Ib/million Ibs) of uranium  trioxide  produced

Chromium (total)         12.880             5.220
Copper                   44.550            21.230
Nickel                   19.140            12.880
Ammonia (as N)        4,639.000         2,039.000
Fluoride              1,218.000           696.000
Uranium                  93.260            52.550
                                13

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PSNS FOR THE SECONDARY URANIUM SUBCATEGORY

(b)  Slag Leach Slurry

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

  rog/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.406             0.570
Copper                    4.864             2.318
Nickel                    2.090             1.406
Ammonia (as N)          506.500           222.700
Fluoride                133.000            76.000
Uranium                  10.180             5.738


PSNS FOR THE SECONDARY URANIUM SUBCATEGORY

(c)  Solvent Extraction Raffinate

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.961             0.795
Copper                    6.784             3.233
Nickel                    2.915             1.961
Ammonia (as N)          706.500           310.600
Fluoride                185.500           106.000
Uranium                  14.200             8.003


PSNS FOR THE SECONDARY URANIUM SUBCATEGORY

(d)  Digestion Operation Wet Air Pollution Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.011             0.005
Copper                    0.038             0.018
Nickel                    0.017             0.011
Ammonia (as N)            3.999             1.758
Fluoride                  1.050             0.600
Uranium                   0.080             0.045
                                14

-------
PSNS FOR THE SECONDARY URANIUM SUBCATEGORY

(e)  Evaporation and Calcination  Wet  Air Pollution
     Control

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

  mg/kg (Ib/million Ibs)  of uranium  trioxide produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0. 000             0. 000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
PSNS FOR THE SECONDARY URANIUM  SUBCATEGORY

(f)  Hydrogen Reduction and Hydrofluorination KOH Wet
     Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium  tetrafluoride
                        produced

Chromium (total)          0.007             0.003
Copper                    0.026             0.012
Nickel                    0.011              0.007
Ammonia (as N)            2.666             1.172
Fluoride                  0.700             0.400
Uranium                   0.054             0.030
                                15

-------
PSNS FOR THE SECONDARY URANIUM SUBCATEGORY

(g)  Hydrofluorination Wet Air Pollution  Control

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

    rag/kg (Ib/million Ibs) of uranium tetrafluoride
                        produced

Chromium (total)          0.000              0.000
Copper                    0.000              0.000
Nickel                    0.000              0.000
Ammonia (as N)            0.000              0.000
Fluoride                  0.000              0.000
Uranium                   0.000              0.000
7.  EPA is not proposing BCT at  this  time  for  the
    secondary uranium subcategory.
                                16

-------
                  SECONDARY URANIUM SUBCATEGORY

                           SECTION III

                         INDUSTRY PROFILE


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

The major use of depleted, or secondary, uranium is  in  ordnance
applications.  The source of secondary uranium  is  depleted
uranium hexafluoride, UFg, resulting from enrichment of natural
uranium for nuclear applications.  The high density  and pyro-
phoricity of uranium metal reduced from depleted UFg make it
ideal for use in antitank and antimissile ammunition.   Depleted
uranium metal is reportedly more effective than tungsten  alloy
ammunition.  Other uses of secondary uranium are containers for
spent nuclear reactor residues, radiation shielding  applications,
ballast and counterweights on aircraft control  surfaces,  and
research.

DESCRIPTION OF SECONDARY URANIUM PRODUCTION

The production of secondary uranium can be divided into two
distinct stages.  The first stage is production of uranium  tetra-
fluoride, UF4, from secondary materials, and the second stage
is magnesium reduction of uranium tetrafluoride to pure uranium
metal.  All the plants in this subcategory perform the  second
stage process, but only one plant produces uranium tetrafluoride
from secondary materials.  The secondary uranium production
processes are shown schematically in Figures III-1 and  III-2, and
are described in the following paragraphs.

RAW MATERIALS

The raw material necessary for the production of uranium by the
magnesium reduction process is uranium tetrafluoride, UF4.
This material is generally obtained from enrichment  plants  which
produce uranium for nuclear energy applications.  The enrichment
process involves separation of enriched UFg from depleted
UFg.  Much of the depleted uranium hexafluoride is converted to
UF4 which is subsequently used as a raw material in  the mag-
nesium reduction process.  Uranium tetrafluoride is  also  produced
from uranium-bearing scrap.  One of the plants  in this  subcate-
gory uses uranium scrap (mainly off-spec product or  machining
                                17

-------
scrap), residues, and magnesium reduction slag as raw materials
in addition to using uranium tetrafluoride.  The following
discussions describe the production of uranium from  secondary
sources and the production of uranium metal from uranium
tetraflnoride in more detail.

URANIUM TETRAFLUORIDE PRODUCTION

One plant in the secondary uranium subcategory has the  capacity
to manufacture uranium tetrafluoride from scrap uranium mate-
rials.  This plant uses the manufactured UF4 in its  magnesium
reduction operation as a supplement to \JF^ obtained  from  other
sources.  This process is primarily a uranium recovery  operation,
as the raw materials are scrap from machining operations, and
slag generated by magnesium reduction.  The magnesium fluoride
slag is recycled to the recovery process whenever its residual
uranium content is economically recoverable.

The first step in the recovery process is acid leaching of  the
raw materials to dissolve the uranium.  Any remaining scrap or
residue is filtered out and discarded.  Next, ammonia is  added to
the uranium-bearing filtrate causing precipitation of an  ammonium
diuranate solid.  This solid is filtered and the filtrate dis-
charged to treatment.  The precipitate is redissolved in  acid  so
that the uranium compound in solution, uranyl nitrate,  UO (NO  )  ,
can be extracted by an organic solvent such as kerosene/tributyl
phosphate.  Following the discharge to treatment of  the solvent
extraction raffinate, the purified uranyl nitrate solution  is
stripped into an aqueous solution.  This solution is concentrated
by evaporation and then calcined to burn off the nitrate, result-
ing in an end product of uranium trioxide, 003.  The final
stage includes a hydrogen reduction process which converts  U03
to uranium dioxide, U02, followed by hydrofluorination.  The
hydrogen is produced by dissociating ammonia.  U02 is contacted
with vaporized hydrofluoric acid at elevated temperatures.   The
resulting product is uranium tetrafluoride, UF4, which  is then
used in the magnesium reduction operation.

The potential waste streams associated with the production  of
uranium tetrafluoride are generated in the preliminary  acid
leaching steps and the solvent extraction and purification
operations.  Wet air pollution controls are also used in  this
process to scrub gases from the acid leaching, evaporation  and
calcination, and hydrogen reduction and hydrofluorination
operations.

MAGNESIUM REDUCTION PROCESS

The magnesium reduction process is widely used to produce uranium
metal from uranium tetrafluoride.  Uranium tetrafluoride  is mixed
with magnesium and reduced to uranium metal in a thermite-type

-------
bomb reduction vessel.  The reduction  reaction requires about
three minutes and reaches a temperature  around 1,900°C.  The
magnesium fluoride slag and uranium metal  separate and are
allowed to cool.  No process water is  associated  with this
process, therefore no waste streams are  generated.

PROCESS WASTEWATER SOURCES

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

     1.  Refinery filtrate,
     2.  Slag leach slurry,
     3.  Solvent extraction raffinate,
     4.  Digestion operation wet air pollution control,
     5.  Evaporation and calcination wet air  pollution control,
     6.  Hydrogen reduction and  hydrofluorination KOH wet air
         pollution control, and
     7.  Hydrofluorination wet air pollution  control.

OTHER WASTEWATER SOURCES

There are other waste streams associated with the secondary
uranium 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 III-3 shows the location  of the three  secondary uranium
plants operating in the United States.   All three plants are on
the eastern part of the country.  Table  III-1 shows the relative
ages of the three plants.  This  shows  that  two plants were built
in the early years of the uranium industry, while the third plant
was built in the early 70's.  It was probably built in anticipa-
tion of the growth of the uranium industry  due to commercial uses
of uranium, primarily in power generation.  Table III-2 gives the
yearly production ranges for the three plants in  this
subcategory.
                                19

-------
Table III-3 provides a summary of the number of plants generating
wastewater for the waste streams associated with various pro-
cesses and the number of plants with the process.
                               20

-------
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-------
                        To Atmosphere
                                       Waste liquor
                                       co Treatment
 Scrap Metal, Residues. MsF- Slag
          Acid.
                                          Slag Leach Slurry
                                          to Treatment (Only
                                          Produced When Slat
                                          is Being Processed)
                                          Refinery Filtrate
                                          to Treatment
                                                                 Waste
                                                                 Liquor
         Vaporized HF
                       Magnesium Reduction
                          Operation
                    Figure III-l
URANIUM TETRAFLUORIDE  PRODUCTION PROCESS
   IN  THE  SECONDARY  URANIUM  SUBCATEGORY
                           24

-------
   UF,
•Mg
Blending UF,
and Mg Metal
\
r
Charging or
Preheating UF,
and Mg Blend
1
t
Magnesium
Reduction
Furnace
\
i
Separation
and
Air Cooling
\
r
Derby
Casting
                I
                              "MgF? Removed
           Uranium Product
            Figure III-2

MAGNESIUM REDUCTION PROCESS  IN THE
  SECONDARY URANIUM SUBCATEGORY
                25

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26

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                  SECONDARY URANIUM SUBCATEGORY

                            SECTION IV
                        SUBCATEGOR
As discussed in Section IV of the i
the nonferrous metals manufacturin
gorized to take into account perti:
which affect the ability of the fa
limitations.  This section summari
during the designation of the secoi
its related subdivisions.  Product
each subdivision will also be disci

FACTORS CONSIDERED IN SUBCATEGORIZ^
The following factors were evaluat
the nonferrous metals manufacturinj

      1.  Metal products, co-produ
      2.  Raw materials;
      3.  Manufacturing processes;
      4.  Product form;
      5.  Plant location;
      6.  Plant age;
      7.  Plant size;
      8.  Air pollution control me
      9.  Meteorological condition
     10.  Treatment costs;
     11.  Nonwater quality aspects
     12.  Number of employees;
     13.  Total energy requirement
     14.  Unique plant characteris
Evaluation of all factors that cou
resulted in the designation of the
Three factors were particularly imp
classifications:  the type of meta
ZATION
eneral Development Document,
 category has been subcate-
ent industry characteristics,
ilities to achieve effluent
es the factors considered
dary uranium subcategory and
on normalizing parameters for
ssed.

TION
d for use in subcategorizing
 category:

ts, and by-products;
lods;
;  and
ics.

d warrant subcategorization
secondary uranium subcategory,
ortant in establishing these
 produced, the nature of the
raw material used, and the manufacturing processes  involved.

