EPA 440/1-75/043
  GROUP I, PHASEII
    Development Document for Interim
   Final Effluent Limitations Guidelines
         and Proposed New Source
           Performance Standards
                   for the

              OTHER NON-FERTILIZER
              PHOSPHATE CHEMICALS
               Segment of the
            PHOSPHATE MANUFACTURING
           Point Source Category
                   *'  m.m  ~b
                  3) «-*2^^R*1 UJ
                    *L PRO^0^


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                  January 1975

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    DEVELOPMENT DOCUMENT FOR INTERIM FINAL
       EFFLUENT LIMITATIONS GUIDELINES
AND PROPOSED NEW SOURCE PERFORMANCE STANDARDS
                   FOR THE
        OTHER NON-FERTILIZER PHOSPHATE
           CHEMICALS SEGMENT OF THE
           PHOSPHATE MANUFACTURING
            POINT SOURCE CATEGORY
               Russell E. Train
                Administrator

                James L. Agee
      Assistant Administrator for Water
           and Hazardous Materials
                 Allen Cywin
    Director, Effluent Guidelines Division
              Chester E. Rhines
               Project Officer

                 January 1975
         Effluent Guidelines Division
   Office of Water and Hazardous Materials
     U.S. Environmental Protection Agency
           Washington, D.C.  20460

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                           Index
TITLE PAGE

ABSTRACT

TABLE OF CONTENTS
Section I

Section II

Section III

Section IV

Section V

Section VI

Section VTI

Section VIII


Section IX



Section X



Section XI


Section XII

Section XIII

Section XIV
Conclusions

Recommen dations

Introduction

Industry Subcategorization

Waste Characterization

Selection of Pollutant Parameters

Control and Treatment Technology

Cost, Energy and Non-Water
    Quality Aspects

Best Practicable Control Technology
    Currently Available, Interim Final
    Guidelines and Limitations

Best Available Technology Economically
    Achievable, Interim Final
    Guidelines and Limitations

Proposed New Source Performance
    Standards and Pretreatment Standards

Acknowledgments

References

Glossary
age

1

5

9

21

25

45

55


69




73




81


85

95

97

99
        TV;
                            AGMCY
                             ii

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•^
                          FIGURES

     UI-1         Defluorinated Phosphate Rock
                      Plant Locations

     HI_2         Defluorinated Phosphoric Acid
                      Plant Locations
                                                               20
     IH-3         Sodium Phosphates Plant Locations

      V-i          Defluorinated Phosphate Rock
                      Fluid Bed Process

      V-2         Defluorinated Phosphoric Acid                4Q
                      Vacuum Process

      v-3         Defluorinated Phosphoric Acid                ^
                      Submerged Combustion

      v-4         Defluorinated Phosphoric Acid                ^
                      Aeration Type

      V-5         Sodium  Phosphate Process from
                      Wet Process Phosphoric Acid

     VII-1         contaminated  (Pond)  Water Treatment          67

    Yin-1         Water Effluent Treatment Costs               72
                                 iii

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                        ABSTRACT
 EL£Ei';g: -«"• ss.-.sesr ssfe- £

 The three  main outputs  from the  study  were-
and  sodium  phosphates.   Notice  of interim final effluS^

^^^%£tdCline;.ha: been drafted ^"exfsSnglourc^s
a^ailaCle   !nd  Practjcable control  technology  currently
available,  and  for best available technology economicallv

   ie                       Stand-ds °f pLlormancealfo?
                           pretreatment  standards   for
Treatment technologies such as in-process or  end-of-process
    on units are available singly or in comb in at--inn -t-n
the recommended effluent guidelines.       "inarion tc
                        IV

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                         SECTION I


                         CONCLUSION


This study  was  conducted  for  the  purpose  of  extending
effluent limitations guidelines and standards of Performance
to   all  the  major  chemical  products  of  the  Phosphate
Manufacturing Point Source Category,  and  was  directed  at
prSduc?s   neither   covered   in   the  Phase  I  phosphate
manufacture  study,  nor  included  among   the   fertilizer
phSsphate products.  The Phase I phosphate study covered the
production   of   phosphorus,   and  products  derived  from
phosphorus.  This Phase II study covers phosphate  chemicals
produced  by  the  defluorination  of  phosphate  rock,  the
derluorination of phosphoric acid, and the sodium phosphates
produced   from   wet   process   phosphoric   acid.     The
Subcategories   previously  established  for  the  Phosphate
Manufacturing Point Source Category were:

    The Phosphorus Derived Chemicals Segment

    Subpart A - Phosphorus Production Subcategory

    Subpart B - Phosphorus Consuming Subcategory

    Subpart C - Phosphate Subcategory.

    The Other Non-Fertilizer   Phosphate  Chemicals   Segment,
    now added,  include:

    Subpart  D  - Defluorinated Phosphate  Rock Subcategory

    Subpart  E  - Defluorinated Phosphoric Acid Subcategory

     Subpart  F  - Sodium Phosphates Subcategory

 The  study  of subparts  A,   B  and  C  (Phase  I)  has been
 completed and  regulations published in the ^der^^e^is^r'
 Title 40, Part 422,  page  6580,  February   20,  1974.   This
 Phase II  study deals only with Subparts D, E, and F.

 The  major  waste water pollutant problems for Subparts D, E
 and F processes of phosphate chemicals manufacture are  much
 closer  associated  with  the  fertilizer phosphate industry
 problems  than  with  Subpart   A,   B   and   C   phosphate
 manufacturing  problems.   The  phosphoric acid raw material
 utilized  for  making  defluorinated  phosphoric  acid,  for
 making   sodium   phosphates,  and  used  as  a  reagent  in

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 ^hJ luPrina tlQn of rock, is exclusively produced by  the  wet
 Phosphoric acid process.  The purification processes car rlld
 on  constantly  in  this segment create fluoride waste water
 nhoSirj*  Resfues from salt purification processes conJain
 Drobl^f "Sldues ?lon9 with s*lt contaminants that  create
 problems  if  recycled  indefinitely,  and require blowdown
 The contaminated water recycle pond, heart of the fertil^Sr
 phosphate waste water treatment system,  provides  the  belt

 FlSorid^anS I?'. dealjng  W±th  most  of  these component?
 Fluorides, sulfates and phosphates deposit  in  the  recycle
 pond     under   favorable   water   balance  circumstances
 rad^10^S WltK?Ut dischar9e °f Process waste water    ?he
 radium  226  problem  is  similar  to that in the fertilizer
 phosphate industry.   Radium 226 can be and is controlled  by
 clar?f??^   Y  a*kaline  coagulation reaction and effective
 SeSS J           carrying out the  double  lime  effluent
 treatment   process.    Extremely   rigorous   controls  are
 essential to prevent flow into ground water through channels
 be bu?ltn,nS lm?r°per ,la?oon Iinin9 operations.   Dikes   mus?
 be built and maintained in a manner that  eliminates failure.
 Dike   failures have  occurred in  the slime ponds  of phosphate
 mining operations.   Dike  failure  is  a   serious   po?IntJa?
 hazard  from  contaminated  water ponds.   Dike failure  would
 lead  to massive  pollution  by at  least 5 highly objectionable
 pollutants  radium  226,  fluoride,  acidic   wastes,   phosphate
 and  suspended  solids.    Recommendations   that  drastically
 reduce  the   dike  failure   hazard  are   provided   in    this
 development  document.

 The   information on  fertilizer phosphates  in  the Development
 Document for  Effluent  Limitations Guidelines  and Slw  Source
smentth                     basic fertilizer cecs
segment of the fertilizer point source category is fully  as
important  as  the  information  gathered  in ?his study

        ""       ^    nc  fert±lizer   hos
   men    of   th                                     mcs
segment   of   the   phosphate  manufacturing  point  source
category.   Practicable  treatment  is  available  to  ?hese
manufacturing  operations  only  through  utilization of the
recirculation and reuse lagoon  developed  for  waste  water
treatment in wet phosphoric acid manufacture.

pEosnho^ odefluorinated  Phosphate  rock  and  defluorinated
?e^5£££?M  H   Processes  the  techniques  and  treatment
technologies  do  exist  and  are  commercially practiced to
achieve  essentially  no  process   waste   water   effluent
discharge  to  navigable  waters.   The  exception  to  tSs
situation  would  be  an  adventitious  condition  such   as
abnormal  rainfall  accumulation.   Under  such  a condition
treatment  technology  does  exist  to  treat   contaminated
process  waste  waters   for  reduction  of contaminants on a

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commerically demonstrated basis to  the  interim  final  and
proposed effluent limitation guideline levels.

in  the  sodium phosphates process, technology does exist to
continuously treat  the  process  waste  water  effluent  to
commercially demonstrated levels that meet the interim final
and proposed effluent limitation guideline levels.

in-process  modifications  and  end-of-process  plant  waste
water treatment technologies are in current   industrial  use
to"    enSle    new   non-fertilizer   phosphate   chemicals
manufacturing  plants   to  meet  the  proposed  new   source
standards.

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                         SECTION II
                      RECOMMENDATIONS

These amendments to the phosphate manufacturing point source
category  are  being introduced to include the defluorinated
phosphate rock subcategory (Subpart  D),  the  defluorinated
phosphoric  acid  subcategory  (Subpart  E)   and  the sodium
phosphates subcategory (Subpart F) .

Interim final effluent limitations  have  been  written- for
existing  sources,  covering  both  best practicable control
technology currently available (BPCTCA), and best  available
technology economically achievable (BATEA).

Notices of proposed effluent limitations and guidelines have
been written for
    1.   Pretreatment standards for existing sources.
    2.   Standards of performance for new sources (NSPS).
    3.   Pretreatment standards for new sources.

The regulations are about to appear in the Federal Register;
the Federal Register presents the  regulations  in  official
form.

The   effluent   guidelines   limitations  written  for  the
defluorinated rock and the defluorinated acid  subcategories
include  both  wastewater  volume  and  wastewater component
concentration limitations.  The guidelines written  for  the
sodium  phosphates  subcategory are based on weight units of
pollutant per weight unit of product.

Defluorinated Phosphate Rock and Defluorinated Phosphoric
Acid Subcategories

The  permissible  wastewater  volume  discharges  have  been
established  by  the  specialized  definitions  and  special
formulae developed for computing the  excess  rainfall  over
evaporation   cited  in  Sections  IX,  X  and  XI  for  the
recirculation and reuse ponds that are utilized in treatment
of wastewater of these subcategories.  It  is  essential  to
refer to these specialized definitions and formulae for full
comprehension of the regulations.  The permissible discharge
for  a  pond is the excess of rainfall collected by the pond
over evaporation from the pond surface.

The permissible discharge volumes  for  existent  ponds  for
BPCTCA,   BATEA   and   pretreatment  may  include  rainfall
collected by the outer surface of  the dam and by  a  seepage

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 interception ditch around the dam.  The  figure used  for  this
 outer   surface  and  ditch  area  may not be  greater than  30
 percent of  the  pond surface at maximum capacity.

 Discharges  from new source ponds and from ponds  constructed
 on or after the date of these regulations must be based  upon
 rainfall on the pond surface area at maximum  capacity.

 Ponds   utilized for BPCTCA must provide  sufficient freeboard
 to contain  the  heaviest rain expected in a ten year  period.
BATEA and NSPS ponds must provide  sufficient  freeboard
contain the heaviest rain expected in a 25 year period.
                                                 to
The  regulations  controlling  permissible discharge volumes
and freeboard requirements of ponds were  established  after
extensive discussions with representatives of industry.
Concentrations   of   pollutant   components
discharges for BPCTCA, BATEA and NSPS:
                                      permitted  in
Effluent
Characteristic
Total phosphorus
   (as P)
Fluoride
TSS
PH
                    Maximum for
                    any one day
(Metric  units,  mg/1)

               70
                        Effluent
                        Limitations

                           Average of  daily
                           values for  thirty
                           consecutive days
                           shall not exceed
35
              30              15
              50              25
              Within the range 6.0 to  9.0
Concentration of pollutant components permitted by  proposed
pretreatment regulations:
Pollutant or
Pollutant Property
                  Pretreatment
                  Standards
                    Maximum for
                    any one day
                          Average of daily
                          values for thirty
                          consecutive days
                          shall not exceed
      (Metric units)    mq/1 of effluent discharged

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BODjj                    	No limitation	
TSS                     	No limitation	
pH                      	No limitation	
Total phosphorus        70               35
Fluoride                30               15

The  volume  of  discharge  permitted  under pretreatment is
determined  by  the  interim  final  regulations  for   best
practicable control technology currently available.

Sodium Phosphates Subcategory

The  following limitations establish the quantity or quality
of pollutants or pollutant properties controlled by  interim
final  regulations  for  best practicable control technology
currently available:

Effluent                         Effluent
Characteristic                   Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall_not exceed

          (Metric units, kg/kkg of product)

TSS                     0.50            0.25
Total phosphorus        0.80            0.40
    (as P)
Fluoride                0.30            0.15
pH                      Within the range 6.0 to 9.0.

          (English units, lb/1000 Ib of product)

TSS                     0.50            0.25
Total phosphorus        0.80            0.40
    (as P)
Fluoride                0.30            0.15
pH                      Within the range 6.0 to 9.0.

The following limitations establish the quantity or  quality
of  pollutants or pollutant properties controlled  by interim
final regulations   for  best  available  control   technology
economically   achievable   and   for  proposed  new   source
performance standards:

Effluent                         Effluent
Characteristic                   Limitations

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                     Maximum for     Average of daily
                     any one day     values for thirty
                                     consecutive days
                     	     shall not exceed_

          (Metric units, kg/kkg of product)

 TSS                     0.35            0.18
 Total phosphorus        0.56            0.28
    (as P)
 Fluoride                0.21            0.11
 PH                      Within the range 6.0 to 9.0.

          (English units, lb/1000 Ib of product)

 TSS                     0.35            0.18
 Total phosphorus        0.56            0.28
    (as P)
 Fluoride                0.21            0.11
 PH                      Within the range 6.0 to 9.0.

 The   following   limitations   establish    the    proposed
 pretreatment   standards  for  existent  sources  and for nev
 sources:

 Pollutant or                 Pretreatment
 Pollutant Property          Standards

                     Maximum for     Average of daily
                     any one day     values  for thirty
                                     consecutive days
                     	     shall not exceed

       (Metric  units)    kq/kkg of product

 BOD5                     	No limitation	
 TSS                     	No limitation	
 pH                      	No limitation	
 Total phosphorus         0.80            O.UO
.Fluoride                  0.30            0.15

       (English units)   Ib/10OP Ib of .product

 BOD5                     	No limitation	
 TSS                     	No limitation	
 pH                      	No limitation	
 Total phosphorus         0.80            0.40
 Fluoride                  0.30            0.15

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                        SECTION III


                        INTRODUCTION


Section 301 (b)  of the Act requires the  achievement  by  not
later  than  July 1, 1977, of effluent limitations for point
sources, other than publicly owned  treatment  works,  which
are based on the application of the best practicable control
technology   currently   available   as   defined   by   the
Administration  pursuant  to  Section  30U (b)  of  the  Act.
section  301(b)  also  requires the achievement by not later
than  July  1,  1983,  of  effluent  limitations  for  point
sources,  other  than publicly owned treatment works.  These
are to be based on the application  of  the  best  available
technology  economically  achievable  which  will  result in
reasonable further progress  toward  the  national  goal  of
eliminating  the  discharge of all pollutants, as determined
in accordance with regulations issued by  the  Administrator
pursuant  to  Section 304(b) of the Act.  Section 306 of the
Act requires the achievement by new  sources  of  a  Federal
standard  of  performance  providing  for the control of the
discharge of pollutants which reflects the  greatest  degree
of  effluent reduction which the Administrator determines to
be achievable through the application of the best  available
demonstrated   control   technology,   processes,  operating
methods, or other alternatives, including where practicable,
a standard permitting no discharge of pollutants.

Section 304 (b) of the  Act  requires  the  Administrator  to
publish within one year of enactment of the Act, regulations
providing  guidelines for effluent limitations setting forth
the degree of  effluent   reduction  attainable  through  the
application  of  the  best  control  measures  and practices
achievable including  treatment  techniques,  processes  and
regulations  proposed  herein set forth effluent limitations
guidelines pursuant to Section 304(b) of  the  Act   for  the
fertilizer manufacturing  category of point sources.

Section  306   of  the Act requires the Administrator, within
one year after a category of sources is included in  a   list
published  pursuant to Section 306 (b)  (1)  (a) of the Act, to
propose  regulations  establishing  Federal   Standards   of
performances   for  new  sources within such  categories.  The
Administrator  published in  the "Federal Register  of  January
16,   1973   (38  F.R.  1624), a list of 27 source categories.
Publication of the  list  constituted  announcement  of  the
Administrator's  intention   of  establishing,  under Section
306,  standards of   performance  applicable   to  new  sources

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 within   the   fertilizer   manufactuirng   category  of   point
 sources,  which included within the  list  published January
 16,  1973.                                                   T

 The    effluent   limitations   guidelines  and  standards   of
 performance proposed  in  this   report were   developed  from
 operating  data,  sampling,  and information gathered from  six
 plants.   These plants represent a  very   high   percentage   of
 the  total number  of the industrial units in two of  the  three
 study processes.   The  methods  and procedures used in  the
 accumulation of the overall information  are described in  the
 following paragraphs.

 Summary of  Methods Used  for   Development of  the   Effluent
 Limitations Guidelines and  Standards  of  Performance

 The    effluent   limitations   guidelines  and  standards   of
 performance proposed  herein were developed in the  following
 manner.   The point source category was first  studied for  the
 purpose   of  determining  whether   separate   limitations  and
 standards are  appropriate for  different  segments within  the
 category.   This analysis  included  a determination of whether
 differences    in   raw   material   used,   product  produced,
 manufacturing   process  employed,   age,   size,   waste   water
 constituents,  and other factors  require  development of  sepa-
 rate  limitations and  standards  for different  segments of  the
 point source category.

 The   raw  waste  characteristics   for each such  segment were
 then  identified.  This  included   an  analysis   of   (1)    the
 source flow and volume of water  used  in  the process employed
 and   the sources of waste and waste waters in the plant;  and
 (2)   the  constituents  (including thermal)   of  all  waste
 waters,  including toxic constituents and other  constituents
 which result in taste, odor,  and  color  in  the  water  or
 aquatic  organisms.   The  constituents  of the waste waters
which should be subject to effluent   limitations  guidelines
 and standards  of performance were  identified.

 The   range  of  control  and treatment technologies existing
within  each   segment  was  identified.    This  included  an
 identification   of  each  distinct  control  and  treatment
technology,  including  both  inplant   and   end-of-process
technologies,   which  are  existent  or  capable  of  being
designed  for   each   segment.    It   also   included   an
 identification  in  terms  of  the  amount  of  constituents
 (including thermal)  and the effluent  level  resulting  from
the   application  of  each  of  the  treatment  and  control
technologies.  The problems, limitations and reliability  of
each were also identified.  In addition,  the nonwater impact
                          10

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of   these   technologies  upon  other  pollution  problems,
including air, solid waste, noise and  radiation  were  also
identified.   The  energy  requirements  of each control and
treatment technology was identified as well as the  cost  of
the application of such technologies.

The  information,  as  outlined above, was then evaluated in
order to determine what levels of technology constituted the
"best practicable control technology  currently  available",
the   "best   available   demonstrated  control  technology,
processes, operating methods, or  other  alternatives".   In
identifying   such   technologies,   various   factors  were
considered.  These included the total cost of application of
technology in relation to the effluent reduction benefits to
be achieved from such application, the age of equipment  and
facilities  involved,  the process employed, the engineering
aspects of the  application  of  various  types  of  control
techniques,  process changes, nonwater quality environmental
impact  (including energy requirements), and other factors.

Delineation of Study

The industry is characterized by a relatively  small  number
of  plants.   Only   1  plant exists for the sodium phosphate
subcategory.  Some of the plants did not cooperate with  the
study  because  of  trade  secret factors.  Fortunately, the
technology developed for the phosphorus derived  segment  of
phosphate  manufacturing,  and for the phosphate subcategory
of fertilizer manufacturing  is  extremely  well  suited  for
handling  the  waste  water  problems of this segment of the
industry.   The  background  technology  has  been  utilized
extensively in establishing  standards for the industry.

