United States Solid Wast® and EPA530-R-97-036
Environmental Protection Emergency Response NTIS: PB97-177 000
Agency (5305W) April 1997
vyEPA Regulatory Impact
Analysis: Application of
Phase IV Land Disposal
Restrictions to Newly
Identified Mineral
Processing Wastes
Printed on paper that contains at lest 20 percent postconsumer fiber
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Application of Phase IV
Land Disposal Restrictions
to Newly Identified
Mineral Processing Wastes
Regulatory Impact Analysis
Office of Solid Waste
United States Environmental Protection Agency
April 15,1997
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50272-101
REPORT DOCUMENTATION 11. Report No,
PAGE |
| EPA530-R-97-036
I
12.
4. Title and Subtitle
REGULATORY IMPACT ANALYSIS: APPLICATION OF THE PHASE IV LAND DISPOSAL RESTRICTIONS TO [ 6.
NEWLY IDENTIFIED MINERAL PROCESSING WASTES |
| 5. Report Date
April IS, 1997
7, Authors)
| 8. Performing Organization Rept, No.
9. Performing Organization Name and Address
U.S. EPA
OFFICE OF SOLID WASTE
401 M STREET, SW
WASHINGTON, DC 20460
110.Proj ect-Task/Work Unit No.
L
II. Contract © or Grant (G) No.
1(G)
12. Sponsoring Organization Name and Address
j 13. Type of Report & Period Covered
| TECHNICAL REPORT
I 14.
15. Supplementary Notes
16. Abstract (Limit: 200 words)
ESTIMATES THE COSTS, ECONOMIC IMPACTS, AND BENEFITS OF THE SUPPLEMENTAL PROPOSED RULE APPLYING PHASE IV LAND DISPOSAL
RESTRICTIONS [LDR] TO NEWLY IDENTIFIED HAZARDOUS MINERAL PROCESSING WASTES. DISCUSSES THE PROPOSED REGULATORY OPTIONS FOR
MINERAL PROCESSING WASTES NO LONGER EXEMPT FROM SUBTITLE C REQUIREMENTS UNDER THE BEVILL EXEMPTION. ADDRESSES UNIVERSAL
TREATMENT STANDARDS (UTS). INCLUDES METHODOLOGIES USED.
17. Document Analysis a. Descriptors
b. Identifiers/Open-Ended Terms
e. COSATI Field Group
18. Availability Statement
119. Security Class (This Report)
121. No. of Pages
| UNCLASSIFIED
! 325
RELEASE UNLIMITED
1
120. Security Class (This Page)
1
122. Price
| UNCLASSIFIED
I
(Sec ANSI-Z39.18)
OPTIONAL FORM 272 (4-77)
(Formerly NTIS-35)
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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 ... 7
2. DEFINING THE UNIVERSE AND ESTIMATING WASTE VOLUMES 9
3. COST AND ECONOMIC IMPACTS OF THE RULE 10
3.1 Methods 10
3.1.1 Waste Management Assumptions ; 12
3.1.2 Cost Modeling Assumptions ..... 15
3.1.3 Economic Impact Analysis 20
3.2 Results 21
3.2.1 Cost Analysis Results 22
3.2.2 Economic Impact Analysis Results 28
4. BENEFITS ASSESSMENT .. 43
4.1 Risk and Benefits Assessments Methodologies '. 43.
4.1.1 Overview of Risk and Benefits Assessment Activities 43
4.1.2 Risk and Benefits Assessment Methods for Nonrecycled Materials .. 45
4.1.3 Risk and Benefits Assessment Methods for the Storage of Recycled
Materials 45
4.2 Risk and Benefits Assessment Results 49
4.2.1 Risks and Benefits Associated With the Disposal of Mineral Processing
Wastes 49,
April 15, 1997
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ii
TABLE OF CONTENTS (continued)
4.2.2 Risk Assessment Results for Recycled Materials Storage: Groundwater
Pathway 53
. 4.2.3 Potential Benefits From Control of Stored Materials: Groundwater
Pathway 55
4.2.4 Risk Assessment Results for Storage of Recycled Materials: Non-
Groundwater Pathways 60
4.2.5 Potential Health Benefits from Regulation of Storage of Recycled
Materials: Non-Groundwater Pathways 64
4.3 Uncertainties and Limitations in the Risk and Benefits Assessment for the
Modified Prior Treatment Baseline 64
5. Other Administrative Requirements 68
6. Conclusions 69
6.1 The Affected Universe 69
6.2 Cost and Economic Impacts of the Rule 69
6.3 Health Benefits of the Proposed LDR 71
APPENDIX A: ANALYSIS OF OPTIONS UNDER ALTERNATIVE BASELINES
APPENDIX B: SUMMARY OF MINERAL PROCESSING FACILITIES PRODUCING
HAZARDOUS WASTE STREAMS
APPENDIX C: MINERAL PROCESSING WASTE TREATMENT AND DISPOSAL COSTS:
LOW-COST ANALYSIS
APPENDIX D: DEVELOPMENT OF COSTING FUNCTIONS
APPENDIX E: TYPE OF UNIT RECEIVING RECYCLED MATERIAL
APPENDIX F: EXPLANATION OF COST MODELING CALCULATIONS
APPENDIX G: MINERAL PROCESSING COST MODEL EXAMPLE CALCULATION:
TITANIUM AND TITANIUM DIOXIDE SECTOR
APPENDIX H: RISK AND BENEFITS ASSESSMENT FOR THE STORAGE OF RECYCLED
MATERIALS
• | ; ; I ; '
1
April 15,1997
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iii
TABLE OF CONTENTS (continued)
APPENDIX I: METHODOLOGY
APPENDIX J: CONSTITUENT CONCENTRATION DATA FOR RECYCLED MATERIALS
April 15,1997
*
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MINERAL PROCESSING WASTES FORMERLY EXEMPT
UNDER THE BEVILL AMENDMENT ,
This regulatory impact analysis (RIA) estimates the costs, economic impacts, and benefits of the
supplemental proposed rule applying Phase IV Land Disposal Restrictions (LDRs) to newly identified
hazardous mineral processing wastes. Today's proposal modifies potential waste management
requirements that were originally proposed on January 25,1996 (61 FR 2338).
In today's notice, EPA is proposing 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 would need to be treated to meet
RCRA Universal Treatment Standards (UTS) before management or disposal in a land-based uijit. At the
same time, however, operators could reclaim hazardous mineral processing residues and store them in
non-land based units prior to reclamation without complying with full Subtitle C requirements, under
certain specified conditions.
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 under 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. EPA 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.
Under the provisions of the Mining Waste Exclusion of RCRA, 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 EPA 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), corrosivity (D002), and/or reactivity (D003).
April 15,1997
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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 authorization
status.
1. REGULATORY OPTIONS
This section presents the options that EPA is considering for applying LDR standards to newly
identified hazardous mineral processing wastes. All of these options are examined in depth in this
Regulatory Impact Analysis, and have been selected for analysis because they reflect the views of various
interested parties and will enable EPA to effectively solicit public comment on appropriate management
standards for the subject wastes. Section 1.1 summarizes the key features of each option. Section 1.2
discusses their implications for the RIA.
1.1 Specific Options
Summarized below are the four options that are the focus of analysis in this RIA. In addition to
the option-specific details outlined below, several of the options share the following common features:
• In all four options, mineral processing wastes being disposed must be treated to
UTS levels prior to disposal in Subtitle D disposal units;
• Operators of facilities that generate and manage hazardous mineral processing
wastes must comply with simplified recordkeeping and reporting requirements
under all four options;
• Secondary mineral processing materials destined for recycling may be stored for
up to one year under all four options; and
• Recycling of non-mineral processing materials outside of RCRA Subtitle C
jurisdiction is prohibited, i.e., the conditional exclusions for certain activities
April 15,1997
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provided in Options 2, 3, and 4 (as described below) are available only for
mineral processing residues.
Option 1 - Subtitle C Jurisdiction
Option 1 represents a comprehensive approach for ensuring that land storage of secondary
materials destined for reprocessing does not contribute to the "waste management problem" and that
recycling claims by the mineral processing industry are legitimate and not simply a mechanism for
disposal of mineral processing wastes outside RCRA Subtitle C jurisdiction. This option is similar to the
first option in the January 1996 supplemental proposal, though it now restricts reintroduction of mineral
processing secondary materials into beneficiation or Bevill process units. The option consists of the
following features:
1. Subtitle C jurisdiction would be extended to cover characteristic sludges and by-
products, even when these materials are reclaimed; i.e., these materials would be
considered solid wastes and thus subject to RCRA jurisdiction in the same
manner that spent materials are currently classified.
2. Storage on land of secondary materials destined for recycling or reprocessing
would not be permitted for materials generated a rates of less than 45,000 metric
tons of solids or one million metric tons of liquids per year.
3. If materials are stored on land, the land-based storage units must not contribute to
significant groundwater contamination through discard. This condition might be
met in one of three ways:1
• The facility operator demonstrates that he/she is not polluting
groundwater at levels exceeding the Maximum Contaminant Level
(MCL) for any hazardous constituent likely to be in the secondary
materials stored (i.e., the toxic metals listed in Appendix Vm of Part 261
and cyanide). The demonstration would be made by means of
groundwater monitoring. If a release were detected that exceeded MCLs,
unit-specific corrective action would be required.
• The unit storing the materials is designed in a manner that obviates the
need for a demonstration that MCLs are not being exceeded.
Specifically, surface impoundment units would need to be constructed to
have the transmissivity equivalent of a 40 mil geomembrane liner on a
surface of 12 inches of 105 cm/sec hydraulic conductivity soil. Storage
of solids in piles located on concrete, asphalt, or soil with the
1 Note that for the purposes of this RIA, EPA has modeled only the cost of complying with the second
of the three alternative conditions (i.e., instillation of liners). Throughout the RIA, the Agency has
assumed that operators will choose the least-cost option for compliance, and upon consideration, has
determined that installing liners in previously unlined land-based units is likely to be the least-cost means
for most operators to continue storing secondary materials on land Installing liners obviates the need to
implement groundwater monitoring and allows the operator to avoid triggering corrective action
requirements. '
April 15,1997
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transmissivity equivalent of three feet of clay with 10"7 cm/sec hydraulic
conductivity also would be permitted.
• Hie facility obtains a determination from an authorized state or (in
unauthorized states) from the Regional Administrator, that a management
practice or alternative design provides adequate assurance that the unit
provides effective containment and will not become part of the waste
disposal problem through discard.
4. All non-land based storage units (i.e., tanks, containers, and containment
buildings (TCBs)) must meet applicable 40 CFR Part 265 standards (standards for
interim status facilities).
5. Facility owners and operators would have to demonstrate that legitimate recycling
is occurring at the facility in the following two ways:
• Demonstrate that the recycled secondary material complies with a
quantitative minimum material content standard; or
• Demonstrate that hazardous constituents different from those normally
found in customarily used raw materials are not present in secondary
materials, thereby precluding the presence of "toxics along for the ride"
or "TAR."
Facilities that fail to meet conditions for legitimate recycling would be subject to
Subtitle C treatment and storage permitting, along with associated financial
responsibility and facility-wide corrective action requirements.
6. Hazardous mineral processing residues could not be recycled to primary
beneficiation operations/units or Bevill process units without loss of the Bevill
exempt status of any beneficiation or other special wastes generated by such units.
That is, these operations would become regulated Subtitle C units and resulting
wastes from these units would lose their Bevill status when mineral processing
residues were mixed with ores, minerals, or beneficiated ores or minerals.
Option 2 — Conditional Exemption from RCRA Jurisdiction (But Including Bevill Unit
Recycling Prohibition)
Option 2 represents mi attempt to both (1) stimulate greater resource recovery in the minerals
industry by not classifying recoverable mineral processing residuals as wastes if they are recovered in
process 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. This option is new (i.e., it was not included in the January 1996 proposed rule). It differs
from Option 1 in two ways: Option 2 does not include a legitimacy test for recycled materials, and it
allows storage in tanks, containers, and buildings that do not meet RCRA part 265 subpart I, J, and DD
standards. The option consists of the following features: ,
1. A conditional exclusion from the definition of solid waste would apply to non-
exempt mineral processing residues stored in tanks, containers, or buildings
April 15,1997
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(TCBs) prior to reinsertion into a mineral processing production unit. TCBs
would not be required to meet any additional design requirements to be eligible
for the conditional exclusion.
Storage on land of secondary materials destined for recycling or reprocessing
would not be permitted for materials generated at rates less than 45,000 metric
tons of solids or one million metric tons of liquids per year.
If materials are stored on land, the land-based storage units must not contribute to
significant groundwater contamination through discard. This condition might be
met in one of three ways:2
• The facility operator demonstrates that he/she is not polluting
groundwater at levels exceeding the Maximum Contaminant Level
(MCL) for any hazardous constituent likely to be in the secondary
materials stored (i.e., the toxic metals listed in Appendix VIII of Part 261
and cyanide). The demonstration would be made by means of
groundwater monitoring. If a release were detected that exceeded MCLs,
unit-specific corrective action would be required.
• The unit storing the materials is designed in a manner that obviates the
need for a demonstration that MCLs are not being exceeded.
Specifically, surface impoundment units would heed to be constructed to
have the transmissivity equivalent of a 40 mil geomembrane liner on a
surface of 12 inches of 10"5 cm/sec hydraulic conductivity soil. Storage
of solids in piles located on concrete, asphalt, or soil with the
transmissivity equivalent of three feet of clay with 10'7 cm/sec hydraulic
conductivity also would be permitted.
• The facility obtains a determination from an authorized state or (in
unauthorized states) from the Regional Administrator, that a management
practice or alternative design provides adequate assurance that the unit
provides effective containment and will not become part of the waste
disposal problem through discard.
4. Hazardous mineral processing residues could not be recycled to primary
beneficiation operations/units or Bevill process units without loss of the Bevill
status of any beneficiation or other special wastes generated by such units. That
is, these operations would become regulated Subtitle G units and resulting wastes
from these units would lose their Bevill status when mineral processing residues
were mixed with ores, minerals, or beneficiated ores or minerals.
2.
3.
2 See previous footnote.
April 15, 1997
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Option 3 - Conditional Exclusion from RCRA Jurisdiction (Excluding Bevill Unit
Recycling Prohibition)
Option 3 includes all of the Option 2 provisions, with one significant exception. The prohibition
on recycling hazardous mineral processing residues through beneficiation or Bevill process units (the last
feature listed in Option 2) would not apply. This option includes the following features:
1. A conditional exclusion from the definition of solid waste would apply to non-
exempt mineral processing residues stored in tanks, containers, or buildings
(TCBs) prior to reinsertion into a mineral processing production unit. TCBs
would not be required to meet any additional design requirements to be eligible
for the conditional exclusion.
2. Storage on land of secondary materials destined for recycling or reprocessing
would not be permitted for materials generated at rates less than 45,000 metric
tons of solids or one million metric tons of liquids per year.
3. If materials are stored on land, the land-based storage units must not contribute to
significant groundwater contamination through discard. This condition might be
met in one of three ways:3
• The facility operator demonstrates that he/she is not polluting
groundwater at levels exceeding the Maximum Contaminant Level
(MCL) for any hazardous constituent likely to be in the secondary
materials stored (i.e., the toxic foietals listed in Appendix VIII of Part 261
and cyanide). The demonstration would be made by means of
groundwater monitoring. If a release were detected that exceeded MCLs,
unit-specific corrective action would be required.
• The unit storing the materials is designed in a manner that obviates the
need for a demonstration that MCLs are not being exceeded.
Specifically, surface impoundment units would need to be constructed to
have the transmissivity equivalent of a 40 mil geomembrane liner on a
surface of 12 inches of 10"5 cm/sec hydraulic conductivity soil. Storage
of solids in piles located on concrete, asphalt, or soil with the
transmissivity equivalent of three feet of clay with 10'7 cm/sec hydraulic
conductivity also would be permitted,
• The facility obtains a determination from an authorized state or (in
unauthorized states) from the Regional Administrator, that a management
practice or alternative design provides adequate assurance that the unit
provides effective containment and will not become part of the waste
disposal problem through discard.
3 See footnote 1.
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Option 4 — 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. This option was included as Option 3 in the January 1996 proposal. This option includes
the following features:
1. 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.
2. Facility operators would not be required to comply with a legitimacy test for
mineral processing residues being recycled.
3. Hazardous mineral processing residues could be recycled to primary beneficiation
operations/units without risk to the Bevill status of any beneficiation wastes
generated by such units, these residues would not be required to meet a
"significantly affected" test.
1.2 Discussion of Options and Implications for the Regulatory Impact Analysis
The Agency has performed a detailed analysis of each of the four options described above,
assuming each of three alternative baselines. The baseline discussed in the remainder of this RIA is the
one the Agency believes 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 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 cement-stabilize their waste(s) to remove the hazardous characteristie(s).4 Because this method also
would be used to achieve UTS, 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. 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 unlined 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.
4 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 by neutralization), which is the basis for the UTS standards, is an effective treatment technology
for removing these hazardous waste characteristics.
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Generally, the Agency believes that the four options described above characterize the range of
alternatives available for addressing storage of secondary materials intended for reinsertion into mineral
production processes, in terms of the trade-offs among costs, economic impacts, and benefits. Costs to
industry would be highest under Option 1, which would impose a number of additional requirements on
facilities recycling secondary materials, while potential benefits in terms of environmental protection could
be greater under Option 1 than under the other three options. At the same time, the restriction against
recycling secondary material through beneficiation or Bevill units, legitimacy tests, and storage unit
standards may serve as a disincentive to recycling, thus discouraging the reuse of these materials at
mineral processing facilities.
Option 2 would impose costs similar to Option 1, driven primarily by the prohibition against
recycling secondary materials to beneficiation or Bevill process units. Two factors make this option
slightly less expensive than Option 1: the absence of a legitimacy test for recycling materials through
mineral processing units; and the provision allowing storage of secondary materials in non-RCRA tanks,
containers, and buildings prior to recycling. As a result of these two factors, Option 2 may be seen as
slightly less protective of the environment (i.e., because the possibility of "sham recycling" exists and
because storage units, though generally assumed to be sturdy, would not have secondary containment).
This option would create a mild disincentive for recycling material through non-Bevill units.
One additional feature of Options 1 and 2 is worthy of more extensive discussion. Either of these
options, if promulgated, would not only prohibit the reintroduction of hazardous mineral processing
wastes into production units that generate Bevill wastes, they also would remove the special waste status
of all extraction, beneficiation, and processing wastes that are generated by units that receive any other
non-Bevill waste streams, irrespective of their hazard characteristics. EPA believes that the effect of this
new, broad-spectrum regulatory control would be that facility operators would cease the practice of
reinserting secondary materials, of any kind, into Bevill production units. Given the substantial degree of
material recycling and resource recovery conducted within the primary minerals industry, adoption of
Options 1 or 2 might therefore impose profound effects on the materials handling and production
processes in use within this industry. Indeed, one result might be that resource recovery would decline in
parallel with a significant increase in the quantities of solid and hazardous wastes generated at mineral
production facilities.
In addition, several other industries that send secondary materials to Bevill production units could
also be affected under Options 1 and 2. Prominent examples of non-mineral processing secondary
materials that are recovered in Bevill units by mineral processors include F006 (wastewater treatment
sludge from electroplating operations), foundry sands, cathode ray tubes, and circuit boards. EPA has not
attempted to quantify the magnitude or distribution of any potential operational, financial, or
environmental impacts associated with the prohibition against recycling any non-Bevill waste stream
through Bevill production units, due to a lack of sufficient data. Nonetheless, the Agency believes that the
logistical and financial impacts on the facility operator associated with enactment of either of these options
might be severe in some cases.
. Option 3 is the least expensive non-land based storage option considered. As stated earlier, the
only difference between Option 3 and Option 2 is that Option 3 does not prohibit recycling through
beneficiation or Bevill process units. As a result, although it may impose a slight disincentive to
recycling. Option 3 is protective of the environment, without interfering excessively with resource
recovery.
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Option 4 would impose no additional requirements for management of secondary materials to be
recycled, regardless of where they are stored. Consequently, this option represents the least cost approach
for industry and may provide greater incentives for materials reuse than the other three 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 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.
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.5 The Agency then narrowed the focus of its data gathering and analysis as it completed each
subsequent step. This six-step methodology is described in detail in the Appendix I.
The Agency's data sets and underlying mineral commodity sector reports 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. Where appropriate, EPA has revised the sector reports and incorporated new information into its
analysis. In addition, 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 RIA.
EPA has 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 are applied consistently across the three cost cases.
As in the December 1995 RIA, 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 was 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, none, 50 percent and 100 percent of the generation rate is included in the minimum, expected,
and maximum value case. That is, the generation rate in each of the cost scenarios was multiplied by a
percentage considered to be hazardous in this analysis, based on the certainty that the wastestream is
hazardous. The remaining "nonhazardous" portion drops out of the analysis. Exhibit 2-2 presents the
5 Appendix B lists the mineral processing facilities affected by this rulemaking.
April 15, 1997
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average facility levels of waste assumed to be "hazardous" in each sector, for the minimum, expected, and
maximum value cases.
Exhibit 2-1
Portion of Waste Stream Considered to Be Hazardous
(in Percent)
Costing Scenario
Hazard Characteristie(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.
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 four 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.
3.1 Methods
This section describes the methodology used to calculate the costs and impacts of managing the
affected mineral processing wastes under each of the four 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 proposal the Agency has conducted a dynamic analysis of shifts in
recycling that models shifts in types or quantities of mineral processing residues between
treatment/disposal and storage/recycling/reclamation .* For Options 1,2, and 3 die analysis examines
various shifts that may diminish recycling, while for Option 4 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.
6 In contrast, data limitations did not allow the Agency to conduct analysis of potential shifts in
recycling for the R1A that accompanied the January 1996 proposal.
April 15,1997
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Exhibit 2-2
Average Facility Waste Type Input Data
Minimum Cost Scenario
Expected Cost Scenario
Maximum Cost Scenario
Number
Waste
1 -10%
Number
Waste
1-10%
Number
Waste
1-10%
of
Water
Solids
Solids
ot
Water
Solids
Solid*
of
Water
Solids
Solids
Commodity
Facilities
(mt/yr)
(mt/yr)
(mt/yr)
Facilities
(mt/yr)
(mt/yr)
(mt/yr)
Facilities
(mt/yr)
(mt/yr)
(mt/yr)
Alumina and Aluminum
23.0
.
.
3.330
23.0
-
-
3.330
23.0
.
3.330
Anlimonv
6.0
53
-
3.532
6.0
4.500
-
3.532
6.0
9.000
-
3,532
Bervillum
20
100
-
100
2.0
50.000
-
23.000
2.0
i.000,000
. .
45.000
Bismuth
t.O
200
200
3.30O
1.0
12.300
12.200
10.020
1.0
24.200
24.000
25.200
Cadmium
2.0
285
190
570
2.0
2.850
, 1.900
5.700
2.0
28.500
19.000
57.000
Calcium
1.0
-
-
40
1.0
-
-
40
1.0
• -
.
40
Coal Gas
.
.
-
-
"
.
-
¦ -
1.0
.
65.000
.
Cooosr
10.0
.
530.000
600
10.0
-
530.000
600
10.0
.
530.000
600
Elemental Phosohorus
2.0
560.000
, 2.000
230
2.0
560.000
2.000
230
2:0
560.000
2.000
230
Fluorspar and Hydrofluoric Acid
.
- -
-
3.0
5.000
-
•
3.0
15.000
.
-
Germanium
4.0
200
10
4.0
1.100
-
161
4.0
2.000
.
302
Lead
4.0
880.000
-
100.770
4.0
880.000
-
123.345
4.0
880.000
-
153.095
Magnesium and Maanesla from Brines
2.0
•
13.038
2.0
-
-
13.380
2.0
,
.
16.800
Mercury
7.0
9.000
-
12
7.0
11.000
-
12
7.0
60.000
.
12
Molybdenum. Ferromolvbdenum. and Ammonium Molvbdate
11.0
91
-
100
11.0
91
23.000
11.0
91
-
45.000
Platinum Grouo Metals
3.0
200
-
2
3.0
1.140
15
3.0
2.000
.
150
Pvrobllumens, Mineral Waxea, and Natural Asphalts
2.0
1
-
1
2.0
5.000
-
23.000
2,0
10.000
-
45.000
Rare Earths
1.0
21.200
-
170
1.0
1,021,000
-
3.000
1,0
>.021.000
.
11.500
Rhenium
2.0
-
•
44.000
2.0
50
44.000
2.0
100
.
44.000
Scandium
7.0
200
-
-
7.0
1.120
-
- -
7.0
2.000
-
.
Selenium
"3.0
22.000
-
68
3.0
22.000
-
680
3.0
22.000
.
6.800
Synthetic Rutile
1.0
30.000
-
75.000
1.0
30.000
-
75.000
1.0
30.000
.
75,000
Tantalum, Columbium, and Ferrocolumblum
2.0
-
75,000
1.500
2.0
. -
75.000
1.500
2.0
.
75.000
1.500
Tellurium
2.0
200
-
200
2.0
11,000
.
2.000
2.0
30,000
.
9.000
Titanium and Titanium Dioxide
7.0
55.289
-
65.114
7.0
75.876
-
68.243
7.0
96.289
.
71.671
Tungsten
6.0
370
-
6.0
730
-
' -
6.0
5.000
.
Uranium
17.0
300
-
100
17.0
1.250
-
650
17.0
2.200
.
1.200
Zinc
3.0
3.243.417
-
16.600
3.0
1.243.417
-
16.600
3.0
1,243.417
.
16.600
Zirconium and Hafnium
2.0
17.100
. ' -
-
2.0
521.000
-
2.0
>,256,000
-
-------
-12-
3.1.1 Waste Management Assumptions
The costs imposed by a particular regulatory 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 four 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
Secondary Materials Recycled
through Bevill Units
Secondary Materials Recycled
through Processing units
Baseline
Treated to TC levels,
disposed
Stored in unlined land-based units
Stored in unlined land-based units
Option 1
Treated to UTS levels,
disposed
No longer recycled, now treated to
UTS levels and disposed
Stored in RCRA tanks, containers,
and buildings (must pass
legitimacy test)
Option 2
Treated to UTS levels,
disposed
No longer recycled, now treated to
UTS levels and disposed
Stored in tanks, containers, and
buildings
Option 3
Treated to UTS levels,
disposed
Stored in tanks, containers, and
buildings
Stored in tanks, containers, and
buildings
Option 4
Treated to UTS levels,
disposed
Stored in unlined units
Stored in unlined units
Pre-LDR Behavior (Baseline)
In the baseline, operators are 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 are 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.7 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.
7 To comply with current regulations, facility operators also could dispose of these wastes in a Subtitle
C permitted landfill. Appendix C presents a break-even analysis showing that treatment and Subtitle D
disposal is less expensive than Subtitle C disposal without treatment, in most cases.
April 15,1997
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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 proposing
revised UTS levels for mineral processing wastes. Exhibit 3-2 presents the TC levels, existing UTS levels,
and revised UTS levels. Based on the revised levels, EPA believes that mineral processing facilities
treating wastes using cement stabilization will not incur any additional costs in order to achieve UTS
levels.
Exhibit 3-2
Existing and Revised UTS Levels
(Nonwastewater Metals)
Waste Code
Constituent
TC
Level
(mg/1)
Existing
UTS
level
(me/1 TCLP)
Proposed
UTS
Level
(Revised)
D004
Arsenic
5.0
5.0
5.0
D005
Barium
100.
7.6
21
D006
Cadmium
1.0
0.19
0.20
D007
Chromium
5.0
0.86
0.85
D008
Lead
5.0
0.37
0.75
D009
Mercury -
Retort residue
0.20
0.20
0.20
D009
Mercury -
all others
.2
0.025
.025
D010
Selenium
1.0
0.16
5.7
DOli
Silver
5.0
0.30
0.11
Antimony
2.1
0.07
Beryllium
0.014
0.02
Nickel
5.0
13.6
Thallium
0.078
0.20
Vanadium
0.23
1.6
Zinc
—
5.3
4.3
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
April 15,1997
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- 14-
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.8 (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.)
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 TCBs that meet Subtitle C standards,® provided these materials are not
recycled through a beneficiation or other Bevill process unit. These materials could be stored in TCBs for
up to one year in the absence of a RCRA Subtitle C permit.10 EPA assumes facility operators will stop
recycling materials through beneficiation or Bevill process units rather than lose the Bevill exempt or
special waste status of the wastes generated by those beneficiation or Bevill process units. Material
formerly recycled through beneficiation or Bevill process units would then be treated and disposed.
Facility operators would continue treating the wasted portion using cement stabilization or neutralization
and dewatering. In addition, facility operators might stop recycling other materials rather than risk failing
a legitimacy test, because facilities that fail to meet conditions for legitimate recycling would be subject to
Subtitle C treatment and storage permitting, along with associated financial responsibility and facility-
wide corrective action requirements.
Under Option 2, facility operators are expected to move material destined for recycling from
unlined land-based storage units to non-RCRA TCBs, provided these materials are not recycled through a
beneficiation or Bevill process unit. These materials could be stored in TCBs for up to one year in the
absence of a RCRA Subtitle C permit." EPA assumes that facility operators would stop recycling
materials through beneficiation or Bevill process units, rather than lose the Bevill exempt or special waste
status of the wastes generated by those beneficiation or Bevill process units. Material formerly recycled
through beneficiation or other Bevill process units would be treated and disposed. Facility operators
would continue treating the wasted portion using cement stabilization or neutralization and dewatering.
Under Option 3, 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
8 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.
9 These standards can be found in 40 CFR 265 subparts I, J, and DD.
10 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.
11 See footnote 10.
April 15, 1997
-------
one year in the absence of a RCRA Subtitle C permit,12 Facility operators would continue treating the
wasted portion using cement stabilization or neutralization and dewatering.
Under Option 4, 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." Facility operators would continue treating the wasted portion using cement
stabilization or neutralization and dewatering.
Dynamic Shifts
As a refinement to the analysis originally prepared for the December 1995 RIA, 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 Options 1 and 2, the analysis assumes that rather than lose the Bevill exclusion for wastes
generated in beneficiation units and process units, facility operators would stop recycling all mineral
processing secondary materials through these units. Option 1 also might create a moderate disincentive
for recycling newly-identified mineral processing wastes through processing units, due to the imposition
of a legitimacy test and more stringent storage unit standards. Option 2 might impose a mild disincentive
for recycling newly-identified mineral processing wastes through processing units due to more stringent
storage unit standards. Option 3 could cause a similar minor disincentive for all recycled wastes,
regardless of the point of reintroduction to the manufacturing process because of the additional storage
unit requirements. Option 4, which does 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
EPA 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 four options,
EPA developed and applied cost-estimating functions for treatment and disposal, as well as storage prior
to recycling. Appendix D provides a detailed discussion of these cost functions. The cost functions
address the capital and O&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.
12 See Footnote 10.
13 See Footnote 10.
April 15, 1997
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-16-
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., earnings, value of product shipments).
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.14
• 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
disposed for each baseline and option. The remaining hazardous material is considered to be recycled.15
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. In response to public comment suggesting that several
mineral processing facilities currently recycle material to beneficiation units, EPA attempted to determine
the point in the production process where each recycled material is reintroduced. Appendix E lists this
information.
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
14 OMB, 1992. Circular A-94.
15 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.
April 15,1997
ft
-------
-17-
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.16
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.
Exhibit 3-3
Proportions of Waste Streams Sent to Treatment and Disposal (in percent)
Baseline or Option
Affected
Material
Percent Disposed
Certainty of Recycling
Y Y? YS YS? N
Baseline
All
0
15
25
80
100
Option 1
Bevill
100
100
100
100
100
Non-Bevill
30
65
100
100
100
Option 2
Bevill
100
100
100
100
100
Non-Bevill
0
25
35
85
100
Option 3
All
0
25
, 35
85
100
Option 4
All
0
15
25 .
80
100
16 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 producing waste requiring treatment. More information on this
totaling process can be found in Appendix F. An example of the cost model calculations for a single sector
can be found in Appendix G.
April 15,1997
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- 18-
Exhibit 3-4
Proportions of Waste Streams Stored Prior to Recycling (in percent)
Affected
Material
Percent Recycled
Baseline or Option
Certainty of Recycling
Y
Y?
YS
YS?
N
Baseline
All
100
85
75
20
0
Option 1
Bevill
0
0
0
0
0
Non-Bevill
70
35
0
0
0
Option 2
Bevill
0
0
0
0
0
Non-Bevill
100
75
65
15
0
Option 3
All
100
75
65
15
0
Option 4
All
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 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.
Bevill means that secondary materials are recycled through beneficiation or Bevill process units.
Non-Bevill means that secondary materials are not recycled through beneficiation or Bevill process units.
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 Treatment 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 175 percent of the mass
entering stabilization.
April 15, 1997
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- 19-
• Management of hazardous mineral processing wastewaters and wastes containing
1 to 10 percent solids involves non-permitted treatment followed by disposal of
the stabilized mass 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 by 55 percent (or 155 percent of the mass entering
stabilization).
These assumptions and their factual basis are documented in Appendix D and Appendix F.
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 879 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
supplemental proposed Phase IV LDR rule will not affect those wastes.
Hie 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
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 Subtide 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 D) 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." To estimate
the impacts of the material reclamation practices outlined above, the Agency used unit cost functions
(described in detail in Appendix D) 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,
17 Some of the 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.
April 15,1997
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-20-
because it is important in many cases that the wastes to be recycled not be commingled. To determine the
total sector storage cost, EPA 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 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 to the total sector incremental storage costs. EPA divided this total
sector cost by the number of facilities in the sector to determine the average facility costs.
3.13 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 with three different measures of
economic activity."
First, EPA compared regulatory costs for each sector to the estimated value of shipments from the
plants in that sector. This provides a rough measure of the extent to which gross margins 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. The Agency recognizes that this
approach produces only a very crude and preliminary estimate of ultimate economic impact on affected
facilities. Unfortunately, however, this is the only ratio analysis for which the needed data were available
for all of the industry sectors. EPA calculated the ratio of annualized incremental cost to the value of
shipments for all four options, has defined the screening level threshold for significant impact as three
percent.
Second, 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
18 EPA did not consider the extent to which industry sectors may be able to pass on to their customers
the costs of regulation. An industry sector's ability to pass on costs depends on two factors: (1) the
elasticity of demand (if demand changes little with a change in price, industry has a greater opportunity to
pass on most of the costs), and (2) the extent of the world market represented by U.S. suppliers (if U.S.
suppliers represent a small portion of the world market, most of the market is unaffected by U.S.
regulations and U.S. suppliers cannot pass through the costs).
April 15,1997
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-21 -
a Census Bureau publication.19 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.20 For this analysis, EPA used a screening level of 10 percent for significant
impact.
Third, for five industry sectors where data were available, EPA compared estimated regulatory
costs for each sector to the estimated profits of that sector. This ratio analysis permits a direct comparison
of regulatory costs to profits, and indicates the maximum extent to which the regulation will reduce
industry profits if industry cannot pass on any of the regulatory costs to customers. To conduct this
analysis, EPA obtained profits data for firms known to be engaged primarily or exolusively in processing a
single type of mineral. The Agency obtained these data from the Disclosure on-line commercial database,
for the most recent year available in the database. (The Disclosure database, in turn, contains data taken
from 10K forms that publicly-held firms must file with the Securities and Exchange Commission.) EPA
based its estimate of profitability for each of the five industry sectors on the weighted average profitability
of the firms in each sector for which data were available.21 For this analysis, EPA selected a screening level
threshold for severe impacts of 100 percent.
3,2 Results
This section presents EPA's estimates of the cost and screening-level economic impacts of Options
1,2,3, and 4. These estimates are provided in-tum by option, followed by some brief comparisons
between options. Please 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
$46,000,000
$58,000,000
$75,000,000
Option 2
$37,000,000
$45,000,000
$55,000,000
Option 3
$5,200,000
$8,400,000
$13,000,000
Option 4
$71,000
$190,000
$190,000
19 Bureau of the Census, U.S. Department of Commerce, 1992 Census of Manufactures, Industry
Series, Smelting and Refining of Nonferrous Metals and Alloys, Industries 3331, 3334, 3339, and 3341
(Washington, DC: U.S. Department of Commerce), p. 33C-9.
20 The Agency's background calculations are provided in Appendix G of the Regulatory Impact
Analysis of the Supplemental Proposed Rule Applying Phase TV Land Disposal Restrictions to Newly
Identified Mineral Processing Wastes, December 1995. ,
21 See previous footnote.
April 15,1997
-------
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 most options, at any given generation rate storage
prior to recycling is less expensive than treatment and disposal. 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 $175 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
Cost impact results are presented in Exhibits 3-6 through 3-9. The options are discussed in order
from the most to the least costly.
Option 1
Under Option 1, EPA anticipates that the total expected incremental cost will be $58,000,000, as
seen in Exhibit 3-6. Twenty-six of the 29 industry sectors (90 percent) are projected to experience
increased costs, one (three percent) is expected to have no additional costs, and two (seven percent) are
anticipated to have cost savings. On a sector basis, the cost changes range from an expected savings of
$43,000 (tungsten) to a cost increase of $27,000,000 (lead). Note that the cost impacts of this option fall
disproportionately on the lead sector, the cost impacts estimated for the lead sector account for more than
46 percent of the total cost impacts estimated under this option.22 EPA expects five of the sectors (17
percent) to have total incremental costs greater than $1,000,000 (alumina and aluminum, copper,
elemental phosphorus, lead, and zinc). Three sectors (10 percent) are expected to have total costs
between $500,000 and $1,000,000 (mercury, synthetic rutile, and titanium and titanium dioxide). Only
22 EPA is currently conducting additional analyses to determine whether costs to the lead sector may be
overstated by the cost model.
April 15,1997
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-23-
Exhibit 3-6
Option 1 Incremental Costs
Minimum Value Case
Expected Value Case
Maximum Value Case
Total
Avg, Fac.
Total
Avg, Fac,
Total
Avg. Fac,
Incremental
Incremental
Incremental
Incremental
Incremental
Incremental
Commodity
Cost ($/yr)
Cost (Vyr)
Cost (Vyr)
Cost (S/yr)
Cost (S/yr)
Cost (S/yr)
Alumina and Aluminum
1,400,000
62,000
2,400,000
100,000
2,900,000
130,000
Antimony
-
-
55,000
9,200
81,000
14,000
Beryllium
-
-
40,000
20,000
800,000
400,000
Bismuth
.
39,000
39,000
72,000
72,000
Cadmium
-
.
63,000
31,000
2,500,000
1,200,000
Calcium
-
4,300
4,300
7,300
7,300
Coal Gas
-
.
-
-
220,000
220,000
Copper
10,000,000
1,000,000
10,000,000
1,000,000
10,000,000
1,000,000
Elemental Phosphorus
3,400,000
1,700,000
3,400,000
1,700,000
3,400,000
1,700,000
Fluorspar and Hydrofluoric Acid
-
190,000
63,000
330,000
110,000
Germanium
-
39,000
9,700
45,000
11,000
Lead
21,000,000
5,200,000
27,000,000
6,700,000
32,000,000
8,100,000
Magnesium and Magnesia from Brines
2,800
1,400
3,100
1,500'
240,000
120,000
Mercury
-
-
680,000
97,000
1,800,000
260,000
Molybdenum, Ferromolybdenum, and
Ammonium Molybdate
16,000
1,400
16,000
1,400
Platinum Group Metals
-
-
5,900
2,000
38,000
13,000
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
140,000
68,000
170,000
83,000
Rare Earths
9,800
9,800
200,000
200,000
1,100,000
1,100,000
Rhenium
-
-
9,500
4,700
31,000
15,000
Scandium
-
-
(22,000)
(3,100)
170,000
25,000
Selenium
81,000
40,000
140,000
46,000
300,000
100,000
Synthetic Rutile
V
-
560,000
560,000
1,000,000
1,000,000
Tantalum, Columbium, and
Fenocolumbium
540,000
270,000
390,000
200,000
390,000
200,000
Tellurium
.
150,000
75,000
180,000
90,000
Titanium and Titanium Dioxide
170,000
83,000
920,000
130,000
1,400,000
200,000
Tungsten
-
-
(43,000)
(7,200)
73,000
12,000
Uranium .
-
.
220,000
13,000
1,100,000
63,000
Zinc
9,700,000
3,200,000
11,000,000
3,700,000
13,000,000
4,200,000
Zirconium and Hafnium
-
-
210,000
110,000
1,200,000
610,000
Total
*
46,000,000
58,000,000
75,000,000
April 15,1997
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Exhibit 3-7
Option 2 Incremental Costs
Minimum Value Case
Expected Value Case
Maximum Value Case
Total
Avg. Fac.
Total
Avg. Fac.
Total
Avg, Fac.
incremental
Incremental
Incremental
Incremental
Incremental
Incremental
Commodity
Cost (Vyr)
Cost ($/yr)
Cost (Vyr)
Cost (S/yr)
Cost {tfyr)
Cost (Vyr)
Alumina and Aluminum
310,000
14,000
810,000
35,000
1,500,000
64,000
Antimony
-
-
24,000
4,000
38,000
6,400
Beryllium
-
- ¦
19,000
9,300
350,000
180,000
Bismuth
-
-
10,000
10,000
22,000
22,000
Cadmium
•
-
53,000
27,000
570,000
280,000
Calcium
-
-
4,300
4,300
7,300
7,300
Coal Gas
-
-
-
-
220,000
220,000
Copper
10,000,000
1,000,000
10,000,000
1,000,000
10,030,000
1,000,000
Elemental Phosphorus
3,400,000
1,700,000
3,400,000
1,700,000
3,400,000
1,700,000
Fluorspar and Hydrofluoric Acid
.
-
52,000
17,000
84,000
28,000
Germanium
-
-
15,000
3,800
17,000
4,300
Lead
21,000,000
5,200,000
27,000,000
6,700,000
32,000,000
8,100,000
Magnesium and Magnesia from Brines
2,800
1,400
3,900
2,000
- 49,000
25,000
Mercury
-
-
680,000
97,000
1,800,000
260,000
Molybdenum, Ferromolybdenum, and
Ammonium Molybdate
16,000
1,400
16,000
1,400
Platinum Group Metals
-
4,600
1,500
11,000
3,700
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
46,000
23,000
57,000
28,000
Rare Earths
9,800
9,800
200,000
200,000
980,000
980,000
Rhenium
-
-
9,500
4,700
31,000
15,000
Scandium
-
.
(94,000)
(13,000)
44,000
6,300
Selenium
81,000
40,000
100,000
34,000
160,000
54,000
Synthetic Rutile
-
80,000
80,000
150,000
150,000
Tantalum, Columbium, and
Ferrocolumbium
170,000
85,000
130,000
67,000
130,000
67,000
Tellurium
-
.
12,000
5,800
40,000
20,000
Titanium arid Titanium Dioxide
76,000
38,000
240,000
34,000
380,000
55,000
Tungsten
-
(43,000)
(7,200)
73,000
12,000
Uranium
-
-
47,000
2,700
100,000
6,200
Zinc
1,500,000
490,000
2,400,000
790,000
2,700,000
890,000
Zirconium and Hafnium
-
-
100,000
50,000
320,000
160,000
Total
37.000,000
45,000,000
; 55,000,000
April 15,1997
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-25-
Exhibit 3-8
Option 3 Incremental Costs
Minimum Value Case
Expected Value Case
Maximum Value Case
Total
Avg, Fac.