In Section IV of the General Development Document,  each of  these
factors is described, and the rationale for selecting metal prod-
uct, manufacturing process, and raw materials as the principal
factors used for subcategorization is discussed.  On this basis,
the nonferrous metals manufacturing category (phase II) was
divided into 21 subcategories, one of them being secondary
uranium.
                                  27

-------
FACTORS CONSIDERED IN SUBDIVIDING THE  SECONDARY URANIUM SUBCATE-
GORY

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

The rationale  for considering further  subdivision of  the second-
ary uranium subcategory is  based primarily  on differences  in the
production processes and raw materials used.  Within  this  subcat-
egory a number of different operations are  performed  which may or
may not have a water use or discharge, and  which may  require the
establishment  of separate effluent  limitations.  While  secondary
uranium is still considered a single subcategory, a more thorough
examination of the production processes  has illustrated  the need
for limitations and standards based on specific flow  allowances
for the following subdivisions:

     1.  Refinery filtrate,
     2.  Slag  leach slurry,
     3.  Solvent extraction raffinate,
     4.  Digestion operation wet air pollution  control,
     5.  Evaporation and calcination wet air  pollution  control,
     6.  Hydrogen reduction and hydrofluorination KOH wet  air
         pollution control, and
     7.  Hydrofluorination  wet air  pollution  control.

These subdivisions follow directly  from  differences within the
process of refining scrap,  residues, and slag to produce uranium
tetrafluoride  for use in magnesium  reduction  to uranium  metal.

Leaching of the raw materials gives rise to the first,  second,
and fourth subdivisions.  A major source of wastewater  is  the
filtrate that  is generated  by leaching uranium  from the  raw
materials and precipitating uranium diuranate.   When  slag  is
used, the residual solids are discharged as a slurry  which may be
a significant source of pollutants.  Wastewater from  scrubbers
which are used to control acid fumes in  the leaching  operation is
also a source of pollutants.

Solvent extraction is used  in the refining  process to purify a
uranium intermediate product.  Solvent extraction results  in a
raffinate waste stream that contains significant quantities of
pollutants.

The last three subdivisions arise from wet  air  pollution controls
which control emissions from the processes  used to refine  scrap,
residues, and  slag to a usable product.  Evaporation, calcina-
tion, hydrogen reduction, and hydrofluorination are all  opera-
tions that necessitate air  pollution control  systems.   In  some
                               28

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cases, water use  is  recycled  into  the  process  rather than dis-
charged.  The potential sources  of wastewater  and  associated
pollutants require that each  subdivision be  examined and  handled
on an  individual  basis.

OTHER  FACTORS

The other factors considered  in  this evaluation  either  support
the establishment of the  seven subdivisions  or were  shown to  be
inappropriate bases  for subdivision.   Air pollution  control
methods, treatment costs, and total energy requirements are  func-
tions  of the selected subcategorization  factors--metal  product,
raw materials, and production processes.   Therefore,  they are not
independent factors  and do not affect  the subcategorization which
has been applied.  As discussed  in Section IV  of the General
Development Document, certain other factors, such  as plant age,
plant  size, and the  number of employees,  were  also evaluated  and
determined to be  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 actual mass of uranium intermediate
product produced will be used as the PNP.  Thus, the PNPs for the
seven  subdivisions are as follows:

          Subdivision                        PNP

1.  Refinery filtrate              kkg of uranium  trioxide
                                   produced

2.  Slag leach slurry              kkg of uranium  trioxide
                                   produced

3.  Solvent extraction raffinate   kkg of uranium  trioxide
                                   produced

4.  Digestion operation wet air    kkg of uranium  trioxide
    pollution control              produced
                               29

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          Subdivision                        PNP

5.  Evaporation and calcination    kkg of uranium trioxide
    wet air pollution control      produced

6.  Hydrogen reduction and         kkg of uranium tetrafluoride
    hydrofluorination KOH wet      produced
    air pollution control

7.  Hydrofluorination wet air      kkg of uranium tetrafluoride
    pollution control              produced
                               30

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                   SECONDARY  URANIUM SUBCATEGORY

                             SECTION V

             WATER USE AND WAbTEWATER CHARACTERISTICS


This  section describes the characteristics  of  the  wastewaters
associated with  the secondary  uranium 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.

Field sampling was  not performed for the secondary uranium sub-
category.  In order to conduct an  analysis of  the  subcategory
waste streams, the  concentrations  of toxic pollutants in the
wastewaters must be known.   Since  direct sampling  data are not
available, data  for use in this  subcategory was obtained from
pilot plant raw  wastewater characterization studies  conducted  at
a uranium ore mill.  The ore mill  uses  an acid leaching  process
to extract uranium  from the ore.   For this reason, it was  judged
that  the data could  be applied, with limitations,  to the process
waters generated in this subcategory.   The data consist  of
analyses for two classes of pollutants:  toxic metal pollutants,
and criteria pollutants (which includes both conventional  and
nonconventional  pollutants).   Samples were not analyzed  for  toxic
organic pollutants  because it  was  not expected that  organic
pollutants would be  present in wastewaters generated in  uranium
ore mill processing.  For the  same  reason, cyanide,  asbestos,  and
TCDD were not analyzed.

As described in  Section IV of  this  supplement, the secondary
uranium subcategory  has been split  into seven  subdivisions or
wastewater sources,  so that the proposed regulation  contains mass
discharge limitations and standards  for seven  unit processes
discharging process wastewater.  Differences in the  wastewater
characteristics associated with these subdivisions are to  be
expected.  For this  reason, wastewater  streams corresponding to
each subdivision are addressed separately in the discussions that
follow.   These wastewater sources  are:
                                31

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     1.  Refinery filtrate,
     2.  Slag leach slurry,
     3.  Solvent extraction raffinate,
     4.  Digestion operation wet air pollution  control,
     5.  Evaporation and calcination wet  air pollution  control,
     6.  Hydrogen reduction and hydrofluorination  KOH wet  air
         pollution control, and
     7.  Hydrofluorination wet air pollution control.

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 uranium product and is therefore  based  on  the sum  of
recycle and make-up flows to a given process.   Wastewater  flow
discharged after pretreatment or recycle  (if these are  present)
is used in calculating the production normalized flow—the volume
of wastewater discharged from a given process to further  treat-
ment, disposal, or discharge per mass of  uranium 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,
refinery filtrate wastewater flow is related to the production of
uranium trioxide.  As such, the discharge rate  is  expressed  in
liters of refinery filtrate per metric  ton of uranium trioxide
produced (gallons of refinery filtrate  per ton  of  uranium
trioxide).

The production normalized discharge flows were  compiled and  sta-
tistically analyzed by stream type.  These production normalized
water use and discharge flows are presented by  subdivision in
Tables V-1  through V-7 at the end of this section.  Where  appro-
priate, an attempt was made to identify factors that could
account for variations in water use and discharge  rates.   These
variations are discussed later in this  section  by  subdivision.  A
similar analysis of factors affecting the wastewater flows is
presented in Sections X, XI, and XII where representative  BAT,
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.
                                32

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WASTEWATER  CHARACTERISTICS  DATA

Data used to  characterize the  various  wastewaters associated with
secondary uranium production come  from two  sources--data collec-
tion portfolios  and  analytical data  from  sampling.

DATA COLLECTION  PORTFOLIOS

In  the data collection portfolios, the secondary uranium plants
were asked  to specify the presence or  absence  of toxic  pollutants
in  their wastewater.  Of the three secondary uranium plants,  two
plants do not generate process wastewater because they  use  a dry
production  process.  The plant responding to this questionnaire
did not report the presence of any toxic  organic pollutants.   The
responses for the toxic metals and cyanide  are summarized below:

                                     Believed Present
                                 (Based on Raw  Materials and
Pollutant     Known  Present       Process Chemicals  Used)

Antimony             0                        0
Arsenic              0                        0
Beryllium            0                        0
Cadmium              0                        0
Chromium             1                        0
Copper               1                        0
Cyanide              0                        0
Lead                 0                        0
Mercury              0                        0
Nickel               1                        0
Selenium             0                        0
Silver               0                        0
Thallium             0                        0
Zinc                 0                        0

FIELD SAMPLING DATA

In order to quantify the concentrations of  pollutants present  in
wastewater  from  secondary uranium plants, analytical data are
used.   Since none of the secondary uranium  plants were  sampled,
analytical  data  from a. uranium  ore mill are being used  to charac-
terize the .wastewaters of the  secondary uranium  subcategory.   A
diagram indicating the sampling  sites  and contributing  production
processes is shown in Figure V-1 (at the  end of  this  section).

Raw wastewater data are presented in Table  V-8.   In  this  table,
analytical  results are given for the combined  wastewater  influent
to the treatment system.   Table V-9 presents analytical data on
the treated effluent prior to being discharged.   Note that  the
stream numbers listed in the tables correspond to those given  in
                                33

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the plant sampling site diagram, Figure V-1.  Where no  data  are
listed for a specific day, the wastewater samples  for the  stream
were not collected.

Several points regarding these tables should be noted.   First,
the data tables include some samples measured at concentrations
considered not quantifiable.  Toxic metal values reported  as  less
than a certain value were considered not quantifiable.

Second, the detection limits shown on the data tables for  toxic
metals and conventional and nonconventional pollutants  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  varia-
tion can occur as a result of a number of laboratory-specific,
equipment-specific, and daily operator-specific factors.   These
factors can include day-to-day differences in machine calibra-
tion, variation in stock solutions, and variation  in operators.

Third, the statistical analysis of data includes some samples
measured at concentrations considered not quantifiable.  For  data
considered as detected but below quantifiable concentrations, a
value of zero is used for averaging.  Nonconventional and  conven-
tional pollutant data reported with a "less than"  sign  are con-
sidered as detected, but not further quantifiable.  A value  of
zero, is used for averaging.  Toxic metal values reported as  less
than a certain value were considered as below quantification, and
consequently were assigned a value of zero in the  calculation of
the average.

WASTEWATER CHARACTERISTICS AND FLOWS BY SUBDIVISION

Since secondary uranium production involves seven  principal
sources of wastewater and each has potentially different charac-
teristics and flows, the wastewater characteristics and  discharge
rates corresponding to each subdivision will be described  sepa-
rately.  A brief description of why the associated production
processes generate a wastewater will also be discussed.

REFINERY FILTRATE

The source of this waste stream is in the refinery digestion
operation.  Here the uranium scrap, residues, and  compounds  are
acid leached, dissolving the uranium into solution.  The residual
solids are filtered and disposed as a filter cake.  Ammonia  is
then added to the filtrate to precipitate the uranium as an
ammonium diuranate solid.  This solid is filtered  and further
processed.  The filtrate is discharged to the treatment  system.
                                34

-------
The production normalized water  use  and  discharge rates  for
refinery filtrate are given  in Table V-1  in  liters  per metric ton
of uranium trioxide produced.