The  effluent  limitations   guidelines and standards of per-
formance  proposed   in  this  report  were  developed   from
operating  data,  sampling,  and information gathered from  6
plants.  The methods and procedures used in the accumulation
of that data is described  in the following paragraphs.

Identification and categorization of  the 3 processes covered
in this report were  made during the  preparation of the  Phase
I portion of  the  industry  report   on  Phosphorus  Derived
Chemicals.  These are:

          Defluorinated Phosphate Rock  (Subpart D)

           Defluorinated Phosphoric Acid  (Subpart EL

           Sodium Phosphates  (Subpart  FL
             (produced  from wet process phosphoric  acid)
                             11

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 Basis for Definition of Technology Levels

 The  validated  data  and samples described in the foregoing
 pages were the primary basis   for  choosing  the  levels  of
 technology which were considered to be  the  "best practicable
 control  technology currently  available",  the "best available
 technology economically achievable",  and  the "best available
 demonstrated  control technology,  process operating methods,
 or other alternatives".    This  selection  of  the  separate
 technologies,   of  necessity,  required  consideration of  such
 additional factors as  evaluation  of  the   engineering   and
 operational problems associated with the technology,  effect
 on existing processes,   total  cost  of  the  technology  in
 relation  to  the effluent reduction  that would be realized,
 energy  requirements  and  cost,   the  range   of   control
 variations on  contaminant concentration and/or quantity,  and
 non-water    quality   environmental  impact.     Information
 regarding   the   influence  of  these  diverse  factors   was
 obtained  from   a  number of sources.   These sources include
 government research information,  published  literature, trade
 organization publications,  United   States   process  patents,
 and qualified consultants.

 Implementation

 The value  of a  study such as this  is  entirely dependent  upon
 the  quality of  the data  from which  it is  made.   Particular
 attention  was,  therefore,  directed  to selecting  criteria  for
 determining  the commercial  installations to be   visited   and
 from  which  to collect information.

 In  this  Phase II  phosphate  study the  selection of  individual
 plants for participation  in the survey required  a  minimum of
 consideration after  the initial U.  S. industry plant identi-
 fication.    Two   of  the  three processes had less than  five
 total U. S. operating plants.   The  third process represented
a slightly larger number of operating plants, nine,  and  was
 found  to  have   essentially   identical  water   usage, water
 management and  effluent treatment characteristics  as one  of
the Phase I Phosphate Fertilizer Industry processes.

Because of the relatively few plants involved in each of the
Phase  II  processes,  the  consideration of exemplary plant
selection for the survey was not used.  For one process, all
U. S.  plants were included.  For another,  all except one  U.
S.  plant  were  included.  For the third process, its close
relationship to a similar Phase I process necessitated  that
only  two  plants  representing  each  of  the two different
                             12

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process variations in industrial  use  be  included  in  the
survey.

Contact  was  then  made with each of the plants selected in
the separate processes to establish a time for  a  screening
visit.   The  screening visit had the objective of informing
the plant manager on the purpose and intent  of  the  study.
Information  acquired during the visit was used to determine
whether that particular plant was  to  be  included  in  the
study  or  whether  other  plants  and/or  conditions better
exemplified industry standards.  The plants included in  the
survey  were found to have good effluent monitoring programs
in effect and were maintaining comprehensive records.  Study
covered the important fluoride, suspended solids, phosphate,
radium 226, and pH parameters.   In  some  cases  the  plant
records  did  not  necessarily isolate the liquid streams to
and from the specific process unit involved  in  the  survey
but  did  provide  valuable  information on water management
control.

A comparative evaluation was  made  of  the  various  plants
visited.   This  evaluation was based upon the criteria used
in the Phase I study.  It consisted of the following points:

1.  Discharge_Effluent Quantities

    Installations with low effluent quantities including
    some plants operating with no discharge of process
    waste water.

2.  Effluent Contaminant Level

    Installations with low effluent contaminant
    concentrations and quantities.

3.  Effluent Treatment Method and Effectiveness

    Installations utilizing the best currently available
    treatment methods, and control equipment.

4.  Water Management  Practice

    Installations with utilization of good management
    practices such as main water re-use,  planning  for
    seasonal rainfall variations, in-plant water  seg-
    regation and  proximity of cooling towers  to
    operating units where airborne contamination  can
    occur.

5-  Land Utilization
                               13

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     Consideration  of  land area  involved in  waste water
     effluent  control  system with the  most acceptable being
     those with the least area.

 6•   Air  Pollution  Control

     Consideration  given  to those plants with  the most compre-
     hensive and effective air pollution control.   In turn
     liquid effluent from such plants  may represent the most
     serious waste  water  effluent condition.   Major air
     pollution problems considered were  fluorine,  sulfur
     dioxide and radon 222.

 7.   Geographic Location

     Consideration  given  to those facilities in close proximity
     to sensitive vegetation, and with high  population density.
     Land availability and local  and state restrictions
     and  standards  were considered.  The greatest  attention
     was  directed to rainfall and evaporation  conditions
     in the area.

 8•   Management Operating Philosophy

     Plants whose management  insists upon effective  equipment
     maintenance and housekeeping practices.

 9.   Diversity of Processgs

     On the basis that other criteria  are met, then
     consideration was given to installations  having  a
     multiplicity of processes.

 Each above criterion  was  assigned   a  range  of  numerical
 values   to allow   a comparative evaluation of the different
 plants visited  in each process category.

 Sampling  Collection and  Validation of Data

 The most  important  item  in a study  of  this  nature   is   to
 obtain  data  representative  of  a   given process under all
 conditions of   operation  and  range  of  production   rates.
 Steps   and   procedures  used   in  selecting  data,   stream
 sampling,  and   sample   analysis  were   all   designed    to
accomplish this goal to the best possible degree.

An  important   step toward this  objective was the assignment
of only highly  experienced operating personnel to the   field
work.  Three persons were used.   The  fertilizer plant opera-
                              14

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ting  experience of these three people ranged from a minimum
of 16 years to 24 years.  With such operational knowledge it
was possible to expeditiously select data, identify specific
process streams for sampling,  and  conduct  sampling  under
readily  discernible plant operating conditions.  The points
considered and identified in all data collection,  sampling,
and validation were:

    1.  segregation of process effluent streams so that only
    an identifiable single process and/or piece of equipment
    was represented.

    2.   Collection  of data and samples at different states
    of process conditions such as normal steady state, plant
    washout when such a procedure is followed on  a  routine
    basis, upset process condition, operation at above/below
    plant  design  rate,  and  during shutdown conditions if
    effluent flow occurs.

    3.  Evaluation  of  the  effect,  if  any,  of  seasonal
    rainfall,  particularly on non-point source effluent and
    ponds.

    4.  Establishment of the existence of  flow  measurement
    devices  and/or  other means of quantitatively measuring
    effluent flows.

    5.  Making positive identity of the type, frequency, and
    handling of the samples represented by collected data   -
    i.e.,  such items as grab, composite, or continuous type;
    shift, daily or weekly frequency, etc.  All samples  col-
    lected by the contractor were composite samples.

    6.   Validation  of  data through determination of plant
    laboratory  analytical  procedures   used   for   sample
    analysis,   check   samples   analyzed   by  independent
    laboratories,   and/or  DPG  sampling  under  known   and
    defined  process  conditions  with sample analysis by  an
    accredited commercial laboratory, was completed at   each
    plant.  A  total of 6 plants were visited  and data  were
    collected at each plant.

GENERAL DESCRIPTION OF  THE INDUSTRY

The segment  of  the  U.S.  phosphate industry  included  in   this
Phase II   survey includes phosphate  manufacturing processes
which utilize  phosphate rock  or wet  process phosphoric   acid
as basic   raw  materials.    Phosphate products manufactured
from   these  processes   are   utilized    as    animal    feed
                              15

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 ingredients,   fertilizer  intermediates,   and  high   quality
 sodium phosphate salts.

 One  of the  phosphate   processes   is   the   defluorination  of
 phosphate   rock.   During   the   early stages  of World War  II
 bone meal for  use as  an  animal   feed   supplement  came  into
 short  supply.   This  short supply situation spurred  activity
 for  finding an alternate source  and/or process  to   satisfy
 this  material  so important  to the production of animal
 foodstuffs.  Bone meal supplies  two important animal mineral
 requirements,   namely calcium   and   phosphorus.   Lack    of
 adequate  levels  of   these ingredients   can result in  such
 animal disorders as aphosphorosis, rickets or infertility.

 Materials which can furnish these  calcium   and  phosphorus
 ingredients  can  be   derived from two general sources.  The
 natural occurring type materials used for  these minerals are
 such items  as  bonemeal,  meatmeal and  fishmeal.   An alternate
 source was  through processing phosphate rock.    The   problem
 with  phosphate  rock as  a direct source  lay in the need  to
 reduce the  3 to 4 percent  fluorine content in the rock to  a
 level which was not harmful to animals upon ingestion.

 The   outcome  of  this animal feed supplement supply problem
 was   that  three  methods   were   developed  and   put  into
 commercial  operation.   Over  the  past   years  process and
 equipment improvements have gradually proven  one  process   to
 have  the better overall commercial values.   This  process  is
 described in detail on the  following  pages of   this   section
 and   is the process used at the  three  plants  included in the
 survey.

 The   estimated   annual   U.S.  production  of    defluorinated
 phosphate rock  for  recent years  is indicated  below.

                   Estimated Annual U.S. Production
                         Thousands of kkg (tons)
                         Defluorinated Rock
                            18%  P Content

1968     1969       1970      1971      1972      1973        1974

373(410) 394(435)  380(430)   394(435)   444(490)  485(535)  485(535)

Plant  site locations for U.S. plants are indicated on Figure
III-l.

A  second  phosphate  process  included  in the study is the
defluorination   of  wet  process  phosphoric   acid.     Acid
defluorination   is accomplished commercially by two methods.
                              16

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The  method  in  most  common  use  is  the  manufacture  of
superphosphoric acid.  This process essentially involves the
concentration   of   phosphoric  acid  from  a  52-51%  P2O5
concentration level to a 68-72% P205 level.  In the  process
of  evaporating  water  from  the  acid,  fluorine  is  also
removed.  The degree of fluorine removal is  dependent  upon
the  initial  fluorine  level  and the final phosphoric acid
concentration.   In  most  cases  the  fluorine  removal  is
sufficient to permit use of the concentrated phosphoric acid
for manufacture of animal feed supplements.

Two types of phosphoric acid evaporators are used to produce
superphosphoric  acid.   One type uses the principle of acid
circulation  in  a  vessel  maintained  at   sub-atmospheric
pressure.   This  is  the  type most prominent in the United
States.  A second type uses the principle commonly  referred
to as submerged combustion.  In this type hot gases directly
from a fuel fired combustion chamber are bubbled through the
acid.

The  second  method of acid defluorination in commercial use
is the combination of the addition of  an  additive  to  the
acid which in turn facilitates fluorine removal by aeration.

Defluorinated acid has several end uses.  A large percentage
of the defluorinated acid is mixed with limestone to produce
dicalcium   phosphate   for   animal  feed  supplement  use.
Increasingly greater quantities are being  used  for  liquid
fertilizer  production.  This use, however, does not require
low fluorine content acid.  There is also an increasing  use
of superphosphoric acid as an intermediate in the production
of dry mixed fertilizer.  The advantage in this latter usage
is  a  combination  of  reducing fluorine evolution  from the
manufacturing process and savings on  raw  material  freight
costs.

The   current    annual   U.S.  production  of  defluorinated
phosphoric acid  is estimated at 760,000 kkg   (835,000  tons)
P2O5.    Plant  site  locations for U.S.  plants are indicated
on Figure  III-2.

The third  phosphate  process included  in the  survey  is  the
production   of   high   quality    sodium  phosphate salts.
Conventionally,  high purity phosphoric  acid as produced  from
thermal  or electric  furnace operations  is  used  as   the  raw
material  for  such  compounds.  Wet process acid  is  however,
used  by  one U.S.  manufacturer  to   produce  these  compounds
primarily  for   use   as  intermediates  in the production  of
cleaning compounds.   The plant site location  map for   this
type  unit  is indicated  as Figure  III-3.
                               17

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                                    DEFLUORINATED PHOSPHATE ROCK
oo
                                             PLANT LOCATIONS
                                                                                    FIGURE III-l

-------
DEFLUORINATED  PHOSPHORIC ACID
       PLANT LOCATIONS
                                               FIGURE III-2

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                                              SODIUM PHOSPHATES
to
o
                                              PLANT LOCATIONS
                                                                                       FIGURE  III-3

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                         SECTION IV

                 INDUSTRY SUBCATEGORIZATION

The  subcategorization  developed  for  this  segment of the
phosphate industry was largely determined in the  course  of
the  Phase  I  phosphate  study  and  the Phase I fertilizer
phosphate study.  Phosphoric acid derived from phosphorus is
a much purer product  than  the  wet  process  acid  of  the
fertilizer  industry.   Human food grade calcium phosphates,
most reagent chemical quality phosphate compounds and sodium
tripolyphosphate are made from phosphorus derived acid.

A  comparative  list  of   the   impurities   and   physical
characteristics  of  furnace  acid  and wet process acid are
indicated in the following table.
     Impurities
      F
     SO3
     A1203
     Fe203
     Water Insolubles

     Total Impurities

     Density kg/1  (Ib/gal)
     a) 27<>C  (80°F)

     Viscosity, cp

     Color
0.6 -
2.7
0.9
1.2
0.8
1.0




Furnace Acid      Wet Process Acid

	Weight Percent
    0.007
   0.003
   0.001
   0.0007
   0.012

   1.57  (13.1)


   18

  Colorless
 6.2 - 6.6

   1.72 (14.3)


   85

Pale green to
 dark brown
Although the phosphate compounds of highest purity  require-
ments  are  made from phosphorus derived acid, a substantial
demand developed for products of adequate quality  for  many
uses,  but  cheaper than the furnace acid derived materials.
Major products in  this  area  are  calcium  phosphates  for
animal   feed,  defluorinated  phosphoric  acid  and  sodium
phosphates.   The  industry  supplied  this  demand  through
defluorination  of  phosphate  rock,  and  defluorination of
phosphoric acid.  The sodium phosphate demand is supplied by
products  derived  from  the  purification  of  wet  process
phosphoric acid, derived from calcined rock.
                               21

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 Within   this   group  of   chemicals,  the   defluorination   of
 phosphate rock  is   carried  out  by   dry   calcining,   which
 distinguishes  it sharply  from  the remaining products derived
 through  defluorinating   liquid  phosphoric  acid.  The most
 favorable water  balance within the  segment is held  by  this
 defluorinated  rock  process.   Substantial evaporation loss
 occurs in stack  washing to control  fluoride  emission.   The
 water  used  for stack washing picks up substantial fluorine
 pollution,  much the  same  as  the   scrubber   water   for
 fertilizer  phosphate plant acid.   The major problem is best
 handled  by recirculation  through a  contaminated  water  pond
 type of  recycle  system.

 Water  is  collected  from  the defluorination of phosphoric
 acid.  This is water driven from the acid  by heat, aided   by
 air streams and/or vacuum.  This water contains the fluoride
 contaminant  common  to   phosphoric  acid   production.   The
 defluorination processes  in   use  are accompained  by the
 formation  of dehydrated  and polymer forms  of phosphate from
 the orthophosphate in rock and in wet  process acid.    These
 phosphate  varieties have high calcium salt solubility; this
 introduces  a  treatment  problem  lacking    in   fertilizer
 phosphate  production  if the  defluorinatied  products get  to
 the waste water.

 Sodium phosphates are produced from conventional wet process
 phosphoric acid, which has been derived from  calcined   rock.
 The  cacining  improves product color  through destruction  of
 organic  components.  The production of sodium phosphates   is
 associated   with   waste  water  problems   similar  to  the
 fertilizer phosphate problems.   The conversion  of  rock   to
 phosphoric   acid  is  by  the  usual  fertilizer  phosphate
 process.   The purification steps conducted  in phosphate salt
 manufacture required the  blowdown  of  process  water  with
 fluorine,  sulphate and phosphate waste water components,   as
 well as other salts and solids.

 Conventional wet acid production is  carried  out  prior  to
 production of both defluorinated acids and the sodium salts.
 These plants have typical wet acid problems.  As a result of
 these considerations, and factors developed in the following
 sections    on   manufacturing  technology  and  waste  water
 characteristics,  3 subcategories have been  established  for
this segment of phosphate manufacturing:

    Subpart D - The Defluorinated Phosphate Rock Subcategory

    Subpart   E   -   The   Defluorinated   Phosphoric  Acid
              Subcategory
                              22

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                         SECTION V

                   WASTE CHARACTERIZATION


The technical aspects of  the  manufacturing  processes  are
described  in  this  section,  along  with identification of
water usage, and the development of waste water flow.

DEFLUORINATED PHOSPHATE ROCK - PROCESS DESCRIPTION

General

As mentioned earlier in Section III, the early World War  II
shortage  of  bonemeal  produced  the necessary incentive to
find an alternate source of animal feed supplement.  The two
ingredients required were calcium and phosphorus  and  these
two  elements  were  prominently  present  in  apatite  type
phosphate rock.  The one  natural  apatite  rock  ingredient
which  prevented  its use as an animal feed material was the
relatively high  (3.0 - U.0%)  fluorine  content.   Basically
the   problem   was   to   find   an   economical  means  of
defluorinating the rock and still have an end product  which
would  be  palatably  acceptable to primarily cows, chickens
and  pigs.   Three  general  methods   were   developed   to
defluorinate the phosphate rock.

One  method  involved  treatment  of  normal superphosphate-
produced  by  mixing  phosphate  rock  with  sulfuric  acid.
Reaction  of  the  phosphate  rock  and  sulfuric breaks the
chemical bond that holds the fluorine  in  the  fluorapatite
lattice.    This   superphosphate   is   then  subjected  to
temperatures which volatize essentially  all  the  fluorine.
The  mono  and dicalcium phosphate compounds in the  material
are converted to alpha and beta tricalcium phosphate  during
the heat treatment.

A  second  method  involves treating a prescribed mixture of
phosphate rock and silica in an  oil  fired  shaft   furnace.
This   also  volatizes  the  fluorine  and  yields   a  fused
tricalcium phosphate mass.  The  hot  mass  is  quenched  in
water  immediately  upon  exit  from  the furnace.   Chemical
composition of the product  is approximately  28%  phosphorus
pentoxide and  0.4% fluorine.

The   third  method  is  described  as  the  calcination  of
phosphate rock without fusion.  It has demonstrated  the most
favorable commercial characteristics and has become  the most
prominent U.S.   defluorination  process.   There  have  been
several  significant modifications to this process since  its
                              25

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 initial  commercial  operation  in  1944.   Initially  the  process
 utilized a  mixture  of  phosphate  rock and  silica   as   a   feed
 material.    The   silica   used was  sand that  is a by-product
 from phosphate   rock   beneficiation.    Ratio   of   silica  to
 phosphate rock was  an  important  criterium in  the  defluorina-
 tion  process.   This charge of silica  and phosphate was  then
 introduced  to a  rotary kiln.  In the interim  years these two
 original steps - use of  silica ratio and  rotary kiln  -   have
 been  modified.   Silica has been partially replaced  with
 sodium compounds and the rotary  kiln has  been replaced by a
 fluid bed   reactor.   Not all U.S. production units  utilize
 both of  these modifications but  both are   practiced   by   the
 major producers.  A more detailed process description of the
 process   using   both these modifications  is presented on the
 following pages.

 The  defluorination  of  phosphate  rock as   practiced  at   U.S.
 commercial   production plants is a  process on which there is
 a limited amount  of published information available.   Plant
 visits   included  only   guarded  technical  discussions   and
 limited  plant observations.   One of the primary reasons   for
 these   practices  is    the   protection of trade  secret
 information.  U.S.  patents were  therefore the major  source
 of process  information.

