UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330 2-80-025
EVALUATION OF PROCESS WASTEWATER SOURCES,
WASTE TREATMENT, AND DISPOSAL SYSTEMS
SCM GLIDDEN-DURKEE, ADRIAN-JOYCE WORKS
Baltimore, Maryland
July 1980
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
vvEPA
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF ENFORCEMENT
EPA-330/2-80-025
EVALUATION OF PROCESS WASTEWATER SOURCES,
WASTE TREATMENT, AND DISPOSAL SYSTEMS
SCM GLIDDEN-DURKEE, ADRIAN-JOYCE WORKS
Baltimore, Maryland
July 1980
Barrett E. Benson
Arthur N. Masse
NATIONAL ENFORCEMENT INVESTIGATIONS CENTER
Denver, Colorado
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CONTENTS
I. INTRODUCTION 1
II. SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS 8
SUMMARY 8
CONCLUSIONS 8
RECOMMENDATIONS 10
III. PROCESS DESCRIPTION, WASTEWATER SOURCES, AND
TREATMENT H
CHRONOLOGY OF COMPANY'S Ti02 PRODUCTION 11
PROCESS DESCRIPTION AND WASTEWATER SOURCES 13
WASTEWATER TREATMENT 23
IV. HAZARDOUS WASTE DISPOSAL 31
V. TREATMENT NEEDS AND PERMIT LIMITATIONS 33
TREATMENT NEEDS 33
PERMIT LIMITATIONS 43
TABLES
1. U.S. Titanium Dioxide Production Facilities 3
2. Effluent Limitations For Titanium Dioxide Industry. . . 5
3. NPDES Permit Limitations 7
4. Summary Of Waste Sources - Sulfate Process 19
5. Summary Of Waste Sources - Chloride Process 24
6. Effluent Quality 30
7. Summary Of Effluent Data - Discharge Monitoring
Reports 34
8. 60-Day Continuous Monitoring Data - Outfall 001 .... 35
9. 60-Day Continuous Monitoring Data - Outfall 002 .... 39
10. Summary Of Effluent Data-PWAN/SWAN Neutralization
Plant 40
11. Summary Of Effluent Data - PWAN/SWAN Neutralization
Process 42
FIGURES
1. Plant Site Plot Plan 2
2. Typical Sulfate Process Flow Diagram 14
3. Ti02 Chloride Process 21
4. Wastewater Treatment Schematic 25
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METRIC/ENGLISH CONVERSIONS
Length
Volume
Velocity
•'low
Weighi
Pressure
Metric Unit
millimeters (mm)
centimeters (cm)
micrometers (urn)
meters (m)
kilometers (km)
square centimeters (cm2)
square meters (m2)
square kilometers (km2)
hectares (ha)
cubic centimeters (cm3)
cubic meters (m3)
liters (1)
meters/second (m/scc)
kilometers/hour (km/hr)
cubic meters/second (m3/sec)
cubic meters/eiay (ni3/day)
grams (g)
metric tons (m tons)
kilograms/sq centimeter (kg/cm2)
0 Celsius (°C)
multiplied
t>y
0 0394 •
* 25.4
0.3937 -
•* 2 54
3.937 x 10"5 -
- 2.545 x 10""
3.281 -
- 0 3048
1 0936 -
* 0 9144
0.6214 -
- 1 6093
0.155 *
- 6.452
10 76 -
- 0.0929
1 196 -
- 0 8361
0 3861 -
- 2.590
247 1 -
- 4 0469 x 10"3
2 471 -
- 0 4047
0 0610 -
* 16 39
35.31 -
- 0.0283
1.3079 -
- 0 7646
1 057 -
» 0.9461
0.2642 -
- 3 785
0.0353 -
<• 28 32
3.281 *
* 0 3048
2 237 -
- 0.447
0 6214 -
- 1 609
0 5396 -
- 1 853
35 31 -
• 0 0283
1 585 x 10" -
- 6 31 x 10"5
22 883 -
- 0 0437
0 1835 -
- 5.4504
2 64 x 10"" -
- 3785
4 086 x 10"" -
- 2450
8 11 x 10"" -
- 1230
0 0353 -
*• 28 3495
2 205 x 10"3 -
- 453 59
1 102 -
* 0 9072
2205 -
- 4 535 x 10""
14 22 -
* 0 0703
9/5 (°C) + 32 -
* 5/9 (°F - 32)
9/5 (absolute) •
- 5/9 (absolute)
English Unit
inches (in)
inches (in)
inches (in)
feet (ft)
yards (yd)
miles (mi)
square inches (In2)
square feet (ft2)
square yards (yd2)
square miles (mi2)
acres
acres
cubic inches (in3)
cubic feet (ft3)
cubic yards (yd3)
quarts (qt)
gallons (gal)
cubic feet (ft3)
feet/second (ft/sec)
miles/hour (mph)
miles/hour (mph)
knots (kn)
cubic feet/second (cfs)
gallons/minute (gpm)
million gallons/day (mgd)
gallons/minute (gpm)
million gallons/day (mgd)
cubic feet/second (cfs)
acre-feet/day (afd)
ounces (oz)
pounds (Ib)
short tons (tons)
pounds (Ib)
pounds/square inch (psi)
0 Fahrenheit (°F)
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I. INTRODUCTION
On January 22 to 25 and February 20 to 22, 1980, personnel from the
National Enforcement Investigations Center (NEIC) and the State of Maryland
Water Resources Administration conducted a plant inspection of process
wastewater sources, wastewater treatment and disposal systems, and solid
and hazardous waste disposal practices at the SCM Glidden-Durkee Adrian-
Joyce Works near Baltimore, Maryland [Figure 1]. The Adrian-Joyce Works is
operated by the Glidden Pigments Group of the Chemical and Metallurgical
Division of SCM. The facility manufactures titanium dioxide (Ti02) by the
sulfate and chloride processes.
Titanium dioxide, a high-volume chemical ranking within the first
fifty of all U.S. chemical production, is manufactured domestically by six
companies in eleven plants [Table 1]. Over 50% of the Ti02 produced is
used in paints, varnishes, and lacquers. About one-third is used in the
paper and plastics industries. Other uses are found in ceramic, ink, and
rubber manufacturing.
Waste streams from the chloride process fall into two categories: (1)
chlorination wastes composed of sludge from titanium tetrachloride pro-
duction, and (2) wastes incurred during the oxidation process and milling
of the Ti02 product. The sulfate process has a very heavy water-borne
waste load consisting of about 2,000 Ibs of sulfuric acid and 1,000 Ibs of
metal sulfates per 1,000 Ibs of product. Waste streams generated in the
sulfate process include: (1) sludge from the digestion and subsequent
filtration of the ore, (2) copperas, (3) strong acid cuts, (4) weak acid
cuts, and (5) titanium dioxide losses. The sulfate process wastewater is
the more difficult to treat due to impurities from the lower-grade ores and
the volumes of sludge and gypsum produced in wastewater neutralization.
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PAGE NOT
AVAILABLE
DIGITALLY
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TABLE 1
U.S. TITANIUM DIOXIDE PRODUCTION FACILITIES
Company
Location
Process
American Cyanamid Co. Savannah, George
E.I. DuPont deNemours
& Co. Inc.
Gulf & Western
Industries, Inc.
Kerr-McGee Corporation
N.L. Industries, Inc.
SCM Corporation
Antioch, California
DeLisle, Mississippi
Edge Moor, Delaware
New Johnsonville,
Tennessee
Ashtabula, Ohio
Gloucester City, New
Jersey
Hamilton, Mississippi
Sayerville, New Jersey
Ashtabula, Ohio
Baltimore, Maryland
Sulfate and chloride
Chloride
Chloride
Chloride
Chloride
Chloride
Sulfate
Chloride
Sulfate
Chloride
Sulfate and chloride
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On March 12, 1974, effluent limitations for the Inorganic Chemicals
Manufacturing Point Source Category were published in the Federal Register
by the U.S. Environmental Protection Agency. Titanium dioxide effluent
limitations were included as a subcategory [Table 2]. The American Cyana-
mid Company in Savannah, Georgia was the first Ti02 manufacturer to build
treatment facilities which produced an effluent that complied with the
limitations. The treatment system produced gypsum as a byproduct of the
neutralization step. White gypsum (contains very little impurities) is
recovered in the first neutralization step (pH 4.5) and red gypsum (con-
tains high levels of impurities) is recovered in the neutralization from pH
4.5 to 7. The red gypsum to date has no market value and presents a dis-
posal problem. Although a market for white gypsum for use as wallboard was
being developed, the cost of natural gypsum was so low as to suppress the
synthetic gypsum market. Therefore, the white gypsum and red gypsum are
being stockpiled onsite in Savannah. However, Cyanamid has recently made
arrangements with Lemco, Inc. for the sale of the gypsum.*
On March 10, 1976, the Unites States Court of Appeals for the Fourth
Circuit decided in E.I. DuPont de Nemours and Company, et al v. Train (No.
74-1261) to set aside and remand for reconsideration a number of general
definitions and specific discharge regulations promulgated in 1974. The
Ti02 subcategory was included in the Court's remand.