Total
Avg. Fac.
Total
Avg. Fac.
Incremental
Incremental
Incremental
Incremental
Incremental
Incremental
Commodity
Cost (S/yr)
Cost (S/yr)
Cost (S/yr)
Cost ($/yr)
Cost (S/yr)
Cost ($/yr)
Alumina and Aluminum
310,000
14,000
810,000
35,000
1,500,000
64,000
Antimony
-
-
24,000
4,000
38,000
6,400
Beryllium
-
19,000
9,300
350,000
180,000
Bismuth
-
-
10,000
10,000
22,000
22,000
Cadmium
-
-
24,000
12,000
490,000
250,000
Calcium
-
-
1,400
1,400
1,400
1,400
Coal Gas
-
-
-
-
68,000
68,000
Copper
2,600,000
260,000
2,500,000
250,000
2,600,000
260,000
Elemental Phosphorus
480,000
240,000
480,000
240,000
480,000
240,000
Fluorspar and Hydrofluoric Acid
.
. -
52,000
17,000
84,000
28,000
Germanium
-
-
15,000
3,800
17,000
4,300
Lead
59,000
15,000
1,100,000
280,000
2,100,000
510,000
Magnesium and Magnesia from Brines
2,800
1,400
3,900
2,000
49,000
25,000
Mercury
-
190,000
27,000
520,000
74,000
Molybdenum, Ferromolybdenum, and
Ammonium Molybdate
16,000
1,400
16,000
1,400
Platinum Group Metals
: , -
.
4,600
1,500
11,000
3,700
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
46,000
23,000
57,000
28,000
Rare Earths
5,200
5,200
94,000
94,000
320,000
320,000
Rhenium
-
-
3,700
1,800
6,200
3,100
Scandium
-
.
(94,000)
(13,000)
44,000
6,300
Selenium
30,000
15,000
44,000
15,000
130,000
44,000
Synthetic R utile
-
.
80,000
80,000
150,000
150,000
Tantalum, Columbium, and
Ferrocoiumbium
170,000
86,000
130,000
67,000
130,000
67,000
Tellurium
--
-
12,000
5,800
40,000
20,000
Titanium and Titanium Dioxide
76,000
38,000
240,000
34,000
380,000
55,000
Tungsten
-
.
27,000
4,400
36,000
6,100
Uranium
-
•
47,000
2,700
100,000
6,200
Zinc
1,500,000
490,000
2,400,000
790,000
2,700,000
890,000
Zirconium and Hafnium
- •
-
100,000
50,000
320,000
160,000
Total
5200,000
8,400,000
13,000,000
April 15,1997
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-26-
Exhibit 3-9
Option 4 Incremental Costs
Minimum Value Case
Expected Value Case
Maximum Value Case
Total
Avg. Faa
Total
Avg. Fac.
Total
Avg, Fac.
Incremental
Incremental
Incremental
Incremental
Incremental
Incremental
Commodity
Cost (S/yr)
Cost (Vyr)
Cost (S/yr)
Cost (S/yr)
Cost (S/yr)
Cost (S/yr)
Alumina and Aluminum
32,000
1,400
32,000
1,400
32,000
1,400
Antimony
-
.
8,500
1,400
8,500
. 1,400
Beryllium
-
-
2,800
1,400
2,800
1,400
Bismuth
-
1,400
1,400
1,400
1,400
Cadmium
-
2,800
1,400
2,800
1,400
Calcium
-
-
1,400
1,400
1,400
1,400
Coal Gas
-
-
-
1,400
1,400
Copper
14,000
1,400
14,000
1,400
14,000
1,400
Elemental Phosphorus
2,800
1,400
2,800
1,400
2,800
1,400
Fluorspar and Hydrofluoric Acid
-
-
4,200
1,400
4,200
1,400
Germanium
-
-
5,600
1,400
5,600
1,400
Lead
5,600
1.400
5,600
1,400
5,600
1,400
Magnesium and Magnesia from Brines
2,800
1,400
2,800
1,400
2,800
1,400
Mercury
-
-
9,900
1,400
9,900
1,400
Molybdenum, Ferro molybdenum, and
Ammonium Motybdate
16,000
1,400
16,000
1,400
Platinum Group Metals
•
4,200
1,400
4,200
1,400
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
2,800
1,400
2,800
1,400
Rare Earths
1,400
1,400
1,400
1,400
1,400
1,400
Rhenium
-
2,800
1,400
2,800
1,400
Scandium
.
9,900
1,400
9,900
1,400
Selenium
2,800
1,400
4,200
1,400
4,200
1,400
Synthetic Ruffle
•
-
1,400
1,400
1,400
1,400
Tantalum, Columbium, and
Ferrocoiumbium
2,800
1,400
2,800
1,400
2,800
1,400
Tellurium
-
' ¦-
2,800
1,400
2,800
1,400
Titanium and Titanium Dioxide
2,800
1,400
9,900
1,400
9,900
1,400
Tungsten
-
.
8,500
1,400
8,500
1,400
Uranium
.
-
24,000
1,400
24,000
1,400
Zinc
4,200
1,400
4,200
1,400
4,200
1,400
Zirconium and Hafnium
- .
-
2,800
1,400
2,800
1,400
Total
71,000
190,000
190,000
April 15,1997
-------
one sector, coal gas, is expected to experience no cost changes. Finally, EPA projects that the scandium
and tungsten sectors will experience cost savings of $22,000 and $43,000, respectively.
On a per facility basis, average expected incremental costs range from a savings of $7,300
(tungsten) to an increase of $6,700,000 (lead). EPA projects that facilities in four sectors (14 percent)
will incur impacts in excess of $1,000,000 (copper, elemental phosphorus, lead, and zinc). Facilities in
only one other sector (three percent) are expected to have average impacts between $500,000 and
$600,000 (synthetic rutile), while facilities in another five sectors (17 percent) are projected to have
average impacts between $100,000 and $200,000 (alumina and aluminum; rare earths; tantalum
columbium and ferrocolumbium; titanium and titanium dioxide; tellurium, and zirconium and hafnium).
The average expected savings for facilities in the scandium and tungsten sectors are $3,100 and $7,200,
respectively.
Option 2
Under Option 2, EPA expects the total incremental cost to be $45,000,000, as shown in
Exhibit 3-7. Twenty-six of the industry sectors (90 percent) are projected to experience increased costs,
one (three percent) is expected to have no additional costs, and two (seven percent) are anticipated to see
cost savings. On a sector basis, incremental costs range from an expected savings of $94,000 (scandium)
to a cost increase of $27,000,000 (lead). Again, as was the case for Option 1, cost impacts fall
disproportionately on the lead sector; lead sector cost impacts account for sixty percent of total industry
impacts under this option.23 EPA expects four sectors (14 percent) to have total incremental costs greater
than $1,000,000 (copper, elemental phosphorus, lead, and zinc) and two (seven percent) to have total
costs between $500,000 and $800,000 (alumina and aluminum, and mercury). As with OpUooJ, only
one sector, coal gas, is expected to experience no cost changes. Finally, EPA expects that Hia feandium
and tungsten sectors will incur cost savings of $94,000 and $43,000, respectively.
On a per facility basis, average incremental costs range from a savings of $13,000 (scandium) to a
cost increase of $6,700,000 (lead). EPA expects facilities in three sectors (10 percent) to incur impacts in
excess of $1,000,000 (copper, elemental phosphorus, and lead) and facilities in one other sector (three
percent) to have cost increases of more than $700,000 (zinc). Facilities in one sector (rare earths) are
expected to incur average impacts of $200,000. Facilities in the remainder of the sectors (83 percent) are
expected to have average cost increases of less than $100,000, except for those in coal gas (no impacts),
scandium (savings of $ 13,000), and tungsten (savings of $7,200).
Option 3
Under Option 3, the total expected incremental cost is $8,400,000; these impacts are shown in
Exhibit 3-8. Twenty-seven of the industry 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
$94,000 (scandium) to an increase of $2,500,000 (copper). EPA expects three sectors (10 percent) to
experience total incremental costs greater than $1,000,000 (copper, lead, and zinc) and one (three percent)
to have total costs of more than $800,000 (alumina and aluminum). The one sector with no expected
costs is coal gas. Finally, EPA expects that the only sector to experience cost savings will be the
scandium sector ($94,000).
23 See previous footnote.
April 15,1997
-------
On a per facility basis, average incremental expected costs range from a savings of $ 13,000
(scandium) to an increase of $790,000 (zinc). Facilities in three other industry sectors (10 percent) arc
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) arc-expected to have cost increases of less
than $100,000, except for coal gas (no impacts) and scandium (savings of $13,000).
Option 4
Under Option 4, the total expected incremental cost to industry is $190,000, significantly lower
than for the other options. These impacts are shown in Exhibit 3-9. Twenty-eight sectors are projected to
experience increased costs, with one sector experiencing no change in costs. Expected incremental costs
range from zero (coal gas) to $32,000 (alumina and aluminum). Four sectors under this option are
expected to experience costs of more than $10,000 (alumina and aluminum; copper, molybdenum,
feiTomolybdenum, and ammonium molybdate; and uranium).
On a per facility basis, average incremental expected costs range from zero (coal gas) to $1,400
for all other sectors. The reason for the uniformity in per facility costs is that 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. For example, facility
operators will continue to store materials to be recycled in unlined land-based units, so no new costs
attributable to storage are expected.
3.2.2 Economic Impact Analysis Results
As described above, EPA conducted three ratio analyses comparing regulatory costs to the
following three financial indicators: (1) value of shipments, (2) value added, and (3) gross profits. Data
were available to determine the ratio of regulatory costs to value of shipments for all 29 industry sectors
affected. However, data were available for only 16 industry sectors to determine the ratio using value
added and for only six industry sectors to determine the ratio using gross profits. This section presents the
results of the three analyses.
Ratio of Regulatory Costs to Value of Shipments
Exhibits 3-10 through 3-13 present the results of the value of shipments analysis.
Economic impacts expressed as a ratio of regulatory costs to the value of shipments suggest that
Options 1 and 2 impose the most significant impact on affected industries and Option 4 imposes the least
impact. Option 1 imposes significant cost impacts (defined as 3 percent of the value of shipments for the
sake of this analysis) on five of the 29 industrial sectors (seventeen percent of the affected sectors) in the
expected value case. EPA projects significantly affected sectors to include cadmium (6 percent impact),
lead (13 percent), mercury (176 percent), pyrobitumens, mineral waxes, and natural asphalt (56 percent),
and selenium (5 percent). The remaining 24 sectors (83 percent of all affected sectors) are expected to
experience economic impacts of three percent or less.
Option 2 would impose burdens very similar to those estimated for Option 1. Like Option 1,
Option 2 imposes significant cost impacts on five of the 29 industrial sectors in the expected value case.
As was the case for Option 1 as well, EPA expects significantly affected sectors to include cadmium (5
percent), lead (13 percent), mercury (176 percent), pyrobitumens, mineral waxes, and natural asphalt (18
April 15, 1997
-------
Exhibit 3-10
Option 1 Impacts
Sector
Production
MT
Price
S/MT
Value of
Shipments
Incremental
Sector Cost
$
Economic Impact
(percent ol Value of Shipments)
$
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.700.000
1.168
4,321.600,000
1.400.000
2.400.000
2.900.000
0.03
0.06
0.07
Antimony
18.000
1.764
31,752,000
.
55.000
81.000
0.00
0.17
0.26
Beryllium
159
352.640
56,069.760
.
40.000
800,000
0.00
0.07
1.43
Bismuth
1.100
7.824
8.606.400
-
39.000
72.000
0.00
0.45
0.84
Cadmium
• 1.050
992
1.041.600
.
63.000
2.500.000
0.00
6.05
240.02
Calcium
1.200
4.605
5.526,000
.
4.300
7.300
0.00
0.08
0.13
Coal Gas
170.000.000
-
-
220.000
0,00
0.00
0.13
Copper
1.770.000
2.029
3.591.330.000
10.000.000
10.000.000
10.000.000
0.28
0.28
0.28
Elemental Phosohorus
311.000
1.833
570.063.000
3.400.000
3.400.000
3.400.000
0,60
0.60
0.60
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
.
190.000
330.000
0.00
1.64
2.85
Germanium
10
1.060.000
10.600.000
39.000
45.000
O.OO
0.37
0.42
Lead
290.000
706
204.740.000
21.000.000
27.000,000
32.000.000
10.28
13.19
15.63
Maaneshim and Maanesia from Brines
145.000
3.219
468.755.000
2.800
3.100
240.000
0.00
0.00
0.05
Mercurv
70
5.512
385.840
.
680.000
1.800.000
0.00
176.24
466.51
Molybdenum. Farromolvtxlenum and Ammonium Molvbdale
239.864.579
.
16.000
16.000
0.00
0.01
0.01
Platinum Group Metals
53.203,971
-
5.900
38.000
0.00
0.01
0.07
Pvrobitumans. Mineral Waxes, and Natural Asphalt
10.000
25
250.000
.
140.000
170.000
0.00
56.00
68.00
Rare Earths
57.372,120
9.800
200.000
1.100.000
_ 0.02
0.35
1.92
Rhenium
5
1.200.000
6.000.000
-
9.500
31.000
0.00
0.16
0.52
Scandium
25
1.500.000
37.500,000
-
(22,000)
170.000
0.00
-0.06
0.46
Selenium
250
11.246
2.811.500
81.000
140.000
300.000
2.88
4.98
10.67
Synthetic Rutile
140.000
345
48.300.000
-
560.000
1.000.000
0.00
1.16
2.07
Tantalum. Columbium, and Ferrocolumblum
60.897.400
540.000
390.000
390.000
0.89
0.64
0.64
Tellurium
60
59.508
3.570.480
.
150.000
180.000
0.00
4.20
5.04
Titanium and Titanium Dioxide
2.516.300.000
170.000
920.000
1.400.000
0,01
0.04
0.06
Tunosten
9.406
40
376.240
.
<43.000!
73.000
0.00
-11.43
19.40
Uranium
40.734.000
.
220.000
1,100.000
0.0C
0.54
2.70
Zinc
505.000
1.014
512.070.000
9.700.000
11.000.000
13.000.000
1.89
2.15
2.54
Zirconium arid Hafnium
379.899.000
'
210.000
1,200.000
0.00
0.06
0.32
Total
46,000,000
58,000,000
75,000,000
-------
Exhibit 3-11
Option 2 Impacts
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
3.700.000
1.168
4.321.600.000
310.000
810.000
1.500.000
0.01
0.02
0.03
Antimony
18.000
1.764
31.752,000
24.000
38.000
0.00
0.08
0.12
Beryllium
159
352.640
56.069.760
19.000
350.000
0.00
0.03
0.62
Bismuth
1.100
7.824
8.606.400
10.000
22.000
' 0.00
0.12
0.26
Cadmium
1.050
992
1.041.600
53.000
570.000
0.00
5.09
54.72
Calcium
1.200
4.605
5.526.000
4.300
7.300
0.00
0.08
0.13
Coal Qas
170.000.000
.
220.000
0.00
0.00
0.13
Copper
1.770.000
2.029
3.591.330.000
10.000.000
10.000.000
10.000.000
0.28
0.28
0.28
Elemental PhosDhorus
311.000
1.833
570.063.000
3.400.000
3.400.000
3.400.000
0.60
0.60
0.60
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
-
52.000
84.000
0.00
0.45
0.73
Germanium
10
1.060.000
10.600.000
-
15.000
17.000
0.00
0.14
0.16
Lead
290.000
706
204.740.000
21.000.000
27.000.000
32.000.000
10.26
13.19
15.63
Maanesium and Maanesla from Brines
145.000
3.219
466.755.000
2.800
3.900
49.000
0.00
0.00
0.01
Mercurv
70
5.512
385.840
-
680.000
1.800.000
0.00
176.24
466.51
Molybdenum. Ferromolvbdenum and Ammonium Molvbdate
239.864.579
-
16.000
16.000
0.00
0.01
0.01
Platinum Group Metals
53.203.971
-
4.600
11.000
0.00
0.01
0.02
Pyrobitumens. Mineral Waxes, and Natural Asphalt
10.000
25
250.000
-
46.000
57.000
0.00
18.40
22.80
Rare Earths
57.372.120
9.800
200.000
980.000
0.02
0.35
1.71
Rhenium
5
1.200.000
6.000.000
9.500
31.000
0.00
0.16
0.52
Scandium:
25
1.500.000
37.500.000
-
(94.000)
44.000
0.00
•0.25
0.12
Selenium
250
11.246
2.811.500
81.000
100.000
160.000
2.88
3.56
5.69
Synthetic Rutile
140.000
345
48.300.000
-
80.000
150.000
0.00
0.17
0.31
Tantalum. Columbium. and Ferrocolumbium
60.897.400
170.000
130.000
130.000
0.28
0.21
0.21
Tellurium
60
59.508
3.570.480
-
12.000
40.000
0.00
0.34
1.12
Titanium and Titanium Dioxide
2.516.300.000
76.000
240.000
380.000
0.00
0.01
0.02
Tunqsten
9.406
40
376.240
-
(43.000)
73.000
0.00
-11.43
19.40
Uranium
40.734.000
-
47.000
100.000
0.00
0.12
0.25
Zinc
505.000
1.014
512.070.000
1.500.000
2.400.000
2.700.000
0.29
0.47
0.53
Zirconium and Hafnium
379.899.000
-
100.000
320.000
0.00
0.03
0.08
Total
37.000.000
45,000.000
55,000,000
-------
Exhibit 3-12
Option 3 Impacts
Sactor
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
3.700.000
1.168
4.321.600.000
310,000
810.000
1.500.000
0.01
0.02
0.03
Antimony
18.000
1.764
31.752.000
-
24.000
38.000
0.OQ
0.08
0.12
Beryllium
159
352.640
S6.069.760
-
19.000
350.000
0.00
0.03
0.62
Bismuth
1.100
7.824
6.606.400
•
10.000
22.000
0.00
0.12
. 0.26
Cadmium
1.050
992
1.041.600
.
24.000
490.000
0.0C
2.30
47.04
Calcium
1.200
4.605
5.526.000
-
1.400
1.400
0.00
0.03
0.03
Coal Gas
170.000.000
• -
-
68,000
0,00
0.00
0.04
Copper
1.770.000
2.029
3.591.330.000
2.600.000
2.500.000
2.600.000
0.07
0.07
0.07
Elemental Phosohorus
311.000
1.833
570.063.000
480.000
480.000
480.000
0.08
0.08
0.08
Fluorspar and Hydrofluoric Acid
60.000
193
11.S80.000
-
52.000
84.000
0.00
0.45
0.73
Germanium
10
1.060.000
10.600.000
.
15.000
17.000
0.00
0.14
0.16
Lead
290.000
706
204.740.000
59.000
1.100.000
2.100.000
0.03
0.54
1.03
Maoneslum and Maanesla from Brines
145.000
3.219
466.7SS.000
2.800
3.900
49.000
0.00
0.00
0.01
Mercury
70
5.512
38S.S40
-
190.000
520.000
0.00
49.24
134.77
Molybdenum. FerramoMxisnum and Ammonium MohMate
239.864,579
.
16.000
16.000
0.00
0.01
0.01
Platinum Group Metals
53.203.971
.
4.600
11.000
0.00
0.01
0.02
Pvrobltumens. Mineral Waxes, and Natural Asphalt
10.000
25
250.000
.
46.000
57.000
0.00
18.40
22.80
Rare Earths
57.372.120
5.200
94.000
320.000
0.01
0.16
0.56
Rhenium
5
1.200.000
6.000.000
-
3.700
6,200
0.00
0.06
0.10
Scandium
25
1.500.000
37.500.000
.
(94.000)
44.000
0.00
-0.25
0.12
Selenium
250
11.246
2.811.500
30.000
44.000
130.000
1.07
1.57
4.62
Synthetic Rutila
140.000
345
48.300.000
.
80.000
150.000
0.00
0.17
0.31
Tantalum. Columblum. and Ferrocolumbium
60.897.400
170.000
130.000
. 130.000
0.28
0.21
0.21
Tellurium
60
59.508
3.570.480
-
12.000
40.000
0.00
0.34
1.12
Titanium and Titanium Dioxide
2.516.300.000
76.000
240,000
380.000
0.00
0.01
0.02
Tungsten
9.406
40
376.24a
.
27.000
36.000
0.00
7.18
9.57
Uranium
40.734.0CX)
.
47.000
100.000
0.00
0.12
0.25
Zinc
505.000
1.014
512.070.000
1.500.000
2.400.000
2.700.000
0.29
0.47
0.53
Zirconium and Hafnium
379.899.000
.
100.000
320.000
-o.od
0.03
0.08
Total
5,200.000
8.400,000
13.000,000
-------
Exhibit 3-13
Option 4 Impacts
Sector
Production
MT
Price
$/MT
Value of
Shipments
Incremental
Sector Coat
$
Economic Impact
(percent of Value of Shipments)
$
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.700.000
1.168
4.321.600.000
• 32.000
32.000
32.000
0.00
0.00
0.00
Antimony
18.000
1.764
31.752.000
-
8.500
8.500
0.00
0.03
0.03
Batyllium
159
352.640
58.069.760
.
2.800
2.800
0.00
0.00
0.00
Bismuth
1.100
7.824
8.606.400
.
1.400
1.400
0.00
0.02
0.02
Cadmium
1,050
992
1,041.600
.
2,800
2,800
0.00
0.27
0.27
Calcium
1.200
4.605
5.526.000
.
1.400
1.400
0.00
0.03
0.03
Coal Gas
170.000.000
-
-
1.400
0.00
0.00
0.00
Copper
1,770.000
2.029
3.591.330.000
14.000
14,000
14.000
0.00
0.00
0.00
Elemental Phosphorus
311.000
1.833
570,063.000
2.800
2,800
2.800
0.00
0.00
0.00
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
.
4.200
4.200
0.00
0.04
0.04
Germanium
10
1.060.000
10.600.000
.
5.600
5.600
o.oc
0.05
0.05
Lead
290.000
706
204.740.000
5.600
5,600
5.600
0.00
0.00
0.00
Magnesium and Maanesla from Brines
145.000
3.219
466.755.000
2.800
2.800
2.800
0.00
0.00
0.00
Mercurv
70
5.512
385.840
.
9.900
9.900
0.00
2.57
. 2.57
Molybdenum. Ferromotvbdenum and Ammonium Molvbdate
239,864.579
.
16.000
-- 16.000
0.00
0.01
0.01
Platinum Group Metals
53.203.971
-
4.200
4.200
0.00
0.01
0.01
Pvrobihjmens. Mineral Waxes, and Natural Asphalt
10.000
25
250.000
.
2.800
2.800
0.00
1.12
1.12
flare Earths
57.372.120
1.400
1.400
1.400
o.oc
0,00
0.00
Rhenium
5
1.200.000
6.000.000
-
2.800
2.800
0.00
0.05
0.05
Scandium
25
1.500.000
37.500.000
.
9.900
9.900
0.00
0.03
0.03
Selenium
250
11.246
2.811.500
2.800
4.200
4.200
0.10
0.15
0.15
Synthetic Rutlle
140.000
345
48.300.000
-
1.400
1.400
0.00
0.001
0.00
Tantalum. Coiumbium. and Ferrocolumbium
60.897.400
2.800
2.800
• 2.800
0.00
0.00
0.00
Tellurium
60
59.508
3.570.480
-
2.800
2.800
0.00
0.08
0.08
Titanium and Titanium Dioxide
2.516.300.000
2.800
9.900
9.900
0.00
0,00
0.00
Tunasten
9.406
40
376.240
.
8.500
8.500
0.00
2.26
2.26
Uranium
40.734.000
.
24.000
24.000
0.0C
0.06
0.06
2nc
505.000
1,014
512.070.000
4.200
4.200
4.200
0.00
0.00
0.00
Zirconium and Hafnium
379.899.000
-
2.800
2,800
o:oo
0.00
0.00
Total
71.000
190,000
190,000
-------
percent), and selenium (3.5 percent). The remaining 24 sectors (83 percent) are expected to experience
economic impacts between zero and three percent. Note that the impact of Option 2, expressed as a
percentage of the value of shipments, is nearly the same under Options 1 and 2.
Option 3 imposes significantly smaller impacts across all sectors. Significant impacts are
expected for only three sectors (ten percent of the affected sectors) in the expected value case. These
sectors are: mercury (49 percent), pyrobitumens, mineral waxes, and natural asphalt (18 percent), and
tungsten (7 percent). In addition, fourteen sectors are expected to realize negative impacts of less than
one tenth of a percent under this option. The remaining 12 sectors (41 percent of the affected sectors) are
expected to experience economic impacts between one tenth of a percent and three percent
Finally, Option 4 is projected to impose the lowest cost burden on affected industrial sectors of
any of the options. EPA estimates that no sectors would experience significant impacts under Option 4.
The most heavily affected sector under this option would be the mercury sector (approximately 2.5
percent), and the second most affected sector would be the tungsten sector (approximately 2 percent).
Impacts would be negligible for most other sectors; 24 of the 29 sectors would experience an impact of
less thai one tenth of a percent.
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, magnesium, molybdenum, titanium, and zinc. Plants
in other sectors (e.g., calcium, platinum group metals) 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 to high incremental waste management costs and low commodity production rates, a low
commodity price, or both. Prominent examples in this category include cadmium, selenium, and
particularly, pyrobitumens, mineral waxes, and natural asphalt. It is worthy of note, however, that several
of these 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 die 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 3-14 displays the relationships between some of these sectors and their
larger associated commodity production operation(s).
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 Exhibits 3-
15 through 3-18.
April 15, 1997
-------
-34-
Exhibit 3-14
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
Analysis of costs as a percentage of value added indicates that as with cost impacts and other
economic impacts, Option 1 is the most burdensome and Option 4 is the least burdensome. For the sake
of this analysis, EPA defined significant economic impacts as greater than 10 percent For Option .1, EPA
anticipates that five of the 16 industry sectors (31 percent of the sectors included in this analysis) will be
significantly affected (lead, cadmium, selenium, tellurium, and zinc). Under Option 2, three of the 16
sectors (19 percent of the sectors analyzed) are expected to be significantly affected (lead, cadmium and
selenium). EPA estimates that Option 3 will significantly impact the cadmium and selenium sectors (13
percent of the sectors analyzed). Finally, EPA expects Option 4 would result in no economic impacts for
any of the 16 sectors examined.
Ratio of Regulator}' Costs to Profits
Comparing regulatory costs to profits allows one to estimate how the costs of regulations will
affect an industry's bottom line, incremental costs that exceed a company's or industry's profits over an
extended period generally will result in facility closures and exit from the industry in question. EPA
obtained limited data on profits for five industry sectors.
Results of the screening level economic impact analysis using profits data are presented in
Exhibits 3-19 through 3-22. None of the five industry sectors for which data were available are projected
to have severe cost impacts (defined as costs that were greater than estimated industry profits) under any
option. In fact, impacts exceed one percent in the expected value case only for the copper sector and only
under Options 1 and 2. Even under the maximum value case, impacts exceed five percent only for the
beryllium sector under Option 1. The Agency recognizes the limitations inherent in this approach,
principally the likelihood that the reported gross income (before tax) for the companies comprising the
five sector sample includes earnings from activities that may be unaffected by today's proposal, and
therefore, may be overestimated for purposes of analyzing economic impacts.
April 15,1997
-------
Exhibit 3-15
Option 1 Impacts (Value Added Analysis)
Incremental Sector Cost
Economic Impact
- $
(Percent of Value Added)
Sector
Estimated Value Added
Minimum
Expected
Maximum
Minimum
Exoected
Maximum
Alumina and Aluminum
1,609,800,000
1,400,000
2,400,000
2,900,000
0.1%
0.1%
0.2%
Antimony
3,381,146
-
55,000
81,000
0.0%
1.6%
2.4%
Beryllium
5,970,650
-
40,000
800,000
0.0%
0.7%
13.4%
Bismuth
916,462
-
39,000
72,000
0.0%
4.3%
7.9%
Cadmium
110,916
-
63,000
2,500,000
0.0%
56.8%
2254.0%
Copper
947,900,000
10,000,000
10,000,000
10,000,000
1.1%
1.1%
1.1%
Germanium
1,128,753
-
39,000
45,000
0.0%
3.5%
4.0%
Lead
21,801,962
'21,000,000
27,000,000
32,000,000
96.3%
123.8%
146.8%
Magnesium and Magnesia from Brines
49,702,916
2,800
3,100
240,000
0.0%
0.0%
•0.5%
Platinum Group Metals
5,665,483
-
5,900
38,000
0.0%
0.1%
0.7%
Rhenium
638,917
-
9,500
31,000
0.0%
1.5%
4.9%
Selenium
299,386
81,000
140,000
300,000
27.1%
46.8%
100.2%
Tellurium
380,206
-
150,000
180,000
0.0%
39.5%
47.3%
Titanium and Titanium Dioxide
267,950,952
170,000
920,000
1,400,000
0.1%
0.3%
0.5%
Zinc
54,528,333
9,700,000
11,000,000
13,000,000
17.8%
20.2%
23.8%
Zirconium and Hafnium
40.453.960
210.000
1.200.000
0.0%
0.5%
3.0%
-------
Exhibit 3-16
Option 2 Impacts (Value Added Analysis)
Incremental Sector Cost Economic Impact
$ (Percent of Value Added)
Sector
Estimated Value Added
Minimum
ExDected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
1,609,800,000
310,000
810,000
1,500,000
0.0%
0.1%
0.1%
Antimony
3,381,146
-
24,000
38,000
0.0%
0.7%
1.1%
Beryllium
5,970,650
-
19,000
350,000
0.0%
0.3%
5.9%
Bismuth
916,462
-
10,000
22,000
0,0%
1.1%
2.4%
Cadmium
110,916
-
53,000
570,000
0.0%
47.8%
513.9%
Copper
947,900,000
10,000,000
10,000,000
'10,000,000
1.1%
1.1%
1.1%
Germanium
1,128,753
-
15,000
17,000
0.0%
1.3%
1.5%
Lead
21,801,962
, 21,000,000
27,000,000
32,000,000
96.3%
123.8%
146.8%
Magnesium and Magnesia from Brines
49,702,916
2,800
3,900
49,000
0.0%
0.0%
0.1%
Platinum Group Metals
5,665,483
¦ -
4,600
11,000
0.0%
0.1%
0.2%
Rhenium
638,917
-
9,500
31,000
0.0%
1.5%
4.9%
Selenium
299,386
81,000
100,000
160,000
27.1%
33.4%
53.4%
Tellurium
380,206
-
12,000
40,000
0.0%
3.2%
10.5%
Titanium and Titanium Dioxide
267,950,952
76,000
240,000
380,000
0.0%
0.1%
0.1%
Zinc
54,528,333
1,500,000
2,400,000
2,700,000
2.8%
4.4%
5.0%
Zirconium and Hafnium
40.453.960
-
100.000
320.000
0.0%
0.2%
0.8%
-------
Exhibit 3-17
Option 3 Impacts (Value Added Analysis)
Incremental Sector Cost Economic Impact
$ (Percent of Value Added)
Sector
Estimated Value Added
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
1,609,800,000
310,000
810,000
1,500,000
0.0%
0.1%
0.1%
Antimony
3,381,146
-
24,000
38,000
0.0%
0.7%
1.1%
Beryllium
5,970,650
-
19,000
350,000
0.0%
0.3%
5.9%
Bismuth
916,462
-
10,000
22,000
0.0%
1.1%
2.4%
Cadmium
110,916
-
24,000
490,000
0.0%
21.6%
441.8%
Copper
947,900,000
2,600,000
2,500,000
2,600,000
0.3%
0.3%
0.3%
Germanium
1,128,753
'
15,000
17,000
0.0%
1.3%
1.5%
Lead
21,801,962
59,000
1,100,000
2,100,000
0.3%
5.0%
9.6%
Magnesium and Magnesia from Brines
49,702,916
2,800
3,900
49,000
0.0%
0.0%
0.1%
Platinum Group Metals
5,665,483
-
4,600
11,000
0.0%
0.1%
0.2%
Rhenium
638,917
-
3,700
6,200
0.0%
0.6%
1.0%
Selenium
299,386
30,000
44,000
130,000
10.0%
14.7%
43.4%
Tellurium
380,206
-
12,000
40,000
0.0%
3.2%
10.5%
Titanium and Titanium Dioxide
267,950,952
76,000
240,000
380,000
0.0%
0.1%
0.1%
Zinc
54,528,333
1,500,000
2,400,000
2,700,000
2.8%
4.4%
5.0%
Zirconium and Hafnium
40.453.960
-
100.000
320.000
0.0%
0.2%
0.8%
-------
Exhibit 3-18
Option 4 Impacts (Value Added Analysis)
Incremental Sector Cost Economic Impact
$ (Percent of Value Added)
Sector
Estimated Value Added
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
1,609,800,000
32,000
32,000
32,000
0.0%
0.0%
0.0%
Antimony
3,381,146
.
8,500
8,500
0.0%
0.3%
0.3%
Beryllium
5,970,650
-
2,800
2,800
0.0%
' 0.0%
0.0%
Bismuth
916,462
-
1,400
1,400
0.0%
0.2%
0,2%
Cadmium
110,916
-
2,800
2,800
0.0%
2.5%
2.5%
Copper
947,900,000
14,000
14,000
14,000
0.0%
0.0%
0.0%
Germanium
1,128,753
-
5,600
5,600
0.0%
0.5%
0.5%
Lead
21,801,962
5,600
5,600
5,600
0.0%
0.0%
0.0%
Magnesium and Magnesia from Brines
49,702,916
2,800
2,800
2,800
0.0%
0.0%
0.0%
Platinum Group Metals
5,665,483
-
4,200
4,200
0.0%
0.1%
0.1%
Rhenium
638,917
-
2,800
2,800
0.0%
a.4%
0.4%
Selenium
299,386
2,800
4,200
4,200
0.9%
1.4%
1.4%
Tellurium
380,206
-
2,800
2,800
0.0%
0.7%
0.7%
Titanium and Titanium Dioxide
267,950,952
2,800
9,900
9,900
0.0%
0.0%
0.0%
Zinc
54,528,333
4,200
4,200
4,200
0.0%
0.0%
0.0%
Zirconium and Hafnium
40.453.960
-
2.800
2.800
0.0%
0.0%
0.0%
-------
- 39-
Exhibit 3-19
Option 1 Impacts (Profits Analysis)
Sector
Estimated
Profits
$
Incremental
Sector Cost
$
Economic Impact
(Percent of Profits)
Minimum
Expected
Maximum
Minimum
Expected
Maximu
Alumina and Aluminum
720,221,231
1,400,000
2,400,000
2,900,000
0.19
0.33
0.40
Beryllium
14,904.254
0
40,000
800,000
0.00
0.27
5.37
Copper
956,454,882
10,000,000
10,000,000
10,000,000
1.05
1.05
1.05
Platinum Group Metals
8,229,711
-
5,900
38,000
0.00
0.07
0.46
Titanium and Titanium Dioxide
1.480.901.274
170.000
920.000
1.400.000
0.01
0.06
0.09
Exhibit 3-20
Option 2 Impacts (Profits Analysis)
Sector
Estimated
Profits
S
Incremental
Sector Cost
$
Economic Impact
(Percent of Profits)
Minimum
Expected
Maximum
Minimum
Expected
Maximu
Alumina and Aluminum
720.221,231
310,000
810,000
1,500,000
0.04
0.11
0.21
Beryllium
14,904,254
0
19,000
350,000
0.00
0.13
2.35
Copper
956,454,882
10,000,000
10,000,000
10,000,000
1.05
1.05
1.05
Platinum Group Metals
8,229,711
-
4,600
11,000
0.00
0.06
0.13
Titanium and Titanium Dioxide
1.480.901.274
76.000
240.000
380.000
0.01
0.02
0.03
Exhibit 3-21
Option 3 Impacts (Profits Analysis)
Sector
Estimated
Profits
$
Sector Cost
$
Economic Impact
(Percent of Profits)
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
720,221,231
310,000
810,000
1,500,000
0.04
0.11
0.21
Beryllium
14,904,254
0
19,000
350,000
0.00
0.13
2.35
Copper
956,454,882
2,600,000
2,500,000
2,600,000
0.27
0.26.
0.27
Platinum Group Metals
8X29,711
-
4,600
11,000
0.00
0.06
0.13
Trtanium and Titanium Dioxide
1.480.901.274
76.000
240.000
380.000
0.01
0.02
0.03
3 J 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 (LDRs).
Approximately 22 small businesses owning approximately 24 facilities may be affected by the rule. The
first subsection describes the methodology EPA ufed in conducting the analysis. The second subsection
presents the results of the analysis. In brief, the analysis concludes that no significant small business
April 15,1997
-------
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Exhibit 3-22
Option 4 Impacts (Profits Analysis)
Sector
Estimated
Profits
$
Sector Cost
$
Economic Impact
(Percent of Profits)
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
720,221,231
32,000
32,000
32,000
0.00
0.00
0.00
Beryllium
14,904,254
0
2,800 .
2,800
, 0.00
0.02
0.02
Copper
956,454,882
14,000
14,000
14,000.
0.00
0.00
0.00 ¦
Platinum Group Metals
8,229,711
-
4,200
4,200
0.00
0.05
0.05
Titanium and Titanium Dioxide
1.480.901.274
2.800
9.90(5
9.900
0.00
0.00
0.00
impacts are anticipated as a result of the rule and, therefore, preparation of a formal Regulatory Flexibility
Analysis is unnecessary.
33.1 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 rule being analyzed, then a formal Regulatory Flexibility
Analysis may be required.
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. EPA does 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.
April 15,1997
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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 1995, 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). Approximately 22 small businesses owning approximately 24
facilities may be affected by the rulemaking.
(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.) EPA obtained data from a variety
of public and commercial sources.
(3) Obtain Compliance Cost Data For Each 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 2 under the assumed baseline, fa 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
33.2 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 and comparing the
ratio to a threshold of three percent. Approximately 22 small businesses owning approximately 24
facilities may be affected by the rale. These facilities fall into the following sectors: alumina/aluminum,
antimony, cadmium, coal gas, germanium, fluorspar/hydrofluoric acid, molybdenum/ferromolybdenum/
ammonium molybdate, platinum group metals, pyrobitumens/mineral waxes/natural asphalts, scandium,
tungsten, and/or zinc. EPA's analysis finds that the proposed rule would not result in a significant impact
April 15,1997
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on a substantial number of small mineral processing entities.24 In fact the proposed rule is unlikely to
result in a significant impact on any small mineral processing entities, and some small business owners
would incur cost savings under the option. 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 are unlikely, as discussed below:
• One company processing hydrofluoric acid is expected to incur annual costs of only $17,000.
Therefore, this company will not incur significant impacts unless it has sales of less than
$566,667 (i.e., $17,000/0.03) or, using the alternate threshold of one percent, less than
$1,700,000 (i.e., $17,000/0.01). Because higher sales can be expected for a sustained
business venture conducting mineral processing,25 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 $2,700.
Thus, if any of the 17 facilities are owned by small business concerns, significant small
business impacts would arise only for those concerns with sales of less than $90,000 (i.e.,
$2,700/0.03) or, using the alternate threshold of one percent, less than $270,000 (i.e.,
$2,700/0.01 ).26 Assuming the total sales of a small business owning a uranium processing
facility are at least as great as the lowest confirmed sales figure ($2,100,000) among all other
small businesses in the analysis, then no impacts arise in the uranium sector under either
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")Jncur significant impacts. This corresponds to five entities
(two under the alternative threshold), and seems highly unlikely.27
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.
24 This analysis was conducted based on the average costs to facilities in a given sector under Option 2.
The findings, however, also apply to the less costly options (option 3 and option 4).
25 For example, the lowest confirmed sales figure among all other small businesses in the analysis
exceeds $2 million
26 This assumes that only one uranium processing facility is owned per small business concern.
27 Even if this had occurred, however, it would not necessarily constitute a substantial number of
entities. Such a determination might also require consideration of other factors, such as the sectors in
which the'entities operate and the absolute number of facilities affected.
April 15, 1997
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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 human exposures and reduced risks to human health.
This section describes the approaches that have been taken to evaluating risks to human health associated
with waste disposal and with storage of recycled materials. Risks have been assessed under the modified
prior treatment baseline, and reductions in risks that may be associated with the various regulatory options
are also identified.
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 rale analyzes baseline assumptions and regulatory options that are to some degree different from those
currently being considered. Most significantly, the modified prior treatment baseline has only quite,
recently become the focus of risk assessment efforts while the initial focus of the risk and benefit
assessment was the no prior treatment baseline.
In evaluating the results of these analyses, it is important to understand that all of the risk
assessment activities described below employ screening methodologies, and do not provide definitive
information about health risks or risk reduction benefits for actual exposed populations. The screening
level methodologies are not site-specific, and they employ generic assumptions about facility
characteristics, exposure pathways, receptors, and receptor behavior. Exposed populations living near
actual mineral processing facilities have not been identified or enumerated, and the applicability of the
various exposure pathways that are evaluated to these populations has not been verified. Cancer risks and
noncancer hazards are calculated for hypothetical individuals under the generic exposure conditions. The
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.
A brief summary of the risk and benefits assessment efforts is provided below to show the
relationships between the risk assessments for the various activities, baselines, and regulatory options. The
major risk assessment efforts have included (in chronological order):
Risk and Benefits Assessment for the Waste Disposal Using Non-Constituent Specific DAFs
This effort involved the development of risk and risk reduction estimates for the wasted
(unrecycled) portions of the mineral processing waste streams. Data regarding constituent concentration?
were available for 38 waste streams, and the risk and benefits assessment were limited to those streams.
The 28 streams comprised approximately 80 percent, by volume, of the total wastes generated by the
mineral processing industry. The assessment was also limited only to health risks arising from
groundwater exposures. Risks were estimated for the no prior treatment baseline (which was then
considered to be a prudently conservative assumption, reasonable representative of current practice), and
April 15, 1997
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risk reductions were estimated for all three of the regulatory options that were then being considered.
Since under all three options (and under all four current options), treatment to UTS levels would be
required prior to disposal of any of the waste streams, the benefit calculations for all three options were the
same.
In this initial analysis, groundwater exposure concentrations were calculated using dilution-
attenuation factor values (DAPs) 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," which are the
estimated numbers of facilities at which given risk reduction would be achieved. Through imposition of
the LDRs. The results of this assessment are summarized in the October 1995 Draft Mineral Processing
LDRsRIA.
Waste Disposal Risk and Benefits Assessment Using Sample-Specific Concentration
Estimates
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. These analyses indicated
the use of mean constituent concentration values obscured important variations in constituent
concentrations within some of the waste streams, as well as variations in the risks that might be associated
with the management of these streams. As a result of this finding, 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. Thus, risk reduction benefits were again the same under all three options, except that one option
would have excluded two spent materials streams from regulation under the no prior treatment baseline.
