United States Solid Waste and EPA530-R-99-027
Environmental Protection Emergency Response NTIS: PB99-156 028
Agency	(5305W)	April 1998	
sEPA Application of the
Phase IV Land
Disposal Restrictions
to Newly Identified
Mineral Processing
Wastes; Regulatory
Impact Analysis

-------
50272-101
REPORT DOCUMENTATION | 1. Report No
PAGE	|
| EPA530-R-99-027
	I	
4. Title and Subtitle
12.
I
I
1_
Application of Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes;
Regulatory Impact Analysis
7. Authors)
I 3. Recipient's Accession No.
I
! PB99-156 028
J	
| 5. Report Date
I April 1998
|6-
I
I
I	
I 8. Performing Organization Rept No.
9. Performing Organisation Name and Address
U.S. EPA
OFFICE OF SOLID WASTE
401 M STREET, SW
WASHINGTON, DC 20460
12. Sponsoring Organisation Name and Address
.L
! 10. ProjeclTask/Work Unit No.
|11. Contract  or Grant (G) No.
|
I
1(G)
I
! 13. Type of Report &. Period Covered
Regulatory Impact Analysis
15. Supplementary Note-
lb Abstract (Limit: 200 words)
Estimates the costs, economic impacts, and benefits of the Phase IV LDR rule on newly identified mineral processing wastes. Addresses
regulatory options. Defines the universe and estimates waste volumes. Provides methodology used to assess cost, economic impacts, and
benefits of this rule. Appendices include analysis of options under alternative baselines, methodology for identifying hazardous waste
streams, mineral processing waste stream status changes since December 1995, mineral processing waste treatment and disposal costs,
development of costing functions, explanation of cost modeling calculations, mineral processing cost model example calculation for the
titanium and titanium dioxide sector, derivation of value of shipments and value added for mineral processing sectors, risk and benefits
assessment for the storage of recycled materials, constituent concentration data for recycled materials, and data summaries for high-risk
mineral processing facilities.
17. Document Analysis a. Descriptors
b. Identifiers/Open-Ended Terms
c. COSATI Field Group
18. Availability Statement
RELEASE UNLIMITED
119. Security Class (This Report) 21. No. of Pages
| UNCLASSIFIED	|
I	i
| 20. Security Class (This Page) | 22. Price
| UNCLASSIFIED	|
(See ANSI-Z39.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)

-------
TABLE OF CONTENTS
Page
MINERAL PROCESSING WASTES FORMERLY EXEMPT
UNDER THE BEVILL AMENDMENT 		 1
Background	 1
1.	REGULATORY OPTIONS 	 2
1.1	Specific Options 	 2
1.2	Discussion of Options and Implications for the Regulatory Impact Analysis ... 3
2.	DEFINING THE UNIVERSE AND ESTIMATING WASTE VOLUMES	 5
3.	COST AND ECONOMIC IMPACTS OF THE RULE	 8
3.1	Methods							 8
3.1.1	Waste Management Assumptions	 8
3.1.2	Cost Modeling Assumptions 			 11
3.1.3	Economic Impact Analysis	 16
3.2	Results	 17
3.2.1	Cost Analysis Results		 18
3.2.2	Economic Impact Analysis Results 	 21
3.3	Regulatory Flexibility Analysis	 27
3.3.1	Methodology 		 27
3.3.2	Results 	 29
3.4	Media Contaminated with Manufactured Gas Plant Wastes		30
3.5	Class I UIC Wells 		36
4.	BFNHFITS ASSESSMENT 		38
"4.1 Risk and Benefits Assessments Methodologies		38
4.1.1	Overview of Risk and Benefits Assessment Activities	 38
4.1.2	Risk and Benefits Assessment Methods for the Storage of Recycled
Materials	 40
4.2 Generic Risk and Benefits Assessment Results	 42
April 30, 1998
i

-------
TABLE OF CONTENTS (continued)
Page
4.2.1	Risk Assessment Results for Recycled Materials Storage: Groundwater
Pathway 	 42
4.2.2	Potential Benefits From Control of Stored Materials: Groundwater
Pathway 			47
4.2.3	Generic Risk Assessment Results for Storage of Recycled Materials:
Non-Groundwater Pathways 				49
4.2.4	Potential Health Benefits from Regulation of Storage of Recycled
Materials: Non-Groundwater Pathways		55
4.3	Qualitative Evaluation of Conditions at High-Risk Facilities		55
4.3.1	Identification of Potential High-Risk Streams and Facilities		55
4.3.2	Land Management of Recycled Streams at Potential High-Risk
Facilities	.		57
4.3.3	Identification of Populations at Risk 		61
4.3.4	Potential Exposure Pathways at the High-Risk Facilities 			61
4.3.5	Documented Environmental Releases and Damages from the High-Risk
Facilities		62
4.4	Uncertainties and Limitations in the Risk and Benefits Assessment for the
Modified Prior Treatment Baseline		63
5.	OTHER REGULATORY ISSUES			66
5.1	Non-LDR Regulatory Issues		66
5.1.1	Use of the TCLP Test for Identifying Hazardous Mineral Processing
Wastes 		66
5.1.2	Remanded Listed Mineral Processing Wastes 		66
5.1.3	Titanium Tetrachloride Chloride-Ilmenite Wastes 		67
5.2	Other Administrative Requirements 		68
5.2.1	Environmental Justice 		68
5.2.2	Unfunded Mandates Reform Act		68
6.	CONCLUSIONS 		70
6.1	The Affected Universe 		70
6.2	Cost and Economic Impacts of the Rule		70
6.3	Health Benefits of the Proposed LDRs				72
APPENDIX A:	ANALYSIS OF OPTIONS UNDER ALTERNATIVE BASELINES
April 30, 1998

-------
APPENDIX B:
APPENDIX C:
APPENDIX D:
APPENDIX E:
APPENDIX F:
APPENDIX G:
APPENDIX H:
APPENDIX I:
APPENDIX J:
APPENDIX K:
APPENDIX L:
TABLE OF CONTENTS (continued)
Page
METHODOLOGY FOR IDENTIFYING HAZARDOUS WASTE STREAMS
SUMMARY OF MINERAL PROCESSING FACILITIES PRODUCING
HAZARDOUS WASTE STREAMS
MINERAL PROCESSING WASTE STREAM STATUS CHANGES SINCE
DECEMBER 1995
MINERAL PROCESSING WASTE TREATMENT AND DISPOSAL COSTS:
LOW-COST ANALYSIS
DEVELOPMENT OF COSTING FUNCTIONS
EXPLANATION OF COST MODELING CALCULATIONS
MINERAL PROCESSING COST MODEL EXAMPLE CALCULATION:
TITANIUM AND TITANIUM DIOXIDE SECTOR
DERIVATION OF VALUE OF SHIPMENTS AND VALUE ADDED FOR
MINERAL PROCESSING SECTORS
RISK AND BENEFITS ASSESSMENT FOR THE STORAGE OF RECYCLED
MATERL\LS
CONSTITUENT CONCENTRATION DATA FOR RECYCLED MATERIALS
DATA SUMMARIES FOR HIGH-RISK MINERAL PROCESSING
Facilities
April 30, 1998

-------
MINERAL PROCESSING WASTES FORMERLY EXEMPT
UNDER THE BEVILL AMENDMENT
This regulatory impact analysis (RIA) estimates the costs, economic impacts, and benefits of the
final rule applying Phase IV Land Disposal Restrictions (LDRs) to newly identified hazardous mineral
processing wastes.
In today's rule, EPA is promulgating standards for mineral processing wastes no longer exempt
from Subtitle C requirements under the Bevill exemption. Under the provisions of today's proposal,
previously exempt Bevill mineral processing wastes destined for disposal need to be treated to meet RCRA
Universal Treatment Standards (UTS) before management or disposal in a land-based unit. At the same
time, however, operators can reclaim hazardous mineral processing residues and store them in non-land
based units prior to reclamation without complying with full Subtitle C requirements, under a new
conditional exclusion.
Background
This component of the Phase IV Land Disposal Restrictions rule is one in a series of regulations
that restricts the continued land disposal of hazardous wastes. EPA has developed these regulations
pursuant to the 1984 Hazardous and Solid Waste Amendments (HSWA) to the Resource Conservation and
Recovery Act (RCRA). At the time HSWA was enacted, EPA was required to promulgate treatment and
disposal standards by May 8, 1990 for wastes already identified or listed as hazardous; EPA completed
development of treatment standards and waste management practices for these wastes in 1990. EPA also
is required to develop treatment standards for wastes subsequently identified or listed as hazardous. F.PA
is addressing these "newly identified'' wastes in several "phases." EPA has finalized rules for three phases
and proposed the Phase IV rule in two parts in August 1995 and January 1996. Subsequently, EPA
finalized a portion of the Phase IV rule on May 12, 1997 and modified parts of the earlier proposals in a
'second supplemental' proposal, also issued on May 12, 1997. Today's rule finalizes the portions of the
Phase IV rule not promulgated earlier.
Under the provisions of the RCRA Mining Waste Exclusion, solid waste from the extraction,
beneficiation, and processing of ores and minerals is exempt from regulation as hazardous waste under
Subtitle C of RCRA, as amended. The Mining Waste Exclusion was established in response to the so-
called "Bevill Amendment." which was added in the 1980 Solid Waste Disposal Act Amendments. The
Bevill Amendment precluded HPA from regulating these wastes until the Agency performed a study and
submitted a Report to Congress. Following a process of litigation and rulemakings that took place over
several years, the Agency promulgated final rules on September 1, 1989 (54 FR 36592) and January 23,
1990 (55 FR 2322) establishing that only 20 specific mineral processing wastes fulfilled the newly
promulgated special wastes criteria; all other mineral processing wastes were removed from the Mining
Waste Exclusion.
These newly identified non-exempt wastes have the same regulatory status as any other industrial
solid waste. Thus, if they exhibit characteristics of hazardous waste or are listed as hazardous wastes, they
must be managed in accordance with RCRA Subtitle C or equivalent state standards. Existing waste
characterization data suggest that many of these wastes may exhibit the characteristic of toxicity for metals
(waste codes D004-D011), corrosivitv (D002), and/or reactivity (D003).
April 30, 1998

-------
EPA considers these wastes to be "newly identified" because they were brought into the RCRA
Subtitle C system after the date of enactment of the HSWA on November 8, 1984. EPA did not include
the newly identified wastes within the scope of the LDRs for Subtitle C characteristic hazardous wastes
published in June 1990, deciding instead to promulgate additional treatment standards (Best Demonstrated
Available Technology, or BDAT) in several phases. At the time, EPA had not performed the technical
analyses necessary to determine whether the treatment standards being promulgated for characteristic
hazardous wastes were feasible for the newly non-exempt mineral processing wastes. In addition, the list
of non-exempt wastes was not yet final, because the regulatory determination for the 20 wastes studied in
the 1990 Report to Congress had not yet been promulgated. The boundaries of the Exclusion have now
been firmly established, and the Agency is ready to characterize and establish treatment standards for all
newly identified hazardous mineral processing wastes.
Today's rule contains elements that are related to non-HSWA provisions of the statute (e.g., the
conditional exclusion from the definition of solid waste for storage of mineral processing residues) as well
as elements that are related to HSWA provisions (the proposed universal treatment standards for land
disposed mineral processing wastes). The definition of solid waste provisions of this rule are not being
promulgated pursuant to HSWA. Thus, these federal requirements will take effect only in states that do
not have final RCRA authorization. In contrast, the universal treatment standards for land disposed
mineral processing wastes are being promulgated pursuant to HSWA. Therefore, these treatment standard
provisions will take effect in all states upon the effective date of the rule regardless of final state
authorization status.
1. REGULATORY OPTIONS
This section presents the final option that EPA is finalizing in today's rule, which applies LDR
standards to newly identified hazardous mineral processing wastes. In addition, this RLA also includes an
analysis of an industry-proposed option. EPA's option is described as Option 1 and the industry option is
described as Option 2. Section 1.1 summarizes the key features of each option. Section 1.2 discusses their
operational implications.
1.1 Specific Options
Summarized below are the two options that EPA has analyzed in this RIA. In addition to the
option-specific details outlined below, both of the options share the following common features:
	Mineral processing wastes being disposed must be treated to UTS levels
prior to land disposal in either Subtitle C or Subtitle D disposal units;
	Operators of facilities that generate and manage hazardous mineral
processing wastes must comply with simplified recordkeeping and
reporting requirements'.
	Secondary mineral processing materials destined for legitimate recycling
may be stored for up to one year; and
	Recycling of non-mineral processing materials outside of RCRA Subtitle
C jurisdiction is prohibited, i.e., the conditional exclusions for certain
activities (as described below) are available only for mineral processing
residues; and
April 30, 1998

-------
Hazardous mineral processing residues can be legitimately recycled to primary
beneficiation operations/units without risk to the Bevill status of any beneficiation
wastes generated by such units. That is, these operations would not become
regulated Subtitle C units and resulting wastes from these units would not lose
their Bevill status when mineral processing residues are mixed with ores,
minerals, or beneficiated ores or minerals, provided that at least 50 percent of the
materials entering the operations are ores, minerals, or beneficiated ores or
minerals.
Option 1  Conditional Exemption from RCRA Jurisdiction
Option 1 represents an attempt to both (1) stimulate greater resource recovery in the minerals
industry by not classifying recoverable mineral processing residuals as wastes if they are not managed in
land-based units, and (2) ensure that appropriate waste treatment standards and technologies are applied to
hazardous mineral processing wastes destined for land disposal, thereby protecting human health and the
environment.
In this option, a conditional exclusion from the definition of solid waste would apply to a non-
exempt mineral processing residue if the following conditions were met:
1) The material contains recoverable amounts of minerals, acids, cyanide, water, or
other values;
2)	The material is legitimately recycled (as defined at 261.2(0);
3)	The material is not accumulated speculatively (as defined at 261.1(c)(8));
4)	The material is stored in tanks, containers, or buildings meeting minimum
integrity standards: and
5)	The owner or operator provides a one-time notification to the EPA Regional
Administrator or State.
Alternatively, facility operators could obtain a determination from an authorized State or from the
Regional Administrator that solid secondary materials may be placed on pads instead of in tanks,
containers, or buildings. These pads must meet minimum design requirements so that the unit provides
effective containment and will not become part of the waste disposal problem through discard.
Option 2 -- Unconditional Exclusion from RCRA Jurisdiction
This option is based on approaches advanced by the mineral processing industry and would
maximize the ability of industry to recycle secondary materials without triggering any additional
requirements. In this option all outputs from mineral processing facilities would be unconditionally
excluded from RCRA jurisdiction regardless of how the materials are stored. Consequently, there would
be no special requirements for any type of unit storing secondary materials.
1.2 Discussion of Options and Implications for the Regulatory Impact Analysis
The Agency has performed a detailed analysis of both of these options, assuming each of three
alternative baselines. The baseline discussed in the remainder of this RIA is the one the Agency believes
April 30, 1998

-------
-4-
best reflects actual operator behavior. EPA refers to this baseline as the "modified prior treatment"
baseline (because it is a variation on the "prior treatment baseline," one of the two baselines modeled in the
December 1995 RIA). A description of the assumptions underlying the alternative baselines (prior
treatment and no prior treatment), and the resulting estimated costs and impacts can be found in
Appendix A.
The modified prior treatment baseline assumes that all generators of hazardous mineral processing
wastes currently dispose those wastes in compliance with Subtitle C treatment standards (except for
LDRs). The least-cost method for attaining compliance for most operators would be to lime neutralize
and/or cemcnt-stabilize their waste(s) to remove the hazardous characteristic(s).1 Because these methods
routinely reduce contaminant concentrations to below UTS levels, there would be essentially no new
treatment required upon promulgation of the LDRs, and hence, no costs or benefits associated with the
LDR portion of the rule.2 The baseline also allows for consideration of apparent confusion within the
regulated community as to requirements that currently apply to their mineral processing operations.
Operators are assumed to temporarily store characteristic spent materials in unlincd land-based units prior
to reinsertion into a mineral processing production unit. This alternative reflects the Agency's belief that
some operators do not clearly understand the Subtitle C regulations that apply to their secondary materials,
i.e., that spent materials intended for recycling are not currently excluded from Subtitle C regulation.
Option 1 requires that if secondary materials are stored prior to reinsertion into the production
process, that they must be stored in tanks, containers, or buildings, or in limited cases, on approved pads.3
The Agency believes that although Option 1 may impose a slight disincentive to recycling, it is protective
of the environment, without interfering excessively with resource recovery. The requirement that
secondary materials be stored off the ground provides higher potential benefits in terms of environmental
protection than Option 2.
Option 2 would impose no additional requirements for management of secondary materials to be
recycled, regardless of how they are stored. Consequently, this option represents the least cost approach
for industry and may provide greater incentives for materials reuse than the RPA's options. At the same
time, this option does little to ensure that recycling is legitimate and also does not impose any standard to
ensure that land-based storage of materials prior to reinsertion into the production process does not result
in releases that contribute to the "waste management problem." This option, therefore, could be expected
to result in greater releases of hazardous constituents to the environment and greater human exposure to
those constituents.
' As discussed in Section 2 below, the vast majority of hazardous mineral processing wastes exhibit
the characteristics of corrosivity and/or toxicity. EPA has shown that cement stabilization (in some cases
preceded bv neutralization), which is the basis for the UTS standards, is an effective treatment technology
for removing these hazardous waste characteristics.
2 As described in more detail in Section 3.1.1, EPA based the final UTS levels on analytical data from
commercial treatment facilities showing that treatment to remove toxicity characteristic metals routinely
achieves the final UTS levels. (Letter from Michael Fusco, Rollins Environmental Inc. to Anita
Cummings, U.S. EPA Office of Solid Waste, December 19, 1996.)
1 These tanks, containers and buildings do not, however, have to meet 40 CFR Part 265 Subpart I, J or
DD standards.
April 30, 1998

-------
-5 -
2. DEFINING THE UNIVERSE AND ESTIMATING WASTE VOLUMES
EPA developed a step-wise methodology for both defining the universe of mineral processing
sectors, facilities, and waste streams potentially affected by the Phase IV Land Disposal Restrictions and
estimating the volumes of wastes potentially affected under the various implementation options being
considered by the Agency. The Agency's methodology began with the broadest possible scope of inquiry
in order to ensure that EPA captured all of the potentially affected mineral commodity sectors and waste
streams. The Agency then narrowed the focus of its data gathering and analysis as it completed each
subsequent step. Appendix B describes this six-step methodology in detail and provides a summary of the
affected secondary materials. Appendix C lists the mineral processing facilities affected by this
rulemaking.
The Agency's data sets and underlying Technical Background Document Identification and
Description of Mineral Processing Sectors and Waste Streams were made available to the regulated
community during the comment period following the January 1996 proposal. In some cases, reviewers
supplied the Agency with additional or more current information about a particular commodity sector. In
addition, some commenters provided subsequent information in public comment submitted following the
May 1997 supplemental proposal. Where appropriate, EPA revised the sector reports in the Technical
Background Document and incorporated new information into its analysis. Further, since the rule was
proposed in January 1996, EPA has obtained other information that it has used to update some of the
sector reports. This information also has been incorporated into the analysis presented in this RLA.4
EPA lias developed a bounded cost analysis, providing an expected cost (expected value case), as
well as a lower bound cost (minimum value case), and an upper bound cost (maximum value case) for each
of the options considered. EPA used two factors, uncertainty about generation rate and uncertainty about
hazardous characteristics, to develop these three cost cases. All other steps in the cost modeling process
arc applied consistently across the three cost cases.
As in the previous RIAs, EPA began with the three estimates of generation rates potentially
affected by this rulemaking for every waste stream: a minimum generation rate, an expected generation
rate, and a maximum generation rate. In some cases, there is no variation in the three estimates because
the generation rate of the stream is known (e.g., it was reported in literature). For a number of these waste
streams, EPA also lacked data about hazardous characteristics. To address these uncertainties, EPA
weighted the volume estimates for each waste stream to account for the degree of certainty that the
particular waste stream exhibited one or more of the RCRA hazardous waste characteristics. As shown in
Exhibit 2-1, 100 percent of each waste stream known to be hazardous was included in the minimum,
expected, and maximum value scenarios. For streams that were only suspected of being hazardous,
however, 0 percent, 50 percent, and 100 percent of the generation rate is included in the minimum,
expected, and maximum value case, respectively. That is, the generation rate in each of the cost scenarios
was multiplied by the percentage considered to be hazardous in this analysis, based on the certainty that the
waste stream is hazardous. The remaining "nonhazardous" portion drops out of the analysis. Exhibit 2-2
presents the average facility levels of waste assumed to be "hazardous" in each sector, for the minimum,
expected, and maximum value cases.
4 Appendix D provides a comparison of waste streams included in the January 1996 RLA, April 1997
RIA, and this RIA.
April 30, 1998

-------
Exhibit 2-1
Portion of Waste Stream Considered to Be Hazardous
(in Percent)
Costing Scenario
Hazard Characteristic(s)
Y
Y?
Minimum
100
0
Expected
100
50
Maximum
100
100
Notes:
Y means that EPA has actual analytical data demonstrating that the waste exhibits one or
more of the RCRA hazardous waste characteristics.
Y? means that EPA, based on professional judgment, believes that the waste may exhibit
one or more of the RCRA hazardous waste characteristics.
April 30, 1998

-------
Exhibit 2-2
Average Facility Waste Type Input Data
>
3
o
sO
vO
00
Commodity
Minimum Cos I Scenario
Kxpected Cost Scenario
Maximum Cost Scenario
Number
(it
Facilities
Waste
Water
hnt/yr)
1  10%
Solids
(mt/yr)
Solids
(mt/yr)
Number
of
Facilities
Waste
Water
(mt/yr)
1  10%
Solids
(mt/yr)
Solids
(mt/yr)
Number
of
Facilities
Waste
Water
(mt/yr)
1 -10%
Solids
(mt/yr)
. Solids
(mt/yr)
Alumina and Aluminum
23


3.330
23


3.330
23

.
3.330
Aminiony
6
53

3.532
6
4.500

3.532
6
9,000

3,532
Beryllium
2
27.600

100
o
77.500
-
23,000
2
1,027.500

45.000
Bismuth
I
200
200
3.300
1
12.300
12,200
10,020
I
24,200
24.000
25,200
Cadmium
2
2X5
190
570
o
2 850
1.900
5.700
2
28.500
19.000
57,000
Calcium
1


40
1


40
1


40
Chroniium unci Ix'rrochromium
1


3.030
1


3.300
1


6.000
Coal Gas
-




-
-

1
-
' 65,000

CopJXM
10

530,000
900
to

530.000
900
10
-
530.000
900
Elemental Phosphorus
2
*560.001
500,000
230
2
560 000
500.1XXI
210
2
560,000
500,(XM)
230
Fluorspar and Hydrofluoric Acid




3
5.000


3
15.000

.
Germanium
4
200

10
4
1.100

161
4
2.000

302
Lead
3
870.000

7,660
3
870.000
-
30.460
3
870,000

60,460
Magnesium and Magnesiii from Urines
j


1 !,0iX
->
-
-
13,380
2


16.800
Mercury
7
9.000

12
7
11.000
-
12
7
60.1KX)

12
Molybdenum. Ferromolybdenum. and Amnx>nium
Molybdate
11
91

100
11
91

23.000
11
91

45,000
Platinum Group MeluU
3
200

2
3
1.140

15
3
2,000
-
ISO
Rare Harths
1
21.200

170
I
1.021.000

3.(XX)
1
2,021,000
-
11.500
Rhenium
2


44.000
2
50

44.000
2
100
-
44,(MX)
Scandium
7
200

-
7
1,120

-
7
2.000
-

ScL'ttium
s
22,000

68
3
22,000
-
680
3
22.000
-
6,800
Synthetic Runic
1
30.000

75.000
1
30,1)00

75,(XX)
1
30.000
.
75.000
Tantalum. Columbium. and Ferrocolumbium
">

75.000
1.500
2

75.000
1.500
2

75.000
1.500
Tellurium
2
200

200
2
11,000

2,000
2
30.000

9,000
Titanium and Tiianium Dioxide
7
55,289

65,114
7
75,876
-
68.243
7
96,289

71.671
Tungsten
6
370

-
6
730
-

6
5.000


Uranium
P
300

100
17
1,250
-
650
17
2.200
-
1,200
Zinc
3
3.243.417

16.600
3
3.243.417
-
16.600
3
3,243,417
-
16,600
Zirconium and Hatnium
2
17.100


2
521,000


2
2.256,000


^4

-------
-8-
3. COST AND ECONOMIC IMPACTS OF THE RULE
This section presents the methodology and results of EPA's analysis of the cost and economic
impacts arising from today's proposed rule. Section 3.1 begins by describing the methods employed to
determine the costs of complying with the two options described above and to compute the screening-level
economic impact measures employed in this analysis. Section 3.2 presents and describes the results of the
analysis. Section 3.3 discusses potential impacts on small entities. Section 3.4 addresses media
contaminated with manufactured gas plant (MGP) waste. Finally, Section 3.5 discusses facilities operating
underground injection control (UIC) wells.
3.1 Methods
This section describes the methodology used to calculate the costs and screening-level economic
impacts of managing the affected mineral processing wastes under each of the two regulatory options. The
basic analytical construct used throughout this analysis is that facility operators will choose the least-cost
option that complies with the law. For today's final rule the Agency has conducted a dynamic analysis of
shifts in recycling that simulates shifts in types or quantities of mineral processing residues between
treatment/disposal and storage/recycling/reclamation. For Option 1 the analysis examines shifts that may
diminish recycling, while for Option 2 the analysis assumes no change in recycling.
To analyze each option, EPA employed a number of steps and assumptions, some of which exert a
major influence on the results obtained. The following sub-sections discuss these major analytical steps.
3.1.1 Waste Management Assumptions
The costs imposed by a particular regulator)' option are measured as the difference in cost between
the current, or baseline, management practices and the lowest-cost alternative practice allowed under the
option. In this analysis, therefore, EPA identified what it believes to be the current management practices
that are applied to the waste streams of interest and then determined the costs of these practices. These
baseline costs are then subtracted from the costs of complying with the least-cost management practice
allowed under each of the options. Exhibit 3-1 summarizes the pre- and post-rule behavior that is
discussed in more detail below.
Exhibit 3-1
Assumed Management Practices
Baseline or Option
Wasted Portion
Recycled Secondary Materials
Baseline
Treated to TC levels, disposed
Stored in unlincd land-based units
Option 1
Treated to UTS levels, disposed
Stored in tanks, containers, and buildings
Option 2
Treated to UTS levels, disposed
Stored in unlined land-based units
April 30, 1998

-------
-9-
Pre-LDR Behavior (Baseline)
In the baseline, operators arc assumed to be in full compliance with RCRA Subtitle C
requirements (but not LDRs) for managing waste materials. The baseline assumes that the operator has
chosen the least-cost option for compliance with these requirements: corrosive and/or TC toxic
wastewaters and slurries arc treated (generally with lime) in tanks; and TC toxic solids, sludges, and other
materials are cement stabilized within 90 days of being generated, and disposed (generally on site) in a
Subtitle D unit.5 Fundamentally, these assumptions are based upon the feasibility of mineral processing
residue treatment by lime neutralization for wastewaters and slurries and cement stabilization for sludges
and solids. These methods, along with high temperature metals recovery (HTMR), are part of the basis for
the UTS standards.
A point of further interest and critical importance to the analysis presented below is the fact that
the very same technologies can be used to treat wastes to the point of removing the hazardous
characteristic(s) and to meet the UTS standards; the difference between achieving removal of the
hazardous characteristic and the UTS standards is simply one of degree. Since the January 1996
supplemental proposed rule, EPA received numerous comments on the use of existing UTS levels for
mineral processing wastes. These comments suggested that some of the existing UTS levels were
inappropriate for mineral processing wastes. In response to these comments, the Agency analyzed
additional stabilization data provided by the commenters and, in light of this new information, is
promulgating revised UTS levels for mineral processing wastes.6 Exhibit 3-2 presents the TC levels,
existing UTS levels, and final UTS levels. Based on the final levels, EPA believes that mineral processing
facility operators treating wastes using cement stabilization will not incur any additional costs in order to
achieve UTS levels.
In the baseline, all secondary materials destined for recycling, including spent materials, are
assumed to be stored in unlined, land-based units for some period of time prior to reinsertion into the
process. This assumption reflects apparent confusion in the regulated community concerning the status of
spent materials, and the proper methods for storing them prior to disposal or reuse.7 (Because sludges and
by-products that are reclaimed are not solid wastes, and hence, not hazardous wastes, there are currently no
standards regulating storage units for sludges and by-products.)
" To comply with current regulations, facility operators also could dispose of these wastes in a Subtitle
C permitted landfill. Appendix E presents a break-even analysis showing that treatment and Subtitle D
disposal is less expensive than Subtitle C disposal without treatment, in most cases. EPA has assumed that
facility operators will opt to treat their waste prior to disposal in all cases, however, based on data from the
biennial reporting system indicating that mineral processing wastes are generally not disposed of in
Subtitle C landfills.
6	Letter from Michael Fusco, Rollins Environmental, Inc. to Anita Cummings, U.S. EPA Office of
Solid Waste, December 19, 1996.
7	Spent materials destined for recycling, if stored, must be stored in tanks, containers, or buildings for
less than 90 days prior to recycling, unless they are stored at a RCRA permitted treatment, storage, or
disposal facility.
April 30, 1998

-------
- 10-
Exhibit 3-2
Existing and Final UTS Levels
(Nonwastewater Metals)
Waste Code
Constituent
TC
Level
(mg/I)
Existing
UTS
level
(mg/I TCLP)
Final
UTS
Level
(mg/I TCLP)
D004
Arsenic
5.0
5:0
5.0
D005
Barium
100.
7.6
21
D006
Cadmium
1.0
0.19
0.11
D007
Chromium
5.0
0.86
0.60
D008
Lead
5.0
0.37
0.75
D009
Mercury
,2
0.025
.025
D010
Selenium
1.0
0.16
5.7
DOII
Silver
5 0
0.30
0.14

Antimony

2.1
1.15

Beryllium

0.014
1.22

Nickel

5.0
11

Thallium

0.078
0.20

Vanadium

0.23
1.6

Zinc

5.3
4.3
Post-Rule Compliance Behavior
To determine the incremental impact of the Phase IV LDR standards, EPA first predicted cost-
minimizing behavior by affected facility operators that would be in compliance with the provisions of each
option analyzed.
Under Option 1, facility operators are expected to move material destined for recycling from
unlined land-based storage units to non-RCRA TCBs. These materials could be stored in TCBs for up to
one year in the absence of a RCRA Subtitle C permit." Facility operators would continue treating the
wasted portion tising cement stabilization or neutralization and dewatering.
8 Note that for purposes of the cost model, although storage for up to one year is possible under this
option, the Agency assumed that facilities only have capacity to store solids for 90 days and liquids for 30
days. In addition, storage is allowed on approved pads in limited circumstances. To be conservative, EPA
has not modeled storage on approved pads.
April 30, 1998

-------
Under Option 2, facility operators are expected to continue storing material destined for recycling
in unlined land-based storage units. These materials could be stored for up to one year in the absence of a
RCRA Subtitle C permit.9 Facility operators would continue treating the wasted portion using cement
stabilization or neutralization and dewatering.
Dynamic Shifts
The Agency has used a dynamic analysis to model changes in the management of newly-identified
mineral processing wastes that might be induced by the new LDR requirements. Specifically, the dynamic
analysis accounts for shifts in the amount of material that is recycled rather than being treated and
disposed. For instance. Option 1 might create a minor disincentive for recycling newly-identified mineral
processing wastes, because of the additional storage unit requirements. Option 2, which docs not impose
any new storage requirements, would neither increase nor decrease the amount of materials recycled
(which are assumed to be stored in land based units without restriction in the baseline).
3.1.2 Cost Modeling Assumptions
HPA estimated the implementation costs of the options for hazardous waste streams from mineral
processing by calculating the difference between the estimated pre- and post-LDR costs. Because of data
limitations, EPA used sector-wide averages and totals for estimating the impacts of the rule. Sector-wide
estimates were developed on an average facility basis, however, so as to correctly address facility-level
economies of scale. Detailed cost model calculations and results are bound in a separate document.
Cost Functions
To calculate the costs of managing the affected wastes under the baseline and the two options,
EPA developed and applied cost-estimating functions for treatment and disposal, as well as storage prior to
recycling. Appendix F provides a detailed discussion of these cost functions. The cost functions address
the capital and 0&M costs associated with each technology, as well as decommissioning costs for on-site
tank treatment and stabilization. These costing equations are expressed as a function of the waste
generation rate (in metric tons/year). In addition, the costing functions provide a means of estimating the
break-even point between off-site and on-site land disposal costs.
The application of new technologies for treating wastes often involves the procurement and
installation of new capital equipment, as well as changes in periodic operating costs. Because this new
equipment is used over an extended period of time (i.e.. not consumed), it is necessary to allocate its
procurement and installation costs over its useful operating life. EPA addressed this issue by annualizing
the initial capital costs over the operating life of the durable equipment, and then adding the discounted
value of the annualized initial capital costs to the annual (recurring) capital, operating, and maintenance
costs associated with the technology, in order to obtain a total annualized cost. This yields a measure of
cost impact that can be compared directly with data reflecting the ability of the affected firms to bear this
incremental cost (e.g., sales, earnings).
9 See previous footnote.
April 30, 1998

-------
- 12-
The costing functions incorporate the following general assumptions:
	Operating Life. The analysis assumes a 20-year operating life for waste
management units and facilities. With a positive and even moderately significant
discount rate, extending the operating life beyond this period adds complexity but
little tangible difference in estimated costs.
	Tax Rate. Costs are estimated on a before-tax basis to facilitate comparisons with
available data related to predicting ultimate economic impacts.
	Discount Rate. The analysis uses a discount rate of seven percent, in keeping
with current Office of Management and Budget (OMB) guidance.10
	Inflation Rate. The analysis is conducted in real terms and, consequently,
assumes an inflation rate of zero.
General Approach to Developing Waste Management Costs
Based on the assumed incentives and/or disincentives for increase recycling, as well as each
stream's certainty of recycling, EPA estimated the percentage of hazardous material sent to treatment and
disposal for each baseline and option. The remaining hazardous material is considered to be recycled."
The dynamic analysis results from the shifts in management in each baseline-option combination. Exhibit
3-3 presents the percentages of hazardous mineral processing waste streams that are sent to treatment and
disposal, in both the baseline and post-rule options. Exhibit 3-4 presents the percentages of hazardous
mineral processing wastes that are recycled.
EPA then aggregated the non-reclaimed hazardous streams by solids content, based on the
assumption that a facility would not build a separate stabilization facility and on-site landfill for each
individual waste stream but would instead handle all wastes requiring neutralization, dewatering,
stabilization, and disposal in common treatment and disposal units. That is, the facility operator would
take advantage of scale economies and co-manage similar waste types. Therefore, EPA calculated the
"model facility" generation rate by mineral processing sector (e.g., lead, copper) for hazardous waste
streams containing 1 to 10 percent solids (i.e., slurries), hazardous waste streams having greater than 10
percent solids, and hazardous wastewaters.12
10 OMB, 1992. Circular A-94.
" EPA developed the recycling assumptions (percentages) using limited empirical data on the
recycling of two listed wastes, K061 (emission control dust from electric arc steel furnaces) and F006
(wastewater treatment sludge from electroplating operations). More information on the derivation of the
percentages in the tables can be found in Appendix A.
EPA added the total sector generation rate of each type of waste and divided these totals by the
maximum number of facilities in the sector generating waste requiring treatment. More information on
this totaling process can be found in Appendix G. An example of the cost model calculations for a single
sector can be found in Appendix H.
April 30, 1998

-------
- 13 -
Exhibit 3-3
Proportions of Waste Streams Sent to Treatment and Disposal (in percent)
Baseline or Option
Percent Disposed
Certainty of Recycling
Y Y? YS YS? N
Baseline
0
15
25
80
100
Option 1
0
25
35
85
100
Option 2
0
15
25
80
100
Exhibit 3-4
Proportions of Waste Streams Stored Prior to Recycling (in percent)
Baseline or Option
Percent Recycled
Certainty of Recycling
Y Y? YS YS? N
Baseline
100
85
75
20
0
Option 1'
100
75
65
15
0
Option 2
100
85
75
20
0
Notes for Exhibits 3-3 and 3-4:
Y	means that EPA has information indicating that the waste stream is fully
recycled.
Y?	means that F.PA, based on professional judgment, believes that the waste
stream could be fully recycled.
YS	means that EPA has information indicating that a portion of the waste stream
is fully recycled.
YS?	means that EPA, based on professional judgment, believes that a portion of
the waste stream could be fully recycled.
N	means that EPA does not believe the stream is or could be recycled.
April 30, 1998

-------
In contrast, quantities of residues destined for recycling were assumed to require segregation, so as
to promote efficient resource recovery. EPA made the conservative assumption that each material to be
recovered would require storage prior to reclamation and, therefore, that each would require its own
storage unit. Consequently, for each recycled stream, EPA divided the total sector quantity stored prior to
recycling by the number of facilities generating that waste stream to determine the "average facility"
quantity recycled. The significant difference in the calculation of the "model facility" totals for treatment
and disposal and "average facility" quantities of materials stored prior to recycling are due to the difference
in management assumption, i.e., streams to be treated are co-mingled while streams to be recycled are not.
Having derived the "model facility" quantity of each type of waste (wastewaters, 1-10 percent
solids, and more than 10 percent solids) going to treatment and disposal, and the "average facility"
quantities of individual streams going to storage prior to recycling in each sector, EPA calculated the cost
associated with each of these activities.
Development of TVeatment Costs
In the analysis, the Agency made the following assumptions about waste treatment and disposal
practices:
	Management of hazardous mineral processing wastes containing more
than 10 percent solids involves non-permitted treatment followed by
disposal of the stabilized mass in a Subtitle D unit. Treatment consists of
cement stabilization, which increases the mass of waste destined for
disposal to 146 percent of the mass entering stabilization.
	Management of hazardous mineral processing wastewaters and wastes
containing 1 to 10 percent solids involves non-permitted treatment
followed by disposal of the stabilized residue in a Subtitle D unit.
Treatment consists of neutralization, followed by dewatering of the
precipitated solids, and cement stabilization of the dewatered sludge. The
precipitated mass from neutralization is 15 percent of the original waste
stream, while the dewatered mass is 15 percent of the precipitated mass
(or 2.25 percent of the original waste stream). Stabilization increases the
mass of the dewatered sludge to 146 percent of the mass entering
stabilization.
These assumptions and their factual basis are documented in Appendix F and Appendix G.
The Agency has assumed that both pre- and post-LDR management of treated residues would
occur in (primarily) on-site Subtitle D waste disposal piles, because under the baseline, affected operators
would have constructed such units to be in compliance with (i.e., avoid) pre-LDR Subtitle C waste
management requirements. For low volume wastes (less than or equal to 3,163 metric tons solids/year or
350 metric tons liquids/year), EPA has assumed that the operator would send the waste to an off-site
Subtitle C facility for treatment (stabilization) and ultimate disposal in a Subtitle D unit. The Agency did
not include non-hazardous waste streams in the analysis because the treatment standards in the Phase IV
LDR rule will not affect those wastes.
The First step in determining the cost of treatment was to compute the quantity of waste requiring
each type of treatment at a "model facility" in each sector, because each treatment technology generates a
residue which must either be further treated or disposed. For example, both wastewaters and wastes with a
April 30, 1998

-------
1 to 10 percent solids content are assumed to be neutralized and dewatered in the same units, while the
sludge (residue) generated from dewatering is mixed with waste with more than 10 percent solids,
stabilized in a single stabilization unit, and disposed in a single Subtitle D waste pile. Once EPA
determined the quantities of waste going to each treatment unit (accounting for volume changes brought
about by each treatment step), the Agency used costing equations (described in detail in Appendix F) to
determine the capital, operating and maintenance, and closure costs of each of the treatment and disposal
units. These costs were then annualized and totaled. In some sectors, there was not enough waste to
justify on-site treatment and disposal, so the Agency used a unit cost to reflect shipping the waste off-site
for treatment and disposal. The "model facility" treatment cost was multiplied by the number of facilities
treating and disposing waste to get the total sector treatment cost.
Development of Storage Costs
To determine the costs associated with storing wastes prior to recycling, EPA assumed that wastes
to be recycled are stored for 30 days or less in drums or tanks if they are liquid and for less than 90 days in
drums, roll-off containers, or buildings if they have a solids content of more than 10 percent.13 To estimate
the impacts of the material reclamation practices outlined above, the Agency used unit cost functions
(described in detail in Appendix F) to calculate the costs associated with storing wastes in piles, surface
impoundments, RCRA TCBs, and non-RCRA TCBs. Again, and in contrast to waste treatment
operations, EPA determined recycling costs on a per waste stream basis, rather than a per facility basis,
because it is important in many cases that the wastes to be recycled not be commingled. To determine the
total sector storage cost, FPA multiplied the cost of storage for each stream by the number of facilities
generating that stream and summed these total sector stream costs.
Development of Administrative Costs
To determine the costs of complying with the administrative requirements of this rule, EPA
assumed that each facility recycling a waste stream would incur a one time notification cost of $100, and
that each facility disposing of a waste would incur a one time waste analysis plan cost of $935 as well as an
annual sampling cost of $470.14 If a facility is partially recycling a waste stream and partially disposing of
it, the facility would incur all three of these costs. EPA annualized the one-time costs for each waste
stream and added the annual sampling costs to determine the total sector administrative costs.
Development of Total Costs
EPA then calculated incremental treatment and disposal costs by subtracting total sector pre-LDR
treatment and disposal costs from total sector post-LDR treatment and disposal costs. EPA calculated total
sector incremental storage costs in a similar manner. EPA calculated the total sector costs by adding the
total sector incremental treatment costs, the total sector incremental storage costs, and the total sector
13	Both options allow a longer period of storage; because, however, facility operators would have to
build larger and more expensive storage units to take advantage of these longer periods of storage, EPA
has assumed that they would attempt to minimize storage time.
14	Costs derived from Supporting Statement for EPA Information Collection Request 1442.15 Land
Disposal Restrictions - Phase IV: Treatment Standards for Wastes from Toxicity Characteristic Metals,
Mineral Processing Secondary Materials, and the Exclusion of Recycled Wood Preserving Wastewaters,
April 1998.
April 30, 1998

-------
administrative costs. EPA divided this total sector cost by the number of facilities in the sector to
determine the average facility costs.
3.1.3 Economic Impact Analysis
To evaluate the significance of increased waste management costs on affected facilities and
industry sectors, EPA employed simple ratio analyses to yield first-order economic impact estimates. The
Agency compared sector-wide estimated regulatory compliance costs for each option with four different
measures of economic activity.
First, EPA calculated the ratio of total annualized compliance costs as a percentage of firm-specific
sales for each affected mineral processing firm.15 To do this, EPA first identified the facilities and firms
that may be affected by the rule based on information contained in the technical background document
Identification and Description of Mineral Processing Sectors and Waste Streams, U.S. EPA Office of Solid
Waste, April 1998, and on information obtained from public comments on the proposed rule. Where
uncertainty existed regarding whether certain facilities currently generate hazardous mineral processing
waste, EPA included the facility in this analysis to avoid understating impacts (even if doing so meant
exceeding the number of facilities estimated in the cost model). EPA then researched the total sales for
each business owning one or more facilities using a variety of public and commercial data sources. For
seven of the 126 facilities in the analysis, FPA could not obtain estimated sales data for the direct owner
and instead calculated the ratio on the basis of the sales of a higher-tier owner (i.e., a corporate parent).
EPA then calculated the ratio of total annualized compliance costs as a percentage of sales for each firm,
and compared it to the threshold value for significant impacts of three percent (and, for sensitivity
purposes, to the alternative threshold of one percent).
Second, EPA compared regulatory costs for each sector to the estimated sector-specific value of
shipments from the facilities in that sector. This provides a rough measure of the extent to which gross
margins for each sector overall would be reduced by the increased waste management costs, or
alternatively, the amount by which the affected commodity price would need to increase to maintain
existing margins. Value of shipments data were derived by multiplying each sector's total production by
the price of the commodity produced. EPA calculated the ratio of annualized incremental cost to the value
of shipments for each option and defined the screening level threshold for significant impact as three
percent.
Third, for 16 industry sectors where data were available, EPA compared estimated regulatory costs
for each sector to the estimated value added by that sector. A ratio of regulatory costs to value added may
be more useful in assessing regulatory impacts than a ratio of regulatory costs to shipments. In particular, a
mineral processing sector (such as the primary copper industry) generally incurs substantial costs to
purchase or produce the raw materials (such as copper concentrate) used in mineral processing activities.
The total dollar value of shipments for a mineral processing industry thus includes not only the costs of
production and profit, but also the costs of raw materials. In contrast, the value added in manufacturing
measures the sales revenue minus the cost of raw materials. Thus, it presents a clearer picture of the extent
of economic activity at the regulated operation, and the basis on which the firm may make profits
attributable to that operation. EPA obtained value added data for copper and aluminum from a Census
15 Although it would be preferable to analyze facility-specific impacts (e.g., plant closures) rather than
firm-specific impacts, available data do not support facility-specific analyses.
April 30, 1998

-------
Bureau publication.16 The Agency obtained value added data for 14 industry sectors categorized as
"primary nonferrous metals, not elsewhere classified" from the same publication, and apportioned the total
value added to each of the 14 sectors according to that sector's proportion of the total value of shipments
for the 14 sectors.17 For this analysis, EPA used a screening level of 10 percent for significant impact.
Fourth, EPA compared estimated regulatory costs to the firm-specific earnings of affected mineral
processing firm. This ratio analysis permits a direct comparison of regulatory costs to earnings and
indicates the maximum extent to which the regulation will reduce earnings if a company cannot pass on
any of the regulatory costs to customers. EPA obtained earnings data for 18 firms that collectively own 39
of the 126 facilities (31 percent) identified as potentially affected by the rule. For an additional 53
facilities (42 percent), EPA was able to obtain estimated earnings data for a higher-tier owner (i.e., a
corporate parent). EPA then calculated the ratio of total annualized compliance costs as a percentage of
earnings for each of the firms owning affected facilities (and, separately, for the higher-tier owners of
affected facilities where necessary).
Finally, EPA also considered the extent to which the affected entities might be able to pass on to
their customers the costs of regulation. Mineral processing firms face significant competition from
international competitors. For most affected sectors, U.S. production represents only a fraction of world-
wide production. Consequently, it may be difficult or impossible for U.S. firms to pass on any incremental
regulatory costs to their customers (i.e., because most producers are unaffected by U.S. regulations).
3.2 Results
This section presents F.PA's estimates of the cost and screening-level economic impacts of Options
1 and 2. These estimates are discussed for each option, followed by a brief comparison between options.
Note that the detailed discussion of cost and economic results presented in Sections 3.2.1 and 3.2.2 focuses
on the expected value case. Exhibit 3-5 highlights the differences between the minimum, expected, and
maximum value cases.
Exhibit 3-5
Summary of Cost Results

Minimum
Expected
Maximum
Option 1
$7,200,000
$10,000,000
$14,000,000
Option 2
$41,000
$230,000
$230,000
EPA's use of the dynamic analysis contributes to some counter-intuitive results such as savings in
some sectors where costs are expected. The unexpected consequences result from relative economies of
scale and a low-volume wastewater treatment unit cost gap. Both are discussed further.
	The dynamic shift and relative economies of scale. The overall cost for an option
will depend on the amount and type of material moving from treatment and
disposal to recycling, the storage requirements, and the relative unit costs. For
both options, at any given generation rate storage prior to recycling is less
16	Bureau of the Census, U.S. Department of Commerce, 1995 Survey of Manufactures.
17	EPA's background calculations arc provided in Appendix I.
	v
April 30, 1998

-------
expensive than treatment and disposal. However, because quantities to be treated
and disposed are aggregated, while quantities to be recycled need to be stored in
dedicated units, moving small quantities of materials from treatment and disposal
to recycling may not produce a cost savings due to relative scale economies. For
example, if a facility were treating and disposing two wastewater streams in the
baseline, one generated at 100,000 mt/yr and one at 150 mt/yr, these two streams
would be commingled and the unit cost of treatment in the baseline would be
based on treating 100,150 mt/yr. If after the rule went into effect the smaller
stream was then fully recycled, the unit cost of storing 150 mt/yr in a dedicated
unit might be higher than the unit cost of treating those 150 mt/yr in the baseline
(when the unit cost was based on treating 100,150 mt/yr).
	Low-volume wastewater treatment unit cost gap. In addition to the problem of
relative scale economies, there is a low volume wastewater treatment unit cost
gap. That is, using available information on pertinent treatment technologies, the
smallest treatment system that can reasonably be built on-site has a capacity of
350 mt/yr, resulting in an annualized cost of about $100 per metric ton, while off-
site treatment and disposal costs SI75 per metric ton. Therefore, for facilities
treating and disposing small quantities of wastewater in the baseline, a slight
increase in the quantity treated and disposed (and, therefore, a slight decrease in
the quantity recycled) may shift treatment from off-site to on-site. Because off-
site treatment is significantly more expensive, the result of this shift is a decreased
cost, rather than an increase (as would be expected).
3.2.1 Cost Analysis Results
Option 1
Under Option 1, the total expected incremental cost is SI0,000,000. These impacts are distributed
by sector as shown in Exhibit 3-6. Twenty-seven of the industry's twenty-nine sectors (93 percent) are
projected to experience increased costs, one sector (three percent) is expected to have no additional costs,
and one (three percent) is anticipated to realize cost savings. On a sector basis, incremental costs range
from an expected savings of $96,000 (scandium) to an increase of S3,800,000 (zinc). EPA expects two
sectors (7 percent) to experience total incremental costs greater than $1,000,000 (copper and zinc) and an
additional three sectors (10 percent) to have total costs of more than S700,000 (alumina/aluminum,
elemental phosphorous, and lead). The one sector with no expected costs is coal gas. Finally, KPA
expects that the only sector to experience cost savings will be the scandium sector ($96,000).
On a per facility basis, average incremental expected costs range from a savings of $14,000
(scandium) to an increase of $1,300,000 (zinc). Facilities in three other industry sectors (10 percent) are
expected to have cost increases between $100,000 and $500,000 (copper, elemental phosphorus, and lead).
Facilities in the remainder of the sectors (83 percent) are expected to have cost increases of less than
$100,000, except that coal gas facilities are not expected to incur any impacts.
Option 2
Under Option 2, the total expected incremental cost to industry is $230,000, significantly lower
than for Option I. These impacts are distributed as shown in Exhibit 3-7. Twenty-eight sectors are
projected to experience increased costs, with one sector experiencing no change in costs. Expected
incremental costs per sector range from zero (coal gas) to $38,000 (uranium). Seven additional sectors
April 30, 1998

-------
under this option arc expected to experience costs of $10,000 or more (alumina/aluminum, cadmium,
copper, germanium, mercury, titanium/titanium dioxide, and zinc).
On a per facility basis, average incremental expected costs range from zero (coal gas) to $6,200
(cadmium). Costs are low under this option because the only costs that the Agency estimates will be
incurred by industry under this option are recordkeeping and reporting requirements. No other cost
impacts are estimated for any of the sectors because the Agency expects that under this option,
management practices will not change, relative to the baseline. That is, facility operators will continue to
store materials to be recycled in unlined land-based units and will continue to treat materials using
stabilization. Therefore, no new costs attributable to storage are expected.
Exhibit 3-6
Option 1 Incremental Costs

Minimum Value Case
Expected Value Case
Maximum Value Case

Total
Avg. Fac.
Total
Avg. FaCi
Total
Avg. Fac.

Incremental
Incremental
Incremental
Incremental
Incremental
Incremental
Commodity
Cost (S/yr)
Cost ($/yr)
Cost ($/yr)
Cost ($/yr)
Cost ($/yr)
Cost
-------
-20-
Exhibit 3-7
Option 2 Incremental Costs

Minimum Value Case
Expected Value Case
Maximum Value Case
Commodity
Total
Incremental
Cost ($/yr)
Avg. Fac.
Incremental
Cost (S/yr)
Total
Incremental
Cost ($/yr)
Avg. Fac.
Incremental
Cost ($/yr)
Total
Incremental
Cost ($/yr)
Avg. Fac.
Incremental
Cost (S/yr)
Alumina and Aluminum
13,000
570
26,000
1,100
26,000
1.100
Antimony
-

6.800
1,100
6,800
1.100
Beryllium
570
570
2,800
1,400
2,800
1.400
Bismuth
-
-
5,600
5,600
5,600
5,600
Cadmium
-
-
12,000
6,200
12,000
6,200
Calcium
-
-
9
9
9
9
Chromium and Ferrochromium
570
570
580
580
580
580
Coal Gas
-
-
-
-
570
570
Copper
5,700
570
17,000
1,700
17,000
1,700
Elemental Phosphorus
4,500
2,300
4,500
2,300
4,500
2,300
Fluorspar and Hydrofluoric Acid
-
-
1,700
570
1,700
570
Germanium
-
-
13,000
3.200
13,000
3,200
Lead
3,400
1,100
6,900
2,300
6,900
2,300
Magnesium and Magnesia trom Brines
1,100
560
1.700
840
1,700
840
Mercury
-
-
12.000
1.700
12.000
1,700
Molybdenum. Ferromolybdenum, and
Ammonium Molybdate
-
.
7,300
660
7,300
660
Pla'mum Group Metals

-
5.100
1,700
5,100
1,700
Rare Earths
1,100
1,100
2.800
2,800
2.800
2.800
Rhenium
-
-
2.300
1.100
2.300
1.100
Scandium


7,900
1.100
7,900
1.100
Selenium
1.100
570
7.900
2.600
7,900
2.600
Synthetic Rulile


590
590
590
590
Tantalum, Colunbium, and
Ferrocolumbium
1.100
570
3.400
1,700
3.400
1.700
Tellurium
-

3.400
1.700
3,100
1,700
Titanium and Titanium Dioxide
3.400
1,700
17,000
2,500
17.000
2.500
Tungsten
-
-
6,800
1,100
6,800
1,100
Uranium
-

38,000
2,300
38,000
2.300
Zinc
5.100
1,700
10.000
3.400
10,000
3,400
Zirconium and Hafnium
-

4.500
2,300 j
4.S00
2.300
Total/ Average
41.000

230,000

230.0C0

April 30, 1998

-------
3.2.2 Economic Impact Analysis Results
As described above, EPA conducted four ratio analyses comparing regulatory costs to the
following four financial indicators: (1) firm-specific sales, (2) sector-specific value of shipments, (3)
sector-specific value added, and (4) firm-specific earnings. This section presents the results of these
analyses.
Approximately 75 businesses owning approximately 126 facilities may be affected by the rule.
These facilities fall into the following sectors: alumina/aluminum, antimony, beryllium, bismuth, cadmium,
calcium, chromium/ferrochromium, coal gas, copper, elemental phosphorous, germanium, fluorspar/
hydrofluoric acid, lead, magnesium and magnesia from brines, mercury, molybdenum/ferromolybdenum/
ammonium molybdate, platinum group metals, rare earths, rhenium, scandium, selenium, synthetic rutile,
tantalum/columbium/ferrocolumbium, tellurium, titanium/titanium dioxide, tungsten, uranium, zinc, and/or
zirconium/hafnium. Firms in these sectors face significant competition from international competitors.
For most sectors, U.S. production represents only a fraction of world-wide production. Consequently, it
may be difficult or impossible for U.S. firms to pass on any incremental regulatory costs to their customers
(i.e., because most producers are unaffected by U.S. regulations).
Ratio of Regulatory Costs to Sales
The first measure considered is the ratio of total annualized compliance costs as a percentage of
firm-specific sales for each affected mineral processing firm. For seven of the 126 facilities in the analysis,
EPA could not obtain estimated sales data for the direct owner and instead calculated the ratio on the basis
of the sales of a higher-tier owner (i.e., a corporate parent). The calculated ratios are compared to the
threshold value for significant impacts of three percent and, for sensitivity purposes, to the alternative
threshold of one percent.
EPA's analysis finds that neither Option 1 nor Option 2 would result in a significant impact on any
mineral processing firm under the three percent threshold. Under the alternative threshold of one percent,
two firms (one that processes copper and one that processes both cadmium and zinc) would incur an
impact. Several possible - but unlikely - exceptions to this finding arise as a result of data limitations.
Because this analysis was unable to obtain sales data for certain businesses, the analysis could not directly
estimate impacts on these companies:
	One company processing hydrofluoric acid is expected to incur annual costs of
only $16,000 under Option 1 or $570 under Option 2. Therefore, this company
will not incur significant impacts under Option 1 unless it has sales of less than
$533,333 (i.e., $16,000/0.03) or. using the alternate threshold of one percent,
sales of less than $1,600,000 (i.e., $16,000/0.01). Under Option 2, the company
will not incur significant impacts unless it has sales of less than SI9,000 (or
$57,000 using the alternate threshold of one percent).
	Similarly, the analysis does not address businesses that own the 17 facilities in the
uranium sector. The average annual cost to such facilities is $3,500 under
Option 1 and $2,300 under Option 2. Thus, significant impacts would arise under
Option 1 only for those concerns with sales of less than $116,667 or, using the
alternate threshold of one percent, less than $350,000 (i.e., $3,500/0.01).18 Under
18 This assumes that only one uranium processing facility is owned per business.
April 30, 1998

-------
Option 2, significant impacts would arise only for those concerns with sales of
less than $76,667 or, using the alternate threshold of one percent, less than
$230,000.
The sales levels required for these companies to avoid significant cost-to-sales impacts are
relatively low in comparison to those of firms for which data are available. For example, the lowest sales
figure that was available for an affected mineral processing firm (excluding small businesses) exceeds
$10,000,000. Even among small businesses (see Section 3.3) the average sales figure exceeds
$90,000,000. Therefore, EPA believes that significant cost-to-sales impacts are unlikely.
Ratio of Regulatory Costs to Value of Shipments
Economic impacts expressed as a ratio of regulatory costs to the value of shipments are shown in
Exhibit 3-8 for Option 1, and in Exhibit 3-9 for Option 2. Option 1 imposes significant cost impacts
(defined as 3 percent of the value of shipments for the sake of this analysis) on three of the 29 industrial
sectors (10 percent of the affected sectors) in the expected value case. EPA projects significantly affected
sectors to include mercury (36 percent impact), tungsten (6 percent), and fluorspar/hydrofluoric acid (4
percent). Two other sectors are expected to incur impacts of between 1-3 percent (cadmium and
selenium). The remaining 24 sectors (83 percent of all affected sectors) are expected to experience
economic impacts of less than one percent.
Option 2 would not impose significant burdens on any of the 29 sectors. Two sectors are expected
to incur impacts of between 1-3 percent (mercury and tungsten) under this option.
The severity of predicted economic impacts does not in all cases reflect the magnitude of increased
waste treatment costs estimated in this analysis. Facilities in several sectors are projected to experience
significant cost increases but are not expected to suffer serious economic impact, because of high
production rates and/or because the commodities that they produce have a high unit market price.
Examples include alumina and aluminum, copper, elemental phosphorous, lead, titanium, and zinc. Plants
in other sectors are projected to experience low impacts because estimated incremental waste treatment
costs are relatively modest.
In contrast, the sectors that are projected to experience the most significant impacts have both
moderate incremental waste management costs and low commodity production rates, a low commodity
price, or both. Prominent examples in this category include cadmium and selenium. It is worthy of note,
however, that several such commodities are co-products. That is, their principal or sole source of
production is another, generally much larger mineral production operation. Consequently, while new
waste management controls (and their costs) might threaten the economic viability of production of these
commodities, they would generally not threaten the viability of the larger operation. This phenomenon is
critically important to evaluating potential impacts on a number of sectors projected to experience
significant cost/economic impacts in this analysis. Exhibit 3-10 displays the relationships between some of
these sectors and their larger associated commodity production operation(s).
April 30, 1998

-------
Exhibit 3-8
Option 1 Impacts (Value of Shipments Analysis)
1
Sector
Production
MT
Price
$/MT
Value of
Shipments
S
Incremental
Sector Cost
$
Economic Impact
(percent of Value of Shipments)
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.600.000
1.543
5.554.800.000
280.000
760.000
1.400.000
0 01
001
0.03
Antimony
_:(), I(X)
3 351
67.355.100

24,000
36.000
0.00
004
0.05
Beryllium
217
352.6-10
76.522.880
53.000
55.000
340.000
0 OK
0 07
044
Bismuth 4
1.100
7 9 57
8 730.700

14.000
25.000
0.00
0 16
0.29
Cjdinium
1.450
2.756
3 996,200

74.000
460.000
0.00
1 85
It 51
Calcium
1.KXJ
4.480
4 928.(HX)

9
9
0 00
0.00
0.00
Chromium 
4.8(X)
92.000
310.000
0.01
0 16
0.54
Rhenium
19
1,100.000
20.900.000

3.100
5,600
0.00
001
0.03
Scandium
25
1.400,000
35.000.000
-
(96.000)
42,(XX)
0 00
-0 27
0.12
Selenium
350
7.055
2 469.250
28.000
46,000
130, (XX)
1.13
I 86
5 26
Svnthctk; Rulilc
140,000
650
91.000.000

73.000
130.000
0.00
0 08
0.14
Tantiilum. Columbium. and Ferrocolumbium


95 777.210
|70,(XX)
170.000
170.000
0.18
0 18
0 IS
Telluiium
60
46,287
2.777.220

17.000
38.000
0.00
061
1 37
Titanium and Titanium Dioxide


UOV707.270
74,(XX)
230.000
370,000
0.00
001
0.01
Tuiijibien
8,449
49
414.001

25,000
34.000
0.00
* 6 04
8 21
Uranium
2.132
31.130
66.369.160

60.000
120.000
0.00
009
0.18
Zinc
620.(XX>
1.124
6%.880.000
2.900.000
.3,800,000
4.000.000
0.42
055
0.57
Zirconium and Hafnium


65.814.000

99.000
370.000
0.00
003
0.09
Total



1.200,000
10.000.000
14,000,000




-------
Exhibit 3-9
Option 2 Impacts (Value of Shipments Analysis)
o
vO
OO
Sector
Production
Mr
Price
$/MT
Value of
Shipments
$
Incremental
Sector Cost
$
Economic Impac
(percent of Value of Shi
t
pments)
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.600.000
1.543
5,554,800.000
13. (XX)
26,000
26,000
000
0.00
0.00
Antimony
20,100
3,351
67,155.100
-
6,800
6,800
0.00
0.01
0.01
Beryllium
217
352,640
76,522,880
570
2,800
2,800
000
0.00
0.00
Bismuth
1 100
7.937
8,/30/'00
-
5,600
5,000
0.00
0.06
0.06
C admium
1.450
2,756
3,996,200
-
12,000
12,000
0.00
0.30
0.30
Calcium
1,100
4,480
4,y28,000
-
9
9
0.00
0.00
0.00
Chromium and Pcnochroiniuin


39,000,000
570
580
580
0.00
0.00
0.00
Coal Gas


186,000,000
-
-
570
0.00
0.00
0.00
Copper
2,000,000
2,249
4,498,000,000
5,700
17,000
17,000
0.00
0.00
0.00
Llemental Phosphorus
311,000
2,756
857,116,000
4,500
4,500
4,500
0.00
0.00
0.00
Fluorspar and Hydrofluoric Acid
8.200
162
1.328.400
-
1,700
1.700
0.00
0.13
0.13
Germanium
18
2.000,000
36,000.000
-
13.000
13.000
0.00
0.04
0.04
Lead
340.000
1,076
365,840,000
3,400
6,900
6.900
0.00
0 00
0.00
Magnesium and Magnesia from Biines
143.000
3.858
551,694,000
1.100
1,700
1.700
0.00
0 00
0.00
Mercury
70
7.542
527.940

12,000
12.000
000
2.27
2.27
Molybdenum, Ferroniolybdenuin and
Ammonium Molybdate


427.500.000

7.300
7,300
0.00
0.00
0.00
Platinum Group Metals


42,792,580
-
5,100
5,100
0.00
0.01
0.01
Rare Earths
20.000
2.870
57,400,000
1,100
2,800
2,800
o.oo
0.00
0.00
Rhenium
19
1.100.000
20.900.000
-
2,300
2.300
0.00
0.01
0.01
Scandium
25
1.400.000
35,000.000
-
7,900
7,900
0.00
0.02
0.02
Selenium
350
7.055
2.469,250
1.100
7,900
7.900
0.04
0.32
0.32
Synthetic Rutile
140.000
650
91,000.000
-
590
590
0.00
0.00
0.00
Tantalum, Columbium, and
Perrocolumbium


95,727,210
1,100
3,400
3,400
0.00
0.00
0.00
Tellurium
w
46.287
2,777,220

3,400
3,400
0.00
0.12
0.12
Titanium and Titanium Dioxide


3.203,707,220
3,400
17.000
17,000
0.00
0.00
0.00
Tungsten
8,449
49
414,001
-
6,800
6,800
0.00
1.64
1.64
Uianium
2.132
31,130
66,369,160

38.000
38.000
0.00
0.06
0.06
Zinc
620.0(H)
1.124
696.8h0.000
5,100
10,000
10,000
0.00
0.00
0.00
Zirconium and Hafnium


365,814,000
-
4.500
4,500
0.00
0.00
0.00
Total



41,000
230.000
230,000



to

-------
Exhibit 3-10
Relationships Among Mineral Commodity Production Operations
Affected Commodity Sector
Primary Associated Commodity
Cadmium
Zinc
Mercury
Gold
Selenium
Copper
Antimony
Lead, silver/copper
Bismuth
Lead, copper/lead
Rhenium
Molybdenum
Tellurium
Copper
Ratio of Regulatory Costs to Value Added
Because value added is less than value of shipments, the ratio of regulatory costs to value added
will be higher than the ratio of regulatory costs to shipments. EPA obtained data on value added for
16 mineral industry sectors. Detailed results of the value-added impact analysis are presented in
Exhibit 3-11. For purposes of this analysis, EPA defined significant economic impacts as greater than
10 percent.
For Option 1, EPA anticipates that two of the 16 industry sectors (13 percent of the sectors
included in this analysis) will be significantly affected (cadmium and selenium). Cadmium is a co-product
of zinc production and selenium is a co-product of copper production; hence, these economic impacts are
expected primarily to affect the production of these co-products and the reclamation of their residuals
rather than the mineral processing operation as a whole. Because recovery is generally less expensive for
these co-product residuals than treatment and disposal, EPA believes that the costs for these residuals will
not significantly decrease their recovery (although the storage costs could add to the expense). Under
Option 2, none of the 16 sectors are expected to be significantly affected.
Ratio of Regulatory Costs to Earnings
Comparing regulatory costs to earnings allows one to estimate how the costs of regulations will
affect a company's bottom line. Incremental costs that exceed a company's or industry's earnings over an
extended period will result in facility closures and exit from the industry in question. HPA obtained
earnings data for 18 firms that collectively own 39 of the 126 facilities (3 1 percent) affected by the rule.
For an additional 53 facilities (42 percent), EPA was able to obtain estimated earnings data for a higher-
tier owner (i.e., a corporate parent). EPA then calculated the ratio of total annualized compliance costs as a
percentage of earnings for each of the firms owning affected facilities (and, separately, for the higher-tier
owners of affected facilities where necessary).
None of the firms analyzed are expected to incur severe impacts based on the cost-to-earnings
ratio. Under Option 1, only three firms are expected to incur costs in excess of even one percent of
earnings, and none of these is expected to exceed three percent of earnings. Under Option 2, no firms are
expected to incur costs of even one percent of earnings.
April 30, 1998

-------
Exhibit 3-11
Option 1 and 2 Impacts (Value Added Analysis)
Sector
Estimated
Value Added
$
Incremental Sector
Cost
$
Economic Impact
(Percent of Value
Added)
Option 1
Option 2
Option 1 Option 2
Alumina and Aluminum
2,874,500,000
760,000
26,000
0.0%
0.0%
Antimony
7.384,052
24,000
6,800
0.3%
0.1%
Beryllium
8.389,104
55,000
2,800
0.7%
0.0%
Bismuth
943.508
14,000
5,600
1.5%
0.6%
Cadmium
438.098
74,000
12,000
16.9%
2.7%
Copper
1,845,200.000
2,500,000
17,000
0.1%
0.0%
Germanium
3,946.633
22,000
13,000
0.6%
0.3%
Lead
40,106.565
830,000
6,900
2.1%
0.0%
Magnesium and Magnesia from Brines
60.481,498
2,600
1,700
0.0%
0.0%
Platinum Group Metals
4,691,295
5,400
5,100
0.1%
0.1%
Rhenium
2,291.240
3,100
2,300
0.1%
0.1%
Selenium
270,701
46,000
7,900
17.0%
2.9%
Tellurium
304,463
17,000
3,400
5.6%
1.1%
Titanium and Titanium Dioxide
351,218,272
230,000
17,000
0.1%
0.0%
Zinc
76,398,052
3,800,000
10,000
5.0%
0.0%
Zirconium and Hafnium
40,103,715
99,000
4,500
0.2%
0.0%
Total
5,316,667.197
8,482,100
142,000
0.2%
0.0%
Summary of Economic Impacts
EPA conducted four ratio analyses comparing regulatory costs to the following four financial
indicators: (I) firm-specific sales, (2) sector-specific value of shipments, (3) sector-specific value added,
and (4) firm-specific earnings. The results of this analysis are summarized in Exhibit 3-12 and discussed
below:
Option 1
	Based on the two firm-specific ratios (cost/sales and cost/earnings), no significant
economic impacts are expected to result from Option 1.
	Based on cost as a percentage of value of shipments, three of the 29 sectors (10
~ percent sectors) are expected to incur significant impacts under Option 1.
Significantly affected sectors are projected to include mercury (36 percent
impact), tungsten (6 percent), and fluorspar/hydrofluoric acid (4 percent).
April 30, 1998

-------
-27 -
Exhibit 3-12
Summary of Economic Impact Screening Results:
Impact Measure
Percent of Firms or Sectors w/ Significant Impacts
Option 1
Option 2
Cost/Sales
0% of firms
0% of firms
Cost/Earnings
0% of firms
07c of firms
Cost/Value of Shipments
10% of sectors
0% of sectors
Cost/Value Added
13 % of sectors
0% of sectors
	Based on cost as a percentage of value added, two of the 16 sectors (13 percent)
are expected to be significantly affected under Option 1 (cadmium and selenium).
Option 2
	Option 2 is not expected to result in significant impacts under any of the four
measures.
The divergence between the Option 1 results based on the firm-specific measures (particularly
cost/sales) and those based on the sector-spccific measures could result from diversified operations of
affected firms. In this case, it is possible that significant impacts might occur at the facility level even if
they do not lead to significant impacts at the firm level (i.e., due to the firm's additional operations besides
those in affected mineral processing sectors).
3.3 Regulatory Flexibility Analysis
This section describes EPA's initial assessment of the small business impacts expected to be
incurred by mineral processing firms as a result of the Phase IV Land Disposal Restrictions (LI.)Rs).
Approximately 20 small businesses owning approximately 22 facilities may be affected by the rule. The
first subsection describes the methodology used in conducting the analysis. The second subsection
presents the results of the analysis. In brief, the analysis concludes that no significant small business
impacts are anticipated as a result of either option and, therefore, preparation of a formal Regulatory
Flexibility Analysis is unnecessary.
3.3.1 Methodology
An initial assessment of small business impacts involves four major tasks: (1) defining "small
entities" for the rule being analyzed, (2) determining what number constitutes a "substantial number" of
these entities, (3) determining how "significant impacts" will be measured, and (4) completing a screening
analysis. If the initial assessment determines that a substantial number of small entities may face
significant impacts as a result of the rale being analyzed, then a formal Regulatory Flexibility Analysis may
be required.
April 30, 1998

-------
Defining "Small Entities" Affected by the Rule
The Phase IV LDRs will affect those mineral processing entities that currently (i.e., prior to the
rule) generate hazardous waste. For purposes of this analysis, "small entity" refers to any such mineral
processing business concern that has 750 or fewer employees including itself and all of its domestic and
foreign affiliates (1000 or fewer employees for entities in the copper and aluminum sectors). This
definition is consistent with the size standards established by the Small Business Administration (SBA) in
13 CFR Sections 121.103 and 121.201 on January 31, 1996 and as reprinted by SBA on January 7, 1998
(63 Federal Register 902). EPA docs not believe that other types of small entities, such as non-profit
organizations or local governments, will be affected by the application of Phase IV LDRs to mineral
processing activities.
Determining What Number Constitutes a Substantial Number
This initial assessment applies a figure corresponding to 20 percent of small entities in determining
whether a "substantial number" of small entities are likely to be impacted by the rule. For sensitivity
analysis purposes, EPA has also applied an alternate figure corresponding to five percent of small entities.
Measuring "Significant Impacts"
To evaluate the impact that a small entity is expected to incur as a result of the rule, this analysis
calculates the entity's ratio of annualized compliance costs as a percentage of sales. Entities are classified
as facing potentially "significant" impacts if this ratio exceeds three percent. For sensitivity analysis
purposes, EPA has also applied an alternate figure of one percent.
Conducting the Screening Analysis
The final task of the initial assessment is to conduct the screening analysis and determine whether,
using the criteria established above, the rule is expected to result in significant impacts on a substantial
number of small entities. The screening analysis involves four steps:
(1) Identify Facilities Generating Hazardous Mineral Processing Waste. EPA
compiled a list of the facilities generating hazardous mineral processing waste
based on information contained in the technical background document
Identification and Description of Mineral Processing Sectors and Waste Streams,
U.S. EPA Office of Solid Waste, December 1997, and on information obtained
from public comments on the proposed rule. Where uncertainty existed regarding
whether certain facilities currently generate hazardous mineral processing waste.
EPA included the facility in this analysis to avoid understating impacts (even if
doing so meant exceeding the number of facilities estimated in the cost model).
April 30, 1998

-------
(2)	Obtain Employee And Sales Data For The Business Concerns Owning Each
Facility. Using the list of facilities developed in the preceding step, EPA
researched the number of employees and total sales for each business concern
owning one or more facility. (As noted earlier, a "business concern" includes not
only the company owning a given facility, but all of its domestic and foreign
affiliates.) The Agency obtained data from a variety of public and commercial
sources. Based on these data, approximately 20 small businesses owning
approximately 22 facilities may be affected by the rulemaking.
(3)	Obtain Compliance Cost Data For F.ach Small Business Concern. For each
facility owned by a small business concern, EPA applied its most current estimate
for the "average" sector-specific facility cost, in the expected value case, of
complying with Option 1 and Option 2 under the assumed modified prior
treatment baseline. In the few cases where a small business concern owns
multiple facilities, EPA added the compliance costs for the individual facilities to
obtain a total compliance cost for the small business owner. For example, if one
company owns two facilities, the costs of these facilities are added together to
determine the total compliance cost to the company.
(4)	Compute Small Business Impacts. Finally, using the data obtained in the
preceding steps, EPA calculated each small business concern's ratio of total
annualized compliance costs as a percentage of sales. EPA then compared the
ratios to the threshold value for significant impacts of three percent, and to the
sensitivity threshold of one percent.
3.3.2 Results
As described above, EPA examined the potential for small business impacts by comparing, for
each small business, the total annualized compliance costs as a percentage of sales. Approximately
20 small businesses owning approximately 22 facilities may be affected hv the rule. These facilities fall
into the following sectors: alumina/aluminum, antimony, cadmium, chromium, coal gas, germanium,
fluorspar/hydrofluoric acid, molybdenum/ferromolybdeiuim/ammonium molybdate, platinum group
metals, scandium, tungsten, and/or /inc. EPA's analysis finds that neither Option 1 nor Option 2 would
result in a significant impact on a substantial number of small mineral processing entities. In fact the
options are unlikely to result in a significant impact on any small mineral processing entities, and some
small business owners would incur cost savings under Option 1. Two possible - but unlikely - exceptions
to this finding arise as a result of data limitations. Because this analysis was unable to obtain sales data for
certain small businesses, the analysis could not directly estimate impacts on these companies.
Nevertheless, significant impacts on these businesses arc unlikely, as discussed below:
	One company processing hydrofluoric acid is expected to incur annual costs of
~ only $16,000 under Option 1 or $570 under Option 2. Therefore, this company
will not incur significant impacts under Option 1 unless it has sales of less than
$533,333 (i.e., $16,000/0.03) or, using the alternate threshold of one percent,
sales of less than $1,600,000 (i.e., $16,000/0.01). Under Option 2, the company
will not incur significant impacts unless it has sales of less than $19,000 (or
$57,000 using the alternate threshold of one percent). Because higher sales can
April 30, 1998

-------
be expected of a sustained business venture conducting mineral processing,19 EPA
believes that this small business will not incur significant impacts.
 Similarly, the analysis does not address small business concerns that may own one
or more of the 17 facilities in the uranium sector. The average annual cost to such
facilities is $3,500 under Option 1 and $2,300 under Option 2. Thus, if any of the
17 facilities are owned by small business concerns, significant small business
impacts would arise under Option 1 only for those concerns with sales of less
than SI 16,667 (i.e., $3,500/0.03) or, using the alternate threshold of one percent,
less than S350,000 (i.e., $3,500/0.01).20 Under Option 2, significant impacts
would arise only for those concerns with sales of less than 576,667 or, using the
alternate threshold of one percent, less than $230,000. Assuming the total sales of
a small business owning a uranium processing facility are at all close to the
average sales figure (over $90 million) for all other small businesses in the
analysis, then no impacts arise in the uranium sector under either option or
threshold.
Even in the unlikely event that any company incurs significant impacts under the scenarios
described above, the rule would not generate significant impacts on a substantial number of small
businesses unless 20 percent or more of small mineral processing firms (five percent or more under the
alternative threshold for "substantial number") incur significant impacts. This corresponds to four entities
(one under the alternative threshold), and seems highly unlikely.
It is worth noting that actual impacts may be even less than estimated above because the facilities
owned by small business concerns may incur smaller than average compliance costs. This could
reasonably occur if small business concerns tend to own smaller than average facilities.
3.4 Media Contaminated with Manufactured Gas Plant Wastes
In addition to the newly identified mineral processing wastes, today's rule will also affect the
remediation of media contaminated with manufactured gas plant (MGP) waste. MGPs produced gasified
coal for lighting prior to the development of natural gas pipelines, and closed in response to natural gas
pipelines in the 1950 s. During MGP operation, soils, sediments, and groundwater often became
contaminated from coal tars generated during the gasification process. Despite relatively high
concentrations of hazardous constituents in the tars, EPA estimates that only about 15 percent of the
contaminated media fail the TC for benzene. The media also commonly contains elevated levels of
volatile organics. monocyclic aromatic hydrocarbons and polycyclic aromatic hydrocarbons.
Today's rule establishes treatment standards for media contaminated with MGP waste because
MGP waste is a newly identified mineral processing waste. Therefore, hazardous contaminated media
must meet UTS levels both for constituents present in concentrations at or greater than TC levels and for
underlying hazardous constituents (UHCs).21 However, today's rule includes a provision ("the alternative
19	For example, the average sales figure among all other small businesses in the analysis exceeds $90
million.
20	This assumes that only one uranium processing facility is owned per small business concern.
21	UIICs are hazardous constituents present in concentrations higher than UTS, but below TC levels.
April 30, 1998

-------
treatment standard") that will allow contaminated media to be treated to either a 90 percent reduction of
initial concentration or 10 times the UTS, whichever is greater, provided the media is not used in a manner
constituting disposal. As a result, there arc two practical ways that remediation of contaminated media
could be affected by today's rule: (1) cases where the baseline treatment method does not lower
contaminant concentrations below applicable treatment levels, or (2) if baseline treatment consists of
decharacterizing the media using dilution, which is prohibited by general LDR requirements.22 EPA
analyzed the costs of today's rulemaking on media contaminated with MGP waste, and believes that only
the second category will be affected. The remainder of this section summarizes the methodology used to
determine the MGP-related costs of today's rulemaking and presents the results of this analysis.23
EPA began the process of estimating the MGP-related costs of today's rule by estimating the
number of sites where remediation will occur (or is presently occurring) and the total quantity of hazardous
media to be remediated. The Agency then calculated the quantity and cost of hazardous media being
treated in the baseline for each of four treatment categories: (1) co-burning; (2) ex-situ thermal
treatment/bioremediation; (3) use constituting disposal; and (4) in-situ stabilization/treatment. Next, the
Agency determined that the only affected treatment category is the use constituting disposal category
because the other treatment categories reduce contaminant concentrations by at least 90 percent, and do not
involve dilution. Consequently, EPA modeled shifts from this category to other treatment methods as well
as to a "no cleanup" option in order to arrive at post-rule treatment quantities and total costs. EPA then
subtracted the baseline costs from the post-rule costs to obtain a total incremental cost. Finally, EPA
calculated the total annual incremental cost, assuming that it will take one year to clean up any given site,
20 years to complete all cleanups, and an equal number of sites will be cleaned up each year.
For purpo*es of this analysis, the Agency has grouped potentially affected former manufactured
gas plant sites into two broad categories: commercial sites and captive sites. Commercial sites are those
sites where historic utility companies manufactured gas for use in lighting and heating applications in cities
and towns. Many of these sites are owned by present-day utility companies. The Agency estimates that
there are 2,500 potentially affected commercial MGP sites in the United States. Captive sites comprise a
larger universe of former manufactured gas plant operations used at rail yards, military outposts,
institutions, large residences, coke works, and tar distilleries. EPA estimates that there are 28,700
potentially affected captive former MGP sites in the United States. Industry representatives estimate that
between 500-5,000 tons of RCRA hazardous contaminated media are likely to be found at former MGP
sites. This analysis assumes that commercial sites (which are, in general, larger than captive sites) contain
5,000 tons of hazardous contaminated media, while captive sites contain 500 tons of hazardous
contaminated media. Applying these quantity estimates to the estimates of potentially affected facilities,
EPA estimates that 12,500,000 tons (2,500 sites x 5,000 tons) of hazardous contaminated media will be
remediated at commercial sites, and 14,350,000 tons (28,700 sites x 500 tons) of hazardous contaminated
media will be remediated at captive sites.
Contamination at former MGP sites is generally remediated using a combination of treatment
methods. Through a review of available literature and personal communication with utility industry
representatives.'the Agency has concluded that, in general, ex-situ remediation is more common than in-
22	"Co-burning," which consists of blending (i.e., diluting) hazardous media with other suitable
combustible media followed by burning in a utility boiler, is not affected by these LDRs.
23	A detailed presentation of the underlying data and methodology used to arrive at these conclusions
is outlined in a memorandum to Paul Borst, EPA, from ICF Incorporated, entitled Cost of the Phase IV
Land Disposal Restrictions on Manufactured Gas Plant Wastes, dated January 28, 1998.
April 30, 1998

-------
-32-
situ remediation. Therefore, this analysis assumes that 75 percent of the total quantity of hazardous
contaminated media will be remediated using ex-situ remediation methods, and 25 percent of the total
quantity will be remediated using in-situ remediation methods. The analysis further divides the ex-situ
remediation quantities into three treatment categories:
	Co-Burning of Wastes in Utility Boilers (Co-Burning);
	Ex-Situ Thermal Treatment/Bioremediation (Ex-Situ TB); and
	Use Constituting Disposal (UCD).
The relative percentages and quantities for which each treatment category is used in full scale
remediation efforts are estimated as follows:
Co-Burning:	40 percent (10,740,000 tons)
Ex-Situ TB:	30 percent (8,055,000 tons)
UCD:	5 percent (1,342,500 tons)
In-Situ ST:	25 percent (6,712,500 tons)
EPA has determined that the only treatment category affected by today's rulemaking is the use
constituting disposal (UCD) category.24 Therefore, the Agency estimated shifts in treatment category for
the quantity of waste originally (i.e., in the baseline) treated using UCD (five percent of the total volume).
Site managers may choose to switch to another treatment category or may opt not to clean up at all.
Because most former MGP sites are cleaned up on a voluntary basis, this analysis has estimated that only
10 percent of the baseline UCD quantity will not be cleaned up.25 The Agency believes that no quantity of
material will shift from UCD to co-burning post-rule because a site manager would have likely chosen the
co-burning option in the baseline if that option were available. Therefore, the Agency split the remaining
90 percent of the baseline UCD quantity between Ex-Situ TB and In-Situ ST based on the overall 75/25
split between ex-situ and in-situ remediation methods. The post-rule shifts from UCD are summarized as
follows:
	Quantity not cleaned up: 1,342,500 tons x 0.10 = 134,250 tons
	Quantity shifted to Ex-Situ TB: 1,342,500 tons x 0.75(0.90) = 906,188 tons
	Quantity shifted to In-Situ ST: 1,342,500 tons x 0.25(0.90) = 302.062 tons
. Given these shifts and the relative use percentages outlined above, EPA calculated quantities of
hazardous contaminated media treated in the baseline and post-rule for each treatment category. Exhibit 3-
13 summarizes this information.
24	Uses constituting disposal include asphalt, brick, and cement manufacturing. Because asphalt,
brick, and some cement manufacturers are not RCRA-permitted facilities, baseline practice is assumed to
consist of diluting the media to remove the characteristic and then using the decharacterized media in the
production of asphalt, brick, or cement. After the effective date of the Phase IV LDRs, dilution will be
prohibited and, as a result, these uses constituting disposal will be discontinued. RCRA hazardous
contaminated media sent directly to a RCRA-permitted cement manufacturer without decharacterization
will be unaffected, however, and is not counted in the UCD category of this analysis.
25	Most MGP sites are remediated voluntarily, because a facility owner is selling the property or
wishes to lower risk levels, although some clean-ups occur under federal or state mandate.
April 30, 1998

-------
-33 -
Exhibit 3-13
Baseline and Post-Rule Treatment Quantities
Facility
Category
No. of
Sites
Haz.
Waste
Tons/Site
Haz.
Waste
Total
Tons
Baseline
Post-Rule
Tons
UCD
Tons
Not Rem.
Tons
Ex-Situ
Tons
In-Situ
Commercial
2,500
5,000
12.500,000
630,000
63,000
420,000
140,000
Captive
28.700
500
14,350,000
720,000
72,000
480,000
160,000
The Agency also collected information on the unit treatment costs of each treatment method and
calculated an average treatment cost for each treatment category. The average treatment cost for each
treatment category are as follows:
	Co-Burning: $135/ton
	Ex-Situ TB: $235/ton
	UCD:	$80/ton
	In-Situ ST: $61 /ton
Using these average treatment costs, the Agency calculated total baseline and post-rule costs.
Total baseline UCD costs and post-rule costs shifted to ex-situ and in-situ remediation are shown in
Exhibit 3-14.
Exhibit 3-14
Baseline and Post-Rule Treatment Costs
Facility
Category
No. of
Sites
Haz.
Waste
Tons/Site
Haz. Waste
Total Ions
Baseline
Post-Rule
$
UCD
$
Not
Rem.
$
Ex-Situ
$
In-Situ
Commercial
.2,500
5,000
12,500,000
50,000.000
-
99,000,000
8,500,000
Captive
28,700
500
14,350.000
58,000,000
-
114.000.000
9,800,000
To determine the incremental cost associated with today's rulemaking, EPA subtracted the
baseline UCD cost from the post-rule cost to arrive at a total incremental cost of $58,000,000 for
commercial sites, and $66,000,000 for captive sites.
The analysis assumes that it takes approximately one year to clean up any given site where media
contaminated with manufactured gas plant wastes exists, that it will take approximately 20 years to clean
up all of the sites in the U.S., and that an equal number of sites are cleaned up each year. Therefore, the
total annual incremental cost of today's rulemaking is assumed constant over a period of 20 years. EPA
divided the total incremental costs of today's rulemaking by the number of commercial and captive
facilities to arrive at an incremental cost per facility. Because of uncertainty regarding how the media used
April 30, 1998

-------
in a manner constituting disposal is distributed among the 31,200 sites, EPA modeled two scenarios to
determine the highest and lowest possible incremental costs and impacts. Scenario 1 assumes that five
percent of the contaminated media at all sites would be affected. In other words, the total amount of
hazardous media used in a manner constituting disposal is assumed to be evenly distributed across all
potentially affected sites but makes up only a small percentage of contaminated media at each site.
Scenario 2 assumes that the total amount of hazardous media used in a manner constituting disposal is
distributed across only five percent of MGP sites or, in other words, that only a small percentage of sites
are affected, but all contaminated media at these sites is used in a manner constituting disposal. Exhibit 3-
15 shows these incremental costs.
Exhibit 3-15
Incremental Costs of Today's Rulemaking for Sites with Media
Contaminated with MGP Wastes
MGP Sites
Total
Incremental
Cost
Scenario 1
Scenario 2
Affected
Sites
Incremental
Cost per Site
Affected
Sites
Incremental
Cost per Site
Commercial
$58,000,000
2,500
523,200
125
$464,000
Captive
$66,000,000
28.700
S2.300
1,435
$46,000
Total
$124,000,000
31,200

1,560
-
To evaluate the potential impacts of these costs, EPA researched the sector-specific annual revenue
or value of shipments and the number of firms for the various SIC codes comprising commercial sites and
three of the four categories of captive sites (excluding domestic and residential gas machines, which are
discussed later). Figures for revenue or value of shipments per sector were then divided by the number of
firms in the sector to calculate the average annual revenue or value of shipments per site, as shown in
Exhibit 3-16.
For these categories, the Agency assessed the impacts of the costs by evaluating the ratio of annual
compliance costs as a percentage of revenue or value added. The resulting impacts, under both Scenario
One and Scenario Two, are estimated to be below EPA's three percent threshold level for all SIC
categories, as shown in Exhibit 3-17. Impacts on owners of domestic and residential gas machines
(believed to be located mansions and other large homes) were assessed indirectly. Under Scenario One,
this class of captive owner will incur significant impacts only it household income is less than $76^667
(i.e., $2,300/0.03). This figure corresponds approximately to the 80th percentile for U.S. household
income. Because mansions and other large homes with domestic or residential gas machines are likely to
be owned by only the very highest-income households, significant impacts are unlikely for this category as
well. Under Scenario Two, however, impacts on owners of residential gas machines are avoided only to
the extent that household income exceeds .$ 1,527,767 (i.e., S45,833/0.03). Data addressing household
incomes at this level are not readily available. Therefore, it is possible (and perhaps likely) that some
mansions and other large homes are owned by households having household incomes lower than
SI,527,767. Because cleanups for these entities are likely to be voluntary, however, owners are unlikely to
conduct the cleanups if doing so would result in significant impacts. Consequently, any impact due to
today's rule is unlikely, even for owners of domestic and residential gas machines under Scenario Two.
April 30, 1998

-------
-35 -
Exhibit 3-16
Revenues and Value of Shipments by SIC Code
VIGP Sites
SIC Code
Number of
Firms
Total Annual
Revenue or
Value of Shipments
Average
Revenue or
Value of
Shipments
Commercial
Jtilities (Revenues)26
Electric and Gas Services
491,2,3
11,156
5292,030,897,000
$26,177,026
Captive
institutional Gas Machines (Revenues)27
Hotels and Motels
7011
41,684
$67,192,806,000
$1,611,957
Hospitals
8062, 9063,
8069
1,403
$28,812,975,000
$20,536,689
jas Producers28
Paper anil allied products
26
4,264
SI 33,200,700,(KX)
$31,238,438
Chemicals and allied products
28
8,312
$305,420,100,(MX)
$36,744,478
Petroleum and coal products
29
1,109
$149,423,800,000
$134,737,421
Rubber and Miscellaneous plastic
products
30
13,142
$113,592,800,000
$8,643,494
Primary Metal Products
33
5,294
$138,287,000,000
$26,121,458
Fabricated Metal Products
34
32.959
$166,532,000,000
$5,052,702
Industrial Machinery and F.quipments
35
50.911
$258,661,400,000
$5,080,658
Transportation equipment
37
9,X78
$399,269,300,000
$40,420,055
Misc. manufacturing industries
39
16.564
S39,498,300,000
$2,384,587
Beehive Cuke Works31'
Petroleum and Coal Products
?,999
m
$841100 000
SI 2.218.841
2f' Revenue data from U.S. Department of Commerce, Bureau of Census. 1992 Census of
Transportation and Public Utilities. Summary Statistics for the United States and States. Table 1, p 8.
21 Revenue data from U.S. Department of Commerce, Bureau of Census. 1992 Census of Services.
Major Sources of Receipts From Customers for the United States and States. Table 2 and 47.
Value of shipments data from U.S. Department of Commerce, Bureau of Census. 1992 Census of
Manufacturing. Summary of Findings: Selected Statistics with Major Groups Ranked by Value Added.
Table A.
25 Value of shipments data from U.S. Department of Commerce, Bureau of Census. 1992 Census of
Manufacturing. Statistics for Industry Groups and Industries: 1992 and Earlier. Table 1-lb.
April 30, 1998

-------
-36-
Exhibit 3-17
Impacts of Rule on Categories
MGP Sites
SIC
Code
Average
Revenue or
Value of
Shipments
Scenario 1
Scenario 2
Avg Cost /
Category
Economic
Impact
Avg Cost /
Category
Economic
Impact
Commercial
Jti lilies
Electric and Gas Services 491, 2, 3
$26,177,026 $23,200 0.09% $464,000 1.877%
Captive
institutional Gas Machines
Hotels and Motels
7011
$1,611,957
$2,300
0.14%
$46,000
2.85%
Hospitals
8062,
9063,
8069
$20,536,689
$2,300
0.01%
$46,000
0.22%
"ias Producers
Paper and allied products
26
$31,238,438
$2,300
0.01%
$46,000
0.15%
Chemicals and allied
products
28
$36,744,478
$2,300
0.01%
$46,000
0.13%
Petroleum and coal
product*
29
$134,737,421
$2,300
0.00%
$46,000
0.03%
Rubber and Miscellaneous
plastic products
30
$8,643,494
$2,300
0.03%
$46,000
0.53%
Primary Metal Products
33
$26,121,458
$2,300
0 01%
$46,000
0.18%
Fabricated Metal Products
34
$5,052,702
$2,300
005%
$46,000
0.91%
Industrial Machinery and
Equipments
35
$5,080,658
$2,300
0.05%
$46,000
0.91%
Transportation equipment
37
$40,420,055
$2,300
0.01%
$46,000
0.11%
Misc. manufacturing
industries
39
S2,384,587
$2,300
0.10%
$46,000
1.93%
ieehivc Coke Works
Petroleum and Coal
Products
2999
$12,218,841
$2,300
0.02%
$46,000
0.38% '
3.5 Class I UIC Wells
Results-of the capacity analysis (conducted under a different work assignment) indicate that there
are only two facilities injecting newly identified mineral processing wastes into Class 1 UIC wells that
might he affected by the Phase IV LDRs. Both of these facilities are owned by the same firm.
Other facilities inject newly identified mineral processing waste but are unaffected either because
the facility has an approved no migration petition for its well or because the facility's waste has been
decharacterized and meets the requirements of the Land Disposal Program Flexibility Act.
April 30, 1998

-------
One of the two potentially affected facilities is in the process of building a treatment plant to
comply with a consent order to cease injecting in its wells by July 1998.10 The cost of the treatment system
is a result of the consent order, and therefore, is not attributable to the Phase IV LDRs.
The firms other facility has submitted a no migration petition to continue injecting its waste
without treatment. It is unclear whether the petition will be approved. If the petition is rejected, the
company could attempt to modify and resubmit the petition or it could build a treatment system. As a
result, EPA has developed three cost estimates:
	The minimum cost estimate assumes that the petition is approved arid that there are no
costs attributable to the rulemaking.
	The intermediate cost estimate assumes that the petition will be rejected initially and be
resubmitted for approval. The revised petition is assumed to have an 86 percent chance of
approval and a 14 percent chance of being rejected/' Thus, the intermediate cost equals
the sum of the cost of modifying a no migration petition plus 14 percent of the cost of
building a treatment system (i.e., the expected value cost).
	The maximum cost estimate assumes that the original petition would be rejected and the
facility would incur the cost of building the treatment system on-site.
The analysis assumes the up-front cost of modifying a no migration petition is $98,000,32 which is
equivalent to an annualized cost of $9,250 over 20 years, assuming a 7 percent interest rate. To calculate
the cost of building a treatment system, the facility's reported flow rate in gallons per minute was
converted to metric tons per year. EPA then applied the cost equations used earlier in this RIA to estimate
the annualized treatment cost to build and operate a treatment system. Application of the assumptions
outlined above results in an estimated minimum cost of SO, an intermediate annualized cost of S.530,000,
and a maximum annualized cost of 53,700,000.
To determine if these additional costs would significantly impact the owner of the facility, these
costs were then added to the other costs to the facility as previously estimated in this RIA. The Agency
then calculated revised firm specific ratios (cost/sales and cost/earnings) for the minimum, intermediate,
and maximum cost estimates, and compared these ratios to the threshold value for significant impacts of
three percent. No significant impacts are expected under either indicator.
30 It appears that the wells are screened into a drinking water source, which is impermissible under
the UIC program. While the company disputes this finding, it signed a consent order to avoid litigation.
'' Analysis of the Effects of EPA Restrictions on the Deep Well Injection of Hazardous Waste, US
F.PA, Office of Ground Water and Drinking Water, EPA 570/9-91-031, October 1991.
32 Regulatory Impact Analysis of Proposed Hazardous Waste Disposal Restrictions for Class I
Injection of Phase III Wastes (p. 3-2).
April 30, 1998

-------
4. BENEFITS ASSESSMENT
The potential human health and ecological benefits of the proposed LDRs for mineral processing
arise from reduced releases of toxic waste constituents to the environment as a result of regulatory controls.
These reductions in release translate into reduced exposures and reduced risks to human health and
ecological receptors. This section describes the approaches that have been taken to evaluating risks to
human health and the environment associated with waste disposal and with storage of recycled materials.
A conservative generic risks assessment methodology was first used to assess potential health risks
associated with groundwater and non-groundwater exposure pathways, and to identify potential high-risk
mineral processing waste streams and facilities. Reductions in potential risks that may be associated with
improved controls on the storage of recycled mineral processing streams were also calculated. Finally,
EPA gathered site-specific data regarding a group of facilities which generate and manage the potential
high-risk streams, and identified specific concerns associated with land management units, exposed
populations, potential exposure pathways, and documented instances of environmental contamination.
4.1 Risk and Benefits Assessments Methodologies
4.1.1 Overview of Risk and Benefits Assessment Activities
In developing this RIA, a number of efforts have been undertaken to evaluate the risks associated
with mineral processing wastes disposal and storage and to assess the health benefits associated with
changes in management practices under the proposed LDRs. These efforts have evolved in parallel,with
changes in the definitions of the baseline assumptions and with changes in the regulatory options that have
occurred during the regulatory development process. Much of the work done early in the development of
the rule analyzes baseline assumptions and regulatory options that are to some degree different from those
currently being considered. Most significantly, the initial focus of the risk and benefit assessment was the
no prior treatment baseline, and changes in risk associated with waste disposal. As the regulatory
development process progressed, however, the focus shifted to measuring the benefits of changes in
storage practices for recycled materials assuming the modified prior treatment baseline.
All of the quantitative risk methodologies described below employ conservative generic
methodologies, and do not provide definitive information about population health risks or risk reduction
benefits for actual exposed populations. The generic level methodologies are not site-specific, and they
employ proxy assumptions about facility characteristics, exposure pathways, receptors, and receptor
behavior as a substitute for site-specific data. Exposed populations living near actual mineral processing
facilities were not at first identified or enumerated, and the applicability of the various exposure pathways
that are evaluated to these populations was not verified. Cancer risks and noncancer hazards arc calculated
for hypothetical individuals under the generic exposure conditions. The specific assumptions used in the
risk assessment have been derived by EPA in the course of numerous regulatory analyses under RCRA,
and they are generally considered to provide conservative, but plausible estimates of individual exposures
and risks.
In keeping with the most current regulatory guidance, the Agency has explored the possibility of
performing site-specific quantitative risk analyses for those facilities identified as generating high-risk
wastes. As will be discussed in Section 4.3, however, the Agency concluded that the available data could
not support such an analysis, and qualitative descriptions of potential risks at these facilities were
developed instead.
April 30, 1998

-------
Generic Risk und Benefits Assessment for the Waste Disposal
The initial risk assessment effort involved the development of risk and risk reduction estimates for
the wasted (unrecycled) portions of the mineral processing waste streams, measured against the no prior
treatment baseline. The assessment was limited to health risks arising from groundwater exposures. In
this initial analysis, groundwater exposure concentrations were calculated using dilution-attenuation factor
values (DAFs) derived by EPA for use in previous regulatory analyses. The DAFs were based solely on
unit characteristics, and did not take into account the geochemical properties of the waste constituents.
Risks were calculated using mean constituent concentrations estimated for each waste stream, and benefits
were estimated in terms of "facility-waste stream combinations" the numbers of facilities at which given
risk reductions would be achieved through imposition of the LDRs. The results of this assessment were
summarized in the December 1995 Draft Mineral Processing LDRs RLA.
Subsequent to the October 1995 RIA, EPA conducted sensitivity analyses to better evaluate
potential sources of uncertainty in the risk and benefits assessment for the RIA. As a result of this analysis,
the risk and benefits assessment were revised, using constituent concentrations from individual waste
samples, instead of mean values, to calculate risks. As in the previous effort, the benefits were calculated
relative to the no prior treatment baseline. This analysis was also presented in the December 1995 Draft
RIA.
For the final analysis of the potential risks associated with the disposal of mineral processing
wastes, fiPA employed DAF values that were derived specifically for waste management units from the
mineral processing industry and which took into account differences in geochemical properties of the waste
constituents. Except for this, this assessment was identical to that described in the previous paragraph, and
evaluated benefits from changes in waste disposal relative to the no prior treatment baseline. The methods
used and results are described in detail in Appendices A.2 and A.3 of this RIA.
Generic Risk Assessment for the Storage of Recycled Streams
As noted above, as the regulatory development process has progressed it has become clear that the
major potential risk reduction for the regulatory options currently under consideration are those associated
with improvements in the storage of recycled materials. The analysis described in Section 4.2 therefore
focuses on the recycled streams, and on the risks associated with storage, rather than only with the disposal
of the wasted portions of the streams. In this effort, KPA has assessed health risks both for groundwater
exposure, as in the previous analysis, and for non-groundwater direct and indirect exposure pathways.
Risks are assessed for 14 waste streams that EPA has identified as being recycled and for which
constituent concentration data were available. These 14 streams account for 40 percent of the total mineral
processing waste generation, and for about 65 percent of the recycled volume. EPA derived groundwater
DAF values specifically for land-based recycling units, and specifically for each waste constituent. EPA
assessed non-groundwatcr risks associated with the storage of recycled materials using methods generally
similar to those'used to derive the proposed Exit Concentrations under the Hazardous Waste Identification
Rule. These methods are described in detail in Appendix J.
No quantitative benefits assessment has been performed for the stored materials. This is because,
under regulatory Option 1, recycled materials would be stored in tanks, containers, or buildings (TCBs) or
in limited cases, on approved pads, and no data or satisfactory models are available which would allow the
estimation of risks associated with these management units. Under Option 2, it is assumed that recycled
materials would be stored in land-based units, and no health benefits from improved storage would be
realized relative to the baseline.
April 30, 1998