N.L. Industries, Gulf & Western, and SCM Glidden-Durkee did not in-
stall best practicable control technology currently available (BPT) for the
sulfate processes and missed the July 1, 1977 compliance date. To date,
neither N.L. nor Gulf & Western have installed treatment systems. N.L.
continues to barge process wastes from Sayerville, New Jersey to the ocean
for disposal. Gulf & Western discharges raw wastes to a slip (which is
subject to daily tidal flooding), then to the Delaware River. SCM Glid-
den-Durkee developed and installed a neutralization-filtration treatment
system for the sulfate wastes, but Discharge Monitoring Reports (DMR's)
submitted by the Company showed that the effluent was not in compliance
with the NPDES permit limitations.
* Chemical Week Technology Newsletter, August 29, 1979.
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Table 2
EFFLUENT LIMITATIONS FOR TITANIUM DIOXIDE INDUSTRY'
March 12, 1974
BPTU
(lb/1,000 Ib)
BATC and NSPSd
(lb/1,000 Ib)
Chloride Process
Total Suspended Solids 4.4
Iron ' 0.72
pH within range 6.0 to 9.0
Sulfate Process
Total Suspended Solids 21
Iron 1.68
pH within range 6.0 to 9.0
2.6
0.36
within range 6.0 to 9.0
10.6
0.84
within range 6.0 to 9.0
a Remanded by the United States Court of Appeals for the Fourth
Circuit, March 10, 1976.
b Best practicable control technology currently available.
c Best available technology economically achievable.
d New source performance standards.
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In August 1978, the State of Georgia and American Cyanamid entered
into a consent decree whereby the effluent limitations were relaxed and the
Company agreed to pay the State $500/day for each day the effluent total
iron exceeds 510 Ibs but does not exceed 60,000 Ibs. If the total iron
exceeds 60,000 Ibs, the Company pays a surcharge based on the amount
discharged. This consent decree was granted because American Cyanamid was
the only Company meeting BPT and was absorbing unit wastewater costs that
were significantly greater than those encountered by the other companies.
The long-term outlook for titanium- dioxide is for modest growth, based
mainly on its established uses as a pigment in paint and other coatings,
paper, and plastics. Ti02 prices are less than twice the level of 1970,
despite soaring increases in all costs.*
The Director of the Enforcement Division of EPA Region III requested
that NEIC investigate the process waste discharges from the Adrian-Joyce
Works and determine what treatment technology is needed to meet the final
permit limitations. The NPDES permit [Table 3] for this facility was based
on best engineering judgment pursuant to Section 402 (a)(l) of the Federal
Water Pollution Control Act PL 92-500 because there were no guidelines for
the industry.
The specific objectives of the NEIC inspection were to:
1. Investigate processes to determine sources of process waste.
2. Evaluate the adequacy of wastewater treatment facilities to
determine the capability of meeting the permit limitations.
3. Recommend effluent limitations for the second round NPDES
permit.
4. Determine the treatment technology available to meet second
round permit limitations.
* Chemical Week, May 21, 1980, page 25.
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TABLE 3
NPDES PERMIT LIMITATIONS
Total Discharge for Outfalls 001 Plus 002
SCM GLIDDEN-DURKEE
ADRIAN-JOYCE WORKS
July 1, 1977 - June 27, 1979
Discharge Limitations
Effluent
Characteristic
Flow - mVday (mgd)
Total Suspended Solids
Total Iron
Temperature
kg/day (Ib/day)
Daily Avg Daily Max
N/A N/A
1,960 (4,320) 2,948 (6,
550 (1,212) 825 (1,
N/A N/A
Other
Daily Avg
N/A
500) N/A
818) N/A
N/A
Units
Daily Max
N/A
N/A
N/A
110° F
Monitoring Requirements
Measurement
Frequency
Continuous
1/2 day
1/2 day
Continuous
Sample
Type
Recorded
24- hr Comp.
24- hr Comp.
Recorded
The pH shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall be moni-
tored continuously and recorded.
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8
II. SUMMARY, CONCLUSIONS, AND RECOMMENDATIONS
SUMMARY
On January 22 to 25 and February 20 to 22, 1980, personnel from the
NEIC and State of Maryland Water Resources Administration conducted an
investigation of the SCM Glidden-Durkee Adrian-Joyce Works operations. The
investigation consisted of discussing processes and waste disposal prac-
tices with Company representatives and verifying the information by touring
the plant, treatment facilities, and disposal areas. The information
developed was used to provide the rationale for limitations for the second
round NPDES permit, and to determine treatment needs to bring the wastewater
effluents into compliance with these limitations.
CONCLUSIONS
The acid-bearing wastewater from the sulfate process can be effec-
tively treated by neutralization and clarification in the PWAN/SWAN*
facility provided that the system is not overloaded due to increased
production. The effluent quality deteriorates with high production. There
is insufficient capacity in the batch attack lagoon (flow equalization
pond) to control flow to the PWAN/SWAN reactors and final clarifier. If
high production is intermittent, an acceptable effluent can be produced if
the batch attack lagoon capacity is increased. If high production becomes
continuous, then the PWAN/SWAN reactors and clarifier systems must be
expanded.
The wastewaters discharged from Outfall 001 will not comply with
effluent limitations without treatment. The discharge in itself exceeds
* Primary Waste Acid Neutralization/Secondary Waste Acid Neutralization.
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the allowable load for iron and TSS for all effluents. The only treatment
provided is pH adjustment which is not always effective. Due to the high
concentrations of iron and TSS contributed by processes and runoff, com-
pliance cannot be achieved without either removing and treating all con-
taminated waste streams discharged to the Outfall 001 line or by treating
the entire flow discharged from 001. The iron must be oxidized to the
ferric form and removed with the solids prior to discharge. The existing
baffled, concrete basin through which the 001 waste stream flows does not
provide adequate sedimentation. Therefore, iron oxidation is necessary and
either a clarifier must be installed or the effluent must be rerouted to
the 002 lagoon system for sedimentation. Better pH control is also re-
quired to meet limitations and to promote the oxidation of the iron.
Outfall 002 contains all the process wastewaters from the chloride
area plus additional flows from the sulfate finishing area. The acidic
chloride process wastewaters are partially neutralized in a pit containing
aragonite, then flow through two lagoons (upper and lower lagoons) prior to
discharge. Between the lagoons, caustic is added for pH control. The
lower lagoon has recently been partially dredged and is being used for
clarification. However, the data submitted by the Company after dredging
of the lagoons indicate that sedimentation alone will not bring the ef-
fluent into compliance. The iron concentrations are excessive (210 mg/1
average). Because the pH frequently is less than 6.0, oxidation of iron
was significantly impaired. The pH must be kept above 6.5. If iron
oxidation is not adequate through pH adjustment, chemical removal or
aeration will be required to reduce the concentration.
The solids load can be reduced by recovering coke and ore from the
chloride process waste streams. The Company has indicated that this can be
done, but wants to determine if the lagoon system can reduce the load
significantly to achieve compliance.
According to an EIMCO study for the Company, solids settle well if a
polymer is added to the wastewater. Since the lower lagoon provides
sufficient surface area for sedimentation, the effluent from 002 should
meet limitations if treatment systems are operated properly.
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10
The Company has developed a treatment system for the process waste-
waters from the sulfate operations. However, the other wastewaters have
not received the same effort in developing adequate treatment. The Company
cannot consider the other waste streams as inconsequential and only provide
minimal treatment. Outfalls 001 and 002 waste streams contain high con-
centrations of iron and solids, are low in pH, and cannot be discharged
without treatment if compliance is to be achieved.
RECOMMENDATIONS
The second round NPDES permit should be based on the EPA's Effluent
Guidelines for the titanium dioxide industry. These limitations were
proposed in the Federal Register in June 1980. The SCM Glidden-Durkee
Adrian-Joyce Works can achieve compliance with these limitations if the
wastewaters from Outfall 001 and 002 are neutralized and clarified.
Based on these limitations, the allowable net loads for the total of
Outfalls 001 and 002, and the effluent from PWAN/SWAN should be the
following:
Total Suspended Solids
Total Iron
PH
30-Day Average
Ib/day
9,510
380
6.0 - 9.0
Daily Maximum
Ib/day
34,800
1,300
The average limitations correspond to TSS and iron concentrations of
57 mg/1 and 2.3 mg/1, respectively, on a net basis with the current
wastewater flows. Based on data supplied by the Company, the gross con-
centrations of TSS and iron in the effluent would average 97 mg/1 and 10.3
mg/1, respectively.
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11
III. PROCESS DESCRIPTION, WASTEWATER SOURCES, AND TREATMENT
CHRONOLOGY OF COMPANY'S Ti09 PRODUCTION
In 1933 the American Zirconium Corporation was formed through a joint
venture between Glidden Company and Metal & Thermit to produce titanium
dioxide pigment. Glidden assumed responsibility for the operations, man-
agement, and sales of the joint effort. Metal & Thermit provided a portion
of the investment and participated in policy formulation. In the early
1940s, Glidden purchased Metal & Thermit's interest in the joint venture
and began operating it as the St. Helena pigment plant of the Glidden
Company.
The initial rated capacity of the St. Helena plant was 6,000 tons of
Ti02 annually. Incremental expansion resulted in a capacity of 18,000 tons
by 1950. By 1956, a completely new production facility was brought on-
stream because of the need for additional capacity and due to technological
improvements made in the industry. The new facility (the Adrian-Joyce
Works) [Figure 1], which occupies 135 acres, was the last sulfate process
Ti02 plant built in the United States and had a rated annual capacity of
15,000 tons. Soon after startup of the new facility, the St. Helena facil-
ities were phased out and capacity at the Adrian-Joyce Works was expanded.