 The   fluorapatite  type  of phosphate rock is  the  primary raw
 material.   Phosphate content of  the rock   is   typically   35%
 P2O5.   Other  raw materials used in lesser amounts but  very
 critical to  the process  include  sodium containing  reagents,
 wet  process  phosphoric acid and  silica.   The  quantity, point
 of   addition of these materials  to the process, and how  they
 are  mixed with the  phosphate rock  constitute  some   of   the
 know-how  involved  to  realize  a  workable   process  and a
 consistent  product quality.  These raw materials  are  added
 in   specific  quantities  or  ratios dependent upon the  feed
 phosphate rock analysis,

 The  sodium containing reagent is commonly soda  ash   (sodium
 carbonate)  which has a Na20 content of approximately 58% or
 over  98%  Na2CO3.   The   wet   phosphoric   acid   reagent
 concentration  used  is  45-54%  P2O5.   Silica addition is in
 the  form of  sand and is dependent on the  silica  present  in
 the  basic phosphate rock feed.   As previously mentioned the
 point of addition and how these materials are mixed together
 either as a physical mixture or  agglomerated  into  nodular
 form  is  one  of  the   trade  secrets.  The above described
 mixture or charge is then fed into either a rotary kiln or a
 fluid bed reactor.  In  the case of a fluid bed  reactor,   it
 is  desirable  that the charge be nodular and dried prior to
being fed into the reactor.   This is in consideration of the
                             26

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fluid   bed   characteristics    of    effecting    particle
classification  and loss in the exhaust gas.  In the kiln or
fluid bed reactor, temperature control  and  retention  time
are  the  process  variables  which  require  close control.
Reaction temperatures are maintained in the  1205  -  1366°C
(2200-2700°F) range with the rotary kiln requiring the uppe^
portion of the range.

Retention  time  ranges from 30 to 90 minutes with the fluid
bed reactor generally requiring the lesser time.

The state of the charge in the kiln or fluid bed reactor  is
highly  dependent  upon the ratio of the raw materials added
to the phosphate rock.  That is,  whether  the  fluorine  is
evolved  in  a minimal time period or in sufficient quantity
and/or whether the charge fuses into  an  unmanageable  mass
that  rings  or  solidifies  in  the unit.  Another critical
factor in  these  units  is  that  water  vapor  content  be
maintained  at  a sufficiently high percentage to effect the
required fluorine evolution.  An equation representative  of
the  chemical reaction and fluorine release in the kilns and
fluid bed reactors is:

   CalOF2(P04)6  +  H20  +  SiO2  =  3Ca3(POU)2  + CaSiO2   +  2HF
phosphate rock   water   silica  tricalcium   calcium    hydrogen
                                 phosphate    silicate   fluoride

From the kiln or fluid bed reactor the defluorinated product
is quickly quenched with air or water.  This is necessary to
maintain  the  product  in  the  alpha  rather   than   beta
tricalcium   phosphate  form.   The  alpha   form  is the high
solubility material most desirable  in  the  final  product.
From this point the product is crushed and  sized for storage
or shipment.


Defluorinated Phosphate Rock - Waste_Water_Characterization

As  previously  mentioned, the detail  and amount of specific
information   on  water  usage  and  effluents   received  and
verified in  this  survey was minimal.   There were two general
reasons for  this  situation.  One was that none  of the  plants
had  operable   flow   metering equipment.  A second  reason  is
the point already mentioned  - that  of reluctance  to  give
technical  data   and  free  access to the plant operating  area
due to the many items regarded as  trade  secrets.   From   a
practical  standpoint  such  information  in this case would
serve only as background data and  a better  understanding   of
the overall  process  water  balance.  On those  items  which are
important  to   the study such  as water management practices,
                              27

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effluent analyses, and permission  to  conduct  sampling  of
inlet  and  outlet  effluents  there  was excellent industry
cooperation and information input.

The following  types  of  water  usage  and  effluents  were
identified.

    A.  Contaminated Water

    B.  Water Supply

    C.  Spills and Leaks

    D.  Non-Point Source Discharges

Each  of the above listed items are further identified below
as to flow and contaminant content  under  their  respective
headings.

    A.  Contaminated Water

         The  greatest  single  process water requirement is
         for use in scrubbing contaminants from the  gaseous
         effluent   streams.    This   instantaneous   water
         requirement is of appreciable magnitude and process
         conditions   do   permit   use   of    recirculated
         contaminated  water  for this service.  The quality
         of this contaminated water is essentially identical
         to that in fertilizer process circulation  systems.
         Contaminant  levels  are dependent on such items as
         rainfall, extent and degree of water treatment  (if
         any),  and the multiplicity of plants (if any)  that
         use contaminated water from  the  same  circulation
         system.   A  water analysis obtained from a Plant B
         sample during the survey is typical of contaminated
         water used in defluorinated phosphate rock  process
         units.

         Contaminated Water Constituents

         Parameter                       Concentration

         pH                                  1.65
         Total suspended Solids             16.00 mg/1
         Total Solids                    2,267.00 mg/1
         Chloride (Cl)                      101.00 mg/1
         Sulfate (S04)                      350.00 mg/1
         Calcium (Ca)                        UO.OO mg/1
         Magnesium (Mg)                      12.00 mg/1
         Aluminum (Al)                       58.00 mg/1
                              28

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         Iron (Fe)                            8.30 mg/1
         Fluorine (F)                     1,930.00 mg/1
         Arsenic (As)                         0.38 mg/1
         Zinc (Zn)                            5.20 mg/1
         Phosphorus (P)                    600.00 mg/1
         BOD5                                3.00 mg/1
         COD                                48.00 mg/1
         Color                            #120 (after filter)
         Turbidity                          45.00 Jackson
                                               Candle Units

The following figures indicate a representative water usage.
These  figures  will  vary  within reasonable limits between
plants  and  at  different  seasons  of  the  year  but  are
representative  of  the  magnitude  of usage required in the
process.

                 1/kkg                      (gal/ton)

                 45,894                       (11,000)

    B-   Water Supply

         Water  supply  water  is  defined  as   essentially
         uncontaminated  water  from  such sources as wells,
         commercial  or   municipal   water   systems,   and
         impoundment  areas  for natural rainfall or runoff.
         Such water is added to the process for such reasons
         as process functions where contaminated  water  use
         is  prohibited due to process requirements, make-up
         water  to  the  contaminated   water   system   and
         equipment,  or  area  wash  downs.   The  following
         figures indicate the usage range.

                 1/kkg                      (gal/ton)

                  877                          (210)


    c-  Spills and Leaks

         Spills and leaks are collected as part  of  process
         efficiency and housekeeping.  Sources of this water
         are  pump  water  seals  and  plant  wash  up.  The
         quantity is minor and  normally  periodic.   Spills
         and   leaks  need  not  indicate  bad  housekeeping
         practices.  Some of these, particularly leaks  from
         pump   seals,   are   an   inherent   part  of  the
         manufacturing  process.   However,  these  must  be
         brought under control to achieve satisfactory waste
                               29

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          water    treatment.     Control    procedures   include
          maintenance of  equipment  and  collecting  of  leaks
          and  spills in the contaminated water  pond.


     D.   Non-Point source Discharge

          The  origin  of this  discharge is dry materials  -
          both raw material and  product  - which dust  over  the
          plant    area    usually   emitted  from   conveying
          equipment.   These  materials  are then solubized or
          sluiced  by rain or  melting  snow  into  the  plant
          drainage system.

     DEFLUORINATED PHOSPHORIC ACID  - PROCESS DESCRIPTION

General

Defluorinated  phosphoric   acid  is   to a   degree  a  bit
misleading  to  persons   associated  with  the   fertilizer
industry.   The   reason   being  that  acid defluorination is
inherently included in the process of evaporating commercial
wet  process 54% P2O5 phosphoric acid to the  superphosphoric
acid   (68-72%  P2O5)  concentration  level.    To  fertilizer
people therefore, the principal  U.  S.   defluorinated  acid
process  is better known  as a superphosphoric acid unit.   Two
different  type   superphosphoric units  are in  commercial  use
in the U. S.

Another method of defluorinating wet process phosphoric acid
has come  into commercial  use in the past  few  years.   This
process also uses commercial wet process  54% P205 phosphoric
acid  as  the  raw material.  In this process an additive is
mixed with the phosphoric acid to aid   in  the  release   and
volatilization  of  fluorine from the liquid.   The mechanism
for fluorine removal from the acid is aeration.

Defluorinated phosphoric acid is used   primarily  as  a  raw
material for production of mixed fertilizer goods - both dry
and  liquid  types.    It is also mixed with limestone in the
manufacture of dicalcium phosphate for use as  an animal feed
supplement.   Approximately  67%  of  the  estimated  U.  S.
835,000  annual  tons  P2O5 quantity of defluorinated acid is
used in fertilizer manufacture and 33% in the  production  of
dicalcium  phosphate.   The degree of defluorination required
to meet animal feed regulations is that the P  to F ratio  be
at least 100 to 1.
         DEFLUORINATED ACID - VACUUM TYPE EVAPORATION
                             30

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The vacuum type evaporation method for defluorination of wet
process  phosphoric  acid  is  essentially  identical to the
procedure and equipment used to produce 54% P2O5  phosphoric
acid from 26-30% P205 strength acid.

Concentration  of 54% P2O5 acid to a  68-72% P2O5 strength is
performed in vessels which use high pressure (450-550  psig)
steam  or  externally  heated  Dowtherm solution as the heat
energy source for evaporation of water from the acid.  These
units effect evaporation  by  circulating  acid  at  a  high
volume  rate  consecutively  through   a  shell and tube heat
exchanger and a flash chamber under  low  absolute   (vacuum)
pressure  conditions.   In  the  heat  exchanger,  steam  or
Dowtherm solution is applied to  the   shell  side  and  acid
flows  through tubes.  Acid flow through the tubes is of the
wetted wall type rather than  full  tube  flow.   The  flash
chamber  serves to provide a large liquid surface area where
water vapor is released without significant acid entrainment
loss.  Fluorine removal from the  acid  occurs  concurrently
with the water vapor release.  Both of these gases pass to a
barometric  condenser  and  are  absorbed  in  the condenser
water.  Dependent upon the quality of  superphosphoric  acid
being   produced    (e.a.   30   or   50-60%   conversion  to
polyphosphates), either a single unit or  a  series  of  two
units  may  be  used  to  accomplish  the evaporation and/or
defluorination required.
         DEFLUORINATED ACID - SUBMERGED COMBUSTION

A second method of phosphoric acid defluorination is by  the
direct  contact  of  hot combustion gases with the acid.  In
this method a combustion chamber fitted  with  one  or  more
fuel  oil  or  gas  burners is mounted directly on top of an
acid containment chamber.  Pressurized hot  gases  from  the
fuel combustion are bubbled through the acid to an immersion
depth of up to approximately 46 cm (18 inches).  Acid in the
containment  chamber  is  maintained  at a constant level by
control of the low concentration feed acid flow.  Evaporated
and defluorinated product acid from the unit  is  continuous
and is controlled by acid boiling point and/or temperature.

Gases  (evaporated  water,  stripped  hydrogen  fluoride and
silcon tetrafluoride) from the evaporation chamber flow to a
series of gas cleaning  and  absorption  equipment.   First,
entrained  phosphoric  acid is recovered from the gas stream
and re-introduced to the unit  or  to  the  phosphoric  acid
plant.   Following  acid removal, the gases pass to a multi-
stage  direct  contact  condenser  system   where   a   high
percentage of the contaminants are removed before exhaust to
                               31

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the  atmosphere.  Water can be used in all or only the final
stages of the condenser system as a condensing and scrubbing
medium.
         DELUORINATED ACID - AERATION

This method of defluorinating phosphoric acid  is  the  most
recent  proprietary  method  to  come  into  commercial use.
Relatively small quantities of diatomaceous silica or  spray
dried  silica gel with high surface area characteristics are
mixed with commercial 54% P2O5 phosphoric acid.  This silica
material addition serves to  supply  sufficient  silica  for
conversion  of  the minor quantity of hydrogen fluoride  (HF)
present in the impure phosphoric acid  to  fluosilicic  acid
(H2SiF6).   Fluosilicic  acid  at an adequate temperature in
turn breaks down to SiF4 and by simple aeration is  stripped
from  the  heated  mixture.   The gaseous effluent stream is
maintained above its dew  point  until  it  enters  the  gas
scrubbing  unit.   At this point the gas stream is contacted
with water to remove  contaminants  before  release  to  the
atmosphere.  Phosphoric acid (54% P2O5) can be defluorinated
to  a  weight  ratio  of  100  to 1 or better P to F by this
method.

Defluprinated Phosphoric Acid - Waste Characterization

Information on water usage and effluents was obtained on two
of  the  three  defluorination  methods  described,  namely,
Defluorinated   Acid   -   Vacuum   Type   Evaporation   and
Defluorinated Acid - Submerged  Combustion.   No  commercial
operating  data  or sampling information was obtained on the
Defluorinated  Acid  -  Aeration  method.   This  method  of
defluorination  has  been  commercial for a relatively short
time and patent protection had not yet been  granted  either
the  original  inventor  or  the  licensee on his additional
modifications.  As a result of this  situation  no  detailed
information  was  attainable  on  this process.  It is known
however,  that the method's usage is confined to  removal  of
air  contaminants  from  the  gaseous  effluent  stream  and
possibly a minor quantity of process water  for  seal  water
use.    Both   of   these   usages  will  qualitatively  and
quantitatively be equal to or less than those indicated  for
the other two methods.

The  following  types  of  water  usage  and  effluents were
identified:

A.  Contaminated Water
                                32

-------
B.  Water Supply

C.  Spills and Leaks

Each of the above listed items are further identified  below
as  to  flow  and contaminant content under their respective
headings.

A.  Contaminated Water

    The only significant water usage in these  defluorinated
    acid  methods  is for use in scrubbing contaminants from
    the gas effluent streams.  The scrubber equipment may be
    in the form of either a barometric condenser or the more
    conventional gas scrubber type.   In  either  case,  the
    instantaneous   water   requirement  is  of  appreciable
    magnitude.  As in the defluorinated phosphate rock,  the
    process  conditions  do permit use of contaminated water
    for this service.  Water quality is essentially the same
    as in fertilizer process circulation systems and at some
    plants is actually part  of  that  system.   Contaminant
    levels  are  dependent on such items as rainfall, extent
    and  degree  of  water  treatment  (if  any) ,  and   the
    multiplicity  of  plants   (if any) that use contaminated
    water  from  the  same  circulation  system.   A   water
    analysis  obtained  from  a  Plant  D  sample during the
    survey  is  typical  of  contaminated  water   used   in
    defluorinated acid process units.

               Contaminated Water Constituents


        Parameter                           Concentration

        PH                                       1-29
        Total Suspended Solids                  30.00 mg/1
        Total Solids                        28,810.00 mg/1
        Chloride  (Cl)                           65.00 mg/1
        Sulfate  (SC4)                        4,770.00 mg/1
        Calcium  (Ca)                         1,700.00 mg/1
        Magnesium  (Mg)                          106.00 mg/1
        Aluminum  (Al)                           260.00 mg/1
        Iron  (Fe)                               180.00 mg/1
        Fluorine  (F)                            967.00 mg/1
        Arsenic  (As)                             0.83 mg/1
         Zinc  (Zn)                                5.30 mg/1
        Total Phosphorus  (P)                5,590.00 mg/1
        BOD5                                    15.00 mg/1
        COD                                     306.00 mg/1
        Color                               #120  (after filter)*
                                33

-------
         Turbidity                             45  Jackson  Candle  Units

         *   Unit  of  color  -  potassium  chloroplatinate


 The  following  figures  indicate a  representative  water  usage.
 These   figures  will   vary  within  reasonable  limits between
 plants   and at  different  seasons  of  the   year  but   are
 representative of the  magnitude required in the  process.
     Method                    1/kkg            jgal/tgn^
     Defluorinated Acid -     70,510             16,900
     Vacuum Type Evaporation

     Defluorinated Acid -     18,024             4,320
     Submerged Combustion

B.   Water Supply

Water  supply  water is defined as uncontaminated water  from
such sources as wells  and  commercial  or  municipal  water
systems.   The  water  is  used  for pump seal water.  Usage
figures are listed below:

     Method                   1/kkg           Igal/tonl

     All Methods               43                14

C.  Spills and Leaks

Spills and leaks are collected as part of process efficiency
and housekeeping.  Sources of this water are pump seals  and
plant wash up.  The quantity is minor and/or periodic.
         SODIUM PHOSPHATE - PROCESS DESCRTPTTDN
General
The  high  quality  standards set by detergent manufacturers
for their products necessitates  that  an  essentially  pure
sodium  phosphate  solution be used as a raw material.  This
high purity standard has greatly  limited  the  use  of  wet
process  phosphoric  acid  as  a  phosphate  source for this
industry.  One U. S. manufacturer however, does commercially
purify wet process acid to the degree necessary to allow its
use in the manufacture of  sodium  phosphate  compounds  for
detergent manufacture.
                          34

-------
Wet process acid contains an appreciable number and quantity
of   impurities   which  must  be  removed  to  achieve  the
acceptable  detergent   purity   requirements.    The   more
significant impurities to be removed include excess sulfuric
acid,   sodium   fluosilicate,   iron   phosphate,  aluminum
phosphate and calcium sulfate.  Many  of  the  process  pro-
cedures  and techniques used for removal of these impurities
are regarded to be trade secrets.


Sodium Phosphates - Process Description

Removal of impurities from the wet process acid used in this
process begins with the phosphate  rock  used  in  the  acid
manufacture.    Calcined  phosphate  rock  is  used  in  the
acidulation step to yield a nearly colorless acid  to  start
the  purification  steps.   Rock  calcination  destroys  the
organic matter inherent in mined rock.  It is organic matter
which   causes   the   brown   coloration   that    normally
characterizes wet process phosphoric acid.

After  the initial 20-25% P2O5 acid is produced, the acid is
treated in a series  of  separate  neutralization  steps  to
individually  remove the various acid impurities.  The first
partial neutralization with recycled sodium phosphate liquor
is designed to  remove  the   fluosilicates.   In  this  step
granular  sodium  fluosilicate   is  precipitated and removed
from the acid solution by filtration.  This precipitate  has
commercial value as 98-9956 sodium silicofluoride  (Na2SiF6) .

The  next  step  consists  of  adding  sodium sulfide to the
remaining solution to  precipitate  the  minor  quantity  of
arsenic  present.   Concurrently with  this  precipitation,
barium carbonate can be added to remove the   excess  sulfate
present  as barium sulfate.   Barium carbonate is not used at
the  plant producing sodium phosphates at the  present  time.
Precipitates  are  now  removed  by another filtration step.
The  quantity of precipitate  is small  and is disposed  of  as
solid  waste.  Local  landfill authorities  should be notified
of the arsenic component.

At this point the partially  neutralized acid  still  contains
iron and aluminum phosphates, and  some  residual fluorine.   A
second  neutralization  is   now  made  with   soda   ash to an
approximate  4.0 pH level.    This  induces   precipitation  of
essentially    all    the    remaining   impurities.    These
precipitated   impurities  are both   quite voluminous    and
difficult  to  separate  from  the  remaining  solution.   Special
techniques   of  heating,  agitation,    and   retention    are
necessary  to  adequately  condition  the   slurry   so that  a
                          35

-------
 filtration separation of the impurities can be made.   These
 impurities  contain  a relatively high quantity of P2O5  (40-
 50%)  and have value as  a  fertilizer  material.   Following
 th 1 S    no 11-hi-a 1 i -»3-4- -i «-»-»   r-,4-^ ^    j_i_ _  	•  •       -,  . .     . "
   ,      	 —_uu „_  ^i  j.t:j. I_JLJLJ.^,ci  nidtez.lax.   rOllO
this   neutralization   step,   the  remaining  solution
sufficiently  pure  for   the   production   of   monoso
phosphate
                                                           is
                                                   monosodium
 Monosodium  phosphate  is  crystallized  from  the  purified
 solution by concentrating the  solution  in  an  evaporator.
 The   monosodium   crystals,    with   further   dehydration,
 neutralization and crystallization, can be converted to such
 °uheru comP°unds  as   sodium   meta   phosphate,   disodium
 phosphate,  and  tri-sodium phosphate.   The several chemical
 equations and steps involved  in this process  are  indicated
 on  the process flowsheet.