This analysis was presented in the December 1995 RIA.
Waste Disposal Risk and Benefits Assessment Using Constituent-Specific DAFs
For this analysis, EPA 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 also described in more detail in Appendix A of this
RIA. •
Risk Assessment for the Storage of Recycled Streams
The latest risk assessment effort, discussed in this document, is the first which has focused 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, EPA 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. Analogous to the methods
used in the August RIA, EPA derived groundwater DAF values specifically for land-based recycling units,
and specifically for each waste constituent. EPA assessed non-groundwater risks associated with the
April 15,1997
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-45-
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 H.
No quantitative benefits assessment has been performed for the stored materials. This is .because,
under three of the four regulatoiy options currently being considered, recycled materials would be stored in
tanks, containers, or buildings (TCBs), and no data or satisfactory models are available which would allow
the estimation of risks associated with these management units. Under Option 4, it is again 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.
Thus, for recycled materials management, EPA has estimated only baseline risks. These 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. The degree
of potential risk reduction associated with the various options differs only in that recycling of secondary
materials through Bevill units would not be allowed under Options 1 and 2.
In the discussion that follows, the primary focus will be an risks relative to the modified prior
treatment baseline, but the risk and benefits assessment for waste disposal, relative to no prior treatment is
also discussed, as it provides information useful in the estimation of disposal risks and risk reductions
under the modified prior treatment baseline.
4.1.2 Risk and Benefits Assessment Methods for Nonrecycled Materials
As noted in the previous section, all of the quantitative risk and benefits assessment work
performed by EPA for the non-recycled portion of the mineral processing waste streams has focused on the
management of these wastes under the no prior treatment baseline. Thus, the baseline risks have been
assessed for final disposal of untreated materials in unlined units, and regulatory benefits have been
evaluated in terms of the risk reduction achievable by initial treatment of all streams to UTS levels prior to
disposal.
Under the modified prior treatment baseline, however, which EPA has recently identified as being
most representative of current practice, it is assumed that all wastes would be stabilized to comply with TC
regulatory levels prior to disposal, even in the absence of LDRs. Thus, potential baseline risks would be
lower than when no prior treatment is assume. Also, the regulatory benefits, which under this baseline
would represent the difference between waste treatment to TC levels and waste treated to UTS levels,
would be considerably lower than the benefits estimated relative to the no prior treatment baseline.
EPA has not quantitatively evaluated the risks associated with the disposal of waste at the TC
levels, and thus has not developed quantitative estimates of benefits associated with changes in waste
disposal practices in relation to the modified prior treatment baseline. The baseline health risks and risk
reduction benefits calculated for the alternative baselines (no prior treatment, prior treatment) are discussed
in detail in Appendix A.2. However, as will be discussed in Section 4.2.1, these estimates provide a useful
basis for evaluating the modified prior treatment baseline.
4.1 J Risk and Benefits Assessment Methods for the Storage of Recycled Materials
As discussed in Section 4.1.1, a quantitative 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
April 15, 1997
-------
-46-
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. Waste streams were also 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.
Exhibit 4-1
Recycled Streams Included in the Storage Risk Analysis
Commodity
Recycled Stream
Aluminum and Alumina .
Cast House Dust
Beryllium
Chip Treatment Wastewater
Copper
Acid Plant Blowdown
Elemental Phosphorus
AFM Rinsate
Elemental Phosphorus
Furnace Scrubber Blowdown
Rare Earths
Process Wastewater
Selenium
Plant Process Wastewater
Tantalum, Columbium, and Ferrocolumbium
Process Wastewater
Titanium and Titanium Oxide
Leach 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), for which
the least-cost management unit is a surface impoundment. The remaining two streams (aluminum cast
house dust and zinc waste ferrosiHcon) are nonwastewaters (NWW), for which the least-cost management
unit is a waste pile.
Constituent concentration data were available from a total of 187 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, 145 were bulk analytical results, and 42 were EP extraction analysis. Of
the available samples, 135 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 DAFs are summarized in Appendix J.
Although storage risks were calculated for only 14 of die 118 total mineral processing waste
streams, these streams represent substantial proportions of the total generated wastes and an even higher ,
April 15,1997
-------
-47-
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 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 H.
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 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 poundwater 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 arsenic28 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 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 H. 1.
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
28 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.
29 U.S. EPA, Technical Support Document for the Hazardous Waste Identification Rule; Risk
Assessment for Human and Ecological Receptors, Office of Solid Waste, August 1995.
v.
April 15,1997
-------
EXHIBIT 4-2. RELEASE AND EXPOSURE PATHWAY MODELING SUMMARY FOR MINERAL PROCESSING STORAGE RISK
ASSESSMENT
UNIT TYPE
RELEASE
EVENT/
MEDIUM
TRANSPORT
MEDIUM 1
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)
i
Crops
Ingestion
Subsistence
Farmer
HWIR-Waste, modified for
non-steady-state conditions
(concentration in crops,
vegetable intake, risk)
Air
Soil/Water
Surface
Water/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 adjacent
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
Control/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)
-------
-49-
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
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 H.2.
4.2 Risk and Benefits Assessment Results
42.1 Risks and Benefits Associated With the Disposal of Mineral Processing Wastes
As noted previously, the estimated benefits associated with the proposed LDRs under the no prior
treatment baseline are substantial, in terms of the numbers of facility-waste stream combinations that move
from high-risk categories under baseline assumptions to lower risk categories under that requirement
wastes be treated to UTS levels prior to disposal. These benefits, which would be realized under all four
regulatory options, are summarized in Exhibits 4-3 and 4-4, and are discussed in detail in Appendix A.2.
It can be seen from these exhibits that there are substantial numbers of waste stream-facility combinations
for which estimated individual cancer risks through groundwater exposures exceed 10'5 and for which the
estimated noncancer hazard quotient values exceed 1.0 under the no prior treatment baseline. This is true
both under central tendency (CT) and high-end (HE) exposure assumptions. In contrast, post-LDR (where
treatment to UTS levels would be required for all wastes), there are no waste stream-facility combinations
for which these risk or hazard quotient levels are exceeded under either CT or HE assumptions.
Under the modified prior treatment baseline (and under the prior treatment baseline), the baseline
risks and risk reduction associated with the first three regulatory options would be considerably lower than
those derived assuming no treatment. This is because treatment to the TC regulatory levels prior to
disposal, as assumed for modified prior treatment, in and of itself is sufficient to reduce the risks for most
of die risk-driving constituents to below levels of concern for groundwater ingestion. In addition, the TC
regulatory level and the UTS leachate level for arsenic, the sole ingestion pathway carcinogen among the
constituents and a frequent risk driver, are the same. Thus, going from treatment to TC levels under
modified prior treatment to UTS levels under the regulatory Options 1 through 4, will yield few benefits,
in terms of reduced groundwater risks.
This is illustrated in Exhibit 4-3 where, post-LDR, cancer risks for all waste stream-facility
combinations (which are all due to arsenic exposures) are below 10 s. Thus, there are no baseline cancer
risks above levels of concern under the modified prior treatment baseline even without LDRs. This, along
with the equality of the TC and UTS treatment levels, means that no reduction in cancer risks would occur
through the LDRs under the assumptions used to define die modified prior treatment baseline and the
regulatory options.
April 15,1997
-------
EXHIBIT 4-3 RISK AND BENEFITS SUMMARY FOR MINERAL PROCESSING WASTE DISPOSAL
Distribution of Waste Stream-Facility Combinations by Groundwater Risk Category: Cancer Risks
Number of
Central Tendency
High
End
Waste Stream-
Facility
Pre-LDR
Post-LDR
Pre-LDR
Post-i fm
Cembinaf
ons*#
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
|0«2
Central
High
io
lo
to
to
to
to
to
to
to
to
*9
io
to
to
to
to
Commodity
Waste Siitan
Tendency
End
<10-5
10.4
10-3
10-2
10-1
>10-1
<109
10 4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
10-1 >10*1
Al andAlunani
Cast house dust
23
23
23
0
0
0
0
0
23
0
0
0
0
0
23
0
0
0
0
0
23
0
0
0
0 (
Sb
Autoclave filtrate
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 (
Be
Spew banc* filtrate streams
1
1
1
0
1
0
0
0
1
0
0
0
0
0
0
1
0
1
0
0
1
0
0
0
0 (
Be
Chip treatment WW
1
2
1
0
0
0
0
0
1
0
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0 (
Co
Acid plant btowdowti
7
7
2
0
2
1
0
1
7
0
0
0
0
0
0
1
0
2
1
1
7
0
0
0
0 (
Cu
Scrubber blowdown
10
10
3
0
?
0
0
0
10
0
0
0
0
0
0
3
0
7
0
0
10
8
0
0
0 (
Elemental Phoiphorui
AFM rinsate
2
2
1
1
0
0
0
0
2
0
0
0
0
0
0
1
1
0
0
0
2
0
0
0
0 (
Elemental Phosphorus
Furnace offgas solids
2
2
2
0
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0 (
Elemental Phosphorus
Furnace scrubber blowdown
2
2
i
1
0
0
0
0
2
0
0
0
0
0
O
i
,
0
0
0
2
0
0
0
0 (
Elemental Phosphorus
Slag quenchwater
2
2
0
2
6
0
0
0
2
0
0
0
0
0
0
0
2
0
0
0
2
0
0
0
0 t
Ge
Waste acid wash/rinse water
2
4
2
0
0
0
0
0
2
0
0
0
0
0
0
4
0
0
0
0
4
0
b
0
0 (
Ge
Ctitorinator wet air poll. Ctrl, sludge
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
0
0
0
0
0
4
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
0
0
4
0
0
0
0 <
Ge
Waste still liquor
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
0
0
0
0
0
4
8
0
0
0 {
Mg and Magnesia (brine)
Smut
2
2
2
0
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0
0
2
0
0
0
0 <
Mo, FcMo, Anm Mo
Liquid residua
1
2
0
0
0
I
0
0
1
0
0
0
0
0
0
0
0
0
2
0
2
0
0
0,
0 (
Rare Earths
Spent amrrxm. nitrate proc sol.
1
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0 (
Rare Earths
PWW
I
1
0
1
0
0
0
0
1
0
0
0
0
0
0
0
|
0
0
0
1
0
0
0
0 <
Se
Flam PWW
2
2
0
2
0
0
0
0
2
0
0
0
0
0
0
0
2
0
0
0
2
,0
0
0
'0 t
Ta, Cohimbium, and PeCol.
PWW
2
2
1
0
0
0
0
0
2
0
0
0
0
0
1
1
0
0
0
0
2
0
0
o
0 (
Titanium and Ti02
Pickle liquor & wash water
2
3
1
1
0
0
0
0
2
0
0
0
0
0
0
2
2
0
0
0
3
0
0
0
0 i
titanium and T»02
Leach liquor & sponge wash water
1
2
1
1
0
0
0
0
1
0
0
8
0
0
0
I
1
0
0
0
2
0
0
o
0 (
Titanium and T.02
Scrap milting 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
o
0 (
Titanium and Ti02
Spent s,i. liquids
4
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0 (
Titanium and Ti02
Spent s.i. solid*
4
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0 (
Titanium and TiQ2
Waste acids (Sulfate process)
1
2
0
I
0
0
0
0
I
0
0
0
0
0
t
0
2
0
0
0
2
0
0
o
0 (
Titanium and Ti02
WWTP sludge/solids
7
. 7
0
0
0
0
0
0
0
0
0
0
0
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 <
Zn
Wane fetrosilicon
1
i
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0 t
Zn
Spent s.i. liquids
3
3
0
0
0
3
0
0
3
0
0
0
0
0
0
0
0
0
3
0
3
0
0
0
0 <
Zn
WWTP solids
3
3
3
0
0
0
0
0
3
0
0
0
0
0
0
3
0
0
0
0
3
0
0
0
0 (
Zn
Spent synthetic gypsum
3
3
3
0
0
0
0
0
3
0
0
0
0
0
2
0
2
0
0
0
3
0
0
0
0 (
Zn
WWTP liquid effluent
3
3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
o
0 (
Zn
Zinc lean slag
1
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
I
0
0
0
O (
TOTALS'
108
133
56
11
II
8
2
i
89
0
0
0
0
0
46
20
14
13
10
5
108 0 0 0 o (
* Sums by riik category may not add to the number of central or high-end
waste streanVfaeility combinations due to rounding.
-------
EXHIBIT 4-4 RISK AND BENEFITS SUMMARY FOR MINERAL PROCESSING WASTE DISPOSAL
Distribution of Waste Stream-Facility Combinations by Groundwater Hazard Category: Non-Cancer Hazards
Commodity
Waste Stream
Number of Waste
Central Tendency
Hi
Eh End
Stream-
Facility
Combinations*
Pre-LDR
Post-LDR
Pre-LDR
Post-LDR
1
10
100
lk
1
10
100
lk
1
10
100 lk
1
10
100
lk
Central
High
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
to
Tendency
End
<1
10
100
Ik
10k
>t0k
<1
10
too
lk
10k
>10k
<1
10
100 lk
10k
>10k
<1
10
100
lk
10k
>10k
A! and Alumina
Cast house dust
23
23
23
0
0
0
0
0
23
0
0
0
0
0
23
0
0
0
0
0
23
0
0
0
0
0
Sb
Autoclave filtrate
4
7
0
0
0
3
1
0
4
0
0
0
0
0
0
0
0
2
2
2
7
0
0
0
0
0
Be
Spent barren filtrate streams
1
1
0
0
1
0
0
0
I
0
0
0
0
0
0
0
0
1
0
0 •
1
0
0
0
0
0
Be
Chip treatment WW
1
2
0
0
0
0
I
0
1
0
0
0
0
0
0
0
0
0
0
2
2
0
0
0
0
0
Cu
Acid plant blowdown
7
7
1
2
2
1
1
0
7
0
0
0
0
0
0
I
1
2
1
|
7
0
0
0
0
0
Cu
Scrubber blowdown
10
10
0
3
7
0
0
0
10
0
0
0
0
0
0
0
0
10
0
0
10
0
0
0
0
0
Elemental Phosphorus
AFM rinsate
2
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
Elemental Phosphorus
Furnace offgas solids
2
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
Elemental Phosphoros
Furnace scrubber blowdown
2
2
1,
I
0
0
0
0
2
0
0
0
0
0
0
0
1
1
0
0
2
0
0
0
0
0
Elemental Phosphorus
Slag quenchwater
2
2
2
0
0
0
0
0
2
0
0
0
0
0
0
2
0
0
0
0
2
0
0
0
0
0
Ge
Waste acid wash/rinse water
2
4
2
0
0
0
0
0
2
0
0
0
0
0
0
0"
4
0
0
0
4
0
0
0
0
0
Ge
Chlorinator wet air poll. Ctrl,
sludge
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
0
0
0
0
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
0
0
4
0
0
0
0
0
Ge
Waste still liquor
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
.0
0
0
0
0
4
0
0
0
0
0
Mg and Magnesia (brine)
Smut
2
2
2
0
0
0
0
0
2
0
0
0
0
0
1
1
0
0
0
0
2
0
0
0
0
0
Mo, FeMo, Amm. Mo
Liquid residues
I
2
0
0
1
0
0
0
1
0
0
0
0
0
0
0
0
2
0
0
2
0
0
0
0
0
Rate Earths
Spent ammon. nitrate proc, sol.
1
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Rare Earths
PWW
1
1
1
0
0
0
0
0
1
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
Se
Plant PWW
2
2
1
1
0
0
0
0
2
0
0
0
0
0
0
0
1
1
0
0
2
0
0
0
0
0
Ta, Columbian*, and FeCol.
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
0
Titanium and Ti02
Pickle liquor & wash water
2
3
0
2
0
0
0
0
2
0
0
0
0
0
0
0
3
0
0
0
3
0
0
0
0
0
Titanium and Ti02
Leach liquor & sponge wash
water
1
2
0
1
1
0
0
0
'
0
0
0
0
0
0
0
2
0
0
0
2
0
0
0
0
0
Titanium and Ti02
Scrap milling 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
0
0
0
Titanium and Ti02
Spent s.i. liquids
4
7
4
0
0
0
0
0
4
0
0
0
0
0
7
0
0
0
0
0
7
0
0
0
0
0
Titanium and Ti02
Spent s.i. solids
4
7
4
0
0
0
0
0
4
0
0
0
0
0
5
2
0
0
0
0
7
0
0
0
0
0
Titanium and Ti02
Waste acids (Sulfate process)
1
2
0
0
1
0
0
0
1
0
0
0
0
0
0
0
1
I
0
0
2
0
0
0
0
0
Titanium and Ti02
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
Spent acid & rinse water
3
6
2
1
0
0
0
0
3
0
0
0
0
0
3
2
0
2
0
0
6
0
0
0
0
0
Zn
Waste fcrrosilicon
1
1
1
0
0
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
3
3
0
1
1
0
1
0
3
0
0
0
0
0
0
1
0
1
0
1
3
0
0
0
0
o
Zn
WWTP solids
3
3
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
Spew synthetic gypsum
3
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
WWTP liquid effluent
3
3
0
1
I
0
0
1
3
0
0
0
0
0
0
0
2
0
0
1
3
0
0
0
0
0
Zn
Zinc lean slag
1
1
1
0
0
0
0
.0
I
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
TOTALS*
108
133
68
16
14
4
4
1
108
0
0
0
0
0
63
15
19
24
4
8
133
0
0
0
0
0
* Sums by hazard category may not add to the number of central or high-
end waste strtam/facility combinations due to rounding.
-------
-52-
In the case of noncarcinogenic constituents, the situation is very similar. Again (see Exhibit 4-4),
treatment of all of the waste streams to UTS levels prior to disposal (post-LDR) results in all waste stream-
facility combinations having noncancer hazard quotients less than 1.0. Unlike the case for arsenic,
however, the UTS concentrations for many of the constituents are lower than the TC concentrations. Even
in these cases, however, screening calculations indicate that, with one possible exception, treatment to the
TC level, as required under the modified prior treatment baseline, would results in hazard quotient values
less than 1.0 for all of the waste samples. The basis for this argument is shown in Exhibit 4-5.
It can be seen from this exhibit that the estimated exposure concentrations in groundwater,
calculated using HE constituent-specific DAF values for surface impoundments30, are all below levels
corresponding to noncancer hazard quotient values of 1.0, with the exception of barium, for which the
exposure concentration corresponding to the TC leachate regulatory level just exceeds the health-based
level. Barium is rarely a risk-driving constituent in the waste disposal risk assessment, and review of the
data base of constituent concentrations indicates that no EP leachate sample from any waste stream has a
barium concentration exceeding the TC level, even prior to treatment, and most of the EP extraction
analytical results are many orders of magnitude below the TC level. Further, only five bulk samples from
any of the waste streams have barium concentrations exceeding 100 mg/kg, and four of these samples are
from nonwastewater streams that would be managed in waste piles rather than in surface impoundments.
The HE DAF for barium release from waste piles is many orders of magnitude lower than the value for
surface impoundments, and thus the calculated groundwater exposure concentrations would also be much
lower for these samples.
The findings presented above provide a high degree of assurance that the groundwater pathway
risks associated with the presence of TC analytes in the disposed mineral processing wastes would pose
low risks under the modified prior treatment baseline. Consequently, the health benefits of the regulatory
options relative to this baseline from reduced groundwater exposures would be minimal for most
constituents, and would be zero for arsenic, for which the TC and the UTS levels are the same.
Exhibit 4-5
Groundwater Concentrations Resulting from Releases of Noncarcinogenic Constituents at TC
Concentrations Compared to Health-Based Levels
Constituent
Health-Based Level
(Groundwater
Concentration
corresponding to HQ = 1)
(mg/1)
TC Regulatory Level
(mg/1)
HE Groundwater
Concentration
Corresponding to Release
at TC Regulatory Level
(mg/1) 2
Barium
2.5
100
6.8
Cadmium
0.035
1
0.00031
Chromium (VI)
0.18
5 '
0.031
Lead
0.0151
- 5
6X10'9
Mercury
0.011
0.025
6X10"6
Selenium
0.18
1
0.0023
Silver
0.18
5
0.010
1 The HBL for lead is the Safe Drinking Water Act MCL.
2 Calculates using the constituent-specific HE DAF value for surface impoundments
30 This is the lowest DAF value used in the analysis, and gives the highest risks.
April 15, 1997
-------
-53-
A similar blanket statement cannot be made for the other constituents (antimony, beryllium,
cyanide, nickel, thallium, vanadium, and zinc) for which TC regulatory levels have not been set, but which
have UTS levels: In these cases, the benefits associated with going from the modified prior treatment
baseline to regulatory options 1-4 could be higher. In the extreme case, (where treatment to reduce the
mobility of the TC analytes does not reduce the mobility of the other UTS constituents), the baseline risks
and regulatory benefits could be almost as high as those shown in Exhibit 4-4. It is likely, however, that
under the modified prior treatment baseline, treatment to reduce leaching of the TC analytes would also
reduce the mobility of the other UTS analytes to a substantial degree. Thus, the baseline groundwater ,
pathway risks, and the risk reduction benefits under this baseline are likely to be much lower than those
indicated in Exhibit 4-4.
Finally, the risk assessment for mineral processing waste disposal has not addressed non-
groundwater pathway risks. It is not known to what extent these risks would be reduced by LDRs
compared to the modified prior treatment baseline.
4.2.2 Risk Assessment Results for Recycled Materials Storage: Groundwater Pathway
Exhibit 4-6 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 49 of these samples were less than 10'5, the level of regulatory
concern, and the risks for 26 of the samples exceeded this value. Cancer risks exceeded 10"5 for one or
more samples from only four waste streams; copper acid plant blowdown, elemental phosphorus furnace
scrubber blowdown, tantalum, eolumbium, 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 3 to 10"2). This waste stream accounted for 14 of the 16 samples with the highest CT
cancer risks. The next highest risks (in the 10"4 to 10"3 range) were associated with one sample each from
tantalum process wastewater and zinc spent surface impoundment liquids.
Using the high-end (HE) DAF values, cancer risks calculated for the groundwater pathway exceeded 10'5
for 50 of the 75 samples. Under this set of assumptions, risks for at least one sample exceeded 10"5 for 10
of the 14 waste streams evaluated. The highest risks (25 of 30 samples > 10"5, highest risk category >10')
were again associated with copper acid plant blowdown, with the next highest risk (102 to 10"1) being
associated with the single sample of zinc spent surface impoundment liquids. Of the wastes whose CT
cancer risks were below 10'5 for all samples, six (elemental phosphorus AFM rinsate, rare earths process
wastewater, selenium plant wastewater, titanium/Ti02 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 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 iri
surface impoundments. In the case of the NWW waste streams managed in piles, both the CT and HE
cancer risks for all samples were below 10"5, 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 10"5 were beryllium chip treatment wastewater and zinc
wastewater treatment plant liquid effluent.
April 15,1997
-------
EXHIBIT 4-6 RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of Samples by Groundwater Risk Category: Cancer Risks
Number
Central Tendency
High End
of Samples
10-5
10-4
10-3
10-2
10-5
10-4
10-3
10-2
with
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
Aluminum, 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
o
0
Copper
Acid plant blowdown
30
9
7
8
3
3
0
5
3
5
8
5
4
Elemental Phosphorus
AFM rinsate
2,
2
0
0
0
0
0
0
1
1
0
0
0
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
i
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 water
2
2
0
0
0
0
0
o
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
11
11
0
0
0
0
0
7
1
3
0
0
0
Total
75
49
10
10
3
3
0
25
16
13
11
6
4
1, Tantalum, Columbium, arid Ferrocolumbium
-------
-55-
Noncancer hazard quotient values for the groundwater pathway for the individual samples of
recycled materials are summarized in Exhibit 4-7. Using the CT DAF values, hazard quotients exceeding
1.0 were calculated for 43 of 135 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 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 100 of
the 135 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 five waste streams (elemental
phosphorus AFM rinsate, rare earths process wastewater, selenium process wastewater, and titanium/Ti02
leach 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.
4.23 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 4-8. Using the methods described in Section
1.1.2, EPA has estimated that CT groundwater pathway cancer risks would exceed 10'5 at approximately
10 of the 57 facility-waste stream facilities.31 AJ1 of these facility-waste stream combinations were
managing either 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 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 seven 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 10"5) was rounded down to
zero. Similarly, in the case of tantalum process wastewater, three of thirteen samples with risks above 10 5
were again rounded downward to 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 !0's.
31 Note that the totals in the risk categories do not sum exactly due to rounding. This is true
for the following exhibit as well.
April 15,1997
-------
EXHIBIT 4-7 RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of Samples by Groundwater Hazard Category: Non-Cancer Hazards
Number of
Samples
Central Tendency
High End
1
10
100
lk
1
10
100
lk
with
to
to
to
to
to
to
to
to
Commodity
Waste Stream
Non-cancer
Hazard
<1
10
100
lk
10k
e
A
<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
l1
0
0
1
0
0
0
0
0
0
0
1
0
Copper
Acid plant blowdown
35
17
10
4
4
0
0
3
7
12
7
4
2
Elemental Phosphorus
AFM rinsate
' 2
2
0
0
0
0
0
0
0
2
0
0
0
Elemental Phosphorus
Furnace scrubber blowdown
14
13
1
0
0
0
0
4
4
5
1
0
0
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 water
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
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
134
91
26
10
7
0
0
34
28
28
28
9
7
1. Tantalum, Columbium, and Ferrocolumbium
-------
EXHIBIT 4-8 RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of Waste Stream/Facility Combinations by Groundwater Risk Category;
Cancer Risks
Number of
Central Tendency
High End
Waste Stream-
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
*
l
e
F"H
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
Copper
Acid plant blowdown
10
10
3
2
3
1
1
0
2
1
2
2
2
2
Elemental Phosphorus
AFM rinsate
2
2
2
0
0
0
0
0
0
1
0
0
0
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.1
PWW
2
2
2
0
0
0
0
0
1
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 ferrosilicon
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
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
57
57
42
3
6
1
1
0
30
e
6
3
5
2
1. Tantalum, Columbium, and Ferrocolumbium
2, Sums by risk category may not add to the number of central or high-end waste stream/facility combinations due to rounding.
-------
When HE DAF values are used, the number of facility-waste stream combinations with cancer
risks above 10'5 increases to 24 of 57 facilities. Under HE assumptions, most of the waste streams show
one or more facilities at risk levels above 10"5. The exceptions include both the two NWW streams that
would be stored in waste piles, as well as beryllium chip treatment wastewater and ziric 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 4-9. 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 are 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, 28 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 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 4-7 and 4-8
provide an upper-bound estimate of the regulatory benefits, in terms of groundwater risk reduction, that
might be achieved by Option 3, under which all recycled materials would be stored in tanks, containers,
and buildings. Under Options 1 and 2, the recycling of secondary materials in Bevill units would be
prohibited. The risks associated with the storage of these wastes (copper acid plant blowdown, and
elemental phosphorus AFM rinsate and furnace scrubber blowdown) would definitely be reduced to below
levels of concern, since these streams would need to be managed in Subtitle C units.
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.
April 15,1997
-------
EXHIBIT 4-9 RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
Distribution of Waste Stream/Facility Combinations by Groundwater Hazard Category:
Non-Cancer Hazards
Number of
Waste Stream-
Central Tendency
High End
Facility
Combinations
1
10
100
lk
1
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
O
A
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
2
0
Copper
Acid plant blowdown
10
10
4
3
1
1
0
0
1
2
3
2
1
l
Elemental Phosphorus
AFM rinsate
2
2
2
0
0
0
0
0
0
0
2
0
0
0
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
I
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 ferrosilicon
1
1
1
0
0
0
0
0
1
0
0
0
0
0
Zinc
Spent s.i. liquids
3
3
2
0
1
1
0
0
0
0
0
1
0
1
Zinc
WWTP liquid effluent
3
3
2
0
0
1
0
0
0
1
1
0
0
1
Zinc
Process wastewater
3
3
2
1
0
0
0
0
1
I
1
1
0
0
TOTAL 2
57
57
45
5
4
3
0
0
29
9
9
4
4
2
1. Tantalum, Columbium, and Ferrocolumbium
2. Sums by hazard category may not add to the number of central or high-end waste stream/facility combinations due to rounding.
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-60-
4.2.4 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
HE 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;
• 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 (greater than one order of magnitude, and sometimes many more)
below the defined levels of concern. 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 4-10 summarizes the results of the comparison of
surface water concentrations 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.
April 15,1997
-------
EXHIBIT 4-10 RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
COMPARISON OF SURFACE WATER CONCENTRATIONS
TO HEALTH-BASED
DRINKING WATER
DUE TO SURFACE IMPOUNDMENT RELEASES
LEVELS 1
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
bv:
Samples Exceeding
HBL by:
Constituent
Commodity
Wastestream
Total Samples
l-10x
10-100%
l-10x
10-lOOx
lOO-lOOOx
l-10x
10-100x
t-lOx
10-I00x
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
1. The HBL for Arsenic corresponds to a 10-5 lifetime cancer risk.. The HBL for cadmium corresponds to a noncancer hazard quotient of 1.0, and the HBL for lead
istheMCL.
-------
-62-
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 1G"5 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 die HBL for only one of the 40 total
samples of 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 of ten or less. Under CT assumptions, there are no surface
water exceedances for cadmium. For cadmium, an HBL excedence 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 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 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. .
As shown in Exhibit 4-11, 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 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 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 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 15,1997
-------
EXHIBIT 4-11 RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
COMPARISON OF SURFACE WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO HEALTH-BASED 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
Concentration from EP
Extraction Samples
Samples Exceeding HBL
bv:
Samples Exceeding HBL
bv:
Samples Exceeding
HBL bv:
Samples Exceeding
HBL bv:
Constituent
Commodity
Wastestream
Total No.
Samples
l-10x
10-100x
100-1000X
l-10x
10-lOOx
100-1000x
l-10x
10-100x
l-10x
10-100x
Arsenic
Copper
Acid Plant Blowdown
40
2
2
1
1
1
Cadmium
Copper
Acid Plant Blowdown
40
2
Rare Garths
Process Wastewater
8
1
Zinc
Process Wastewater
40
6
Zinc
Spent Surface
Impoundment Liquids
24
6
3
1
1
1
Zinc
WWTP Liquid Effluent
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
TiQ>
Leach liquid & sponge
wash water
8
1
Copper
Acid Plant Blowdown
40
1
Zinc
Zinc
Spent Surface
Impoundment Liquids
24
5
Zinc
WWTP Liquid Effluent
5
1
1. The HBL for Arsenic corresponds to a 10-5 lifetime cancer risk.. The HBL for the other constituents correspond to a noncancer hazard quotient of 1.0.
-------
-64-
4.2.5 Potential Health Benefits from Regulation of Storage of Recycled Materials: Non-
Groundwater Pathways
Exhibit 4-12 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 Options 1 and 2, copper acid plant blowdown could no longer be
recycled through a Bevill unit, and treatment of this stream as a Subtitle C waste would undoubtedly result
in a high degree of risk reduction. Under Option 3, all of the streams could be managed in TCBs, and the
degree of risk reduction and the magnitude of health benefits for storage are harder to estimate. Since the
magnitude of exceedances of the HBLs for most waste stream-facility combinations are rather low for the
surface water pathways, it is possible that most of these risks would, in fact, be reduced below levels of
concern under Option 3. In terms of reduced risks from the storage of recycled materials, Option 4
provides no benefits over the modified prior treatment baseline.
4.3 Uncertainties and Limitations in the Risk and Benefits Assessment for the Modified Prior
Treatment Baseline
As noted in section4.1.1, 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. 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 hedlth risks faced by hypothetical individuals under the defined
exposure conditions. •
The screening level analysis also 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 focused on limitations
specific to the multipathway analysis.
As noted previously, 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. 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.
April 15,1997
-------
EXHIBIT 4-12 RISK SUMMARY FOR STORAGE OF RECYCLED MATERIALS
DISTRIBUTION OF WASTE-STREAM FACILITY COMBINATIONS BY DEGREE OF HBL EXCEEDENCE UNDER THE MODIFIED
PRIOR TREATMENT BASELINE
Number of Waste Stream-Facility
Combinations with High-End
Exceedences of HBLs by:
Waste Stream-Facilty
Combinations with
Central Tendency
Exceedences of HBLs bv:
Commodity
Waste Stream
Sector Total
Waste Stream-
i Facility
Combinations
1-10X
10-100X
100-1000X
1-10X
10-100X
1. Drinkina Water
Copper
Acid Blowdown
10
1
Zinc
Spent Surface Impoundment Liquids
3
2. Fish Inaestion
Copper
Acid Blowdown
10
2
1
Rare Earths
Process Wastewater
1
-
Titanium, TiO,
Leach Liquor and Sponqe Wash Water
2
Zinc
Process Wastewater
3
Zinc
Spent Surface Impoundment Liquids
3
1
1
Zinc
WWTP Liquid Effluent
3
1
1
-------
-66-
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
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 through other pathways (e.g. particulate suspension) is reduced.
Mass balance calculations were performed for the non-groundwater release pathways (see
Appendix H.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. SCREEN3 is
a widely-accepted screening level EPA 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, for example, 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
April 15,1997
-------
Run-off releases were evaluated using the same model the Universal Soil Loss Equation, USLE,
applied in HWIR-Waste, with input parameters varied slightly to reflect the operating characteristics of the
waste piles being simulated and die 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
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 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 thelonly ones 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 BAF 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 analysis, since the fish
ingestion pathway resulted in the highest risks predicted for several of the constituents and waste streams.
April 15,1997
-------
-68-
5. 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 proposed rule.
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, EPA'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 proposal covers wastes from mineral processing operations. The environmental problems
addressed by this proposed rulemaking 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 proposed 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 minority
or low income communities relative to affluent or non-minority communities.
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 where the estimated costs to state, local, or
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 impacted by
the rule.
EPA has completed an analysis of the costs and benefits from today's proposed rule and has
determined that this proposed rale 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 also
will not incur costs exceeding $100 million per year under any of the three costing scenarios described in
Section 4.4, Cost and Economic Impacts of the Rule, above.
April 15,1997
-------
-69-
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 RIA prepared in support of the January 1996 proposed rule, 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 118 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, and
3) wastes that are known or expected to be non-hazardous. 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 highly variable estimates of costs and
benefits arising from new regulatory controls.
The Agency recognizes the limitations that these data gaps and simplifying assumptions impose on
the accuracy of the analyses presented above. EPA 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.
EPA recognizes the limitations that these data gaps and simplifying assumptions impose on the
accuracy of the analyses presented above. EPA 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.
62 Cost and Economic Impacts of the Rule
A summary of the projected costs of implementing the four options analyzed in this RIA is
provided in Exhibit 4-13, below.
As can be seen in Exhibit 4-13, cost impacts are highest for Options 1 and 2, ranging between $46
million and $75 million annually for Option 1 and $37 million and $55 million annually for Option 2.
Option 3 results in significantly lower cost impacts, with costs ranging only from $5.2 million to $13
million annually. Option 4 results in significantly lower cost impacts than the other three options, with
impacts ranging only from $71,000 to 190,000 annually.
April 15,1997
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-70-
Exhibit 6-1
Summary of Cost Analysis Results
(Results in $ Thousands per Year)
Costing
Modified Prior
Option"
Scenario
Treatment
Option 1
Minimum
46,000
Expected
58,000
Maximum
75,000
Option 2
Minimum
37,000
Expected
45,000
Maximum
55,000
Option 3
Minimum
5,200
Expected
8,400
Maximum
13,000
Option 4
Minimum
- 71
Expected
190
Maximum
190
a Options are described in detail in Section 4.1,
The high costs associated with Option 1 are the result of additional requirements the option would .
impose on facility operator recycling secondary materials. Option 2 costs are slightly lower than Option 1
costs, and are driven primarily by the option's prohibition against recycling secondary materials to
beneficiation or Bevill process units. The absence of a legitimacy test for recycling and the option's
provisions that allow for storage of secondary materials in non-RCRA tanks, containers, and buildings
prior to recycling account for Option 2's lower costs relative to Option 1.
Option 3 has the lowest costs of the non-land based storage options. The significantly lower costs
associated with Option 3 result from the option's lack of prohibition in the recycling of secondary
materials through beneficiation or Bevill process units. Option 4 results in relatively low net costs to
industry because the option essentially allows facilities to continue operating as they currently operate.
The Agency assumes that in some cases, facility owners and operators, out of misunderstanding of current
requirements, handle spent materials improperly. Option 4 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.
A brief summary of the projected economic impacts of the rale, assuming the modified prior
treatment baseline, is summarized in Exhibit 4-14. Again, impact ratios are the annualized costs of
compliance divided by annual value of shipments.
April 15,1997
-------
Exhibit 6-2
Summary of Economic Impact Screening Results:
Modified Prior Treatment Baseline
Option
Costing
Scenario
Sectors
with
Impacts
Option 1
Minimum
1
Expected
5
Maximum
7
Option 2
Minimum
1
Expected
5
Maximum
6
Option 3
Minimum
0
Expected
3
Maximum
5
Option 4
Minimum
0
i
Expected
0
Maximum
0
Analysis of costs as a percentage of value added indicates that only Option 4 results in no
significant impacts (defined as greater than 10 percent) to industry. Option 3 will significantly impact the
cadmium and selenium sectors (13 percent of the sectors analyzed). Greater impacts are expected to result
from Options 1 and 2. For Opdon 1, EPA anticipates that five of the 16 industry sectors (31 percent of the
sectors included in this analysis) will be significantly affected (lead, cadmium, selenium, tellurium, and
zinc). Under Option 2, three of the 16 sectors (19 percent of the sectors analyzed) are expected to be
significantly affected (lead, cadmium and selenium).
None of the five industry sectors for which profits data were available are projected to have severe
cost impacts (defined as costs greater than estimated industry profits) under any option. In fact, impacts
exceed one percent in the expected value case only for the copper sector and only under Options 1 and 2.
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 under different sets of baseline assumptions, 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 potential groundwater exposures tatoxic 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
April 15,1997
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-72-
disposal are found in Appendix A, and descriptions of the methods used for the risk assessment for waste
storage are found in Appendix H of this RIA.
Under the modified prior treatment baseline, which EPA believes is the most realistic and
representative characterization of current industry practice, it is assumed that the wasted (unrecycled)
portion of all waste streams would be treated by stabilization to achieve compliance with the TC regulatory
leachate levels prior to land disposal. Under this set of assumptions, the baseline groundwater pathway
risks associated with the disposal of the wastes have been estimated to be quite low. As discussed in
Section 4.2,1, disposal of the waste streams in compliance with the TC regulatory levels would result
groundwater risks below levels of concern (10 s cancer risk or noncancer hazard quotient of 1.0) for all of
the TC analytes except arsenic. For arsenic, disposal at the TC concentration would result in estimated
cancer risks that just exceed 10'3. EPA believes (although the issue has not been evaluated quantitatively)
that stabilization to comply with the TC regulatory levels also will control the mobility of most toxic non-
TC inorganic constituents to the extent that baseline groundwater risks for these constituents also will be
below levels of concern.
For these reasons, EPA estimates that the health benefits from improved waste disposal practices
under all 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 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.
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 4.2.3. Estimated groundwater pathway
cancer risks under high-end (HE) baseline assumptions exceeded 10'5 at 24 of 57 facilities storing recycled
streams, while under central tendency (CT) assumptions, only 11 facilities exceed this level (Exhibit 4-8).
The HE noncancer hazard quotients for groundwater exposures exceed 1.0 at 28 facilities storing recycled
materials, and under CT assumptions baseline hazard quotients exceed 1.0 at 12 facilities (Exhibit 4-9).
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 die pathways evaluated, estimated 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 10'5. 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 storage facilities exceeded levels of concern for the fish ingestion
pathway. These results are summarized in Exhibit 4-12.
April 15,1997
-------
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 Options 1-3. If these options completely or substantially eliminate 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 benefits. Under Options 1 and 2, the risks for three of the streams managed through Bevill
units (copper acid plant blowdown, and the two streams from elemental phosphorus production) would be
greatly reduced by the requirement to manage them in Subtitle C units. Copper acid plant blowdown
figures prominently as a contributor to storage risks through both the groundwater and non-groundwater
pathways. Under Option 4, no health benefits associated with the storage of recycled materials would be
realized, as there is no requirement for improved management of these streams.
*
April 15,1997
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6{fHf-3oa3Q,4
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, 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.1 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. 1-1 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. 1-1. The
information in Exhibit A. 1-2 combines into an overall impact all incentives operating at a facility. For
instance, under Option 3 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 15,1997
-------
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.l-1
Changes in Management of Hazardous Mineral Processing Waste
Baseline/Option
Affected
Material
Required
Change in Management
Implied Change
In Recycling
NPT
Wasted
Portion
Disposal to UTS and Disposal
Increase
MPT/PT
TC to UTS
No Change
NPT/MPT to Option 1
Non- Bevill
Unlined Units to RCRA TCBs
Decrease
Legitimacy Test, Sig. Aff.
Bevill
Unlined Units to No Recycling
Complete Halt
NPT/MPT to Option 2
Non-Bevill
Bevill
Unlined Units toTCBs
Decrease
Unlined Units to No Recycling
Complete Halt
NPT/MPT to Option 3
All
Unlined Units to TCBs
Decrease
NPT/MPT to Option 4
All
Unlined Units to Unlined Units
No Change
PT (SL/BP) to Option 1
Non- Bevill
Unlined Units to RCRA TCBs
Legitimacy Test, Sig. Aff.
Decrease
Bevill
Unlined Units to No Recycling
Complete Halt
PT (SL/BP) to Option 2
Non-Bevill
Bevill
Unlined Units toTCBs
Decrease
Unlined Units to No Recycling
Complete Halt
PT (SL/BP) to Option 3
All
Unlined Units to TCBs
Decrease
PT (SL/BP) to Option 4
All
Unlined Units to Unlined Units
No Change
PT (SM) to Option 1
Non-Bevill
TCBs to RCRA TCBs
Legitimacy Test, Sig. Aff.
Decrease
Bevill
TCBs to No Recycling
Complete Halt
PT (SM) to Option 2
Non-Bevill
Bevill
TCBs toTCBs
No Change
TCBs to No Recycling
Complete Halt
PT (SM) to Option 3
All
TCBs to TCBs
No Change
PT (SM) to Option 4
All
TCBs to Unlined Units
No Change
Option 1 - Storage in RCRA Tanks, Containers, and Buildings Only, Recycling of Materials through Bevill Units
Prohibited
Option 2 - No Land-based Storage Recycling of Materials through Bevill Units Prohibited
Option 3 - No Land-based Storage
Option 4 - Land-based Storage without restriction
Bevill means that secondary materials are recycled through beneficiation or Bevill process units
Non-Bevill means that secondary materials are not recycled through beneficiation or Bevill process units
i
April 15,1997
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A-3
Exhibit A.l-2
Overall Predicted Changes in Recycling
Option 1*
Option 2*
Option 3
Option 4
No Prior Treatment
Small
Decrease
Increase
Increase
Big
Increase
Modified Prior Treatment and
Prior Treatment (SL/BP)
Moderate
Decrease
Small
Decrease
Small
Decrease
No Change
Prior Treatment (SM)
Decrease
No Change
No Change
Increase
* For materials recycled through non-Bevill Units only. Materials recycled through Bevill units
will completely cease to be recycled under Options 1 and 2.