Production of Ti02 at St. Helena ceased after 1958; by that time the annual
capacity at the Adrian-Joyce Works had reached 35,000 tons. In 1962,
another expansion raised the rated capacity to 48,000 tons/yr.
The chloride process for producing Ti02 was gaining acceptance by the
industry because of the pollution control problems associated with the
sulfate process. In the late 1960s, Glidden purchased the chloride process
technology from the Kerr-McGee Corporation and started construction of a
second plant at the Adrian-Joyce Works. The new chloride facility went on-
stream in 1969.
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12
In October 1974, the Sherwin-Williams Ti02 plant in Ashtabul'a, Ohio
was purchased by Glidden. It was built in 1969 using DuPont's chloride
process technology, and produces only rutile Ti02 pigment. This was the
only license granted by DuPont for the use of their chloride process.
The DuPont oxidation process was incorporated into the chloride
process at the Adrian-Joyce Works in the mid 1970s and the Kerr-McGee
oxidation process was phased out. However, the Kerr-McGee chlorination
process is still used.
SCM Glidden-Durkee's planned addition of 10,000 tons/yr of chloride
process titanium dioxide in Baltimore will enhance its second place
standing among U.S. producers. The additional capacity, to be completed
around July 1981, will raise the Company's chloride process capacity to
84,000 tons/yr, and increase its total capacity to 135,000 tons/yr. The
sulfate and chloride Ti02 capacities at Baltimore are currently 51,000 and
32,000 tons/yr, respectively. The Ashtabula plant has a chloride Ti02
capacity of 42,000 tons/yr.*
Because SMC Glidden-Durkee officials requested that detailed process
descriptions and wastewater treatment methods be considered CONFIDENTIAL,
the processes are described in general to define where waste streams
originate. The treatment of the sulfate process wastewater streams is also
discussed in general terms. The Company officials answered all questions
concerning waste sources, treatment processes, and provided data to NEIC
personnel.
Titanium Dioxide Production
Titanium dioxide occurs naturally in three crystalline forms; anatase,
brookite, and rutile. These crystals are substantially pure titanium
dioxide but usually contain impurities, such as iron, which give them a
* Chemical Week, May 21. 1980, page 25.
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13
dark color. Brookite is rare and the crystalline structure is orthorhombic
(three unequal axes at right angles to each other). Anatase and rutile are
tetragonal (three axes at right angles and the two lateral axes equal), but
are not isomorphous (identical or like form). Rutile forms slender,
prismatic crystals, and anatase usually occurs in near-regular octahedra.
Titanium dioxide pigments are manufactured by the sulfate and chloride
processes. In the sulfate process, the essential step is hydrolysis, under
carefully controlled conditions, of an acid solution of titanyl sulfate,
followed by calcination and milling of the hydrous precipitate. In the
chloride process, the essential step is the burning of titanium tetra-
chloride in oxygen to yield titanium dioxide and chlorine.
The raw material for the sulfate process is ilmenite ore or ferrous
titanate (FeO-Ti02) or Quebec Iron and Titanium Corporation (QIT) slag.
The ilmenite ore contains around 60% Ti02 and the QIT slag contains about
72% Ti02. The raw material for manufacturing titanium tetrachloride is
mineral rutile which is essentially pure titanium dioxide. The relative
abundance of ilmenite compared with rutile makes beneficiation of the
former attractive. Beneficiation is the removal of part of all of the iron
from the ilmenite, leaving a product soluble in sulfuric acid, or which can
be chlorinated economically.
PROCESS DESCRIPTION AND WASTEWATER SOURCES
Sulfate Process [Figure 2]
Raw material is stored outside behind a wooden wind screen. Runoff
from the storage area and adjacent plant grounds is collected in drainage
channels and discharged through Outfall 001. The ore or slag is dried in
driers fueled by No. 2 fuel oil and then ground in ball mills. The gas
stream from the driers passes through baghouses (one baghouse for each
drier); recovered material is returned to the driers. Coarse material from
the ball mills is returned to the feed end of the mills and the fines are
digested in the batch attack vessels (digesters) with sulfuric acid. The
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SULFURlC AClD-i
TITAMUM BCAMM6 ONE
DNESTION
9ETTUNO
EXCESS TO
STOCKPILE
CLARIFICATIOM
IRON REMOVAL
SALE
MET
COPPERAS
PRECIPITATION
AND SOLIDS
SEPARATION
WASHING
CALCINATION * y >
TiOg OUST
WET TREATMENT
FILTRATION
AND
WASHING
_w
DRYING
AND
GRINDING
TIOj PIGMENT PACKING
CHLOWDE ,.
PROCESS—y
VIWSTE
STREAM
Figure 2.
Typical Sulfate Process Flow Diagram
For TiO2 Industry
176
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15
mixture of ground ore and sulfuric acid is agitated by an air stream, with
live steam blown in. When the temperature reaches about 160°C (320°F), a
violent exothermic reaction occurs and the mixture is converted to a porous
cake containing ferric, ferrous, and titanium sulfates. The digesters are
vented through a manifold system to one of two scrubbers, operated in
parallel. Each scrubber uses river water on a once-through basis. The
scrubbers are manually turned on for the critical exothermic reaction
period which lasts about 30 minutes. About 6,000 gal/min of river water is
pumped into the scrubber during the critical reaction; this flow rate
currently causes a hydraulic problem as the pumping capacity cannot main-
tain the high pumping rate. The scrubber water is discharged from Outfall
001 for a period of 15 to 30 minutes. The Company plans to install a
28,000 gal holding tank to recyle the scrubber water.
The porous cake is extracted with water or dilute sulfuric acid and
the ferric iron in solution is reduced to ferrous by means of scrap iron.
Reduction is carried to the point where some trivalent titanium is present
in order that all the iron is kept in the ferrous state during subsequent
handling of the liquor.
Sedimentation then follows in covered clarifiers to remove insoluble
residues remaining after digestion. In the clarification process, hydrogen
sulfide (H2S) is liberated and collected in a manifold system vented to a
low-rate continuous scrubber. Sodium hydroxide (NaOH) is used for scrub-
bing and is recycled through the scrubber; the bleed-off is discharged to
Outfall 001. The "bottom mud" or underflow from the clarifiers is washed
and dewatered on precoated rotary filters. The filter solids (gangue
solids) are landfilled on Company-owned land, about 3 miles from the plant
site. The filtrate is sent to the feed tank for the vacuum crystallizers
along with the "black solution" or clarifier overflow. Spills from the
clarification process flow to the batch attack lagoon.
- Much of the iron present in the black solution is removed by crys-
tallization as copperas (FeS02'7H20) in the vacuum crystallizers; the
solution is chilled to approximately 10°C. A steam jet booster evacuator
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16
pulls a vacuum on the crystallizer. The condensate is discharged to
Outfall 001. After crystallization, the black solution is washed and
filtered; the filter cake is copperas which is stored on a pad onsite until
shipped. Drainage from the pad is collected in a sump and pumped to the
batch attack lagoon.
Water is removed from the black solution (copperas filtrate) in three
Struthers-Wells Concentrators which use steam jet evacuators; the con-
densate is discharged to Outfall 001. After concentration, the black
solution is filtered in pressure filters; the filter residue is combined
with the gangue solids and sent to the landfill.
The next stage, precipitation of the titanium as hydrous titanium
dioxide by hydrolysis, is the most critical one in the entire process.
Ferric iron cannot be present in solution. The precipitation is accom-
plished under controlled conditions so that the precipitate can be readily
filtered and washed and, upon subsequent calcination, give crystals of the
correct type and dimensions. Steam is circulated through coils in the
lined hydrolysis tanks; fresh water is added to replace water lost in
boiling to maintain a uniform solution level. All Ti02 precipitated is in
the anatase form.
The precipitate is then filtered and washed in the first Moore Filter
sequence. There are two first Moore Filter lines, operated in parallel.
The precipitate is picked up on the precoated filter leaves in the pickup
tank. The vacuum on the filters pulls the acid solution through the filter
leaves and the precoat and pigment are retained. The first 45 minutes of
filtration produces a strong acid (or mother liquor) which is either re-
cycled to the digesters or discharged as wastewater to the batch attack
lagoon. The filter frame is transferred by overhead crane to the Moore
wash tank; city water is used to wash impurities out of the pigment. The
wash water or weak acid is discharged to the batch attack lagoon. After
washing, the filter frame is transferred to the stripper tank; the pigment
is stripped from the filter and dropped into a repulp tank. Sulfuric acid
and aluminum powder are added to bleach the precipitated pulp under reducing
conditions to remove iron. The repulped precipitate is then filtered
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17
in the second Moore Filter sequence. There are two parallel second Moore
Filter lines. Filtrate from the second Moore pickup tanks and wash tanks
is recycled to the first Moore wash step; filtrate which is not recycled is
discharged to the batch attack lagoon. After washing, the pigment is
stripped from the second Moore filter frame and placed in tanks for pre-
calcination treatment.
The pretreated pigment is filtered on rotary vacuum filters, repulped,
and screw conveyed to the three calciners. The filtrate from the vacuum
filters is sent to filter receivers, then to Dorr tanks. The underflow
from the Dorr tanks is sprayed on the rotary vacuum filters. The Dorr tank
overflows are discharged to the upper lagoon.