This waste stream was not sampled  at a secondary uranium produc-
tion plant.  As previously mentioned, data were  obtained from a
uranium ore mill which uses  an acid  leaching operation to extract
uranium from ore.  Based on  the  similarities between these two
waste streams, the refinery  filtrate waste stream may be expected
to contain treatable concentrations  of toxic metals such as
copper and nickel, treatable  concentrations  of  suspended solids,
ammonia, and an acidic pH.

SLAG LEACH SLURRY

This waste stream originates  in  the  refinery digestion operation.
The slag that is used in the  leaching operation  comes from the
magnesium reduction process.  The  magnesium  fluoride slag con-
tains residual levels of uranium and when it is  economically
advantageous to do so, the slag  is acid  leached  to  recover the
uranium.  After leaching, the remaining  slag solids are  filtered
and discharged to treatment  as a slurry.   The filtrate is then
combined with the uranium-bearing  spent  acid from other  leaching
operations and goes through  further  processing.   The production
normalized water use and discharge rates  for slag leach  slurry
are given in Table V-2 in liters per metric  ton  of  uranium
trioxide produced.

Since no sampling data are available from the secondary  uranium
industry, the wastewater characteristics  of  the  slag leaching
slurry will be based on sampling data from a uranium ore mill.
Judging from the data, presented in  Table V-8,  the  slag  leach
slurry can be characterized  by treatable  concentrations  of toxic
metals, fluoride, suspended  solids,  and  acidic pH.

SOLVENT EXTRACTION RAFFINATE

Solvent extraction follows the acid  leaching operation and is
used for purification of the  uranium compound.   An  organic
solvent, tributyl phosphate  in a kerosene carrier,  is used to
selectively extract the uranium  compound  from an acid solution.
The solvent extraction raffinate is  discharged  to treatment.
Table V-3 presents the production  normalized water  use and
discharge rates for the solvent  extraction raffinate in  liters
per metric ton of uranium trioxide produced.

Although this waste stream was not directly  sampled, it  can be
expected, based on the materials present  in  the  process  and the
process operation, that the  solvent  extraction  raffinate waste
stream can be characterized  by acidic pH  and significant con-
centrations of some toxic metal  pollutants,  as well as ammonia.
                                35

-------
EPA also recognizes the possibility  that  organics  from the
solvent extraction process may be carried over  to  the  raffinate
stream and thus be present in the discharge.  Based  on data,
comments, and other information to be received  prior to promul-
gation, EPA may find it necessary to regulate toxic  organics  in
this subcategory.  The Agency solicits comments  and  data from the
industry in this regard.

DIGESTION OPERATION WET AIR POLLUTION CONTROL

The acid leach operation, at the start of the uranium  scrap,
residue, and slag refining process,  includes a  water scrubbing
system to control the discharge of acidic fumes  and  particulate
matter. The scrubber liquor is completely recycled within the
system until its scrubbing efficiency drops, then  it is batch
discharged to treatment.  The production normalized  water use and
discharge flows for digestion operation scrubber water are  pre-
sented in Table V-4 in liters per metric  ton of  uranium trioxide
produced.

This waste stream was not sampled at a. secondary uranium produc-
tion plant.  Although no data are available, it  is expected,
based on the process operation and the materials involved,  that
the digestion operation scrubber water would be  characterized by
acidic pH, treatable concentrations  of suspended solids, and  some
toxic metal pollutants.

EVAPORATION AND CALCINATION WET AIR  POLLUTION CONTROL

Multiple scrubbers are used to control vapors and  fumes from  the
evaporation and calcination operations.   Evaporation is used  to
concentrate the uranium solution (uranyl nitrate)  after it  has
been stripped from the organic phase into an aqueous phase.
After the evaporation operation, the concentrated  intermediate
uranium product is calcined to drive off  the nitrate bound to the
uranium and produce uranium trioxide in a dry form.  The nitrates
in the air react to form nitric acid, and the scrubbers are used
to control these acid fumes.  Table  V-5 shows the  production
normalized water use and discharge rates  for the combined system
of scrubbers.

Because the scrubber liquor is relatively clean, and due to its
acid content, it is recycled for use in the digestion  operation.
There it is used to dilute fresh acid that is used for acid
leaching.  Because the scrubber liquor is entirely reused,  no
discharge of wastewater is practiced in the evaporation and
calcination operations.
                                36

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HYDROGEN REDUCTION AND HYDROFLUORINATION  KOH WET  AIR POLLUTI  N
CONTROL

This scrubber handles gas emissions from  both  the hydrogen
reduction and hydrofluorination operations.  The  first  opera  ion
includes cracking ammonia so that uranium trioxide  can  be  re  uced
by the hydrogen gas to uranium dioxide.   This  product then v  der-
goes hydrofluorination and is converted to uranium  tetrafluc  ide.
The gases produced in both operations are scrubbed  by this a  r
pollution control unit.  Production normalized water use and  dis-
charge rates are presented in Table V-6 in liters per metric  ton
of uranium tetrafluoride produced.

This waste stream was not sampled in the  secondary  uranium s  b-
category.  Considering the production processes contributing  to
the exhaust gases cleaned by this scrubber, it is expected t  at
this scrubber liquor would be characterized by suspended sol  ds,
fluoride, and acidic pH.

HYDROFLUORINATION WET AIR POLLUTION CONTROL

The hydrofluorination unit produces uranium tetrafluoride  by
contacting uranium dioxide with vaporized hydrofluoric  acid  t
elevated temperatures.  The off-gases from this operation  cc  tain
significant quantities of unreacted hydrofluoric  acid.  The
scrubber on this unit scrubs the acid fumes from  the operati  n by
absorbing the hydrofluoric acid in the scrubber liquor.  Tab  e
V-7 shows the production normalized water use  and discharge  ates
in liters per metric ton of uranium tetrafluoride produced.

Since the hydrofluorination scrubber cleans what  is predomir  ntly
vaporized unreacted hydrofluoric acid, the scrubber liquor c  n-
centrates this acid as it is recycled through  the system.   V  en
the desired concentration of hydrofluoric acid is attained,   he
liquor is drawn off and sold for industrial use.  For this
reason,  no discharge of wastewater occurs from the  hydrofluc  -
ination operation.
                               37

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                     Table V-1

         WATER USE AND DISCHARGE RATES FOR
                 REFINERY FILTRATE
     (1,000 1/kkg of uranium trioxide produced)

                                          Production
                           Production     Normalized
               Percent     Normalized     Discharge
Plant Code     Recycle     Water Use         Flow

   1175           0           34.8           34.8
                         38

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                     Table V-2

         WATER USE AND DISCHARGE RATES FOR
                 SLAG LEACH SLURRY
     (1,000 1/kkg of uranium trioxide produced)

                                          Production
                           Production     Normalized
               Percent     Normalized     Discharge
Plant Code     Recycle     Water Use         Flow

   1175           0            3.8            3.8
                        39

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                     Table V-3

         WATER USE AND DISCHARGE RATES FOR
            SOLVENT EXTRACTION RAFFINATE
     (1,000 1/kkg of uranium trioxide produced)

                                          Production
                           Production     Normalized
               Percent     Normalized     Discharge
Plant Code     Recycle     Water Use         Flow

   1175           0            5.3            5.3
                         40

-------
                            Table V-4

                WATER USE AND DISCHARGE RATES FOR
          DIGESTION OPERATION WET AIR POLLUTION CONTROL
             (1,000 1/kkg of uranium trioxide produced)

                                                 Production
                                  Production     Normalized
                      Percent     Normalized     Discharge
       Plant Code     Recycle     Water Use         Flow

          1175          NR            NR           0.030
NR - Present but data not reported in dcp,
                                41

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                            Table V-5

                WATER USE AND DISCHARGE RATES FOR
      EVAPORATION AND CALCINATION WET AIR POLLUTION CONTROL
            (1,000 1/kkg of uranium trioxide produced)

                                                 Production
                                  Production     Normalized
                      Percent     Normalized     Discharge
       Plant Code     Recycle     Water Use         Flow

          1175          100           NR             0
NR - Present but data not reported in dcp,
                               42

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                            Table V-6

                WATER USE AND DISCHARGE RATES FOR
             HYDROGEN REDUCTION AND HYDROFLUORINATION
                  KOH WET AIR POLLUTION CONTROL
          (1,000 1/kkg of uranium tetrafluoride produced)

                                                 Production
                                  Production     Normalized
                      Percent     Normalized     Discharge
       Plant Code     Recycle     Water Use         Flow

          1175          NR            NR           0.020
NR - Present but data not reported in dcp.
                                43

-------
                            Table V-7

                WATER USE AND DISCHARGE RATES FOR
           HYDROFLUORINATION WET AIR POLLUTION CONTROL
         (1,000 1/kkg of uranium tetrafluoride produced)

                                                 Production
                                  Production     Normalized
                      Percent     Normalized     Discharge
       Plant Code     Recycle     Water Use         Flow

          1175          100           NR             0
NR - Present but data not reported in dcp
                               44

-------
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                 Acid-
             Other•
          Materials
Discharge
                            !_£
                             Acid
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                          Purification
                              and
                          Concentration
    n.25
                              I
                        Ore Mill Product
                         Solids
•Uranium Ore
                                              Spent Acid
  Waste Stream
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Filtration



Neutralization,
Flocculatlon,
Sedimentation
1

                                       Solids
                          Figure V-1
              SAMPLING SITES AT URANIUM ORE MILL
                               48

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                  SECONDARY URANIUM SUBCATEGORY

                            SECTION VI

                SELECTION OF POLLUTANT  PARAMETERS


Section V of this supplement presented  data which were used  for
the secondary uranium subcategory.  This section examines  that
data and discusses the selection or exclusion of pollutants  for
potential limitation.

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 and nonconventional pollutants for
effluent limitations.  Also described is the analysis that was
performed to select or exclude, toxic pollutants for  further  con-
sideration 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 NONCONVENTIQNAL POLLUTANT PARAMETERS

This study examined samples for two conventional pollutant param-
eters (total suspended solids and pH) and several nonconventional
pollutant parameters.

CONVENTIONAL AND NONCONVENTIONAL POLLUTANT PARAMETERS SELECTED

The conventional and nonconventional pollutants or pollutant
parameters selected for limitation in the secondary  uranium
subcategory are:
                               49

-------
     ammonia
     fluoride
     uranium
     total suspended solids (TSS)
     pH

Ammonia is used in the uranium scrap processing operation  fol-
lowing acid leaching.  To extract dissolved uranium present  in
the spent leaching acid, ammonia is added to precipitate a
uranium-ammonia complex.  This precipitate is filtered and the
filtrate discharged.  Although there are no analytical data  of
this waste stream, it is expected that substantial concentrations
of residual ammonia could be present in the filtrate and thus be
discharged.  For this reason, ammonia is selected for limitation
in the secondary uranium subcategory.