-------
-40-
Thus, for recycled materials management, EPA has estimated only potential baseline risks. These
potential risks represent upper-bound estimates of the achievable health benefits if releases to the
environment are completely abolished under the regulatory options under the modified prior treatment
baseline.
4.1.2 Risk and Benefits Assessment Methods for the Storage of Recycled Materials
As discussed in Section 4.1.1, a generic risk assessment has been performed for the storage of
recycled materials under the modified prior treatment baseline. Under this baseline, (as under the no prior
treatment baseline), all recycled streams are assumed to be stored in unlined land storage units prior to
recycling. Streams were included in the analysis if EPA identified them as having non-zero recycled
volumes under the "expected" cost scenario. Liquid waste streams were eliminated from the risk
assessment if the estimated annual recycled volume was so low (less than 500 tons per year) that storage in
land units would not be cost-effective. Based on these criteria, 14 streams were included in the risk
assessment for stored materials, as shown in Exhibit 4-1. The waste constituent data used as inputs to this
analysis are found in Appendix K.
Exhibit 4-1
Recycled Streams Included in the Storage Risk Analysis
Commodity
Recycled Stream
Aluminum and Alumina
Cast House Dust
Beryllium
Chip Treatment Wastewater
Beryllium
Spent Barren Filtrate
Copper
Acid Plant Slowdown
Elemental Phosphorus
Furnace Scrubber Blowdown
Rare Earths
Process Wastewater
Selenium
Plant Process Wastewater
Tantalum, Columbium, and Fcrrocolumbium
Process Wastewater
Titanium and Titanium Oxide
Lcach Liquor and Sponge Wastewater
Titanium and Titanium Oxide
Scrap Milling Scrubber Water
Zinc
Waste Ferrosilicon
Zinc
Spent Surface Impoundment Liquids
Zinc
Waste Water Treatment Plant Liquid Effluent
Zinc
Process Wastewater
All but two of these streams are wastewaters (WW) or liquid nonwastewaters (LNWW), lor which
the least-cost management unit is a surface impoundment. The remaining two streams (aluminum cast
house dust and zinc waste ferrosilicon) are nonwastewaters (NWW), for which the least-cost management
unit is a waste pile.
April 30, 1998

-------
Constituent concentration data were available from a total of 191 samples from the recycled
materials, only three of which are of the two NWW streams, with the remainder representing WW and
LNWW streams. Among these, 148 were bulk analytical results, and 42 were HP extraction analysis. Of
the available samples, 138 had concentration data for constituents having toxicity criteria values that could
be used in quantitative risk assessment. Again, three of the samples were from NWW streams. The data
used to derive constituent-specific DAFs for stored recycled streams are summarized in Appendix K.
Although storage risks were calculated for only 14 of the 121 total mineral processing waste
streams (due to a lack of constituents concentration data for the remaining streams), these streams represent
a substantial proportion of the total generated wastes and an even higher proportion of the recycled wastes.
Depending on which estimate of waste generation is used (minimum, expected, or maximum), the 14
recycled streams included in the risk analysis represent between approximately 32 and 42 percent of the
total waste generation, and account for between 57 and 68 percent of the total recycled volume. This is
because constituent concentration data are available for a substantial proportion of the high-volume waste
streams. The extent of coverage of the storage risk assessment for the various commodity sectors is
discussed in Appendix J.
To estimate groundwater exposure concentrations, bulk concentrations or adjusted EP constituent
concentrations from each waste sample were divided by central tendency (CT) and high-end (HE) DAF
values. The DAF values were derived specifically for the size and configuration of units (waste piles and
surface impoundments) estimated in the cost and economic analysis as being necessary to contain recycled
materials at representative size facilities in each commodity sector. DAF derivations were performed
employing regionally representative ground-water transport parameters and climatological data for those
facilities where these data were not available, or whose location was not known.
In evaluating potential risks, the 75th percentile constituent-specific DAFs were used to estimate
central tendency (CT) groundwater concentrations. The rationale for using the 75th percentile DAFs rather
than, for example, the 50th percentile value was that the EPACMTP model used to derive DAFs does not
consider fractured or channeled flow or other facilitated transport mechanisms which may occur at some
sites, resulting in higher groundwater concentrations than those predicted for homogeneous flow processes
modeled by EPACMTP. The 95th percentile constituent-specific DAF values were used to estimate high-
end (HE) groundwater concentrations, in keeping with the definition of a high-end receptor as someone
exposed at levels between the 90th and 99th percentiles of all exposed individuals.
Risks for groundwater exposures were calculated assuming groundwater would be used as a
drinking water supply by residents living near the management units for substantial proportions of their
lives. Cancer risks were calculated for exposures to inorganic arsenic"8 using the Cancer Slope Factor
(CSF) value from EPA's IRIS data base. For all other constituents, noncancer hazard quotients were
calculated using EPA's chronic ingestion pathway Reference Doses (RfDs). The DAF values derived for
mineral processing storage units, along with the exposure factor values and equations used to estimate
groundwater pathway risks, are provided in Appendix J. 1.
2fl Consistent with previous risk assessment efforts for mineral processing wastes, EPA chose not to
model the potential ingestion pathway cancer risks associated with exposure to beryllium because,
although beryllium has an approved Cancer Slope Factor in the IRIS data base, the value is currently under
review, and there is a substantial degree of uncertainty surrounding the activity of beryllium as an ingestion
pathway carcinogen.
April 30, 1998

-------
Non-groundwater pathway risks for land storage of recycled materials were estimated using a
variety of models, most of which generally follow the methods described in EPA's Technical Support
Document for the proposed "HWIR-Waste" exit level derivation.29 Exhibit 4-2 identifies the non-
groundwater release events and exposure pathways for which risks were evaluated, and provides brief
descriptions of the methods used to estimate exposures and risks. The release events that were evaluated
for waste piles include air particulate generation by wind disturbance and materials handling, and surface
run-off caused by rainfall. For surface impoundments, releases due to run-on and inlet/outlet control
failure events were evaluated. Owing to the nature of the constituents being evaluated (all inorganics),
volatilization release events were not considered.
The transport and exposure media which were evaluated included air, soils, home-grown
vegetables, surface water, and game fish. Exposure pathways and exposure factor values were generally
consistent with the child/adult resident, subsistence farmer, and subsistence fisher receptors used in the
proposed HWIR-Waste exit level determination. Cancer risks and noncancer hazard quotients were
calculated for all pathways using standard pathway models and ingestion and inhalation pathway
toxicological parameters from IRIS. The methods used to estimate exposures and to evaluate risks from
the storage of recycled materials through non-groundwater pathways are described in detail in
Appendix J.2.
4.2 Generic Risk and Benefits Assessment Results
4.2.1 Risk Assessment Results for Recycled Materials Storage: Groundwater Pathway
Exhibit 4-3 summarizes the carcinogenic groundwater risk results for the 75 samples identified as
containing arsenic, the sole ingestion pathway carcinogen among the waste constituents. Using the CT
DAF values, the calculated cancer risks for 48 of these samples were less than 105, the level of regulatory
concern, and the risks for 27 of the samples exceeded this value. Cancer risks exceeded 105 for one or
more samples from only five waste streams; beryllium spent barren filtrate, copper acid plant blowdown,
elemental phosphorus furnace scrubber blowdown, tantalum, columbium, and ferrocolumbium process
wastewater, and zinc spent surface impoundment liquids. The highest cancer risks were associated with
three samples of copper acid plant blowdown (10 ' to 10^). This waste stream accounted for 14 of the 16
samples with the highest CT cancer risks. The next highest risks (in the 104 to 103 range) were associated
with one sample each from tantalum process wastewater and zinc spent surface impoundment liquids.
29 U.S. EPA, Technical Support Document for the Hazardous Waste Identification Rule: Risk
Assessment for Hitman and Ecological Receptors. Office of Solid Waste, August 1995.
April 30, 1998

-------
Exhibit 4-2
Release and Exposure Pathway Modeling Summary for Mineral Processing Storage Risk Assessment
>
T3
o
o
o
00
Unit Type
Release Event/
Medium
Transport
Medium I
Transport
Medium II
Transport
Medium III
Exposure
Pathway
Receptors
Modeling Approaches
Waste Pile
Particulate
Generation by
Wind, Materials
Handling
Air


Inhalation
Adult Resident
SCREEN3 (Emissions) ISCST3
(Deposition) HWIR
(Exposure/Risk)


Air
Soil
(deposition)

Ingestion
Child/Adult
Resident
HWIR-Waste (Exposure/Risk)





Dermal
Child Resident
HWIR-Waste


Air
Soil
(deposition)
Crops
Ingestion
Subsistence
Farmer
HWIR-Waste, modified for non-
sleady-state conditions
(concentration in crops,
vegetable intake, risk)


Air
Soil/Water
Surface
Waler/Fish
Ingestion
Subsistence
Fisher
Bounding analysis (100 percent
deposition in water body)
Waste Pile
Runoff
Soil
""
"
Ingestion
Child Resident
Bounding analysis; 100 percent
runoff to adjacent garden/yard,
HWIR-Waste (exposure and risk)


Soil
""
"
Dermal
Child Resident
Bounding analysis; 100 percent
runoff to adjaqent garden/yard,
HWIR-Waste (exposure and risk)


Soil
Crops
--
Ingestion
Subsistence
Farmer
Bounding Analysis; HWIR-
Waste


Soil
--
Surface
Water/Fish
Ingestion
Subsistence
Fisher
Bounding analysis (100 percent
deposition in water body)
Surface
Impoundment
Conlrol/Berm
Failure
Surface Water


Ingestion
Adult Resident
HWIR-Waste (Release
algorithms, exposure, drinking
water ingestion)


Surface Water
Fish
"
Ingestion
Subsistence
Fisher
HWIR-Waste (Releases, dilution,
fish ingestion, risk)
Oj

-------
Exhibit 4-3
RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of* Samples by Groundwater Risk Category: Cancer Risks
>
T3
3.
U>

vO
SO
OO


Number














of Samples

Central Tendency




High End




with

10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2



Cancer

to
to
to
to


" to
to
to
to

Commodity
Waste Stream
Risk
<10-5
10-4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
10-1
>10-1
Muminum, Alumina
Cast house dust
2
2
0
0
0
0
0
2
0
0
0
0
0
Beryllium
Chip treatment WW
1
1
0
0
0
0
0
1
0
0
0
0
0
Beryllium
Spent Barren Filtrate
1
1
0
0
0
0
0
1
0
0
0
0
0
Copper
Acid plant blowdown
30
9
7
8
3
3
0
5
3
5
8
5
4
Elemental Phosphorus
Furnace scrubber blowdown
8
7
1
0
0
0
0
3
3
2
0
0
0
Rare Earths
PWW
2
2
0
0
0
0
0
0
2
0
0
0
0
Selenium
Plant PWW
2
2
0
0
0
0
0
0
1
1
0
0
0
Tantalum, etc. 1
PWW
13
10
2
1
0
0
0
7
3
0
3
0
0
Titanium and Ti02
Leach liquor & sponge wash waier
2
2
0
0
0
0
0
0
1
1
0
0
0
Titanium and Ti02
Scrap milling scrubber water
1
1
0
0
0
0
0
0
1
0
0
0
0
Zinc
Waste ferrosilicon
0
0
0
0
0
0
0
0
0
0
0
0
0
Zinc
Spent S.I. liquids
1
0
0
1
0
0
0
0
0
0
0
1
0
Zinc
WWTP liquid effluent
0
0
0
0
0
0
0
0
0
0
0
0
0
Zinc
Process wastewater
II
11
0
0
0
0
0
7
1
3
0
0
0
Total

75
48
11
10
3
3
0
26
15
13
11
6
4
i
1. Tantalum, Columbium, and Ferrocolumbium

-------
Using the high-end (HE) DAF values, cancer risks calculated for the groundwater pathway
exceeded 10'5 for 49 of the 75 samples. Under this set of assumptions, risks for at least one sample
exceeded 105 for 11 of the 14 waste streams evaluated. The highest risks (25 of 30 samples > 10highest
risk category >10') were again associated with copper acid plant blowdown, with the next highest risk (102
to 10 ') being associated with the single sample of zinc spent surface impoundment liquids. Of the wastes
whose CT cancer risks were below 105 for all samples, five (rare earths process wastewater, selenium plant
wastewater, titanium/TiO, leach liquor and sponge wash water and scrap milling scrubber water, and zinc
process wastewaters), had at least one sample with HE cancer risks above this level.
Cancer risks lor most of the samples increased about two orders of magnitude from the CT to HE
case. This is consistent with the difference between the CT and HE DAF values for arsenic managed in
surface impoundments. In the case of the NWW waste streams managed in piles, both the CT and HR
cancer risks for all samples were below 10'\ For aluminum/alumina cast house dust, this reflected the
much higher CT and HE DAF values for arsenic managed in waste piles, compared to surface
impoundments. Arsenic was not detected in the single sample of waste ferrosilicon from zinc production.
Thus, no carcinogenic risks were calculated for this waste. The two other streams for which all HE
sample-specific cancer risks were below 105 were beryllium chip treatment wastewater and zinc
wastewater treatment plant liquid effluent.
Noncancer hazard quotient values for the groundwater pathway for the individual samples of
recycled materials are summarized in Exhibit 4-4. Using the CT DAF values, hazard quotients exceeding
1.0 were calculated for 46 of 136 total samples from the 14 waste streams. As was the case for cancer
risks, copper acid plant blowdown had the highest number of samples with noncancer hazard quotients
above 1.0 (18 of 35 samples), and had the highest number of samples (4) in the highest-risk category (HQ
from 100 to 1000). Samples from zinc production (11 of 22 for spent surface impoundment liquids and 8
of 16 for process wastewater) account for the bulk of the remaining hazard quotients above 1.0. The only
other waste streams with CT hazard quotients above 1.0 included beryllium spent barren filtrate (three
samples), beryllium chip treatment wastewater (one sample), elemental phosphorus furnace scrubber
blowdown (one sample), tantalum process waste water (three samples), and zinc wastewater treatment
plant liquid effluent (one sample).
When the HE DAF values are used to calculate exposures, hazard quotients exceed 1.0 for 102 of
the 136 samples. As was the case for cancer risks, most of the hazard quotient values for individual
samples are increased one to two orders of magnitude in the HE case compared to the CT case, reflecting
the higher HE DAF values for the risk-driving constituents managed in surface impoundments. As for
cancer risks, both the CT and HE DAF values for waste piles for all of the constituents are so high that no
samples of either of the two streams stored in waste piles have hazard quotients exceeding 1.0 in either the
CT or HE case. Hazard quotient values for one or more samples from four waste streams (rare earths
process wastewater, selenium process wastewater, and titanium/Ti02 lcach liquor and sponge wash water
and scrap milling scrubber sludge) which were all below 1.0 in the CT case exceeded 1.0 in the HE case.
April 30, 1998

-------
Exhibit 4-4
RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of Samples by Groundwater Hazard Category: Non-Cancer Hazards


Number of














Samples














with

Central Iendency



High End




Non-

1
10
100
lk


1
10
100
lk



canccr

to
to
to
to


to
to
to
to

Commodity
Waste Stream
Hazard
<1
10
100
lk
10k
>10k
<1
10
100
lk
10k
>10k
Aluminum, Alumina
Cast house dust
2
2
0
0
0
0
0
2
0
0
0
0
0
Beryllium
Chip treatment WW
1
0
0
1
0
0
0
0
0
0
0
1
0
Beryllium
Spent Barren Filtrate
4
1
3
0
0
0
0
0
1
3
0
0
0
Copper
Acid plant blowdown
35
17
10
4
4
0
0
3
7
12
7
4
2
Elemental
Furnace scrubber blowdown
14
13
1
0
0
0
0
4
4
5
1
0
0
Phosphorus














Rare Earths
PWW
4
4
0
0
0
0
0
2
2
0
0
0
0
Selenium
Plant PWW
2
2
0
0
0
0
0
0
2
0
0
0
0
Tantalum, etc.1
PWW
21
18
3
0
0
0
0
13
3
0
5
0
0
Titanium and Ti02
Leach liquor & sponge wash
2
2
0
0
0
0
0
0
1
1
0
0
0

water













Titanium and Ti02
Scrap milling scrubber water
1
1
0
0
0
0
0
0
1
0
0
0
0
Zinc
Waste ferrosilicon
1
1
0
0
0
0
0
1
0.
0
0
0
0
Zinc
Spent S.I. liquids
22
11
5
4
2
0
0
4
3
2
7
2
4
Zinc
WWTP liquid effluent
3
2
0
0
1
0
0
0
1
1
0
0
1
Zinc
Process wastewater
24
16
7
1
0
0
0
5
4
5
8
2
0
Totals

136
90
29
10
7
0
0
34
29
29
28
9
7
1. Tantalum, Colurnbiuni, and Ferrocoluinbium

-------
4.2.2 Potential Benefits From Control of Stored Materials: Groundwater Pathway
The cancer risk results for the individual samples, distributed across the numbers of facilities
generating and storing the wastes, are summarized in Exhibit 4-5. Using the methods described in Section
4.1.2, EPA has estimated that CT screening level groundwater pathway cancer risks would exceed 105 at
approximately 11 of the 56 facility-waste stream facilities.30 All of these facility-waste stream
combinations were managing copper acid plant blowdown (7 facility-waste stream combinations), zinc
spent surface impoundment liquids (3 combinations), or beryllium spent barren filtrate (one combination).
These results, of course, generally reflect the pattern of sample-specific risk results for the various
commodity sectors. It should be noted, however, that for two waste streams, findings of one or more
sample with greater than 10"s risks did not translate into any facility-waste combinations above 105 risks.
In the case of elemental phosphorus furnace scrubber blowdown, only one of eight samples had a cancer
risk of just above 10'5. Distributed across only two facilities estimated to be storing this waste, this result
(one-seventh of the samples having risks above 105) was rounded down to zero. Similarly, in the case of
selenium plant process wastewater, a finding of hazard quotients greater than 1.0 at three of 13 facilities
translates into zero of two facility-waste stream combinations. This occurrence is the almost inevitable
result of having so few facilities in some of the commodity sectors, and the fact that non-integral numbers
of waste-stream facility combinations are meaningless as risk or benefit indicators. It would be reasonable
to interpret these results as indicating that either zero or one facility in these industries might have a CT
cancer risk above 10"5. Finally, the single facility managing beryllium chip treatment wastewater was
placed in the 10-10 J CT cancer risk category. Since there were only there were only two samples of this
waste, one falling into this category, and one falling into the next lower risk category, the facility could
also have been placed in the lower category.
When HE DAF values arc used, the number of fucility-waste stream combinations with cancer
risks above 10'5 increases to 23 of 56 facilities. Under HE assumptions, most of the waste streams show
one or more facilities at risk levels above 10 \ The exceptions include both the two NWW streams that
would be stored in waste piles, as well as beryllium chip treatment wastewater and zinc wastewater
treatment plant liquid effluent. As noted previously, arsenic is not reported as a constituent of the latter
waste.
Note that the totals in the risk categories do not sum exactly due to rounding,
following exhibit as well.
April 30, 1998
This is true for the

-------
Exhibit 4-5
RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of Waste Stream/Facility Combinations by Groundwater Risk Category: Cancer Risks


Number of














Waste Stream-

Central Tendencv



Hiuh End




Facility














Combinations

10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2



Central
High

to
to
to
to


to
to
to
to

Commodity
Waste Stream
Tendency
End
<10-5
10-4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
10-1
>10-1
Aluminum, Alumina
Cast house dust
23
23
23
0
0
0
0
0
23
0
0
0
0
0
Beryllium
Chip treatment WW
2
2
2
0
0
0
0
0
2
0
0
0
0
0
Beryllium
Spent Barren Filtrate
1
1
0
1
0
0
0
0
0
0
1
0
0
0
Copper
Acid plant blowdown
10
10
3
2
3
1
1
0
2
1
2
2
2
2
Elemental Phosphorus
Furnace scrubber blowdown
2
2
2
0
0
0
0
0
1
1
1
0
0
0
Rare Earths
PWW
1
1
1
0
0
0
0
0
0
1
0
0
0
0
Selenium
Plant PWW
2
2
2
0
0
0
0
0
0
1
1
0
0
0
Tantalum, etc. '
PWW
2
2
2
0
0
0
0
0
1
1
0
0
0
0
Titanium and Ti02
Leach liquor & sponge wash
9
2
2
0
0
0
0
0
0
1
1
0
0
0

water














Titanium and Ti02
Scrap milling scrubber water
1
1
1
0
0
0
0
0
0
1
0
0
0
0
Zinc
Waste ferrosilicon
1
1
0
0
0
0
0
0
0
0
0
0
0
0
Zinc
Spent S.I. liquids

3
0
0
3
0
0
0
0

0
0
3
0
Zinc
WWTP liquid effluent
3
3
0
0
0
0
0
0
0
0
0
0
0
0
Zinc
Process wastewater
3
3
3
0
0
0
0
0
2
0
1
0
0
0
TOTAL 2

56
56
<10
3
6
1
1
0
31
7
6
3
5
2
1.	Tantalum, Columbium, and Fenocolumbium
2.	Sums by risk category may not add to the number of central or high end waste stream/facility combinations due to rounding.

-------
The distribution of facility-waste stream combinations by noncancer risk category is summarized
in Exhibit 4-6. Using the CT DAF values, 12 facility-waste stream combinations are identified as having
noncancer hazard quotients greater than 1.0. Five of these facilities are managing copper acid plant
blowdown, two pre managing beryllium chip treatment wastewater, and two of the facility-waste stream
combinations are associated with the management of zinc spent surface impoundment liquids.
Using HE DAF values, 26 facility-waste stream combinations are identified as being associated
with noncancer hazard quotients above 1.0. Again, four waste streams have no facility-waste stream
combinations with hazard quotients above levels of concern: aluminum/alumina cast house dust, rare earth
chip treatment wastewater, tantalum process wastewater, and zinc spent waste ferrosilicon.
As discussed previously, if regulatory options completely abolish groundwater releases from the
mineral processing storage units. post-LDR risks for all of the waste stream-facility combinations would
drop below levels of concern. Thus, the numbers of facilities above levels of concern in Exhibits 4-5 and
4-6 provide an upper-bound estimate of the regulatory benefits, in terms of groundwater risk reduction,
that might be achieved by Option I, under which all recycled materials would be stored in tanks,
containers, and buildings.
The extent to which these benefits might actually be realized is difficult to predict without explicit
modeling of releases from the tanks, containers, and buildings. These technologies would probably
provide substantial risk reduction for most wastes, but EPA does not have sufficient data to estimate the
level of risk reduction. Probably those streams with storage risks which just exceed levels of concern
would be more likely to fall below levels of concern if managed in TCBs than those streams for which
risks exceed levels of concern by many orders of magnitude, because a lower degree of control would be
necessary to control these risks. EPA also believes that it will be easier to manage the low-volume
recycled streams to achieve high levels of control than it will be to manage the higher volume streams.
4.2.3 Generic Risk Assessment Results for Storage of Recycled Materials: Non-Groundwater
Pathways
The health risks associated with recycled materials storage that were calculated for most of the
non-groundwater release events and exposure pathways under the modified prior treatment baseline were
below levels of concern (lifetime cancer risk less than 10'5, hazard quotients less than 1.0). All risks under
HF. and CT assumptions were below these levels for the following release events/exposure pathway
combinations:
	Inhalation of airborne particulate;
	Ingestion and dermal contact with soil contaminated by airborne particulate;
	Ingestion of crops grown in soil contaminated by airborne particulate;
April 30, 1998

-------
Exhibit 4-6
RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of Waste Stream/Facility Combinations by Groundwater Hazard Category:
Non-Cancer Hazards


Number of
Waste Stream-
Facility
Central Tendency


Hish
Knd


















Combinations

1
10
100
lk


1
10
100
Ik



Central
High

to
to
to
to


to
to
to
to

Commodity
Waste Stream
Tendency
Knd
<1
111
Kill
lk
10k
>10k
<1
10
100
Ik
10k
>IOk
Aluminum, Alumina
Cast house dust
23
23
23
0
0
0
0
0
23
0
0
0
0
0
Beryllium
Chip treatment WW
2
2
0
0
2
0
0
0
0
0
0
0
1
0
Beryllium
Spent Barren Filtrate
1
1
0
1
0
0
0
0
0
0
1
0
0
0
Copper
Acid plant blowdnwn
10
10
4
3
1
1
0
0
1
2
3
2
l
I
Elemental Phosphorus
Furnace scrubber
blowdown
2
2
2
0
0
0
0
0
1
1
1
0
0
0
Rare Earths
PWW
1
1
1
0
0
0
0
0
1
0
0
0
0
0
Selenium
Plant PWW
2
2
2
0
0
0
0
0
0
2
0
0
0
0
Tantalum, etc 1
PWW
2
2
2
0
0
0
0
0
1
0
0
0
0
0
Titanium and Ti02
Leach liquor & sponge
wash water
2
2
2
0
0
0
0
0
0
1
1
0
0
0
Titanium and Ti02
Scrap milling scrubber
water
1
1
1
0
0
0
0
0
0
1
0
0
0
0
Zinc
Waste lerrosilicon
1
1
1
0
0
0
0
0
1
0
0
0
0
0
Zinc
Zinc
Spent S.I. liquids
WWTP liquid effluent
3
3
3
3
2
2
0
0
1
0
1
1
0
0
0
0
0
0
0
1
0
1
1
0
0
0
I
I
Zinc
Process wastewater
3
3
2
1
0
0
0
0
1
1
1
1
0
0
TO TAL 2

55
55
43
5
4
3
0
0
20
9
7
4
4
2
1.	Tantalum, Columbium, and Fcrrocolumbium
2.	Sums by hazard category may not add to the number of central or high-end waste stream/facility combinations due to rounding

-------
- 51 -
	Ingestion and dermal contact with soil contaminated by surface run-off;
	Ingestion of crops grown on soil contaminated by surface run-off;
	Ingestion of surface water contaminated by airborne particulate and surface run-
off and;
	Ingestion of game fish harvested from surface water contaminated by airborne
particulate and surface run-off.
All of the pathways identified are complete only for waste piles. Thus, these findings indicate, as
was the case for the groundwater pathway, that all non-groundwater risks for the two recycled streams
stored in waste piles are less than levels of concern. In almost all cases, estimated cancer risks and
noncancer hazard quotients were far below the defined levels of concern (usually by more than one order
of magnitude). The only exception among all of these pathways was the HE inhalation pathway hazard
quotient for barium inhalation from aluminum cast house dust, which was 0.19, or five times below the
level of concern. Detailed risk results for these pathways are given in Appendix H.2.
The only pathways for which some risks exceeded levels of concern were ingestion of surface
water contaminated by surface impoundment failure, and ingestion of fish harvested from waters
contaminated by surface impoundment failures. Exhibit 4-7 summarizes the results of the comparison of
surface water concentrations resulting from impoundment releases to HBLs for the water ingestion
pathway.
Because there are multiple samples available for most of the waste streams managed in surface
impoundments, the results of the comparison to HBLs are reported in terms of the numbers of samples and
recycled streams for which the HE and CT surface water concentrations from impoundment releases
exceed the HBLs, presented in order-of-magnitude categories.
Releases from surface impoundment failures were modeled as resulting in potential exceedances of
HBLs for water ingestion for three constituents: arsenic, cadmium, and lead. Under high-end dilution
assumptions, the arsenic concentrations in five samples (four bulk samples, one EP extraction.) would
exceed the drinking water HBL by up to one thousand-fold. (This is equivalent, in this case, to saying that
the estimated cancer risks under HE assumptions would exceed the 10 3 level of concern by up to a factor
of 1000.) All of these samples came from the copper acid plant blowdown stream, and under CT dilution
assumptions the surface water concentration for arsenic exceeds the HBL for only one of the 40 total
samples of this stream.
April 30, 1998

-------
Exhibit 4-7
RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
COMPARISON OF SURFACE WATER CONCENTRATIONS DUE TO SURFACE IMPOUNDMENT RELEASES
TO HEALTH-BASED LEVELS 1
DRINKING WATER PATHWAY

High-End
Surface Water
Concentration
from Bulk
Samples
High-End Surface Water
Concentration from EP
Extraction Samples
Central Tendency
Surface Water
Concentration
from Bulk
Samples
Central Tendency
Surface Water
Concentration from
EP Extraction
Samples
Samples
Exceeding HBL
by:
Samples Exceeding HBL
by:
Samples
Exceeding HBL
by:
Samples Exceeding
HBL by:
Constituent
Commodity
Waste Stream
Total Samples
l-10x
10-I00x
l-10x
10-lOOx
lOO-lOOOx
l-10x
10-100x
1-lOx
HMOOx
Arsenic
Copper
Acid Plant blowdown
40
3
1 


1


1

Cadmium
Zinc
Spent Surface
Impoundment Liquids
24
1








Lead
Copper
Acid Plant Blowdown
40
1









Zinc
Spent Surface
Impoundment Liquids
24
1
1







I. The HBL lor Arsenic corresponds lo a 10-5 lifetime cancer risk.. The HBL for cadmium corresponds to a noncancer hazard quotient of 1.0, and the HBL for
lead is the MCL.

-------
The concentration of cadmium in one of 24 samples from the zinc spent surface impoundment
liquid stream results in surface water concentrations exceeding the drinking water HBL under HE
assumptions. The HBL is exceeded by a factor of ten or less. Under CT assumptions, there are no surface
water exceedances for cadmium. For cadmium, an HBL exceedance corresponds to a hazard quotient
value exceeding 1.0 for its critical toxic effect on kidney function. The lead concentrations in hulk
samples from two waste streams result in estimated surface water concentrations exceeding the drinking
water HBL. One sample of copper acid plant blowdown shows a concentration of lead such that the HE
concentrations exceeds the HBL by a factor of less than ten. Under CT assumptions, this sample no longer
exceeds the HBL. Two bulk >umples of /.inc spent surface impoundment liquids result in HE lead
concentrations in surface water that exceed the HBL by a factor of up to 100. Again, under the CT
dilution assumptions, the predicted lead concentrations in surface water are reduced to below the drinking
water HBL. As noted previously, the HBL for lead is simply the Drinking Water MCL of 15 ug/l.
As shown in Exhibit 4-8, the predicted surface water concentrations of six contaminants released
from surface impoundments also were such that HBLs derived for the ingestion of fish by subsistence
fishers were exceeded. Six arsenic samples (again all from copper acid plant blowdown) resulted HE
surface water concentrations exceeding the fish consumption HBLs by up to a factor of 1000. Four of
these were bulk samples, and the remainder were EF extraction samples. Under CT assumptions, only one
sample exceeded the arsenic fish ingestion HBL.
A total of 20 samples (one EP extraction, the rest bulk) contained cadmium concentrations which
resulted in HE surface water concentrations exceeding the fish ingestion HBL by up to 1000-fold. These
samples came from zinc spent surface impoundment liquids (10), zinc process wastewater (6), copper acid
plant blowdown (2 samples), and one sample each from rare earths process wastewater and zinc
wastewater treatment plant liquid effluent. Under CT dilution assumptions, the number of samples
exceeding the HBL is reduced to 3 samples, and the maximum level of exceedance is reduce to less than
100-fold.
Under HE assumptions, five samples give mercury concentrations in high-end surface water
exceeding the fish ingestion HBL. These samples come from copper acid plant blowdown (3) and zinc
spent surface impoundment liquids (2). and under CT assumptions, none of these samples exceeds the fish
HBL. In the case of mercury, an HBL exceedance is equivalent to a hazard quotient greater than 1.0 for
reproductive effects.
A single sample result for selenium in copper acid plant blowdown results in surface water
concentrations above the HBL, as do two thallium results (one each from titanium/TiO, leach liquor and
sponge wash water and from copper acid plant blowdown). For all of these samples, no excedences occur
under CT dilution assumptions. The same is true for the six analytical results for zinc (all from zinc
commodity streams). All six of the samples exceed the fish ingestion HBL under HE but not under CT
dilution assumptions.
April 30, 1998

-------
Exhibit 4-8
RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
COMPARISON OI SURFACE WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO HEALTII-UASKD LEVELS 1
FISH INGESTION PATHWAY




High-End Surface Water
Concentration from Bulk
Samples
High-End Surface Water
Concentration from EP
Extraction Samples
Central Tendency
Surface Water
Concentration from
Bulk Samples
Central Tendency
Surface Water V
Concentration from Klf
Extraction Samples 11




Samples Exceeding HHL
by:
Samples Exceeding HBL
by:
Samples Exceeding
HBL by:
Samples Exceeding |
HBL by: |
Constituent
Commodity
Waste Stream
Total No.
Samples
1-IUx
10-100x
1(10-10(10*
l-10x
IO-IOOx
lOO-lOOOx
1-I0x
10-100x
l-10x
IO-IOOx 1
\rsenic
Copper
Acid Plant Blowdown
40
2
2

1

1


1

Cadmium
Copper
Acid Plant Blowdown
40
2










Kare Haiths
Process Wastewater
8



1







Zinc
Process Wastewater
40
6










Zinc
Spent Surface
Impoundment Liquids
24
(i
3
1



1
1



Zinc
WWTP Liquid Rllluenl
5


1




1


Vlercury
Copper
Acid Plant Blowdown
40
2


1







Zinc
Spent Surface
Impoundment Liquids
24
1
1








Selenium
Copper
Acid Plant Blowdown
40
1









I'hallium
Titanium and
no,
Leach liquid & sponge
wash water
8
1










Copper
Acid Plant Blowdown
40



1






iine
Zinc
Spent Surface
Impoundment Liquids
24
5










Zinc
WW'I'P Liquid Lllluent
5
1









1 'l he HBL lor Arsenic corresponds to a 10-5 lifetime cancer risk.. 'Hie HBI. for ihe other constituents correspond to a noncancer hazard quotient of 1.0.

-------
4.2.4 Potential Health Benefits from Regulation of Storage of Recycled Materials: Non-
Groundwater Pathways
Exhibit 4-9 summarizes the estimated numbers of facility-waste stream combinations which
exceed HBLs for both surface water pathways under the modified prior treatment baseline. Under the
ingestion pathway, the three facilities with HBL exceedances under HE assumptions drops to zero under
CT assumptions, as do the two facilities storing zinc spent surface impoundment liquids. Similarly, when
the fish ingestion pathway is considered, a large number of facilities storing six different waste streams
show exceedances of the HBLs under HE assumptions, but only one facility (storing zinc spent surface
impoundment liquids) exceeds an HBL under CT assumptions.
As was the case with the groundwater pathway, effective management of the recycled materials
could reduce all of the estimated risks to below levels of concern. Again, however, there is no way to
estimate how much risk reduction would be achieved without explicit modeling of the non-groundwater
pathway releases from TCBs. Under Option 1, all of the streams could be managed in TCBs, and the
degree of risk reduction and the magnitude of health benefits for storage are difficult to estimate. Because
the magnitude of exceedances of the HBLs for most waste stream-facility combinations are rather low for
the surface water pathways, it is likely that most of these risks would, in fact, be reduced below levels of
concern under Option 1. In terms of reduced risks from the storage of recycled materials, Option 2
provides no benefits over the modified prior treatment baseline.
4.3 Qualitative Evaluation of Conditions at High-Risk Facilities
As noted in the preceding section, the screening level risk analyses identified a number of waste
streams as posing potentially significant risks to human health through the groundwater and surface water
pathways. To further evaluate these potential risks, the Agency has conducted a limited analysis of site-
specific conditions at some facilities where these wastes are generated and recycled. The following sections
summarizes the results of this analysis.
4.3.1 Identification of Potential High-Risk Streams and Facilities
Using the screening level analyses described in Section 4.2, the Agency has identified a group of
wastes for which storage prior to recycling could pose high risks to human health. The criteria used to
identify these streams was the estimation of central tendency individual cancer risks greater than 10 or
noncancer hazard quotients above 1.0 for a large proportion of the waste sample data in the Agency's
waste composition database associated with recycling operations for either groundwater or non-
groundwater pathways. The streams which were identified and the exposure pathways of concern are
identified in Exhibit 4-10.
The Agency then explored the possibility of refining the risk analysis for facilities at which these
streams are recycled. Information from the Agency files and other sources (technical literature, EPA
Regional and state regulators, public comments) related to recycling and management practices, regulatory
status, environmental settings, and potential receptors, were examined for the facilities that generated the
wastes. The intent was to explore the possibility of site-specific population risk assessments for these sites,
to supplement the screening level assessments previously described.
April 30, 1998

-------
Exhibit 4-9
RISK SUMMARY FOR STORAGE OF RECYCLED MATERIA!.S
DISTRIBUTION OF WASTE-STREAM FACILITY COMBINATIONS BY DEGREE OF IIBL EXCEEDANCE UNDER THE
MODIFIED PRIOR TREATMENT BASELINE
Commodity
Waste Stream
Sector Total
Waste Stream-
Facility
Combinations
Number of Waste Stream-Facility
Combinations with High-End
Exceedances of HllLs by:
Waste Stream-Facility
Combinations with Central
Tendency Fxcecdances of
HBLs by.
I-IOX
IO-100X
100-1000X
I-10X
10-100X
1. Drinkina Waier
Copper
Acid Slowdown
10
1




'.ine
Spent Surface Impoundment Liquids
3





2. Fish Ingestion
Cupper
Acid Blowdown
10
2
1



Rare Earths
Process Wastewater
1





Titanium, TiO;
Leach Liquor and Sponge Wash Water
2





iinc
Process Wastewater
3





/.inc
Spent Surface Impoundment Liquids
3
1
1



fane
WWTP Liquid F.flluenl
3


1

1

-------
-57 -
Exhibit 4-10
High-Risk Wastes and Exposure Pathways of Concern for Mineral Processing Wastes
Identified in the Screening Risk Assessment
Commodity Sector
Waste Stream
Groundwater
Surface Water
Cancer
Noncancer
Drinking
Water
Pish
Ingestion
Beryllium
Chip Treatment Wastewater

X


Cupper
Acid Plant Blowdown
X
X
X
X
Elemental Phosphorus
AFM Rinsale
Furnace Scrubber Blowdown
X
X
X
X


Selenium
Plant Process Wastewater
X
X


Tantalum. Columbuim,
and Ferrocolumbium
Process Wastewater
X
X


Titanium. Titanium
Dioxide
Leach Liquor and Sponge
Wash Water
X
X

X
Zinc
Spent Surface Impoundment
Liquids
Wastewater Treatment Plant
Liquid Effluent
Process Wastewater
X
X
X
X
X
X
X
X
4.3.2 Land Management of Recycled Streams at Potential High-Risk Facilities
The first step in the evaluation of potential risks at these facilities was to confirm that land
management of the high-risk materials has or is still occurring at these facilities and to characterize the
nature of the land management units. The facilities generating and recycling the potentially high-risk
materials were identified from a review of the Agency's database related to waste composition. Thus,
specific waste composition data (waste volumes, constituent identities and concentrations) could be linked
to specific facilities and locations, focusing the search for additional information. The nine facilities that
were identified are shown in Exhibit 4-11.
Data from a number of sources were reviewed to locate information related to the current and past
land management practices for the recycled wastes. The sources which were reviewed include past
Agency evaluations of mineral processing waste management, computer data bases related to RCRA and
CERCLA activity at facilities, NPDES and RCRA permit information, and documents related to RCRA
corrective actions and closures and CERCLA remediation activities.31
31 A complete list of the data sources may be found in "Data Gathering Results for Site-Specific
Modeling of High-Risk Mineral Processing Waste Management", memorandum to Paul Borst, USEPA,
from William Mendez, et. al., ICF Kaiser International, October 30, 1997.
April 30, 1998

-------
-58 -
Exhibit 4-11
Identification of Facilities Generating and Recycling Potential High-Risk Waste Streams
Facility Number
Industry Sector
High-Risk Waste Stream
Location
1
Beryllium
spent barren filtrate*
Utah
*>
Copper
acid plant blowdown*
Arizona
3
Elemental Phosphorous
furnace scrubber blowdown
Idaho
4
Zinc
process wastewater*
Tennessee
5
Titanium and Ti02
waste acids ( sulfate process)
Georgia
6
Copper
acid plant blowdown*, scrubber
blowdown
Arizona
7
Titanium and Ti02
scrap milling scrubber water, waste acids
(sulfate process)
Maryland
8
Zinc
spent surface impoundment liquids*,
process wastewater*
Pennsylvania
9
Zinc
process wastewater*
Oklahoma
* Recycled stream
Information related to land management at the nine potential high risk facilities is summarized in
the second column of Exhibit 4-12. It can be seen from these data that land management units were
historically used in the management of the majority of the high-risk streams. At least five of the nine
facilities, and possibly two others, appear to have managed such streams in surface impoundments at some
point in the past. Since all of the potential high-risk wastes are wastewater or liquid nonwastewaters.
management in waste piles or landfills was not encountered frequently, although one, or possible two,
facilities may have co-disposed or "stored" small-volume liquid wastes in piles of non-liquid wastes (e.g.,
tailings piles).
There is also a pattern, however, of moving away from land management, possibly under the
influence of RCRA and State regulatory initiatives, in the 1980s and 1990s. Post-1990, evidence was
found that indicated only one facility (facility 2) continues to manage recycled streams in land units. It
appears, however, that even these units arc engineered structures (heap-leach piles and solar pads) with
low-permeability liners used to recycle copper acid plant blowdown. Recent data suggest that another
facility (facility.6) may no longer recycle copper acid plant blowdown. but treat it by mixing it with a
large-volume tailings stream. Information related to potential releases from these management units are
not available.
April 30. 1998

-------
- 59 -
Exhibit 4-12
Summary of Site-specific Data for High-risk Mineral Processing Facilities
Facility
Number
(Sector, State)
Land Management
Units
Receptors
Potential
Groundwater
Exposures
Potential Non-
Groundwater
Exposures
Incidents of Environmental
Contamination/ Damage
1 (Beryllium,
Utah)
Conflicting
information; barren
filtrate is cither
recycled in process
vessels or co-
disposed with tailings
Approximately 1000
nearby residents; no
aquatic ecological
receptors
Local wells draw from
deep aquifer; no
evidence for
contamination of this
aquifer
There appear to be no
significant water bodies
nearby; no air releases
Some contamination of
shallow aquifer, no evidence
for contamination of deeper
aquifer, documented acute
release incidents do not
appear to be related to
recycling
2 (Copper,
Ari/.ona)
Historical recycling
units arc
impoundments,
recent data indicate
blowdown is recycled
to lined heap leach
piles, solar pad
Approximately 3700
residents within one
mile. No ecological
receptors identified
Closest known wells
appear to be outside of
groundwater How path
from recycling units
Nearby down-gradient
water bodies are
intermittent, do not
support fisheries, low
potential for air releases
Extensive regional
groundwater and surface water
contamination', recycling may
have contributed, but there are
many potential sources other
than recycling operations
3 (Elemental
Phosphorous,
Idaho)
Historical unils are
impoundments; these
have been closed and
treatment is currently
in tanks
Spring-led water
supply serves
approximately 1100
people; Ecological
receptors in nearby
streams and river
No downgradient wells
before discharge to
surface water
Adjacent streams;
Portneul river; springs
fed by river used lor
drinking water
Groundwater contamination
documented downgradient 1
from historical recycling units; 1
limited evidence of discharge 1
to river |
4 (Zinc,
Tennessee)
Surface
impoundments and
tanks are in use for
waste management;
available data does
not indicate which
are used lor recycling
Approximately 33,000
residents within three
miles; facility
surrounded by
wetlands, near river
Potential nearby
groundwater use
Nearby wetlands, lakes;
no air releases
Metals contamination in |
sediments and soils beneath H
unils; oflsile exposures, |
damage not demonstrated E
April 30, 1998

-------
-60 -
Exhibit 4-12 (con(ilined)
Summary of Site-specific Data for High-risk Mineral Processing Facilities
Facility
Number
(Sector, State)
Land Management
Units
Receptors
Potential
Groundwater
Exposures
Potential Non-
Groundwater
Exposures
Incidents of Environmental
Contamination/ Damage
5 (Titanium and
Tiianium
Oxide,
Georgia)
Historical SWMUs
(impoundments) are
no longer used;
treatment apparently
in tanks
Approximately 25,000
within three miles;
facility isolated near
river
Groundwater
discharges to river, with
no wells
Discharge lo adjacent
Savannah River;
dilution volume
probably precludes
adverse effect; no air
releases
Low-level sediment and
stream water contamination
from past releases; unclear if
related lo recycling operations
6 (Copper,
Ari/.ona)
Historical recycling
units (impoundments
and piles) appear to
be closed, facility
treats blowdown by
mixing with tailings
Power than 10
residents within 1
mile; no nearby
ecological receptors
identified
Nearby wells do not
appear to be in
groundwater llow path
Does not appear lo be-
any discharge to nearby
water bodies; low
potential for air releases
Regional groundwater
contamination from historical
activities; a few instances of
hazardous substances releases
not known to be associated
wilh recycling
7 (Tiianium &
TiO,,
Maryland)
Landfill in use for
waste management,
no information on
recycling unit
characteristics
Approximately 10,000
residents within three
miles of facility
;ceoiogical receptors
in adjacent estuarine
river
Discharge to river; no
wells
River volume
(Palapsco) may
preclude adverse
effects.
No data ielalcd lo releases
from recycling
8 (Zinc,
Pennsylvania)
Historical
management units arc-
surface
impoundments,
piles, no recent data
on recycling units
approximately 2,5000
residents within Vi
mile; nearby sensitive
ecosystems in creek,
river
Discharge lo Raccoon
Creek, Ohio River
River volume may
preclude effects
No data related lo releases
from recycling
9 (Zinc,
Oklahoma)
No data; production
reported to have
ceased in 1996
No data on ecological
receptors
No data
No data
Metals contamination in soils,
sediment, and surface water;
link lo recycling not
established. E
April 30, 1998

-------
In addition, data on land management units were absent or conflicting for several of the facilities.
At facility 1 (a beryllium ore processor in Utah), information presented in public comments indicated both
that spent barren filtrate was recycled in process vessels (tanks) or that it was not recycled, and instead
disposed, along with other streams, in a large surface impoundment. At facilities 4 and 7, data were not
available to indicate whether land management of recycled streams is still occurring, and at facility 9. the
data gathering effort was curtailed when it was determined that the facility stopped production in 1996.
4.3.3	Identification of Populations at Risk
EPA also reviewed information related to the human populations and ecological receptors
potentially exposed to pollutants near the nine high-risk facilities, and regarding potential exposure
pathways for site releases. Detailed summaries of this information for each of the nine facilities may be
found in Appendix L, and these results are summarized in the third column of Exhibit 4-12.
It can seen that most of the potential high-risk facilities have substantial nearby resident
populations. Seven of the eight facilities for which population data were developed have greater than
1.000 people living within three miles of the facility center coordinates, and the nearby resident
populations were greater than 10.000 at three of the facilities. Only one facility (number 6, a copper
smelter in Arizona), appears to be truly remote from significant populations: fewer than ten people reside
within one mile of this facility.
These statistics may somewhat overstate the potential exposed populations, however. The
population residing directly adjacent to most of the facilities is generally much smaller than the three-mile
total, and at three facilities, the bulk of the nearby population is located across intervening water bodies
that preclude groundwater exposure and reduce the potential for other exposures as well. In addition, as
will be seen below, site characteristics are also present (low dependence on groundwater, etc.) that further
reduce the potential for exposures.
Potential ecological receptors were also identified at the majority of the facilities. Five of the
facilities are located adjacent to rivers, streams, or wetlands, into which releases may occur through
groundwater discharge or surface runoff. At three other sites located in arid regions, there appear to be no
perennial water bodies near the facilities and no aquatic biota receptors were identified. No information
was developed on potential terrestrial receptors near these facilities. The other facility (number 9, a zinc
smelter in Oklahoma) was determined to have ceased production operations in 1996, and no data were
developed on receptors.
4.3.4	Potential Exposure Pathways at the High-Risk Facilities
The fourth and fifth columns of Exhibit 4-12 summarize the information that was gathered related
to potential exposure pathways at the nine high-risk facilities. One striking feature of these data is that
there appears to be only one facility (number 4, a zinc smelter in Tennessee) where potential exposure
through the groundwater pathway appears to be plausible. Even at this site, the possibility of groundwater
exposures depends on whether significant releases actually occur, and it is unclear from the evidence in the
record whether land management units (as opposed to tanks) are still in use at this facility to process or
store recycled materials. At the other seven facilities where data are available, evidence suggests that
groundwater exposures are unlikely, either because there are no wells located downgradient of the
treatment units, because groundwater is drawn from a deep aquifer which is isolated from shallow
groundwater contamination, or because the facilities are located adjacent to rivers into which groundwater
discharge occurs without any intervening wells.
April 30, 1998

-------
Significant surface water exposure (to biota or humans consuming biota) appears to be plausible at
some of the facilities located near water bodies. The facilities where this appears to be most likely include
facility 4 (again assuming releases occur), which is located adjacent to wetlands, and facilities 2 and 8,
where groundwater discharges into relatively low-volume surface water bodies. At facility 3, the
groundwater flow discharges to a small river near river-fed springs which are used as a drinking water
supply at a large railyard and for approximately 30 residences. There is as yet, however, no evidence for
significant groundwater discharge from this facility to the river. At facility 8 (a zinc smelter in
Pennsylvania), runoff releases are a plausible exposure mechanism in a creek adjacent to the site.
Discharges to surface water are also possible at other facilities, but the large volume of the
receiving waters appears to reduce the potential significance of these exposures. This is the case at facility
5, which is adjacent to the Savannah River, and facility 7, which is on the shore of the Patapsco river in
Maryland. At facility 8, groundwater discharge (and runoff to the creek) ultimately discharge to the Ohio
River.
4.3.5 Documented Environmental Releases and Damages from the High-Risk Facilities
Several of the facilities have long histories of documented environmental contamination.
However, in most cases, the connection between recycling operations and the observed releases cannot be
confirmed. Facilities 2 and 6 , for example, are located in an area of Arizona where there are many mining
an mineral processing operations. Particularly near facility 2, there is severe regional groundwater
contamination, associated with the combined releases from many mines, ore processing, and smelting
operations. In addition, there is a large lake not far from the facility that is contaminated with copper, iron,
and other metals at concentrations that cause the water to be visibly brown or blue-green, as well as toxic
to aquatic organisms. This lake is located in the midst of several very large mining and ore processing
operations.
It is difficult to attribute these instances of groundwater and surface water contamination to any
single source. While it is possible that historical recycling operations have contributed to this problem, the
magnitude of this contribution cannot easily be quantified. It is likely, however, that the releases from
recycling, while not completely abolished, may have been substantially reduced by the move away from
land management units.
At several other sites, instances of environmental contamination can be more plausibly linked to
specific facilities and historic recycling, if not to current waste management operations. At facility 1. for
example, there is documented contamination of shallow groundwater under the tailings impoundment that
may have been used to co-dispose of the potentially recycled barren filtrate stream. At facility 3, well-
defined plumes of groundwater contamination have been characterized downgradient of historic (now
closed) units that were used to store recycled streams. At facilities 4 and 5, monitoring has shown the
presence of sediment and groundwater contamination beneath and adjacent to waste management units, but
the available data do not allow this contamination to be attributed to recycling operations. At the
remaining facilities, no data related to past releases from recycling were identified. At a few sites, releases
of hazardous materials have been reported, but no link can be established to recycling.
April 30, 1998

-------
Damage to ecological receptors is poorly documented at the nine high-risk facilities. In some
cases (the Arizona copper facilities) ecological damage has undoubtedly occurred due to widespread
excavation and disturbance of natural habitats, and probably due to widespread surface and groundwater
contamination from multiple mines, mills, and smelters. The contribution of recycling to this damage is
not known, however.
4.4 Uncertainties and Limitations in the Risk and Benefits Assessment for the Modified Prior
Treatment Baseline
Given unlimited resources and data, the ideal way to estimate the benefits of the LDRs for mineral
processing wastes would have been to conduct site-specific population risk assessments for each of the
facilities and units where these wastes are managed. This was not possible for obvious practical reasons
and because of limited data. Instead, the Agency has used generic screening level analyses to identify
potentially high-risk streams and facilities and to see whether the number of facilities with high recycling
risks would change in response to regulation. In addition, the Agency conducted limited reviews of site-
specific data at facilities where the screening analysis predicted high risks in order to confirm the
plausibility of the risk estimates and document whether environmental releases or damages had already
occurred. The remainder of this section provides a brief discussion of the key assumptions and methods
used in the screening level assessment and potential uncertainties and limitations of that assessment.
The generic multipathway risk assessment for the storage of mineral processing recycled materials
relies on relatively simple, conservative models of contaminant releases, transport, exposures, and risks.
Therefore, the risk assessment results cannot be used to estimate risk reduction benefits for actual exposed
populations residing near the mineral processing facilities. Instead, they only provide plausible estimates
of the potential health risks faced by hypothetical individuals under the defined exposure conditions.
The assessment also shares the limitation of all generic analyses that high levels of uncertainty and
variability may not be adequately treated, since only a limited number of simple models and representative
data are used to model risks from a wide range of units, wastes, and constituents. Many of these generic
sources of uncertainty have been addressed in our previous work on mineral processing wastes, and the
following discussion is focused on limitations specific to the multipathway analysis.
As noted previously, constituent concentration data are available for only 15 recycled waste
streams, and for some wastes only small numbers of samples are available. It is interesting to note that two
of the wastes for which estimated risks are the highest (copper acid plant blowdown and zinc spent surface
impoundment liquids) also are those for which the largest number of samples are available. It is not
possible to estimate which of the other wastes might also show risks above levels of concern if more data
were available. As noted previously, the storage risk assessment covers waste streams representing about
40 percent of the total waste generated and about 65 percent of the recycled volume.
Limited data also are available concerning waste characteristics, including constituent speciation.
solubility, and bioavailability. Throughout this analysis, we have assumed that all constituents would
behave in such a manner as to maximize exposure potential. For example, we have assumed that none of
the constituents would leach from soils after their initial deposition, and that all of the constituents would
be bioavailable in the water column. Generally these assumptions increase the level of conservatism of the
risk assessment.
In evaluating potential risks to human health, exposure through multiple release pathways
(leaching to groundwater, particulate suspension, surface runoff, inlet/outlet failure for surface
impoundments) were considered. In this analysis, it was assumed that all of the constituent mass placed in
April 30, 1998

-------
the management units was available for release through all release pathways. This assumption may have
resulted in the overestimation of risks for some pathways due to double counting of constituent mass. For
example, if constituent mass is depleted over time due to leaching, then the mass of constituent available
for release thruu'gh other pathways (e.g. paniculate suspension) is reduced.
Mass balance calculations were performed for the non-groundwater release pathways (see
Appendix 1.2.2.1), and it was found that the proportion of constituent mass released by all of these
pathways was below one percent of the total mass present in the management units. Thus, the neglect of
mass balance considerations for these pathways resulted in negligible bias in the risk assessment results.
The mass balance calculations did not include the groundwater pathway, however, because the
methodology used did not allow release masses (only release concentrations) to be calculated. It is
therefore possible that substantial depletion of some soluble and mobile constituents could occur through
groundwater leaching, and these constituents would not be available for release by other pathways. This
possibility has little or no impact on the findings of the risk assessment for waste piles, since, even if it is
assumed that all of the constituents are released through every pathway, all calculated risks are below
levels of concern. While it is not possible to estimate the magnitude of the potential bias in the risk results
for surface impoundments, it is likely to be low, because of the relatively high through-put which is
assumed for the impoundments, relative to plausible leachate release volumes.
Releases to groundwater and groundwater fate and transport were evaluated using EPA's
EPACMTP model. Leachate concentrations and constituent- and facility-specific DAFs were derived
using the best available data, which, although limited, provided a reasonable basis for generic modeling of
the representative facilities. High-end (95th percentile) and central tendency (75th percentile) DAFs were
used to explore the levels of uncertainty and variability in groundwater fate and transport processes.
Comparison of the HE and CT DAFs indicates that the probability distribution of the DAF values is quite
broad, and that the level of uncertainty is quite high. As for the other pathways, exposure assumptions
were used that provide a moderate degree of conservatism for the groundwater pathway risk estimates.
Release events and amounts for non-groundwater pathways were simulated mostly using the
general methods adopted in HWIR-Waste. The one exception is air particulate generation, which was
estimated using the SCREEN3 model, rather than the model recommended in HWIR-Waste. SCRBHN3 is
a widely-accepted screening level EFA model. We believe that it is appropriate for the types of release
events that were modeled. The use of SCREEN3 is unlikely to have biased the results of the risk
assessment significantly compared to other methods. However, no data were available concerning the
particle size characteristics of the two wastes streams that were modeled, so EPA relied on data from an
earlier study of mineral processing wastes stored in waste piles. Based on limited information, the Agency
believes that the particle size distribution which was used may overstate the potential for particulate release
of the more coarse-grained, high-density zinc waste ferrosilicon, while more accurately describing the
potential for particulate releases of aluminum cast house dust.
Run-off releases were evaluated using the same model (the Universal Soil Loss Equation. USLE)
applied in the HWIR-Waste risk analysis, with input parameters varied slightly to reflect the operating
characteristics of the waste piles being simulated and the likely geographic distribution of the recycling
facilities. We also assumed that no runoff controls would be used. The risk results are not particularly-
sensitive to these assumptions, as exposure concentrations in soil and surface water due to run-off events
are very far below the levels of concern for all exposure pathways.
The ISCST3 model used to predict particulate air concentrations and deposition rates is a state-of-
the-art model that has been used in many regulatory proceedings by EPA. The input data that were used,
the "worst-case" meteorological conditions, were somewhat more conservative than the meteorological
April 30, 1998

-------
data used in HWIR-Waste with a similar model. Thus, our estimates of air impacts are likely to be higher
than those that would have been achieved had we replicated the HWER-Waste approach. Again, however,
all the estimated risks and exposure concentrations for air releases are far below levels of concern, despite
this conservatism.
The modeling of releases from surface impoundments reproduced exactly the approach used in
HWIR-Waste. This release model and its input parameters were derived based on data from management
units in the pulp and paper industry, and just how reliably they predict releases from surface
impoundments in the mineral processing industries is not known. This is clearly a major source of
uncertainty in the risk assessment, as these release events are the only non-groundwater releases for which
health risks are predicted to be above levels of concern.
Because of resource limitations and the specific characteristics of the facilities that we were
evaluating, we developed simplified approaches to modeling the concentrations of waste constituents in
surface soils and surface water to substitute for the much more elaborate methods used in HWIR-Waste.
In the case of surface run-off, in the absence of site-specific data, we conservatively assumed that soil
contamination would be limited to relatively small distances (50 or 100 meters) from the piles in arbitrarily
defined circular plumes. This is only intended as a bounding analysis, and the finding that this pathway is
not a major concern can be supported by the fact that, even with these relatively small exposure areas (and
the resultant high soil concentrations), constituent concentrations due to run-off events were two or more
orders of magnitude below levels of health concern.
Similarly, to be conservative, we assumed that all of the run-off and all of the particulate generated
by the waste piles would be deposited on the watershed in such a way that all of these materials would
rapidly find their way into surface water. This approach, while it resulted in surface water concentrations
far below levels of health concern, may be less conservative than the approach taken for surface soils,
because the CT and HE streams are both rather large, and the model does not take into account possible
run-off or deposition into smaller streams, lakes, or ponds where constituents may accumulate in surface
water or sediment.
The approach taken in evaluating fish tissue concentrations was also somewhat more conservative
than that taken in HWIR-Waste, in that the highest available BCF or B AF values were used, rather than
representative values, in our calculations. For some constituents (arsenic, cadmium, mercury, thallium),
this approach resulted in considerably higher tissue concentrations than would have been calculated had
we used the HWIR-Waste values. This may be a major source of uncertainty in this screening level
assessment, since the fish ingestion pathway resulted in the highest risks predicted for several of the
constituents and waste streams.
April 30. 1998

-------
5. OTHER REGULATORY ISSUES
This section discusses aspects of today's final rule that are not directly related to the application of
LDR standards to newly identified hazardous mineral processing wastes, as well as certain other
administrative requirements.
5.1 Non-LDR Regulatory Issues
Today's final rule addresses several issues that relate to the definition and regulation of hazardous
mineral processing wastes. The Agency is today taking final action in response to several Appeals Court
remands of previous regulatory activity that relate to both particular waste categories and the identification
of hazardous mineral processing wastes generally. These topics are discussed briefly helow,
5.1.1	Use of the TCLP Test for Identifying Hazardous Mineral Processing Wastes
The Agency has decided to continue using the TCLP (SW-846 Test Method 1311) as the basis for
determining whether mineral processing wastes and manufactured plant gas wastes are hazardous by the
toxicity characteristic. The applicability of the TCLP to mineral processing wastes was challenged in
Edison Electric Institute v. EPA (2 F.3d 438 (D.C. Cir. 1993)). In the Edison case, the Court held that
EPA had not provided sufficient information in the record to establish a rational relationship between the
TCLP's mismanagement scenario'^ and management of mineral processing wastes. Specifically, the Court
remanded use of the TCLP for identifying hazardous mineral processing wastes and directed EPA to
demonstrate that disposal of mineral processing wastes in a municipal solid waste landfill is a "plausible1'
mismanagement scenario.
After further research and analysis, the Agency has compiled a substantial amount of evidence to
suggest that mineral processing wastes may plausibly be mismanaged in a manner similar to that described
in the TCLP mismanagement scenario. In particular, the Agency has identified a number of cases in which
mineral processing wastes are likely to have been co-disposed with municipal solid waste. The specific
details of these cases are discussed in the preamble to today's rule and in the supporting TCLP Technical
Background Document, available in the public docket. As a consequence of this evidence, the Agency has
concluded that the TCLP should continue to be used to determine whether mineral processing wastes are
hazardous by the toxicity characteristic.
The Agency also has determined that a Regulatory Impact Analysis (RIA) is not necessary for this
rule. Today's final rule does not change existing Agency regulations or policy; rather, it merely complies
with the Court's ruling that the Agency provide more extensive evidence for an existing Agency position.
It is, therefore, unlikely that there will be a significant additional impact associated with continuing
application of the TCLP to mineral processing wastes
5.1.2	Remanded Listed Mineral Processing Wastes
The Agency also is today revoking the current hazardous waste listings for five court-remanded
smelting wastes. The Agency has determined not to re-list the wastes, but will instead regulate them,
where appropriate, as characteristic wastes.
3~ The mismanagement scenario assumes that wastes will be co-disposed with municipal solid waste
and forms the basis for the TCLP.
April 30, 1998

-------
In 1980. the Agency listed as hazardous eight wastes generated from primary metal smelters.
Later that year, in response to enactment of the Bevill Amendment, the Agency withdrew the listings. In
1985, after further study of the wastes, the Agency proposed to relist six of the wastes, but did not finalize
the listings and withdrew the proposal in October 1986. In response to a court order {Environmental
Defense Fund v. EPA, 852 F. 2d 1316 (D.C. Cir. 1988)), EPA relisted the six wastes. This relisting was
subsequently challenged by the American Mining Congress (American Mining Congress v. EPA. 907 F. 2d
1179 (D.C. Cir. 1990)). The Court upheld one of the listings (K088, spent potliners from primary
aluminum reduction), but determined that the Agency's record for the five remaining waste streams did not
adequately address certain issues raised by commenters during the rulemaking. These five listings are:
K064 --	Copper acid plant blowdown;
K065 --	Surface impoundment solids at primary lead smelters;
K066 --	Acid plant blowdown from primary zinc production;
K090 --	Emission control dust and sludge from ferrochromium-silicon production; and
K091 	Emission control dust and sludge from ferrochromium production.
The Court did not vacate the listings, and therefore they remain in effect.
Upon further study, the Agency determined that current waste generation and management
practices did not warrant the listing of these five wastes. Many of the wastes are no longer generated, and
of the wastes that continue to be generated, many are recycled. As a consequence, the Agency has
determined that these wastes may be best regulated by characteristic and not as listed wastes. A detailed
description of current management of these wastes, along with a discussion of the Agency's specific
rationale for its decision to withdraw the five waste listings, are provided in the Five-Remanded Wastes
Technical Background Document, available in the public docket accompanying today's rule.
The Agency also has determined that a Regulatory Impact Analysis (RIA) is not necessary for this
proposal. As discussed above, many of the wastes affected by the Agency's decision are no longer
generated. In addition, a relatively small number of facilities generate the remaining wastes, and most of
these remaining wastes are recycled. Consequently, the Agency does not anticipate that a significant
impact will be incurred by the regulated community as a result of today s rule.
5.1.3 Titanium Tetrachloride Chloride-Ilmenite Wastes
Finally, the Agency has determined to classify titanium tetrachloride chloride-ilmenite wastes as
mineral processing wastes not eligible for Bevill exemption. Waste acid from the production of titanium
tetrachloride also was among the many wastes conditionally-exempted from Subtitle C regulation under the
1980 Bevill Amendment. In 1989, the Agency determined that the waste did not qualify for Bevill-exempt
status because the Agency found that the waste is a mineral processing waste that did not meet the criteria
for exemption for mineral processing wastes (high volume and low hazard).
One titanium tetrachloride producer, the DuPont Corporation, requested a determination that waste
from its production process be classified as beneficiation waste, and therefore eligible for the Bevill
Exemption. DuPont argued that its process differed from that used by other manufacturers and included a
beneficiation step that generated the wastes in question. When the Agency determined that the wastes
were generated as a result of mineral processing operations and not beneficiation activities, DuPont
April 30, 1998

-------
challenged the determination in court (Solite Corporation v. EPA, 952 F.2d 473 (D.C. Cir. 1991)). Based
on the challenge, the Court remanded the Agency's determination for further consideration.
After a detailed analysis of DuPont's chloride-ilmenite production processes, the Agency has again
concluded that the waste acid (ferric chloride) is a mineral processing waste and is not eligible for the
Bevill exemption because it does not meet the criteria for exempting such wastes. The Agency's
determination is based on a more detailed understanding of DuPont's production process that found no
evidence to support DuPont's contention that some steps in the process, including the step generating the
waste acid, can be classified as beneficiation. Details concerning DuPont's process, and the Agency's
analysis of the process and its rationale for determining that the process does not include beneficiation
operations, are provided in the preamble to today's rule.
The Agency also has determined that a Regulatory Impact Analysis (RIA) is not necessary for this
rule. Today's proposal clarifies earlier Agency regulatory determinations and affects only one member of
the regulated community. As a consequence, the Agency anticipates that there will be no significant
impact on the regulated community as a result of this rule.
5.2 Other Administrative Requirements
This section describes the Agency's response to other rulemaking requirements established by
statute and executive order, within the context of today's final rule.
5.2.1	Environmental Justice
EPA is committed to addressing environmental justice concerns and is assuming a leadership role
in environmental justice initiatives to enhance environmental quality for all residents of the United States.
The Agency's goals are to ensure that no segment of the population, regardless of race, color, national
origin, or income bears disproportionately high and adverse human health and environmental impacts as a
result of EPA's policies, programs, and activities, and that all people live in clean and sustainable
communities. In response to Executive Order 12898 and to concerns voiced by many groups outside the
Agency. FPA's Office of Solid Waste and Emergency Response formed an Environmental Justice Task
Force to analyze the array of environmental justice issues specific to waste programs and to develop an
overall strategy to identify and address these issues (OSWER Directive No. 9200.3-17).
Today's final rule covers wastes from mineral processing operations. The environmental problems
addressed by this rule could disproportionately affect minority or low income communities, due to the
location of some mineral processing and waste disposal facilities. Mineral processing sites are distributed
throughout the country and many are located within highly populated areas. Mineral processing wastes
have been disposed of in various states throughout the U.S., representing all geographic and climatic
regions. In some cases, mineral processing waste is generated in one state and disposed of in another. In
addition, mineral processing wastes are occasionally disposed of in municipal solid waste landfills.
Today's rule is intended to reduce risks from mineral processing wastes, and to benefit all
populations. It is, therefore, not expected to result in any disproportionately negative impacts on low
income or minority communities relative to affluent or non-minority communities.
5.2.2	Unfunded Mandates Reform Act
Under Section 202 of the Unfunded Mandates Reform Act of 1995, signed into law on March 22.
1995, EPA must prepare a statement to accompany any rule for which the estimated costs to state, local, or
April 30, 1998

-------
-69-
tribal governments in the aggregate, or to the private sector, will be $100 million or more in any one year.
Under Section 205, EPA must select the most cost-effective and least burdensome alternative that achieves
the objective of the rule and is consistent with statutory requirements. Section 203 requires EPA to
establish a plan for informing and advising any small governments that may be significantly affected by the
rule.
HPA has completed an analysis of the costs and benefits from today's final rule and has determined
that this rule does not include a federal mandate that may result in estimated costs of $100 million or more
to either state, local, or tribal governments in the aggregate. The private sector is also not expected to incur
costs exceeding S100 million per year under either Option considered in this RIA.
April 30, 1998

-------
6. CONCLUSIONS
This section presents the Agency's preliminary conclusions regarding the regulatory impacts of
implementing the options presented in today's notice. The chapter is organized around the central elements
of the analyses provided in previous sections, namely characterizing the affected population of waste
streams, facilities, and mineral industry sectors, analyzing the cost and economic impacts of implementing
the options, and assessing the human health benefits of adopting these regulatory alternatives.
6.1	The Affected Universe
As described in depth in the preceding sections, EPA conducted intensive research in an attempt to
identify and characterize all of the waste streams that might be affected by imposition of LDR
requirements on non-exempt hazardous mineral processing wastes. This research has yielded a group of
121 potentially hazardous mineral processing residues that may be subject to Subtitle C controls and
accordingly, to new LDR treatment standards.
This number is far smaller than the total population of mineral industry wastes, and reflects EPA's
step-wise process of eliminating from the analysis wastes that are: (1) generated by extraction and
beneficiation operations (these are Bevill-exempt), (2) the 20 exempt special mineral processing wastes,
(3) wastes that are known or expected to be non-hazardous, and (4) wastes believed to be fully recycled
and not stored on the land. The remaining waste streams have been included in the Agency's analyses,
though in many cases substantial uncertainties regarding their generation rates, hazardous characteristics,
and management practices have led EPA to develop several different estimates of these parameters, which
in turn produce variable estimates of costs and benefits arising from new regulatory controls.
EPA recognizes the limitations that these data gaps and simplifying assumptions impose on the
accuracy of the analyses presented above. HPA has provided detailed analyses of the potential cost and
benefit impacts of the LDR options in the interests of providing interested parties with as much pertinent
information as possible.
The analysis also examines the remediation of media contaminated with manufactured gas plant
(MOP) waste. EPA estimates that there are approximately 2,500 potentially affected commercial MGP
sites in the United States, and approximately 28,700 potentially affected captive MGP sites. Each
contaminated site is believed to have between 500 and 5,000 tons of RCRA hazardous contaminated
media. The total amount of hazardous contaminated media at all sites is estimated at over 26 million tons.
Finally, this analysis examines the impact of today's rule on facilities operating Class I U1C wells, and
finds that only two facilities are likely to be affected.
6.2	Cost and Economic Impacts of the Rule
Option 1 is estimated to result in annual costs to the regulated community of approximately
S10,000,000. In contrast. Option 2 is estimated to result in costs of only about 5230,000. These figures
represent best estimates. Exhibit 6-1 highlights the differences between the minimum, expected, and
maximum value cases.
April 30, 1998

-------
-71 -
Exhibit 6-1
Summary of Cost Analysis Results
($/Year)

Minimum
Expected
Maximum
Option 1
S7.200.000
$10,000,000
514,000,000
Option 2
S41,000
S230.000
$230,000
J Options are described in detail n Section 1.
Option 1, although it is the higher cost option, results in relatively low costs due to the option's
lack of prohibition in the recycling of secondary materials through beneficiation or Bevill process units.
Option 2 results in relatively low net costs to industry because the option essentially allows facilities to
continue operating as they currently operate. EPA assumes that in some cases, facility owners and
operators, out of misunderstanding of current requirements, handle spent materials improperly. Option 2
would allow these owners and operators to continue to handle spent materials in this manner. The only
costs incurred by facility owners under this option are relatively insignificant recordkeeping and reporting
requirements.
Additional costs will be incurred due to the rule's effects on cleanups of contaminated media at
manufactured gas plants. The incremental annual cost associated with these cleanups is estimated at
approximately $6,200,000 (which is in addition to the costs summarized in Exhibit 6-1). Finally, EPA
estimates the cost of today's rule to facilities operating UIC wells to range from a minimum annualized
cost of $0, to an intermediate annualized cost of $530,000, to a maximum annualized cost of $3,700,000
Economic impacts on the mineral processing industry were estimated using four screening ratios.
The results of this analysis arc summarized in Exhibit 6-2 and discussed below:
Exhibit 6-2
Summary of Economic Impact Screening Results:
Impact Measure
Percent of Firms or Sectors w/ Significant Impacts
Option 1
Option 2
Cost/Sales
0<7c of firms
0% of firms
Cost/Earnings
0% of firms
0% of firms
Cost/Value of Shipments
10% of sectors
0% of sectors
Cost/Value Added
13% of sectors
0ck of sectors
April 30. 1998

-------
Option 1
	Based on the two firm-specific ratios (cost/sales and cost/earnings), no significant
economic impacts are expected to result from Option 1.
	Based on cost as a percentage of value of shipments, three of the 29 sectors (10
percent sectors) are expected to incur significant impacts under Option 1.
Significantly affected sectors are projected to include mercury (36 percent
impact), tungsten (6 percent), and fluorspar/hydrofluoric acid (4 percent).
	Based on cost as a percentage of value added, two of the 16 sectors (13 percent)
are expected to he significantly affected under Option 1 (cadmium and selenium).
Option 2
	Option 2 is not expected to result in significant impacts under any of the four
measures.
The divergence between the Option 1 results based on the firm-specific measures (particularly
cost/sales) and those based on the sector-specific measures could result from diversified operations of
affected firms. In this case, it is possible that significant impacts might occur at the facility level even if
they do not lead to significant impacts at the firm level (i.e., due to the firm's additional operations besides
those in affected mineral processing sectors).
Like the impacts on mineral processing firms, impacts on owners of MGP sites and UIC wells are
not expected to be significant due to (1) the low costs per facility, and (2) the strong likelihood that MGP
sites with relatively higher cleanup costs are owned by relatively large utilities.
6.3 Health Benefits of the Proposed LDRs
The benefits of the proposed LDRs for mineral processing wastes take the form of reduced risks to
human health and the environment from improved management of the subject wastes. EPA has conducted
analyses of the potential health risks associated with the disposal of mineral processing wastes and the
storage of recycled streams and of the potential reductions in health risks that may be achieved under the
proposed regulatory options. Potential risks and benefits have been evaluated for groundwater exposures
to toxic waste constituents arising from waste disposal, and for groundwater and non-groundwater pathway
exposures to constituents released during the storage of recycled streams. Detailed descriptions of the
methods used to evaluate risks and benefits for waste disposal are found in Appendix A. and descriptions
of the methods used for the risk assessment for waste storage are found in Appendix J of this RIA. In
addition to these quantitative analyses, the Agency has conducted a limited evaluation of site-specific data
at nine mineral processing facilities identified as managing potentially high-risk wastes. This evaluation
examined current waste management practices, potential release and exposure pathways, identified
potentially exposed populations, and reviewed the history of environmental releases and contamination at
the facilities.
EPA estimates that the health benefits from improved waste disposal practices under either of the
regulatory options would be quite low compared to the modified prior treatment baseline, considering only
groundwater pathway exposures. For arsenic, which is a major risk-driving constituent for many wastes,
risk reduction would not occur, since the TC regulatory level and UTS leachate concentration are
identical. For other constituents, some exposure reduction could occur under these options, since the UTS
April 30, 1998

-------
levels are lower than the TC leachate concentrations, and because some non-TC analytes may not be
effectively immobilized by treatments designed to comply with the TC.
F.PA's evaluation of the potential groundwater risks associated with the storage of recycled streams
under the modified prior treatment baseline is described in Section 4.2. Estimated groundwater pathway
cancer risks under high-end (HE) baseline assumptions exceeded 103 at 23 of 56 facilities storing recycled
streams, while under central tendency (CT) assumptions, only 11 facilities exceed this level (Exhibit 4-5).
The HE noncancer hazard quotients for groundwater exposures exceed 1.0 at 26 facilities storing recycled
materials, and under CT assumptions baseline hazard quotients exceed 1.0 at 12 facilities (Exhibit 4-6).
All of the facilities for which baseline cancer risks or noncancer hazard quotients exceed levels of concern
manage wastewater and liquid nonwastewater streams in impoundments. Owing primarily to the low
recycled volumes and small facility sizes, the baseline groundwater risks for the two nonwastewater
streams managed in waste piles are below levels of concern under both CT and HE assumptions.
The analysis of non-groundwater pathway risks associated with waste storage under the modified
prior treatment baseline indicated that, for the majority of the pathways evaluated, estimated baseline risks
were far below levels of concern. As was the case for the groundwater pathway risk assessment, risks from
the storage of the two nonwastewater streams in waste piles were less than levels of concern for all release
events and exposure pathways.
Baseline risks greater than levels of concern were found for exposures to surface water
contaminated by releases from surface impoundment failures of some waste streams, however. In the case
of the direct ingestion pathway, one facility storing copper acid plant blowdown had an HE cancer risk
exceeding 10 \ Under CT assumptions, the estimated cancer risk for this facility was below the level of
concern. When exposure through fish consumption is considered, six facilities from three commodity
sectors had HE risks from waste storage exceeding cancer or noncancer levels of concern. Under CT
assumptions, risks from only two >torage facilities exceeded levels of concern for the fish ingestion
pathway. These results are summarized in Exhibit 4-9.
EPA did not quantitatively estimate the extent of risk reduction or the level of health benefits that
could be brought about by the proposed LDRs' effects on recycled materials storage. This is because the
available data and models do not allow the development of risk reduction estimates for tanks, containers,
and buildings, which would be the required management units for most of the recycled streams under
regulatory Option 1. If this option completely or substantially eliminates the release of recycled streams to
groundwater and other media, the baseline risks discussed in the previous paragraphs could all be reduced
to below levels of concern. Lesser degrees of control would result in less risk reduction and lower health
benefit*.
EPA evaluated site-specific conditions related to exposures and risk at nine facilities identified as
generating and managing potentially high-risk recycled streams. The results of this analysis are
summarized in Exhibit 4-12. The Agency found that, while management of these wastes in unlined land
units was historically commonplace, there has been a marked tendency in recent years (since about 1980)
to employ management techniques such as tanks or lined pads. In addition, while the resident populations
near the majority of these facilities are quite large (greater than 10,000 at three facilities), direct
groundwater exposures generally do not appear to be occurring, either because well locations are outside of
groundwater flow patterns from recycling units, drinking water is obtained from deep aquifers isolated
from shallow groundwater contamination, or groundwater discharges to surface water bodies adjacent to
the facilities, and no wells are present. At only one of the nine sites does there appear to be the potential
for human exposures through the consumption of groundwater contaminated by recycling operations, but
no releases have been documented at that site. At three sites, groundwater discharge to surface water is
April 30, 1998

-------
-74-
unlikely to pose significant risks due to the large dilution volume of the receiving waters, and the absence
of nearby water intakes. At one facility, contaminated groundwater may discharge to a small river near a
river-fed spring that is used as a drinking water supply. However, there is no evidence that contamination
from the mineral processing operations has yet reached the surface water.
Significant regional groundwater and surface water contamination is present in the vicinity of the
two copper smelting facilities in Arizona. However, this contamination cannot be attributed to current
recycling operations, but rather is the combined result of the large number of mines, mills, and smelters
that have operated in the area over the last century. At several of the facilities where sediment or
groundwater contamination can be attributed to historical recycling operations (e.g., in surface
impoundments), contamination is localized and no human health risk or damage to the environment has
been documented.
April 30, 1998

-------
ANALYSIS OF OPTIONS UNDER ALTERNATIVE BASELINES
APPENDIX A
This appendix presents the estimated costs, economic impacts, and benefits of regulatory options
under two alternative baselines, the "no prior treatment" baseline and the "prior treatment" baseline, for
mineral processing wastes under Phase IV LDRs. Under the no prior treatment baseline, wastes are
assumed to be managed (i.e., stored or disposed of), untreated, in unlined surface impoundments and waste
piles, i.e.. the practices that were generally in place prior to removal of these wastes from the Bevill
exclusion in 1989 and 1990. Under the prior treatment baseline, wastes are either treated to UTS levels
and disposed in a Subtitle D unit or stored prior to recycling in tanks, containers, and buildings if they are
spent materials or in unlined land based units if they are sludges or byproducts. The prior treatment
baseline assumes facility operators clearly understand the Subtitle C regulations that apply to their
secondary materials, i.e., that spent materials intended for recycling are not currently excluded from
Subtitle C regulation.
Although the costs and economic impacts under the no prior treatment baseline were analyzed in
the December 1995 RIA to the proposed rule, they are not analyzed in today's RIA because the costs of
managing wastes with no prior treatment are not properly attributed to this rule. In addition, while the
prior treatment baseline may more accurately assess the cost attributable to this rulemaking than the
modified prior treatment baseline (i.e., the baseline used in the main analysis). EPA believes the modified
prior treatment baseline more accurately reflects actual practice in the mineral processing industry. In both
cases, however, EPA has elected to present the cost and benefits attributable to these other baselines in this
Appendix.
The methodology for estimating the costs and economic impacts under these alternative baselines
is the same as the methodology used in the primary analysis, which is discussed in Section 3.1. The
estimated costs and economic impacts under these baselines are presented in Section A.l of this Appendix.
Section A.2 presents the results of the risk analysis for the no prior treatment baseline. Additional
information supporting the risk analysis is included in Section A.3.
A.l Costs and Impacts
In developing its estimates of the proposed rule's costs and economic impacts, EPA used a
dynamic analysis to predict changes in the management of newly identified mineral processing wastes.
The dynamic analysis accounts for a shift in the amount of material that is recycled rather than being
treated and disposed due to incentives and disincentives for future recycling. EPA estimated the
percentage of hazardous material sent to treatment and disposed for each baseline and option. The
remaining hazardous material is considered to be recycled. The dynamic analysis reflects the shifts in
management anticipated in each baseline/option combination.
Exhibit A.l-1 presents required changes in management practices as a result of the proposed Phase
IV Land Disposal Restrictions for the wasted portion and the recycled portion of hazardous mineral
processing secondary materials for the four regulatory options. Exhibit A. 1-2 presents the predicted
changes in recycling, given the required changes in management practices listed in Exhibit A.l-1. The
information in Exhibit A. 1-2 combines into an overall impact all incentives operating at a facility. For
instance, under Option 1 assuming the modified prior treatment baseline, Exhibit A.l-1 suggested that
there would be (1) no change in the amount recycled due to treatment requirements, and (2) a decrease in
the amount recycled because of the stricter recycling unit standards. Because, however, the incremental
cost of storing material in a tank, container, or building prior to recycling is usually less than the cost of
moving that material to treatment and disposal, the overall predicted effect of this option-baseline
April 30, 1998

-------
A-2
combination is a small decrease in the amount of material recycled. (That is, a facility operator in this
option-baseline combination would usually pay the extra cost of storage rather than changing management
practices.)
Exhibit A.1-1
Changes in Management of Hazardous Mineral Processing Waste
Baseline/Option
Affected Material
Required
Change in Management
Implied Change In
Recycling
NTT
Wasted
Disposal to UTS and Disposal
Increase
MPT/PT
Portion
TC to UTS
No Change
N'PT/MPT to Option 1

Unlined Units to TCBs
Decrease
PT (SL/BP) to Option 1

Unlined Units to TCBs
Decrease
PT (SM) to Option 1
Recycled
TCBs to TCBs
No Change
NPT/MPT to Option 2
Portion
Unlined Units to Unlined Units
No Change
PT (SL/BP) to Option 2

Unlined Units to Unlined Units
No Change
PT (SM) to Option 2

TCBs to Unlined Units
No Change
NPT - No Prior Treatment Baseline	SL - Material classified as a Sludge
MPT - Modified Prior Treatment Baseline	BP - Material classified as a Byproduct
PT - Prior Treatment Baseline	SM - Material classified as a Spent Material
Exhibit A. 1-2
Ov erall Predicted Changes in Recycling

Option 1
Option 2
No Prior Treatment
Increase
Big Increase
Modified Prior Treatment and Prior Treatment ( SL/BP)
Small Decrease
No Change
Prior Treatment (SM)
No Change
Increase
Exhibit A. 1-3 presents the percentages of the hazardous portion of mineral processing waste
streams that are sent to treatment and disposal, in both the baseline and post-rule options, and Exhibit A.l-
4 presents the percentages stored prior to recycling. Exhibits A. 1 -3 and A. 1 -4 are based on (1) the overall
predicted changes in recycling listed in Exhibit A. 1 -2 and (2) empirical data, as described below. For
option-baseline combinations that eliminate the differences in regulatory requirements for recycled
sludges, by-products, and spent materials, the proportion of material recycled is the same for all three types
of material after the rule goes into effect. Lastly, Exhibit A. 1 -5 shows the change in recycling percentage
for each option-baseline combination. For option-baseline combinations that increase recycling, the largest
shift is seen in Y? materials, and the smallest shift is seen in YS? materials.
April 30, 1998

-------
A-3
The limited available data on the recycling of two listed wastes, K061 (emission control dust from
electric arc steel furnaces) and F006 (wastewater treatment sludge from electroplating operations) were
used to quantify the expected shift in recycling. These data were used due to the fact that an increase in
the amount of K061 and F006 being recycled was observed after Land Disposal Restrictions (LDRs) for
K061 and F006 were promulgated.1 A 75 percent increase in K061 recycling was observed after the LDR
for K061 was implemented, from an average of 15 percent recycled pre-LDR to 90 percent recycled post-
LDR. Similarly, a 15-20 percent increase in the amount of F006 recycling was observed as a result of the
F006 LDR, from 0 percent recycled pre-LDR to 15-20 percent recycled post-LDR.2 Therefore, in the
December 1995 RLA, the Agency modeled the 75 percent shift for Y? materials from the No Prior
Treatment Baseline to Option 2 on K061, and the 15 percent shift for YS? materials from the No Prior
Treatment Baseline to Option 2 on F006. Because Option 2 in the December 1995 RIA is no longer
modeled, and Option I of today's proposal requires slightly more expensive storage units (tanks,
containers, and buildings instead of lined land-based units, EPA adjusted these data slightly for use in
Option 1 of today's RIA. The predicted shift in these two options for Y? material is 70 percent and the
predicted shift for YS? materials is 10 percent. EPA used best professional judgement to estimate the
shifts in the other option-baseline combinations.
Exhibit A. 1-3
Proportions of Waste Streams Treated and Disposed (in percent)
Baseline or Option
Affected
Material
Percent Treated and Disposed
Certainty of Recycling
Y Y? YS YS? N
Prior Treatment
SL/BP
0
15
25
80
100
Prior Treatment
SM
n
25
35
85
100
Modified Prior Treatment
All
0
15
25
80
100
No Prior Treatment
All
0
100
60
100
100
Option 1 from PT
All
0
25
35
85
100
Option 1 from MPT
All
0
25
35
85
100
Option 1 from NPT
All
0
30
40
90
100
Option 2 from PT
All
0
15
25
80
100
Option 2 from MPT
All
0
15
25
80
100
Option 2 from NPT
All
0
15
25
80
100
' 1990 Survey of Selected Firms in the Hazardous Waste Management Industry, Final Report, U.S.
E.P.A. Office of Policy Analysis, (July 1992).
2 Report to Congress on Metal Recovery, Environmental Regulation. & Hazardous Waste, U.S.
E P A., Washington. D.C., (February 1994).
April 30. 1998

-------
A-4
Exhibit A. 1-4
Proportions of Waste Streams Stored Prior to Recycling (in percent)
Baseline or Option
Affected
Material
Percent Recycled
Certainty of Recycling
Y Y? YS YS? N
Prior Treatment
SL/BP
100
85
75
20
0
Prior Treatment
SM
1(X)
75
65
15
0
Modified Prior Treatment
All
100
85
75
20
0
No Prior Treatment
All
100
0
40
0
0
Option 1 from PT
All
100
75
65
15
0
Option 1 from MPT
All
100
75
65
15
0
Option 1 from NPT
All
100
70
60
10
0
Option 2 from PT
All
100
85
75
20
0
Option 2 from MPT
All
100
85
75
20
0
Option 2 from NPT
All
100
85
75
20
0
Exhibit A.1-5
Change in Recycling Percentage for Affected Option-Baseline Combinations
Baseline or Option
Increase in Recycling (percent)
Certainty of Recycling
Y Y? YS YS? N
Option 1 from NPT
0
70
20
10
0
Option 1 from MPT & PT (SL/BP)
0
-10
-10
-5
0
Option 1 from PT (SM)
0
0
0
0
0
Option 2 from NPT
0
85
35
20
0
Option 2 from MPT & PT (SL/BP)
0
0
0
0
0
Option 2 from PT (SM)
0
10
10
5
0.00
Notes for Exhibits A.1-3, A.1-4, and A.1-5:
Bold type indicates shifts derived from empirical data
Y means that EPA has information indicating that the waste stream is fully recycled.
Y? means that EPA, based on professional judgment, believes that the waste stream could be fully
recycled.
YS means that EPA has information indicating that a portion of the waste stream is fully recycled.
YS? means that EPA, based on professional judgment, believes that a portion of the waste stream
could be fully recycled.
SM - Spent material BP - Byproduct SL - Sludge
Cost results for all three baselines are summarized in Exhibit A. 1-6. In general, the costs for the
no prior treatment baseline are greater than for the modified prior treatment baseline (the baseline used in
the main analysis) because facilities incur the full cost of waste treatment when coming into compliance
April 30, 1998

-------
A-5
from the no pnor treatment baseline. Conversely, the costs in the prior treatment baseline are lower than
the modified prior treatment baseline because recycled spent material are assumed to be already managed
in tanks, containers, and buildings. The savings in the prior treatment baseline attributed to baseline
management practices is most clearly 
-------
A-6
Exhibit A.1-7
Option 1 Incremental Costs Assuming No Prior Treatment

Minimum Value Case
Expected Value Case
Maximum Value Case

Total
Avg. Fac.
Total
Avg. Fac.
Total
Avg. Fac.

Incremental
Incremental
Incremental
Incremental
Incremental
Incremental

f'mt H/vri
fncf iVvrl











Alumina and Aluminum
1. 100.000
49.000
3.200.000
140.000
4.800.000
210.000
Antimony


2.100.000
360,000
3,800.000
640.000
HervlP'.im
230.000
250.000
2.300.000
1.100.000
9,900.000
4.900.000
Bismuth


710.000
710.000
1.800.000
1.800.COO
Cadmium

-
730.000
360.000
4,500.000
2.200.000
Calcium


9
9
9
9
Chromium and Ferrochromium
190.000
190.000
190,000
190.000
200.000
200,000
Coal Ctas



-
260.000
260.000
Copper
10.000.000
1.000,000
10.000.000
1,000.000
11.000.000
1.100.000
Elemental Phosphorus
2.700.000
1.300.000
2.700.000
1,300.COO
2.700.000
1,300.COO
Fluorspar and Hydrofluoric Acid


180.000
59.000
370.000
120.000
Germanium


210.000
52.000
470.000
120.000
Lead
84.000
28.000
5,100.000
1.700.000
9,900.000
3.300.000
Magnesium and Magnesia from
Brines
2.000.000
990.000
2,000.000
1,000.000
2,100,000
1.100.000
Mercury
-
-
420.000
60.000
1400,000
200.000
Molybdenum. Ferromolybdenum.
and Ammonium Molybdate

-
10,000.000
920.000
29,000,000
2.600,000
Platinum Group Metals
-
-
160.000
53.000
250.000
82.000
Rare Eanhs
220.000
220.000
1.700.000
1.700.000
5.000.000
5.000.000
Rhenium
-

2,900.000
1.400.000
5.100.000
2.500.00C
Scandium
-
-
260.000
37.000
460.000
66.000
Selenium
530.000
270.000
720.000
240.000
2.400.000
790.00C
S\nthetic Ruttle
.

1.400.000
1.400.000
2.400,000
2,400,000
Tantalum. Columbium. and
Ferroeolumbtum
460.000
230.000
680.000
340.000
920.000
460.000
Tellurium
-

390.000
200.000
1.900.000
930.000
Titanium and Titanium Dioxide
1.700.000
840.000
16.000.000
2,300,000
28,000,000
4.000.000
Tunssten


320,000
53,000
680,000
110.000
Uranium
.
.
830.000
49.000
1.500.000
90.000
Zinc
11,000,000
3.700.000
14,000.000
4.700,000
18,000.000
5.900.000
Zirconium and Hafnium
.

1.900.000
970,000
11.000.000
5,600.000
Total / Average
10.000,000

81.000.00f0

160,000,000

April 30, 1998

-------
A-7
Exhibit A. 1-8
Option 1 Incremental Costs Assuming Prior Treatment

Minimum Value Ca*>e
Expected
Value Case
Maximum Value Case

Total
Avg. Fac.
Total
Avg. Fac.
Total
Avg. Fac.

Incremental
Incremental
Incremental
Incremental
Incremental
Incremental













Alumina and Alumimm
2^0.000
12,000
760.000
33.000
1.400.000
61.000
Antimonv


6.800
1.100
6.d00
MOO
Bervlli.irn
570
570
2.800
1 400
2.800
1.400
Bismuth


5.600
> 600
6.200
6.200
Cadmium

-
67.000
34,000
430.000
220.000
Calcium
.
-
9
9
9
9
Chromium and Ferrochromtum
57.000
57 000
57.000
57.000
64.000
M.OCO
Coal Gas
.
-
-
-
66.000
66.000
Copper
2.700.000
270.000
2.500.000
250.000
2.500.000
250.000
Elemental Phosphorus
290.000
140.000
290.000
140.000
290,000
140.000
Huorspar and Hydrofluoric Acid

-
49.(XX)
16.000
81,000
27.000
Germanium
-
-
14.000
3.400
16,000
3.900
Ix'ad
27,000
9.000
89.000
30,000
120,000
40.000
Magnesium and Magnesia from
Br.nes
1. LOO
560
2.600
1.300
44.000
22.000
Mercury
-

12.000
1.700
12,000
1.700
Molybdenum. Ferromol>bdenuiii,
and Ammonium Molvhdate
-

7,100
660
7.300
660
Platinum Group Metals
-

5.400
1,800
11.000
3.800
Rare Earths
! 100
1.100
90.000
90.000
M 0.000
310.000
Rhenium


3.100
1.500
5.600
2.800
Scandium


7.900
1.100
7,900
1.100
Selenium
1.100
S70
17.000
5.600
110.000
35.000
Svn'.hetic Ruiile


64.000
64.000
120.000
120.000
Tantalum. Columbium. and
Ferrocolumbium
1.100
570
3,400
1,700
3.400
1,700
Tellurium


10,000
5.200
15,000
7.600
Titanium and Titanium Dioxide
3.700
1.800
130.000
19.000
240,000
35.000
Tunssten


6,800
1.100
6.800
1.100
Uranium
-

56.000
3.300
110.000
6.700
Zinc
62.000
21,000
no.ooo
38.000
150.000
51.000
Zirconium and Hafnium
.
.
4.500
2.300
4.500
2.300
Total i Average
3.400.000

4.4QO.OOO

6,100.000

April 30, 1998

-------
A-8
Exhibit A.1-9
Option 2 Incremental Costs Assuming No Prior Treatment

Minimum Value Case
Expected Value Case
Maximum Value Case

Total
Avg. Fac.
Total
Avg. Fac.
Total
Avg. Fac.

Incremental
Incremental
Incremental
Incremental
Incremental
Incremental

f*r*t
C
Cnet
TikI fxr\
Pnct (t'vr'i
Poet (Vvrj
Alumna and Aluminum
730.300
32.000
2.100.000
91.000
2.900.000
120.000
Antimonv


2.100.000
350.000
3.800.000
6^0.000
Beryllium
160.000
160.000
2.200.000
1.100.000
9.-100.000
4.700.000
Bismuth


710.000
710.000
1.800.000
1.800.000
Cadmium


630.000
320.000
3.800.000
1.900.000
Calcium


9
9
9
9
Chromium and Ferroeh.romium
110.000
110.000
110.000
110,000
110,000
110.000
Coal Gas

.
.

ISfi.000
180,000
Cooper
7.400.000
740,000
7.50(1000
750,000
7.700.000
770,000
Elemental Phosphorus
1.700.000
860,000
1.700.000
860,000
1.700.000
860.000
Fluorspar and Hydrofluoric Acid


110.000
38.000
260.000
87,000
Germanium
-

190,000
17.000
450.000
 ! 10 000
Lead
56,000
19.000
4.100.000
1.400.000
8.100.000
2.700.000
Magnesium and Magnesia from
Brines
2.000,000
990,000
2.000,000
1.000,000
2,100.000
1,000.000
Mercurv
.
.
190.000
27,000
800.000
110.000
Molybdenum. Ferromolybdenum,
and Ammonium Molvbdate


10,000,000
920.000
29.000.000
2.600.000
Platinum Group Metals
.
.
160.000
53.000
240 000
79.000
Rare Eanhs
210.000
210,000
1.600.000
1.600.000
4.600.000
4.600.000
Rhenium


2.900,000
1.400.000
5.100.000
2,500.000
Scandium

-
350.000
51.000
420,000
60,000
Selenium
-190.000
2-0.000
660.000
220.000
2.200.000
750,000
Svnthetic Rutile


1.300.000
1,300.000
2,200,000
2.200.000
Tantalum, Columbium. and
Ferrocolumbium
260,000
130.000
4-80,000
240.000
720.000
360,000
Tellunum


370.000
190.000
1,800. W0
900,000
Titanium and Titanium Dioxide
1.600.000
800.GOO
16.000.000
2,300,000
23.000.000
4.000.000
T>.:nestcn
.
.
280,000
47.000
640.000
110.000
Uranium
.
.
800.000
47.000
1.400.000
84.000
Zinc
8.000,000
2.700 000
10.000.000
3.300.000
13.000.000
-.200.000
Zirconium and Hafnium
.

1 800.000
910.000
11,000,000
5,400.000
Total / Average
23,000.000

70.000.000

140.000,000

April 30, 1998

-------
A-9
Exhibit A.1-10
Option 2 Incremental Costs Assuming Prior Treatment

Minimum Value Case
Kxpected
Value Case
Maximum Value Case

Total
Avg. Fac.
Total
Avg. Fac.
Total
A>g. Fac.

Incremental
Incremental
Incremental
Incremental
Incremental
Incremental













Alumina and Aluminum
13.000
570
26.000
i.ioo
26 000
i ioo
Antimonv


(IO.OOOi
(1.700)
(19.000)
(3.100
Bervlliurn
(55.000)
(55.000'
(45.000)
(22.000)
(310.000)
il 60.000
Bismuth
-
-
(1.700)
(l.'OO)
(12.000)
o
o
o
ri
Cadmium


5.600
2.800
(16,000)
(8.100
Calcium


9
9
9
9
Chromium and Ferrochromium

570
-Jt
oo
O
580
580
580
Coal Gas
-



570
570
Copper
5.700
570
(3.900)
(390)
9.900
990
Elemental Phosphorus
(550,000'i
(280.000)
(550.000)
(280.000)
(550.000)
(280,000
Fluorspar and Hvdrotluonc Acid


1.700
570
1.700
570
Germanium


4.200
1.000
4.400
1.100
Lead
1,300
450
>670.000)
(220.000)
(1.200.000)
(410.000
Maunesium and Magnesia from
Brines
1,100
560
1.700
840
1,700
840
Mercury
-
-
< 160.000)
(23.000)
(470.000)
(67.000
Mol>bdenum, Fercomolybdenum.
and Ammonium Molvbdate


7.500
660
7,300
660
Platinum Croup Metals

-
5.100
1.700
5.100
1.700
Rare Earths
(1.400)
(1.000)
1.400
1.400
1.500
1.500
Rhenium
.

2.300
1.100
2,300
1.100
Scandium
.