Calcination occurs in gas-fired inclined rotary kilns. As it travels
through the kiln, the wet pulp is first dried, then water and S03 are
driven off (7 to 8% S03 is strongly adsorbed by the precipitated pulp and
cannot be removed by washing). Conversion to rutile and crystalline growth
to pigmentary size only occur in the last few feet of the kiln. The con-
version to rutile is governed primarily by the amount of rutile seed or
nuclei added to the nucleation stage. After calcination, the pigment is
cooled in drum-type barrel coolers on the exit side of the kilns. The
cooled pigment is then conveyed to storage bins.
Each calciner has its own air emission scrubber system. The calciner
exhaust gas passes through a cyclone and scrubber. Recovered particulate
is sent to the filter Dorr tank. The Dorr tank underflow is returned to
the rotary vacuum filters which feed the calciner repulp screw. Cyclone
exhaust gas is scrubbed in a slot scrubber and then a venturi scrubber.
The slot scrubber water is recycled from the scrubber Dorr tank. Overflow
from the filter Dorr tank is sent to the scrubber Dorr tank. The scrubber
water for the venturi scrubber is recycled from the "recover tank." Fresh
water is added to the recover tank as makeup; bleed-off from the venturi
scrubber is sent to the scrubber Dorr tank. Overflow from the scrubber
Dorr tank is discharged to the batch attack lagoon. The underflow from the
scrubber Dorr tank is returned to the hydrolysis tank.
-------
18
The scrubber on the sulfate process calciner is manually removed from
service every Thursday for inspection. The gas stream from the slot
scrubber is routed through an electrostatic precipitator (ESP) and separate
stack.
The anatase pigment is then prepared for shipment by either milling in
a roller mill, or steam-jet mills (micronizers). The rutile pigment is wet
milled, surface treated, filtered, dried and packaged for shipment. Wash
waters from the surface treatment and filtering operations are collected in
Dorr tanks (grade specific). Underflow from the Dorr tanks is returned to
the finishing process and the overflow is discharged to the upper lagoon.
Steam condensate from the jet mills is sent to the Dorr tanks.
The wastewater, air emission, and solid waste sources from the sulfate
process are summarized in Table 4.
Chloride Process [Figure 3]
Pigments manufactured by the chloride process were first introduced
commercially in the U.S. by DuPont in 1958. The process produces pigment
by the oxidation of titanium tetrachloride (TiCl4) which is obtained from
the mineral rutile by chlorination in the presence of carbon. There are
two methods by which Ti02 can be produced from TiCl4 in the vapor phase:
by hydrolysis, and by oxidation. Hydrolysis was initially used at the
Adrian-Joyce Works, but was replaced by the DuPont oxidation process
because the chlorine produced as a co-product can be recycled, thereby
reducing waste products and because less process equipment is required.
The chloride process uses rutile or upgraded ilmenite ores and coke as
raw material. The ore and coke are dried and then reacted with chlorine to
form TiCl4 at a temperature between 800° and 1000°C (1472° and 1832°F) in a
fluidized bed reactor. The chlorinator is cooled by cascading water over
the exterior; this cooling water is recycled. The cooling water is bled
off to the upper lagoon after it has been neutralized.
-------
19
TABLE 4
SUMMARY OF WASTE SOURCES
Sulfate Process
SCM GLIDDEN-DURKEE
ADRIAN-JOYCE WORKS
Waste Source and Type
Treatment
Disposal
Runoff from raw ore storage
area
Gas stream from ore driers
Dust from ball mill grinding
of ore
Fumes from batch attack
digesters
Scrubber water for digester
scrubber
H2S gas liberated in
settling tanks
H2S scrubber water
Batch attack mud or gangue
solids
Spills from digester set-
tling tanks
Condensate from vacuum
crystal!izers steam
evactors
Sedimentation/Neutrali- Patapsco river (001)
zation in concrete
basin
Collected in baghouse,
fines returned to
drier
Collected in cyclone
and baghouse; coarse
returned to ball mill
Collected in scrubber
during critical
reaction
Once through river
water discharged to
001 sewer; ineffective
neutralization with
caustic in concrete
basin
Collected in scrubber
Baghouse vented
to atmosphere
Cyclone and bag-
house vented to
process
Scrubber vented
to atmosphere
Patapsco river (001)
Scrubber vented
to atmosphere
Recycled through scrub- Patapsco river (001)
ber; bleed-off neu-
tralized with caustic
in concrete basin
Dewatered on rotary
filter; filtrate
returned to process
Landfilled at
Designated Haz-
ardous Substance
(DHS) Site
Sent to batch attack Patapsco river (002)
lagoon and neutralized
at PWAN/SWAN
Sedimentation/Neutrali- Patapsco river (001)
zation in concrete
basin
-------
20
Table 4 (Cont'd)
SUMMARY OF WASTE SOURCES
Sulfate Process
SCM GLIDDEN-DURKEE
ADRIAN-JOYCE WORKS
Waste Source and Type
Treatment
Disposal
Drainage from copperas
process
Residue solids from con-
centrator filters
First Moore Filter strong
acid
First Moore Filter weak
acid
Second Moore Filter acids
Rotary Filter (preceding
calciner) filtrate
Gases from calciners
Venturi scrubber water
Finishing process rotary
filter filtrate
Sent to batch attack Patapsco river (002)
lagoon and neutra-
lized at PWAN/SWAN
Collected on cartridges Landfilled at DHS
Patapsco river (002)
Recycled to process or
sent to batch attack
lagoon and neutralized
at PWAN/SWAN
Sent to batch attack Patapsco river (002)
lagoon and neutralized
at PWAN/SWAN
Recycled to First Moore
or sent to batch
attack lagoon and
neutralized at PWAN/
SWAN
Collected in Dorr tank;
tank overflow dis-
charged to upper
lagoon
Collected in venturi
scrubber system
Recycled through
scrubber; bleed-off
sent to batch attack
lagoon and neutralized
at PWAN/SWAN
Collected in Dorr
tanks; tank over-
flows discharged
to upper lagoon
Patapsco river (002)
Patapsco river (002)
Scrubber vented
to atmosphere
Patapsco river (002)
Patapsco river (002)
-------
CO + CO,
» PURIFICATION
MCl,
OXTCEN
( TiO, + MO ) + C + Cl,
Oil COKf CHlOIINf
[ TiCI4 * O, * TiO, + 2CI,J
TiCI4 + MCIB * CO * CO,
TICKlE ME1AL C»««OH MONOXIDE
CH1OIIDES k DIO'lDe
FINISHING
Figure 3.
TiO, Chloride Process
ro
-------
22
The product gases leaving the chlorinator consist of TiCl4, unreacted
chlorine, carbon dioxide, carbon monoxide, and minor amounts of heavy metal
chlorides. The gases are cooled initially to 250°C (482°F) with liquified
titanium tetrachloride to remove impurities. The impurities are collected
in the two waste solid pits along with the chlorinator cooling water
bleed-off. Prior to discharge to the upper lagoon, the effluents from the
pits flow through a neutralization pit; aragonite (a mineral composed of
calcium carbonate) is used to neutralize the waste stream.
After cooling and impurity removal, the gas is condensed. Cooling
water is recycled to a cooling tower; blow-down from the cooling tower is
discharged to the upper lagoon.
In the chlorination-condensation sequence, the only air emission is
controlled by a venturi water scrubber. The water is continually recycled;
the bleed-off is done at a controlled rate to maintain an acid concen-
tration of 20%. The bleed-off is discharged to the acid storage system,
then to the aragonite neutralization pit.
The liquified TiCl4 contains impurities such as aluminum chloride,
silicon tetrachloride, etc., which are removed by distillation. Non-
contact steam condensate from distillation is discharged to the upper
lagoon. The distillate, or purified TiCl4, is oxidized by a process
patented by DuPont. The Ti02 passes through two layers of serpentine pipe
inside a concrete basin. The cooling water in the basin is recycled
through an indirect heat exchanger. The overflow from the cooling basin is
discharged to the upper lagoon. After cooling, the Ti02 solids and
chlorine gas stream are separated in a baghouse. The chlorine is recycled
to the chlorination process and the Ti02 is sent to the finishing oper-
ation.
In the finishing operation, the Ti02 is ground, filtered, dried and
milled. Filtrates and wash waters are collected in grade-specific Dorr
tanks (primary and secondary). The Dorr tanks underflows and the secondary
Dorr tank overflows are recycled. The overflows from the primary Dorr
-------
23
tanks are discharged to the upper lagoon. All floor washings, spills,
etc., in the finishing process are collected in a sump. A Hydrosieve is
used to separate trash from the wastewater; the screenings are landfilled
and the wastewater is sent to the primary Dorr tank.
After milling, the Ti02 is sent to a baghouse. The product from the
baghouse is sent to packaging and stored for shipment. The baghouse gas
passes through a steam-barometric condenser. Condensate from the hot well
is discharged to either the secondary Dorr tanks or directly to the
filters.
The wastewater, air emissions, and solid waste sources for the
chloride process are summarized in Table 5.
WASTEWATER TREATMENT [Figure 4]
PWAN/SWAN
The Primary Waste Acid Neutralization (PWAN) and Secondary Waste Acid
Neutralization (SWAN) systems are proprietary wastewater treatment oper-
ations developed by the Company to comply with the effluent limitations for
the sulfate process wastewaters.