 Water   effluents  from  these  different  processes are from
 spills  and  leaks,   filtration  washes,  and  gas  scrubber
 liquors.
 Sodium  Phosphates  -  Waste_characterization

 The   survey  of this process  was  limited by the same type of
 conditions and for the same   reason  which   existed  in  the
 defluorinated phosphate rock  process.   This was that many of
 the   various unit  operations  are  considered trade secret and
 therefore  plant   access   was    necessarily   limited   to
 observations  of   effluent  streams  external to the process
 buildings.   As  previously    stated,    from   a   practical
 standpoint  this   restricted   access  takes  nothing away from
 the value of the study other  than background information and
 a better understanding of the overall process water balance.
 On those items which were basic and important to the  study,
 the   industry   cooperation   and  response  to  information
 requests was  excellent.   The installed  process  effluent
 measurement  and monitoring facilities  were found to be well
 developed and maintained.

 The following  types  of  water   usage   and  effluents   were
 identified.

               A.  Water Supply
               B.  Contaminated Effluent
               C.  Spills and  Leaks
               D.  Non-Point  Source Discharges

Each  of the above listed items are further identified  below
as to flow and contaminant content.
                          36

-------
A.  Water Supply

    Water supply is defined  as  uncontaminated  water  from
    wells.   The  water  is  used for pump seal water and in
    various  product  filtration  and  washing   procedures.
    Usage figures are listed below.

               kkg              (gal/ton)^

           9992-12349            2395-2960

B.  Contaminated Effluent

    This effluent is essentially the used process water with
    impurities  that were added from the process function in
    which it was used.  An effluent analysis typical  of  an
    effluent sample from Plant E is listed below.

               Contaminated Water^Constituents

               Parameter                  Concentration

               pH                               7.8
               Total Suspended Solids         460    mg/1
               Total Solids                  2100    mg/1
               Chloride (Cl)                    90    mg/1
               Sulfate  (SO4)                   240    mg/1
               Calcium  (Ca)                    95    mg/1
               Fluorine (F)                     15.0  mg/1
               Total Phosphorus (P)          250    mg/1
               BOD5                            31.0  mg/1
               COD                             55.0  mg/1
               Temperature                     78°F

The  following figures represent the range of water effluent
guantities found.

               1/kkg               (gal/ton)

             7640-10013            1830-2400

C.  Spills and Leaks

    The guantity of this effluent is minor and  is  directed
    into  the  overall  waste  sewer  system  as part of the
    contaminated effluent.1  Leaks from pumps are  normal  in
    chemical manufacturing.  Considerable effort is required
    to bring under control.  The use of reliable pumps, with
    a  serviceable packing component, and diligent servicing
    schedules in all points that may develop leaks are vital
                         37

-------
    factors  for  limiting  waste  water  discharge.   Where
    possible,   spills   and  leaks  must  be  recycled  and
    converted to product.

D.  Non-Point Source^Discharge

    The origin of this discharge is  primarily  dry  product
    which   dusts   over   the  plant  area  from  conveying
    equipment.  This product is periodically solubilized  by
    rain  or  melting  snow and collected by the plant waste
    sewer system.  In this process the  non-point  discharge
    is  considered to be a significant periodic influence on
    the plant effluent contaminant level.

E.  The raw waste loads are summarized below:

Defluorinated Phosphate Rock
    Flow:  46,000 1/kkg  (11,000 gal/ton)
    Total Phosphorus (P)   600   mg/1
    Fluoride (F)          1930   mg/1
    TSS                    16   mg/1
    pH                      1.65

Defluorinated Phosphoric Acid
    Flow:  Vacuum Type Evaporation   70,500 1/kkg  (16,900 gal/ton)
           Submerged Combustion      18,000 1/kkg  (4,300 gal/ton)
    Total Phosphorus (P)  5590   mg/1
    Fluoride (F)           967   mg/1
    TSS                    30   mg/1
    pH                      1.29

Sodium Phosphates
    Flow:        7,600 - 10,000 1/kkg  (1,830 - 2,400 gal/ton)
    Total Phosphorus (P)   250   mg/1
    Fluoride (F)            15   mg/1
    TSS                   460   mg/1
    pH                      7.8
                             38

-------
DEFLUORINATED PHOSPHATE ROCK

Phosphate
Rock
FLUID BED PROCESS

Phos-
phoric
Acid
Other
Def luori-
nating
Reagents
4 *
Non-Agglomer
Feed
Fluidizing Gas

W V It
Mixer
v
Dryer
V
Screen
atedw

Heater
To
Make Up Water . Atmo-phcrc
877 1/kkg * f OAtmo_phcrc
ziu cf/s . L . .,.*,-. cuiH-aiuj.na Ltiu
4k p v Water
Effluent Gas ^ Sciubbei.
^ &
P.yr 1 nnp

Fluid V/ V
Bed Y Contaminated
Reactor I Water to
p __ ^bust uctcntion
Y^ ' Recycle Pond
y 45,894 1/kkg
Agglomerated and 11,000 g/s.t.
Def luorinated
Phosphate
Product
                                                      Figure V-I

-------
                             DEFLUORINATED PHOSPHORIC ACID - VACUUM PROCESS
                                           (Super Phosphoric)

                       Water                         Water
         Water
54% Phos-
phoric Acid
             No. 1
             Evapo-
             rator
                               I
 Shipping












	





T ~ i "
^ 1 'gy

L ,

No. 2
Evapo-
rator
	 i

rfl



                Pump
Product
Cooler
                                              To Cooling Pond
                                               70,510  1/kkg
                                               16,900  g/s.t.
                                                                     Pump
                                                                                Alternate Heat
                                                                                  Medium
                                                                I
                                                        Alternate Heat Medium
                                                       	I       I
                                                         "	._ — i    Combustion
                                                            T         Gases
                                                                                   Fuel
                                                        Process
                                                        Water
                                                        43  lAkg
                                                        14  g/s.t.
                                                                                        Figure  V-2

-------
                                  DEFLUORINATED PHOSPHORIC ACID
                                     (Submerged Combustion)
     Gas
Air
                54% P2O5
                Feed Acid
              Burner
            I Dip Tube  i
             Evaporator
                                        Scrubber
Gas
Cooler
     Superphosphoric
        Acid
    (To shipping)



Acid
Cooler


ra-
1
	 &
V

«—


Air cooler
                                    To Cooling
                                       Pond
                                  43 1/kkg
                                  14 g/s.t.

                                  Weak Acid
                                  (To phos.
                                      0 Acid
                                      Plant)
                                                 Product
                                                 Pump
    And Sludge
      Tank
                                                                              Scrubber
                                                                              Tank
                                                                                    Figure  V-3

-------
                                DEFLUORIN'ATED ACID - AERATION TYPE
Process
 Water
Silica
                                                   Contaminated
                                                   Water
                                                     To
                                                  Atmosphere
       545'=
Phosphoric
P205
Acid
                                                                             Contaminated Water
                                                                                  Pond
                                                                      Steam
                                                             Heat
                                                             Exchanger
                                                             	>Condensate Return
                                                      Circulation Pump
                     Product to
                      Shipping
                                                                            Figure  V - 4

-------
Wet Process Phosphoric Acid
SODIUM PHOSPHATE PROCESS
 FROM WET PROCESS
 PHOSPHORIC ACID
 MONO SODIUM
 PHOSPHATE
                         T
                       SODIUM
                   META PHOSPHATE
                                                            7640-10013 1/kkg
                                                            (1830-2400 gal/s.t.)
                                                    DISODIUM PHOSPHATE
                                                    DUOHYDRATE  OR
                                                    ANHYDROUS
                           DISODIUM PHOSPHATE
                              CRYSTAL
                                 TETRA SODIUM PYRO
                                      PHOSPHATE
                                                                                                             Figure   V-S

-------
                         SECTION VI

             SELECTION OF POLLUTANT PARAMETERS
General

The selection of pollutant parameters was a necessary  early
step  of  the  study.   Collection  of  meaningful  data and
sampling was dependent on knowing  what  fertilizer  process
contaminants  are important so far as degradation of natural
water resources are concerned.

The  general  criteria  considered  and  reviewed   in   the
selection of pollutant parameters included:

- quality of the plant intake water

- products manufactured

- raw materials used

   environmental  harmfulness  of  the compounds or elements
included in process effluent streams

Qther^Non-Fertilizer Phosphate^Chemicals

Effluent waste waters from the three processes  included  in
this  survey  are  similar  to  those  associated  with  the
phosphate fertilizer  industry.   The  primary  factors  and
contaminants  to  be  controlled  to  achievable levels are:
suspended solids, pH, phosphorus and fluorides.

Radium 226 is considered to be a very  important  raw  waste
load   component.    Radium  226  coprecipitates  with  most
sedimentary fractions, particularly at a reasonably high  pH
level.  The pH 6.0 to 9.0 range set for effluent discharges,
along  with  the  limitations  as  suspended  solids,  deals
effectively with the effluent  problem.   The  Environmental
Protection  Agency has ongoing studies and is initiating new
studies on the problem of radium-226 in gypsum pond  waters.
Such  studies  indicate  that  double lime treatment to a pH
range of 6.0 to 9.0 is required to achieve  optimum  removal
of  radium-226.   Additional information obtained from these
studies will be evaluated, and  where  appropriate,  current
effluent  guidelines  may  be amended.  Procedures currently
proposed are judged to be adequate and provide for  rigorous
control  of  radium-226.  A more detailed discussion of this
problem can be found in references N and 0.
                           45

-------
Secondary parameters which should be monitored  but  do  not
warrant   definitive  guidelines  are:    temperature, . total
dissolved solids, chemical oxygen demand (COD), arsenic, and
cadmium.  The prime reason for not  setting  guidelines  for
these secondary parameters is that treatment for the primary
parameters  will  effect removal of also the secondary ones.
A considered additional reason  is  that  insufficient  data
exists from which to establish responsible guidelines.

Selection  of these parameters is justified by the fact that
best available technology economically achievable as well as
best demonstrated technology is in current commercial use.

Rationale for Selection of Parameters

Temperature

Temperature is one of the  most  important  and  influential
water quality characteristics.  Temperature determines those
species  that  may  be present; it activates the hatching of
young,  regulates  their   activity,   and   stimulates   or
suppresses  their  growth  and development; it attracts, and
may kill when the water becomes too hot or  becomes  chilled
too    suddenly.     Colder   water   generally   suppresses
development.  Warmer water  generally  accelerates  activity
and  may  be a primary cause of aquatic plant nuisances when
other environmental factors are suitable.

Temperature is a prime regulator of natural processes within
the water environment.  It governs  physiological  functions
in   organisms   and,   acting  directly  or  indirectly  in
combination  with  other  water  quality  constituents,   it
affects  aquatic  life  with  each  change.   These  effects
include  chemical  reaction  rates,   enzymatic   functions,
molecular   movements,   and   molecular  exchanges  between
membranes within and between the physiological  systems  and
the organs of an animal.

Chemical  reaction rates vary with temperature and generally
increase as the temperature is increased.  The solubility of
gases in water varies with temperature.  Dissolved oxygen is
decreased by the decay or decomposition of dissolved organic
substances and the decay rate increases as  the  temperature
of  the  water  increases  reaching  a maximum at about 30°C
 (86°F).   The  temperature  of  stream  water,  even  during
summer,   is  below  the  optimum  for  pollution-associated
bacteria.  Increasing the water  temperature  increases  the
bacterial   multiplication  rate  when  the  environment  is
favorable and the food supply is abundant.
                           46

-------
Reproduction  cycles  may  be   changed   significantly   by
increased  temperature  because  this  function  takes place
under restricted temperature ranges.  Spawning may not occur
at all because temperatures are  too  high.   Thus,  a  fish
population  may  exist  in  a  heated area only by continued
immigration.   Disregarding   the   decreased   reproductive
potential,  water  temperatures need not reach lethal levels
to decimate a species.  Temperatures that favor competitors,
predators, parasites, and disease can destroy a  species  at
levels far below those that are lethal.

Fish  food  organisms are altered severely when temperatures
approach or exceed 90°F.  Predominant algal species  change,
primary  production  is  decreased,  and  bottom  associated
organisms may be depleted or altered drastically in  numbers
and  distribution.   Increased  water temperatures may cause
aquatic plant nuisances when other environmental factors are
favorable.

Synergistic actions of pollutants are more severe at  higher
water  temperatures.   Given  amounts  of  domestic  sewage,
refinery wastes, oils, tars, insecticides,  detergents,  and
fertilizers  more  rapidly deplete oxygen in water at higher
temperatures, and the  respective  toxicities  are  likewise
increased.

When  water  temperatures  increase,  the  predominant algal
species may change from diatoms to green algae, and  finally
at high temperatures to blue-green algae, because of species
temperature   preferentials.   Blue-green  algae  can  cause
serious odor  problems.   The  number  and  distribution  of
benthic  organisms  decreases as water temperatures increase
above 90°F, which is close to the tolerance  limit  for  the
population.   This  could seriously affect certain fish that
depend on benthic organisms as a food source.

The cost of fish being attracted to heated water  in  winter
months may be considerable, due to fish mortalities that may
result when the fish return to the cooler water.

Rising  temperatures  stimulate the decomposition of sludge,
formation  of  sludge  gas,  multiplication  of  saprophytic
bacteria  and fungi (particularly in the presence of organic
wastes), and  the  consumption  of  oxygen  by  putrefactive
processes,  thus  affecting  the  esthetic  value of a water
course.

In general, marine  water  temperatures  do  not  change  as
rapidly  or range as widely as those of freshwaters.   Marine
and  estuarine  fishes,  therefore,  are  less  tolerant  of
                           47

-------
temperature  variation.   Although this limited tolerance is
greater in estuarine than  in  open  water  marine  species,
temperature  changes  are  more important to those fishes in
estuaries and bays than  to  those  in  open  marine  areas,
because  of  the  nursery and replenishment functions of the
estuary  that  can  be   adversely   affected   by   extreme
temperature changes.

E3* Acidity and Alkalinity

Acidity  and  alkalinity  are  reciprocal terms.  Acidity is
produced  by  substances  that  yield  hydrogen  ions   upon
hydrolysis  and  alkalinity  is  produced by substances that
yield hydroxyl ions.  The terms "total acidity"  and  "total
alkalinity" are often used to express the buffering capacity
of  a  solution.   Acidity  in  natural  waters is caused by
carbon dioxide, mineral acids, weakly dissociated acids, and
the salts of strong acids and  weak  bases.   Alkalinity  is
caused  by strong bases and the salts of strong alkalies and
weak acids.

The term pH is a logarithmic expression of the concentration
of hydrogen ions.  At a pH of 7, the hydrogen  and  hydroxyl
ion  concentrations  are  essentially equal and the water is
neutral.  Lower pH  values  indicate  acidity  while  higher
values indicate alkalinity.  The relationship between pH and
acidity or alkalinity is not necessarily linear or direct.

Waters  with  a  pH  below  6.0 are corrosive to water works
structures,  distribution  lines,  and  household   plumbing
fixtures  and  can  thus  add  such constituents to drinking
water as iron, copper, zinc, cadmium and lead.  The hydrogen
ion concentration can affect the "taste" of the water.  At a
low pH water tastes  "sour".   The  bactericidal  effect  of
chlorine  is  weakened  as  the  pH  increases,  and  it  is
advantageous to keep the  pH  close  to  7.   This  is  very
significant for providing safe drinking water.

Extremes  of  pH  or  rapid  pH  changes  can  exert  stress
conditions  or  kill  aquatic  life  outright.   Dead  fish,
associated  algal  blooms,  and  foul stenches are aesthetic
liabilities of any waterway.   Even  moderate  changes  from
"acceptable"  criteria  limits of pH are deleterious to some
species.  The relative toxicity  to  aquatic  life  of  many
materials   is   increased  by  changes  in  the  water  pH.
Metalocyanide complexes  can  increase  a  thousand-fold  in
toxicity  with  a drop of 1.5 pH units.  The availability of
many nutrient substances  varies  with  the  alkalinity  and
acidity.  Ammonia is more lethal with a higher pH.
                           48

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The   lacrimal   fluid   of  the  human  eye  has  a  pH  of
approximately 7.0 and a deviation of 0.1 pH  unit  from  the
norm   may   result  in  eye  irritation  for  the  swimmer.
Appreciable irritation will cause severe pain.

Total Suspended Solids

Suspended  solids  include  both   organic   and   inorganic
materials.  The inorganic components include sand, silt, and
clay.   The  organic  fraction  includes  such  materials as
grease, oil, tar, animal and vegetable fats, various fibers,
sawdust, hair, and various  materials  from  sewers.   These
solids  may settle out rapidly and bottom deposits are often
a mixture  of  both  organic  and  inorganic  solids.   They
adversely  affect  fisheries  by  covering the bottom of the
stream or lake with a blanket of material that destroys  the
fish-food  bottom  fauna  or  the  spawning  ground of fish.
Deposits containing organic  materials  may  deplete  bottom
oxygen   supplies   and  produce  hydrogen  sulfide,  carbon
dioxide, methane, and other noxious gases.

In raw water sources for domestic use,  state  and  regional
agencies  generally specify that suspended solids in streams
shall not be  present  in  sufficient  concentration  to  be
objectionable   or   to   interfere  with  normal  treatment
processes.  Suspended solids in  water  may  interfere  with
many  industrial processes, and cause foaming in boilers, or
encrustations on equipment exposed to water,  especially  as
the  temperature rises.  Suspended solids are undesirable in
water for textile industries;  paper  and  pulp;  beverages;
dairy  products;  laundries;  dyeing;  photography;  cooling
systems, and power plants.  Suspended particles  also  serve
as a transport mechanism for pesticides and other substances
which are readily sorbed into or onto clay particles.

Solids may be suspended in water for a time, and then settle
to  the  bed of the stream or lake.  These settleable solids
discharged  with  man's  wastes   may   be   inert,   slowly
biodegradable materials, or rapidly decomposable substances.
While  in  suspension,  they  increase  the turbidity of the
water,   reduce   light   penetration   and    impair    the
photosynthetic activity of aquatic plants.

Solids  in  suspension  are aesthetically displeasing.  When
they settle to form sludge deposits on the  stream  or  lake
bed, they are often much more damaging to the life in water,
and  they  retain  the  capacity  to  displease  the senses.
Solids, when  transformed  to  sludge  deposits,  may  do   a
variety  of damaging things, including blanketing the stream
or lake bed and thereby destroying  the  living  spaces  for
                             49

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those  benthic  organisms  that  would  otherwise occupy the
habitat.  When of  an  organic  and  therefore  decomposable
nature,  solids use a portion or all of the dissolved oxygen
available in the area.  Organic materials also  serve  as  a
seemingly  inexhaustible  food  source  for  sludgeworms and
associated organisms.

Turbidity is principally a measure of  the  light  absorbing
properties  of suspended solids.  It is frequently used as a
substitute method of quickly estimating the total  suspended
solids when the concentration is relatively low.


Fluorides

As the most reactive non-metal, fluorine is never found free
in  nature  but  as  a constituent of fluorite or fluorspar,
calcium fluoride, in sedimentary rocks and also of cryolite,
sodium aluminum fluoride, in igneous rocks.  Owing to  their
origin  only  in  certain  types  of rocks and only in a few
regions, fluorides in high concentrations are not  a  common
constituent of natural surface waters, but they may occur in
detrimental concentrations in ground waters.

Fluorides are used as insecticides, for disinfecting brewery
apparatus,  as  a  flux  in  the  manufacture  of steel, for
preserving wood and mucilages, for the manufacture of  glass
and  enamels,  in  chemical industries, for water treatment,
and for other uses.

Fluorides in sufficient quantity are toxic to  humans,  with
doses  of  250  to  150 mg giving severe symptoms or causing
death.

There  are  numerous  articles  describing  the  effects  of
fluoride-bearing  waters on dental enamel of children; these
studies lead to the  generalization  that  water  containing
less  than  0.9  to  1.0  mg/1 of fluoride will seldom cause
mottled enamel in children, and for  adults,  concentrations
less  than  3  or  4  mg/1  are  not likely to cause endemic
cumulative  fluorosis  and   skeletal   effects.    Abundant
literature  is  also  available describing the advantages of
maintaining 0.8 to 1.5 mg/1  of  fluoride  ion  in  drinking
water  to  aid  in the reduction of dental decay,  especially
among children.