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-rale options, and Exhibit A.1-
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.l-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. The
opposite is true for option-baseline combinations that decrease recycling. Generally the largest shift should
be seen in the YS? case. This trend is not always apparent, however, because the percentage recycled is
limited to the range from 0 to 100 percent.
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 RIA, 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 RIA is no longer modeled,
and Options 2 and 3 of todays proposal require slightly more expensive storage units (tanks, containers,
and buildings instead of lined land-based units, EPA adjusted these data slightly for use in Options 2 and 3
of todays RIA. The predicted shift in these two options for Y? material is 70 percent and the predicted
11990 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 15,1997
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A-4
shift for YS? materials is 10 percent. EPA used best professional judgement to estimate the shifts in the
other option-baseline combinations.
Exhibit A.l-3
Proportions of Waste Streams Treated and Disposed (in percent)
Percent Recycled
Affected
Certainty of Recycling
Baseline or Option
Material
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
All
0
15
25
80
100
No Prior Treatment
AH
0
100
60
100
100
Option 1 from PT
Bevill
100
100
100
100
100
Non-Bevill
30
65
100
100
100
Option 2 from PT
Bevill
100
100
100
100
100
Non-Bevill
0
25
35
85
100
Option 3 from PT
All
0
' 25
35
85
100
Option 4 from PT
All
0
15
25
80
100
Option 1 from MPT
Bevill
100
100
100
100
100
Non-Bevill
30
65
100
100
100
Option 2 from MPT
Bevill
100
100
100
100
100
Non-Bevill
0
25
35
85
100
Option 3 from MPT
All
0
25
35
85
100
Option 4 from MPT
All
0
15
•25
80
100
Option 1 from NPT
Bevill
100
100
100
100
100
Non-Bevill
20
100
90
100
100
Option 2 from NPT
Bevill
100
100
100
100
100
Non-Bevill
0
30
40
85
100
Option 3 from NPT
All
0
30
40
85
100
Option 4 from NPT
All
0
15
25 .
80
100
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 oh professional judgment, believes that a portion of the waste
stream could be fully recycled.
Bevill means that secondary materials are recycled through beneficiation or Bevill process units
Non-Bevill means that secondary materials are not recycled through beneficiation or Bevill
process units
April 15,1997
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A-5
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
100
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
Bevill
0
0
0
0
0
Non-Bevill
70
35
0
0
0
Option 2 from PT
Bevill
0
0
0
0
0
Non-Bevill
100
75
65
15
0
Option 3 from PT
All
100
75
65
15
0
Option 4 from PT
All
100
85
75
20
0
Option 1 from MPT
Bevill
0
0
0
0
0
Non-Bevill
70
35
0
0
0
Option 2 from MPT
Bevill .
0
0
0
0
0
Non-Bevill
100
75
65
15
0
Option 3 from MPT
All
100
75
65
15
0
Option 4 from MPT
All
100
85
75
20
0
Option 1 from NPT
Bevill
0
0
0
0
0
Non-Bevill
80
0
10 .
0
0
Option 2 from KPT
Bevill
0
0
0
0
0
Non-Bevill
100
70
60
15
0
Option 3 from NPT
All
100
70
60
15
0
Option 4 from NPT
All
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 be folly recycled.
Bevill means that secondary materials are recycled through beneficiation or Bevill process units
Non-Bevill means that secondary materials are not recycled through beneficiation or Bevill
process units
April 15,1997
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A-6
Exhibit A.1-5
Change in Recycling Percentage for Affected Option-Baseline Combinations
Increase in Recycling (percent)
Affected
Certainty of Recycling
Baseline or Option
Material
Y
Y?
YS
YS?
N
Option 1 from NPT
Bevill
A >100
0.00
-40
-^0.00.^
;V:::;:o->
Non-Bevill
-20
0.00
-30
0 '
Option 2 from NPT
Bevill
-40
::r'0.O0^
Non-Bevill
0.00
70
20
10
0
Option 3 from NPT
All
0.00
70
20
10
0
Option 4 from NPT
All
0;00
85
35
20
0
Option 1 from MPT & PT (SL/BP)
Bevill
-100
-85
-75
-:-20^
Non-Bevill
-30
-50
-75
>.'^20 3-
0
Option 2 from MPT & PT (SL/BP)
Bevill
400
-85
-75
-20
Non-Bevill
0.00
25
35
85
0
Option 3 from MPT & PT (SL/BP)
All
0.00
-10
-10
-5
0
Option 4 from MPT & PT (SUSP)
All
0,00
0.00
0.00
0.00
.0
Option 1 from PT (SM)
Bevill
-100
-65
-15
V Ov-S
Non-Bevill
-30
-40
-65
-15
0
Option 2 from PT (SM)
Bevill
-100.
-^73
-65
- -15
0
Non-Bevill
0.00
0.00
0.00
0.00
0
Option 3 from PT (SM)
All ~
0.00
0.00
0.00
0.00
0
Option 4 from PT (SM)
All
0.00
10
10
5
0.00
indicates shifts derived from empirical data.
indicates shifts that break expected pattern because 100 percent is sent to treatment or
recycling.
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
from the no prior 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 seen under Option 4, which yields an overall savings. Sector
specific cost results for the no prior treatment baseline are presented in Exhibits A. 1-7 through A. 1-10, and
cost results for the prior treatment baseline are presented in Exhibits A.l-11 through A.l-14. Value of
shipment impact results for the ho prior treatment baseline and the prior treatment baseline are shown in
Exhibits A. 1-15 through A. 1-22,
Notes:
Bold type
Gray shading
April 15,1997
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A-7
Exhibit A.l-6
Summary of Cost Results for All Option-Baseline Combinations
Minimum
Expected
Maximum
Option 1 PT
43,000,000
53,000,000
66,000,000
Option 2 PT
33,000,000
40,000,000
48,000,000
Option 3 PT
2,000,000
3,000,000
5,000,000
Option 4 PT
(3,000,000)
(4,900,000)
(7,100,000)
Option 1 MPT
46,000,000
58,000,000
75,000,000
Option 2 MPT
. 37,000,000
45,000,000
55,000,000
Option 3 MPT
5,200,000
8,400,000
13,000,000
Option 4 MPT
71,000
190,000
190,000
Option 1 NPT
67,000,000
120,000,000
220,000,000
Option 2 NPT
54,000,000
110,000,000
200,000,000
Option 3 NPT
24,000,000
74,000,000
160,000,000
Option 4 NPT
17,000,000
63,000,000
140,000,000
April 15,1997
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A-8
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
Commodity
Cost (Vyr)
Cost (Vyr)
Cost ($/yr)
Cost (S/yr)
Cost (Vyr)
Cost (S/yr)
Alumina and Aluminum
3,000,000
130,000
4,800,000
210,000
6,400,000
280,000
Antimony
-
1,600,000
270,000
2,500,000
410,000
Beryllium
-
1,800,000
910,000
10,000,000
5,100,000
Bismuth
-
510,000
510,000
1,700,000
1,700,000
Cadmium
-
670,000
330,000
7,000,000
3,500,000
Calcium
.
4,300
4,300
7,300
7,300
Coal Gas
-
-
-
390,000
390,000
Copper
15,000,000
1,500,000
15,000,000
1,503.000
15,000,000
1,500,000
Elemental Phosphorus
3.500,000
1,700,000
3,500,000
1,700,000
3,500,000
1,700,000
Fluorspar and Hydrofluoric Acid
-
-
290,000
97,000
590,000
200,000
Germanium
-
-
220,000
54,000
500,000
120,000
lead
21,000,000
5,200,000
32,000,000
7,900,000
43,000,000
11,000,000
Magnesium and Magnesia from Brines
1,600,000
820,000
1,700,000
830,000
2,100,000
1,000,000
Mercury
-
-
850,000
120,000
2,600,000
370,d00
Molybdenum, Ferromolybdenum, and
Ammonium Motybdate
8,100,000
740.000
29,000,000
2,600,000
Platinum Group Metals
-
160,000
54,000
290,000
98,000,
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
1,600,000
820,000
5,400,000
2,700,000
Rare Earths
220,000
220,000
1,600,000
1,600,000
5,600,000
5,600,000
Rhenium
.
-
2,600,000
1,300,000
5,100,000
2,500,000
Scandium
-
-
370,000
53,000
590,000
85,000
Selenium
" 580,000
290,000
830,000
280,000
1,900,000
640,000
Synthetic Rutile
.
-
1,600,000
1,600,000
3,000,000
3,000,000
Tantalum, Columbium, and
Ferrecolumbium
810,000
410,000
870,000
440,000
,960,000
480,000
Tellurium
-
.
510,000
250,000
1,600,000
780,000
Titanium and Titanium Dioxide
1,300,000
640,000
17,000.000
2,400,000
31,000,000
4,400,000
Tungsten
.
-
230,000
38,000
710,000
120,000
Uranium
-
-
980,000
58,000
2,400,000
140,000
Zinc
20,000,000
6,500,000
23,000,000
7,700,000
27,000.000
9,000,000
Zirconium and Hafnium
-
-
1,600,000
790,000
12,000,000
5,900,000
Total 67.000,000 120,000,000 220,000.000
April 15,1997
-------
Exhibit A.l-8
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
Commodity
Cost (S/yr)
Cost (S/yr)
Cost ($/yr)
Cost (S/yr)
Cost (S/yr)
Cost (S/yr)
Alumina and Aluminum
1,200,000
52,000
3,300,000
140,000
4,700,000
210,000
Antimony
-
1,600,000
270,000
2,500,000
410,000
Beryllium
-
.
1,800,000
910,000
10,000,000
5,000,000
Bismuth
-
•
490,000
490,000
1,700,000
1,700,000
Cadmium
-
620,000
310,000
4,400,000
2,200,000
Calcium
-
-
4,300
4,300
7,300
7,300
Coal Gas
-
-
-
-
390,000
390,000
Copper
15,000,000
1 500,000
15,000,000
1,500,000
15,000,000
1,500,000
Elemental Phosphorus
3,500,000
1,700,000
3,500,000
1,700,000
3,500,000
1,700,000
Fluorspar and Hydrofluoric Acid
-
-
180,000
60,000
370,000
120,000
Germanium
-
-
200,000
51,000
480,000
120,000
Lead
21,000,000
5,200,000
32,000,000
7,900,000
43,000,000
11,000,000
Magnesium and Magnesia from Brines
1,600,000
820,000
1,700,000
830,000
1,800,000
900,000
Mercury
-
850,000
120,000
2,600,000
370,000
Molybdenum, Ferromolybdenum, and
Ammonium Motybdate
8,100,000
740,000
29,000,000
2,600,000
Platinum Group Metals
-
160,000
53,000
250,000
83,000
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
1,500,000
770,000
5,300,000
2,700,000
Pare Earths
220,000
220,000
1,603,000
1,600,000
5,500,000
5,500,000
Rhenium
-
-
2,600,000
1,300,000
5,100,000
2,500,000
Scandium
-
-
260,000
38,000
470,000
67,000
Selenium
580,000
290,000
770,000
260,000
1,700,000
570,000
Synthetic Rutile
-
-
1,300,000
1,300,000
2,400,000
2,400,000
Tantalum, Columbium, and
Ferrocolumbium
470,000
240,000
620,000
310,000
700,000
350,000
Tellurium
-
-
390,000
200,000
1,500,000
730,000
Titanium and Titanium Dioxide
1,200,000
610,000
16,000,000
2,300,000
29,000,000
4,100,000
Tungsten
-
-
230,000
38,000
710,000
120,000
Uranium
.
-
820,000
48,000
1,500,000
91,000
Zinc
9,600,000
3,200,000
13,000,000
4,300,000
17,000,000
5,600,000
Zirconium and Hafnium
-
1,500,000
750,000
11,000,000
5,600,000
Total
54,000,000
110,000,000
200,000,000
April 15,1997
-------
A-10
Exhibit A.l-9
Option 3 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
Commodity
Cost ($/yr)
Cost ($/yr)
Cost (S/yr)
Cost ($/yr)
Cost (S/yr)
Cost ($/yr)
Alumina and Aluminum
1,200,000
52,000
3,300,000
140,000
4,700,000
210,000
Antimony
-
-
1,600,000
270,000
2,500,000
410,000
Beryllium
' -
-
1,800,000
910,000
10,000,000
5,000,000
Bismuth
-
-
490,000
490,000
1,700,000
1,700,000
Cadmium
-
-
590,000
300,000
4,300,000
2,200,000
Calcium
-
1,400
1,400
1,400
1,400
Coal Gas
-
-
-
.
260,000
260,000
Copper
8,200,000
820,000
8,100,000
810,000
8,200,000
aa),ooo
Elemental Phosphorus
540,000
270,000
540,000
270,000
540,000
270,000
Fluorspar and Hydrofluoric Acid
-
-
180,000
60,000
370,000
120,000
Germanium
-
-
200,000
51,000
480,000
120,000
Lead
120,000
30,000
6,100,000
1,500,000
13,000,000
3,200,000
Magnesium and Magnesia from Brines
1,600,000
820,000
1,700,000
830,000
1,800,000
900,000
Mercury
-
-
420,000
60,000
1,400,000
210,000
Molybdenum, Fenomoiybdenum, and
Ammonium Molybdate
8,100,000
740,000
29,000,000
2,600,000
Platinum Group Metals
-
-
160,000
53,000
250,000
83,000
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
_
.
1,500,000
770,000
5,300,000
2,700,000
Rare Earths
220,000
220,000
1,500,000
1,500,000
5,000,000
5,000,000
Rhenium
-
-
2,600,000
1,300,000
5,100,000
2,500,000
Scandium
- -
-
260,000
38,000
470,000
67,000
Selenium
550,000
270,000
730,000
240,000
1,700,000
570,000
Synthetic Ruffle
-
1,300,000
1,300,000
2,400,000
2,400,000
Tantalum, Columbium, and
Ferrocolumbium
470,000
240,000
620,000
310,000
700,000
350,000
Tellurium
-
-
390,000
200,000
1,500,000
• 730,000
Titanium and Titanium Dioxide
1,200,000
610,000
16,000,000
2,300,000
29,000,000
4,100,000
Tungsten
'
-
320,000
53,000
690,000
110,000
Uranium
-
-
820,000
48,000
1,500,000
91,000
Zinc
9,600,000
3,200,000
13,000,000
4,300,000
17,000,000
5,600,000
Zirconium and Hafnium
-
-
1,500,000
750,000
11,000,000
5,600,000
Total 24,000,000 74,000,000 160,000,000
April 15, 1997
-------
A-ll
Exhibit A.l-10
Option 4 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
Commodity
Cost ($/yr)
Cost (Vyr)
Cost{$/yr)
Cost (Vyr)
Cost ($/yr)
Cost ($/yr)
Alumina and Aluminum
770,000
34,000
2,200,000
95,000
3,000,000
130,000,
Antimony
• --
-
1,600,000
260,000
2,400,000
400,000
Beiyllium
-
•
1,800,000
900,000
9,500,000
4,700,000
Bismuth
•
-
480,000
480,000
1,700,000
1,700,000
Cadmium
-
-
560,000
280,000
3,600,000
1,800,000
Calcium
-
-
1,400
1,400
1,400
1,400
Coal Gas
•
-
-
-
180,000
180,000
Copper
5,200,000
520,000
5,200,000
520,000
5,200,000
520,000
Elemental Phosphorus
57,000
29,000
57,000
29,000
57,000
29,000
Fluorspar and Hydrofluoric Acid
-
¦ -
120,000
39,000
270,000
89,000
Germanium
.
-
180,000
46,000
460,000
110,000
Lead
65,000
16,000
4,800,000
1,200,000
10,000,000
2,600,000
Magnesium and Magnesia from Brines
1,600,000
820,000
1,700,000
830,000
1,700,000
870,000
Mercury
-
-
190,000
27,000
810,000
120,000
Molybdenum, Ferromolybdenum, and
Ammonium Moiybdate
„
8,100,000
740,000
29,000,000
2,600,000
Platinum Group Metals
-
160,000
53,000
240,000
79,000
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
_
1,500,000
740,000
5,200,000
2,600,000
Rare Earths
220,000
220,000
1,400,000
1,400,000
4,500,000
4,500,000
Rhenium
-
-
2,600,000
1,300,000
5,100,000
2,500,000
Scandium
-
360,000
51,000
430,000
61,000
Selenium
500,000
250,000
670,000
220,000
1,600,000
520,000
Synthetic Rutile
-
-
1,100,000
1,100,000
2,100,000
2,100,000
Tantalum, Columbium, and
Ferrocolumbium
260,000
130,000
470,000
230,000
550,000
280,000
Tellurium
-
-
380,000
190,000
1,400,000
700,000
Titanium and Titanium Dioxide
1,100,000
560,000
15,000,000
2,200,000
28,000,000
4,100,000
Tungsten
•
-
280,000
47,000
650,000
110,000
Uranium
.
-
780,000
46,000
1,400,000
84,000
Zinc
7,600,000
2,500,000
9,800,000
3,300,000
13,000,000
4,200,000
Zirconium and Hafnium
-
1,400,000
690,000
11,000,000
5,300,000
Total
17,000,000
63,000,000
140,000,000
April 15, 1997
-------
A-12
Exhibit A.l-11
Option 1 Incremental Costs Assuming 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
Commodity
Cost ($/yr)
Cost ($/yr)
Cost ($/yr)
Cost (S/yr)
Cost (Sfyr)
Cost (Sfyr)
Alumina and Aluminum
1,400,000
62,000
2,400,000
100,000
2,900,000
130,000
Antimony
-
-
40,000
6,700
52,000
8,600
Beiyllium
-
-
24,000
12,000
440,000
220,000
Bismuth
-
. -
30,000
30,000
53,000
53,000
Cadmium
-
56,000
28,000
.2,400,000
1,200,000
Calcium
-
.
4,300
4,300
7,300
7,300
Coal Gas
-
-
-
.
220,000
220,000
Copper
10,000,000
1,000,000
10,000,000
1,000,000
10,000,000
1,000,000
Elemental Phosphorus
3,100,000
1,600,000
3,100,000
1,600,000
3,100,000
1,600,000
Fluorspar and Hydrofluoric Acid
.
-
190,000
63,000
330,000
110,000
Germanium
.
.
30,000
7,500
37,000
9,200
Lead
21,000,000
5,200,000
26,000,000
6,500,000
30,000,000
7,600,000
Magnesium and Magnesia from Brines
2,800
1,400
3,100
1,500
240,000
120,000
Mercury
-
-
500,000
72,000
1,300,000
190,000
Molybdenum, Ferromolybdenum, and
Ammonium Molytxfate
„
16,000
1,400
16,000
1,400
Platinum Group Metals
-
-
5,900
2,000
38,000
13,000
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
93,000
46,000
110,000
56,000
Rare Earths
6,100
6,100
200,000
200,000
1,100,000
1,100,000
Rhenium
•
9,500
4,700
31,000
15,000
Scandium
-
-
82,000
12,000
140,000
20,000
Selenium
53,000
27,000
•110,000
36,000
280,000
94,000
Synthetic R utile
-
-
550,000
550,000
1,000,000
1,000,000
Tantalum, Columbium, and
Ferrocolumbium
370,000
180,000
260,000
130,000
260,000
130,000
Tellurium
-
-
140,000
71,000
160,000
78,000
Titanium and Titanium Dioxide
93,000
46,000
810,000
,120,000
1,300,000
190,000
Tungsten
-
-
(62,000)
(10,000)
45,000
7,500
Uranium
-
-
220,000
13,000
1,100,000
63,000
Zinc
7,100,000
2,400,000
7,600,000
2,500,000
8,800,000
2,900,000
Zirconium and Hafnium
-
-
110,000
57,000
900,000
450,000
Total
43.000,000
53,000,000
66,000,000
April 15,1997
-------
A-13
Exhibit A.l-12
Option 2 Incremental Costs Assuming 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
Commodity
Cost (Vyr)
Cost($/yr)
Cost ($/yr)
Cost (S/yr)
Cost (S/yr)
Cost ($/yr)
Alumina arid Aluminum
310,000
14,000
810,000
35,000
1,500,000
64,000
Antimony
-
-
8,500
1,400
8,500
1,400
Beryllium
-
2,800
1,400
2,800
1,400
Bismuth
-
-
1,400
1,400
2,100
2,100
Cadmium
-
47,000
23,000
530,000
270,000
Calcium
-
-
4,300
4,300
7,300
7,300
Coal Gas
-
-
-
¦
220,000
220,000
Copper
10,000,000
1,000,000
10,000,000
1,000,000
10,000,000
1,000,000
Elemental Phosphorus
3,100,000
1,600,000
3,100,000
1,600,000
3,100,000
1,600,000
Fluorspar and Hydrofluoric Acid
-
.
52,000
17,000
84,000
28,000
Germanium
-
-
6,400
1,600
8,600
2,200
Lead
21,000,000
5,200,000
26,000,000
6,500,000
30,000,000
7,600,000
Magnesium and Magnesia from Brines
2,800
1,400
3,900
2,000
49,000
25,000
Mercury
-
.
500,000
72,000
1,300,000
190,000
Molybdenum, Ferromolytodenum, and
Ammonium Molybdate
.
16,000
1,400
'16,000
1,400
Platinum Group Metals
- -
-
4,600
1,500
11,000
3,700
Pyrobrtumens, Mineral Waxes, and
Natural Asphalts
_
2,800
1,400
2,800
1,400
Rare Earths
6,100
6,100
200,000
200,000
980,000
980,000
Rhenium
•
-
9,500
4,700
31,000
15,000
Scandium
-
-
9,900
1,400
9,900
1,400
Selenium
53,000
27,000
71,000
24,000
140,000
47,000
Synthetic R utile
.
-
71,000
71,000
130,000
130,000
Tantalum, Columbium, and
Ferrocolumbium
2,800
1,400
2,800
1,400
2,800
1,400
Tellurium
-
4,500
2,300
17,000
8,500
Titanium and Titanium Dioxide
3,200
1,600
130,000
19,000
260,000
37,000
Tungsten
-
-
(62,000)
(10,000)
45,000
7,500
Uranium
-
-
43,000
2,500
100,000
6,000
Zinc
(1,200,000)
(390,000)
(1,100,000)
(370,000)
(1,000,000)
(350,000)
Zirconium and Hafnium
-
-
2,800
1,400
2,800
1,400
Total
33,000,000
40,000,000
48,000,000
April 15,1997
-------
A-14
Exhibit A.l-13
Option 3 Incremental Costs Assuming 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
Commodity
Cost (S/yr)
Cost (S/yr)
Cost ($fyr)
Cost ($/yr)
Cost (S/yr)
Cost (S/yr)
Alumina and Aluminum
310,000
14,000
810,000
35,000
1,500,000
64,000
Antimony
-
-
8,500
1,400
8,500
1,400
Beiyiiium
-
-
2,800
1,400
2,800
1,400
Bismuth
-
-
1,400
1,400
2,100
2,100
Cadmium
-
-
18,000
8,800
460,000
' 230,000
Calcium
-
-
1,400
1,400
1,400
1,400
Coal Gas
-
-
-
-
68,000
68,000
Copper
2,600,000
260,000
2,500,000
250,000
. 2,600,000
260,000
Elemental Phosphorus
200,000
100,000
200,000
100,000
200,000
100,000
Fluorspar and Hydrofluoric Acid
-
-
52,000
17,000
84,000
28,000
Germanium
-
-
6,400
1,600
8,600
2,200
Lead
56,000
14,000
120,000
30,000
150,000
38,000
Magnesium and Magnesia from Brines
2,800
1,400
3,900
2,000
49,000
25,000
Mercury
-
-
9,900
1,400
9,900
1,400
Molybdenum, Ferromolybdenum, and
Ammonium Molybdate
16,000
1,400
16,000
1,400
PlaBnum Group Metals
-
-
4,600
1,500
11,000
3,700
Pyrobitumens, Mineral Waxes, and
Natural Asphalts
2,800
1,400
2,800
1,400
Rare Earths
1,400
1,400
92,000
92,000
320,000
320,000
Rhenium
-
-
3,700
1,800
6,200
3,100
Scandum
-
-
9,900
1,400
9,900
1,400
Selenium
2,800
1,400
14,000
4,600
110,000
37,000
Synthetic Rutile
*
-
71,000
71,000
130,000
130,000
Tantalum, Columbium, and
Ferocolumbium
2,800
1,400
2,800
1,400
2,800
1,400
Tellurium •
-
-
4,500
2,300
17,000
8,500
Titanium and Titanium Dioxide
3,200
1,600
130,000
19,000
260,000
37,000
Tungsten
-
-
8,500
1,400
8,500
1,400
Uranium
-
-
43,000
2,500
100,000
6,000
Zinc
(1,200,000)
(390,000)
(1,100,000)
(370,000)
(1,100,000)
(350,000)
Zirconium and Hafnium
-
-
2,800
1,400
2,800
1,400
Total
2,000,000
3,000,000
"" 5,000,000
April 15,1997
-------
A-15
Exhibit A.l-14
Option 4 Incremental Costs Assuming 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
Commodity
Cost (S/yr)
Cost (S/yr)
Cost (Vyr)
Cost (Vyr)
Cost (S/yr)
Cost (S/yr)
Alumina and Aluminum
32,000
1,400
32,000
1,400
32,000
1,400
Antimony
-
-
(6,900)
(1,100)
(17,000)
(2,900)
Beryllium
-
(11,000)
(5,700)
(330,000)
(160,000)
Bismuth
-
-
(5,900)
(5,900)
(16,000)
(16,000)
Cadmium
-
-
(3,600)
(1,800)
(26,000)
(13,000)
Calcium
-
-
1,400
1,400
1,400
1,400
Coal Gas
-
-
-
1,400
1,400
Copper
14,000
1,400
14,000
1,400
14,000
1,400
Elemental Phosphorus
(240,000)
(120,000)
(240,000)
(120,000)
(240,000)
(120,000)
Fluorspar and Hydrofluoric Acid
-
-
4,200
1,400
4,200
1,400
Germanium
-
-
(3,100)
(780)
(3,000)
(740)
Lead
2,700
660
(920,000)
(230,000)
. (1,700,000)
(430,000)
Magnesium and Magnesia from Brines
2,800
1,400
2,800
1,400
2,800
1,400
Mercury
-
-
(160,000)
(23,000)
(480,000)
(68,000)
Molybdenum, Ferromolybdenum, and
Ammonium Molybdate
16,000
1,400
16,000
1,400
Platinum Group Metals
-
-
4,200
1,400
4,200
1,400
Pyrobftumens, Mineral Waxes, and
Natural Asphalts *
(39,000)
(20,000)
(49,000)
(25,000)
Rare Earths
(1,700)
¦ (1,700)
(30)
(30)
18
18
Rhenium
-
-
2,800
1,400
2,800
1,400
Scandium
-
110,000
16,000
(20,000)
(2,900)
Selenium
(23,000)
(11,000)
(24,000)
(8,000)
(15,000)
(5,100)
Synthetic Rutile
.
-
(6,100)
(6,100)
(13,000)
(13,000)
Tantalum, CoJumbium, and
Ferrocolumbium
(160,000)
(80,000)
(120,000)
(60,000)
(120,000)
(60,000)
Tellurium
•
-
(2,600)
(1,300)
(17,000)
(8,500)
Titanium and Titanium Dioxide
(65,000)
(32,000)
(85,000)
(12,000)
(110,000)
(15,000)
Tungsten
-
-
(9,800)
(1,600)
(16,000)
(2,600)
Uranium
-
-
20,000
1,200
22,000
1,300
Zinc
(2,600,000)
(870,000)
(3,400,000)
(1,100,000)
(3,700,000)
(1,200,000)
Zirconium and Hafnium
•
-
(87,000)
(44,000)
(300,000)
(150,000)
Total
{3,000,000)
(4,900,000)
(7,100,000)
April 15,1997
-------
A - 16
Exhibit A.l-15
Option 1 No Prior Treatment Baseline Impacts
Sector
Production
MT
Price
VMT
Value of
Shipments
Incremental
Sector Cost
$
Economic Impact
(percent of Value of Shipments)
$
Minimum
Expected
Maximum
Minimum
Expected
Maximum
AJumina and Aluminum
3.700.000
1.168
4.321,600.000
3,000.000
4.800.000
6.400.000
0.07
0.11
0.15
Antlmonv
18,000
1.764
31,752.000
-
1.600.000
2.500.000
0.00
5.04
7.87
Beryllium
159
352.640
56.069.760
-
1.800.000
10.000.000
0.00
3.21
17.83
Bismuth
1.100
7.824
8,606,400
-
510.000
1.700.000
0.00
5.93
19.75
Cadmium
1.050
992
1,041,600
-
670.000
7.000.000
0.00
64.32
672.04
Calcium
1.200
4.605
5.526.000
¦ -
4.300
7.300
0.00
0.08
0.13
Coal Gas
170.000.000
-
-
390.000
0.00
0.00
0.23
Copper
1.770.000
2.029
3.591.330.000
15.000.000
15.000.000
15.000.000
0.42
0.42
0.42
Elemental Phosphorus
311.000
1.833
570.063.000
3.500.000
3.500.000
3.500.000
0.61
0.61
0.61
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
-
290.000
590.000
0.00
2.50
5.09
Germanium
10
1.060.000
10.600.000
-
220.000
500.000
0.00
2.08
4.72
Lead
290.000
706
. 204.740.000
21.000.000
32.000.000
43.000.000
10.26
15.63
21.00
Maaneslum and Maanesia from Brines
145.000
3.219
466.755.000
• 1.600.000
1.700.000
2.100.000
0.34
0.36
0.45
Mercury
70
5.512
385.840
-
850.000
2.600.000
0.00
220.30
673.85
Molybdenum. Ferromolvbdenum and Ammonium Molvbdate
239.864.579
-
8.100.000
29.000.000
0.00
3.38
12.09
Platinum GrouD Metals
53.203.971
-
160.000
290.000
0.00
0.30
0.55
Pvrobitumens. Mineral Waxes, and Natural Asphalt
10.000
25
250.000
-
1.600.000
5.400.000
0.00
640.00
2.160.00
Rare Earths
57.372.120
220.000
1.600.000
5.600.000
0.38
2.79
9.76
Rhenium
5
1.200.000
6.000,000
-
2.600.000
5.100.000
0.00
43.33
85.00
Scandium
25
1.500.000
37,500.000
-
370.000
590.000
0.00
0.99
1.57
Selenium
250
11.246
2.811.500
580.000
830.000
1.900.000
20.63
29.52
67.58
Synthetic Rutile
140.000
345
48.300.000
-
1.600.000
3.000.000
0.00
3.31
6.21
tantalum. Columbium. and Ferrocolumbium
60.897.400
810.000
870.000
960.000
1.33
1.43
1.58
Tellurium
60
59.508
3.570.480
.
510.000
1.600.000
0.00
14.28
44.81
Titanium and Titanium Dioxide
2.516.300.000
1.300.000
17.000.000
31.000.000
0.05
0.68
1.23
Tunasten
9.406
40
376.240
-
230.000
710.000
0.00
61.13
188.71
Uranium
40.734.000
.
980.000
2.400.000
0.00
2.41
5.89
Zinc
505.000
1.014
512.070.000
20.000.000
23,000.000
27.000.000
3.91
4.49
5.27
Zirconium and Hafnium
379.899.000
-
1.600.000
12.000.000
0.00
0.42
3.16
Total
67,000,000
120,000.000
220,000,000
April 15, 1997
-------
A - 17
Exhibit A.l-16
Option 2 No Prior Treatment Baseline Impacts
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
3.700.000
1.168
4.321.600.000
1.200.000
3.300.000
4,700.000
0.03
0.08
0.11
Antimony
18.000
1.764
31.752,000
-
1.600.000
2.500.000
0.00
5.04
7.87
Beryllium
159
352,640
56.069.760
1.800.000
10.000,000
0.00
3.21
17.83
Bismuth
1.100
7.824
8.606.400
490.000
1,700,000
0.00
5.69
19.75
Cadmium
1.050
992
1.041.600
620.000
4.400,000
0.00
59.52
422.43
Calcium
1.200
4.605
5.526.000
4.300
7.300
0.00
0.08
0.13
Coal Gas
170.000.000
-
390.000
0.00
0.00
0.23
Copper
1.770.000
2.029
3.591.330.000
15.000.000
15.000.000
15.000.000
0.42
0.42
0.42
Elemental Phosphorus
311.000
1.833
570.063.000
3.500.000
3.500.000
3.500.000
0.61
0.61
0.61
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
-
180.000
370.000
0.00
1.55
3.20
Germanium
10
1.060.000
10.600.000
-
200.000
480.000
0.00
1.89
4.53
Lead
290.000
706
i 204.740.000
21.000.000
32.000.000
43.000.000
10.26
15.63
21.00
Maanesium and Maanesia from Brines
145.000
3.219
466.755.000
1.600.000
1.700.000
1.800.000
0.34
0.36
0.39
Mercury
70
5.512
385.840
-
850.000
2.600.000
0.00
220.30
673.85
Molybdenum. Ferromolvbdenum and Ammonium Moivbdate
239.864.579
-
8.100.000
29.000.000
0.00
3.38
12.09
Platinum Group Metals
53.203.971
-
160.000
250.000
0.00
0.30
0:47
Pvrobitumens. Mineral Waxes, and Natural Asphalt
10.000
25
250.000
-
1.500.000
5.300.000
0.00
600.00
2.120.00
Rare Earths
57.372.120
220.000
1.600.000
5.500.000
0.38
2.79
9.59
Rhenium
5
1.200.000
6,000.000
-
2.600.000
5.100.000
0.00
43.33
85.00
Scandium
25
1.500.000
37,500.000
-
260.000
470.000
0.00
0.69
1.25
Selenium
250
11.246
2.811.500
580.000
770.000
1.700.000
20.63
27.39
60.47
Synthetic Rutile
140.000
345
48.300.000
-
1.300.000
2.400.000
0.00
2.69
4.97
Tantalum. Columbium. and Ferrocolumblum
60.897.400
470.000
620.000
700.000
0.77
1.02
1.15
Tellurium
60
59.508
3.570.480
-
390.000
1.500.000
0.00
10.92
42.01
Titanium and Titanium Dioxide
2.516.300.000
1.200.000
16.000.000
29.000.000
0.05
0.64
1.15
Tunasten
9.406
40
376.240
-
230.000
710.000
0.00
61.13
188.71
Uranium
40.734.000
-
820.000
1.500.000
0.00
2.01
3.68
Zinc
505.000
1,014
512.070.000
9.600.000
13.000.000
17.000.000
1.87
2.54
3.32
Zirconium and Hafnium
379.899.000
-
1.500.000
11.000.000
0.00
0.39
2.90
Total
54.000,000
110.000.000
200,000,000
April 15, 1997
-------
A -18
Exhibit A.l-17
Option 3 No Prior Treatment Baseline Impacts
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
3.700.000
1.168
4,321,600.000
1,200.000
3.300.000
4.700.000
0.03
0.08
0.11
Antimony
18.000
1.764
31.752.000
.
1,600.000
2.500.000
0.00
5.04
7.87
Beryllium
159
352.640
66.069.760
-
1.800.000
10.000.000
0.00
3.21
17.83
Bismuth
1.100
7.824
8.606.400
.
490.000
1.700.000
0.00
5.69
19.75
Cadmium
1.050
992
1,041.600
-
590.000
4.300.000
0.00
56.64
412.83
Calcium
1,200
4.605
5.526.000
.
1.400
1.400
0.00
0.03
0.03
Coal Gas
170.000.000
. .
.
260.000
0.00
0.00
0.15
Copper
1,770.000
2.029
3.591.330.000
8.200.000
8.100.000
8.200.000
0.23
0.23
0.23
Elemental Phosphorus
311.000
1,833
' 570.063.000
540.000
540,000
540.00)
0.09
0.09
0.09
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
.
180.000
370.0®
0.00
1.55
3.20
Germanium
10
1.060.000
10.600.000
.
200.000
480.000
0.00
1.89
4.53
Lead
290.000
706
204.740.000
120.000
6.100.000
13.000.000
0.06
2.98
6.35
Maaneslum and Magnesia from Brines
145.000
3.219
466,755.000
1.600.000
1.700.000
1.800.000
0.34
0.36
0.39
Mercury
70
5.512
385.840
.
420.000
1.400.000
0.00
108.85
362.84
Molybdenum. Ferromolvbdemim and Ammonium Molvbdate
239.864.579
.
8.100.000
29.000.000
0.00
3.38
12.09
Platinum Group Metals
53.203.971
160.000
250.000
0.00
0.30
0.47
Pvrobltumens, Mineral Waxes, and Natural Asphalt
10.000
25
250.000
.
1.500.000
5.300.000
0.00
600.00
2.120.00
Rare Earths
57.372.120
220.000
1.500.000
5,000,000
0.38
2.61
8.72
Rhenium
5
1.200,000
6.000.000
-
2.600.000
5,100.000
0.00
43.33
85.00
Scandium
25
1.500.000
37.5m.000
.
260.000
470.000
0.00
0,69
1.25
Selenium
250
11.246
2.811.500
550.000
730.000
1.700.000
19.56
25.96
60.47
Synthetic Rutile
140.000
345
48.300.000
.
1.300.000
2.400.000
0.00
2.69
4.97
Tantalum, Columblum, and Ferrocolumbium
60.897.400
470.000
620.000
700.000
0.77
1.02
1.15
Tellurium
60
59.508
3.570.480
.
390.000
1.500.000
0.00
10.92
42.01
Titanium and Titanium Dioxide
2.516.300.000
1.200.000
16.000.000
29.000,000
0.05
0.64
1.15
Tungsten
9.406
40
376.240
.
320.000
690.000
0.00
85.05
183.39
Uranium
40.734.000
.
820.000
1.500.000
0.00
2.01
3.68
2nc
505.000
1.014
512,070.000
9.600.000
13.000.000
17.000.000
1.87
2.54
3.32
Zirconium and Hafnium
379,899,000
.
1,500.000
11.000.000
0,00
0.39
2.90
Total
24,000,000
74,000,000
160,000,000
-April 15, 1997
-------
A- 19
Exhibit A.l-18
Option 4 No Prior Treatment Baseline Impacts
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
3.700.000
1.168
4.321.600.000
770.000
2.200.000
3.000.000
0.02
0.05
0.07
Antlmonv
18.000
1.764
31.752.000
1.600.000
2.400.000
0.00
5.04
7.56
Beryllium
159
352.640
56.069.760
1.800.000
9.500.000
0.00
3.21
16.94
Bismuth
1.100
7.824
8.606.400
480.000
1.700.000
0.00
5.58
19.75
Cadmium
1.050
992
1.041.600
560.000
3.600.000
0.00
53.76
345.62
Calcium
1.200
4.605
5.526.000
1.400
1,400
0.00
0.03
0.03
Coal Gas
170.000.000
-
180.000
0.00
0.00
0.11
Copper
1.770.000
2.029
3.591.330.000
5.200.000
5.200.000
5.200.000
0.14
0.14
0.14
Elemental Phosphorus
311.000
1.833
570.063,000
57.000
57.000
57.000
0.01
0.01
0.01
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
-
120.000
270.000
0.00
1.04
2.33
Germanium
10
1.060.000
10.600,000
-
180.000
460.000
0.00
1.70
4.34
Lead
290.000
706
204,740.000
65.000
4.800.000
10.000,000
0.03
2.34
4.88
Maaneslum and Maanesia from Brines
145.000
3.219
466,755,000
1.600.000
1.700.000
1.700.000
0.34
0.36
0.36
Mercurv
70
5.512
385,840
-
190.000
810.000
0.00
49.24
209.93
Molybdenum. Ferromolvbdenum and Ammonium Molvbdate
239.864.579
-
8.100.000
29.000.000
0.00
3.38
12.09
Platinum Group Metals
53.203.971
-
160.000
240.000
0.00
0.30
0.45
Pvrobitumens, Mineral Waxes, and Natural Asphalt
10.000
25
250.000
-
1.500.000
5.200.000
0.00
600.00
2.080.00
Rare Earths
57.372.120
220.000
1.400.000
4.500.000
0.38
2.44
7.84
Rhenium
5
1.200.000
6,000.000
¦
2.600.000
5.100.000
0.00
43.33
85.00
Scandium
25
1.500.000
37.500.000
-
360.000
430.000
0.00
0.96
1.15
Selenium
250
1.1.246
2.811.500
500.000
670.000
1.600.000
17.78
23.83
56.91
Synthetic Rutile
140.000
345
48.300.000
-
1.100.000
2.100.000
0.00
2.28
4.35
Tantalum. Columbium. and Ferrocolumbl'um
60.897.400
260.000
470.000
550.000
0.43
0.77
0.90
Tellurium
60
59.508
3.570.480
-
380.000
1.400.000
0.00
10.64
39.21
Titanium and Titanium Dioxide
2,516,300.000
1,100,000
15.000,000
28.000.000
0.04
0.60
1.11
Tunasten
9.406
40
376.240
280.000
650.000
0.00
74.42
172.76
Uranium
40.734,000
-
780.000
1.400.000
0.00
1.91
3.44
Zinc
505.000
1,014
512.070,000
7.600.000
9,800,000
13.000.000
1.48
1.91
2.54
Zirconium and Hafnium
379.899.000
-
1.400.000
11.000.000
0.00
0.37
2.90
Total
17,000,000
63,000,000
140,000,000
April 15, 1997
-------
A-20
Exhibit A.l-19
Option 1 Prior Treatment Baseline Impacts
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
3.700,000
1.168
4.321600.000
1.400.000
2.400.000
2.900.000
0.03
0,06
0.07
Antimony
18.000
1.764
31.752.000
-
40.000
52.000
0.00
0.13
0.16
Beryllium
159
352.640
S6.069.760
-
24.000
440.000
0.00
0.04
0.78
Bismuth
1.100
7.824
8.606.400
-
30.000
53.000
0.00
0.35
0.62
Cadmium
1.080
992
1.041.600
-
56.000
2.400.000
0.00
5.38
230.41
Calcium
1.200
4,605
5.526.000
-
4.300
7,300
0.00
0.08
0.13
Coal Gas
170.000.000
-
-
220,000
0.00
0.00
0.13
Copper
1.770.000
2.029
3.591.330.000
10.000,000
10.000.000
10.000.000
0.28
0.28
0.28
Elemental Phosohonjs
311.000
1.833
570.063.000
3.100.000
3.100.000
3.100.000
0.54
0.54
0.54
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
"
190.000
330.000
0,00
1.64
2.85
Germanium
10
1.060,000
10.600.000
-
30.000
37.000
0.00
0.28
0.35
Lead
290.000
706
. 204.740.000
21.000.000
26.000.000
30.000.000
10.26
12.70
14.65
Maanesium and Maanesla from Brines
145.000
3.219
466.755.000
2.800
3.100
240.000
0.00
0.00
0.05
Mercury
70
5.512
385.840
-
500.000
1.300.000
0.00
129.59
336.93
Molybdenum. Ferromolybdenum and Ammonium Molvbdate
239.864.579
-
16.000
16.000
0,00
0.01
0.01
Platinum Group Metals
53.203.971
-
5.900
38.000
0.00
0,01
0 07
Pvrobltumens, Mineral Waxes, and Natural Asphalt
10.000
25
250,000
-
93.000
110.000
0 00
37.20
44.00
Rare Earths
57.372.120
6.100
200.000
1.100.000
0.01
0.35
1.92
Rhenium
5
1,200.000
6.000.000
.