Based on an examination of the raw materials and production  pro-
cesses employed in the secondary uranium subcategory, it is
expected that significant concentrations of fluoride are present
in the wastewater generated in this subcategory.  To produce ura-
nium tetrafluoride, uranium dioxide is reacted with hot vaporized
hydrofluoric acid.  The reaction gases, containing unreacted
hydrofluoric acid, are scrubbed with either water or a caustic
scrubber, the latter being discharged to treatment.  It is in
these liquors that fluoride is expected to be concentrated.  For
this reason, fluoride is selected for limitation in this
subcategory.

Analytical data for uranium are present in the sampling data
transferred to this subcategory from a uranium ore mill.   The
data show concentrations of uranium in the combined raw waste-
water that are treatable by chemical precipitation and sedimenta-
tion technology (17 mg/1 and 19.8 mg/1).  It is expected that
treatable concentrations of uranium will also be present in
wastewaters of the secondary uranium subcategory because of
uranium's solubility in acid.  Acid solutions are commonly
present in uranium scrap processing operations so it is likely
that uranium is present in wastewaters from those operations.
Therefore, uranium is selected for limitation in this
subcategory.

TSS concentrations of 40 and 168 mg/1 were observed in the two
raw waste samples analyzed for this study.  These concentrations
are well above the 2.6 mg/1 treatable concentration.  Most of the
specific methods used to remove toxic metals do so by converting
these metals to precipitates, and these toxic-metal-containing
precipitates should not be discharged.  Meeting a limitation on
total suspended solids helps ensure that removal of these  precip-
itated toxic metals has been effective.  For these reasons,  total
suspended solids are selected for limitation in this subcategory.
                                50

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The pH values observed during this study were  1.6 and  1.7.   Both
of these values are outside the 7.5 to  10.0 range considered
desirable for discharge to receiving waters.   Many  deleterious
effects are caused by extreme pH values or rapid changes  in  pH.
Also, effective removal of toxic metals by precipitation  requires
careful control of pH.  Since pH control within the desirable
limits is readily attainable by available treatment, pH is
selected for limitation in this subcategory.

TOXIC POLLUTANTS

The frequency of occurrence of the toxic pollutants in the raw
wastewater samples taken is presented in Table VI-1.   Table  VI-1
is based on the raw wastewater data from stream 113 (see  Section
V).  These data provide the basis for the categorization  of
specific pollutants, as discussed below.  Treatment plant samples
were not considered in the frequency count.  Note that sampling
was not done for any organic toxic pollutants.

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*
      17.  bis (chloromethyl) ether (deleted)*
      18.  bis (2-chloroethyl) ether*
      19.  2-chloroethyl vinyl ether (mixed)*
      20.  2-chloronaphthalene*
      21.  2,4,6-trichlorophenol*
      22.  parachlorometa cresol*
      23.  chloroform (trichloromethane)*
      24.  2-chlorophenol*
      25.  1,2-dichlorobenzene*
                               51

-------
26.  1,3-dichlorobenzene*
27.  1,4-dichlorobenzene*
28.  3,3'-dichlorobenzidine*
29.  1,1-dichloroethylene*
30.  1,2-trans-dichloroethylene*
31.  2,4-dichlorophenol*
32.  1,2-dichloropropane*
33.  1,2-dichloropropylene (1,3-dichloropropene)*
34.  2,4-dimethylphenol*
35.  2,4-dinitrotoluene*
36.  2,6-dinitrotoluene*
37.  1,2-diphenylhydrazine*
38.  ethylbenzene*
39.  fluoranthene*
40.  4-chlorophenyl phenyl ether*
41.  4-bromophenyl phenyl ether*
42.  bis(2-chloroisopropyl) ether*
43.  bis(2-choroethoxy) methane*
44.  methylene chloride (dichloromethane)*
45.  methyl chloride (chloromethane)*
46.  methyl bromide (bromomethane)*
47.  bromoform (tribromomethane)*
48.  dichlorobromomethane*
49.  trichlorofluoromethane (deleted)*
50.  dichlorodifluoromethane (deleted)*
51.  chlorodibromomethane*
52.  hexachlorobutadiene*
53.  hexachlorocyclopentadiene*
54.  isophorone*
5 5.  naphthalen e*
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*
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)*
                         52

-------
      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.  a-endosulfan-Alpha*
      96.  b-endosulfan-Beta*
      97.  endosulfan sulfate*
      98.  endrin*
      99.  endrin aldehyde*
     100.  heptachlor*
     101.  heptachlor epoxide*
     102.  a-Alpha-BHC*
     103.  b-Beta-BHC*
     104.  r-Gamma-BHC(lindane)*
     105.  g-Delta-BHC*
     106.  PCB-1242 (Arochlor  1242)*
     107.  PCB-1254 (Arochlor  1254)*
     108.  PCB-1221 (Arochlor  1221)*
     109.  PCB-1232 (Arochlor  1232)*
     110.  PCB-1248 (Arochlor  1248)*
     111.  PCB-1260 (Arochlor  1260)*
     112.  PCB-1016 (Arochlor  1016)*
     113.  toxaphene*
     116.  asbestos (Fibrous)
     121.  cyanide (Total)*
     129.  2, 3, 7,8-tetra chlorodibenzo-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.
                               53

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TOXIC POLLUTANTS NEVER FOUND ABOVE THEIR ANALYTICAL QUANTIFICA-
TION CONCENTRATION

The toxic pollutants listed below were never found above their
analytical quartification concentration in any raw wastewater
samples from this subcategory; therefore, they are not selected
for consideration in establishing limitations.


    114.  antimony
    123.  mercury
    126.  silver
    127.  thallium

TOXIC POLLUTANTS PRESENT BELOW CONCENTRATIONS ACHIEVABLE BY
TREATMENT

The toxic pollutant listed below is not selected for considera-
tion in establishing limitations because it was not found  in any
raw wastewater samples from this subcategory above concentrations
considered achievable by existing or available treatment
technologies.

     117.  beryllium

Beryllium was detected below its treatability concentration of
0.20 mg/1 in one raw wastewater sample analyzed.  The sample
contained 0.03 mg/1 beryllium; therefore, there is no reason to
further consider beryllium for limitation.

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.

     11 5.  arsenic
     118.  cadmium
     119.  chromium
     120.  copper
     122.  lead
     124.  nickel
     125.  selenium
     128.  zinc

Arsenic was detected above its treatability concentration  of  0.34
mg/1 in one sample.  This sample showed 2.5 mg/1 arsenic in  the
raw wastewater.  Therefore, arsenic  is selected for further  con-
sideration for limitation.
                                54

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Cadmium was detected  slightly above  its  treatable  concentration
in a sample containing 0.05 mg/1.  Treatability  for  cadmium
begins at 0.049 mg/1; thus, cadmium  is selected  for  further
consideration for limitation.

Chromium was detected above its treatability concentration in  two
samples analyzed.  The analytical data showed 0.67 mg/1  and  0.86
mg/1 chromium in the raw wastewater.  Since the  treatable concen-
tration for chromium  is 0.07 mg/1, chromium is selected  for
further consideration for limitation.

Copper has a treatability concentration  of 0.07 mg/1.  Two
samples were analyzed showing copper concentrations  of 3.2 mg/1
and 4.0 mg/1.  Both samples are significantly above  treatable
concentrations for copper; therefore, copper is  selected for
further consideration for limitation.

Lead was detected in treatable concentrations in both samples
analyzed.  The samples indicated 0.93 mg/1 and 1.3 mg/1  of lead
in the raw wastewater.  Lead concentrations starting at  0.08 mg/1
are considered treatable.  For this reason, lead is  selected for
further considered for limitation.

Nickel was detected above its treatability concentration in  two
samples analyzed.  The analytical data showed 1,0 mg/1 and 1.4
mg/1 of nickel in the untreated wastewater.  Since the treatable
concentration for nickel is 0.22 mg/1, nickel is selected for
further consideration for limitation.

Selenium was detected above its treatability concentration of
0.20 mg/1 in one raw wastewater sample.  The result  showed 2,0
mg/1 selenium in the untreated wastewater.  Therefore, selenium
is selected for further consideration for limitation.

Zinc has a treatability concentration of 0.23 mg/1.  One sample
analyzed showed zinc at a concentration of 6.1 mg/1  in the raw
wastewater.  This sample is significantly above the  treatable
concentration for zinc; for this reason, zinc is selected for
further consideration for limitation.
                               55

-------
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                                                                    56

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                  SECONDARY  URANIUM SUBCATEGORY

                           SECTION  VII

                CONTROL AND  TREATMENT TECHNOLOGIES


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

CURRENT CONTROL AND TREATMENT PRACTICES

Control and treatment technologies  are discussed in  general  in
Section VII of the General Development Document.  The basic  prin-
ciples of these technologies and the applicability  to wastewater
similar to that found in this subcategory  are  presented  there.
This section presents a summary  of  the control and  treatment
technologies that are currently being applied  to each of the
sources generating wastewater in this subcategory.   As discussed
in Section V, wastewater associated  with the secondary uranium
subcategory is characterized by  the  presence of the  toxic metal
pollutants and suspended solids.  This analysis is supported by
the raw (untreated) wastewater data, presented in Section V,  from
a uranium ore mill.  It is expected  that these pollutants are
present in each of the waste streams at concentrations above
treatability, and these waste streams are  commonly combined  for
treatment.  Construction of  one wastewater treatment system  for
combined treatment allows plants to  take advantage of economic
scale and in some instances  to combine streams of different
alkalinity to reduce treatment chemical requirements.  The direct
discharging plant in this subcategory currently has  a combined
wastewater treatment system  including chemical precipitation  and
sedimentation.  The options  selected for consideration for BPT,
BAT, NSPS, and pretreatment will be  summarized toward the end of
this section.

REFINERY FILTRATE

Uranium production from scrap and residues begins with acid
leaching the raw materials.   This dissolves the uranium  to facil-
itate separation from residual solids by filtration.  Ammonia is
added to the acid filtrate to precipitate  dissolved  uranium  and
the solids are again filtered, but  this time retained for further
processing.   The filtrate is discharged, along with  other process
                               57

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wastewater, to treatment which consists  of neutralization,  floc-
culation and sedimentation, and discharge to a  surface water.

SLAG LEACH SLURRY

In addition to solid uranium scrap and uranium  residues, magne-
sium fluoride slag from the magnesium reduction operation  is
sometimes used as a raw material for uranium recovery.  The
recovery process also involves acid leaching of the  slag which
dissolves uranium so that it is carried  away in the  acid.   Sepa-
ration of the uranium-containing acid and the leached slag  is
done by filtration, after which the slag solids are  discharged as
a slurry.  The slurry goes to the treatment system,  along with
other process wastewater, for lime and settle treatment, and
final discharge to a surface water.