110.000
16.000
(22,000)
(3.200
Selenium
(24.000)
(12.000)
(19.000)
(6.500)
(11,000!
(3.700
Synthetic Rutile


16.900)
(6.900)
(14,000)
(14.000
Tantalum. Columbium, and
Ferrocolumbium
(160.000)
(79,000)
(160.000)
(78.000)
(160,000)
(78.000
Tellurium


(2.000)
(1.000)
(16.000)
(8,200
Titanium and Titanium Dioxide
("62.000)
(31.000)
(75.000)
di.ooo:
(95,000)
(14.000
Tunpsten
.
.
(11.000)
(1.900)
(17.000)
(2.900
Uranium
-
-
35.000
2.000
36.000
2.100
Zinc
(2,600,000)
(850,000)
(3.400.000)
(1.100.000)
(3.600,000)
(1.200.000
Zirconium and Hafnium


(82,000)
(41,000)
(280.000)
(140.000
Total/ Average
(3.400.000)

(5,000.000)

(6.700,000)

April 30, 1998

-------
Exhibit A. 1-11
Option 1 No Prior Treatment Baseline Impacts
1
Sector
Production
MT
Price
S/MT
Value of
Shipments
Incremental
Sector Cost
$
Economic Impact
(percent of Value of Shipments)
$
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.600.0(X>
1,543
5.554.800.000
1,100,000
3.200.000
4.800.000
0 02
0 06
0 09
Antimony
20.100
3,351
67,355,100

2,100 000
3,800,000
0 00
3 12
5 t>4
beryllium
217
352.640
76,522.880
230.000
2.300.000
9.900,000
0.30
301
12 94
Bismuth
1.100
/.937
H,730.700

710.000
1,800,000
0.00
8 13
20.62
Cadmium
1.450
2,756
3.996.200
-
730,000
4,500.000
0.00
18 27
1I2.G1
Calcium
1.100
4,480
4.928,000

9
9
000
000
0.00
Chromium and FerrocMrornium


39,000,000
190.000
190,000
200,000
0 49
0 49
0 51
Coal Gas


186,000,000


260.000
000
0.00
0.14
Copper
2.000.000
2,249
4,498.000 000
10.000,000
10,000,000
11.000.000
0 22
0 22
0.24
Elemental Phosphorus
311.000
2,756
857,116 000
2,700,000
2.700.000
2,700,000
0 32
0 32
0 32
1 luorspar and Hydrofluoric Acid
8.200
162
1,328,400

180,000
370.000
000
13.55
27 85
Germanium
10
2,000.000
36 000.000

210,000
470.000
000
0.58
1.31
Lead
340.000
1,076
365 840,000
84,000
5.100,000
9.900 000
n 02
1 39
2 71
Magnesium and Mannesia from Brines
143.000
3.858
551.694.000
2,000.000
2 000.000
2.100.000
0 36
0 36
0.38
Meieuiv
70
/.S42
527,940

420,000
1.400.000
0 00
79.55
265.18
MolytxJcnum, FerromcHvbdenum and Ammonium MoMxialo


427,500,000

10.000,000
29.000.000
0 oo
2 :w
6 78
Platinum Group Metals


42,792.580

160,000
250 000
000
037
0 58
Rare Earths
20,000
2,070
57,400.000
220,000
1,700,000
5.000.000
0 38
2.96
8 71
Rhenium
19
1.100.000
20.900.000

2,900,000
5,100 000
0 00
1388
24 40
Scandium
25
1.400.000
35.000.000

260.000
460.000
0 00
0 74
131 I
Selenium
350
7,055
2,469,250
530,000
720,000
2.400.000
21.4b
2CJ 16
9/ 20 (
Synthetic Rutile
140.000
650
91.000.000

1.400,000
2,400,000
0.00
1 54
2.64 |
Tantalum. Columbium, and Ferrocolumbium


95.727.210
460.000
680,000
920.000
048
071
0 96 I
Tellurium
GO
46.287
2,777.220

390,000
1 900,000
0 00
14 04
bH 41 1
Titanium and Titanium Dioxide


3.203,707,220
1,700.000
16,000,000
28,000,000
0 05
0 50
0.87
Tunusten
8.449
40
414,001

320,000
680.000
0 00
77 29
164.25
Uranium
2 132
31.130
66,369,160

830,000
1 500.000
0 00
1 25
2 26
Zinc
620.000
1.124
696,880.000
11,000.000
14,000,000
18 000,000
1 58
201
2 58 E
Zirconium and Halnium


36b.814.000

1.900.000
11 000.000
0 00
0 52
301 |
Total



30.000.000
81,000.000
160 000,000


1

-------
Kxhibit A.1-12
Option 1 Prior Treatment Baseline Impacts
1
Sector
Production
MT
Price
$/MT
Value of
Shipments
$
Incremental
Sector Cost
$
Economic Impact
(percent of Value of Shipments)
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.600.000
1,543
5,554 800.000
280 000
760.000
1.400.000
0 01
0 01
0 03
Antimony
20.100
3.351
67.355.100
-
6.800
6.800
0 00
001
0.01
Beryllium
217
352.640
76.52? fiflO
570
2.800
2.800
0 00
0 00
0.00
Bismuth
1.100
7.937
8.730.700

5.GOO
G.200
0.00
0 06
0 07
Cadmium
1.450
2.756
3 996,200
-
67.000
430,000
o.oc
1 68
10 76
Calcium
1.100
4,480
4.928,000

9
9
o.oc
0 00
0.00
Chromium and Ferrochromium


39,000,000
57,000
57.000
64 000
0 10
0 15
0 16 [
Coal Gas


186.000.000


66 000
0.00
000
0 04 II
Copper
2,000.000
2,249
4.498,000,000
2,/00,000
2.500,000
2,500.000
0.06
006
0 06
Elemental Phosphorus
311.000
2.756
857.116.000
290.000
290.000
290.000
0.03
003
0 03
Fluorspar and Hydrofluoric AckJ
8 200
162
1,328,400

49.000
81 000
0.00
369
6 10
Germanium
18
2.000,000
36,000.000

14,000
16 000
0 00
0 04
0 04
Lead
340,000
1,076
365.840.000
27,000
89.000
120,000
001
0.02
0 03
Maanesiurn and Magnesia from Brines
143.000
3 858
551.694,000
1,100
2.600
44 000
0.00
0.00
001
Mercury
70
7.542
527.940

12.000
12,000
0 00
2 ?7
2 27
Molybdenum, Ferromclybdenum and Ammonium Molybdate


427.500.000

7.300
7.300
0.00
O.OC
000
Platinum Group Metals


42,792.580

5.400
11,000
000
0 01
0 03
Hare F.arths
20.000
2.870
57,400,000
1.100
90,000
310,000
0 00
0.16
0 54
Rhenium
19
1,100.000
20.900,000

3.100
5,600
0 00
001
0 03
Scandium
25
1 400.000
35.000.000

7.900
7.900
0.00
0.02
0.02
Selenium
350
7,055
2,469.250
1,100
17.000
110.000
0 04
0 69
4 45
Synthetic Rutile
140.000
650
91.000.000

64,000
120.000
000
0.07
0.13
Tantalum. Columbium. and Ferrocolumbium


95,727,210
1,100
3.400
3.400
000
0.00
0 (K)
Tellunum
60
46.287
2.777.220

10.000
15,000
000
0.36
0 54
Titanium and Titanium Dioxide


3,203.707,220
3,700
130.000
240,000
0 00
000
0 01
Tunasten
8,449
49
414,001

6.800
6,800
0 (K)
1 64
1 64
Uranium
2.132
31.130
66.369,160

56.000
110,000
0 00
008
0.17
Zinc
620.000
1.124
696.880.000
62,000
110.000
150.000
001
0.02
0.02
Zirconium and Hafnium


365.814,000

4.500
4.500
0 00
0 00
0 00
Total



3,400,000
4,400,000
6,100,000




-------
Exhibit A.1-13
Option 2 No Prior Treatment Baseline Impacts
Sector
Production
MT
Price
S/MT
Value of
Shipments
S
Incremental
Sector Cost
$
Economic impact
(percent of Value of Shipments)
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.600.000
1.543
5,554,800,000
730,000
2.100.000
2,900,000
001
004
0 05
Antimony
20.100
3.351
b/.3b5.100

2,100 000
3.800,000
0 00
3 12
5 64
Beryllium
217
352,640
76.522,880
1 GO.000
2.200.000
9,400 000
0 2!
2 a/
12 2H
Uismulh
1.100
7.937
8,730.700

710,000
1,800.000
0 00
8 13
20 62
Cadmium
1,450
2./S6
3.996.200

630.000
3.800.000
0 00
15 76
95 09
Calcium
1.100
4.480
4.928.000

9
9
0 00
0 00
0 00
Chromium and Ferrochromium


39,000,000
110000
110.000
110.000
0.28
0.28
0 28
Coal Gas


1H6.000.000


180.000
000
000
0.10
Copper
2,000.000
2.249
4.498.000.000
7.400.000
7,500.000
7,700,000
0 1H
0 1/
0 17
Elemental Phosphorus
311.000
2.756
857 116.000
1.700.000
1,700,000
1.700.000
0.20
0 20
0.20
Fluorspar and Hvdiofluuric Acid
8,200
162
1,328.400

110.000
260.000
0 00
8 28
19.57
Germanium
18
2.000.000
36,000.000

190.000
450,000
000
0 53
1.25
Lead
340.000
1.076
365.840.000
56.000
4.100.000
8 100.000
0.02
1 12
2 21
Maqnesium and Maqnesia from Brines
143.000
3,858
551.694 000
2.000.000
2,000,000
2.100.000
0 36
0 36
0.38
Mercurv
70
7,542
527.940

190,000
800,000
000
35 99
151.53
Molybdenum, Ferrumulvtodenum and Ammonium Motvbdale


427 500,000

10,000.000
29 000.000
0.00
2 34
6.78
Platinum Group Metals


42.792.580

160,000
240.000
0 00
0 37
0 56
Rare Earths
20.000
2.870
57,400,000
210.000
1,600.000
4.600,000
0 37
2 79
8.01
Rhenium
19
1.100.000
20 900.000

2.900.000
5.100.000
0.00
13 88
24.40
Scandium
25
1.400,000
35.000,000

350.000
420,000
0 00
1 00
1 20
Selenium
350
7.055
2,469.250
490.000
660.000
2 200,000
19.84
20.73
89.10
Synthetic Rulile
140.000
650
91,000.000

1.300.000
2.200.000
0.00
1.43
242
Tantalum. Columbium. and Ferrocolumbium


95.727.2t0
260,000
480.000
720.000
0 27
0 50
0 75
Tellurium
60
46.287
2.777.220

370.000
1.800,000
0.00
1332
64.81
Titanium arid Titanium Dioxide


3.203.707,220
1.600.0(30
16.000.000
20.000.000
0.05
0.50
0.87
Tunnslen
8.449
49
414.001

280.000
640,000
000
G7.G3
154.59
Uranium
2.132
31,130
66.369.160

800.000
1.400,000
000
1.21
2 11
Zinc
020.000
1,124
696.880.000
8.000.000
10.000.000
13,000,000
115
1.43
1.87
Zirconium and Hafnium


365.814,000

1.800.000
11.000.000
000
0 49
301
Total



23.000.000
70.000.000
140.000.000




-------
Exhibit A. 1-14
Option 2 Prior Treatment Baseline Impacts
>
3.
O
o
vO
oo
Sector
Production
MT
Price
$/MT
Value of
Shipments
$
Incremental
Sector Cost
$
Economic Impact
(percent of Value of Shipments)
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3,600.000
1.543
5.554 800 000
13000
26,000
26,000
0 00
0 00
0 00
Antimony
20.100
3,351
67 355 100
-
(10,000)
(19.000)
0.00
-0 01
-0.03
Beryllium
217
352.640
76.522 880
(55 000)
(45.000)
(310.000)
-0 07
-0 06
-0 41
&smulh
1.100
7,93/
ft 730./00

(1,/00)
(12 0(H))
0 00
0 0?
0 14
Cadmium
1.450
2,756
3 996,200

5.600
(16 000)
0.00
0 14
0 40
Calcium
1.100
4.480
4.928,000

9
9
O.OC-
0 00
000
Chromium and Ferrochromium


39.000.000

580
5H0
0 00
0 00
OOO
Coal Gas


186.000.000


570
000
0 00
0.00
Copper
2.000.000
2,249
- 4.498.000.000
5.700
(3.900)
9.900
o.oc
oco
0 00
Elemental Phosphorus
311.000
2.756
B57.116,000
(550.000)
(550,000)
(550.000)
0 06
-0 06
-0 06
Fluorspar and Hydrofluoric Acid
8.200
162
1.328.400

1.700
1,700
O.OC
0 13
0.13
Germanium
18
2.000,000
36.000.000

4.200
4.400
0.00
0 01
001
Lead
340.000
1,076
365,840,000
1,300
(670,000)
(1 200,000)
000
-0 18
-0 33
Mannesmm and Maqnesia from Brines
143.000
3.858
551,694,000
1.100
1.700
1.700
000
0 00
0.00
Meicurv
70
7.54?
527,940

(160.000)
(470.000)
0 00
30 31
-89.03
Molybdenum. Fcrromolvbdenum and Ammonium Molvbdate


427.500.000

7.300
7,300
0.00
000
0.00
Platinum Group Metals


42.792.580

5.100
5.100
0.00
001
0 01
Rare Earths
20,000
?,H70
57.400,000
(1,900)
1 4(X)
1.500
0 00
0 00
0 (X)
Rhenium
19
1,100,000
20,900,000

2.300
2,300
000
001
001
Scandium
25
1.400,000
35.000,000

110 000
(22.000)
0.00
0.31
006
Selenium
350
7.055
2,469.250
(24.000)
(19 OOO)
(11,000)
-0 9/
-0 //
-0 45
Synthetic Rutile
1*10.000
650
91,000,000

(6 900)
(14.000)
0 00
-0.01
-0 02
Tantalum. Columbium, and Ferfocolnmbium


95.727,210
(160.000)
(160.000)
(160.000)
-0.17
-0.17
-0 17
Tellurium
60
46.287
2.777,2?0

(? OOO)
(16,000)
0 00
-0 0/
-0 58
Titanium and Titanium Dioxide


3.203.707.220
(62.000)
(75.000)
(95,000)
0.00
O.OC
000
Tunqsten
8.44D
49
414.001

(11 000)
f 17.000)
0 00
-2.66
4.11
Uranium
2.13?
31,130
66.3G9.1G0

35.000
36.000
0 00
0 05
0 05
Zinc
620.000
1,124
696.880.000
(2.600.000)
(3.400.000)
(3,600,000)
-0.37
-049
-0 52
Zirconium and Hafnium


36b,814.000

(82.000)
(280,000)
000
0.02
-0 08
Total



(3,400,000)
(5.000,000)
(6./00.000)



>

-------
A-L4
A.2 Risk and Benefits Assessment Assumptions, Methods, and Results
A.2.1. Introduction
As discussed in Section 4.1, while EPA's current judgement is that the modified prior treatment
baseline best represents current industry practice, the Agency has conducted a substantial amount of risk
and benefits assessment work for the alternative baseline scenarios. This is particularly true for the no
prior treatment baseline, which was regarded early in the regulatory development process as a prudently
conservative characterization of current practice. EPA has also evaluated some potential risks and
benefits for the prior treatment baseline as well. As w ill be discussed further below, some of the risk and
benefits assessment for the activities evaluated (disposal or storage) are applicable to more than one
baseline, and to more than one regulatory option, because the behavioral assumptions made for that activity
are the same under the various baselines and options. Thus they can be used to infer baseline risks and risk
reduction benefits for other sets of baseline assumptions.
This appendix describes in detail the risk and benefits assessments that have been performed for
the alternative baselines. The primary focus is on the work that EPA has done to evaluate groundwater
pathway risks associated with waste disposal under the no prior treatment baseline. In addition, it
discusses in less detail aspects of the risk and benefits assessments for the storage of recycled materials
compared to the modified prior treatment baseline that are relevant to the alternative baselines.
A.2.1.1 Groundwater Risk and Benefits Assessment for Waste Disposal
The bulk of this appendix is devoted to a description of the risk and benefits analysis for mineral
processing waste disposal. As discussed in Section 4.1, EPA has performed quantitative risk and benefits
analysis for the groundwater pathway risks associated with the disposal of these wastes. EPA analyzed
risks for all 42 (later reduced to 34) of the spent materials, sludges, and byproduct streams from the
mineral processing industry for which constituent concentration data were available. Pre-regulatory risks
were analyzed under the no prior treatment baseline, which assumed final disposal of untreated materials in
land units (waste piles and surface impoundment). Benefits were estimated for the three regulatory options
under consideration at the time of the analysis. For all three options, it was assumed that the wastes, would
be treated to meet UTS levels for all constituents prior to disposal.
Since the modified prior treatment baseline assumes that all wastes would be treated to meet TC
regulatory levels, the no prior treatment and modified prior treatment baseline risks are not the same, and
the health benefits of moving from the baseline to the regulated environment are not equivalent. On the
other hand, the post-regulatory requirements for treatment of all wastes to meet the UTS requirements
remains a feature of the current regulatory options. Thus, the post-regulatory risks calculated for waste
disposal are still relevant to the current options, as was discussed in Section 4.2.
A.2.1.2 Groundwater and Multipathway Risk Assessment for Recycled Materials
The methods used to evaluate risks associated w ith the storage of recycled materials are
described in detail in Appendix H, and will not be discussed in detail here. Risks were assessed for waste
storage under the modified prior treatment baseline, which assumes that the recycled materials would be
stored in unlined land-based units (waste piles and surface impoundments). This assumption is the same
as that made in the no prior treatment baseline. Therefore the risks associated with these two baselines are
the same, and this provides the rationale for including a discussion of these results in this appendix.
Because suitable models and data are not available that would allow risk estimation for tanks,
containers, and buildings, the risks associated with the storage of recycled materials under the prior
April 30, 1998

-------
A-15
treatment baseline and under regulator)' Options 1-3 have not been evaluated quantitatively. In section 4.2,
the potential degrees of risk reduction associated with the various regulatory options are discussed
qualitatively.
A.2.2 RISK AND BENEFITS ASSESSMENT METHODS
A.2.2.1 Risk Assessment Methods for Waste Disposal
A.2.2.1.1 Identification of Waste Streams for Quantitative Risk and Benefits Analysis
The procedures used to identify waste streams for inclusion in the risk and benefits assessments
in the December 1995 RIA are described in Section 5.1.1.1 of that RIA.3 The number of waste streams
that could be evaluated with regard to risks and benefits was limited by the lack of constituent
concentration data to a small fraction of the wastes that were evaluated in the cost and economic analysis.
To evaluate prc-LDR constituent concentrations, bulk concentration data were used for wastewaters
(WW), and EP leachate data were used to estimate release concentrations for liquid nonwastewaters
(LNWW) and nonwastewaters (NWW). Wastes for which these types of data were not available were
excluded from the quantitative risk and benefits assessments.
The procedures used to identify waste streams for inclusion in the sample-specific risk and
benefits were slightly different, as described in Section 5.5.1.1 of the December 1995 RIA. First, the data
requirements for including a waste in the quantitative risk assessment were relaxed somewhat, allowing
inclusion of LNWW and NWW wastes for which only bulk concentration data were available. Second, the
assumed proportion of high-probability ("Y") recycled materials that would be disposed was reduced from
20 percent to zero. This resulted in the removal of the two recycled materials for which constituent
concentration data were available from the quantitative risk assessment, making the risk and benefits
analysis for Regulatory Options 1 and 2 the same, in terms of the waste streams that were included.
A total of 42 waste streams ultimately met the criteria for inclusion in the sample-specific risk
and benefits assessments for changes in waste disposal practices under the proposed LDRs. These waste
streams represent a relatively small proportion, in terms of numbers, of the waste streams included in the
cost and economic analysis. However, as discussed in the December 1995 RIA Appendix J, the wastes
that are included in the risk and benefits analysis for waste disposal account for between 71 and 92 percent
of the estimated total waste volume covered by the cost and economic analysis, depending on which
volume estimates are used.
These same 42 wastes were included in the preliminary risk and benefits calculations (ICF
Incorporated 1996a). Since that time, as discussed above, a number of waste streams have been eliminated
from the risk and benefits assessments, as summarized in Exhibit A.2-1. Two beryllium sector waste
streams were removed because they are beneficiation wastes, and would not be addressed by LDRs. One
waste stream in the copper commodity sector was removed from the waste disposal risk and benefits
assessment because EPA believes that it is fully recycled. Another copper waste stream
5 Regulatory Impact Analysis of the Supplemental Proposed Rule Applying Phase IV Land Disposal
Restrictions to Newly Identified Mineral Processing Wastes, December 1995.
April 30, 1998

-------
A-16
Exhibit A.2-1
Commodity Waste Streams Included in Revised Benefits Analysis
Commodity
Waste Stream
Aluminum and Alumina
Antimony
Beryllium
Dcrylliurn
Beryllium
Deryllium
Copper
Copper
Copper
I Cast house dust
Autoclave filtrate
Spent barren filtrate streams
Denrandite thiiAenm sluny
Chip treatment wastewater
'i[ienl iaffiliate.
Acid plant blowdown (1)
Scrubber blowdown
Spent bleed clLLliulyte
Copper
Elemental Phosphorous
Klemental Phosphorous
Elemental Phosphorous
Elemental Phosphorous
Germanium
Germanium
Germanium
Germanium
Lead
trad
Magnesium and Magnesia (brine)
Molybdenum, Ferromolybdcnum, Ammonium Molvbdate
Rare Earths
Rare Earths
Selenium
Tantalum. Columbium. and FerTocolumbium.
Titanium and Titanium Dioxide
Titanium and Titanium Dioxide
Titanium and Titanium Dioxide
Titanium and Titanium Dioxide
Titanium and Titanium Dioxide
Titanium and Titanium Dioxide
Titanium and Titanium Dioxide
Tilamum and Titanium Dioxide
Tungsten
Zinc
Zmc
Zinc
Zinc
Zinc
Zinc
Zinc	-		 	 	
Suiface impoundment waste liquids
AFM rinsate
Furnace offgas solids
Furnace scrubber blowdown
Slag quenchwater
Waste acid wash/rinse water
Chlorinator wet air pollution control sludge
Hydrolysis filtrate
Waste still liquor
Priiic..vs wastewater
Surface impoundment wmt liquids
Smut
I.iquid residues
Spent ammonium nitrate processing solution (2)
Process wastewater (2)
Plant process wastewater
Process wastewater
Pickle liquor & wash water
Leach liquor & sponge wash water
Scrap milling scrubber water
Spent surface impoundment liquids
Spent surface impoundment solids
Waste acids (Chloride process)
Waste acids (Sulfate process)
Wastewater treatment plant sludge/solids
Spent acid & rinse water
Waste ferrosilicon
Process wastewater
Spent surface impoundment liquids (3)
Spent surface impoundment solids (4)
Spent synthetic gypsum (3)
Wastewater treatment plant liquid effluent (3)
Zinc lean slag	
Noles:
Strikethrough indicates streams that have been removed because they are fully recyled. no longer generated,
or not disposed in land units.
(1)	Number of facilities reduced from 9 to 7.
(2)	Number of facilities reduced to 1.
(3)	Number of facilities reduced from 4 to 3.
(4)	Name changed to Wastewater treatment plant solids.
April 30. 1998

-------
A-17
was removed because it appears to be redundant with another stream. Two waste streams from lead
production were removed, one because it is fully recycled, and another because it is no longer generated.
Acid waste from titanium chloride production was removed from the analysis because EPA received
information indicating that it is currently deep-well injected, and not land disposed. One waste stream
from zinc production was removed because it is either recycled or not stored in land-based units. After
removing these streams, 34 were left in the risk and benefits analysis for waste disposal. A zinc waste
stream, "spent surface impoundment solids," was renamed to "waste water treatment plant solids," but
remained in the analysis.
A.2.2.1.2 Waste Characterization Data and Release Concentration Estimates
The source of the mineral processing waste constituent concentration data used in the pre-LDR
risk estimates is the same source as that used in the December 1995 RLA sample-specific risk assessment.
These data are summarized in Appendix K of the December 1995 RLA. In this analysis a slightly different
approach from that used in the RIA was adopted to enumerate samples of each waste type. In the
December 1995 RIA, when both bulk analyses and EP leachate sample results were available for a LNWW
or NWW stream, only the leachate data were used to estimate release concentrations. In the revised risk
assessment presented below, both types of samples, when available, were used in the risk assessment to
develop separate risk estimates. This approach makes the best possible use of the available data, and takes
into account that, in many cases, it was not clear that the EP and bulk analyses for a given waste stream
were from the same samples or batch of waste.
In adopting this approach, it was assumed that the observed differences in the release
concentrations calculated from the two types of samples of the same wastes reflect real variability in waste
stream constituent concentrations and in the leaching characteristics of the various constituents. In the
December 1995 RIA, a total of 126 waste samples were evaluated for carcinogenic risks, and 217 samples
were evaluated for noncarcinogenic risks. Using all of the available data in the revised risk assessment and
excluding the wastes as described above. EPA calculated carcinogenic risks and noncarcinogenic hazard
quotients for 115 samples and 190 samples, respectively. The number of samples evaluated for
carcinogenicity was also reduced because EPA no longer calculated carcinogenic risks for beryllium (see
below), and thus only streams containing detectable levels of arsenic were considered to pose carcinogenic
risks.
For WW streams, the bulk concentration sample results were used directly as release
concentration estimates. For LNWW and NWW streams, EP leachate concentrations were also used
directly as release concentrations. For LNWW and WW bulk samples, release concentrations (mg/1) were
conservatively estimated as being equal to the bulk constituent concentrations (mg/kg) divided by 20. This
approach conservatively assumes that all waste constituents are completely teachable into the EP leachant.
For the post-LDR scenario, release concentrations for all constituents were estimated to be equal
to one-half the landfill UTS concentrations for each constituent, or they were to be as being equal to the
sample concentration, if that value was less than one-half the UTS concentration. The decision to use one-
half the UTS concentration, instead of the UTS concentration itself, was based on EPA's assumption that
waste managers required to comply with UTS would give themselves a conservative margin of safety and
assume that all of the constituents are completely leachable. The basis for this judgment is discussed in
Section 5.5.1.3 of the December 1995 RIA.
April 30, 1998

-------
A-18
A.2.2.1.3 Exposure Assessment
Exposure concentrations of the waste constituents in ground water were estimated by dividing
the release concentrations by the recently-developed constituent-specific DAF values derived for mineral
processing wastes. Under the no-treatment baseline scenario, all NWW streams were assumed to be
disposed in waste piles. Therefore, the 75th and 95th percentile wastepile DAF values were used to
evaluate central tendency (CT) and high end (HE) exposure concentrations, respectively. All WW and
LNWW wastes were assumed to be disposed in surface impoundments, and the 75th and 95th percentile
impoundment DAFs were therefore used to calculate the CT and HE exposure concentrations for these
wastes.
In evaluating risks, the 75th percentile constituent-specific DAFs were used to estimate central
tendency (CT) groundwater concentrations. The rationale for using the 75th percentile DAFs rather than,
for example, the 50th percentile value was that the EPACMTP model used to derive DAFs does not
consider fractured or channeled flow or other facilitated transport mechanisms which may occur at some
sites, resulting in higher groundwater concentrations than those predicted for homogeneous flow processes
modeled by EPACMTP. The 95th percentile constituent-specific DAF values were used to estimate high-
end (HE) groundwater concentrations, in keeping with the definition of a high-end receptor as someone
exposed at levels between the 90th and 99th percentiles of all exposed individuals.
In the post-LDR case, all wastes (WW, LNWW, NWW) were assumed to be treated and
disposed of in landfills. Since no data related to mineral processing waste disposal in landfills were
available, DAFs values derived for waste piles were used for estimating all of the exposure concentrations
in the post-LDR scenario.
As noted above, the DAF values used in this analysis differed from those used previously The
DAF values used here were derived based on data on constituent concentrations, facility and waste
volumes, and locational data specifically for mineral processing wastes, rather than on generic values. In
addition, the DAF values used in this assessments were calculated separately for pre- and post-LDR release
concentration distributions. Thus, these values better reflect the expected fate and transport characteristics
of the mineral processing industry waste constituents than did the values used previously. In particular, the
revised DAFs account for the concentration-dependence of groundwater transport for each constituent and
regional variations in precipitation and groundwater transport. These variations were not taken into
account in the previous DAF derivations.
The constituent-specific DAF values used in the risk assessment for waste disposal are provided
in Exhibit A.2-2. The surface impoundment DAFs, which are used in this analysis only for evaluating pre-
LDR risks for liquid wastes, are summarized in the second and third columns of the Exhibit A.2-2. Most
of the 75th percentile DAF (CT) values are lower than the CT value of 500 used in the RLA risk analysis.
The values for antimony, arsenic, chromium, mercury, and thallium are only slightly lower (within about a
factor of ten), while the values for barium, beryllium, cadmium, nickel, selenium, silver, and zinc are
much lower (greater than a factor of ten) than the CT DAF values used in the December 1995 RIA. For
these liquid waste stream constituents, the estimated pre-LDR constituent groundwater concentrations were
greater than those estimated in the RIA. In contrast, the 75th percentile surface impoundment DAF value
for lead and cyanide used in this analysis increased by several orders of magnitude over the CT DAFs used
in the RIA. and thus the pre-LDR groundwater concentration estimates are lower for lead- and cyanide-
containing liquid waste streams than they were in previous analyses.
April 30, 1998

-------
Exhibit A.2-2
Revised Constituent-Specific DAFs for the Mineral Processing Industry

Surface Impoundments (1)

Waste Piles
I
Constituent
Central Tendency
(75th percentile)
Pre-LDK
High End (95th
percentile) Pre-LDR |
Central Tendency
(75th percentile)
Pre-LDK
High End (95th
percentile) Pre-LDK
Central Tendency
(75th percentile)
Post-LDR
High Knd (95th
percentile) Post-1 .DK
Antimony
I.93E+02
2.28E+01
>10
8.36E+03
>10
" 8.36E t03
Arsenic
1.66E+02
1.7IE+0I
>10
2.56E+03
4.37E+09
2.56E+03
Barium
5.81 b+00
I.I7E+00
2.22E+03
I.38E+OI
2.33E+03
1.46E+01
Beryllium
8.47E+00
1.24E+00
>10
4.87H+02
>10
"5.54E+02
Cadmium
2.49F+0I
1.40E+0U
>10
2.67E+03
>10
" 3.26E+03
Chromium
9.82E+01
I.15E+01
2.21E+04
1 60E+02
2.21 E+04
1.60E+02
Cyanide
2.8IE+10
4.20E+03
- (2)
--(2)
-(2)
-(2)
L.cad
7.llli+05
4.98E+00
>10
2.270+05
>10
"8.93E+08
Mercury
I.97E+02
8.051'+00
>10
4.29E+03
>10
"4 29K)03
Nickel
2.23E+01
1.51 E-tOO
l.54E-06
1.41E+02
I.97E+06
I.46E+02
Selenium
2.70E+0I
3.38E+00
1.I8E+08
4.28E+02
I.I9E+08
4.28E+02
Silver
I.I 1E+01
1.23E+00
>10
4.96F.+02
>10
"4.87 E+02
Thallium
2.97E+02
4.I5E+0I
>10
9.63 E+04
>10
" 9.63E+04
Vanadium
5.67E+00
2.03E+00
>10
>10"
>10"
>10"
I Zinc
1 23E+01
1.35R+CM)
>10
>10"
>10"
>10"
Source:	U.S. EPA (19%)
Notes:
(1)	Posl I.DR DAFs for surface impoundment;, were nul used in (he nsk calculations because it was assumed that all liquid wastes would he dewatered under LDRs
(2)	No DAI-s were derived lor cyanide disposed in waste piles because cyanide concentration data lor non-liquid wastes were not available.

-------
A-20
The 95th percentile surface impoundment DAF values derived for this analysis are generally
similar to the HE DAF values used in the 1995 RIA. The HE DAF values in the December 1995 RIA risk
analysis ranged between 6 and 100. The constituent-specific DAFs used in this analysis range between 1.3
and 200 for all but one constituent. The sole outlier is the DAF for cyanide, which is 4200. For all
constituents except cyanide, the 95th percentile surface impoundment DAFs used in this assessment result
in pre-LDR estimated groundwater concentrations and health risks for liquid waste streams of generally
similar magnitude to those calculated in the December 1995 RIA.
The constituent-specific waste pile DAF values derived for mineral processing wastes are shown
in the last four columns of Exhibit A.2-2. These values were derived for both pre-LDR and post-LDR
constituent concentrations. The former values were used to evaluate risks for all non-liquid waste streams
pre-LDR, and the latter were used to evaluate risks post-LDR for all wastes, as explained above. The 75th
percentile waste pile DAFs used in this analysis are. with few exceptions, many orders of magnitude
greater than the CT DAF value (50) used in the December 1995 RIA. Thus, the predicted pre- and post-
LDR risks for non-liquid waste streams containing these constituents are much lower than in the RIA. The
lowest CT waste pile DAF value (about 2200), which was estimated for barium, is still about 40 times
greater than the CT DAF value used in the RIA.
In comparison, most of the 95th percentile constituent-specific DAFs for the mineral processing
wastes are somewhat closer to the range of HE values (12 to 100) used in the RIA. The pre-LDR HE
waste pile DAFs are less than 10,000 for all but two contaminants, which are within two to three orders of
magnitude of the RLA HE DAF range. Lead, vanadium, and thallium have HE DAFs that are higher than
the values used in previous assessments. Post-LDR, the situation is similar. Most of the constituent-
specific post-LDR DAF values for waste piles are less than 10,000, with the outliers again being lead and
vanadium for which the DAF values are much higher. As with the 75th percentile DAFs, these revised
95th percentile DAF values result in the prediction of lower groundwater concentrations than those
predicted in the previous assessments.
A.2.2.1.4 Risk Characterization
Lifetime cancer risks for the hypothetical receptor are calculated using the following equation:
Cancer Risk -
EC IK * EF  ED  CSF
BW.365 -AT
(1)
Where:
EC
IR
EF .
ED
CSF
BW
AT
Exposure concentration of constituent in groundwater, mg/1
Water ingestion rate (1.4 1/day)
Exposure frequency (350 days/year)
Exposure duration (9 years)
Ingestion pathway Cancer Slope Factor (mg/kg-day)'1
Adult body weight (70 kg)
Averaging time for dose estimation (70 years)
April 30, 1998

-------
A-21
Chronic noncanccr hazard quotients for exposure to waste constituents in groundwater are
calculated as follows:
u j	EC-IR-EF
Hazard Quotient - 		{-)
BW-365 *RfD
where the RfD is the EPA chronic ingestion pathway Reference Dose for the constituent,' and the other
variables have the same meaning as in Equation (1). The rationale for selecting the exposure factor values
used in liquations (1) and (2) is discussed in Section 5.2.1.2 of the December 1995 R1A.
Two changes were made in the toxicological parameter values which were used to calculate risk
results in this analysis. First, bery llium was no longer treated as an ingestion pathway carcinogen. While
EPA has published an ingestion pathway cancer slope factor for beryllium, the Agency has not applied this
value in several recent rulemakings, citing the great uncertainty surrounding the data supporting the
cancer-causing potential of beryllium by the oral route. Thus, cancer risks are no longer calculated for
beryllium-containing wastes, and arsenic is the sole carcinogenic constituent by the ingestion route
included in the risk assessment. The other change in the toxicological parameter values was to use an
updated IRIS RfD value for manganese, which had a very limited effect on the risk and benefits results.
A.2.2.2 Risk Assessment Methods for Storage of Recycled Materials
Risks associated with the storage recycled streams were assessed both for groundwater and non-
groundwater pathways, as described in Appendix H. These methods will not be discussed in detail here.
A.2.2.3 Benefits Assessment Methods for Waste Disposal
A.2.2.3.1 Unit of Analysis for Benefits Assessment
Consistent with the December 1995 RIA, the unit of analysis of the benefits assessment is the
"waste stream-facility combination." To calculate the benefits of improved management for a given waste
stream, the number of facilities is first estimated, as described in Section A.2.2.3.2 of the RIA. Then, the
numbers of facilities the imposition of the LDRs would result in changes in risk are calculated and
categorized based on the order-of-magnitude change in risks pre- and post-LDR. The benefit measure is
the number of facilities generating the waste (i.e., waste stream-facility combinations) that move from
high-risk categories pre-LDR to lower-risk categories post-LDR. One feature of this approach is that a
single facility that disposes of more than one waste stream will be counted in the benefits assessment as
more than one waste stream-facility combination. Thus, the total number of waste stream-facility
combinations in the benefits assessment exceeds the total number of facilities affected by the LDRs.
Another feature of this approach is that, as will be seen in Appendix A.2.2.3.3, not every
exceedence of risk levels of concern pre-LDR results in an estimated benefit post-LDR. This is because if
only a small number of samples from a given waste stream (one of 20, for example) give risk results above
the level of concern, this may not translate into even one facility waste-stream combination if the number
of facilities managing the waste is small (two or three). In this case, the estimated number of facilities with
pre-LDR risks at levels of concern is zero. (Or more properly, it is less than one.)
1 Since there is currently no RfD value for lead, EPA calculated the hazard quotient for lead as the
ratio of the exposure concentration to the MCL of 15 ug/1.
April 30, 1998

-------
A-22
This approach does not provide an estimate of risk reduction for identifiable exposed individuals,
nor does it allow calculations of population risk reduction. As explained in the December 1995 RIA, the
lack of data regarding the number of individuals exposed to groundwater around mineral processing
facilities precludes the development of population risk and benefit estimates.
A.2.2.3.2 Estimation of Numbers of Facilities Managing Mining Wastes
The total number of facilities managing specific wastes were estimated as described in Chapter 4
of the December 1995 RIA. For the HE benefits estimates, the total estimated numbers of facilities
generating the various waste streams nation-wide were used in the benefits estimation. For the CT benefits
estimates, a reduced number of facilities managing some of the waste streams was used. For all of the
waste streams categorized "Y?" (i.e., low likelihood of being TC hazardous), the CT number of facilities
was estimated as the total facilities generating the waste stream divided by two. Odd numbers of facilities
were rounded up by one to generate an even number (e.g.. an HE estimate of seven facilities resulted in a
CT estimate of four facilities).
A.2.2.3.3 Attribution of Risks to Facility-Waste Stream Combinations
If there were always one and only one sample result per waste stream per facility, then the
attribution of risks across waste streams and facilities would have been simple. (Each sample risk result
would correspond to one facility-waste stream combination in the benefits analysis.) Unfortunately, the
number of samples per waste stream and per facility varied considerably, necessitating the development of
a method for distributing risk results from single samples and groups of samples across multiple facility-
waste stream combinations. The approach used to distribute risks across facilities used in the revised
benefits assessment is essentially identical to that described in detail in Section 5.5.2.4 of the December
1995 RIA, and can be summarized as follows:
Where there is only one sample result for a waste stream, all of the facilities managing
that waste arc assigned the risk value associated with the pre- or post-LDR disposal of
a waste having the same composition as the sample;
	Where there are multiple samples from a waste stream, the facilities disposing of that
waste are assigned risk values in the same proportion as the risks are distributed across
the samples. For example, if there are four waste samples and eight facilities disposing
of the wastes, the risk results from each of the four waste samples are assigned to two
facility-waste stream combinations;
	Where there are multiple samples from a single facility, the risk results for each sample
at the facility are counted as separate risk estimates only if they are significantly
different from one another.5 However, if multiple samples from a single facility result
in risks that are very similar, the risks for all of those samples are averaged and counted
as a single sample for purposes of the benefits analysis. The facility-waste stream
combinations for a waste stream arc then assigned to risk categories according the risk
results from the individual samples from that waste stream, and from the combined
5 Risk from multiple samples are considered to be similar (homogeneous) if the same constituents
account for the bulk of the risks, and if all of the sample-specific cancer risks or hazard quotients are
within one to two orders of magnitude. (See the December 1995 RIA, p. 5-37.)
April 30, 1998

-------
A-23
samples counted as a single sample. This approach avoids giving too great a weight to
multiple samples from the same facility and the same batch of wastes.
The approach described above is rather complex, and requires a certain amount of professional
judgment. However, as was the case for the sample-specific risk analysis in the December 1995 RIA,
decisions about whether to combine samples within facilities had relatively little impact on either the pre-
LDR or post LDR n>k distributions, and the distribution of facility-wastes stream combinations across risk
categories followed the distribution of the individual samples risk results quite closely.
A.2.2.4 Benefits Assessment Methods for Storage or Recycled Materials
As discussed in Section 4.2, a quantitative benefits assessment was not performed for recycled
materials storage. Instead, the baseline risks arc identified as an upper bound estimate of the risk reduction
that could occur if all releases of toxic constituents were eliminated by storage in tanks containers, and
buildings. This assumption also holds true for the no treatment baseline, since no treatment of stored
materials is assumed under that baseline. The risk assessment for storage does not provide an estimate of
the magnitude of the potential benefits associated with the prior treatment baseline. Analogous to the case
for the disposal of treated wastes, it is likely that the benefits of improved storage under any of the
regulatory options over the prior treatment baseline would be minimal.
A.2.3 RESULTS OF RISK AND BENEFITS ASSESSMENT FOR THE NO TREATMENT
BASELINE
This section summarizes the results of the revised generic risk and benefits calculations that were
completed using the constituent-specific DAFs, as described in Section A.2.2.1.
A.2.3.1 Risk and Benefits Assessment Results for Waste Disposal
The results of the risk assessment for mineral processing wastes are summarized in Exhibits A.2-
3 and A.2-4. Exhibit A.2-3 provides the results of the pre- and post-LDR assessments of the individual
cancer risks calculated for each sample, and Exhibit A.2-4 provides the results of the noncancer hazard
quotient calculations for the samples.
The general pattern of waste disposal risks calculated in the December 1995 RIA is replicated in
the risk calculations that use the newly-revised constituent-specific DAFs, but in a more extreme fashion.
Waste streams move from higher risk categories pre-LDR to lower risk categories post-LDR. The most
striking difference between the risk results presented here and those in the 1995 RIA is that all of the
wastes with estimated health risks (both CT and HE) above levels of concern pre-LDR (greater than 10 -
cancer risk or hazard quotient > 1.0) move to below the levels of concern post-LDR.
Pre-LDR, CT cancer risks greater than 10 were predicted for 58 of 115 samples, with risk
results distributed through all of the categories up to >10'. The pre-LDR HE cancer risks for 80 of 115
samples were greater than 10'5, with the highest risks again reaching the highest risk category. These
April 30, 1998

-------
A-24
Exhibit A.2-3
Distribution of Samples by Groundwater Risk Category: Cancer Risks







Central Tendency










tlieli 1 fid







Number


Pre-
.l)K


Post-IJ>R
Ptt-1.DK
Post-l.l)K

i
or Samples

10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2



with

lo
lo
to
to


to
to
to
to


to
to
to
to


lo
to
to
to

Cooiniudity
Waste Stream
Cancer Kisk
<10.5
1IM
10-3
10-2
10-1
> IU-1
< 10-5
10-4
J (J-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
1(1-1
>10!
<10-5
10-4
10-3
10-2
10-1
>10-1
Al ;iiul Alumina
Cast house dust
2
2
0
0
0
0
0
>
0
0
[>
0
0
7
0
{)
0
t)
0
2
0
0
0
0
0
Sb
Autoclave filtrate
H
0
0
0
T
6
0
X
0
(J
0
0
0
0
0
0
0
2
(>
*
0
0
0
0
0
Be
Spew barren filtrate streams
2
1
0
1
0
0
0
2
0
0
0
0
0
0
1
0
1
U
0
2
0
(}
0
0
u
ik-
Chip treatment WW
I
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Cu
Acid plan! blowdown
30
7
4
10
4
3
2
30
0
0
0
u
0
1
(3

10
4
5
30
0
0
0
0
0
Cu
Scrubber blowdown
3
1
0
2
0
0
0
3
0
0
0
0
0
{)
1
0
?
4)
0
<
0
0
0
0
0
tlememal Pliosplwrous
AHM liusate
2
1
1
0
0
0
0
2
0
0
0
n
(1
0
1
1
0
0
0
)
0
0
[J
0
0
l:lemenial Pljospliorous
Furmice ottgns solids
9
9
o
0
0
0
0
9
0
0
0
(J
0
9
0

u
0
()
9
0
t)
0
0
0
lilemeni.il Pl*>sptk>ri>us
l-'urnuce scrubber blowdown
8
I
3
1
0
0
0
8
0
0
0
0
0
1
3
3
I
0
0

u
0
0
0
0
l-lemcnial Plwsplwrous
Slag quenchwaier
1
0
1
0
0
0
0
1
0
0
0
0
0
0
0
1
0
U
0
1
0
0
0
0
0
Ge
Wasie acid wash/rinse water
1
1
0
0
0
0
0
1
0
0
0
1)
0
0
1
0
0
1)
0
1
1)
1)
0
0
0
tie
Chlorinalot wet aii (toll. till. sludge
1
1
0
0
0
0
0
1
0
(1
0
0
0
1
0
(J
I)
1}
0
1
u
0
(1
n
0
Ge
Hydrolysis liluate
1
1
[)
0
0
0
0
1
0
0
0
0
0
1
0
1)
u
0
0
1
u
0
(1
u
0
2
Pickle liquor &. wash waier
3
2
1
0
0
0
0
3
0
0
0
0
0
0
2
1
0
(1
(}

0
0
0
1)
0
Tilanium an J Ti()2
I .each liquor & sponge watli water
2
1
1
0
i)
0
n
-)
0
0
0
0
{>
u
1
1
0
u
(J

0
0
0
0
0
Titanium and Ti()2
Sciap nulling sciubbci water
1
0
1
0
0
(1
<1
1
0
0
0
0
0
0
0
I
0
u
0
1
t)
0
0
0
0
Titanium jiiJ T.O?
Spent s i liquid*
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
11
0
0
0
0
0
0
0
Titanium and 1i()2
Spent s i solids
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
()
0
0
0
0
0
0
0
I)
0
Titanium and Ti02
Waste acids (Sulfate process)
4
I
3
0
0
0
0
4
0
0
0
0
(1
1
(1
I
0
0
(1
4
0
0
0
0
0
I'Hanium and Ii02
WW TP sludge/solids
0
0
0
0
0
0
0
0
0
0
0
0
11
0
u

0
0
u

I)
0
0
u
0
W
Spent acid & rinse water
2
1
0
I
0
0
0
2
0
0
0
0
0
0
1
0
1
0
0
2
0
0
0
0
0
/.u
Waste terrosilieon
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0

0
0
0
0
0
0
0
0
0
Zn
Spent s.i. liquids
1
0
0
0
1
0
0
1
0
0
0
0
0
0
0
0
0
1
0
1
0
0
0
0
0
Zn
WWTP solids
1
1
0
0
0
0
0
1
0
0
0
{)
(1
0
1
0
0
0
0
I
0
0
0
0
0
7n
Spent synthetic gypsum
4
4
0
0
0
0
0
4
0
0
0
0
I)
-
0
2
0
0
0
4
[>
0
0
0
0
Zn
WW I P liquid efilueni
0
0
0
0
0
0
0
0
0
0
0
I)
0
0
0
0
0
0
0
0
0
0
0
0
0
Zii
Zinc lean slag
2
2
0
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0
0
Total*

115
57
21
17
y
9
2
115
0
0
0
0
0
35
21

IK
X
11
115
0
0
0
0
a
April 30, 1998

-------
A-25
Kxhibit A.2-4
Distribution of Samples by Groundwater Hazard Category: Non-Canter Hazards



Central T
rmlcncv
HilIi Fuel


Number u('


Pre
l.l)K


Post-1.1)K


Pre
-I.DK


Past-WW

i
Samples with

l
10
100
Ik


1
1U
UNI
Ik


1
10
100
Ik


1
10
100
Ik



Nori-cunccr

to
to
to
to


to
to
to
to


to
to
to
to


to
to
to
to

Commodity
Waste Stream
Hazard
<1
III
KM)
Ik
10k
>IOk
<1
10
100
Ik
10k
> 1 Ok
<1
10
MM)
Ik
10k
>IOk
<1
10
100
Ik
10k
> lt)k
A1 arnJ Alumina
Cast house dust
2
2
0
0
0
0
0
j
0
0
0
0
0

0
0
0
0
0
2
0
0
0
0
0
Sb
Autoclave filliaie
H
{)
0
0
4
4
0
8
0
0
0
0
0
0
0
0


1

0
0
0
0
0
Be
Spent barren (titrate streams
5
0
1
4
0
0
0
5
0
0
0
0
0
0
0
1
4
0
0
5
0
0
0
0
0
Hr
C.'hip lrcaiiii.nl WW
I
0
0
0
0
1
0
I
0
0
0
0
0
I)
0
0
0
0
1
1
0
0
0
0
0
( u
Acid plant blowdown
35
6
8
13
5
3
0
35
0
0
0
0
0
0
3
X
14

s
ts
0
0
(1
II
0
Cu
Scrubber blowdown
3
0
1
2
0
0
0

0
0
0
0
0
0
0
0
3
0
0
3
0
0
0
0
u
fcleiiuntal Phos"plwrous
AHM misaie
2
0
2
0
0
0
0
2
0
0
0
0
0
0
0
0
2
0
0
2
0
0
0
0
0
lileuienlal Pliosphoious
furnace ottgas solids
14
14
0
0
0
0
0
14
0
0
0
0
0
14
0
0

0
0
14
0
(J
0
0
0
llcnvnl.il I'liosphorims
l-urnace scrubber blowdown
11
5
6
2
1
0
0
14
0
0
0
0
0
1
I
6
5

0
14
0
1)
0
0
0
l.lemental Phosphorous
Slag quenchwater
1
1
0
0
0
0
0
1
0
0
0
0
0
0
1
0
0
0
0
1
0
1)
0
0
0
Gc
Waste acid wash/nnse water
1
1
0
0
0
0
0
1
0
0
0
0
0
0
0
1
(j
0
0
1
0
0
0
0
0
Go
Chlorinjtor wei air poll ctil sludge
1
1
0
0
0
0
0
1
0
0
u
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Go
Hvdiulysis 1'iluaie
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
1)
0
0
0
I
0
0
0
0
0
Ge
Waste -villi liquor
1
1
0
0
0
0
0
1
0
0
0
0
u
1
0
I)
0
0
0
I
0
I)
0
0
0
Mg and Magnesia (brine)
Smut
2
2
0
0
{)
0
0
2
0
0
0
0
0
1
1
0
11
0
0
-)
0
0
0
0
0
Mo. I cMo. Amin Mo
liquid residues
1
0
0
1
0
0
0
i
0
0
0
0
1)
0
0
1)
1
0
0
1
0
0
0
0
0
Kiire harths
Spent amnion iiiirate proc sol.
6
5
I
0
0
0
0
6
0
0
0
0
u
4
1
1

0
0

0
0
0
0
0
Rare l.arths
pww
4
2
2
0
(1
0
u
4
0
0
0
0
I)
1
1
1
1
0
0
4
0
0
0
0
0
Se
Plant PWW
2
I
1
0
0
0
u
2
0
0
0
0
0
0

1
1
0
0
T
0
0
0
I)
0
Ta, Culuninum, aikl IvCol
PWW
21
13
2
5
0
1
0
21
0
0
0
0
0
X
2
3

0
4
?l
0
0
0
0
0
Titanium and Ti()2
Pickle liquor & wash water
3
0
3
0
0
0
0
3
0
0
0
0
0
0
0
3
0
0
0
<
0
u
0
0
0
liianiiim .mil Ti02
1 xruch liquor &. sponge wash waier
2
0
1
I
0
0
0
>
0
0
0
0
0
0
0
2
0
u
0
1
0
0
0
0
0
liiar.ium and Ti02
Scrap nulling scrubber water
1
0
1
0
0
0
0
1
0
0
0
0
(J
0

1
0
0
0
1
0
0
0
0
0
Titanium and Ti02
Spent s i liquids
10
10
0
0
0
0
0
10
0
a
0
0
0
10
0
0
0
0
0
10
0
0
0
0
0
Titanium and '1i()2
Spent s i solids
6
6
0
{)
0
0
0
6
0
0
0
0
0
3
3
0
0
0
0
6
0
{I
0
0
u
Titanium ami 11()2
Waste acids (.Sulfate process)
4
0
0
4
0
0
0
4
0
0
0
0
0
0
0
1
>
0
0
4
0
0
0
0
0
Titanium and I K)2
WWTP sludge/solids
2
2
0
0
0
0
0
9
0
0
(1
0
0
I
1
11
0
0
I)
2
I)
0
0
0
0
W
Spent acid & rinse waier
4
3
1
[)
0
0
0
4
(}
0
0
0
0
->
1
{)
1
0
0
4
0
0
0
0
0
Zn
Waste lenusilicun
1
1
0
11
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Zn
Spent s i liquids
22
4
I
3
6
4
1
22
0
0
0
0
0
0
5
2
3
6
(.
??
0
0
0
0
0
Zn
WWII' solids
7
7
0
0
0
0
0
7
0
0
0
0
0
2
4
1
0
0
0
7
0
0
0
0
0
Zn
Spent synthetic gypsum
4
4
0
0
0
0
0
4
0
0
0
0
(1
2
2
0
0
0
0
4
0
0
0
0
y
'/
WWTP liquid effluent

0
1
1
0
0
1

0
0
0
0
0
0
I)
2
I)
<1
1

0
0
0
0
0
Zn
Zinc lean slag

\
0
0
0
0
0
3
0
0
0
0
0
3
0
0
0
1)
0

0
0
0
0
0
Tut uls

l')7
y.s
35
36
16
13
2
147
0
(1
0
(1
0

26
IS
41
16
21
197
0
0
0
0
l>
April :*(), 1998
i

-------
A-26
proportions are not very different from those seen pre-LDR in both the December 1995 RLA. As noted
above, estimated cancer risks for all of the waste samples post-LDR are below 103.
The dis-tribution of pre-LDR cancer risks across waste streams is generally the same as that seen
in the previous risk assessments, with exception that several of the high-risk waste streams have been
eliminated from the analysis, as described above. The majority of samples with risks above 10 ' pre-LDR
were from antimony autoclave filtrate, copper acid plant blowdown, elemental phosphorous furnace
scrubber blowdown. tantalum, columbium and ferrocolumbium process wastewater, and titanium/titanium
oxide waste acids from the sulfate process. High-risk streams from the previous analysis which were
eliminated in this analysis include beryllium spent raffinate, lead process wastewater, and zinc process
wastewater.
As was the case for cancer risks, all of the wastes with pre-LDR noncancer hazard quotients
above the level of concern drop below this level post-LDR, under both CT and HE assumptions (Exhibit
A.2-4). Pre-LDR, the CT hazard quotients for 102 of 197 waste samples are above 1.0, while 139 of 197
samples had HE pre-LDR hazard quotients above 1.0. All of the same wastes having high pre-LDR cancer
risks also had high pre-LDR hazard quotients. In addition, a substantial number of samples from zinc
spent surface impoundment liquids and waste water treatment plant solids both had high noncancer hazard
quotients pre-LDR. As was the case for cancer risks, the reduction in hazard quotients below the level of
concern post-LDR is the result of the higher post-LDR DAF values that were derived using data for the
mineral processing waste constituents.
The results of the benefits analysis for cancer risks and noncancer risks under the no prior
treatment baseline are summarized in Exhibits A.2-5 and A.2-6. respectively. As discussed previously, the
distribution of risks across facility-waste stream combinations closely follows that seen for the individual
samples.
In the CT case, the number of facility-waste stream combinations with pre-LDR cancer risks
greater than 10"5 is 33 out of an estimated 108 facilities.6 Post-LDR, all of the facility-waste stream
combinations fall below the lO'^ CT risk level. In the HE case. 62 out of 133 facility-waste stream
combination have pre-LDR cancer greater than 105. All of these waste stream-facility combinations fall
into the risk category less than 10 5 post-LDR
The number of facility-waste stream combinations with pre-LDR CT hazard quotients greater
than 1.0 is 39 out of 108. In the HE case, 70 of 133 facilities have pre-LDR hazard quotients greater than
1.0. Post-LDR, all of the waste stream-facility combinations fall below the level of concern. The changes
in the distributions of facility-waste stream combinations across cancer risk and hazard quotient categories
associated with the LDRs for mineral processing wastes are shown graphically in Exhibit A.2-7.
6 In reviewing Exhibits 5, the reader will note that the sums of the waste-stream-facility combinations
in each risk category do not add up to the total number of facilities. This is because some of the facilities
do not produce wastes with carcinogenic constituents (e.g.. arsenic).
April 30, 1998

-------
A-27
Exhibit A.2-S
Distrihution of Waste Stream/Facility Combinations by Groundwater Risk Category: Cancer Risks


Number of
Central Tendency
III
ih Km) II


Waste Stream/
I'rtl.DK
Post-1.l)K
Pre-LDK
Post-1.1>K


facility

























1
Combination*" tt

10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2


10*5
10.4
10-3
10-2



Central
t"K'<

to
lu
tu
lo


to
to
to
lo


to
lo
lo
tu


tu
lo
lu
lu

Commodity
Waste Stream
TWideiicr
End
<10-5
IO-4
10-3
10-2
MM
>10-1
<10.5
10-4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
Ml-1
>10-1
<10-5
10-4
l3
10.2
1(1.1
>10-1
Al and Aluiiuiia
Cast Ikiusc dusl
2 *
2\
2i
0
0
0
0
0
23
U
0
0
0
0
23
0
0
0
0
u
23
0
0
0
0
0
Sb
Autoclave liliraie
4
7
0
0
0
2
2
0
4
0
0
0
0
0
0
0
0
0
4
4
7
0
0
0
0
0
He
Spent barren 1'iltrate streams
1
1
1
0
1
0
0
0
1
0
0
0
0
0
0
1
0
I
0
(1
1
0
0
0
0
0
Be
Chip treatment WW
I
2
)
0
0
0
0
0
1
0
0
0
0
0
)
0
{)
(1
0
0

0
0
0
0
0
Cu
Acid plant blowdown
7
7
2
o
2
1
0
1
I
0
0
I)
0
0
0
1
0
2
1
I
7
0
0
0
0
0
Cu
Saubber blowdown
10
10
i
n
;
0
0
0
10
0
0
0
u
0
0
3
0
7
0
0
14)
0
0
0
0
0
Klementul Phosphorous
APM rmsate
2
2
I
i
0
0
0
0
2
0
0
0
0
0
0
1
1
(J
0
u
2
0
0
0
0
0
l.lenvntal Phosphorous
Purnaee olVgas solids
2
2
2
0
0
0
0
0
. 2
0
0
0
0
0
2
(1
0
U
0
(I
)
0
0
0
0
t)
I JciiLiUdl Phosphorous
l:uniaee scrubber blowdown
2
2
1
i
0
0
0
0
2
0
0
0
0
0
0
1
1
(1
0
0

0
0
0
0
0
Hlentulal Phosphorous
Slag quenchwaier
2
2
0
2
0
0
0
0
2
0
0
0
0
0
0
(1
2
(1
0
0

0
(J
0
1)
0
Ge
Wjsie acid wasli/nnve water
2
4
2
0
0
[1
0
u
2
0
0
0
0
0
I)
4
0
0
0
(1

0
0
0
0
0
Ge
ChloiiiMlor wet air poll Ctrl sludge
2
4
2
0
0
0
0
0
2
0
0
u
0
0
4
0
0
(J
u
0
4
0
0
0
0
0
Ge
Hydrolysis filtrate
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
0
0
0
1)
0
4
0
0
0
0
0
lie
Waste still liquor
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
0
0
0
1)
0
4
0
0
0
1)
0
Mg uiu) Magnesia (brine)
Smut
2
>
2
0
0
0
0
0
2
0
0
0
0
0
2
O
0
0
u
0
2
0
0
0
0
0
Mo. leMo. A nun. Mo
Uquid residues
1
2
0
{)
0
1
0
0
1
0
1)
0
0
0
0
0
0
0
2
0

0
(J
0
0
0
Rate Karths
Spent auuitoii nittalc pan: sol
1
1
1
0
(1
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Rare liarths
pww
1
1
0
1
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
1
0
0
0
0
0
Sc
IMant PWW
i
>
0
2
0
0
0
0
2
0
0
0
0
0
0
0
2
0
0
0
)
0
0
0
0
0
Ta. Coluinhmm. ami 1-cCol
PWW
2
2
1
0
0
0
0
0
2
0
0
0
0
0
1
1
0
0
0
0
2
0
{)
0
0
0
1 itaiuum and Ti02
Pickle liquor & wash water
2
3
I
1
0
0
0
0
T
0
0
0
0
0
0
2
2
0
I)
0
3
0
0
0
u
0
Titanium and Ti02
Leach liquoi & spoiipe wash water
1
2
1
1
0
0
0
0
1
0
0
0
u
0
0
1
1
0
0
0
2
0
0
0
0
0
Titanium and Ii02
Scup nulling scrubber water
1
1
0
1
0
0
0
0
1
0
0
0
0
0
0
0
1
0
(1
0
1
0
0
0
0
0
Titanium and Ti()2
Spent s i lii|inds
4
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
(1
0
0
0
0
0
0
0
Titanium and '1 i(J2
Spent s i. solids
4
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
(1
0
0
I)
0
0
0
0
litaiiiumund li()2
Waste acids (Sulfate process)
1
2
0
1
0
0
(]
0
1
1)
0
0
M
0
I
0
2
0
0
0
-)
I)
0
0
u
0
Titanium and 1i02
WWTP sludge/solids
7
7
0
(}
0
0
(J
(J
0
u
0
0
(1
0
0
0
0
0
{)
0
0
0
0
0
0
0
W
Spent acid & rinse water
3
6
2
0
2
0
0
0
3
0
0
0
0
0
0
3
0
3
0
0
6
0
0
0
0
0
Zi.
Waste ferrosihcon
I
1
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2a
Spent s i liquids
3
3
0
0
0
3
0
0
3
0
0
0
0
0
0
0
0
()
\
0
3
0
0
0
0
0
/n
WWTP solids
3
3
3
0
0
0
0
{)
3
0
0
{)
0
u
0
3
0
0
0
0
3
0
u
0
0
0
/o
Spetil synthetic gypsum
3
*
3
0
0
0
0
{)
3
0
0
0
0
0
2
0
2
0
0
0

0
0
0
0
0
Zn
WWTP liquid diluent
3

0
0
0
0
0
0
0
0
0
0
0
0
0
O
0
0
0
0
0
0
(~
0
0
0
Zn
/.iIK lean slag
1
1
1
0
0
0
0
0
1
0
0
0
0
(J
1
0
0
0
0
0
1
0
0
0
0
0
TOTAUS*

108
133
56
11
11
8
2
1
89
0
0
0
0
0
46
20
14
n
10
5
10S
0
0
0
0
0
* Sums by risk category may not add to (lie number (it central or high-end wasie sueanvTucdiiy combinations due 10 rounding
ft Includes wasie sireanVlacility combinations with no cancer risk (but with an associated noti-cancet ha/.aid)
April .10, 1998

-------
A-28
Exhibit A.2-6
Distribution of Waste Stream/Facility Combinations by Groundwater Hazard Category: Non-Canter Hazards


Number of




c
ntral Tendency









Hit!
It ml







Waste Streamy
Prc-LDR
Post-urn
Pre-I.DK


Post-
l)K




family


























1
Comhiiiatioi
IS*

|
10
100
Ik


1
10
100
Ik


i
10
100
Ik


1
10
100
Ik



Central
High

to
to
to
to


to
to
tu
lo


lo
to
to
to


to
to
lo
lo

Commodity
Waste Stream
Tentleiicv
Knd
<1
10
KM)
Ik
10k
vIOk
<1
10
100
Ik
10k
>IOk
<1
10
100
Ik
10k
>IOk
<1
10
KM)
Ik
10k
>l0k
Al and Alumina
Cast house ilusi
2.1
23
2 \
0
0
0
0
0
23
0
0
0
0
0
23
0
0
0
0
u
> 1
0
0
0
0
0
Sh
Autoclave filtrate
4
7
0
0
0
3
1
0
4
0
0
0
0
0
0

0
2
2
>
7
0
0
0
0
(J
be
Spent barren filtrate streams
1
I
0
0
1
0
0
0
1
0
0
1)
0
0
0
0
0
I
0
0
1
1)
0
0
0
0
Be
Chip treatment WW
1
2
0
0
0
0
1
0
1
{)
0
0
0
0
{)
0
0
I)
0
2
2
0
0
0
0
0
Cu
Acid plant bluwdown
7
7
1
2
2
1
1
0
7
0
0
0
0
0
0
1
1
2
1
1
7
0
0
0
0
0
Cu
Sv rubber blowdown
10
10
u
3
7
0
0
0
10
0
0
0
0
0
(1
0
0
10
0
0
ID
0
0
0
0
u
l-lcmental l*hi>spht>r
0
u
0
0
0
Uciiteitial Phosphorous
Slag quenchwaicr
2
"
0
0
0
0
0
0
2
0
0
I)
u
0
0

0
0
0
0
2
0
0
0
0
u
Ge
Waste acid wash/rinse water
?.
4
2
0
0
0
0
0
1
0
0
0
0
0
0
0
4
0
0
0
-l
0
0
0
0
0
Gc
Chlorinator wet air poll Ctrl sludge
2
4
2
(1
0
0
1)
0
2
0
0
0
0
0
4
0
0
0
0
4)
4
{)
0
0
0
0
(>e
Hydrolysis filtrate
2
1
2
0
0
CI
0
0
2
0
0
0
0
0
4
0
0
0
0
0
4
0
0
0
0
0
(ic
Waste still liquor
2
4
2
0
1)
D
0
0
2
0
0
(1
0
0
4
0
0
0
(1
1)
4
0
0
I)
0
[}
Mg and Magnesia (brme)
Smut
2
0
2
0
0
0
0
0
2
0
0
0
I)
0
1
1
0
0
0
u
2
0
0
0
0
0
Mo, i'oMo, Aniin Mo
Liquid residues
1
2
0
0
1
0
u
u
1
0
0
0
0
0
0
0
0
2
u
u
2
0
0
0
0
0
Rare barths
S|H.-nt amnion nitrate proc sol
1
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
(j
0
1
0
0
I)
0
0
Kaie rialitis
I'WW
1
1
I
0
Q
0
I)
0
1
0
0
0
0
0
0
0
0
0
(J
0
1
0
0
0
0
0
Sc
Plant PWW
2
2
1
1
0
0
0
0
2
0
0
0
0
0
0
0
1
1
(1
0
2
0
0
0
0
0
lu. Columbiurn. and
pww
2
2
1
0
0
0
0
0
2
0
0
0
0
0
1
0
0
0
0
0
2
0
0
0
(}
0
l:eCol



























Titanium and Ti02
Pickle liquor & wash water
2
3
0
2
u
0
0
0
2
0
0
0
0
0
0
0
3
0
I)
0
3
0
0

0
0
Titanium and TiC>2
Ixsuh liquor \ sponge wash water
1
j
0
1
1
0
0
0
1
0
0
{)
0
0
0
0
2
0
0
(.)
>
0
0
0
0
0
Titanium and Ti()2
Scrap nulling scrubber water
1
1
0
1
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
1
0
0
(1
0
0
1 nanium and TiC)2
Spent s i liquids
4
7
4
0
0
0
u
0
4
0
0
0
0
u
7
0
u
0
0
u
7
0
0

0
0
Titanium and Ti()2
Spent s i. solids
4
7
4
0
{)
0
11
0
4
0
0
0
0
0
5
2
0
0
0
0
7
0
0
0
u
0
Titanium and Ti02
Waste acids (Sulfate process)
1
2
0
0
1
0
u
0
1
0
0
0
0
0
0
0
1
I
0
0
2
0
u

u
0
Titanium and Tit)2
WWTP sludge/solids
7
7
7
0
0
0
0
0
7
0
0
0
0
0
4
4
0
0
0
0
7
0
0
0
0
0
W
Sjxrnt acid & rinse water
3
6
2
1
0
0
0
0
3
0
0
0
0
0
3
J
0
2
0
[1
6
0
0
0
0
0
Zn
Waste t'errosilicoii
1
1
I
0
0
0
0
0
1
0
0
0
0
(1
1
0
0
0
0
u
1
0
0
0
0
0
Zn
Spent s i. liquids
3
3
0
1
1
0
1
0
3
1)
0
0
0
0
0
1
0
1
0
1
3
0
{)

0
0
Z11
WWTP solids
i
3

0
0
0
0
0
3
0
0
0
0
0
1
I
1
0
0
0
3
0
0
0
0
0
Zn
Spent synilkciic gypsum
i
3
3
0
0
0
0
0
3
0
0
0
0
0
2
2
0
0
0
0
3
0
0
0
0
0
Zn
WW I I' liquid diluent
3
3
0
1
1
0
0
1
3
u
0
0
0
0
0
1}

0
0
1
1
0
0
0
0
0
Zn
Zinc lean slag
1
1
I
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
t)
0
0
{)
TOTAlJi*

11)8
133
6K
Ift
14
4
4
1
108
0
0
0
0
0
63
15
l>
24
4
K
133
0
0
0
0
t)
* Sums by ha/.aid category may rail add 10 the number ol central ur lugh end wa.sk* streun^tacility combinations due 10 rounding
April 30, 1998

-------
A-29
Exhibit A.2-7
Distribution of Waste Stream/Facility Combinations by Groundwater Risk
and Hazard Categories
a 100
 &  ^
3 1 i 30
5 | | SO
2 g 1
is5 20
o
40

Cancer Risk
Central Tendency
~ Pre-LOR
IPcst-LDR
CZL
<10E-5 1C6-5 to 10E4 10E-4 to 10E-3 1CE-3:o 10E-2
Risk Category
10E-2 to'OE-1
:	 s
	s s
	||
a	 O
f 20
*00
30
00
40
20
0
I
Cancer Risk
High End
o
(A
>.
(ft
120 -
*
5
o
<8
c
o

100 -
80 -
o
n
1
(B
1)
S
a
E
60 -
40 -
E
3
A
CO
o
o
20 -
z

0 -
10E-8 to 1QE-4 10E-4 to 10E-3 10E-3 to 10E-2 10E-2 to 10E-1
Risk Category
J
m
1 to 10
Non-Cancer Risk
Central Tendency
i C to
100
IOC 10
i.OCO
1.000 to
10000
>10,000
Risk Category
 c a
j 3i o
150
100 t
50
0 ;
J
Ko 10
Non-Cancer Risk
High End
1	1
10 to
10C
too k)
1,000
1,000 :o
1 C.GOG
C.COO
Risk Category
April 30, 1998

-------
A-30
A.2.3.2 Risk and Benefits Assessment Results for Storage of Recycled Materials
EPA's evaluation of the potential groundwater risks associated with the storage of recycled
streams under the modified prior treatment baseline is described in Section 4.2 of this RIA. These results
will not be discussed further here.
A.2.4.0 LIMITATIONS AND UNCERTAINTIES OF THE GENERIC RISK AND BENEFITS
ASSESSMENT FOR WASTE DISPOSAL
The section presents a brief discussion of the major uncertainties and limitations in the risk and
benefits assessment for the no prior treatment baseline scenario. As stated in A.2.1. the discussion will be
limited primarily to the sources of uncertainty specific to the revised analysis, and issues associated with
previous risk and benefits work will only be mentioned briefly.
A.2.4.1 Major Uncertainties in the Risk Assessment for Waste Disposal
The major uncertainties associated with the risk assessment for mineral processing wastes are
discussed in detail in Section 5.3.4 of December 1995 RIA, the major factors limiting the ability to
quantify risks associated with the pre- and post-LDR disposal of mineral processing wastes include:
	Uncertainty about the identities, amounts, toxicity characteristics, elemental
composition, and leaching behavior of wastes;
	Uncertainty about pre- and post-LDR waste amounts, waste management,
recycling, and disposal practices;
	The use of the generic chemical release, groundwater transport, and exposure
models instead of facility-specific data;
	The use of toxicity criteria derived primarily from animal studies; and
	The use of simplified models for predicting cancer risks and the potential for
adverse noncancer affects.
This analysis represents EPA's attempt to address some of these uncertainties, continuing the
process of refinement which began with the sensitivity analysis performed as part of the December 1995
RIA. In addition. EPA has incorporated information received from commenters on the RIA to further
assure that the risk assessment is consistent with the most recent information available. The efforts taken
to incorporate new data, and their affect on the risk results, are discussed below.
EPA received no substantial new information regarding the identities of additional waste streams
or constituent concentrations that could be incorporated into the risk analysis. Based on public comments
on the December 1995 RIA, a number of waste streams were removed from the risk and benefits analysis,
cither because they are no longer generated, or because EPA has determined that they are fully recycled
and not disposed in land units. Removing these wastes from the analysis resulted in a reduction in the
number of samples for which risks were calculated and in the number of facilities in the benefits analysis.
The analysis is more accurate than the previous risk and benefits assessment in that it no longer includes
waste streams that would not be covered by the LDRs. It should be remembered, however, that the risk
and benefits assessment, while it still covers the majority of the estimated mineral processing waste
volume, does not address the majority of waste streams that are included in the cost and economic impact
April 30, 1998

-------
A-31
analysis. Thus, it is likely that benefits from controls on waste disposal are underestimated, given that the
risks for many wastes streams could not be calculated.
Several commenters on the December 1995 RIA noted the relatively limited amount of
constituent concentration data that was used for the risk and benefits analysis, and criticized the
assumptions used to characterize the leaching characteristics of wastes for which only bulk concentration
data were used. In order to help address the shortage of data and to evaluate the impact of the leaching
assumption, the both the HP and bulk analysis data were used in this analysis to develop separate risk
estimates for NWW and I.NWW waste streams when both are available, instead of using only the leachate
data. This expansion of the analysis resulted in increases in the numbers of samples for which risk
estimates were developed, as discussed in Section 4.1.2. This change in approach, which was adopted to
make the fullest possible use of the available data, did not result in significant changes in the distribution
of risks for the mineral processing waste samples as a whole, or for any of the individual waste streams.
This also suggests that the particular leaching assumption that was used did not result in any significant
bias in the risk assessment results.
The major change in the risk results from previous analyses of waste management practices is the
dramatic reduction in estimated post-LDR groundwater pathway risks, to the extent that no waste samples
had CT or HE post-LDR cancer risk or hazard quotients above levels of concern. This change is due to
the changes in the method used to estimate groundwater concentrations. Like the previous analyses, the
results presented in this assessment were derived using DAF values instead of site-specific modeling. In
the original risk modeling, the DAFs were specific to the type of management unit, but were not
constituent-specific, and they were derived for a nationally representative set of hydrogeological
conditions. They, therefore, did not reflect (1) the inherent geochemical properties of the waste
constituents, (2) the variations in transport that could be expected to occur as release concentrations varied,
or (3) the specific hydrogeologic regimes at mineral processing facilities. In contrast, the DAF values used
in this analysis take into account all of these factors. They were derived using constituent-specific
geochemical characteristics, waste management unit sizes, waste volumes, and constituent concentrations
from mineral processing industries, as well as hydrogeological variable values typical of the regional
distribution of mineral processing facilities.
Thus, while the approach to groundwater transport modeling taken in this analysis is still not site-
specific. it has been carefully adjusted to incorporate all of the available data affecting potential releases
and transport of waste constituents in groundwater. The degree of uncertainty associated with groundwater
transport modeling, while still large, has thus been reduced substantially from previous analysis, and biases
in the modeling resulting from failure to incorporate key variables has been greatly reduced.
The only major change in the toxicological parameter values that has been made since the
previous risk analyses has been to eliminate consideration of beryllium as an ingestion pathway
carcinogen. This change resulted in minimal impacts on the risk or benefits analysis, because beryllium
was a risk driver for only a few waste streams. The impact of this change was reduced further because two
of the waste streams from the beryllium industry were removed from the analysis for other reasons, as
discussed in Section A.2.2.1.2.
April 30, 1998

-------
A-32
A.2.4.2 Major Uncertainties in the Risk Assessment for Storage of Recycled Materials
The major limitations and sources of uncertainty in the mukipathway risk assessment for the
storage of recycled materials are discussed in detail in Appendix H, and will not be further addressed here.
A.2.5 REFERENCES CITED
ICF Incorporated (1996a). "Preliminary Results of Mineral Processing Wastes Risk and Benefits
Assessments Using Constituent-Specific DAFs" technical memorandum submitted to the USEPA Office of
Solid Waste, May S, 1996.
ICF Incorporated (1996b), "Revised Results of Mineral Processing Wastes Risk and Benefits Assessments
Using Constituent-Specific DAFs Derived for Mineral Processing Waste" technical memorandum
submitted to the USEPA Office of Solid Waste, July 2, 1996.
ICF Incorporated (1995), "Regulatory Impact Analysis of the Supplemental Proposed Rules Applying
Phase IV Land Disposal Restrictions to Newly Identified Mineral Processing Wastes", submitted to the
USEPA Office of Solid Waste, December 1995.
USEPA, Office of Solid Waste (1996), "Groundwater Pathway Analysis for Mineral Processing Wastes
Background Document (Draft), July 1996.
A.3 Risk Characterization Spreadsheets
This section of Appendix A presents the data and calculations that were used to characterize risk
changes for waste disposal pre- and post-LDR under the no prior treatment baseline scenario. Exhibit A.3-
1 presents the list of wastes for which constituent-specific data were available. Exhibit A.3-2 presents the
constituent-specific DAFs used to evaluate groundwater exposures. Exhibit A.3-3 presents the toxicity
parameter values used in the risk analysis. Finally, Exhibit A.3-4 presents an example risk calculation for
a single waste sample from concentration data to risk results.
April 30. 1998

-------
A-33
Exhibit A.3-1
List of Wastes for Which Constituent-Specific Data were Available
Commoditv
Waste Stream
Aluminum and Alumina
Cast house dust
Antimony
Autoclave filtrate
Berryllium
Spent barren filtrate streams
Berrvllium
Chip treatment wastewater
Copper
Acid plant blowdown
Copper
Scrubber blowdown
Elemental Phosphorous
AFM rinsate
Elemental Phosphorous
Furnace offgas solids
Elemental Phosphorous
Furnace scrubber blowdown
Elemental Phosphorous
Slag quenchwater
Germanium
Waste acid wash/rinse water
Germanium
Chlorinator wet air pollution control sludge
Germanium
Hydrolysis filtrate
Germanium
Waste still liquor
Magnesium and Magnesia (brine)
Smut
Molybdenum. Ferromolybdenum, Ammonium Molybdate
Liquid residues
Rare Earths
Spent ammonium nitrate processing solution
Rare Earths
Process wastewater
Selenium
Plant process wastewater
Tantalum, Columbium, and Ferrocolumbium
Process wastewater
Titanium and Titanium Dioxide
Pickle liquor & wash water
Titanium and Titanium Dioxide
Leach liquor & sponge wash water
Titanium and Titanium Dioxide
Scrap milling scrubber water
Titanium and Titanium Dioxide
Spent surface impoundment liquids
Titanium and Titanium Dioxide
Spent surface impoundment solids
Titanium and Titanium Dioxide
Waste acids (Sulfate process)
Titanium and Titanium Dioxide
Wastewater treatment plant sludge/solids
Tungsten
Spent acid & rinse water
Zinc
Waste ferrosilicon
Zinc
Spent surface impoundment liquids
Zinc
Wastewater treatment plant solids
Zinc
Spent synthetic gypsum
Zinc
Wastewater treatment plant liquid effluent
Zinc
Zinc lean slag
April 30, 1998

-------
Exhibit A.3-2
Constituent-Specific l)AFs Used to Evaluate Groundwater Exposures

Surface Impoundments
Waste Piles

Central Tendency
High End
Central Tendency
High End
Central Tendency
High Knd

(75th percentile)
(95th percentile)
(75th percentile)
(95th percentile)
(75th percentile)
(95th percentile)
Constituent
Pre-LDR
Pre-LDR
Pre-LDR
Pre-LDR
Post-LDR
Post-LDR
Antimony
1 93E+02
2.28F.+OI
>10
8.36E (03
>10
"8.36E+03
Arsenic
I.66E+02
I.71E+01
>10
2.56E+03
4.37E+09
2.56E+03
Barium
5.81 R+(M)
1.17R t ()()
2.22E+03
1.38K+01
2.33E+03
1.40E+01
Beryllium
8.47E+00
1.24E+00
>10
4.87 E+02
>10
"5.541-1(02
Cadmium
2.49EtOI
1 .40E+00
>10
2.67E+03
>10
"3.26E+03
Chromium
9.82E+01
1.I5E+01
2.21E+04
I.60F.+02
2.21 It +04
1 .60E+02
Cyanide
2.8IH+10
4.20E+03
--
--

--
Lead
7.1 IE (05
4.98E+00
>10
2.27E+05
> 10
"8.93E+08
Mercury
1 .97H+02
8.05E+00
>10
4.29E+03
>10
"4.29F.+03
Nickel
2.23H+0I
1.51E+00
1.54E+06"
1.41 E+02
I.97E+06
1.46E+02
Selenium
2.70E+0I
3.38E+09
1 18E+08
4.28Ei()2
1.191- (08
4.28E+02
Silver
1.1 IE+01
1.23E+00
>10
4.96E+02
>10
"4.87E+02
Thallium
2.97 E+02
4.15E+0I
>10
9.63K (04
>10
"9.63E+04
Vanadium
5.67E+00
2.03E+00
>10
>10"
>10"
>10"
Zinc
I.23E+01
l.35E-t()()
>10
>10"
>10"
>10"
Note: Central Tendency values arc the 75th percentile of the distribution of DAF values and the High F.nd values are the 95th percentile.

-------
A-35
Exhibit A J-3
Toxicity Parameter Values Used in the Risk Analysis
Constituent
Oral Cancer
Slope Factor (CSF)
l/(mg/kg-day)
Oral Reference 1
Dose (RfD)
mg/kg-day
Antimonv
	
0.0004
Arsenic
1.5
0.0003
Barium
	
0.07
Beryllium
	
0.005
Boron

0.09
Cadmium

0.0005
Chromium

0.005
Lead

0.0003
Manganese

0.047
Mercury

0.0003
Molybdenum

0.005
Nickel
	
0.02
Selenium
	
0.005
Silver
	
0.005
Thallium
	
000008
Vanadium
	
0.007
Zinc
	
0.3
Cvanidc
	
0.02
Fluoride
-
0.06
Source: EPA IRIS (1996) and HEAST (1995)
The Lead RID is derived from the EPA action level of 0.015 mg/L.
The RfD for Chromium is from Cr+6
The RfD for Thallium is from Thallium sulfate.
There were no toxicity values for the following constituents: Aluminum,
Cobalt, Copper, Iron, Magnesium, Phosphate, Silica, Chloride, TSS,
pH, Organics (TOC), Sulfide, or Sulfate.
April 30, 1998

-------
A-36
Exhibit A.3-4 - Example Risk Calculation for a Single Waste Sample from Concentration Data to Risk Results
Waste Stream Data & Calculations
Commodity Waste Stream
Hare Earths Spent ammonium nitrate
processing solution
Facility Identifier = Res. Chem, Phoenix
State - AZ
Sample
Number
Cancer
Central Tendency	High End
Pro-LDR Post-LDR Pre-LDR Post-LDR
5.57E-08 2 12E-12 5.41E-07 5.41E-07
Non-Cancer
Central Tendency	High End
Pre-LDR Post-LDR Pre-LDR Post-LDH
3.85E-03 4.47E-04 1.41E-QI 1 17E-02
The cancer risk values are the sum ol risks from each constituent in a sample.
The non-cancer hazard values represent tho highest hazard quotient for a constituent in a sample
Treatment Type
Waste 1 10%
Water Solids
Total
Constituent EP Toxicity
Pre-LDR DAFS Post-LDR DAFS
Analysis Analysis Central
High
Central
High
1
Solid
Constituents
(ppm)
(ppm) Tendency
End
Tendency
End
0
0
Aluminum





0
0
Antimony

1.93E+02
2.28E+01
3.00E+13
8 36Ei-03
0
0
Arsenic
0.0025
1.66E+02
1.71E+01
4.37E+09
2.56E+03
0
0
Barium
0.05
5.81E+00
1.17E+00
2.33E+03
1.46E+01
0
0
Beryllium

8.47E+00
1.24E+00
2.13E+15
5.54E+02
0
0
Boron
0.12




0
0
Cadmium
0.0025
2 49E+01
1.40E+00
6.12E+16
3.2GE+03
0
0
Chromium
0.01
9.82E+01
1.15E+01
2.21E+04
1.60E+02
0
0
Copper
0.005




0
0
Iron





0
0
Lead
0.011
7.11E+05
4.98E+00
1.00Et30
8.93E+08
0
0
Magnesium





0
0
Manganese
0.005




0
0
Mercury
0.0001
1 97E+02
8 05E+00
6 37E+1?
4.29E+03
0
0
Molybdenum





0
0
Nickel

2.23E+01
1.51Ei00
1.97E+06
1.46E.02
0
0
Selenium
0.0025
2.70E+O1
3.38E+00
1.19E+08
4.28E+02
0
0
Silver
0.005
1.1 tE+01
1 23E+00
1.33E+10
4.87E+02
0
0
Thallium

297E+02
415E+01
1.23E+2B
9.63E+04
0
0
Vanadium

5.67E+00
2.03E+00
1.00E+30
1.00E+30
0
0
Zinc
 0 005
1 23E401
1.35E+00
1.34E + 16
1 77E+03
0
0
Cyanide
0.005
2.81E+10
4.20E+03


0
0
Sulfide
0.025




0
0
Fluoride





For constituents with a DAF, if the treatment typo is solid (tho solid column has a 1), tho DAF value returned is for wasto piles;
otherwise, the DAF value returned is tor surface impoundments. See Exhibit A.3-2 for the DAF values.
April 30, 1998

-------
A-3 7
Exhibit A.3-4 (Continued) - Example Risk Calculation for a Single Waste Sample from Concentration Data to Risk Results

Host-LDRs (UTS) - Central Tendency


Post-LDHs (UTS) - High End


Groundwater
Cancer
Noncancer Lifetime

Groundwatei
Cancer
Moncancer Lifetime


Cone
Dose
Dose Excess
Hazard
Cone
Dose
Dose Excess
Hazard
Constituents
(pp'm=mq/L)
(mtj/kq-d)
(mq'kq-d) Cancer Risk
Quotient
(ppm=mq/L) (mq/kg-d)
(mcy1
-------
A-38
Exhibit A.3-4 (Continued) - Example Risk Calculation for a Single Waste Sample from Concentration Data to Risk Results


Pre-LDRs  Central Tendency

Pre-LDHs - High End


Groundwate
Cancer
Noncancer Lifetime
Groundwate
Cancer
Noncancer Lifetime


Cone
Dose
Dose Excess Hazard
Cone
Dose
Dose Excess
Hazard
Constituents (ppm=mg/L) (mg/kg-d)
(mq/kg-d) Cancer Risk Quotient
(ppm=mg/L) (mg/kq-d)
(mti'kq-d) Cancer l-tisk
Quotient
Aluminum







Antimony







Arsenic
1.51E-05
3.71E-08
2.89E-07 5.57E-08 9.63E-04
1.4GE-04
3.60E-07
2.80E-06 5.41 E-07
9 35E-03
Barium
8.61 E-03
2.12E-05
1.65E-04 2.3GE-03
4.27E-02
1.05E-04
8 20E-04
1 17E-02
Beryllium







Boron







Cadmium
1.00E-04
2.48E-07
1.93E-06 3.85E-03
1.79E-03
4.40E-06
3.42E-05
6 85E-02
Chromium
1.02E-04
2.51 E-07
1.95E-06 3.91 E-04
8.70E-04
2.14E-0G
1 67E-05
3.34E-03
Copper







Iron







Lead
1.55E-08
3.81E-11
2.97E-10 9.89E-07
2.21 E-03
5.45E-06
4 24E-0S
1.41E-01
Magnesium







Manganese







Mercury
5.08E-07
1.25E-09
9.74E-09 3.25E-05
1.24E-05
3.06E-08
2.38E 07
7.94E-04
Molybdenum






Nickel







Selenium
9.26E-05
2.28E-07
1.78E-0G 3.55E-04
7.40E-04
1.82E-06
1.42E-05
2.84E-03
Silver
4.50E-04
1.1 1E-06
8.64E-06 1.73E-03
4.07E-03
1.00E-05
7.80E-05
1.56E-02
Thallium







Vanadium







Zinc
4.07E-04
1 OOE-06
7.80E-06 2.60E-05
3 70E-03
9.13E-0G
7.10E-05
2.37E-04
Cyanide
1.78E-13
4 39E-16
3.41E-15 1.71E-13
1.19E-06
2 94E-09
2.28E-08
1.14E-06
Sulfide







Fluoride







Groundwater (gw) concentration = tolal constituent analysis concentration / DAF (for waste waters with a total constituent analysis concentration)

gw concentration = EP toxicity analysis concentration / DAF (for non-waste waters with an EP toxicity analysis concentration)

gw concentration = total constituent analysis concentration / 20 / DAF (for solids with a total constituent analysis concentration and no EP toxicity analysis concentration)
gw concentration = total constituent analysis concentration / DAF (for 10% solids with a total constituent analysis concentration and no EP toxicity analysis concentration)
No gw values are returned for constituents with no DAF or total constituent analysis concentration



Cancer dose - gw concentration x cancer gw inta Noncancer dose = gw concentration x noncancer gw intake.



Cancer gw intake = (gw intake'exposure duration'exposure frequency)/(cancer averaging time"365"body weight) = 0.00247 L/kg-day.

Noncancer gw intake =
(gw intake'exposure duration'exposure frequency)/(noncancer averaging time'365"body weight)
= 0.01918 L/ky-Uay.