9.500
31.000
0.00
0.16
0.52
Scandium
25
1.500.000
37.500.000
-
82.000
140.000
0.00
0.22
0.37
Selenium
250
11.246
2,811.500
53.000
110.000
280.000
1.89
3.91
9.96
Synthetic Rutile
140,000
345
48.300.000
-
650.000
1.000.000
0.00
1.14
2.07
Tantalum. Columblum. and Fenrocolumbium
60.897.400
370.000
260.000
260.000
0.61
0.43
0.43
Tellurium
60
59.508
3.570.480
-
140.000
160.000
0.00
3.92
4.48
Titanium and Titanium Dioxide
2,516.300,000
93.000
810.000
1.300.000
0.00
0.03
0.05
Tunaslen
9.406
40
376.240
-
{62.000)
45.000
0.00
-16.48
11.96
Uranium
40.734.000
.
220.000
1.100.000
0,00
0.54
2.70
Zinc
505.000
1.014
512.070.000
7.100.000
7,600.000
8.800.000
1.39
1.48
1.72
Zirconium and Hafnium
379.899.000
.
110.000
900.000
0.00
0.03
0.24
Total
43,000,000
53,000,000
66,000,000
April 15, 1997
-------
A-21
Exhibit A.l-20
Option 2 Prior Treatment Baseline Impacts
Sector
Production
MT
Price
$/MT
Value ol
Shipments
incremental
Sector Cost
$
Economic Impact
(percent ot Value of Shipments)
$
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.700,000
1.168
4.321,600.000
310.000
810.000
1.500.000
0.01
0.02
0,03
Antlmonv
18.000
1.764
31.752.000
8.500
8.500
0.00
0.03
0.03
Beryllium
159
352.640
56.069.760
2.800
2.800
0.00
0.00
0.00
Bismuth
1.100
7.824
8.606.400
1.400
2.100
0.00
0.02
0.02
Cadmium
1.050
992
1.041.600
47.000
530.000
0.00
4.51
50.88
Calcium
1.200
4.605
5.526.000
4.300
7.300
0.00
0.08
0.13
Coal Gas
170.000.000
.
220,000
0,00
0.00
0,13
Copper
1.770.000
2.029
3.591.330.000
10.000.000
10.000.000
. 10.000.000
0.28
0.28
0.28
Elemental Phosphorus
311.000
1.833
570.063.000
3.100.000
3.100.000
3.100.000
0.54
0.54
0.54
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
-
52.000
84.000
0.00
0.45
0.73
Germanium
10
1.060.000
10.600.000
.
6,400
8.600
0.00
0.06
0.08
Lead
290.000
706
, 204.740.000
21.000.000
26.000.000
30.000,000
10.26
12.70
14.65
Magnesium and Maanesia from Brines
145.000
3.219
466.755.000
2.800
3.900
49.000
0.00
0.00
0.01
Mercury
70
5.512
385.840
-
500.000
1.300.000
0.00
129.59
336.93
Molybdenum. Ferromotvbdenum and Ammonium Molvbdate
239.864.579
.
16.000
16.000
0.00
0.01
0.01
Platinum Grew Metals
53.203.971
.
4.600
11,000
0,00
0.01
0.02
Pvrobltumens. Mineral Waxes, and Natural Asohalt
10.000
- 25
250.000
-
2.800
2.800
0.00
1.12
1.12
Rare Earths
57.372.120
6.100
200.000
- 980.000
0.01
0.35
1.71
Rhenium
5
1.200.000
6.000.000
.
9.500
31.000
0.00
0.16
0.52
Scandium
25
1.500,000
37.500.000
.
9.900
9.900
0.00
0.03
0.03
Selenium
250
11.246
2.811.500
53,000
71.000
140.000
1.89
2.53
4.98
Synth etioRutile
140,000
345
48.300.000
.
71.000
130.000
0.00
0.15
0.27
Tantalum, Columbium. and Ferrocolumbium
60.897.400
2.800
2.800
2.800
0.00
0.00
0.00
Tellurium
60
59.508
3.570.480
.
4.500
17.000
0.00
0.13
0.48
Titanium and Titanium Dioxide
2.516.300.000
3.200
130.000
260.000
0.00
0.01
0.01
Tunasten
9.406
40
376.240
-
(62,000)
45.000
0.00
-16.48
11.96
Uranium
40.734.000
-
43.000
100,000
0.00
0.11
0.25
Zinc
505.000
1.014
512.070.000
n.200.000)
(1.100,000)
(1.000.000)
-0.23
-0.21
-0,20
Zirconium and Hafnium
379.899.000
.
2.800
2.800
0.00
0.00
0.00
Total
33,00^000
40,000,000
48,000,000
April 15, 1997
-------
A-22
ExhibitA.l-21
Option 3 Prior Treatment Baseline Impacts
Sector
Production
MT
Price
pm
Value of
Shipments
Incremental
Sector Cost
$
Economic Impact
{percent of Value ot Shipments)
$
Minimum
Expected
Maximum
Minimum
Expected
Maximum
Alumina and Aluminum
3.700.000
1.168
4.321.600.000
310.000
810.000
1.500.000
0.01
0.02
0.03
Antlmonv
18.000
1.764
31.752.000
-
8.500
8.500
0.00
0.03
0.03
Beryllium
. 159
352.640
56.069.760
-
2.800
2,800
0.00
0.00
0.00
Bismuth
1.100
7.824
6.606.400
-
1.400
2.100
0.00
0.02
0.02
Cadmium >
1.050
992
1.041.600
.
18.000
460.000
0.00
1.73
44.16
Calcium
1.200
4.605
5.526.000
•
1,400
1.400
0.00
0.03
0.03
Coal Gas
170.000.000
-
-
68.000
0.00
0.00
0.04
Copper .
1.770.000
2.029
3.591.330.000
2,600.000
2.500.000
2.600.000
0.07
0.07
0.07
Elemental Phosohorus
311.000
1.833
570.063.000
200.000
200.000
200.000
0,04
0.04
0.04
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
-
52.000
84.000
0.00
0.45
0.73
Germanium
10
1.060.000
10.600.000
.
6.400
8.600
0.00
0.06
0.08
Lead
290.000
706
204.740.000
56.000
120.000
150.000
0.03
0.06
0.07
Maanesium and Maanesia from Brines
145.000
3.219
466.755.000
2.800
3.900
49.000
0.00
0.00
0.01
Morcurv
70
5.512
385.840
•
9.900
9.900
0.00
2.57
2.57
Molybdenum. Ferromotvbdemim and Ammonium Molvbdate
239.864.579
.
16.000
16.000
0.00
0.01
0.01
Platinum Grouo Metals
53.203.971
.
4.600
11.000
0.00
0.01
0.02
Pyrobitumens. Mineral Waxes, and Natural Asohalt
10.000
25
250,000
.
2.800
2.800
0.00
1,12
1.12
Rare Earths
57.372.120
1.400
92.000
320.000
0.00
0.16
0.56
Rhenium
5
1.200.000
6.000.000
•
3.700
6.200
0.00
0,06
0.10
Scandium
25
1.500.000
37.500.000
-
9.900
9.900
0.00
0.03
0.03
Selenium ..
250
11.246
2.811.500
2.800
14.000
110.000
0.10
0.50
3.91
Synthetic Rutile
140.000
345
48.300.000
-
71.000
130.000
0,00
0.15
0.27
Tantalum. Columbium.and Ferrocolumbium
60.897.400
2.800
2.800
2.800
0.00
0.00
0.00
Tellurium
60
59.508
3.570.480
'
4.500
. 17.000
0.00
0.13
0.48
Titanium and Titanium Dioxide
2.516.300.000
3.200
130.000
260.000
0.00
0.01
0.01
Tunasten
9.406
40
376.240
.
8.500
8.500
0.00
2.26
2.26
Uranium
40.734.000
-
43.000
100.000
0.00
0.11
0.25
Zinc
505.000
1.014
512.070.000
f 1.200.000]
H,100,000)
(1.100.000)
-0.23
-0.21
-0.21
Zirconium and Hatnium
379,899,000
• .
2,800
2.800
0.00
0.00
0.00
Total
2,000,000
3,000,000
5,000,000
April 15, 1997
-------
A-23
Exhibit A.l-22
Option 4 Prior Treatment Baseline Impacts
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
3.700.000
1.168
4.321.600.000
32.000
32.000
32.000
0.00
0.00
0.00
Antimony
18.000
1.764
31.752.000
"(6.900)
(17.000)
0.00
-0.02
-0.05
Beryllium
159
352.640
56.069.760
(11.000)
(330.000)
0.00
-0.02
-0.59
Bismuth
1.100
7.824
8.606.400
(5.900)
(16.000)
0.00
-0.07
-0.19
Cadmium
1.050
992
1.041.600
(3.600)
(26.000)
0.00
-0.35
-2.50
Calcium
1.200
4.605
5.526.000
1.400
1.400
0.00
0.03
0.03
Coal Gas
170.000.000
-
1.400
0.00
0.00
0.00
Copper
1.770.000
2.029
3.591.330.000
14.000
14.000
14.000
0.00
0.00
0.00
Elemental Phosphorus
311.000
1.833
570.063.000
(240.000)
(240.000)
(240.000)
-0.04
-0.04
-0.04
Fluorspar and Hydrofluoric Acid
60.000
193
11.580.000
-
4.200
4.200
0.00
0.04
0.04
Germanium
10
1.060.000
10.600.000
-
(3.100)
(3.000)
0.00
•0.03
-0.03
Lead "
290.000
706
. 204.740.000
2.700
(920.000)
(1,700.000)
0.00
-0.45
-0.83
Maaneshjm and Maonesla from Brines
145.000
3.219
466.755.000
2.800
2.800
2.800
0.00
0.00
0.00
Mercurv
70
5.512
385.840
-
(160.000)
. (480.000)
0.00
-41.47
-124.40
Molybdenum. Ferromolybdenum and Ammonium Molvbdate
239.864.579
-
16.000
16.000
0.00
0.01
0.01
Platinum Group Metals
53.203.971
-
4.200
4.200
0.00
0.01
0.01
Pvrobltumens. Mineral Waxes, and Natural AsDhalt
10.000
25
250.000
-
(39.000)
(49.000)
0.00
-15.60
-19.60
Rare Earths
57.372.120
(1.700)
(30)
18
0.00
0.00
0.00
Rhenium
5
1.200.000
6,000.000
-
2.800
2.800
0.00
0.05
0.05
Scandium
25
1.500.000
37.500.000
-
110.000
(20.000)
0.00
0.29
-0.05
Selenium
250
11.246
2.811.500
(23.000)
(24.000)
(15.000)
-0.82
-0.85
•0.53
Synthetic Rutlle
140.000
345
48.300.000
-
(6.100)
(13.000)
0.00
-0.01
-0.03
Tantalum. Columbium. and Ferrocolumbium
60.897.400
(160.000)
(120.000)
(120.000)
-0.26
-0.20
-0.20
Tellurium
60
59.508
3.570,480
-
(2.600)
(17.000)
0.00
-0.07
-0.48
Titanium and Titanium Dioxide
2.516.300.000
(65.000)
(85.000)
(110.000)
0.00
0.00
0.00
Tunasten
9.406
40
376.240
-
(9.800)
(16.000)
0.00
-2.60
-4.25
Uranium
40.734.000
-
20.000
22.000
0.00
0.05
0.05
Zinc
505.000
1.014
512.070.000
(2.600.000)
(3.400.000)
(3.700.000)
-0.51
-0.66
-0.72
Zirconium and Hafnium
379.899.000
.
(87.000)
(300.000)
0.00
-0.02
-0.08
Total
(3,000,000)
(4,900,000
(7,100,000)
April 15, 1997
-------
A-24
A.2 Risk and Benefits Assessment Assumptions, Methods, and Results
AJS.l. 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 will 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 with 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 a§ 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.
April 15,1997
-------
A-25
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
treatment baseline and under regulatory 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.2.1.1 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
pre-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 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 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 was removed
because it appears to be redundant with another stream. Two waste streams from lead production were
3 Regulatory Impact Analysis of the Supplemental Proposed Rule Applying Phase IV Land
Disposal Restrictions to Newly Identified Mineral Processing Wastes, December 1995.
April 15,1997
-------
A-26
Exhibit A.2-1
Commodity Waste Streams Included in Revised Benefits Analysis
Commodity
Waste Stream
Aluminum and Alumina
Antimony
Beryllium
Beiylliuro
Beiyllium
Beryllium
Copper
Copper
Copper
Copper
Elemental Phosphorous
Elemental Phosphorous
Elemental Phosphorous
Elemental Phosphorous
Germanium
Germanium
Germanium
Germanium
Lead
Magnesium and Magnesia (brine)
Molybdenum, Ferromolybdenum, Ammonium Molybdate
Rare Earths >
Rare Earths
Selenium
Tantalum, Columbium, and Ferrocolumbium.
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
Titanium and Titanium Dioxide
Tungsten
Zinc
T —
Z3fIC
Zinc
Zinc
Zinc
Zinc
Cast house dust
Autoclave filtrate
Spent barren filtrate streams
Derttanditc tliicke.nci slurry
Chip treatment wastewater
Spent raffinate
Acid plant blowdown (1)
Scrubber blowdown
Spent bleed electrolyte
Surface 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
Process wastewater
Surface impoundment waste liquids
Smut
Liquid 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) .
^^^SSSs^Ssss=s=s=sssss=ss=sa==
April 15,1997
-------
A-27
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 RIA sample-specific risk assessment
These data are summarized in Appendix K of the December RIA, 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 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 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 arsenic were assumed to be carcinogenic.
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 leachable 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 die
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 RIA.
A.2.2.13 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
April 15,1997
-------
A-28
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 precipitatipn and groundwater transport. These variations were
not taken into account in the previous DAF derivations.
The constituent-specific DAF values used in this risk assessment 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 RIA 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 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.
The 95th percentile surface impoundment DAF values derived for this analysis are generally
similar to the HE DAF values used in the RIA. The HE DAF values in the December 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
April 15,1997
-------
A-29
Exhibit A.2-2
Revised Constituent-Specific DAFs for the Mineral Processing Industry
Surface Impoundments (1)
Waste Piles
Constituent
Central Tendency
(75th percentile) Pre-
LDR
High End (95th
percentile) Pre-LDR
Central Tendency (75th
percentile) Pre-LDR
High End (95th
percentile) Pre-LDR
Central Tendency (75th
percentile) Post-LDR
High End (95th
percentile) Post-
LDR
Antimony
1.93E+02
2.28E+01
>10®
8.36E+03
>10"
8.36E+03
Arsenic
1.66E+02
1.71E+01
<3*
O
A
2.56E+03
4.37E+09
2.56E+03
Barium
5.81E+0Q
1.17E+00
2.22E+03
1.38E+01
2.33E+03
1.46E+01
Beryllium
8.47E+00
1.24E+00
>10S
4.87E+02
>10*
5.54E+02
Cadmium
2.49E+01
1.40E+00
>10*
2.67E+03
>10"
3.26E+03
Chromium
9.82E+01
1J5E+01
2.21E+04
1.60E+02
2.21E+04
1.60E+02
Cyanide
2.81E+10
4.20E+03
- (2)
-(2)
--(2)
-(2)
Lead
7.1 IE+05
4.98E+00
>109
2.27E+05
>109
8.93E+08
Mercury
1.97E+02
8.05E+00
>10*
4.29E+03
>10"
4.29E+03
Nickel
2.23E+0I
1.51E+00
1.54E+06
1.41E+02
1.97E+06
1.46E+02
Selenium
2.70E+G1
3.38E+00
1.18E+08
4.28E+02
1.19E+08
4.28E+02
Silver
1.I1E+01
1.23E+00
>10*
4.96E+02
>10"
4.87E+02
Thallium
2.97E+02
4.15E+01
>10®
9.63E+04
>109
9.63E+04
Vanadium
5.67E+00
2.03E+00
>10"
>109
>109
>10"
Zinc
1.23E+01
I.35E+00
>10"
>109
>109
>10* •
Source: U.S. EPA (1996)
Notes:
(1) Post LDR DAFs for surface impoundments were not used in the risk calculations because it was assumed that all liquid wastes would be dewatered under LDRs.
(2) No DAFs were derived for cyanide disposed in waste piles because cyanide concentration data for non-liquid wastes were not available.
April 15, 1997
-------
A-30
in pre-LDR estimated groundwater concentrations and health risks for liquid waste streams of generally
similar magnitude to those calculated in the December 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 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 RIA 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 \v
Lifetime cancer risks for the hypothetical receptor are calculated using the following equation:
^ D. , -EC*IR*EF*ED*CSF
CancerRisk= : ¦—
BW*365 *AT
(1)
Where:
EC = Exposure concentration of constituent in groundwater, mg/1
IR = Water ingestion rate (1.41/day)
EF = Exposure frequency (350 days/year)
ED = Exposure duration (9 years)
CSF = Ingestion pathway Cancer Slope Factor (mg/kg-day)"1
BW = Adult body weight (70 kg)
AT = Averaging time for dose estimation (70 years)
Chronic noncancer hazard quotients for exposure to waste constituents in groundwater are
calculated as follows:
„ *• * EC*IR*EF
HazardQuotient=
BW *365 *RfD
(2)
April 15,1997
-------
A-31
where the RfD is the EPA chronic ingestion pathway Reference Dose for the constituent,4 and the other
variables have the same meaning as in Equation (1). The rationale for selecting the exposure factor values
used in Equations (1) and (2) is discussed in Section 5.2.1.2 of the December RIA.
Two changes were made in the toxicological parameter values which were used to calculate risk
results in this analysis. First, beryllium 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-
ground water 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.2.23.1 Unit of Analysis for Benefits Assessment
Consistent with the December 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.i 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.)
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 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.
4 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 15,1997
-------
A-32
A .2.23.2 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
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 are 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 are then assigned to
risk categories according the risk results from the individual samples from that
waste stream, and from the combined 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
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 RIA, p. 5-37.)
April 15,1997
-------
A-33
judgment. However, as was the case for the sample-specific risk analysis in the December RIA, decisions
about whether to combine samples within facilities had relatively little impact on either the pre-LDR or
post LDR risk 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 are 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 screening 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 RIA is replicated in the risk
calculations that use the newly-revised constituent-specific DAFs are used, 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 RIA is that all of the wastes
with estimated health risks (both CT and HE) above levels of concern pre-LDR (greater than 10 s cancer
risk or hazard quotient > 1.0) move to below the levels of concern post-LDR.
Pre-LDR, CT cancer risks greater than 10"5 are 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 s, with the highest risks again reaching the highest risk category. These proportions
are not very different from those seen pre-LDR in both the December RIA. As rioted above, estimated
cancer risks for all of the waste samples post-LDR are below 10"5.
April 15,1997
-------
EXHIBIT A.2-3
Distribution of Samples by Groundwater Risk Category: Cancer Risks
Central Tendency
Hleh End
Number
Pre-LDR
Post'LDR
Pre-LDR
Post-LDR
of Samples
10-5
104 10-3
IQ'2
10-5
10-4
10-3
10-2
10-5
104
10-3
10-2
10-5
10-4
10-3
10-2
with
to
to to
to
to
to
to
to
to
to
to
to
to
to
to
to
Commodity
Waste Stream
Cancer Risk
<10-5
10*4
10-3 10-2
101
>10-1
<105
10-4
10-3
10-2
10-1
>10-1
<10-5
10-4
10-3
10-2
10-1
>10-1
<10 5
10-4
10-3
10-2
io-i
>10-1
Al and AHimina
Cast house dust
2
2
0
0
0 0
0
2
0
0
0
0
0
2
0
0
0
O
0
2
0
0
0
0
0
Sb
Autoclave filtraie
8
0
0
0
2 6
0
8
0
0
0
0
0
0
0
0
0
2
6
8
0
0
0
o
0
8c
Spent barren filtrate streams
2
1
0
1
0 0
0
2
0
0
0
0
0
0
1
0
1
0
0
2
0
0
0
0
0
Be
Chip treatment WW
1
1
0
0
0 0
0
i
0
0
0
0
0
i
0
0
0
0
0
1
0
0
0
0
0
Cu
Acid plant blowdown
30
?
4
10
4 3
2
3D
0
0
0
0
0
I
6
4
10
4
5
30
0
0
0
0
0
O*
Scrubber blowdown
3
*
0
2
0 0
0
3
0
0
0
0
0
0
1
0
2
0
0
3
0
0
0
0
0
Elements! Phosphorous
AFM rinsate
2
1
1
0
0 0
0
2
a0
0
0
0
0
0
1
1
0
0
0
2
0
0
0
0
0
Elemental Phosphorous
Furnace offgas solids
9
9
0
0
0 0
0
9
0
0
0
0
0
9
0
0
0
0
0
9
0
0
0
0
0
Elemental Phosphorous
Furnace scrubber blowdown
S
4
3
I
0 0
0
8
0
0
0
0
0
1
3
3
I
0
0
8
0
0
0
0
0
Elemental Phosphorous
Slag quenchwater
1
0
1
0
0 0
0
1
0
0
0
0
0
0
0
I
0
0
0
1
0
0
0
o
0
Oc
Waste acid wash/rinse water
1
1
0
0
0 0
0
1
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
0
Oc
Chlorinator wet air poll, clrt. sludge
1
1
0
0
0 0
0
I
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Ge
Hydrolysis filtrate
1
1
0
0
0 0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Oc
Watte still liquor
1
1
0
0
0 1 0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Mg and Magnesia (brine)
Smut
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
Mo, FcMo, Amm Mo
Liquid residues
j •
0
0
0
1 0
0
1
0
0
0
0
0
0
0
0
0
1
0
1
0
0
0
0
0
Rare Earths
Spent ammon nitrate proc. sol.
5
5
0
0
0 0
0
3
0
0
0
0
0
5
0
0
0
0
0
5
0
0
0
0
0
Rare Earths
PWW
2
0
2
0
0 0
0
2
0
-0
0
0
0
0
0
2
0
0
0
2
0
0
0
0
0
Se
Flint PWW
2
0
2
0
0 0
0
2
0
0
0
0
0
0
0
2
0
0
0
2
0
0
0
0
0
Ta, Columbium. and FeCol.
PWW
13
8
2
2
1 0
0
13
0
0
0
0
0
6
3
1
3
0
0
13
0
0
0
0
0
Titanium and Ti02
Pickle liquor & wash water
3
2
1
0
0 0
0
3
0
0
0
0
0
0
2
1
0
0
0
3
0
0
0
0
0
Titanium and Ti02
Leach liquor St sponge wash water
2
i
1
0
0 0
0
2
0
0
0
0
0
0
I
1
0
0
0
2
0
0
0
0
0
Titanium and TI02
Scrap milling scrubber water
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
Titanium and TI02
Spent s i, liquids
0
0
0
0
0 0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Titanium and Ti02
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
0
0
' 0
Titanium and Ti02
Waste acids (Sulfate process)
4
1
3
0
0 0
0
4
0
0
0
0
0
1
0
3
0
0
0
4
0
0
0
0
0
Titanium and.Ti02
WWTP sludge/solids
0
0
0
0
0 0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
W
Spent acid & rinse water
2
1
0
0 0
0
2
0
0
0
0
0
0
1
0
1
0
0
2
0
0
0
0
0
Zn
Waste ferrosiUcon
0
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 si, liquids
0
a
0
1 0
0
1
0
0
0
0
0
0
0
0
0
1
0
I
0
0
0
0
0
Za
WWTP solids
I
1
0
0
0 0
0
1
0
0
0
0
0
0
1
0
0
0
0
1
a
0
0
0
0
Zii
Spent synthetic gypsum
4
4
0
0 -
0 0
0
4
0
0
0
0
0
2
0
2
0
0
0
4
0
0
0
0
0
Zn
WWTP liquid effluent
0
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
Zinc leanilag
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
Totala
1
57
21
17
9 9
2
IIS
0
0
0
0
0
35
21
22
18
8
II
115
o
0
0
0
0
-------
EXHIBIT A.2-4
Distribution of Samples by Groundwater Hazard Category: Non-Cancer Hazards
Central Tendency
Hieh Knd
Number of
Pre-LDR
Posi-LDR
Pre-LDR
Post-LDR
Samples with
1
10
100
Ik
1
10
100
Ik
1
10
100
Ik
1
10
too
Ik
Non*can«r
to
io
to
to
lo
lo
lo
lo
(o
lo
lo
to
to
lo
lo
lo
Commodity
Waste Stream
Hazard
<1
10
too
Ik
10k
>IOk
<1
10
100
Ik
10k
>10k
<1
10
100
Ik
10k
>10k
<1
10
100
lk
10k
>IOk
A! and Alumina
Cast house dust
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
Sb
Autoclave nitrate
8
0
0
0
4
4
0
8
0
0
0
0
0
0
0
0
2
2
4
8
0
0
0
0
0
Be
Spent barren filtrate 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
Be
Chip treatment WW
1
0
0
0
0
1
0
1
0
0
0
0
0
0
0
0
0
0
1
I
0
0
0
0
0
Cu
Acid plant blowdown
35
6
8
13
5
3
0
35
0
0
0
0
0
0
3
8
14
5
5
35
0
0
0
0
0
Cu
Scrubber blowdown
3
0
1
2
0
0
0
3
0
0
0
0
0
0
0
0
3
0
0
3
0
0
0
0
0
Elemental Phosphorous
AFM rinsate
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
Elemental Phosphorous
Furnace offgas solids
14
14
0
0
0
0
0
14
0
0
0
0
0
14
0
0
0
0
0
14
0
0
0
0
0
Elemental Phosphorous
Furnace scrubber blowdown
14
5
6
2
1
0
0
14
0
0
0
0
0
1
1
6
5
1
0
14
0
0
0
0
' 0
Elemental Phosphorous
Slag quenchwater
1
1
0
0
0
0
0
I
0
0
0
0
0
0
1
0
0
0
0
1
0
0
0
0
0
Ge
Waste acid wash/rinse water
1
1
0
0
0
0
0
1
a
0
0
0
0
0
0
1
0
0
0
1
0
0
0
0
0
Oe
Chlorinalor wet air poll. ctrl. sludge
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
Ge
Hydrolysis filtrate
1
1
0
0
0
°
0
1
0
0
0
0
0
1
0
0
0
0
0
I
0
0
0
0
0
Ge
Waste still liquor
1
1
0
0
0
0
0
1
0
0
0
0
0
I
0
0
0
0
0
1
0
0
0
0
0
Mg and Magnesia (brine)
Smut
2
2
0
0
0
0
0
2
0
0
0
0
0
1
1
0
0
0
0
2
0
0
0
0
0
Mo, FeMo, A mm. Mo
liquid residues
1
0
0
1
0
0
0
1
0
0
0
0
0
0
0
0
r
0
0
1
0
0
0
0
0
Rare Ruths
Spent amnion, nitrate proc sol.
6
3
1
0
0
0
0
6
0
0
0
0
0
4
I
1
0
0
0
6
0
0
0
0
0
Rate Earths
PWW
4
2
2
0
0
0
0
4
0
0
0
0
0
1
1
I
i
0
0
4
0
0
0
0
0
Se
Flam PWW
2
1
1
0
0
0
0
2
0
0
0
0
0
0
0
i
i
0
0
2
0
0
0
0
0
Ta, Columblum, and FeCol
PWW
21
13
2
5
0
1
0
21
0
0
0
0
0
8
2
3
2
2
4
21
0
0
0
0
0
Titanium and H02
Pickle liquor A wash water
3
0
3
0
0
0
0
3
0
0
0
0
0
0
0
3
0
0
0
3
0
0
0
0
0
Titanium and T»02
Leach liquor & sponge wash water
2
0
1
I
0
0
0
2
0
0
0
0
0
0
0
2
0
0
0
t
0
0
0
0
0
Titanium and Ti02
Scrap milting scrubber water
1
0
1
0
0
0
0
1
0
0
0
0
0
0
0
1
0
0
0
1
0
0
0
o
o
Titanium and Ti02
Spent »i.'liquids
10
io
0
0
0
0
0
10
0
0
0
0
0
10
0
0
0
0
0
10
0
0
0
0
o
Titanium and Ti02
Spent s i. solids
6
6
0
0
0
0
0
6
0
0
0
0
0
3
3
0
0
0
0
6
0
0
0
0
o
Titanium and Ti02
Waste acids (Sulfate process)
4
0
0
4
0
0
0
4
0
0
0
0
0
0
0
2
2
0
0
4
0
0
0
0
o
Titanium and Ti02
WWTP sludge/solids
2
2
0
0
0
0
0
2
0
0
0
0
0
1
1
0
0
0
0
2
0
0
0
0
o
W
Spent acid & rinse water
4
3
1
0
0
0
0
4
0
0
0
0
0
2
1
0
1
0
0
4
0
0
0
0
0
Zn
Waste ferrosilicon
1
I
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
o
Zit
Spent a.l, liquids
22
4
4
3
6
4
1
22
0
0
0
0
0
0
5
2
3
6
6
22
0
0
0
0
o
Zn
WWTP 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
0
2
1,
0
0
0
0
4
0
0
0
0
0
Zn
WWTP liquid effluent
3
0
1
I
0
0
1
3
0
0
0
0
0
0
0
2
0
0
i
3
0
0
0
0
0
Zn
Zinc lean slag
3
3
0
0
0
0
0
3
0
0
0
0
0
3
0
0
0
0
0
3
0
0
0
0
0
Totals
197
95
35
36
16
13
2
197
0
0
0
0
0
58
26
35
41
16
21
197 0 0 0 0 O
-------
A-36
The distribution 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"5 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 s is 33 out of an estimated 108 facilities.6 Post-LDR, all of the facility-waste stream
combinations fall below the 10'5 CT risk level. In the HE case, 62 out of 133 facility-waste stream
combination have pre-LDR cancer greater than 10 s. 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.
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 4.2.1 of this RIA. Estimated
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 15,1997
-------
EXHIBIT A.2-5
Distribution of Waste Stream/Facility Combinations by Groundwater Risk Category: Cancer Risks
Number of
Waste Stream/
Central Tendency
Hlch End
Facility
Pre-L
DE
Post-LDR
Pre-LDR
Post-LDR
Combinations* #
10-5
10-4
I0-3
10-2
10-5
10-4
10-3
10-2
10-5
10-4
10-3
10-2
10.5 10.4 IA4
10-2
Central
High
to
to
to
to
to
to
to
to
to
to
to
to
IwV ¦ ~ IV J
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
<0-1
>10-1
<10-5
tfl-4
10-3
10-2
10-1
>10-1
<10-5
10-4 10-3 10*2
10-1
>10*1
Al and Ahmvrut
Cast house dust
23
23
23
0
0
0
0
0
23
0
0
0
0
0
23
0
0
0
0
0
23
0 0
0
0
0
Sb
Autoclave filtrate
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
Be
Spent barren filtrate streams
1
I
1
0
1
0
0
0
I
0
0
0
0
0
0
i
0
t
0
0
I
0 0
0
0
0
Be
Chip treatment WW
1
2
\
0
0
0
0
0
1
0
0
0
0
0
2
0
0
0
0
°
2
0 0
0
0
0
Cu
Acid plant blowdown
7
7
2
0
2
1
0
1
7
0
0
0
0
0
0
t
0
2
1
1
1
-0 0
0
0
0
Cu
Scrubber blowdoWn
10
10
. 3
0
7
0
0
0
10
0
0
0
0
0
0
3
0
7
0
0
10
0 0
0
0
0
Elemental Phosphorous
AFM rinsate
2
2
1
0
0
0
0
2
0
0
0
0
0
0
1
|
0
0
0
2
0 0
0
0
0
Elemental Phosphorous
Furnace offgas solids
2
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
Elemental Phosphorous
Furnace scrubber blowdown
2
2
1
0
0
0
0
2
0
0
0
0
0
0
i
1
0
0
0
2
0 0
0
0
0
Elemental Phosphorous
Slag quenchwaier
2
2
0
2
0
0
0
0
2
0
0
0
0
0
0
0
2
0
0
0
2
0 0
0
0
0
Ge
Waste arid wash/rinse water
2
4
2
0
0
0
0
0
2
0
0
0
0
0
0
4
0
0
0
0
4
0 0
0
0
0
Ge
Chlorinator wet air poll, Ctrl, sludge
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
0
0
0
0
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
0
0
4
0 0
0
0
0
Ge
Waste still liquor
2
4
2
0
0
0
0
0
2
0
0
0
0
0
4
0
0
0
0
0
4
0 0
0
0
0
Mg and Magnesia (brine)
Smut
2
2
2
0
0
0
t 0
0
2
0
0
0
0
0
2
0
0
0
0
0
2
0 0
0
0
0
Mo, BeMo, Amm. Mo
Liquid residues
1
2
0
0
0
1
0
0
t
0
0
0
0
0
0
0
0
0
2
0
2
0 0
0
0
0
Rare Earths
Spent arnmon. nilrafe proc, sol.
1
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
1
0 0
0
0
0
Rare Earths
PWW
1
1
0
0
0
0
0
I
0
0
0
0
0
0
0
1
0
0
0
I
0 0
0
0
0
Se
Plant PWW
2
2
0
2
0
0
0
0
2
0
0
0
0
0
0
0
2
0
0
0
2
0 0
0
0
0
Ta, Cotinribium. and EeCol.
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
0
Titanium andT102
Pkkle liquor & wash water
2
3
i
0
0
0
0
2
0
0
0
0
0
0
2
2
0
0
0
3
0 0
0
0
0
Titanium and IKK
LAch liquor &. sponge wash water
I
2
i
0
0
0
0
1
0
0
0
0
0
0
1
1
0
0
0
2
0 0
0
0
o
Titanium and 1102
Scrap nailing scrubber water
1
1
0
0
0
0
0
1
0
0
0
0
0
0
6
1
0
0
0
1
0 0
0
0
0
Titanium and Ti(>2
Spent a.i. liquids
4
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0 0
0
0
0
Titanium and Ti02
Spent s.i. solids
4
?
0
0
0
0
0
0
0
0
0
0
0
0
0
D
0
6
0
0
0
0 0
0
0
0
Titanium and Ti02
Waste acids (Sulfate process)
t
2
0
0
0
0
0
1
0
0
0
0
0
1
0
2
0
0
0
2
0 0
0
0
0
Titanium and Ti02
WWTP sludge/solids
7
7
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0 0
0
0
0
W
Spent actd & 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
Zn
Waste ferrosiltcon
1
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
Zn
Spent si. liquids
3
3
0
0
0
3
0
0
3
0
0
0
0
0
0
0
0
0
3
0
3
0 0
0
0
0
Zn
WWTP solids
3
3
3
0
0
0
0
0
3
0
0
0
0
0
0
3
0
0
0
0
3
0 0
0
0
0
Zn
Spent synthetic gypsum
3
3
3
0
0
0
0
0
3
0
0
0
0
0
2
0
2
0
0
0
3
0 0
0
0
o
Zn
WWTP liquid effluent
3
3
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0 0
G
0
0
Zn
Zinc lean stag
1
1
1
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0
0
0
'
0 0
0
0
0
TOTALS*
103
133
56
11
11
8
2
,
89
0
0
0
0
0
46
20
14
13
10
5
108 0 0 0 0 0
~ Suira by risk category rmy not add to the number of centra! or high-end waste stream/facility combinations due
lo rounding.
i Includes watte strcamrtadlity combinations with no cancer risk (but with an Associated non-
cancer hazard)
-------
EXHIBIT A.2-6
Distribution of Waste Stream/Facility Combinations by Groundwater Hazard Category: Non-Cancer Hazards
Number of
Waste Stream/
Central Tendency
High End
Facility
Pre-LDR
Post-LUK
Pre-LDR
Post-LDR
*
Combinations*
1
10 100 lk
1
10 100 lk
1
10
100
lk
1 10
100 lk
Central
High
to
to to
to ,
to
to to to
to
to
to
to
to to
to to
Commodity
Waste Stream
Tendency
End
<1
10
100 lk
10k
>10k
10k
<1
10
100
lk
10k
>10k
<1
10 100 lk 10k
>10k
A! and Alumina
Cast house dust
23
23
23
0
0
0 0
0
23
0 0 0
0
0
23
0
0
0
0
0
23
0
0 0
0
0
Sb
Autoclave filtrate
4
7
0
0
0
3 1
0
4
0 0 0
0
0
0
0
0
2
2
2
7
0
0 0
0
0
Be
Spent barren filtrate streams
1
1
0
0
1
0 0
0
1
0 0 0
0
0
0
0
0
1
0
0
1
0
0 0
0
0
Be
Chip treatment WW
1
2
0
0
0
0 1
0
I
0 0 0
0
0
0
0
0
0
0
2
2
0
0 0
0
0
Cu
Acid plant biowdown
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
Scrubber biowdown
10
10
0
3
7
0 0
0
10
0 0 0
0
0
0
0
0
10
0
0
10
0
0 0
0
0
Elemental Phosphorous
AFM rinsate
2
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
Elemental Phosphorous
Furnace offgas solids
2
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
Elemental Phosphorous
Furnace scrubber biowdown
2
2
1
1
0
0 0
0
2
0 0 0
0
0
0
0
1
1
0
0
2
0
0 0
0
0
Elemental Phosphorous
Slag quenchwater
2
2
2
0
0
0 0
0
2
0 0 0
0
0
0
2
0
0
0
0
2
0
0 0
0
0
Ge
Waste acid wash/rinse water
2
4
2
0
0
0 0
0
2
0 0 0
0
0
0
0
4
0
0
0
4
0
0 0
0
0
Ge
Chlorinator wet air poll. Ctrl, sludge
2
4
2
0
0
0 0
0
2
0 0 0
0
0
4
0
0
0
0
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
0
0
4
0
0 0
0
0
Qe
Waste still liquor
2
4
2
0
0
0 0
0
2
0 0 0
0
0
4
0
0
0
0
0
4
0
0 0
0
0
Mg and Magnesia (brine)
Smut
2
2
2
0
0
0 0
0
2
0 0 0
0
0
1
1
0
0
0
0
2
0
0 0
0
0
Mo, FeMo, A mm. Mo
Liquid residues
1
2
0
0
1
0 0
0
I
0 0 0
0
0
0
0
0
2
0
0
2
0
0 0
0
0
Rare Earths
Spent amnion, nitrate proc. sol.
1
I
1
0
0
0 0
0
1
0 0 0
0
0
1
0
0
0
0
0
|
0
0 0
0
0
Rare Earths
PWW
1
1
I
0
0
0 0
0
1
0 0 0
0
0
0
0
0
0
0
0
1
0
0 0
0
0
Se
Plant PWW
2
2
1
1
0
0 0
0
2
0 0 0
0
0
0
0
1
1
0
0
2
0
0 0
0
0
Ta, Columbium, and FeCoI.
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
0
Titanium and Ti02
Pickle liquor & wash water
2
3
0
2
0
0 0
0
2
0 0 0
0
0
0
0
3
0
0
0
3
0
0 0
0
0
Titanium and Ti02
Leach liquor & sponge wash water
1
2
0
1
1
0 0
0
1
0 0 0
0
0
0
0
2
0
0
0
2
0
0 0
0
0
Titanium and Ti02
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 0
0
0
Titanium and Ti02
Spent s.i. liquids
4
7
' 4
0
0
0 0
0
4
0 0 0
0
0
7
0
0
0
0
0
7
0
0 0
0
0
Titanium and Ti02
Spent s.i. solids
4
7
4
0
0
0 0
0
4
0 0 0
0
0
5
2
0
0
0
0
7
0
0 0
0
0
Titanium and Ti02
Waste acids (Sulfate process)
1
2
0
0
1
0 0
0
1
0 0 0
0
0
0
0
1
1
0
0
2
0
0 0
0
0
Titanium and Ti02
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
Spent acid & rinse water
3
6
2
1
0
0 0
0
3
0 0 0
0
0
3
2
0
2
0
0
6
0
0 0
0
0
Zn
Waste fetrosilicon
1
1
1
0
0
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
3
3
0
1
1
0 1
0
3
0 0 0
0
0
0
1
0
1
0
1
3
0
0 0
0
0
Zn
WWTP solids
3
3
3
0
0
o b
0
.3
0 0 0
0
0
1
1
|
0
0
0
3
0
0 0
0
0
Zn
Spent synthetic gypsum
3
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
WWTP liquid effluent
3
3
0
1
1
0 0
1
3
poo
0
0
0
0
2
0
0
1
3
0
0 0
0
0
Zn
Zinc lean slag
1
1
1
0
0
0 0
0
1
0 0 0
0
0
'
0
o
0
0
0
1
0
0 0
0
0
TOTALS*
-
108
133
63
16
14
4 4
,
ios
0-0 0
0
0
63
15
19
24
4
8
133
0
0 0
0
0
* Surra by hazard category may not add to the number of centra) or high-end waste stream/facility
combination! due to rounding.
-------
A-39
Exhibit A.2-7
Distribution of Waste Stream/Facility Combinations by Groundwater Risk
and Hazard Categories
100 T
J-* »
sr c
— o
80 -
(R S
•7 «
> c
60 -
E 3
S &
40 -
|o
20 -
o-
u
Cancer Risk
Central Tendency
~ Pre-LDR
I Post-LDR
<10K
I
10&5KJ10E4 10E-4 to 10E-3 10E-3» 10E-2
Risk Category
10E-2&10E-1
>106-1
120
5 | | «0
I
" ¦ c
ll i
|Su 20
* 8
120 T
: rl
Cancer Risk
'High End
£S toes <0 foe-* f oe-4 to foe-j to me-i f oe-2 to f oe-r
J7<(k Category
1 to 10
Nan-Cancer Risk
Central Tendency
10tO
100
100 to
1,000
1,000*)
10,000
>10,000
Risk Category
$
$
•
jj
150 -
|
i
«
o
«
100 -
o
e
©
JD
a
a>
2
E
50 -
£
3
£
5>
o
o
z
0 ••
: I
10,000
Risk Category
April 15,1997
-------
A-40
groundwater pathway cancer risks under high-end (HE) baseline assumptions exceeded 10"5 at 24 of 57
facilities storing recycled streams, while under central tendency (CT) assumptions, only 11 facilities
exceed this level (Exhibit 4-8). The HE noncancer hazard quotients for groundwater exposures exceed 1.0
at 28 facilities storing recycled materials, and under CT assumptions baseline hazard quotients exceed 1.0
at 12 facilities. 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 die pathways evaluated, estimated 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 Ml 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 for 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 10'5. 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 storage facilities exceeded levels of concern for the fish ingestion
pathway. These results are summarized in Exhibit 4-12.
As noted above, the 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 required management units for most of the recycled
streams under regulatory Options 1-3. If these options completely or substantially abolish 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 results in less risk
reduction and lower health benefits. Under options 1 and 2, it is clear that risks for three of the streams
currently managed through Bevill units (copper acid plant blowdown, and the two streams from elemental
phosphorous production) would be greatly reduced by the requirement to manage these wastes in Subtitle
C units. Copper acid plant blowdown figures prominently as a contributor to storage risks through both
the groundwater and non-groundwater pathways. Under Option 4, no health benefits associated with the
storage of recycled streams would be realized, as there is no requirement for improved management of
these streams.