SOLVENT EXTRACTION RAFFINATE

Purification of the uranium compound that results  from acid
leaching is done by solvent extraction.  An organic  solvent is
used to extract the uranium compound from the acid solution.  The
organic solvent selectively extracts the uranium compound.  Thus,
impurities from acid leaching are left in the acid solution.
This solvent extraction raffinate is discharged to combined
treatment consisting of neutralization and sedimentation,
followed by discharge to a surface water.

DIGESTION OPERATION WET AIR POLLUTION CONTROL

The acid leaching operation includes a water scrubber for control
of acid fumes generated by leaching.  The system completely
recirculates water to absorb particulates and acid gases until
scrubbing efficiency drops, and then the scrubber  liquor is batch
dumped into a sump.  In the sump, lime is added and  the batch is
allowed to settle.  The settled solids are collected and recycled
back into the digestion operation.  The  clarified  liquid is dis-
charged to combined treatment including  neutralization and
sedimentation, followed by discharge to  a surface water.

EVAPORATION AND CALCINATION WET AIR POLLUTION CONTROL

Evaporation follows the purification step in which the uranium
compound was extracted into an organic solvent.  After re-extrac-
tion into aqueous solution it is concentrated by evaporation.
The calcination step which follows converts the uranium compound
to uranium trioxide.  These off-gases contain much nitric acid.
Since the scrubber liquor absorbs the nitric acid, the liquor is
not discharged as a wastewater.  Rather  it is recycled to be used
to dilute fresh acid in the digestion operation.   Therefore, no
wastewater is discharged from the evaporation and  calcination
operations.
                                58

-------
 HYDROGEN REDUCTION AND HYDROFLUORINATION KOH WET AIR POLLUTION
 CONTROL

 Hydrogen reduction and hydrofluorination involve the final stages
 of preparing uranium tetrafluoride for the magnesium reduction
 operation.   Hydrogen reduction converts uranium trioxide produced
 in the  calcination step to uranium dioxide.  Hydrofluorination
 involves contacting uranium dioxide with hydrofluoric acid to
 produce uranium tetrafluoride.   The off-gases from these
 operations  are  scrubbed by a circulating KOH solution which
 neutralizes and scrubs the acidic fumes.  The scrubber liquor is
 completely  recycled until  scrubber efficiency diminishes;  then
 the liquor  is batch discharged to combined treatment.  Treatment
 consists of neutralization and  sedimentation,  followed by direct
 discharge to a  surface water.

 HYDROFLUORINATION WET AIR  POLLUTION CONTROL

 Hydrofluorination,  as described above,  involves contacting ura-
 nium dioxide with vaporized hydrofluoric acid  at elevated  temper-
 atures.   Within the off-gases  is a substantial concentration of
 unreacted hydrofluoric acid.   These fumes are  passed through a
 water scrubber  which absorbs much of the hydrofluoric acid.   Some
 gases pass  to the second scrubber noted above.   Since the  scrub-
 ber liquor  over the hydrofluorination unit absorbs acid,  and
 since there are not expected to be many contaminants in the  acid
 fumes,  the  scrubber liquor is  circulated until a desired  concen-
 tration of  hydrofluoric acid is attained.   Then the solution is
 drawn off and sold  for industrial use.   Therefore, the hydro-
 fluorination scrubber generates no wastewater  that needs  to  be
 treated or  discharged.

 CONTROL AND TREATMENT OPTIONS

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

 Examination  of  the  waste streams  in this subcategory shows  that
 no  further  in-process flow reduction is achievable.   Therefore,
 options  including flow reduction  were not  considered.   On  the
 assumption  that no  organics are present (  discussed in Section
 VI), options  including  activated  carbon adsorption were not
 considered.

 OPTION A

 Option A  for  the  secondary uranium subcategory  requires control
 and treatment technologies  to reduce  the discharge of pollutant
mass.
                                59

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

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

OPTION C

Option C for the secondary uranium subcategory consists of all
control and treatment requirements of Option A (ammonia steam
stripping, chemical precipitation and sedimentation) plus multi-
media filtration technology added at the end of the Option A
treatment scheme.  Multimedia filtration is used to remove
suspended solids, including precipitates of metals, beyond the
concentration attainable by gravity sedimentation.  The filter
suggested is of the gravity, mixed- media type, although other
forms of filters, such as rapid sand filters or pressure filters
would perform satisfactorily.  The addition of filters  also
provides consistent removal during periods of time in which  there
are rapid increases in flows or loadings of pollutants  to the
treatment system.

EPA is investigating whether organic solvent is discharged as
part of the solvent extraction raffinate waste stream.  If so,
the Agency will consider including organic removal technologies
such as activated carbon or chemical oxidation in the Option C
treatment scheme at promulgation.
                                60

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                   SECONDARY URANIUM SUBCATEGORY

                            SECTION VIII

            COSTS,  ENERGY,  AND NONWATER QUALITY ASPECTS


This  section  presents a  summary  of compliance  costs  for  the
secondary  uranium  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 Section X of  this  supplement, these cost
estimates  provide  a basis  for evaluating  each  regulatory option.
These cost  estimates are also used in  determining  the probable
economic impact of regulation on the subcategory at  different
pollutant discharge levels.   In  addition, this section addresses
nonwater quality environmental impacts of wastewater treatment
and control alternatives,  including air pollution,  solid wastes,
and energy  requirements, which are specific to the secondary
uranium 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 secondary  uranium  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.

Preliminary treatment consisting of ammonia steam  stripping for
waste streams containing treatable concentrations  of ammonia is
also  included in Option  A.

OPTION C

Option C for the secondary uranium  subcategory consists  of all
control and treatment requirements  of Option A (ammonia  steam
stripping,  chemical precipitation  and  sedimentation)  plus  multi-
media  filtration technology  added  at the  end of the  Option A
treatment scheme.

COST METHODOLOGY

A detailed  discussion of the methodology used  to develop  the
compliance costs is presented  in Section VIII  of the  General
Development Document.   Plant-by-plant compliance costs have  been
                               61

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estimated for the nonferrous metals manufacturing category and
are presented in the administrative record supporting this regu-
lation.  The costs developed for the proposed regulation are
presented in Table VIII-1 for the direct dischargers in this
subcategory.

Each of the general assumptions used to develop compliance costs
is presented in Section VII1 of the General Development Document.
No subcategory-specific assumptions were used in developing
compliance costs for the secondary uranium 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 secondary
uranium 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 76,000 kWh/yr, and for Option C the estimated require-
ment is 85,000 kWh/yr.  Option C energy requirements increased
over those for Option A because filtration is being added as an
end-of-pipe treatment technology.  Since recycle and reuse of
scrubber liquor is already practiced in this subcategory, energy
requirement savings resulting from flow reduction measures are
not reflected in this analysis.  Both Option A and Option C
energy requirements represent less than 1 percent of the energy
usage in the secondary uranium industry.  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 secondary uranium subcategory is due to
the precipitation of metals as hydroxides and carbonates using
lime.  Sludges associated with the secondary uranium subcategory
will necessarily contain quantities of toxic metal pollutants.
Wastes generated by secondary metal industries can be regulated
as hazardous.  However, the Agency examined the solid wastes that
would be generated at secondary nonferrous metals manufacturing
plants by the suggested treatment technologies and believes they
are not hazardous wastes under the Agency1s regulations imple-
menting Section 3001 of the Resource Conservation and Recovery
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Act.   None  of  the  secondary uranium  subcategory  wastes  are  listed
specifically as hazardous, nor  are they  likely to  exhibit a char-
acteristic  of  hazardous waste.   This judgement is  made  based on
the recommended technology of lime precipitation and  filtration.
By the addition of a  small excess of lime  during treatment,  simi-
lar sludges, specifically toxic metal bearing sludges,  generated
by other  industries such as the iron and steel industry passed
the Extraction Procedure (EP) toxicity test.  See  40  CFR §261.24.
Thus,  the Agency believes that  the wastewater sludges will
similarly not  be EP toxic if the recommended technology is
applied.

Although  it is the Agency's view that solid wastes generated as a
result of these guidelines are  not expected to be  hazardous,
generators  of  these wastes must test the waste to  determine  if
the wastes  meet any of the characteristics of hazardous  waste
(see 40 CFR 262.11).

If these  wastes should be identified or are listed as hazardous,
they will come within the scope of RCRA's  "cradle  to  grave"  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 CFR Part 464 46  FR 2802 (January 12,  1981), 47 FR
32274  (July 26, 1982).

Even if these wastes are not identified as hazardous, they still
must be disposed of in compliance with the Subtitle D open dump-
ing standards, implementing 4004 of  RCRA.  See 44  FR  53438
(September 13, 1979).   It is estimated that the  secondary uranium
subcategory will generate 262 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.
                                63

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AIR POLLUTION

There is no reason to believe that any substantial air pollution
problems will result from implementation of ammonia steam strip-
ping, chemical precipitation, sedimentation, and multimedia fil-
tration.  Ammonia steam stripping yields an aqueous ammonia
stream.  The other technologies transfer pollutants to solid
waste and are not likely to transfer pollutants to air.
                               64

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                Table VIII-1

COST OF COMPLIANCE FOR THE SECONDARY URANIUM
                SUBCATEGORY
             DIRECT DISCHARGERS

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

    A            28,600            73,644

    C            54,312            86,452
                     65

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                  SECONDARY URANIUM SUBCATEGORY

                            SECTION IX

     BEST PRACTICABLE CONTROL TECJhiNOLOGY CURRENTLY AVAILABLE


This section defines the effluent characteristics attainable
through the application of best practicable control technology
currently available (BPT), Section 301(b)(a)(A).  BPT reflects
the existing performance by plants of various sizes, ages, and
manufacturing processes within the secondary uranium 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. 1176JIBPT focuses on
end-of-pipe treatment rather than process changes or internal
controls,  except where such practices are common industry
practice.

TECHNICAL APPROACH TO BPT

The Agency studied the nonferrous metals category to identify the
processes used, the wastewaters generated, and the treatment pro-
cesses installed.  Information was collected from industry using
data collection portfolios, and specific plants were sampled and
the wastewaters analyzed.  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.
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As explained in Section IV, the secondary uranium  subcategory has
been subdivided into seven potential wastewater  sources.   Since
the water use, discharge rates, and pollutant  characteristics of
each of these wastewaters is potentially unique, effluent  limita-
tions will be developed for each of the seven  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
analyzed to determine the flow to be used as part  of the basis
for BPT mass limitations.  The selected flow (sometimes  referred
to as the BPT regulatory flow 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, the  current  control
and treatment technologies consist of chemical precipitation  and
sedimentation (lime and settle technology) and a combination  of
reuse and recycle to reduce flow.  Ammonia steam stripping is
applied to streams with treatable concentrations of ammonia.