Cancer risk = slope factor x cancer dose
Hazard quotient (hq) = noncancer dose / RfD. See Exhibit A.3-3 for slope factors and HIDs

Body Weight = 70 kg


Exposure Duration = 9 years
Non-cancer Averaging Time = 9 years

Exposure Frequency -
350 days/year

Cancer Averaging Time = 70 years
Groundwater Ingestion Rate = 1.4 L/day

No cancer risk values are returned for constituents with no slope factor; no hq values are returned for constituents with no RfD

April 30, 1998

-------
METHODOLOGY
APPENDIX B
This appendix details EPA's step-wise methodology for defining the universe of mineral
processing sectors, facilities, and waste streams potentially affected by the proposed Phase IV Land
Disposal Restrictions. The Agency developed a step-wise methodology that began with the broadest
possible scope of inquiry in order to assure that EPA captured all of the potentially affected mineral
commodity sectors and waste streams. The Agency then narrowed the focus of its data gathering and
analysis at each subsequent step. The specific steps and sources of data employed throughout this analysis
are described below, and are summarized in Exhibit B-l.
Exhibit B-l
Overview of the Agency's Methodology for
Defining the Universe of Potentially Affected
Mineral Processing Waste Streams
Step One
Identify Mineral
Commodity
Sectors of Interest
Slep Two
Conduct Exhaustive
Information Search on
Mineral Commodity
Sectors of Interest
Step Three
Prepare Mineral Commodity
Analysis Reports on
Each Sector
~
Step Four
Define Universe of Mineral
Processing Waste Streams
Potentially Affected hy
the Phase IV f.DRs
T
Step Five
Define Universe of Mineral
Processing Facilities
Potentially Affected hy
the Phase IV LDRs
Step Six
Prepare Finai Estimates of
the Voiume of Mineral
PrcKC5smg Waste Streams
Potentially Affected by
the Phase IV LDRs
April 30, 1998

-------
B-2
Step One	B. 1 Identify Mineral Commodity Sectors of Interest
EPA reviewed the 36 industrial sectors
(commodities) and 97 different general categories of wastes
previously developed and published in the October 21,
1991 Advanced Notice of Proposed Rule Making
(ANPRM). EPA also reviewed the U.S. Bureau of Mines's
1991 Minerals Yearbook, 1995 Mineral Commodities
Summary, and the 1985 Mineral Facts and Problems. The
Agency reviewed this comprehensive listing of all of the
mineral commodity sectors and removed from further
consideration all non-domestically produced mineral
commodities; all inactive mineral commodities, such as
nickel: and all mineral commodities generated from
operations known not to employ operations that meet the
Agency's definition of mineral processing.' As a result of
this process, EPA identified a total of 62 mineral
commodities that potentially generate "mineral processing"
waste streams of interest. These mineral commodity sectors
arc listed below in Exhibit B-2.
The Agency notes that Exhibit B-2 represents
EPA's best efforts at identifying mineral commodities
which may generate mineral processing wastes. Omission
or inclusion on this list does not relieve the generator from
managing wastes that would be subject to RCRA Subtitle C
requirements.
B.2 Conduct Exhaustive Information Search on Mineral Commodity Sectors of Interest
EPA researched and obtained information characterizing the mineral processing operations and
wastes associated with the mineral commodities listed in Exhibit B-2. This information was used by EPA
both to update existing data characterizing mineral processing wastes obtained through past Agency efforts
and to obtain characterization information on newly identified waste streams not previously researched.
To provide the necessary foundation to develop a fully comprehensive inventory of mineral
commodity sectors, facilities, and waste streams that might be affected by the Phase IV LDRs program,
EPA embarked on an ambitious information collection program. Specifically, to capitalize on information
collected through past efforts, as well as to collect more recent data, the Agency conducted the following
activities:
1 Sectors that employ operations that mill (e.g., grind, sort, wash), physically separate (e.g., magnetic,
gravity, or electrostatic separation, froth flotation), concentrate using liquid separation (e.g., leaching
followed by ion exchange), and/or calcine (i.e., heat to drive off water or carbon dioxide), and use no
techniques that the Agency considers to be mincral processing operations (e.g., smelting or acid digestion)
are unaffected by the Phase IV LDRs.
Icentify Mineral Commodity
.Sectors of Interest
Conduct Bxhausti
u:i Mmer.il Corr.m
formation Search
Sectors of Interest
April 30. 1998

-------
R-3
Exhibit B-2
Mineral Commodities Of Potential Interest
n
Aluminii
32)
Lightweight Aggregate
2)
Aluminum
33)
Lithium (from ore-;)
3)
Ammonium Molybdate
34)
Lithium Carbonate
't.i
AiUimony
35)
Magnesia (from brines)
5)
Arsenic Acid
36)
Magnesium
6)
Asphalt (natural)
37)
Manganese and MnO,
7)
Beryllium
38)
Mercury
8)
Bismuth
39)
Mineral Waxes
9)
Boron
40)
Molybdenum
10.1
Bromine (from brines)
41)
Phosphoric Acid
11)
Cadmium
42)
Platinum Group Metals
12)
Calcium Metal
43)
Pyrobitumens
13)
Cerium. Lanthanides. and Rare Earths
44)
Rhenium
14)
Cesium/Rubidium
45)
Scandium
15)
Chromium
46)
Selenium
16)
Coal Gas
47)
Silicomanganese
17)
Copper
48)
Silicon
18)
Elemental Phosphonis
49)
Soda Ash
19)
Ferrochrome
50)
Sodium Sulfate
20)
Ferrochrome-Silicon
51)
Strontium
21)
Fcrrocolumbium
52)
Sulfur
22)
Ferromanganese
53)
Synthetic Rutile
23)
I-erromolvbdenum
54)
Tantalum/Columbium
21)
Fenosilicon
55)
Tellurium
25)
Gemstones
56)
Tin
26)
Germanium
57)
Titanium/TiO,
27)
Gold and Silver
58)
Tungsten
28)
Hydrofluoric Acid
59)
Uranium
29)
Iodine (from brines)
60)
Vanadium
30)
Iron and Steel
61)
Zinc
31)
Lead
62)
Zirconium/Hafnium
April 30, 1998

-------
B-4
Step Tw o
Identify Mineral Cnmmorlit
Sector* of Interest
C:>."ul:
c: fxhimtiv
firrmtirn Seirch
HI VI. 11
r^l Cu nit.vX
.S A.'ulysi
Reviewed the National Survey of Solid Wastes From
Mineral Processing Facilities (N'SSWMPF) survey
instruments and public comments (submitted in
response to the 1991 ANPRM) for process-related
information (e.g., process flow diagrams, waste
characterization data, and waste management
information).
Reviewed numerous documents ie.g., Buteau of
Mines publications, the Randol Mining Directory
and other Industrial Directories, and various
Agency contractor reports ) for process-related
information.
Reviewed trip reports prepared both by EPA and its
contractors from sampling visits and/or inspections
conducted at approximately 50 mineral processing
sites located through out the United States.
Reviewed sampling data collected by EPA's Office
of Research and Development (ORD), EPA's Office
of Water (OW), and Agency survey data collected to
support the preparation of the 1990 Report to
Congress.
Reviewed both the 1993, 1994, and 1995 "Mineral
Commodity Summaries" prepared by the U.S.
Bureau of Mines (BOM) for salient statistics on
commodity production.
Partially reviewed and summarized damage case information presented in the "Mining
Sites on the National Priorities List, NPL Site Summary Reports" to support work on
assessing the appropriateness of the Tonicity Characteristic Leaching Procedure (TCLP)
for mineral processing wastes.
Contacted the BOM Commodity Specialists associated with the commodity sectors of
interest to (1) obtain current information on mining companies, processes, and waste
streams, and (2) identify other potential sources of information.
Retrieved applicable and relevant documents from the BOM's FAXBACK document
retrieval system. Documents retrieved included monthly updates to salient statistics,
bulletins, and technology review papers.
Conducted an electronic query of the 1991 Biennial Reporting System (BRS) for waste
generation and management information on 34 mineral processing-related Standard
Industrial Classification (SIC) numbers.
Conducted an electronic literature search for information related to mineral processing and
waste treatment technologies contained in numerous technical on-line databases,
April 30. 1998

-------
B-5
including: NTIS, Compendex Plus, MF.TADEX, Aluminum Industry Abstracts,
ENVIROLINE, Pollution Abstracts. Environmental Bibliography, and GEOREF.
EPA focused its search for relevant information (published since 1990) on the mineral
commodities listed in Exhibit B-2. The Agency chose 1990 as the cutoff year so as not to duplicate past
information collection activities conducted by EPA and its contractors, and to obtain information on
minenil processes "retooled" since clarification of the Bevill Amendment to cover truly "high volume, low
hazard" wastes. After an exhaustive search through both the publicly available and Agency-held
information sources, EPA assembled and organized all of the collected information hy mineral commodity
sector.
.... ,	B 3 Prepare Mineral Commodity Analysis Reports on Each of
' P	the Identified Sectors
i
Cord-jri [.ihausLv: Interrr-aiton S Pyi
-------
B-6
waste stream sources and form (i.e.. wastes with less than 1 percent solids and
total organic content, wastes with 1 to 10 percent solids, and wastes with greater
than 10 percent solids):
Bevill-btdusion status of the waste stream (i.e.. extraction/beneficiation waste
stream, mineral processing waste stream, or non-uniquelv.associated waste
stream).
waste stream characteristics (total constituent concentration data, and statements
on whether the waste stream exhibited one of the RCRA hazardous wa^te
characteristics of toxicity, ignitability, corrosivity, or reactivity):
annual generation rates (reported or estimated);
management practices (e.g., tank treatment and subsequent NPDES discharge,
land disposal, or in-process recycling); and
whether the waste stream was being (or could potentially be) recycled, and be
classified as either as a sludge, by-product, or spent material.
The collection and documentation of the commodity summary and process description sections of
the mineral commodity analysis reports was relatively straight-forward and involved little interpretation on
the part of HPA. However, the preparation of the process waste stream sections of the mineral commodity
analysis reports required extensive analysis and substantive interpretation of the publicly available
information by the Agency The process used by EPA to develop descriptions of waste stream sources,
form, characteristics, management, and recyclabilitv is described below.
Waste .Stream Sources and Form
EPA reviewed process descriptions and process flow diagrams obtained from numerous sources
including. Kirk-Othmer. HPA's Effluent Guideline Documents. bPA survey instruments, and the literature
As one would expect, the available process descriptions and process flow diagrams varied considerably in
both quality and detail, both by commodity and source of information. Therefore, EPA often needed to
interpret the information to identify specific waste streams. For example, process descriptions and process
flow charts found through the Agency's electronic literature search process often focused on the production
process of the mineral product and omitted any description or identification of waste streams (including
their point of generation). In such cases, the Agency used professional judgment to determine how and
where wastes were generated.
Bevill-Exclusion Status
EPA used the Agency's established definitions and techniques for determining which operations
and waste streams might be subject to LOR standards. HPA deci-ions concerning whether individual
wastes are within the scope of the RCRA Mining Waste Exclusion were based upon a number of different
factors. The Agency examined these factors in sequence, in such a way as to yield unambiguous and
consistent decisions from sector to sector. The step-wise methodology used for this analysis is presented
below and summarized in Exhibit B-.V
April 30. 1998

-------
Exhibit B-3
Process Summary for Exclusion Determinations
Not Subjecl
roRCRA
Yes
Not Cuvsred
by \ht M.nmg
Waste Hxclusiort
No
(e g , spent solvents
u^ed u:l. bb
No
(e g , alloying wastes.
cherm:al manufacturing
No
No
Yes
One of the ^
:0 Special Mineral
Processing
v Wasies?
Exempt from
RCRA Subtitle C
April 30, 1998

-------
B-8
Ascertain whether the material is considered a solid waste under RCRA.
	Determine whether the waste is generated by a primary mineral production step,
and, more generally, whether or not primary production occurs in the
sector/within a process type.
	Establish whether the waste and the operation that generates it are uniquely
associated with mineral production.
	Determine whether the waste is generated by a mineral extraction, beneficiation.
or processing step.
	Check to see whether the waste, if a processing waste, is one of the 20 special
wastes from mineral processing.
This analytical sequence results in one of three outcomes:
(1)	the material is not a solid waste and hence, not subject to RCRA;
(2)	the material is a solid waste but is exempt from RCRA Subtitle C because of the
Mining Waste Hxclusion; or
(3)	the material is a solid waste that is not exempt from RCRA Subtitle C and is
subject to regulation as a hazardous waste if it is listed as a hazardous waste or it
exhibits any of the characteristics of hazardous waste.3
Waste Stream Characteristics
EPA used waste stream characterization data obtained from numerous sources to ducument
whether a particular waste stream exhibited one (or more) of the characteristics of a RCRA hazardous
waste (i.e., toxicity, corrosivity, ignitability, and reactivity). In cases where actual data indicated that a
waste did exhibit one of the characteristics of a hazardous waste, the specific characteristics : was
designated with a Y. However, despite more than ten years of Agency research on mineral processing
operations. tPA was unable to find waste characterization data for many waste streams. To present
mineral commodity profiles that were as complete as possible, EPA used a step-wise methodology for
estimating waste characteristics for individual waste streams when documented waste generation rates and
analytical data were not available. Specifically, due to the paucity of waste characterization data
(particularly, TCLP data), EPA used total constituent data (if available) or professional judgment to
determine whether a particular waste exhibited one of the characteristics of a RCRA hazardous waste (i.e.,
toxicity, corrosivity, ignitability, and reactivity).
1 RCRA Subtitle C regulations define toxicity as one of the lour characteristics of a hazardous waste.
KPA uses the Toxicity Characteristic Leaching Procedure (TCLP) to assess whether a solid waste is a
hazardous waste due to toxicity. The TCLP as applied to mineral processing wastes was recently
remanded to the Agency, for further discussion, see the Applicability of TCLP Technical Background
Document in the docket for the January 1996 Supplemental Proposed Rule.
April 30, 1998

-------
B-9
To determine whether a waste might exhibit the characteristic of toxicity, FPA first compared
1/20^ of the total constituent concentration of each TC metal to its respective TC level.4 In cases where
total constituent data were not available, hRA then used professional judgment to evaluate whether the
waste stream could potentially exhibit the toxicity characteristic for any of the TC metals. For example, if
a particular waste stream resulted through the leaching of a desired metal from an incoming concentrated
feed, the Agency assumed that the precipitated leach stream contained high total constituent (and therefore,
high leachahle) concentrations of non-desirable metals, such as arsenic. Continuing through the step-wise
methodology. EPA relied on professional judgment to determine, based on its understanding of the nature
of a particular processing step that generated the waste in question, whether the waste could possibly
exhibit one (or more) of the characteristics of ignitability, corrosivity, or reactivity. Waste streams that
EPA determined could potentially exhibit one or more of the characteristics of a RCRA hazardous waste
were designated by Y?. The Agency acknowledges the inherent limitations of this conservative, slep-wi^e
methodology and notes that it is possible that EPA may have incorrectly assumed that a particular waste
does (or does not) exhibit one or more of the KCKA hazardous waste characteristics.
The Agency stresses that the results and information presented in the individual commodity
analysis reports are based on the review of publicly available information. The accuracy and
representativeness of the collected information are only as good as the source documents. As a result of
this limited data quality review, EPA notes that in some instances, Extraction Procedure (EP) leachate data
reported by various sources arc greater than 1 /20s- of the total constituent concentration. Generally one
w ould expect, based on the design of the EP testing procedure, the total constituent concentrations to be at
least 20-limes the EP concentrations. This apparent discrepancy, however, can potentially be explained if
the F.P results were obtained from total constituent analyses of liquid wastes (i.e.. EP tests conducted on
wastes that contain less than one-half of one percent solids content are actually total constituent analyses).
Waste Stream Generation Rates
As data were available, EPA used actual waste generation rates reported by facilities in various
Agency survey instruments and background documents However, due to ihe general lack of data for many
of the mineral commodity sectors and waste streams, the Agency needed to develop a step-wise method for
estimating mineral processing waste stream generation rates when actual data were unavailable.
Specifically. EPA developed an "expected value" estimate for each waste generation rate using
draft industry profiles, supporting information, process flow diagrams, and professional judgment. From
the "expected value" estimate, EPA developed upper and lower bound estimates, which reflect the degree
of uncertainty in our data and understanding of a particular sector, process, and/or waste in question. For
example. EPA obtained average or typical commodity production rates from published sources (e.g., BOM
Mineral Commodity Summaries) and determined input material quantities or concentration ratios from
published market specifications. In parallel with this activity, KPA reviewed process flow diagrams for
information on flow rates, waste-to-product ratios, or material quantities. The Agency then calculated any-
additional waste generation rates and subtracted out known material flows, leaving a defined material flow,
which was allocated among the remaining unknown waste streams using professional judgment. Finally,
EPA assigned a minimum, expected, and maximum volume estimate for each waste stream.
4 Based on the assumption of a theoretical worst-case leaching of 100 percent and the design of the
TCLP extraction test, where 100 grams of sample is diluted with two liters of extractant. the maximum
possible TCLP concentration of any TC metal would be 1 /20th of the total constituent concentration.
April 30, 1908

-------
B -10
A key element in developing waste generation rates was the fact that by definition, average facility
level generation rates ct solids and sludges are less that 45.000 metric tons/year, and generation rates of
wastewaters are less than 1,000.000 metric tons/year. Using this fact, in the absence of any supporting
information, maximum values for solids and sludges were set at the highest waste generation rate found in
the sector in question or 45,000 metric tons/year/facility, whichever was lower.
The precise methodology for determining waste generation rates varied depending on the quantity
and quality of available information. The waste streams for which EPA had no published annual
feneration rate were divided into five groups and a methodology for each group was assigned as follows.
1.	Actual generation rates for the waste in question from one or more facilities
were available. EPA extrapolated from the available data to the sector on the
basis of waste-to-product ratios to develop the expected value, and used a value of
plus or minus 20 percent of the expected value to define the upper and lower
bounds.
2.	A typical waste-to-product ratio for the waste in question was available.
EPA multiplied the waste-to-product ratio by sector production (actual or
estimated) to yield a sector wide waste generation expected value, and used one-
half and twice this value for the lower and upper bounds, respectively.
3.	No data on the waste in question were available, but generation rates for
other generally comparable wastes in the sector were. bPA used the
maximum and minimum waste generation rates as the upper and lower bounds,
respectively, and defined the expected value as the midpoint between the two ends
of the range. Adjustments were made using professional judgment if
unreasonable estimates resulted from this approach.
4 No data were available for any analogous waste streams in the sector, or
information for the sector generally was very limited. EPA drew from
information on other sectors using analogous waste types and adjusting for
differences in production rates/material throughput. The Agency used upper and
lower bound estimates of one order of magnitude above and below the expected
value derived using this approach. Results were modified using professional
judgment if the results seemed unreasonable.
5. All EPA knew (or suspected) was the name of the waste. The Agency used the
high value threshold (45.(UK) metric ums/year/facility or 1,000,000 metric
tons/year/facility) as the maximum value, 0 or 100 metric tons per year as the
minimum, and the midpoint as the expected value.
Waste Stream Management Practices
EPA reviewed process descriptions and process flow diagrams obtained from numerous sources
including, Kirk-Othmer. EPA's Effluent Guideline Documents. EPA survey instruments, and the literature
As noted earlier, the available process descriptions and process flow diagrams varied considerably in both
quality and detail, both by commodity and source of information. Therefore. FPA often needed to
interpret the information to determine how specific waste streams were managed. For example, process
descriptions and process flow charts found through the Agency's electronic literature search process often
April 30. 1998

-------
B-11
focused on the production process of the mineral product and omitted any description or identification of
how or where waste streams were managed. In such cases, the Agency used professional judgment to
determine how and where specific waste streams were mamiged. Fur example, HPA considered (1) how
similar waste streams were managed at mineral processing facilities for which the Agency had
management information. (2) the waste form and whether 11 was amenable to tank treatment, (3; generation
rates, and (4) proximity of the point of waste generation to the incoming raw materials, intermediates, and
finished products to predict the most likely waste management practice.
Waste Stream Recvdabililv anil ClasMfication
As was the case for the other types of waste stream-specific information discussed above, EPA was
unable to locale published information showing that many of the identified mineral processing waste
streams were being recycled. When information showing that a particular waste stream was being either
fully or partially recycled was found, the recyclabilitv of the waste stream was designated by Y and YS,
respectively.
However, due to the paucity of data for many of the mineral commodity sectors and waste streams,
the Agency developed n method for determining whether a particular mineral processing waste stream was
expected to be either fully or partially recycled, designated by Y? and Y'S?, respectively. This method was
designed to capture the vatious types of information that could allow one. when using professional
judgment, to determine whether a particular waste stream could be recycled or if it contained material of
value.
If bPA determined that the waste stream was or could be fully/partially recycled, it used the
definitions prov ided in 40 CFR <; 260.10 and 261.1 to categorize the waste stream as either a by-product,
sludge, or spent material.
bPA. through the process of researching and preparing mineral commodity analysis reports for the
mineral commodities listed in Exhibit B-2. identified a total of 533 waste streams that arc believed to be
generated at facilities involved in mineral production operations.
April 30, 1998

-------
B.4 Define the Universe of "Mineral Processing" Waste Streams Potentially Affected bv the Phase IV
LDRs
Step Four
	_i	
Pvp.ife Minimi Co-nnoci'.v -\nalyns
RcjJvMli ->r. E.*.h Sri tor
IVfir..- I nsA-ne .:1 Mino-il rtocei'inj Waste
.Sut.-,ms Prtentiall) Affected by
	 Tl ~hn<- IV 1 DR\		
	 t _
I	Uef:r.e L'uvcite of Mineral
.	Pt<.'iTs\inj racili'ies Poirrr.imlly
I	Atlci fed by the Phiisc IV_|.DR^_
i """
The Agency then evaluated each of the waste streams
using the process outlined in Exhibit B-4, to remove waste streams
that would not be affected by the Phase IV LDRs. Specifically.
EPA removed:
	All of the extraction and beneficiation waste
streams;
	The "Special 20" Bevill-F.xempt mineral
processing waste streams;
	Waste streams that were known to be fully
recycled in process; and
	All of the mineral processing waste streams that
did not exhibit one or more of the RCRA
characteristics of a hazardous waste (based on
either actual analytical data or professional
judgment).
As a result of tliis evaluation process, EPA narrowed the
potential universe of waste streams that could potentially be
affected by the proposed Phase [V I.DRs to the 121 hazardous
mineral processing waste streams presented below in Exhibit
B-5 '
' EPA strongly cautions that the list of waste streams presented in Exhibit B-5 should not be
construed to be the authoritative list of hazardous mineral processing waste streams. Exhibit B-5
represents EPA's best effort, and clearly does not include every potential waste stream. Furthermore, the
omission of an actual waste stream (and thus its not being classified as a hazardous mineral processing
waste does not relieve the generator from its responsibility of correctly determining whether the particular
waste is subject to Subtitle C requirements.
April 30, 1998

-------
B-13
Exhibit B-4
Schematic of the Agency's Process for Defining the Universe of Mineral Processing Waste Streams
Potentially Affected by the Phase IV LDRs
Waste Sliean; Not
Covered by the
Mining Waste Exclusion
Yes
Yes
Does Material
Meet Conditional
. Exclusion?**
Rccvclcd?
No
No
/ Does \
Material Exhibit
Hazardous
Characteristics'1*
Not A Solid
W asie
Subject to
LDRs
Not a Hazardous
Waste
* Listed hazardous waste are excluded from further analysis because they arc already subject to all relevant Subtitle C
requirements.
** To :r.eet the conditional exclusion, materials must he sirred in tanks, ro- triinc-s. of buildings *"or loss thin one year
or have a -site specific determination that sold material may be stored on a concrete or asphalt pad. (Other requirements
can be fou:.u in 261.
-------
B-14
Exhibit B-5
Potentially Hazardous Mineral Processing Waste Streams by Commodity Sector
Alumina and Aluminum
Cast house dust
bxctiolssis waste
Antimony
Autoclav: f'iltnio
Slag ?.nd fuma.c residue
Stripped /.nolyte Solids
Beryllium
Chip treatment wastewater
Filtration discard
Spent Barren F-Urate
Bismuth
Alloy residues
Spetv. caustic soda
Electrolytic slimes
Lcac and zinc chlorides
Metal chloride residues
Slag
Spent electrolyte
Spent soda solution
Waste acid solution*
Wasie acids
Cadmium
Causae washwater
Copper and lead sulfate tiller c.ikes
Copper removal filter cake
lion containing impurities
Spent !eacn so/.;tion
I .end .iiilfatc wsste
Post-leach filter cake
Speiu punlication solution
Scrubber wastewater
Spent electrolyte
Zinc precipitates
Calcium
Dust with quick lime
Chromium and Ferrochromium
LSP Dust
GCT Sludge
Coal Gas
Multiple effects evaporjtor concentrate
Copper
A::d plant frowdown
WWTP Uudje
Elemental Phosphorus
Andersen filter Media
Precipitator slurry
NOSAP slurry
Phossy Water
Furnace buildiny washduwn
Funace scrubber blowdown
Fluorspar and Hydrofluoric Acid
Off-spec fluosilicic acid
Germanium
Waste acid wash and rinse water
Chlorim-.tor wet air pollution control
sluege
Hydrolysis filtrate
Leach residues
Spent ncid/leachale
Waste sail liquor
I^ead
Acid plant sludge
Ba^house incinerator ash
Sj.imci: APC dust
Solid residues
Spent furnace brick
Stockpiled miscellaneous plant waste
Wastewater treatment plant houid effluent
Magnesium and Magnesia from Brines
Cast house cust
Srr.ut
Mercury
Dust
Furnai-j residue
Quench water
April 30, 1998

-------
B-15
Exhibit B-5 (continued)
Ml> bdenum, Ferromolybdenum, and
\mmonium Molybdate
Hue dust/gases
Liquid residues
Platinum Group Metals
Sine
Spent acids
Speni solvents
Rare Earths
Spent ammonium nitrate processing
solution
Electrolytic cell caustic wet APC
sludge
Process wastewater
Spent scrubber liquor
Solvent extraction cn:c
Wastewater from caustic wet APC
Rhenium
Spent barren scrubber liquor
Spent rhenium rr.frlnate
Scandium
Spent acids
Spent solvents from solvent extraction
Selenium
Spent filter cake
Plant process wastewater
Slag '
Tellurium slime wastes
Waste solids
Synthetic Rutile
Spent iron oxide slurry
APC dtisi/slunges
Spent acid solution
Tantalum, Coiumbium, and Ferrocolumbium
Digester sludge
Process wastewater
Spent rafiV.ate solids
Tellurium
Slag
Solid waj>te tesidues
Waste electrolyte
Wastewater
Titanium and Titanium Dioxide
Pickle liquor and wash water
Scrap mi ling scrubber water
Smur from Mg recovery
Leach liquor and spenge wash water
Speiiv surface impoundment liquids
Spent surface impoundments solids
Waste acids (Sulfate process;
WWTP slud^c/solids
Tungsten
Spent acid and rinse water
Process wastewater
Uranium
Waste nitric acid from UO, pioductiun
Vaporizer condensate
Superheater condensate
Slag
Uranium chips from ingot production
Zinc
Acid plant blowdown
Waste ferrcsihccn
Process wastewater
Discarded refractory brick
Spent cloths, bags, and filters
Spent goetlnte and leach cake residues
Spent surface impoundment liquids
Spent synthetic gypsum
TCA tower blowdown
Wastewater treatment plan, liquid diluent
WWTP solids
Zirconium and Hafnium
Spent acid leachate from zirconium
alloy production
Spent acid leachate from 7ronium
metal production
Leaching rinse water from zitcor.ium
alloy production
Leaching rinse water from zireor.-iim
metal production
Note: EPA was unable to collect sufficient information to determine whether the production of
Bromine, Gemstones. Iodine. Lithium and Lithium Carbonate, Soda Ash, Sodium Sulfate, and
Strontium produce mineral processing wastes
April 30. 1998

-------
B-16
B 5 Define the Universe of "Mineral Processing" Facilities Potentially Affected by the Phase [V
LDRs
EPA then used the information contained in the individual
sector analysis reports to identify the number of facilities, by
commodity, that potentially generated the hazardous mineral
processing wastes listed in Exhibit B-5. As discussed earlier, the
irdividual sector analysis reports listed the facilities involved in the
production of a particular mineral commodity In addition, as the
available information allowed, the Agency also < 1) identified the
specific processes used by each facility and (2) identified the
specific waste streams generated by process. However, in cases
where the Agency had insufficient information to determine which
of the individual facilities generated a particular waste stream.
EPA assumed that the waste stream was generated at all of the
reported facilities known to be using the same process.
The Agency then used the individual sector analysis
reports, various U.S. Bureau of Mines documents, the Randol
Mining Directory, and the Mine Safety and Health Administration
(MSHA) address/employment database to determine which of the
mineral processing facilities were collocated with mining and/or
extraction/bencficiation facilities.
Lastly, the Agency used the 1990 Report to Congress and
the individual commodity sector analysis reports to identify the
mineral processing facilities that also generate one (or more) of the
special 20 Bevill-Exempt mineral processing wastes.
Appendix C presents a summary of the mineral processing
facilities by mineral commodity sector that generate hazardous mineral processing wastes. Appendix C
also indicates whether the mineral processing facilities are collocated and/or generate one (or more) of
the "Special 20" waste streams.
B.6 Prepare Final Fsiimates of the Volume of Mineral Processing Waste Streams Potentially
Affected bv the Phase TV LDRs
The Agency compiled the information in the previous steps to arrive at the final data set
Exhibit B-6 presents for each potentially affected waste stream in all affected sectors, the reported and/or
estimated generation rate, the hazardous characteristics, information about recycling status, RCRA waste
type, and treatment type (physical form).
April 30, 1998
Step Five
T
t	
Defi* I'niverse of Mir.cia! Preceding Waste
Sir- .rrs Pnt-t t ;il!,	by
The Pfa.ie.IV LDRi
" ~
Define Iniv<*re of MineraJ
F.vilili^"- Po'f-itnUy
Prepare F;na!	cv ihs Viilim- . J
Mineral l'roccs>in2 Waite St/oamj
P.-tcrialb A:L\tcd_bv nc j'hjjc IV LDR>

-------
13-17
Exhibit B-6
Final Data Set


Reported
(icmrulion
(lOOUmt/vn
Fvl./Hrporlwl
CtnrrJtum (IQOOmt/vr >
Number
AraBi
Fyeility (riuutimi (int.'vr)
CtMimodity 1
Wustc Strum
Miri
*Vft.
Mai
with Process
Minimum
lCxpct*d
Maximum
Aim dim .m l AlmiiMiuin
C*r tlusi
19
|y
19
19
21
8.0
*(.'
8:0 |

F3ctifol)i.i *jmc
>
Sh
5X

'.M
2 SU)
2 MiO
2.500
Anlirtoriy
Autoclave rjliu:e
NA
0 *2
27
*4
*
 \
4.<(Xj
9.00")

Sir.ppod .irlvic* sntuU
o r>
0.19
0 19
0 19

"5

95

Sli dtui t'uiliiic.* irsnlu-
21
21
21
21
(
3.S H)
l/oo
VSOO
Bif) Ilium
Ch.p lrial;l*m wastewater
NA
o.:
100
2000
:
100
*0,1)00
1,'XX>.000

S|>eiil bjncii til:raic
5S
55
 la
NA
0 1
( 1
12
i
10(1
'.100
l.'.tXH

1 Iri irn'viif nIii-.v.n
NA
0
0 02
0 2
i
0
2i*
20)

Ixad and iiiie ihlunJci
NA
o :
<
ft
i
IOI)
<,(XX)
6)

Mciul ebiondc residues

3

3
i
V'XXI
vooo
v(X>.!

SLir
NA
it i
1
10
i
too
l.(KK)
10.U>.!

Sp-w'W eljvHolyie
NA
0 1
ft 1
12

100
MIX)
1 2.000

Sji -hi voiti m>Ii.linn
N A
0 1
6 1
12
i
100
moo
12,(KX'

Waste aeiJ solutons
NA
0 1
( 1
12
i
|(N)
100
l.'.OOO

WttSll' a.lJj
NA
0
0.1
0.2

0
100
200
CaJniium
C-Rnli. Wuiliw.itct
NA
1119
1 11
19
2
OS
950
9.500

C\ ppci jiiJ lcJO bullalr tiller riles
NA
n j
1 9
19
2
95
95tl
9.5'XI

C\ ppei n'nwviil tiller i'ike
NA
u.iy
1.9
19
2
95
950
9..VX)

Irrn containing .inpnrities
NA
0.19
1.9
19
2
95
9S0
9,5iX)

Spew lcr;:ch soh.non
NA
0.19
1.9
19
2
95
9 SO
9,5iXt

l^xd sulfate waste
NA
0 ll>
i y
19
.'
'J5
950
9 500

P.iM-lcjch filter cake
NA
0 19
1 9
19
2
95
950
9.5'X>

S.x nl ) ail'i. .Uiihi voliiimii
NA
0 19
19
19
2
9>
9.SO
9.500

Scrubber wastewater
NA
0 .9
I 9
19
->
9S
9 SO
9 5 X)

Spent cic.rlrolyte
NA
0 .9
1.9
1>
>
95
95(
i) s;xi

ZiiK piceipitaies
NA
O ,0
1 9
19
'
A
>S{
9 5<)
April 30, l9')K

-------
B-18


Kc|>urlcl
Kst.'Ktporti-d
(itiKralion <1000tnt/yr>
Numbrc
\>crnc KjciIiIv (iriii'i
turn (iiiL/yn
CtmiinmlKv
Waste Stream
(lOOOml/yr)
Min
\%R.
Ma*
ut hiKiiilics
Willi PflXL-iN
Minimum
h.|HCll'li
Minimum
(Vcium
IX.M Wi l li qui; Ll-ilk-
U(H
0 04
(KM
004
1
40
40
10
Hi. mmum and
hMTOvltlY'lJLum ,
I.SP dllit
3
3


'
3.000
1000
.'.(.00

OCT sludge
NA
oo.<
0"
1

.l(J
100
3.000
ri..iOjv
Multiple efletb cvyp.w, lor coi ccnii.iii;
NA
0
0
OS
'
II
0
(>*> .000
Copper
A' li) pldii! bluwdown
1100
5300
5.W)
5?00
10
<;i().:jOo
V>0.000
- 10,000

SfKmr t'unuie bikk
1
*
i
}
10
100

'0(1

WWII' sludge
ft
0
ft
6
10
'MX)
600
too
hlcnvnial l'lo\jiliiwu\
Aiiceiseii Filter Media
i l 46
040
0 16
0 46
-1
2 Hi
2*0
.! H

Pivi i|m,iloi slurry
160
1(0
160
160
2
KOOtM)
*0.01)0
hO.OOO

M SAlk i uify
160
lf.0
160
160

HO.IXMJ
*0 000
0.0(H)

FI:osb>- Waicr
6/0
0V0
6MJ
070
;
M0.0U0
. 10 000
140.000

I-uinao.' scrubber bKmdowii
410
410
410
410
2
210 000
210 000
">10.000

Ivitnace Boildug Wa*hk>wn
700
7i)0
/OO
/(Ml

350 000
3 SO 000

Si
100

ll)drul>\i* liln. k-
NA
0 01
0 71
0 4

(
S \
UK)

residues
0 01
001
:> o i
001

.1

t

.Spent ac:d/kML'hali'
NA
0 4

4

I'X)
ISt)
I.CHXl

Wa>ic Mill iiquuf
NA
001
C.2I
uA



100
U-a.j
A. id |>I. im ilud^e
14
:4
14
14

4.700
4.7001
4 700

IJjfchoiu.: niciiH fjinr 4%li
NA
0 4

V)

100
1.000
.ri.oo:-

Sluiiicd AK' 1>u.u
7
I
7
7

2.7CXJ
2,'MX)
2.MK;

Solid residLCb
0 1
04
0 4
0 4

130
1 U)
I3J

S|i hi liviuuc bikt
1
1
1
1

no
3>
3 .to |

Stockpikd :iiisc-,*llJiieoi.i plum A.isit*
NA
0*
67
1 (0

100
?".*(
4UXH |

VV Wl 1' lu|iihi c-r1l*ic-m
-WW
2600
*.00
260.)

S/O.OO*
s;o.ou
K70.(XhJ I
Magm-snini ami M.t^in-sKi
irum Brutes
( hou*-.* durvi
NA
0.070
0 7o
7 6

"V*
76(
7.600

Sn.u:
26
20
26
:o

13 ,000

1-I.III.KC ICi.dlK.'
<1077
oo/;
0.077
0 07"*

1 1
II
11
AjJiil M), 1998

-------
B-IS)
CuilHlliKiilY
W.iMr SiiI'uin
Hcportcd
(.envration
(IWMImL'yrl
hsUKi-poflcd
(ai'iirrjtiun ()r)
Min
Avr.
M jx
Minimum
Expected
Mjviinum
Molybikm.m,
Irnvmnlyhdrmm-.. .iini
Ammonium Molybdatc
Hue'
NA
1 1
250
?00
11
100
21,000
45.U00
'
Liquid residues
1
I
1
1
2
0
MX)
I'laiiimiii (iioup Metals
Slag
NA
0 0046
0 046
O >6
.1
2
I-
1 >0

Spent acids
NA
0 *
1.7
1

IO'i
570
1 (K.O

Spent solvents
NA
0.1
1 7
y

101
570
I oo
Rare r.uilw
S|ktill aiiuiKiuuin lUKaic pfkM.cv>iiig sol.jtiix
14
14
14
14

14.UM
I4.(KN)
14.(K.O

tell .auilic wot AI*C sludge
NA
oov
(U
7

7;i
7tm
7 (K.O

l':.*css ^asicwatiT
;
)
7
7

UO0
7,(XXI
7 (K.O

Spent scrubber l.quor
NA
. 0 1
500
10)0

100
500.000
mkkhko |J

Snlvi'M *xiracm>n crud
NA
0 1
2 .1
4 5

100
T KKi
4 5.'i0 fl

WiNlpwjiri wet APO
NA
0 1
StK>
10)0

MX)
MXi.OtXI
l (XHHXO U
Uknuim
S|nl bancn scrubber liquor
NA

0 1
0 2
2
0
50
100 |

Sf-rm fh.-n.um ratlin,lie
XX
Xh
X8
5K
2
44 .(AX)
4-. .000
44.0CO
Scandium
S(>ei)i jjids
NA
0 7
1 <\
7
7
100
5W1
1 0(>0

S)k'h( v:l\rni% from si Ivor* cxlmchon
NA
(:.7
1 9
7
/
l60
1.000
SeV.iiuin
Spent lihjc viik.*
NA
0I
05
5

17
l">0
1.700

Pliini process wastewater
66
66
66
66
2
n o;
1.1 000
.11.(XX)

Sljjt
NA
OOS
0 5
S
1
17
1 7{i
1 7(H)

Tellurium .slime wastes
N \
0 05
05
s
1
17
170
1,70i)

Wiiilc ioJids
NA
0 05
OS
5
<
17
1 /(I
H
Syr.llwMic Ruiilc
.Spent iron oxide sluuy
4}
45
45
45
1
45.000
45.000
45.00.)

AI'C duil/sludges
10
M)
.10
30
1
10 OfO
10.000
SO 000

Spent .Kid solution
JO
V.)
H)
30
1
10 000
O.IXX)
.0.00i>
Taitalum Colunihiurri.
anJ Femxoluinb.uni
Digester luilgc
1
1
J
I

5(X)
500
500

Process wastewater
150
l0
150
150
2
75.WNJ
/ . 1NMl
7\lOO

Spent r.iftin.itr *olids
!
-
i
2
-
1.000
I,(XX)
1,000
Tclljrium
Slug
NA
02
2
')

KM
1 .(KM)
4,5tMl

Solid wxslc rCMdues
NA
02
2

?
UK
1.00<
4.5lX

Waste eleeliulyic
NA
O?
7
'Ml

l(M>
1 .(XK)
lO.t.HKl

Wastewater
NA
02
20
40
-
ICK
JO.(XX)
?0.(W
April 30, 1998

-------
B-20


Reported
E>t./K-ported
(it nt-ratum (HKMImt/vr}
Number
<\rtagi- K.H ilily li water
NA
2.2
2.7
1 7

710
VCXJ
l.KX)

Strap ntlkit): -.eruhlvr .valor
NA
1
5
b
1
I.OiX)
5.> recovery
NA
0 1
2?
45
*>
50
1 .000
2V000

[.each litJbtM and ipun^L wash warei
NA
W'
4h0
5^0
>
1 <>0 0UJ
2 Ml.OOO
2ipiiii*innit lu[i*d\
NA
Oh'
i 4
t 1

'/0
4VO
'Kh)

Spent suxIjcc inipuurvjrucms si Ud>


.<<
*t>

5.KM)
5.HX)
5 IOJ

Wustc ac:ds {Su.lulc p.'v>cc:>s>
NA
u .

)!

IlKi
.0.000
>*> IXXJ

WWTP slud^c/solKJv
120
420
4?0
420

60.000
r.n.noo
WI.(XX)
Tuiigslen
S|xiil Ji nl and rinse waier
NA
0
0
21

0
0
\ MM

I'iik css w.iMrwalitr
NA
2.J
44
;
5
Mi)
/.i 0
I.50U
Uranium
WaSic tunc acid irom L 02 (MvdiKin n
NA
1.7
2 5
.14
17
100
154)
20)

Va;x>me: condensate
NA
1.7
9 )
17
17
100
550
l.iXX)

Su,*iIicjici coudeitijie
NA
17
') 1
17
17
100
550
l.lXXj

st?
NA
0
a 5
17
17
0
500
I

l.li inium ti'niri infill pnxl.u lion
NA
1 7
2 5
I 4
'
100
1 50
j(>;
/jlk.
Avid pk.nl blmvdown
I Ml
1%
no
130
1
IvO.jOO
l.0,0(X)
no oo;

VVaik* IcfTiiMlicoti
17
17
17
1?
1
I7.uOO
1 7.000
I7.IXXJ

Piocess <*asiewjiiT
SOtXI
5
1
5,"(XI
*. v()
2M
.'">0

Wjstew;:ier treatment plant liquid cttluciu
^600
2600
260U
'2CO0

87U.OOO
K70.IKX
X70.OJ0
Zileoniiim and hLlnmni
S;ient arid lrj> b.ie from Zt alloy pr*l
NA
0
1)
a 50
2
0
I
4UU*X>

Srxrm acid leuchjic from Zj ncul pio.1
NA
0
0
l COO
o
n
1
K(Xi.(NX)

1 .'a.'lnnj; iinsr wjii i Iuwd7j .ill>> |>rHl
NA
*4
4?
51
2
17,(mX)
21 
loot:


MX
-oo.ow
1.000.0" K
April 30, 1008

-------
B-21
(.'oft modi!)

TC Metal*
Corr
Igml
Kctv
Hiir..'

Wyslc l>|W
I riaimciil Tviw
Current
IUc)u%c (just


V






N>

1
Y?


'
0
0
I

L.c-arvilyiii waslc




V



N !
N'
N '
().*
Y '



i)
(}
I
Antimony
Ai.t:lavc filirrfie
Y?

Y*.

Y '
V


V-'
N'
N''
1) %
YS'

1

I
0
0

Snipped aiwlyie
solkis
Y?







N?
N1
N'
U.5
Y
I


<;
0
I

Slaj mid iumiihc
kJue




Y }



N':
N"1
V
II 5
N




0
!
Ueiylbum
Oiif) iie^intnt
Wf.sicw.ucr



Y"




N-
N"'
N'>
0.5
YS?

1

i
0
0

Spent barren filtrate






Y

n:
N"?
N '
1
YS

1

i
II
I)

I ihrjlidti d.M ard




Y '



N"
fV'
N''
(I S
N




0
I
Disnxih
Alloy rcsidiKS




V-I



rJ-
K1'1
W-!
64
N




0
I

.S|X.nt CUU.MIC SOild




Y



N"
N'.'
N'
0 5
Y'

1


I
0

hkvirol>Ui. sliiih^




Y\;



N'.'
N"'
N''
05
Y7
1



{>
I

l.c*jd und zinc
Jiliindrs




YV



N'
N'.'
N''
0.!>
N




0
I

MrtaUhk-iuIr
residues




V



N-
N'
N>
0 5
N




0
I

Slau




Y\>



N
N7
NT
05
N




0
I

Spc: elcjlrolyli.




Y'



N'
N?
N
OS
N




I
0

SpcM soila ioluli.tu




Y\'



Y
N?
N'
0 5
Y>

1

\
0
0

Wxsic at id
s| ilium








Y1
N?
N>
0 5
N



i
I)
0

WjMc.u.ds








Y"'
N'
V
0 S
YS"



I
0
0
r.nlrr.iuni
("aijslir w ishw aHr


V-i





V-i

SI'1
M
Y''

1

I
0


Co.'.jict di d lead
Mlll.llO tlfc.T J-)k<'S


Y'J

Y-i



N'
N'
N'>
OS
Y*
1


0
I)
- I

Cop|)er rciU'val
liliet take


Y?





N1*
N'
K>
0 5
Y"
1


0
0
I

lion amiatiung
llllplll l(H->


Y.'





N '
N'
N>
05
N



0
0
I

Sjirnl lr.n h solution
y.

Y'

Y-.



Y->
N'
N->
0 >
Y-.



0
I
0

U-*ls..ll;.icwj%:r


Y-'

Y*



N7
N'
N'.'
0 5
Y"
1


{I
0
I

IVki-Ii\i.Ii filte r
cake


Y>





M
N'
N?
0 5
N



0
0
'

Spciil (Hi!:fKalioit
j:hiiu>n


Y-





Y*
N*>
N
0 5
N



I
0
0

Scrubber
w isitwuic


Y:





V
N''
N'.'
0 >
Y"


1

0
0

.S|.ii[ eleUinlyle


Y-





V
N '
N''
0 5
N



0
I
0

Vhi. nr.-i nni iu s


Y'





M
_L_
	Cll
_ili_

. .1


0
0
I
April 30, 1998

-------
B-22

N
N'>
0.5
Y


1
0
	T"
1
Chromium .md
|-erroi hr.)iiunm
I.Sl" it.iM



V


i

N>
N?
N''
1
Vs


1
0
0
1

CU 'I '



YV




N?
N'
N''
I) 5
Y


1
0
0
I
Coal C>^$
Mult| If effects
evaporator
.I'liLvalmic
V





V

N *
N>
N-1
1
YS
1


0
1
ti
Cl-ppci
Acid plant
')iowd.!Wii
M. y

V
V


V
Y
Y
N>
N"1
1
Y.^


i
0
I
0

Sjw-ni luniacc brick.



Y?




N 
N.
N''
0 5
Y'

1

0
0
1

WWTP sIikIbc


Y?

Y >



N 7
N?
N''
0.5
YJ>


1
0
0
1
l.lcmvt'l
Phosphorus
^rulri sfli 1-ilU r
Mcil.a


Y





N?
N.
N*
I
N



h
.
1

Prtiipnator slurry


yi





N'
Y
Y
1
YS


I
0
i
0

NOSAP slunr>








N'
N'
Y
I
N



0
i
o n

Phossv Water


Y7





N'
Y
Y
1
YS

I

0
i
0

ruinate scrubber
blowdown


Y





Y
N*
N-'
1
Y


1
1
{l
0 U

i iirn.n c l)inld.i|
Wa-.li.low n


Y





N>
N?
N'
1
Y

1

1
0
0 1
i lin 11 \| hi .mil
Hydrofluoric At.u1
OilHuo>.liu.
.n nl








Y '
N'
N"'
0 5
YS
!


1
n
0 1
Gomuniuni
Wa^lc acid w;i.li
.ind ru sc wji.t
Y 

V
Y '
Y '

V';
V'1
V
TTT
N"1
M
YS'

1

1
o
0 1

Chlorriutor v,cl air
|H'llnti ii ;oniio]
sludge
V '

Y '
Y"*
Y"

Y :
Y?
N>
N?
N"1
0 5
YS1


1
u
u
1

Hydro.ysis lilti.ilf
1 '

Y'
y>
Y?

Y7
V>
N>
N>
N1
0 5
N



0
ii
1

I-cmcI. residue*.


Y7

Y '



N>
N'>
N''
05
N



0
0


Sport .iLi
NP
W
0 5
YS1

1

1
i'
O

Wj-.tc still litjiior
Y 

Y'
Y'
Y"'

Y-'
V
N'
V
W
0 5
N



0
y
1
UaJ
\iuJ ;>fcmt >;li dro








V*
N>
N1
05
W


i
0
0
1

iJjfilio.ise
iiKiir.uioi ,i%|


Y

Y



N'
N>
N''
1
N



0
0
1

Slum -
N'
N''
1
Y



0
0
1

Solid irsulti: %




Y '



N
N?
N1
0.5
Y?
1


0
0
1

Spent tiimacc brick




Y



N>
K>
N''
1
Y

1

0
[}
1

Stockpiled
miscellaneous plant
w;istC


Y

Y



N>
M
N?
1
YS'

1

0
11
1

'AAV I I' lu|uiil
i-l'liiriii




Y''



Y'
N'
N''
0 5
Y

1

1
'
0 |
M.iVM-.:biuiii .iikJ
Mi,ciics.a iioin
Urine*
C.im house iluu

V






N'
k"
N7
0 5
Y>


i
0
0
1

Snuit

	L.






N'
M
N'*
1
N



0
c
1
April 30, 1998

-------
\i-2i











KCKA Waste Tvpc
Treatment Tvpf



TC Metals





Carrtnt

Spent

Watte
M(lc'r.

Cufnmodit)
Waste Stream
As
It..
Cd
Cr
Pl>
Mfi
St
AR
l.'urr
Ignit
Kctv
Ha/?
Recvrle
Prod.
Mall
Sladge
Water
Solids
Solid
Men in y
l>ml





Y?


N>
W*
N->
0<
N



ft
ft
H

Qiu *a'e:




Y *
V '


N'
N*
N''
0 5
Y 

1

1
0
n

1'imvH < rcvi.Juc





V '


N>
K'
N?
0.5
N



0
n
u
Molyl'JciKJiiL
1 rnti4i!ytvlrruni.
and A:nj;x>niuri
Violybdtto
Hui- 

y>

N>
K'
N"7
0.5
N



1
0
0 II
Platinum (irocp
Mclals
Slag




V*

Y''

N'
K
M?
0.5
V>
I


0
0
1 1

Spent .icmIs




v >


Y
Y'
N1
N?
05
N



1
{)
o n

S(e:* iolve ils




Y"'


Y>
N>
Y*
N?
0.5
N



1
0
0 I
Rate Lanlis
Spc* immoiunm
nurale prixessing
iolmion








Y
N'*
W
I
N



1
0
0 U

l-'ltMiolvlit tell
cau5lr wet API'
sludge








Y*
N"

0 5
Y


1
0
(1
'

Pn*.cv> w.i>tew.iier




Y



Y
N''
N>
I
YS?

1

1
0
0 1

Spent i. riib'H i
liqu<*








Y'
N-*
N >
0 5
YS'


1
1
0
0 [

Solve# r*li; cimn
Crud








N**
Y"
V
0 5
N



0
0
'

Waii^*atct liom
i .invli wet A PC



Y>
Y .



Y'
N
S7
05
YS?


1
1
0
0 |

Sjh'ni li.tiren
jcruhber Itqjor






V.'

k1'1

N
0 5
V?


1
1
0
0 1

.Spent rlicnimt
raltiraie




y.>



N'
N'
N >
0 5
N



0
0
1
Sjjin
Y
N '
0.5
Y'>

1

1
0
0 I
Selenium
Spcn: filler cike








N"
N'
N'>

V*
I


0
0


PI.ii* ;m>t
w.isie^aiei




V



y
N':
N?
I
YS^

1

1
0
0

Slac






Y?

N'
N?
N7
05
YS'
I


0
0
1

Icllu' nut finite






V >

N
N'
N?
05
Y?
I


0
0


Waste solid*.








N7
N';
N">
0 <
N



(1
0
1
Synthetic Kuiilt
Spi n' iron o*de
slurry


Y*
yv




N;
N\;
N>
ft?
V!!*
i


0
6
1

AI'C d.isi/vliMJcts


Y '
Y '




N ;
N'J
N>
0.5
Y


l
0
u
1

Sih-ii' a. ul s, Union


Uy
Y '




Y>
N?


Y

I

1 
0
(1
April :>, IW8

-------
B-24











KCNA Waste Type
Treatment Tvi*- ||



T<
MiUls





Current
Bj
Spent

Waste
M0%
II
Cummodit.v
Wask Slrtam
A 5
Itj
CH
Cr
PI.
He
Sr
AK
Co*r
(Bali
Rctv
flaz?
Recycle
Prod.
Klal I
Sladgc
Water
Solids
Solid H
1 ,inulii:n.
Columhhim. an !
IVrnxiiliniihuii i
IllKfVtfl slujR;*








YV
. SP
M
0.4
N



0
<">
'

Pn*. <'v> u. jsk-ViU'1
r>

Y '
Y?
Y '

Y>

Y
NV
N''
I
V

1

0
1
0

Spoil' i.ilfnui *
solics








Y>
N?
N"'
0 5
N



0
0
1
'tVllui iur:i
SIUR








N>
Sl-l
N1
0 5




0
0
]

Si'1 id jwuitc
fl'slllll.'S






Y'

N.'
N,;
M
0 s
N



0
0
1

Wa.N'e electrolyte




Y'.'

Y 

N'
M'i
N*
0 5
N'



1
0
0

Wamewnter






Y'

Y>
N>
N'
0 5
Y

1

1
0
0
Tiiaiuuiu ,mJ
1 'laivmi: Dioxide
Pickle liquor ^nd


Y
Y-,
Y.



V'
N'<
N *

Y*



1
0
0

Scrap nulling
scrubber water


Y7
Yv
Y"

Y>

N'
NV
N">
05
YS?


1
1
0
0

Smut "'roni Mg
recovery








N?
N'.'
Y
 I
Y?



il
0
1

l-cueh :K|uor iithl
V|MHI)t(.' MJtll WJIt!



y>
Y'



Y
NV
K>
I
YS''

1

I
0
0

S|n.'ni mii facv
iinpi'Uiulnvii:



Y '
Y.'



N'
N':
N>
0 5
Y?

1

1
0
c

Spent .surlucc
irupoiKidnien'S
SOllds



V
Y'-



N1
N';
K
05
N



0
0
1

Wasic iieids
(Sultj r pruvss)
V


Y


Y
Y
Y
N
N
I
N



1
0
0

WW1T
-linlp:7<;oli(1s



Y-




N
N
N
0 5
N



0
u
'
Fungsrei:
Spent acid ard rinse
WillCI








YV
N":
N.'
(V.<
w

1





I'ri'asJ wnsi.'wakr








V
N*>
N*
0 5
YS?

1

1
0
() 1
Uiiiiuuii
Wjiic unit acid
fmmlin?
pnnfciciion








Y'i
N?
N>
0 5
YS?

1

1
0
"

,/xt
. imlr-ts.ilr








Y"
N':
N'
05
N



1
(1
0

SuperlkMler
cihle:isaiL'








Y '
N':
N '
0 5
N



1
0


si,,;








N?
YV
N'
0 5
Y
I



0
1

I'rjiuum chips liom
IIIS'C' IMOllll. Ill HI








N.'
Y';

0 5
Y '
I


0
0
11
April 30, 1998

-------
H9CR*rr'
B-25
Commodity
Wastr Stream
TC Mitals
Corr
Ignii
Rctv
H ai?

KCKA Waste Tvt*
Treatment l\pr
< urrrnl
Recycle
M 
Prod.
Sprnt
Mat 1
Sludge
Wasit
Waltr
.Solids
Sulk)
\s
Ba
Cil
Cr
IM>

St

ZltH
A.ill pl.inl
bl;>w low ri


Y
"V
Y"'
V*
 V
Y
Y
N
>1
1
Y


1
1
O
I)

Wiisic




Y>



N>
N >
N-'
0 5
Y?



U
A
1

I'fiHVS? WdSlCWdlCI
Y

Y
Y
Y

Y
Y
Y
N?
N"1
1
Y?

I

1
0
0

l)Kc;.rtk*d
iHi.h mty t** k
V

V
Y'
Y?



N'
N?
N"
0 5
N



u
O
1

S|>cni cluihv b.itfs
iiiKihers


Y.

V
Y '
Y'1
Y
N'
K7
N
0.5
Y

1

0
A
1

Spent gix'ihitf iiml
Icnch cfikc residues
Y

Y
Y
Y
Y>
Y
Y
N'
N?
N'.'
1
y

1

0
0
1

Spcin suifacc
 Mi|ioiHii1iirn'
liquid?


Y '





Y
N '
N?
1
Ys>

J

1
0
A

wwtp .Soiuj
Y .

\ '

Y'
Y-
y-;
Y?
N-'
N'

u5
YS


1
0
0
1 u

Spert synthetic
cypsLin
Y

Y

y



N'
N '
N>
1
N



0
0
'

14 A l.mer
:-lowd :n


Y '

Y*
Y7
Y '

Y'
N*
Vj>
05
YS

1

1
0
0 1

WiiMf^aier
'iLMinwnl plinii
!h|iiiiI -HTiifii


Y '





N'>
N''
N>
0 5
YS-*

1

1
0
U 1
'/iKomi.tn and
) Minium
Spent n id lenrli.iic
:iom 7s allov prod








y.
N"
M7
0 5
N



1
0
0

Spent xkI IcikImu-
ironi y.t mcial |rcil.








Y''
N"
N?
05
N



1
0
0

1 x-nrl'in^', rinc
wiiici 'turn /j alloy
prod








Y '
NV
N
05
YS?

1

1
0
0

IxMil.iiu: tim.*
watc irotn 7s mri;r
nmil








V
N7
N?
0 5
YS?

1

1
0
0
April 30, 1998

-------

-------
SUMMARY OF MINERAL PROCESSING FACILITIES
PRODUCING HAZARDOUS WASTE STREAMS
APPENDIX C
Mineral
Commodities
Facility Names
FadHfy Locations
Mining and MP
Facility Collocated
Comments
Generates one of the
Special 2* Wastes
Alumina &
Aluminum
Alcnn Aluminum Corp.
Henderson. KY
no
Processing
Nu

ALCOA
Warrick. IN
no
Processing
No

ALCOA
Masscna. NY
no
Processing
No

ALCOA
Bailin, NC
no
Processing
No

ALCOA
Alcoa, TN
no
Processing
No

ALCOA
RiKrkihile. TX
no
Processing
No

ALCOA
Wenatchee. WA
no
Processing
No

ALUMAX
Mi. Holly. SC
no
Processing
No

Columbia Aluminum
Ci'tp.
Goldendale, WA
no
Processing
No

Columbia Falls
Aluminum Corp.
Columbia Falls, MT
no
Processing
No

Lashco
Frederick, MD
no
Processing
No

Inlalco Aluminum Corp.
Icrndale, WA
no
Processing
No

Kaiser Aluminum Corp
Spokane, WA
no
Processing
No

K.uscr Aluminum Corp.
Tacoma. WA
no
Processing
No

N.Uional South Wne
HaWL'sville. KY 
no
Processing
No

Nornndn Aluminum
New Madrid, MO
no
Processing
No

Northwest Alloys Inc.
The Dalles. OR
no
Processing
No

Ornicl
Hannibal, OH
no
Processing
No
April 30, 1998

-------

C-2
Mineral
Commodities
Facility Names
Facility Locations
Mining and MP
Facility Collocated
Comments
Generates one of the
Special 20 Wastes
Aluminum
(continued)
Ravenssvood Aluminum
Corp.
Rovenswood. WV
no
Processing
No
Reynolds
Masscna. NY
no
Processing
No
Reynolds
I routdiilc, OR
no
Processing
No
Reynolds
l.ongviow. WA
no
Processing
No
Vcnalco
Vancouver, WA
no
Processing
No
Anlimony
Amspec C.'hcmiciil Corp
Cilouehestei. NJ
no
Processing
No
An/on. Inc.
Laredo, IX
no
Processing
No
ASARCO Inc.
Oinah,). NF,
no
Processing
No
Laurel Ind.
LaPoite.TX
no
Processing
No
Sunshine Mining
Company
Kellogg, ID
yes
Processing
no
US Anlimony Corp
Thompson Tails, MT
no
Piocessing
no
Beryllium
Brush Wcllman
Delia. U 1
yes
mining, produces Be(OM)-
no U
Brush Wcllman
Fllmore, Oil
no
Secondaiy oie piocessing of Be
Metal and Alloys
no |
NC.K Metals
Revere, PA
no
Secondary ore processing of Be
Melal
no |
Bismuth
ASARCO
Omana, NH
no
Processing
yes
Cadmium
ASARCO
Denver, CO
no
Processing
no
Big Rivci Zinc Cwp.
Sntigci. IL
no
Processing
no
Ic'scy Miniere Zinc.
Corp
Clarkivillc. TN
yes
(Gordonsville)
Processing
no
ZCA
Bartlesville, OK
no
Processing
no
Calcium Metal
Pli/er Clicm (Qu^lcy
Company)
Canaan, CI'
no
Processing
no
Chromium
MacaMoy Corp
CharL'slon, SC
no
Processing
no
April 30, 19%

-------
C-3
Mineral
Commodities
Facility Names
Facility Locations
Mining and MP
Fudlity Collocated
Comments
Generates one of the
Special 20 Wastes
Coal gas
(iic.il Plains Ci'.il
Gasification Plant.
Dakota Gasification Co.
Heulah. ND
yes
Synthetic Gas produced
Yes.
Gasiler Ash. Process
Wastewater
Copper
ASARCO
Rl Paso, TX
no
Smelting
Yes. Slag, slag tailings andAu
Liilcium .sulfate sludge

ASARCO
Amaiillu. TX
no
Electrolytic Refining
Yes. Slag, slag tailings and/or
calcium sulfate sludge

ASARCO
Hayden. AZ
yes
Mining. Smelling and
Flc.rtrowinning
Yes. Slag, slag tailings and/or II
calcium sulfate sludge II

Copper Range
While Pine, MI
yes
Mining, Smelting & Refining
Yes, Slag, sing tailings and/ur 11
calcium sullate sludge D

Cyprus
Claypool, A7.
yes
Mining, Smelting, Refining, &
Hlectrowinning
Yes. Slag, slag tailings and/or
calcium sulfate sludge

Kcniiecott
Cat Held, UT
yes
Mining, Smelting and Refining
Yes. Slag, slag tailings and/or
calcium sulfate sludge

Magm.i (BUI*)
Sao Manuel. AZ
yes
Mining, Smelling, Refining, and
Electrowinning
Yes. Slag, slag tailings and/oi 1
calcium sulfate .sludge I

Phelps Dodge
Pla>us. NM
no
Smelting only
Yes. Slag, slag tailings and/or |
calcium sulfate sludge |

Phelps Dodee
Rl Paso, TX
no
Refining only
Yes. Slag, slag tailings and/oi
calcium sulfate sludge 1

Phelps Dod^e
Hurley. NM
yes
Mining, Smelting and
F.lectrowinning (same as Chino
Mines)
Yes. Slag, slag tailings and/or 1
calcium sulfate sludge J
Elemental
Phosporous
FMC
Pocatello, ID
yes
Processing
Yes. Sing

Munsanio
Soda Springs, ID
yes
Processing
Yes. Slag 1
Ormanium
Aiomergic C. hem
Plainvicw, NY
no
Processing
no I

Cjbot
Revere, PA
no
Processing
no

Fagle-Pichei
Quapaw. OK
no
Piocessing
no
April 30, 1998

-------
C-4
Mineral
Commodities
Facility Names
Facility Locations
Mining and MP
Facility Collocated
Comments
Geuerates one of the
Special 20 Wastes
Germanium
(continued)
Muslo LxpUmiion
(inactive)
St Georgt*. 1 T
yes
Mining and Refining
no
Fluoru^par and
Hydrofluoric Acid
Allied Signal
Gcismur, LA
no
Processing
Yes. Fluorogypsum and
process wastewater
F. 1 diiPonl
Lh Port. I X
no
Processing
Yes. Fluorogypsum and
process wastewater
Altochcmical, N A.
Calvert Ciiy. KY
no
Processing
Yeb. Huocogypsum and
process wastewater
Lead
ASAKCO
East Helena, MT
yes
Smeller
Yes. Slag
ASAKCO
Glover. MO
yes
Siuellei/Reliueiy
Yes. Slag
Doe Run Co.
Hcrculancum, MU
yes
Smelter/Refinery
Yes Slag
Mauni'sium
Dow Chemical Co.
Frroport, TX
yes
MgCI from seuwjter, Mg metal
processing, magnesia processing
no
MagneMum Corp. ol
AmeritJ
Salt Lake City, I T
yes
Mg metal processing from lake
hrines
Yes Process waslewyici
Nonhwest Alloys Inc.
Addy, WA
no
Mg metal processing
no
Mercury
Barrick Mccur Gold
Mines, Inc.
Toole. UT
yes
Mining and Retorting
no
FMC Gold Co.
Humboldt, N V
yes
Mining
no
FMC Gold Co.
Gubhs. NV
yes
Mining
no
Homeslake Mining Co.
Napa. CA
yes
Mining, leaching
no
Independence Mining
Co. Inc.
riko. NV
>cs
Mining
no
Ncwmoni Gold Co.
F-ureka. NV
yes
Mining
no
Placer I\>inc U.S.
E.isi Blv. NV
>vs
Mining
no
April 30, 1998

-------
C-5
Mineral
Commodities
Facility Names
Facility Locations
Mining and MP
Facility Collocated
Comments
Generates one of the
Special 20 Wastes
Molybdenum, Ferro
molybdenum and
Ammonium
Molybdale
Cyprus Climax-
Henderson
Liiipire, CO
ves
Mining and Processing
no
Cypi us-Climax
Port Madison. IA
no
Processing
no
Cyprus-Climax
Cold Watci, Ml
no
Processing, possibly phased out
no

Cvptu.s-Cliinax- Green
Valley
Tucson, A/
no
Processing
no

Kcnncrott
Bingham Canyon.
LIT
yes
Processing
copper slag, slag tailings,
W'WTP sludge

Montana Resources Inc
Uutle, MT
yes
Processing
no

Phelps Dodge
Hurley, NM
yes
Processing
no

San Manuel
San Manuel. AZ
yes
Processing
no

San Manuel
Morenci, A/
yes
Processing
no

Thompson Creek
Challis. ID
yes
Processing
no

Thompson Creek
1-angcliMh, PA
no
Processing
no
Platinum (.roup
Metals
ASARCOInc.
Amaiillo. TX
no
Processing


Kennecolt Corp
Salt Lake City, UT
yes
Processing


Stillwater Mine
Nye, MT
yes
Mining and Smelting
no
Pyrobitumeiis,
Mineral Waxes, and
Natural Asphalts
Amciicun Gilsoniie
Bonaza, UT
\ jntah County
yes
Production of gilsonite (natural
asphalt)
no

Ziegler Chemical and
Mineral Corp
Vernal. UT
Uintah County,
yes
Production of gilsonite (natural
asphalt)
no
Rare Earths
Molycorp
Mountain Pass, CA
yes
Mining of Baslnasite
no
Rhenium
Cyprus-Climax
Green Valley. A/,
yes
Recovers and refines rhenium
no

Cyprus-Climax
Foil Madison, lA
no
Rhenium recovery
no
April 30, 1998

-------
C-6
Mineral
Commodities
Facility Names
Facility Locations
Miniug and MP
Facility CoUouited
Cunimeota
Generates one of the
Special 20 Wastes
Scandium
Baldwin Mclals
Processing Co.
Phoenix. \/
no
Processing
no

Boulder Scientific Co.
Mead. CO
no
Refining
no

Intcrpro i. subsidiary ot
Concord Trading Corp.)
Golden, CO
. no
Refining
no

Mateuals Prepaiation
Ccnicr
Ames, IA
no
Processing
no

Rhone-Poulcnc, Inc.
Mioeni/., AZ
no
Processing
no

API - Kngineered
M iitci iaJs
I rbana, IL
110
Refining
no

Sausville Chemical Co
(liirlield, NJ
no
Refining
no
Selenium
ASARCO
Amarillo, 1X
no
Piocessing
no

K.enneco'.t
Garfield, l.'T
yes
Processing
yes

Phelps Dodge
El Paso, TX
no
Processing
no
Synthetic Rutile
Kerr-McGee Chemical
Coi|>.
Mobile. AL
no
Processing
no
Tantalum,
Columbium and
Cabot Corp
Hoyertown, PA
no
Cb and Ta peiitoxide/iiietal. FeCb.
Ta capacitor powder
no
Ferrocolumbium
Shicldalloy
Metallurgical Corp.
Newlield, NJ
no
FeCb
no
Tellurium
ASARCO
Amarillo, I X
no
Processing
no

Kennecott Corp.
Ciailield, l.'T
yes
Mining, Smelting and Refining
Yes. Slag, slag tailings and/or j
calcium sulfate sludge |
April 30. 1998

-------
Mineral
Commodities
Facility Names
Facility Locations
Mining am) MP
Facility Collocated
Comments
Generates one of the
Special 20 Wastes
Titanium and
Titanium Dioxide
E.I. duPont oe Nemours
&. C8

-------
C-8
Mineral
Commodities
Futility Nantes
Facility Locutions
Mining nod MP
Facility Collocated
Comments
Generates one of the
Special 20 Wastes
Zinc
Dig River Zinc Corp
Saugcl, 11.
no
Smelter (electrolytic)
no
Savage Zinc
C.'larksville. I N
yes
Smeller (electrolytic)
no 1
Zinc- Corp of America
Monaco, PA
no
Smelter (pyromctallurgical \
Yes. Slay
Zirconium and
Hafnium
Tcledyne
Albany, OK
no
Processing
no
Western Zirconium
Option. 1 IT
no
Processing
no
April 30, 1998

-------
MINERAL PROCESSING WASTE STREAMS
STATUS CHANGES SINCE DECEMBER 1995
APPENDIX D
Sector
Waste Stream
Waste Tvpe
Action
Date
Reason
Antimony
Autoclave fillrale
Liquid
Number ol" facilities changed
from seven 10 six
April 1997
McGean Chemical
removed, inactive
Antimony
Slug and furnace residue
Solid
Number of facilities changed
from seven U) six
April 1997
McGean Chemical
removed, inactive
Beryllium
Berirandite thickener slurry
Liquid
Dropped Out of Analysis
April 199/
Public comment indicate
previous agency decision
on beneficiaiion
processing line
Beryllium
Beryl thickener slurry
Liquid
Dropped Out of Analysis
April IW
Public comment indicate
previous agency decision
on beiieliciaiion
processing line
Beryllium
Spent barren filtrate streams
Liquid
Dropped Oul of Analysis
April 1997
Public comment indicate
previous agency decision
on beneficiaiion
pnxvssing line
Beryllium
Spent barren fillrale streams
Liquid
Added to Analysis
April 199H
Further review indicated
that ihis waste stream was
a processing waste
Beryllium
Spent raffinale
LiquiJ
Dropped Oul of Analysis
April 1997
Public comment indicate
previous agency decision
on benelicialion
processing line
Boron
Waste liquor
Liquid
Dropped Oul of Analysis
April 1997
Determined to he not-
ha/.aidous
Cadmium
Scrubber waslewaier
Liquid
Former RCRA waste lype
changed from speni material to
sludge
April 1997
Incorrectly characterized
in original analysis
April 30, IW8

-------
0-2
Sector
Waste Stream
Waste Type
Action
Date
Reason
Ch roin i u m/Fe rr< )c h romi u m
HSP dusl
Solid
Added 10 Analysis
Aprd I99X
Waste was delisted, now
subject to LDRs
Chromium/Fern Hrhminium
C.CT sludge
Solid
Added u> Analysis
Apnl 199X
Waste was delisted, now
subject to LDRs
Copper
Acid plant blowdown
Liquid
Increased number of facilities
from nine to ten
April 1997
('hanged to re tlect
potential double counting
tt sciuhber blowdown
Copper
Acid plant blowdown
liquid
Former RCRA waste type
changed from by-pruduel to
sludge
April 1997
Incorrectly characterized
in original analysis
Copper
APC dust/sludge
Solid
Dropped Oui of Analysis
April 1997
Not land stored
Copper
Process wastewaters
I iquid
Dropped Oul of Analysis
April 1997
Not land stored
Copper
Serubber blowdown
Liquid
Dropped Oul of Analysis
April 1997
Believed to be same as
acid plant blowdown,
removed to prevent
double counting
Copper
Spent bleed electrolyte
liquid
Dropped Out of Analysis
April 1997
Not land stored
Copper
Spent furnace brick
Solid
Added to Analysis
April I99S
New information indicates
land stored prior to
iccycling
Copper
Surface impoundment waste
liquids
1. iquid
Dropped Out of Analysis
April 1997
Double counted (same as
process wastewaters)
Cupper
Tankhousc slimes
Solid
Dropped Out of Analysis
April 1997
Not land stored
Coppei
Waste contact cooling water
Liquid
Dropped Out of Analysis
April 1997
Not land stored
Hlemenlal Phosphorous
AFM rinsate
Liquid
Changed Generation Rate
April 1997
Commenler provided data
Hlemenlal Phosphorous
AFM rinsate
Liquid
Current recycling status
changed hum N U> V
April 1997
Commenter provided data
Elemental Phosphorous
AFM rinsate
Liquid
Dropped Oul of Analysis
April 199S
Commenior provided data
Elemental Phosphorous
Andersen Filler Media
Solid
Added to Analysis
April 1997
Commenler indicated this
material is hazardous
Elemental Phosphorous
Dust
Solid
Dropped Out of Analysis
April 1997
Commenter provided data
April 30, 1998


-------
i)-:i
Sector
Waste Stream
Waste Type
Action
Date
Reason
blciDcnlal Phosphorous
Furnace Building Washdown
Liquid
Added to Analysis
April l'W7
Commcnlcr provided data
Elemental PIius|)Ik)K)us 
Furnace otlgas solids
Solid
Dropped Out of Analysis
April 1997
Cummcntcr provided data
Elemental Phosphorous
Furnace set ubbei blowdown
Liquid
Changed Generation Kate
April 1997
Commcnlci provided data
Elemental Phosphorous
Furnace scrubber blowdown
Liquid
Current, recycling status
changed liom N to Y
April 1997
Commenier provided data
Elemental Phosphorous
Furnace scrubber blowdown
Liquid
Corrosivity changed from YS to
Y
April 1997
Coniinenier provided data
Elemental Phosphorous
Prccipiiator slurry
Liquid
Added to Analysis
April 1998
New information indicates
thill waste stream is
hazardous
Elemental Phosphorous
NOSAP slurry
Liquid
Added 10 Analysis
April 1998
New information indicates
that waste stream is
hazardous
Elemental Phosphorous
Phossy Water
Liquid
Added lo Analysis
April 1998
New information indicates
that waste stream is
hazardous
Gold and Silver
Rcilning wastes
Solid
Dropped Out of Analysis
April 199/
Generated at secondary
smelter only
(told and Silver
Slag
Solid
Diopped Out of Analysis
April 1997
Not land stored
Gold and Silver
Spent Furnace Dust
Solid
Dropped Out of Analysis
April 1997
Not land stored
Gold and Silver
Wastewater
Liquid
Dropped Out of Analysis
April 1997
Generated at secondary
smelter only
Gold and Silver
Wastewater treatment sludge
Solid
Dropped Out of Analysis
April 1997
Generated at secondary
smelter only
Lead
Acid plant blowdown
Liquid
Dropped Out of Analysis
April 1997
Fully recyekul, not land
stored
Lead
Uaghouse dust
Solid
Dropped Out of Analysis
April 1997
Fully recycled, not land
stored
Lead
Process wastewater
Liquid
Dropped Out of Analysis
April 1997
Fully recycled, not land
stored

April 30, 1998

-------
D-4
Sector
Waste Stream
Waste Type
Action
Date
Reason
Lead
Stockpiled miscellaneous plain
waste
Sfliil
Number >! JacilHies changed
from lour to three
Ajnii I99X
ASARCO. Oni.tha NF
Licihlv removed - inaelive
Lead
Surface impoundment waste
liquids
Liquid
Dropped Oul of Analysts
Apnl1997
No longer generated
Ixad
WWTP liquid diluent
Liquid
Couosivily changed horn Y lo
Y7
Apnl 1997
To icllecl vunability ol
stream at different
facilities
I .end
WWTP liquid eflluem
Liquid
Number of facilities changed
from four to three
Apnl1998
ASARCO, Omaha NL
facility removed - inactive
Lead
WWTP liquid efnucni
Liquid
Former RCRA waste type
changed liom sludge lo spent
material
April 1997
Incorrectly characterized
in original analysis
Lead
WWTP solids/sludge
Solid
Dropped Oul of Analysis
April I99K
Fully recycled, noi land
stored
Magnesium and Magnesia
Irom Brines
Smul
Solid
CunciU recycling status
changed from Y? lo N
April 1997
Review of recycling
information yielded new
conclusion
Mercury
Dusi
Solid
Gurrcnt recycling status
changed from YS? lo N
April 1997
Review of recycling
information yielded new
conclusion
Mercury
Dust
Solid
Number of facilities decreased
from nine to seven
April 1997
Pinson Mining and
Western Hog Ranch
facilities no longer
recovering mercury
Mercuiy
Furnace residue
Solid
Number of facilities decreased
from nine to seven
April 1997
Pinson Mining and
Western Hog Ranch
facilities no longer
recovering mercury
Mercury
Quench Water
Liquid
Numhci ol laciliiics decreased
from nine lo seven
April 1997
Pinson Mining and
Western Hog Ranch
facilities no longer
recovering mercury
April 30, IW8

-------
D-5
Sector
Waste Stream
Waste Type
Action
Date
Reason
Molybdenum,
Fcrromolybdenum, and t
Ammonium Molybdate
Hue dusl/gases
Solid
Number of facilities decreased
from twelve to eleven
April 1997
Cyprus Climax Bagdad
facility removed - no
processing mineral
occulting
Molybdenum,
Ferromolybdenum, and
Ammonium Molybdate
Molybdic oxide refining wastes
Solid
Dropped Out of Analysis
April 1997
No longer generated
Pyrobilumcns, Mineral
Waxes, and Natural
Asphalts
Still bottoms
Solid
Dropped Out of Analysis
April I99X
Production facilities no
longer in o[K*iation
Pyrobilumens, Mineral
Waxes, and Natural
Asphalts
Waste catalysis
Liquid
Dropped Out of Analysis
April 199S
Production facilities no
longer in o[>eralion
Rare hartlis
Solvent extraction crud
Solid
Number of facilities decreased
Iron) twenty to one
April 1997
Nineteen production
facilities no longer in
operation
Rare Earths
Solvent extraction crud
Solid
Current recycling status
changed from YS? to N
April 1997
Review of recycling
information yielded new
conclusion
Hare Earths
Spent lead filter cake
Solid
Dropped Out of Analysis
April 1997
Fully recycled, not land
stored
Rare Earths
Spent sciubbei liquor
Liquid
Corrosivily changed from YS to
Y?
April 1997
YS not an allowable entry
Rare Earths
Spent scrubber liquor
Liquid
Former RCRA waste type
changed from spent material lo
sludge
Apnl 1997
Ineoirectly characterized
in original analysis
Rare Earths
Waste solvent
Liquid
Dropped Out of Analysis
April 1997
Fully recycled, not land
stored
Rare Earths
Waste zinc contaminated with
mercurv
Solid
Dropped Out of Analysis
April 1997
No longer generated
April 30. 1998

-------
D-6
Sector
Waste Stream
Waste Type
Action
Dale
Reason
Rare F.arlhs
Wastewater from caustic wet
Arc
LiquiJ
F:ormer RCRA waste type
changed from spent material to
sludge
April IW
Incorrectly characterized
in original analysis
Rhenium
Spent barren scrubber liquor
Liquid
f ormer RCRA waste type
changed I'rom spent material to
sludge
April 1997
Incorrectly characterized
in original analysis
Selenium
Tellurium slime wastes
Solid
Current recycling status
changed from YS? lu Y?
April 1997
Review of recycling
information yielded new
conclusion
Tantalum, Columbium. and
Ferrocnlumbium
Digester sludge
Solid
Corrosiviiy changed from Y to
Y?
April 1997
Original source did not
provide data, based on
expert opinion
Tantalum, Columbium, and
Ferrocolumbium
Spent raffinale solids
Solid
Corrosivily changed fiom Y to
YV
April 1997
Original source did not
provide data, based on
expert opinion
Tellurium
Slag
Solid
Number ol facilities changed
from one to two
April 1997
KcnnccoU taciliiy added
to analysis based on
information in comment
Tellurium
Solid waste residues
Solid
Numbci ol facilities changed
from one to two
April 1997
Kennecott facility added
lo analysis based on
information in comment
Tellurium
Waste electrolyte
Liquid
Number of facilities changed
from one to two
April 1997
Kennecott facility added
to analysis based on
information in comment
Tellurium
Wastewater
Liquid
Number of facilities changed
Irom one to two
April 1997
Kennecott facility added
lo analysis based on
inlonnation in comment
Tellurium
Wastewater
Liquid
Corrosivity changed from Y to
Y?
April 1997
No supporting data
showing stream is
definitely corrosive
Titanium and Titanium
T)i 111 W, 1998

-------
13-7
Sector
Waste Stream
Waste Type
Action
Date
Reason
Titanium and Titanium
Dioxide
Scrap milling scrubber water
Liquid
Former RCKA waste type
changed from spent material to
sludge
April 1997
Incorrectly characterized
in original analysis
Titanium and Titanium
Dioxide
Spent surface impoundment
liquids
Liquid
Waste treatment type changed
lrom solid to wastewater
April 1997
Incorrectly characterized
in original analysis
Titanium and Titanium
Dioxide
Waste acids (Chloride process)
Liquid
Dropped Out of Analysis
April 1997
Fully recycled/Treated,
not land stored
Titanium and Titanium
Dioxide
Waste ferric cliloiide
liquid
Dropped Out of Analysis
April 199*7
Same as Wastes acids
(chloride process)
Titanium and Titanium
Dioxide
WW TP sludge/solids
Solid
Chromium toxicity changed
from Y to Y >
April 1997
No supporting data
showing stream fails CP or
TCLP lest for chromium
T ungsten
Process wastewater
Liquid
Number of facilities changed
from five, to six
April 1997
Produced at all facilities
Zinc
Acid plant blowdown
Liquid
Former RCRA waste type
changed from spent material to
sludge
April 1997
Incorrectly categorized in
original analysis
Zinc
Process wastewater
Liquid
Number of facilities changed
from four to three
April 1997
Zinc Corporation of
Amcrica-Bartlesville,
Oklahoma facility no
longer operational
Zinc
Spent cloths, bags, and filters
Solid
Number of facilities changed
from four to three
April 1997
Zinc Corporation of
America-Darllesville,
Oklahoma facility no
longer operational
Zinc
Spent surface impoundment
solids
Solid
Number of tacililics changed
from four to three
April 1997
Zinc Corporation of
America-Baitlesville,
Oklahoma facility no
longer operational
Zinc-
Spent surface impoundment
solids
Solid
Dropped Out of Analysis
April 1997
No longer generated
April 30, 1998

-------
D-8
Sector
Waste Stream
Waste Typo
Action
Date
Reason
Zinc
Spent synthetic gypsum
Solid
Number of facilities chungeJ
from lour to three
April 1997
Zinc Corporation of
Aiaei ica-Baillesville,
Oklahoma facility no
longer operational
Zinc
Zinc-lean slag
Solid
Dropped Out of Analysis
April 1997
I his is a special waste
Zinc
WWTP liquid effluent
Liquid
Number of facilities changed
from four to three
April 1997
Zinc Corporation of
America Barllesville,
Oklahoma (acilily no
longer operational
Zinc
WWTP solids
Solid
Added lo Analysis
April 1997
New information on
mnnagi'moni practices
Zinc
WWTP solids
Solids
Number of facilities changed
from four lo three
April 1997
Zinc Corporation of
Aincrica-Bartlesville,
Oklahoma facility no
longer operational
Zinc
WWTP solids
Solid
Current recycling status
changed Irom N lo YS
April 1997
Zinc Corporation of
America-Baiilesville,
Oklahoma facility no
longer operational
April SO, I'MX

-------
MINERAL PROCESSING WASTE TREATMENT AND
DISPOSAL COSTS: LOW-COST ANALYSIS	
APPENDIX E
This appendix comprises an analysis of the treatment and disposal options available to owners
and/or operators of mineral processing facilities. The appendix presents the available technically feasible
treatment and disposal options, a cost comparison of those options, and a determination of the lowest-cost
alternative.
l.'nder the current regulations governing the disposal of hazardous mineral processing waste,
owners and/or operators of mineral processing facilities have several disposal options available, depending
on the physical form of the waste(s) in question:
	Characteristic Solid wastes may be:
Disposed of in a Subtitle C landfill;
Treated, followed by disposal 111 a Subtitle C landfill; or
Treated, followed by disposal in a Subtitle D landfill.
	Characteristic Liquid wastes may be:
Treated, followed by disposal of solid residues in a Subtitle C landfill; or
Treated, followed by disposal of solid residues in a Subtitle D landfill.
\Vith today's completion of this rulemaking, owners and/or operators of mineral processing
facilities that generate characteristic hazardous waste (whether solid or liquid) must choose one of the
following treatment and disposal options:
	Treated and disposed of in a Subtitle D landfill: or
	Treated and disposed of in a Subtitle C landfill.
Depending on the quantity of waste generated, owners and/or operators of mineral processing facilities
may choose to send the waste off-site for treatment and disposal, or build a treatment system on-site.
E.l Pre-Rule Lowest Cost Option
E.l.l Analysis of Treatment and Disposal Costs
Using on-site cost functions and off-site unit prices from Appendix F, EPA has calculated pre-
rule (or baseline) treatment and disposal costs over a range of waste generation rates (100 mt/yr - 175,000
mt/vr) for on- and off-site Subtitle C landfill disposal, and on- and off-site treatment followed by Subtitle
D landfill disposal. Exhibit E-l shows the total treatment and/'or disposal cost plotted against a range of
waste generation rates.' The total cost of disposing mineral processing wastes increases as the quantity of
waste increases using all four alternatives.
' Because Subtitle C landfill disposal is more expensive than Subtitle D landfill disposal, EPA
assumes that if facility operators treated their wastes, they would opt for treatment followed by Subtitle D
disposal rather than treatment followed by Subtitle C disposal. Therefore, treatment followed by Subtitle C
disposal is nut included in Exhibit E-l.
April 30, 1998

-------
Total treatment and/or disposal cosh were divided by the waste generation rate to obtain unit
cos:s. Exhibit E-2 shows the unit treatment and/or disposal cost plotted against a range of waste
generation rates. Note that the unit cost of off-site treatment and disposal is constant, while the unit cost
of on-site Subtitle C landfilling and treatment and disposal decreases as waste quantity increases.
Exhibit E-l
Total Cost of Treatment and/or Disposal Alternatives
$1,-10C.OOO
$t.20C,000
11.000.000
r seoo.ooo
3.1C3 nfyr
$600,200
$400,000
$200,000
1,000
3.000	4.coo	s.n:o
Waste Generation Rate (mt/yr)
6,000
|	O'f-Site Sjbrite C 	O.n-Site Subtile C 	Oft&'eT&D 	O'.-SMe T4D
E.1.2 Subtitle C Disposal vs. Treatment and Subtitle D Disposal
Exhibits E-I and E-2 show that treatment followed by disposal in a Subtitle D landfill is less
costly than Subtitle C landfilling for virtually the entire range of solid waste generation rates under
consideration in this rulemaking. For small waste generation rates, however, off-site Subtitle C
landfilling is actually a lower cost option than treatment and Subtitle D disposal. Likewise, for waste
generated in excess of approximately 150,000 mt/yr (not shown in the exhibits), on-site Subtitle C
landfilling is a lower cost option than treatment and Subtitle D disposal. However, data for the biennial
reporting system indicate that few, if any, mineral processing facilities are currently sending waste off-site
for Subtitle C disposal. Therefore, EPA believes that owners and/or operators of mineral processing
facilities generating very small quanlilies of waste or facilities generating waste in excess ut 150.000
mt/yr will opt to treat and dispose the waste in a Subtitle D landfill. As a result. EPA considers on- and
off-site treatment and Subtitle D disposal to be the lowest-cost disposal options for managing hazardous
wastes from mineral processing.
April 30, 1998

-------
E-3
Exhibit E-2
Unit Cost of Treatment and/or Disposal Alternatives
Sl aoo -
$1,200 -]
I
5
(A
o
o
c S60C
D
$20C
1.000
2,000
3.000
4,000
5.C0C
6.C0C1
Waste Generation Rate (mtfyr)
	Cti-Site SuDtine C 	Qn-Site SuBtite C	On-Site TAD 	Off-Sits~&D j
E.1.3 On-Site vs. Off-Site Treatment and Subtitle D Disposal
In addition to determining that treatment and disposal is the lowest-cost disposal option. EPA has
identified a "break-even" point at which it is more economical to treat and dispose of waste on-site rather
than send wastes off-site for treatment and disposal. Exhibit E-2 shows the "break-even" point between
off-site treatment and disposal and on-site treatment and disposal. This "break-even" point occurs at
approximately 3,163 mt/yr, and therefore waste that is generated in small quantities (0 mt/yr - 3,163
mt/vr) will be sent off-site for treatment and disposal rather than be treated and disposed on-site. Waste
generated in excess of 3.163 mt/yr, however, will be treated and disposed on-site, assuming cost-
minimizing behavior.
E.2 Post-Rule Lowest Cost Option
Because Subtitle C landfill disposal is more expensive than Subtitle D landfill disposal, EPA
assumes that if facility operators treated their wastes, they would opt for treatment followed by Subtitle D
disposal rather than treatment followed by Subtitle C disposal. Additionally, the above analysis shows
that on-site treatment and disposal is less expensive than off-site treatment and disposal for waste
April 30, 1998

-------
quantities above 3,163 mt/yr. Therefore, F.PA assumes that the post-rule lowest-cost option is off-site
treatment followed by Subtitle D disposal for wastes generated in quantities below 3.163 mt/yr, while on-
site treatment followed by Subtitle D disposal is the lowest cost option for wastes generated in quantities
in excess of 3,163 mt/yr.
E.3 Conclusion
EPA believes that Subtitle C disposal is generally more expensive than treatment followed by
Subtitle D disposal. This assertion, coupled with data oil current management practices, has led fcPA to
assume that owners and/or operators of mineral processing facilities will choose to treat waste to UTS
levels and dispose of the treated waste in a Subtitle D landfill. Therefore, in both the pre-rulc (baseline)
and post-rule (option) scenarios, the mineral processing cost model reflects the assumption that for waste
generated in quantities below 3.163 mt/yr, owners and'or operators will send the waste off-site for
treatment and disposal, while owners/operators will build an on-site treatment system for waste generated
in excess of 3.163 mt/yr.
April 30, 1998

-------
DEVELOPMENT OF COSTING FUNCTIONS
APPENDIX F
EPA's cost analysis is based on costing functions and/or unit costs for on- and off-site treatment
and disposal costs and for on-site storage of recyclable materials. To develop the cost functions, EPA
identified all of the treatment and disposal permutations that are available in the various baseline-option
scenarios. Similarly, EPA identified all of the possible storage practices available under any of the
assumed baseline practices and regulatory options considered. The costing functions were developed by
estimating costs for facilities of different sizes and curve-fitting these individual facility costs For some
equipment associated with disposal and storage practices, the Agency has used rental costs rather than
purchase costs, irrespective of the quantities of material involved. EPA recognizes the likelihood that
mineral processing facilities actually own this equipment, such as front end loaders and dump trucks. To
be conservative, however, the Agency included rental costs as a simple way to account for the use of this
equipment.
The cost functions and associated assumptions are presented in the following six sections:
1.	Annualization of Before-Tax Compliance Costs
2.	On-site Treatment and Disposal Costs
3.	Off-site Treatment and Disposal Costs
4.	Storage of Solid Materials
5.	Storage Of Liquid Materials
6.	Curve-fit Cost Functions
F.l Annualization of Before-Tax Compliance Costs
Under Executive Order 12866. EPA must determine whether a regulation constitutes a "significant
regulatory action." One criterion for defining a significant regulatory action, as defined under the
Executive Order, is if the rule has an annual effect on the economy of $100 million or more. To determine
whether a rule is a significant regulatory action under this criterion, all costs are annualized oil a before-tax
basis assuming a seven percent real rate of return and a 20-year operating life. The savings attributable to
corporate tax deductions or depreciation on capital expenditures for pollution control equipment arc not
considered in calculating before-tax costs.
Annual before-tax compliance costs were determined for on-site treatment, disposal, and storage.
Before-tax compliance costs were used because they represent a resource cost of the rule, measured before
any business expense tax deductions available to affected companies. Also, as described in section 3.1.2
of tliis R1A, screening level economic impacts are computed based upon other pre-tax indications ol
financial wherewithal, such as value of shipments and value added. Accordingly, computing management
and compliance costs on a pre-tax basis provides a consistent measure of impacts on all affected facilities,
and is the method used throughout this RIA In reformulating the costs of compliance. EPA used a public
sector discount rate of seven percent and assumed a 20-year operating life for annualizing capital costs.
The following formula was used to determine before-tax annualized costs:
Belore-Tax Costs = (Capital Costs)(CRF) + (Annual Capital + O&M Costs) + (Closure
Costs)! CRFV( 1.07"')
April 30, 1998

-------
F-2
Where: CRF	= Capital recovery' factor based on a 1 percent real rate of return (i) as
follows:
fl + i1"(i1 = 0.09439 where n = 20
(1 + i)n-l
F.2 On-site Treatment and Disposal
Treatment of Acidic and Caustic Liquid Wastes
Treatment of liquid waste involves neutralization, precipitation, and dewatering, resulting in a
sludge requiring stabilization/solidification. Neutralization is the process of adjusting either acidic or
caustic liquid waste streams to a pH of approximately seven. Many manufacturing and processing
operations produce effluents that are acidic or alkaline (caustic) in nature. Neutralization of acidic or
caustic waste streams is necessary in a variety of situations: (1) to prevent metal corrosion and/or damage
to other construction materials; (2) as a preliminary treatment for optimum operation of subsequent waste
treatment processes; and (3) to provide neutral water for recycling, either as process water or as boiler feed.
Treatment to adjust pH also may be desirable to break emulsions, to precipitate certain chemical species, or
to control chemical reaction rates (e.g., chlorination). Precipitation, which may occur as a result of the
addition of neutralization reagents, or which may require additional reagents, is necessary to remove
dissolved solids, such as toxicity characteristic metals from solutions. Corrosive waste streams are
neutralized by the addition of an alkaline material, such as lime. Caustic waste streams are neutralized by
the addition of an acidic material, such as sulfuric acid. Additional reagent will cause precipitation of
dissolved metals. The precipitated metal sludge or slurry is then dewatered in preparation for stabilization.
There is probably no lower limit on the solids content of sludges handled by cement solidification,
although dewatering is advantageous as a volume reduction measure
Cost estimates were prepared assuming 1,752 hours per year for waste flow rates of 35.130 metric
tons per year (mt/yr) to 350,000 mt/yr, while batch runs were assumed for 3,510 mt/yr and 350 mt/yr,
adjusting the operating hours per year to 876 and 88. respectively.
Neutralization
Cavitui Ct'if.v
The following assumptions were used in developing the direct capital cost equations lor
neutralization in Exhibit F-l:
	Stainless steel neutralization reactor (1) - '/i-hour retention time, 57c over design (based oil
waste and calcium hydroxide or sulfuric acid solution flows);
Stainless steel mix tank (1) - two-hour retention time, 5?c over design (based on 10?c
calcium hydroxide or 20% sulfuric acid solution flows);
	Piping, electrical, and instrumentation; and
April 30. 1998

-------
F-3
EXHIBIT F-l
COST EQUATIONS FOR ON-SITE NEUTRALIZATION
AM) PRECIPITATION OF PHASE IV WASTES (1995 $)
Neutralization
Capital Costs (350 < Q < 370,000 mt/yr)'
O&M Costs / Yr (350 < Q < 370,000 mt/yr)
Precipitation
Capital Costs (350 < Q < 370,000 mt/yr)2
O&M Costs / Yr (350 < Q < 370,000 mt/yr)
Closure
Closure Costs (Q < 37,910 mt/yr)
Closure Costs (37,910  Q  370,000 mt/yr)
Cost(S) = 36.131 + 151.95 Q'
Cost($) = -206,719 + 36,594 In Q
Cost(S) = 3,613 + 15.195 Q'
Cost($) = 0.3465 Q + 826.48
Cost($) = 6,493
.Cost(S) = 6,361 + 3.0 x 10'? Q
Note:
For quantities above the upper limit of the cost equations, a second system is required.
1 Q = Annual quantity of acidic or caustic waste managed (mt/yr). Capital and O&M
equations apply to either type of waste (similar costs due to use of high cos! stainless steel
reactor in both designs and roughly equal neutralizing material costs). Fifteen percent of the
waste stream neutralized and precipitated will need to be dewatcrcd and stabilized.
Neutralization is performed in a less than 90 day accumulation treatment tanks (40 CFR
262.34); therefore, a RCRA permit is not required.
Acidic Waste Onl\
Carbon steel holding tank (1) - two-hour retention time. 5% over design (b;ised on 107c
calcium hydroxide solution flow);
Carbon steel centrifugal pumps (3) - for the calcium hydroxide solution out of the mix
tank and out of the holding tank, and for the waste flow into the reactor;
Stainless steel centrifugal pump (li - for the waste (low into the reactor;
i
April 30, 1998

-------
F-4
	Cast iron agitators (2) - for the mix tank and the holding tank; and
	Stainless steel agitator (1) - for the reactor.
Caustic Waste Onh
	Stainless steel pump (1) - for sulfuric acid flow out of the mix tank;
	Carbon steel pumps (2) - for the waste flow into and out of the neutralization reactor; and
Stainless steel agitators (2) - for the sulfuric acid mix tank and the neutralization reactor.
Capital costs are similar for either type of waste due to the use of a high cost stainless steel reactor
in both designs.
Operation and Maintenance Costs
The following assumptions were used in development of the O&M cost equations for
neutralization in Exhibit F-l:
	Operating hours - 90 percent operating factor (i.e., 330 days/year);
	Labor - one operator at 20 percent time for continuous systems, or '/2 hour of labor per
batch;
	Power - electricity for pumps and agitators: and
	Materials - waste pH was assumed to be 1.0 (acidic wastes) and 13 0 (caustic wastes) and
waste specific gravity was assumed to be 1.03. Material quantities calculated from the
stoichiometric addition of 0.033 gallon of 10% calcium hydroxide or 0 022 gallon of 20%
sulfuric acid solution needed per gallon of waste.
O&M costs are similar for either acidic or alkaline waste due to roughly equal neutralizing material costs.
Performance Assumptions
The following performance goals were assumed for neutralization:
	Neutralized waste exits with a pll of approximately seven;
	Solid residuals are generated, with half of inlet total suspended solids (TSS) level of 3.09^
assumed to settle and form a sludge with 10% solids content. Therefore, 159t of the
original waste stream will leave the neutralization step as hazardous sludge, due to
precipitation of a portion of the 500 ppm TC-metals assumed to be in the inlet waste
streamthis sludge will require dewatenng. stabilization, and disposal; and
	The quantity of calcium hydroxide or sulfuric acid solutions added to the waste streams
results in minimal flow changes.
April 30, 1998

-------
F-5
Closure Costs
Cost equations for closure of the neutralization tanks and associated equipment are listed in
Exhibit F-l and include the following components:
	Decontamination of tank interiors, pumps, and liners;
	Management and off-site disposal of decontamination residuals as hazardous waste;
	Testing rinsate to demonstrate tanks and equipment are successfully decontaminated; and
	Certification of closure by a professional engineer.
Precipitation
EPA has assumed that in some cases, precipitation will require more reagent than used for
neutralization, though these reagents will be added to the same reactor vessel. To account for this
possibility, the Agency has determined that the capital cost for precipitation will consist of the cost of a
small reagent holding tank, assumed to be 10 percent of the capital cost equation. O & M costs will
consist of doubling the original reagent cost. Cost equations for this additional precipitation step are
included in Exhibit F-l.
Surge Capacity
HPA also has assumed that a seven day surge tank is needed. The cost of this tank was developed
along with that of other storage tanks, and is presented below in section 5.
Dewatenng
Capiuit Costs
The following assumptions were used in development of the direct capital cost equations for
dewatenng, which are presented in Exhibit F-2.
	The dewatering direct capital cost includes a scroll centrifuge;
	Installation charges were estimated at 15% of the equipment purchase costs;
Operation and Maintunanrf Costs
The following assumptions were used in the development of the O&M cost equations for
dewatering in Exhibit F-2:
	Direct operation and maintenance costs consist of operating labor and electricity;
	Operating hours--90% operating factor (i.e., 330 days/year);
	The dewatered sludge has a solids content of 60 percent and a specific gravity of
1.03;
April 30, 1998

-------
F-6
EXHIBIT F-2
COST EQUATIONS FOR ON-SITE DEWATERING
OF PILASE IV WASTES (1995 $)
Dewatering of 1-10% Solids-Containing Wastes
Capital Costs (350 
-------
F-7
	The ratio of cement to waste to water is 36:100:10 by weight, based on information from
the Portland Cement Association. McCutcheon Enterprises, and Rollins Environmental.1
	Five days worth of water and cement would be stored.
	The density of cement is 85 lbs/ft' (which is the density of crushed furnace slag).
	The front end loader can move 20 shovelfuls per hour.
	The front end loader mu^t be rented for full days.
	The number of operating days was calculated by assuming that the facility operator would
only run the waste treatment equipment when enough waste was available for a full day's
operation. This assumption maximizes use of equipment while ensuring that waste is
treated within 90 days of generation.
	Freight and installation of major equipment would be approximately 30 percent of the
purchase price, if not included in the price quotation.
	The amount of solidified waste disposed of in a landfill is 1 .46 times the quantity, on a
weight basis, of the waste being stabilized. The density of this stabilized waste is
110 lb/ft3.
	Stabilization is performed in a less-than-90 day accumulation treatment tank (40 CFR
262.34), so that a RCRA permit is not required.
Cost Data:
	The cost of cement was assumed to be $84.20 per short ton, which is the average of three
price quotations: S60/ton. S74 50/ton and $76/ton (Allentown Cement Company. Illinois
Cement Company, and Kaiser Cement Company), plus 20 percent of this average to cover
shipping.
The cost of a 700 ft5 silo is SI 3.340. the cost of a 9,000 ft' silo is $28,000, and the cost of
a 19,000 ft' silo is $36,000 (Virginia Silo and Rock Systems Inc.).
	The cost of an auger for the cement is SI0.000 to S15.000 per silo (Virginia Siloi.
' This is a much lower ratio of cement to waste than had been assumed in the previous
stabilization cost function. A representative of the Portland Cement Association suggested a ratio of S to
20 percent cement to waste (by weight) was sufficient, and that previous EPA estimates were high. A
representative of McCutcheon Enterprises suggested a range of 10 to 36 percent cement to 100 percent
waste by weight. Furthermore. Rollins Environmental Inc.. a commercial treater, indicated that they added
20 to 25 percent Portland cement to waste. EPA chose 36 percent cement to waste to be conservative.
(Personal communication between ICF Incorporated and Jack Miller. McCutcheon Enterprises. September
3, 1997; personal communication between ICF Incorporated and Chuck Wilk. Portland Cement
Association, September 9. 1997; and Letter from Michael Fusco, Rollins Environmental Inc.. to Anita
Cuinmings. US HPA, Of fice of Solid Waste. December 19, 1996.)
April 30, 1998

-------
F-8
The cost of renting a 7.5 yd' capacity 375 horsepower front end loader is $1,400/day
(Means. 1995).
The fuel and maintenance cost of the front end loader is $56.15/hr (Means, 1995).
The cost of a heavy equipment operator is S28.70/hr (Engineering News Record. July 29.
1996. p. 63).
The cost of a small equipment operator is S26.13/hr (Engineering News Record, July 29.
1996, p. 63).
The cost of electricity is S0.07/kWh (CKD Cost Model Documentation).
The cost of a 10 gallon per minute 0.5 horsepower centrifugal pump is $7.34, and the cost
of a 100 gallon per minute 5 horsepower centrifugal pump is $2,007 (Means
Environmental Restoration Unit Cost Book, p. 8-356).
The cost of a ore cubic yard plywood box is $48.59 (Means Environmental Restoration
Unit Cost Book, p. 8-215).
The cost of water is S25 for 3,000 gallons (McCutcheon Enterprises).
Cost for tanks of various sizes are as follows:
500 gallon tank: S450,
1.000 gallon tank: SI,246,
2.000 gallon tank: SI.681.
8.000 gallon tank: $4,593,
15.000 gallon tank: $6,876,
20.000 gallon tank: $8,332,
25,000 gallon tank: $9,405. and
29.600 gallon tank: $10,567.
In some cases multiple tanks are needed. (Availability and Costs of Storage Units Suitable
for Mineral Processing Secondary Materials. Chcm-tainer Price List Attachment, p.2. and
Highland Tank Attachment, p.3).
A 7.5 horsepower eight ton capacity waste hopper costs $9,640 while a 10 horsepower 14
ton capacity waste hopper costs $28,693 (Rock Systems, Inc.).
A pugmill that processes three ton^/hr costs $20,000, a pugmill that processes 60
tons/hour costs $45,000, and a pugmill thai processes 187 tons,'hour costs SI00,000 (Scott
Equipment Manufacturing).
April 30, 1998

-------
F-9
Exhibit F-3 prcsenLs the cost data for the specific cost elements for each of the eight waste
generation rates. Exhibit F-4 plots annualized cost as a function of waste generation rate. The curve fit
cost function is also shown in Exhibit F-4. The equation for this cost function is:
Y = 49.177 (X) +342,233
where Y is the annualized cost of ccmcnt stabilization in dollars per year, and X is the annual quantity of
waste to be stabilized in metric tons per year
On-site Subtitle C Landfill
Initial Capita! Costs and Assumptions
The landfill design assumes a 20-vear operating life with one new cell opened per year (20 cells
for 20-year operating life). The following assumptions were used in the development of the initial capital
cost equation for landfill operations in Exhibit F-5:
	Land, which includes 5 meters between cells, 15 meters between the cells and the edge of
the active area, and a 46-meter buffer around the 20 cell area:
	Site preparation, which includes clearing the 20-cell area and 21 meters around the 20-cell
area of vegetation;
	Gravel roads within the active area;
	A .50 foot x 35-foot concrete pad for unloading waste and truck cleaning;
	Warning, stop, and directional signs:
	A maintenance building for equipment repair:
	Utilities site work that includes the installation of electricity, a septic system, a domestic
well, a gas line to propane tank, and a telephone at the site;
	An earthen berm around the 20-cell active area for surface water control;
	A package leachate treatment system;
	A groundw ater monitoring system that includes six upgradient wells (three shallow wells
to provide a horizontal profile of groundwater composition and one cluster of three wells
at different depths near one another to provide a vertical profile of groundwater
composition'! and a minimum of nine downgradicnt wells (three three-well clusters with
the wells in each cluster at different depths). For facilities with an active area side
dimension greater than 300 ft, the unit would have the minimum three three-well cluster
tor the first 300 ft, plus one cluster of three wells for every additional 1 50 ft;
April 30, 1998

-------
F- 10
Exhibit F-3
Annual Stabilization Cost of Solids and Dewatered Sludges
ABCDE	F	G	H	Notes
Waste Quantities (mt/vr)
900
1,500
3.000
15,000
30,000
75.000
150,000
300,000

Waste Quantities (mt''qti)
225
375
750
3.750
7,500
18,750
37,500
75.000

Operational Hours por day
R
8
B
8
8
8
R
8

Operational days per quarter
lb
Xb
51
13
26
63
41
81
3tph, 60tpn. or 187 tph
Operational days per year
64
104
204
52
104
252
164
324

Waste Quantities (rnt'dav)
14
14
15
288
283
298
915
926

Waste Quantities (ml/hr)
2
2
V
3G
36
37
114
116











Reagent









Cement (mt/Uav)
5.1
5.2
5.3
104
104
107
329
333
36 % by weiaht
Cemenl (tt3/dav)
131
135
137
2.693
2.693
2.779
8,540
8.645
85/b/ft3
Horsepower - screw convcver
7.5
7 8
7 5
10
10
10
28
28

Capitaf Cost









Silo
13,340
13.340
13.340
36.000
36,000
3H.OOO
100.000
108,000
includes freiaht
Screw Conveyor
10.000
10.000
10,000
15,000
15.090
15.000
40.000
40,000
includes Ireiqht
O&M Cost









Cernont ($)
30,071
50.119
100,238
501.190
1.002.301
2.505.95?
5.011.905
10.023,810
$84.2/short ton
Labor
14,694
23 878
46.838
11,939
23,878
57.859
37,654
74.390
$28.70/tir  heavy equip, oper.
Electricity
200
326
639
217
434
1.052
1.883
3,721

Maintenance
2.334
2.334
2,334
5,100
5,100
5.100
14,800
14,800
10% capital










Water Usaqe









Water (mt/dav)
14
1.4
1.5
28.8
28 8
29.8
91. fa
92.6
10% waste quantity
Water (ual/dav)
372
381
3H9
7.G24
7,624
7.866
24,173
24,471

Horsepower  pump
0.5
0.5
0.5
5
5
5
5
5

Capital Ccst









Tank
1.681
1,681
1.681
16.654
16,664
16.664
47.025
47,025

Treiqht and Installation
504
504
504
4,999
4,999
4.999
14,108
14,108
30% of purchase price
Pump
734
734
734
2,007
2,007
2.007
2.007
2.007
10GPM. 100GPM
O&M Cost









Water ($)
198
330
660
3,302
6.60.5
16,511
33.023
6G,045
$25/3000qal
Labor
13,379
21,740
42,644
10,870
21.740
52.678
34.283
67,729
$26 13/hr
Electridiv
13
2?
43
109
217
526
342
676

Maintenance
242
242
242
1.867
1,867
1.867
4,903
4,903
10% capital










April 30, 1998

-------
r-11
ABCDE	F	G	H	Notes
Waste Mandlinq









horsepower  waste hopper
7 :
7.5
7.5
10
10
10
20
20

Capital Cost









Waste Hopper
9.6-10
9.640
9,640
28,693
28,093
28.693
57,386
57,386

O & M Cosls









Fronl End Loader  Rental ($/yrJ
U9.bU(5
145.GOO
285,600
72,600
145,600
352,800
229.600
453,600
$1400/dav. 7.5vd3 bucket
FEl. - Fuel and Maintenance
28,749
46,717
91.637
P3.35H
40,717
113,198
73,669
145,541
$56.15/hr
Electricity
20C
326
639
217
434
1.05?
1.370
2,706
$0.07/kWh
Labor
29.380
47,757
93,6/7
23,878
47.757
115.718
75.309
148./HI
$?8 70/hr, 2 laborers
Maintenance
964
964
964
2.869
2,869
2.869
5.739
5.739
10% capital










Pugmlll System









Mass Processed {mt/davl
21
21
21
421
421
435
1,335
1,352

Horsepower - ouQtnill
15
15
15
75
75
75
150
150

Capital Ccsl









Puqmill
20,000
20,000
20.000
45.000
45,000
45,000
100,000
100,000

Freiqht and Installation
6.000
6,000
6,000
13,500
13,500
13,500
30,000
30.000
30% of purchase price
0 & M Costs









Electricity
401
651
1.278
1,629
3.257
7,89?
10,273
20,295
$0.07/kWh
Labor
14,694
23,878
46.838
11.939
23,878
57.859
37.654
74,390
$28.70/hr
Maintenance
2,000
2,000
2,000
4,500
4,500
4,500
10.000
10,000
10% capital










Castinq Equipment









Number of 1 cv forms required
244
406
813
4064
8128
20320
40640
81281
form used 4 times
OA M Costs









Forms (S/vr)
11 ,856
19,776
39,504
197,518
394,988
987.397
1,974.746
3.949.444
$48 sa/fnrm










Total Capita* Cost ($)
61.899
61,899
61,899
161.863
161.863
161,863
39fl.S?B
398,526

Annualized Capital Cost ($/yr)
5.843
5,843
5,843
15,278
15.278
15,278
37.617
37.617

0 & M Cost CS/yr)
238/985
;m6,660
755,775
873,304
1,732,224
4,284.834
7,557.153
15.066.570

Total Annualized Cost ($/yr)
244,828
392,503
761.617
888.583
1,747,502
4.300,112
7,594,769
15,104,187

Unit Cost <$/m0
272.03
261.67
253.0/
59.24
58.25
57.33
50.63
50.35

April 30, 1998

-------
F- 12
Fxhihit K-4
Annual On-site Stabilization Cost of Solids
16.000,000
14,000,000
y = 49.177x +342233
R2 = 0.9988
2.000,000
0,000,000
(0
o
O
TJ

8,000,000
N
n
3
C
< 6,000,000
4,000,000
2,000,000
50000
0
1C0000
200000
250000
300000
350000
150000
Waste Quantity (mt/yr)
April 30, IW8

-------
F-13
EXHIBIT F-5
COST EQUATIONS FOR ON-SITE SUBTITLE C LANDFILLS
PHASE IV WASTES (1995 $)
Capital Costs (Q k 1,000 mt/yr)	Cost($) = 83,378 + 23,422 Q"
Annual Capital Costs (Q > 1,000 mt/yr)	Cost($.) = 3,137 QnM
O&M Costs / Y r (Q > 1,000 mt/yr)	Cost(S) = 114,223 + 1,73 7 Q5
Closure Costs (Q i 1,000 mt/yr)	Cost($) = 1,829 Q05'
Post-Closure Costs / Yr(Q i 1,000 mt/yr)	Cost(S) =1,523 Q050
Cover Replacement Costs / Yr (Q > 1,000 mt/yr)	Cost($) = 3,502 Q"
Note: Q = Annual quantity of waste managed (mt/yr) ranging from 1.000 to 150,000
MT/yr.
Portable submersible pumps for cell dewatering and leachate removal if sump pump fails;
Heavy equipment, which includes dozers, landfill compactors, scrapers, and utility trucks:
Construction of the first cell with the following containment system design in descending
order starting with the layer closest to the waste:
0.3 meter protective soil layer;
geotextile filter fabric:
0.3 meter sand layer;
30 mil HDPE liner:
0.3 meter sand layer;
30 mil HDPE liner; and
0.91 meter clay layer;
Wet wells and purnps for the leachate collection system and the leachate detection system;
April 30, 1998

-------
F-14
	RCRA initial costs, which include the following items:
ID number;
waste analysis:
waste analysis plan:
inspection schedule;
personnel training;
alarm and spill equipment;
arrangement with local land authority;
contingency plan;
operating record:
groundwater monitoring plan;
background groundwater monitoring:
closure plan, closure cost estimate, post-closure plan, post-closure cost estimate;
closure/post-closure financial assurance (obtain mechanism - excludes payments
to mechanism);
liability insurance (obtain mechanism - excludes payments to mechanism);
Part A permit application; and
Part B permit application; and
	Fees, which include construction quality assurance (CQA), engineering, construction and
inspection, construction and field expenses, contractor's overhead and profit, spare parts
inventory, and contingency.
Annual Capita! Costs and Assumptions
Annual capital costs include the construction of one new cell and closure (i.e., final cover) of the
previously used cell each year for the operating life (i.e., 19 years). The following assumptions were used
in the development of the annual capital cost equation for landfill operations in Exhibit F-5:
	Cell construction consisting of the same containment design as described in the initial
capital cost assumptions;
	Construction of each cell's cover with the following cover system design 111 ascending
order starting w ith the layer closest to the waste:
0.6 meter clay layer;
30 mil PVC liner:
0.3 meter sand layer;
geotextile filter fabric.
0.6 meter topsoil layer; and
vegetation;
	Fees which include CQA. engineering, construction and inspection, contractor's overhead
and profit, and contingency.
April 30, 1998

-------
F-15
Operation and Maintenance Costs ami Assumptions
The following assumptions were used in the development of the O&M cost equation for landfill
operations in Exhibit F-5:
	Labor for personnel to operate the landfill, which includes equipment operators, laborers,
clerical staff, a technician, a manager, and an engineer:
	RCRA administrative costs, which include the following items:
review waste analysis and plan;
conduct and record inspections;
training program review for facility personnel;
review contingency plan:
maintain operating record;
review closure/post-closure plan;
update closure/post-closure cost estimate;
review closure/post-closure financial assurance mechanism:
review third party liability mechanism;
review corrective action schedule; and
permit renewal (Assumed the Part B permit is renewed every five years.
Averaged the periodic costs out on an annual basis );
	Maintenance labor and supplies;
Leachate treatment;
	Groundwater monitoring semi-annually for the following parameters: pH: specific
conductance; total organic carbon; total organic halogens: metals: and VOC s; and
	Utilities, which include fuel lor heavy equipment, electricity for maintenance building and
pumps, and heat for maintenance building
(.'Injure Costs and Assumptions
The following assumptions were used in the development of the closure cost equation for landfill
operations in Exhibit F-.i:
	Construction of the final cell's (cell 20) cover consisting of the same cover design
described in the annual capital cost assumptions;
	Decontamination by steam cleaning of heavy equipment (dozers, scrafwrs, compactors,
and trucks). Assumed residuals generated at 100 gal/hr and managed off-site as a
hazardous waste (transportation 100 miles one-way and commercial hazardous waste
treatment):
	Pumps and lines decontaminated with an alkaline solution. Assumed residuals generated
at 500 gal/pump and managed off-site as a hazardous waste (transportation 100 miles one-
way and commercial hazardous waste treatment):
April 30, 1998

-------
F-16
	Certification of closure by an independent registered professional engineer; and
	Fees, which include CQA, engineering, construction and inspection, contractor's overhead
and profit, and contingency.
Post-Closure and Cover Replacement Costs and Assumptions
The following assumptions were used in the development of the post-closure and cover
replacement cost equations for landfill operations in Exhibit F-5:
	Survey plat indicating location and dimension of cells to permanently surveyed
benchmarks;
	Waste record submitted to local land authority;
	Note added to property deed stating previous land use;
	Final cover inspected semi-annually;
	Maintenance of final cover (i.e., mow semi-annually and fertilize annually);
	Reseed, fertilize, mulch, and water 1/6 of entire 20-ceIl area every five years;
	Conduct routine erosion damage repair of cover and ditch every five years;
	Exterminate for burrowing rodents every two years;
Replace the cover on the first five cells during the last five years of post-closure.
	Lcachatc managed off-site as a hazardous waste (transportation 100 miles one-way and
commercial hazardous waste treatment) for all landfill sizes;
	Pumps replaced annually;
	Groundwater monitoring semi-annually for the following parameters; pH; specific
conductance; total organic carbon; total organic halogens; metals; and VOC's;
	Certification of post-closure by an independent registered professional engineer; and
	Fees, which include administration, CQA, engineering, construction inspection testing,
construction and field expenses, contractor's overhead and profit on the cover replacement
" cost, and contingency
Disposal of Solid Materials in On-sile Subtitle D Files
The waste pile disposal cost function includes land, a compacted soil base, and the costs of a dump
truck to move the material to the pile.
EPA made the following assumptions in assembling these cost functions:
April 30, 1998

-------
F-17
	The purchase cost of land is $2500/acre (from CKD Monofill Model Cost Documentation.
1995);
	The unit does not require a formal liner, though it is assumed that it will need at least a
foot of compacted soil as a base;
	The cost of compacted soil is $0.2325/ft' (from CKD Monofill Model Cost
Documentation. 1995);
	The unit must be sized for 20 years' accumulation of waste;
	The necessary land area is determined by assuming the material is stored in a conical pile
with a maximum height of 100 It, where the height of the pile is Vz the radius and the
volume of the pile is calculated using the following formula; V = 1/371^;
	The length of a side of the square plot for a single pile is the twice the radius plus a ten
foot buffer zone around the edge of the pile to move equipment; therefore, the area of the
pile is [2*(r+10)_l2 ;
	The area of the square plot for multiple piles is calculated by assuming that the volume to
be stored is equally divided b> the number of piles, then adding the area of each individual
pile with its buffer zone (to allow equipment to move between the piles);
The density of solid materials is the same as crushed furnace slag (85 lb/ft3);
The cost of purchasing a 25 short ton capacity dump truck is S275.000 ( vendor quote,
1996);
	The cost of renting a 25 short ton capacity dump truck is S775/day (from Means. 1995);
	The fuel and maintenance cost of the mick is S1 S.S5,'hr (from Means, 1995);
	The cost of labor to operate the truck is 522.80/hr (Engineering News Record, 10/31/94, p.
49);
	It would take Vi hour to drive the dump truck to Ihe waste pile, empty it, and return to the
point of generation;
	There is no cost associated with a conveying system at the waste pile; and
	Below 50 mt/yr. facilities would not use a pile for disposal as it would be more
" economically attractive to send the material off-site for disposal, even for Subti'.le C
treatment and disposal.
The costs of disposing solid materials in on-site Subtitle D piles are shown in Exhibit F-6. Exhibit
F-7 plots annualized cost as a function of waste generation rate, and displays the curve fit cost function.
April 30, 1998

-------
F-18
Disposal of Liquid Materials in Surface Impoundments (On-Site Subtitle D)
On-site disposal of liquids (for the no prior treatment baseline) poses some interesting problems, in
that release of wastewater is regulated under the NPDES programs, which places limits on what
"pollutants" can be released into the environment, including heat, turbidity, and percent solids, to name a
few. Because EPA has assumed simple release of materials (for this baseline) under the RCRA program,
but some treatment or settling is required under the NPDES programs, EPA has assumed that a facility
operator will "treat" liquid waste in surface impoundments, by adding reagent in a tank basin before the
waste enters the surface impoundment. Further, EPA has assumed that the facility will then hold the
material in the surface impoundment for 15 days before release. Because, however, facility operators will
have to treat these, waste liquids to UTS levels in a tank system before release, EPA believes the cost of
constructing the surface impoundment is a sunk cost, and should not be counted towards calculating the
baseline cost.2
Equations were developed for the capital and O & M costs for on-site neutralization of acidic and
caustic wastewaters subject to federal NPDES standards. The cost functions were developed by estimating
the costs for different size facilities and curve fitting the results. These equations are presented in Exhibit
F-8. Because the capital costs for acidic and caustic wastes are very close, EPA used the costs for acidic
wastes for all waste streams in the cost model. The Agency based this decision on the assumption that the
majority of corrosive mineral processing wastestreams were acidic rather than caustic.
F.3 Off-Site Treatment and Disposal
The cost of sending liquids off-site for treatment and disposal of residues is $ 175/mt, which
includes a cost of $25/mt for transportation and a cost of $150/mt for treatment. The cost of sending solid
waste off-site for treatment is S164/mt. which includes S25/mt for transportation, S88/mt for stabilization,
and S35/mt for disposal (which is adjusted to S51/mt because stabilization increases the mass of waste to
be disposed to 146 percent of the original mass). The price of off-site treatment of liquids was taken from
the September 1994 document Estimating Costs for the Economic Benefit of RCRA Noncompliance. The
cost of off-site Subtitle D disposal is taken from the Technical Background Document: Data and Analyses
Addressing the Costs of CKD Management Alternatives. The commercial price for stabilization is
estimated at $88/mt, based on an $80/'short ton difference between off-site landfill and stabilization
($ 17(i/sliort ton) and off site landfill alone (S90/short ton) reported in EI Digest, November 1994.
F.PA believes it is inappropriate to include sunk capital costs in the baseline, because the incremental costs
of this rule arc calculated as the difference between the post rule costs and the baseline costs. If EPA included these
non recoverable costs in the baseline, the incremental cost of the rule would be underrated.
April 30, 1998

-------
F- 19
Lxhihit F-6
Annual Disposal Cost of Solids in Waste Piles
Waslo Pile  Disposal	Unit Cost	A	B	C	D	E	K	G	H
Waste Quantities (nd^vr;

50
500
b.COO
50.000
75.000
100.030
250.000
r.ooooo
Waste Quantity ''U-'vr)

1,297
lu.yon
t29 62
1,295.824
1.945.235
2.593.647
6.4B4.118
12.fi6fl.??5
Total Unit Wasis Quantity (fl3l

?r> 930
259.365
>".593 647
25 9:if>.471
38.904./U6
51,872,941
124002.353
259.jH4.7CC

'








Unit Construction









NumL^Cf of Piles

1
1
1
7
10
13
31
62
Radius of Pile {ft)

47
yy
180
202
205
207
210
210
Height of Pile III)

18
10
85
9fi
98
99
100
10;,|
Unit S'Zfi (ft?)