Strong and weak acidic wastewaters from the sulfate process are
discharged to the batch attack lagoon. The waste acid is pumped from the
lagoon and mixed with aragonite to neutralize the free acid. In the
neutralization process, primary synthetic gypsum (CaS04-2H20) is produced
as a wet slurry. The slurry is dewatered on a vacuum filter and stockpiled
onsite or on adjacent Company-owned property used for hazardous waste
disposal. The Company has developed a market for the primary gypsum and
currently sells some of the material.
The PWAN effluent is neutralized with more aragonite to convert
ferrous iron to ferric hydroxide and remaining acid to secondary gypsum.
The secondary gypsum is also dewatered on a vacuum filter and stockpiled at
the hazardous waste site.
-------
24
TABLE 5
SUMMARY OF WASTE SOURCES
CHLORIDE PROCESS
SCM GLIDDEN-DURKEE
ADRIAN-JOYCE WORKS
Waste Source and Type
Treatment
Disposal
Non-contact cooling water
(NCCW) from chlorinator
Waste solids from chlori-
nation process
NCCW from condensation
sequence
Gas stream after condensa-
sation of TiCl4
Venturi scrubber water
Condensate from distillation
sequence
NCCW from oxidizer cooling
pond
Filtrate from rotary filters
in finishing sequence
Waste acid and base from
regeneration of ion ex-
change resins
Neutralized and sent
to upper lagoon
Collected and slurried
through aragonite
neutralization pit
to upper lagoon
Recycled to cooling
tower; bleed-off
sent to upper lagoon
Collected in venturi
scrubber system
Sent through aragonite
neutralization pit
to upper lagoon
Sent to upper lagoon
Patapsco river (002)
Patapsco river (002)
Patapsco river (002)
Scrubber vented to
atmosphere
Patapsco river (002)
Patapsco river (002)
Sent to upper lagoon Patapsco river (002)
Collected in Dorr Patapsco river (002)
tanks; overflow
discharged to
upper lagoon
Sent to upper lagoon Patapsco river (002)
-------
BAROMETRIC
CONDENSER
WATER
CAUSTIC
ADDITION
DICE
SCRU
HATE
STORMrfATER
t
COOLING
WATER WAS
STER SY
BBER LE
R
I1
1 1 n
1 FLUMES
CONCRETE
TC .r,n NEUTRALIZATION
It HL 1 U „ . P . ..
STEM BAbIN
AKS
001
SULFATE
PROCESS
WASTES
BREAK IN
SEWER LIME
CHLORIDE
PROCESS
NON-ACIDTT
WASTEWATERS
UPPER
LAGOON
FLUME
LOWER
LAGOON
OVERFLOW FROM
VAC. CRYST. SEWER
3 COMPARTMENT
JUNCTION BOX
ARAGONITE
NEUTRALIZATION
PIT
CHLORIDE PROCESS
ACIDIC WASTEWATERS
Figure 4
WdStewater Treatment Schematic
SCM Glidden-Durkee
Adrian Joyce Works
Baltimore, Maryland
INJ
cn
-------
26
The SWAN effluent and the gypsum filtrates from PWAN/SWAN are sent to
a 60 ft diameter x 16 ft SWD flat bottom clarifier. Bottom rakes are
positioned at a 30° angle to provide a false cone effect for the clarifier.
The rake mechanism continually removes solids from the clarifier to a drum
filter. The dried filter cake, or gel mud, is landfilled at the hazardous
waste disposal site.
The clarifier rake mechanism has been a problem. The rake shaft has
been fitted with a torque indicator which raises the rake off the bottom
whenever the torque reaches a specified level. A broken bearing in the
shaft resulted in operational problems which increased the effluent solids
level.
The effluent from the clarifier is pumped to the Patapsco River. The
flow normally combines with other effluents downstream of a three-com-
partment junction box. The junction box receives the effluent from the
lower lagoon, overflow from the batch attack lagoon, and an excess overflow
from the vacuum crystallizer building (sulfate process). The junction box
splits the flow into three pipes which are designated Outfall 002. How-
ever, the effluent pipe from the clarifier has been broken along the river
bank and the effluent flows into the river at this location. The Company
would like to have this discharge designated Outfall 003.
Lagoon System
There are four lagoons used for wastewater treatment [Figure 1]. The
surface areas of each lagoon, estimated from Company drawings, are as
follows:
batch attack lagoon
upper lagoon
middle lagoon
lower lagoon
Surface Area
14 acres
13.5 acres
7.1 acres
24.7 acres
Depth
26 ft
26 ft
26 ft
26 ft
-------
27
The batch attack lagoon receives sulfate process wastewaters prior to
neutralization in PWAN/SWAN. During periods of high rainfall, etc., the
batch attack lagoon will overflow to the junction box at Outfall 002. The
three remaining lagoons are filled with solids from the processing oper-
ations. The Company currently discharges process wastewaters from the
chloride process to the upper lagoon which connects to the lower lagoon.
The flow is measured in a 36-in Parshall Flume located between the upper
and lower lagoons. The middle lagoon is by-passed and receives no waste
material. Because of the deposited solids, the wastewater in the upper and
lower lagoons is channeled directly to the junction box at Outfall 002.
Company personnel estimated that more solids are leaving the lower lagoon
than are currently being deposited.
The acidic effluent from the chloride process enters the upper lagoon
after it is neutralized; a small pit estimated to be 8 ft x 8 ft deep is
used for neutralization. Coarse aragonite is periodically placed in the
pit and the acidic wastewaters flow through the pit into the upper lagoon.
Non-acid wastewaters (finishing processes, demineralizer regeneration
backwash, and cooling water) enter the lagoon at other locations.
The Company has hired contractors to dredge the lower lagoon to pro-
vide settling for the chloride process solids. Until recently, the con-
tractors have not been able to dredge the lagoons because the equipment
would remove too much water and insufficient quantities of solids. How-
ever, the current contractor is using a dredge with a pump that can handle
solids concentrations of 200 gram/1 and has been able to successfully
dredge the solids.
The dredged solids will be stockpiled in the middle lagoon and allowed
to dewater before being landfilled offsite. If the dredging operation is
successful, the Company intends to divide the lower lagoon into two cells;
once the first cell is full, flow will be diverted to the second cell, and
the solids will be dredged from the first cell.
-------
28
The chloride process wastewaters contain coke, ore, metal chlorides,
and Ti02 solids from finishing. The Company personnel estimated that the
load to the lagoons ranges between 15 and 30 tons/day which must be removed
to comply with the effluent limitations. Company in-house laboratory tests
indicate that the coke and ore solids could be recovered and recycled,
reducing the solids load to the Outfall 002 lagoons by 40 to 50%.
Non-Process and Other Wastewaters
Wastewaters not treated in PWAN/SWAN or collected in the upper and
lower lagoons are discharged from Outfall 001. These include: (1) storm
water runoff from the plant processing site (except for the chloride pro-
cessing area, the runoff flows to the upper and lower lagoons); the raw
material storage areas, and PWAN and SWAN treatment area; (2) river water
used for cooling and barometric condensers; (3) scrubber water from the
digester scrubbers; and (4) leaks in the sewers serving the waste acid
system in the finishing area, even though a major portion of the sewer has
been replaced.
With the exception of some storm water runoff, these wastewaters are
collected in a concrete basin about 100 ft long x 20 ft wide x 10 ft deep.
The basin is partially subdivided by six concrete baffles which direct the
flow around the baffles in a serpentine route. The pH of the wastewater is
measured immediately upstream of the concrete basin, however, this mea-
surement is only used as an indicator by the operators whenever they are in
the area. The wastewater is neutralized in the basin with sodium hydroxide
which is controlled by pH probes in the first, third, and fourth chambers
created by the baffles. The caustic can be added to either the first or
third chambers.
The system is supposed to control the basin effluent pH at 7, however,
due to the 6,000 gal/min flow from the digester scrubbers over a 30-minute
period four or five times/day, the pH drops to levels below 6.0 (permit
limit). Sufficient sodium hydroxide cannot be added to neutralize the
highly-acid scrubber water. The effluent from the basin flows through two
-------
29
parallel pipes into two Palmer-Bowles flumes, and then to the concrete
headwall into the Pataspco River (Outfall 001). Flow is measured in one
flume and then doubled for the total flow.
Effluent Quality
The characteristics of the effluents discharged from Outfalls 001 and
002, and the PWAN/SWAN treatment system are summarized from Discharge
Monitoring Reports in Table 6. The river water intake averages 15 mgd with
a total suspended solids concentration of 200 mg/1. The Company personnel
do not know how much river water flows into the 001 or 002 drainage
systems. Through in-plant process flow estimates, they estimated that
between 25,000 and 50,000 gal/day of river water is discharged from Outfall
002; the rest is discharged from Outfall 001. The amount of water pumped
from the river is measured. The amount of water purchased is also mea-
sured. Company personnel have estimated that 0.5 mgd is discharged from
001, the rest through 002. Storm water runoff is computed for the area
drained, the number of days/month that rain occurred, and a factor for the
amount that would run off. The flow from the clarifier is measured. These
data are put into a computer and the flows and net loads are calculated.
The basic flow formulae for each outfall are as follows:
Outfall 001 Flow (mgd) =0.5 mgd + (River Water Intake Flow -
0.05 mgd) + Runoff
Outfall 002 Flow (mgd) = River Water Intake Flow of 0.05 mgd +
Runoff + SWAN effluent flow + (Purchased Water - 0.5 mgd).
Samples for permit parameters are collected once/week over a 24-hour
period and composited on an equal-volume basis.