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 kilogram  of pro-
duction - mg/kg) were calculated based on the  BPT  regulatory  flow
(1/kkg) and the concentration achievable by the  BPT level  of
                                68

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treatment technology (mg/1) for each pollutant parameter  to  be
limited under BPT.  These mass loadings are published  in  the
Federal Register and in CFR Part 400 as the effluent limitations
guidelinesT

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 secondary uranium 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 Weyerhaueser
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, and
                               69

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ammonia steam stripping preliminary treatment to remove ammonia.
These technologies are demonstrated and economically achievable
since they are already in place at several discharging plants
throughout the nonferrous metals manufacturing category.

Ammonia steam stripping is demonstrated at seven facilities in
the nonferrous metals manufacturing category.  These facilities
are treating ammonia bearing wastewaters associated with the
production of primary tungsten, primary columbium and tantalum,
primary molybdenum, secondary tungsten and cobalt, secondary
molybdenum and vanadium, and primary zirconium and hafnium.  EPA
believes that performance data from the iron and steel manufac-
turing category provide a valid measure of this technology's per-
formance on nonferrous metals manufacturing category wastewater
because raw wastewater concentrations of ammonia are of the same
order of magnitude in the respective raw wastewater matrices.

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

The Agency has verified the proposed steam stripping performance
values using steam stripping data collected at a primary zir-
conium and hafnium plant which has raw ammonia levels as high as
any in the nonferrous metals manufacturing category.  Data col-
lected by the plant represent almost two years of daily opera-
tions, and support the long-term mean used to establish treatment
effectiveness.

Implementation of the proposed BPT limitations will remove annu-
ally an estimated 1,280 kg of toxic metals, 283 kg of uranium,
and 1,763 kg of TSS.  While the one discharging plant has most of
the equipment in-place to comply with BPT, EPA does not believe
that the plant is currently achieving the proposed BPT limita-
tions.  The Agency projects capital and annual costs of $28,600
and $73,644 (1982 dollars) respectively for modifications to
technology presently in-place at the discharging facility to
achieve proposed BPT regulations.  The end-of-pipe treatment
configuration for Option A is presented in Figure IX-1.
                                70

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WASTEWATER  DISCHARGE  RATES

A BPT discharge  rate  is  calculated  for  each subdivision based on
the average  of the  flows  of  the  existing  plants,  as  determined
from analysis of 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  seven 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 the intermediate product
which is produced by  the  process associated with  the waste stream
in question.  These production normalizing  parameters,  or PNPs,
are also listed  in  Table  IX-1.

Section V of this document further  describes  the  discharge flow
rates and presents  the water use and discharge flow  rates for
each plant  by subdivision in Tables V-1 through V-7.

REFINERY FILTRATE

The BPT wastewater  discharge rate for refinery filtrate is 34,800
1/kkg (8,350 gal/ton)  of uranium trioxide produced.   This rate is
allocated for those plants that  acid leach  scrap  uranium mate-
rials to recover the  uranium.  After the  dissolved uranium in the
acid is precipitated  and  filtered,  the  filtrate is discharged to
treatment.   Only one  plant in this  subcategory employs  this oper-
ation.  This plant  is a direct discharger and  the waste generated
is treated with  lime  and  settle  technology  prior  to  discharge to
a surface water.  Production normalized flows  for this  waste
stream are presented  in Table V-1.

SLAG LEACH  SLURRY

The BPT wastewater  discharge rate for slag  leach  slurry is 3,800
1/kkg (910 gal'/ton) of uranium trioxide produced.  This rate is
allocated only for  those plants  which leach magnesium fluoride
slag, recycled from the magnesium reduction operation,  to recover
the residual uranium  in the  slag.   The  method  of  recovery is by
dissolving  the uranium by acid leaching the slag, then  separating
the uranium-containing acid  from  the leached slag.   The solution
goes to further  processing while  the slag is discharged as a
slurry and undergoes neutralization and sedimentation treatment.
Water use and wastewater discharge  rates  for slag leach slurry
are presented in Table V-2.

SOLVENT EXTRACTION  RAFFINATE

The BPT wastewater discharge rate for solvent  extraction raffi-
nate is 5,300 1/kkg (1,270 gal/ton) of  uranium trioxide produced.
                               71

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This rate is allocated for those plants which purify the  acid-
dissolved uranium compound by extracting the uranium compound
into an organic solvent, leaving behind all impurities that were
leached along with the uranium.  One plant in this subcategory
employs such a purification process and it discharges the  extrac-
tion raffinate to its lime and settle treatment system before
direct discharge.  The production normalized flows for this
subdivision are presented in Table V-3.

DIGESTION OPERATION WET AIR POLLUTION CONTROL

The BPT wastewater discharge rate for digestion operation  wet air
pollution control is 30 1/kkg  (7.2 gal/ton) of uranium trioxide
produced based on partial recycle of scrubber liquor.  This rate
is allocated only for those plants that incorporate a water
scrubber on the acid leaching system.  The plant  in this  subcate-
gory that has a scrubber over its acid leaching operation  pres-
ently practices complete recycling of the scrubber liquor  until
scrubber efficiency drops and the solution is batch dumped.
Because recycle was already in use by the plant,  the BPT  dis-
charge rate was based on recycle.  The wastewater from this
scrubber is pretreated to recover solids which are reused  in the
digestion operation.  The remainder of the wastewater is  treated
and discharged.  Water use and discharge rates for the digestion
operation scrubber are presented in Table V-4.

EVAPORATION AND CALCINATION WET AIR POLLUTION CONTROL

No BPT wastewater discharge rate is provided for  evaporation and
calcination wet air pollution control.  This requirement  is
applicable to those plants that use evaporators and calcinators
to respectively concentrate an intermediate uranium compound and
then effectively burn it to convert it to uranium trioxide.  The
BPT discharge rate is proposed as zero because the one discharg-
ing plant in this subcategory that uses these operations  recycles
all their scrubber liquor to the digestion operation to use for
dilution of fresh leaching acid.  Because 100 percent recycle  is
demonstrated in this subcategory, the BPT discharge rate  reflects
this capability.  This production normalized discharge rate is
also presented in Table V-5.

HYDROGEN REDUCTION AND HYDROFLUORINATION KOH WET  AIR POLLUTION
CONTROL

The BPT wastewater discharge rate for hydrogen reduction  and
hydrofluorination KOH wet air pollution control is 20 1/kkg  (4.8
gal/ton) of uranium tetrafluoride produced based  on partial
recycle.  This rate is allocated only for those plants that use
hydrogen reduction to convert uranium trioxide to uranium dioxide
and then hydrofluorinate uranium dioxide to produce uranium
                                72

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tetrafluoride, and scrub the gases from  these  operations  with  a
KOH scrubber.  Since this plant presently operates  the  scrubber
at a high recycle rate, the BPT discharge rate reflects this
demonstrated performance.  Table V-6 also presents  the water use
and discharge rates for this waste stream.

HYDROFLUORINATION WET AIR POLLUTION CONTROL

No BPT wastewater discharge rate is proposed for hydrofluorina-
tion wet air pollution control.  This requirement is  applicable
only to those plants which use a water scrubber to  control  acid
fumes from the hydrofluorination unit.   The BPT discharge rate is
.proposed as zero because the one plant in this subcategory  that
operates such a scrubber recycles the scrubber liquor to  absorb
the hydrofluoric acid fumes until a desired concentration of
hydrofluoric acid is attained.  Then the scrubber solution  is
drawn off and sold for industrial use.   Since  this  recycle  tech-
nology is demonstrated within this subcategory, the BPT discharge
rate reflects that capability.  Table V-7 also presents the water
use and discharge rate for the hydrofluorination wet  air  pollu-
tion control system.

REGULATED POLLUTANT PARAMETERS

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

     119.  chromium
     120.  copper
     124.  nickel
           ammonia
           fluoride
           uranium
           TSS
           pH

EFFLUENT LIMITATIONS

The treatable concentrations achievable  by application of the
proposed BPT are discussed in Section VII of the General  Devel-
opment Document and summarized there in  Table  VII-19.  These
treatable concentrations (both one day maximum and  monthly  aver-
age values) are multiplied by the BPT normalized discharge  flows
summarized in Table IX-1 to calculate the mass of pollutants
allowed to be discharged per mass of product.   The  results  of
these calculations in milligrams of pollutant  per kilogram  of
product represent the BPT effluent limitations and  are presented
in Table IX-2 for each individual waste  stream.
                               73

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-------
                       Table IX-2

              BPT MASS LIMITATIONS FOR THE
             SECONDARY URANIUM SUBCATEGORY
(a)  Refinery Filtrate

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)         15.310             6.264
Copper                   66.120            34.800
Nickel                   66.820            44.200
Ammonia (as N)        4,639.000         2,039.000
Fluoride              1,218.000           696.000
Uranium                 139.200            78.300
Total Suspended       1,427.000           678.600
 Solids
pH                     Within the range of 7.5 to  10.0
                                at all times
(b)  Slag Leach Slurry

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.672             0.684
Copper                    7.220             3.800
Nickel                    7.296             4.826
Ammonia (as N)          506.500           222.700
Fluoride                133.000            76.000
Uranium                  15.200             8.550
Total Suspended         155.800            74.100
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
                               75

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                 Table IX-2 (Continued)

              BPT MASS LIMITATIONS FOR THE
             SECONDARY URANIUM SUBCATEGORY
(c)  Solvent Extraction Raffinate

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

  rog/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          2.332             0.954
Copper                   10.070             5.300
Nickel                   10.180             6.731
Ammonia (as N)          706.500           310.600
Fluoride                185.500           106.000
Uranium                  21.200            11.930
Total Suspended         217.300           103.400
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
(d)  Digestion Operation Wet Air Pollution Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.013             0.005
Copper                    0.057             0.030
Nickel                    0.058             0.038
Ammonia (as N)            3.900             1.758
Fluoride                  1.050             0.600
Uranium                   0.120             0.068
Total Suspended           1.230             0.585
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
                                76

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                 Table  IX-2  (Continued)

              BPT MASS  LIMITATIONS  FOR THE
             SECONDARY  URANIUM  SUBCATEGORY
(e)  Evaporation and Calcination Wet  Air  Pollution
     Control

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

  mg/kg  (Ib/million Ibs) of uranium  trioxide produced

Chromium  (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia  (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
Total Suspended           0.000             0.000
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all  times
(f)  Hydrogen Reduction and Hydrofluorination KOH Wet
     Air Pollution Control

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

           ing/kg  (Ib/million  Ibs) of  uranium
                  tetrafluoride  produced

Chromium (total)          0.009             0.004
Copper                    0.038             0.020
Nickel                    0.038             0.025
Ammonia (as N)            2.666             1.172
Fluoride                  0.700             0.400
Uranium                   0.080             0.045
Total Suspended           0.820             0.390
 Solids
pH                     Within the range of 7.5 to 10.0
                                 at  all  times
                               77

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                 Table IX-2 (Continued)

              BPT MASS LIMITATIONS FOR THE
             SECONDARY URANIUM SUBCATEGORY
(g)  Hydrofluorination Wet Air Pollution  Control

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

    mg/kg (lb/mi11ion Ibs) of uranium tetrafluoride
                        produced

Chromium (total)          0.000              0.000
Copper                    0.000              0.000
Nickel                    0.000              0.000
Ammonia (as N)            0.000              0.000
Fluoride                  0.000              0.000
Uranium                   0.000              0.000
Total Suspended           0.000              0.000
 Solids
pH                     Within the range of  7.5 to 10.0
                                at all times
                                78

-------
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                  SECONDARY URANIUM 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 (B.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
evaluated the available possibilities to ensure that the most
effective and beneficial technologies were used as the basis of
BAT.  To accomplish this, the Agency elected to examine two tech-
nology options which could be applied to the secondary uranium
subcategory as alternatives for the basis of BAT effluent
limitations.