H. /33
31.772
130.272
1.142.363
1.683.210
2.223,596
5.463.850
10.9^7.695
Unit Size facros)

0.20
1
3
26
39
51
125
251
Annualized Land (S/vr)
J2500.'acrn
17
172
706
CO
a:
9.118
12.046
P9.M9
59 19ii
Unit base {compacted so'l)
$0 ?325fi3

697
2.859
25.070
36.939
40,798
119.908
239.816










Dumo Truck









Number ol t'iDS  Annual

3
?.1
221
2.205
3.307
4.410
11.C23
22.046
Nunibt)! of k ours  annu-il

1.5
12
111
M03
1.654
2.205
5 51?
11.023
Annun Rental Cost
$7/VddV
? :\?r,
17.825






Number of Ordinal Trucks Needed

i
1
1
1
1
1
3
5
Lifetime of lruck(s>

2\.
?0
20
20
16
12
14
12
Total Number ol Trucks Needed

1
1
1
1
2
2
G
1U
AnnuaJ'zed Purchase cost
$275,000


25.957
25.957
34.915
37.646
107.762
1S8.224
Annual /cd ! abor Cost
%2? H(Vh'
:?4
262
J>.5i19
25.13/
37.700
50.274
125.662
251.324
Ann. Fu^l and Mainiiian:e Cos'
$*8 81>/hr
28
217
2.063
20,782
31.1fifi
4 1.564
103.892
207 784










Total Annual Cost IVvr)


19.173
114.124
103.135
149.841
190.329
406.82'J
946.345
Unit Cost ($/mtl

b'2 SI
38.35
6 02
2.06
2.00
1.90
1.95
1.69
April 30, 1998

-------
F - 20
Exhibit K-7
Disposal of Solids in Subtitle D Wuslc Piles
1,000,000
y = 1.870?x ~ 12308
R* = 0.9994
800,000
700,000
600,000
500,000
400,000
300,000
200,000
100,000
100,000 150,000 200,000 250,000 300,000 350,000 400,000 450,000 500,000
50,000
Waste Quantity (mt/yr)
April 30, 1998

-------
F-21
Exhibit F-8
COST EQUATIONS FOR ON-SITE DISPOSAL OF WASTEWATERS
(TO MEET NPDES STANDARDS ONLY -1995 $)
Capital Costs (350 s Q < 350,000 mt/yr)lCost($) = 16,777 + 75.08 Q 5
O&M Costs / Yr (350 s Q < 350,000 mt/yr)Cost(S) = -113,989 + 19.114 In Q
 Q = Annual quantity' of waste managed (mtyvr)
F.4 Storage of Solid Materials
Storage of Solid Materials in Drums
The drum storage cost function for solids includes the capital cost of the drums, labor to open and
close drums, and labor to move the drums either manually (using a handtruck) or using a pallet truck. The
drum(s) would be filled by placing them under a hopper or chute, and would then be closed by a laborer.
The drum would be moved to a storage area within the same area of the facility either on a handtruck
(using manual labor) or on a pallet truck. Later, the drum would be moved to the point of reentry and
opened The normal feed handling equipment would be used to reinsert the material back into the process
The Agency made the following assumptions in assembling these cost functions:
The capital cost of a carbon steel drum is S52 (from Non-RCRA Tanks, Container-, and
Buildings, December 1996, p. 17. This price includes $2 per drum for freight):
	55 gallon drums have 50 gallons of usable capacity;
	The density of solid materials is the same as crushed furnace slag (85 lb/ft*);
	A laborer could close (or open) drums at the rate of 12 drums [>er hour,
	A laborer could move a drum from the point of generation to the storage area (or back
from the storage area to the point of reentry) using a handtruck at a rate of 8 drums per
hour;
	A laborer could move drums from point of generation to the storage area (or back from the
storage area to the point of reentry) using a pallet truck at a rate of 32 drums per hour:
	The material to be stored is generated continuously, therefore, unless mors than 90 drums
are generated, the efficiencies of using a pallet truck would be lost and facilities would use
manual labor to move drums rather than use the pallet truck:
(
I
April 30. 1998

-------
F-22
	The cost of unskilled labor is S19/hr (from CKD Monofill Model Cost Documentation.
1995):
. The cost of a small equipment operator is $24.60/hr (Engineering News Record, 10/31/94,
p. 49):
	The cost of a handtruck is $209, and the cost of a pallet truck is $3,020 (from Peters and
Timmerhaus, 1990, updated to 1995 dollars);
The cost of fuel and maintenance for the pallet truck is S1.50/hr, which is estimated to be
the same as the fuel and maintenance cost of a gasoline powered cart (from Means
Building Construction Cost Data, 1995, p. 18);
	Once a drum had been returned to the point of reentry it would be handled by the normal
processing equipment, and would not incur any further "storage" costs; and
The upper limit nf material being stored in drums is 200 mt/yr. because having more than
200 drums would both be impractical and impose opportunity costs that have not been
fully accounted for (there is likely to be both a practical limit on the floor space available
to store the drums, and a cost associated with using additional floor space).
The costs of storing solid materials in drums are shown in Exhibit E-9.
Storage of Solid Materials in Roll-off Containers
The roll-off container storage cost function includes the capital cost of the containers, and the
rental of a truck to move full roll-offs first to the storage area and then to the point of re-entry. It also
includes labor, fuel, and maintenance to operate the truck.
A roll-oil container would be filled by parking it beneath a hopper or chute. It would then be
driven across the site to a storage area by a truck designed to move roll off containers. The container
would be "rolled off the truck and set on the ground. Later the container would be picked up by the truck
dnd driven back across the site to the point of re-entry and the contents dumped into a pile beside the
normal feed materials, where the material would be picked up by the normal feed handling equipment
The Agency made the following assumptions in assembling these cost functions:
The purchase price of a 20 yd1 roll-off container is S2670, a 30 yd* container is S3,045 and
a 40 yd3 container is S3.510 (from Non-RCRA Tanks. Containers, and Buildings.
December. 1996, p.27);
	The cost of shipping is S320 per container, based on a shipping cost of SI .60 per mile and
an assumed distance of 200 miles (from Non-RCRA Tanks, Containers. and Buildings,
December, 1996, p.27);
April 30. 1998

-------
! - 23
Exhibit K-'J
Annual Storage Cost Assuming Quarterly Storage of Solids in Drums
Drum Storage Cost (Solids)	Unit Cost	A	B	 C	D	E	F	G	H
Waste Quantities (ml'vr)

0-5
4
10
50
75
100
150
200
Waste Qjantilos fmt/qtr)

0.125
1
2.5
12.5
1b 75
25
37.5
50
Waslo Quantitv (aaVqtr)

24.25
194 0?
485.04
242522
3637 03
4850.44
7275.67
9/U0.89










Purchase of Drums









Number of Drums PC auarter

1
4
10
49
73
96
146
iyb
Annualized Cost of Drums
$5?/drum
4.91
19.63
49.08
240.51
358.30
481.01
716.61
957 11










Labor to Open/Close Drums









Number of Hours uer vcar

067
P.67
6.67
32.67
48 67
65.33
97.33
130.00
Annual Labor Cost
$ 19/tir
12.67
50.67
126.67
6?0.67
924 67
1241.33
1049.33
2470.00










Move Drums









Ann. Handtruck Cap;lal. Cost
$209
19.73
19.73
19 73
0.00
0.00
0.00
0.00
0.00
Ann. pallet truck Cat". Cost
$3020
0.00
0 00
0 00
285.06
285.06
285 06
285.06
28506
Numbnr of Hours  Annual

1
4
10
25
18.25
24.5
36.5
48.75
Annual Labor Cost
seo notes
19
76
190
301 35
448.95
602.7
897.9
1199.25
Annual Fuel nnrt OSM Cost
$1 SO.'hr
0
0
0
18.38
27.38
36.75
54.75
73 13










Total Annual Cost ($/vr)

56.30
166.03
385.48
1465.96
2044.35
?64R 85
3803.65
4984.55
Unit Cost (S/mt)

112.60
41 .til
38.55
29.32
27.26
26.47
25.36
24.92
April 30, 1998

-------
F-24
	The cost of a tarp is S425 (from Non-RCRA Tanks, Containers, and Buildings, December,
1996, p.25);
	The density of solid materials is the same as crushed furnace slag (85 lb/ft3):
	11 would take 2 hours to move a roll-oft container from the point of generation to the
storage area (or back from the storage area to the point of reentry);
The roll-off truck must be rented in full day inciements each time it is necessary to move a
roll-off container;
The cost of renting the roll-off truck is S500/day or $4,500/month (based on a vendor
quote of S4,500/month. and standard construction estimating practices that daily rental is a
third of weekly rental, which is a third of monthly rental);
The cost of labor to operate the roll-off truck is S22.80/hr (Engineering News Record,
10/31/94, p. 49);
The fuel and maintenance cost of the roll-off truck is $ 18.85/hr (which is the fuel and
maintenance cost of a 25 ton off-road dump truck from Means, 1995); and
Once the contents of a roll-off container had been emptied into a pile at the point of
reentry they would be handled by the normal processing equipment, and would not incur
any further "storage" costs.
The costs of storing solid materials in roll-off containers are shown in Exhibit F-10.
Storage of Solid Materials in Buildings
The building storage cost function includes the capital cost of constructing a dome style building,
such as those used by regional highway departments to store road chemicals. This cost function also
includes rental of a dump truck to move material from the point of generation to the storage area and later
to the point of re-entry, labor to operate the truck, truck fuel, and maintenance as well as the capital,
operating, and maintenance costs of a front end loader to fill the truck at the storage building. The
following is a brief description of how materials would be stored in buildings.
The dump truck would be tilled by parking it under a hopper or chute, and would then be driven
across the site u> a storage building where it would dump the material onto the pad outside the entrance to
the bailding. The front end loader would then push the material into a pile in the dome. Later the material
would be picked up by a front end loader and put back into the dump truck, be driven across the site to the
point of re-entry and dumped into a pile beside the normal feed materials, where it would be picked up by
the normal feed handling equipment.
The Agency made the following assumptions in assembling these cost functions:
April 30. 1998

-------
I; - 25
Exhibit F-10
Annual Storage Cost Assuming Quarterly Storage of Solids in Roll-Off Containers
Rolloff Storage Coal	Unit Cost	A	B	C	D	E	F	G	H
Waste Quantities {mt/Y^

50
75
100
500
1 000
2.50C
5000
7.50*"
Waste Quantities (ml/qf)

2.5
10
25
125
yso

1 VbO
1.0/:.
Wasto Quantity (v1'Vn:ri


t8
24
120
240
600
1.201
1.801
1









Purchase of Roll-olfs









Nunu>er tjf 20 yd 3 Roll-nils

1
1






Ccs! ol Roll-oils
$?670/R-utf
2.070
2.670






Numoer cf 30 vd;i Roll-alts



1





Cost ol Roll-oils
$3045/r-;f1


3.045




.
Numuer of 30 vd3 Roll-yl(s





7
16
31
46
Cost ol Roll oils
S3510/r off



14.040
24.570
56.160
108.810
161.460
lam
$4?r> each
4?r,
425
420
1.700
2.975
G.800
13.175
19.550

S320 Ea:h
320
320
320
1.280
2.240
5.120
9.920
14.720
Anmaliznd Cost of Roli-offs

322
32?
358
1.60/
2.S11
6.426
12.451
10.4/5










Rcl-oH Truck









Numhftr ol 1 nns  Annual

H
0
8
32
GC
128
24R
rrca
Number ol Rental (Javs

8
8
8
32
56
128
248
3*5
Ann jol Rontal of Roll off Truck
$500/dav
4.000
4.000
4.000
16.000
28.000



Amual Rental n( ^nll-nll 1 nuk
$45(HVr-o
0
0
0
0
0
54000
54000
54020
Number of Hours  Annual

16
16
16
64
112
256
496
7"6
Annjal Labor Cool
Sc2.8Q.rt
365
3bb
36S
1.4b
2.554
5.83/
11.309
16,/bl
Ann Fuel and Maintenance Cost
$18.85/fr
302
302
3C2
1.206
2.111
4.826
9.350
13.874










Total Annual Cost ($/v<1

4.9HS
4.989
0.0>'4
90 y 7?
35.4/0
71 088
H7.109
103.1;-*)
Unit Cost

99.77
e.c.r,2
5024
40.54
3548
?8.44
17.42
13.75
April 30, 1998

-------
F-26
	The capital cost of a building is based on the average price for dome buildings (see Tables
14, 15, and 16 of N'on-RCRA Tanks. Containers, and Buildings, December. 1996. pp. 32-
33);
	The capacity utilization of these buildings is assumed to be 80 percent, since a conveying
system is not used;
The dome will be built on an asphalt hase pad that is a square with sides equal in length to
the diameter of the building plus 20 feet;
	The cost of the asphalt pad is S6.50/yd~ (from Means Site Work 1994, p. 59);
The density of solid materials is the same as crushed furnace slag (85 lb/ft1);
The cost of purchasing a 25 short ton capacity dump truck is $275,000. The expected
lifetime of this equipment is 26.000 operating hours (vendor quote, 1996);
The fuel and maintenance cost of the truck is $18.85/hr(from Means, 1995);
	The cost of labor to operate the truck is $22.80/hr (Engineering News Record, 10/31/94. p.
49);
It would take '/i hour to drive the dump truck to the building, empty it, and return to the
point of generation;
	It would take Vi hour to drive the truck back from the storage area to the point of reentry,
and dump the contents on the ground;
The cost of renting a 7.5 yd1 capacity 375 hp front end loader is $ 1,400/day (from Means,
1995),
The fuel and maintenance cost of the front end loader is $56.15/hr (from Means. 1995);
	The cost of labor to operate the front end loader is S26.90/hr (Engineering News Record,
10/31/94. p. 49);
The front end loader can move 20 shovelfuls per hour,
The front entl loader must be rented for full days; and
	Once the contents of the dump truck had been emptied into a pile at the point of reentry
they would be handled by the normal processing equipment, and would not incur any
further "storage" costs.
The costs of storing solid materials in buildings are shown in Exhibit F-l 1.
April 30, 1998

-------
F- 27
Kxhibit F-l 1
Annual Storage Cost Assuming Quarterly Storage of Solids in Dome Buildings
BuHding Storage Cost	Unit Com	A 	BCD	E	F		G	H_
Waste Quantities imW'i

*.380
2.C48
2.660
15.800
17.952
28.448
42.072
50.7C4
Was1# Qjanlitieb fmlAjii *

315
5*2
bbb
3.950
4.4E18
7.112
10.518
12.691
Waste (XanMv ff:3'0tr)

8.948
13,279
17.248
102/49
116.403
184.460
27?.fl00
329.160
Waste Quantity ftfXJ/Q*r: '

Ml
492
639
3.734
4.311
6.83?
10.104
12.191










Capital Cost









Number o1 Buildinqs

1
1
1
1
1
1
1
1
Diameter ol LJuMnmn (ft'

40
40
50
100
100
124
150
150
size of baso oad (vd^>)

400
400
544
1.600
t .600
2.304
3.211
3.?' 1
Asphalt Pad
6 50MJ2
2.600
2.603
3.539
1C.400
10 400
14.478
?0.872
20.872
Total Cost of Buildinn

50,500
H2.500
72.OU0
121.000
134.000
190.000
343.000
381 50C
Annualized Cost of Bwldmo

r>.oi?
6.145
7/30
12.403
13.630
19.318
34.3*6
3/.UH0










Dump Truck









Number of tups  Quarter

32

60
350
31)6
r?n
W-\
1.120
Number of tik>s  annual

128
184
240
1.400
1.584
2.512
3.7" c
4.48 j
Number of hours  annual

64
92
20
700
792
1.255
1.855
L'.LMj
Lifetime of Truck

20
23
20
20
20
20
14
12
Annualizes Purcfiaso cost
$275,000
2h.tef
2b itf>7
K.Vjf
2L.9S?
25.957
25.957
"6.01 B
37.793
Annual l.abor Cost
$22 80/hr
'459
2,098
2.736
15.960
18.058
28.63/
42.317
51.072
Ann Fuk! and Maintenance Cost
$18 8Mir
1.206
1.734
2.262
13.-95
14.929
23.676
34.98b
42.224










Front End Loadar









Nuniier o' Hours (annual)

9
-3
1/
101
11S
1H2
269
?2fi
Number o' Davs 'annual^

4
4
4
12
12
20
26
36
Annual Rental
$1.400/(Jv
5.600
5.600
5.600
16.800
16.800
28.000
39.200
50,400
Arnual Labor Cost
$*> 90/hr
2nn
:m
4f>fl
?.7 ??
3 093
4.901
7.248
8,745
Arn. Fuel and Mamtenanco Cost
$ 50 15/h-
496
736
0b/
5.681
6.455
10.230
15.129
18254










Total Annual Cost (S/vr)

39.<*>9
42,623
45.' 00
92.718
98 922
140.748
209.243
246,469
Unit Cost (S/mt)

2d 96
2C.81
16.95
5.87
5.51
4.95
4.97
4 85
April 30, 1998

-------
F-28
Storage of Solid Materials in Unlined Waste Piles
The waste pile storage cost function includes land, the costs of a dump truck to move the
material to the storage site and back, and a front end louder to move the material at the pile. The following
is a brief description of how solid materials would he stored in waste piles.
A durftp truck would be filled by parking it under a hopper or chute, and would then be driven
across the site to a waste pile where it would dump the material (either on the lined site directly, or onto a
conveyor system). Later, the material is picked up by a front end loader, put back into the dump truck,
driven across the site to the point of re-entry, and dumped into a pile beside the normal feed materials,
where it would be picked up by the normal feed handling equipment.
EPA made the following assumptions in assembling these cost functions:
	The purchase cost of land is 52,500/acre (from CKD Monofill Model Cost
Documentation, 1995);
	The cost of compacted soil is $0.2325/ft' (from CKD Monofill Model Cost
Documentation, 1995);
	The necessary land area is determined by assuming the material is stored in a conical pile
with a maximum height of 100 ft, where the height of the pile is V? the radius and the
volume of the pile is calculated using the following formula: V = l/37trh;
	The length of a side of the square plot for a single pile is the twice the radius plus a ten
foot buffer zone around the edge of the pile to move equipment; therefore, the area of the
pile is [2*(r+10)]i;
	The area of the square plot for multiple piles is calculated by assuming that the volume to
be stored is equally divided by the number of piles, then adding the area of each individual
pile with its buffer zone (to allow equipment to move between the piles);
	The density of solid matenals is the same as crushed furnace slag 185 lb/ft1);
	The cost of purchasing a 25 short ton capacity dump truck is S275.000. The expected
lifetime of this equipment is 26.000 operating hours (vendor quote, 1996):
	The fuel and maintenance cost of the truck is 518.85/hr (from Means, 1995);
 The cost of labor to operate the truck is 522.80/hr (Engineering News Record. 10/31/9-1, p.
49);
	It would take Vi hour to drive the dump truck to the waste pile, empty it, and return to the
point of generation;
	There is no cost associated with a conveying system at the waste pile:
April 30, 1998

-------
F-29
	It would take 'A hour to drive the truck back from the storage area to the point of reentry,
and dump the contents on the ground;
The cost of reming a 7.5 yd' capacity 375 lip front end loader is S1,400/day (from Means,
1995 s;
%
 The fuel and maintenance cost of the front end loader is $56.l5/hr(from Means, 1995);
	The cost of labor to operate the front end loader is $26.90/hr (Engineering News Record,
10/31W, p. 49);
	The front end loader can move 20 shovelfuls per hour;
	The front end loader must be rented for full days; and
	Once the contents of the dump track had been emptied into a pile at the point of reentry
they would be handled by the normal processing equipment, and would not incur any-
further "storage" costs.
The costs of storing solid materials with no free liquids in waste piles are shown in Exhibit F-
12. EPA developed the costs of just the operation and maintenance costs of storing materials in unlined.
unmonitored units for baseline option combinations that induce a change of storage units from land based
to non-land based units (i.e , storing sludges in the prior treatment baseline and in RCRA containment
buildings in Option 1). The O&M costs of storing materials in unlined, unmonitored piles are shown in
Exhibit F-13.
F.5 Storage of Liquid Materials
Storage of Liquid Materials in Drums or Mobil* Mini-Bulk Tanks
Low volumes of liquid materials can be stored in either drams or mnhile mini-bulk container^,
which are small tanks that are designed to be moved by a pallet truck. The costs associated with storing
liquid materials in drums are calculated in same manner as storing solid materials in drums, with the
following exceptions:
	Liquid materials are stored for 30 days, while solid materials are stored for 90 days.
Therefore, fewer drums are required;
 Because liquid materials are often corrosive, polyethylene drums and mini-hulk containers
are used;
	The density of liquid materials is the same as water (62.4 lb/ft );
The capital cost of a 55-galIon polyethylene dram is S127 (from Non-RCRA Tank?.
Containers, and Building. December 1996, p. 17. This price includes S2 per drum for
freight);
April 30, 1998

-------
F - 30
Exhibit F-12
Annual SlonijjL' Cost Assuming Quarterly Storage of Solids in Unlined, Unmonitored Waste Piles
Waste Pil - Free Liquids	Unit Cost	A	8	C	D	E	F	G	H
Waste Quantities (rn:/vr)

500
5.000
15.000
25,000
40.000
70.000
90.000
120.00C
Waste Quantities (mt/qtr)

125
1.250
3.750
6,250
10.000
17.500
22.500
30,000
Waste Qjuntitv (ft3'n:r)

3.242
32.421
97,262
162.103
259.365
453.888
583.5/1
7 7H.094
Waste Quantitv (vd3/qtr)

120
1.201
3.602
6.004
9.606
16.811
21.614
2H.81B










Untt Construction









Unit si/e (ft2)

3.218
9.825
17.987
24.118
31.772
44.394
51.693
61.619
Annualized Land (S/vr)
S2b00/acre
17
53
97
131
172
240
200
334
Unit base 'compacted soil'
$0 ?3?fvtn
71
216
395
529
697
974
1.134
1.35?










Dump Truck









Number of trios - auarter

12
11?
33?
552
882
1.544
1.986
2.646
Number of trios - anrual

48
448
1.328
2.208
3.528
6.176
7.944
10.584
Number of hours - annual

24
224
664
1,104
1.764
3.088
3.9/?
b.292
Number of Oriainal Trucks Needed

1
1
1
1
1
2
2
?
Lifetime of TrucMs)

20
20
20
20
15
17
13
10
Total Number of Trucks Needed

1
I
1
1
2
4
4
4
Annualized Purchase cost
$275,000
25.957
25.957
25.957
25.957
35.533
68.529
73.324
70.617
Annualized Labor Cost
$22.80/hr
54/
5,10/
15.139
25.171
40.219
70.406
90.562
120.658
Ann. Fuel and Maintenance Cost
$1 B.R5/hr
452
4,22 2
12,516
20,810
33.251
58.209
74.872
99.754










Front End Loader









Number of Hours (annual';

3.20
3? 02
96.06
160.10
256 16
448.28
576.37
768.49
Number of Davs (annual)

4
8
16
24
36
60
76
100
Annual Mental
$i.400/dav
5.600
11.200
22.400
33.600
50.400
84.000
106.400
140.000
Annual Labor Cost
$26.90rtir
86
361
2.584
4.307
6.891
12.059
15.504
20.67?
Ann. Fuel and Maintenance Cost
$56 15/hr
180
1.798
5.394
8.990
14.384
25.171
32.363
43.15t










Total Annual Cost {SNt)

32,9!1
43.415
84,483
119,495
181,547
319589
394.439
504,538
Unit Cost

65.82
9.88
5.63
4.78
4 54
4.57
436
4.20
April 30, 1998

-------
F - 31
Kxhibit F-13
Annual Storage Cost (O & M only) Assuming Quarterly Storage of Solids in Unlined, Unnionitored Waste Piles
Waste Pile - Free Liquids	Unit Cost	A	B	C	D	E	F	G	H
Waste Quantities frnt/vr)

500
5.000
15.000
25,000
40.000
70,000
90.000
120.000
Waste Quantities (mt/qtr)

125
1.250
3.750
6.250
10.000
17.500
22.500
30,000
Waste Qjantitv (fl3'atrl

3.242
32.421
97.262
162. -03
259.365
453.888
5:i.hf1
7 78.094
Waste Quantitv (vd3/citr)

120
1 201
3.602
6.004
9.606
16.811
21 614
28,818










Unit Construction









Unit size (ft?)

3,218
9.825
17.987
24.118
31.772
44.394
51.693
61.619
Annualized Lind (S/vr)
$25U0/acre








Unit base (compacted soil)
$0.?3?5/f!3


















Dump Truck









Number of trios - Quarter

12
11?
rw?
552
882
1,544
1.986
2.646
Number of tries - annual

48
448
1.328
2.208
3.5?8
6.176
7.944
10,584
Number of hours - annual

24
224
664
1J04
1.764
3.088
3.972
5.292
Number ol Oriainal Trucks Needed

1
1
1
1
1
2
2
2
Lifetime of Trjckfsi

20
20
20
20
15
17
13
10
Total Number of Trucks Needwd

I
1
1
1
2
4
4
A
Annualized Purchase cost
S275.000
25.957
25.957
25.957
25.957
35.533
68.529
73.324
78.617
Annuaiizod Labor Cost
S22.HU/hr
547
5.107
15.139
25.171
40.219
70.406
90.562
120,658
Ann. Fuel and Maintenance Cost
$18.8S/hr
452
4,222
12.516
20.810
33.251
58.209
74.872
99./r.4










Front End Loader









Number of Hours (annual

3.2D
3? 0?
96 OR
160.10
256.16
448.28
576.37
768.49
Number of Davs (annual)

4
8
16
24
36
60
76
100
Annual denial
Si ,400/dav
5.600
11,200
22.400
33.600
50.400
84.000
106.400
140.UC0
Annual Labor Cost
$26 90/tir
86
861
2.584
4.307
6.891
12.059
15.504
20,672
Ann. Fuel and Maintenance Cosl
$56.15/hr
181)
1.798
5.394
8.990
14.384
25.171
32.363
43,151










Total Annual Cost (S/vr)

32.823
49,146
83.991
118,835
180.678
318.374
393.025
502,852
Unit Cost (S/mt)

65.65
9.83
5.60
4.75
4.52
4.55
4.3/
4 19
April 30, 1998

-------
F-32
	The capital cost of a 220-gallon polyethylene mini-bulk tank is $285 (from Ncn-RCRA
Tanks. Containers, and Building. December 1996, Appendix D); and
A laborer could move mini-bulks from point of generation to the storage area (or back
from the storage area to the point of reentry) using a pallet truck at a rate of 4 tanks per
hour:
The costs of storing liquid materials in drums and mobile mini-bulk tanks are shown in
Exhibit F-14.
Storage of Liquid Materials in Tanks
The tank storage cost function includes the capital cost of the tanks, as well as piping to move
the liquids from the point of generation to the storage area and then back to the point of re-entry. Liquid
materials would be piped from the point of generation to storage tanks. Prior to reuse, these materials
would be piped back through the same pipes to the point of re-entry, where they would be handled by the
normal feed dispersing equipment.
The Agency made the following assumptions in assembling the tank storage cost function.
	Liquids are stored for a maximum of 30 days;
The density of liquid materials is the same as water (62.4 lb/ft^);
	Tank capital and O & M costs were developed following the method u>ed by DPRA for
the "Organic Dyes and Pigments Waste Listings Document," 199"!, and include the
minimal plumbing associated with the tank only;
For tanks with a capacity of or less than 25,000 gallons, the base capital cost was updated
using the price of a single walled vertical tank (l rom Non-RCRA Tanks. Containers, and
Building. December 1996, p. 22.)
	Tor tanks greater than 25,000 gallons EPA used the cost from the "Organic Dyes and
Pigments Waste Listings Document" (these costs were adjusted to use the correct discount
rate and retention time);
The distance from the point of generation to the storage tank, and from the storage tank
back to the point of reentry are a function of the amount of material to be stored. Small
volumes of liquid material to be stored do not require additional piping, while large
volumes of material to be stored will need to be piped to storage areas further away;
	There is no cost associated with pumping the material to and from the lank; and
Once the liquid has been returned to the point of reentry it will be handled by the normal
processing equipment, and would not incur any further "storage" costs.
The costs of storing liquid materials in tanks are shown in Exhibit F-15.
April 30. 1998

-------
W"
F - 33
Exhibit F-14
Annual Storage Cost Assuming 30 Day Storage of Liquids in Drum and Mini-Bulks
Drum Storage Cost (liquids) Unit Cost A	B	C	D	E 	F	 G 	H
Waste Quantities (mt/yr)

O.b
10
50
75
100
150
200
250
Waste Quantities (mt'mo)

0.042
0 833
4 167
6250
8 333
12.500
16.667
20 833
Waste Quantity (qal/mo) 

11.01
220 24
1101 ?0
1651 79
2202.39
3303.59
4404.78
5505.98










Purchase of Drums









Number of Drums

1
5
0
0
0
0
0
0
Annualized Cost of Drums
$127/drurn
127.00
635.00
0 00
0 00
0.00
0.00
0.00
0.00
Number of 220-qallon Mini-bulks

0
0
6
8
11
16
21
26
Cost of Mini-bulk
$285/tank
0.00
0.00
1881 00
2508.00
3448,50
5016.00
6583.50
8151.00
Annualized Capital Cost

11.99
59.94
177 55
?36 73
325 50
473.46
621.42
769.37










Labor to Open/Close Drums









Number of Hours per voar

2
10
.
.
-
-
-
-
Annual Labor Cost
SI 9/hr
38
190


-
.
.
.










Move Drums









Ann. Handtruck Capital. Cost
$209
19.73
19./3
0.00
0.00
0 00
0.00
0 00
0.00
Ann. Pallet Truck Cao. Cost
$3020
0
0
285
285
285
285
285
28b
Number of Hours - Annual

1
5
12
16
22
3?
42
52
Annual Labor Co;;t
SI 9/hr
19
95
228
304
418
608
798
988
Ann. Tuel and Maintenance Cost
31.5/hr
0
0
18
24
33
48
63
78










Total Annual Cost ($/vr)

88.72
364.67
708.61
849 79
1061.56
1414.52
1767.47
2120.43
Unit Cost ($/mtl

177.43
36.4/
14.17
11.33
10 62
9.43
8.84
8.48
April 30. 1WX

-------
F - 34
Exhibit F-15
Annual Storage Cost Assuming 30 Day Storage of Liquids in Tanks
Tank Storage Cost (Liquids) Unit Cost ABC	D	E 	F
Waste Quantities (mt'vr)

45 4
227.0
1,135.1
22,70? 6
90,810.4
181.620.7
Waste Quantity (aal/vr)

12.000
60,000
300,000
6.000.000
24.000,000
4fl.000.000
Waste Quantity (ual/ino)

1,000
5.000
25.000
500.000
2,000,000
4.000.000
Waste Flow rate (nal/davl

33
167
033
16.667
66,667
133,333








Purchase of Tanks







Number ot tanks

1
1
1
1
1
1
Cap. Cost ot Double Walled Tanks

1.246
3,466
9.405



Frciqht and Installation

374
1.040
2.822



Indirect Capital

518
1,442
3,912



Annualized Cost of Tanks

202
561
1,523
9.318
23,897
40.604
Annual O & M

141
393
1.065
6,515
16.710
28.392








Piping







Lenqth ot additional pipe (ft)



.
500
1.000
1,000
Piping - Annualized Capital


.
.
425
821
821
Piping - Annual O & M

-
.
-
1,000
1,000
1,000








Total Annual Cost ($/vr)

343
954
2,589
17,258
42.428
70,817
Unit Cost ($/mt)

7.55
4.20
2.28
0.76
0.47
0.39
April 30, 1998

-------
K-35
Storage of Liquid Materials in Unlined Surface Impoundments
The surface impoundment storage cost function includes the capital cost of land, site
preparation, a liner, and piping of liquids to the surface impoundment. Liquid materials would be piped
from the point of generation to the surface impoundment. When these materials are going to be reused
they would be piped back through the same pipes to the point of reentry, where they would be handled by
the normal feed equipment.
The Agency made the following assumptions in assembling the surface impoundment storage
cost function:
	Liquid materials are stored for a maximum of 30 days;
	The density of liquid materials is the same as water (62.4 lb/fr );
	The purchase cost of land is S2500/acre (from CKD Monofill Model Cost Documentation,
1995):
The cost of excavation is SO. 1077/ftJ (from CKD Monofill Model Cost Documentation,
1995):
	The area of the surface impoundment is calculated using the formulas described in section
D.7 of the April 15, 1997 R1A;
	The distance from the point of generation to the surface impoundment, and from the
surface impoundment back to the point of reentry, are a function of the amount of material
to be stored, but the minimum distance is 500 feet. Larger quantities of material to be
stored will need to be piped 1000 feet away.
	There is no cost associated with pumping the material to and from the surface
impoundment: and
Once the liquid lias been returned to the point of reentry it will be handled by the normal
processing equipment, and would not incur any further "storage" costs.
The costs of storing liquid materials in unlined surface impoundments without groundwater monitoring arc
shown in Exhibit F-16 In addition. EPA developed the costs of just the operation and maintenance costs
of storing materials in unlined, unmonitored units for baseline-option combinations that induce a change of
storage units from land based to non-land based units (i.e., storing by-products in the prior treatment
baseline and in RCRA tanks in Option 1). The O & M costs of storing materials in unlined, unmonitored
surface impoundments are shown in Exhibit F-17
Storage of Liquid Materials in Seven Day Surge Tank
The cost- of storing liquid materials in a seven day surge tank are shown in Exhibit F-18 Ttiese
costs are similar to the costs of storing liquid materials in a 30 day accumulation tank with one notable
exception, the length of storage is seven days rather than 30.
April 30, 1998

-------
F-36
F.6 Curve Fit Cost Functions
The Agency plotted and curve fit each set of cost results (from Exhibits F-9 through F-1S) to
transform the costs into cost functions. Exhibit F-19 presents these curve fit storage and disposal cost
functions, along with the range for winch these cost equations are valid. EPA determined the break-ven
points between the relevant storage methods for each Baseline or Option Exhibit F-19 also presents the
optimum management ranges allowed under each baseline and option. Cells in this exhibit which have
been blacked out under a particular option or baseline arc unallowable management methods. Finally,
Exhibits F-20 through F-28 present graphs of the individual cost for our sample waste generation rates
along with the resulting curve fit cost functions.
April 30, 1998

-------
F- 37
Kxhibit '-16
Annual Storage Cosl Assuming 30 Day Storage of Liquids in Unlined, llnmonitored Surface Impoundments
Surface Impoundment	Unit Cost ABC	D	E 	F		G 	H
Waste Quantities (mt'yr)

5C0
5,000
25,000
50,000
100,000
500,000
1,000,000
2.000,000
Waste Quantities (mt'rno)

42
417
2,083
4,167
8.333
41,667
83.333
166.667
Waste Quantity 
-------
F - 38
Kvhibit F-17
Annual Storage Cost (O & M only) Assuming 30 Day Storage of Liquids in Unlined, llnmonitored Surface Impoundment
Surface Impoundment	Unit Cost ABC	D	E 	F 	G 	H
Waste Quantities (mt'vfl

500
5.000
25,000
50,000
100,000
500.000
1,000,000
2,000,000
Waste Quantities (mt/mo)

42
417
2,083
4,167
8.333
41.667
83,333
166.6G7
Waste Quantity (ft3/mo)

1,472
14,721
('3.604
147.209
294.418
1,472 089
2,944,177
5,888.355
Waste Quantity (oal/mo)

11,012
110.120
550,598
1,101,196
2,202.392
11,011 959
22,023,919
44,047.837
Waste Quantity (qal/day)

367
3,671
18.353
36.707
73.413
367.065
734,131
1,468,261










Unit Construction









Unit size (1t2)

4.061
6.410
15,688
26,478
47.192
204,364
395,890
774.557
Unit size (acres)

0.09
0.15
0.36
0.61
1.08
4.69
9.09
17 78
Annualized Land ($/vr)
$2bOU.'acre








Annualized Excavation
$0.17077/ft3


















Material Handlinq









Distance: to Unit (ft)

500
500
L>00
500
1,000
1.000
1,000
1,000
Piping - annualized capital









Pipinq  annual 0 & M

1,000
1.000
1,000
1,000
1,000
1.000
1.000
1.000










Total Annual Cost ($/yr)

1,000
1.000
1,000
1,000
1,000
1,000
1,000
1,000
Unit Cost ($/mt)

2.00
0.20
0.04
0 02
0.01
0.00
0 00
0.00
April 30, 1998

-------
h - 39
Exhibit F-18
Annual Storage Cost Assuming 7 Day Storage of Liquids in Surge Tank
Tank Storage Cost (Liquids) Unit Cost A	B	C	D	E 	F
Wiisle Quantities (int/vr)

197
984
4,919
98,378
393.512
787.023
Waste Quantilv laal/vr)

52.000
260,000
1.300,000
P6.000.000
104,000.000
208.000.000
Waste Quantity (aat/week)

1,000
5,000
25.000
500.000
2.000.000
4.000.000
Waste How rate (qal'dav)

143
714
3,571
71,429
285,714
571,429








Purchase of Tanks







Number of Tanks

1
1
1
1
1
1
Annualized Cost of Tanks

796
1.892
3.307
9.318
23.897
40.604
Annual OS M

55G
1,323
2.313
6.515
16.710
28.39?








Pipinq







Length of additional pipe (ft)


-
-
500
1.000
1.000
Pipinn  Annualized Capital

.
.
-
425
821
8? I
Pioina  Annual 0 & M

.
.
.
1,000
1.000
1.000








Total Annual Cost (S/vr)

1,352
3,215
5,620
17,258
42.428
70,817
Unit Cost ($/mt)

6.87
3.27
1.14
0.18
0 11
0 09
April 30. 1998

-------
I- - 40
Exhibit F-19
Relevant Ranges of Use for Curve Fit Cost Functions
Solids
Equation
Range
NPT, MPT
PT SL/BP
PT SM
Opt. 1
Opt. 2
Drums  solid
V = 24.589x + 132.23
0.5 -200
0 - 200
0 - 200
0-200
0 - 200
0 - 200
Roll-off
V = - 0.0022xn2 + 29.272X +4840.9
50-7500
200 - 935
200 - 935
200- 1343.1
200- 1343 1
200 - 935
Buildinu
V - 0.00002x^2 t 3.2395X - 35800
1300-51000

1343.1 + +
1343.1 ++

Unlined Pile
V=4 0335X~ 26522
500 - 120.000
935 ++
935 ^

Unlined Pile - O $ M
V = 4.0207x +26271
500- 120,000
935++
935 ++








Disoosal Pile
V = 1.8703x + 12308
50 -500000





























Liquids







Drum
V = -0.0074xA2+9.4798x+189.34
0.5 - 250
0-220
0-220
0-220
0-220
0-220
Tanks
V = -9e-7xA2 -r 0 5bx + 1795.7
45 - 200000
220-500
220-500
220++.
220 - 1 million
220-500
Unlined SI
V = 0.05x + 1565.9
500 - 2000000
500++
500 r +

500++
Unlined SI (O & M)
V= 1000
500 - 2000000
500-+
500++
500++
April 30, 1998

-------
F-41
Kx libit F-20
Storage of Solids in Drums






y - 24.589X
RJ0.
+ 132.23
>984











<




~




0	50	100	150	200	250
Waste Quantity (mt/yr)
April 30, 1998

-------
F - 42
Exhibit K-21
Storage of Solids in Roll-off
120,000
100,000
.0022X1 ~ 2t.27Jx ~ 4640.0
R* - 0.911^
BO.000
60,000
m
o
o
40,000
20,000
0
1000
2000
3000
8000
4000
6000
7000
6000
April 30. 1998

-------
l; - 43
Exhibit F-22
Storage of Solids in Dome Buildings
250,000
200.000
y = 2E-05X2 + 3395x + 35800
R2 = 0 !>3
150 000
8
o
100.000
40,000
50,000
60,000
30.000
10.CO0
20,000
Waste Quantity (mt/yr)
April 30, 1998

-------
'
F- 44
Exhibit F-23
Storage of Solids in Unlined Piles
600,000
4.0336k ~ 2*922 !
r1 i o.wr>^t
600,000
400,000
>
p
o
200,000
100,000
20,000
40,000
60,000
Watt* Quantity (mt/yr)
April 30, 1998

-------
m***"
F - 45
Exhibit K-24
Storage of Solids in Unlined Pile (O & M only)
909,000
y - 4.0207x * 2(271
	
400,000
Ib

~ 300,000
o
o
200,000
100,000
20,000
100,000
120,000
40,000
60,000
0,000
Watte Quantity (mt/yr)
April 30, 1998

-------
IPW""
F - 46
Exhibit -25
Storage of Liquids ia Drums/Mini-Bulks
2,500.00
2,000.00
 I.47MX ~ 160.34
 0.1021
1,500 00
o
o
1,000.00
500.00
160
200
250
50
100
0
Wftstft Quantity (mtfyr)
April 30, 1998

-------
P"""
F - 47
Exhibit F-26
Storage io Tanks
70,000
0,000
y - -te-07 C ~ 0.M* ~
R1  0.9067
30.000
20,000
10,000
200,000
140,000
100,0M 10,000
20,000
40,000
100,000
120,000
M,000
60,000
Waste Quantity (mt/yr)
April 30, 1998

-------
PF*"'"
F- 48
Exhibit F-27
Storage of Liquids in Unlined Impoundments
100.000
80,000
60,000
40,000
20,000
290,000 400,000 $00,000 tOO.OOO 1,000,000 f,20t,000 1,400.0*0 1 ,#00,000 1,100.000 2,000.000
Wast* Quantity (mt/yr)
April 30, 1998

-------
I- - 49
Exhibit K-28
Storage of Liquids in Sewn Day Accumulation Tank
80,000
70,000
0.1175X +3(79.5
0.9962
60,000
50,000

M
O
u
40,000
20,000
10,000
BOO,000
100.000
200,000
300.000
500,000
600,000
700,000
400,000
Quantity (mt/yr)
April 30, 1998

-------
EXPLANATION OF COST MODELING CALCULATIONS
APPENDIX G
This appendix describes the cost modeling assumptions and procedure used by EPA in developing
cost estimates suppurting the final RCRA Phase IV Land Disposal Restrictions (LDR) cost and economic
impact analyses for mineral processing wastes EPA performed the cost modeling was performed in six
steps, hirst, EPA manipulated the input data to determine the portion of each waste stream that is
considered to be hazardous. Second, EPA divided the hazardous portion of each waste stream into a
portion of material sent to treatment and disposal, and a portion stored prior to recycling. Third, EPA used
these portions of material to determine the average facility and total sector costs associated with treatment
and disposal. In the fourth step, EPA calculated the average facility and total sector costs associated with
storage prior to recycling. Fifth, EPA calculated administrative costs for each sector. Finally, the costs
attributable to this rule were calculated by subtracting the cost of the. baseline from the cost of each
regulatory option. Appendix H presents a detailed example of the cost model calculations for the titanium
and titanium dioxide sector.
Determine Portion of Waste Stream Considered to Be Hazardous
To account for the uncertainty in the data caused by the lack of documented information on both
waste characteristics and recyclability. F.PA developed a range consisting of minimum, expected, and
maximum value estimates of waste volumes potentially affected by the various options. Then EPA
weighted these volume estimates for each waste stream to account for the degree of certainly that the
particular waste stream exhibited one or more of the RCRA hazardous waste characteristics.
As shown below in Exhibit G-l, EPA used a matrix to account for the uncertainty in waste
characterization. Each waste stream was assigned a multiplier in each costing scenario (i.e., minimum,
expected, and maximum) based on the whether the waste stream was known to be hazardous (Y) or only
suspected to be hazardous (Y?). Therefore, in the expected value case, if a waste stream was only
suspected to be hazardous, only half of it was counted in the analysis and the rest was assumed to be non-
hazardous. In the minimum value scenario, the stream would drop out of the analysis, and 111 the
maximum value ca^e the entire stream would be analyzed as if it was known to be hazardous.
Determine Portion of Waste Stream Sent to Treatment and Disposal and the Amount Recycled
EPA also used a set of matrices to divide the hazardous portion of each waste stream into a
component sent to treatment and disposal and a component stored prior to recycling. EPA used [he tables
in Exhibits G-2 and G-3 to determine each of these portions for the appropriate baseline or option For
example, in the modified prior treatment baseline, 15 percent of the hazardous portion of a waste believed
lo be fully recyclable (Y?) is assumed to be sent to treatment and disposal while 85 percent of the
hazardous portion is assumed to require storage prior to recycling.
April 30, 1998

-------
G-2
Exhibit G-l
Portion of Waste Stream Considered to Be Hazardous (Percent)
('listing Scenario '
Hazard Characteristic(s)
Y
Y?
Minimum
100
0
Kxpccted
100
50
Maximum
100
100
where:
Y means that EPA has data demonstrating thai the waste exhibits one or more of the RCRA hazardous
waste characteristics; and
Y? means that EPA. hased on professional judgment, believes that the waste may exhibit one or more of
the RCRA hazardous waste characteristics.
Exhibit G-2
Proportions of Waste Streams Treated and Disposed
(in percent)
Baseline or Option
Percent Recycled
.Certainty of Recycling
Y Y? YS YS? N
Prior Treatment (SL/BP)
0
15
25
80
100
Prior Treatment (SM)
0
25
35
85
100
.Modified Prior Treatment
0
15
25
80
100
No Prior Treatment
0
100
60
100
100
Option 1 from PT
0
25
35
85
100
Option 2 from PT
0
15
25
80
100
| Option 1 from MPT
0
25
35
85
100
1 Option 2 from MPT
0
:5
25
80
100
J Oplion 1 from NPT
0
30
40
85
iOO
I Option 2 from NPT
0
15
25
80
100
Notes:
Y means that EPA has information indicating that ".he waste stream is :ully recycled.
Y? means that EPA. based on professional judgment, believes that the waste stream could be fully rcc.VL.ed.
YS means that EPA has information in
-------
G-3
Exhibit G-3
Propnrti(ins of Waste Streams Stored Prior to Recycling (in percent)
Baseline or Option
Percent Recycled J
Certainty of Recycling |
Y Y? ' YS " YS? N [
Prior Treatment (SL/BP)
100
85
75
20
0
Prior Treatment (SM)
100
75
65
15
0
Modified Prior Treatment
100
85
75
20
0
No Prior Treatment
100
0
40
0
0
Option 1 from PT
100
15
65
15
0
Option 2 from PT
100
85
75
20
0
Option 1 from MPT
100
75
65
15
0
Option 2 from MPT
100
85
75
20
0
Option 1 from NPT
100
70
60
10
0
Ontion 2 from NPT
100
85
75
20
0
Notes:
Y means that EPA has information indicating that the waste stream is fully recycled.
Y? means that EPA. based on professional judgment, believes that the waste stream could be fully recycled.
YS means that EPA has information indicating that a portion of the waste stream is fully recycled.
YS? means that EPA, based on professional judgment, believes that a portion of the waste stream could he fully
recycled.
PT -- Prior Treatment Baseline
MPT - Modified Prior Treatment Baseline
NPT -- No Prior Treatment Baseline
SL -- RCRA Sludge
BP-- RCRA By-Product
SM - RCRA Spent Material
Calculate Treatment Cost
"Model facility" generation rates of each type of waste sent to treatment (i.e.. wastewaters, wastes
with 1 to 10 percent solids, and wastes with more than 10 percent solids) were computed in each sector by
summing the total sector quantities of each waste type sent to treatment and dividing by the maximum
number of affected facilities in each costing scenario. These data can be found in the input data tables of
tiie Cost Model. These "model facility'' generation rates of each type of waste were used to first determine
whether wastes would be treated on- or off-site and then to determine the cost associated with their
treatment. EPA assumed that the most efficient means of treating a number of waste streams was to
commingle these streams and build a single treatment facility on-site. This treatment system would
sequentially treat each type of waste by first neutralizing liquid streams (wastewaters and wastes with 1 to
10 percent solids), precipitating the metals in these liquid streams, dewatering the residue from
precipitation, stabilizing both the residue from dewatering and any solid wastes, and disposing ol the
stabilized mass. As indicated, each step in the process would generate a residue requiring further treatment
or disposal. Therefore, EPA calculated the total quantity requiring neutralization and precipitation (100
percent of the liquid streams), the quantity being dewatered (15 percent of liquid streams), the quantity
April 30, 1998

-------
G-4
being stabilized (15 percent of the quantity being dewatered, which equals 2.25 percent of the total
quantity of liquid streams, plus 100 percent of solid streams), and the quantity being disposed (146 percent
of the quantity being stabilized, which equals 3 29 percent of the total quantity of liquid streams, plu< 146
percent of the total quantity of solid streams). If the quantity requiring neutralization was below 350 mt/yr,
F.PA assumed that the waste would be sent off-site for treatment. If the quantity requiring stabilization was
below 3,163 mt/yr, EPA assumed that the waste would be sent off-site for treatment and disposal. These
quantities represent economic break-even points for on-site and off-site application of each management
practice.
EPA then applied these estimated quantities to the treatment and disposal costing Functions
described in Appendix F to estimate "model facility" treatment costs for each baseline and option The
model facility cost was then multiplied by the maximum number of affected facilities in each sector, to
determine the total sector cost. EPA calculated the incremental total sector treatment and disposal cost by
subtracting the total sector baseline treatment and disposal cost from the total sector post-rule treatment
and disposal cost.
Calculate Recycling Costs
Recycling costs are specific to each waste stream, based on the assumption that it is important not
to commingle materials prior to reclamation. Quantities of individual streams destined for recovery were
therefore not totaled.
EPA assumed that the only costs associated with recycling wastes are the costs of constructing and
operating storage units. For each waste stream, EPA used the quantity (proportion) of each waste stream
that is recycled to calculate storage costs for the three baselines and three options. EPA then multiplied the
average facility recycling cost by the number of facilities generating that waste stream to calculate the total
sector cost for each waste stream The total sector costs were then added for each waste stream to
determine the total sector recycling cost in each baseline and post-rule option EPA then calculated the
incremental total sector storage costs by subtracting the total sector baseline recycling storage costs from
the total sector post-rule option recycling storage costs.
Calculate Administrative Costs
Administrative costs also are specific to each waste stream. For each waste that is known not to be
recycled (N recycling status) and therefore requires treatment and disposal, there is a one-time cost of $935
to develop a waste analysis plan, and an annual testing cost of $470 For each waste that is known to be
fully recycled (Y recycling status), there is a one-time notification cost of $100.' Wastes that are partially
recycled and partially treated/disposed (Y'\ YS. and YS'1 recycling status) incur all three administrative
oosK Nute that in the minimum value case, wastes w ith Y? hazard certainty are assumed to not be
hazardous Therefore, in the minimum value case, wastes with Y? hazard certainty do not incur any
administrative costs. EPA calculated a total administrative cost for each waste stream by multiplying the
appropriate adfhinistrative costs by the number of facilities generating the waste stream. Administrative
costs for all waste streams in the sector were then summed to obtain a total sector administrative cos:.
'Costs derived from Supporting Statement for EPA Information Collection Request 1442.H Land
Disposal Restrictions - Phase IV- Treatment Standards for Wastes from Toxicity Characteristic Metals,
Mineral Processing Secondary Materials, and the Exclusion of Recycled Wood Preserving Wastewaters,
April 1998.
April 30, 1998

-------
Calculate Total Sector Costs and Impacts
Finally, EPA calculated the total sector costs by adding the total sector incremental treatment and
disposal costs, total sector incremental recycling costs, and total sector administrative costs. EPA divided
this total sector cost by the number of facilities to determine the average facility cost. EPA then divided
the total sector costs by the value of shipments to determine the screening-level economic impact estimates
in each sector
April 30, 1998

-------

-------
MINERAL PROCESSING COST MODEL EXAMPLE CALCULATION:
TITANIUM AND TITANIUM DIOXIDE SECTOR	APPENDIX H
This appendix presents a stepwise example of how the mineral processing cost model calculates
the cost of this rulemaking for Option 1 assuming the Modified Prior Treatment baseline for the sector
producing titanium and titanium dioxide.1 The intermediate quantities and cost results presented in this
appendix are calculated using the same methodology as used by the cost model. These quantities urul
results differ slightly from those found in the cost mode! printouts due to rounding.
The appendix is divided into six sections, each of which describes one important facet of the data
or calculations used in the cost model. The first section reviews the input data required for cost
calculations. The second section shows how the input data are manipulated for use in later cost
calculations. The third section presents calculations of treatment costs. The fourth section presents
calculations of storage costs The fifth section presents calculations of administrative costs. Finally, in the
sixth section, the incremental treatment and storage costs are combined, along with administrative costs, to
obtain the total incremental sector cost.
H.l. Review of Input Data
This section reviews the five types of input data used to calculate the cost of this rulemaking to the
titanium and titanium dioxide mineral processing sector:
1.	Waste stream generation rates;
2.	Hazardous characteristics;
3.	Certainty of recycling;
4.	Physical form (i.e. wastewater, waste with 1 to 10 percent solids, or solid); and
5.	Former regulatory classification (i.e., by-product, spent material, or sludge)
These data are used to calculate sector costs as described in later sections of this appendix.
H.l.l Waste Stream Generation Rate and Number of Wiiste-Goncrating Facilities
The titanium and titanium dioxide mineral processing sector generates eight waste streams
Exhibit H-l shows the number of waste generating facilities and the total sector waste stream generation
rates for each of these eight waste streams. The number of facilities generating each waste stream varies,
ranging from one facility producing scrap milling scrubber water to seven facilities generating waste water
treatment plant (WWTP) sludges or solids. EPA obtained data on the generation rate for two of the eight
streams (spent surface impoundment solids and WWTP sludges or solids). For the six waste streams for
which dais were unavailable, EPA estimated a minimum generation rate, an expected generation rate, and
a maximum generation rate.
1 For the purpose of simplicity, this section only describes calculations for the Modified Prior
Treatment baseline and Option 1. Calculations for all of the other baselines and the other option follow the
same pattern as described below.
April 30, 1998

-------
H-2
Exhibit H-l
Waste Stream Generation Rates
Titanium
Waste Stream
Number of
Facilities
Estimated or Reported Generation
(mt/yr)
Minimum
Expected
Maximum
Pickle Liquor and Wash Water
3
2,200
2,700
3,200
Scrap Milling Scrubber Water
1
4,000
5.000
6,000
Smut from Mg Recovery
2
100
22,000
45,000
l.each 1 .iquor and Sponge Wash Water
2
380.000
480.000
580,000
Spent Surface Impoundment Liquids
7
630
3.400
6,700
Spent Surface Impoundment Solids
7
36,000
36,000
36,000
Waste Acids (Sulfate Process*
2
200
39,000
77,000
WWTP Sludges/Solids
7
420.000
420,000
420,000
H.1.2 Hazardous Characteristics
Each waste stream in the data set is known or suspected to be hazardous for at least one of the four
RCRA hazard characteristics:
Toxicity (i.e., containing one or more of the eight TC metals);
Corrusivily;
Ignitahilitv; and
Reactivity.
Exhibit H-2 summarizes the status of each of the eight waste streams for the four hazardous
characteristic categories, as well as each stream's overall hazard certainty Three of the waste streams in
the sector are known to be hazardous for at least one of the characteristics, as indicated in the far right
column by a "Y" (yes) overall hazard certainty classification. The other five streams in the sector are only
suspected to be hazardous and are assigned a "Y?" hazard certainty classification in the far right column.
For example, leach liquor and sponge wash water is known to be hazardous because it is corrosive, even
though the stream is only suspected to be hazardous for chromium and lead, and is not believed to be
ignitnblc or reactive.
Exhibit H-2
Hazardous Characteristics
Titanium
Waste Stream
TC Metals
Corr
Ignit
Rctv
Overall
Ha*0
As
Ba
Cd
Cr
Pb
Hg
Sc
A?
Pickle Liauor and Wash Water


y>
V
Y?



Y?
N?
N?
Y?
Scrap Milling Scrubber Water


V
y i
Y?

Y?

N?
N?
N?
Y?
Smut from Mg Recovery








N?
N?
Y
Y
Leacr. 1.iquor and Sponge Wash Water



Y?
Y.'



Y
N?
N?
Y
Spent Surface Impoundment Liquids



y>
Y?



N'.'
N?
N?
Y?
Spenr Surface Impoundment Solids



Y1
Y?



N1
N?
N?
Y?
Waste Acids (Sulfate Process)
Y


Y


Y
Y
Y
N
N
Y
WWTP Sludges/Solids



Y?




N
N
N
Y?
Y = known to he hazardous, Y? = suspected to be hazardous
April 30, 1998

-------
H-3
H.1.3 Recycling Status, RCRA Waste Type, and Waste Treatment Type
Exhibit H-3 depicts the recycling status, RCRA waste type, and physical form of each of the waste
streams in the titanium sector. Of the eight waste streams in the sector, none are assigned a "Y" (yes) 111
Exhibit H-3 because none are known to be fully recycled. Two are believed to be fully recycled (Y?)
None are assigned a "YS" (yes sometimes) because none are known to be partially recycled, but three are
believed to be partially recycled (YS?). Three arc assigned "N" (no) because they are known not to be
recycled at all 
-------
H-4
There is a critical difference between "model facility" totals for treated and disposed waste and
average facility quantities for waste stored prior to recycling. "Model facility" totals, which are used to
model treatment of all waste streams in a sector in a single treatment system at each facility, are calculated
on a sector basis. In contrast, average facility quantities, which are used to calculate storage costs of
individual waste streams that must not be commingled, are calculated on an individual waste stream basis.
H.2.1 Estimate Waste Stream Portion Assumed to be Hazardous
As indicated in Exhibit H-2 above, five of the waste streams in the titanium and titanium dioxide
mineral processing sector are only suspected to be hazardous (Y?). To apportion this uncertainty over the
minimum, expected, and maximum value cases, we multiply the overall waste stream generation rates
( minimum, expected, and maximum) for each of the eight waste streams from Exhibit H-l by the
following percentages in Exhibit H-4, to calculate the minimum, expected, and maximum quantities of the
waste stream estimated to be both generated and hazardous:
Exhibit H-4
Hazard Certainty Multipliers
Costing Scenario
Hazard Ccrtainlv
Y ?
Y
Minimum
0%
10(V7r
Expected
50%
100%
Maximum
100%
100%
The resulting quantities of waste estimated to be hazardous for each waste stream in the titanium
and titanium dioxide sector are shown in Exhibit Ho. The effect of this procedure is to bound the
analysis, which is especially important for the five streams that are only suspected to be hazardous. For
example, the quantity of pickle liquor and wash water (Y? hazard certainty) assumed to be hazardous in the
minimum value case would be 0 mt/yr [i.e., 22,000 mt/yr generated (from Exhibit H-l) x 0% (from Exhibit
H-4) = 0 nit/vrj. while the expected value case hazardous portion would be 13,500 mt/yr [27,000 mt/yr
generated (from Exhibit H-l) x 50% (from Exhibit H-4) = 13,500 mt/yr]." In the maximum value case, the
entire quantity (32,000 mt/yr) is assumed to be hazardous. For the three titanium waste streams known to
be hazardous (Y). the entire generated quantity of those wastes is included in the analysis.
2 Conversely, note that 22,000 mt/yr of the waste is considered non-hazardous in the minimum
value case, while 13,500 mt/yr is considered non-hazardous in the expected value case. The portion of
waste that is assumed non-hazardous drops out of the analysis from this point forward.
April 30, 1998

-------
H-5
Exhibit H-5
Portion of Waste Assumed to be Hazardous
Titanium
Waste Stream
Hazard
Certniniy
Portion of Waste that is Hazardous
(mt/yr)
Minimum
Expected
Maximum
Fickle Liquor and Wash Water
Y?
0
1,350
3.200
Scrap Milling Scrubber Water
Y?
0
2,500
6.000
Smut from Mg Recover)'
Y
100
22,000
45.000
Leach Liquor and Sponge Wash Water
Y
380,000
480,000
580,000
Spent Surface Impoundment Liquids
Y?
0
1,700
6,700
Spent Surface Impoundment Solids
Y?
0
18,000
36,000
Waste Acids (Sulfate Process)
Y
200
39,000
77,000
WWTP Sludges/Solids
Y?
. 0
210,000
420.000
H.2.2 Divide Hazardous Quantities Into Portion Treated/Disposed and Portion
Stored Prior to Recycling
The hazardous portion of each waste stream (from Exhibit H-5) is then divided into a component
of waste that is treated/disposed, and a component that is stored for recycling. To determine these
portions, the model applies an appropriate multiplier, depending on its particular recycling status (as
indicated in Exhibit H-3 above). The treatment/disposal multipliers are shown in Exhibit H-6, and the
recycling multipliers are shown in Exhibit H-7. Note that in all cases the treatment and disposal multiplier
in Exhibit H-6 and the recycling multiplier in Exhibit H-7 sum to 100 percent (i.e., all waste is assumed to
be handled in accordance with F.PA regulations and either treated and disposed, or stored prior to
recycling). The multipliers are applied to the portion of material considered to be hazardous in the
minimum, expected, and maximum value cases.
April 30, 1998

-------
H-6
Exhibit H-6
Proportions of Waste Streams Treated and Disposed (in percent)

Percent Disposed
Baseline or Option

Recycling Status


Y
Y?
YS
YS''
N
No Prior Treatment
0
100
60
100
100
Modified Prior Treatment
0
15
25
SO
100
Prior Treatment (SL/BP)
0
15
25
80
100
Prior Treatment (SM)
0
25
35
85
100
Option 1 from NPT
0
30
40
90
100
Option 1 from MPT
0
25
35
85
100
Option 1 from PT (SL/BP)
0
25
35
85
100
Option 1 from PT (SM)
0
25
35
85
100
Option 2 from NPT
0
15
25
80
100
Option 2 from MPT
0
15
25
80
100
Option 2 from PT (SL/BP)
0
15
25
80
100
Option 2 from PT (SM)
0
15
25
80
100
SL = Sludge, BP = By-Product, SM = Spent Material, PT = Prior Treatment, MPT =
Modified Prior Treatment, NPT = No Prior Treatment
Exhibit H-7
Proportions of Waste Streams Stored Prior to Recycling (in percent)

Percent Recycled
Baseime or Option

Recycling Status


Y
Y1
YS
YS'1
N
No Prior Treatment
100
0
40
0
0
Modified Prior Treatment
100
85
75
20
0
Prior Treatment (SI,/BP)
100
85
75
20
0
Prior Treatment (SM)
100
75
65
15
0
Option 1 from NPT
100
70
60
10
0
Option 1 from MPT
100
75
65
15
0
Option 1 from PT (SL/BP)
100
75
65
15
0
Option 1 from PT (SM)
100
75
65
15
0
Option 2 from NPT
100
85
75
20
0
Option 2 from MPT
100
85
75
20
0
Option 2 from PT (SI/BP)
100
85
75
20
0
Option 2 from PT (SM)
100
85
75
20
0
SL = Sludge. BP = By-Product, SM = Spent Material, PT = Prior Treatment, MPT =
Modified Puor Treatment, NPT = No Prior Treat mem
April 30, 1998

-------
H-7
The quantities of waste treated/disposed and the quantities of waste stored prior to recycling lor
each waste stream in the sector are shown in Exhibits H-8 and H-9, respectively. Quantities reported in
Exhibits H-8 and H-9 are calculated by multiplying the portion of waste that is hazardous (Exhibit H-5) by
the appropriate treatment/disposal or recycling multipliers (from Exhibits H-6 and H-7). For example, of
the 1,350 mt/yr of pickle liquor and wash water assumed to be hazardous in the expected value case of the
Modified Prior Treatment baseline, 80 percent of the waste, or approximately 1,080 mt/yr (1.350 mt/yr x
0.80), is sent to treatment/disposal, while 20 percent of the waste, or approximately 270 mt/yr (1,350 mt/yr
x 0.20), is stored prior to recycling.
II.2.3 Calculate Total Quantity Treated und Disposed at a "Model Facility"
In performing cost modeling, EPA assumes that each facility operator generating waste in the
titanium sector builds a single treatment plant to treat all wastes, rather than building a separate treatment
plant for each waste stream. Therefore, to obtain the quantity of waste treated and disposed at a "model
facility," the model sums the treated and disposed portion of all eight waste streams by physical form (i.e.,
wastewaters, wastes with one to ten percent solids, and wastes with more than ten percent solids) and
divides by the maximum number of facilities generating waste in the sector, which in this sector example is
two in the minimum value case, and seven in the expected and maximum value cases. The reason why
there are only two facilities generating waste in the minimum value case is that there is uncertainty about
the hazard characteristics (Y?) of several of the titanium waste streams (see Exhibit H-5). Recall that
waste streams that have a Y? hazard certainty classification are considered not hazardous in the minimum
value case. 50% hazardous in the expected value case, and 100% hazardous in the maximum value case
(see Exhibit H-4). Therefore, the maximum number of facilities generating at least one hazardous titanium
waste drops to two in the minimum value case, because all of the titanium waste streams generated by
more than two facilities have a Y? hazard certainty classification (see Exhibit H-l). For purposes of EPA's
calculations, it does not matter whether some types of waste are generated at fewer facilities, because the
model assumes a single treatment system for all types of waste generated at all facilities, hor example, the
total wastewater treated/disposed for the prc-rule expected value case is 426.335 mt/yr (which is the sum of
the wastewater streams in Exhibit H-10). Dividing by seven, the model facility wastewater
treated/disposed for the expected value case is 60,905 mt/yr Exhibit H-8 presents the model facility waste
treated/disposed for the minimum, expected, and maximum value scenarios.
April 30, 1998

-------
H-8
Exhibit H-8
Portion of Hazardous Wastes Generated Treated and Disposed
Waste Stream
Multiplier
Portion of Waste Treated/Disposed
(mt/yr)
Minimum
Expected
Maximum
Pre-Rule (Modified Prior Treatment)
Pickle Liquor and Wash Water
0.80
0
1,080
2,560
Scrap Milling Scrubber Water
0.80
0
2,000
4,800
Smut from Mg Recovery
0.15
15
3,300
6,750
Leach Liquor and Sponge Wash Water
0.80
304,000
384,000
464,000
Spent Surface Impoundment Liquids
0.15
0
255
1,005
Spent Surface Impoundment Solids
1
0
18.000
36,000
Waste Acids (Sulfate Process)
1
200
39,000
77.000
WWTP Sludges/Solids
I
0
210,000
420,000
Post-Rule (Option 1)
Pickle Liquor and Wash Water
0.85
0
1,148
2.720
Scrap Milling Scrubber Water
0.85
0
2.125
5,100
Smut from Mg Recovery
0.25
25
5.500
11.250
Leach Liquor and Sponge Wash Water
0.85
323,000
408.000
493.000
Spent Surface Impoundment Liquids
0 25
0
425
1.675
Spent Surface Impoundment Solids
1
0
18.00(1
36,000
Waste Acids (Sulfate Process)
1
200
39,000
77.000
WWTP Sludges/Solids
1
0
210.000
120.000
April 30, 1998

-------
H-9
Exhibit H-9
Portion of Hazardous Wastes Generated that is Stored Prior to Recycling
Waste Stream
Multiplier
Portion of Waste Stored Prior to
Recycling
(mt/yr)
Minimum
Expec'.ed
Maximum
Pre-Rule (Modified Prior Treatment)
Pickle Liquor and Wash Water
0.20
0
270
640
Scrap Milling Scrubber Water
0.20
0
500
1,200
Smut from Mg Recover)'
0.85
85
18.700
38.250
Leach Liquor and Sponge Wash Water
0.20
76,000
96,000
116,000
Spent Surface Impoundment Liquids
0.85
0
1,445
5,695
Spent Surface Impoundment Solids
0
0
0
0
Wast: Acids (Sulfate Process)
0
0
0
0
WWTP Sludges/Solids
0
0
0
0
Post-Rule (Option 1)
Pickle Liquor and Wash Water
0.15
0
203
4 SO
Scrap Milling Scrubber Water
0.15
0
375
900
Smut from Mg Recover)'
0.75
75
16,500
33.750
Leach Liquor and Sponge Wash Water
0.15
57,000
72,000
87,000
Spent Surface Impoundment Liquids
0.75
0
1,275
5.025
Spent Surface Impoundment Solids
0
0
0
0
Waste Acids (Sulfate Process)
0
0
0
0
WWTP Sludges/Solids
0
0
0
0
April 30, 1998

-------
H-10
Exhibit H-10
Model Facility Quantity of Waste Treated/Disposed
Baseline/Option
Model Facility Waste Treated/Disposed (mt/yr)
Minimum
Expected
Maximum
Waste-
waters
1-10#.
Solids
Solids
Wasie-
*ateis
I-ICa
SuliJs
Solids
Waste-
water
1-10*
Solids
Sulitls
Pre-Rule (MPT)
152. ICO
0
8
60.905
0
33.043
78.481
r,
6ft. 10/
Post Rule
(Option 1)
161.100
0
13
54,385
0
33.357
82.785
0
66.750
H.2.4 Calculation of Average Quantity Recycled
Because recycling costs are specific to each waste stream in the sector, the cost model does not
calculate model facility totals for recycling. Rather, it calculates an average facility total by dividing the
portion of each waste stream that is stored prior to recycling (from Exhibit H-9) by the number of facilities
that generate each waste (from Exhibit H-l). Exhibit H-11 shows the results of this calculation.
Exhibit H-ll
Average Facility Quantities Stored Prior to Recycling
Waste Stream
Number
of
Facilities
Average Facility Waste
Stored Prior it) Recycling
(mt/yr)
Minimum
Expected
Maximum
Pro-Rule (Modified Prior Treatment)
Pickle Liquor and Wash Water
3
0
90
213
Scrap Milling Scrubber Water
1
0
500
1.200
Smut from Mg Recovery
>
43
y.350
19.125
Lcach Liquor and Sponge Wash Watei
->
38,000
48.000
58.000
Spent Surface Impoundment Liquids
-r
0
206
814
Spent Surface Impoundment Solids
7
0
0
0
Waste Acids (Sulfate Process)
->
0
0
0
WWTP Sludges/Solids
7
0
0
0
Post-Rule (Option 1)
Pickle Lie Jor and Wash Water
3
0
68
160
Scrap Milling Scrubber Water
1
0
375
900
Smut "from Mg Recovery
2
38
8.250
16.875
I cneh Liquor and Sponge Wash Water
2
28.500
36.000
43.500
Spent Surface Impoundment Liquidb
7
0
182
718
Spcn: Surface Impoundment Solids
7
0
0
0
Was*: Acids {Sulfate Process *
2
0
0
0
WWTP Sludges/Solids
7
0
0
0
April 30, 1998

-------
H-l 1
H.3. Treatment Cost Calculations
This section of the appendix explains how the cost model calculates the total incremental treatment
cost incurred by the titanium and titanium dioxide mineral processing sector.
The model first determines if the treated and disposed waste quantities from Exhibit H-10 are large
enough to warrant on-site treatment. Next the model calculates neutralization, dewatering. stabilization,
and disposal costs. The model then annualizes capital and closure costs and calculates a total sector
treatment cost. Finally, the model calculates the total titanium sector incremental treatment cos: All
treatment and disposal calculations are performed using the "model facility" quantities calculated in
Section H.2.3 of this document.
H.3.1 Determination of On-Site versus Off-Site Treatment
The model assumes that low-volume wastes {< 3.163 mt/yr solids or  350 mt/yr liquids) will be
sent off-site for treatment and disposal. All wastes generated in the titanium sector are assumed to be
treated on-site, because both wastewaters and solids are generated in quantities above the low-volume
threshold in all three costing scenarios (see Exhibit H-10).
H.3.2 Neutralization and Precipitation Costs
 Five of the eight titanium waste streams are wastewaters and therefore require neutralization,
precipitation, dewatering. and stabilization prior to disposal. (The other three streams are solids, and do not
require neutralization, precipitation, and dewatering.) The model uses four equations to determine the
neutralization cost for wastewaters:'
In all four of the above equations, Q (the amount of waste requiring neutralization) equals the sum
of wastewaters and waste streams with one to ten percent solids requiring treatment. I'^ing the pre-r.ile
expected value case as an example, the model facility quantity of wastewater requiring treatment is 60,905
mt/yr. and the quantity of wastes with one to ten percent solids content is 0 mt/yr ("see Exhibit H-10).
Therefore, neutralization surge tank storage costs equal SI0.985. neutralization capital costs equal
$73,631, neutralization O&M cons equal J196,440 per year, and neutralization closure costs equal S6.422.
Exhibit H-12 shows the neutralization costs for the titanium and titanium dioxide sector.
3 Equations from Exhibit F-l, Appendix F.
Surge Tank Costs (S/vr)
4x 10 s Qn: + 0.1175Q. + 3.680
36.131 + 151.95 Q: 5
-206,719  36,594 In Q,
6,361 + 10 ' Q
Capital Costs (i)
O&M Cost- (S/'yr)
Closure Costs ($)
April 30. 1998

-------
H-12
Exhibit H-12
Neutralization Costs
Baseline/Option
Costs
Neutralization Costs
Minimum | bxpecteJ | Max:mum
Pre-Rule
- Surge ($/vr)
22.477
10.985
13,148
- Cap:tal (5)
95.392
73.631
78,699
- O&M (S/yr)
22y .931
196.440
205,718
- Closure (50
0,513
6.422
6.439
Post-Rule
- Surge ($/yr)
23,713
11.411
13.681
- Capital ($)
97,214
74,687
79.851
- O&M (S/yr)
232,148
198.473
207,672
 Closure ($)
6.523
6.425
6.444
The model uses two equations to determine the precipitation cost for wastewaters:4
 Capital Costs ($) = 3,61.3 + 15.195 Qp:?
O&M Costs (S/yr) = 820.48 + 0.3465 Q ,
In the above equations, Qp (the amount of waste requiring precipitation) equals the sum of
wastewaters arid waste streams with one to ten percent solids requiring treatment. Using the pre-nile
expected value case as an example, the model facility quantity of wastewater requiring treatment is 60.905
mt/yr, and the quantity of wastes with one to ten percent solids content is 0 mt/vr (see Exhibit H-10).
Therefore, precipitation capital costs equ.il $7,363. and precipitation O&M costs equal $21.930 per year,
fcxhibit H-13 shows the precipitation costs for the titanium and titanium dioxide sector.
Exhibit H-13
Precipitation Costs
Baseline/Option
Costs
Precipitation Costs
Minimum | Expected | Maximum
Pie-Rule
- Capital ($)
9.539
7,363
7.870
- OiM (Vyr!
53.529
21.930
28.C20
Post Rule
- Capital (S >
9.721
7,469
7,985
- O&M (S/yr)
56.821
23.136
29.511
4 EPA assumes that neutralization and precipitation occur within the same unit, therefore,
precipitation closure costs arc included in the neutralization closure cost equation.
April 30, 1998

-------
H-13
H.3.3 Dewatering and Stabilization Costs
Neutralization operations produce a slurry that must be dewatered, stabilized, and disposed of.
About 15 percent of the quantity introduced into the neutralization operation leaves as this slurry.
Therefore, in the following equations, Qd, the amount of material requiring dewatering, is 15 percent of
the sum of the quantity of wastewaters and wastes with a solids content of 1 to 10 percent requiring
treatment"
For example, in the post-rule expected value case, Qdw is equal to 9,658 mt/yr [(64,385 mt/vr
wastewaters plus 0 mt/yr wastes with a solids content of 1 to 10 percent (from Exhibit H-10)) x 0.15],
Therefore, the capital cost associated with dewatering 9,658 mt/yr waste is SI60,655, and the O&M cost is
$40,410 per year.
Dewatering produces a sludge, which needs to be stabilized and disposed of. The dewatered
sludge, equal to about 15 percent of the mass entering dewatering, is combined with the solid waste
streams requiring stabilization and disposal in the following equation:6
In these equations, therefore, the quantity requiring stabilization, Q,, is 2.25 percent' of the sum of
the original quantity of wastewaters and wastes with a solids content of 1 to 10 percent requiring treatment,
added to the entire quantity of solid waste requiring treatment. For example, in the post-rule expected
value case. Q, is equal to 34,806 mt/yr [1.449 mt/yr wastewaters and wastes with I to 10 percent solids
((64,385 mt/yr + 0 mt/yr, from Exhibit H-10, * 0.0225) plus 33.357 mt/yr solids (from Exhibit H-10)].
Therefore, the cost associated with stabilizing 34.806 mt/yr waste is $2,053,871. Exhibits H-14 and H-15
show the dewatering and stabilization costs, respectively, for the titanium and titanium dioxide sector.
* Equations obtained from Exhibit F-2, Appendix F.
6 Equations obtained from page F-9. Appendix F.
This is equal to 15 percent of the quantity entering dewatering, w hich is 15 percent of the
original quantity requiring treatment.
Capital Costs ($)
O&.VI Costs (S/yrj
95,354 + 664.48 Qiuc'
12,219 + 286.86 Qj>'
Stabilization Costs ($)
49.177QS+342,233
April 30, 1998

-------
H-14
Exhibit H-14
l)cwatering and Stabilization Costs
Baseline/Option
Costs
Dewatenng Costs
Minimum I Expected | Maximum
Pre-Rule
- Capital ($)
195,721
158.366
167.450
0&.V1 ($/yr)
55.5'-8
39.637
43.345
Post-Rule
- Capital ($)
198.808
160.6.15
169.4(H)
- O&M (f/yr)
<6.881
40.410
44,185
Exhibit H-15
Stabilization Costs
Baseline/Option
Costs
Stabilization Costs
Minimum
Expected
Maximum
Pre-Rule
510,922
2,034,579
3,680.015
Post-Rule
521,127
2,053,871
3,716.398
II.3.4 Disposal Costs
After neutralization, precipitation, dewatenng, and/or stabilization, stabilized residues from
titanium sector wastes are disposed of in a pile. The cost of disposal in a pile is described by the following
equation:8
File Costs (S/yr)	= 1 87(n Q,,, + 12,30!-
In the above equation, Qds, the quantity being disposed cf, is equal to 146 percent of the mass
entering stabilization from dewatenng added to 145 percent of the solid wastes entering stabilization.
Alternatively, Qd, is the sum of [1.46 x (0.0225 x (quantity of wastewaters and wastes with a 1 lo 10
percent solids content requiring treatment)] and [1.46 x (quantity of solids requiring treatment)]. For
example, in the expected value case of Option 3, QJs is equal to 50,817 mL/yr |( 1.449 mt/yr x 1 46) plus
(33,357 rnt'yr x 1.46)]. Therefore, the cost of disposal in a pile is equal to $ 107,351. Exhibit H-l 6 depicts
the di-posal costs lor the sector.
Exhibit H-16
Disposal Costs
Baseline/Option
CoMs
Disposal Co
-------
H-15
H.3.5 Annualization of Costs and Calculation of Total Sector Treatment Costs
Because capital and closure costs are one-time costs, they are annualized so that total annualized
titanium sector incremental treatment costs may be calculated. The model annualizes the. titanium sector
capital costs by multiplying them by a capital recovery factor (CRF) of 0.09439.'' Closure costs, which are
assumed to be incurred after 20 years of operation (i.e., in year 21), are reduced to present value and then
annualized tiding the CRF The annualization process and the calculation of total neutralization,
precipitation, dewatering. and stabilization costs are accomplished using the following formula:1"
 Annualized Cost = (Capital Costs)(CRF) + O&M Costs + (Closure
Costs)(CRF)/( 1.07'1)
Using the above formula, the model combine? the capital, O&M. and closure costs to obtain total
annualized neutralization, precipitation, and dewatering costs for the titanium sector.11 For example, the
prc-rule expected value case annualized neutralization cost in the titanium and titanium dioxide sector
equals ($73,631 x 0.09439) + $10,985 + SI 96,440 + ((56,422 x 0.09439)/ 1.073'). or $214,521. The
disposal and stabilization cost functions are already annualized. Exhibit H-17 presents the total
annualized neutralization, precipitation, dewatering, stabilization, and disposal costs for the titanium
sector.
Exhibit H-17
Annualized Neutralization, Precipitation, Dewatering, Stabilization, and Disposal Costs
(Modified Prior Treatment Baselirie and Option 1)
Baseline/Option
Costs

-------
H 16
Total titanium sector pre- and post-rule treatment costs are calculated by summing the annualized
neutralization, preciphatiun, dewatering. stabilization, and disposal costs from Exhibit 11-17, and
multiplying the sum by the maximum number of facilities in the titanium sector (two in the minimum value
case, seven in the expected and maximum value cases). Therefore, the total titanium sector expected value
case pre-rule treatment cost in this example is equal to ((S214.521 + $22,625 + 554,632 + $2,034,579 +
$106,278 = $2,432,635) x 7), or $17,028,445. Similarly, the total titanium sector expected value case
post-rule treatment cost in this example is equal to (($217,080 + S23.841 + $55,574 + S2,053,871 +
$107,349 = S2,399,311) x 7), or $17,204,005.
H.3.6 Total Sector Incremental Treatment Cost
The total titanium sector incremental treatment cost is calculated by subtracting the pre-rule total
sector treatment cost from the post-rule total sector treatment cost. In this example, the total titanium
sector incremental treatment cost is $38,720 in the minimum value case, $175,560 in the expected value
case, and S304,360 in the maximum value case.
II.4. Storage Cost Calculations
This section of the appendix calculates the total sector incremental storage cost incurred by the
titanium and titanium dioxide mineral processing sector. This process involves four steps: (1) the
appropriate storage unit for each waste stream is selected; (2) the average facility storage cost is calculated
lor each, waste stream; (3) a total sector storage cost is calculated; and (41 a total sector incremental storage
cost is calculated. Note that until the total sector storage cost is calculated at the end of lhi~ section, all
calculations in this section are performed on an average facility basis.
H.4.1 Storage Unit and Cost Equation Determination
Depending on the quantity of recyclable waste generated and the physical form of the waste (liquid
or solid), wastes that require storage prior to recycling can be stored in a variety of storage units. EPA
developed individual cost equations for each type of storage unit and used these cost equations to
determine, for any quantity being stored, the least cost storage unit available, Exhibit H-1S shows these
cost (unctions for the various storage units available for use in the Modified Prior Treatment baseline and
Option I, as well as the range of quantities for which that unit would be employed.12 In each of these
equations, 0 is the annual quantity requiring storage prior to recycling.
2 For a full list of storage unit functions, refer to Exhibit F-l 8, Appendix F.
April 30. 1998

-------
H-17
Exhibit H-18
Storage Cost Equations
Modified Prior Treatment Baseline
Waste
Type
Storage Unit
Quantity Range
(mt/yr)
Cost Equation
Liquid
Drum
0- 220
Y = -0.0074 Q: t- 9.4798 Q + 189.34
Tank
220- 500
Y = -9x10' Q;+ 0 55 Q + 1.795.7
Unlined S.I.
> 500
Y = 1,000
Solid
Drum
0-200
Y = 24.589 Q + 132.23
Roll-Off
200 - 935
Y = -0.0022 Q- * 29.272 Q + 4.840.9
Unlined Pile
a 935
Y = 4.0207 Q- 26.271
Option 1 (from MPT)
Waste
Type
Storage Unit
Quantity Range
(mt/yr)
Cost Equation
Liquid
Drum
0-220
Y = -0.0074 Q: + 9.4798 Q -v 139.34
Tank
220 - 1 million
Y - -9xl07 Q;- 0.55 Q + 1.795.7
Lined S.I.
> 1 million
Y = 0.0704 Q - 1,955.1
Solid
Drum
0 - 200
Y = 24.589 Q- 132.23
Roll Off
200  1343.1
Y = 0.0022 Q: + 29.272 Q + 4.840.9
Building
13431 -45,000
Y = 0 00002 Q; + 3 2395 Q + 35,800
Lined Pile
> 45.000
Y = 4.0924 0 + 27.676
Exhibit H-19 shows the storage units used in the minimum, expected, and maximum value cases
for the eight waste streams generated in the titanium sector. For example, scrap milling scrubber water is
stored in an ur.lined surface impoundment in the pre-rule maximum value case because it i> a liquid waste
(i.e.. a wastewater) and the quantity stored prior to recycling (i.e., 1,200 mt/yr) exceeds the threshold
quantity of 500 mt/yr needed to store liquids in an unlined surface impoundment.
H.4.2 Storage Costs
Exhibit H-20 shows the storage costs for each of the eight titanium waste streams. The quantities
in Exhibit H-20 are created by putting the quantity of waste stored prior to recycling (Exhibit H-l 1) into
the appropriate cost function from Exhibit H-18. For example, leach liquor and sponge wash water is
stored in a tank in all three costing scenarios under Option 3. Therefore, the cost equation for the
minimum, expected, and maximum value case is as follows:
Cost = -9x10 ' Q- + 0.55 Q + 1,795.7
Inser.ing 28.50D mt/yr. 36,000 mt/yr, and 43.500 mt/yr into the minimum, expected, and maximum cost
equations, respectively, yields a storage cost of $16,740 in the minimum value case. S20.429 in the
expected value case, and S24.01S in the maximum value case.
April 30, 1998

-------
H-i 8
Exhibit H-19
Storage Units Used in the Modified Prior Treatment Baseline and Option 1
Titanium Waste Stream
Storage Unit
Minimum | Expected | Maximum
Pre-Rule (Modified Prior Treatment)
Pickle Liquor and Wash Water
Not Recycled
Drum
Drum
Scrap Milhng Scrubber Water
Not Recycled
Unlined S.I.
Unlined S.I.
Smut from .Mg Recovery
Drum
Unlined Pile
Ltnlined Pile
Loach Liquor and Sponge Wash Water
Unlined S I.
Unlined S.I.
Unlined S I.
Spent Surface Impoundment Liquids
Nat Recycled
Drum
Unlined S I.
Spent Surface Impoundment Solids
Not Recycled
Not Recycled
Not Recycled
Waste Acids (Sulfate Process)
Not Recvcled
Not Recycled
Not Recycled
WWTP Sludges/Solids
Not Recycled
Not Recycled
Nol Recycled
Post-Rule (Option 1)
Pickle Liquor and Wash Water
Not Recvcled
Drum
Drum
Sciap Milling Scrubber Water
Not Recycled
Tank
Tank
Smut from Mg Recovery
Drum
Building
Building
Leach Liquor and Sponge Wash Water
Tank
Tank
Tank
Spent Surface Impoundment Liquids
No: Recvcled
Drum
Tank
Spent Surface Impoundment Solids
Not Recvcled
Not Recvcled
Not Recvcled
Waste Acids (Sulfate Process)
Not Recvcled
Not Recvcled
Not Recvcled
WWTP.Slur ?es/Snlid?
Net Recvcled
Not Recvcled
Nol Recvcled
Exhibit H-20
Average Facility Storage Costs
Titanium Waste Stream
Average Facility Storage Cost (S>
Minimum | Expected | Maximum
Pre Rule ' Modified Prior Treatment)
Pickle Liquor and Wash Water
Not Recycled
98 J
I.X73
Scrap Mi 11 ir ji Scrubber Water
Not Recycled
1.000
1.000
Smut trom Me Recoverv
1.190
6?. 86?
103.167
Leach Liquor and Sponge Wash Water
1.000
1.000
I.000
Spent Surface Impoundment Liquids
Not Recycled
1.828
1.000
Spent Surface Impoundment Solids
Not Recvcled
Not Recvcled
Not Recycled
Wr.ste Acids (Sulfate Process)
Not Recvcled
Not Recvcled
Not Recycled
WWTP Sludnes/Solids
Not Recvcled
Noi Recvcled
Not Recycled
Post-Rule 'Option I)
Pickle Liquor and Wash Water
No'. Recvcled
780
1.517
Scrap Milling Scrjbbcr Water
No: Recycled
7.002
2,290
Smut from Mj Recoverv
1.067
63.887
96.162
Leach Liquor and Sponge Wash Water
16.740
20.429
24.CI8
Spent Surface lir*);iun;lment Licuids
Net Recvcled
1,670
2.190
Spent Surface Impoundment Solids
Not Recvcled
Not Recvcled
Not Recvcled
Waste Acids (Sulfate Process)
Not Recycled
Not Recycled
Not Recycled
WWTP Sludges/Solids
Not Recvcled
Not Recvcled
Not Recycled
April 30, 1998

-------
H-19
H.4.3 Total Sector Storage Cost
To obtain a total sector storage cost, pre-rale (Modified Prior Treatment baseline) and post-rule
(Option I) total sector storage costs must be calculated under each scenario for eaL'h waste stream and
summed. Total sector pre- and post-rale f torage costs are calculated by multiplying the minimum,
expected, and maximum average facility storage cost for each titanium waste stream (Exhibit H-20) by the
number of facilities generating the waste stream. Using leach liquor and sponge wash water as an
example, the post-rule total sector storage cost is S42.792 ($21,396 x 2 facilities) in the minimum value
case, $52,244 ($26,122 x 2 facilities) in the expected value case, and $60,916 (30,458 x 2 facilities) in the
maximum value case. Exhibit H-2I shows the total sector storage cost for each waste stream and the total
storage cost for the entire sector.
Exhibit H-21
Total Sector Storage Costs
Baseline or Option
Number of
Facilities
Storage Cost
(S)

Minimum
Expected
Maximum
Pre-Rule (Modified Prior Treatment)
Pickle Liquor and Wash Water
3
0
2.949
5.619
Scrap Milling Scrubber Water
I
0
1.000
1.000
Smut hum Mg Recovery
2
2..^n
127730
206.334
Leach Liquor and Sponge Wash Water
0
2.000
2.000
2.000
Spent Surface Impoundment Liquids
1
0
12.796
7,000
Spent Surface Impoundment Solids
7
0
0-
0
Waste Acids (Sulfate Process)
2
0
0
0
WWTP Sludges/Solids
7
0
0
0
Pre-Rule Total Sector

4,380
146,475
221.953
Pos:-Rule (Option 1)
Pickle Liquor and Wash Water
3
0
2..V0
4.551
Scrap Milling Scrubber Water
1
0
2,002
2.29C
Smut from Me Recovery
2
2.: 34
127.774
192.324
Leuv'h Liquui and Sponge Wash Water
-)
i.
33,480
40.858
48.036
Spent Surface Impoundment Liquids
-r
0
11.69U
15.330
Spent Surface Impoundment Solids
7
0
0
0
Waste Acids (Sulfate Process)
-i
0
0
0
W W T P S111 (i s AS o 1 i ri s
7
0
0
0
Post-Rule Total Sector

35.614
184,664
262.?31
April 30, 1998

-------
H-20
H.4.4 Total Sector Incremental Storage Cost
The total titanium sector incremental storage cost is calculated by subtracting the pre-rule total
sector storage cost from the post-rule total sector storage cost. In this example (where the pre-rule scenario
is the Modified Prior Treatment baseline, and the post-rule scenario is Option 1), the total titanium sector
incremental storage cost is $31,234 in the minimum value case. $38,189 in the expected value case, and
$40,578 in the maximum value case.1'
H.5. Administrative Cost Calculations
Administrative costs are specific to each waste stream generated in the titanium/titanium dioxide
sector. For the three titanium wastes that are known not to be recycled (N recycling status-see Exhibit H-
3) and therefore requires treatment and disposal, there is a one-time cost of S935 to develop a waste
analysis plan, and an annual testing cost of $470. The remaining wastes the titanium/titanium dioxide
sector are partially recycled and partially treated/disposed (Y?. YS. and YS? recycling status- see Exhibit
H-3) incur the $935 waste analysis plan and $470 annual testing costs, as well as a one time recycling
notification cost of $100. Recall from Exhibit H-2 that in the minimum value case, titanium/titanium
dioxide wastes with Y ? hazard certainty are assumed not to be hazardous. Therefore, in the minimum value
case, wastes with Y? hazard certainty do not incur any administrative costs. Both the waste analysis plan
cost and the recycling notification costs are one-time in nature, so they are annualized by multiplying by a
CRF of 0.09439." Exhibit H-22 shows the administrative costs for the titanium/titanium dioxide sector.
FPA calculated a total administrative cost for each waste stream in the titanium/titanium dioxide
sector by multiplying the appropriate administrative costs by the number of facilities generating the waste
stream. Administrative costs for all of waste streams in the titanium/titanium dioxide sector were then
summed to obtain a total sector administrative cost of $3,408 in the minimum value case, and $17,599 in
the expected and maximum value cases
In the minimum value case, there is a savings in storage cost due to a slight decrease in the
amount of material recycled.
14 Derivation of the CRF may be found on page F-2 of Appendix F.
April 30, 1998