-------
30
TABLE 6
EFFLUENT QUALITY3
SCM GLIDDEN-DURKEE
ADRIAN JOYCE WORKS
Characteristic
Flow nrVday
mgd
pH
TSS ing/1
kg/day
Ib/day
Iron mg/1
kg/day
Ib/day
Outfall 001
39,500
10.45
0.0 to 14
65
2,600
5,700
65
1,100
2,400
Outfall 002
15,100
4
0.0 to 10
960
14,500
32,000
790
12,000
26,400
PWAN/SWAN
Clarifier
5,450
1.44
7.2 to 7.5
20b
108
240
6b
32
72
a 1978-1979 Discharge Monitoring Reports.
b Best results obtained.
-------
31
IV. HAZARDOUS WASTE DISPOSAL
Land space for solid and hazardous waste disposal is not available at
the main plant site. The Company owns a 51-acre site on Quarantine Road,
about 2 miles from the main plant. The Quarantine Road site, or the Desig-
nated Hazardous Substance (DHS) area, is part of a larger tract of land
used for landfilling municipal refuse by Browning-Ferris, Inc., (BFI). The
entire site was owned by DuPont and was used for waste disposal from their
Curtis Bay sulfate plant. BFI purchased the tract from DuPont, except for
the 51 acres purchased by SCM. SCM negotiated a contract with BFI to
operate the DHS area for them. However, SCM could not obtain a permit from
the State for disposal of the process solids, therefore, BFI could not
accept the SCM wastes. Access to the BFI site is across the DHS area, SCM
has denied access to BFI, therefore, the BFI landfill is inactive.
SCM currently hauls the digester gangue solids, the SWAN gel mud, and
excess copperas to the DHS area for burial. The SWAN gypsum is being
stored above ground near the burial cells; excess PWAN gypsum is also
stored at the DHS site, but away from the burial cells.
SCM has retained the consulting firm of Harrington and Lacey to design
a landfill which will comply with State and Federal regulations for haz-
ardous waste disposal. The site is being developed currently. A leachate
collection, monitoring, and treatment facility is being designed by In-
dustrial Pollution Control; samples for design parameters are still being
collected in a temporary pit.
The State has issued a draft disposal permit for the DHS site. If the
digester gangue solids, gel mud, and copperas are the only materials re-
quired to be landfilled, SCM estimates that the expected life of the site
will be 8 years.
-------
32
The SWAN gypsum contains high concentrations of impurities including prior-
ity pollutant metals such as zinc and chrome. According to Company person-
nel, the State maintains that the SWAN gypsum must be considered hazardous
and must be landfilled in the DHS site. The Company's position is that if
the SWAN gypsum is landfilled, the effective life of the DAS site will be
less than one year. Disposal costs will increase rapidly if the solid
wastes have to be landfilled at an off site location after the DHS site is
closed. The alternatives for the Company are to develop a market for the
SWAN gypsum or to demonstrate that the gypsum does not fall under EPA's
criteria as a hazardous waste. Preliminary data from the Extraction Proce-
dures (EP)* indicate that the extract from the SWAN gypsum does not contain
levels of hazardous materials exceeding those listed. The EP test was
conducted by a consultant laboratory.
* Federal Register, "Hazardous Waste and Consolidated Permit Regulations";
Monday, May 19, 1980, Part III, Subpart C Section E, pages 33110 to
33112.
-------
33
V. TREATMENT NEEDS AND PERMIT LIMITATIONS
TREATMENT NEEDS
The NPDES permit limits the discharge of pollutants to the Patapsco
River from Outfalls 001 and 002. After the permit had been issued, the
sewer conveying the PWAN/SWAN treated wastewater failed and the wastewater
is discharged directly to the river instead of combining with the waste-
waters discharged from Outfall 002. SCM, therefore, has three separate
waste streams; 001, 002, and PWAN/SWAN.
Although the Company had been submitting monitoring data as required
by the permit, NEIC personnel requested that the Company monitor each
discharge and the salt water intake on a daily basis to determine daily
fluctuations.
Outfall 001
The waste stream discharged from Outfall 001 is composed of storm
water runoff, river water from the sulfate process vacuum crystallizers and
evaporators, intermittent discharges of once-through scrubbing water from
the sulfate process digester scrubbers, and waste acid and ammonia overflow
from the sewer carrying the wastewater to Outfall 002. Caustic is added to
the wastewater in the baffled, concrete basin for neutralization. Due to
velocities and basin design, adequate sedimentation is not achieved in the
basin.
The DMR data for 1978 and 1979 are summarized in Table 7, and the
daily monitoring data for March 7 to May 5, 1980, are summarized in Table 8.
During the NEIC inspection, the total suspended solids concentration
-------
34
TABLE 7
SUMMARY OF EFFLUENT DATA
Discharge Monitoring Reports
SCM GLIDDEN-DURKEE
ADRIAN-JOYCE WORKS
January 1978 to September 1979
Parameter
Flow, mgd
Total Iron, Ib/day
TSS, Ib/day
pH, S.U.
pH reported each month
Outfall 001
Average
10.45
2,420
5,170
<2.7
Range
4.89-18.45
470-16,250
300-21,590
0.04-14
Outfall 002a
Average
8.78
32,000
26,400 2
<1.4
Range
4.99-15.94
6,400-51,000
,800-173,000
1-10
a Includes PWAN/SWAN effluent.
b Flows for June 1978 to September 1979.
-------
TABLE 8
60-DAY CONTINUOUS MONITORING DATA - OUTFALL 001
SCM GLIDDEN-DURKEE - ADRIAN-JOYCE WORKS
March 7 - May 5, 1980
35
Date
3/7
8
g
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
4/1
2
3
4
5
6
7
8
g
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
5/1
2
3
4
5
AVG
JEH
S U
6.2
7.2
6 9
5 1
6.4
7.6
6.2
6 9
8.1
6 0
3.0
6.7
6 5
7 0
7.2
8.1
8 2
8.4
7.3
6 3
6.1
5 7
6.3
7.0
3 0
5 3
6 8
5 3
7.5
7 2
7 2
6 5
4.6
7.5
6 2
7 3
7 5
7 5
7.2
7 5
7.0
7.3
6 8
7.0
7.5
7 3
7.4
7 0
7 0
7 2
6.4
6 5
7.6
6 9
7.1
6.6
7 0
7.2
7 3
7 4
6 8
Gross
Cone
mg/1
27
12
27
53
9
12
62
12
10
18
336
50
10
13
38
46
5
22
20
36
25
8
35
40
34
23
60
26
45
29
25
59
79
32
95
4
4
5
5
6
3
4
12
12
14
6
7
9
12
3
25
64
28
26
32
35
17
12
18
17
30
Iron
Process3
Cone.
mg/1
20
7
19
17
7 '
1
57
5
6
8
308
49
0
0
29
22
0
20
15
34
23
6
33
32
27
15
54
19
40
21
15
35
65
29
90
0
0
<1
0
1
<1
0
1".
12C
12
4
0
0
12,.
3C
25<
64C
24
20
29
29
14
10
7
15
24
Net Loadb
Ib/day
2,335
825
2,226
2,068
817
141
6,621
600
708
950
35,795
5,687
0
0
3,386
2,618
0
2,326
1,751
3,953
2,668
700
3,911
3,736
3,152
1,759
6,280
2,218
4,663
2,460
1,349
3,051
5,689
2,565
7,951
0
0
13
0
101
8
0
887
1,058
1,063
358
0
0
887
264
2,205
5,645
2,127
1,779
2,565
2,573
1,242
887
646
1,328
2,510
Gross
Cone.
mg/1
16
12
78
96
10
78
206
20
34
54
100
34
0
56
264
204
100
116
76
106
106
36
16
116
48
80
166
70
152
70
104
166
276
154
292
8
2
12
10
38
34
46
20
74
66
86
76
88
78
16
166
334
182
64
130
192
64
70
122
158
94
TSS
Process3
Cone
mg/1
0
6
68
65
0
25
194
0
0
32
62
0
12
0
222
122
29
79
38
100
86
34
<1
102
0
27
104
34
138
44
75
129
144
129
263
6
0
0
0
22
11
19
16c
74C
45
37
0
0
31c
16c
166^
334C
141
31
113
126
54
66
110
55
64
Net Loadb
Ib/day
0
708
7,914
7,506
0
2,927
22,534
0
0
3,769
7,289
0
0
0
25,862
14,136
3,436
9,148
4,503
11,617
9,999
3,953
41
11,867
0
3,160
12,093
4,036
16,046
5,170
6,605
11,389
12,704
11,358
23,188
534
0
0
0
1,982
945
1,661
1,421
6,527
3,938
3,306
0
0
2,772
1,411
14,642
29,460
12,458
2,735
9,926
11,115
4,789
5,832
9,733
4,864
6,383
a Process concentration equals amount added to background levels to produce net load
b Flow = 13.594 mgd of river water + 0.314 mgd of added water = 13 908 mgd for March 7 to
April 15. Flow = 10 262 mgd of river water + 0.314 mgd of added water = 10 516 mgd for
April 6 to May 5
c No sample collected of river water
-------
36
in the wastewater discharged from Outfall 001 seemed, by appearance, to be
less than the concentrations reported in the 1978 to 1979 DMR's. Company
representatives were not aware that the effluent was, by itself, exceeding
the permit limitations for the total of all plant effluents. It was their
opinion that sampling and/or analytical procedures were in error. However,
the data for March 7 to May 5, 1980, verifies that both TSS and iron levels
discharged from Outfall 001 exceed the existing permits total allowable
load for the three outfalls. The pH control is not acceptable as the
composite pH was less than 6.0 on seven days.