For the development of BAT effluent limitations, mass loadings
were calculated for each wastewater source or subdivision in the
subcategory using the same technical approach as described in
Section IX for BPT limitations development.  The differences in
the mass loadings for BPT and BAT are due to increased treatment
                              81

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

The treatment technologies considered for BAT are summarized
below:

Option A (Figure X-1):

     •  Preliminary treatment with ammonia steam stripping
        (where required)
     •  Chemical precipitation and sedimentation

Option C (Figure X-2):

     •  Preliminary treatment with ammonia steam stripping
        (where required)
     •  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 pro-
gress toward the reduction of pollutant discharges above  and
beyond the progress achievable by BPT.

OPTION A

Option A for the secondary uranium subcategory  is equivalent to
the control and treatment technologies which were analyzed  for
BPT in Section IX (see Figures IX-1 or X-1).  The BPT  end-of-pipe
treatment scheme includes chemical precipitation and sedimenta-
tion, with ammonia steam stripping preliminary  treatment  of
wastewaters containing treatable concentrations of ammonia.  The
discharge rates for Option A are equal to the discharge rates
allocated to each stream as a BPT discharge flow.

OPTION C

Option C for the secondary uranium subcategory-consists of  all
control and treatment requirements of Option A  (chemical  precipi-
tation and sedimentation, with ammonia steam stripping prelimi-
nary treatment of wastewaters containing treatable concentrations
of ammonia) plus multimedia filtration technology added at  the
end of the Option A treatment scheme  (see Figure X-2).  Multi-
media filtration is used to remove suspended solids, including
precipitates of toxic metals, beyond the concentrations attain-
able 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.
                               82

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EPA is investigating whether organic solvent  is  discharged  as
part of the solvent extraction raffinate waste stream.   If  so,
the Agency will consider including organics removal  technologies
such as activated carbon or chemical oxidation in  the  Option C
treatment scheme at promulgation.

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, or benefit, achieved  by the  applica-
tion of the various treatment options is presented in  Section X
of the General Development Document.  In short,  sampling  data
collected during the field sampling program were used  to  charac-
terize the major waste streams considered for regulation.   At
each sampled facility, the sampling data were production  normal-
ized for each unit operation (i.e., mass of pollutant  generated
per mass of product manufactured).  This value,  referred  to as
the raw waste, was used to estimate the mass  of  toxic  pollutants
generated within the secondary uranium subcategory.  The  pollu-
tant removal estimates were calculated for each  plant  by  first
estimating the total mass of each pollutant in the untreated
wastewater.  This was calculated by first multiplying  the raw
waste values by the corresponding production value for that
stream and then summing these values for each pollutant for every
stream generated by the plant.

Next, the volume of wastewater discharged after  the  application
of each treatment option was estimated for each  operation at each
plant by comparing the actual discharge to the regulatory flow.
The smaller of the two values was selected and summed  with  the
other plant flows.  The mass of pollutant discharged was  then
estimated by multiplying the achievable concentration  values
attainable with the option (mg/1) by the estimated volume of
process wastewater discharged by the subcategory.  The mass of
pollutant removed is the difference between the  estimated mass  of
pollutant generated by each plant in the subcategory and  the mass
of pollutant discharged after application of  the treatment
option.  The pollutant removal estimates for  direct  dischargers
in the secondary uranium 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
                               83

-------
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
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 annualized  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 secondary uranium 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, with ammonia steam
stripping preliminary treatment of wastewater containing  treat-
able concentrations of ammonia.  The estimated capital cost of
proposed BAT is $54,312 (1982 dollars) and the annual cost is
$86,452 (1982 dollars).  The end-of-pipe treatment configura-
tion for Option C is presented in Figure X-2.

EPA is proposing multimedia filtration as part of the BAT tech-
nology because this technology is demonstrated by 25 plants in .
the nonferrous metals manufacturing category, and results in
additional removal of toxic metals.  In addition, filtration  adds
reliability to the treatment system by making it  less susceptible
to operator error and to sudden changes in raw wastewater flow
and concentrations.

Implementation of the control and treatment technologies  of
Option C would remove annually an estimated  1,304 kilograms of
toxic metal pollutants and 289 kilograms of uranium, which is  24
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 seven 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 the intermediate product
which is produced by  the process associated with  the waste stream
                                84

-------
in question.  These production normalizing parameters,  or  PNPs,
are also listed in Table X-3.

The BAT discharge rates reflect no flow reduction  requirements  as
compared to the BPT option flows.  In-process  flow reduction  was
not achievable for any waste streams  in this subcategory.   As an
example, the acid leach scrubber used at one of  the secondary
uranium plants already operates with  extensive recycle.  Conse-
quently, 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)  (1976),  the
Agency placed particular emphasis on  the toxic pollutants.  The
raw wastewater concentrations from individual  operations and  the
subcategory as a whole were examined  to select certain  pollutants
and pollutant parameters for limitation.  This examination and
evaluation was presented in Section VI.  The Agency, however, has
chosen not to regulate all eight toxic pollutants  selected 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 estimate analysis.
The pollutants selected for specific  limitation  are listed below:

     119.  chromium
     120.  copper
     124.  nickel
           ammonia
           fluoride
           uranium

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
                               85

-------
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.

The toxic metal pollutants selected for specific limitation  in
the secondary uranium subcategory to control the discharges  of
toxic metal pollutants are chromium, copper, and nickel.  Ammonia
is also selected for limitation since the methods used to control
chromium, copper, and nickel are not effective  in the control of
ammonia.  The following toxic metal pollutants  are excluded  from
limitation on the basis that they are effectively controlled by
the limitations developed for chromium, copper, and nickel:

     115.  arsenic
     118.  cadmium
     122.  lead
     125.  selenium
     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.
                                86

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                      Table X-2

              COST OF COMPLIANCE FOR THE
            SECONDARY URANIUM SUBCATEGORY

                  Direct Dischargers


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

  A                    28,600                   73,644

  C                    54,312                   86,452
                         88

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                       Table X-4

              BAT MASS LIMITATIONS FOR THE
             SECONDARY URANIUM SUBCATEGORY
(a)  Refinery Filtrate

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)         12.880             5.220
Copper                   44.550            21.230
Nickel                   19.140            12.880
Ammonia (as N)        1,439.000         2,039.000
Fluoride              1,218.000           696.000
Uranium                  93.260            52.550
(b)  Slag Leach Slurry

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.406             0.570
Copper                    4.864             2.318
Nickel                    2.090             1.406
Ammonia (as N)          506.500           222.500
Fluoride                133.000             76.000
Uranium                  10.180             5.738
(c)  Solvent Extraction Raffinate

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium  (total)          1.961             0.795
Copper                    6.784             3.233
Nickel                    2.915             1.961
Ammonia (as N)          706.500            310.600
Fluoride                185.500            106.000
Uranium                  14.200             8.003
                               90

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                 Table X-4  (Continued)

              BAT MASS LIMITATIONS  FOR  THE
             SECONDARY URANIUM  SUBCATEGORY
(d)  Digestion Operation Wet Air  Pollution Control

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

  mg/kg (Ib/million Ibs) of uranium  trioxide  produced

Chromium  (total)          0.011              0.005
Copper                    0.038             0.018
Nickel                    0.017             0.011
Ammonia (as N)            3.999             1.758
Fluoride                  1.050             0.600
Uranium                   0.080             0.045
(e)  Evaporation and Calcination Wet  Air  Pollution
     Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide  produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0. 000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
(f)  Hydrogen Reduction and Hydrofluorination KOH Wet
     Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium  tetrafluoride
                        produced

Chromium (total)          0.007              0.003
Copper                    0.026              0.012
Nickel                    0.011              0.007
Ammonia (as N)            2.666              1.1 72
Fluoride                  0.700              0.400
Uranium                   0.054              0.030


                                91

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                 Table X-4  (Continued)

              BAT MASS LIMITATIONS FOR  THE
             SECONDARY URANIUM SUBCATEGORY
(g)  Hydrofluorination Wet Air Pollution  Control

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

    rog/kg (Ib/million Ibs) of uranium  tetrafluoride
                        produced

Chromium (total)          0.000              0.000
Copper                    0.000              0.000
Nickel                    0.000              0.000
Ammonia (as N)            0.000              0.000
Fluoride                  0.000              0.000
Uranium                   0.000              0.000
                                92

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                  SECONDARY  URANIUM SUBCATEGORY

                             SECTION XI

                 NEW  SOURCE  PERFORMANCE  STANDARDS


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

This section describes  the technologies  for treatment  of waste-
water from new  sources  and presents  mass discharge standards  for
regulatory pollutants for NSPS  in the secondary  uranium 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
secondary uranium plants.  This result is a consequence of care-
ful review by the Agency of  a wide  range of technical  options  for
new source treatment  systems which  is discussed  in Section XI  of
the General Development Document.   This  review of  the  secondary
uranium 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
characteristics of new plants would  not  be similar to  those from
existing plants, since the processes used by new sources are  not
expected to differ from those used  at existing sources.  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
X-3.

Treatment technologies considered for the NSPS options are
identical to the treatment technologies  considered for the BAT
options.   These options are:
                               95

-------
OPTION A
     •  Preliminary treatment with ammonia steam stripping
        (where required)
     •  Chemical precipitation and sedimentation

OPTION C

     •  Preliminary treatment with ammonia steam stripping
        (where required)
     •  Chemical precipitation and sedimentation
     •  Multimedia filtration

EPA is investigating whether organic solvent is discharged as
part of the solvent extraction raffinate waste stream.   If so,
the Agency will consider including organics removal technologies
such as activated carbon or chemical oxidation in  the Option C
treatment scheme at promulgation.