-------
H 21
Exhibit H-22
Annualized Administrative Costs
Titanium Waste Stream
No
of
Fac.
Waste
Analysis Plan
Cost
Annual
Testing Cos:
Recycling
Notification
Cost
Waste Stream
Administrative
Cost
M:n.
ExpV
Maa.
Mir:.
Exp.V
Max
Mm
Exp/
Max
Mm.
F.xp!
Max
Pickle Liquor and Wash Water
3
0
2M
0
1.410
0
2S
0
1.702
Scrap Milling Scrubber W'aier
1
0
S3
0
47C
0
9
0
567
Smut from Me Recovery
?
177
177
940
940
19
!9
1.136
1 136
Leach Liquor and Sponge
Wasli Water
2
177
177
941)
940
19
19
1.136
1.136
Spent Surface impoundment
Liquids
7
0
618
0
3,290
0
66
0
3.974
Spent Surface Impoundment
Solids
7
0
618
0
3.290
0
66
0
V974
Waste Ac;ds (Sulfate Process)
7
jn
177
S)4()
940
19
19
1.136
i.136
WWTP Sludges/Solids
7
0
613
0
3,290
0
66
0
3,974
Total Sector Administrative Cost
3.408
17.599
H.6. Incremental Cost Calculations
This section of the appendix shows how the model calculates the total incremental cost of the
rulemaking for the titanium sector. The total incremental cost is calculated by adding the total sector
incremental treatment cost (calculated in Section H.3). the total sector incremental storage cost (calculated
in Section H.4), and a total sector administrative cost (calculated in Section II.5). Thus, for the titanium
and titanium dioxide sector, the incremental cost of this rulemaking is equal to $73,362 (538.720
incremental treatment cost + $31,234 incremental storage cost + $3,408 total sector administrative cost) in
the minimum value case of Option 1 from the Modified Prior Treatment baseline, $231,348 (5175,560
incremental treatment cost + $38,189 incremental storage co-t + S17,/599 total sector administrative cost)
m the expected value case of Option 1 from the Modified Prior Treatment baseline, and $362,537
(S304.360 incremental treatment cost + 5-0.578 incremental storage cost + $17,599 total sector
administrative cost) in the maximum value case of Option 1 from the Modified Prior Treatment baseline.
The total cost incurred by an average facility in this sector is $36,681 in the minimum value case,
S33.050 in the expected value case, and 551,791 in the maximum value case. Average facility costs are
calculated by dividing the total sector incremental cost by the maximum number of facilities in this sector.
Note that in this example the average facility cost in the minimum value case ($36.681) is larger than the
a\eruge faeilitycost in the expected value case (S33,050). This i> due to the fact that there are only two
facilities producing wa>te in the minimum value case, and seven facilities producing waste in the expected
and maximum value cases. This results in a higher average facility cost because the total sector
incremental cost is divided by two rather than seven.
April 30, 1998

-------
DERIVATION OF VALUE OF SHIPMENTS AND VALUE ADDED
FOR MINERAL PROCESSING SECTORS
APPENDIX I
In estimating the cost impacts of the Phase IV LDRs for mineral processing sectors generating
hazardous waste, EPA gathered information on the current value of shipments from the 1997 Mineral
Commodity Summaries' (1997 MCS), other literature sources, and conversations with Mineral Commodity
specialists at the United States Geological Survey. In general, the Agency multiplied price data (S/mt) with
production data (mt) to determine the value of shipments, where sufficient information was available.
Price and production data for the sectors listed below were taken or estimated from a number of sources.
Details are provided below for each of these sectors, as are the raw price and production data for combined
sectors. A concluding table shows the similar process used to derive value added estimates for 16 sectors.
Aluminum:
Production:
Price:
Mineral Commodity Summary 1997 ( pi8) Primary Production 1996: 3,600,000 mt
Mineral Commodity Summary 1997 (pl8) Price 1996: ignot, average U.S. market (spot),
70.0 cents/pound (0.70 $/pound * 2204.623 pounds/mt = 1543 $/mt)
Antimony:
Production:
Price:
Mineral Commodity Summary 1997 (p20) Production 1992: Primary Smelter 20,100 mt
Mineral Commodity Summary 1997 (p20) Price 1996: average 152 cents/pound (1.52
S/pound * 2204.623 pounds/mt = 3351 S/mt)
Beryllium:
Production:
Price:
Mineral Commodity Summary 1997 (p31) Mine Production 1996: 217 mt
Mineral Commodity Summary 1997 (p3l) Price 1996: Domestic, beryllium-coppcr master
alloy, contained beryllium 160 $/pound. (160$/pound * 2204.623 pounds/mt = 352.640
$/mt)
Bismuth:
Production:
Price:
Cadmium:
Production:
Price:
Caluum:
Production:
Price:
Production capacity used in 1985 Mineral Facts and Problems (1983): 1,100 MT
Mineral Commodity Summary 1997 (p33) Price 1996: 3.60 S/pound (3.60$/pound '
2204.623 pounds/mt = 7936.64 $/mt)
Mineral Commodity Summary 1997 (p39) Production 1996: refinery 1,450 mt.
Mineral Commodity Summary 1997 (p39) Price 1996: metal. 1.25 dollars/pound (1.25
S/pound * 2204 623 pounds/mt = 2,756 $/mt)
Mineral Commodity Specialists (USGS) Production: 1,000 tons (1,000 tons * 1.1 mt/tons
= 1,100 mt)
Mineral Commodity Specialists (USGS) 4.24 S/kg Russian, 4.72 $/kg Chinese. The CLF
price is what the cost of these imports would be in the US, which should he similar to the
price of domestic calcium. Average the two to obtain 4.48 S/kg. (4.48 $/kg * 1000 kg/mt
= 4480 $/mt)
' Mineral Commodity Summaries. United States Geological Service 1997.
April 30, 1998

-------
1-2
Chromium and ferrochromium:
Sales from Macalloy Corporation dated Dec 11, 1997 were used as a proxy for the value
of shipments in the ferrochromium sector. Dun and BrncNtreet. 1997
Coal Gas:
Production: Dakota Gasification Company Bulletin:
Price:	DBA Statistics, Energy Prices and Taxev Fourth Quarter 1996 (p272) Natural Gas for
Industry: $128.80 per 10E7 kilocalories GCV. (153 mmscf/day * 128.80 $/107kcal *
9139 kcal/m' * lnr/35.3107 ft! * 355 day/yr = S186,000,000/year.)
Copper:
Production: Mineral Commodity Summary 1997 (p53) Production 1996: Refinery, Primary -
2.000,000 mt.
Price:	Mineral Commodity Summary 1997 (p53) Price 1996: Average London Metal Exchange,
high grade - 102 cents/pound. (1.02 $/pound * 2204.623 pounds/mt = 2,249 $/mt)
Elemental Phosphorus:
Production: 1990 Report to Congress on Special Wastes from Mineral Processing: 311,000 mt.
Price:	Mineral Commodity Specialist (USGS) - 1.25 S/pound. (1.25 $/pound * 2204.623
pounds/rnl = 2,756 S/mt)
Fi.ourspar and Hydrofluoric Acid:
Production: Mineral Commodity Yearbook. 1996 Table 1: Production: Shipments United Stales:
8.200 mt
Price:	Mineral Commodity Yearbook 1996 (p3), 142 - 152 $/ton (Average = 147 S/ton * 1
ton/,9072 mt - 162 $/mt).
Gkrmanilm:
Production: Mineral Commodity Summary 1997, (p68) Production 1996: Refinery 18,000 kg (18,000
kg * 1 mt/1.000 kg = 18 mt)
Price:	Mineral Commodity Summary 1997, (p68) Price 1996 yearend: Zone refined - 2,000
S/kg. (2,000 $/kg * 1.000 kg/1 mt = 2,000,000 S/mt)
Lead:
Production: Mineral Commodity Summary 1997, (p94) Production 1996: Mine, lead m ^uncentiates
Primary refinery: From domestic ore- 340.000 mt.
Price:	Mineral Commodity Summary 1997 (p93) Price 1996 average,: US - 48.8 cents/pound.
(.488 S/pound * 2204.623 pounds/mt = 1076 S/mt)
Macafsivm and Magnesia from Brines:
Production' - Mineral Commodity Summary 1997 (pi02) Production: Primary 1996- 143,000 mt.
Price:	Mineral Commodity Summary 1997 {p 102) Price 1996, yearend. Metais Week. US spot
Western, average 1.75 $/pound. (1.75 S/pound * 2204.623 pounds/mt = 3.S58 $'mt)
April 30, 1998

-------
1-3
MkrCUKY:
Production: Mineral Commodity Summary 1994 (pi 10) Production 199?: Mine- 70 mi
Price:	Mineral Commodity Summary 1997 (109)Price 1996. average value 260 $/flask. (260
$/flask * 29.0082 flask/int = 7542 S/mt)
Molybdenum, Ferromolybdenlm, and Ammonium Molybdate:
Molybdenum
Production: Mineral Commodity Summary 1997 (pi 14) Production: 1996 mine -57.000 mt
Price:	Mineral Commodity Summary 1997 (pi 14) Price, 1996 average value 7.50 $/kg. (7.50
dollars/kg ~ 1,000 kg/mt = 7.500 S/mt)
Ferromolvbdenum
Production: Mineral Commodity Specialist (USGS) -70 kg (70 kg * 1 mt/1000 kg = .07 mt)
Price:	Mineral Commodity Specialists (IJS(iS) - 15 $/kg. <15 $/kg * 1000 kg/1 ml = 15,000
S/mt)
Ammonia Molybdate
No data were available, therefore the estimated value of shipments may be low.
Platinum Group Metals:
Platinum:
Production: Mineral Commodity Summary 1997,(p 126) Mine Production 1996: Platinum 1,600 kg.
(1.600 kg * 1 nit/1.000 kg = 1.6 ml)
Price:	Mineral Commodity Summary 1997, Price 1996, average daily, New York, 410 S/troy
ounce. (410 S/troy ounce * 32.1507 troy ounce/kg * 1,000 kg/mt = 13,181,787 $/mt)
Palladium:
Production: Mineral Commodity Summary 1997,(pl26)Mine Production 1996: Palladium 5,000 kg.
(5.000kg * 1 mt/1,000kg = 5mt)
Price:	Mineral Commodity Summary 1996,(pi 26) Price 1996, average daily. New York.: 135
S/troy ounce. (135 $/troy ounce * 32.107 troy ounce/kg * 1,000 kg/mt = 4,340,344 $/mt)
Rare Karths:
Production: Mineral Commodity Summary 1997 (p 135). Production 1996: Bastanite concentrates -
20,000 mt.
Price:	Mineral Commodity Summary 1997 (pi35). Price 1996, yearend: Bastarnte concentration.
REO basis -2.87 S/kg. (2.87 $/kg * 1000 kg/mt = 2,870 $/mt)
Monazite and Mischmetal:
_ No data were available, therefore the estimated value of shipments may be low.
Rhenium:
Production: Mineral Commodity Summary 1997 (pi37), Production 1996: 18.500 kg. (18.500 kg * 1
mt/1000 kg = 19 mt
Price-	Mineral Commodity Summary 1997 (pi37), Price 1996, average value. Metal powder.
99.99% pure - 1,100 $/kg. (1.100 S/kg * 1.000 kg/mt =1,100,000 S/mt)
April 30. 1998

-------
1-4
Scandium:
Production: Estimated based in engineering judgement: 25 mt
Price:	Mineral Commodity Summary 1997. Price., 19% yearend , oxide 99.9% purity 1,400
S/kg. (1,400 $/kg * 1,000 kg/mt = 1,400.000 $/mt)
Selenium:
Production: Mineral Commodity Summary
Price:	Mineral Commodity Summary
3.20 $/pound. (3.20 S/pound *
1997. Production 1996, refinery: 350 mt
1997. Price, dealers, average, 100 pound lots, refined:
2204.623 pounds/mt = 7,055 $/mu
Synthetic Rltii.e:
Production: Mineral Commodity Specialist 1994: 140,000 mt
Price:	Mineral Commodity Summary 1997 (p 140). Price, 1996 yearend: Bulk, f.o.b. Australian
ports - 650 S/mt.
Tantalum, Columbium, and Ferrocollmbilm:
Tantalum:
Production: Mineral Commodity Summary 1997 (p 170), consumption 1996: reported, raw material
490,000 kg. (490,000 kg * 1 mt/1000 kg = 490 mt)
Price:	Mineral Commodity Summary 1997(p 170): 27.75 S/pound (27.75 $/pound * 2204.623
pounds/mt = 61,178 $/mt)
Columbium:
Production: Mineral Commodity Summary 1997 (p51), Consumption, apparent 3,800,000 kg.
(3,800,000 kg * 1 mt/1000 kg = 3.800 mt)
Price	Mineral Commodity Summary 1997 (p51). Price 1996: Columbite 3.00 $/pound. (3 00
S/pound * 2204.623 pounds/mt = 6613 S/mt)
Ferrocoluinbium:
Production: Mineral Commodity Summary 1997 (p 51) Consumption 1996, reported:
2,800,000 kg. (2.800,000 kg * 1 mt/1.000 kg = 2,800 mt)
Price:	Mineral Commodity Summary 1997 (p 51) Price of steelmaking grade Ferrocolumbium
6.58 $/pound. (6.58 S/pound * 2204.623 pound/nit = 14,506 S/mt)
Tellurium:
Production: Tellurium is primarily produced from copper tankhouse (or anode) slimes. The reported
waste generation of these slimes was 4.000 mt/yr. We estimated that no more than 10
percent of this stream was tellurium, and hence, the generation rate of tellurium was 400
mt/yr.
Price:	Mineral Commodity Summary 1997 (p 172) Price 1996, 99.7% minimum: 21 S/pound.
- (21 S/pound * 2204.623 pounds/mt = 46,287 S/mt)
Titanium, and Ti i anium Dioxide:
Titanium Dioxide:
Production: Mineral Commodity Summary 1997, Titanium Dioxide -Production 1996- 1,230,000 mt
Price:	Mineral Commodity Summary 1997, Titanium Dioxide, 1996 Puce, rutile. list, yearend:
1.09 $/pour.d. (1.09 $/pound * 2204.623 pound/mt = 2403 $/mt).
April 30, 1998

-------
1-5
Titanium Sponge:
Production: Mineral Commodity Summary 1994: 25,000 mt (estimated based upon 1989 and 1990
production levels)
Price:	Mineral Commodity Summary' 1997, (p 181) Price 1996 yearend 4.50 $/pound. (4.40
S/pound * 2204.623 pound/mt ~ 9920 S/mt)
Tungsten:
Production:
Price:
Mineral Commodity Specialist 1996: 8,449 mt.
Mineral Commodity Summary 1997 Price 1996. concentrate average: US spot market,
Metals Week - 67 $/mtu W O (67 $/mtu * mtu/7.93 kg * 1000 kg/mt = 8449 S/mt)
Uranium:
Production:
Price:
Energy Information Administration, Uranium Industry Annual 1997, April 1997 (pi 3)
Production, 1997: 4,700,(MM) pounds. (4,700,000 pounds * mt/2204.623 pounds =2132
mt)
Energy Information Administration, Uranium Industry Annual 1997, April 1997 (p 12)
Price 1997: 14.12 S/pound. (14.12 $/pound T 2204.623 pounds/mt = 31.130 $/mt)
Zinc:
Production:
Price:
Mineral Commodity Summary 1997, (pl90> Production 1996: Mine recoverable 620.000
mt.
Mineral Commodity Summary 1997 (pi90) Price 1996: average, Domestic producers -
51 0 cents/pound. (.51 $/pouiid * 2204.623 pounds/mt = 1124 $/mt)
Zirconium and H afnium:
Zirconium:
Production:
Price:
Mineral Commodity Specialist 1993: 9,000 mt/yr
Mineral Commodity Summary 1997, (pi92) Price 1996: Zirconium Sponge 9-12 S/pound
(Average 9-12 S/pound * 2204.623 $/mt = 22,146 $/mt)
Hafnium:
Production: Mineral Commodity Specialist 1993 - 900 mt/yr
Price:	Mineral Commodity Summary 1997, (pi92) Price 1996: Hafnium Sponge 165 - 210 S/kg
(Average 165-210 S/kg - 1000 kg/mt = 185,000 S/mt)
April 30, 1998

-------
1-6
Calculations lor Value Added
For Industry Sectors in SIC 3339
Primary Smelting and Refining of Nonferrous Metals, N.E.C. (SIC 3339)
Census of Manufactures. 1995
Value Added bv Manufactures = 989,900,000
Sector
Value of
Shipments $
Ratio of
Sector/Total
Shipments
Value Added (Ratio x
Value Added) $
Antimonv
67.355,100
0.0074594
7,384,052
Beryllium
76,522,880
0.0084747
8,389.104
Bismuth
8,606/00
0.0009531
943.508
Cacmium
3.996.200
0.0004426
438,098
Germanium
36,000,000
0.0039869
3,946,633
Gold and Silver
3.584 214,601
0.3969419
392,932,803
Lead
365 840,000
0.0405158
40,106,565
Maanesium and Magnesia
551.594,000
0.0610986
60,481,498
Platinum Group Metals
42.792.580
0.0047392
4.691.295
Rhenium
20,900.000
00023146
2.291,240
Selenium
2,469.250
0.0002735
270,701
Tellurium
2.777.220
0.0003076
304,463
Titanium and Titanium Dioxide
3,203.707.220
0.3548018
351,218,272
Zinc
696,880,000
0.0771775
76,398,052
Zirconium and Hafnium
365,814,000
0.0405129
40,103,715
TOTAL VALUE
9,029,569,451
1.00
989,900,000
April 30, 1998

-------
RISK AND BENEFITS ASSESSMENT FOR THE STORAGE OF
RECYCLED MATERIALS 	
APPENDIX J
This appendix presents a brief summary of the groundwater (Section J.l) and the multipathway
(Section J.2) risk assessment for the land storage of newly-identified mineral processing wastes under the
modified prior treatment baseline. This effort builds on previous efforts on the identification of recycled
waste streams, the estimation of recycled volumes, the identification of waste management strategies, and
in the development of waste constituent concentration data, described in the December 1995' and August
1996: Draft RIAs for the Phase IV LDRs and in the Technical Memorandum reporting the Revised Risk
Assessment Results for groundwater submitted to EPA in July, 1996. '
The analyses presented in this appendix differ from the previous risk assessments for mineral
processing wastes, first, in that risks from land storage, rather than ultimate disposal, are evaluated. The
assessment is limited to only those waste streams that have been identified as being recycled by the
Agency. This effort also differs from previous risk assessments in that it only addresses risks under the
modified prior treatment baseline, and does not quantitatively evaluate residual risks under any of the
proposed regulatory alternatives. This is because, under three of the regulatory alternatives, requirements
would be imposed requiring the storage of recycled materials in either buildings or tanks, rather than on the
ground, and release and transport models appropriate to evaluating risks associated w ith these technologies
are not available. Thus, the assessment presented below evaluates only "baseline" risks by identifying
specific waste streams and constituents posing risks of regulatory concern under the modified prior
treatment assumptions. These risks would be reduced under the proposed regulatory controls, but
quantitative estimates of the benefits of these regulatory controls (e.g. the numbers of facilities going from
high-risk to low-risk categories) are not developed. Under Option 4, no controls would be imposed on the
storage of recycled materials, so there would be no health benefits.
Finally, the risk assessment described in this appendix differs from previous risk assessments for
mineral processing wastes in that risks are evaluated for pathways other than groundwater ingestion. As in
previous risk assessments, we evaluate leachate releases from land-based units to groundwater and
subsequent groundwater ingestion. However, in Section J.2 we evaluate the risks associated with other
release events, transport and exposure media, and exposure pathways. This multipathway analysis
evaluates risks associated with air particulate and surface runoff releases from waste piles, and risks arising
from surface impoundment runon events and mlet/'outlei control failures. The transport and exposure
media that are evaluated include air, soil and surface water, as well as home-grown crops and game fish.
' ICF Incorporated. Regulatory Import Anahsis of the Supplemental Proposed Rules Applying Phase
IV Land Disposal Restrictions to A'ewh Identified Mineral Processing Wastes, Submitted to the Office of
Solid Waste. US Environmental Protection Agency, December 199::.
2	ICF Incorporated, Regulatory Impact Analysis of the Application of Phase IV Land Disposal
Restrictions to \'cw!y Identified Mineral Processing Wastes, Submitted to the Office of Solid Waste, US
Fnvironmental Protection Agency, August 1996.
3	ICF Incorporated. Revised Results oj Mineral Processing Wastes Risk and Benefits Assessments
Using Constituent-Specific DAFs Derived for Mineral Processing Waste, Submitted to the Office of Solid
Waste. US Environmental Protection Agency, July 1. 1996.
April 30, 1998

-------
J-2
J. l Risk assessment Methods and Results for the Groundwater Pathway
This section of Appendix J presents a brief summary of the groundwater pathway risk assessment
for the land storage of newly identified mineral processing wastes under the Modified Prior Treatment
baseline. The analyses presented below employ very similar methods for estimating constituent releases,
groundwater exposure concentrations, and health risks as were employed in the previous analyses. The
only major differences from previous efforts are that groundwater DAFs have been derived using
constituent concentration data for only those facilities and waste streams identified as being involved in
recycling, and that the DAFs have been derived assuming a release duration of 20 years, corresponding the
assumed life of the recycling storage facilities, instead of the much longer release period assumed for
disposal facilities This section addresses only those potential health risks arising from exposures through
consumption of contaminated groundwater. Potential risks associated with other release, transport, and
exposure pathways are evaluated in Section J.2.
J.1.1 Methods and Assumptions
J.1.1.1 Regulatory Scenarios
As noted previously, risks have been assessed for the modified prior treatment baseline. Under
this baseline, it is assumed that recycled spent materials and sludges and byproducts from mineral
processing will be stored land-based units prior to recycling. Nonwastewaters would be stored in unluied
waste piles, and wastewater and liquid nonwastewater streams would be stored in unlined surface
impoundments. Unlike the situation for disposal facilities, it is assumed that, where two or more recycled
streams are generated at a facility, the streams would be stored in separate units prior to recycling, and that
there would be no comanagement. Also, it has been assumed that the storage units would be sized to just
accommodate the required amount of recycled material; three months' generation rates in the case of
nonwastewaters, and one month's generation in the case of wastewaters and liquid nonwastewaters. The
assumptions used to evaluate the size and configuration of storage facilities are described in detail in the
December 1995 RLA and in Appendix D of this RIA.
.1.1.1.2 Identification of Waste Streams
Under the modified prior treatment baseline, it is assumed that all recycled spent materials and
recycled sludges and byproducts would be managed in land-based units. Thus, all of these waste stream*
were candidates for the storage risk assessment. Constituent concentration data were available for only
some of these streams, however. Risks were therefore evaluated only for the 14 recycled waste streams
listed in Exhibit J-l. Two of the waste streams (aluminum and alumina cast house dust and zinc waste
errosilicon'i arc nonwastewaters. and the remainder are wastewaters or liquid nonwastewalers.
Although groundwater pathway risks were calculated for only 14 of the 117 total mineral
piocessing w;Me streams, these streams represent substantial proportions of the total generated wastes and
an even higher-proportion of the recycled wastes. Depending on which estimate of waste generalion is
used (minimum, expected, or maximum), the 14 recycled streams included in the risk analysis represent
between 32 and 61 percent of the total waste generation, and account for between 60 and 89 percent of the
total recycled volume. This is because constituent concentration data are available for a substantial
proportion of the high-volume waste streams. The extent of coverage of the storage risk assessment for the
various commodity sectors is summarized in Attachment J.A to this appendix
April 30. 1993

-------
J-3
J.1.1.3 Waste Characterization Data and Release Concentration Estimates
The original source of constituent concentration data for the recycled materials used in the pre-
LDR risk estimates is the same as that used in the RIA sample-specific risk assessment. These data are
summarized in Appendix K of the December 1995 RIA. Consistent with the previous risk assessment,
constituent concentration data from both bulk samples and EP extraction analysis were used in the risk
assessment, when they were available, to develop separate risk estimates lbr the same waste streams. This
was done in order to make the best possible use of the available data, and because in many cases we could
not be sure that EP and bulk analyses from a given waste stream were from the same samples or batch of
waste.
Exhibit J-l
Recycled Streams Included in The Storage Risk Analysis
Commoditv
Recvcled Stream
Aluminum and Alumina
Cast House Dust
Beryllium
Spent Barren Filtrate Streams
Beryllium
Chip Treatment Wastewater
Copper
Acid Plant Blowd
-------
J-4
Exhibit J-2
Distribution of Samples hy Waste, Sample, and Facility Type
Waste Type
Bulk
Samples
EP Extraction
Sample
Known
Facilities
Unknown
Facilities
Nonwastewater
2
1
0
3
Wastewater
97
27
68
56
Liquid Nonwastewater
49
16
12
53
Arsenic concentration data were available for 75 of the waste samples, allowing the calculation of
cancer risks for these samples. Noncarcinogen concentration data for constituents having DAF values and
RfTK were available for 136 samples, which include all 75 of those with arsenic data. For WW streams,
the bulk concentration sample results were used directly as release concentration estimates. For LN'WW
and NWW, EP leachate concentrations were also used directly as release concentrations. For LNWW and
WW bulk samples, release concentrations (mg/1) were conservatively estimated as being equal to the bulk
constituent concentrations (mg/kg) divided by 20. This approach conservatively assumes that all waste
constituents are 100 percent leachable,
. All of the analytical results from every sample were used to evaluate risks, with one exception. A
single biilk analytical result for selenium (100,000 mg/l) in zinc process wastewater was omitted from the
risk analysis because this value far exceeds the maximum solubility of most naturally occurring selenium
compounds, and is clearly spurious, based on the results for other samples from the same waste stream.
J.1.1.4 Exposure Assessment
Analogous to the procedures used in previous risk assessments, two sets exposure of exposure
estimates were developed. Central tendency  exposure concentrations were estimated by dividing the
release concentrations of each constituent from each waste stream by the 75tli percentile DAF value
derived for that constituent. High-end (HF.) exposure concentrations were estimating by dividing the
release concentrations by the 95th percentile DAF values. The rationale for using the 75th percentile
DAFs rather than, for example, the 50th percentile value was that the EPACMTP model used to derive
DAF> does not consider fractured or channeled flow or other facilitated transport mechanisms which may
occur at some sites, resulting in higher groundwater concentrations than those predicted for homogeneous
flow proc?sses modeled by EPACMTP. The 75th percentile of the DAF distribution was therefore judged
by EPA to be more nearly representative of dilution conditions for the entire population of facilities than
'Jit SOtli percentile. The 95th percentile constituent-specific DAF values were used to estimate high-end
i'HH; groundwater concentrations in keeping with the definition of a high-end receptor as someone
exposed at levels between the 90th and 99th percentiles of all exposed individuals. Separate exposure and
risk estimates were developed for each waste sample, analogous to the approach used for the analysis of
disposal risks DAF values were derived separately for waste piles and surface impoundments, and used to
estimate exposure concentrations for nonwastewaters and liquid nonwastewatcrs/wastewaters, respectively.
The DAF values derived by EPA for use in the mineral processing recycled materials storage risk
assessment are shown in Exhibit.!-?.
It can be seen from this exhibit that the DAF values (both the 75th and 95th percentile) derived for
the management of recycled materials in waste piles are generally very much higher than those derived for
April 30. 1998

-------
surface impoundments. This is due primarily to the lower leachate volume generated hy the waste piles
than by surface impoundments. In the waste piles, leachate generation is limited by rainfall (and a large
proportion of the facilities are in relatively dry areas), whereas surface impoundments provide their own
leachate source to drive releases, in the form of the aqueous liquid wastes which they contain.
For all of the constituents, the CT DAF values for waste piles are greater than 1012, implying, as
will be seen below, such high dilutions of leachate that CT risks from all the constituents released from
waste piles are well below levels of regulatory concern. The HE DAF value for waste piles tire much
lower for most constituents (in the range of 1QJ to 1 (f). but still generally several orders of magnitude
above even the corresponding HE values for surface impoundments. Thus, even the HE exposure
concentrations associated with releases from waste piles result in relatively low risks.
The CT surface impoundment DAF values for all of the constituents but cyanide, lead, and
mercury are all around 1000. The HE DAF values surface impoundments are mostly less than 100, with
the exceptions being vanadium, cyanide and lead. As will be seen below, these lower DAF values imply
higher risks for given constituent concentrations than 'do the DAF values for waste piles.
Exhibit J-3
DAF Values Used in the Storage Risk Assessment
Omstituint
Waste Pile DAF
Surface Impoundment DAF
75;li PeiLciitile
95th Pciccntiii:
75ili PeieerUile
95(:i Percentile
Antimimv
>10i:
2.0X10'
2.7X10*
53XKV
Arsenic
>I0':
1.8X10"
1.1X10'
3.37X10
Barium
>;o'-
I.2X104
1 5X10-
2.9
Cadmium
>10':
2.-X10"
2.1X10*
1.3X10-
Chromium (+6)
>10'"
9.9X10'
6.3X10-
2.4X10'
Cvanidc
NA*
NA
2.9X10"
1.8X10'
Lend
>10"
>10"
>10':
1.2X10-'
Mcicurv
>10':
3.3X10"
1,5X10'
2.6X10'
Nickel
>10-
3 4X10"
1,6X10-'
1 2X10'
Sclen.um
>10:"
2 4X10J
1.9X10:
62
Silver
>10 ?
2.5X10'
4,3X10-'
4.2
Thallium
NA
NA
3.5X10'
9.0X10'
Vanadium
NA
NA
>10"
>10"
Zinc
>10"
5.SXI0"
6.7X1 ():
3.9
* OAFs w;rc not derived for these constituents because nc analytical data were reported for these constituent* in
any of the wastes disposed in waste piles.
April 30. 1998

-------
J-6
J. 1.1.5 Risk Characterization
Daily intakes of the waste constituents due to groundwater ingestion are estimated in precisely the
same way as described in the July memorandum.2 For arsenic, (the unly constituent considered to be
carcinogenic by ingestion), lifetime daily intake is calculated for a 70-kg adult drinking 1.4 liters per day of
contaminated groundwater 350 days per year for nine years, assuming a "70-year life-span for averaging
purposes. Daily intakes of noncarcinogens are calculated using the same assumptions, except that the dose
is averaged over the period of exposure, rather than over a lifetime-
Lifetime cancer risks arc calculated by multiplying the lifetime daily arsenic intake (from those
waste streams having arsenic as a constituent) by the. ingestion Cancer Slope Factor for arsenic of 1.5
(mg/kg-day)'1. Noncancer hazard quotients for exposure to waste constituents are calculated by dividing
the daily constituent intake of each constituent by its ingestion pathway Reference Dose (RfD) The
toxicity values used in the assessment all come from FPA's IRIS database, and are current as of December
1996
J.1.2 F.stimation of Numbers of Facilities at Specific Risk Levels
In the previous risk and benefits assessments performed for the disposal of mineral processing
wastes, the measure of the benefits of the regulatory alternatives was the reduction in the number of
facilities at which waste management would results in risks above levels of regulatory concern. As nuted
previously, no risk assessment has been performed for the storage of recycled materials under any of the
regulatory alternatives. Thus, a similar quantitative benefits assessment is not possible for waste storage
under the various regulatory alternatives.
This risk assessment, however, does provide an estimate of the numbers of facilities in the various
commodity sectors at which risks exceed levels of regulatory concern under the modified prior treatment
baseline. This estimate presents an upper bound limit on the possible regulatory benefits; e.g., if regulation
reduced releases of all waste constituents to zero, then all of the baseline risks greater than levels of
regulatory concern would go to zero as well. Less than perfect control of releases would result in
correspondingly smaller reductions in the number of facilities at high risk levels (yielding lower benefits),
although the magnitude of risk reduction has not been quantified.
J. 1.2.1 Estimation of the Numbers of Facilities Storing Recycled Materials
Risks have been assessed for all of the commodity sectors and waste stream which have been
identified by the Agency as being involved in recycling under the modified prior treatment baseline, and
for which constituent concentration data are available, as identified in Exhibit J-l. In this analysis, it has
been assumed that all of the facilities in each commodity sector not only generate but store recycled
sludges, byproducts, and spent materials. Thus, the numbers of facilities included in the assessment are
simply equal the estimated numbers of facilities in the commodity seclot, which is exactly analogous to the
approach taken" in the analysis of the risk? associated with waste disposal.
In this analysis, it has been assumed that all of the facilities identified as generating the recycled
streams also recycle them, under both CT and HE assumptions. Thus, the number of waste stream-facility
combinations in each commodity sector is the same for the HE and CT risk estimates Analogous to the
previous analysis, where a single facility stores more than one waste stream, it is counted as more than one
"waste stream-facility combination."
April 30, 1998

-------
J-7
J. 1.2.2 Attribution of Risks to Facility-Waste Stream Combinations
As was the case for the analysis of disposal risks, the number of risk estimates (one from each
sample) does not always equal (in fact, rarely equals) the number of facilities storing the wastes. Thus, in
estimating the distribution of risks across a commodity sector it is necessary to apportion the risks from
individual samples to the CT and HE numbers of facilities.
The procedures used to do this are described in detail in Section 2.2.2 of the July memorandum.
Basically, the approach involves distributing risk levels across the facilities in commodity sector in as close
to the same proportions as they are distributed across the individual waste samples from the waste
generated by that sector. For example, if there are two samples of a given waste stream in the data base,
one with an estimated cancer risk of 10" and one with an estimated risk of 10 \ half the facilities in the
commodity sector would be placed in the "< 105" category, and half would fall into the "10! to 102'
category. One of the outcomes of using this approach is that not every risk result above a level of concern
translates into a waste stream-facility combination. For example if there is only a very small proportion of
samples (for example, one in 20) giving high risks, this may translate into zero waste stream facility
combinations if there are, for example, only two or three total facilities in the industry. The July memo
describes the approaches used for rounding the estimates of facilities in the various risk categories, where
apportionment cannot be done evenly, and for combining risk estimates from multiple samples from a
single facility so, so as not to give them undue weight across an entire industry.
J.1.3 Results of the Groundwater Risk Assessment
J.1.3.1 Risk Assessment Results by Sample
Exhibit J-4 summarizes the carcinogenic groundwater risk results for the 75 samples identified as
containing arsenic, the sole ingestion pathway carcinogen among the waste constituents Using the central
tendency DAF values, the calculated cancer risks for of these samples were less than 10 \ the level of
regulatory concern, and the risks for 27 of the samples exceeded this value. Cancer risks exceeded 10 for
one or more samples from only four waste streams; copper acid plant blowdown, elemental phosphorous
furnace scrubber blowdown. tantalum, columbium. and ferrocolumbium process wastewater, and zinc
spent surface impoundment liquids. The highest risks cancer risks were associated with three samples of
cuppei acid plant blowdown (10' to 101). This waste stream accounted for 14 of the 16 samples with the
highest CT cancer risks. The next highest risks (in the I0"4 to 10'3 range) were associated with one sample
each from tantalum process wastewater and zinc spent surf ace impoundment liquids.
Using the high-end (CT) DAF values, cancer risks calculated for the groundwater pathway
exceeded 10'5 for 49 of the 75 samples. Under this set of assumptions, risks for at least one sample
exceeded 10? for 10 of the 14 waste streams evaluated. The highest risks (highest risk category >10-1)
were again' associated with copper acid plant blowdown (4 of its 30 samples), with the next highest risk
(10 ; to 10 ') being associated w ith the singie sample of zinc spent surface impoundment liquids Of the
wastes whose CT cancer risks were below 10f for all samples, five (rare earths process wastewater,
selenium plant wastewater, titanium/TiO, leach liquor and sponge wash water and scrap milling scrubber
water, and zinc process wastewaters), had at least one sample with HE cancer risks above this level.
April 30. 1998

-------
J-b
Exhibit J-4
Distribution of Samples by Groundwater Risk Category: Cancer Risks



Central Tendency


lliuh
Lnd




Number




o( Samples

10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2



with

to
to
to
to


to
to
lo
to

Commodity
Waste Stream
Cancer Risk
<10-5
10-4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
10-1
>10-1
Aluminum and Alumina
Cast house dust
2
o
0
0
0
0
0
2
0
0
0
0
0
Beryllium
Spent barren filtrate streams
2
1
1
0
0
0
0
1
0
1
0
0
0
Beryllium
Chip treatment WW
1
1
0
0
0
0
0
1
0
0
0
0
0
Copper
Acid plant blowdown
30
9
7
8
3
3
0
5
3
5
8
5
4
Elemental Phosphorus
Furnace scrubber hlnwdown
8
7
1
0
0
0
0
3
3
2
0
0
0
Rare Rarlhs
PWW
2

u
0
0
0
0
0
*>
0
0
0
0
Selenium
Plant PWW
2
2
0
0
0
0
0
0
1
1
0
0
0
Tantalum, Columhium, and
I'crruculumbium.
PWW
13
10
2
1
0
0
0
7
3
0
3
0
0
Titanium and TiO,
l.each liquor i& sponge wash walei
2
2
0
0
0
0
0
0
1
1
0
0
0
Titanium and TiO,
Scrap milling scrubber water
1
1
0
0
0
0
0
0
1
0
0
0
0
Zinc
Waste fcrrosilicon
0
0
0
0
0
0
0
0
0
0
0
0
0
Zinc
Spent s.i. liquids
1
0
0
1
0
0
0
0
0
0
0
1
0
Zinc
WWTP liquid effluent
0
0
(J
0
0
0
0
0
0
0
0
0
0
Zinc
Process wastewater
II
II
()
0
0
0
0
7
1
3
0
0
0
Totals

75
4S
II
10
3
3
()
26
15
13
II
6
4
April 30. 1998

-------
J-9
Cancer risks for most of the samples increased about two orders of magnitude from the CT to HE
case. This is consistent with the difference between the CT and HE DAF values for arsenic managed in
surface impoundments. In the case of the NWW waste streams managed in piles, both theCT and HE
cancer risks for all samples were below 10'\ For aluminum/alumina cast house dust, this reflected the
much higher CT and HE DAF values for arsenic managed in waste piles, compared to surface
impoundments, as well on the relatively small mass of arsenic present in the waste pile. Arsenic was not
detected in the single sample of waste feirosilicon from zinc production. Thus, no carcinogenic risks were
calculated for this waste. The two other streams for which all HE sample-specific cancer risks were below
10> were beryllium chip treatment wastewater and zinc wastewater treatment plant liquid effluent.
Noncancer hazard quotient values for groundwater pathway for the individual samples of recycled
materials are summarized in Exhibit J-5 Using the CT DAF values, hazard quotient values exceeding 1.0
were calculated for 46 of 136 total samples from the 14 waste streams. As was the case for cancer risks,
copper acid plant blowdown had the highest number of samples with noncancer hazard quotients above 1.0
(18 of 35 samples), and had the highest number of samples (4) in the highest risk category (HQ = 100 to
1000). Samples from zinc production (11 of 22 for spent surface impoundment liquids and 8 of 16 for
process wastewater) account for the bulk of the remaining hazard quotients above 1.0. The only other
waste streams with CT hazard quotients above 1.0 included beryllium spent barren filtrate streams (three
samples), beryllium chip treatment wastewater (one sample), elemental phosphorous furnace scrubber
blowdown (one sample), tantalum, etc., process waste water (three samples), and zinc wastewater
treatment plant liquid effluent (one sample).
When the HE DAF values are used to calculate exposures, hazard quotients exceed 1.0 for 102 of
the 136 samples. As was the case for cancer risks, most of the hazard quotient values for individual
samples are increased one to two orders of magnitude in the HE case compared to the CT case, reflecting
the changes in the DAF values for the risk driving constituents managed in surface impoundments. As for
cancer risks, both the CT and HE DAF values lor waste piles for .ill (if the constituents are so high, and the
masses of constituents are so low, that no samples of the two waste streams managed in waste piles have
hazard quotient; exceeding 1.0 in either the CT or HE case. Hazard quotient values for four waste streams
that were all below 1.0 in the CT case exceeded 1.0 in the HE case for at least one sample (rare earth
process wastewater, selenium process wastewater, and titanium/TiO, leach liquor and sponge wash water
and scrap milling scrubber sludge).
J.1.3.2 Risk Driving Constituents
For all of the cancer risk calculations, arsenic, being the only ingestion pathway carcinogen among
the constituents evaluated, was always the risk driver In the case of noncancer risks, many constituents
drove risks (had the highest hazard quotients) for the samples evaluated. The noncancer risk driving
constituents (constituents with the highest HE hazard quotients) for the various waste streams are identified
in Exhibit J-6.
April 30, 1998

-------
J ID
Exhibit J-5
Distribution of Sum pics by Groundwater Hazard Category: Non-cancer Hazards



Central Tendency
High F.nd


Number of




Samples with

1
10
100
Ik


1
10
100
lk



Non-cancer

to
to
to
to


to
to
to
to

Commodity
Waste Stream
Hazard
<1
10
100
Ik
10k
>IOk
<1
10
100
lk
10k
>10k
Aluminum and Alumina
Cast house dust
2
2
0
0
0
0
0
2
0
0
0
0
0
Beryllium
Spent barren filtrate streams
4
1
3
0
0
0
0
0
1
3
0
0
0
Beryllium
Chip treatment WW
1
0
0
1
0
0
0
0
0
0
0
1
0
Copper
Acid plant hlowdown
35
17
10
4
4
0
0
3
7
12
7
4
2
Elemental Phosphorus
Furnace scrubber blowdown
l<1
n
1
0
0
0
0
4
4
5
1
0
0
Rare Earths
PWW
4
<1
0
0
0
0
0
2
2
0
0
0
0
Selenium
Plant PWW
2
2
0
0
0
0
0
0
2
0
0
0
0
Tantalum, Columbium,
PWW
21
18
3
0
0
0
0
13
3
0
5
0
0
and Femicolumbium














Titanium and TiO,
l.cach liquor A sponge
2
2
0
0
0
0
0
0
1
1
0
0
0

wash water













Titanium and TiCX
Scrap milling scrubber
1
1
0
0
0
0
0
0
1
0
0
0
0

water













Zinc
Waste fcrrosilicon
1
1
0
0
0
0
0
1
0
0
0
0
0
Zinc
Spent s i. liquids
22
II
5
4
2
0
0
4
3
2
7
2
4
Zinc
WWTP liquid effluent
3
2
0
0
1
0
0
0
1
1
0
0
1
Zinc
Pmccss wastewater
2.1
16
7
1
0
0
0
5
4
5
8
2
0
Totals

l?6
90
29
10
7
0
0
34
29
29
28
9
7
April 30. 1998

-------
J-l I
Kxhibit J-6
Constilucnts Driving Non-cancer Hazard Quotients in Recycled Streams
Commodity
Waste Stream
Driving Constituent (number of samples)
Aluminum and Alumina
Cast house dusl
2 samples total, no ha/.atd quotients greater than 1
Beryllium
Spent barren liltrate streams
Beryllium (4/7), Thallium (1)
Beryllium
Chip treatment WW
Beryllium (l/l)
Copper
Acid plant blowdown
Arsenic (15/35), Cadmium (II), Chromium (1), Lead (1), Selenium (1), Thallium (1 >, Zinc (2)
Klemental Phosphorus
Furnace scrubber blowdown
Cadmium (8/14), Cluomium (1), Thallium (1)
Rare F.arths
PWW
Thallium (2/4)
Selenium
Plant PWW
Arsenic (1/2), Thallium (1)
Tantalum. Culumtiium, and
PWW
Antimony 11/21), Cadmium (3), Chromium (4)
Perrocolumbium


Titanium and TiO:
1 -each liquor ite sponge wash water
Thallium (2/2)
Titanium and TiO,
Scrap nulling scrubber water
Thallium (l/l)
Zinc
Waste Icrrosilicon
1 sample total; no hazard quotients greater than 1
Zinc
S|>enl s i. liquids
Cadmium (12/22), Zinc (6)
Zinc
WWTP liquid effluent
Cadmium (2/3), Zinc 11)
Zinc
Process wastewater
Cadmium (12/2"1 *), Zinc (7)
* A sample with a selenium concentration of 100.000 ppm was excluded from Ihc analysis
April 30, 1998

-------
J-12
J.1.2.3 Risk Assessment Results by Facility
The cancer risk results for the individual sample1;, distributed across the numbers of facilities
generating and storing the wastes, are summarized in Exhibit J-7. Using the methods described in Section
J 1 1.2. it was estimated that CT groundwater pathway cancer risks would exceed 10'5 at 11 of the 56 waste
stream-facility facilities4. All of these waste stream-facility combinations were managing either bery llium
spent barren filtrate streams (1 facility-waste stream combinations), copper acid plant blowdown (7
facility-waste stream combinations), or zinc spent surface impoundment liquids (3 combinations). These
results, of course generally reflect the pattern of sample-specific risk results for the various waste sectors.
It will be noted, however, that for two waste breams, findings of one or more sample with greater than 10 1
risks did not translate into any facility-waste combinations above 105 risks. In the case of elemental
phosphorous furnace scrubber blowdown, only one of seven samples had a cancer risk of just above 10'\
Distributed across two facilities estimated to be storing this waste, this result (one-seventh of the samples
having risks above 10'') was rounded down to zero Similarly, in the case of tantalum, etc., process
wastewater, three of thirteen samples with risks above 10 " was again rounded downward to zero of two
facility-waste stream combinations. This occurrence is the almost inevitable result of having so few
facilities in so many industries, and the fact that non-integral numbers of waste-stream facility
combinations are meaningless as risk or benefit indicators. It would be reasonable to interpret these results
as indicating that either zero or one facility in these industries might have CT cancer risk above 10 \
When Hb DAF values are used, the number of facility-waste stream combinations with cancer
risks above 1()'5 increases to 23 of 56 facilities. Under HE assumptions, most of the waste streams show
one or more facilities at risk levels above 10 \ the exceptions being the four low-risk waste streams
identified in Exhibit J-4. These include both the two NWW streams that would be stored in waste piles, as
well as beryllium chip treatment wastewater and zinc wastewater treatment plant liquid effluent. As noted
previously, arsenic is not reported as a constituent of the latter waste.
The distribution of facility-waste stream combinations by noncancer risk category is summarized
in Exhibit J-8. Using the CT DAF values, 12 waste stream-facility combinations are identified as having
noncancer hazard quotients greater than 1.0. Five of these facilities are managing copper acid plant
blowdown. two are managing beryllium chip treatment wastewater, and two ol' the facility-waste stream
combinations are associated with the management of zinc spent surface impoundment liquids.
Using HE DAF values, 27 waste stream-facility combinations are identified as being associated
with noncancer hazard quotients above 1.0. Again, four waste streams have no facility- waste stream
combinations with hazard quotients above levels of concern: aluminum/alumina cast house dust, rare earth
process wastewater, tantalum, etc., process wastewater, and zinc waste ferrosilicon.
J Note thai the totals in the risk categories e;> not sum exactly due to rounding This is true for the foliowir.i:
exhibit as well.
April 30. 1998

-------
Exhibit J-7
Distribution of Waste Stream-Facility Combinations by Groundwater Risk Category: Cancer Risks


Number of















Waste Stream/

Central Tendency



High End




Facility















Combinations* #

10-5
10-4
10-3
10-2


10-5
10-4
10-3
10-2



(Central
High

to
to
to
to


to
to
to
In

Commodity
Waste Stream
Tendency
End
<10-5
10-4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
10-1
>10-1
Aluminum and Alumina
Cast house dust
2 3
23
23
0
0
0
0
0
23
0
0
0
0
0
Beryllium
Spent barren filtrate streams
1
1
0

0
0
0
0
0
0

(]
(t
u
Beryllium
Chip treatment WW
}
2
2
0
0
0
0
0
2
0
0
u
0
0
Copper
Acid plain blowdown
10
10
3
2
3


0
2

2
*>
2
2
Elemental Phosphorus
Furnac e scrubber blowdown
2
2
2
0
0
0
0
0



0
0
U
Rare Earths
PWW
1
I

0
0
0
0
0
0

0
0
0
0
Selenium
Plant PWW
2
2
2
0
0
0
0
0
0


0
0
0
Tantalum, Colunibium, and
PWW
2
2
2
0
0
0
0
0

1
0
0
0
0
l-errocolumbiu m















Titanium ;ind I K).
Leach liquor & sponge wash water
2
2
2
0
0
0
0
0
0


0
0
0
Iitanium and Ti(J>
Scrap milling scrubber water
1
1

{)
0
0
0
0
0
1
0
0
0
0
Zinc
Waste leitosilicon
1
1
0
0
0
0
0
0
0
0
0
0
0
0
Zinc
Spent s i. liquids
3
3
0
0
3
0
0
0
0
0
0
0
3
0
Zinc
WWI'P liquid eltlueut
3
3
0
0
0
0
0
0
0
0
0
0
0
0
Zinc
Process wastewater
3
3
3
0
0
0
0
0
2
0
1
0
0
0
TOTALS-

56
56
40
3
e>
1
1
0
30
7
6
3
5
2
4 Sums by risk category may noi add to ihc number of central or high-end waste stream/facility combinations due to rounding.
# Includes waste st-vam'larility combinations with no career risk (but wr.h an associated non-cancer hazard)
April 30. 1998

-------
.114
KxhihitJ-8
Distribution of Waste Stream-facility Combinations by Groundwater Hazard Category:
Non-cancer Hazards


Numbci ul















Waste StreaiiV



Central Tendency




High Fnd




Facility





Combinations*


|
10
100
lk



10
100
lk



Central
High

to
to
to
to


to
to
to
to

Commodity
Waste Stream
Tendency
End
<1
10
100
lk
10k
>10k
<1
*10
100
lk
10k
>IOk
Aluminum and Alumin;i
C.isi house cIiim
23
21
21
0
0
0
0
u
23
0
0
0
0
0
Beryllium
Spent barren Ullralr streams
1
1
0
]
0
0
0
0
(}
0

0
0
0
Beryllium
Chip treatment WW
2
2
0
0
2
0
0
0
0
0
0
0
2
0
Copper
Avid plant blowdown
10
10
4
.1
1
1
0
0

2
3
->
1
1
Flemcntal Phosphorus
Furnaee scrubber blowdown
2
2
2
0
0
0
0
0


1
0
0
0
Rare Earths
PWW
1
1

0
0
0
0
0

0
0
0
0
0
Selenium
Plant PWW
2
2
2
0
0
0
0
u
0
2
0
0
0
0
Turuulum, Columbium. anil
PWW
' )
.
2
0
0
0
0
0

0
0
0
0
0
Fctiocolumbium















Titanium and I'iU>
Leach liquui & sponge wash water
2
2
2
0
0
0
0
0
0

1
0
(J
IJ
Titanium and TiO;
Scrap milling sciubber waier
1
1

0
0
0
0
0
0
1
0
0
0
0
Zinc
Waste Icno.Mhcon
1
1

0
0
0
0
0

0
0
0
0
0
'/-UK
Spent s.i. liquids
3
3
2
0
1
1
0
0
ft
n
0

0
1
Zinc
WWTP liquid diluent
3
*
2
0
0
1
0
0
0
l
1
0
0
1
Zinc
1'iocess wastewater
J
3
2
1
0
0
0
0

l
1
I
0
0
TOTALS*

.-56
Sf)
44
5
4

0
0
29
9
K
4
4
->
* Sums by hazard category may nol add to the nunu'Ci ul central or high L-nd \v;isle slieurn tacilny combination;. due to rounding.
April 30. 1998

-------
J-15
J.1.4 Summary of Groundwater Pathway Risk Results
The preceding analysis indicates that the storage of some mineral processing recycled materials in
land-based units under modified prior treatment baseline assumptions may be associated with significant
health risks due to groundwater consumption. Cancer risks greater than 105 and hazard quotients greater
than 1.0 are predicted for the minority of waste streams and individual samples under CT exposure
assumptions and for the majority of waste streams and samples under HE exposure assumptions.
Estimated cancer risks range up to 10' for some samples under CT exposure assumptions and exceed 10 1
under HE assumptions. Hazard quotient values similarly approach 1,000 under CT assumptions and
exceed 10.000 lor a few waste streams using the HE DAF values.
Copper acid plant blowdown has the largest number of samples with high cancer risks, and the
highest cancer risks for this recycled stream exceed those for the next highest stream by one to two orders
of magnitude. This stream also has the largest number of samples with hazard quotients above 1.0.
followed by zinc spent surface impoundment liquids and process wastewater.
Aluminum/alumina cast house dust and zinc waste ferrosilicon are the only two waste streams for
which no samples exceed 105 cancer risk or noncancer hazard quotient value of 1.0 under either CT or HE
assumptions. These are the only two nonwastewater streams evaluated, and the low risk results are
primarily a function of the very high DAF values for waste piles compared to the values derived for surface
impoundments. Two other waste streams (bery llium chip treatment wastewater and zinc wastewater
treatment plant liquid effluent) have low cancer risks even under HE assumptions, but one or more samples
of each of these wastes is associated with hazard quotients greatly exceeding 1.0, even under CT
assumptions.
Aluminum and alumina cast house dust (23 facilities) and copper acid plant blowdown (10
facilities) account for almost half the facilities evaluated in the analysis. As noted above, risks for the
former stream are all low, so cast house dust has no waste stream-facility combinations above risk levels of
concern. The majority of the waste stream-facility combinations managing copper acid plant blowdown, in
contrast, are placed into risk categories above levels of concern under both CT and HEassumptions, and
this waste stream contributes the largest number of waste stream-facility combinations at high risk levels of
any waste stream.
On a volume basis, two streams (copper acid plant blowdown and zinc process wastewater!
account for approximately 86 percent of the total recycled materials volume for which constituent
concentration data are available. As noted above, copper acid plant blowdown is one of the highest-risk
waste streams While the cancer risks estimated for zinc process wastewater generally fall into the low-risk
categories, the noncancer hazard indices associated with this waste stream are generally quite high,
especially under HE assumptions.
J. 1.5 L^certainties/Limitation of Analysis
Most of the. major sources of uncertainty for this risk assessment of storage of mineral processing
recycled materials are the same as those for the previous analyses of mineral processing waste disposal.
These uncertainties are discussed in detail in the cited references. To summarize briefly, the major
uncertainties include:
 Limitations in data concerning the identities, amounts, constituent concentrations,
and leaching behavior of the recycled materials.
April 30. 1998

-------
J-16
	Limitations in data concerning the amounts of the specific recycled streams
generated at specific facilities and the management methods used during storage.
	Limitation in knowledge concerning the locations, climatic, and hvdrogeological
settings at mineral processing facilities.
	Uncertainties and variability in the methods used to model leaching and
groundwater transport (DAFs) of the toxic constituents of recycled materials.
	Uncertainties in the methods used to identify exposed receptors, estimate human
exposures, and in characterizing the toxicological impacts of exposure to toxic
constituents of recycled materials.
All of these sources of uncertainty (and variability) apply at least as much to the evaluation of
storage risks as they did to the evaluation of risks from waste disposal. As noted above, the number of
samples used to derive DAFs, and for estimating risks for the recycled materials, is quite limited, even
more so than in the case of the waste disposal risk assessment. This is especially true for the
nonwastewaters managed in waste piles, for which only three samples from two waste streams (all from
unknown facilities) were available.
J.2 Risk Assessment Methods and Results for Non-Groundwater Pathways
This section presents a summary of the risk assessment for the land storage of newly-identified
mineral wastes under the non-groundwater modified pnor treatment baseline.
J.2.1 Methods and Assumptions
J.2.1.1 Overview of Risk Assessment Methods
The multimedia risk assessment for the storage of mineral processing wastes employs many of the
methods and assumptions used by EPA to develop the proposed risk-based exit levels for the Hazardous
Waste Identification Rule (HWIR-Waste). The HWIR-Waste Technical Support Document'1 provides a
detailed description of methods for evaluating releases, characterizing transport, and estimating exposures
and risks associated with a number of non-hazardous waste management units. Individual algontlm^ an J
equations from HWIR-Waste arc used to evaluate human exposures and risks associated with specific
types of release events from land-based units (waste piles and landfills) that manage mineral processing
recycled materials. In most cases, the HWIR-Waste methods are used without significant modification.
However, in some instances, models were adjusted or simplified to reflect the specific characteristics of the
facilities and constituents being modeled. For example, since none of the constituents addressed in this
effort are appreciably volatile, the volatilization release and depletion equations from the HWIR-Waste
models were not used and, since the recycling storage units were assumed to operate for only 20 years, the
long-term steady-state assumptions employed in HWIR-Waste to estimate media concentrations were not
valid, and time-dependent methods were substituted. Because of the shorter operating life spans of the
storage units, compared to the assumptions made in HWIR-Waste, we also eliminated the scil depletion
algorithms related to leaching and runoff. Thus, all soil contaminants were assumed to be fully conserved
for the entire, exposure period. Finally, particulate release and transport models were used which differed
USEPA. Technical Support Document for the Hazardous Waste Identification Rule: Risk
Assessment for Human and Ecological Receptors, Office of Solid Waste. August 1995.
April 30, 1998

-------
J-17
slightly from those used in HWJR-Waste, and generic climatic assumptions were used in the evaluation of
air transport. These methods are described in detail in Attachment J-B.
The same general assumptions regarding receptors and receptor behavior were employed in this
analysis as were used in FIWIR-Waste. With a few exceptions, the same values for exposure frequency
and duration and other exposure factors are used as were employed in HWIR-Waste. Most of the exposure
factors corresponded either to the adult resident, child resident, subsistence farmer, or subsistence fisher
receptors defined in HWIR-Waste, depending on whichever had the highest exposures and risks. The only
major exception was again related to the characteristics of the facilities being evaluated, in that release and
exposure durations were adjusted to 20 years for "direct" pathways, corresponding to the assumed life-span
of the management units. A full 30 years high-end exposure assumption is employed, however, for
exposures to persistent constituents in soils.
Input data for the release models come from the database of waste constituent concentrations
developed in support of the RIA (see Section J.1.1.3). In this case, however, only those streams are
included which hPA has identified as having non-zero recycled volumes in the expected cost scenario of
the modified prior treatment baseline. Facility characteristics and sizes from the least-cost management
strategies developed in the RIA are used, as discussed in Section 3.0 of this RIA.
The exposure and risk assessment algorithms are applied in a screening mode to identify those
management units, release events, and exposure pathways that may be associated with risks exceeding
regulatory levels of concern. In the screening mode, relatively conservative assumptions regarding
releases, exposures, and the toxicity characteristics of the waste constituents are used to provide a high
degree of assurance that exposures that could be associated with significant risks arc not missed. For most
of the release events, high-end (HE) assumptions are first used to identify the highest risks pathways and
constituents. If HE assumptions indicate that all risks are below levels of concern for a given pathway, no
further risk assessment is performed. If Hb risks are above levels of concern, central tendency (CT)
assumptions are used to determine whether risks are still of concern for particular waste management units,
waste streams, and constituents, and to help characterize the variability in risks that is associated with
changes in key variables.
The risk assessment presented below summarizes risks for single-release events and exposure
pathways. Risks are not summed across exposure pathways, unless it clear that exposure through one
pathway would reasonably he associated with exposure through another pathway for the same receptor
(risks from the ingestion of home-grown root and above ground vegetables are summed, for example).
The risk assessment has not been structured to consider detailed mass balances across release events or
exposure media, although each release event is evaluated to determine if it would result in a substantial
reduction of the amount of constituent available for release by other events. As will be seen in
Section J 2.2, no individual events were found that release substantia! portions of the annual recycled
volumes from any of the management units.
J.2.1.2" Regulatory Scenarios
As for the groundwater pathway, risks have been assessed for the modified prior treatment
baseline. Under this baseline, it is assumed that recycled spent materials, sludges, and byproducts from
mineral processing will be stored in land-based units prior to recycling. Nonwastewaters would he stored
in unlined waste piles, and wastewater and liquid nonwastewater streams would be stored in unlined
surface impoundments. Unlike the situation for disposal facilities, it is assumed that where two or more
recycled streams are generated at a facility, the streams would be stored in separate units prior to recycling,
and that there would be no comanagement. Also, it has been assumed that the storage units would be sized
April 30. 1998

-------
J-18
to just accommodate the required amount of recycled material  three months' recycled volume in the
case of nonwastewaters. and one month's recycled volume in the case of wastewaters and liquid
nonwastewaters. The assumptions used to evaluate the size and configuration of storage facilities are
described in detail in the August 1996 RIA.
J.2.1.3 Identification of Recycled Waste Streams
The same 14 waste streams were evaluated a.s in the groundwater pathway assessment. Since the
April 1997 RIA, the beryllium spent barren filtrate waste stream was added to the list of recycled waste
streams. This wastestream is however not listed further in this Appendix as it was evaluated and found not
to be a significant contributer to risk. As noted previously, the 14 streams which are evaluated account for
between approximately 32 and 61 percent of the total waste generated, and for between about 60 and 89
percent of the annual recycled volume, depending on which estimates are used, from the mineral
processing industries that have been evaluated. The extent of coverage of waste streams from the
individual industry sectors is summarized in Attachment J.A to this appendix.
J.2.1.4 Waste Characterization Data
The same data sources related to waste constituent concentration were used as described for the
groundwater pathway assessment in Section J. I. No data were available related to the particulate
characteristics of the two waste streams managed in waste piles. A reasonably conservative set of
assumptions were therefore developed regarding waste silt content, particle size distribution, and particle
size density, based partially on assumptions used in IIWIR-Waste and on assumptions made by EPA as
part of previous risk assessment efforts for similar mineral processing waste streams. These assumptions
are described in more detail in Attachment J.B
J.2.1.5 Facility Characterization Data
As noted above, facility size and configuration were determined for each recycled waste stream as
pan of the cost and economic impact analysis for the proposed Mineral Processing LDR. These methods
are described in detail of Appendix E of the August 1996 RIA. Under the modified prior treatment
scenario, it is assumed that all 14 recycled streams will be managed in unlined land-based units,
nonwastewaters in waste piles and wastewaters and liquid nonwastewaters in surface impoundment*. The
management units were assumed tn be sized to just meet the needs of the recycling units. Based on the
Agency's evaluation of recycling practices, and considering the constraints on the duration of storage
under existing regulations, it was assumed that all recycling storage piles would be sized to accommodate
one quarter of the annual recycled volumes for typical facilities in the various commodity sectors, and that
surface impoundments would be sized to accommodate one-twelfth of the annual recycled volumes of
liquid streams. Thus, all units disposing of the same waste streams in any given commodity sector are
assumed to be the same size Further, it is assumed that no comanagement of multiple waste streams
would occur :ii any management units.
For costing purposes, waste piles have been assumed to be conical, with side slopes of 2:1. Piles
are assumed to be unlined and uncovered, with no special controls of runoff or particulate suspension. For
purposes of emissions estimation, it is assumed that the piles are at full capacity at all times, and that the
entire annual recycled volumes of the waste streams pass through the units each year, being added and
removed at uniform rates on every day of operation throughout the year. It is assumed that, below a
minimum recycled volume (500 mt/yr per facility ! it is cheaper to store recycled materials in roll-off
containers than in piles, and recycled streams with an annual recycled volume less than this amount were
therefore not included in the risk assessment for waste piles. There was also an upper limit on the height
April 30, 1998

-------
J-19
and area of a single pile, but none of the recycled nonwastewater streams were recycled in large enough
volumes to reach this limit.
Surface impoundments used for recycling were assumed to be rectangular in shape, with a 2:1
length, width ratio and a rectangular prism-shaped bottom with a maximum depth of seven feet Again,
streams with annual recycled volumes of less than 500 mt/year per facility were assumed to be managed in
tanks or containers, rather than impoundments. All of the recycled wastewater and liquid nonwastewater
streams for which constituent data were available equaled or exceeded this volume, and thus all of them
were included in the risk assessment.
The characteristics of the units used to store the recycled streams prior to recycling are summarized
in Exhibit J-9 It can be seen that the two nonwastewater streams are both relatively low-volume, and the
management units are correspondingly small. The sizes of the surface impoundments for the storage of
liquid waste streams, on the other hand, span the range of the smallest possible facility size (42 cubic
meters for titanium/TiO, scrap milling scrubber water) to extremely large (99,167 cubic meters for zinc
process wastewater).
J.2.1.6 Identification of Release Pathways
The screening-level risk assessment addressed non-groundwater release events from waste piles
and surface impoundments managing mineral processing recycled streams. As an initial step in the risk
assessment, release events and pathways were identified and screened to determine which would be the
most likely to result in significant health risks to human receptors. The initial menu of events that were
considered came lrom the HW1R-Waste Technical Background Document. The results of the screening
are summarized in Exhibit .1-10. As noted previously, many release events were screened out because of
the characteristics of the units or the wastes involved. For example, volatilization release were eliminated
for all management units and streams, because none of the toxic constituents, in the chemical forms that
they are likely to be present, would be appreciably volatile.
The release events that have been addressed include the generation of air particulates and runoff
from waste piles, and the releases of liquid recycled streams from surface impoundments due to inlet/outlet
failures and ninon events during large storms. Groundwater releases from these units have been addressed
previously and are not further evaluated here
April 30. 1998

-------
J-20
Exhibit J-9
Facility Sizes for the Recycled Waste Streams
Commodity
Recycled Stream
Facility
Type1
Facility
Volume
(mJ)
Facility
Area
(mJ)
Aluminum and Alumina
Cast House Dust
WP
107
108
Beryllium
Chip Treatment Wastewater
SI
417
558
Copper
Acid Plant Blowdown
SI
22,083
10.441
Klemental Phosphorous
Furnace Scrubber Blowdown
SI
17,500
8.420
Rare Earths
Process Wastewater
SI
117
385
Selenium
Plant Process Wastewater
SI
550
631
Tantalum. Cfiiumbium, and
Ferrocolumbium
Process Wastewater
SI
4,375
2.517
Titanium and Titanium Oxice
Leach Liquor and Sponge Wastewater
SI
4,000
2.3-1
Titanium and Titanium Oxide
Scrap Milling Scrubber Water
SI
42
340
7.i re
Waste Perrosilicon
WP
1,003
509
Zinc
Sper.i Surface Impoundment Liquids
SI
10.500
5 .'19
Zinc
Waste Water Treatment Plant Liquid
Effluent
SI
7.250
3.H50
Zinc
Process Wastewater
SI
yy. i 67
43.3 ?4
Notes: 1. .SI = Surface Impoundment, WP = Waste Pile
Exhibit J-10
Release Events Retained in the Mineral Processing Screening Risk Assessment
Management Unit
Release Events
Waste Pile
Paniculate Generation by Wind
Particulate Generation by Materials Handling
Surface Runoff due to Rain Events
Surface Impoundments
Releases Due to Inlet/Outlet bailuie.-.
Releases Due to Runon F.vents
April 30, 199b

-------
J-21
J.2.1.7 Transport and Exposure Pathways
After releases from the land storage units, waste constituents may he transported or appear as
contaminants in various environmental media, depending on the characteristics of the release event, the
facility characteristics, and the environmental fate and transport properties of the constituents. In H W1K-
waste, a large number of transport and exposure pathways were identified for the various units and
waste/constituent types, only a minority of which were evaluated in this risk assessment. Reasons for
excluding transport and exposure pathways from the assessment included (1) the pathways were not
relevant to the units and waste being evaluated, (2) pathway models were not adequately developed or
were too complex to apply in the context of this screening level assessment, or (3) it became apparent that
the transport and exposure routes were very unlikely to be associated with significant risks. In some cases,
simple screening-level models were substituted for the more detailed transport and exposure models from
HWIR-Waste. Exhibit J-ll summarizes the fate and transport pathways that were evaluated in this
assessment and provides a general description of the exposure and risk modeling procedures used to
evaluate them.
Probably the most significant transport pathway that was omitted from the assessment was the
discharge of groundwater to surface water. This pathway was not considered because of the absence of
applicable DAF values and groundwater discharge volume estimates that would have allowed EPA to
estimate surface water exposure concentrations.
J.2.1.8 Release, Transport, and Exposure Modeling
J.2.1.8.1 Air Particulate Generation. Meteorological Modeling, and Deposition on Soils
Airborne particulates generation from waste piles storing the two nonwastewater streams was
estimated using EPA's SCREEN3 model. Long-term concentrations of particulates in air and long-term
particulate deposition rates were calculated using the more detailed ISCST3 model. Because the locations
of the facilities managing these streams are not known (all the analytical data come from facilities without
identifiers), it was not possible to use site-specific meteorological or climatic data in the modeling of
particulate generation and transport. Therefore, the models were run using a generic "worst-case" set of
meteorological input data that is provided on part of 1SCST3 for use in screening level analyses. High-End
(HEi exposure concentrations (air and deposition values) were estimated for the point of maximal long-
term impact (111 meters from the unit boundary in the case of aluminum cast house dust, and 24X meters
in the case of zinc waste ferrosilicon). and the central tendency (CT) exposure estimates were deriving
using the air concentrations and deposition rates averaged at every 100 meters from the unit boundary out
to a distance of 2000 meters in the direction of maximal impact. The procedures and assumptions used in
particulate generation and transport modeling are described in more detail in Attachment J-B.
April 30, 1998

-------
J-22
Exhibit J-ll
Exposure Pathway Modeling Summary for Mineral Processing Storage Risk Assessment
Unit Type
Release
Event/
Medium
Transport
Medium I
Transport
Medium II
Transport
Medium III
Exposure
Pathway
Receptors
Modeling Approaches
Waste Pile
Particulate
Generation
by Wind,
Materials
Handling
Air


Inhalation
Adult Resident
SCREEN3 (Emissions)
ISC.ST3 (Deposition)
HWIR (Exposure,'Risk)


Air
Soil
(deposition)
--
Ingestion
Child/Adult
Resident
HWIR-Waste
(Exposure/Risk)





Dermal
Child Resident
HWIR-Waste


Air
Soil
(deposition)
Crops
Ingestion
Subsistence
Farmer
HWIR-Waste, modified
for non-steadv-state
conditions (concentration
in crops, vegetable
intake, risk)


An
Soil/Water
Surface
Water/Fish
Ingestion
Subsistence
Fisher
Bounding analysis (100
percent deposition in
water bocy)
Waste Pile
Runoff
Soil


Ingestion
Child Resident
Bounding analysis; 100
percent runoff to
adjacent garden/yard.
HWIR-Waste (exposure
and risk)





Dermal
Child Resident
Bounding analysis; 100
percent runoff to
adjacent garden/yard.
HWIR-Waste (exposure
and risk )


Soil
Crops
--
Ingestion
Subsistence
Farmer
Bounding Analysis,
HWIR-Waste


Soil

Surface
Water/Fish
Ingestion
Subsistence
Fisher
Rounding analysis, 100
percent deposition to
surface water: HWIR-
Waste
Surface
Impoundment
Control/
3erm
Failure
Surface
Water


Ingestion
Adult Resident
HWIR-Waste (Release
algorithm-, exposure,
drinking water inccstion)


Surface
Water
Fish

Ingestion
Subsistence
Fisher
HWIR-Waste (Releases,
dilution, fish ingestion,
risk)
April 30, 1998

-------
J-23
As was the case for the meteorological data, vers' little information was available related to the
physical characteristics (fraction of particulate present in waste, particle size distribution, particle density )
of the nonwastewater streams. Data developed by EPA in previous analyses of potential risks from similar
mineral processing wastes known to be managed in piles were used in the absence of information specific
to aluminum cast house dust and zinc waste ferrosilicon. These data are summarized in Exhibit J-ll.
along with the other parameter values used to estimate exposure concentrations in soil resulting from
particulate deposition.
Accumulation of particulate material? in soils was assumed to occur for the entire 20-year lifespan
of the waste piles. Exposure to the contaminated soil was assumed lo begin at the end of the deposition
period (when soil concentrations of deposited constituents would be the greatest), and it was assumed that
the deposited constituents would not be depleted from the soil by leaching, runoff, or volatilization (ks =
zero). This latter assumption adds a degree of conservatism to the estimation of soil concentrations, as
some proportion of the deposited inorganics might, in the real world, be removed by runoff or leaching.
The soil concentrations from soil deposition were calculated using a variation of Equation 6-1 in
the HWIR-Waste Technical Support Document. The equation was first rearranged to allow the calculation
of soil concentrations from deposition rates, instead of vice-versa, and the exponential terms relating to the
depletion of deposited material from the soil were eliminated from the equation. The result is a simple
relationship describing the dilution of the deposited constituents uniformly in the mass of soil represented
by the mixed layer. Consistent with HWFR-Waste, shallow mixing depths (1 and 2.5 cm) were used to
calculate, exposure concentrations for use in the soil ingestion and dermal contact pathways, and greater
mixing depths (10 and 20 cm), corresponding to tilled depths, were used to calculate soil concentrations
for the root vegetable consumption pathway. All other parameter values were the same as those to
calculate soil concentration in the HWIR -Waste assessment.
J.2.1.8.2 Deposition of Airborne Particulates into Surface Water
The parameter values used in the estimation of particulate pathway emissions and transport
modeling arc summarized in Exhibit J-12. In HWIR-Waste, the relationship between airborne particulates
and surface water contamination is modeled by a complex set of equations that simulate the both the direct
deposition of particulates to surface water, and the deposition to 
-------
Exhibit J-12
Parameter Values Used in Particulate Pathway Emissions and Transport Modeling
Variable
Description
CT
Value
HE Value
Units
Source
SC
Sill Content
(both streams)
1.6
9.1
percent
Footnote 5

Particulate Size
Distribution
66
49
n
18
66
49
32
18
percent < 15 um
percent < 10 um
percent < 5 um
percent < 2.5 um
Footnote 5
PD
Particle Density
2.65
2.65
gm/cc
Value for SiO, (san
509
509
m;
Waste data base,
cost/economic impact
methodology
Z
Soil Mixing
Depth (Dermal
and Ingestion
Exposures!
2 5
1
cm
Typical values for
untilled soils
Z
Soil Mixing
Depth (Root
Vegetable
Ingestion I
20
10
cm
Typical tillage depths
BD
Soil Bulk
Density
1.5
1.2
gm/crr,'
Typical for l.' S. .-.oils
ks
Soil Loss
Constant
0
0
years 1
Assumes no soil
depiction of deposited
materials
I
Deposition
Period
20
20
years
Assumes unit lifespan
of 20 years
DV
Surface Water
Dilution Volume
3.0X10"
1.3X107
i:i '/yeJr
Third- and Fifth-
Order Stream Flow,
respectively, HWIR-
Waste Equation 7-09
April 30, 1998

-------
J-25
An additional simplifying assumption has been made regarding the behavior of deposited
particulate in the surface water bodies, and regarding the speciation and solubility of particle-bound
constituents. To estimate surface water concentrations, it is assumed that all of the constituents will he in
the dissolved or suspended phase, and that none will remain bound to. or buried in, bottom sediment. This
assumption probably overestimates the concentrations of some constituents in the water column, as some
proportion of them would probably remain insoluble and bound to sediment.
Following the HWIR-Waste methodology, the airborne particulate matter is assumed to be
deposited in either a "fifth order" or "third order" stream. These are streams or rivers of a given size and
annual flow rate that have been selected (HWIR-Waste Technical Background Document Section 7.7.6.2)
as the HE and CT surface water bodies, respectively The long-term average concentration of constituents
in surface water resulting from airborne particulate deposition is thus:
Csw (mg/1) =	PG * Cwaste	(1)
DV * 1000 L/m3
where PG is the annual paniculate generation rate (in kg) from the waste pile, and DV is the surface water
annual dilution volume as defined in Exhibit J-12. Since deposition is assumed to occur continuously
throughout the year into a continuously flowing stream, there is no need to multiply by the 20-year facility
life span
J.2.1.8.3 Runoff to Surface Soils
The amount of waste released to surrounding soils from waste piles through runoff events was
calculated using the Universal Soil Loss Equation (USLE), in a manner very similar to that described for
waste piles in Section 7-4 of the HWIR-Waste Technical Support Document. As in the case of particulate
leleases. some of the assumptions and parameter values that were used were changed to reflect the
characteristics of the units and wastes being addressed, and to address the specific geometry of the delivery
of sediment to the surrounding soils.
The parameter values used in the estimation of releases to soils from the waste piles and the
resulting concentrations of constituents in soils and surface water are summarized in Exhibit J-13. In
c,;k-iil;itine runoff releases, in the absence of data related to the specific wastes and pile configurations
being evaluated, we used the same values for soil crodability (k) and length-slope factors (LS) as were used
for Subtitle I) waste piles in HWIR-Wastes. The rainfall factor values (R) were changed slightly,
however. The CT value used in the analysis was selected from the data in Table 7-42 of the HWIR-Waste
Technical Support Document to reflect rainfall frequencies in the western US (where the majority of
mineral processing waste, by volume, is managed), while the HE value was selected to be more
representative of nationally-averaged conditions. In this analysis, the values for the USLfc cover factor 
and control practices factor were increased to 1 0 in both the CT and HE cases These values reflect the
likelihood that an active storage pile would not have any vegetative cover, and the conservative assumption
(consistent with the cost and economic analysis) that there would be no special precautions taken to
prevent runoff losses.
April 30, 1998

-------
J-26
Exhibit J-13
Parameter Values Used in Runoff Release and Transport
Modeling from Waste Piles
Variable
Description
CT Value
HE Value
Units
Source
Xe
RunolT loss lroin
waste pile
calculated
calculated
kg/iu'-
vcar
HWIK-Wasle equation 7-52
Achd
Area of Waste Pile
(Cast House Dust)
108
108
m:
Waste data base,
cost/ceonomic impact
methodology
Afcsi
Area of Waste Pile
(Ferrosilicon)
509
509
m:
Waste data base,
cost/economic impact
methodology
R
USLE Rainfall
Factor
50
110
years 1
CT= Typical of western US
HE = US Median value
I.S
Length-Slope Factor
1
3

HWIR-Waste value for
Subtitle D ash piles
K
Soil Erodnbilitv
Factor
0.25
0 25
unities? -
HWIR-Waste value for
Subtitle D ash piles
C
Cover Factor
1
1
unitless
Assumes no vegetative
cover on waste piles
P
Control Practices
Factor
1
1
unitless
Assumes no measures to
control runc'J
r
Radius of area
contaminated b>
runoff
5.000
10.000
cm
Contamination is assumed
to be distributed uniformly
in a circular area around the
conical piles
nv
Surface Water
Dilution Volume
3.0X10*
1.3X10''
mJ/ycar
Third- and Fifth-Order
Stream Flow, respectively,
HWIR-Waste Equation 7-
69
April 30, 1998

-------
J-27
A very simple sediment deliver>' model was used to estimate the concentrations of waste
constituents in soils resulting from runoff. Currently, the sediment delivery model in the HWIR-Waste
modeling system is under review, and final decisions about the configurations of waste management units,
buffer zones, and receiving areas have not been made. In the absence of a definitive model, soil
concentrations were simply calculated by assuming that the conical waste piles would generate circular
"plumes" of runoff that would deposit evenly within defined distances from the center of the piles. For HE
exposure estimates, the area of soil contaminated by runoff was assumed to be 100 meters in diameter,
while for CT exposures, the area of contaminated soil was assumed to be 200 meters in diameter, or four
times larger. This approach assumes that a storage pile would be located near the edge of a facility, that
exposed receptors would reside directly adjacent to the facility boundary, and that there would be 110
preferred runoff path or deposition areas. As was the case for air particulate deposition, it was again
assumed that deposition would occur for 20 years, and that the deposited constituents would not be further
depleted by runoff or leaching after initial deposition.
The soil concentration resulting from surface runoff from waste piles was thus calculated using the
following equation:
Csoil (mg/kg) = Xe (ki?/m2-vearl * Achd for AfesiKm2 ')* Cwaste I'mg/ke'i* t Cvears^ (2)
BD (gm cm3) * Z (cm) * X * r (cm*)* 0.001 kg/gm
where the variable definitions and values arc given in Exhibit J-13.
This approach to estimating soil concentrations from waste pile runoff greatly simplifies the
potentially complex processes that would, in the real world, govern the generation and distribution of
runeff contamination. It is intended only as a conservative screening tool to provide indication'- of the
relative risks associated with the various waste and constituents and to provide a high degree of assurance
in ruling out wastes and constituents that pose no significant risks through this pathway.
J.2.1.8.4 Runoff To Surface Water
The deposiiion of runoff to surface water bodies was evaluated using a screening approach
analogous to that used to evaluate the impacts of airborne particulate deposition on surface water quality.
Again, it was assumed that 100 percent of the runoff-borne constituents would eventually find their way
into the CT or HE streams. Thus, the equation used to estimate the concentration of runoff-bome
constituents in surface water during the operation of the storage piles is:
Csw (mg/1) = Xe i'kg/m2-year) * Achd for AfesiHm2 )* Cwaste (nig/kg)	(3)
DV (nr/year) * 1000 L/m3
The annual average runoff from the piles is again released to surface water and diluted in the CT
or HE stream dilution volume (DV, see Exhibit J-13> to provide a long-term average water concentration
Again, it is assumed that none of the runoff materials would become buried in bottom sediment.
April 30, 1998

-------
J-28
J.2.1.8.5 Surface Impoundment Releases to Surface Water
To evaluate surface water concentrations associated with releases from surface impoundments, we
used precisely the same method as used in HWIR-Waste (Equation 7-70). Again, the release model has
been simplified by removal of all of the equations related to volatilization.
The equation from HWIR-Waste estimates releases to surface water from runon events
(overtopping due to unusually high rainfall) and from inlet-outlet control failures. It does not include
releases due to berm failure or leakage. The model is probabilistic, estimating long-term average releases
of impoundment contents as a function of annual event probabilities. As was the case for air deposition
and runoff from waste piles, the average surface w ater concentrations during facility operations are
calculated assuming that the annual waste releases due to the two types of events (summed) are diluted into
the annual flow of the CT atid Ht streams, without partitioning to sediment. 1'he major variables used to
estimate surface water concentrations of constituents from impoundment failure tire summarized in Exhibit
J-I4.
Exhibit J-14
Parameters Used in The Estimation of Surface Impoundment Releases to Surface Water And Soils
Variable
Description
CT Value
HE Value
Units
Source
RV
Release volume
(annual average)
Calculated
Calculated
m!/year
HWIR-Waste, equation 7-
70
Frumm
Probability of
runon event
2X10J
2X10"1
yeiirs'1
DPRA. 1991 (sec text)
Tfk.yd
Duration of
Flooding
21,600
21.600
seconds
DPRA, 1991
Vrunan
Runon velocity
0.5
0.5
m/sec
DPRA. 1991
-h
Difference in height
hctwecn food and
berm
0.0127
0.0127
m
DPRA. 1991
A
Area of surface
impoundment
Waste-
specific
Waste-
spccific
m:
Mineral Processing data
base, co;t/cconormc
analysis
Pio
Probability of
inlet/outlet control
event
0.0:07
0.0107
years 1
DPRA, 1991
I)
Berm heighi
0.457
0.457
m
DPRA. 1991
April 30, 1998

-------
5-29
The uncertainty associated with release and exposure estimates from this pathway must be
regarded as very high The model was originally intended to estimate long-term average releases from rare
acute events occurring over the course of very many years. Thus, it may not be appropriate for estimating
releases from rather short-lived storage impoundments (20 years) being evaluated in this assessment. In
addition, the model does not capture the effects of the single acute releases on water quality in the short-
term Finally, the model and the parameter values used to estimate releases were originally derived by
EPA based on data from a sample of surface impoundments in the pulp and paper industry.' It is likely
that the designs, sizes and operating parameters for impoundments in the mineral processing industry are
substantially different, and the expected releases could also be different. One feature of the model that
tends to result in conservatism in the exposure estimates from this pathway is that no dilution of recycled
materials by runon events is assumed. In an actual extreme runon event, dilution of the wastes could be
substantial, lowenng the concentration of released materials.
J.2.1.9 Exposure and Risk Characterization
J.2.1.9.1 Toxicoloeical Criteria
With a single exception, quantitative risk estimates have been developed using toxicity criteria
values obtained from USEPA's IRIS data base or the HEAST tables and updates. To calculate inhalation
pathway cancer risks and noncancer hazard quotients, inhalation Unit Risk and chronic inhalation pathway-
Reference Concentration (RfC) values are used. For the ingestion pathways. Cancer Slope Factors (CSFs)
and chronic Reference Doses (RfDs) are used The IRIS values arc current as of December 1996. These
values are summarized in Exhibit J-15.
Ingestion pathway RfD values are available for all of the constituents except lead (see below).
Arsenic is the only constituent that is considered to be an ingestion pathway carcinogen in this assessment,
so it is the only constituent with an ingestion pathway CSF. Inhalation pathway RfCs were available for
only two of the constituents (barium and mercury), so inhalation pathway hazard quotients could be
calculated only for these elements. Inhalation cancer Unit Risk values are available for five constituents
considered to be inhalation pathway carcinogens, however.
Inorganic lead was the only constituent for which a different approach to risk characterization was
employed. Since there is no RfD or RfC value for lead, the toxicity criterion that was used to evaluate
potential noncancer risks associated with lead exposure was the Clean Water Act MCL of 15 ug/L. This
value was used to evaluate concentrations in surface water arising from particulate deposition and runoff,
assuming, in effect, that the water body would be used as a drinking water supply. Risks associated with
lead exposure through other pathways were not evaluated because of the lack of acceptable toxicity criteria
lor these pathways.
' DPRA. Surfac e Water Control Berms for Pulp and Paper Mill Sludge Landfills and Surface
Impoundments, Memo to Priscilla Halloran, OSW. July 18 1991.
April 30, 1998

-------
J-30
Exhibit J-15
Toxicity Criteria Values Used in the Mineral Processing Storage Risk Assessment
Constituent
Ingestion Pathway
Cancer Slope
Factor
(mg-kg-day)'1
Inhalation
Pathway Unit Risk
(uu/nvV
Chronic Ingestion
Pathway Reference
Dose
(mc/kg-dayl
Chronic Inhalation
Pathway Reference
Concentration
(mg/m')
Ant'.mony


4X10J

Arsenic
1.5
4.3x10'


Barium


7X10:
5X101
Beryllium
4.3 1
2.4X105
5X10J

Cadmium

1 8X101
5X10"1

Chromium (VI)

1.2X10r
5X103

Lead


0.015 mg/I.'

Mercury


3X10J
3X104
Nickel

1.8XI0"1
2X10'

Selenium


5X10''

Silver


5X10-3

Thallium


SXI0-5

Vanadium


7X10-3

Zinc


3X10-1

Notes:
1- No used in risk assessment because of low weight uf evidence
2. Based on the Safe Drinking Water Aet MCL for inorganic lead.
April 30. 1998

-------
J-31
For purposes of the assessment, it was assumed that all of the chromium present in the stored
waste streams would be in the more toxic hexavalent form. This assumption will overstate risks when (as
in most cases) the bulk of the chromium is in lower oxidation states.
J.2.1.9.2 Inhalation
Risks associated with inhalation pathway exposure to particulates released from waste piles are
calculated directly from the estimated paniculate concentrations in air generated by the ISCST3 model.
Lifetime cancer risks associated with exposure to airborne particulates are calculated as:
Risk = C^ (ug/mJ) * C>lstt (mg/kg) * 10c kg/mg * UR (ug/m3)1	(4)
where Cpin is the particulate concentration from the ISCST model, CAUlc is the concentration of arsenic in
the waste sample, and UR is the unit risk value constituent.
Inhalation noncancer hazard quotients are calculated as:
HQ = Cf)n (ug/m3) * C-,..c fmg/kg) * 10" kg/mg * IP"3 mg/ug	(5)
RfC (rng/m3)
In both cases, the receptor is an adult resident, residing at either the point of maximum long-term
air concentration (HE estimate), or at the point of average concentration within 2000 in of the facility (CT
estimate). For screening purposes, exposure is assumed to be continuous for 365 days per year, and for
carcinogenic constituent?, the exposure duration is assumed to be the 20-year operating lifespan of the
facility. As will be seen in Section J.2.1, in both the CT and HE cases, cancer risks were all below 105 and
inhalation hazard quotients were all below 1.0 under these very conservative screening assumptions, so
more refined modeling scenarios were nol developed lor this pathway..
J 2.1.9.3 Soil Ingestion and Dermal Contact
Cancer and chronic noncancer risks were evaluated for dermal and incidental ingestion exposures
to soil contaminated by particulate deposition (Section J.2.1.9.3 ) and by deposition of surface runoff
(Section J 2 1.9.4). For each pathway, the soil concentrations after 20 years of deposition were used as
inputs to the risk assessment, assuming no depletion of deposited materials from soils by volatilization,
leaching, or runoff. For both the dermal and ingestion pathways, the shallower soi! mixing depths (1.0 and
2.5 cai) were u^ed to estimate soil concentrations of constituents consistent with the assumption of no
tilln.se or soil disturbance.
Risks associated with soil ingestion were calculated using Hquation .i-ft I'rotn the HWIR-Waste
Technical Support Document, adapted to calculate risk as a function of concentration, instead of vice
versa, and with the soil constituent depletion terms removed. Cancer risks were calculated for lifetime
exposures to a child/'adult resident, consistent with the HWIR-Waste approach, and noncancer hazard
quotients were calculated for the child resident receptors, who receive the highest dose per body weight by
this pathway. The exposure parameter values used to calculate contaminant intake anc risks from soil
ingestion arc summarized in Exhibit J-16.
April 30, 1998

-------
J-32
Exhibit J-16
Exposure Factor Values for Soil Ingestion and Dermal Contact Pathways
Variable
Description
CT Value
HE Value
Units
Source
AT
Averaging time
(carcinogens)
70
70
years
Assumed lull life span
EF
Exposure
frequency
350
350
days/year
Worst-case assumption of
year-round residency
IRc
Soil ingestion rate
(child)
200
200
ing/dav
HWIR-Waste Equation 5-6
IRa
Soil Ingestion rate
(adult)
100
100
mg/day
HWIR-Waste Equation 5-6
BWc
Body weight
(child)
15
15
kg
HWIR-Waste F.qua:ion 5-6
DWa
Body weight
(adult)
70
70
kg
HWIR-Waste Equation 5-6
HEX-
Exposure duration
(child)
6
6
years
HWIR-Waste Equation 5-6
ED*
Exposure duration
(adult)
3
24
yeais
Assumes 30 years' total
residential tenure, six as a
child, remainder as an adult
Kpw
Skin permeability
constant for water
0.001
0 001
cm/hr
HWIR-Waste Equation 5-14
Y
Soil particle
densitv
2.65
2.65
gin/ec
HWIR-Waste Equation 5-14
AF
Adherence factor
0.2
1.0
gm/cnr
HWIR-Waste Equation 5-23
Teveni
Event Duration
5
1?
hours
IIWIR-Waste Equation 5-23
For the most part, these are standard values used in Agency rulemaking and risk assessments for
contaminated sites. Differences from the HWIR-Waste assumptions include more frequent exposures (350
days/year) for adults and children, and a slightly shorter HE exposure duration (30 years, as opposed to 40
years in HWIR-Waste).
Risks from dermal exposure^ to contaminated soils were likewise calculated using equations based
on the HWIR-Waste methodology. Specifically, equations 5-14 and 5-20 through 5-23 (adjusted as for the
ingestion pathway) were used to calculate dermal contact rates with soil, dermal permeability constants,
dermal absorbed doses, and risks from dermal exposures
The soil concentration inputs were again the concentrations resulting from 20 years of
contamination by runoff or air particulate deposition. As was the ca-e for soil ingestion, exposure factor
values were essentially the same as those used in the HWIR-Waste methodology. These values are
summarized in the bottom rows of Exhibit J-16. All of the values for body weights, exposure duration,
and exposure frequency are the same as those used for the ingestion pathway.
April 30, 1998

-------
J-33
J.2.1.9.3 Ingestion of Home-Grown Vegetable
Crops grown near waste piles may become contaminated either from being grown in contaminated
soil or from the deposition of particulates directly on the above-ground portions of the vegetables. In this
analysis, risks were calculated for vegetable consumption by a subsistence fanner on soils contaminated
cither bv particulate deposition or runoff. In each case, the methods used to calculate the intake of toxic
constituents and risks were the same as those used in Equations 5-58, 5-59, 6-48, and 6-49 in the HWIR-
Waste Technical Support Document
Soil concentrations used to calculate root vegetable constituent concentrations were calculated as
described previously. In the case of the root vegetable pathway, the soil mixing depths were either 20 cm
(CT) or 10 cm (HE) instead of the shallower values used for the ingestion and dermal contact pathways.
The exposure [actor values used to estimate intake and risks for this pathway are summarized in Exhibit J-
17. These values are essentially the same as those used on HWIR-Waste, the primary exception being the
use of an HF, exposure duration of 20 years, corresponding to the assumed life of the storage units, rather
than the 40-vear value used in HWIR-Waste.
J.2.1.9.4 Ingestion of Surface Water
Releases to surface water from surface impoundment failures and runoff from waste piles have
been modeled. For both types of releases, the methods used to estimates constituent intakes and health risk
are the same, and consistent with that used in the HWIR-Waste methodology.
As described previously, releases to surface water are assumed to be diluted into either a typical
third-order (CT) or fifth-order (HE) stream. In this analysis, it is assumed that the surface water body in
question would be used as a drinking water source, without further treatment to reduce exposure
concentrations. Adult residents would then ingest either 1.4 liters (CT) or 2.0 liters (HE) of surface water
for 350 days per year for 20 years. Lifetime doses of carcinogens are calculated based on an assumed
lifespan (averaging time) of 70 years as for the other pathways, with residential exposure durations of
either 9 (CT) or 30 (HE) years. Cancer risks arc calculated as follows:
Risk = C	(mg/1) * Wl (1/dav) * EF (davs/vear) * ED (years) * CSF (mg/kg-dav)' (6)
BW (kg) * AT (years) * 365 (days/year)
where WI is the daily water intake, in liters. Noncancer hazard quotients are calculated as:
Hazard Quotient = C	(mg/1) * WI (1/dav) * EF (days/year)	(7)
BW (kg) * 365 (days/year) * RfD (mg/kg-day)
In the actual risk assessment, these equations were used, similar to the approach taken in HWIR-
Waste. to calculate water concentrations of the constituents that would result in lifetime cancer risks of IO'1"
or hazard quotfents of 1.0 under CT and HE assumptions. These health-based levels (HBLs) were then
used as a screening tool to determine which, if any, waste samples or constituents exceeded cancer risks or
hazard quotient values of concern under either the CT or HF. assumptions, so that more detailed analysis
could he confined only to those wastes posing significant risks.
April 30, 1998

-------
J-34
Exhibit J-17
Exposure Factor Values Used for Crop Ingestion Pathway
Variable
Description
CT Value
HE Value
Units
Source
l
Deposition period
20
20
years
20 years = facility life span
kd
Soil-Water
Dissociation
Constant
constituent-
specific
constituent-
specific
1/kg
HWIR-Waste data base
RCF
Root
Concentration
Factor
constituenl-
specific
constituent-
specific
mg/kg (veg.)
mg/kg (soil)
HWIR-Waste data base
Vg
Surface
correction factor
for volaliles
1
1
unitless
All constituents are inorganic
Br
Plant-Soil BCF
constituent-
specific
constituent-
specific
ug/kg (veg.)
ug/kg (soil)
HWIR-Waste data base
Rp
Interception
fraction
005
0.05
unitless
HWIR-Waste Equation 6-48
kp
Plant surface loss
coefficient
18
IB
years:
HWIR-Waste Equation 6-4X
'P
Plant exposure to
deposition
0.16
0.16
year*
HWIR-Waste Equation 6-48
Yp
Crop yield
1.7
1.7
kg/m" 1D^)
HWIR-Waste Equation 6-48
BWa
Adult Body
Weight
70
70
kg
Standard Assumption
F
Fraction from
contaminated soil
0.4
0.9
unitless
HWIR-Waste Subsistence
Farmer
Cra
Consumption of
above-ground
vegetables
197
19.7
gm/day
HWIR-Waste Subsistence
Fanner
Crr
Coii5utiip:ion of
root vegetables
2X
2K
gm/day
HWIR-Waste Subsistence
Farmer
HF
F.xposure
Frequency
?50
350
days/year
HWIR-Waste Subsistence
Farmer
F.n
Exposure
duration
9
20
years
HWIR-Wase (CT). =
deposition period (HF.)
AT
Averaging time
70
70
years
full life span
April 30, 199S

-------
J-35
J.2.1.9.5 Ingestion of Fish from Contaminated Surface Water Bodies
In addition to being screened for potential risks associated with ingestion, the estimated surface
water concentrations resulting from air particulate deposition, runoff, and surface impoundment failure
were also screened to determine the potential risks associated with ingestion of fish from the contaminated
surface water bodies. The primary inputs to this analysis were the surface water concentrations resulting
from the various release pathways. The concentrations of toxic constituents in fish tissue were calculated
as follows:
Cfofc img/kg) = C,lc: (mg/l) T max (BCF, BAF) (l/kg)
To calculate fish tissue concentrations, the estimated surface water concentrations were multiplied
by the higher of either the fish bioconcentration factor (BCF) or fish bioaccumulation factor (BAF) values
for the constituents. The primary source of these values was the chemical-specific data base from HWIR-
Waste, but the values from that source were supplemented by values from other literature sources, as
summari7.ed in Attachment J-C. Where both a BCF and a BAF value were available for a constituent, the
higher of the two values was chosen. Where multiple BCF values were found, we generally took what we
considered to be the highest reliable value from either HWIR or the literature. Since the values in HWIR
were intended to be representative, rather than conservative, this procedure resulted in our using higher
BCF values for a number of constituents than were used in HWIR-Waste risk calculations, and the
resultant hazard-based levels (HBLs) for this pathway were thus lower than those derived in HWIR-Waste
for some constituents.
Constituent intakes and risks from fish ingestion were calculated using equations 5-67 and 5-68
from HWIR-Waste. Consistent with the HWIR-Waste approach, health-based levels (HBLs) were
calculated for surface water exposures through fish ingestion for the adult subsistence fisher who is
assumed to consume 60 gms (C I") or 130 gms (HE) ol list) per day for 350 days per year, using a target
cancer risk level of 10 1 and a target hazard quotient value of 1.0. These HBI.s were ihen used to screen
the surface water concentrations resulting from air deposition, runoff, and surface impoundment failures
J.2.2 Results of [VI u It i path way Risk Assessment
This section presents the results of the multimedia risk assessment for the storage of mineral
processing recycled streams. It begins with a review of the release modeling from the point of view of
mass balance considerations, and then presents discussions of the risk results for each of the release events,
exposure media, and pathways.
J.2.2.1 Mass Balance for Release Pathways
As noted above, the risks associated with releases from for mineral processing facilities presented
in this analysis have been evaluated separately. In other words, it has been assumed that releases occur
independently of one another, and that all of the materials in the storage units are available for release by
all release pathways. In this section, we review whether this assumption is valid by comparing the amounts
of materials released from the storage units by the different release events.
Apnl 30, 1998

-------
J-36
The masses of recycled materials released from the various storage units are summarized in
Exhibit J-18. It can be,seen that only a very small proportion of the total annual recycled volume of all of
the waste streams are released from waste piles. In the case of the two nonwastewater streams managed in
piles, the annual release volumes from the two types of release events (particulate generation and runoff)
are both far below one percent of the total annual recycled volume. Thus, depletion of material by these
pathways will not seriously affect the total mass of material remaining in the piles, and thus the release
estimates for runoff and particulate generation do not bias each other significantly Similarly, releases
from these pathways do not deplete the amount of materials available for leaching to groundwater.
Likewise, the estimated annual releases from surface impoundments also represent very small
proportions of the total impoundment capacities and the annual recycled volumes. Thus, releases due to
these events will not in the long run seriously deplete the amount of materials available for release by other
pathways. For surface impoundments, the only other significant release pathway is infiltration to
groundwater, since particulate generation and runoff arc not important. The issue of whether leaching to
groundwater might reduce the concentration of some constituents in the storage units has not been
specifically addressed. EPA does not believe (hat, given the short operation life of these units and their
continual replenishment with recycled materials, leaching to groundwater would seriously deplete any of
the constituents.
J.2.2.2 Risk Results for Inhalation of Particulate
The estimated health risks associated with inhalation of particulates released from storage waste
piles are quite low. as summarized in Exhibit J-l 9. Because of the lack of inhalation toxicity criteria,
cancer risks could only be calculated for four constituents, and noncancer hazard quotients could be
calculated for only two constituents. Since no inhalation toxicity criteria were available for the only two
constituents analyzed for in zinc waste ferrosiheon (lead and zinc), no inhalation pathway risks could be
calculated for that waste.
In the case of aluminum cast house dust, the highest cancer risks were associated with exposures to
chromium (VI). followed by arsenic, nickel, and cadmium exposures The HE cancer risk estimates for
these constituents ranged from 10 '- to lfl'i0, far below the 10 ? cancer risk level of regulatory concern, and
the CT risks were even lower. As noted previously, the assumption that all of the chromium present would
by hexavaicnt is very conservative, and risks for chromium exposures are likely to substantially
overestimated tor this reason.
The estimated inhalation hazard quotient values for aluminum cast house dust are also below
levels that indicate the potential for significant adverse effects. The highest HF. hazard quotient value (for
barium) is 0 2, while for mercury the HE hazard quotient is less than 10';. Both of these values are below
the 1.0 value, which indicates the potential for adverse effects, although the HE hazard quotient for barium
approaches the level of concern.
April 30. 1998