The river water discharged from Outfall 001 is 98% of the total flow;
the river water iron and total suspended solids concentrations averaged 8
mg/1 and 40 mg/1, respectively. After correcting for the raw intake con-
centrations, the process effluent iron and TSS concentrations averaged 24
mg/1 and 64 mg/1, respectively.
The method used by the Company for computing flows and net loads is
questionable. On nine of the 60 days, the net iron load was zero and the
net TSS load was zero on 13 days. Based on the data submitted, it is not
reasonable that a zero value would occur on any day.
Due to the high concentrations of iron and total suspended solids
contributed by processes and runoff, the Company cannot achieve compliance
with effluent limitations without either removing and treating all con-
taminated waste streams from the 001 waste stream or by treating the entire
wastewater prior to discharge. The elimination of the once-through scrub-
ber water from the sulfate process digesters from the 001 waste stream
should reduce the pollutant load, however, the scrubber water bleed-off
will have to be treated before discharge. Additional sources of wastewater
will have to be isolated and removed from the 001 waste stream and treated
to comply with effluent limitations.
If the Company prefers to treat the entire wastewater flow, the iron
will have to be oxidized to the ferric form and removed with the solids by
sedimentation. After iron oxidation, the wastewater could be routed
-------
37
through the Outfall 002 lagoon system for sedimentation or a clarifier
could be installed and the effluent discharged through Outfall 001.
It is impossible to determine the amount of iron and TSS contributed
by runoff because the Company does not monitor individual waste sources.
The 60-day data do not indicate runoff was present, therefore, runoff could
increase the TSS load significantly.
Outfall 002
The wastewaters discharged from Outfall 002 includes process waste
streams from the chloride process, about 50,000 gpd of river water from the
sulfate process, process wastewater from the sulfate finishing area, the
waste acid and base from the regeneration of ion exchange resins, floor
drain wash waters and spills except those collected in the recovery
systems, leakage from the copperas vacuum crystallizers and evaporators,
and sanitary wastes from the chloride processing areas.
The acidic process wastewaters from the chloride process pass through
an 8 ft x 8 ft chamber containing unground aragonite. The aragonite sup-
plies about 85% of the alkaline demand. The wastewater from the chamber
then passes through the upper lagoon and through the Parshall flume to the
lower lagoon. Caustic is added to the wastewater as it leaves the flume to
adjust the pH to the 6 to 9 range. The valves which supply the caustic
have been sticking and the pH was not above 6.0 for 31 of the 60 days.
During the NEIC inspections, both lagoons were completely full of
settled material and the wastewaters were conveyed through the lagoons in
shallow channels without sedimentation. The Company reported that pre-
viously settled solids were scoured and carried over into the effluent.
The lower lagoon was recently dredged successfully and the Company
representatives believed that the solids would be removed prior to dis-
charge. The TSS load reported in the 1978 to 1979 DMRs [Table 7] averaged
32,000 Ib/day; this included the PWAN/SWAN effluent. After dredging, the
-------
38
TSS load discharged March 7 to May 5, 1980, [Table 9] averaged 4,241 Ib/day.
Over the same 60-day period, the solids from PWAN/SWAN averaged 538 Ib/day
[Table 10]. However, the total iron discharged from March 7 to May 5
averaged 11,425 Ib/day from the lagoons, and 97 Ib/day from PWAN/ SWAN.
The high iron levels discharged from the lagoons are partially due to poor
pH control. For the first 30 days, the pH never exceeded 5.5 and averaged
3.1. The iron load for March 7 to April 5 averaged 11,400 Ib/day. The
data for April 6 to May 5 showed that the average iron load decreased to
7,750 Ib/day, which includes very high iron loads for days when the pH was
less than 6.0 (April 27 to May 5). The iron load for the days the pH was
6.0 or greater averaged 2,150 Ib/day. At low pH levels, the iron will be
in the soluble ferrous form and will not be removed. For effective treat-
ment, the pH must be maintained above 6.5 to effectively convert the fer-
rous iron to ferric which will precipitate and be removed with the solids.
At pH levels less than 6.5, the rate of oxidation is very slow. The Com-
pany must ensure that effective pH adjustment is maintained to enhance
treatment and comply with effluent limitations.
A study of the settleability of the solids in the 002 waste stream was
conducted for the Company by the EIMCO Process Machinery Divison.* The
study showed that the solids settled well if a polymer is added, and that
the settled solids can be dewatered to 25 to 45% solids in either a vacuum
or pressure filter. The area required for sedimentation to produce an
effluent containing less than 15 mg/1 TSS would be 1,800 ft2, considerably
less than the 12.4 acres that will be available when the lower lagoon is
dredged and divided into two compartments.
The preliminary data (March 7 to May 5) indicate that effective sedi-
mentation occurred, but additional treatment such as polymer addition may
be required to reduce TSS levels. Iron removal should improve with pH
control. However, the Company should initiate treatability studies if the
TSS and iron concentrations are not reduced to permitted levels by sed-
imentation and precipitation in the lower lagoon. In addition, the Company
* "Water Clarification and Solids Dewatering for Glidden Plants, Inc.
SCM Corporation, Baltimore, Maryland", September 1979.
-------
TABLE 9
OUTFALL 002
60-DAY CONTINUOUS MONITORING DATA
SCM GLIDDEN-DURKEE - ADRIAN-JOYCE WORKS
MARCH 7 - May 5, 1980
39
Date
3/7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
4/1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
5/1
2
3
4
5
AVG
a Process
b Flow =
pH
S.U.
3.4
4.2
4.8
3 1
2.5
1 4
1 5
2.9
3.0
3 1
3.0
2.7
1.8
2.7
2.4
1.2
3 4
3 4
2 7
2 7
3 1
3.6
2 7
3.1
3.0
2 7
3.0
5.5
5.3
5.5
6 6
6 0
6.3
5 8
6.8
7.1
7.0
7.5
6.9
7.7
8 1
8 3
8.0
7.6
6 9
7 1
6.9
6 8
6 3
6 9
6 0
5.1
4 7
6 0
5.8
5 9
5.9
5 6
4.1
5 6
4.8
Gross
Cone
mg/1
300
277
303
351
555
890
995
225
179
151
138
135
108
122
219
1,140 1
110
154
163
164
112
73
170
173
352
352
308
162
215
80
32
35
102
186
74
23
15
8
22
6
1
20
11
23
27
29
53
26
113
14
132
237
265
191
252
268
198
300
827
445
210
concentration
0 25
Iron
Process3
Cone
mg/1
300
277
303
349
555
890
995
225
179
151
137
135
107
121
218
,140
110
154
163
164
112
73
169
173
352
352
308
162
215
80
28
27
96
185
72
21
13
6
28
4
0
18
10
23
26
28
48
20
112
14
132
237
264
189
251
251
197
299
823
444
209
u
Net Load
Ib/day
11,859
10,950
11,976
13,819
21,967
35,203
39,373
8,890
7,080
5,954
5,404
5,337
4,253
4,795
8,648
45,069
4,336
6,088
6,438
6,496
4,428
2,885
6,697
6,830
13,919
13,919
12,176
6,396
8,498
3,152
1,696
1,651
5,788
11,104
4,332
1,246
765
368
1,073
247
0
1,066
615
1,381
1,576
1,697
2,867
1,200
6,742
841
7,928
14,235
15,827
11,337
15,068
15,962
11,825
17,974
49,425
26,683
9,598
equals amount added to
mgd of river water +
4 496 ngd of
Gross
Cone.
mg/1
16
152
34
86
76
68
58
42
40
36
36
34
8
26
110
90
18
48
58
72
90
26
22
58
66
38
34
66
64
30
140
176
180
138
74
12
10
38
6
32
20
22
46
164
82
108
182
130
204
68
124
76
26
18
190
158
34
234
294
654
87
background levels to
added water = 4.746
TSS
Process3
Cone
mg/1
14
152
34
84
75
65
57
39
37
35
34
32
5
21
108
86
14
46
56
72
89
26
21
57
63
35
33
64
64
29
129
162
129
128
63
11
0
29
0
26
11
11
44
164
74
89
119
76
186
68
124
76
10
5
183
132
30
233
289
614
79
produce
mgd for
h
Net Load
Ib/day
567
6,004
1,326
3,336
2,977
2,577
2,268
1,559
1,476
1,376
1,342
1,267
200
834
4,270
3,386
558
1,818
2,218
2,835
3,519
1,025
834
2,268
2,493
1,392
1,317
2,535
2,522
1,134
7,732
9,714
7,742
7,702
3,767
675
0
1,741
0
1,561
660
689
2,672
9,850
4,429
5,358
7,140
4,559
11,170
4,084
7,448
4,565
614
314
11,006
7,956
1,816
13,965
17,388
36,890
4,241
net load.