Chronic fluoride poisoning of livestock has been observed in
areas  where  water  contained  10  to  15  mg/1   fluoride.
Concentrations  of  30  -  50  mg/1 of fluoride in the total
ration of dairy cows is considered  the  upper  safe  limit.
Fluoride  from waters apparently does not accumulate in soft
                             50

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tissue to a significant degree and it is  transferred  to  a
very  small  extent  into the milk and to a somewhat greater
degree into  eggs.   Data  for  fresh  water  indicate  that
fluorides  are  toxic  to fish at concentrations higher than
1.5 mg/1.

Phosphorus

During the past 30 years, a formidable  case  has  developed
for  the  belief  that  increasing standing crops of aquatic
plant growths, which often interfere with water uses and are
nuisances  to  man,  frequently  are  caused  by  increasing
supplies  of phosphorus.  Such phenomena are associated with
a  condition  of  accelerated  eutrophication  or  aging  of
waters.   It  is generally recognized that phosphorus is not
the sole cause of eutrophication, but there is  evidence  to
substantiate that it is frequently the key element in all of
the elements required by fresh water plants and is generally
present in the least amount relative to need.  Therefore, an
increase in phosphorus allows use of other, already present,
nutrients   for   plant   growths.   Phosphorus  is  usually
described, for this reasons, as a "limiting factor."

When a plant population  is  stimulated  in  production  and
attains  a  nuisance  status,  a  large number of associated
liabilities are immediately apparent.  Dense populations  of
pond  weeds  make  swimming  dangerous.   Boating  and water
skiing and sometimes fishing may be  eliminated  because  of
the mass of vegetation that serves as an physical impediment
to  such activities.  Plant populations have been associated
with stunted fish populations and with poor fishing.   Plant
nuisances  emit  vile  stenches,  impart tastes and odors to
water supplies, reduce  the  efficiency  of  industrial  and
municipal  water  treatment, impair aesthetic beauty, reduce
or restrict resort trade, lower waterfront property  values,
cause  skin rashes to man during water contact, and serve as
a desired substrate and breeding ground for flies.

Phosphorus in the elemental form is particularly toxic,  and
subject  to bioaccumulation in much the same way as mercury.
Colloidal  elemental  phosphorus  will  poison  marine  fish
(causing  skin  tissue  breakdown and discoloration).  Also,
phosphorus  is  capable  of  being  concentrated  and   will
accumulate  in  organs  and  soft tissues.  Experiments have
shown that marine  fish  will  concentrate  phosphorus  from
water containing as little as 1 ug/1.

Radioactivity
                           51

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Ionizing  radiation,  when  absorbed  in  living  tissue  in
quantities substantially above that  of  natural  background
levels,  is  recognized  as  injurious.   It  is  necessary,
therefore, to prevent excessive  levels  of  radiation  from
reaching   any   living   organism   humans,   fishes,   and
invertebrates.  Beyond the  obvious  fact  that  radioactive
wastes  emit  ionizing  radiation,  they are also similar in
many respects to other chemical wastes,  Man's senses cannot
detect radiation unless it is present in massive amounts.

Plants and animals, to be of any significance in the cycling
of radionuclides in the aquatic environment, must accumulate
the radionuclide, retain it, be eaten by  another  organism,
and be digestible.  However, even if an organism accumulates
and  retains a radionuclide and is not eaten before it dies,
the radionuclide will enter the "biological  cycle"  through
organisms  that decompose the dead organic material into its
elemental  components.   Plants  and  animals  that   become
radioactive  in this biological cycle can thus pose a health
hazard when eaten by man.

Aquatic  life  may  receive  radiation  from   radionuclides
present   in   the   water   and  substrate  and  also  from
radionuclides that  may  accumulate  within  their  tissues.
Humans  can  acquire  radionuclides  through  many different
pathways.  Among the most  important  are  through  drinking
contaminated  water, and eating fish and shellfish that have
concentrated nuclides from the water.   Where fish  or  other
fresh  or  marine products that have accumulated radioactive
materials are used as food by humans,  the concentrations  of
the  nuclides  in  the  water must be further restricted, to
provide assurance that the  total  intake  of  radionuclides
from all sources will not exceed the recommended levels.

In  order  to  prevent  unacceptable doses of radiation from
reaching humans, fish, and other  important  organisms,  the
concentrations  of  radionuclides  in  water, both fresh and
marine, must be restricted.

Radium-226

Radium-226 is one of the most hazardous radioisotopes of the
uranium decay scheme, when present in water.  The human body
preferentially utilizes  radium  in  lieu  of  calcium  when
present  in  food  or drink.  Plants and animals concentrate
radium, leading to a multiplier effect up the food web.

Radium-226 decays by alpha emission into radon-222, a radio-
active gas with a half life of 3.8 days.  The decay products
of  radon-222,  in  turn,  are  particulates  which  can  be
                             52

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adsorbed  onto  respirable particles of dust.  Radon and its
decay products has been implicated in an increased incidence
of lung cancer in  those  workers  exposed  to  high  levels
(Bureau  of  Mines, 1971).  Heating or grinding of phosphate
rock would liberate radon and  its  decay  products  to  the
surrounding atmosphere.

It is generally agreed that unlike other materials, there is
no threshold value for radiation exposure.  Accordingly, the
Federal  Radiation  Council  has  repeatedly stated that all
radiochemical material  releases  are  to  be  kept  to  the
minimum  practicably  obtainable.   The  Council  states "It
should be general practice to reduce exposure to  radiation,
and  positive  efforts  should be carried out to fulfill the
sense of these recommendations.  It is basic  that  exposure
to  radiation should result from a real determination of its
necessity (Federal Radiation Council, I960)."
                    METHODS OF ANALYSIS
The  methods  of  analysis  to  be  used  for   guantitative
determination  are  given in the Federal Register 40 CFR 136
for the following parameters pertinent to this study:
                  Alkalinity (and Acidity)
                  fluoride
                  oxygen demand, chemical
                  phosphorus
                  solids, total
                  suspended nonfilterable solids, total
                  temperature
                             53

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                        SECTION VII

              CONTROL AND TREATMENT TECHNOLOGY

The factors and  contaminants  in  non-fertilizer  phosphate
chemical  process  effluent  streams  have for the most part
been well identified and well known for many  years.   As  a
consequence considerable effort has been expended to correct
or  minimize  the  majority  of those which are particularly
detrimental to natural water receiving bodies.  Much of this
work has been directed  at  correcting  the  source  of  the
contamination  or  an  in-process improvement rather than an
end-ofpipe  type  of  treatment.   A  large  part   of   the
motivation  for  such  improvement has been economics - that
is,  improved  operating   efficiency   and   costs.    Such
improvements  are  just  plain  good  business  and  justify
capital expenditure required to achieve them.

With an appreciation  of  the  above  mentioned  facts,  the
following   criteria   were   established   as   bases   for
investigating treatment technology.

- To determine the extent of existing  waste  water  control
and treatment technology

   To  determine  the availability of applicable waste water
control and treatment technology regardless of whether it be
intra-industry transfer technology

- To determine the degree of treatment cost reasonability

Based upon these stated criteria  the  effort  was  made  to
factually investigate overall treatment technologies dealing
with  each of the primary factors and contaminants listed in
Section VI.

Process technology does exist both for containment  and  for
treatment   and   reduction   of  the  primary  factors  and
contaminants  present  in   the   non-fertilizer   phosphate
chemical  processes  as  defined  in Section VI.  These have
been divided into two separate  technologies  to  make  them
better  adaptable to all the processes.  For example, in two
of the processes it is very possible that both  technologies
need  to  be  used  and  therefore be considered as a single
treatment method.  In another process however  it  would  be
somewhat  impractical to consider using more than one of the
technologies although they are closely inter-related.  These
two technologies are  therefore  described  separately  even
though  it  is  recognized  that  they  may  be  essentially
integral in some cases.
                            55

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Containment and Cooling Pond

The title provides a reasonably  good  description  of  this
technology.   That  is,  it  is  simply  an  area  where the
contaminated effluent is contained  in  sufficient  guantity
and for a sufficient time to satisfy the process conditions.
The  process  conditions alluded to are instantaneous volume
needs and temperature reduction or cooling.  Due to the fact
that individual process requirements essentially dictate the
area required it is not possible to be  more  specific.   An
indication  of  the land area used for this purpose is shown
by the fact that survey plant A utilizes approximately  0.11
hectare  (0.26  acre)  per daily production ton.  This figure
also includes area adequate to  contain  excessive  rainfall
collection until normal conditions can be restored.

Factors in Pond Construction and Management that Provide
Pond Reliability and Efficiency of Operation

A.  Prevention of Dike Failure

Dike failure has been by far the greatest cause of navigable
water contamination from phosphate mining operations.   Many
slime  pond  dike failures have occurred.  These have caused
massive contamination of surface waters.

A  similar  potential  hazard  exists  from   gyp-pond   and
recirculation   cooling   pond  dikes,  although  these  are
generally much smaller structures than the slime pond dikes.
Gypsum derived from  total  manufacturing  and  waste  water
treatment  practices  is  the  only  dike  material  readily
available at many sites.  It is not an  ideal  material  for
construction  of dams.  A dam constructed entirely of gypsum
has a uniform and relatively high permeability.  Water seeps
through the structure.  Saturation is maintained in much  of
the  dam  mass unless special provision is made for drainage
of the toe.  Some States maintain a degree of regulation  of
dikes.  The State of Illinois requires some underdrainage of
gyp-pond dikes at Joliet, Illinois.

A  saturated  dam  is  weakened in a number of ways.  Piping
occurs in the outer toe.  The water in  the  dam  buoys  the
structural  material,   reducing  the dikes effective weight.
Granular  materials  saturated  with   water   will   become
momentarily  fluid  if  an earthquake or a shock wave of any
type sets up a tremor.

Hazardous conditions  are  common  in  gyp-pond  dams.   The
contractors  diagram  of  a  typical dam, supplied with this
study, indicates, no provision of underdrainage.   The  lack
                              56

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of   specifications  that make dikes safe, and/or the  lack of
enforcement  of   these  specifications  can  lead  to  dike
failures.

A gyp-pond or recirculation pond dike must be constructed in
a manner that maintains effective drainage in the outer half
of   the dike.  If gypsum is the sole material in the  dike, a
farm tile  (or other equally effective) underdrainage  system
should  be  provided in the toe of the dike.  The tile lines
must be close enough together,  located  below  sufficiently
permeable  liner  materials and sloped adequately.  The tile
field  must  remain  operational   and   drain   effectively
throughout  the   entire  period  of waste water containment.
The  engineering details of any  new  gyp-pond  utilized  for
treating   the  waste  water  in  the  other  non-fertilizer
phosphate chemicals segment of the  phosphate  manufacturing
should be submitted to and approved by EPA prior to use.

In   the  event of declining efficiency of a drainage  system,
relief wells should be provided  to  maintain  the  drainage
function.

Both a  relief  well  system  or  a farm tile underdrainage
system leading to an underground sump have  many  advantages
over the  open  ditches commonly utilized to catch seepage.
The  underground systems permit  return  of  seepage  without
lowering  the  outer  edge of the dam.  This strongly favors
dike  safety.   The  ditch  alone  provides  none   of   the
underdrainage required to make the dam safe.

An inherent advantage of the underground sump or relief well
system is that seepage can be returned to the lagoon free of
rain  run-off water.  No ditch is provided (or essential)  to
collect this run-off.

Planting the dam slopes with low plants can be  utilized  to
improve  the water balance and to stabilize the dam surface.
Tall plants that reduce wind velocity over the pond  surface
must be avoided,  wind is an aid to cooling.

The  U.S.  Department of Interior, Bureau of Reclamation, book
"Design  of Small Dams" presents discussions and diagrams of
toe draining systems, with a horizontal drainage blanket,  an
underground drainage trench, and an underground pipe conduit
leading to an outfall.  This system can readily replace  the
open   seepage   interceptive  ditch  in  common  use.   The
intercepted seepage can be pumped back to the pond  from  an
underground  sump.   This system does not return runoff from
outer slopes to the lagoon.
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The reliability of a properly installed underground drainage
system is extremely high.  A soundly designed system assures
a safe dam for its full service life.

If some local factor introduces a  reliability  problem  two
control measures should be considered:

1.   Install  a  conduit  to  the  top altitude of the drain
    system for  periodic  drain  pipe  flushing  to  prevent
    plugging.

2.   Install  a vertical permeable pipe at the center of the
    damf through which the phreatic line  may  be  measured.
    The  design  engineer  should  specify  the maximum safe
    height of this phreatic line for each dam.

New ponds for BPCTCA should have  underdrainage  systems  to
eliminate  the  need  to recycle rainfall on the outer slope
and seepage interceptor ditch.   These  ponds  require  only
freeboard  for  containing  the heaviest expected rain in 10
years.  The freeboard requirement  changes  abruptly  to  be
sufficient to hold the heaviest expected rain in 25 years in
1983.  From practical considerations, it may be advisable to
provide  the  25  year  freeboard  in a new pond to avoid an
alteration problem before 1983.

B.  Control of Seepage

A pond, to be acceptable for use in waste  water  treatment,
should  be  provided  with a liner that prevents significant
percolation  to  ground  water,  and  that  blocks  flow  to
groundwater  through underground channels.  Furthermore, any
waste  water  seepage  must  have  no  solution  action   on
underlying  layers.  It is particularly important to prevent
acidic waste water  seepage  through  limestone  formations.
Some  liming  may  be required, particularly at start-up, to
protect limestone layers, to provide sediment  for  plugging
of  the  bottom  liner,  and to prevent seepage of fluoride,
radium-226 and phosphate components.

Relief wells, underdrainage or other provision must be  made
to  prevent  upflow  of groundwater into the lagoon.  Upflow
into a lagoon normally breaches the liner and  permits  flow
of waste water through existent channels to groundwater when
lagoon   hydrostatic   pressure   exceeds   the  groundwater
pressure.

Groundwater monitoring by means of wells in the  percolation
area  should  be  installed  whenever the lagoon is provided
with a liner of questionable impermeability.   The  addition
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of  lime  to  bottom  sediments  in  lagoons  will  lead  to
neutralization of waste water  seeping  into  ground  water.
The  use  of  lime  will also provide sedimentary conditions
that tend to block seepage.

The liming of pond water can be utilized  to  aid  both  air
pollution   control  and  to  reduce  loss  of  waste  water
pollutants by seepage.

C.  Deposits of Objectionable Substances at
    Phosphate Manufacturing Plants

Various deposits of  objectionable  waste  water  components
occur  in  ponds  or  landfill areas.  Examples of these are
calcium fluoride, radium-226  and  arsenic  sulfide.   Local
State  and  EPA  authorities  with  jurisdiction  over  this
landfill problem should be notified of the deposits and  the
control measures required should then be established.  It is
vital that percolating water does not carry these substances
into ground water or into surface waters.

D.  Ponds in Regions with Severe Cold Seasons

The cooling problem for a  reuse  and  cooling  pond  varies
drastically  from summer to winter seasons in cold climates.
It  is  essential  to  install  conduits   underground,   or
otherwise protect from freezing.  Provision must be made for
isolation  of  a pond with a limited surface area for winter
operation.  The  heat  discharged  to  the  pond  in  normal
operation  will then prevent troublesome freezing incidents.
The winter pond must be deep enough to remain operable after
a plant shutdown.

National standards are not being proposed for  recirculation
and  reuse ponds.  Some State and local authorities have set
standards.  Monitoring should cover the factors that control
loss of waste water to surface and ground waters, and  local
authorities  should  be  notified  of conditions threatening
navigable and ground waters with pollution.

ContaminatedT (Pond)  Water Treatment

This technology is identical to  that  treatment  technology
designated  as gypsum pond (contaminated) water treatment in
the phosphate fertilizer section of the development document
for the Basic Fertilizer Chemicals Manufacturing Industry.

The Containment and Cooling Pond technology described  above
is intended to function as a no discharge closed loop system
the  majority of the time.  This "no discharge" situation is
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however dependent upon  the  quantity  of  rainfall  it  can
accept  before its water storage capacity is exceeded.  Once
the storage area approaches  capacity  it  is  necessary  to
begin   treating   the  contaminated  water  for  subsequent
discharge to natural drainage areas.   Similarly,  in  those
processes  in which a containment pond is impractical it may
be necessary to continuously treat the contaminated  process
effluent  water.   This  technology in part or as a whole is
capable of treating the contaminated effluent of either  the
containment pond or the process effluent streams.

Process Description

Contaminated water can be treated effectively for control of
the  pollution  parameters  identified in Section VI, namely
suspended solids, pH, phosphorus, radium-226, and fluorides.
The treatment described is by means of either single or two-
stage  lime  neutralization  procedure.    In   the   Sodium
Phosphate  process  there  are  indications that only single
liming is required for removal of the impurities.

Normally  two  stages  of  liming  or   neutralization   are
necessary to effect an efficient removal of the fluoride and
phosphate  contaminants.  Fluorides are present in the water
principally  as  fluosilicic  acid  with  small  amounts  of
soluble  salts  as  sodium  and  potassium fluosilicates and
hydrofluoric acid.  Phosphorus  is  present  principally  as
orthophosphoric  acid  with  some  minor  amounts of soluble
calcium orthophosphates in the conventional  wet  phosphoric
acid   production   process.   Polyphosphates  that  require
special pretreatment prior  to  lime  sedimentation  may  be
present in lagoons accepting waste water from defluorination
processes,  and from the manufacture of defluorinated (poly)
phosphates.

The first treatment stage provides sufficient neutralization
to raise the contaminated water containing up to 9,000  mg/1
F  and  up  to  6,500 mg/1 P from pH 1-2 to pH 3.5-4.0.   The
resultant  treatment  effectiveness  is,  to  a  significant
degree, dependent upon the mixing efficiency at the point of
lime  addition and the constancy of the pH control.  At a pH
level  of  3.5  to  U.O,  the  fluorides  will   precipitate
principally  as  calcium  fluoride  (CaF2)   as  shown by the
following chemical equation.

  H2SiF6  +  3 CaO  +  H20     =     3 CaF2  +  2 H20  +  Si02

Fluosilicic    Lime    Water         Calcium     Water    Silica
  Acid
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This mixture is then held in a quiescent area to  allow  the
particulate CaF2 to settle.

Equipment  used  for neutralization ranges from crude manual
distribution of lime with  localized  agitation  to  a  well
engineered  lime  control system with a compartmented mixer.
Similarly the  quiescent  areas  range  from  a  pond  to  a
controlled,   settling   rate  thickener  or  settler.   The
partially neutralized water following  separation  from  the
CaF2,  (pH 3.5-4.0) now contains 30-60 mg/1 F and up to 5,500
mg/1 P.  This water is again treated with lime sufficient to
increase  the  pH  level  to 6.0 or above.  At this pH level
calcium  compounds,  primarily  dicalcium   phosphate   plus
additional  quantities  of  CaF2  precipitate from solution.
The primary reactions are shown by  the  following  chemical
equation:
   2 H3PO4  *  CaO  *  H20
 Phosphoric    Lime    Water
   Acid

   Ca(H2P04)2  +  CaO  +  H20
 Monocalcium      Lime    Water
  Phosphate
Ca(H2PO<*)2
Monocalcium
 Phosphate

   2CaHP04
   Dicalcium
   Phosphate
2 H20
 Water
2 H20
 Water
As  before,  this mixture is retained in a quiescent area to
allow the CaHPO4 and minor amounts of CaF2 to settle.

After settlement, the clear, neutralized water will  contain
15-30 mg/1 F and 30-60 mg/1 P at a pH of 6-8.  The reduction
of the P value is strongly dependent upon the final pH level
and  quality  of the neutralization facilities, particularly
mixing efficiency.  Neutralization to pH levels of 9-11 will
reduce P values to  15-30 mg/1 or less.  Figure VII-1 shows a
sketch of a well designed "double lime" treatment  facility.
Plants B, C and D all practice some degree of liming.
                              61

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 Some   special precautions are  essential at a  plant producing
 sodium phosphates.  All meta,  tetra, pyro and polyphosphate
 waste   water in  spills should  be diverted to  the reuse pond.
 These  phosphates will not precipitate satisfactorily in  the
 lime   treatment  process and will interfere with the removal
 of  fluoride and  suspended solids.