-------
J-37
Exhibit J-18
Masses and Proportions of Recycled Streams Released by Specific Release Events
Commodity
Recycled Stream
Management
Unit
Annual
Recycled
Volume
(kg/year)
Release Event
HE Amount
Released
(kg/year)
Proportion
of Annual
Volume
Aluminum and
Alumina
Cast House Dust
Waste Pile
581,000
Air Particulate
Generation
324
0.06%
Runoff
5.416
0.93%
Zinc
Waste Ferrosilicon
Waste Pile
5.950,000
Air Particulate
Generation
1,520
0.03%
Runoff
25,527
0.43%
Beryllium
Chip Treatment
Wastewater
Surface
Impoundment
2.500,000
Runon, Inlet/Outlet
Control Failure
2,012
0.08%
Copper
Acid Plant
Blowdown
Surface
Impoundment
265,000,000
Runon. Inlet/Outlet
Control Failure
28,330
0.01%
Elemental
Phosphorous
Furnace Scrubber
Blowdown
Surface
Impoundment
210,000,000
Runon. Inlet/Outlet
Control Failure
23.127
0.01%
Rare Earths
Process Wastewater
Surface
Impoundment
700,000
Runon. Inlet/Outlet
Control Failure
1,480
0.21%
Selenium
Plant Process
Wastewater
Surface
Impoundment
3,300.000
Runon. Inlet/Outlet
Control Failure
2.232
0.07%
Tam.ilum.
Columbum,
Ferrocolumbi'.im
Process Wastewater
Surface
Impoundment.
37.500.000
Runcn. Inlet/Outlet
Control Failure
7,530
0.02%
Titanium, TiO,
Leach Liquor,
Sponge Wash Water
Surface
Impoundment
24.000.000
Runon. Inlet/Outlet
Control Failuie
7.050
0.03%
Titanium. TiO,
Scrap Milling
Scrubber Water
Surface
Impoundment
5,00,000
Runon. Inlet/Outlet
Control Fail are
1.337
0.27%
Zinc
Spen: Surface
Impoundment
Liquids
Surface
Impoundment
63,000,000
Runon. Inlet/Outlet
Control Failure
15.005
0.02%
Zinc
Wastewater
Treatment Plant
Liquid Effluents
Surface
Impoundment
4 3,500,000
Runon. Ink'.t/Outlet
Control Failure
11.115
0.0 V*
Zinc
Process Wastewater
Surface
Impoundment
850.000,000
Runon, Inlet/Outlet
Control Failure
111.784
0.01%
Apnl 30. 1998

-------
J-38
Exhibit J-19
Estimated Inhalation Pathway Risks for
Aluminum Cast House Dust
Constituent
CT Constituent
Concentration
in Air (ue/m31
HE Constituent
Concentration
in Air (ue/m3)
CANCER RISK HAZARD
QUOTIENT
CT
HE
CT
HE
Antimonv
1 73F.-05
2.42H-04




Arsenic
7.36E-05
1.03E-03
3.90E-I3
1.22E-11


Barium
2.30E-05
3.23E-04


1.92E-01
1.92E-01
Cadiiiium
1.66E-05
2.33E-04
3.67E-14
1.15E-12


Chromium(VI)
2.53E-04
3.55E-03
3.7CE-12
1.17E-10


Lead
3.91E-05 "
5.-9E-04




Mercury
2.30E-10
3.23E-09


3.20E-06
3.20E-06
Nickel
5 98E-04
8 40E-03
3.54E-13
1.10E-11


Selenium
2.12E-06
2.97E-05




Silver
4 37H-06
6 l^E-05




Zinc
2 76E-04
3.S3E-03




J.2.2.3 Risk Results for Soil Particulate Deposition
Particulate matter generated from waste piles may also be deposited onto soils and crops, resulting
in direct exposure to contaminated soils and through the consumption of home-grown vegetables. In
addition, impacts of particulate deposition to surface water have also been modeled The risk results for
these pathways are discussed in the following sections.
J.2.2.3.1 Incidental Ingestion and Dermal Contact Pathways
Risk results for the incidental ingestion and dermal contact pathways for soils contaminated by
paniculate deposition are summarized in Exhibit J-20. As was the case tor the inhalation pathway,
estimated cancer risks and hazard quotients for all of the constituents in both nonwastewater streams are
below levels of concern for exposure by both pathways. The cancer risks and hazard quotients for the two
pathways are generally within about one order of magnitude of each other, with higher risks for the
ingestion pathways in some cases and higher risks for dermal contact in others.
The HE lifetime cancer risk associated w ith soil ingestion exposures to arsenic in aluminum cast
house dust is 7X10", while the CT value is 4X10''. In comparison, the HH and CT cancer risk estimate:-
for dermal exposures are lX10*and 1X10s, respectively. The highest HE hazard quotient for ingestion
exposures (again associated with exposures to arsenic) is IX10"". while the highest HE hazard quotient for
dermal exposures is 4X10 " (for arsenic). Hazard quotients for the remaining constituents range downward
by many orders of magnitude from these values.
April 30. 1998

-------
J 39
Exhibit J-20
Soil Ingestion and Dermal Contact Pathway Risk Assessment Results for Particulate Deposition
Constituent
CI Soil
Concentration at
21) Years (inu/ku)
HE Soil
Concentration at
20 Years 
4 11-05


6.04L-IX)
4.09E-04
Zinc
8 4IK-02
1. 14H+00


3.74E-06
5.06E-05


2.95FA)6
1 I2F-04
Zinc Waste
3.M)F.f00
4.75E+01








Ferrosilicon
Lead
Zinc
2.80F.+0I
3.K0E+02



I.69E-02


9.84E-04
V72F.-02
April 30, 1998

-------
J-40
Zinc is the unly constituent in zinc waste lerrosilicon lor which a toxicity value is available for the
ingestion and dermal pathway. Hazard quotient values for ingestion and dermal exposures to zinc from
this stream are on the order of 104 to 102, which is similar to the values for aluminum cast house dust.
While there is no ingestion pathway toxicity parameter for lead, it should be noted that the
predicted HE soil concentration (48 mg/kg) is about ten times lower than EPA's recommended risk-based
cleanup standard for lead in residential soils of 500 mg/kg.
These values in and of themselves are. as noted above, below the levels of concern. In fact, the
values are low enough so that simultaneous exposures to all of the contaminants through both pathways
results in a summed cancer risk less than 105 and a combined hazard index of less than 1. Given the
conservative methods used to derive these values, and the small size of the units being evaluated, these
results provide a high degree of assurance that risks for actual receptors would be below levels of concern.
J.2.2.3.2 Ingestion of Home-Grown Crops
The risk results for exposures to particulates deposited on soils and crops are summarized in
Exhibit J-21. The HE estimated cancer risks associated with exposures to arsenic in aluminum cast house
dust (7X10 7) is very close to that for the ingestion pathway The CT cancer risk for this pathway is 3X10
k. The highest HF. noncancer hazard quotient for this pathway is 6X10"'. again associated with arsenic
exposures, and the CT value for arsenic is one order of magnitude lower (5X10'J). Hazard quotient values
for the other constituents through the ingestion of home-grown crops are all much lower than the
corresponding values for arsenic.
J.2.2.3.5 Particulate Deposition to Surface Water
Because the releases to air are so small and the surface water dilution volumes arc so high, risks
associated with surface water deposition are evaluated using a screening approach not unlike that used in
the HWIR-Waste Technical Background Document to establish media concentrations corresponding to
risk levels of concern. In this analysis, the methods and assumptions described in Section J.2.1 were used
to calculate concentrations in surface water that corresponded to calculated cancer risk levels of 1X10 s and
hazard quotients of 1.0. HE exposure assumptions were used to evaluate exposures through the drinking
water and fish ingestion pathways. These HE health-based levels were then used as a basis for comparison
with the results of the concentration modeling for particulate deposition to surface water, as shown in
Exhibit J-22.
April 30, 1993

-------
J-41
Kxliihit .1-21
llome-CJruwn Crop Ingestion Pathway Risk Assessment Results for Particulate Deposition
Constituent
cr Soil
Concentration at
20 Years
GI--U4
I.SUli-03
1.44b 04
1.050-03
4 160-05
4.510-04


4.56E-06
8.590-05
Zinc
1.05 E 02
1 I4F. 01
7 490-03
4 950-02
1 160-05
1.250-04


2.82E 06
4.20F.-05
Zinc Waste
4.1XK-0)
4 TSF+m
2.0.(0-01
8.7XO-OI
1 410-08
1.53b 07




Ferrnsilicon
Ia\k)
/ inc
3.5or-:-fK)
3.800+01
2.5UOtOO
1.650+01
> 850-03
4.180-02


9.39F-04
1.400-02
April W, 1998

-------
J-42
Exhibit J-22
Screening Results for Particulate Deposition to Surface Water
Constituent
Concentrations Resulting from Releases of
Aluminum Cast House Dust
Concentrations Resulting from Releases of Zinc
Waste femtsilicon
Surface Water HRI, Concentrations (mg/L)1
Maximum
Concentration in
Waste (mg/kg)
CT Water
Concentration
(mg/L)
HK Water
Concentration
(mg/L
Maximum
Concentration
in Waste
(mg/ke)
CT Water
Concentration
(nig/L)
HE Wuter
Concentration
(mg/L)
FLsh -
Nnncancer
Fish -
(dancer
Drinking
Water -
Monoincer
Drinking
Water -
Cancer
Antimony
7.5
8.10E-09
8.77E-07





l.40i:-02

Arsenic
.12
3.46E-0S
3.74E-06




7.40F.-04

8.40F-04
Barium
10
1.USE-08
1.I7E-06



3.77E-OI

2.45E+00

Beryllium






2.84E-02

1 75H 01

Cadmium
7.2
7.7HE-09
8.42F.-07



7.J5L-05

J.50E-02

rhromium(Vl)
110
I.19H-07
1.29E-05



9.00E-0I

l.75F.-ni

Lead
17
I.84E-08
1.99E-0(i
WOO
5 40E-06
5.85E-04


I.50E-02

Mercury
U.UUUI
1 USE-1 *
1.17E-11





1.05F.-02

Nickel
260
2.8IE 07
X04E-05



I.02E-0I

7.00K-01

Selenium
0.92
9.94E-1 i' i
1 08E-07



8.40E-03

I.75F.-0I

Silver
1.9
2.05E-09
2.22E-07



1.8UE-02

I.75F.-0I

111 allium






102E-05

2 80F.-01

Vanadium








2.45E-01

Zinc
120
|.?0E-07
1.40E-05
40000
4 32E-05
4.68E-03
3.I2E-OI

I.0.SE+OI

1 HHI.S correspond in an estimated lower risk of 10a noncancer hazard quotient of 1.0, or for lead, the MCL.
April 30, 1998

-------
J-43
As can be seen from the exhibit, the predicted surface water concentrations of the toxic waste
constituents associated with air particulate deposition are all many orders of magnitude below the HBLs
for drinking water or fish ingestion (corresponding to 105 cancer risk and hazard quotient equal to 1.0).
Cadmium, with an HE predicted concentration of about two orders of magnitude below the HBL for fish
ingestion, and chromium (VI), with an HE concentration of about four orders of magnitude below the HBL
for drinking water ingestion, come the closest to any of the HBLs among the constituents of aluminum cast
house dust. In the case of zinc waste ferrosiiicon, the HE surface water concentration of zinc is about two
orders of magnitude below the HBL for fish ingestion, and the HE concentration of lead is about thirty-fold
below the drinking water HBL, which is based on the Clean Waster Act MCL. All of these results indicate
little cause for concern for adverse health effects through this pathway, especially considering the
conservativcness of the exposure assumptions (e.g., 100 percent of the particulate is deposited in surface
water).
J.2.2.4 Risk Results for Runoff Releases to Surface Soils
The screening methods used to estimate constituent concentrations in surface soils due to runoff
release from waste piles are summarized in Section J.2.1.8.3. Risks from this pathway were again
evaluated by comparison of the resultant concentrations to HBLs. In this case, however, the HBLs were
soil concentrations derived for the incidental ingestion and dermal contact pathways, and for the ingestion
of contaminated root vegetables. The results of this analysis are summarized in Exhibit J-23.
As was the case for the air deposition pathway, the concentrations of toxic constituents in soils
resulting from runoff releases are all below levels that would be associated with concern for adverse health
effects. Both in the case of the ingestion and dermal exposure pathways, where shallow mixing depths
were used, and in the case of the root vegetable ingestion pathway, where greater mixing depths were used,
the estimated HE and CT concentrations of toxic constituents in soils are generally several orders of
magnitude below the levels that might be associated with significant adverse health effects. (In the case of
arsenic, the HBLs correspond to soil concentrations that would be associated with an HE cancer risk of 10
\ For the other constituents, the HBLs correspond to soil concentrations resulting in HE noncancer hazard
quotient values of 1.0.)
These results hold true both for aluminum cast house dust and zinc waste ferrosiiicon, even
though, in the latter case, the predicted HE concentration of zinc is quite high (4,000 mg/kg). This finding
is a result of zinc's relatively low human toxicity. The predicted HE concentration of lead (497 mg/kg) is
just below EPA's recommended risk-based cleanup standard for lead in residential soils.
J.2.2.5 Risk Results for RunofT Deposition to Surface Water
Runoff from the waste piles may also be deposited into surface water. Long-term concentrations
of waste constituents in surface water resulting from runoff loading were calculated for both waste streams,
as described previously, and the resulting concentrations were compared to HBLs for surface water in the
same fashion as was done for deposition of airborne particulates.
April 30, 1998

-------
J-44
Exhibit J-23


COMPARISON OF SOIL CONCENTRATIONS FROM RUNOFF RKLKASES TO HEALTH-BASEL) LEVELS






Aluminum Cast House Dust
Zinc Waste Ferrosilicon
Constituent
Soil
Ingestion
Health-
Based
Level
(mg/kg)
Soil Derinal
Contact
Health-
Riised Level
(mg/kg)
Home-Grown
Vegetable
Consumption
Health-Based
Level (mg/kg)
CT Soil
Concentration
(Ingestion and
Uermal)
(mg/kg)
HE Soil
Concentration
(Ingestion and
Dermal Contact)
(mg/kg)
CI' Soil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
HE Soil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
CT Soil
Concentration
(Ingestion and
Dermal)
(mg/kg)
HE Soil
Concentration
(Ingestion and
Dermal Contact)
(mg/kg)
CT Soil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
HF. Soil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
Antimony
10
3.54
74.1
1 92E-03
I.58F.-0I
2.39E-04
I.58E-02




Arsenic
4.26
2.11
24.5
8.17F-03
6.74E-0I
1.02E-03
6.74F.-02




Barium
525
27.600
>1,000,000
2.55E-03
2.1 IE-01
3.19E-04
2.1 IE-02




Beryllium
NA
NA
NA








Cadmium
37.5
61.1
3470
I.84E-03
I.52F.-0I
2.30F.-04
I.52E-02




Chromium
375
90.7
55600
2 8IE-02
2.32E+00
3.5IE 03
2.32E-01




Cyanide
NA
NA
NA








I-cad
NA
NA
NA
4.34E-03
3.58E-0I
5.43E-04
3.58E-02
6 02F.+00
4.97E+02
7.52E-01
4.97F, tOI
Mercury
22.5
21,000
>1,000,000
2.55E-OX
2.I1E-06
3.I9E-09
2.1IE-07




Nickel
1,500
1.300
569,000
6.64F.-02
5.48E+00
8.30E-03
5.48E-0I




Selenium
375
47
2,710
2.35H-04
1.94F.-02
2.94F.-05
1 940-03




Silver
375
44.1
55.6
4.85E 04
4 00E-02
6.07E-05
4.00E-03




Thallium
NA
NA
NA








Vanadium
NA
NA
NA








Zinc
22,500
10,200
758,000
3.07C-02
2.53E+(X)
3.83E-03
2.53F.-OI
4.82E+0I
3.97E+03
6.02E+00
3 97F+02
April ?(), IW8

-------
J-45
The results of that analysis are summarized in Exhibit J-24. As might be expected, since the
amounts of materials released through surface runoff are roughly comparable to the amounts of air
particulate generated, the results of the screening surface water risk analysis for this pathway are similar to
those for air particulate deposition, in that all of the calculated concentrations of constituents in the surface
water bodies are far below the HBLs for either surface water ingestion or the ingestion of fish.
Exhibit J-24
COMPARISON OF SURFACE WATER CONCENTRATIONS DUE TO SOIL RUNOFF RELEASES TO
HEALTH-BASED LEVELS
Constituent
Drinking
Water
Health-
Based Level
(mg/1)1
Fish Ingestion
Health-Based
Level (rag/I)
Aluminum Cast House Dust
Zinc Waste Ferrosilicon
Maximum
High-End
Surface Water
Concentration,
Bulk Samples
(mg/1)
Maximum
Central
Tendency
Surface Water
Concentration,
Bulk Samples
(mg/1)
Maximum
High-End
Surface Water
Concentration,
Bulk Samples
(mg/1)
Maximum
Central
Tendency
Surface Water
Concentration,
Bulk Samples
(mg/1)
Antimony
0.014
NA
7.52E-09
1.15E-06


Arsenic
0.00084
0.00074
3.21E-08
4.89E-06


Barium
2.45
0.377
1.00E-08
1.53E-06


Beryllium
0.175
0.0284




Cadmium
0.035
0.0000735
7.22E-09
1.10E-06


Chromium
0.175
0.9
1.10E-07
1.68E-05


Cvanide
0.7
36.5




Lead
0.015
NA
1.71E-08
2.60E-06
2.36E-05
3.60E-03
Mercury
0.0105
0.00000125
1.00E-13
1.53E-11


Nickel
0.7
0.102
2.61E-07
3.97E-05


Selenium
0.175
0.0084
9.23E-10
1.41E-07


Silver
0.175
0.018
1.91E-09
2.90E-07


Thallium
0.0028
00000302




Van.-idium
0.245
NA




Zinc
10.5
0.312
1.20E-07
1.83E-05
1.89E-04
2.88E-02
1 HBLs correspond to a lower risk of 105, a noncancer hazard quotient of 1.0, or, for lead, the MCL value.
For aluminum cast house dust, the highest HE surface water concentrations (of antimony, arsenic,
chromium, lead, and nickel) associated with runoff releases were all in the range of 106 to 105 mg/1. all of
which were lower than the corresponding HBLs. In the case of zinc waste ferrosilicon, the estimated HE
concentrations of lead and zinc, the two constituents for which concentration data were available, are both
about ten fold lower than the lowest HBLs. These results indicate that runoff releases to surface water are
unlikely to be associated with significant risks to human health.
April 30, 1998

-------
J-46
J.2.2.6 Risk Results for Surface Impoundment Releases to Surface Water
The surface water concentrations of toxic constituents resulting from surface impoundment
releases were also compared to surface water HBLs. Unlike the other pathways evaluated, the screening
comparison indicates the potential for adverse effects on human health above levels of concern for a few
constituents from some samples from several waste streams. These results are summarized below.
J.2.2.6.1 Ingestion of Surface Water
Exhibit J-25 summarizes the results of the comparison of surface water concentrations from
impoundment releases to HBLs. Because there are multiple samples available for most of the waste
streams managed in surface impoundments, the results of the comparison to HBLs are reported in terms of
the numbers of samples and recycled streams for which the HE and CT surface water concentrations from
impoundment releases exceed the HBLs, presented in order-of-magnitude categories.
Releases from surface impoundment failures were modeled as resulting in potential exceedences of
HBLs for water ingestion for three constituents: arsenic, cadmium, and lead. Under high-end dilution
assumptions, the arsenic concentrations in five samples (four bulk samples, one EP extraction) would
exceed the drinking water HBL by up to one thousand-fold. (This is equivalent, in this case, to saying that
the estimated cancer risks under HE assumptions would exceed the 105 level of concern by up to a factor
of 1000.) All of these samples came from the copper acid plant blowdown stream, and under CT dilution
assumptions the surface water concentration for arsenic exceeds the HBL for only one of the 40 total
samples from this stream.
The concentration of cadmium in one of 24 samples from the zinc spent surface impoundment
liquid stream results in surface water concentrations exceeding the drinking water HBL under HE
assumptions. The HBL is exceeded by a factor often or less. Under CT assumptions, there are no HBL
exceedences for cadmium. For cadmium, an HBL exceedence corresponds to a hazard quotient value
exceeding 1.0 for its critical toxic effect on kidney function.
The lead concentrations in bulk samples from two waste streams result in calculated surface water
concentrations exceeding the drinking water HBL. One sample of copper acid plant blowdown shows a
concentration of lead such that the HE concentrations exceeds the HBL by a factor of less than ten. Under
CT assumptions, this sample no longer exceeds the HBL. Two bulk samples of zinc spent surface
impoundment liquids result in HE lead concentrations in surface water that exceed the HBL by a factor of
up to 100. Again, under the CT dilution assumptions, the predicted lead concentrations in surface water
are reduced to below the drinking water HBL. As noted previously, the HBL for lead is simply the
Drinking Water MCL of 15 ug/1.
April 30, 1998

-------
J-47
Exhibit J-25
COMPARISON OF SDK PACK WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO HEALTH-BASEI) LEVELS
DRINKING WATER

Maximum High-End
Surface Water
Concentration, Bulk
Samples
Maximum High-End
Surface Water
Concentration, EP Samples'
Central Tendency
Surface Water
Concentration, Bulk
Samples
Central
Tendency
Surface Water
Concentration,
EP Samples2
Compared to HBL1
Compared to HBL
Compared to HBL
Compared to
HBL
Constituent
Commodity
Wastestream
Total No.
Samples
l-10x
10-100x
1-1 Ox
ltt-IOOx
lOO-lOOOx
l-10x
10-lOOx
l-10x
10-lOOx
Arsenic
Copper
Acid plant blowdown
40
3
1


1


1

Cadmium
Zinc
Spent surface
impoundment liquids
24
1








1 -ead
Copper
Acid plant blowdown
40
1








Zinc
Spent surface
impoundment liquids
24
1
1







NOmS:
1.	HBLs correspond to a lower risk of 10 \ a noncnnccr hazard quotient of 1.0, or, for lead, (he MCL value.
2.	F;P samples arc adjusted (i.e., have been multiplied hy 1.95) to extrapolate to bulk concentrations.
April 30, 1998

-------
J-48
J.2.2.6.2	Ingestion of Contaminated Fish
The predicted surface water concentrations of six contaminants released from surface
impoundments also were such that HBLs derived for the ingestion of fish by subsistence fishers were
exceeded. The results are presented in Exhibit J-26. Six arsenic samples (again all from copper acid plant
blowdown) were associated with HE surface water concentrations exceeding the fish consumption HBLs
by up to a factor of 1000. Four of these were bulk samples, and the remainder were EP extraction samples.
Under CT assumptions, only one sample exceeded the arsenic fish ingestion HBL.
A total of 20 samples (one EP extraction, the rest bulk) contained cadmium concentrations which
resulted in surface water concentrations exceeding the fish ingestion HBL by a up to 1000-fold. These
samples came from zinc spent surface impoundment liquids (10), zinc process wastewater (6), copper acid
plant blowdown (2 samples), and one sample each from rare earths process wastewater and zinc
wastewater treatment plant liquid effluent. Under CT dilution assumptions, the number of samples
exceeding the cadmium HBL is reduced to 3 samples, and the maximum level of exceedence is reduce to
less than 100-fold.
Under HE assumptions, five samples give mercury concentrations in surface water exceeding the
fish ingestion HBL. These samples come from copper acid plant blowdown (3) and zinc spent surface
impoundment liquids (2), and under CT assumptions, none of these samples exceeds the fish HBL. In the
case of mercury, an HBL exceedence is equivalent to a hazard quotient greater than 1.0 for reproductive
effects. '
A single sample result for selenium in copper acid plant blowdown results in surface water
concentrations above the HBL, as do two thallium results (one each from titanium/TiO, leach liquor and
sponge wash water and from copper acid plant blowdown). For all of these samples, no exceedences occur
under CT dilution assumptions. The same is true for the six analytical results for zinc (all from zinc
commodity streams); all six samples exceed the fish ingestion HBL under HE but not under CT dilution
assumptions.
J.2.2.7 Summary of Non-Ground water Pathway Risk Assessment Results
The findings of this analysis parallel the results of the groundwater risk assessment for the storage
of mineral processing wastes, which found generally very low risks for the nonwastewater streams
disposed in waste piles, and higher risks (exceeding 10'5 cancer risk and hazard quotients of 1.0 in some
instances) for the wastewaters and liquid nonwastewater streams disposed in surface impoundments.
In the groundwater analysis, the major reasons for the relatively low estimated risks were the
generally low DAF values for waste piles, and the relatively low masses of toxic constituents in the
relatively small piles. In this analysis, the small size of the waste piles (corresponding to the low recycled
volumes of these streams) is again decisive in determining the generally low risks for the nonwastewater
streams. None of the release events and exposure pathways that were evaluated for waste piles resulted in
risks greater than the previously-noted levels of concern under either CT or HE assumptions. Estimated
releases from both runoff and air particulate generation were low (in the range of a few hundred to a few
thousand kilograms per year total mass), and even moderate dilution in exposure media was enough to
reduce exposure concentrations below levels of concern with regard to adverse health effects.
April 30, 1998

-------
J-49
Exhibit J-26
COMPARISON OK SURFACE WATER CONCENTRATIONS FROVI SURFACE IMPOUNDMENT RELEASES TO HEALTH-BASED LEVEIES
FISH INGESTION

Maximum Hig>li-Eiid Surface
Water Concentration, Bulk
Samples
Central Tendency
Surface Water
Concentration,
Bulk Samples
Maximum High-End Surface
Water Concentration,
EP Samples'
Central Tendency
Surface Water
Concentration,
EP Samples2
Compared to HBL1
Compared to HBL
Compared to HBL
Compared to HRL
Constituent
Commodity
Wasteslream
Total No.
Samples
l-10x
10-100x
lOO-IOOOx
l-10x
10-100x
l-10x
10-lOOx
ion-iooo*
I-10x
10-lOOx
Arsenic
Copper
Acid plant blowdown
40
2
2



1

i
1

Cadmium
Copper
Acid plant blowdown
40
2









Rare Earths
Process wastewater
8





1




Zinc
Process wastewater
40
6









Zinc
Spent surface
impoundment liquids
24
(>
3
1
1
1





Zinc
WW IP liquid diluent
5


1

1





Mercury
Copper
Acid plant blowdown
40
2




1




Zinc-
Spent surface
impoundment liquids
24
1
1








Selenium
Copper
Acid plant blowdown
40
1









Thallium
Titanium and
Titanium
Dioxide
Leach liquid & sponge
wash water
8
1









C oppcr
Acid plant blowdown
40





1




Zinc
Zinc
Spent surface
impoundment liquids
24
5









Zinc
WWTP liquid diluent
5
1









NOTES;
1.	HBL = health-based level deiived for lish ingestion based on worst-cast subsistence Usher
2.	EP samples are adjusted (i.e.. have been multiplied by I ,y5) lo extrapolate to bulk
concentrations.
April W, 1998

-------
J-50
The comparatively higher risks associated with waste managed in surface impoundments was
primarily a function of the larger volumes of waste being managed and correspondingly larger release
volumes. Even though the proportions of the recycled materials released from impoundments were
relatively low, there was still enough mass present in the impoundments to result in surface water
concentrations exceeding HBLs. It should be noted, however, that even for these high-volume wastes,
exceedences of HBLs were limited to only a small minority of the constituents, samples and waste streams,
and the greatest numbers of exceedences were for the fish ingestion pathway, where the HBLs for several
constituents have been derived quite conservatively. Under HE assumptions, only nine samples (out of
135 having analytical data) resulted in exceedences of the drinking water HBL, and this number dropped
to one under CT assumptions. Under HE assumptions, a total of 40 samples exceeded the far more
stringent fish ingestion HBLs, and this number dropped to 4 under CT assumptions.
Two of the twelve wastewater and liquid nonwastewater streams evaluated in the analysis
accounted for the bulk of the HBL exceedences. Under HE assumptions, samples from copper acid plant
blowdown accounted for six of the nine exceedences of the drinking water HBL, and zinc spent surface
impoundment liquids accounted for the remaining three. Between them , these two streams also accounted
for 34 of the 40 HE exceedences of the fish ingestion HBLs (copper acid plant blowdown 13, zinc spent
surface impoundment liquids 21). Two other streams from the zinc commodity sector (six samples from
process wastewater and two samples from waste water treatment plant liquid effluent) also accounted for
one or more exceedences of the fish consumption HBL. Beyond that, only two other commodity sectors
(rare earths and titan ium/Ti02) had any exceedences (one each, only under HE assumptions).
Thus, this analysis clearly identifies two commodity sectors and four waste streams as dominant in
driving potential risks from the storage of mineral processing wastes, at least among the streams for which
analytical data are available. Whether there are other streams and commodities for which non-groundwater
risks might also exceed levels of concern cannot be determined without additional data concerning waste
characteristics and composition.
J.2.2.8 Uncertainties/Limitations of the Analysis
As discussed in Section J.2.1, the multipathway risk assessment for the storage of mineral
processing recycled materials relies on relatively simple, generic models of contaminant releases, transport,
exposures, and risks. As such, this screening level analysis shares the general limitations of all generic
analyses in that high levels of uncertainty and variability may not be adequately treated, since only a
limited number of generally applicable models and generally representative data are used to model risks
from a wide range of units, wastes, and constituents. Many of these generic sources of uncertainty have
been addressed in our previous work on mineral processing wastes, and the following discussion is limited
to limitations specific to the multipathway analysis
Constituent concentration data are available for only 14 recycled waste streams, and for some
wastes only small numbers of samples are available. It is interesting to note that two of the wastes for
which estimated risks are the highest (copper acid plant blowdown and zinc spent surface impoundment
liquids) also are those for which the largest number of samples are available. It is not possible to estimate
which of the other wastes might also show risks above levels of concern if more data were available.
April 30, 1998

-------
J-51
Limited data are also available concerning waste characteristics, including constituent speciation,
solubility, and bioavailability. Throughout this analysis, we have assumed that all constituents would
behave in such a manner as to maximize exposure potential. For example, we have assumed that none of
the constituents would leach from soils after their initial deposition, and that all of the constituents would
be bioavailable in the water column. Generally these assumptions increase the level of conservatism in the
risk assessment.
Release events and amounts were simulated mostly using the general methods adopted in HWIR-
Waste. The one exception is air particulate generation, which was estimated using the SCREEN3 model,
rather than the model recommended in HWIR-Waste. SCREEN3 is a widely-accepted screening level
EPA model, however, and EPA believes that it is appropriate for the types of release events that were
modeled. The use of SCREEN3 is unlikely to have biased the results of the risk assessment significantly
compared to other methods. However, as noted previously, no data were available concerning the particle
size characteristics of the two wastes streams that were modeled, so we relied on data from an earlier study
of mineral processing wastes stored in waste piles. Based on limited information, we believe that the
particle size distribution that was used may overstate the potential for particulate release of the more
coarse-grained, high-density zinc waste ferrosilicon, while more accurately describing the potential for
particulate releases of aluminum cast house dust.
Runoff releases were evaluated using the same model (USLE) applied in HWIR-Waste, with input
parameters varied slightly to reflect the operating characteristics of the waste piles being simulated and the
likely geographic distribution of the recycling facilities. The risk results are not particularly sensitive to
these changes, as exposure concentrations for runoff events are below the levels of concern for all of the
runoff exposure pathways.
The ISCST3 model used to predict particulate air concentrations and deposition rates is a state-of-
the-art model that has been used in many regulatory proceedings by EPA. The input data that were used,
the "'worst-case" meteorological conditions that are supplied with ISCST3 specifically for use in screening
level assessments, were somewhat more conservative than the meteorological data used in HWIR-Waste
with a similar model. Thus, our estimates of air impacts are likely to be higher than those that would have
been achieved had we replicated the HWIR-Waste approach. Again, however, all risks associated with this
pathway were far below levels of concern.
The modeling of releases from surface impoundments reproduced exactly the approach used in
HWIR-Waste. This release model and its input parameters were derived based on data from management
units in the pulp and paper industry, and just how reliably they predict releases from surface
impoundments in the mineral processing industries is not known. This is clearly a major source of
uncertainty in the risk assessment, as these release events are the only non-groundwater releases for which
health risks are predicted to be above levels of concern.
Because of resource limitations and the specific characteristics of the facilities that were evaluated,
simplified approaches were developed to estimate the concentrations of waste constituents in surface soils
and surface water to substitute for the much more elaborate methods used in HWIR-Waste. In the case of
surface runoff, in the absence of site-specific data, we conservatively assume that soil contamination would
be limited to relatively small distances (50 or 100 meters) from the piles in arbitrarily defined circular
plumes This is only intended as a bounding analysis, and the finding that this pathway is not a major
concern can be supported by the fact that, even with these relatively small exposure areas (and the resultant
high soil concentrations), constituent concentrations due to runoff events were below levels of health
concern.
April 30, 1998

-------
J-52
Similarly, to be conservative, we assumed that all of the runoff and all of the particulate generated
by the waste piles would be deposited on the watershed in such a way that all of these materials would
rapidly find their way into surface water. This approach, while it resulted in surface water concentrations
far below levels of health concern, may be less conservative than the approach taken for surface soils, in
that the CT and HE streams .are both rather large, and the model does not take into account possible runoff
or deposition into smaller streams, lakes, or ponds where constituents may accumulate in surface water or
sediment.
The approach we took in evaluating fish tissue concentrations was also somewhat more
conservative than that taken in HWIR-Waste, in that we used the highest reliable BCF or BAF values,
rather than representative values, in our calculations. For some constituents (arsenic, cadmium, mercury,
thallium), this approach resulted in considerably higher tissue concentrations than would have been
calculated had we used the HWIR-Waste values, and considerably lower HBLs. This may be a major
source of uncertainty in this analysis, since the fish ingestion pathway resulted in the highest risks for
several of the constituents.
April 30, 1998

-------
ATTACHMENT J.A
Proportion of Mineral Processing Wastes Covered by the Storage Risk
Assessment

-------
ATTACHMENT J.A-1
PROPORTION OF RECYCLED MINERAL PROCESSING W/
IN THE RISK ASSESSMENT FOR RECYCLED MA
STE STREAMS A[
TERIALS STORAG
SORESSED
E
Commodity
Waste Stream
Total Recycled Volume
Recycled
Volume
Analyzed In Risk
Assessment
Percent Analyzed in Risk Assessment
Min.
Ave.
Max.
Expect.
ExpJMIn.
Expect/Ave.
ExpjMax.
A IJ'^ll'*IJT>,
Au^ra
Cast Houe Dust
16.227
16 227
16.227
'5.227
100.00%
10000%
100.00%

Electrons Waste

24 438
48.875





Sector
1622?
40 6S5
65/'22
'5.227
100 00%
39 90%
24 93%









3er\'ii un
Soon: Barron Frtraie Streams
41.250
41.250
41.250
41.250
100.00%
100.00%
100 00%

Ch p Treatment Wastewaie'

10.0:0
400.000
"0.000

100.00%
2 50%

Sector
41 250
51 2:0
441 ?50
51.250
124.24%
100 00%
11 61%
j








CoopP'
Acid Plant Slowdown
3.37S.0C0
3.375.0C0
3.975.000
3.975.000
100.00%
10000%
100 00%

WWTP S udoe

2 250
4.500




i
Sector
3.375.000
3,57/.250
3.979,500
3 975.000

99 94%
99.89%









Fiemsn'al
Fh^schorus
F-jrnace Scrubber Biowdown
42C.000
420,300
420.000
420.000
10-3 00%
10000%
100 00%

Fjrnace Buildnq Washcowr
700.'COO
700,000
700.300





Sector
1.123.000
1.122.000
 120.000
420 00C
37.50%
37.5C%
37.50%









Pare Eanns
E ectro: Cell Caustic Wet APC
S:ud

350
7,000





Process Wastewater
1.4:0
1,4:0
1.4C0
1.400
100 00%
100.00%
i:0.00%

Seen Scrubber Liquo*
20
lOO.OOO
20O.COO





Wastewater from APC

SC.000
200.00:





Sector
1.420
151.75:
4:8 400
1 400
95 59%
0 9?%
0 34%









Seie"ium
Soeit Filter Cake

217
4.335





ia~t Process Wastewater
13,200
13.200
13.200
13.20:
100.00%
100.00%
100.:0%

Sla~,

5"
1.020





Tftliur un S ire Wastes

217
4.335





Sector
13.200
13.685 
22. =90
13 20C
100 00%
95 46%
57 67%









~3itaiom,
Fs'rosolum-
hui-n Pt-
Process Wastewater
127,500
127.50C
127.500
127.500
100.00%
100.00%
100.00%

Sector
27 500
*?7 500
* 27 500
127.500
100 00%
100.00%
 :o 00%









T f3iium.
T taniLm Oxoc
Fickei -icuor a-d Wash Water

270
56:





Sc*ap M ii nc Scruober Wotc

500
1.200
500

:o.oo%
41 ?%

Srtiut 'rO"n Mg Recove"/
85
18.70:
39.10c





leacn -iGuor.Spcnqe Wasn Wat^r
76.00C
36.:o:
116000
96 000
26 32%
-:o.co%
E2.76%

Spent Su-'ace imoo-jncmflnt
LiQU ds

1,658
5.712





Sector
76 085
116 928
162.672
96 500
126.83%
82.53%
59.32%









Z:nc
Acid P'ani Slowdown
130.OX
130 000
130.000





Waste Fernsiiiccn

7.225
14 45C
7 225

CO 00%
50 00%

Process Wastewater
4.335 000
4.335 00C
4,335 000
4.33.0:0
CO 00%
* 00 00%
100 0:%

Seen- Clothes Bags, and Frte's

75
15C





Sperv Goetn te. Leach Cake
Resisues
15.000
15.00C
15000





Spent Surlace Imyounsmenl
L-QUidS
378.0:0
378 000
375.0:0
378.000
100 00%
100 00%
ioo.oc%

WWTP Sends

281
563





"AC Tower Biowdowr

94
188





WWTP Lnjjid Eff uent

261.0:0
522.OCO
261.000

100.00%
50 00%

Sector
4.858.000
5.126675
95,351
4.981.225
102 54%
97.16%
92 32%









All Sectors
10.868,862
12,849,809
16,160,523
9.682.302
69.08%
75.35%
59.91%
Nof(
Proportion of streans ccverec = 14/72 =19 4 cr:onr
Commodities rot covered = Antimony. Bismuth Cacrrium. Calcium. Coa! Gas Fluo-spar and Hydro'luonc Acid, German.un, Lead, Magnesium anc
Wajnesia. Merc-ry, Platinum Group Metals. Pyrobitjmens, Rhenum. Scandium, Synthetic Rutile. Tellunjm, Tungster, Uranijm. Zirconium aid Hafnium

-------
ATTACHMENT J.A-2
PROPORTION OF MINERAL PROCESSING WASTE STREAMS ADORESSED IN THE RtSK ASSESSMENT FOR RECYCLED MATERIALS STORAGE
Corwrtodttv
Waete Stream
Generation Rata
flacrclad Volume
Percent Racvcl*4
Mln
Ava.
Max.
Mln.
Eipact.
Mu
MlnAltn.
Eipcel.'Ave.
P
I1
A/.jainu-n
Aljmna
Cast HluS* Oust
10.000
10 COO
10 COO
16 22T
t6 22T
16^2?
85 41%
85 41%
85 41%

F r in lysA Waste
58
0
58







Sac tor

1SC58
I'^ifl
16 22?
l22T
6 J27
95 3%
8S 13%
3a 15%











?rfVl uTI
3jf nt 'lorrfln - *rax Slroan-.
si JOO
as coo
as XO
41 250
41 250
41 250
;iw.
75 00%
75 00%

C m ~- ii n*-t WaVa:or
200
100 ox
2 COO OX
0
ic joo
: 'JOC
3 Xs.
0 00%
20 00%

Fnitttor 0-4r.irn
200
430
K COO







Sector
5C 4rtO
i';4=0
?  4 5  4P:;
100
500.00c
 coo 000







Sector
2' 370
1 C?33/0
2 C25 2X
 400
t 400
1 40C
6 55%
C 14%
* "57%











Seieomm
Spent F I'er Cake
50
SOO
5 000







Flant 'rocess Wariowa'er
96 XO
66 XO
56 000
13.200
1.1 POO
13 200
20 00%
?0 00%
20 00%

Slag
SO
500
a 000







Tnllururr Skm W^sls
50
SOO
5 OOC







waste So k
SO
soo
a 000







Sector
*6 XC
56 XO
96 COO
n ?oo

13200
13 94%
1941%












"anialun.
Frroolu*n-C"jm
ok:
0*,MSir SluiJya
1 000
1 000
t OOC







P-ccoss Wastowaior
lSO.OOt
150 000
'50 000
127 500
 ?7 500
1 ?7 5CO
83 0C%
85 00%
a; 00%

Spool Rattra-e Soles
2000
2 000
2 OOC







Seclar
1 S3 OOC
153 000
-53 000
127 SOO
'?.7 500
127 500
83 33%
83 33%
83 33%











""tarixn. "laniun
O de
Pckol Liquor a*>c Wasfi Wj:r
2 200
2 700
3200







Scap Vi irq Scrueear Wa0
421 TO







S*ctor
807 130
972 100
  37 JOO
76 COO
96 500
117 200
9 4?%
9 93%
to 33".











Zric
Aco Plant Siowdowi
 30.000
30 000
*3: XO







Waste Fems'coo
17.000
17 COO
17000
)
7 225
14 450
0 00%
42 50%
a-i oc%

Process Wastewater
5 000 000
5 OOO .OOO
5 000 XO
4 335 XO
4 335 000
4.33S OCO
36 70%
3-3 7C%
85 7C%

r>.M.ardMi s Anirno-iy R.vruift C a drnnun . Caecum Ccal Oas. Fluorspar ana Hvdrof uox Acd. Getmantni. Lood Uaqnesjm and Maye$. Mercury
MwtyCdtnum Furronolybdeiurr anc A/rrrorwjm Mo>yMate Pyrobtjfn^oj. Rhenwrn. Scandum Swlhw ^uiio. Tolluncn. Tjn9t!an. llra-nun

-------
ATTACHMENT J.B
Summary of Particulate Generation, Air Transport, and Deposition
Modeling

-------
ATTACHMENT J.B. Air Quality Modeling in Support of Mineral
Processing Storage Analysis
Model Selection and Options
The Industrial Source Complex Short Term (ISC3ST- version 96113) was used to model the impacts of
fugitive emissions from materials handling and wind erosion at the mineral processing facilities. The
ISC3ST model is the model recommended by EPA in the Guideline On Air Quality Models (Revised),
EPA-450/2-78-027R, Appendix W of 40 CFR Part 51 and Part 52. As stated in the guidance document:
"Fugitive emissions are usually defined as emissions that come from an industrial source complex.
They include the emissions resulting from the industrial process that arc not captured and vented
through a stack but may be released from various locations within the complex. Where such fugitive
emissions can be properly specified, the ISC model, with consideration of gravitational settling and dry
deposition, is the recommended model."
The ISC3ST model was set-up to run using the following regulatory default options:
	Final plume rise
	Stack-tip downwash
	Buoyancy-induced dispersion
	Calms processing
	Default wind profile exponents
	Default vertical potential temperature gradients
	No exponential decay.
However, since the only sources included were fugitive area sources, the options applicable to stack point
sources (e.g. stack-tip downwash) were not applied.
Emission Estimates
Emissions associated with the storage of mineral processing waste (aluminum/alumina cast house dust and
ferrosilicon waste from zinc production) were estimated to occur from the aggregate handling of the waste
materials and from the wind erosion of the waste piles. Emissions from the aggregate handling of the
waste piles vary in proportion to the mean wind speed and the moisture content of the waste. Emissions
generated by wind erosion of the waste piles were related to threshold friction velocity and the wind gusts
of the highest magnitude routinely measured as the fastest mile. Because the lack of data, we made a few
assumptions in estimating these emissions:
a)	The material in the storage piles has a moisture content of 4.8 percent
b)	The threshold friction velocity for the waste piles is the same as the threshold friction velocity for
fine coat dust stored on a concrete pad. This assumption would overestimate emissions for the waste
piles since fine coal dust on concrete pad has a greater erosion potential than the waste piles.
c)	The fastest mile, (i.e., the wind gusts of the highest magnitude) occurs during period between
disturbances to the piles.

-------
d) The surface area of the storage pile which is disturbed during each work day is equal to 25 percent
of the total pile surface area.
e) Data for the annual mean wind speed and for the fastest mile were taken for Kansas City which
has an average values of the cities surveyed in "Extreme Wind Speed at 129 Stations in the
Contiguous United States".
Emissions from handling of the waste materials and from the w ind erosion of the waste piles were
estimated using equations from EPA's AP-42, Compilation of Air Pollution Emission Factors, Volume I:
Stationary Point and Area Sources. As previously stated, these equations relate parameters such as
exposed surface area, moisture content, mean wind speed, threshold friction velocity, fastest mile to total
TSP and PM10 emissions.
Meteorological Assumptions
In addition to the meteorological assumptions needed to estimate emissions from mineral processing waste
piles, meteorological data was required to complete the air quality dispersion modeling analysis using
ISC3ST. To conservatively predict the impacts of the emission sources, worst-case meteorological data
was used in ISC3ST.
The worst-case meteorological data is similar to that incorporated in the EPA model, SCREEN3. The
worst-case meteorological data set contains an array of all possible combinations of wind speed, wind
direction and stability class that could exist in an actual location. The data set of meteorological
conditions consisted of:
	Mixing heights of 1000 meters
	Ambient temperatures of 298 DegK
	Wind directions varying from 10 to 360 degrees
	Wind speeds (varying from 1.0 m/sec to 20.0 m/sec) assigned to stability classes A through F
A few additional parameters are required to estimate deposition using the ISC3ST model. Those
parameters include: The variables are: friction velocity at the application site (m/s), Monin-Obukhov length
at the application site (m) and roughness length at the application site (m). The EPA model RAMMET,
version 95227 was used to estimate these parameters. RAMMFT requires data on surface roughness
length at application site, noon time albedo and Bowen ratio, which vary by season and land-use type.
Values by season and land-use type (10% urban, deciduous forest, coniferous forest, grassland and desert
shrubland share the 90%, i.e., 22.5% each) were estimated. The appropriate fraction velocity, Monin-
Obukhov length and roughness length values were extracted from the RAMMET output and added to
worst case meteorological data for the deposition calculations.
Location of Maximum and Area-Average Concentrations and Concentrations
As with many Gaussian dispersion models. ISC3ST results are accurate no closer than 100 meters from
each source. Thus to calculate impacts of the two sets of storage piles, both piles were placed in a
prototypical facility with property boundaries located approximately 100 meters from the edge of each
storage pile. Two sets of receptor grids were used to determine maximum peak 24 hour and annual
average concentration and deposition values at points located around the property boundary. To pinpoint
the maximum values, a grid of receptor points, with receptors located from 100 meters to 250 meters in
each direction, with a resolution of 50 meters was input to ISC3ST. An array of polar receptors, at 45
degree intervals, from 200 to 3,000 meters was used to estimate area average concentrations.

-------
Results
The maximum predicted 24 hour and annual average concentration (ug/m3) and deposition (g/m;) values
are listed in Table 1. These maximum concentration were predicted to occur 180 meters from the A1 cast
house dust storage pile and 104 meters from the Ferrosilicon storage pile. Area average values were
estimated over the entire polar receptor grid.
Table 1- Modeling Results
Pollutant

TSP
PM.o

24 Hour
Annual Average
24 hour Annual Average
Max. Concentration
Area Average
Max Deposition
Area Ave. Dep.
258.4	64.6
18.5	4.6
2.6e-3	6.5e-4
5.9c-4	1,5e-4
192.2	32.3
9.2	2.3
5.4e-4	l.3e-4
l.le-4	2.9e-5

-------
ATTACHMENT J.C
Fish Bioconcentration and Bioaccumulation Factor Values and Data
Sources

-------
Attachment J.C
Fish BCF, and Toxicity Values
Chemical
Ous
Number
BAK fish (L/kg
body weight)
(total) 
Source
BCF fish (LVkg)
(dissolved)
Source
kid
(mg/kg/day)
Source
Oral CSF
(mg/kg/day)-l
Source
KfC (mg/mJ)
Source
Inhul UKF
Iug/in3)-l
Source
Antjinony
7440-36-0
NA

not significant
Barrows el al 1980 (in
LP A 1988)*
4 00E-04
IRIS
NA

NA

NA

Arsenic
7440-38-2
NA

4
Harrows el al 1978*
3 00E-U4
IKIS
1.MJE+00
IKIS
NA

4.30E-03
IKIS
Barium
7440. ;^-3
NA

100
Schrtvilcr I970*
7 IH1F-02
IRIS
NA

5 (101-04
Mi: AST
NA

Beryllium
7440-41-7
NA

19
Harrows el al 1978*
5 00K-03
IRIS
4 30F.+00
IKIS
NA

2 40K-03
IRIS
Cadmium
7440-43-9
NA

3-7,440
Benoil et al l976(inFPA
1985a)*; Uiesy et al. 1977
(in F.isler 1985)*
5 00E-04
IRIS
NA

NA

1 80E-03
IKIS
Chromium
(VI)
18540 29-9
NA

3
EPA 1985b
5.00E-03
IKIS
NA

NA

1 20E-02
IKIS
C vaniile
57-12-5


0.3
Kenaga 1980 (KCN>*
2.00E 02
IRIS
NA

NA

NA

l-ead
7439-92-1
8

1 726
Maddock and Taylor 1980
Un Eisler 1988)*; Wong cl
al. 1981 (in Eisler 1988)-

NA
NA

NA

NA

Mercury
7439-97-6
6 OOE+04
EPA 1993b
129-10,000
(mercury(ID);
10.000 85.700
(meihylmi/rairy)
Various rels in EPA
1985c4"
3 00E-04
IRIS
(HgCI2>
NA

V0OE-M4
IRIS
NA

Nickel
7440-02-0
NA

47-106
l.ind et al manuscript (in
EPA 1986)*
2.00E-02
IKIS
(soluble
sails)
NA

NA

NA

.Selenium
7482-49-2
0.5 1.0
Cleveland
el al 1993
5-322
Cleveland el. al 1993*;
Ingersoll et. al 1990*
5.00E-03
IRIS
NA

NA

NA

Silver
7440-22-4
NA

11-150
EPA 1987
5.00E 03
IRIS
NA

NA

NA

Thallium
7440-28-0
NA

27 1430
Zitkoetal 1975; Barrows
et al 1978*
8.00E-05
IRIS
(TI2Ch2
03,TICI,
or
TI2H2S
04)
NA .

NA

NA

Vanadium
7440-62-2
NA

NA

7.00E-03
HEAST
NA

NA

NA

Zinc
7440-66-6
4 4

275-519
Xu and Pascoe 1993*
3.00E01
IRIS
NA

NA

NA


-------
ATTACHMENT J.D
Risk Characterization and Screening Spreadsheets
J.D-l	Inhalation Pathway
J.D-2	Particulate Depostion Soil Ingestion and Dermal Contact
J.D-3	Particulate Deposition to Surface Water Risk Screening Results
J.D-4	Runoff Deposition to Soils Screening Results
J.D-5	Runoff Deposition to Surface Water Screening Results
J.D-6	Surface Impoundment Releases to Surface Soils Screening Results

-------
ATTACHMENT J.D-1
Inhalation Pathway
Exposure and Risk Calculations for Particulate
Deposition
COMMODITY:
WASTE
STREAM:
CT PM 10
Concentration
HEPM10
Concentration
Alumina and Aluminum
Cast house dust
2.3 ug/m3
32.3 ug/m3
Constituent
RIC (mgfrn3)
Unit Risk (ug/m3)-1
Maximum
Concentration in
Waste (mg/kg)
CT Cor\stiluent
Concentration in
Paniculate (ug/m3)
HE Constituent
Concentration in
Particulate (uy/in3)
CT Cancer Risk
HE Cancer Risk
Antimony


7.5
1.73E-05
2 42E-04
O.OOE+OO
O.OOE+OO
Arsenic

4.30E-03
32
7.36L-05
1 03L-03
3.90E-13
1 22E 11
Barium
5 00E-04

10
2.30E-0b
3.23E-04
O.OOEtOO
O.OOEtOO
Beryllium

240L-03
0
O.OOE+OO
O.OOEtOO
O.OOEtOO
O.OOE+OO
Cadmium

1 OOE-03
7.2
1.66E-05
2.33E-04
3.67E-14
1 15E-12
Chromium(VI)

1 20E-02
110
2.53E-04
3.55E-03
3.74E-12
1 17E-10
Lead


17
3 91E-05
5 49E 04
O.OOE+OO
O.OOE+OO
Mercury
3 00E-04

0.0001
2.30E-10
3.23E-09
O.OOE+OO
O.OOEfOO
Nickel

4.80E-04
2G0
G98E-04
8.40E-03
3 54E-13
1 10E 11
Solenium


092
2 12E-0K
2.9/E-05
O.OOEtOO
O.OOE.OO
Silver


1.9
4.37E-06
6.14E 05
O.OOE+OO
O.OOE+OO
Thallium


0
O.OOEtOO
O.OOE+OO
O.OOE+OO
O.OOE+OO
Vanadium


0
O.OOE+OO
0.00E+00
O.OOE+OO
O.OOE+OO
Zinc


120
276E-04
3.88E-03
O.OOE+OO
0 OOtl+OO
Exposure
Variables

CT
HE
Units



EF
Exposure
Frequency
350
350 days/year



EDa
Exposure
Duration
(Adult)
9
20 years



CT Noncancer
Ha^atd Quotient
I.92E-01
HE Noncancer
Hazard Quotient
1.92E-01
Cancer Risk = U.R. * PM10 ' Max Cone.' IOMj' (EF/365) * (ED/70)
Hazard Quotient = (EF/365) * (Max Cone.* 10^-6) / RIC

-------
ATTACHMENT J.D-2
Particulate Deposition - Soil Ingestion and Dermal Contact
Wllkk C tkyMIOM M PmIc
COMMODITY:	At.
C? long Tm D^uIUeo	 JOC-04 ynW-huii	4i?tC*> ?nx2 i<
f i nriQ Tm rfinilUnn	t U 04 grni2 nou	   t 07
He C-nnWH
C>nai)*ii  ld>i |"V9>
kigMMi (rn^V^
S< u uvpirv
0*J I u* (V*
5ic* r.
Cfjnwan(Vl)
LotO
t> 00c .UJ
1 406.00
0 30i.00
0 Xf-OO
oootoo
0OOt-00
ooocoo
ooc*.ou
0 :e.OC
0 OOt >OC
ococ
0>EUs
3	0Q 34
700C-QS
iCCf 01
SOC* 04
4	0CE 03
OOOC.OO
3 OOF 04
2 OCt CO
tOGC 03
&0CC-O3
I Od 4
0 00 tOC
mica
70iEM
ooct 
14^04
\ 33E 03
OOOC-OO
9i M
oooeoc
I 04* .00
I tlfc 01
} 49 0/
t*rf
% nun
' 6oe (c
ooct .cc
o ax mi.
 WE 09
C OOt.00
C006.00
OcJirf.uu
9/1fc M
I 49E CI
0 CCE >00
I 411 C*
*43E C?
2 92E U
oooe-do
uir-oa
wt o?
ME Of
00i00
.
CX JO
S3 t>>
OCCf-CO
> 12fc 06
4* UJ
Oifc 0*
2> 09
00 [ .OO
00 L >00
00 >00
Wb to
0IU -OO
OOCE.00
OOM..OO
0 CfcE-00
OOCt-OO
oa(-o
000
0006 >00
0 OOt -00
;b w
I 30E C4
I lM 14
*06t 04
0 OOt-00
0 Oct .00
I dlfc x>
0 JUC'OC
3 MOmimicmhci
Corlkj*v	CSF
CMlwtiM	CuikanaMNnal
h>e srn	su
Co
naMC<^.tUr>:
llA.)
!*>*
Nonca>un<^i
(^9 ort

OOM '00
i iCC.00
0CC<.0
0004.00
ooot-oo
aoot-oo
SUM >ai
0 OOt >00
OOOCtOO
OOOCrOO
OQOf HO
i>00 *00
oooeoo
0 OOt .00
4CCE-C4
J OOC -04
roctcs
6	OOt 04
&ooc os
oocc*oo
3 004 04
2OOt 02
SOOt 03
5 OOf Qi
 OOt 04
7	OOt 03
aooc-oi
2 304 CC
2 90COt
i 3CCC2
 2CC.01
4 30C *00
4OOt CI
i OOt-01
ooe*oi
SAt^li
2 24E 02
/01C 03
u XX- -CC
(06t 03
? /'E M
i lS M
/ciEoft
1 B2tOI
4SE 04
I 33i OJ
#	4X 
0	OOE >00
	 : 02
1	04(1.00
i eic oi
ttwur
3 *11-00
trj cu
x aoc 
U.UF^U
0	306 >00
1	14E.OO
1004
jsto
ire.o*
60e-0t>
7*E 06
4JC-04
\ Of 06
iHJf MJ)
I 72E-C1
9 43 CO
7 14 02
I lit <
3 Ufe 01
\ '3E Ot
SMC OS
 IOt<
1 .4k-00
1 2i^5l
e 7 Oi
iuo^-o;
llUJl
3 46E 32
i ME 02
3&7COO
I df OS
11A*U
Jiit-O*
? iOC^C
I iit-02
7lb 01
6l 02
0'.
3	JM 01
224E02
1 ME 01
47ECI
4	29t M
I iU 04
rwo
3M 01
1CCt>0
I MC-01
 96tO
2 53E 10
ie io
400EM
~ 4St>0
92>E 10
0 00t>00
OWE Ml)
27CC-M
OOC >00
or u
000t>00
oou# k
2 'it-0
7 UE 09
0	OOC >00
1	aseo4
I )lh 06
J41t 11
4 tc ie
3 Wt 09
0 OOC-00
0	OOt *30
1	99c 0/
7 ME 10
1	J0C-t4
3 il OS
2	34  04
0 OOC -00
o00C>00
ooucoo
OMk-OC
OOJC>OC
0 OOt .00
OUtf. J0
OQCf-OO
C Xi-co
3 ilE 
ocac-oo
oooeoo
mc
3 4E Ob
OJOtwX
4 ME 04
0	UOE .oo
UOC/.OU
1	1it4
Mr "marntfmr C'onMM'W- '*)
Owrm* m>M Oof ti XSf.i
IWIW 
'A
& j iu* Cvxwm
0 00' crr>*v
2 45
65
0 l^nii
0 l>Mt
Fipntao 5il4Mc
(l4UUllluM
(ttJJUl
*"V1I

* ^
1 Mm i/4*f
iroo cttl?
340 uay>r
Fiiqjtncr
i.^.vunfW*
(U'AJ)
I	tDuaku.
Oirt Ctntm S
?oo itvan
100 r^.u,

-------
ATTACHMENT J.D-2 (Continued)
Particulate Deposition - Vegetable Ingestion
fcipMut* Kt	io< fvOcuiM*
COWMOUYY:	Kkths *J
Knnn
WASTE	Cmi >Ai
ST ROM
CT Lw>9-T*	1 SOC 04 wn2  7C-0* n't* <.	1 lit-00	rm
Ofcuno*
K Long-TwPfcfon	4 40c 04 (MMW ISik-O' gW w	itVt^O ^oUim
CT St*	ME !mj4 CI Conc ME Ciw*<*i CI Cyncn*ui ME Cmi
;Vrcan9Kion	iiUwiiiiinl i Axviw.t*vl	 Ami	n K
30 YMil ;mgiVi|) 30 r
Uu'>
b*r/*MT
CA>ora>n00
0 (I* >00
0 QCt -oo
0CCC.00
0 CC-f -oo
0 CJUt 00
Oct 04
OOC u
oof 
 76E 04
090t00
Djirm
94C 03
1	49C 00
7yfc
2	Mb HI
E 06
1 MEM
OCI# CC
00Ci.CC
I cnt00
OOt .00
in 06
J6fc i*
 07
OOt .00
7 jf 
1E 34
47k 3*
ill 34
uocoo
1 4t <
700
0	00 >00
1	m o?
ME AMutMtJ
/UIP-07
3i'lE 37
0	ME.00
?Mf 37
1	40t 36
2	07C 0/
I2?t 12
J fif JC
I 2CE 3fl
 tec 07
O0rf.CC
CT Autvbad mC amumu
t34 0%
0 00b*CC
4 10fc 37
7 7&C 06
 04E Of
0 OOC OC
9f 07
4 ICt oe
7 !>CC O?
4 04fc12
i *E
4CE 0*
4 M 07
0 OOC oc
C Out
C OOt
0 OOC .00
C U0 .CD
1 SI ct
0 OtE -00
 torn CnO*<*d

UanoOpt
soa niKV
Cg>iur
l>4potonP.
t4uiu Dvc>
So* IkJi IMTMy

2B

^ka-tEapCteJtlo
CuinfKt>

-------
ATTACHMENT J.D-3
Air Emissions to Surface Water - Risk Screening Results
Exposure and Risk Calculations lor Air Emissions
COMMODITY:
WASTE STREAM:
CT Long-Term
Emissions
HE Long-Term
Emissions
Alumina and
Aluminum
Cast house dust
3.24E+08
1.52E+09
mg/year
mg/year
Flow Rate
3.00E+11
1 30E+10
L/year
L/year
Constituent
Maximum
Concentration in
Waste (mg/kg)
CT Water
Concentration
(mg/L)
HE Water
Concentration
(mg/L)
Surface Water HBL Concentrations fmu/L>
Fish - Noncancer Fish - Cancer Drinking Water  Drinking Water -
Noncancer	Cancer
Antimony
Arsenic
liarium
Beryllium
Cadmium
Chromium(VI)
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
7.5
32
10
0
7.2
110
17
0 0001
260
0.92
1.9
0
0
120
8.10E-09
3.46E-08
1 08E-08
O.OOE+OO
7.78E-09
1 19E-07
1.84E-08
1 08E-13
2.81 E-07
9.94E-10
2.05E-09
O.OOE+OO
O.OOE+OO
1.30E-07
8.77E-07
3.74E-06
1 17E-06
0.00E+00
8.42E-07
1.29E-05
1.99E-06
1 17E 11
3.04E-05
1.08E-07
2.22E-07
0.00E+00
0.00E+00
1.40E-05
NA
NA
3 77E-01
2.84E-02
7.35E-05
9 00E-01
NA
NA
1.02E-01
8.40E-03
1 80E-02
3.02E-05
NA
3.12E-01
NA
7.40E-04
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
1.40E-02
NA
2.45E+00
1.75E-01
3.50E-02
1 75E-01
1.50E-02
1.05E-02
7.00E-01
1.75E-01
1	75E-01
2.80E-03
2	45E-0I
1.05E+01
NA
8.40E-04
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

-------
ATTACHMENT J.D-4
Runoff Deposition to Soils Screening Results
Release, Exposure Risk Calculations for Waste Piles
1. Aluminum Cast House Oust
Constituent
l~gesf 0" Pathway Ingestion Pathway Max:num 3uik
Cdf-;e- Si;o? Factor RfO .Ti^/Vg-day) Concertra'ion in
im^-kg-dayi-
(m^kg)
Concen'rat on
(1~ges:o-: and
Dermal) img/Vg)
HE 3oi'
Concen:rat on
(Ingestion and
Der-iai Contact;
(irgftg;
CT Soil
S:ncoitration
HE Soil
Concentration
(Ingestion of home- (l-gestion o' Home-
G'cv%n Ve^etan as) Growr Vegetables)
(Tig/kg)	i^yVg)
A-Ucnony
A'senic
Barium
Beryllium
Cadmium
Chrom^mi VI)
Lead
Mercury
Nicke
Selenium
S-lver
Thallium
Vanadium
Zmc
0.C004
o. :oo3
0 07
0-07
o :oos
0.005
0.0003
0.02
0 005
0 005
oocooe
0 009
0 3
75
32
10
72
".10
17
0.C001
260
0 92
 9
1	32E-03
8.17E-03
2.55E-03
1.34E-C3
2.31E-02
4.34E-03
2	55E-C8
664EC2
2 35E-C4
4.85E-C4
1	53E-01
6.74E-01
2.VE-01
1.52E-0'
2	32E+00
3.58E 0*
2 11E-06
5.48E+00
1.34E-02
4.:0E-02
2	3311-04
1.02E-03
3.19E-04
2.30E-O4
3	51E-03
5	43E-04
3 19E-09
8 30E-02
2 94E-05
6	07E-05
1-58E-02
6 74E-02
2.ME-02
1 52E-02
2.32E-01
3.58E-02
2.' *E-07
5.48E-01
1.94E-03
4.0CE-03
Pathway Variables
USLE Reieaso Wode'rg <7-52)
AWPd
AWPf
R
K
LS
C
P
SL
SL
Area ol Waste PHe !DuSt)
Area ol Waste Pre ;Ferrcs iicon)
Rairia I factor
Son Erodabi ity
Facto'
Lergn-Siopa Factor
Ccver Factor
Ccntroi Practices
Factor
Total Soil Less
(Djst)
Total Soil Loss (Ferrosilicon)
108
509
50
0.25
1
1
1
301
108 m2
509 m2
110 i//ear
0.25 t/year
3 unities*
1 unitless
1 unitless
1986 kg/year
3360 k^/year
So d Dehv^ry
Radius of contaminated area
So J Concentration due :o Deposition: Dermal and ingestion
7.
BD
ks
Mixing Oeptti
Soil Bulk Oensity
Soil Loss Constant
Deposition Penod
Mixed Soil Mass (Dermal and Ingestion)
2.5
1.5
0
20
1 18F.+06
1 cm
t.2 grr/cc
0 1/years
2Z years
9.42E+04 kg
So;/ Concentraticn due to Deposition: Root Vegetabios (6-58)
L
8D
ks
Mixing Depth
Soil Bulk Density
Soil Loss Constant
Deposition Ponod
Mi*ed Soil Mass (Root Vegetables)
20
1.5
0
20
9 42E+06
10 cm
1.2 gm/cc
0 1/yea-s
20 years
9.42E+05 kg

-------
ATTACHMENT J.D-4 (Continued)
Runoff Deposition to Soils Screening Results
Release, Exposure Risk Calculations for Waste Piles
2. Zinc Waste Frrosillcon
C
-------
ATTACHMENT J.D-5
Runoff Deposition to Surface Water Screening Results
Release, Exposure Risk Calculations for Waste Piles
1. Aluminum Cast House Dust
Constituent	Ingestion Pathway ingestion Pathway
Cancer Slooe Factor PfD (mg/kg-day)
(mg-kg-day)-1
Antimony	0.0004
Arsenic	1 5 0.0003
Barium	0.07
Beryllium	0.07
Cadmium	0.0005
Chromium(VI)	0.005
Lead
Mercury	0.0003
Nickel	0.02
Selenium	0.005
Silver	0.005
Thallium	0.00008
Vanadium	0.009
Zlno	0.3
Pathway
Variables
USLE Release Modeling (7-52)
AWPd	Area ot Waste Pile (Dust)
AWPI	Area ol Waste Pile (Ferrosilicon)
R	Rainfall factor
K	Soil Erodability
Factor
LS	Length-Slope Factor
C	Cover Factor
P	Control Practices
Factor
SL	Total Soil Loss
(Dust)
SL	Total Soil Loss (Ferrosilicon)
Surface Water Characteristics
Flow Rate
Maximum Bulk CT Waterbody HE Waterbody
Concentration in Concentration Concentration
Waste (mg/kg)	(mg/1)	(mg/l)
7.5	7.525-09	1.15E-06
32	3.21 E-08	4.89E-06
10	1.00E-08	1.53E-06
7 2	7.22E-09	1.10E-06
110	1.10E-07	1.68E-05
17	1.71 E-08	2.60E-06
0.0001	1.00E-13	1.53E-11
260	2.61 E-07	3.97E-05
0.92	9.23E-10	1.41 E-07
1.9	1 91E-09	2.90E-07
120	1.20E-07	1.83E-05
CT	HE	Units
108	108 m2
509	509 m2
50	110 1/year
0.25	0.25 t/year
1	3 unitless
1	1 unitless
1	1 unitless
301	1986 kg/year
1418	9360 kg/year
3.00EVI1	1.30E+10 liter/year

-------
ATTACHMENT J.D-5 (Continued)
Runoff Deposition to Surface Water Screening Results
Release. Exposure Risk Calculations for Waste Piles
2. Zinc Waste Ferrosilicon
Constituent	Ingestion Pathway Ingestion Pathway
Cancer Slcpe Factor RfD (mg/kg-day)
(mg-kg-day)-l
Antimony	0.0004
Arsenic	1.5 0.0003
Barium	0.07
Beryllium	0.07
Cadmium	0.0005
Chromium(VI)	0.005
Lead
Mercury	0 0003
Nickel	0.02
Selenium	0.005
Silver	0.005
Thallium	0.00008
Vanadium	0.009
Zinc	0.3
Pathway
Variables
USLE Release Modeling (7-52)
AWPd	Area of Waste Pile (Dust)
AWPf	Area of Waste Pile (Ferrosilicon)
R	Rainfall factor
K	Soil Erodability
Factor
LS	Length-Slope Factor
C	Cover Factor
P	Control Practices
Factor
SL	Total Soil Loss
(Dust)
SL	Total Soil Loss (Ferrosilicon)
Surface Water Characteristics
Flow Rate
Maximum Bulk CTWaterbody	HEWaterbody
Concentration in Concentration Concentration
Waste (mg/kg)	(mg/l) (mg/1)
5000	2.36361 E-05 0.003599954
40000	0.000189089 0.028799636
CT	HE Units
108	108 m2
509	509 m2
50	110 1/year
0.25	0.25 t/year
1	3 unitless
1	1 unitless
1	1 unitless
301	1986 kg/year
1418	9360 kg/year
3.00E+11	1.30E+10 liter/year

-------
ATTACIIMKNT J.D-6
Surface Impoundment Releases to Surface Water Screening Results
COMPARISON
FISH HGESTIC
OF SURFACE t
N	
WATER CONCE
NTRATIONS FF
OMSURFACE
MPOUNOUEN'
RELEASES TO HEALTH-BAS
i
Maximum High-End Surface
Water Concentration, Bulk
Samples
ED LEVELS |
Central Tendency Surface
Water Concentration, Bulk
Samples
Maximum High-End Surface Water
Concentration, EP Samples
Central Tendency Surface
Water Concentration, EP
Samples





Slate
Compared to HBL
Compared to HBL
Compared to HBL
Compared to HBL
Constituent
Hazard-Based
Level (mo/1)
Commodity
WMtMlraam
Facility
1-10* ! 10-100*
MOx
10-100*
MOx
KMOOx
100-1000X
MOx
10-100*
Arsenic
0.00084
Copper
AckJ plant
biowdown
Unknown
Unknown
! *









Copper
Acid plant
blowdovm
Unknown
Unknown
Unknown
Unknown
X
X










Copper
Acid plant
hlowdown


Copper
Acid plant
Wowdown
Unknown
Unknown
*

























Copper
Ac>d plant
blawdown
Magma. San
Manuol
AZ






X
X
















Cadmium
0035
Zinc
Spent surface
impoundment
llQUldS
Zinc Corp of
America,
Monaca
PA
*








Load
0015













Zinc
Speni surface
impoundment
liquids
Zinc Corp ot
America,
Monaca
PA

X









Copper
Acid plant
blowdown
Unknown
Unknown
X








'
Zinc
Spent surface
impoundment
liquids
Big River Zinc
IL
X

*







-------
ATTACHMENT J.D-6 (Continued)
Surface Impoundment Releases to Surface Water Screening Results
COMPARISON OF SURFACE WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO HEALTH-BASED LEVELS

I

1
1
FISH INGESTION






1





Hazard-





Maximum High-End Surface Water
Concentration, Bulk Samples
Central Tendency
Surface Water
Concentration, Bulk
Samples
Compared to HBL
Maximum HiglvEnd Surface
Water Concentration, EP
Samples
Central Tendency
Surface Water
Concentration, EP
Samples
Compared to HBL

Based


,


Compared to HBL
Compared to HBL
Constituent

-------
CONSTITUENT CONCENTRATION DATA
FOR RECYCLED MATERIALS	APPENDIX K
April 30, 1998

-------
K-1
SUMMARY OF BULK AND EP ANALYSIS RESULTS FOR MINERAL PROCESSING WASTE (RECYCLED PORTION)
November, 1996
Bulk Samples. Nonwastewaters.
Faciiit-/ dentif er

Number


Ccnst tuems
Detections
Commodity
Waste Stream
Arfmonv
1
Aljfi'-a and 4lumn .m
Cast nojse 3usf
A;sen c
l
Aijmra and Alum n_m
Cast -lojsa Just
3
(3)
Ccsiituent
Mass m
Suia^e
Impojndme'-t
(V5)
(4)
A*ca of
5u-*a:e
Impoundment
Antimony
31 Beryllium
Chip treatment wastewater
One Unnamed Facility
Unknown
0003
417
0GC1Z5
Antimony
Copper
Acd pi ant slowdown
Unknown
Unknown
140
22:83
305'. 66667
Antimony
Copper
Acid p-a-t slowdown
Unknown
U nun own
5
22:83
11041667
Antimony
Copper
Ac d plant oicwdown
Unknown
Unknown
OS
22C83
11 04167
Antimony
Copper
Ac d p-ant oicwdown
Unknown
Untnown
0263
22583
5 80732
Antimony
Eienentai ehcssncnjs
Furnace scubtoer blowdown
Unknown Amencan Plant
Unknown
48
17500
84
Antimony
Elemental Phcs-hcnjs
Furnaco scubber btowdown
Urknown Amencan Plant
Unknown
24
17500
42.
Antimony
Elemental Phcschcrus
Fumace scubber blowdown
FMC Pc-catello
ID
2
17500
35.
Antimony
elemental Phcschcois
Furnace scubber blowdown
FMC PccaleJio
ID
1.16
17=00
20 3
Antimony
Elemental Phoschcrus
Fumace scubber blowdown
Startler. Mt Pleasant
TN
0.05
1750C
0 875
Antimony
Elemental Phrsph^rus
Furnace scubber btowdown
Stau-tter. Mt Pleasant
TN
0.05
17500
0 875
Ant rrcy
Elemental Phoschcrus
Fumace scubber biowdcwn
Unknown Amnncan Plant
Unknown
0 016
17S0C
228
_ Antimony
Elemental Phoschcrus
Fumace scubber btowdewn
Unknown Amencan Plant
Unknown
0016 '
17=0C
"29
Antimony
Rar Earns
Process wastewater
Mofycorp. Louviors
CO
0 5
117
0 05833
Antimony
Rare Earths
Process wastewater
Molycorp Louviers
CO
03
117
0 C5333
Antimony
Selenium
Plant p'ocess wastewaters
AMAX. Fort Madiso^
1A
05
550
0 275
Antimony
Tanta'um. Colurrb um. and Ferrocdurrb'um Process wastewater
Urnamed Facility
Unknown
0 1
4375
0 4375
Antimony
Ttanium and Ttanium Dioude
Leach hqind & sponge wash water
Timet. Hencerson
NV
25
4COO
' 2.
Ant-mcy
"Haniun and Ttaniurr Dioxide
Leacti liquid & sponge wash wnter
Unnamed Plant
Unnown
0074
4000
0 296
Ant rro"y
7-tanium and T taniurr Diowde
Scrap milling scruboe.' water
SCM. Bait more
MD
05
42
0 02003
4n|:rrony
Znc
Process wastewater
Zinc Corp. Bart esviiie
OK
0933
99167
92 5225
Antimony
Z.ns
Process wastewater
Zinc Corp. Bart'esvdie
OK
05
39167
4958333
An:imony
Z.nc
Process wastewater
Zinc Corp. Monaca
PA
1
99167
49 58333
An:ir"ony
Znc
Process wastewater
Unknot
Unknown
05
99167
49 58333
Antimony
Zmc
Process wastewater
Unknown
Unknowr
05
99167
4958333
An'irno.ny
Z.nc
Process wastewater
Zinc Corp. Monaca
PA
0 155
S9167
15.37083
An-*-io"iy
7 nr.
Process wastewater
Zinc Corp, Monaca
PA
0.05
99167
4 95833
Antimony
Znc
Process wastewater
Zinc Corp. Monaca
PA
0.05
99167
4 95833
Antimony
Znc
Process wastewater
Zinc Corp. BartiesviMe
OK
0.05
99167
495833
Aniimony
Znc
Process wastewater
Zinc Corp, BartiesviMe
OK
0.05
99167
4 95833
Antimony
Z.nc
Process wastewater
Zinc Corp. BartiesviMe
OK
0.05
99167
4 95833
Arseric
43 Ber/iiium
Chip treatment wastewater
One Unnameo Facility
Unknot
0.003
417
0.00125
Arseric
Copper
Aod plant biowdcwn
Unknown
Unknown
5800
22083
1280R3 33333
Arsenc
Copoer
Acid p7
Arsenic
Cooper
Ac.d plant btowdewn
Unknown
Unknown
005
22083
1.104*7
Arsenic
Cooper
Ac d plant blowdown
Unknown
Unknown
0.05
22083
1.104' 7
Arsenic
Elemental Phoschcrus
Fumace scrjbber blowdown
Unkrown American Plan
Unknown
8.7
17500
152 25
Arsenic
Elemental Phosphorus
Fumace scrjbber blowdown
Unkrown
Unknown
1
17500
175
Arsonrc
Elemental Phosphorus
Fumace scrjbber blowdown
Unknown Amencan Plant
Unknown
0.501
17500
8 7575
Arsenic
~ementaJ Phoschcrus
Fumace scrjbber blowdown
FMC. Pocateiio
ID
0.5
17500
8.75
Arsenic
Elemental Phoschcrus
Fumace scrjbber blowdown
Unknown Amencan P'ant
Unknown
0.4
17500
7.
Arsenic
Elemental Phosphorus
Fumace scrjboer blowdown
Stau'ter. Mt. Pleasant
TN
005
17500
C.875
Arsenic
Elemental Phosphorus
Fumace scrubber b owdown
Staufler. Mt Pleasant
TN
0 05
17500
C.875
Arsenic
Elemental Phosphorus
Fumace scruboer b owdown
Unknowr Amencan Plan
Unknown
3.016
17500
0 28
Arsenic
Rare Earths
Process wastewater
Molyco-p. Louviers
CO
0.5
117
0.05833
Arsenic
Rare Eartfts
Process wastewater
Molyco-p. Louviers
CO
C.5
117
0.05833
558
044"
044-
' 044'
*0441
8429
8429
8429
3429
8429
3429
3429
34?9
33S
385
63'
2517
234-
234*
,140
43334
43334
43334
43354
43334
43334
43334
43334
43384
43364
433S4
558
1T441
1C441
1C441
1C441
1C44 t
1 C'44 1
10441
104-11
10441
10441
10441
10441
10441
10441
10441
8429
8429
8429
8429
8429
8429
8429
8423
385
April 30, 1998

-------
K-2
Arsenic
Selan'U'n
Want process wastewaters
Climax Molyt-
IA
2.4
550
1 32
631
Arsenc
Se'en;um
Plant process wastewaters
AMAX, Fort Madison
IA
Cf>
sro
0 275
631
Arservc
T'.Af um 302 Titan un D'ode
leacr iiq-jic & sponge wash water
Timet. Henderson
NV
2 S
4000
10
2341
Arsenc
T'tar um an-: Titan un Dioade
leacf hqjic & sponge wash water
Jnnar*ed P'ant
Unknown
0.1
4QCO
0.4
2341
Arsenic
T.for un ana Trtan-um Dionde
Scrap mill ng scrubber water
5CW. Bal'irro'e
MO
05
42
0 02083
240
Arsenic
Zn-
Process wastewater
Zi"c Corp. Ba-!esviiie
OK
2 54
99157
251 88333
43384
Arsenic
Znz
Process wastewater
Zrc Ccp. M:naca
PA
1
99157
1 j6 85
43j84
Arseric
Zr.Z
Process wastewater
Jnkncwn
Unknown
1.1
95*67
109 08333
43"84
A.'seric
2n;
Prcccss wastewater
Zrc Co-p. Ba-tcsviife
OK
:.s
95-67
49 58333
43384
A'senc
Zno
Prrc^ss wastewater
7j'c Co-p. Mr.n.aca
PA
o
o
99157
4.fJb833
43284
A'^'vc
2n:
Prccess wastewater
Zrc Co*p, Mcnaca
PA
0 05
99*57
4 Q5633
43184
Arsenic
Zn:
Process wastewa'er
Zrc Co*p. Mcnaca
PA
0 05
99*57
4.55833
13384
Arsenic
Z nc
Prccess wastewater
Zi-c Co-p. ea^ies/iiie
OK
0 05
99*57
4 35S33
43384
Arsenic
Z n-
Prcccss wastewater
Zi-c CO'p. Bar*iesviiie
OK
0 05
99-37
4 95533
43184
Arser'C
Zr:
Prrc*5s wastewa'er
Zrc CO'p. Bariosviiie
OK
C002
99*57
0.19833
-1338-1
A.-seric
Z:
Process wastewater
'Jr^n^wn
Urknown
:oo2
99157
C.19833
43384
A/seriC
Zrz
Spert su-iaoe impoundment i quros Biq River Zinc
IL
214
* 0500
2247
5319
Ear uti
35 CoppH
Aoc olant Diowcoivn
jnKncwn
Urknown
59
22093
130 29167
10441
Ba-u.Ti
Copper
AciC ctant blowcown
Jnkncwn
Unknown
5.8
22033
123 C-SL'3J
10441
Ea'um
Copper
Ac.c orant biowcown
Jnkncwn
Ur known
1 4
220!?3
30.91667
10441
B
-------
K-3
Ca3n"i^m
Ccpce*
Acc plant fciowcown unknown
Unknown
j. 2
22C93
4 4 1667
10441
Cadrum
 enentaJ Pnosot"or\,s
Fjmace scaibber Wowdown FMC. r>ocate'to
ID
9C
1 75C0
'58.
8423
Canr-i-m
E ementat Phosphorus
Fjmace scrubber btowdow* FMC. locate lo
ID
4 75
1 7530
83 125
8429
Cadrr^m
f: re
MD
0 05
42
0:020a
340
CadrriLm
Zir.c
P*ocess wastewale' Zmc Corp. Bartiesv>iie
OK
55
99*67
55037 5
43384
Caim.m
Zmc
P'ocess wastewater L"npoundmpnt liquids Z\'-c Co-p cf America. Monaca
PA
870
10530
9^35
5J' J
Cadnum
Zinc
Sect surface impoundment i:qjids Zi~c Co-u 2f America. Monaca
PA
650
10530
5825
53:3
Cadmium
Zinc
S:e-t surface impoundment i-quifls Big Hivor Zm;
IL
600
io s:o
53:0
53'3
Cadmium
Zjnc
Sce"t yjrface impotmrlment i.quids Zrc Co'p cf Amenca
OK
160
105:0
1630.
53-3
Cadnum
Zmc
Sce-t surface impoundmeni i quids Zi"C Co-p rt Amenca
OK
100
1C5C0
1050
53-3
Ca^r-i-m
7inc
Sce-t surface impoundment i-quss Z"rc Co'p ot Amenca
OK
93
105CO
375 5
5*13
Cadnum
Zmc
Sp"t suiace i-npoundment i-quias Zrc Co'p of Amenca
OK
90
105:0
945
5319
Cadnum
Zmc
Spent surface impoundmeni! qui^s Zrc Co-p America
OK
70
105CO
rj$
5313
Cadnum
Zinc
Sper.t surface impoundment I quids Jersey Mi'-iere
TN
45
I05CO
472 S
53' 9
Cadnum
Zinc
Spe^t surface impoundment! quids Big River Znc
IL
5.2
105CO
54 6
5"' 9
Cadnum
Zinc
Spent surface impoundment I q.iwS Zi-e Co-p of Amenca
OK
13
105CO
1365
533
Cadnum
Zmc
Spent Surface impoundment! quics Zi"C Corp of America
OK
1 3
105CO
1365
5319
Cadr-i_m
7inc
Spent surface impoundment I qiss Zrc Corp of Amenca. Monaca
PA
0.3
10500
3 15
53 IS
Cadni.m
Zmc
Spent surface impoundment 1 q.cs ZJ>"c Co'p of Amenca. Monaca
PA
0.2
105:0
2.1
5319
Cadnum
Zmc
WWT liquid e'tLe^t Zi"c Corp of America
OK
24200
72S0
1 .'5450
3850
Cadni jm
Zinc
WWTP liquid elLe"t Zinc Corp cf Amenca
OK

7250
7 25
3E50
Ch-o'nium
44 Reryl'ii.m
Chip treatment wastewate' One unnamed Fac;ti:y
Unknown
74
417
108333
559
Cn-oniurr
Ccpce'
Acid plant Wowdown Llnknown
Unknown
2"
22083
453.75
10441
Oh-nmurr
Ccpce*
Acid plant Wowdown Unknown
Unknown
19
22083
415.58333
10441
Ch'orn jrr
Ccpce.*
Acid plant Wowdown Unknown
Unknown
2 37
22063
52.3375
10441
Ch'Oniyrr
Ccpser
Acia plant bJowoown Unknown
Unknown
18
22083
39.75
10441
Ch'oniufT
Ccpser
AciC plant Mowdown Unknown
Unknown
1.4
22083
30.91667
10^41
CH'OTiium
Ccp-er
Acid plant Howdown Unknown
Unknown
1 2
22063
26 5
10441
Chromium
Ccp^e*
Acid pJant Wowaown Unknown
Unknown
1.05
22083
23 1875
10441
Ch'O-nium
Ccpce'
Acid plant Wowaown Unknown
Unknown
1
22063
22.08333
1CW41
Ch'O'nium
Ccpce"
Acid plant Wowdown Unknown
Unknown
0 78
22063
17 225
10441
Ch'cnrjrr
Ccpce-
Acid plant Howdown unknown
Unknown
0.4
22083
8 83333
10441
Ch.'ontjrr
Ccpcer
Acid plant Wowcown J.-iVnown
Unknown
0259
22083
5.71958
10^41
Ch'
-------
K-4
Cn-omi jm

Zmc
P'ocess wastewate'
Zinc Corp. Bartiesviie
OK
J.386
99167
38.27333
43384
Ch-oni jrr>

i'.r\ c
Process wastewate'
Unknown
Unknown
0 06
99167
5 9=
43304
CM'orn jm

?.nc
P'ocess wastewater
Zinc Corp, Vonaca
PA
0 05
99167
4 =55333
4.3"84
Cn*omum

Zinc
P-ocess wastewate'
Zmc Corp, Vonaca
PA
0 05
99167
4 35533
43384
O'onum

Zinc
P'ocess wastewate'
Zinc Corp. Voraca
PA
0 05
99167
4.35533
43384
Ch'onum

Zinc
P-ocess wastewate'
Zinc Corp. Baniesv iie
OK
0 05
99167
4 35=33
43184
Cn*onium

Zinc
P'ocess wastewater
Zinc Corp Bartissvile
OK
0 05
99167
4 35333
43384
0*3mi.,m

Z:nc
P ocess wastewate'
Zinc Corp Bartlesv lie
OK
0C45
99167
4 4525
43384
Chrsf'-ni

Zmc
P-ocess wastewate'
UnPi d

Zn:
Spent surface impoundment liquids
Zinc Cohd ol Amenca Monaca
PA
5X0
10500
52500.
5319
Lead

Z nc
Spent surface impoundment liquids
Zinc Cors ol Amenca. Monaca
PA
25C0
10500
26250.
5313
Lead

Z nc
Spen' surface impoundment iiquS3
inc Corp ot Amenca. Monaca
PA
07
10500
7 35
5319
Lead

Zn:
WWTP liqu d effluent
Zinc Corp ot Amenca
OK
61 CO
7250
44225.
3850
M-rcu'y
42
BeryHuj-n
Chip treatment wastewater
Ore Unrarred Facility
Unxnown
0 0002
417
0 000-08
558
Msrcu7

Cooper
Acid plant slowdown
U-knftwn
Unknown
: 5
22083
33'25
044*
MorCud p-ant slowdown
Unknown
Unknown
0-0428
22083
0 94517
'0441
Marco"/

Cooper
Acid p
-------
K-5
Me-c^ry
Zinc
Process was*ewater
Zmc Corp. Monaca
PA
0
r9167
34 bl
43384
Me'Cury
Zinc
P'ocess wastewater
Zinc Corp. Bartiesvihe
OK
0 0274
99167
2 717'7
43384
We'C-ry
Zi-c
Process wastewater
Unknown
Unkncwn
0-010
99167
1.785'
43384
Mcc-jry
Zr c
Process was'ewater
Zinc Corp. Bart'esvii'e
OK
0.00999
99167
0 99063
43384
Me-c_ry
Zrc
Process wastewater
2m: Corp, Monaca
PA
C 0065
99167
0 54453
433P.4
Me'C^ry
ZirC
3rocess wastewater
Zmc Corp, Monaca
PA
2.0031
59167
0 307c2
43?e4
Me*cry
Zrc
3rocess wastewater
Zmc Corp. Ban esviile
OK
0.0019
39167
0 188*2
433b4
Me'C.ry
7mc
Process wastewater
Zinc Corp, Bartesvilie
OK
0 00075
99167
0 07438
43354
Me'c^ry
Zrc
process wastewater
Zmc Corp. Monaca
PA
C.00C1
99167
0 00992
43394
Mercury
Z.TC
Process wastewater
7inr. Corp. Bart esviile
OK
: 0001
99167
0 00392
4j3t;4
Mercury
7rr.
Process wastewater
Urknown
Unknown
z.ooz-
99167
0 0099?
433!?4
Merc-ry
Z.rc
3oent s irface moourdment liquids B g Hive* Zinc
H
23 8
10500
249 9
53'9
Mercury
Arc
Syent sjrfaca 'rrouurdment liqu ds fl g Rive' Znc
IL
3 538
1C500
J7 *49
=319
Mero-ry
Z.rc
Spent sjrfacs impoundment "iqu:ds
. ^e-sey M n er9
TN
1
lOiOO
105
5319
Mercery
Zrc
Spent sjrtace impoundment hquds B g Rive' Zinc
IL

tosoo
10 5
53t9
Ve'Cury
Zirc
Spent surface imooix"T~int liqu ds
. 8 g Rive Zinc
IL
Z 17
10500
1 7S5
S319
Nickel
43 Ber^lurr
Cue reatrre-t wastewater
One U"inamec Facility
Unknown
: 7H
4" 7
0 325
553
Nickel
Conner
Acid olant biowdcwn
Urknown
Unkncwn
1450
22C83
32020 83333
it441
Nickel
Copper
Acid Dlar! biowdcwn
Urknown
jnxnown
940
^2:83
20758 3o333
IC441
Nickel
Cooper
Acid oia/>; biowdcwn
Urknown
'Jnknewn
20
22-83
44 * 66667
1 C44 t
Nickel
CofiDfir
Acid oiart biowdcwn
Urknown
Jnknewn
16
22C03
353
1:44?
Nickel
Copper
Acid olan* biowdcwn
Unknown
Jnknewn
2
22C83
44 t666?
1C-441
Nicfcel
Cooper
Acid olant biowdcwn
Unk-own
Unknown
1.95
22C83
43.0625
IC441
Nickel
Copper
Acid oian: biowdcwn
Unknown
Jnknewn
' 8
22C83
33.7S
1 C44 1
Nicxol
Cocper
AcjcI 3 an? biowdcwn
Unknown
jnknewn
1 2
22:83
26.5
1 C44 1
Nickel
Copper
Acid plan: Slowdown
Unk-own
Unkncwn
' 2
22383
26.5
1C441
Nicxel
Copper
Acid o*ant biowdown
Unknown
Unknown
0 481
22383
10 6??08
1:441
Nickel
Copper
Acid 3an* slowdown
Unk-own
Unknown
0.005
22383
0.11042
1 :441
Nickel
Elements Prospno-us
Furnace scrjboe* b owdown
Unk-own Amencan Plant
Unknown
530
1750C
9275.
8429
Nickel
Elemenia PI"OSpno*us
Fur ace scrjcoe' b owdown
Unk-own A.Tienoan Plant
Unknown
19
1750C
332 5
94?9
Nickel
Elementa Prospno*^
Fur-ace scr^boe' b'owdown
IJnkrown Amenoan Plant
Unknown
1.3
1 7503
22 75
5429
Nickel
Elemental PFosphous
Fur ace scrboe' bio wdown
FMC, Pocatello
ID
05
17f;03
8 75
3429
Nickel
Elemental Pnosptx>.us
Fur ace scr-boe* b'owdown
F^C. Pocatello
!D
02
17503
35
3429
Nickel
Eiementa: Pnospno.-vs
Fur-ace scr-boe- biowdown
StauMer. Mt. Pleasant
TN
0.05
17503
0 875
3429
Nickel
Dementa: Pnosphor\J3
Fur ace scr,boe' biowoown
StauMer, Mt. Pteasant
TN
005
1750C
0 875
f?429
Nickel
Elemental Phosphorus
Fur ace scr_bbe' biowdown
Unknown Amencan P ant
Unknown
0.309
I'SOC
0.1575
9429
Nic
-------
So enurr
Zinc
Process wastewaie'
Ziic Corp. Monaca
PA
0.05
95' 7
4 95833
43384
S eii jir
Zinc
Process wastewate'
Zi->c Corp. BaHesviiie
OK
0 05
93'67
4 9S833
43 j84
Se e^'urr
Zmc
Process wastewate'
Zinc Corp. Banies-/iiie
OK
0 05
93'57
4 95833
43384
Se enrjfr
Zinc
Process wa*t?wa
Chip treatmen* wastewater
One Unramad Faclity
Urknown
004
417
:01667
559
Si ver
C-jczer
Ao;o plant b owdown
Un allium
Titan um and Titan'um Oioiode
Scrap milling scubber water
SCM. Baltirrore
MD
2.5
42
0"0417
340
Thallium
Zinc
Process wastewater
Zinc Co-p. Sarlesvi le
OK
3.59
99167
356 00833
43384
Thallium
Zinc
Process wastewater
Zmc Co^o, Sarttesvi'le
CK
25
99167
247.91667
43384
Thallium
Zinc
Process wastewater
Zirc Corp, Monaca
PA
3
99167
247 91667
43384
Thallium
Zinc
Process wastewater
Zirc Corp. Monaca
PA
0.25
99167
24.79-57
43384
Thallium
Zmc
Process wastewater
Zirc Corp. Monaca
PA
0.25
99167
24.79-57
'3384
Thallium
Zinc
Procoss wastewater
Zirc Corp. Monaca
PA
025
99167
24 79"67
43394
Thallium
Zinc
Process wastewater
Zirc Corp, Bartiesviile
CK
0.25
99167
24.79-67
43384
Traiiium
Zinc
Process wastewater
Zirc Corp. Bartiesviile
OK
0.25
99167
24.79*67
43384
Thailium
Zinc
Process wastewater
Unknown
Unnnown
0.17
99167
16.85833
43384
Thallium
Zinc
Process wastewater
Unknown
Uncrown
0.35
99167
4 95833
43364
lhaiiium
Zinc
Process wastewater
Zinc Corp. Bartlesvi'le
OK
0 024
99167
2.38
43384
Vanadium
27 Copoer
Acta ptant biowcown
Unknown
Unknown
2 72
22033
60 05667
10441
Vanadium
Copper
Acid plant biowdown
Unknown
Unknown
C.C5
22063
' 13417
10441
va.naaum
E omental Phosphorus
Furnace scruober olewdown
Unknown American Plant
Unknown
710
17500
12425.
8429
Vanadwm
E emental Phosphorus
Furnace scrubber biowdown
Unknown American Plant
Unknown
35
17500
6125
3429
Vana
-------
K-7
vanac? un

Zinc
P*ocess wastewater
Zmc Corp. Bartiesviio
OK
0 05
99*67
4.D5S33
vanadun

Zmc
P*ocess wastewater
Zinc Corp. Bartlesvlle
OK
0 05
93' 37
4 95P33
Varied urn

Zmc
P-ocess wastawaie'
Zinc Corp. Bartlesvlle
OK
0 05
99' 67
4 95933
Vand urn

Zinc
P-ocess wastewater
Zmc Corp. Bamesviie
OK
0 03
99:67
2.975
vanadun

Zinc
P-ocess wastewater
UrospK,.o'\js
Fur*ace scrubber b owdown
FMC. Pocaieib
ID
2't
17500
3692 5
7 nc

lerren:al Pf"OSp-orjs
Fur"ace 3crbcerbowsown
KMC. Hocatolio
10
196
17500
3433
Znc

elemental Pf-osp"orjs
Fyr-ace sen.oner b ow.-own
FMC. Pocatelb
ID
160
17500
2BO-0
Znc

Elemental Pr.osp'*o'\js
Fur ace scrubser b owdown
Unkrown American Plait
Unkncwn
130
17500
2275.
Znc

Eiemen*ai P^osp-o-js
Fur-ace scr_bser b owsown
Unkrown Amencan Plant
Unknown
77
17500
1347 5
Znc

Elemental Ptosp^o'js
Fur-ace scr-bser b owcown
Unkrown Amencan Plant
Unknown
69
17500
1207 5
Znc

Elemental Pfosp-o-JS
Fur*ace scrbser o owcown
FMC. Pocateiio
10
50
17500
875.
Z nc

Elemental Pbosp-OMS
Fur-ace scrbser b owcown
Worsanto. Soda Springs
ID
47
17500
822.5
Znc

Elemental Proso"o*js
Funace scr.bser b owcown
Stau'ler. Ml Peasant
TN
3 94
17500
68 95
Znc

rlemental Pf"OSp-0*us
rur-ace scrubser b owcown
Stauier. Stive' Bow
MT
3.94
17500
66 95
Zmc

Elemantai Pf osd"o-js
Fur-ace SCr-DSe' b owcown
St^u'ier. Mt Pleasant
TN
1 30
17500
?4 '5
Znc

Elemental Prosp-o-js
Furace scr05ef b owcown
Unkrown A,Tncan P'ant
Unknown
0.223
17500
0.4025
Zmc

Rare Earths
Process wastewater
Voiyccp. Louviers
CO
'4.2
117
1.65667
Zmc

Rare Earths
Process wastewater
Mo'y-orp, Louviers
CO
1 98
117
0.?31
Zinc

Selenium
Plant process wastewater?
AMAX. Fcrt Madison
IA
0 5
550
0.275
Zmc

Titanum and Titanium Dioxide
Leacn icu d 5 sponge wash water
imat. Henderson
NV
25
4000
10.
Zinc

T.larium and Titanium Ciorde
-each icu d & sponge wash water
Unnamed Plent
Unknown
0.64
4000
2*5
Zinc

Titarium ar.d Titanium Diox.de
Scrap milling scrubber water
SCM. 5atn>ore
MD
05
42
0 02283
Zmc

Zi-C
Process wastewater
Unknow.
Unknown
6OCO0
99167
5950000
Zinc

Zi-C
Process wastewater
Unnow.
Unknown
25COC
99167
2479166.66567
Zinc

Zrc
Process wastewater
Zmc Ccrp Bartlesv'lle
OK
20100
99'67
1993250.
Zmc

Zrc
Process wastewater
Unnnow"
Unknown
11COC
99'67
1090833 33333
Zinc

Zi.-c
Process wastewater
Z.nc Corp, Woraca
PA
1C.200
99'67
1011500.
Zinc

Zi"C
Process wastewater
Jersey Mmiere. C-d'Hsv-ne
TN
6000
99:67
595000.
Zmc

Zi-C
Process wastewater
Unknown
Unknown
490-0
99'67
485916.56667
Zinc

Zrc
Process wastewater
Jersey Miniere. C;arxsv-.ll
TN
2e4o
99'07
291633 33333
Zinc

Zrc
P-ocess wastewater
Un
Unknown
50
99167
4958 33333
Znc

Zi-.c
Process wastewater
Unknown
Unknown
50
99' 67
4958 33333
7. nr.