A.2.4.0 LIMITATIONS AND UNCERTAINTIES OF RISK AND BENEFITS ASSESSMENT
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. -
April 15,1997
-------
A-41
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 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 an attempt to address some of these uncertainties, continuing the
process of refinement which began with the sensitivity analysis performed as part of the December 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 has 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 RIA, a number of waste streams were removed from the risk and benefits
analysis, either 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
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 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 EP and bulk analysis data were used in this analysis to develop separate risk estimates for NWW and
LNWW 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 2.1.2. 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
April 15,1997
-------
A-42
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 die
dramatic reduction in estimated post-LDR 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 (e.g., primarily western, with low rainfall and high depth to groundwater).
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.
A.2.4.2 Major Uncertainties in the Risk Assessment for Storage of Recycled Materials
The major limitations and sources of uncertainty in the multipathway risk assessment for the
storage of recycled materials are discussed in detail in Appendix H, and will not be further addressed here.
A.23 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 8,1996.
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.
April 15,1997
-------
A-43
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.
A3 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 15,1997
-------
A-44
Exhibit A3-1
List of Wastes for Which Constituent-Specific Data were Available
Commodity
Waste Stream
Aluminum and Alumina
Cast house dust
Antimony
Autoclave filtrate
Berryllium
Spent barren filtrate streams
Berryllium
Chip treatment wastewater
Copper
Acid plant blowdown
Copper
Scrubber blowdown
Elemental Phosphorous
AFMrinsate
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, Femomolybdenum, 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
Wastp acids (Sulfate process)
Titanium and Titanium Dioxide
Wastewater treatment plant sludge/solids
Tungsten
Spent acid & rinse water
Zinc
Waste fenosilicon
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 15,1997
-------
A-45
Exhibit A.3-2
Constituent-Specific DAFs Used to Evaluate Groundwater Exposures
Surface Im
loundments
Waste Piles
Constituent
Central Tendency
High End (95th
Central Tendency (75th
High End (95th
Central Tendency (75th
High End (95th
-
(75th percentile) Pre-
percentile) Pre-LDR
percentile) Prc-LDR
percentile) Pre-LDR
percentile) Post-LDR
percentile) Post-
LDR
LDR
Antimony
1.93E+02
2.28E+01
>10®
8.36E+03
>10®
8.36E+03
Arsenic
1.66E+02
1.71E+01
>10*
2.56E+03
4.37E+09
2.56E+03
Barium
5.81E+00
1.17E+00
2.22E+03
1.38E+01
2.33E+03
1.46E+01
Beryllium
8.47E+00
1.24E+00
>10*
4.87E+02
>10®
5.54E+02
Cadmium
2.49E+01
1.40E+00
>109
2.67E+03
>10®
3.26E+03
Chromium
9.82E+01
1.15E+01
2.21E+04
1.60E+02
2.21E+04
1.60E+02
Cyanide
2.81E+10
4.20E+03
-
-
-
-
Lead
7.11E+05
4.98E+00
>109
2.27E+05
>10'
8.93E+08
Mercury
1.97E+02
8.05E+00
>10"
4.29E+03
>10®
4.29E+03
Nickel .
2.23E+01
1.51E+00
1.54E+06
1.41E+02
1.97E+06
1.46E+02
Selenium
2.70E+01
3.38E+00
1.18E+08
4.28E+02
1.19E+08
4.28E+02
Silver
l.HE+01
1.23E+00
>10®
4.96E+02
>10®
4.87E+02
Thallium
2.97E+02
4.15E+01
>10"
9.63E+04
>10®
9.63E+04
Vanadium
5.67E+00
2.03E+00
>10"
>10®
>10®
>10?
Zinc
1.23E+01
1.35E+00
>10*
>10®
>10'
>10®
Note: Central Tendency values are the 75th percentile of the distribution of DAF values and the High End values are the 95th percentile.
April 15,1997
-------
A-46
Exhibit A.3-3
Toxicity Parameter Values Used in the Risk Analysis
Oral Cancer
Oral Reference
Slope Factor (CSF)
Dose (RfD)
Constituent
l/(mg/kg-day)
mg/kg-day
Antimony
—
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
—
0.00008
Vanadium
—
0.007
Zinc
—
0.3
Cyanide
—
0.02
Fluoride
—
0.06
Source; EPA IRIS (1996) and HEAST (1995)
The Lead RfD is derived from the EPA action level of 0.015 mg/L.
The RfD for Chromium is from Cr+6.
The RID for Thallium is from Thallium sulfate.
t
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 15,1997
-------
A-47
Exhibit A.3-4 - Example Risk Calculation for a Single Waste Sample from Concentration Data to Risk Results
Waste Stream Data & Calculations
Cancer
Non-Cancer
Sample
Central Tendency
High End
Central Tendency High End
Commodity Waste Stream Number
Pre-LDR
Post-LDR
Pre-LDR
Post-LDR
Pre-LDR
Post-LDR Pre-LDR Post-LDR
Bare Earths Spent ammonium nitrate 7
5.57E-08
2.12E-12
5.41 E-07
5.41 E-07
3.85E-03
4.47E-04 1.41E-01 1.17E-02
processing solution
The cancer risk values are the sum of risks from each constituent In a sample.
Facility Identifier = Res. Chem, Phoenix
The non-cancer hazard values represent the highest hazard quotient for a constituent In a sample.
State = AZ
. •
Total
Treatment Type
Constituent EP Toxicity
Pre-LDR DAFS
Po§t-LDR DAFS
Waste 1 10%
Analysis
Analysis
Central
High
Central
High
Water Solids
Solid
Constituents
(pom)
(ppm)
Tendencv
End
Tendency
End
1 0
0
Aluminum
10
0
Antimony
1.93E+02
2.28E+01
3.00E+13
8.36E+03
1 0
0
Arsenic
0.0025
1.66E+02
1.71E+01
4.37E+09
2.56E+03
1 0
0
Barium
0.05
5.81 E+00
1.17E+00
2.33E+03
1.46E+01
1 0
0
Beryllium
8.47E+00
1.24E+00
2.13E+15
5.54E+02
1 o
0
Boron
0.12
1 0
0
Cadmium
0.0025
2.49E+01
1.40E+00
6.12E+16
3.26E+03
1 0
0
Chromium
0.01
9.02E+O1
1.15E+01
2.21 E+04
1.60E+02
1 0
0
Copper
0.005
1 0
0
Iron
1 0
0
Lead
0.011
7.11E+05
4.98E400
1.00E+30
8.93E+08
1 0
0
Magnesium
1 0
0
Manganese
0,005
1 0
0
Mercury
0.0001
1.97E+02
8.05E+00
6.37E+12
4.29E+03
1 0
0
Molybdenum
1 0
0
Nickel
2.23E+01
1.51 E+00
1.97E+06
1.46E+02
1 0
0
Selenium
0.0025
2.70E+01
3.38E+00
1.19E+08
4.2SE+02
1 0
0
Silver
0.005
1.11E+01
1.23E+00
1.33E+10
4.87E+02
1 0
0
Thallium
2.97E+02
4.15E+01
1.23E+28
9.63E+04
1 0
0
Vanadium
5.67E+00
2.03E+00
1.00E+30
1.00E+30
1 0
0
Zinc
0.005
1.23E+01
1.35E+00
1.34E+16
1.77E+03
1 0
0
Cyanide
0.005
2.81E+10
4.20E+03
1 0
0
Sulfide
0.025
1 0
0
Fluoride
For constituents with a DAF, If the treatment type Is solid (the solid column has a 1), the DAF value returned Is for waste piles;
otherwise, the DAF value returned Is tor surface Impoundments. See Exhibit A.3-2 for the DAF values.
April 15, 1997
-------
A-48
Exhibit A.3-4 (Continued) - Example Risk Calculation for a Single Waste Sample from Concentration Data to Risk Results
1.51E-05
8.61 E-03
1.00E-04
1.02E-04
Qroundwate
Cone
Constituents (ppm=mg/L)
Aluminum
Antimony
Arsenic
Barium
Beryllium
Boron
Cadmium
Chromium
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Molybdenum
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Cyanide
Sulfide
Fluoride
Pre-LDRs - Central Tendency
Cancer Noncancer Lifetime
Dose Dose Excess Hazard
(mq/kq-d) (mg/kg-d) Cancer Risk Quotient
3.71 E-08 2.89E-07 5.57E-08 9.63E-04
2.12E-05 1.65E-04 2.36E-03
Pre-LDRs - High End
2.48E-07 1.93E-06
2.51 E-07 1.95E-06
1.55E-08 3,81 E-11 2.97E-10
5.08E-07 1.25E-09 9.74E-09
3.85E-03
3.91 E-04
9.89E-07
3.25E-05
9.26E-05
4.50E-04
4.07E-04
1.78E-13
2.28E-07 1.78E-06
1.11E-06 8.64E-06
1.00E-06 7.80E-06
4.39E-16 3.41E-15
3.55E-04
1.73E-03
2.60E-05
1.71E-13
Qroundwate Cancer Noncancer Lifetime
Cone Dose Dose Excess Hazard
(ppm=mg/L) (mg/kg-d) (mg/kg-d) Cancer Risk Quotient
1.46E-04 3.60E-07 2.80E-06 5.41 E-07 9.35E-03
4.27E-02 1.05E-04 8.20E-04 1.17E-02
1.79E-03 4.40E-06 3.42E-05
8.70E-04 2.14E-06 1.67E-0S
2.21 E-03 5.45E-06 4.24E-05
1.24E-05 3.06E-08 2.38E-07
7.40E-04 1.82E-06 1.42E-05
4.07E-03 1.00E-05 7.80E-05
3.70E-03 9.13E-06 7.10E-05
1.19E-06 2.94E-09 2.28E-08
6.85E-02
3.34E-03
1.41E-01
7.94E-04
2.84E-03
1.56E-02
2.37E-04
1.14E-06
Groundwater (gw) concentration = total 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 Ihta Noncancer dose = gw concentration x noncancer gw Intake.
Cancer gw Intake = (gw Intake'exposure duratlon'exposure frequency)/(cancer averaging tlme'365'body weight) = 0.00247 L/kg-day.
Noncancer gw Intake = (gw intake'exposure duration'exposure frequency)/(noncancer averaging tlme*365*body weight) = 0.01918 L/kg-day.
Cancer risk = slope factor x cancer dose. Hazard quotient (hq) = noncancer dose / RfD. See Exhibit A.3-3 for slope factors and RfDs.
Body Weight = 70 kg Exposure Duration = 9 years Non-caneer 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 15, 1997
-------
A-49
Exhibit A.3-4 (Continued) - Example Risk Calculation for a Single Waste Sample from Concentration Data to Risk Results
Post-LDRs (UTS) - Central Tendency
Post-LDRs (UTS) - High End
Groundwater
Cancer
Noncancer Lifetime
Groundwatei
Cancer
Noncancer Lifetime
Cone
Dose
Dose Excess
Hazard
Cone
Dose
Dose Excess
Hazard
Constituents
(ppm=mg/L)
(mq/kg-d)
(mg/kq-d) Cancer Risk
Quotient
(ppm=mg/L) (mg/kg-d)
(mq/kq-d) Cancer Risk
Quotient
Aluminum
Antimony
Arsenic
5.72E-10
1.41E-12
1.10E-11 2.12E-12
3.66E-08
1.46E-04
3.60E-07
2.80E-06 5.41 E-07
9.35E-03
Barium
1.63E-03
4.02E-06
3.13E-05
4.47E-04
4.27E-02
1.05E-04
8.20E-04
1.17E-02
Beryllium
Boron
Cadmium
1.S5E-18
3.83E-21
2.98E-2Q
5.95E-17
2.91 E-05
7.19E-08
5.59E-07
1.12E-03
Chromium
1.85E-05
4.80E-08
3.73E-07
7.46E-05
8.70E-04
2.14E-06
1.87E-05
3.34E-03
Copper
'
Iron
Lead
1.85E-31
4.56E-34
3.55E-33
1.18E-29
2.07E-10
5.11E-13
3.97E-12
1.32E-08
Magnesium
Manganese
Mercury
1J6E-15
4.84E-18
3.76E-17
H25E-13
2.91 E-06
7.18E-09
5.59E-08
1.86E-04
Molybdenum
Nickel
Selenium
6.72E-10
1.66E-12
1.29E-11
2.58E-09
1.87E-04
4.61 E-07
3.58E-06
7.17E-04
Silver
1.13E-11
2.78E-14
2.16E-13
4.33E-11
3.08E-Q4
7.59E-07
5.91 E-06
1.18E-03
Thallium
Vanadium
Zinc
1.98E-16
4.88E-19
3.79E-18
1.26E-17
1.50E-03
3.69E-06
2.87E-05
9.57E-05
Cyanide
Sulfide
-
Fluoride
Groundwater (§w) concentration = treatment level
/ DAF (If pre-LDR gw concentration Is greater than the treatment level / DAF); otherwise
gw concentration = pre-LDR gw concentration
No gw values are returned for constituents with no DAF or treatment level.
See the previous page for an explanation of the dose, risk, and hazard calculations.
April 15, 1997
-------
SUMMARY OF MINERAL PROCESSING FACILITIES
PRODUCING HAZARDOUS WASTE STREAMS
APPENDIX B
!t«wsl
Alumina &
Aluminum
Alcan Aluminum Corp.
Henderson, KY
no
Processing
No
ALCOA
Newburgh, IN
no
Processing
No
ALCOA
Massena, NY
no
Processing
No
ALCOA
Badin, NC
no
Processing
No
ALCOA
Alcoa, TN
no
Processing
No
ALCOA
Rockdale, TX
no
Processing
No
ALCOA
Wenatchee, WA
ho
Processing
No
ALUMAX
Mt, Holly, SC
no
Processing
No
Columbia Aluminum
Corp.
Goidendale, WA
no
Processing
No
Columbia Falls
Aluminum Corp.
Columbia Falls, MT
no
Processing
No
Easiico
Frederick, MD
no
Processing *
No
intalco Aluminum Corp.
Ferndale, WA
no
Processing
No
Kaiser Aluminum Corp.
Spokane, WA
no
Processing
No
Kaiser Aluminum Corp.
Tacoma, WA
no
Processing
No
National South Wire
Hawesville, KY
no
Processing
No
Noranda Aluminum
New Madrid, MO
no
Processing
No
Northwest Alloys Inc.
The Dalles, OR
no
Processing
No
Ormet
Hannibal, OH
no
Processing
No
April 15,1997
-------
B-2
¦iailiiBSl
Mitring fend
wiMiafi
MNHMHh
Aluminum
(continued)
Ravenswood Aluminum
Corp.
Ravenswood, WV
no
Processing
No
Reynolds
Massena, NY
no
Processing
No
Reynolds
Troutdale, OR
no
Processing
No
Reynolds
Longview, WA
no
Processing
No
Venalco
Vancouver, W A
no
Processing
No
Antimony
Amspec Chemical Corp
Glouchcsler, NJ
no
Processing
No
Anzon, Inc.
Laredo, TX
no
Processing
No
ASARCO Inc.
Omaha, NE
no
Processing
No
Laurel Ind.
LaPorte, TX
no
Processing
No
Sunshine Mining
Company
Kellogg, ID
»
yes
Processing
no
US Antimony Corp.
Thompson Falls, MT
no
Processing
no
Beryllium
Brush Weliman
Delta, UT
yes
mining, produces Be(OH)2
no
Brush Weliman
Elmore, OH
no
Secondary ore processing of Be
Metal and Alloys
no
NGK Metals
Revere, PA
no
Secondary ore processing of Be
Metal
no
Bismuth
ASARCO
Omaha, NE
no
Processing
yes
Cadmium
ASARCO
Denver, CO
no
Processing
no
Big River Zinc Corp.
Sauget, IL
no
Processing
no
Jersey Miniere Zinc.
Corp
Clarksvillc, TN
yes
(Gordonsville)
Processing
no
ZCA
Bartlesville, OK
no
Processing
no
Calcium Metal
Pfizer Chem (Quigley
Company)
Canaan, CT
no
Processing
no
April 15,1997
-------
B-3
1—
^Facility; weapons,.
iilnl
iistsiisiis
Coal gas
<3reat Plains Coal
Gasification Plant,
Dakota Gasification Co,
Beulah, ND
yes
Synthetic Gas produced
yes
Gasifer Ash, Process
Wastewater
Copper
ASARCO
El Paso, TX
no
Smelting
Yes. Slag, slag tailings
and/or calcium sulfate sludge
ASARCO
Amarillo, TX
no
Electrolytic Refining
Yes. Slag, slag tailings
and/or calcium sulfate sludge
ASARCO
Hayden, AZ
yes
Mining, Smelting and
Electrowinning
Yes. Slag, slag tailings
and/or calcium sulfate sludge
Copper Range
White Pine, Ml
yes
Mining, Smelting & Refining
Yes. Slag, slag tailings
and/or calcium sulfate sludge
Cypres
Claypool, AZ
yes
Mining, Smelting, Refining, &
Electrowinning
Yes, Slag, slag tailings
and/or calcium sulfate sludge
Kennecott
Garfield, UT
yes
Mining, Smelting and Refining
Yes. Slag, slag tailings
and/or calcium sulfate sludge
Magma (BHP)
San Manuel, AZ
yes
Mining, Smelting, Refining, and
Electrowinning
Yes. Slag, slag tailings
and/or calcium sulfate sludge
Phelps Dodge
Playas, NM
no
Smelting only
Yes. Slag, slag tailings
and/or calcium sulfate sludge
Phelps Dodge
El Paso, TX
no
Refining only
Yes. Slag, slag tailings
and/or calcium sulfate sludge
Phelps Dodge
Hurley, NM
yes
Mining, Smelting and
Electrowinning (same as Chino
Mines)
Yes. Slag, slag tailings
and/or calcium sulfate sludge
Elemental
Phosporous
FMC
Pocatello, ID
yes
Processing
Yes. Slag
Monsanto
Soda Springs, ID
yes
Processing
Yes. Slag
Germanium
Atomergic Chem
Plainview, NY
no
Processing
no
Cabot
Revere, PA
no
Processing
no
Eagle-Picher
Quapaw, OK
no
Processing
no
April 15,1997
-------
B-4
HS!i§
—Mi
j^l^l^Locatloirts'v
iwJiiife
. Germanium
(continued)
Musto Exploration
(inactive)
St. George, UT
yes
Mining and Refining
no
Fluorospar and
Hydrofluoric Acid
Allied Signal
Geismar, LA
no
Processing
Yes. Fluorogypsum and
process wastewater
B.I. duPont
La Port, TX
no
Processing
Yes. Fluorogypsum and
process wastewater
Atlochemical, N.A.
Calvert City, KY
no
Processing
Yes. Fluorogypsum and
process wastewater
Lead
ASARCO
East Helena, MT
yes
Smelter
Yes. Slag
ASARCO
Glover, MO
yes
Smelter/Refinery
Yes. Slag
ASARCO
Omaha, NE
no
Refinery
Yes. Slag
Doe Run Co,
Herculaneum, MO
yes
Smelter/Refinery
Yes. Slag
Magnesium
Dow Chemical Co.
Freeport, TX
yes
MgCl from seawater, Mg metal
processing, magnesia processing
no
Magnesium Corp. of
America
Salt Lake City, UT
yes
Mg metal processing from lake
brines
Yes. Process wastewater
Northwest Alloys Inc.
Addy, WA
no
Mg metal processing
no
Mercury
Barrick Mecur Gold
Mines, Inc.
Toole, UT
yes
Mining and Retorting
no
FMC Gold Co.
Humboldt, NV
yes
Mining
no
FMC Gold Co.
Gabbs, NV
yes
Mining
no
Horaestake Mining Co.
Napa, CA
yes
Mining, leaching
no
Independence Mining
Co. Inc.
Elko, NV
yes
Mining
no
Newmont Gold Co.
Eureka, NV
yes
Mining
no
Placer Dome U.S.
East Ely, NV
yes
Mining .
no
April 15, 1997
-------
B-5
I—1
iiisgpgpsis
SHM
Molybdenum,
Ferro molybdenum
Cyprus-Climax-
Henderson
Empire, CO
yes
Mining and Processing
no
and Ammonium
Cyprus-Climax
Fort Madison, IA
no
Processing
no
Molybdate
Cyprus-Climax
Cold Water, Ml
no
Processing, possibly phased out
no
Cyprus-Climax- Green
Valley
Tucson, AZ
no
Processing
no
Kennecott
Bingham Canyon,
UT
yes
Processing
copper slag, slag tailings,
WWTP sludge
Montana Resources Inc.
Butte, MT
yes
Processing
no
Phelps Dodge
Hurley, NM
yes
Processing
no
San Manuel
San Manuel, AZ
yes
Processing
no
San Manuel
Morenci, AZ /
yes
Processing
no
Thompson Creek
Challis, ID
yes
Processing
no
Thompson Creek
Langeloth, PA
no
Processing
no
Platinum Group
Metals
ASARCO Inc.
Amarillo, TX
no
Processing
Kennecott Corp.
Salt Lake City, UT
yes
Processing
Stillwater Mine
Nye, MT
yes
Mining and Smelting
no
Pyrobitumens,
Mineral Waxes, and
Natural Asphalts
American Gilsonite
Bonaza, UT
Uintah 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 Bastnasite
no
Rhenium
Cyprus-Climax
Green Valley, AZ
yes
Recovers and refines rhenium
no
Cyprus-Climax
Fort Madison, IA
no
Rhenium recovery
no
April 15, 1997
-------
B-6
I?—i
Scandium
Baldwin Metals
Processing Co.
Phoenix, AZ
no
Processing
no
Boulder Scientific Co.
Mead, CO
no
Refining
no
Interpro (subsidiary of
Concord Trading Corp.)
Golden, CO
no
Refining
no
Materials Preparation
Center
Ames, IA
no
Processing
no
Rhone-Poulenc, Inc.
Phocniz, AZ
no
Processing
no
APL Engineered
Materials
Urbana, 1L
no
Refining
no
Sausville Chemical Co.
Garfield, NJ
no
Refining
no
Selenium
ASARCO
Amarillo, TX '
no
Processing
no
Kennecott
Garfield, UT
yes
Processing
yes
Phelps Dodge
El Paso, TX
no
Processing
no
Synthetic Rutile
Kerr-McGee Chemical
Corp.
Mobile, AL
no
Processing
no
Tantalum,
Columbium and
Ferrocolumbium
Cabot Corp.
Boyertown, PA
no
Cb and Ta pentoxide/metal, FeCb,
Ta capacitor powder
no
Shieldalloy
Metallurgical Corp.
Newfield, NJ
no
FeCb
no
Tellurium
ASARCO
Amarillo, TX
no
Processing
no
Kennecott Corp.
Garfield, UT
yes
Mining, Smelting and Refining
Yes. Slag, slag tailings
and/or calcium sulfate sludge
April 15,1997
-------
B-7
aaaKBgai
iitsiisiij
Yes. Chloride process waste
solids
Titanium and
Titanium Dioxide
E.I. duPont de Nemours
& Co. Inc.
Antioch, CA
110
Ti02 Production
E.I. duPont
Edgemoor, DE
no
TiOj Produclion
Yes. Chloride process waste
solids
E.I. duPont
New Johnsonville,
TN
no
Ti02 Production
Yes. Chloride process waste
solids
E.I. duPont
Pass Christian, MS
no
TiOj Production
Yes. Chloride process waste
solids
Kcmira, Inc.
Savannah, GA
no
TiOj Production
Yes. Chloride process waste
solids
Kerr-McGee Chemical
Corp.
Hamilton, MS
no
TiOj Production
Yes. Chloride process waste
solids
Kronos, Inc.
Lake Charles, LA »
no
Ti02 Production
Yes. Chloride process waste
solids
SCM Chemicals, Inc.
Ashtabula, OH
no
TiOj Production
Yes. Chloride process waste
solids
SCM Chemicals, Inc.
Baltimore, MD
no
Ti02 Production
Yes. Chloride process waste
solids
Tunpten
Buffalo Tungsten
Depew, NY
no
Processing
no
General Electric
Euclid, OH
no
Processing
no
OSRAM Sylvania, Inc.
Towanda, PA
no
Processing
no
Kennametal
Fallon, NV
100-150 miles to
Humbold and
Starlight mine
Processing
no
Kennametal.
LaTrobe, PA
no
Processing
no
Teledyne Advance
Materials
Huntsville, AL
no
Processing
no
Uranium
no facilities listed
April 15,1997
-------
B-8
'SlS'littS
—
/
facility, Locations, i
lyiihlngaridMP,:
Zinc
Big River Zinc Corp.
Sauget, 1L
no
Smelter (electrolytic)
no
Jersey Miniere Zinc Co.
Ciarksvillc, TN
yes
Smelter (electrolytic)
no
Zinc Corp. of America
Monaco, PA
no
Smelter (pyrometallurgical)
Yes. Slag
Zirconium and
Hafnium
Teledyne
Albany, OR
no
Processing
no
Western Zirconium
Ogden, UT
no
Processing
no
April 15, 1997
-------
#sfJLif-3003£>.
MINERAL PROCESSING WASTE TREATMENT AND
DISPOSAL COSTS: LOW-COST ANALYSIS APPENDIX C
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 comparison of those options, and a determination of the lowest-cost
alternative.
Under 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 type of waste that is generated:
• Solid wastes may be:
• Disposed of in a Subtitle C landfill; or
• Treated and disposed of in a Subtitle C landfill; or
• Treated and disposed of in a Subtitle D landfill. '
• Liquid wastes may be:
• • Treated, with solid wastes disposed in a Subtitle C landfill; or
• Treated, with solid wastes disposed in a Subtitle D landfill.
Upon completion of this rulemaking, owners and/or operators of mineral processing facilities that
generate hazardous waste must choose between two treatment and disposal options. Both solid and liquid
wastes may be:
• Treated aid 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,
C.1 Pre-Rule Lowest Cost Option
C.l.l Analysis of Treatment and Disposal Costs
Using on-site cost functions and off-site unit prices from Appendix D, EPA has calculated pre-
rule (or baseline) treatment and disposal costs over a range of waste generation rates (100 mt/yr -175,000
mt/yr) for on- and off-site Subtitle C landfill disposal, and on- and off-site treatment followed by Subtitle
D landfill disposal. Exhibit C-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.
Total treatment and/or disposal costs were divided by the waste generation rate to obtain unit
costs. Exhibit C-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 Subtitle C landfilling and on-site treatment and disposal decreases as waste quantity increases.
April 15,1997
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C-2
Exhibit C-l
Total Cost of Treatment and/or Disposal Alternatives
135,000,000
$30,000,000
y'
^ $20,000,000
$15,000,000
$10,000,000
$5,000,000
60.000
100,000
120,000
140.000
20,000
40,000
160.000
180,000
Wast* G•titration Rat* (mt/yf)
-Off-Sim Subtitla C On»Sita SubtfflaC Off-$it« T&P ———On Site T&p[
C.1.2 Subtitle C Disposal vs. Treatment and Subtitle D Disposal
Exhibits 1 and 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 very 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, on-site Subtitle C landfilling is a lower cost option than treatment
and Subtitle D disposal. However, liability costs (from corrective action requirements) of Subtitle C
landfills arc not accounted for in the on-site Subtitle C cost functions or the off-site Subtitle C unit
disposal price described in Appendix D. It is EPA's assertion that owners and/or operators of mineral
processing facilities generating very small quantities of waste or facilities generating waste in excess of
150,000 mt/yr will treat and dispose the waste in a Subtitle D landfill due to the potentially high liability
cost associated with Subtitle C landfilling. Therefore, EPA considers on- and off-site treatment and
Subtitle D disposal to be the lowest-cost disposal options for mineral processing hazardous wastes.
April 15,1997
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C-3
Exhibit C-2
Unit Cost of Treatment and/or Disposal Alternatives
$2,500
$2,000
$1,500
$1,000 ¦¦
$500
SO
20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 ' 180,000
Watt* Generation Rata (mt/yr)
-Off-SHe Subtitle C
•On-Slte Subtitle C
-Gn.Stte TS0
- OH-Scte T&D
C.1.3 On-Slte 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 send waste off-site for treatment and
disposal rather than treat and dispose of waste on-site. Exhibit C-3 (an enlargement of Exhibit C-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 879 mt/yr, and therefore waste that is generated in small
quantities (0 mt/yr - 879 mt/yr) will be sent off-site for treatment and disposal rather than be treated and
disposed on-site. Waste generated in excess of 879 mt/yr, however, will be treated and disposed on-site.
April 15,1997
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C-4
Exhibit C-3
Treatment and Subtitle D Disposal Unit Costs
$1,200 -
'
$1,000 -
$800 -
,879 mt/yr
*
». -
&
f $600
S
1
\
$400 -
\
\
$200 -
$0 -
1,000 2,000 3,000 4.000 5,000
Wuta Q»n»r»lion Rata (mt/yr)
• [ On-Slte T4D OH-Site T»D |
C.2 Post-Rule Lowest Cost Option
Based on the above analysis that shows that disposal of waste in a Subtitle C landfill alone is
almost always more expensive than treatment and disposal of waste in a Subtitle D landfill, EPA asserts
that treatment and disposal of waste in a Subtitle C landfill is clearly more expensive than treatment and
disposal of waste in a Subtitle D landfill. Therefore, EPA assumes that the post-rule lowest-cost option is
treatment followed by Subtitle D disposal.
C.3 Conclusion
EPA believes that Subtitle C disposal is generally more expensive than treatment followed by
Subtitle D disposal. This assertion, coupled with potentially high Subtitle C liability costs, has led EPA
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-rule (baseline)
and post-rule (option) scenarios, the mineral processing cost model assumes that for waste generated in
quantities below 879 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
879 mt/yr.
April 15,1997
-------
DEVELOPMENT OF COSTING FUNCTIONS
APPENDIX D
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 seven sections:
a. Annualization of Before-Tax Compliance Costs
b. On-site Treatment and Disposal Costs
c. Off-site Treatment and Disposal Costs
d. Storage of Solid Materials
e. Storage Of Liquid Materials
f. Curve-fit Cost functions
g. Costs of Groundwater Monitoring
D.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 rale has an annual effect on the economy of $100 million or more. To determine
whether a rale is a significant regulatory action under this criterion, all costs are annualized on 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 are 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 rale, measured before
any business expense tax deductions available to affected companies. Also, as described in section 3.2.2
of this RIA, screening level economic impacts are computed based upon other pre-tax indications or
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.
April 15,1997
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D-2
The following formula was used to determine the before-tax annualized costs:
Before-Tax Costs = (Capital Costs)(CRF) + (Annual Capital + O&M Costs) + (Closure
Costs)*(CRF)/(1.0721)
Where: CRF = Capital recovery factor based on a 7 percent real rate of return (i) as
follows:
q-t-jyffl = 0.09439 where n = 20
(1 + i)"-l
D.2 On-site Treatment and Disposal
Neutralization and Precipitation of Acidic and Caustic Liquid Wastes
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 assumptions described
in the following subsections were used in preparing cost estimates, with one exception: batch runs were
assumed for 3,510 metric tons per year (mt/yr) and 350 mt/yr, adjusting the operating hours per year to
876 and 88, respectively, while 1,752 hours per year was assumed for waste flow rates of 35,130 mt/yr to
350,000 mt/yr.
Capital Costs - Neutralization
The following assumptions were used in developing the direct capital cost equations for
neutralization in Exhibit D-l:
• Stainless steel neutralization reactor (1) - 14-hour retention time, 5% over design (based on
waste and calcium hydroxide or sulfuric acid solution flows);
• Stainless steel mix tank (1) - two-hour retention time, 5% over design (based on 10%
calcium hydroxide or 20% sulfuric acid solution flows);
• Piping, electrical, and instrumentation; and
April 15,1997
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D-3
• Neutralization is performed in <90 day accumulation treatment tanks (40 CFR 262.34);
therefore, a RCRA permit is not required.
Acidic Waste Only
• Carbon steel holding tank (1) - two-hour retention time, 5% over design (based on 10%
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 (1) - for the waste flow into the reactor;
• Cast iron agitators (2) - for the mix tank and the holding tank; and
• Stainless steel agitator (1) - for the reactor.
Caustic Waste Only
• 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 typetrf waste due to the use of a high cost stainless steel reactor
in both designs.
Operation and Maintenance Costs - Neutralization
The following assumptions were used in development of the O&M cost equations for
neutralization in Exhibit D-l:
• Operating hours - 90 percent operating factor (i.e., 330 days/year);
• Labor - one operator at 20 percent time for continuous systems, or Vz 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.
April 15,1997
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D-4
EXHIBIT D-l
COST EQUATIONS FOR ON-SITE NEUTRALIZATION
AND PRECIPITATION OF PHASE IV WASTES (1995 $)
Neutralization
Capital Costs (350 sQs 370,000 mt/yr)1 "
Cost($) = 36,131+ 151.95 Q5
O&M Costs / Yr (350 sQs 370,000 mt/yr)
Cost($) = -206,719 + 36,594 In Q
Precipitation
Capital Costs (350 s Q s 370,000 rat/yr):
Cost($) = 3,613 + 15.195 QJ
O&M Costs / Yr (350 sQ< 370,000 mt/yr) Cost($) = 0.3465 Q + 826.48
Closure Costs (37,910 sQs 370,000 mt/yr) Cost($) = 6,361 + 3.0 x 10"3 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 cost 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 treated by stabilization due to
sludge formation (see cost equations for Case A in Exhibit D-2 and use 0.15 * Q).
Perforniance Assumptions
The following performance goals were assumed for neutralization:
Closure
Closure Costs (Q < 37,910 mt/yr)
Cost($) = 6,493
Neutralized waste exits with a pH of approximately seven;
Solid residuals are generated, with half of inlet total suspended solids (TSS) level of 3.0%
assumed to settle and form a sludge with 10% solids content. Therefore, 15% of the
original waste stream will leave the neutralization step as hazardous sludge, due to
April 15,1997
-------
D-5
precipitation of a portion of the 500 ppm TC-metals assumed to be in the inlet waste
stream-this sludge will require dewatering, stabilization, and disposal; and
• The quantity of calcium hydroxide or sulfuric acid solutions added to the waste streams
results in minimal flow changes.
Closure Costs
Cost equations for closure of the neutralization tanks and associated equipment are listed in
Exhibit D-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.
Suree Capacity
EPA 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.
On-Site Dewatering and Stabilization
Chemical stabilization/fixation, which consists of cement solidification and pozzolonic (lime-fly
ash) solidification, is used to solidify organic and inorganic sludges. It also may be used to reduce the
leachability of solid residues by first dissolving the materials and subsequently precipitating and fixing the
dissolved solids. This technology adds cement and water to hazardous sludges to form a rock-like
material that binds waste constituents in a solidified matrix. The process improves the physical
characteristics of the waste by increasing its strength and reducing the leachability of contaminants after
the solidified waste is land disposed. Cement solidification is particularly successful with sludges
generated by the precipitation of heavy metals because the high pH of the cement mixture tends to keep
the metals in the form of insoluble hydrated oxides, hydroxides, or carbonates. 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.
April 15,1997
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D-6
The stabilization process requires storage tanks and weighing equipment for both cement and the
hazardous waste, a concrete mixer, and a loading hopper. Waste streams and cement are pumped from
storage tanks to their respective weigh batchers, where the proper ratio for cement fixation is obtained.
The two materials are then discharged from the weigh batchers to a concrete mixer. The proper amount of
water is added to the two materials in the mixer, which then produces a homogeneous mixture. The
mixture is discharged into a loading hopper, which may be transported by truck to a landfill site for
disposal.
The assumptions described in the following subsections were used in generating cost equations for
on-site dewatering and stabilization.
Capital Costs
The following assumptions were used in development of the direct capital cost equations for
dewatering and stabilization presented in Exhibit D-2:
• Stabilization direct capital costs include the purchase costs for storage bins, weigh
batchers, a concrete mixer, a loading hopper, instruments, controls, and pumps;
• The dewatering direct capital cost includes a scroll centrifuge;
• Installation charges were estimated at 15% of the equipment purchase costs;
• Storage tanks have a maximum capacity to store waste and cement for five days.
The system is run as a batch processing operation. Waste rates considered range
from 350 mt/yr to 370,000 mt/yr; and
• Stabilization is performed in a <90 day accumulation treatment tank (40 CFR
262.34); therefore, a RCRA permit is not required.
Operation and Maintenance Costs
The following assumptions were used in the development of the O&M cost equations for
stabilization in Exhibit D-2:
• Direct operation and maintenance costs consist of operating labor, electricity, and
cement and water consumption;
• The cement mixer has a minimum retention time of 15 minutes;
• Operating hours~90% operating factor (i.e., 330 days/year);
April 15,1997
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D-7
EXHIBIT D-2
COST EQUATIONS FOR ON-SITE DEWATERING AND
STABILIZATION OF PHASE IV WASTES (1995 $)
Case A - Dewaterine of 1-10% Solids-Containing Wastes
Capital Costs (350 sQs 370,000 mt/yr)1 Cost($) = 95,354 + 664.48 Qs
O&M Costs / Yr (350 10% (35% average) Solids-Containing Wastes
Capital Costs (425 sQs 200,000 mt/yr) Cost(S) = 207.93 Q78
O&M Costs / Yr (425 sQ<; 200,000 mt/yr) Cost(S) = 87,839 + 52.16 Q
Closure Costs
Closure Costs (350 sQs 200,000 mt/yr) Cost($) = 9,806 + 0.19 Q
1 Q = Annual quantity of waste managed (mt/yr)
• The dewatered sludge (Case A) has a specific gravity of 1.03, while wastes with
greater than 10 percent solids (Case B) have a specific gravity of 1.25;
* The Case A mixing ratio for fixation is 0.05 : 0.50 : 1.00 (water: cement: waste)
by weight. The mixing ratio assumes that the stabilized waste quantity is
approximately equal to 9% of the initial sludge amount prior to being dewatered
to a sludge consisting of 60% solids and specific gravity of 1.56; and
* The Case B mixing ratio for fixation is 0.05 : 0.70; 1.00 (water: cement: waste)
by weight. The mixing ratio assumes that the stabilized waste quantity is equal to
100% of the initial sludge amount with a solids content of 35% and sludge
specific gravity of 1.25.
Performance Assumptions
The following performance goals were assumed for stabilization:
• The subsequent leaching of hazardous constituents from land disposal of a
stabilized waste is reduced by approximately two orders of magnitude; and
April 15,1997
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D-8
• The amount of solidified waste disposed of in a landfill is 1,55 (Case A) and 1.75
(Case B) times the quantity, on a weight basis, of the waste generated.
Closure Costs
Cost equations for closure of the stabilization tanks and associated equipment are listed in Exhibit
D-2 and include the following components:
• Decontamination of tank interiors, pumps, and lines;
• 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.
On-site Subtitle C Landfill
Initial Capital Costs and Assumptions
The landfill design assumes a 20-year 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 D-3:
• 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 the 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;
April 15,1997
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D-9
EXHIBIT D-3
COST EQUATIONS FOR ON-SITE SUBTITLE C LANDFILLS
PHASE IV WASTES (1995 $)
Capital Costs (Q a 1,000 mt/yr)
Cost($) = 83,378 + 23,422 Q05
Annual Capital Costs (Q * 1,000 mt/yr)
Cost($) = 3,137 Q064
O&M Costs / Yr (Q ;> 1,000 mt/yr)
Cost($)= 114,223 + 1,737 Q0J
Closure Costs (Q z. 1,000 mt/yr)
Cost($) = 1,829 Q057
Post-Closure Costs / Yr (Q a 1,000 mt/yr)
Cost($) = 1,523 Q050
Cover Replacement Costs / Yr(Q s 1,000 mt/yr) Cost($) = 3,502 Q0 59
Note: Q = Annual quantity of waste managed (mt/yr) ranging from 1,000 to 150,000
A groundwater 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 downgradient 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
for the first 300 ft, plus one cluster of three wells for every additional 150 ft.;
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,
MT/yr.
April 15,1997
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D-10
geotextile filter fabric;
0.3 meter sand layer (LCS);
30 mil HDPE liner;
0,3 meter sand layer (LDS);
30 mil HDPE liner; and
0.91 meter clay layer;
• Wet wells and pumps for the leachate collection system and the leachate detection system;
• 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
v inspection, construction and field expenses, contractor's overhead and profit, spare parts
inventory, and contingency.
Annual Capital 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 D-3:
April 15,1997
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D-ll
• 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 in ascending
order starting with 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; and
• Fees which include CQA, engineering, construction and inspection, contractor's overhead
and profit, and contingency.
Operation and Maintenance Costs and Assumptions
The following assumptions were used in the development of the O&M cost equation for landfill
operations in Exhibit D-3:
• Labor for personnel to operate-the landfill, which includes equipment operators, laborers,
clerical, 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.);
April 15,1997
-------
D-12
• 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 for heavy equipment, electricity for maintenance building and
pumps, and heat for maintenance building.
Closure Costs and Assumptions
The following assumptions were used in the development of the closure cost equation for landfill
operations in Exhibit D-3:
• 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, scrapers, 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);
• 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 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 D-3:
• 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); ,
April 15,1997
-------
D-13
• Reseed, fertilize, mulch, and water 1/6 of entire 20-cell 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;
• Leachate 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-site Subtitle D Piles
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:
• 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/ft3 (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 ft, where the height of the pile is 1/2 the radius and the
volume of the pile is calculated using the following formula: V = l/3rcr2h;
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)j2;
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);
April 15,1997
-------
D-14
• The density of solid materials is the same as crashed furnace slag (85 lb/ft3);
• The cost of purchasing a 25 short ton capacity dump truck is $275,000 (vendor quote,
1996);
• The cost of renting a 25 short ton capacity dump truck is $775/day (from Means, 1995);
• The fuel and maintenance cost of the truck is Si 8.85/hr (from Means, 1995);
• The cost of labor to operate the truck is S22.80/hr (Engineering News Record, 10/31/94, p.
49);
• It would take 1/2 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; 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 Subtitle C
treatment and disposal.
The costs of disposing solid materials in on-site subtitle D piles are shown in Exhibit D-4.
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.1
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
D-5. 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 basal this decision on the assumption that the
majority of corrosive mineral processing wastestreams were acidic rather than caustic.
*EPA believes it is inappropriate to include sunk capital costs in the baseline, because the incremental costs of this rule
are calculated as the diffrence between the post rale costs and the baseline costs. If EPA included these non-recoverable costs in
the baseline, the incremental cost of the rule would be understated.