 Polyphosphate in waste water will exert  a  desirable  anti-
 fouling action  if diverted to the cooling water stream from
 the reuse lagoon.  Furthermore, the compound  will  hydrolyze
 and precipitate  in the lagoon.

 Domestic   waste,   unless   completely   bio-oxidized,  has
 undesirable effects in sodium  phosphate plant effluent.  The
 amino  acids and  other organic  components interfere with both
 precipitation and flocculation.  The high calcium  level  of
 the recycle  pond is lacking  in the waste water stream from
 the sodium phosphate plant.  Lime and/or calcium  salts  may
 be  required  for  acceptable  removal of P and F pollutants.
 Adequate  precipitant  reagent use  must  be  supported  by
 effective clarification for control of F, P and SS.

 In  some  circumstances  it may be desirable  to strip carbon
 dioxide from the waste stream  before lime treatment so  that
 carbonate   does   not   compete   with   phosphate  in  the
 precipitation reaction.

 The sodium  phosphates  subcategory  manufacturing  process
 utilizes  a  series  of salting out processes for separating
 various crystallized products.  The  resultant  waste  water
 streams  contain  a  variety   of contaminants that cannot be
 recycled  in  the  process  without   degenerating   product
 quality.   The  manufacturing  processes isolate some of the
 potential waste water  pollutants  from  the  waste  stream.
 Sodium  silicofluoride  is  precipitated  out  and sold as a
 byproduct; this process disposes of most of the  troublesome
 fluoride  problem.   Radium  226  is segregated into various
 sediment  fractions.    Arsenic  is  separated   as   sulfide
 precipitate.  Sedimentation occurs in the waste streams from
 the sodium phosphate processes and the sediments are removed
 by  clarification.  The technical details of these processes
 have not been fully disclosed by the manufacturer.

A recirculation pond is available on the site  for  handling
 difficult  waste  water streams to the same extent that this
 lagoon system is available for defluorinated rock  and  acid
waste water.

Modified  forms  of  phosphate  create  a  unique  treatment
 problem at defluorination plants.    Phosphoric  acid  and/or
                               62

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phosphate   salts   undergo   polymerization  and  molecular
rearrangement reactions when subjected to severe dehydration
treatment.  The acid defluorination treatments  applied  are
predominantly  operated  with  application of heat and a gas
stripping action.  These heating  and/or  stripping  actions
induce  a  substantial degree of molecular conversion in the
defluorinated acids.  The conversion is particularly high in
super-acid grades  concentrated  to  a  high  P2^05  content.
Likewise,   the   high   temperatures   applied   for   rock
defluorination  convert  the  raw  orthophosphate  rock   to
polyphosphates.

These    modified    phosphates    differ    sharply    from
orthophosphates in solubility.  Calcium orthophosphates have
extremely low solubility in moderately  alkaline  solutions;
the   calcium   salts   of   the  modified  phosphates  have
appreciable solubility.  In fact, these modified  phosphates
are  applied  extensively  as  chelating  agents  to  combat
calcium induced hardness.   These  modified  phosphates  are
relatively  stable  at  ambient temperatures.  The half life
varies from compound to compound and is poorly defined; this
half life is commonly taken to be about  2  days  in  acidic
waters, but is several weeks in neutral or alkaline waters.

These modified phosphates enter the process waste water from
various  sources.   Stack  washing introduces some dust from
rock  defluorination.    Spray   carryover   to   barometric
condenser  water is a common source of contamination in acid
defluorination.  Spills and leaks carry polyphosphates  into
waste  water  in  all  the subcategories.  Rain run-off from
drying, packaging, loading and shipping  areas  carry  these
modified phosphates into the waste water stream.

It  is  vitally  important  that  waste  water bearing these
modified phosphates be excluded from streams flowing to lime
treatment  facilities;  this  is  especially   objectionable
without  impoundment.   The  calcium salts of these modified
phosphates  are  much  more   soluble   than   the   calcium
orthophosphate  salts.  Satisfactory phosphate precipitation
will   not   occur   on   lime   treatment.     Furthermore,
polyphosphates exert an objectionable interference action on
clarification  processes.   And  still  further, the soluble
calcium salts of molecular species other than orthophosphate
act  as  individual  agents  in  the  calcium  precipitation
process.   Thus,  a  system  with  only  orthophosphate will
remain saturated with  calcium  orthophosphate.   The  mixed
system will remain saturated with calcium orthophosphate and
with  each  component  calcium  phosphate.   The  sum of the
phosphate components in solution will  be  higher  than  the
orthophosphate component alone.
                              63

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Where  waste  water  contamination  does  occur  with  these
modified phosphates, the resultant waste streams, should  be
directed to a special holding pond, along with acidic wastes
that  speed  hydrolysis.   Completing  of  hydrolysis can be
promoted further by discharge into  the  contaminated  water
recirculation  pond.   The  modified phosphates continue the
hydrolysis to orthophosphate in  the  recirculation  lagoon.
This  factor  adds another plus value to the desirability of
the recirculation and reuse lagoon at a  phosphate  facility
with  defluorination  processes.   The holding is especially
beneficial at  the  typical  low  pH  levels  prevailing  in
typical   contaminated   water   ponds.    Acidity   hastens
hydrolysis to the orthophosphate form.

A unique condition prevails in  the  waste  water  discharge
from  the  single  plant  producing sodium phosphates.  This
stream also contains the domestic waste discharge  from  the
septic  tanks  accepting  the  plant's  domestic sewage.  An
efficient aerobic bio-oxidation step applied to  this  waste
water  would  destroy  most  of  the organic substances that
interfere  with  sedimentation;   furthermore,   this   bio-
oxidation   process   will   catalyze   the   hydrolysis  of
polyphosphates present in the waste water to orthophosphate.
Bio-oxidation  may  be  the  most   practicable   means   of
converting  any  polyphosphates present to orthophosphate in
this situation.  The waste stream is neutral; hydrolysis  of
polyphosphates  will  be extremely slow unless bio-catalytic
action  is  induced  in  the  system.   Many  microorganisms
produce    enzymes   that   catalyze   the   hydrolysis   of
polyphosphates.  Reference P brings out the observation that
no problem was encountered in  precipitating  phosphates  in
domestic  waste  water  following bio-oxidation of the waste
water.

It must be recognized that pH alone does  not  indicate  the
total  effectiveness  of  the  precipitating  reagent.   The
calcium content in the pond water will also be a factor  and
will  vary widely.  The sulfate ion competes for the calcium
ion; a high sulfate content will tend to reduce the  calcium
content   of  a  pond  and  create  a  condition  relatively
unfavorable for fluoride and phosphate  precipitation.   The
pH   change  induced  by  lime  addition,  gives  a  general
indication of the precipitation potential in the system.   A
pH  rise  from  lime  addition  is  accompanied by a rise in
soluble calcium content.  In normal circumstances,  lime  to
pH  6.0  will  be  adequate  for  precipitating fluorine and
phosphate to meet required limitations, but lime  will  have
to   be  added,  as  required,  if  fluoride  and  phosphate
limitations are not met.
                              64

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 Soluble  iron and aluminum  compounds  are  present  at  high
 concentrations in many ponds.  The iron and aluminum cations
 exert a  strong influence on phosphate precipitation.

 Strong   winds  interfere  with  sedimentation in lagoons.  A
 covered  terminal sedimentation basin,  or  a  covered  final
 segment  of  a sedimentation basin will be indispensable for
 attaining satisfactory suspended solids removal  under  many
 conditions.   A  cover is particularly beneficial in periods
 of  cold weather.   Temperature  inversion  currents  cause
 severe   disturbance  of sedimentation in open basins in cold
 weather.   Inlet  and  outlet  arrangements  are   critical.
 Poorly   designed  inlets  and outlets permit excessive short
 circuiting.  Arrangements that direct flow tangentially  are
 vastly   superior to arrangements that direct flow from inlet
 toward outlet structure.

 Monitoring Treatment After Rainfall Breaches the
 Required Freeboard of a Lagoon

 The authority monitoring a lagoon should specify a treatment
 rate for the waste water breaching  the  required  freeboard
 high   enough   to  restore  the  required  freeboard  in  a
 reasonable  time  period.   If  treatment  is  delayed,   or
 conducted  at an unreasonably slow rate, overflow will occur
 from rains considerably below the heaviest expected rainfall
 in a 10  or 25 year period.

 Control  of Unusual Discharges to Pond

 Monitoring authorities should require a report on all  waste
 water  streams  discharged  to  the  recirculation and reuse
 pond.  Problems may arise at plants discharging waste  water
 from   processes   other  than  phosphate  manufacturing  or
 fertilizer  phosphate  production.   Ponds  should  also  be
 managed  and  located  in  a  manner that limits ammonia and
 organic compound intrusion.

 The recirculation and  reuse  pond  will  have  considerable
 capacity  to absorb noncontact cooling water that has become
 contaminated  by  leaks  and  process  waste   waters   from
ancillary  phosphate manufacturing operations at most sites;
however, the situation at a  point source should be monitored
to make certain that the point source is not  utilizing  the
pond  as  a  device  for  evading regulations on waste water
discharges from unrelated manufacturing operations.

Ponds should be managed and  located in a manner  that  limit
ammonia and organic substance intrusion.
                            65

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Many  objectionable  metals  are  kept  under control by the
sedimentation processes in the pond and by the terminal lime
treatment process.  The presence  of  ammonia  and  of  some
organic  compounds  interfere seriously with these treatment
processes.  Particular care should be  taken  around  plants
producing  ammonia and other nitrogenous fertilizers; drying
towers and  other  facilities  losing  ammonia  gas  to  the
atmosphere   are   particularly   troublesome   sources   of
contamination.   Domestic  wastes   interfere   with   metal
precipitation    processes   and   with   flocculation   and
clarification processes.

Rationale for New Pond "Within the Impoundment" Definition

An explanation was requested for the rationale  applied  for
adopting  the  "within  the  impoundment" definition for new
source impoundments, and for all impoundments constructed on
or after the date of this regulation.

Technical  information  is  provided  in  this  section  and
Reference   L  on  the  use  of  underdrainage  systems  for
collection and removal of the waste water that seeps through
the dam.  Information is also provided on the use of  relief
wells  for  removal  of  seepage water from the toe of dams.
One or both of these systems may  be  essential  to  prevent
weakening  of a dam by saturation with water.  A combination
of underdrainage and relief well systems  is  a  practicable
and  economically feasible means of collecting seepage water
and returning it to the lagoon.  This combination will  cost
very  little  more than the usual lagoon, with the periferal
collection ditch seepage return system in common  use.   The
underdrainage  combination  will  cost  less  than the usual
system at sites with high-cost land.

The underdrainage and relief well system can be operated  in
a  manner  that collects no rain runoff from the outer slope
of the dam.  This procedure reduces the waste  water  volume
that  must  be  treated  and  discharged during periods when
rainfall exceeds evaporation.  Inasmuch as  this  technology
is  readily  applicable to new lagoons, for all impoundments
or new source impoundments constructed on or after the  date
of  this  regulation,  the term "within the impoundment" for
purposes of calculating the volume of  process  water  which
may  be  discharged shall mean the water surface area within
the impoundment at maximum capacity.
                            66

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I LIME |
HOPPER
 CAR
                            DUST COLLECTOR
T3Lti
                      LIME
                   FEEDER
        STEAM
HOT WATER
  TANK
                                                                       _
                                                                  STORAGE
                                           TO GYPSUM POND
                                                                             CALCIUM PHOSPHATE
                                                                                  POND
                                                                                 TO RIVER OR
                                                                                 PROCESS UNITS
                          CONTAMINATED (POND)  WATER TREATMENT
                                                                              FIGURE VII-1

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                        SECTION VIII

         COST, ENERGY AND NON-WATER QUALITY ASPECT
General
The costs - capital and operating - have been estimated  for
the  two  treatment  technologies  described in Section VII.
These costs are given as August 1971 dollar values.  In  the
case of the costs indicated for Containment and Cooling Pond
technology,  there  is  additional  explanation made on what
they represent and  how  they  might  be  used.   The  costs
indicated   for  the  Contaminated  (Pond)   Water  Treatment
technology are based on a specific treatment  capacity  such
as  would  be found at a moderate size production unit.  The
following paragraphs  provide  identification  of  the  cost
elements used in this section and indicated on Table VIII-1.

Cost Elements

Investment

This  is  the  capital cost associated with the engineering;
site preparation; construction and  installation;  and  such
other  costs  required to place the technology in operation.
It does not include production loss or profits loss that may
be encountered  from  tying  the  new  facilities  into  the
existing plant operations.

Interest

This  cost  is  based  on  the  assumption  that the capital
expenditure was borrowed at a 7.5% annual interest rate.

Depreciation

The nature and service life expected of this type  equipment
were the bases for selection of an assumed ten year straight
line depreciation.

Operating and Maintenance Costs

The  items  included  in  this  cost  element  are operating
supplies, replacement  parts,  insurance,  taxes,  operating
labor and maintenance labor.

Energy.
                             69

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This  item  is  the  power  costs  to operate the mechanical
equipment.  Electrical energy is assumed at the cost  of  10
mils per KWH.

Total Annual Costs

An accumulation of the various cost items described above.

Installation and Operation of Technologies

Containment and Cooling Pond

The  cost of this technology is difficult to estimate due to
the need of a specific design  for  each  individual  plant.
Pond  size  is  a function of many items including the water
temperature  (cooling) required for process, the economics of
land availability, provision for rainfall, and  geographical
location.    The   indicated  investment  cost  is  that  to
establish a 10" high dike around one  (1)  acre.   This  cost
also assumes that the dike will be established from earth at
the  site  and strictly by large earth-moving equipment - no
transportation of earth to the site.  Cost of  earth  moving
has been estimated at $1.50 per cubic yard.

It can be stated that a minimum containment and cooling pond
for a moderate size plant would be 10 - 20 acres.

Construction time is estimated at 80 hours per acre.

There  would  be  no  interruption of plant operation during
construction.

Contaminated  (Pond) Water Treatment

This is the  same technology and  costs  estimated  for  Pond
Water  Treatment  in the phosphate fertilizer  section of  the
Basic Fertilizer Chemicals Survey.

Time required for engineering, procurement, and  construction
is  15 - 18 months.

There would  be no interruption  of   plant  operation  during
construction.

Start-up  and  initial operation would  require approximately
24  hours  of  continuous  operation  to  establish   stabilized
conditions.

Air  Pollution Control
                               70

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Air  pollution  control  poses  a  serious  problem  in  the
industry, particularly in the defluorinated  phosphate  rock
subcategory.  The fluoride expelled from the rock on heating
would  cause  an  extremely  serious air pollution situation
without the stack scrubbing applied in  the  industry.   The
EPA air pollution control authorities are initiating studies
to  determine  the  status of the air pollution problem, and
the relationship to the water pollution problem.

Information must also  be  gathered  on  radon-222  and  the
radioactive  breakdown  solid substances derived from radon-
222.  Radon-222 is an inert gas with a very short half life.
Exposure of human beings to these radioactive products  must
be   held   to   safe   levels.   Hopefully,  more  definite
information will soon be available on how to deal with  this
problem.   The use of solid wastes, particularly gypsum, for
home construction is inadvisable unless found to be free  of
radioactive component hazard.

Solid Wastes

Many solids residues are left as solid wastes.

For  those  waste  materials  considered to be non-hazardous
where land disposal is the choice  for  disposal,  practices
similar  to  proper  sanitary  landfill  technology  may  be
followed.  The  principles  set  forth  in  the  EPA's  Land
Disposal of Solid Wastes Guidelines (40 CFR 211) may be used
as guidance for acceptable land disposal techniques.

For  those  waste  materials  considered  to  be  hazardous,
disposal may  require  special  precautions.   In  order  to
ensure   long-term  protection  of  public  health  and  the
environment, special preparations and  pretreatment  may  be
required  prior  to  disposal.   If  land  disposal is to be
practiced, these sites must not allow movement of pollutants
such as fluoride and radium-226 to either ground or  surface
water.   Sites should be selected that have natural soil and
geological conditions to prevent such contamination  or,  if
such  conditions  do  not  exist,  artificial  means   (e.g.,
liners) should be provided to ensure long-term protection of
the   environment   from   hazardous    materials.     Where
appropriate,  the  location  of  solid  hazardous  materials
disposal  sites  should  be  permanently  recorded  in   the
appropriate  office  of  the legal jurisdiction in which the
site is located.
                              71

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                         SECTION IX

            BEST PRACTICABLE CONTROL TECHNOLOGY
                    CURRENTLY AVAILABLE

          INTERIM FINAL GUIDELINES AND LIMITATIONS

Introduction

The effluent limitations which must be achieved by  July  1,
1977   are   based  on  the  degree  of  effluent  reduction
attainable through the application of the  best  practicable
control   technology  currently  available.   For  the  non-
fertilizer phosphate chemicals manufacturing industry,  this
level   of   technology   is  based  on  the  best  existing
performance by exemplary plants of various sizes,  ages  and
chemical processes within each of the industry's categories.
In some cases where no truly exemplary plants were surveyed,
this level of technology is based upon state-of-the-art unit
operations commonly employed in the chemical industry.

Best practicable control technologies currently available in
the non-fertilizer phosphate chemicals industry involve both
in-process techniques and end-of-process treatment.

Based  upon the information contained in Section III through
VIII of this report, the following determinations were  made
on   the   degree   of   effluent  reduction  attainable  by
application  of  the  best  practicable  control  technology
currently  available  in  the individual process of the non-
fertilizer phosphate chemical  industry.   Each  process  is
presented separately in the following paragraphs.

Specialized Definitions

(a) Except  as  provided  below,  the  general  definitions,
abbreviations  and  methods  of analysis set forth in 40 CFR
U01 shall apply to this subpart.

(b) For all impoundments constructed prior to  the  date  of
this regulation, the term "within the impoundment" when used
for  purposes  of  calculating  the  volume of process waste
water which may be discharged shall mean the  water  surface
area  within  the  impoundment  at maximum capacity plus the
area of the inside and outside slopes of the impoundment dam
and the  surface  area  between  the  outside  edge  of  the
impoundment  dam  and any seepage ditch immediately adjacent
to the dam upon which rain falls  and  is  returned  to  the
impoundment.   For  the  purpose  of  such calculations, the
surface area allowances set forth above shall  not  be  more
                              73

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than  30  percent  of  the  water  surface  area  within the
impoundment dam at maximum capacity.

(c) For  all  impoundments  or   new   source   impoundments
constructed  on  or  after  the date of this regulation, the
term "within the impoundment11 for  purposes  of  calculating
the  volume  of  process water which may be discharged shall
mean the  water  surface  area  within  the  impoundment  at
maximum capacity.

(d) The term "pond water surface area"  when  used  for  the
purpose  of  calculating the volume of waste water which may
be discharged shall mean the water surface  area  at  normal
operating  level  of the pond created by the impoundment for
storage of process waste water.  This surface  shall  in  no
case  be  less  than  one-third  of  the surface area of the
maximum amount of water which  could  be  contained  by  the
impoundment.   Normal  operating  level shall be the average
level of the pond during the preceeding calendar month.

(a), above, applies to all three subcategories; (b) , (c)  and
(d) apply  to  the  defluorinated  phosphate  rock  and  the
defluorinated phosphoric acid subcategories.

    Subpart D - Defluorinated Phosphate Rock Subcategory

The  provisions of this subpart are applicable to discharges
resulting from  the  defluorination  of  phosphate  rock  by
application  of  high  temperature  treatment along with wet
process phosphoric acid, silica and other reagents.