Zinc
Process wastewater
Un
-------
K-8
EP Analysis Samples. Nonwastewaters.
Number of
Corstitjents Oetsctions Comr.cdty
Antimony
Arsenc
Arse^'C
Arsenc
Ear j "
6aru-n
Ea' um
Cadmium
Cadmium
Cacmium
Chromtm
Cf!r jrru.m
Chromum
Leac
Leac
Leac
Mercu"/
MorC'J"/
Mrcu7
NickeJ
Se enum
Se-e'ium
Seenijm
Silver
Silver
Silver
Zinc
?i">C
Zinc
A-urrna ard ALmmum
Aiijni-a ard ALmmum
VagnssiuT ard Usg-esia
Vacnasium ard Magnesia
A'unna ard ALmmum
Macnjbiu'T> ard \1?g-esia
Magnesium ard Mag-e^a
Alumna ard ALmnum
Magnesium ard Uag-esia
Magnesium ard Mag-esia
Alumna ard ALmmum
Magnesium ard Mag-esia
Magnssum ard Mfg"esia
Alumna ard ALmmum
Magnesium ard Magnesia
Magnesium ard Mag-esa
Alumna ard ALmmum
Magnesium ard Magnesia
Magnesium ard Vag-esia
Alumna ard ALmmum
Alumna ard ALmmum
Magnesium ard Uag-esia
Magnestum ar d Magnesia
Alumna ard ALminum
Magnesium ard Slag-esia
Magnesium ar>d Mag-esia
Alumna ard ALmmum
Magnesium ard MagMesii*ies Surveyed
Unknown
0.84
tC7
2.-13363
1C8
Unknown Ameican Plant
Unknown
C.001
1671
0"4!:49
676
Unknown Ameican Plant
Unknown
0 0008
167'
C 03639
676
Facilities Su*veyed
Unknown
0 74
'27
2.14925
103
Facilities Su'veyed
Unknown
C- 001
27
0C029
108
Unknown Arrercan Plant
Unknown
0.016
167*
372/85
676
jnknewn Amercan Plant
Unknown
0-013
167i
2 59135
676
-acihties Surveyed
Unknown
0.15
'27
0.43565
108
Jnknewn Amencan Plant
Unk'own
0 14
1671
o 36S67
676
Unkncwn Arrercan Plan:
Unknown
0.05
167'
2 27452
676
Fatties Surveyed
Unknown
0.58
107
1 68*55
108
'Jnknewn Amercan Plant
Unknown
069
1671
31 38843
576
Unknown Amercan Plant
Unknown
0 02
167'
0 9098'
575
EP Analysis Samples. Wastewaters and Liquid Nonwastewaters.
Number of
Detections CommotJty
Facility dentifier
Constituent
Concentration
n Leachate
(rrgfl)
Vsurre of
Sjrtace
Imco.jndrrert
(m*)
(3)
-eachabte
Constituent
Mass ^ Surface
Imcojndment
;*S)
{6'i
Area of
Surface
"ijOi.ndrrert
Antimony
24 Coppor
Acd p a-"t clcwdown
Cyprus. Clay Pool
A2
5
22083
215 3-55
10441
Anhrroiy
Cooper
Actd pa"t cicwoown
Kennecott. Bingnam Canyon
irr
0 150
22083
7 5345
104 41
Anrrrony
El-rre''tal Phos'honjS
Furnace scrubber biowdcwn
Unknown
Un nown
* 6
17500
54 6
8429
Ant irony
Elemental Phosphcrus
Furnace scrubber btowdr-wn
U'known
Unknown
1.17
J7500
39 92655
8429
Anhrroiy
Elemental Phosphorus
Furnace scrubber Dfowdcwn
Unknown
Unknown
2.47
17500
16 03875
8^29
Antimony
Elemental Phoschcrus
Furnace scubbor blowdcwn
U-known
Unknown
0 16
17500
5.46
8*29
Antimony
Eisrre~tai Phosphorus
Furnace scubber btowdowri
U"known
Unknown
3.16
17500
5 46
8429
Actirrony
Elorre-tai Pnospncnjs
Fumace scubber blowdown
Unknown
Unknown
0.05
17500
! 7C655
8429
Ant rr.o-y
Eleme-tal P^osphcois
Fy.'nace scrubber btowoown
Unknown
Unknown
0.05
17500
t 7C655
8*29
Ant rro^y
Pare Eartns
Process wastewater
Unknown
Unknown
05
1' 7
0 11375
385
Ant rro-y
Pare Eartns
Process was'ewater
Unknown
Unknown
05
117
011375
385
Ant rro~y
Pare Earths
Process wastewater
Urknown
Unknown
OS
117
0 11375
335
Antimony
Pare Fartns
Process wastewater
Urknown
Unkncwn
05
1 * 7
0 11375
385
Anhmony
Rare Earths
Process wastewater
Urknown
jnknewn
05
1" 7
011375
335
Anhrrony
Fare Earths
Process wastewater
Unknown
Unkncwn
05
17
0 t1375
335
Aniirrony
Seienr.jm
Plant process wastewaters
Ur.known
Unknown
05
55C
0 53625
631
Antimony
Se enum
Plant process wastewaters
Unknown
Unknown
05
56C
0 53625
631
Art:rrony
Se enum
siant process wastewaters
Znc Corp o' Amexa. Monaca
PA
05
55C
0 53625
631
Ant rro"y
Tantaljm. Ccl-.mbium. and Femxoiumbium Process wastewater
Unknown
Unknown
0.224
4375
1.911
5517
Ant rrory
Tantalum. CoLmtwjm. and Ferrocdumb um Process wastewater
Unknown
jnknewn
0 05
437=
0.42656
5517
Ant mor.y
Tantalum. CoiumWum, and Ferrocolumb'um Process wastewater
Unknown
Unknown
0.05
4375
0 42656
5517
Ant rrony
Tantalum. Coiumbhjm. and Ferrocotumb.um Process wastewater
Unknown
Unknown
0.05
4375
0.42656
5517
Ant ro"v
TantaLm. Columbium. and Ferrocdurrb'um Process wastewater
Unkrown
Unknown
0.05
4375
0.42656
2517
Ant rrony
TantaLm, Columbium. and Ferrocoiurrbium Process wastewater
Unkrown
Unknown
0 05
4375
0.42555
2517
Arssftjc
48 Copper
Acd piant btowdown
Magma. San Manuel
AZ
12900
22083
551200
10441
A/seotc
Copper
Acd gtant btowoown
CBI
CBI
193
22083
8311 0525
10441
Arsenic
Copper
Ac;d slant blowdown
C8I
CBI
126
22083
5425 375
104*1
Arsenic
Copper
Acid slant blowdown
Kennecott. 3inghar! Canyon
UT
32.3
22083
1412 45
10441
Arsenic
Copper
Acid plan: blowdown
Kennecott. Bingham Canyon
UT
31.1
22083
1339.24375
10441
Arsenic
Copper
Acid ptant blowdown
Magma. Sa^ Manuel
AZ
29 9
22083
<287.56675
104*1
Arsenic
Copoer
Acid plant blowdown
CBI
CBI
21.6
22083
930 t5
10441
Arsenic
Copper
Aod plant biowdown
CBI
CBI
"4 1
22083
607 18125
10441
A,*sanic
Coppr
Add plant blowdown
Magma, San Manuel
AZ
11 2
22053
482.3
10441
A:sen.c
Cooper
Aod olant biowdown
Cyprus. Clay Pool
AZ
5
22033
2153125
10441
A-sen c
Copper
Aod plant biowdown
CBI
CBI
0 19
22083
3.18188
10441
Arsen c
Copper
Add clant b owdown
CBI
CBI
0 18
22033
7.75125
10-141
Arsen c
Copper
Aod ^ant b owdown
Magma. San Manuel
AZ
005
22033
2.15313
10441
Arsen c
Copper
Aod plant b'owdown
Magma. San Manuel
AZ
0.05
22083
2.15313
10441
Arsenic
Copper
Acid clan: biowdown
Magma. San Maruel
AZ
004
22003
1.7225
10441
Arsenic
Elemental Pt^ospnonis
Fumace scrubber biowdown
Unknown
Unknown
0543
175C0
19 5298a
8429
Arsenic
Elemental Pfcospncus
Furnace scru&Cer biowdown
Unkncwn
Unk-own
0.15
175CO
5.* 1875
8429
Arsenic
Elemental Prospnoms
Furnace scrubber blowdown
Unkncwn
Unknown
o:i9
175C0
2.-1234
8423
Arsenic
Elemental Phospnonjs
Fumace scrubber Wowdowr
Unknown
Unknown
005
17500
1 70625
8425
A'sen:c
Elemental Prospnonjs
Fumace scrubber biowdown
Unknown
Unknown
0.C5
17500
1.7:625
8429
Arsenx
Elemental Prospnoojs
Fumace scrubtmr blowdown
Unkncwn
Unkrown
0 05'25
17500
0 04256
8429
Apnl 30. 1998

-------
K-9
Arsenic

Ra'e Earns Process wastewater
Unknown
Un. ard Fe**rx:o umbium Procss wastewater
Unknown
Unkrown
0.0S
4375
0/.2656
25*/
Arsenic

"ortaium, ^oiurro um, ard Fe"oco umbiun Process wastewater
Unknown
Unkrown
0 05
4375
C 42656
25*7
A'seric

Tantaii.rr. CoiuTb um. ard Fcoco umbium Process wastewater
Unknown
Unkrown
0.05
4375
: 42656
25*7
Arsenic

'anta'ur-. Column um ard f?voco'u"nbium Process wastewater
Unknown
Unkrown
O.OS
43/5
:.2656
25"7
Arsenic

Tantaiur. Coiurro u"\ ard re"'>'.o u.mbium Process wastewater
Unknown
Unkrown
0 05
4375
C.<2556
25-7
Arsenic

""sntaiur. Coiurrb um. ard Hcoco-umbium Process wastewater
Unknown
Unkrown
0 05
4375
C 42656
25* 7
Arsenic

f-.ntaiur-. Column um. ard Terrocoiumbium Process wastewater
AMAX. East it. LOUIS
11
0.05
4375
0-2656
25-7
Arsenic

Tantalum. Colurro um. ard Fe"(X-o:umbium Process wastewater
Unnamed P'a~t
Unkrown
0.027
43/5
0 2J03iurr and Ttanium D oxioe Leach i q^id & sponge wash water
Unnamed P a"l
Unkrown
0 003
4000
0 0234
2241
Arsenic

Ttaniurr. and Ttanmr- 0 o*i_e leaon I q^id 4 soo~go wash water
Unknown
Unkrown
0.002
4000
0.0156
2341
Arsenic

T tanujrr and Titanium D oxice Scrac mi ling scrubber water
Unknown
Unkrown
0.02
42
0.OO'63
240
Arsenic

7,tanium and T taniuiT D owce Scrao mi ling scrubber water
Unknown
Unkrown
0.0*25
42
000*02
"AZ
3arum
50
Cooper Acid piant biowdown
cei
C8I
10.9
22083
'69 38' 25
10441
3aru*r>

Cosoer Acid p-ant biowdown
CBI
CBI
9.6
22083
412.4
10441
Ear um

Copper Acid plant biowdown
Cytrus, Clay Pool
AZ
5
22083
2153*25
10441
Earun

Cooper Acid p-ant Wowdowr
Magma San Manuel
AZ
5
22083
2153*25
10441
Barum

Cooper Acid p ant wowdow-
Magna. San Manuel
AZ
5
22083
215 3t 25
10441
Barum

Cooper Actd piant biowdown
CBI
CBI
08
22083
34 45
10441
Barum

Copper Acid piant biowdown
Magma San Manuel
AZ
0.4
22083
17 225
t04-i1
Bar urn

Copper Ac 17
Earum

""antaJum. Coiurrbium, and Ferrocolumb un Process wastewater
IJ-known
Unknown
05
4375
4 26563
2517
Earum

Tantalum. Coiurrbium. and Forrocotunb:um Process wastewater
Unknown
Unknown
05
4375
4 26563
2517
Barum

Tantalum. Cci'irrbium. and Ferrocoturrbium Process wastewater
Unknown
Unknown
05
4175
4 26563
2517
3arum

Tantaium. Coiurrbium. and Ferrrjcofumbium Process wastewater
AMAX. East St. LO--IS
L
OS
4375
4 26563
2517
Barum

Tantalum. Cciurrbiun. and Ferrocoiumbium Process wastewater
2inc Corp o< Ar"nca, Monaca
PA
OS
42/5
4 26563
2517
Barum

Tantalum. Cclurrbiun. and Ferrocolurrbium Process wastewater
Urknown
Unknown
0218
4375
1 85981
2517
3arum

Tantalum. Cci'jrrbium. and Ferrocdurrbium Process wastewater
Unknown
Unknown
0.083
4375
0 70809
?S17
Earun

Tantalum, Cciurrbiun, and Ferrocolumbium rocess wastewater
Urknown
Unknown
0.066
4375
0.47775
2517
Garum

Tentaium, Cciumbium. and Ferrocolurrbium Process wastewater
Urknown
Unknown
0.05
437S
0 42656
2517
Earum

Tanta'urr. Cciumbtum. and Ferrocdurr.bium Process wastewater
Urknown
Unknown
005
4375
0 42656
2517
Earun

Tantalum, CoKimbtum, and Ferroco^umb-um Process wastewater
Urknown
Unknown
0.05
4375
0 42656
2517
Sarun

Tantalum. Columbtum, and Ferrocrtumbum Process wastewater
Ur known
Unknown
O.OS
4375
0.42656
2517
Bar um

Tantalum, CoJjmWum, and Ferrocoljmb'um Process wastewater
Unknown
Unknown
0 05
4375
0.42556
2517
Barum

Tantalum, CoJumbiurn. and Ferrocoiumbtum Process wastewater
Unknown
Unknown
O.OS
4373
0 42656
2517
Barum

Tantalum. Columtxum, and Ferrocolurrbium Process wastewater
Unk-own
Unknown
0.206
4375
o.:si *9
2517
erjrtli jrr
22
Cocper Ac d plant biowdcwn
Cvpros, C ay Poo-
AZ
05
220B3
21.53125
10441
3erytftjrr

Copper Ac d plant blowdcwn
Kenneoott. Bingnam Canyon
UT
0.005
22083
0 2*531
10441
3erylh jm

Elemental P^iosphoojs Furnace scrubcer b'owdown
Unknown
Unknown
0.025
17500
0.353*3
8429
Beryllijm

Elemental Piosphonjs Fumace scnjbcer b owdown
Unknown
U"known
0.011
17500
0.37=33
6429
3eryllum

Elemental Piosphorus Fumace scr^bser b owdown
Unknown
Unknown
0.CO5
17500
0 17C63
8429
Beryilum

Elemental Phosphorus Fumace scrubcer b'owdown
Unknown
Unknown
Q.COS
7500
0.17C63
6429
lerylti'jm

Elemental Phosphorus Fumace scr-boer b owdown
Unkrown
U"known
0 0C2S
t 7500
0.:8=31
8429
Beryllium

Elemental Pnosphorus Furnace scr-bcer biowdown
Unknown
Unknown
00C25
*7500
0.:8531
6429
Beryllium

Rare Earns Process wastewater
Unkrown
Unknown
005
 17
0:1i3S
365
Beryllium

Pars Eart-s Process wastewater
Unkr.own
Unknown
0 05
117
3.01138
365
Beryllium

Pare Eart-s Process wastewater
Unkrow^
Unknown
0 05
' 17
2 01138
385
Beryllium

Rare Earns Process wastewater
Unknown
Unknown
0 05
*17
101138
385
3erylli'jm

F.ar9 Earfs Process wastewater
Zinc Corp erf America. Monaca
PA
005
117
2.01138
385
Beryllium

Rare Eartrs P'ocess wastewater
Unknown
Unknown
0.025
117
2.00569
385
soryiiium

Se enrjm Plait orocess wastewaters
Unknown
Unknown
2.025
550
?02681
331
Beryllium

Se enrjm Plan process wastewaters
Un
-------
K-10
BcVun

Tantau'n. Co'tjmbium. and Ferrocolumo
i'jr P'ocess wastewate'
Unnncwn
U-known
C.005
4375
0.:4266
2517
Be-/d Fe'rocolumc
im Process wastewate'
IJnKn-wn
Unknown
o:-os
4375
0.:426c
2517
CdUn^ium
48
Copper
Acid plant bowdown
CBI
CBI
24.5
22083
*055 03125
104-11
Cadmium

Copper
Acid plant b owdown
CBI
CBI
19 3
22083
856.94375
10441
Cadmium

Cooper
Acid p'ant o owdown
Magma. 3an Maruet
AZ
6
22083
258 375
10441
Cadmium

Cooper
Aci2 plant bowdown
Magma, San Maruai
A2
4 5
22C83
193.78*25
1 0441
Cadrr:uTi

Copper
A.i j plant bowejown
Magma. San Maruel
M
2 24
22083
96*6
0441
CaorMjm

Cocper
Acid plant b owcown
CBI
cei
1 49
22083
64 1631.1
'0441
Cacrr. u*n

Copoer
Acic plan: b owdown
C8I
C3I
1.46
22083
62 87125
' 0441
Cacr. u*n

Cocper
A-r: plan: b'owcown
Kennecot4. Bmgham Canyon
UT
1.24
22083
53.39/5
* 044 1
Cidr* urn

Copper
Aoc plant o'owcown
K-iner.ot*. B n^ham Canyon
UT
1 03
22083
46 5075
'0441
Cadmium

Cocpr
Acic ptant biowcown
Magma, San f/aruet
AZ
0.52
22083
22.3925
 0441
Cadmium

Cooper
Acre plant b'owcown
Cyprus. Ciay Pool
M
0.5
22083
21.53125
0441
Cadmium

Copper
Aac plant b;owjown
CBI
CBI
0 31
22083
13 3^938
1C441
Cartrnum

Copper
Ac;d plant bowcown
Magma. San Manuel
A2
0 23
22083
9 W438
10441
CaOrrium

Copper
Ace plant b'Owcown
CBI
CBI
0 15
22083
6 89
10441
Cadmium

Copper
Ac;r. plant t> ow-own
Magma. San Manuet
AZ
0 05
22083
2.153-3
10441
Cadmuti

E omental Phosphorus
Fjrnace scrubber blowdow
Unkntwn
Unknown
2 07
'7500
70 =3375
8429
CdJf-ium

F enental Phosphorus
Fjmace scrubber biowdown
Unknown
Unknown
' 42
'7500
48.4575
8429
Cadmium

E enentai hcsphorus
F.jmace scrubber blowdow-
Unknown
U"known
0.3
7500
10 2375
8429
Cadmium

E enentai Phospnorus
Fjrnace scrubber biowdown
Unknown
Unknown
00194
"7500
0.56203
8429
Cadmium

E erv*n?al "hnsphorus
Furnace scrubber biowdown
Unknown
Unknown
0 01
 7500
0 34125
64?9
Cadmium

E erwital rhcspoon.s
Furnace scrubber biowdown
Unknown
Unknown
0 01
* 75C0
0.34125
8429
CrdfT!iU"Tl

E enental Phosphorus
Fjmace scrubber Wowdown
U'nkncwn
Unknown
C005
175CO
0.17063
8429
Cadmium

Rare Earhs
Process wastewater
Unknown
U"known
35.4
* 17
8 0535
385
Cadmium

Rare Earns
Process wastewater
Unkncwn
U'known
15
11 7
3 64
385
Cadmium

Rare Earf^s
Process wastewater
Unnaned Plant
Unknown
"1 1
117
2.52525
385
Cadmium

Rare Ea"hs
Process wastewater
Unkncwn
Unknown-
2 70
117
0.53245
385
Cadmium

Solon un
Piani process wastewaters
Unnar-ed Plant
Unknown
0 52
550
0 5577
631
Cadmium

Selen um
Plant process wasiewaters
Unkncwn
Unknown
05
550
0 53C25
631
Cadmium

Tarraum. Cdunbium. ard Fe'rocoiu.mbium Process wastewater
Unknown
Urknown
023
4375
1.362-9
2S17
Cadmium

Tan'a-um, Coiunbium, and Fe'rocoiumticm Prccess wastewater
Unknown
Urknown
:.196
4375
1.583-J
2517
Cadmium

labium, Coiunbium, and Ferrocoiu.mbium Process wastewater
Unnarred P a~t
Urknown
o ia
4375
1.53563
2517
Cadmium

Tanta um. Coluribium. and Fe'rocoiumbmm Process wastewater
AM.J<. East St. Louis
IL
007
4375
0 5971?
2517
Cadmium

Tantaium, Coiunbium. and Fe-rocolumbmm Process wastewater
Unknown
Urknown
0.05
4375
0.42656
2517
Cadmium

Tan*aum, Coiuribium. and Fe'rocoiumpium Process wastewater
Unknown
Unknown
0.05
4375
0 *2656
2517
Cadmium

Tanta'um. Coiunbium, and Fe'rocoiumbwm Process wastewater
Unknown
Unkoown
0 05
4375
0 42656
2517
Cadmium

Tan*a'um. Coiunbium. and Fe*rocoiumbmm Process wastewater
Unknown
Unknown
0.05
4375
0 42656
2517
Cadmium

Tantalum, Coiunbium, ard Fa'rocolu-nbium Process wastewater
Unknown
Unknot
0.05
4375
0 42656
2517
Cadmium

Tan*a'um, Coiumbium. aid Fe'roco.umbum Process wastewater
Zirc Con ot America, Monaca
PA
0.05
4375
0 42656
2517
Cadmium

Tan-a'um, Coiunbium. a-d Fe'rocoiumbtum Process wastewater
Unknown
Unknown
0 0499
4375
0 42571
2517
Cadmium

Tantalum. Coiunbium. a"d Ferrocoumbi
um Procass wastewater
Unknown
Unk.no'#n
0.0432
4375
0 36855
2517
Cadmium

Titanum and Titan un 0 onde
Leach i quid & sporge wasn water
Unknown
Unknown
0.025
40:0
0*95
2341
Cadmium

Ttan:un and Titari'un D oxide
Leach i quic & spo-ge wasn water
Unknown
Unknown
0 023
4000
0 1794
2341
Cadmium

Ttanium anc Titan'un 0 oade
Leach i quia & spo^go wash water
Unknown
Unknown
0.018
4000
0 1404
2341
Cadmium

T taniun and Titanium 0 onde
L^ach i quia & spo~ge was.i water
Unknown
Unknown
0 007
4 QOQ
0 0546
2341
Cadmium

T taniun anc Titaniun O.oade
Leach i quid & sponge wash water
Unknown
Unknown
0.005
4000
0.039
2341
Cadmium

Ttaniun ano Titaniun DowCe
Leach i quio & sponge wasn water
Unknown
Unknown
0.003
4000
0 0214
2341
Cadmium

Ttaniun anc Titaniun Oioxice
Scrac ni!l ng scnjbber water
Unknown
Unknown
0.03
42
0.00244
34C
Cadmium

r taniun anc Titaniun D'owce
Scrap ni!i ng scnjbber water
Unknown
Unknown
0.02S
42
0.00203
340
Chromium
47
Copper
Acid plant biowdowh
Cyprus, Ciay Pool
AZ
5
22083
215 1125
10441
Chromium

Copper
Ac<) plant Wowdown
Kennecott Bingham Canyon
UT
0254
22003
10 93788
10441
Chromium

Copcer
Acid plant biowdown
Magna San Manuel
AZ
0.25
22093
1C. 76563
t0441
Chromium

Copper
Acki plant wowdown
Kennecctt. Bingham Canyon
UT
0.241
22083
10 37806
10441
Chromium

Copper
Ackt p'ant biowdown
Magma. San Manuel
AZ
0."71
22083
7 36369
10441
Chromium

Copper
Acid p'ant biowdown
Magna San Manuel
AZ
0.1
22083
4.30625
10441
C'iromium

Copper
AckJ pant biowdown
CBI -
CBI
0 029
22063
1 24881
10441
Chromium

Copper
Acid p ant biowdown
Magna. San Manuel
AZ
0.029
22083
1.24881
10441
Chromium

Coppor
Acid p-ant blcwdown
C5l
CBI
0.024
22083
1 0335
10441
Chromium

Copper
Acid p-ant blcwdown
CBI
C8I
0 008
22083
0 3445
10441
Chromium

Copper
Acid plant ttcwdowr.
Magrra. San Manuel
AZ
0 005
22083
021531
10441
Chromium

Copper
Acid plant blcwdown
Magma. San Manuel
AZ
0.005
22083
0.21531
10441
Chromium

Copper
Acid plant blcwdown
CBI
CBI
0 005
22083
0.21531
10441
Chromium

Copper
Acid plant Slowdown
CBI
CBI
0.0C5
22083
0 21S31
10441
Chromium

Cooper
Acid plant slowdown
CBI
CBI
0 003
22083
0/2919
10441
Chromium

Elemental Phosphorus
Furnace scrubber biowdown
Unknown
Unknown
09
17500
307*25
8429
C"ironium

Elemental Phosphorus
Furnace scrubber biowdown
U"known
Unknown
0 841
17500
28.69913
8423
Chromium

Elemental Phosphorus
Furnace scrubber biowdown
Unknown
Unkrown
0.5
17500
17.0625
8429
Ciromiu.m

Elemental Phosohorua
Furnace scrubber biowdown
Unknown
Unknown
0.22
17500
7 5075
8429
Cnrumtum

Elemental Phosphorus
Furnace scrubber biowdown
Unknown
Unun\ ana Ferrocoiumbiun Process wastewater
Unkrown
Unknown
0.05
4375
0.42656
2517
Chronvum

Tantalum. Coi-mbiirr, and Ferrocolurrbiun Process wastewater
Unknown
Unkncwn
0 05
4375
0.42656
2517
Chromium

Tantalum, CoUmbiurr, ana Ferroco(umbiun Process wastewater
Unkrown
Unkncwn
0.05
4375
0 42656
2517
Chromium

Tantalum. Coumoum. and FerrocoiumDtun Process wastewater
Unknown
Unknown
005
4375
0.42656
2517
Chromium

Tantatm, Cofejmbum. and Femocotumbum Process wastewater
Unknown
Unknown
0 05
4375
0.42556
2517
Cromiun

Tantalum, Coiumbium. and Fernocoiumbium Process wastewater
Unknown
Unknown
0.C39
4375
0 31272
2517
Chromium

Tantalum, Coiumttum. and FerrocoLmbium Process wastewater
Unknown
Unknown 
003
4375
025594
2517
April 30, 1998

-------
K-11
Ch'onium

TitarvuTi and Titanium Oiorde -each icu;d S sponge wash water
Unnamed Ptfln:
Unknown
0.012
4 zo:
0.C936
Ch-omum

Tit.miu-n and titanrum Dioxde teach icu d i spenge wash water
Unhrown
Unknown
0.005
4C-0C
0 039
Cn-ornum

Titan u-n and Titanium Dioicde Leach cu d & sponge wasn wator
Un.named Plant
Unknown
0.001
4:oc
o.:o78-
Ch'ormjm

Titan'um and Titanium Diorde Leach icu d & spcnce wash water
Unnamed Plan:
Unknown
0.001
4C02
o.:c78
Ch'omisjm

Titanium and Titanium Dioxde Scrap milling scrubber water
Unknown
Unknown
0 027
42
0 00219
O'-onrjm

Titan um and Titanium Dioxde Scrap milling scrubber water
AMAX East St Lo-_is
>L
0.025
42
0 0C2:3
Lead
43
Ccpce' Acid slant biowoown
Kenrecon. Birgram Canyon
'JT
6.74
22:83
230 24-25
Leac

Copce' Acid clan' btowdown
Kenrecott. Birgham Canyon
UT
6.47
22:83
278 G14-8
Lcac

Cooce' Acid clan'biowdown
Magma. San Manuel
AZ
5.71
22083
245 83638
Lear:

Coc:e- Acid slant biowdcwn
Manma. San Mani.el
A2
38
22083
163.5375
leac

Cuecer Acid clam blowcown
Macma. San Manuel
AZ
3.73
22083
60 62313
Leaa

Coccer AcuJ ciarv biowdown
CBl
CBl
2 89
22083
'24.45053
Leac

Cooce' Acid clan: Slowdown
C8l
C8I
2 S5
22083
'09.9:938
L03C

Cocce' Acid clan' Slowdown
Cypr_s C ay Pool
AZ
25
22083
07 65625
Leas

Copce' Acid dan; slowdown
Magma. San Manuel
AZ
25
22083
07 65625
L*ac

Cocce' Acid cian: slowdown
CBl
CBl
2 49
22C83
107 22563
Leac

Copce' Acd clan: oiowdown
CBl
CBl
1.74
22:83
74 92875
Lead

Copce' Aad clan: biowdown
CBl
CBl
0.896
22:83
38 554
Lead

Copce' Aad cian: slowdown
Magma. San Manuel
A 7.
0 25
22:83
10 755c3
Lead

Copce' Acsd dan; biowdown
Maama. San Manuel
AZ
02
22C83
3 6125
Lead

Copce' Add clan: biowdown
CBl
CBl
0.042
22:83
 8C853
Lead

E e-ncntai Phospfon^s Furrace scnjbser b owcown
Unknown
Unknown
0.42
17=00
 4.2325
Lea J

E e-nental Phospfon-s Fumaco scrubcer b owcown
Unnr-own
Unknown
0 42
17=03
 4.^325
Lead

E emental Phosp^or-s Furnace scrubcer b'OwCOwn
Unknown
Unknown
0 357
17500
12 18263
Lead

E ementai Phosprors Furrace scrtbce' b'owdown
Unnnowr
Unknown
0217
17500
7 40513
Leac

E'ementaJ Phosphors Furrace scrubee' biowdown
Unknown
Unkncwn
0 125
17*0:
4 26563
Lead

Eiemental Phosp^o^s Furnace scrubSe* blowcown
Unknown
Unknown
0.11
1750C
3 75375
1 ad

Rare Earths P'ocess wastewater
UnKnow**
Jnkncwn
2.5
117
0 56875
Leao

Rare Earths Process wastewater
Unnamed Plant
Unkncwn
2 36
117
: f..V,9
Lead

Rare Eaihs Process wastewater
Untnown
Unknown
1.99
117
0.45273
Lead

Rate Eaihs Process wastewate'
Unknown
Unknown
1
117
0.2275
Lead

Selenium P ant orocess wastewaters
AMAX. East St Lous
IL
1
550
1.0725
Lead

Selenium P a.it process wastewaters
Unknown
Unknown
0.623
55C
0.67353
Leac

Tantaium. Co'u-nbium. and Ferrocoiumbum P'ocess wastewater
Ln
-------
K-12
Me'cury

Tiiarium and Tran^m Dox>de
Sc ap miih-g scrubber water
Unknown
Unknown
O.OOOI
42
0 00001
340
Nickel
21
Cooper
Ac d pianr biowdown
Cyprus. Clay Pool
AZ
5
22083
2153125
0441
Nickel

Copper
Ac d plant biowdown
KenecotT, 8rgnam Canyon
UT
0466
22383
20 067U
*0441
Nickel

Cooper
Acd plani blowdcwn
Magma San Man..el
AZ
C-.C2
22383
086125
<0441
Nickel

Elemental Phosphorus
Furnace scjbber biowdown
Unknown
Unnnown
C 25
17500
8 531?5
3429
Nickel

Elemental Phosphorus
Funace sc-jbber biowdown
Unknown
Unknown
0 155
17500
5 63063
8429
Nickel

E.emofiiai Prospnorus
Fu-nace scubber biowdown
Unknown
Unnn'a; PhoSPhOrtJS
Funace scjbber biowdown
Unknown
Unknown
0.35
17500
1 7362S
8429
Nicko

!em9r.'a Phosphorus
Fu-nace scjbber biowdown
Unknown
Unknown
o.:3
17500
1.02375
8429
Nicke-

Eiementa Phosphorus
Fu-nace scjbber biowdown
Unknown
Unknown
0015
17500
051-38
8*29
Nicke

Rarp Earths
Process wastewater
Unknown
Lr.xrown
05
117
0 '1375
385
Ni;ko

Ra"? Eanhs
Process wastewater
Unknown
Lncss wastewater
Unknown
Lnxrown
0.C5
550
0 05363
63-
Nickel

Tantalum Cofumoum. one Ferrccoijrrbu'n Process wastewater
Unknown
Unknown
o.:s
4375
0.42656
2517
Nickel

Ta-i'ak.m C-oU.m-i jm. ano Ferrocoljrrbiun Process wastewater
Unknown
L'n
-------
K-13
Silver

Rare Ear'hs
P'ocess wastewater
Unknown
Unknown
0.5
117
0.11375
335
Silver

Seien um
P am process .wastewaters
Unkr.own
Unkncwn
05
550
0 53625
631
Silver

Seien u'n
P ant process wastewaters
Zinc Ccrp o' Amehca. Monaca
*A
05
55C
0 53625
631
Silver

Sclor. un
Pant process wastewaters
AM AX East St Louis
IL
0.07
550
0 07508
631
Si;ver

Taniaum, Coumpium
and Ferrocclumbiurr Process wastewater
Unk-own
Unknown
0 05
4375
0 42656
2517
Silver

Tantaum. Co unoium. and Ferrocciumbium P'ocess wastewater
Unk-own
Unkncwr
0.05
4375
0 42656
2517
Silver

Tama um. Co umbujm. and Ferrocctumbiurr P-ocess wastewater
Unk-own
Unknown
C.05
4375
0 42656
251/
Silver

Tantaun, Coumbwm.
and Fefrocoiumourr P-ocess wastewater
Unk-own
Jnknown
C.C-5
4375
0.42656
2517
S.iver

Tama u'n. Co umbium
and Ferrocclumbiurr P-ocess wastewater
Unk-own
Unknown
: 05
4375
0 42656
2517
Silver

TantauTi. Co umbium
and Ferrocclumbiurr P*ocess wastewater
Unk.-own
Unknown
0.C5
43/5
0 42656
251 7
Silver

Tama u'n, Co-umbwm
and Ferroc:Lmtun- P-ocess wastewater
Urk.iown
Unknown
: cs
4375
0 42656
2517
Silver

T*nra ijT,. Cc unburn.
and Fcrrocciim&ur- p-ocoss wastewater
Urkiown
LnknoMffi
0 038
375
0 32419
2517
Silver

Tama u-n. Cc uT'&i-jm
and Ferroccu.mbiur- P-ocess wastewater
Urknown
Unknown
0 025
4375
0.21328
251 /
S.iver

Tama u'n, Coumosjm
and Ferroc:Lmoi7
S< ver

TartaiuTi. Co.umbu.m,
and FerroccLmpiu^ P-ocess wastewater
Urkiown
Unknown
0 GC9
4375
0.07678
2517
& ver

Tartalum, ColumbiLm.
and F?froc::i..rnbiun P-ocess wastewater
Urkiown
Unknown
0 0C5
4375
0.042S6
2517
& ver

Tartaiu.-n. Coiumcii_m.
and FerroccLmbiun P-ocess wastewater
Ur known
Unknown
o 0:5
437S
0 042=6
2517
3i ver

Tantalum. ColumtiLm.
and FerroccLmbiuri P-occss wastewater
Ur.kiown
Unknown
0.0015
4375
0.:*28
2517
Thaliun
22
Ccpce*
Acid nian* biowdown
Cyprus. Cay Pool
AZ
25
22083
"076.5625
10^41
Tha lium

Ccpce'
Acid o^ant biowdown
Kt#n-"ecott. 0i-gnam Canyon
UT
0 25
22083
10 75553
10441
TV-a lium

Ccpce*
Acid plant biowdown
Magma, San Manuel
AZ
0.25
22083
10.75553
10441
r?a iiun

E omental Pnospro"Js
Fur-ace scr.boe- b'owdown
Unknown
Unknown
1 25
17500
42 6=625
&420
Thallium

C emental Phosp-o-js
Fur-ac scrboe' bowoown
Unknown
Unknown
0.455
17500
15 57638
3429
1>aliun

E emental Phosp-o-us
Fur-ace scr-bbe* biowaown
Unknown
Unknown
0455
17500
1552638
8429
Tha hum

E emental Phosp-oiis
Fur-ace scr.bbe' b;owdown
Unknown
Unknown
C.25
17500
8S3*.?5
8429
"H-alu"!

Fvempnrai Phosp-o*us
Fur-ace scr.&oer b owaown
Unk-own
Unknown
025
17500
8 53125
8429
~ha I un

Elemental Phosp-'ons
Fur-ace scr^bcer b owcown
Unk-own
Unknown
0.014
17500
047775
8429
"Va I u-n

Rare Earths
P-occss wastewater
Unk-own
'Jnkncwn
25
117
0 55875
385
Taium

Rare Earths
P-ocess wastewater
Unk-own
Unknown
25
r 7
0 5S8/5
385
7>aiu"-i

Rare Earths
P-ocess wastewater
Unk-own
Unknown
25
117
0 S6875
385
Tha i u-n

Rare Earths
P-ocess wastewater
Unknown
Unknown
2 5
1' 7
0 558V5
085
Tha.i u.m

Rare Earths
P-ocess wastewater
Zinc Ccrp of Ameiea. Monaca
PA
2 5
117
0 5=875
o85
r-aii-um

Rare Earths
P ocess wastewater
Unknown
Unknown
0.55
1" 7
0 12513
385
T"-aii u-n

Selenium
Plait process wastewaters
Unknown
Unknown
0 55
550
0 58988
631
"">iah u-n

Selenium
Plait process wastewaters
Unknown
Unknown
0.25
550
0 26813
631
Tna um

Selenium
Plait process wastewaters
Unkrown
Unknown
0.25
550
0 26813
631
Tnai u.ti

Tantalum. Cofumoijm.
and Ferrocclimbiur* P'ocess wastewater
Unknown
Unknown
025
4375
2.13281
2517
Thai um

Tantalum. Coiumoum.
and FerrocciLmDiur' P-ocess wastewater
Unkrown
Unknown
0 25
4375
213281
2517
"*an un

Tantalum Cotumcum.
and Ferroccii.mbiurt" P'ocess wastewater
Unkrown
Unknown
0.2S
4375
2 13281
2517
"""nan um

Tantalum, Columcium, and Ferrocoiumoiurr P'orwss wastewater
Unkrown
Unknown
0.25
4375
2.13281
251/
Vanadium
2"
Copper
Aad clan; b owdown
Cypr.s. Clay Pcol
AZ
5
22C83
215 3125
10441
Vanacfum

C-.pper
Aad clan? b'owdown
Kennecott. Singnam Canyon
ur
0.05
22083
2.15313
10444
Vanadum

Elemental P^spnous
Furra.-e sc/Lbter bl owcown
Unkrown
Unknown
0.794
17500
27.09525
8429
Vanadium

Elemental Ptiosprcus
Furrace scrLbter Wowcown
Unkrown
Unknown
0.6
17500
20 475
3429
Vanadiun

Elemental Ptiosp-ous
Furrace scaDter wowcown
Unkrown
Unknown
0.58
17500
1? 79?5
3429
Vanad;un

Elemental Pfiosp-ous
Furrace scrubber blowcown
Unkrown
Unknown
0.05
17500
l 70625
3429
Vanadun

Elemental Pt^osp-o-us
Furrace scn_bter blowsown
Unknown
Unknown
0.05
1 .'500
1 70625
3429
Vanadum

Elemental Pfiosp-cus
Furrace scn.bCer biowdown
Unkrown
Unknown
0 0*5
17500
0.51188
3429
Varad u'n

Elemental Phosp-o"us
Furrace scrubber Wowdowi
Unknown
Unknown
0.0*5
1700
0 51188
?4?9
vanadum

Rare Earths
P-ocess wastewater
Unkrown
Unknown
0.5
117
0.11375
335
Vanadiun

Rare Earths
P-ocess wastewater
Unknown
Unknown
0.5
117
0.11375
3d5
Vanad um

Rare Earths
Process wastewater
Unknown
Unknown
05
117
011375
335
Vanad um

Rare Earths
P'ocess wastewater
Unknown
Unknown
0.5
117
0.11375
335
Vanadiun

Rare Earths
P-ocess wastewater
Unknown
Unknown
0.5
117
0 11375
335
Vanad un

Rare Earths
P'ocess wastewater
Zinc Ccrp of Amenca. Monaca
PA
OS
117
0.11375
335
Van ad u'n

Seien rum
P:a."t process wastewaters
Un
Unknown
0.05
55C
0 05363
631
vanadum

Seien urn
Pia"t process wastewaters
Un-uiow"1
Unknown
0.05
550
0.05363
631
Var.ad-un

Soienium
piart process wastewaters
Unknown.
Unknown
005
550
0.05363
631
V?.nHd:urn

Tantalum, Columfcium. 
and Ferrocolumbiurr P'ocess wastewate'
Unknown
U-known
0.05
4375
0 42656
2517
Vanadiun

Tantalum. Columcium, and Ferrocclumbiurr P-ocess wastewater
Unknown
Unknown
005
4375
0.42656
251 7
Vcraa un

Tartalum. Coiurnptum, and Ferrocclumbiurr P'ocess wastewate'
Unknown
U-known
005
4375
0.42656
25iT
Znc
33
Ccpce'
Acid pant b owdown
CBI
CBI
467
22083
20110.1975
10441
2

Copcer
Aad plant b owdown
CBI
CBI
365
22083
'57178125
10441
Znc

Ccpcer
Aad plant b-owdown
Cyprus. Clay Pool
AZ
115
22083
4952-375
<0441
Zn:

Ccpcor
Add p^ant b owdown
Magma. San Manuel
AZ
22 25
22083
958.14063
10441
7 nr.

Ccpcer
Aad plant b owdown
CBI
CBI
7 47
22083
321 57588
10441
Znc

Ccpce'
Add plant b'owdown
Kennocott. Bingham Canyon
UT
7 14
22083
30746525
1P441
Znc

Ccpcer
Add plant biowdown
Magma. San Marue*
AZ
7 08
22083
304 8325
10441
Znc

Ccpcer
Acid plant biowdown
CBI
CBI
663
22083
205 =0433
10441
Znc

Ccpcer
Aad plant b&waown
CBI
CBI
623
22083
263.27938
10441
Znc

Ccpcer
Acid plant biowcown
CBJ
CBI
3 16
22083
36 0775
10441
7 nc

E omenta) Phosphorus
Furnace scrubber wowdown
Un
-------
K-14
Znc
Tan'a'um. Coiunbium. and Fo"ocoiuntoiu Process wastewater
Unknown
Un/mg)
5.	(kg) = Ciueyy g (ng-1) * 20 lT
-------
DATA SUMMARIES FOR HIGH-RISK
MINERAL PROCESSING FACILITIES	APPENDIX L
The following appendix summarizes EPA's efforts to gather data to support site-specific (or
facility-specific) assessment of health and environmental risks associated with the management of high-risk
recycled waste streams. These waste streams were identified in Section 4.2.
April 30, 1998

-------
L.l Facility 1 (Beryllium Production)
L.l.l Facility Background
Facility 1 is located in Millard County, 1 mile west of Highway 6, and 10 miles northeast of Delta,
Utah.1 The site's location is 39.417219 degrees latitude and -112.472777 degrees longitude." The mill
extracts bery llium from low-grade bertrandite ore (mined about 55 miles to the west) and from high-grade
beryl ore imported from foreign sources.1 Bertrandite is a hydrous beryllium silicate, Be4Si207(0H),. The
extraction processes for each ore tire slightly different.1" The concentrate from the mill is packed in drums
and shipped to the company's facility in Ohio.1
The open-pit commenced in 1968 and the milling facility began operating in September, 1969.
Between the years of 1978 and 1981, additional facilities were constructed on the site. This was done to
accommodate the extraction and recovery of beryllium values from imported beryl ore, increase capacity of
the bertrandite plant by 25 percent, and recover the uranium values associated with the bertrandite ore as a
salable uranium by-product. The life of the ore reserve, as of 1990, was said to be 50 years (at the existing
ore production rate); consequently, this was estimated to be the life span as the tailings pond used to
manage wastes for the facility used to manage wastes from the facility (discussed below).'"
L.l.2 Wastes
The mill processes result in the following waste streams for which we currently have data '"
	Tailings;
	Treated sanitary wastewater;
	Solid wastes; and
Treated water from the oil water-separator of an underground storage tank
remediation system.
Both beryllium extraction processes produce leached or spent solids, which are separated from the
beryllium sulfate leach liquor using thickeners and washing by countercurrent decantation (CCD) before
discarding the solids to the tailings pond."1 Solid waste includes inert materials such as packaging, pallets,
process sludges, ore samples, and other beryllium-contaminated items."' The average tailings slurry
discharge rate ranges from 800 to 920 gallons per minute. In 1989, the total annual discharge of tailings
slurry was 258.6 million gallons.'"
The tailings slurry contain about 9 to 10 percent solids by weight and consists mainly of fine sand,
silt, and clay. Tailings deposition is controlled mainly by the grain size and distance from the discharge
point. The waste solutions are generally acidic with apH between 1.5 and 2. Filtered analyses of the
tailings solutions show high concentrations of ammonia, fluorine, sulfate, dissolved solids (TDS), and
various metals ^constituent/concentration data available). Typical samples of tailings pond water contain
more than 40,000 mg/1 dissolved solids and 29,000 mg/1 sulfate. Water forming the seepage mound
beneath the pond has a neutral pH and generally lower concentrations of dissolved constituents.'
The barren filtrate from a filtration process contains uranium values. This waste stream was
identified as the high-risk waste stream in the RIA. No composition data is available for this stream other
than the five samples used in the RIA. This waste was transferred to solar ponds for storage and
subsequent processing for uranium recovery.'" The State of Utah was contacted (November 1997) and
indicated there were 3 ponds from 1979 to 1985. The solar ponds were officially closed in 1994. At the
time, they were synthetically lined and one pond was 2 acres, while the other two ponds were 1 acre. This
April 30, 1998

-------
L-3
waste stream is now disposed in the tailings pond. No waste materials are currently recycled; all wastes are
put into the tailings pond.
L.1.3 Solid Waste Management Units (SWMUs)
As a result of the Ground Water Discharge Permit, the documents currently focus on the tailings
pond. The 220-acre tailings pond is just north of the plant and holds solid wastes and all liquid wastes
(including the'treated sanitary wastewater) from the facility.1 The treated sanitary wastewater has been
historically mixed with the tailings slurry before being discharged to the tailings pond. Solid waste has
also been disposed of by being buried in the tailings, under the 1987 permit and the renewed permit in
1994 (running to March 1999).I1V The treated water from the oil water-separator was planned to be test
mixed with the tailings slurry before being discharged under the renewed permit for a 15-day period.'
As of 1990, the waste slurry is transported to the tailings pond through a pipe and dumped in one
location for a period of time. The sand portion of the tailings slurry settles out in a mound directly under
the discharge point; the finer grained material flows with the water along the gradual south to north slope
of the settled tailings in the pond. The fine sand and silt portion of the tailings settles out on the broad
slope between the discharge points and the northern end of the tailings pond. The clay fraction is
deposited in the northern portion of the pond area. The location of the discharge point is moved around
the pond area as needed to uniformly deposit the tailings solids."1
The construction permit for the pond was issued in 19fi9. In 1986. the facility determined that
additional tailings pond storage was needed and applied for a permit to raise the dike levees. As part of the
permit, the facility made a groundwater study to better determine the subsurface hydrology, water quality,
and to monitor the rate of growth of a perched seepage mound beneath the tailings pond. Efforts since
1986 to seal the pond have only been partially successful. This resulted in the need for a groundwater
discharge permit, which was issued in 1992.
As a result of the permit requirements, the capacity of the tailings pond was to be increased by
adding a lift which was to provide 15 additional years of life (starting 1993). This was to be constructed
out of earth borrow obtained on site and was to be built in a downstream manner. The discharge rate was
to be 872 acre-feet per year. The evaporation rate from the tailings pond was to be increased by pumping
collected tailings water from the submerged low end of the tailings basin through pipes to the upper, dry
end where it was planned to be spread out on the tailings surface. This was to increase the evaporation rate
of the tailings facility to about 472 acre feet per year. The seepage rate from the tailings pond was to be
reduced by sealing the surface of the tailings solids with a 24-inch thick layer of low-permeability tailings
slimes (fine silt and clay); this was to be done by processing the tailings with cyclones to remove the sand
and then evenly discharging the slime slurry through pipes. All told, it was expected to take 5 to 6 years to
complete and reduce the seepage rate down to 250 acre-feet per year. Recovery wells were also planned to
be installed over the seepage mound. The wells were to extract approximately 250 acre-feet per year from .
the seepage mound and this water was to be disposed of in the tailings pond by evaporation. The well field
was to be designed to remove up to 541 acre-feet per year, the additional water would be disposed of by
evaporation in the tailings ponds and/or recycling it to the mill where it would replace fresh water currently
being used in the process.'
April 30, 1998

-------
L-4
L.1.4 Facility Setting
Little information is currently available on the facility setting. The population in the area is,
however, known in detail. About 987 people live within a half mile of the facility. The population within
one mile of the site is estimated to be 2,991, and 5,689 people live within three miles of the facility, based
on 1990 US Census data. Most of the population lives east of the facility and only about 20 percent of the
people live west of the facility.
The ground water geology and the hydrology at the facility is also fairly well understood. The
USGS has made a digital model and water level maps of the Sevier Desert, which includes the facility site.
In addition, more than 100 boreholes have been drilled in the area.
The available information indicates the deposits beneath the tailings pond consist of alluvial and
lacustrine material composed of interbedded sand, silt, gravel and clay, to a depth of 40 to 70 feet.' More
specifically, the soil type for the area of the tailings pond is the Yenrab-Uvada association (Soil
Conservation Service as cited in 4). These are well drained, strongly to very strongly saline, moderately to
strongly alkali sands and silt loams.'"
L.1.5 Environmental Contamination
The tailings pond or seepage mound could potentially penetrate the upper artisian aquifer in the
area. According to calculations using site-specific geohydrological data, this will not occur for at least
1,000 years. In 1992 and 1993, the facility owner sampled and analyzed wells tapping the upper artesian
aquifer near the plant to determine if contaminants from the seepage mound had entered the aquifer. The
evidence suggested the aquifer had not been contaminated. However, the water quality of the aquifer is
not consistent across the property and appears to locally contain dissolved arsenic in elevated
concentrations not unlike the condition described by the USGS for other areas of the Sevier Basin (sample
data available).'
In 1987, the northwest portion of the tailings pond had very little of the (low-permeability) tailings
solids in it and the tailings water was able to readily seep into the foundation soils. This was proposed to
be mitigated so that the seepage rate would be decreased; the State of Utah agreed that no additional
mitigative action was necessary but inposed an expanded monitoring requirement.'"
L.1.6 References
EPA Region 8 referred us to the Utah Department of Environmental Quality (IJI)HQ). The
following officials from the UDEQ assisted our efforts in gathering data for this site:
	Blake Robertson;
	Shelly Milligan, State RCRA Program; and
	Larry Mize, Ground Water Division.
April 30, 1998

-------
L-5
ENDNOTES
i.	Statement of Basis. Beryllium Mill. Author and date not given. 1993-7?.
ii.	ENV1ROFACTS (EPA database).
iii.	Ground Water Discharge Permit Application for the (Company Name) Tailings Pond. Delta, Utah.
November 15, 1990. Prepared by JBR Consultants Group for the facility owner.
iv.	Groundwater Discharge Permit. Permit No. UGW270001. State of Utah. Division of Water
Quality. Department of Environmental Quality. Date not given, but, it is 1993 or 1994.
April 30, 1998

-------
L.2 Facility 2 (Copper Processor)
L.2.1 Facility Background
Facility 2 is located in Gila County, on Highway 60 near Claypool, Arizona. The site's exact
location is 33.43981 degrees latitude and 110.87455 degrees longitude.' The facility began operations
around 1906, and currently uses a smelter and converter system, an anode furnace, and an electrolytic
refinery system in mining and processing copper ore.'"" Because the facility is not a large quantity
generator and does not generate any wastes (since all potential waste streams are supposed to be recycled)
it is not regulated under RCRA. A Preliminary Assessment was performed at the site in 1983, and it was
believed that hazardous waste may have been disposed of on site. Inclusion in the Superfund program,
however, was delayed pending further investigation. To this date, the facility is not regulated under
CERCLA, but it is currently monitored by the Arizona State Superfund program as part of Arizona's
groundwater protection strategy.
L.2.2 Wastes
The waste streams that we have data for from this facility are:
	Smelter slag;
	Converter and anode furnace slag:
	Flu dust;
	Acid plant blowdown; and
	Tankhouse slimes (from the electrolytic refinery and the copper leaching circuit).
Smelter slag is generated in the greatest quantity of all the waste streams at facility 2. This waste
is a typically gravel or cobble sized solid material, composed primarily of iron silicates, calcium oxide, and
alumina. The material also contains trace amounts of copper, lead, zinc, and other metals. The amount of
smelter slag generated is in the range of 165,000 to nearly 500,000 metric tons per year. The facility also
generates between 30,000 and 250,000 metric tons of converter and anode furnace slag. The flu dust,
recovered from converter electrostatic precipitators may contain up to 25 percent copper concentration.
Because of its value, this material is reprocessed in the flash furnace.IV
Acid plant blowdown and tankhouse.slimes are perhaps most significant because of their potential
threat to human health and the environment. Acid plant blowdown, which also contains APC dust sludge
and scrubber blowdown. is a liquid waste with a pH of approximately 2. Tankhouse slimes produced in
the electrolytic refinery are stored in 55 gallon drums before being shipped to gold and silver refineries,
and tankhouse slimes from the copper leaching circuit are stored in boxes and eventually sold as scrap
metal.'"
L.2.3 Solid Waste Management Units (SWMUs)
While information regarding the exact number and locations of SWMUs are not yet available
(we may obtain these data from the Arizona Department of Environmental Quality), it is known that the
site uses both waste piles and tanks to treat and store generated waste streams. Slag is deposited on waste
piles at the edge of a tailings pond. The basal area of the piles may range from 7 to 26 hectares, and the
height from 6 to 45 meters. Acid plant blowdown was treated in unlined surface impoundments until at
least the mid 1980's, but is now managed using heap leaching piles and a solar evaporation containment
pad.v The solid portion of the blowdown is filtered out and sent to the lined evaporation pad, and the
liquid material is piped to heap leaching piles. Tankhouse slimes, as mentioned above, are stored in 55
April 30, 1998

-------
L-7
gallon drums and roll-off boxes before being shipped to gold and silver refineries. Thus, it appears that
recycled materials are not currently managed in land units.
L.2.4 Facility Setting
Gila County is a mountainous region with rugged peaks separated by narrow, deep canyons. Much
of the area surrounding the facility is characterized by foothill terrain, with colorful rock out cropping and
desert flora. The climate tends to be cool and sub-humid at higher elevations, and warm and semi-arid in
lower areas. The two seasons in which precipitation is the most frequent are summer and winter, with
average monthly precipitation of 3.33 inches in August and 2.40 inches in December. The average annual
rainfall is about 18 inches.1'1
Currently, we do not have much detailed information regarding land use in the area, but we will
probably receive better data from AZDEQ. We do know, however, that much of the land in the area is
administered by the U.S. Forest Service. In the Globe/Miami area, which includes Claypool, it is estimated
that there are over 100 active and inactive mines. The population of the area is known in greater detail.
The closest residence is located 60 meters from the site, and about 150 people live within a half mile of the
facility.'" The population within one mile of the site is estimated to be 3,728, and 9,541 people live within
three miles of the facility, based on 1990 US Census data. Most of the population in the surrounding area
lives south and west of the facility, and only about 10 per cent of the people live east of the site.
Furthermore, there are three nearby sensitive ecological receptors; (1) Salt River, the nearest surface water
body, located about 24 km from the mine; (2) Roosevelt Lake, a resort area in the vicinity; and (3) a
National Forest (the name of which is not indicated in any documentation we gathered).1"
L.2.5 Environmental Contamination
Information on the type and extent of environmental contamination is limited, but there has never
been any observed human death or ecological damage attributed to a mineral processing waste.'"
Additionally, as of 1988, there had been no observed releases of hazardous materials to surface water,
ground water, or air.v" Although the Emergency Response Notification System (ERNS) does not track
chronic releases (e.g., leaching to groundwater), the database docs track isolated releases from the facility.
The database indicated that in 1997, there were four incidents of releases at the site: (1) air release of 800
pounds of ammonia; (2) release into the soil of 10 gallons of liquid material spilled from a box containing
F006 material; (3) release into soil of 10,000 gallons of copper sulfate; and (4) a soil release of an
unknown quantity of mercury.vl" The sources of these releases, as well as the responses to the spills are
unknown.
On a more regional scale, there is evidence of regional groundwater pollution. A large proportion
of the area in Gila County has been disturbed by open-pit mining, tailings piles, and surface
impoundments. Thus, there certainly has been significant environmental degradation, but the extent to
which facility 2 is responsible is unclear.
April 30, 1998

-------
L-8
L.2.6 References
The following officials from the Arizona Department of" Environmental Quality assisted our efforts
in gathering data for this site:
Jack Kemper, Aquifer Protection Program;
	Lowell Cartv, State Superfund Program; and
	Ed Pond, State Superfund Program.
ENDNOTES
i.	ENVIROFACTS (EPA database).
ii.	"Currently" means as of October, 1997.
iii.	Report to Congress on Special Wastes from Mineral Processing, Volume II: Methods and Analyses.
United States Environmental Protection Agency, Office of Solid Waste. July 1990.
iv.	Memorandum from Jim O'Leary, Definition of Solid Waste Task Force, summarizing the results of a
site visit to facilities 2 and 6.
v.	Preliminary Assessment. U.S. EPA Region 9. February 1983; and the Memorandum from ICF
reporting waste management information gathered during an interview with Mr. Larry LeCompte of
Facility 2.
vi.	National Prototype Copper Mining Management Plan. Central Arizona Association of Governments.
September 1983.
vii.	Reassessment of (Company Name). ICF Technology Incorporated. September, 1988.
viii.	Emergency Response Notification System (EPA database).
April 30, 1998

-------
L-9
L.3 Facility 3 (Elemental Phosphorus)
L.3.1 Facility Background
Facility 3 is located in Bannock County, on Highway 30, near Pocatello, Idaho. The site's exact
location is 42.938 degrees latitude and -112.488 degrees longitude.1 Since 1949, the facility has
continuously been producing elemental phosphorus from shale, silica, and coke by using the electric arc
furnace method. Operations at the facility include ore handling and preparation, furnace feed preparation,
furnace operation, and by-product handling. Originally, mineral processing wastes generated at the plant
were excluded from RCRA regulation by the Bevill exemption. In 1989, however, the exemption was
removed for almost all production processes. In the early 1990s, the facility submitted both Part A and B
RCRA applications. In 1987, a site investigation conducted under CERCLA indicated that groundwater
contamination existed in the northeast part of the site. As a result of this and other findings, the site was
placed on the National Priorities List in August, 1991. The CERCLA work plan called for a remedial
investigation and feasibility study, and this was conducted at the site in 1992."
L.3.2 Wastes
The waste streams that we have data for from this facility are:
	Precipitator dust slurry;
	Blowdown wastewater from the Anderson and Medusa scrubbers;
	Phosphorus-laden wastewater from furnace washdown (identified as a high-risk
waste); and
	Phosphorus-containing wastewater from surface impoundments.
These waste streams are regulated as hazardous waste, and are recycled after being processed in
treatment units. The precipitator dust slurry, generated during the process that removes particulates from
furnace off-gasses, exceeds the toxicity characteristic leaching procedure (TCLP) standard for cadmium.
The blowdown wastewater from the Medusa scrubber, which also exceeds the TCLP criterion for
cadmium, is combined with the Anderson scrubber wastewater before being diverted to the scrubber
blowdown wastewater treatment unit. The furnace washdown phosphorus-containing wastewater used to
exceed the TCLP criterion for cadmium when it was routed through the slag pit before being collected in a
sump. The facility changed its management practice by collecting the waste in a tank, and the waste no
longer contains excess cadmium. The wastewater from surface impoundments does exceed the cadmium
standard (cadmium concentration is 2.0 ing/L), and also exhibited the hazardous waste characteristic of
ignitability."
Other wastes produced on-site include waste slag and ferrophos, both of which are not recycled.
Waste slag contains various metals including arsenic, barium, cadmium, lead, and zinc. It is not regulated
as a hazardous waste, as it is exempt from RCRA due to the Bevill exclusion. The facility stores furnace
slag in stockpiles that contain between 1.5 to 21 million tons of slag. Ferrophos waste is a mixture of iron-
phosphorus compounds that contains chromium and vanadium. The material is stored on waste piles on
site.
April 30, 1998

-------
L-10
L.3.3 Solid Waste Management Units (SWMUs)
Maps indicating the exact location of the SWMUs are available. There are a total of 84 SWMUs
on site including storage piles, treatment units (tanks), and surface impoundments. Of these 84 units, the
CF.RCLA remediation investigation feasibility study identified nine units for further investigation; there
are 16 such RCRA-identified units.
The precipitator dust slurry is pumped to a 2.8 acre surface impoundment that is double lined with
polyvinyl chloride material. The pond, constructed in 1984, holds approximately 27 acre-feet of slurry
with suspended solids that are stirred in the pond and occasionally dredged to another surface
impoundment. The unit is equipped with a lcachate detection and collection system to prevent
environmental contamination."
Phosphorus-laden wastewater and, until 1981, some precipitator dust slurry used to be discharged
into an unlined surface impoundment. In 1981, a Phosphorus Recovery Process was installed near the
impoundment to recover elemental phosphorus from the pond solids. From 1981 through 1991, the facility
dredged solids from the pond and diverted them to the recovery process. During this period, wastewater
containing phosphorus continued to be discharged into the impoundment. The pond, which was
constructed in 1970 with a capacity of 70 acre-feet, was determined in 1993 to be causing groundwater
contamination. The unlined impoundment ceased operation in August, 1993 and the facility initiated a
"time-critical removal" of (he unit in October of that year. The facility removed waste water from the
pond, installed a temporary cap, and submitted monitoring progress reports to EPA on a quarterly basis.
Final closure activities identified in 1997 include placing a low permeability flexible membrane liner on
the impoundment."1
The wastewater from furnace blowdown is combined with the Medusa scrubber and Anderson
filter media wash water. The combined waste stream is sent to a scrubber blowdown wastewater treatment
tank. The treated effluent is then sent to settling ponds, and the clarified water is recycled back to the
scrubbers. The waste slag and ferrophos are extracted from process furnaces several times a day and
transported to a storage pile or crushing plant."
L.3.4 Facility Setting
The facility is located at the northern end of the Bannock Mountains at an elevation of
approximately 4,400 feet above sea level. The Portneuf River is the only perennial stream in the vicinity
of the site. Adjacent to facility 3 is another facility that has produced concentrated phosphoric acid,
ammonium phosphate, and other products from phosphate-containing ore since 1944.'v The climate of
Pocatello varies depending on the season. The mean daily maximum temperature during the summer
months is 51 degrees Fahrenheit, and the mean precipitation is 2.13 inches per month. During winter
months, the mean daily maximum temperature is 35.4 degrees Fahrenheit, and the mean precipitation is
2.95 inches per month."
The land in Pocatello is zoned primarily for residential use. The current land use is 60 percent
residential, 15 percent industrial, and 10 percent commercial. The nearest residences to the site are located
300 meters downgradient of the facility, and another residential area is located about 2.5 miles from the
facility. Three schools and one nursing home are located in these two residential areas, and the entire
Pocatello region has 28 schools and 5 nursing homes."
There are several sensitive ecological receptors located near the facility. The Portneuf River, a
major tributary of the Snake River, is approximately half a mile northeast of the facility. The river is used
April 30, 1998

-------
L-ll
for fishing, recreation, and irrigation downstream from the site.'" Additionally, there are numerous springs
adjacent to the Portneuf River channel, including Batiste Springs and a fish hatchery located 2.4 km
downstream from the facility. Batiste Spings has historically been used for drinking water by more than
1.000 employees of a nearby railroad and 30 residences in Pocatello."
L.3.5 Environmental Contamination
The greatest extent of contamination is due to leaching from the unlined surface impoundment
used for precipitator dust slurry and phosphorus-containing wastewater. The contamination, which
includes arsenic, chloride, fluoride, and sulfate, has affected on-site shallow groundwater and off-site
springs to the degree that ingesting or coming into direct contact with the groundwater may pose a health
threat." On-site soils also contain high levels of toxic constituents such as cadmium, chromium, copper,
and zinc. Finally, off-site soils located northwest of the facility contain elevated levels of fluoride, zinc
and cadmium as a result of airborne releases from plant processes, roads, storage areas, and wastewater
ponds. Direct contact with these soils may also pose a health threat.
There are also several toxic plumes that have been identified in the vicinity of the site. Three
arsenic plumes and a major nitrate plume exist in the shallow interval of the uppermost aquifer at the site.
These plumes are migrating in a northeasterly direction, which is consistent with the direction of
groundwater flow. The highest detected arsenic concentration is 0.56 mg/L, and the highest concentration
of nitrate was determined to be 23 mg/L. The source areas for this contamination is not fully determined,
but the contamination is probably related to the numerous waste ponds, the slag pit, and/or the phosphorus
recovery unit. Although there is a high degree of groundwater contamination from waste management
activities at the facility, no damages have been attributed with confidence to a mineral processing special
waste.'1 1'his may be because the residents of Pocatello rely on drinking water from a "deep aquifer"
system comprised of the Tertiary Starlight Formation, Rig Hole Basalt, and Sunbeam Formation
Additionally, gradients in the area are very flat, ranging from one to five feet per mile.
L.3.6 References
The following officials from EPA Region 10 assisted our efforts in gathering information on
facility 3:
	Bill Adams and Tracy Chellis, Region 10 Superfund Program.
ENDNOTES
i.	BNVLROFACTS (HPA database).
ii.	Facility Assessment, (Company Name), Phosphorus Chemicals Division. June 1991.
iii.	Public Notice regarding Facility 3 published on the World Wide Web; US HPA Region 10;
September, 1997.
April 30, 1998

-------
L-12
L.4 Facility 4 (Zinc Manufacturer)
L.4.1 Facility Background
Facility 4 is located in Montgomery County, on Zinc Plant Road, outside of Clarksville,
Tennessee. The site's exact location is 36.208333 latitude and -86.766667 longitude.' The facility began
operations in 1978, and as of 1995 operations consisted of producing zinc metal from concentrated ore
using an electrolytic process. Facility 4 is listed as a RCRA Small Quantity Generator, and although it is
not a Superfund site, several CERCLA studies have been conducted. A Preliminary Assessment was
conducted in November, 1983, and a subsequent inspection was performed in March, 1984. A Site
Inspection Prioritization Report, conducted in May 1995, called for further action to be taken at the site.
Additionally, the facility is subject to NPDES permits issued by the State of Tennessee and EPA.
L.4.2 Wastes
The facility generates the following five waste streams that arc regulated under the NPDES Permit
issued by EPA in 1994: (1) Electrolyte Bleed; (2) Cathode/Anode Wash; (3) Casting Contact Cooling
waste; (4) Cadmium Plant residue; and (5) Metallurgical Acid. The facility generates more than 300 tons
per day of Electrolyte Bleed, Cathode/Anode Wash, and Casting Contact Cooling waste, and more than
500 tons per day of Metallurgical Acid. 1.71 tons per day of Cadmium Plant residue is produced at the
facility." These wastes consist of metals such as cadmium, copper, lead, zinc, and arsenic.
Additional wastes include sulfuric acid generated during processing activities. The acid is
returned by pipeline to barges on a nearby river, and is eventually sold to fertilizer companies. The facility
also generates metal by-products, referred to as leachate residue. These wastes, which are generated during
the ore purification process, contain zinc, cadmium, copper, cobalt, lead, and germanium.1" Finally, the
facility generates recycle slurry. None of the above wastes are identified with high-risk waste streams for
zinc manufacturing.
L.4.3 Solid Waste Management Units (SWMUs)
The SWMUs consist of six outfalls, four surface impoundments, three waste piles, and numerous
treatment and storage tanks. A map detailing information on the exact locations of the SWMUs is
available.|V The Outfalls are used in the metals recovery and wastewater treatment process in the following
manner:
	Outfall No. 1 discharges processed water beneath the surface of the Cumberland
River. All of the five regulated waste streams are treated in a metals recovery
facility prior to discharge in Outfall No. 1. Additionally, the treated recycled
slurry is discharged via Outfall No. 1. This occurs after heavy metals have been
precipitated out of the waste, and the slurry has been neutralized;
	Oufall No. 2 is used to discharge wastewaster consisting of filter backwash water
and demineralizer regeneration water into the Cumberland River;
	Oufall No. 3 discharges stormwater, exposed to the manufacturing portion of the
plant, into a tributary of the Cumberland River;
	Oufalls No. 4 and 6 discharge stormwater onto near-by pasture land; and
April 30, 1998

-------
L-13
	Oufall No. 5 drains pasture land and product storage facilities by discharging
wastewater into an unnamed tributary of the Cumberland River."
The metal by-products are stored in four large, unfenced impoundments that are lined with clay
and synthetic material. There is no evidence, however, that high-risk wastes are stored in the
impoundments. The total surface area of the impoundments is 756,875 square feet, and the total volume is
339,740 cubic meters/ The three separate waste piles, each approximately 150 cubic feet in volume,
contain cobalt, copper, and zinc and are located near Impoundment No. 1
L.4.4 Facility Setting
The climate of Montgomery County is characterized by relatively mild winters and warm
summers, with the average annual temperature at Clarksville around 60 degrees Fahrenheit. The average
annual precipitation in the area is 48 inches, but due to a high mean lake pan evaporation rate of 37 inches
per year, the net annual rainfall is only 11 inches.
A map of Clarksville indicates that the site is surrounded by wetlands, Lake Barkley, and the
Cumberland River.1" There are also several smaller bodies of water in the area where recreational and
commercial fishing occur. There are many residential areas and schools in the vicinity of the site, with the
nearest residence being approximately 500 feet south of the plant.'" Based on 1990 US Census data,
approximately 33,000 people live within 4 miles of the facility, with over half living between three and
four miles away.
In addition to the substantial human population around the site, there are also several sensitive
ecological receptors. Approximately 229 acres of wetlands, which provide habitat to state threatened and
endangered species, are located within a four-mile radius of the site. The threatened plant species include
sweet coneflower, muskingum sedge, and the Canada lily; endangered birds in the area include the osprey,
bewick's wren, and the bachman's sparrow.'" Finally, pasture land used for com and soybean cultivation is
located northwest of the site, between wetlands.
L.4.5 Environmental Contamination
Elevated concentrations of toxic metals such as copper, lead, mercury, and zinc represent the
greatest soil contamination at the site. Sediment samples taken in 1995 from impoundment numbers 1, 2,
and 3 showed high concentrations of these metals, as did soil samples collected downgradient from the
impoundments. Sediment from impoundment number 1 contained a high concentration of arsenic, and
sediment from the nearby wetlands area contained cadmium, manganese, and mercury.'" In 1981, a sulfur
dioxide release to air was detected at a nearby school, which is now equipped with a sulfur dioxide
monitor. The 1995 Site Inspection Prioritization Report, finding that exposure to contaminated soil and
potential air contamination poses a threat to human health and the environment, recommended that further
action (under the Superfund program) be taken at the facility.
April 30,1998

-------
L-14
L.4.6 . References
The following EPA Region 4 officials assisted our efforts in gathering data for this site:
	Mike Creeson, Region 4 NPDES Program;
	Loften Carr, Region 4 Superfund Program; and
Kris Lipper, Region 4 RCRA Program.
ENDNOTES
i.	ENVIROFACTS (EPA database).
ii.	NPDES permit issued by U.S. Environmental Protection Agency; June, 1994.
iii.	Site Inspection Prioritization Report. U.S. EPA, Waste Management Division. May 1995.
iv.	JMZ Electrolytic Zinc Plant, Facility Layout; EMPE, Inc; 1993.
v.	Site Inspection Prioritization Report. U.S. EPA, Waste Management Division. May 1995.
vi.	JMZ Electrolytic Zinc Plant, Location Map; EMPE, Inc; 1993.
April 30, 1998

-------
L-15
L.5 Facility 5 (Titanium Dioxide Manufacturer)
L.5.1 Facility Background
Facility 5 is located in Chatham County, approximately 1.5 miles outside of Savannah, Georgia.
The site's exact location is 32.081 degrees latitude and -81.029 degrees longitude.' The facility purchased
the site in 1985 from a chemical manufacturing company that had operated on-site since around 1955. As
of 1993, the facility manufactured titanium dioxide pigment by the chloride and sulfate processes. The
process used was dependent on the quality of titanium ore feedstock, with the chloride process used for
high quality ore and the sulfate process applied to lower quality ore. The former owner of the site operated
a RCRA permitted facility, and the permit was transferred to the current owner in 1985. In 1991, the
current owner requested and received revocation of their hazardous waste facility permit because the only
hazardous waste management activity conducted at the site is operation of an elementary neutralization
unit. A Site Inspection under the authority of CERCLA was conducted in 1993 to determine the need for
additional investigation under the Superfund program. The facility received a NPDES permit in 1976
specifying the amounts and constituents of processed waste streams discharged into the Savannah River.
L.5.2 Wastes
The waste streams that we have data for from this facility are (1) weak and strong acid streams
generated from the sulfate process; (2) Chloride process wastes; and (3) Contact cooling water, but we do
not know the extent to which these wastes are recycled.
The chloride process, because it is used on high quality titanium ore, generates a small volume of
waste which consists primarily of iron and titanium chlorides. The sulfate process, however, generates
both weak and strong acid solutions from a process that filters precipitated titanium. Both of these acid
solutions are identified as high-risk wastes. Approximately 15 percent of the filtrate can be reprocessed,
and the remainder constitutes a strong acid waste stream containing 20 percent free sulfuric acid, 5 to 10
percent ferrous sulfate, and trace amounts of dissolved heavy metals." The weak acid, generated during the
sulfate process, contains about three percent free sulfuric acid, approximately 0.5 percent ferrous sulfate,
and smaller amounts of dissolved heavy metals. The waste stream generated from the chloride process and
the strong acid stream are diverted to the weak acid stream.
The contact cooling water contains (1) process waste water; (2) storm water, (3) sanitary waste;
and (4) leachate. The process waste water, wash water from scrubbers and filters, is neutral but contains
suspended solids such as titanium oxide. The storm water is from the manufacturing areas of the plant,
and the sanitary waste is collected from various points at the site and pumped into the contact cooling
water stream. The leachate, which flows into the waste stream, is from an area that formerly stored
copperas (an iron sulfate compound)."
L.5.3 Solid Waste Management Units
The historical waste management area at the facility covers 64 acres and consists of five unlined
surface impoundments, a settling pond, and two dredge spoils. A map of the management area indicates
that the SWMUs are bounded on the north by the Savannah River, on the west by the manufacturing plant,
and on the south and cast by marsh land."1 The weak acid waste stream used to be pumped to the settling
pond before being diverted to a neutralization plant. Similarly, the contact cooling water stream used to
flow to a plant which neutralized the material with slaked lime (Ca(OH)2) before settling in an effluent
pond. In 1988, however, the facility changed its management practices and stopped using surface
impoundments to treat and store these waste streams. Instead, the facility started using elementary
April 30, 1998

-------
L-16
neutralization systems (comprised of tanks) to treat all chloride and sulfate wastes.'" The ponds were
closed, and in 1991, the facility had its Hazardous Waste Management Permit revoked upon request. The
revocation of the permit was granted because (1) the facility discontinued the practice of storing hazardous
waste in surface impoundments; (2) the facility was not handling any waste previously excluded from
RCRA by the Bevill Amendment; and (3) the facility was not managing any historical accumulations of
wastes previously excluded by the Bevill Amendment."
L.5.4 Facility Setting
The Savannah area is located within the Atlantic Coast Physiographic Province where the climate
is characterized by a warm, moist climate. Temperatures range from an average of 51 degrees Fahrenheit
in January to 81 degrees Fahrenheit in July, and the area's net annual precipitation is 4 inches/
While the Savannah watershed is mostly forested, the area around the facility is primarily
industrial. Based on 1990 census data, there are no residential dwellings within a mile of the facility. The
nearest residential development and school is located two miles from the plant, and it is estimated that
more than 25,000 people live between two and three miles away. Over 90 percent of this population live
southwest of the plant." Although the facility is located in an area of low elevation adjacent to the
Savannah River, the nearby population is not a groundwater target because the river is not used for
drinking water. Instead, residents in the Savannah area use municipal or subdivision water systems
drawing from the principal artesian aquifer. The city of Savannah operates 21 wells, three of which are
within 4 miles of the historical waste management area.
There arc several sensitive ecological receptors in the area. There are several surrounding water
bodies, such as the Savannah, Wilmington, and Bull Rivers, that support recreational and commercial
fisheries. Additionally, several endangered and threatened species may be found in the Savannah area,
including the short-nosed sturgeon, the Atlantic green sea turtle, the brown pelican, manatee and bald
eagle. Finally, the area has been proposed as a National Estuary Program/Near Coastal Water Program
sensitive area due to its brackish water chemistry/
L.5.5 Environmental Contamination
In 1993, samples were taken from the waste management area that was closed five years earlier.
The soil and groundwater samples indicated that there is no ongoing release of hazardous materials from
the former hazardous waste management area." Analysis of surface water revealed that although samples
of runoff and sediment indicate the presence of hazardous materials from the acid streams, the
concentrations of hazardous constituents are low. Thus, it appears that there is little threat to human health
and the environment from chronic releases of hazardous materials into soil, groundwater, or surface water.
Although there does not appear to be any ongoing releases, the facility has had several isolated
hazardous waste releases in the past. In June, 1968, waste acid flowed through a break in the dike
surrounding waste acid ponds. Approximately 30,000.000 gallons of waste flowed into the Savannah
River through a drainage ditch. Additionally, during the period from 1982 to September 1984, seepage
escaped through the dikes of the weak acid pond. The seepage, which had been treated in the cooling
water treatment system, amounted to about 2 gallons per hour. This release was corrected in late 1984 by
constructing a slurry wall in the dike."1
April 30, 1998

-------
L-17
L.5.6 References
The following officials from EPA Region 4 and the State of Georgia assisted our efforts in
gathering data for this site:
	Mike Creeson, NPDES Program;
	Alan Yarborough, Superfund Program; and
	Xiabing Chen, State RCRA Program.
ENDNOTES
i.	FNVIROFACTS (EPA database).
ii.	RCRA Part B Application, Revisions and Additions; November 4, 1985.
iii.	Pond Survey, Exhibit G; 1988.
iv.	Facility's letter to Georgia's Environmental Protection Division requesting that its Hazardous Waste
Facility Permit be revoked.
v.	Site Inspection Narrative Report; Georgia Department of Natural Resources, Environmental
Protection Division. Hazardous Waste Management Branch; April 23, 1993.
vi.	Based on 1990 Census Data.
April 30, 1998

-------
L-18
L.6 Facility 6
L.6.1 Facility Background
facility 6 is located in Pinal County, on Highway 76, near San Manuel, Arizona. The site's exact
location is 32.811059 degrees latitude and -110.75291 degrees longitude.' The facility began operations in
1956, and currently uses a smelter and converter system, an anode furnace, and an electrolytic refinery
system in its mineral processing activities. The facility's processes include mining, milling and processing
copper ore, and the mine has been a RCRA permitted facility since November, 1980. As of 1989, the
facility was listed in the RCRA database as a Generator and as a Treatment, Storage, and Disposal Facility
(TSDF) operating under interim status." A Preliminary Assessment, conducted in the early 1980's,
indicated that there was no evidence of waste disposal problems at the site and recommended no further
action.'" To this date, facility 6 is not regulated under CERCLA.
L.6.2 Wastes
The waste streams that we have data for from this facility are:
	Smelter slag;
	Slag tailings;
	Flue dust; and
	Acid plant blowdown slurry.
Smelter slag is a gravel or cobble sized solid material, composed primarily of iron silicates,
calcium oxide, and alumina. The material also contains trace amounts of copper, lead, zinc, and other
metals. The 2,000 tons of slag produced per day is comprised of 1.8 per cent copper, which is sufficient to
recycle economically."' Slag tailings, settled from a slurry, are composed of particles smaller than sand.
The tailings, generated from smelter slags sent to a concentrator, principally contain silicon, iron,
magnesium, and sodium. The tailings also contain smaller amounts of copper, lead, and zinc. The flu
dust, recovered from converter electrostatic precipitators, may contain up to 25 per cent copper
concentration. This valuable material is reprocessed in the flash furnace." Acid plant blowdown,
generated during a process in which off-gas from the flash furnace is cleaned, is a liquid recycled waste
with a pH of approximately 2.
In addition to these waste streams, there are a total of 33 hazardous wastes generated on site.
These substances include sodium cyanide, vanadium pentoxide, arsenic trioxide, acetone, chloroform,
cyclohexane. ethyl acetate, isobutyl alcohol, molybedenum disulfide, and sulfuric acid.
L.6.3 Solid Waste Management Units (SWMUs)
A map-which provides detailed information on the exact number and locations of SWMUs is
available." The site uses both waste piles and tanks to treat and store generated waste streams. While it is
clear that the facility used surface impoundments in the 1980s, the map (produced in 1997) does not
indicate such units. It is therefore apparent that the facility no longer uses surface impoundments to treat
and store solid waste.
April 30, 1998

-------
L-19
Smelter slag is deposited on waste piles, and slag tailings were deposited in six tailings ponds
located on-site. The basal area of the slag piles may range from 7 to 26 hectares, and the height from 6 to
45 meters. The amount of slag in a particular pile ranges from 2.7 to 20.9 million metric tons. The total
surface area of the six tailings ponds is 1,042 acres.1V As of 1988, there were six settling ponds, three weak
acid ponds, two oxidation and oil disposal ponds, and one spill pond." The map docs not indicate these
SWMUs, and they therefore may no longer be in use at the facility.
L.6.4 Facility Setting
We do not have detailed information regarding the climatology of the area, but we may receive
more data from the Arizona Department of Environmental Quality. Facility 6 is located in a similar setting
as facility 2, and therefore probably experiences the same degree of precipitation. A map of the area
surrounding the facility indicates that much of the surrounding land belongs to the State of Arizona, and
the Bureau of Land Management.
The immediate vicinity of the mine is sparsely populated. It is estimated that only 10 people live
within one mile of the site, and the nearest town is San Manuel which is located approximately 1.5 miles
from the tailings ponds." It is estimated from 1990 census data that 8,810 people live within three miles of
the facility, most of whom live east of the site. Although the distance from the nearest tailings pond to
surface water (the San Pedro River) is 1,000 feet, the river is a dry wash and there is no population served
by surface water within three miles downstream of the facility. Furthermore, there is no ecologically
sensitive environment within one mile of the site."
L.6.5 Environmental Contamination
Information on the type and extent of environmental contamination is limited, but there has never
been any observed human death or ecological damage attributed to a mineral processing waste generated at
this facility.1' The Emergency Response Notification System (ERNS) does not track chronic releases, but
the database docs indicate isolated incidents. In 1997 there were three such releases at the site: (1) release
to the soil of 2,861 pounds of sulfuric acid; (2) release to the soil of 186 gallons of sulfuric acid; and (3)
release to the soil of 370 gallons of sulfuric acid. The sources of these releases, as well as the responses to
the spills are unknown.
L.6.6 References
The following officials from the Arizona Department of Environmental Quality assisted our efforts
in gathering data for this site:
	Mike Savka, Aquifer Protection Program;
	Lowell Carty, State Superfund Program; and
	Joe Giudici, State Department of Solid Waste.
April 30, 1998

-------
L-20
ENDNOTES
i.	ENVIROFACTS (EPA database).
ii.	Reassessment of Magma Copper Company San Manuel Mine and Smelter. Ecology and
Environment, Inc. October 1988.
iii.	Preliminary Assessment. U.S. Environmental Protection Agency, Region 9. Date unknown.
iv.	Report to Congress on Special Wastes from Mineral Processing, Volume II: Methods and Analyses.
United States Environmental Protection Agency, Office of Solid Waste. July 1990.
v.	Memorandum from Jim O'Leary, Definition of Solid Waste Task Force, summarizing the results of a
site visit to facilities 2 and 6.
vi.	Facility 6 map, "Mine Site Area Wide Aquifer Protection Permit Facilities"; Hargis & Associates, Inc;
June, 1997.
April 30, 1998

-------
L-21
L.7 Facility 7 (Titanium-Titanium/Dioxide)
L.7.1 Facility Background
Facility 7 consists of six plants at various locations in Baltimore. Maryland, according to EPA's
FINDS database. The facility produces titanium and titanium dioxide. At this time, due to the lack of
documents and references, we cannot determine the exact relationship and function of each of the plants.
Documents that exist, but, have not been obtained include: a preliminary assessment conducted in 1980,
two screening assessments done in 1980 and 1985, an RFA, and state site investigations.
For now, we will concentrate our efforts on the plant that matches the location of the facility in the
January 1997 Population Studies report. Our only current reference is EPA's Envirofacts database. This
database provides some information on location, environmental releases, and waste management units.
Envirofacts indicates the selected plant's exact location is 39.205833 degrees latitude and -76.543333
degrees longitude. The facility is regulated under RCRA and CWA.
L.7.2 Wastes
Scrap milling scrubber water and waste acids (sulfate process) are the waste streams identified as
high risk in the RIA. The scrubber water was also identified as being recycled. No other was composition
data is available other than the one sample for each waste stream used in the RIA.
The facility had an NPDES permit (that expired in 1990) to discharge the following
chemicals/substances through points (pipes): pH, total suspended solids, arsenic, cadmium, chromium,
copper, total iron, dissolved iron, lead, nickel, zinc, antimony, and flow (in conduit or thru treatment
plant). Information on what waste streams were allowed (to be discharged under this permit) is not
available.
According to RCRIS, the facility has a RCRA Part A permit and is subject to comprehensive
evaluation inspections. According to 1995 TRI data, the facility releases chemicals/substances to air,
underground injection, land, and surface water (constituent and amount data available).
L.7.3 Solid Waste Management Units (SWMUs)
Relatively little data are available about SWMUs beyond the fact that the facility has a landfill
with a design capacity of 1860 acre-feet. It is not known what wastes are disposed here or where the
recycled waste stream is stored.
L.7.4 Facility Setting
According to a USGS quad map, the facility is in a fairly remote location, near the Patapsco River.
Other facilities in the area are unidentified, except for the Coast Guard. The 1990 Census data confirms
this. No people live within a half mile of the facility The population within one mile of the site is
estimated to be only 8, while 9,841 people live within three miles of the facility. Most of the population
 lives south of the facility and about 36 percent of the people live north of the facility. No hydrogeologic
data have been attained, but it appears as if the groundwater at the site discharges to the Patapsco River.
This appears to rule out groundwater consumption as an exposure pathway.
April 30, 1998

-------
L-22
L.7.5 Environmental Contamination
No information is currently available on environmental contamination.
L.7.6 References
Only one document, or in this case a database, was available to analyze facility 7:
ENVIROFACTS (EPA database)
The following officials from EPA Region 3 and the Maryland Department of the Environment
assisted our efforts in gathering data for this site:
	Mildred Orusko at Region 3 (RCRA);
	Jim Webb at Region 3 (Superfund);
	Jim Leizeare, State of Maryland, RCRA-Hazardous Waste; and
	Don Mouldin, State of Maryland, Public Information.
As mentioned, there are other documents available, but they generally require a FOIA Request:
	RFA is at Region 3 Document Center (FOIA needed);
A Preliminary Assessment conducted in 1980 and two Screening Assessments
done in 1980 and 1985 are available (may need a FOIA); and
	Site investigations on file.
April 30, 1998

-------
L-23
L.8 Facility 8 (Zinc Production)
L.8.1 Facility Background
Facility 8 is located in Beaver County, on Frankfort Road in Potter Township, which is near
Monaca, Pennslyvania.' The site's exact location is 40.671389 degrees latitude and -80.337778 degrees
longitude." The facility is 29 miles downstream from Pittsburgh on the Ohio River.'" The facility began
operations in 1936 and was modernized in 1980, at which time four elcctrothermic furnaces began
operation.IV
The facility manufactures zinc products from zinc concentrates and purchased zinc bearing
secondaries (recycled zinc scrap).1'" A electrothermic zinc smelter - using a pyrometallurgical process -
produces zinc metal slabs and ingots, zinc oxide, zinc dust, and sulfuric acid."' v The annual production
rate of zinc is approximately 156,000 tons per year, as of 1995.v The facility is located on approximately
450 acres of land and the company owns more than 1,000 acres surrounding the smelter. A 120-Megawatt,
coal burning power plant is also operated on site to provide energy for the smelter.'"
L.8.2 Wastes
We currently have data for the following waste streams:
	Zinc slag;
	Spent surface impoundment liquids;
	Process wastewater;
	Wastewater treatment plant (WWTP) solids; and
	Waste oils.
The waste streams identified as high risk in the RLA are spent surface impoundment liquids and
process wastewater; both streams are currently recycled. From the RIA, composition data is available from
four and eight samples of the waste streams, respectively.
Zinc slag is the major waste stream (by volume) generated at the site. The zinc slag is a rock-like
solid material, with pieces ranging in size from 3 inches to a foot in diameter; it is composed primarily of
iron, silicon, and unrcacted coke. EPA evaluated the composition of zinc slag, processed slag, and
ferrosilicon and found lead frequently exhibiting extraction procedure (EP) toxicity. The generation of
furnace slag was approximately 157,000 metric tons in 1988, with the waste-to-producl ratio of 1.6 metric
tons of slag to each metric ton of zinc product."
The facility has a NPDES permit that expires in 2000. A wide variety of discharge sources are
allowed under this permit: outfall, sewage treatment plant, power plant cooling condenser, flyash settling .
ponds, flyash landfill, flue gas residual from landfill, stormwater runoff, process and storm water, and non-
contact cooling water. The constituents/parameters allowed to be discharged under this permit are:
thermal, dissolved oxygen, pH, total suspended solids, oil and grease-, arsenic, cadmium, hexavalent
chromium, copper, iron, lead, manganese, zinc, aluminum, selenium, flow (in conduit or thru treatment
plant), total residual and free available chlorine, fecal coliform, and biological oxygen demand (most limits
are available; in addition, samples were taken at various outfalls)." The wastewater treatment plant effluent
is from cooling tower blowdown, scrubber wastewater, roaster plant boiler blowdown, zinc oxide recovery
wastewater, zinc sulfate production wastewater, chem lab wastes, zinc dust area floor drains, and
stormwater runoff from production areas. The receiving waters are the Ohio River, Poorhouse Run, and
Raccoon Creek.1
April 30, 1998

-------
L-24
According to 1995 TRI data, the facility releases chemicals/substances to air, underground
injection, land, and surface water (constituent and amount data available)."
L.8.3 Solid Waste Management Units (SWMUs)
Most of the available data on SWMUs are from the 1980s. The following data is from a 1990
report. A series of crushing/separation operations are employed to separate the slag into four material
streams: processed slag, ferrosilicon, zinc fines, and reclaimed coke. The fines and coke are recycled to
beneficiation and processing operations at the facility. The processed slag is stored in slag waste piles,
disposed in a flyash landfill (see below), or sold for such uses as road gravel or construction aggregate.
The ferrosilicon is accumulated in a stockpile until it can be sold.
The following information comes from 1995 reports. The solids generated at the industrial
(smelter) wastewater treatment plant are recycled back into the manufacturing process. There is no
information as to the type of units that are used to store and treat the WWTP solids. Other solids generated
at this facility arc landfilled.' Slag is disposed of in an off-site landfill.' In addition, sewage sludge
generated at the treatment plant is pumped and hauled to a municipal treatment plant for further
processing. Stormwater from the 60-acre production area is collected, treated at the wastewater treatment
plant and discharged in a permitted outfall.' This data does not indicate whether there are any waste piles.
As for waste grease and oil, they are accumulated in several large waste oil tank's and in drums (located in
the facility drum storage building) before being sent to disposal."1
L.8.4 Facility Setting
The facility is located in a 100-year floodplain near the Ohio River.'" About 2,449 people live
within a half mile of the facility. The population within one mile of the site is estimated to be 4,892, and
31,688 people live within three miles of the facility, based on 1990 US Census data. The majority of the
population lives east of the facility and about 33 percent of the people live west of the facility.
L.8.5 Environmental Contamination
According to a 1990 report, of the four wastestreams arising from slag processing, zinc fines and
reclaimed coke are recycled directly to the production process without any potential contact with the
environment. The other two streams, ferrosilicon and processed slag, were evaluated and could (under
very conservative assumptions) be a potential human health and environmental threat."
In addition, there have been two reported release incidents. The first occurred in 1989, when
approximately 350 pounds of chlorine gas was released. In 1990, approximately 1500 pounds of sulfur
dioxide gas was released. No apparent damage was caused by either releases.'"
April 30, 1998

-------
L-25
L.8.6 References
The following officials from the EPA Region 3 and Pennsylvania Department of Environmental
Resources assisted our efforts in gathering data for this site:
	Edna Jones, Region 3 NPDES Branch;
	Gale Campbell, State of Pennsylvania;
	Ed Duval, State of Pennsylvania; and
	Shawn Stely, State of Pennsylvania.
ENDNOTES
i.	Authorization to Discharge under the National Pollutant Discharge Elimination System. Permit
PA0002208. Commonwealth of Pennsylvania. Department of Environmental Resources. Bureau of
Water Quality Management. August 29, 1995.
ii.	ENVIROFACTS (EPA database).
iii.	Preparedness, Prevention, and Contingency Plan for (Company Name). Monaca, Pennsylvania.
February 1995.
iv.	Report to Congress on Special Wastes from Mineral Processing, Volume II: Methods and Analyses.
U.S. Environmental Protection Agency. Office of Solid Waste. July 1990. Chapter 14: Primary Zinc
Processing.
v.	Application for NPDES Permit. New and Existing Industrial Dischargers. Pennsylvania Department
of Environmental Resources. Water Management Program. March 30, 1995.
April 30, 1998

-------
L-26
L.9 Facility 9
L.9.1 Facility Background
Facility 9 is a located on a 150-acre property on the west side of Bartlesville, Oklahoma, near the
Washington County line.' The site's exact location is 36.742429 degrees latitude and -95.989218
longitude.'' Lead and zinc ores are present in the area, which led to the development of the facility. The
facility began zinc smelting operations in 1907, and produces various metals, especially zinc, from refining
zinc concentrates, secondary materials, and other materials that are rich in zinc. The facility began using
three horizontal retort zinc smelters. Two of the smelters ceased operations in the 1920s. Numerous other
industrial processes related to zinc refining were also conducted at the facility, but many of these processes
have been altered significantly since the facility began producing zinc in 1907. As a result, there are
remnants of outdated plants and industrial activities throughout the facility. Air emissions were
uncontrolled until 1976 when the old gas-fired retort furnace was replaced with an electrolytic zinc
refinery. As of 1996, the refinery was not operating and no longer engaged in zinc production. The State
of Oklahoma reported that the new process reduced emissions of total suspended particulates (TSP) by
99.7 percent. The facility was previously regulated under the CWA and is currently regulated under
RCRA. Under CERCLA, the surrounding area was proposed to the National Priorities List in 1993."" 'v
L.9.2 Wastes
The data we currently have are old, and probably outdated. This data provides little, if any,
information on the quantity and constituent content of waste and recycled waste materials. Historical
sources of metals at the site area included:
	Ore concentrates delivered to the facility by railcar;
	Dust from the transport and storage of ore concentrates and solid waste materials
at the facility;
	Metals emissions from roasting and smelting processes; and
	Airborne particulates from smelting materials (e.g., retort and sinter residues, slag,
crashed retorts, and condenser sands).
The waste streams cited in the RLA, and consequently we have sample data for, are;
	Process wastewater, the high-risk waste stream (also a recycled waste);
	Spent surface impoundment liquids; and
	Wastewater treatment plant liquid effluent.
During the time the horizontal retorts were in operation, metals contained in the airborne emissions
from the smelter were deposited over much of the area of Bartlesville.
April 30, 1998

-------
L-27
In 1977, emissions of sulfur dioxide and sulfur trioxide (Sox) and/or acid mist, the result of an
upset or malfunction at the sulfuric acid plant, affected properties next to the plant. Later in 1977, EPA
surveyed SO,, TSP, sulfate, and metal emissions from the facility and their effects on ambient air quality,
soils, and vegetation in the area. EPA found high sulfate levels and high concentrations of metals - of
particular concern were lead and cadmium - downwind of the plant.'
L.9.3 Solid Waste Management Units (SWMUs)
Waste management procedures at the facility have changed over time in response to changing
environmental regulations and manufacturing processes. In addition, two tracts on the site were originally
(but not currently) operated as a solid waste landfill by the City of Bartlesville. Limited information was
available on the type and capacity of waste management units. However, their locations and contents are
for the most part not included in our current references.
In 1992, the facility submitted a RCRA Part A Permit application that identified 27 RCRA-
regulated units: 2 underground injection control (UIC) wells, 5 waste piles, 12 surface impoundments, and
8 tanks. There is a lead concentrate storage unit at the lead processing facility. The State of Oklahoma
performed a compliance evaluation inspection and found, among other things, several incomplete manifest
records, incomplete analysis of wastes at specific units, and inadequate management of waste piles. In
addition there were the following failures: to provide run-on and runoff controls, listing waste piles on the
Part A Permit application, and maintaining a 200-foot buffer zone for all surface impoundments. The
facility failed to identify a goethite waste pile, two nickel and cobalt waste piles, and a north-central
surface impoundment.
Later in 1992, a Part B Permit application was submitted. The new application included
information on lead concentrate materials and units related to the processing of lead concentrate. Those
units are: two Class I injection wells, two surface impoundments (the north and south UIC) basins, and
units that manage wastes containing material derived from the processing of lead concentrate.
The regulated hazardous waste management units at the facility have been equipped with a
groundwater monitoring system. A RCRA facility assessment (RFA) conducted in 1992 identified 41
SWMUs: each of these had at least a medium potential for release through one or more environmental
pathways.'
Under the RCRA Part A permit, the facility submitted information about the SWMUs. The
facility utili/.es underground injection well disposal (design capacity of 4,500,000,000 gallons), a waste
pile (design capacity of 81,700 cubic yards), surface impoundment storage (design capacity of 53,027,313
gallons), and tank treatment (design capacity of 48,000 gallons/day). An EPA inspection verified the
following: 2 landfills (0.001 and 125 acre feet capacities), a waste pile (610 cubic yard capacity), surface
impoundment storage (113,000 gallon capacity), and surface impoundment treatment (likely the tank
treatment cited above, 660,000 gallons/day capacity)." Information on whether the surface impoundments
were lined or stored and treated recycled waste streams is not available.
April 30, 1998

-------
L-28
L.9.4 Facility Setting
Although a description of the county's landscape and climate is not in current references,
information was provided on other aspects of the facility setting. The area surrounding the facility is a
mixed residential, commercial, industrial, recreational, and agricultural area. There are also some
undeveloped lands that serve as wildlife habitat.
The facility is bounded (as of 1996) to the west, northwest, and south by industrial and commercial
properties. Further to the west and south land uses are primarily rural and agricultural. Residential
properties border the facility to the north, northeast, east, and southeast. The central, eastern, and northern
portions of the site are primarily urban. The main commercial district in the area is in the center of
Bartlesville, approximately 1.5 miles to the east of the facility. The city is essentially bisected from north
to south by the Caney River. Portions of the area lie within the flood plain of the Caney River.
The area includes schools, day care facilities, and playgrounds. Approximately 5,000 people live
within 3 miles of the site. Houses occupied by members of the Cherokee Indian Nation are located
adjacent to the east boundary of the facility. An estimated 1,700 students attend two schools and three day
care centers located nearby that are known to have contaminated soils. Approximately 170 people work at
these facilities. The population of Bartlesville is approximately 35,000.' The community has reported on
numerous occasions to the State of Oklahoma that there have been difficulties in raising garden crops,
ornamental plants, and grass in the area; it was not however determined that this was caused by
environmental contamination."
Since an extensive soil removal project was begun in 1992, contamination has been reduced in the
surrounding area. In addition, in 1992 the facility owner met with EPA and indicated they eliminated all
surface impoundments as a potential source of groundwater contamination at the facility by retrofitting
them to meet minimum technology requirements under RCRA.'
In the lower reach of the North Tributary, which flows directly into Eliza Creek, there arc mature
trees along the riparian zone that provide an important bird habitat. Both the tributary and creek have
established habitats that support a variety of aquatic and terrestrial organisms.1' In 1989 the State of
Oklahoma and U.S. Fish and Wildlife Service investigated the death of 19 migratory birds at the facility
and identified one of the surface impoundments as causing the deaths.'
There are no groundwater contamination issues at the site as of June 1997. However, groundwater
at the site is not used for drinking water because aquifers under the site yield only small amounts of poor
quality water due to natural geologic conditions and historical oil production activities. Groundwater in
the vicinity of the area is not used for public or private drinking water supply but docs discharge into
surface water in certain areas.v:
L.9.5 Environmental Contamination
Widespread soil contamination in the area surrounding the facility, including a large portion of
west Bartlesville and much of the downtown area, has been traced back to the uncontrolled air emissions of
the smelting operations as well as the use of slag and other smelter waste for fill projects throughout the
area. Approximately 8 square miles of surface soil surrounding the facility is contaminated. This
contamination included air dispersion of heavy metals - lead, cadmium, arsenic, selenium, and zinc - and
the community fill projects using smelter slag. Concentrations are highest at the smelter and decrease
away from the smelter.
April 30, 1998

-------
L-29
There is also sediment contamination by lead, cadmium, selenium, and zinc over a relatively
widespread area. Sediments in two main areas of the North Tributary have metal concentrations that
exceed preliminary remediation goals. Airborne emissions from historical smelting operations and
associated activities appear to be a significant and likely the most important mechanism of dispersal of the
contaminants across the site. In addition, spillage and wind transport of ore concentrates from rail cars
may have also contributed to elevated metals at the site. It is also likely that solid waste materials from the
smelters were physically moved to areas within the site boundaries for use as fill or for other purposes.
The concentrations of metals are not uniform across the site and some areas within the site boundaries are
not significantly affected. Studies of site-specific partitioning coefficient or Kds have indicated that site
sediments have a high adsorption capacity.
Elevated metals concentrations in surface water have been observed coincident with elevated
metals levels in sediment." From 1975 to 1980, the facility's liquid effluent discharge to a tributary to
Eliza Creek and a tributary to Sand Creek was allowed under its National Pollutant Discharge Elimination
System (NPDES) permit. In 1976, EPA found violations pertaining to exceeding daily maximum levels of
total suspended solids (TSS), cadmium, zinc, selenium, and mercury. Later in 1978, the facility responded
to requirements including installing systems to halt discharge of effluent during power outages and to
contain and treat contaminated storm water runoff from the ore waste storage areas. Since early 1981, the
facility began injecting all storm water and wastewater from industrial operations into UIC wells. Treated
wastewater is pumped to the north and south basins before being disposed of at UIC wells 1 and 2.'
Shallow groundwater is also a potential concern because metals may be transported from the
facility to the surface water south of the facility." A 1992 investigation collected soil, sediment, and
groundwater samples at various SWMUs. High concentrations of arsenic, cadmium, chromium, copper,
lead, mercury, nickel, selenium, thallium, and zinc were detected in sediment samples collected from the
north and south UIC basins. In addition, concentrations in groundwater samples from several monitoring
wells exceeded the TCLP regulatory level for cadmium and lead.' The groundwater contamination does
pose a potential ecological threat.' Various other reports indicated that releases to air of particulates from
waste piles, raw materials, and smelters constituted a potential hazard.'
L.9.6 References
The following officials from the EPA Region 6 and Oklahoma Department of Environmental
Quality assisted our efforts in gathering data for this site:
	Noel Bennett at Region 6 Superfund;
	Adolphis Talton and Mike Hebcrt at Region 6 RCRA;
	Scott Thompson at State Superfund;
	Don Barrett and Tammy Johnson at State RCRA.
April 30, 1998

-------
/
*
L<30
r
ENDNOTES
i.	Regulatory Compliance Review. U.S. EPA, Region 6. March 31, 1994. Prepared by PRC
Environmental Management, Inc.
ii.	ENVIROFACTS (EPA database).
iii.	Site Summary. EPA Region 6. July 16, 1997.
iv.	EPA National Priorities List. Fact Sheet. Office of Emergency and Remedial Response. May 1996.
v.	Record of Decision for Operable Unit One. Oklahoma Department of Environmental Quality. Date
not listed.
vi.	Record of Decision for Remedial Action at Operable Unit 2 (Ecological Unit). Oklahoma
Department of Environmental Quality. September 27, 1996.
April 30, 1998

-------