March 7 to
oni __.j £•.._
April 5 Flow = 2.706 mgd of river water + 4.496 mgd of water added = 7.202 mgd for
April 6 to May 5
-------
40
TABLE 10
SUMMARY OF EFFLUENT DATA
PWAN/SWAN Neutralization Plant
SCM GLIDDEN-DURKEE
ADRIAN-JOYCE WORKS
March to June 1979
Date
March 1979
April
May
June
Average
Flow
mgd
1.46
1.35
1.34
1.39
1.39
Total
mg/1
144
54
46
36
72
Iron
Ib/day
1,762
612
518
423
829
mg/1
247
219
52
59
146
TSS
Ib/day
3,017
2,476
577
687
1,689
-------
41
should implement in-plant recovery of the coke and ore solids which are
currently discharged in the effluent. Company data indicate that these
solids comprise 40 to 55% of the solids discharged and that they are
recoverable. Recovery will extend the period between dredging of the lower
lagoon cells, reduce the volume of dredged solids to be dewatered and
landfilled, and reduce the load on a new clarification system if the lagoon
does not reduce the solids load.
PWAN/SWAN Neutralization Plant Effluent
The PWAN/SWAN plant, which treats the combined strong and weak acid
wastewaters from the sulfate process, is a two-stage neutralization and
sedimentation process. The effluent data for March to June 1979 and
March 7 to May 5, 1980, are summarized in Tables 10 and 11, respectively.
The 1979 data indicate that, although iron was being removed by
treatment, the concentrations were still high. The 60-day monitoring data
in 1980 show that the iron can be removed to very low levels. The total
suspended solids in 1980 were also reduced significantly from 1979.
However, further reduction of solids can be achieved by using the existing
25-ft diameter sand filter for polishing the clarifier effluent. The sand
filter was not being used during the NEIC inspection and Company repre-
sentatives stated that there are no plans for using the filter.
Use of the sand filter may not be required if the Company can ef-
fectively treat and remove the solids from the effluents discharged from
Outfalls 001 and 002. The average iron and TSS loads discharged from the
neutralization facility during March 7 to May 5, 1980 were only 8 and 12%
of the 30-day average limitations in the existing permit, respectively.
The Company must solve the serious problem of overloading the PWAN/
SWAN system. At high production rates, the batch attack lagoon, which is
used for flow equalization, cannot contain the flows and the neutralization
systems and clarifier cannot be operated efficiently. If high production
is periodic, then increased flow equalization would be required. However,
-------
42
TABLE 11
SUMMARY OF EFFLUENT DATA
PWAN/SWAN Neutralization Process
SCM GLIDDEN-DURKEE - ADRIAN-JOYCE WORKS
March 7 to May 5, 1980
Date
3/7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
4/1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
5/1
2
3
4
5
AVG
A
7.7
7.3
7.4
7 9
7.6
7.8
7.7
7.0
7.1
7.0
7.2
6.8
7.0
7.1
7.6
7.7
7.6
7.8
7.6
7.4
7.8
7.0
7.6
7.5
7.5
7.6
7.6
7.5
7.6
7.4
7.5
7.4
7.5
7.4
6.8
6.8
6.6
6.3
7.0
7.0
7.6
6.7
7.4
7.5
7.5
7.7
7.8
7.8
7.7
6.9
7.5
7.6
7.7
7.5
7.5
7.6
7.1
7.4
7 5
7.7
7 4
Iron
mg/1
2
3
11
1
5
15
3
7
5
9
14
7
6
8
2
6
1
18
49
53
16
3
17
3
8
6
7
1
6
8
10
2
2
1
14
8
25
74
8
3
3
4
7
2
4
7
5
2
3
5
6
2
2
1C
5
8
2
2
2
2
t 0
Ib/day
21
31
114
5
52
156
31
73
52
93
145
73
63
83
21
63
10
187
509
550
166
31
177
31
83
63
73
10
63
83
115
23
23
12
161
92
289
855
92
35
34
46
81
23
46
81
57
23
35
58
69
23
23
185
57
93
23
24
23
23
97
TSS
mg/1
10
24
14
26
20
32
36
40
42
56
50
32
8
52
68
84
42
80
240
174
126
200
102
84
40
24
76
4
6
28
8
28
26
62
54
6
46
16
12
26
46
32
51
6
34
58
34
48
32
20
18
76
46
104
46
84
14
16
34
72
49
Ib/day
104
249
145
270
208
332
374
415
436
581
520
332
83
540
706
872
436
831
2,492
1,806
1,308
2,077
1,059
872
415
249
789
42
63
291
92
324
300
717
624
70
531
185
139
301
532
370
601
69
393
670
393
555
370
231
208
879
531
1,202
532
971
162
185
393
832
538
Flow = 1.245 mgd for March 7 to April 5 and 1,386 mgd for April 6 to
May 5.
-------
43
if production schedules dictate extended periods of high production, the
Company must increase flow equalization and install additional neutral-
ization and clarification systems to produce an acceptable effluent.
PERMIT LIMITATIONS
Existing Permit
The existing NPDES permit limits the TSS and total iron loads on a
total plant basis, i.e., the summation of the loads discharged from Out-
falls 001 and 002, and "break" in the pipe for PWAN/SWAN cannot exceed
4,320 Ib/day and 1,212 Ibs/day, respectively (30-day average). At the
existing flow rate of 19.90 mgd,* the allowable concentrations of TSS and
iron are 26 mg/1 and 7 mg/1, respectively, on a net basis.
The existing permit limitations were based on best engineering judg-
ment, the remanded 1974 Effluent Guidelines and from data submitted by SCM
Glidden-Durkee and the Ti02 industry. SCM reported a process wastewater
flow of 4 mgd from the production of 150 tons/day by the sulfate process,
and 50 tons/day by the chloride process. The Company also reported that
1.95 mgd of the total flow was from the sulfate process Moore filters,
one-third of which was strong acid and the rest weak acid.
Two-stage neutralization was the treatment operation selected by
industry to reduce iron from the sulfate process strong acid waste streams
to 5 mg/1 with a final pH ranging between 7 and 8. The weak acid waste
streams were to be neutralized to a pH 4 to 5 resulting in a final iron
concentration of 100 mg/1. The final iron load for the chloride process
was calculated to be 0.62 Ib/ton based on a concentration of 5 mg/1 and a
flow of 15,000 gal/ton (9,000 gal/ton from milling and 6,000 gal/ton from
other process wastes). The chloride production was assumed to be 100
tons/day based on SCM projections. Calculations of the final effluent iron
load were as follows:
* 13.908 mgd (001) + 4.746 mgd (002) + 1.245 mgd (PWAN/SWAN).
-------
44
Sulfate Process
a) Strong acid: 1.95 mgd x 8.34 x 5 mg/1 = 27 Ib/day
3
b) Weak acid: 1.95 mgd x 2 x 8.34 x 100 mg/1 = 1,084 Ib/day
3
Total = 1,111 Ib/day
Roundoff = 1,150 Ib/day
Chloride Process: 0.62 Ib/ton x 100 tons/day = 62 Ib/day
30 Day Average Total = 1,212 Ib/day
Daily Max = 1 1/2 Daily Ave = 1,818 Ib/day
At the production capacity of 200 tons/day and total wastewater flows
of 4 mgd, approximately 2.05 mgd would be milling wastes. At the increased
production level of 250 tons/day, the milling wastes flow would be 2.56 mgd.
The TSS concentration in the milling wastes was assumed to be 50 mg/1 and
200 mg/1 in the mixed acid waste after treatment. The TSS load was cal-
culated as follows:
Milling wastes: 2.56 mgd x 8.34 x 50 mg/1 = 1,067 Ib/day
Mixed acid wastes: 1.95 mgd x 8.23 x 200 mg/1 = 3,252 Ib/day
Total = 4,319 Ib/day
30-Day Average = 4,320 Ib/day
Daily Max = 1 1/2 Daily Average = 6.500 Ib/day
Second Round Permit Limitations
The Effluent Guidelines Division has published the "Development
Document for Effluent Limitations Guidelines and Standards the Inorganic
Chemicals Manufacturing Point Source Category", June 1980 (proposed).
Base level performance for Best Practicable Control Technology (BPT)
currently available for the sulfate process has been identified as
multiple-stage neutralization of acid wastes with limestone and lime,
aeration for removal of ferrous iron, and settling. The Adrian-Joyce Works
uses a multiple-stage neutralization system followed by clarification.
Data supplied by the Company demonstrate that the treatment system can
-------
45
produce an acceptable effluent and will meet the proposed effluent limi-
tations. The sulfate process base level effluent concentrations for TSS
and iron are 64 mg/1 and 2.5 mg/1, respectively, on a net basis.
The chloride process base-level treatment consists of neutralization,
final clarification, and ponding. This is the system used by the Company;
however, neutralization achieved in the aragonite pit is questionable. The
base-level effluent concentrations for TSS and iron from the chloride
process are 64 mg/1 and 2.5 mg/1, respectively, on a net basis. The
Company can achieve the TSS and iron concentrations if they commit them-
selves to treatment rather than considering the wastewaters as an envi-
ronmental stream with minimal treatment.
Based on the Development Document, the total wastewater load dis-
charged from the PWAN/SWAN system and Outfalls 001 and 002 should not
exceed the following on a net basis:
Total Suspended Solids
Iron
PH
30- Day Average
Ib/day
9,510
380
6.0 - 9.0
Daily Maximum
Ib/day
34,500
1,300
Based on the current flow rates provided by the Company, the TSS and
iron concentrations in the entire plant load average 57 mg/1 and 2.3 mg/1,
respectively. Using the data submitted to NEIC by the Company for March 7
to May 5, 1980, river water TSS and iron concentrations averaged 40 mg/1
and 8 mg/1, respectively. The allowable effluent concentrations on a gross
basis would be 97 mg/1 for TSS and 10.3 mg/1 for iron.
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