April 15,1997
-------
Exhibit D-4
Annual Disposal Cost of Solids in Waste Piles
Wa»t» Pile - Disposal Unit Cost A B C D E F G H
Waste Quantities (mt/yr)
50
500
5,000
50,000
75,000
100,000
250,000
500,000
Waste Quantity (It3/vrt
1.297
12.968
129.682
1.296.824
1.945.235
2.593.647
6.484,118
12.968.235
Total Unit Waste Quantity (f131
25.936
259.365
2.593.647
25.936.471
38.904.706
51.872.941
129.682.353
259.364.706
Unit Construction
Number of Piles
1
1
1
7
10
13
31
62
Radius of Pile fit)
47
89
180
202
205
207
210
210
Heiaht of Pile
-------
D-16
Exhibit D-5
COST EQUATIONS FOR ON-SITE DISPOSAL OF WASTEWATERS
(TO MEET NPDES STANDARDS ONLY -1995 $)
Capital Costs (350 sQs 350,000 mt/yr)'Cost($) = 16,777 + 75,08 Q5
O&M Costs / Yr (350 sQs 350,000 mt/yr)Cost($) = -113,989 + 19,114 In Q
1 Q = Annual quantity of waste managed (mt/yr)
D.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 $175/mt, which includes $25/mt for transportation, $88/mt for stabilization,
and $35/mt for disposal (which is adjusted to $61/mt because stabilization increases the mass of waste to
be disposed to 175 percent of the original mass). The price of off-site treatment ofliquids 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
($170/short ton) and off-site landfill alone ($90/short ton) reported in EI Digest, November 1994.
D.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:
April 15,1997
-------
D-17
The capital cost of a carbon steel drum is $52 (from Non-RCRA Tanks, Containers, 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 Ib/ft3);
A laborer could close (or open) drums at the rate of 12 drums per 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 more 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;
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 $1.50/hr, which is estimated to be
the same as the fiiel 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 of 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 drams, and a cost associated with using additional floor space).
The costs of storing solid materials in drums are shown in Exhibit D-6.
April 15, 1997
-------
Exhibit D-6
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 fml/vrt
0.5
4
10
50
75
100
150
200
Waste Quantities (mt/atr)
0.125
1
2.5
12.5
18.75
25
37.5
50
Waste Quantity (aal/alO
24.25
194.02
485.04
2425.22
3637.83
4850.44
7275.67
9700.89
Purchase of Drums
Number of Drums Der Quarter
1
4
10
49
73
98
146
195
Annualized Cost of Drums
$52/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 per vear
0.67
2.67
6.67
32.67
48.67
65,33
97.33
130.00
Annual Labor Cost
$19/hr
12.67
50.67
126.67
620.67
924.67
1241.33
1849.33
2470.00
Move Drums
Ann. Handtruck Capital. Cost
$209
19.73
19.73
19.73
0.00
0.00
0.00
0.00
0.00
Ann. pallet truck Cap. Cost
$3020
0.00
0.00
0.00
285.06
285.06
285.06
285.06
285.06
Number of Hours - Annual
1
4
10
12.25
18.25
24.5
36.5
48.75
Annual Labor Cost
see notes
19
76
190
301.35
448.95
602.7
897.9
1199.25
Annual Fuel and O & M Cost
$1.50/hr
0
0
0
18.38
27.38
36.75
54.75
73.13
Total Annual Cost ($/vr)
56.30
166,03
385.48
1465.96
2044.35
2646.85
3803.65
4984.55
Unit Cost (S/mfl
112.60
41.51
38.55
29.32
27.26
26.47
25.36
24.92
April 15, 1997
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D-19
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-off 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
and 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 yd3 roll-off container is $2670, a 30 yd3 container is $3,045
and a 40 yd3 container is $3,510 (from Non-RCRA Tanks, Containers, and Buildings,
December, 1996, p.27);
• The cost of shipping is $320 per container, based on a shipping cost of $1.60 per mile and
an assumed distance of 200 miles (from Non-RCRA Tanks, Containers, and Buildings,
December, 1996, p.27);
• The cost of a tarp is $425 (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);
• It would take 2 hours to move a roll-off container from the point of generation to the
storage area (or back from the storage area to the point of reentry);
• The roll-off track must be rented in full day increments each time it is necessary to move
a roll-off container,
• The cost of renting the roll-off truck is $500/day or 34,500/month (based on a vendor
quote of $4,500/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 $22.80/hr (Engineering News Record,
10/31/94, p. 49);
• The fuel and maintenance cost of the roll-off truck is S18.85/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.
April 15,1997
-------
D-20
The costs of storing solid materials in roll-off containers are shown in Exhibit D-7.
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 track, 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 filled by parking it under a hopper or chute, and would then be driven
across the site to a storage building where it would dump the material onto the pad outside the entrance to
the building. 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:
• The capital cost of a building is based on the average price for dome buildings (see Tables
14, 15, and 16 of Non-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 base 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 $6.50/yd2 (from Means Site Work 1994, p. 59
• The density of solid materials is the same as crashed furnace slag (85 lb/ft3);
• 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 track is $ 18.85/hr (from Means, 1995);
• The cost of labor to operate the track is $22.80/hr (Engineering News Record, 10/31/94,
p. 49);
• It would take 1/2 hour to drive the dump truck to the building, empty it, and return to the
point of generation;
• It would take 1/2 hour to drive the truck back from the storage area to the point of reentry,
and dump the contents on the ground;
April 15, 1997
-------
Exhibit D-7
Annual Storage Cost Assuming Quarterly Storage of Solids in Roll-Off Containers
HolloW Slorafla Coal Unit Coal A B C D E F G H
Waste Quantities (ml/vr)
50
75
100
500
1.000
2.500
5.000
7,500
Waste Quantities (mt/cilr)
12 5
19
25
125
250
625
1.250
1,875
Waste Quantity (vd3/atrl
12.0
18
24
120
240
600
1.201
1.801
PurchM* of Roll-offs
Number ol 20 vd3 Roll-offs
1
t
-
-
.
.
.
Cost ol Roll-offs
12670/R-oll
2,670
2,670
-
-
-
-
-
Number of 30 vd3 Roll-oils
.
.
1
.
.
-
.
.
Cost of Roll-oils
$3045/r-oll
-
-
3.045
-
-
-
Number of 30 vd3 Roll-offs
.
-
-
4
7
16
31
46
Cost of Roll-offs
$3510fr-otf
-
-
14.040
24.570
56.160
108,810
161,460
$425 each
425
425
425
1.700
2,975
6.800
13,175
19.550
S320 Each
320
320
320
1.280
2.240
5.120
9.920
14.720
Annualized Cost of Roll-offs
322
322
358
1.607
2.811
6.426
12.451
18.475
Roll-off Truck
Number of Trios - Annual
8
8
8
32
56
128
248
368
Number of Rental days
8
8
8
32
56
128
248
365
Annual Rental of Roll-off Trock
*500/dav
4.000
4.000
4.000
16.000
28.000
-
.
.
Annual Rental of Roll-off Truck
S4S00/mo
0
0
0
0
0
54000
54000
54000
Number of Hours - Annual
16
16
16
64
112
2S6
496
736
Annual Labor Cost
$22.80/hr
365
365
365
1,459
2.554
5.837
11.309
16.781
Ann.Fuel and Maintenance Cost
$18 85/hr
302
302
302
1.206
2.111
4.826
9.350
13,874
Total Annual Cost ($/vr)
4.989
4.989
5.024
20.272
35.476
71.088
87.109
103.129
Unit Cost (S/mO
99.7?
66.52
50.24
40.54
35.48
28.44
17.42
13.75
April 15, 1997
-------
D-22
• The cost of renting a 7.5 yd3 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 $26.90/hr (Engineering News Record,
10/31/94, 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 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 D-8.
Storage of Solid Materials in RCRA Containment Buildings
The RCRA containment building storage cost function is similar to the regular building cost
functions, with two exceptions: 1) the RCRA building is assumed to be rectangular rather than round, and
2) the building itself must meet the standards outlined in 40 CFR 264 Subpart DD. EPA used containment
building costs from the Cost and Economic Impact Analysis of Land Disposal Restrictions for Newly
Listed Wastes and Contaminated Debris (Phase 1 LDRs1) Final Rule. EPA Office of Solid Waste, June 10,
1992. The annualized capital cost listed on Page 3-17 of that document includes the capital cost of the
building (annualized using a 3 percent social discount rate over 20 years) as well as an O & M cost
(equivalent to 10 percent of the initial capital). Because EPA has used a 7 percent discount rate in other
parts of this analysis, the Agency backed out the original capital costs and re-annualized them using a
seven percent discount rate. The Agency then used these annualized costs in the building cost calculations
to compute the cost of storage in RCRA containment buildings.
The Agency made the following assumptions in assembling these cost functions:
• The necessary building area is determined by assuming the material is stored in a conical
pile with a maximum height of 18 ft, (or for smaller piles the height of the pile is equal to
the radius) where the volume of the pile is calculated using die following formula: V =
l/3w2h;
• The length of a side of the building is the twice the pile radius plus a ten foot buffer zone
around the edge of the pile to move equipment; therefore, the area of the building is
[2*(r+10)]2;
DRAFT - February 12, 1997
-------
Exhibit D-8
Annual Storage Cost Assuming Quarterly Storage of Solids in Dome Buildings
Building Storage Coal UnltCoet A B C 0 E F G H
Waste Quantities (mt/vr)
1.380
2,048
2.660
15,800
17.952
28,448
42.072
50,764
Waste Quantilies (mt/atr)
348
512
665
3,950
4.488
7.112
10.518
12,691
Waste Quantity (ft3/atr)
8.948
13.279
17.248
102.449
116.403
184,460
272.800
329,160
Waste Quantity (vd3/qtr)
331
492
639
3.794
4.311
6,832
10.104
12.191
Capital Coat
Number of Buildinqs
1
1
1
1
1
1
1
1
Diameter ol Buildinq (ft)
40
40
50
100
100
124
150
150
size of base Dad (vd2)
400
400
544
1.600
1.600
2.304
3.211
3.211
Asphalt Pad
6,50/vd2
2.600
2,600
3.539
10.400
10.400
14.976
20.872
20.872
Total Cost of Buildlna
50.500
62.500
72.000
121.000
134.000
190.000
343,000
381.500
Annualized Cost of Buitdina
S.012
6.145
7.130
12.403
13.630
19.348
34,346
37.980
Dump Truck
Number of trios - Quarter
32
46
60
350
396
628
928
1.120
Number o! trios - annual
128
184
240
1.400
1.584
2.512
3,712
4.480
Number of hours - annual
64
92
120
700
792
1.256
1.856
2.240
Lifetime of Truck
20
20
20
20
20
20
14
12
Annualized Purchase cosl
$275,000
25.95?
25.957
25.957
25,957
25.957
25,957
36.018
37,793
Annual Labor Cost
$22.80/hr
1.459
2.098
2.736
15.960
18.058
28.637
42.317
51.072
Ann. Fuel and Maintenance Cost
S18.85/hr
1,206
1.734
2.262
13.195
14.929
23.676
34,986
42.224
Front End Loader
Number of Hours (annual)
9
13
17
101
115
182
269
325
Number ol Days (annual)
4
4
4
12
12
20
28
36
Annual Rental
$1,400/dav
5.600
5.600
5.600
16.800
16.800
28.000
39.200
50.400
Annual Labor Cost
$26.90/hr
238
353
458
2.722
3.093
4.901
7.248
8.745
Ann. Fuel and Maintenance Cost
$ 56.15/hr
496
736
957
5,681
6.455
10,230
15.129
18,254
Total Annual Cost (i/vr)
39.969
42.623
45.100
92,718
98,922
140.748
209.243
246.468
Unit Cost ($/mt)
28.96
20.81
16.95
587
5.51
495
4,97
4 86
April 15, 1997
-------
D-24
• If the volume to be stored exceeds 290,600 ft3, more than one building must be
constructed;
* The costs of the dump truck and front end loader are based on the same assumptions used
in calculating the dome building cost function.
The costs of storing solid material in RCRA containment buildings are shown in Exhibit D-9.
Storage of Solid Materials in Lined Waste Piles (Assuming No Free Liquids)
The waste pile storage cost function includes land, a liner base, a liner, liner protections, the
costs of a dump truck to move the material to the storage site and back, and a front end loader to move the
material at the pile. The following is a brief description of how solid materials would be stored in waste
piles.
A dump 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
conveyer system). The waste pile is lined with a foot of compacted soil under 3 feet of compacted clay.
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 $2500/acre (from CKD Monofill Model Cost Documentation,
1995);
• The cost of compacted soil is $0.2325/ft3 (from CKD Monofill Model Cost
Documentation, 1995);
• The cost of compacted clay is $0.3667/ft3 (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
1/2 the radius and the volume of the pile is calculated using the following formula: V =
1/3 7tr2h;
• 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)]2;
• 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);
April 15, 1997
-------
Exhibit D-9
Annual Storage Cost Assuming Quarterly Storage of Solids in RCHA Containment Buildings
Building Storage Cos! Unit Cost A B C D E
Waste Quantities (mt/vr)
135
600
2.400
8,245
42,130
Waste Quantities (mt/qtr)
34
150
600
2,061
10,533
Waste Quantitv (It3/atr)
875
3.890
15.562
53,462
273.176
Waste Quantitv (vd3/alr)
32
144
576
1.980
10.118
CBpltal Cost
Fixed height pile
0
0
1
1
1
Number of Bulldlnas
1
1
1
1
1
Averaqe sa (t of bulldlna
1.509
2.599
6.001
16,005
68.000
Capital Cost of bulldlna
400.679
514.305
777.438
1.375.466
4,784,231
Maintenance cost of bulldlna
40.068
51.430
77.744
137.547
478,423
Annualized Cost of Bulldlna
77.888
99.976
151.126
267.377
930.007
Dump Truck
Number of trios - auarter
4
14
54
182
930
Number of trios - annual
16
56
216
728
3.720
Number of hours - annual
8
28
108
364
1.860
Lifetime of Truck
20
20
20
20
14
Annualized Purchase cost
$275,000
25.957
25.957
25.957
25,957
36.039
Annual Labor Cost
122.80/hr
182
638
2,462
8.299
42.408
Ann. Fuel and Maintenance Cost
$18,B5/hr
151
528
2.036
6.861
35,061
Front End Loader
Number of Hours (annual)
1
4
15
53
270
Number of Davs (annual)
4
4
4
8
28
Annual Rental
$1.400/dav
5.600
5.600
5.600
11,200
39.200
Annual Labor Cost
$26.90/hr
23
103
413
1.420
7.258
Ann. Fuel and Maintenance Cost
$ 56.15/hr
49
216
863
2.965
15.149
Total Annual Cost (Vvr)
109.850
133,018
188,458
324,080
1.105.121
Unit Cost ($/mt)
813.71
221.70
78.52
39.31
26.23
April 15, 1997
-------
D-26
• The density of solid materials is the same as crashed furnace slag (85 lb/ft3);
• 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 S18.85/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 1/2 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;
• It would take 1/2 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 yd3 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 $26.90/hr (Engineering News Record,
10/31/94, 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 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 with no free liquids in waste piles are shown in Exhibit
D-10.
Storage of Solid Materials in Unlined Waste Piles (with Groundwater Monitoring)
The costs of storing materials in unlined waste piles are very similar to the costs of storing
materials in lined waste piles, with two notable exceptions: The costs of the liner and liner protection are
not used, and costs of groundwater monitoring have been added. (The development of groundwater
monitoring costs is described later in this Appendix.) One of the stipulations of using these units is that if
monitoring reveals contamination, the facility is responsible for the costs of corrective action. However,
even without adding the potential costs of corrective action, these costs of regular monitoring are higher
than the costs of liners. Therefore, EPA considered this option to be economically inferior to storage in
waste piles with liners, and did not attempt to add corrective action costs to the costs shown in Exhibit
D-ll.
April 15, 1997
-------
Exhibit D-10
Annual Storage Cost Assuming Quarterly Storage of Solids with No Free Liquids in Lined Waste Piles
Wwh Pile - No Frm Uquldt Unit Coat ABCD E F G H
Waste Quanlities (ml/yr)
500
5.000
15.000
25.000
40.000
70.000
90,000
120,000
Waste Quantities (mt/atrt
125
1.250
3.750
6.250
10.000
17,500
22.500
30.000
Waste Quanlltv (ItSfatrt
3.242
32.421
97.262
162.103
259.365
453,888
583.571
778,094
Waste Quantity (vd3/air)
120
1.201
3.602
6.004
9.606
16.811
21.614
28.818
Unit Construction
Unit size (It2)
3.218
9.825
17.987
24.118
31.772
44.394
51.693
61,619
Annualized Land (S/vri
$2500/acra
17
53
97
131
172
240
280
334
Ann. Liner base (comoacted soil)
SO.2325/113
71
216
395
529
697
974
1.134
1.352
Annualized Liner (3 ft ol clav)
$0.3667/113
334
1,020
1.868
2.504
3.299
4.610
5.368
6.398
Ann. Liner Protection (cmoct soil)
$0.2325/113
71
216
395
529
697
974
1,134
1.352
Dump Truck
Number of trios - Quarter
12
112
332
552
882
1.544
1.986
2,646
Number ol trios - annual
48
448
1.328
2.208
3.528
6.176
7.944
10.584
Number ol hours - annual
24
224
664
1.104
1.764
3.088
3.972
5.292
Number ol Oriainal Trucks Needed
1
1
1
1
1
2
2
2
Lifetime of Truck(s)
20
20
20
20
15
17
13
10
Total Number ol Trucks Needed
1
1
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
78.617
Annualized Labor Cost
$22 80/hr
547
5.107
15.139
25.171
40.219
70.406
90.562
120.658
Ann. Fuel and Maintenance Cost
$10.85/br
452
4.222
12.516
20.810
33.251
58.209
74.872
99.754
Front End Loader
Number of Hours (annual)
3.20
32.02
96.06
160.10
256.16
44828
576.37
768 49
Number ol Days (annual)
4
8
16
24
36
60
76
100
Annual Rental
$1.4QO«av
5.600
11.200
22.400
33.600
50.400
84.000
106.400
140.000
Annual Labor Cost
$26.90/hr
86
861
2.584
4.307
6,891
12.059
15.504
20.672
Ann. Fuel and Maintenance Cost
$56.15/hr
180
1.798
5.394
8.990
14.384
25.171
32.363
43.151
Total Annual Coat (S/yr)
33.316
50.651
86.745
122.529
185.543
325.173
400,942
512.289
Unit Coat ($/mt)
66.63
10.13
5.78
4.90
464
4.65
4.45
427
April 15, 1997
-------
Exhibit D-11
Annual Storage Cost Assuming Quarterly Storage of Solids in Unlined Waste Piles with Groundwater Monitoring
Wa»t« Pll» • Fn» Liquid* Unit Coal A B C D E F Q H
Waste Quantities (mtfrO
500
5.000
15,000
25.000
40.000
70.000
90.000
120.000
Waste Quantities (mt/atr)
125
1.250
3.750
6.250
10.000
17.500
22.500
30.000
Waste Quantity (ft 3/alrt
3.242
32.421
97.262
182.103
259.365
453.888
583.571
778.094
Waste Quantity (vdJ/Qtr)
120
1.201
3.602
6.004
9.606
16.811
21 614
28.818
Unit Construction
3.218
9825
17.987
24.118
31.772
44.394
51.693
61.619
Annualized Land (S/wl
52500/acre
1?
53
97
131
172
240
280
334
Unit base (comoacied soil)
S0.2325M3
71
216
395
529
697
974
1.134
1.352
Groundwater Monitoring
Number of Downaradiant Wells
3
3
3
3
3
3
3
3
Annualized Caoilal Cost
6.722
6.722
6.722
8.722
6.722
6.722
6.722
6.722
Annual O & M Cost
7.290
7,290
7.290
7290
7.290
7.290
7.290
7.290
Oumo Truck
Number ot trios - Quarter
12
112
332
552
882
1.544
1.986
Number of trios - annual
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
3.972
5.292
Number of O/iamal Trucks Needed
1
t
1
1
1
2
2
2
Lifetime of Truckfs)
20
20
20
20
15
17
13
10
Total Number of Trucks Needed
1
1
1
1
2
4
4
4
Annualized Purchase cost
S27S.OOO
25.957
25.957
25.957
25.957
35.533
" 68.529
73.324
78.617
Annualized Labor Cost
%2'lBO/hr
547
5.107
15.139
25.171
40.219
70.406
90.562
120.658
Ann. Fuel and Maintenance Cost
$18 05/hf
452
4.222
12.516
20.810
33.251
58.209
74.672
99.754
Front End Loader
Number of Hours {annual)
320
32 02
9606
160 10
256 16
44828
576.37
768 49
Number of Dava {annual)
4
8
16
24
36
60
76
100
Annual Rental
S1.400/dav .
5.600
11.200
22.400
33.600
50.400
84.000
106.400
140.000
Annuel Labor Cost
S28.90mr
86
881
2,584
4.307
6,691
12.059
15504
20.872
An^. Fuel and Maintenance Cost
$50.15/tir
180
1.798
8.990
14.384
25.171
43.151
Total Annual Coat (S/vr)
40.923
63.427
98.495
133.508
195.560
333.601
408.452
518.551
UnliCsMiltatL __ _ _ _
93.85
1269
6 57
5 34
489
4,77
4,54
4.32
April 15, 1997
-------
D-29
Storage of Solid Materials in Unlined, Unmoriitored Waste Piles
The costs of storing materials in unlined, unmonitored waste piles are similar to the costs of
storing wastes in lined piles. The notable exception is the cost of the liner and liner protection. These
costs are listed in Exhibit D-12. 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 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 D-13.
D.5 Storage of Liquid Materials
Storage of Liquid Materials in Drums or Mobile Mini-Bulk Tanks
Low volumes of liquid materials can be stored in either drums or mobile mini-bulk containers,
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 drams are required;
• Because liquid materials are often corrosive, polyethylene drums and mini-bulk containers
are used;
• The density of liquid materials is the same as water (62.4 lb/ft3);
• The capital cost of a 55-gallon polyethylene drum is $127 (from Non-RCRA Tanks,
Containers, and Building, December 1996, p. 17. This price includes $2 per drum for
freight);
• The capital cost of a 220-gallon polyethylene mini-bulk tank is $285 (from Non-RCRA
Tanks, Containers, and Building, December 1996, Appendix D); and
• A laborer could move mini-bulks from point of generation to the storage area (or back
from the storage area to the point of reentry) using a pallet truck at a rate of 4 tanks per
hour;
The costs of storing liquid materials in drams and mobile mini-bulk tanks are shown in
Exhibit D-14.
April 15, 1997
-------
Exhibit D-12
Annual Storage Cost Assuming Quarterly Storage of Solids in Unlined, Unmonitored Waste Piles
Waste Pile - Free Liquids Unit Cost A B C D E F * G H
Waste Quantllles (rnl/vr)
500
5.000
15,000
25.000
40,000
70.000
90.000
120,000
Waste Quantities (mt/qtr)
125
1.250
3.750
6,250
10,000
17.500
22,500
30,000
Waste Quantity (ft3/atrt
3.242
32.421
97.262
162.103
259.365
453.888
583.571
778.094
Waste Quantity (yd3/qtrt
120
1,201
3,602
6.004
9.606
16,811
21,614
28,818
Unit Construction
Unit size (ft2)
3.218
9.825
17.987
24.118
31.772
44.394
51.693
61,619
Annualized Land <$/vrt
$2500/acre
17
53
97
131
172
240
280
334
Unit base (compacted soil)
S0.2325/H3
71
216
395
529
697
974
1.134
1,352
Dump Truck
Number ot tfIds - Quarter
12
112
332
552
882
1.544
1.986
2,646
Number of trios - annual
48
448
1.328
2.20B
3.528
6.176
7.944
10,584
Number of hours - annual
24
224
664
1.104
1.764
3,088
3.972
5.292
Number of Orlainal Trucks Needed
1
1
1
1
1
2
2
2
Lifetime of Truck(s)
20
20
20
20
15
17
13
10
Total Number of Trucks Needed
1
1
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
78.617
Annualized Labor Cost
$22.80/hr
547
5.107
15.139
25.171
40.219
70.406
90,562
120.658
Ann. Fuel and Maintenance Cost
$18.85/hr
452
4.222
12.516
20.810
33.251
58.209
74.872
99,754
Front End Loader
Number of Hours (annual)
3.20
32.02
96.06
T60.10
256.16
448.28
576.37
768,49
Number of Days (annual)
4
8
16
24
36
60
76
100
Annual Rental
$1.400/dav
5.600
11.200
22.400
33.600
50.400
84.000
106.400
140.000
Annual Labor Cost
$26.90/hr
86
861
2.584
4.307
€.891
12.059
15.504
20.672
Ann. Fuel and Maintenance Cost
$56.15/hr
180
1.798
5.394
8.990
14.384
25.171
32.363
43.151
Total Annual Cost ($/vr)
32,911
49,415
84.483
119,495
181,547
319.589
394,439
504,538
Unit Cost (S/mt)
65.82
9.88
5.63
4.78
4.54
4.57
4.38
4.20
April 15, 1997
-------
Exhibit D-13
Annual Storage Cost (O & M only) Assuming Quarterly Storage of Solids in Unlined, Unmonitorcd Waste Piles
Waste Pile - Free liquids Unit Cost A B C D E F G H
Waste Quantities (mt/vr)
500
5,000
15,000
25.000
40.000
70,000
90.000
120,000
Waste Quantities fmt/atr!
t25
1.250
3.750
6,250
10,000
17,500
22,500
30,000
Waste Quantity (ft3/alr)
3.242
32.421
97.262
162.103
259.365
453.888
583.571
778.094
Waste Quantity (vd3/atri
120
1.201
3.602
6.004
9.606
16.811
21.614
28.818
Unit Construction
Unit size (ft2)
3.218
9.825
17.987
24.118
31,772
44.394
51.693
61.619
Annualized Land ISNt)
S2500/acre
Unit base (compacted soil)
S0.2325/H3
Dump Truck
Number of trtes - auarter
12
112
332
552
882
' 1.544
1.986
2.646
Number of trtos - annual
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
3.972
5.292
Number of Orlainal Trucks Needed
1
1
1
1
1
2
2
2
Lifetime of Truckfs)
20
20
20
20
15
17
13
10
Total Number of Trucks Needed
1
1
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
78.617
Annualized Labor Cost
$22.80/hr
547
5.107
15.139
25.171
40.219
70.406
90.562
120.658
Ann. Fuel and Maintenance Cost
$18.85/hr
452
4.222
12,516
20.810
33.251
58.209
74.872
99.754
Front End Loader
Number of Hours (annual)
3.20
32.02
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 Rental
S1,400/dav
5.600
11.200
22.400
33.600
50.400
84.000
106.400
140.000
Annual Labor Cost
$26.90/hr
86
861
2.584
4.307
6,891
12.059
15.504
20.672
Ann. Fuel and Maintenance Cost
$56.15/hr
180
1.798
5.394
8.990
14,384
25.171
32.363
43.151
Total Annual Cost ($/vr)
32;823
49,146
83,991
118,835
180,678
318,374
393,025
502,852
Unit Cost (|/mt)
65.65
9.83
5.60
4.75
4.52
4.55
4.37
4.19
April 15, 1997
-------
Exhibit D-14
Annual Storage Cost Assuming 30 Day Storage of Liquids in Drum and Mini-Bulks
Drum Storage Cost (liquids) Unit Cost A B C P E F G H
Waste Quantities (mt/vr)
0.5
10
50
75
100
150
200
250
Waste Quantities (mt/mo)
0.042
0.833
4.167
6.250
8.333
12,500
16.667
20.833
Waste Quantity (qal/mo)
11.01
220.24
1101.20
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/drum
127.00
635.00
0.00
0.00
0.00
0.00
0.00
0.00
Number of 220-aatlon 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
236.73
325.50
473.46
621.42
769.37
Labor to Opert/CIose Drums
Number of Hours per vear
2
10
-
-
-
-
.
.
Annual Labor Cost
$19/hr
38
190
-
-
-
.
.
.
Move Drums
Ann. Handtruck Capital. Cost
$209
19.73
19.73
0.00
0.00
0.00
0.00
0.00
0.00
Ann. Pallet Truck Cap. Cost
$3020
0
0
285
285
285
285
285
285
Number of Hours - Annual
1
5
12
16
22
32
42
52
Annual Labor Cost
$19/hr
19
95
228
304
418
608
798
988
Ann. Fuel and Maintenance Cost
$1.5/hr
0
0
18
24
33
48
63
78
Total Annual Cost {$/yr)
88.72
364.67
708.61
849.79
1061.56
1414.52
1767.47
2120.43
Unit Cost ($/mt)
177.43
36.47
14.17
11.33
10.62
9.43
8.84
8.48
April 15, 1997
-------
D-33
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. When these materials are going to
be reused they 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/ft3);
• Tank capital and O & M costs were developed following the method used by DPRA for
the "Organic Dyes and Pigments Waste Listings," 1995, 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 (from Non-RCRA Tanks, Containers, and
Building, December 1996, p. 22.)
• For 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 tank; 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 farther "storage" costs.
The costs of storing liquid materials in tanks are shown in Exhibit D-15.
Storage of Liquid Materials 111RCRA Tanks
The RCRA storage tank cost function is similar to the regular storage tank cost functions, with
the exception that the tank must have secondary containment, and be inspected daily. (See 40 CFR 264
Subpart J.) EPA assumed double walled tanks to meet the secondary containment requirement. EPA used
the prices from Non-RCRA Tanks, Containers, and Building, December 1996, p. 22 for tanks with a
capacity of 25,000 gallons or less, and vendor quotes for large field erected double walled tanks.
April 15, 1997
-------
Exhibit D-15
Annual Storage Cost Assuming 30 Day Storage of Liquids in Tanks
Tank Storage Cost (Liquids) Unit Cost A B C D E F
Waste Quantities (mt/vrt
45.4
227.0
1,135.1
22,702.6
90,810.4
181,620.7
Waste Quantity (qal/vr)
12,000
60,000
300,000
6,000,000
24.000.000
48,000,000
Waste Quantity laal/mo)
1,000
5,000
25,000
500,000
2,000,000
4.000,000
Waste Flow rate (aal/dav)
33
167
833
16.667
66.667
133.333
Purchase of Tanks
Number of Tanks
1
1
1
1
1
1
Cap. Cost of Double Walled Tanks
' 1.246
3,466
9,405
Freiaht 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 of additional pipe (ft)
-
-
500
1.000
1,000
Pipina * Annualized Capital
-
.
425
821
821
Pipina - Annual O & M
-
.
.
1.000
1.000
1,000
Total Annual Cost ($/yr)
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 15, 1997
-------
D-35
EPA also assumed that it would take a skilled laborer ($39.50/hr, from CKD Monofill Model
Cost Documentation, 1995) a half hour per day to inspect a tank and file any necessary paperwork. The
cost of storage in RCRA storage tanks are shown in Exhibit D-16.
Storage of Liquid Materials In Lined 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/ft3);
• The purchase cost of land is S2500/acre (from CKD Monofill Model Cost Documentation,
1995);
• The cost of excavation is $0.1077/ft3 (from CKD Monofill Model Cost Documentation,
1995); The cost of a 40 mil HDPE geomembrane liner is 0.5602/ft2 (from CKD Monofill
Model Cost Documentation, 1995);
The area of the surface impoundment is calculated using the formulas described in section
D.7;
• 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 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.
April 15,1997
-------
Exhibit D-16
Annual Storage Cost Assuming 30 Day Storage of Liquids in RCRA Tanks
Tank Storage Cost (Liquids) Unit Cost A B C D E F G
Waste Quantities (mt/vr)
45.4
227.0
1,135.1
5,221.6
21.340.4
52,261.4
184,390.4
Waste Quantity (qal/yr)
12,000
60,000
300,000
1,380,000
5,640,000
13,812,000
48.732,000
Waste Quantity (qal/mo)
1,000
5,000
25,000
115,000
470,000
1.151.000
4,061,000
Waste Flow rate (aal/dav)
33
167
833
3,833
15.667
38.367
135.367
Purchase of Tanks
Number of Tanks
1
1
1
1
1
1
1
CaD. Cost of Double Walled Tanks
1,619
6,164
17.417
110.000
200.000
350,000
900.000
Freiaht and Installation
486
1,849
5.225
33.000
60.000
105.000
270.000
Indirect Capital
32% of cap
674
2.564
7.245
45,760
83,200
145,600
374.400
Annualized Cost of Tanks
262
998
2.821
17.817
32.395
56,691
145.776
Annual 0 & M
183
698
1.973
12.458
22.651
39,640
101.930
Annual Inspection Cost (Labor)
$39.5/hr
7.209
7,209
7.209
7.209
7.209
7.209
7.209
Piping
Length of additional Dips (ft)
-
-
-
1.000
1.000
1,000
1.000
Pipina - Annualized Capital
-
-
-
821
821
821
821
Pipina - Annual O & M
-
-
-
1.000
1.000
1.000
1.000
Total Annual Cost ($/vr)
446
1,697
4,794
32,096
56,867
98,151
249,528
Unit Cost ($/mt)
9.81
1
7.47
4.22
6.15
2.66
1.88
1.35
April 15, 1997
-------
D-37
The costs of storing liquid materials in lined surface impoundments are shown in Exhibit D-17.
Storage of Liquid Materials in Unlined Surface Impoundments with Groundwater
Monitoring
The costs of storing materials in unlined surface impoundments are very similar to the costs of
storing materials in lined surface impoundments, with two notable exceptions: The cost of the liner is not
used, and costs of groundwater monitoring have been added. (The development of groundwater
monitoring costs are described later in this Appendix.) One of the stipulations of using these units is that
if monitoring reveals contamination, the facility is responsible for the costs of corrective action. However,
even without adding the potential costs of corrective action, these costs of regular monitoring are higher
than the costs of liners. Therefore, EPA considered this option to be economically inferior to storage in
surface impoundments with liners, and did not attempt to add corrective action costs to the costs shown in
Exhibit D-18.
Storage of Liquid Materials in Unlined, Unmonitored Surface Impoundments
The costs of storing materials in unlined, unmonitored surface impoundments are similar to the
costs of storing wastes in lined surface impoundments. The notable exception is the cost of the liner. The
costs of storing liquid materials in unlined surface impoundments without groundwater monitoring are
shown in Exhibit D-19. 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 D-20.
D.6 Curve Fit Cost Functions
The Agency plotted and curve fit each set of cost results (from Exhibits D-4, and D-6 through
D-20) to transform the costs into cost functions. Exhibit D-21 presents these curve fit storage and disposal
cost functions, along with the range for which these cost equations are valid. EPA determined the break-
even points between the relevant storage methods for each Baseline or Option. Exhibit D-21 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 are unallowable management methods. Finally,
Exhibits D-22 through D-38 present graphs of the individual cost for our sample waste generation rates
along with the resulting curve fit cost functions.
April 15, 1997
-------
Exhibit D-17
Annual Storage Cost Assuming Quarterly Storage of Solids in Unlined, Unmonitored Waste Piles
Waste Quantities (mt/vr)
500
5,000
25,000
50,000
100,000
200,000
1,000,000
2,000,000
Waste Quantities (mt/mo)
42
417
2,083
4,167
8,333
16.667
83.333
166,667
Waste Quantity (ft3/mo)
1.472
14,721
73,604
147,209
294.418
588,835
2,944,177
5,888,355
Waste Quantity (qal/mo)
11,012
110,120
550,598
1.101.196
2.202.392
4,404.784
22,023,919
44.047,837
Waste Quantity (qal/dav)
367
3,671
18.353
36,707
73,413
146,826
734,131
1,468,261
Unit Construction
Unit size (ft2)
4,061
6.410
15,688
26.478
47,192
87,314
395.890
774.557
Unit size (acres)
0.09
0.15
0.36
0.61
1.08
2.00
9.09
17.78
Annualized Land ($/vr)
$2500/acre
22
35
85
143
256
473
2.145
4,196
Annualized Excavation
$0.17077/ft3
24
237
1,186
2,373
4,746
9.491
47.457
94.914
Ann. Liner (40 mil qeomembrane)
$0.5602/ft2
215
339
830
1.400
2.495
4.617
20,934
40,956
Material Handling
Distance to Unit (ft)
500
500
500
500
1.000
1.000
1,000
1,000
PiDina - annualized capital
425
425
425
425
821
904
1.120
1,390
Pipinq - annual 0 & M
1,000
1.000
1.000
1.000
1.000
1.000
1.000
1,000
Total Annual Cost ($/yr)
1,685
2,036
3,526
5,341
9,318
16,485
72,655
142,457
Unit Cost ($/mt)
3.37
0.41
0.14
0.11
0.09
0.08
0.07
0.07
April 15, 1997
-------
Exhibit D-18
Annual Storage Cost Assuming 30 Day Storage of Liquids in Unlined Surface Impoundments with Groundwater Monitoring
* Surface Impoundment Unit Cost A B C D E_ F G H
Waste Quantities (ml/vr)
500
5,000
25,000
50,000
100,000
500,000
1.000,000
2,000,000
Waste Quantities (mt/mo)
42
417
2,083
4,167
8.333
41,667
83.333
166.667
Waste Quantity (ft3/mo)
1.472
14.721
73.604
147.209
294.418
1.472.089
2.944.177
5.888.355
Waste Quantity (aal/mo)
11.012
110.120
550.598
1.101.196
2.202.392
11.011.959
22.023.919
44.047,837
Waste Quantity (oai/dav)
'
367
3.671
18.353
36.707
73.413
367.065
734,131
1.468,261
Unit Construction
Unit size (ft2)
4.061
6.410
15.688
26,478
47,192
204.364
395.890
774,557
Unit size (acres)
0.09
0.15
0.36
0.61
1.08
4.69
9.09
17.78
Annualized Land ($/vr)
$2500/acre
22
35
85
143
256
1.107
2,145
4,196
Annualized Excavation
$0.17077/ft3
24
237
1,186
2.373
4,746
23.729
47.457
94.914
Groundwater Monitoring
Number of Downaradient Wells
3
3
3
3
4
7
10
13
Annualized Capital Cost
6.722
6.722
6.722
6.722
7.840
11.193
14.545
17.898
Annual O & M Cost
7.290
7.290
7.290
7.290
8.760
13.170
17.580
21.990
Material Handling
Distance to Unit (ft)
500
500
500
500
1.000
1.000
1.000
1.000
PiDina - annualized capital
425
425
425
425
821
985
1.120
1,390
Piping - annual 0 & M
1.000
1,000
1.000
1.000
1,000
1.000
1,000
1,000
Total Annual Cost l$Nt)
15,483
15,709
16,709
17,954
23,423
51,183
83,847
141,388
Unit Cost ($/mt>
30.97
3.14
0.67
0.36
0.23
0.10
0.08
0.07
April 15, 1997
-------
Exhibit 1)-19
Annual Storage Cost Assuming 30 Day Storage of Liquids in Unlined, Unmonitored Surface Impoundments
Surface Impoundment Unit Cost A B C O E F G H
Waste Quantities (mt/vr)
500
5,000
25,000
50.000
100,000
500,000
1,000,000
2.000,000
Waste Quantities (mt/mo)
42
417
2.083
4.167
8,333
41,667
83,333
166,667
Waste Quantity (ft3/mo)
1,472
14,721
73,604
147.209
294,418
1,472,089
2,944,177
5.888.355
Waste Quantity (gal/mo)
11.012
110,120
550.598
1.101,196
2.202.392
11,011.959
22,023,919
44,047,837
Waste Quantity (qal/dav)
367
3.671
18,353
36,707
73.413
367,065
734,131
1,468.261
Unit Construction
Unit size (ft2)
4.061
6.410
15.688
26,478
47,192
204.364
395,890
774,557
Unit size (acres)
0.09
0.15
0.36.
0.61
1.08
4.69
9.09
17.78
Annualized Land ($/vr)
$2500/acre
22
35
85
143
256
1.107
2,145
4,196
Annualized Excavation
$0.17077/ft3
24
237
1.186
2,373
4.746
23,729
47,457
94,914
Material Handling
Distance to Unit (ft)
500
500
500
500
1,000
1,000
1.000
1.000
Pioinq - annualized capital
425
425
425
425
821
985
1.120
1,390
Pioina - annual 0 & M
1.000
1.000
1.000
1.000
1.000
1,000
1.000
1,000
Total Annual Cost ($/vr)
1,470
1,697
2,696
3,941
6,823
26,820
51,722
101,500
Unit Cost ($/mt)
2.94
0.34
0.11
0.08
0.07
0.05
0.05
0.05
April 15, 1997
-------
Exhibit D-20
Annual Storage Cost (O & M only) Assuming 30 Day Storage of Liquids in Unlined, Unmonitorcd Waste Piles
Surface Impoundment Unit Cost A B C P E F G H
Waste Quantities (mt/vr)
500
5.000
25,000
. 50,000
100,000
500,000
1,000,000
2,000,000
Waste Quantities (mt/mo)
¦42
417
2.083
4,167
8,333
41,667
83,333
166,667
Waste Quantity (ft3/mo)
1,472
14.721
73,604
147.209
294.418
1.472.089
2.944.177
5.888.355
Waste Quantity (aal/mo)
11.012
110.120
550.598
1.101.196
2.202.392
11.011.959
22.023.919
44.047.837
Waste Quantity (aal/dav)
367
3.671
18.353
36.707
73.413
367.065
734.131
1.468.261
Unit Construction
Unit size (ft2)
4.061
6.410
15.688
26.478
47.192
204.364
395.890
774,557
Unit size (acres)
0.09
0.15
0.36
0.61
1.08
4.69
9.09
17.78
Annualized Land ($/vr)
$2500/acre
Annualized Excavation
$0.17077/ft3
Material Handling
.
Distance to Unit (ft)
500
500
500
500
1.000
1.000
1.000
1.000
PiDina - annualized capital
Pioina - annual O & M
1,000
1.000
1.000
1.000
1.300
1.000
1.000
1.000
Total Annual Cost ($/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 15, 1997
-------
Exhibit D-21
Relevant Ranges of Use for Curve Fit Cost Functions
¦ I " I. - — — -- ...
Solids
Equation
Range
NPT. MPT PT SL/BP PT SM
2EL1
Opt. 2
Opt. 3
Opt. 4
Drums - solid
M = 24.589X + 132.23
0.5 -200
0-200
0-200
0-200
0-200
0-200
0-200
0-200
Roll-off
V = - 0.0022xA2 + 29.272X +4840.9
50-7500
200 - 935 200 - 935
Building
v = 0,00002x^2 + 3.2395X + 35800
1300 - 51000
RCRA BUildina
y = 23.399X + 121689
120-45000
Line Pile
v = 4.0924x + 27676
500 -120.000
200 -1343.1 200-7500
200-1343.1 200-1343.1 200-935
Unlined Pile
v = 4.0335X4 26522
500 -120.000
lUnlined Pile - O $ M
v a 4.0207X + 26271
500 -120,000
1343.1 ++
1343.1 ++
45000++
45000++
935 ++
935 ++
935 ++
935++
935 ++
Disposal 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
0-250
0-220
0-220
0-220
y = -9e-7xA2 + 0.55x + 1795.7
45 - 200000
Tanks
220-500
220-500
220++
220-1 million
250 -1 million
1 million ++ 11 million ++ 11 million ++
220 -1 million
220-500
RCRA Tanks
y = -4e-6xA2 + 2.0665x + 6953.8
45 - 200000
Lined SI
Y = 0.0704X + 1955.1
500 - 2000000
Unlined S
v = 0.05x+ 1565.9
500 - 2000000 500++
500++
500++
Unlined SI (O & M)
y = 1000
500 - 2000000
500++
500++
500++
Disposal SI
y = G.025x+ 1491.4
500 - 2000000
April 15, 1997
-------
Exhbit 1)22
Storage of Solids in Drums
250,000
200,000
395x+35800
R2 = 0.(993
150,000
I
I
100,000
50,000
10,000
20,000
30,000
40,000
50,000
60,000
Waste Quantity (mt/yr)
April 15, 1997
-------
Exhibit D-23
Storage of Solids in Roll-off
y - -0 0022x + 39.27: x * 4«40.»