In establishing the limitations set forth in  this  section,
EPA  took  into  account  all  information  it  was  able to
collect, develop and solicit with respect to  factors  (such
as  age  and  size  of  plant,  raw materials, manufacturing
processes,   products   produced,    treatment    technology
available,  energy  reqxiirements and costs)  which can affect
the   industry   subcategorization   and   effluent   levels
established.  It is, however, possible that data which would
affect  these  limitations have not been available and, as a
result, these limitations should  be  adjusted  for  certain
plants  in this industry.  An individual discharger or other
interested  person  may  submit  evidence  to  the  Regional
Administrator  (or  to  the  State,  if  the  State  has the
authority to issue NPDES permits)  that factors  relating  to
the  equipment  or facilities involved, the process applied,
or  other  such  factors  related  to  such  discharger  are
fundamentally  different  from the factors considered in the
establishment of the  guidelines.   On  the  basis  of  such
evidence   or  other  available  information,  the  Regional
                              74

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Administrator (or the State) will  make  a  written  finding
that such factors are or are not fundamentally different for
that facility compared to those specified in the Development
Document.  If such fundamentally different factors are found
to  exist,  the  Regional  Administrator  or the State shall
establish for the discharger  effluent  limitations  in  the
NPDES   permit  either  more  or  less  stringent  than  the
limitations established herein, to the  extent  dictated  by
such fundamentally different factors.  Such limitations must
be  approved  by  the  Administrator  of  the  Environmental
Protection  Agency.   The  Administrator  may   approve   or
disapprove  such  limitations, specify other limitations, or
initiate proceedings to revise these regulations.

The following limitations establish the quantity or  quality
of   pollutants   or  pollutant  properties,  which  may  be
discharged by a point source subject to  the  provisions  of
this  subpart  after  application  of  the  best practicable
control technology currently available.

 (a) Subject to the provisions of paragraphs   (b) ,   (c) ,  and
 (d)  of this section, there shall be no discharge of process
waste water pollutants into navigable waters.

 (b) A process waste water   impoundment  which  is  designed,
contructed  and  operated so as to contain the precipitation
from the  10 year, 2H hour rainfall event as  established  by
the   National   Climatic   Center,   National   Oceanic  and
Atmospheric Administration,  for  the  area  in  which such
impoundment  is located may discharge that volume of process
waste  water  which  is  equivalent   to   the   volume   of
precipitation that falls within the  impoundment  in  excess of
that  attributable  to  the 10 year, 2U hour rainfall  event,
when such event occurs.

 (c) During any calendar month there  may be discharged  from  a
process  waste water impoundment either a volume  of  process
waste    water   equal   to   the   difference    between  the
precipitation  for  that  month  that   falls    within  the
 impoundment  and   either the evaporation from the pond water
 surface  area for that month, or a volume  of  process  waste
water equal to the difference between the mean  precipitation
for  that month  that  falls within the impoundment and the
mean evaporation from the pond water surface  area   for that
month  as established  by  the  National  Climatic Center,
National Oceanic and  Atmospheric  Administration,  for  the
area  in which such impoundment is  located  (or  as  otherwise
 determined if  no monthly data have been established by  the
National Climatic  Center),  whichever is greater.
                           75

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 (d)  Any process waste water discharged pursuant to paragraph
 (c)  of this  section shall comply with each of the  following
 requirements:

 Effluent                         Effluent
 Characteristic                    Limitations

                     Maximum for      Average of daily
                     any one day      values for thirty
                                     consecutive days
                     	      shall not exceed_

          (Metric units, mg/1)

 Total  phosphorus       70              35
   (as  P)
 Fluoride               30              15
 TSS                     50              25
 PH                      Within the range  6.0  to 9.0.

 Rationale^for Best  Practicable Control  Technology
 Currently Available

 The  criteria   used   for  selection  of   the   technology was
 information  obtained at three of  the   four  total operating
 plants  in the U.S.   Two of  the three plants (survey plants A
 and  B)  have the Containment and Cooling Pond Technology in
 service  and  to  date  have  never found it necessary to  treat
 or   discharge   water  to  navigable  waters.   Survey Plant C
 stated  plans of  installing  this technology   in the  near
 future.

 The  proposed   limitations  are based on composite (not grab)
 sampling and years   of   historical  effluent   data.   These
 limitations  represent values which are being achieved by the
 better exemplary plants surveyed.

 The  volume  of process waste water that may be  discharged is
 determined by the rainfall-evaporation circumstances at  the
 site,  and   by the definitions and regulations  pertaining to
 the  structure of the recirculation and reuse pond.   Process
 waste  water  discharge   is  not  necessary  at   some sites.
 Plants that  discharge process waste water normally  do  this
 only in periods of heavy  rainfall.

 Discharged   effluent  must  be  lime  treated.   This  is  a
 relatively costly operation.   Diligent  water  conservation
 and  reuse  practices  have proven to be the most economical
means to handle the waste water problem.
                              76

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   Subpart E - Defluorinated Phosphoric Acid Subcategory

The provisions of this subpart are applicable to  discharges
resulting  from  the defluorination of phosphoric acid.  Wet
process phosphoric acid is dehydrated by application of heat
and other processing aids such as vacuum and air  stripping.
The  acid  is  concentrated  up to 70-73 percent P2O5 in the
defluorination process.

The technology described as Containment and Cooling Pond  is
defined as the best practicable control technology currently
available.   This  technology  confines  all  process  waste
waters  to  the  plant   area.    Recirculation   of   these
contaminated  process  waters  to  the process together with
good water management practices  essentially  eliminate  the
need  for  treatment  or  discharge  of treated contaminated
process water to navigable waters.  In the event of  a  need
for  emergency  type discharge, then the Contaminated  (Pond)
Water treatment technology or a facsimile of it  would  also
be indicated.

    The  following  limitations  establish  the  quantity or
quality of pollutants or pollutant properties, which may  be
discharged  by  a  point source subject to the provisions of
this subpart  after  application  of  the  best  practicable
control technology currently available:

(a) Subject to the provisions of paragraphs   (b),   (c),  and
(d)  of this section, there shall be no discharge of process
waste water pollutants into navigable waters.

(b) A process waste water  impoundment  which  is  designed,
contructed  and  operated so as to contain the precipitation
from the 10 year, 2U hour rainfall event as  established  by
the   National   Climatic   Center,   National  Oceanic  and
Atmospheric Administration,  for  the  area  in  which  such
impoundment  is located may discharge that volume of process
waste  water  which  is  equivalent   to   the   volume   of
precipitation that falls within the impoundment in excess of
that  attributable  to  the 10 year, 24 hour rainfall event,
when such event occurs.

(c) During any calendar month there may be discharged from a
process waste water impoundment either a volume  of  process
waste   water   equal   to   the   difference   between  the
precipitation  for  that  month  that   falls   within   the
impoundment  and  either the evaporation from the pond water
surface area for that month, or a volume  of  process  waste
water equal to the difference between the mean precipitation
for  that  month  that  falls within the impoundment and the
                              77

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mean evaporation from the pond water surface area  for  that
month  as  established  by  the  National  Climatic  Center,
National Oceanic and  Atmospheric  Administration,  for  the
area  in  which such impoundment is located (or as otherwise
determined if no monthly data have been established  by  the
National Climatic Center), whichever is greater.

(d) Any process waste water discharged pursuant to paragraph
(c) of this section shall comply with each of the  following
requirements:

Effluent                         Effluent
Characteristic                   Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall not exceed_

         (Metric units, mg/1)

Total phosphorus        70             35
   (as P)
Fluoride                30             15
TSS                     50             25
pH                      Within the range 6.0 to 9.0.

         Subpart F - Sodium Phosphates Subcategory

The  provisions of this subpart are applicable to discharges
resulting from the manufacture of purified sodium phosphates
from wet process phosphoric acid.

The  technology  described  as  Contaminated  (Pond)   Water
Treatment   is  defined  as  the  best  practicable  control
technology currently available, and/or in-process technology
- whichever will achieve the same  results.   Process  waste
water   is  also  continuously  treated  and  discharged  to
navigable waters.  A lagoon recirculation system is  in  use
for  treatment of the process waste water from production of
the  raw  product  acid  required  for   sodium   phosphates
manufacture, and can be utilized for disposal of troublesome
waste water streams.

    The  following  limitations  establish  the  quantity or
quality of pollutants or pollutant properties, controlled by
this section, which may be  discharged  by  a  point  source
subject  to the provisions of this subpart after application
of  the  best  practicable  control   technology   currently
available:
                              78

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Effluent                         Effluent
Characteristic                   Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall not exceed

         (Metric units, kg/kkg of product)

TSS                     0.50             0.25
Total phosphorus        0.80             0.40
   (as P)
Fluoride                0.30             0.15
pH                      Within the range 6.0 to 9.0.

         (English units, lb/1000 Ib of product)

TSS                     0.50           0.25
Total phosphorus        0.80           0.40
   (as P)
Fluoride                0.30           0.15
pH                      Within the range 6.0 to 9.0.

Rationale for Best Practicable Control Technology
Currently Available

The  criteria used for selection of the treatment technology
included a variety of items ranging  from  consideration  of
the  process  characteristics to the known commercial limits
of capability.

In this process, the conditions are such  that  contaminated
process  water  cannot  be  re-used  or  treated  due to the
product  purity  specifications  and  the  unit   operations
reguired  to attain that purity.  Therefore, fresh water use
is a process requirement and continuous discharge of process
water is a necessity.   Based  on  this  consideration,  the
capability  of  treating  the  contaminated process water to
achieve significant reduction of contaminants to  acceptable
levels  has  been commercially proven.  The recognition that
this end-of-process treatment is sensitive to water quantity
variations with subsequent adverse quality effects indicated
the need to base limitations on  production- tonnage  rather
than the best possible treatment results and concentrations.
Six  different  process areas contribute to the contaminated
process water stream and process water effluent quantity  is
a   function   of  the  number  of  units  in  instantaneous
operation.
                               79

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Another  consideration  was  that  the  proposed  guidelines
coincide   with   commercial  operations  for  reduction  of
parameters within limits that would not  initiate  the  need
for   additional   treatment   facilities.    That  is,  the
guidelines  proposed  coincide   with   contaminant   levels
attainable  at  the  proposed pH 6.0 to 9.0 treatment range.
This  pH  range  permits  direct  discharge   of   clarified
effluent,  without  neutralization.   All waste streams that
bear any of the dehydrated products,  metaphosphate  through
polyphosphate,  can  be  diverted  to the recirculation pond
when  flow  to  the  clarifier  is  sufficient  to  cause  a
discharge   violation.   These  modified  phosphates  create
problems in the usual clarification process.   The  treatment
system  will  require  a  hydrolytic  process  that converts
phosphate  components  to   the   orthophosphate   form   if
significant   quantities   of   polyphosphate   waste  water
components are in the stream undergoing  lime  precipitation
and clarification.  These processes are discussed in Section
VII.
                                80

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                         SECTION X


     BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE

          Interim Final Guidelines and Limitations

The  effluent  limitations which must be achieved by July 1,
1983,  are  based  on  the  degree  of  effluent   reduction
attainable   through   application  of  the  best  available
technology   economically   achievable.    This   level   of
technology  was based on the very best control and treatment
technology employed by a specific point  source  within  the
industrial  category  and  on sound, established waste water
management and treatment processes.

Specialized  definitions  are  the  same  as  for  the  best
practicable control technology currently available.

    Subpart D - Defluorinated Phosphate Rock Subcategory

    The  following  limitations  establish  the  quantity or
quality of pollutants or pollutant properties, which may  be
discharged  by  a  point source subject to the provisions of
this  subpart  after  application  of  the  best   available
technology economically achievable:

(a) Subject to the provisions of paragraphs   (b),  (c),  and
(d)  of this section, there shall be no discharge of process
waste water pollutants into navigable waters.

(b) A process waste water  impoundment  which  is  designed,
contructed  and  operated so as to contain the precipitation
from the 25 year, 24 hour rainfall event as  established  by
the   National   Climatic   Center,   National  Oceanic  and
Atmospheric Administration,  for  the  area  in  which  such
impoundment  is located may discharge that volume of process
waste  water  which  is  equivalent   to   the   volume   of
precipitation that falls within the impoundment in excess of
that  attributable  to  the 25 year, 24 hour rainfall event,
when such event occurs.

(c) During any calendar month there may be discharged from a
process waste water impoundment either a volume  of  process
waste   water   equal   to   the   difference   between  the
precipitation  for  that  month  that   falls   within   the
impoundment  and  either the evaporation from the pond water
surface area for that month, or a volume  of  process  waste
water equal to the difference between the mean precipitation
for  that  month  that  falls within the impoundment and the
                             81

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mean evaporation from the pond water surface area  for  that
month  as  established  by  the  National  Climatic  Center,
National Oceanic and  Atmospheric  Administration,  for  the
area  in  which such impoundment is located  (or as otherwise
determined if no monthly data have been established  by  the
National Climatic Center), whichever is greater.

(d)  Any process waste water discharged pursuant to paragraph
(c)  of this section shall comply with each of the  following
requirements:

Effluent                         Effluent
Characteristic                   Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall not exceed

         (Metric units, mg/1)

Total phosphorus        70             35
  (as P)
Fluoride                30             15
TSS                     50             25
pH                      Within the range 6.0 to 9.0.

Rationale for the Best Available Technology Economically
Achievable

The  rationale  is  identical  to  that for best practicable
control  technology  currently  available,  except  that   a
greater  freeboard  is  required  for  retention  of heavier
rains.  The required technology to achieve  BATEA  has  been
established at exemplary plants.

   Subpart E - Defluorinated Phosphoric Acid Subcategory

    The  following  limitations  establish  the  quantity or
quality of pollutants or pollutant properties, which may  be
discharged  by  a  point source subject to the provisions of
this  subpart  after  application  of  the  best   available
technology economically achievable:

(a)  Subject to the provisions of paragraphs   (b) ,   (c) ,  and
(d)   of this section, there shall be no discharge of process
waste water pollutants into navigable waters.

(b)  A process waste water  impoundment  which  is  designed,
contructed  and  operated so as to contain the precipitation
                              82

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from the 25 year, 2U hour rainfall event as  established  by
the   National   Climatic   Center,   National  Oceanic  and
Atmospheric Administration,  for  the  area  in  which  such
impoundment  is located may discharge that volume of process
waste  water  which  is  equivalent   to   the   volume   of
precipitation that falls within the impoundment in excess of
that  attributable  to  the 25 year, 24 hour rainfall event,
when such event occurs.

(c) During any calendar month there may be discharged from a
process waste water impoundment either a volume  of  process
waste   water   equal   to   the   difference   between  the
precipitation  for  that  month  that   falls   within   the
impoundment  and  either the evaporation from the pond water
surface area for that month, or a volume  of  process  waste
water equal to the difference between the mean precipitation
for  that  month  that  falls within the impoundment and the
mean evaporation from the pond water surface area  for  that
month  as  established  by  the  National  Climatic  Center,
National Oceanic and  Atmospheric  Administration,  for  the
area  in  which such impoundment is located  (or as otherwise
determined if no monthly data have been established  by  the
National Climatic Center), whichever is greater.

(d) Any process waste water discharged pursuant to paragraph
(c) of this section shall comply with each of the  following
requirements:

Effluent                         Effluent
Characteristic                   limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall not exceed^

          (Metric units, mg/1)

Total phosphorus        70             35
   (as P)
Fluoride                30             15
TSS                     50             25
pH                     Within the  range 6.0 to 9.0.

         Subpart F - Sodium Phosphates Subcategory

The   best   available   treatment  economically  achievable
includes  the  use  of  the  contaminated  water  pond   and
continuous lime  treatment  of some waste water streams.
                              83

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The   best   available   treatment  economically  achievable
standards for the sodium phosphates subcategory are  set  at
70  percent  of  the  discharge levels for suspended solids,
fluoride and phosphate waste water components  proposed  for
the best practicable control technology currently available.
It  is  the  opinion  of the Environmental Protection Agency
staff and its advisors that this reduction  can  be  readily
achieved.  Improvements of this order and greater are common
in  fertilizer phosphate plants facing the need for improved
water conservation practices to avoid excessive costly  lime
treatment.   The recirculation lagoon is available to handle
waste streams that present difficult treatment problems.

    The following  limitations  establish  the  quantity  or
quality of pollutants or pollutant properties, controlled by
this  section,  which  may  be  discharged by a point source
subject to the provisions of this subpart after  application
of the best available technology economically achievable:

Effluent                         Effluent
Characteristic                   Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall not exceed

         (Metric units, kg/kkg or lb/1000 Ib of product)

TSS                     0.35             0.18
Total phosphorus        0.56             0.28
  (as P)
Fluoride                0.21             0.11
PH                      Within the range 6.0 to 9.0.
                              84

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                         SECTION XI
         PROPOSED NEW SOURCE PERFORMANCE STANDARDS
                 AND PRETREATMENT STANDARDS
Proposed New Source Performance Standards

This  level  of technology is to be achieved by new sources.
The term "new source" is defined in the  Act  to  mean  "any
source,   the  construction  of  which  is  commenced  after
publication of proposed regulations prescribing  a  standard
of  performance." New source performance standards are to be
evaluated by adding  to  the  consideration  underlying  the
identification   of   best  practicable  control  technology
currently available, a determination of what  higher  levels
of  pollution  control  are  available  through  the  use of
improved production processes and/or  treatment  techniques.
Thus,  in addition to considering the best in-plant and end-
of-process  control  technology,  new   source   performance
standards  are to be based upon an analysis of how the level
of effluent  may  be  reduced  by  changing  the  production
process itself.  Alternative processes, operating methods or
other  alternatives  are to be considered.  However, the end
result of the analysis identifies effluent  standards  which
would  reflect  levels of control achievable through the use
of  improved  production  processes  (as  well  as   control
technology),  rather  than  prescribing a particular type of
process or technology which must  be  employed.   A  further
determination   which   was   to  be  made  for  new  source
performance standards is whether a  standard  permitting  no
discharge of pollutants is practicable.

The  following factors were to be considered with respect to
production processes which were analyzed  in  assessing  new
source performance standards:

    a.   The type of process employed and process changes.

    b.   Operating methods.

    c.   Batch as opposed to continuous operations.

    d.   Use of alternative raw materials and mixes  of  raw
         materials.

    e.   Use of dry rather  than  wet  processes   (including
         substitution of recoverable solvents for water).
                               85

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    f.   Recovery of pollutants as by-products.

Specialized definitions are the same as for best practicable
control technology  currently  available.   All  new  source
ponds  come  under  new source regulations; surface area for
the purpose of computing rainfall is  the  area  within  the
impoundment at maximum capacity.
    Subpart D - Defluorinated Phosphate Rock Subcategory

The   following   standards  of  performance  establish  the
quantity or quality of pollutants or  pollutant  properties,
controlled by this section, which may be discharged by a new
source subject to the provisions of this subpart:

(a) Subject to the provisions of paragraphs  (b) ,  (c) ,  and
(d)  of this section, there shall be no discharge of process
waste water pollutants into navigable waters.

(b) A process waste water  impoundment  which  is  designed,
contructed  and  operated so as to contain the precipitation
from the 25 year, 24 hour rainfall event as  established  by
the   National   Climatic   Center,   National  Oceanic  and
Atmospheric Administration,  for  the  area  in  which  such
impoundment  is located may discharge that volume of process
waste  water  which  is  equivalent   to   the   volume   of
precipitation that falls within the impoundment in excess of
that  attributable  to  the 25 year, 24 hour rainfall event,
when such event occurs.

(c) During any calendar month there may be discharged from a
process waste water impoundment either a volume  of  process
waste   water   equal   to   the   difference   between  the
precipitation  for  that  month  that   falls   within   the
impoundment  and  either the evaporation from the pond water
surface area for that month, or a volume  of  process  waste
water equal to the difference between the mean precipitation
for  that  month  that  falls within the impoundment and the
mean evaporation from the pond water surface area  for  that
month  as  established  by  the  National  Climatic  Center,
National Oceanic and  Atmospheric  Administration,  for  the
area  in  which such impoundment is located  (or as otherwise
determined if no monthly data have been established  by  the
National Climatic Center), whichever is greater.

(d) Any process waste water discharged pursuant to paragraph
(c) of this section shall comply with each of the  following
requirements:
                             86

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Effluent
Characteristic
                    Maximum for
                    any one day
         (Metric units, mg/1)
Total phosphorus
   (as P)
Fluoride
TSS
PH
70

30
50
         Effluent
         Limitations

            Average of daily
            values for thirty
            consecutive days
            shall not exceed
35

15
25
Within the range 6.0 to 9.0.
   Subpart E - Defluorinated Phosphoric Acid Subcategory

The   following   standards  of  performance  establish  the
quantity or quality of pollutants or  pollutant  properties,
controlled by this section, which may be discharged by a new
source subject to the provisions of this subpart:

(a) Subject to the provisions of paragraphs  (b) ,  (c) ,  and
(d)  of this section, there shall be no discharge of process
waste water pollutants into navigable waters.