NSPS OPTION SELECTION

EPA proposed that the best available demonstrated  technology for
the secondary uranium subcategory be equivalent to Option C
(ammonia steam stripping, chemical precipitation,  sedimentation,
and multimedia filtration).  Filtration technology is demon-
strated  in 25 plants in the nonferrous metals manufacturing
category.  Ammonia steam stripping technology is transferred from
the iron and steel category as noted in the discussion of the BAT
option selection in Section X.

The wastewater flow rates for NSPS are the same as the BAT flow
rates.  Flow reduction measures for NSPS are not feasible as a
review of the industry indicates that no new demonstrated tech-
nologies that improve on BAT technology exist.  EPA does not
believe that new plants could achieve any additional  flow reduc-
tion beyond the 90 to 100 percent scrubber effluent recycle
presently practiced in the industry.

REGULATED POLLUTANT PARAMETERS

The Agency has no reason to believe that the pollutants  that will
be found in treatable concentrations in processes  within new
sources will be any different than with existing sources.
Accordingly, pollutants and pollutant parameters selected for
limitation under NSPS, in accordance with the rationale  of
Sections VI and X, are identical to those selected for BAT.  The
conventional pollutant parameters TSS and pH are also selected
for limitation.
                                96

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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 calcu-
lations are the production-based new source performance  stand-
ards.  These standards are presented in Tables XI-2.
                               97

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-------
                       Table XI-2

       NSPS FOR THE SECONDARY  URANIUM  SUBCATEGORY
(a)  Refinery Filtrate

   Pollutant or        Maximum for       Maximum  for
Pollutant Property _ Any One Day _ Monthly Average
mg/kg (Ib/million
Chromium (total)
Copper
Nickel
Ammonia (as N)
Fluoride
Uranium
Total Suspended
Solids
pH
Ibs) of uranium trioxide produced
12.880
44.550
19.140
4,639.000
1,218.000
93.260
522.000

Within the
5.220
21.230
12.880
2,039.000
696.000
52.550
417.600

range of 7.5 to 10.0
                                at all times
(b)  Slag Leach Slurry

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          1.406             0.570
Copper                    4.864             2.318
Nickel                    2.090             1.406
Ammonia (as N)          506.500           222.700
Fluoride                133.000            76.000
Uranium                  10.180             5.738
Total Suspended          57.000            45.600
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
                               99

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                 Table XI-2 (Continued)

       NSPS FOR THE SECONDARY URANIUM SUBCATEGORY


(c)  Solvent Extraction Raffinate

   Pollutant or        Maximum for       Maximum for
Pollutant Property _ Any One Day _ Monthly Average
mg/kg (Ib/million
Chromium (total)
Copper
Nickel
Ammonia (as N)
Fluoride
Uranium
Total Suspended
Solids
pH
Ibs) of uranium trioxide produced
1.961
6.784
2.915
706.500
185.500
14.200
79.500

Within the
0.795
3.233
1.961
310.600
106.000
8.003
63.600

range of 7.5 to 10.0
                                at all times
(d)  Digestion Operation Wet Air Pollution Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium, (total)          0.011             0.005
Copper                    0.038             0.018
Nickel                    0.017             0.011
Ammonia (as N)            3.999             1.758
Fluoride                  1.050             0.600
Uranium                   0.080             0.045
Total Suspended           0.450             0.360
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
                               100

-------
                 Table XI-2  (Continued)

       NSPS FOR THE SECONDARY  URANIUM SUBCATEGORY
(e)  Evaporation and Calcination Wet  Air Pollution
     Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide  produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0. 000             0. 000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
Total Suspended           0.000             0.000
 Solids
pH                     Within the range of 7.5 to 1 0. 0
                                at all  times
(f)  Hydrogen Reduction and Hydrofluorination KOH Wet
     Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium  tetrafluoride
                        produced

Chromium (total)          0.007             0.003
Copper                    0.026             0.012
Nickel                    0.011              0.007
Ammonia (as N)    '        2.666             1.172
Fluoride                  0.700             0.400
Uranium                   0.054             0.030
Total Suspended           0.300             0.240
 Solids
pH                     Within the range of 7.5 to 10.0
                                at  all times
                               101

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                 Table XI-2 (Continued)

       NSPS FOR THE SECONDARY URANIUM SUBCATEGORY


(g)  Hydrofluorination Wet Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium tetrafluoride
                        produced

Chromium (total)          0.000             0.000
Copper                •    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
Total Suspended           0.000             0.000
 Solids
pH                     Within the range of 7.5 to 10.0
                                at all times
                               102

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                  SECONDARY URANIUM SUBCATEGORY

                           SECTION XII

                      PRETREATMENT STANDARDS


Section 307(b) of the Act requires EPA to promulgate pretreatment
standards for existing sources  (PSES), which must be achieved
within three years of promulgation.  PSES are designed to prevent
the discharge of pollutants which pass through, interfere with,
or are otherwise incompatible with the operation of publicly
owned treatment works (POTW).  The Clean Water Act of 1977
requires pretreatment for pollutants, such as heavy metals, that
limit POTW sludge management alternatives.  Section 307(c) of the
Act requires EPA to promulgate pretreatment standards for new
sources (PSNS) at the same time that it promulgates NSPS.  New
indirect discharge facilities, like new direct discharge facili-
ties, have the opportunity to incorporate the best available
demonstrated technologies, including process changes, in-plant
controls, and end-of-pipe treatment technologies, and to use
plant site selection to ensure adequate treatment system instal-
lation.  Pretreatment standards are to be technology based,
analogous to the best available technology for removal of toxic
pollutants.

Pretreatment standards for existing sources (PSES) will not be
proposed for the secondary uranium 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 sec-
ondary uranium subcategory.  Pretreatment standards for regulated
pollutants are presented based on the selected control and
treatment technology.

TECHNICAL APPROACH TO PRETREATMENT

Before proposing and promulgating pretreatment standards, the
Agency examines whether the pollutants discharged by the industry
pass through the POTW or interfere with the POTW operation or its
chosen sludge disposal practices.  In determining whether pollu-
tants 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
                               103

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

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

The Agency compares percentage removal rather than the mass  or
concentration of pollutants discharged because  the latter  would
not take into account the mass of pollutants discharged to the
POTW from non-industrial sources or the dilution of  the
pollutants in the POTW effluent  to lower concentrations due  to
the addition of large amounts of non-industrial wastewater.

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
Deve1opment Document.

Treatment technologies considered for  the PSNS  options are:

OPTION A

     •  Preliminary treatment with ammonia steam stripping
        (where required)
     •  Chemical precipitation and sedimentation

OPTION C

     •  Preliminary treatment with ammonia steam stripping
        (where required)
     •  Chemical precipitation and sedimentation
     •  Multimedia filtration
                                104

-------
EPA is investigating whether organic  solvent  is  discharged as
part of the solvent extraction raffinate waste stream.   If so,
the Agency will consider  including  organics removal  technologies
such as activated carbon  or chemical  oxidation in  the Option C
treatment scheme at promulgation.

PSNS OPTION SELECTION

Option C (ammonia steam stripping pretreatment,  chemical precipi-
tation, sedimentation, and multimedia filtration)  has been
selected as the regulatory approach for pretreatment standards
for new sources.  The basis of this selection is in  accordance
with the rationale for selection of the BAT option in Section X.

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
should achieve flow reduction beyond  the 90 to 100 percent
scrubber effluent recycle presently practiced in the industry.

REGULATED POLLUTANT PARAMETERS

Pollutants selected for limitation, in accordance  with the
rationale of Sections VI  and X, are identical to those selected
for limitation for BAT.   It is necessary to propose  PSNS to
prevent the pass-through  of chromium,  copper, nickel,  ammonia,
fluoride, and uranium, 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 are presented in  Table XII-2.
                               105

-------
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-------
                       Table XII-2

       PSNS  FOR  THE  SECONDARY  URANIUM SUBCATEGORY


 (a)  Refinery Filtrate

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

  rag/kg  (Ib/million  Ibs) of uranium  trioxide  produced

 Chromium (total)         12.880             5.220
 Copper                   44.550            21.230
 Nickel                   19.140            12.880
 Ammonia  (as N)         4,639.000         2,039.000
 Fluoride               1,218.000            696.000
 Uranium                  93.260            52.550


 (b)  Slag Leach  Slurry

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

  mg/kg  (Ib/million  Ibs) of uranium  trioxide  produced

 Chromium (total)          1.406             0.570
 Copper                    4.864        .     2.318
 Nickel                    2.090             1.406
 Ammonia  (as N)          506.500            222.700
 Fluoride                133.000            76.000
 Uranium                  10.180             5.738


 (c)  Solvent Extraction Raffinate

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

  mg/kg  (Ib/million  Ibs) of uranium  trioxide  produced

 Chromium (total)          1.961             0.795
 Copper                    6.784             3.233
 Nickel                    2.915             1.961
Ammonia (as N)          706.500            310.600
 Fluoride                185.500            106.000
 Uranium                  14.200             8.003
                               J07

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                Table XII-2 (Continued)

       PSNS FOR THE SECONDARY URANIUM SUBCATEGORY


(d)  Digestion Operation Wet Air Pollution Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.011             0.005
Copper                    0.038             0.018
Nickel                    0.017             0.011
Ammonia (as N)            3.999             1.758
Fluoride                  1.050             0.600
Uranium                   0.080             0.045
(e)  Evaporation and Calcination Wet Air Pollution
     Control

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

  mg/kg (Ib/million Ibs) of uranium trioxide produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0,000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
(f)  Hydrogen Reduction and Hydrofluorination KOH Wet
     Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium tetrafluoride
                        produced

Chromium (total)          0.007             0.003
Copper                    0.026             0.012
Nickel                    0.011             0.007
Ammonia (as N)            2.666             1.172
Fluoride                  0.700             0.400
Uranium                   0.054             0.030
                               108

-------
                Table XII-2  (Continued)

       PSNS FOR THE SECONDARY URANIUM  SUBCATEGORY


(g)  Hydrofluorination Wet Air Pollution Control

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

    mg/kg (Ib/million Ibs) of uranium  tetrafluoride
                        produced

Chromium (total)          0.000             0.000
Copper                    0.000             0.000
Nickel                    0.000             0.000
Ammonia (as N)            0.000             0.000
Fluoride                  0.000             0.000
Uranium                   0.000             0.000
                               109

-------
                  SECONDARY URANIUM SUBCATEGORY

                           SECTION XIII

          BEST CONVENTIONAL POLLUTANT CONTROL TECHNOLOGY


EPA is not proposing best conventional pollutant control technol-
ogy (BCT) for the secondary uranium subcategory at this time.
                               Ill

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