(b) A process waste water  impoundment  which  is  designed,
contructed  and  operated so as to contain the precipitation
from the 25 year, 2U hour rainfall event as  established  by
the   National   Climatic   Center,   National  Oceanic  and
Atmospheric Administration,  for  the  area  in  which  such
impoundment  is located may discharge that volume of process
waste  water  which  is  equivalent   to   the   volume   of
precipitation that falls within the impoundment in excess of
that  attributable  to  the 25 year, 24 hour rainfall event,
when such event occurs.

(c) During any calendar month there may be discharged from a
process waste water impoundment either a volume  of  process
waste   water   equal   to   the   difference   between  the
precipitation  for  that  month  that   falls   within   the
impoundment  and  either the evaporation from the pond water
surface area for that month, or a volume  of  process  waste
water equal to the difference between the mean precipitation
for  that  month  that  falls within the impoundment and the
mean evaporation from the pond water surface area  for  that
month  as  established  by  the  National  Climatic  Center,
National Oceanic and  Atmospheric  Administration,  for  the
area  in  which such impoundment is located  (or as otherwise
                               87

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determined if no monthly data have been established  by
National Climatic Center), whichever is greater.
                                 the
(d)  Any process waste water discharged pursuant to paragraph
(c)  of this section shall comply with each of the  following
requirements:
Effluent
Characteristic
                    Maximum for
                    any one day
         (Metric units, mg/1)
Total phosphorus
   (as P)
Fluoride
TSS
PH
70
         Effluent
         Limitations

            Average of daily
            values for thirty
            consecutive days
            shall not exceed
35
30             15
50             25
Within the range 6.0 to 9.0,
         Subpart F - Sodium Phosphates Subcategory

Performance  standards  for  new sources are the same as for
best available technology economically achievable:

The  following  standards  of  performance   establish   the
quantity  or  quality of pollutants or pollutant properties,
controlled by this section, which may be discharged by a new
source subject to the provisions of this subpart:
Pollutant or
Pollutant Property
                    Maximum for
                    any one day
         Effluent
         Limitations

            Average of daily
            values for thirty
            consecutive days
            shall not exceed
          (Metric units, kg/kkg of product)
TSS
Total phosphorus
   (as P)
Fluoride
PH
 0.35
 0.56
    0.18
    0.28
 0.21              0.11
 Within the range 6.0 to 9.0.
          (English units, lb/1000 Ib of product)

-------
TSS                      0.35              0.18
Total phosphorus         0.56              0.28
   (as P)
Fluoride                 0.21              0.11
pH                       Within the range 6.0 to 9.0.

Pretreatment Standards for Existing Sources

    Subpart D - Defluorinated Phosphate Rock Subcategory

The pretreatment standard under section 307(b)   of  the  Act
for   a  source  within  the  defluorinated  phosphate  rock
subcategory which is a user of a  publicly  owned  treatment
works and a major contributing industry as defined in HO CFR
128   (and which would be an existing point source subject to
section 301 of the Act, if it were to  discharge  pollutants
to the navigable waters), shall be the standard set forth in
40  CFR,  128, except that, for the purpose of this section,
40 CFR  128.121,  128.122,  128.132  and  128.133  shall  not
apply.   The following pretreatment standard establishes the
guantity or quality of pollutants or  pollutant  properties,
controlled  by  this  section,  which may be discharged to a
publicly owned treatment works by a point source subject  to
the provisions of this subpart:

The  volume  of  waste  water  that  may  be  discharged  is
established by the interim final  guidelines  for  the  best
practicable control technology currently available.

Pollutant or                     Effluent
Pollutant Property               Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	shall^ not exceed

         (Metric units)    mq/1 of effluent discharged

BOD5                         	No limitation	
TSS                          	No limitation	
pH                           	No limitation	
Total phosphorus             70                 35
Fluoride                     30                 15

   Subpart E - Defluorinated Phosphoric Acid Subcategory

The  pretreatment  standard  under section 307(b)  of the Act
for  a  source  within  the  defluorinated  phosphate   rock
subcategory  which  is  a user of a publicly owned treatment
                                89

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works and a major contributing industry as defined in 40 CFR
128  (and which would be an existing point source subject  to
section  301  of the Act, if it were to discharge pollutants
to the navigable waters), shall be the standard set forth in
40 CFR, 128, except that, for the purpose of  this  section,
40  CFR  128.121,  128.122,  128.132  and  128.133 shall not
apply.  The following pretreatment standard establishes  the
quantity  or  quality of pollutants or pollutant properties,
controlled by this section, which may  be  discharged  to  a
publicly  owned treatment works by a point source subject to
the provisions of this subpart:

The  volume  of  waste  water  that  may  be  discharged  is
established  by  the  interim  final guidelines for the best
practicable control technology currently available.

Pollutant or                     Effluent
Pollutant Property               Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     Shall not exceed

         (Metric units)     mg/1 of effluent__discharged

BOD5                         	No limitation	
TSS                          	No limitation	
pH                           	No limitation	
Total phosphorus             70                 35
Fluoride                     30                 15

         Subpart F - Sodium Phosphates Subcategory

The pretreatment standard under section 307(b)  of  the  Act
for   a  source  within  the  defluorinated  phosphate  rock
subcategory which is a user of a  publicly  owned  treatment
works and a major contributing industry as defined in 40 CFR
128   (and which would be an existing point source subject to
section 301 of the Act, if it were to  discharge  pollutants
to the navigable waters) , shall be the standard set forth in
40  CFR,  128, except that, for the purpose of this section,
40 CFR 128.121,  128.122,  128.132  and  128.133  shall  not
apply.   The following pretreatment standard establishes the
quantity or quality of pollutants or  pollutant  properties,
controlled  by  this  section,  which may be discharged to a
publicly owned treatment works by a point source subject  to
the provisions of this subpart:

Pollutant or                     Effluent
                           90

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Pollutant Property               Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall_not exceed_

         (Metric units)    kg/kkg of product

BOD5                         	No limitation	
TSS~                         	No limitation	
pH                           	No limitation	
Total phosphorus             0.80               0.40
Fluoride                     0.30               0.15

         (English units)   lb/IOOO_lb_of_£roduct

BOD5                         	No limitation	
TSS                          	No limitation	
pH                           	No limitation	
Total phosphorus             0.80               0.40
Fluoride                     0.30               0.15

Pretreatment Standards  for New Sources

    Subpart D - Defluorinated Phosphate Rock Subcategory

The  pretreatment  standard  under section 307(b) of the Act
for  a  source  within  the  defluorinated  phosphate   rock
subcategory  which  is  a user of a publicly owned treatment
works and a major contributing industry as defined in 40 CFR
128  (and which would be an existing point source subject  to
section  301  of the Act, if it were to discharge pollutants
to the navigable waters), shall be the standard set forth in
40 CFR,  128, except that, for the purpose of   this  section,
40  CFR  128.121,  128.122,  128.132  and   128.133 shall not
apply.  The following  pretreatment standard establishes  the
quantity  or  quality  of pollutants or pollutant properties,
controlled by this section, which may  be  discharged  to   a
publicly  owned treatment works by a point source subject to
the provisions of this  subpart:

The  volume  of  waste water  that  may  be   discharged  is
established  by  the   interim  final guidelines for the best
practicable control technology currently available.

Pollutant or                     Effluent
Pollutant Property               Limitations

                    Maximum for     Average of daily
                         91

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                    any one day     values for thirty
                                    consecutive days
                    	     shall not exceed

          (Metric units)    mq/1 of effluent discharged

BOD5                         	No limitation	
TSS                          	No limitation	
PH                           	No limitation	
Total phosphorus             70                 35
Fluoride                     30                 15

   Subpart E - Defluorinated Phosphoric Acid Subcategory

The pretreatment standard under section 307(b)  of  the  Act
for   a  source  within  the  defluorinated  phosphate  rock
subcategory which is a user of a  publicly  owned  treatment
works and a major contributing industry as defined in 40 CFR
128   (and which would be an existing point source subject to
section 301 of the Act, if it were to  discharge  pollutants
to the navigable waters) , shall be the standard set forth in
40  CFR,  128, except that, for the purpose of this section,
40 CFR 128.121,  128.122,  128.132  and  128.133  shall  not
apply.   The following pretreatment standard establishes the
quantity or quality of pollutants or  pollutant  properties,
controlled  by  this  section,  which may be discharged to a
publicly owned treatment works by a point source subject  to
the provisions of this subpart:

The  volume  of  waste  water  that  may  be  discharged  is
established by the interim final  guidelines  for  the  best
practicable control technology currently available.

Pollutant or                     Effluent
Pollutant Property               Limitations

                    Maximum for     Average of daily
                    any one day     values for thirty
                                    consecutive days
                    	     shall not exceed^

         (Metric units)     mg/1 of effluent discharged

BOD5                         	No limitation	
TSS                          	No limitation	
PH                           	No limitation	
Total phosphorus             70                 35
Fluoride                     30                 15

         Subpart F - Sodium Phosphates Subcategory
                          92

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         Subpart F - Sodium Phosphates Subcategory

The  pretreatment  standard  under section 307(b) of the Act
for  a  source  within  the  defluorinated  phosphate   rock
subcategory  which  is  a user of a publicly owned treatment
works and a major contributing industry as defined in 40 CFR
128  (and which would be an existing point source subject  to
section  301  of the Act, if it were to discharge pollutants
to the navigable waters), shall be the standard set forth in
40 CFR, 128, except that, for the purpose of  this  section,
40  CFR  128.121,  128.122,  128.132  and  128.133 shall not
apply.  The following pretreatment standard establishes  the
quantity  or  quality of pollutants or pollutant properties,
controlled by this section, which may  be  discharged  to  a
publicly  owned treatment works by a point source subject to
the provisions of this subpart:
Pollutant or
Pollutant Property
                    Maximum for
                    any one day
      Effluent
      ^imitations

         Average of daily
         values for thirty
         consecutive days
         shall not exceed
         (Metric units)
BOD5
TSS
pH
Total phosphorus
Fluoride
kg/kkq of product

  	No limitation	
  	No limitation	
  	No limitation	
  0.80               0.40
  0.30               0.15
         (English units)    Ib/IOOO^lb of product
BOD 5
TSS
PH
Total phosphorus
Fluoride
  	No limitation	
  	No limitation	
  	No limitation	
  0.80               0.40
  0.30               0.15
                           93

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                        SECTION XII

                       ACKNOWLEDGMENT
This report was prepared  by  the  Environmental  Protection
Agency  on  the  basis of a comprehensive study performed by
Davy Powergas, Inc., under contract  no.  68-01-1508,  model
#2.  Mr. R. W. Heinz, Project Manager, prepared the original
(contractor's)  report.   Mr.  Heinz  was  assisted  in  the
preparation of this report, by the following personnel:  Mr.
D. W. Ross, Mr. Charles T. Harding, Mr.  Gerald  T.  Fields,
Mr.  N.  V. Fry, Mr. George Telatnik, Mr. Jack Frost, Mr. E.
Singler, and Mr. H. Honey.

This study was initiated under the supervision and  guidance
of  Elwood  E.  Martin.   The final phases of the study were
supervised by Chester E. Rhines, with  extensive  transition
assistance from Mr. Martin.

Overall  guidance  and  excellent assistance was provided by
the author's associates in the Effluent Guidelines Division,
particularly Messrs. Allen Cywin, Director, Ernst  P.  Hall,
Deputy Director, and Walter J. Hunt, Branch Chief.

The  cooperation  of  manufacturers who offered their plants
for survey and  contributed  pertinent  data  is  greatfully
appreciated.  The operations and the plants visited were the
property of the following companies:

         Borden Chemical Company, Plant City, Fla.

         Occidental Chemical Co., Houston, Tex.

         Olin Corporation, Stamford, Conn.

         J. R. Simplot Co., Pocatello, Idaho

         Thornton Laboratory, Tampa, Fla.

The  members  of  the  working  group/steering committee who
participated in the internal EPA review are:
                                                           •
         Mr. Walter J. Hunt, Chairman, Effluent Guidelines
                   Division

         Mr. Elwood Martin, Effluent Guidelines Division

         Dr. Robert Swank , NERC, Corvallis (Athens)
                            95

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         Mr. Paul Desrosiers, ORM, Headquarters

         Mr. James Kamihaci, OPE, Headquarters

         Dr. Edmund Lomasney, Region IV

         Mr. James Rouse, NFIC, Denver

         Dr. Chester E. Rhines, Effluent Guidelines Division

Acknowledgement and appreciation is also given to  Ms.  Kaye
Starr,  Ms.  Nancy  Zrubek,  Ms.  Alice  Thompson,  and  Ms.
Ernestine Christian  of  the  Effluent  Guidelines  Division
secretarial  staff  and  to  the  secretarial  staff of Davy
Poowergas, Inc., for their efforts in the typing of  drafts,
necessary  revisions,  and the final preparation of this and
the contractor's draft document.
                            96

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                        SECTION XIII

                         REFERENCES


A.  Phosphoric Acid, Phosphates and Phosphatic Fertilizers by
    William Henry waggaman. University Microfilms, Inc., Ann
    Arbor, PP. 233-236, original volume copyright 1927, 1952,
    by Reinhold Publishing corporation, Library of Congress
    Card Number 52-9791.

B.  Defluorination of Phosphate Rock by Clinton A. Hollingsworth,
    Lakeland, Florida, assignor to Smith-Douglas Company, Inc.,
    Norfolk, Va., United States Patent Office Number 2,995,437,
    Patented Aug. 8, 1961.

C.  Method of Defluorinating Phosphate Rock in a Fluid
    Bed Reactor by Clinton A. Hollingsworth and John H. Snyder,
    Lakeland, Fla., assignors to the Borden Company, New York, N.Y.
    a corporation of New Jersey, United States Patent Office
    Number 3,364,008, Patented January 16, 1968.

D.  Method^of Agglomerating Phosphate Material by Clinton A.
    Hollingsworth and Jack F. Lewis, Lakeland, Fla., assignors,
    by mesne assignments, to The Borden Company, United States
    Patent Office, Number 3,189,433, Patented June 15, 1965.

E.  Chemical Economics Handbook
    Stanford Research Institute, Phosphorus and Compounds,
    762.2030 A, 762.2030 B, 762.2030 C, December 1969.

F.  Phosphorus and Its Compounds
    John R. Van Wager, Interscience Publishers, Inc., New
    York  (1961)  Library of Congress Card No. 58-10100.

G•  1972 Fertilizer Summary Data
    Norman L. Hargett, National Fertilizer Development Center,
    Tennessee Valley Authority, Muscle Shoals, Alabama.

H•  Development Document for Effluent Limitations
    Guidelines and New Source Performance Standards for_the
    Phosphorus Derived Chemicals Segment of the Phosphate
    Manufacturing Point Source Category
    United States Enivronmental Protection Agency, EPA
    440/1-74/006, January,  1974.

I.  Development Document^for Effluent Limitations
    Guidelines and New Source Performance Standards for the  Basic
    Fertilizer Manufacturing Point Source Category, United
    States Environmental Protection Agency, EPA 440/1-
    74-011-a, March,  1974.
                           97

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J.  Engineering Field Manual for Conservation Practices
    U.S. Department of Agriculture, Soil Conservation Service
    Section I, 1969 and Section 2, 1971.

K-  Earth Manual
    U.S. Department of the Interior, Bureau of Reclamation,
    First Edition, Denver, Colorado, July, 1940  (a new edition
    is being printed).

L.  Design of Small Dams
    U.S. Department of the Interior, Bureau of Reclamation,
    Second Edition, 1973.

M.  Those Nasty Phosphatic Clay Ponds, Environmental
    Science and Technology, page 312, April, 1974.

N.  Reconnaissance Study of Radiochemical Pollution from
    Phosphate Rock Mining and Milling, National Field Investi-
    gations Center-Denver, Denver, Colorado, Revised May, 1974.

O.  Interim Radium-226 Effluent Guidance for Phosphate
    Chemicals and Phosphate Fertilizer Manufacturing, Statement
    of Considerations - August 5, 1974, Criteria and Standards
    Division, Office of Radiation Programs, Environmental
    Protection Agency,  Washington, D.C.   20460.

P.   Black & Veatch, Consulting Engineers, Process Design
    Manual for Phosphorus Removal, U.S. Environmental
    Protection Agency Program 17010 GNP, Contract 14-12-936
    (October 1971).

Q.   "Water Quality Criteria 1972," National Academy of Sciences
    and National Academy of Engineering for the Environmental
    Protection Agency,  Washington, D.C.  1972 (U.S. Govt. Printing
    Office  Stock No. 5501-00520).
                            98

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                        SECTION XIV
                          GLOSSARY
Apatite

A natural  calcium  phosphate  usually  containing  fluorine
occurring as phosphate rock.

PPG

Davy Powergas

Gyp-pond

This  term  is widely used at fertilizer phosphate plants to
indicate the pond receiving waste  water  and  acting  as  a
recirculation,  cooling  and  water reuse pond.  Many plants
have ponds with a variety of functions such as receiving the
calcium  sulfate  residue  from  acid  treatment  of   rock,
receiving   calcium   fluoride  from  first  stage  of  lime
precipitation,  receiving  calcium  phosphate  and   calcium
fluoride  sediment  from second stage of lime precipitation,
recirculation of stack washing and tail gas  scrubber  water
and   simultaneously   removing   heat   and  sediment,  and
deposition of troublesome solids, as arsenic sulfide.  Local
authorities will have to determine  specific  pond  uses  in
order   to  establish  essential  solid  waste  control  and
groundwater pollution control measures.
1,000 kilograms

I

liter

Process Waste Water

The term "process waste water" means any water which, during
manufacturing or processing, comes into direct contact  with
or  results  from the production or use of any raw material,
intermediate product, finished product, by-product, or waste
product.

Ton

All uses of term  "ton"  imply  short  ton  equal  to  2,000
pounds.
                           99

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                                                 METRIC UNITS
                                               CQT.V1SRSICN TABLE
o
o
MULTIPLY  (ENGLISH UNITS)

  ENGLISH UNIT       ABBREVIATION

acre                   ac
acre - feet            ac ft
British Thermal        BTU
  Unit
British Thermal        BTU/lb
  Unit/pound
cubic feet/minute      cfm
cubic feet/second      cfs
cubic feet             cu ft
cubic feet             cu ft
cubic inches           cu in
degree Fahrenheit      °F
feet                   ft
gallon                 gal
gallon/minute          gpm
horsepower             hp
inches                 in
inches of mercury      in Eg
pounds                 Ib
million gallons/day    mgd
mile                   mi
pound/square inch      psig
   (gauge)
square feet            sq ft
square inches          sq in
tons  (short)           ton

yard                   yd
        by

    CONVERSION

      0.405
   1233.5
      0.252

      0.555

      0.028
      1.7
      0.028
     28.32
     16.39
      0.555  (°F-32)*
      0.3048
      3.785
      0.0631
      0.7457
      2.54
      0.03342
      0.454
       3,785
      1.609
(0.06805 psig  +1)*

      0.0929
      6.452
      0.907

      0.9144
                                                                          TO OBTAIN  (METRIC UNITS)

                                                                      ABBREVIATION      METRIC UNIT
ha
cu m
kg cal

kg cal/kg

cu m/min
cu m/rnin
cu m
1
cu cm
°C
m
1
I/sec
kw
cm
atm
kg
cu m/day
km
atm

sq m
sq cm
kkg

m
hectares
cubic meters
kilogram-calories

kilogr£im calories/
 kilogram
cubic neters/minute
cubic neters/minute
cubic neters
liters
cubic centimeters
degree Centigrade
meters
liters
liters/second
kilowatts
centimeters
atmospheres
kilograms
cubic meters/day
kilometer
atmospheres
  (absolute)
square meters
square centimeters
metric tons
  (1000 kilograms)
meters
            *Actual conversion, nor a multiplier

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