It* - O.MSI
2000
4000
Waist* Quantity (mt/yr)
April 15, 1997
-------
Exhibit D-24
Storage of Solids in Dome Buildings
250,000
200,000
y = 2E-05X2 + 3,5 395x + 35000
Rz = 0.1993
150,000
100,000
50,000
10,000
20,000
30,000
40,000
50,000
60,000
Waste Quantity (mt/yr)
April 15, 1997
-------
Exhibit D-25
Storage of Solids in RCRA Containment Building
IN
J
10000
8000
1S000
0
20000
30000
36000
2S000
40000
4S000
Watt* Quantity (mt/yr)
April 15, 1997
-------
Exhibit I>-26
Storage Cost of Solids In Lined Piles
y ¦ 4.0924X * 211
R* » O.MB0
#71
3
u
20,000
40,000
•0,000
Wuli Quantity (mt/yr)
80,000
100,000
120,000
April 15, 1997
-------
Exhibit D-27
Storage of Solids in Unlined Piles
- 4.033SX + 2*822
—II1 ¦O.IIWV^
¦c
t
o
o
200,000
•0,000
120,000
Watt* Quantity (mtfyr)
April 15,1997
-------
Exhibit D-28
Storage of Solids in Unliocd Pile (O & M only)
- 4.0207X + 26271
R,«oj»n7'
100,000
120,000
Willi Quantity (mtAyr)
April 15,1997
-------
Exhibit D-29
Storage of Liquids in Drums/Mini-Bulks
2,100.00
2,000.00
o
0
1,800.00
1,000.00
SOO.OO
<
y • -0.0074*1
R»
~ I.47HX ~ 1tt.34
• 0 J92»
~
*
~
~
so
100 180
Watt* Quantity (mt/yr)
200
280
April 15, 1997
-------
Exhibit D-30
Storage in Tanks
y • -9E-07 r ~ 9M» * I79S.7
20,000
10,000
100,000 120,000 140,000 100,000 100,000 200,000
Waal* Quantity (mUyr)
April 15, 1997
-------
Exhibit D-31
Storage of Liquids in RCRA Tanks
250,000
f 2.0665X i 6953.8
= 0.9917
200,000
150,000
I
I
100,000
50,000
20,000 40,000 60,000 80,000 100,000 120,000 140,000 160,000 180,000 200,000
Waale Quantity (mt/yr)
April 15, 1997
-------
Exhibit D-32
Storage of Liquids in Lined Impoundments
110,000
140,000
130,000
100,000
z 00.000
•
o
o
•0,000
40,000
20,000
y-0.0704*
H*.
~ 18S5.1
1
J. . '
200,000 400,000 000,000 000,000 1,000,000 1,200,000 1,400,000 1,000,000 1,000,000 2,000,000
Watt* Quantity (mt/yr)
April 15, 1997
-------
Exhibit D-33
Storage of Liquid* in Unlined Impoundments
120,000
100,000
y • 0.05k * 1SII.0
•0,000
c
§
* 10,000
o
o
40,000
too,000 400,000 100,000 000,000 1,000,000 1,200,000 1,400,000 1,000,000 1,800,000 2,000,000
Wa«t« Quantity (rotfyr)
April 15, 1997
-------
Exhibit D-34
Disposal of Solids in (Jnlined Waste Pile
y« 1.070: ix * 12901
R* - i i.S0»4 /
700,000
•00,000
¦c
t
z *00,000
m
o
»
400,000
80,000 100,000 100,000 200,000 280,000 300,000 380,000 400,000 480,000 800,000
Waslt Quantity (mt/yr)
.April 15, 1997
-------
Exhibit D-35
7 day storage Tanks
0.117SX ~ 31 r>.«
0.0002
e
% 40,000
e
o
20,000
10,000
400,000
700,000
Quantity (mt/yr)
April 15, 1997
-------
D-57
D.7 Costs Associated with Groundwater Monitoring
Background and Requirements
Several options allow for storage of high volume material in land based units prior to reclamation,
if several conditions are met. One of these conditions includes a groundwater monitoring requirement if
unlined piles or surface impoundments are being used. The minimum requirements for establishing a
ground water monitoring program include:
At least three downgradient and one upgradient ground water monitoring wells,
6 test borings (4 of which are converted into the wells), and
Sampling to indicate if hazardous contaminants are migrating out of the unit.
The specific costs associated with groundwater monitoring include the following.
Capital and Initial Costs
Installation of wells-
Facility monitoring equipment:
Administrative time
- engineering study
- soil borings
- report preparation
- sampling arid analysis plan
Establish Background Concentrations:
Assess groundwater quality:
Report Results:
$5,600 / well (2 inch diameter, 50 feet deep)
$5,500 / facility
$15,360/ facility
$600 / facility
$6240 /well
$1,860/facility
$540 / facility
TOTAL FACILITY CAPITAL COST
$11,840(N+1) +$23,860
Operating and Annual Costs
Administrative Costs: $930 / facility
- Evaluate groundwater elevation
- Report results
Sampling and Analysis: $480 / facility
; $1.470/well
TOTAL FACILITY OPERATING COST S1,470(N+1) + $1,410
where N is the number of groundwater monitoring wells.
While the minimum number of wells is four (three down gradient and one up gradient), the
Agency assumed that more downgradient wells may be necessary for large units. The procedure for
determining the number of downgradient wells (N) is presented below. If N is calculated to be less than
three, N is assumed to be three.
April 15,1997
-------
D-58
Number of Ground Water Monitoring Wells for Waste Piles
The waste is assumed to be stored in a conical pile. The number of downgradient wells (N) will be
half the perimeter (P) of the waste management area divided by 150 ft The waste management area is a
circle surrounding the waste pile, with a radius of 30 feet plus the radius of the actual pile. Therefore,
there will be one well every 150 feet around the 10 foot downgradient buffer of the pile, or
N=-
2x150
where
P = 2rc(r+30)
where r can be determined from the volume of the pile (V)
V=Kr^h
3
If we assume h = r, this formula becomes:
V=
7t r
Solving for r,
r=
3V
%
Therefore, the number of downgradient wells, by substitution is:
N--
11
3
3V
—+30
>
71
150
Where V is in ft3.
April 15,1997
-------
D-59
Number of Groundwater Monitoring Wells for Surface Impoundment
Shape of surface impoundment as follows:
H*HJ_
20ft T
t -f" I
f I w
7 ^
7
8 ft
T
The number of wells (N) will be the half of the perimeter (P) of the waste management area, divided by
150 feet That is, one well every 150 feet on the downgradient half of the perimeter of the 10 foot buffer
zone surrounding the unit.
jy=_JL_
2x150
where
P=2(L+20)+2( W+20)
The length and width of die unit can be determined from the volume. The volume of the unit in cubic feet
can be calculated by breaking the unit into the center rectangular (swimming pool shaped) section, the four
triangular (prism) shaped sides, aid the four corner sections, or
V=V +V +V
r s c
Assuming a depth of 8 ft, and a side slope of 2.5 horizontally for every vertical foot (resulting in the
outside 20 feet of the unit being part of the triangular sides), the volume of the center section (Vr) is
Vr =(L -40)x( W-40)x8
The volume of the sides is calculated:
2xi-x20x8x(W-40)j +| 2x|x20x8x(L-40)j
Finally, the volume of the comers is calculated by putting all four comers together to form a four sided
April 15,1997
-------
D-60
pyramid, with diagonals of 40 ft. and sides of
20y/2
. Therefore, V, is:
y _ 20^2x20^x8
3
Therefore,
V=(L-40)x(W-40)x8+f 2x—x20x8x(V^-40) +( 2xIx20x8x(L-40)) + 20V^x20V^x8
By assuming L = 2W, this equation can be rewritten,
V=16W2-480W-9387
Or, using the quadratic formula,
480_V( -480)2+4( 16X9387+V)
2(16)
Therefore, substituting this back into the number of wells equation,
N=
L+W+40 3W+40
3x
480_V( -480)2 +4{16X9387+V)
150
150
2(16)
150
+40
April 15,1997
-------
TYPE OF UNIT RECEIVING RECYCLED
MATERIAL
APPENDIX E
Bevili Special 20
Processing Unit/
Beneficiation Unit/
Sector and Wastestream
Recycling
Status
Processing Unit/
Both/Neither
Notes
Alumina & Aluminum
Casthouse Dust
Y?
Process unit
Close to final unit
Electrolysis
Y?
Process unit
Appears to be mainly recycled to
unit generating it
Antimony
Autoclave Filtrate
Y?
Process unit
Water reuse (may require
treatment)
Stripped Analytic Solids
Y
Process unit
Goes back to leach circuit (may be
in-process material)
Beryllium
Chip treatment wastewater
YS?
Process unit
Water reuse (may require treatment;
generated at facilities without
beneficiation Unit)
Bismuth
Spent Caustic Soda
Y?
Process unit
Generated near end of processing,
Electrolyte Slimes
Y?
Process unit
may require treatment
Recoverable products
Spent Soda Solution
Y?
Process unit
Generated new and of processing
Waste Acids
YS?
Process Unit
may require treatment
Acid reuse, many parts of process
used acid (may require treatment)
Cadmium
Caustic Wastewater
Y?
Process Unit
Reuse for caustic value; may
Copper and land sulfate filter cakes
Y?
Process Unit
require treatment
These would likely be sent to
processing operations in copper and
lead sectors for metal recovery
Copper removal filter cake
Y?
Process Unit
Would likely be sent to processing
operations in copper and lead
sectors for recovery
Spent leach solution
Y?
Both
Reuse for acid value, may require
treatment
Lead sulfate waste
Y?
Process Unit
Would likely be sent to processing
Scrubber wastewater
Y?
Both
operations in lead sector
Reuse for water/acid value, may
require treatment
Zinc Precipitates
Y?
Process Unit
Would likely be sent to processing
oDerations in zinc sector
Calcium
Oust with quicklime
Y
Beneficiation Unit
Dust may be recycled to mixer and
briauettes. orior to retorting
April 15,1997
-------
E-2
Bevill Special 20
Processing Unit/
Benefidation Unit/
Sector and Wastestream
Recycling
Status
Processing Unit/
Both/Neither
Notes
Copper
Acid Plant Slowdown
YS
Both
Usually separated - liquids to
benefidation processes, solids to
smelter (may be treated before
WWTP Sludge
YS
Process unit
separation)
Appears to go to flush furnace or
filter plant
Coal Gas
MEE concentrate
YS
Process unit (gasifier)
Either recycled to gasifier or sent to
indnerator
Elemental Phosphorous
AFM Rinsate
Y
Both
Water is usually recycled in process
after furnace, but sometimes to
Furnace Scrubber Blowdown
Y
Both
calcining unit (spedal waste unit)
Furnace Building Washdown
Y
Both
FluorsDar
Off-spec fluosilicic acid
YS
Off-site
Water fluoridation
Germanium
Waste acid wash and rinse water
YS?
Process unit
Recycled for acid and/or water
Chlorinator wet air pollution control
YS?
Process unit
reuse within processing steps
Recycled to chlorinator for further
sludge
removal of Ge
Spent acid/leachate
YS?
Process unit
Recycled to leaching unit for reuse
as leaching agent to remove Ge
from zinc sintering fumes
Lead
Acid plant sludge
Slurried APC dust
Y?
Y
Benefidation Unit
Benefidation Unit
Recycled to sintering machine
Recycled to sintering machine
Solid residues
Spent furnace brick
Y?
Y
Benefidation Unit
Bevill Proc. Unit
(sinter feed preposition step)
Recycled to sintering machine
Recycled to blast furnace
Stockpiled miscellaneous plant waste
WWTP liquid effluent
WWTP sludges/solids
YS?
Y
Y
Bevill Proc. Unit
Benefidation Unit
Benefidation Unit
Recycled to blast furnace
Recycled to sintering machine
Recycled to sintering machine
Maenesium
Cast House Dust
Y
Process unit
Oose to final unit
Smut
N
Not recycled
Low grade Na/Ca/Me sludze
Mercury
Dust
Quench Water
N
Y?
Not recycled
Benefidation Unit
Dust usually recycled for metal
value - because of Hg low boiling
point likely will not contain metal
Recycled to CIL drcuit
Molvbdenum
Hue Dust/gases
N
Neither
No evidence that it could be
recycled1, text states it is not
recycled and appendix says not
recyclable
Platinum Grouo Metals
Slat
Y?
Process Unit
Recycled to electric furnace
April 15,1997
-------
E-3
Bevill Special 20
Processing Unit/
Beneficiation Unit/
Recycling
Processing Unit/
Sector and Wastestream
Status
Both/Neither
Notes
Pvrobitumens. et al.
Waste catalysts
Y?
Proeess/Off-site
Either reused in cracking operation
or sent off-site for reclamation
Rare Earths
Electrolytic cell caustic wet APC
Y
Process Unit
Aqueous streams can be used in
sludge
numerous leaching, washing, and
other operations
Process wastewater
YS?
Beneficiation Unit
Spent scrubber liquor
YS?
Beneficiation Unit
Solvent extraction crad
N
Not Recycled
Wastewater from caustic cost APC
YS?
Beneficiation Unit
Rhenium
Spent barren scrubber liquor
Y?
Both
Water-reuse, both beneficiation.
and Processing units on-site
Scandium
Spent solvents from solvent extraction
Y?
Process Unit
Probably recycled directly to
process (may require treatment) or
sent off-site to solvent recovery
Selenium '
Spent filter cake
Y?
Process Unit
Recovery of other precious metals
Plant Process wastewater
YS?
Both
Water/acid reuse (may require
treatment)
Slag
YS?
Process Unit
Copper Smelting
Tellurium slime wastes
Y?
Process Unit
Tellurium Recovery
Svnthetic Rutile
Spent Iron Oxide Slurry
YS?
Process Unit/off-site
Would be recycled for iron value.
possibly at iron facilities
APC dust/sludge
Y
Process Unit
Recycled to process, pass roaster
Spent acid solution
Y
Process Unit
Recvcled to dieester
Tellurium
Slag
YS?
Process Unit
May be returned to copper anode
for further processing
Wastewater
Y
Process Unit
Sent to selenium recovery (which is
processing operation)
Titanium and Ti02
B
Pickle liquor washwater
YS?
Process Unit
Recycled to acid pickling step
Scrap milling scrubber water
YS?
Process Unit
Recycled to Ti scrap washing step
after treatment to remove oil and
grease and suspended solids
Smut from Mg recovery
Y
Process Unit
Recycled to reduction reactor in
Knoll process
Leach liquor and sponge wash
YS?
Process Unit
Either reused after treatment as dust
suppressant on needs, or recycled to
acid leaching step
Spent furnace impoundment liquids
Y?
Process Unit
May be recycled to the finishing
step in the chloride-ilmenite process
April 15,1997
-------
E-4
Bevill Special 20
Processing Unit/
Beneficiation Unit/
Recycling
Processing Unit/
Sector and Wastestream
Status
Both/Neither
Notes
Tantalum. Columbium. FeCb
Process Wastewater
Y?
Process Unit
Water Reuse - may require
treatment - only processing on-site
Tunesten
Spent acid and rinsewater
YS?
Both
Water and acid reuse - may require
3
(to be getting) treatment - some
facilities
Process wastewater
YS?
Both
Water reuse, see above
Uranium
Waste nitric acid rinse from UOs prod
YS?
Process Unit
May require treatment, possible
reuse in yellowcake and dissolution
other acid uses
Slag
Y
Process Unit
Recycled to process
Uranium chips from ingot prod
Y?
Process Unit
May be recycled to reduction
furnaces
Zinc
Acid plant biowdown
Y
Process Unit
Recycled to hot tower
Waste ferrosilicon
Y?
Process Unit
Sold off-site
Process wastewater
Y?
Process Unit
Recycled to process units (e.g..
casting)
Spent cloths, bags, and filters
. Y
Neither/off-site
Bags/filters recycled to
manufacturer
Spent goethite and leach cake residues
N
Process Unit
Not recycled in our opinion
Spent surface impoundment liquids
YS?
Process Unit
To various process units
WWTP solids
YS
Bevill process
Recycled to zinc ore roaster
TCA tower biowdown
YS
Process Unit
Recycled to zinc acid plant
WWTP liquid effluent
YS?
Process Unit
To various process units
Zirconium and Hafnium
Leaching rinsewater from Zr alloy
YS?
Process Unit
Water reuse
prod.
Leaching rinsewater from Zr metal
YS?
Process Unit
Water reuse
April 15,1997
-------
EXPLANATION OF COST MODELING CALCULATIONS
APPENDIX F
This appendix describes the cost modeling assumptions and procedure used by EPA in developing
cost estimates supporting the proposed RCRA Phase IV Land Disposal Restrictions (LDR) cost and
economic impact analyses for mineral processing wastes. In general, the cost modeling was performed by
manipulating the input data to determine portions of material sent to treatment and disposal, as well as
storage prior to recycling. These portions of material were then used to determine the average facility and
total sector costs associated with treatment and disposal, and storage prior to recycling for each baseline
and option considered. The costs attributable to this rale were calculated by subtracting the cost of the
baseline from the cost of each regulatory option. Appendix G presents & 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, EPA developed a range consisting of minimum, expected, and maximum
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 certainty in whether the particular waste stream
exhibited one or more of the RCRA hazardous waste characteristics.
As shown below in Exhibit F-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 in the
maximum value case the entire stream would be counted as if it was known to be hazardous.
Exhibit F-l
Portion of Waste Stream Considered to Be Hazardous (Percent)
¦ " "¦ ¦— IT !¦ I 1 \ mil !!>¦ nil I I , I III ni I 111 in I nl —
Costing Scenario
Hazard Characteristic(s)
Y
Y?
Minimum
100
0
Expected
100
50
100
100
where:
Y means that EPA has data demonstrating that the waste exhibits one or more of the RCRA
hazardous waste characteristics; and
Y? means that EPA, based on professional judgment, believes that the waste may exhibit one or
more of the RCRA hazardous waste characteristics.
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 sent into a
DRAFT-February 12, 1997
-------
F-2
component sent to treatment and disposal and a component stored prior to recycling, EPA used the tables
in Exhibits F-2 and F-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
to 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.
Exhibit F-2
Proportions of Waste Streams Treated and Disposed (in percent)
Baseline or Option
Affected
Material
Percent Recycled
Certainty of Recycling
Y Y? YS YS? N
Prior Treatment
SL/BP
0
15
25
80
100
Prior Treatment
SM
A
W
25
35
85
100
Modified Prior Treatment
AO
0
15
25
80
100
No Prior Treatment
All
0
100
60
100
100
Option 1 from PT
Bevill
100
100
100
. 100
100
Non-Bevill
30
65
100
100
100
Option 2 from PT
Bevill
100
100
100
100
100
Non-Bevill
0
25
35
85
100
Option 3 from PT
All
0
25
35
85
100
Option 4 from PT
All
0
15
25
80
100
Option 1 from MPT
Bevill
100
100
100
100
100
Non-Bevill
30
65
100
100
100
Option 2 from MPT
Bevill
100
100
100
100
100
Non-Bevill
0
25
35
85
100
Option 3 from MPT
All
0
25
35
85
100
Option 4 from MPT
All
0
15
25
80
100
Option 1 from NPT
Bevill
100
100
100
100
100
Non-Bevill
20
100
90
100
100
Option 2 from NPT
Bevill
100
100
100
100
100
Non-Bevill
0
30
40
85
100
Option 3 from NPT
All
0
30
40
85
100
Ontion 4 from NPT
n
15
c
OC
100
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 be
fully recycled.
Bevill means that secondary materials are recycled through beneficiation or Bevill process units
Non-Bevill means that secondary materials are not recycled through beneficiation or Bevill process units
April 15,1997
-------
F-3
Exhibit F-3
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
CT fOX>
100
85
75
20
0
Prior Treatment
SM
100
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
Bevill
0
0
0
0
0
Non-Bevill
70
35
0
0
0
Option 2 from PT
Bevill
0
0
0
0
0
Non-Bevill
100
75
65
15
0
Option 3 from PT
All
100
75
65
15
0
Option 4 from PT
All
100
85
75
20
0
Option 1 from MPT
Bevill
0
0
0
0
0
Non-Bevill
70
35
0
0
0
Option 2 from MPT
Bevill
0
0
0
0
0
Non-Bevill
100
75
65
15
0
Option 3 from MPT
All
100
75
65
15
0
Option 4 from MPT
All
100
85
75
20
0
Option 1 from NPT
Bevill
0
0
0
0
0
Non-Bevill
80
0
10
0
0
Option 2 from NPT
Bevill
0
0
0
0
0
Non-Bevill
100
70
60
15
0
Option 3 from NPT
All
100
70
60
15
0
ODtion 4 from NPT
All
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 be
fully recycled.
Bevill means that secondary materials are recycled through beneficiation or Bevill process units
Non-Bevill means that secondary materials are not recycled through beneficiation or Bevill process units
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
the Cost Model Appendix (bound separately). These "model facility" generation rates of each type of
April 15,1997
-------
F-4
waste were used to first determine whether wastes would be treated on- or off-site and then to determine
the cost associated with their being sent to 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 of 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 being stabilized (2.25 percent of liquid streams plus 100 percent of
solid streams), and the quantity being disposed (3.49 percent of liquid streams, and 175 percent of solid
streams). If the quantity requiring neutralization was below 350 mt/yr, EPA assumed that this waste would
be sent off-site for treatment If die quantity requiring stabilization was below 870 mt/yr, EPA assumed
this waste would be sent off-site for treatment and disposal.
EPA then applied these estimated quantities to the treatment and disposal costing functions
described in Appendix E 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
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 die only costs associated with recycling wastes are the costs of constructing and
operating storage units. For each waste stream, EPA used the quantity 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 aided 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 Total Sector Costs and Impacts
Finally, EPA calculated the total sector costs by adding the total sector incremental treatment costs
to the total sector incremental recycling costs. EPA divided this total sector cost by die number of
facilities to determine die average facility cost EPA then divided the total sector costs by the value of
shipments (and multiplied by 100) to determine the percentage impacts in each sector.
April 15,1997
-------
MINERAL PROCESSING COST MODEL EXAMPLE CALCULATION:
TITANIUM AND TITANIUM DIOXIDE SECTOR APPENDIX G
This appendix presents a stepwise example of how the mineral processing cost model calcluates
the cost of this rulemaking for Option 3 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 and
results differ slightly from those found in the cost model printouts due to rounding.
The appendix is divided into five 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. Finally, in the fifth section, the incremental treatment and storage costs are
combined, along with recordkeeping costs, to obtain the total incremental sector cost.
G.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, solid); and
5. Regulatory classification (i.e. by-product, spent material, sludge).
These data are used to calculated sector costs as described in later sections of this appendix.
G.l.l Waste Stream Generation Rate and Number of Waste-Producing Facilities
The titanium and titanium dioxide mineral processing sector generates eight waste streams.
Exhibit G-l shows the number of waste producing 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 data 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 3. Calculations for all of the other baselines and options follow the same pattern as described below.
April 15,1997
-------
G-2
Exhibit G-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
Leach Liquor and Sponge Wash Water
2
38g;oog
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
G.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
hazardous characteristics:
• Toxicity (i.e., containing on or more of the eight TC Metals);
• Corrosivity;
• Ignitability; and
• Reactivity.
Exhibit G-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. Four 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 four 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
ignitable or reactive.
Exhibit G-2
Hazardous Characteristics
Titanium
Waste Stream
TC h
letals
COTT
Ignit
Rctv
Overall
Haz?
As
Ba
Cd
Cr
Pb
Hg
Se
Ag
Pickle Liquor and Wash Water
Y?
Y?
Y?
Y?
N?
N?
Y?
Scrap Milling Scrubber Water
Y?
Y?
Y?
Y?
N?
N?
N?
Y?
Smut from Mg Recovery
N?
N?
Y
Y
Leach Liquor and Sponge Wash Water
Y?
Y?
Y
N?
N?
Y
Spent Surface Impoundment Liquids
Y?
Y?
N?
N?
N?
Y?
Spent Surface Impoundment Solids
Y?
Y?
N?
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 be hazardous, Y? = suspected to be hazardous
April 15,1997
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G-3
G.l J Recycling Status, RCRA Waste Type, and Waste Treatment Type
Exhibit G-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) in
Exhibit G-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 are assigned "N" (no) because they are known not to be
recycled at all (N). Of the five streams that are recycled in some capacity, three are spent materials, one is
a by-product, and one is a sludge. Five of the waste streams in the sector are wastewaters, and three waste
streams are solids.
Exhibit G-3
Recycling Status
Titanium
Recycling
RCRA
Physical
Waste Stream
Status
Waste Type
Form
Pickle Liquor and Wash Water
YS?
Spent Mat'l
Wastewater
Scrap Milling Scrubber Water
YS?
Sludge
Wastewater
Smut from Mg Recovery
Y?
By-Product
Solid
Leach Liquor and Sponge Wash Water
YS?
Spent Mat'l
Wastewater
Spent Surface Impoundment Liquids
Y?
Spent Mat'l
Wastewater
Spent Surface Impoundment Solids
N
NA-
Solid
Waste Acids (Sulfate Process)
N
NA
Wastewater
WWTP Sludges/Solids
N
NA
Solid
G.2. Manipulation of Input Data
This section shows how input data described in the previous section are manipulated so that
treatment and storage costs can be calculated. The model combines uncertainty about hazard
characteristics with uncertainty in generation rates to create a bounded cost analysis, i.e., an expected value
case with minimum and maximum value cases providing estimated lower- and upper-bound costs. This
section of the appendix helps set the stage for later calculation of expected value costs, upper bound costs,
and lower bound costs by calculating the quantity of each waste stream that must be treated and disposed
versus recycled in the expected value case, the upper bound case, and the lower bound case.
Manipulation of input data occurs in four steps which are listed here and described in detail later
in this section:
1) The estimated or reported generation rate for each of the eight waste streams (from Exhibit
G- 1) is divided into a hazardous component and a non-hazardous component;
2) The hazardous portion of each waste stream is divided into a component that is treated and
disposed, and a component that is stored prior to recycling;
3) "Model facility" totals are calculated for the treated and disposed waste; and
4) Average facility quantities are calculated for waste stored prior to recycling.
April 15,1997
-------
G-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 while 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.
G.2.1 Estimate Waste Stream Portion Assumed to be Hazardous
As indicated in Exhibit G-2 above, four 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 G-l by the
following percentages in Exhibit G-4, to calculate the minimum, expected, and maximum quantities of
the waste stream estimated to be both generated and hazardous:
Exhibit G-4
Hazard Certainty Multipliers
Costing
Scenario
Hazard Certainty
Y?
Y
Minimum
0%
100%
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 G-5. The effect of this procedure is to bound the
analysis, which is especially important for the four 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 G-l) x 0% (from
Exhibit G-4) = 0 mt/yr], while the expected value case hazardous portion would be 13,500 mt/yr [27,000
mt/yr generated (from Exhibit G-l) x 50% (from Exhibit G-4) = 13,500 mt/yr].2 In the maximum value
case, the entire quantity (32,000 mt/yr) is assumed to be hazardous. For the four titanium waste streams
known to be hazardous, the entire generated quantity of those wastes is included in the analysis.
1 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 on.
April 15, 1997
-------
G-5
Exhibit G-5
Portion of Waste Assumed to be Hazardous
Titanium
Waste Stream
Hazard
Certainty
Portion of Waste that is Hazardous
(mt/yr)
Minimum
Expected
Maximum
Pickle Liquor and Wash Water
Y?
0
1,350
3,200
Scrap Milling Scrubber Water
Y?
0
2,500
6,000
Smut from Mg Recovery
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
G.2.2 Divide Hazardous Quantities Into Portion Treated/Disposed and Portion
Stored Prior to Recycling
The hazardous portion of each waste stream (from Exhibit G-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 G-3 above). The treatment/disposal multipliers are shown in Exhibit G-6, and the
recycling multipliers are shown in Exhibit G- 7. Note that in all cases the treatment and disposal multiplier
in Exhibit G-6 and the recycling multiplier in Exhibit G-7 sum to 100 percent (i.e., all waste is assumed to
be handled in accordance with EPA 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 15,1997
-------
G-6
Exhibit G-6
Proportions of Waste Streams Treated and Disposed (in percent)
Baseline or Option
Affected
Material
Percent Disposed
Recycling Status
Y Y? YS YS? N
No Modified Prior Treatment
All
0
100
60
100
100
Modified Prior Treatment (SL/BP) &
MPT
All
0
15
25
80
100
Modified Prior Treatment (SM)
All
0
25
35
85
100
Option 1 from NPT
All
20
100
90
100
100
Option 2 from NPT
Bevill*
100
100
100
100
100
Option 3 from NPT
All
0 .
30
40
90
100
Option 4 from NPT
All
0
15
25
80
100
Option 1 from MPT & PT (SL/BP)
All
30
65
100
100
100
Option 2 from MPT & PT (SL/BP)
Bevill*
100
100
100
100
100
Option 3 from MPT & PT (SL/BP)
All
0
25
35
85
100
Option 4 from MPT & PT (SL/BP)
All
0
15
25
80
100
Option 1 from PT (SM)
All
30
65
100
100
100
Option 2 from PT (SM)
Bevill*
100
100
100
100
100
Option 3 from PT (SM)
All
0
25
35
85
100
Option 4 from PT (SM)
All
0
15
25
80
100
* For materials recycled through Bevill Units only - Materials not recycled through Bevill Units are treated and
disposed according to Option 3 multipliers.
SL = Sludge, BP = By-Product, SM = Spent Material
April 15,1997
-------
G-7
Exhibit G-7
Proportions of Waste Streams Stored Prior to Recycling (in percent)
Percent Recycled
Baseline or Option
Affected
Recycling Status
Material
Y
Y?
YS
YS?
N
No Modified Prior Treatment
All
100
0
40
0
0
Modified Prior Treatment (SL/BP) &
All
100
85
75
20
0
MPT
Modified Prior Treatment (SM)
All
100
75
65
15
0
Option 1 from NPT
All
80
0
10
0
0
Option 2 from NPT
Bevill*
0
0
0
0
0
Option 3 from NPT
All
100
70
60
10
0
Option 4 from NPT
All
100
85
75
20
0
Option 1 from MPT & PT (SL/BP)
All
70
35 -
0
0
0
Option 2 from MPT & PT (SL/BP)
Bevill*
0
0
0
0
0
Option 3 from MPT & PT (SUBP)
All
100
75
65
15
0
Option 4 from MPT & PT (SUSP)
All
100
85
75
20
0
Option 1 from-PT (SM)
All
70
35
0
0 .
0
Option 2 from PT(SM)
Bevill*
0
0
0
0
0
Option 3 from PT (SM)
All
100
75
65
15
0
Option 4 from PT (SM)
All
100
85
75
20
0
* For materials recycled through Bevill Units only ~ Materials not recycled through Bevill Units are stored
prior to recycling according to Option 3 multipliers.
SL = Sludge, BP = By-Product, SM = Spent Material
The quantities of waste treated/disposed and the quantities of waste stored prior to recycling for
each waste stream in the sector are shown in Exhibit G-8 and G-9, respectively. Quantities reported in
Exhibit G-8 and G-9 are calculated by multiplying the portion of waste that is hazardous (Exhibit G-5) by
the appropriate treatment/disposal or recycling multipliers (from Exhibit G-6 and G-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, 85 percent of the waste, or approximately 1,150 mt/yr (1,350 mt/yr x
0.85), is sent to treatment/disposal, while 15 percent of the waste, or approximately 200 mt/yr (1,350 mt/yr
x 0.15), is stored prior to recycling.
G.23 Calculate Total Quantity Treated and Disposed at a "Model Facility"
The cost model assumes that each facility 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 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 die
titanium waste streams (see Exhibit G-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 G-4), Therefore, the maximum
number of facilities generating at least one titanium waste drops to two in the minimum value case,
because ail of die titanium waste streams generated by more than two facilities have a Y? hazard certainty
April 15,1997
-------
G-8
classification (see Exhibit G-l). For purposes of 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. For example, the total wastewater treated/disposed for the pre-rule
expected value case is 450,573 mt/yr (which is the sum of the wastewater streams in Exhibit G-10).
Dividing by seven, the model facility wastewater treated/disposed for the expected value case is 64,368
mt/yr. Exhibit G-10 presents the model facility waste treated/disposed for the minimum, expected, and
maximum value scenarios.
Exhibit G-8
Portion of Hazardous Wastes Generated Treated and Disposed
Waste Stream
Multiplier
Portion of Waste Treated/Disposed
(mt/yr)
Minimum
Expected
Maximum
Pre-Rule
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)
I
200
39,000
77,000
WWTP Sludges/Solids
1
0
210,000
420,000
Post-Rule
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
18,000
36,000
Waste Acids (Sulfate Process)
1
200
39,00)
77,000
WWTP Sludges/Solids
1
0
210,000
420,000
April 15,1997
-------
G-9
Exhibit G-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
Expected
Maximum
Pre-Rule
Pickle Liquor and Wash Water
0.20
0
270
640
Scrap Milling Scrubber Water
0.20
0
500
1,200
Smut from Mg Recovery
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
Waste Acids (Sulfate Process)
0
0 •
0
0
WWTP Sludges/Solids
A
u
0
0
0
Post-Rule
Pickle Liquor and Wash Water
0.15
0
203
480
Scrap Milling Scrubber Water
0.15
0
375
900
Smut from Mg Recovery
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
Exhibit G-10
Model Facility Quantity of Waste Treated/Disposed
Baseline/Option
Model Facility Waste Treated/Disposed (mt/yr)
Minimum
Expected
Maximum
11
1-10%
Solids
Solids
Waste-
waters
1-10%
Solids
Solids
Waste-
waters
1-10%
Solids
Solids
Pre-Rule
152,100
0
8
60.905
0
33,043
78,481
0
66,107
Post-Rule
161,100
0
13
64,385
0
33,35?
82,785
0
66.750
G.2.4 Calculation of Average Quantity Recycled
Since 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 G-9) by the number of facilities
that generate each waste (from Exhibit G-l). Exhibit G-l 1 shows the results of this calculation.
April 15, 1997
-------
G-iO
Exhibit G-ll
Average Facility Quantities Stored Prior to Recycling
Waste Stream
Number
of
Facilities
Average Facility Waste
Stored Prior to Recycling
(mt/yr)
Minimum
Expected
Maximum
Pre-Rule
•
Pickle Liquor and Wash Water
3
0
90
213
Scrap Milling Scrubber Water
1
0
500
1,200
Smut from Mg Recovery
2
43
9,350
19,125
Leach Liquor and Sponge Wash Water
2
38,000
48,000
58,000
Spent Surface Impoundment Liquids
7
0
206
814
Spent Surface Impoundment Solids
7
0
0
0
Waste Acids (Sulfate Process)
2
0
0
0
WWTP Sludges/Solids
7
0
0
0
Post-Rule
Pickle Liquor 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
Leach Liquor and Sponge Wash Water
2
28,500
36,000
43,500
Spent Surface Impoundment Liquids
7
0
182
718
Spent Surface Impoundment Solids
7
0
0
0
Waste Acids (Sulfate Process)
2
0
0
0
WWTP Sludges/Solids
7
0
0
0
G.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 G-10 axe
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 cost.
All treatment and disposal calculations are performed using the "model facility" quantities calculated in the
last section of this document
G.3.1 Determination of On-Site versus Off-Site Treatment
The model assumes that low-volume wastes (s 879 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 G-10).
April 15,1997
-------
G-n
G.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:3
Surge Tank Costs (S/yr) = 4 x 10"8 Qn2+0.1175Q„ + 3,680
Capital Costs ($) = 36,131 + 151.95 Q„°5
O&M Costs (S/yr) = -206,719 + 36,594 In Q„
Closure Costs ($) = 6,361 + 10"3 Q„
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. Using the pre-
rule 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 G-
10). Therefore, neutralization surge tank storage costs equal 510,985, neutralization capital costs equal
$73,631, neutralization O&M costs equal $196,440 per year, and neutralization closure costs equal
$6,422. Exhibit G-12 shows the neutralization costs for the titanium and titanium dioxide sector.
Exhibit G-12
Neutralization Costs
Baseline/Option
Costs
Neutralization Costs
Minimum
Expected
Maximum
Pre-Rule
- Surge ($/yr)
22,477
10,985
13,148
- Capital ($)
95,392
73,631
78,699
- O&M ($/yr)
229,931
196,440 -
205,718
- Closure ($)
6,513
6,422
6,439
Post-Rule
- Surge ($/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 ($) = 3,613 + 15.195 Qpos
O&M Costs ($/yr) = 826.48 + 0.3465 Qp
In the above equations, Qp (the amount of waste requiring precipitation) equals the sum of
wastewaters and waste streams with one to ten percent solids requiring treatment Using the. pre-rule
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 G-
3 Equations from Exhibit D-l, Appendix D.
4 EPA assumes that neutralization and precipitation occur within the same unit, therefore, precipitation closure
costs are included in the neutralization closure cost equation.
April 15, 1997
-------
G-12
10). Therefore, precipitation capital costs equal $7,363, and precipitation O&M costs equal $21,930 per
year. Exhibit G-13 shows the precipitation costs for the titanium and titanium dioxide sector.
Exhibit G-13
Precipitation Costs
Baseline/Option
Costs
Precipitation Costs
Minimum
Expected
Maximum
Pre-Rule
- Capital ($)
9,539
7,363
7,870
- O&M (S/yr)
53,529
21,930
28,020
Post-Rule
- Capital ($)
9,721
7,469
7,985
- O&M ($/yr)
56,821
23,136
29,511
G3.3 Dewatering and Stabilization Costs
Neutralization operations produce a shiny which must be dewatered, stabilized, and disposed,
About 15 percent of the quantity introduced into the neutralization operation leaves as this slurry.
Therefore, in the following equations, Qdw» 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:5
Capital Costs ($) = 95,354 + 664.48 Qdw05
O&M Costs ($/yr) = 12,219 + 286.86 Qdw05
For example, in the post-rule expected value case, is equal to 9,658 mt/yr [(64,385 mt/yr
wastewaters plus 0 mt/yr wastes with a solids content of 1 to 10 percent (from Exhibit G-10)) x 0.15].
Therefore, the capital cost associated with dewatering 9,658 mt/yr waste is $160,655, and the O&M cost
is $40,410 per year.
Dewatering produces a sludge which needs to be stabilized and disposed. The dewatered
sludge, equal to about 15 percent of the mass entering dewatering, is combined with the solid waste
streams requiring stabilization and disposal in the following equations:6
Capital Costs ($) = 207.93 Q,0 78
O&M Costs ($/yr) = 87,839 + 52.16 Qs
• Closure Costs ($) = 9,806 + 0.19 Q,
In these equations therefore, the quantity requiring stabilization, Qs, is 2.25 percent7 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 1 to 10 percent
solids ((64,385 mt/yr + 0 mt/yr, from Exhibit G-10, * 0.0225) plus 33,357 mt/yr solids (from Exhibit G-
10)]. Therefore, the capital cost associated with stabilizing 34,806 mt/yr waste is $725,110, the O&M
5 Equations obtained from Case A, Exhibit D-2, Appendix D.
6 Equations obtained from Case B, Exhibit _D-2, Appendix D.
' •This is equal to 15 percent of the quantity entering dewatering, which is 15 percent of the original quantity
requiring treatment.
April 15, 1997
-------
G-13
cost is $1,903,302 per year, and the closure cost is $16,419. Exhibit G-14 shows the dewatering and
stabilization costs for the titanium and titanium dioxide sector.
Exhibit G-14
Dewatering and Stabilization Costs
Baseline/Option
Costs
Dewatering and Stabilization Costs
Minimum
Expected
Maximum
Dewaiering
Stabilization
Dewatering
Stabilization
Dewatering
Stabilization
Pre-Rule
- Capital ($)
195,721
118,979
158,866
718,728
167,450
1,220,787
- O&M ($/yr)
55,548
266,761
39,637
1,882,840
43,343
3,628,085
- Closure ($)
NA
10,458
NA
16,345
NA
22,702
Post-Rule
- Capital ($)
,198,808
124,857
160,655
725,110
169,400
1,231,154
- O&M (S/yr)
56,881
278,171
40,410
1,903,302
44,185
3,666,676
- Closure ($)
NA
10,499
NA
16,419
NA
22,842
G3.4 Disposal Costs
After neutralization, precipitation, dewatering, 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
Pile Costs ($/yr) = 1.8703 Q* + 12,308
In die above equation, Q^, the quantity being disposed, is equal to 155 percent of the mass
entering stabilization from dewatering added to 175 percent of the solid wastes entering stabilization.
Alternatively is the sum of [1.55 x (0.0225 x (quantity of wastewaters and wastes with a 1 to 10
percent solids content requiring treatment)] and [1.75 x (quantity of solids requiring treatment)]. For
example, in the expected value case of Option 3, QdJ is equal to 60,621 mt/yr [(1,449 mt/yr x 1.55) plus
(33,357 mt/yr x 1.75)]. Therefore, the cost of disposal in a pile is equal to $130,717. Exhibit G-15
depicts the disposal costs for the sector.
Exhibit G-15
Disposal Costs
Baseline/Option
Costs
Disposal Costs
Minimum
Expected
Maximum
Pre-Rule
22,255
124,431
233,797
Post-Rule
22,859
125,686
236,182
* Equation obtained from Exhibit D-21.
April 15, 1997
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G-14
GJ.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 incuned after 20 years of operation (i.e., in year 21), are reduced to present value and
then annualized using the CRF. The annualization process and the calculation of total neutralization,
precipitation, dewatering, and stabilization costs are accomplished using the following formula:10
• Annualized Cost = (Capital Costs)(CRF) + O&M Costs +
(Closure Costs)(CRF)/(1.0721)
Using the above formula, the model combines the capital, O&M, and closure costs to obtain
total annualized neutralization, precipitation, dewatering, and stabilization costs for the titanium sector."
For example, the pre-rule annualized stabilizationn cost in the titanium and titanium dioxide sector equals
($718,728 x 0.09439) + $1,882,840 + (($16,345 x 0.09439)/1.0721), or $1,951,053. The disposal cost
function is already annualized. Exhibit G-16 presents the total annualized neutralization, precipitation,
dewatering, stabilization, and disposal costs for the titanium sector.
Exhibit G-16
Annualized Neutralization, Precipitation, Dewatering, Stabilization, and Disposal Costs
(Modified Prior Treatment Baseline and Option 3)
Baseline/Option
Costs
($)
Costing Scenario
Minimum
Expected
Maximum
Pre-Rule
- Neutralization
261,531
214,521
226,441
- Precipitation
54,429
22,625
28,763
- Dewatering
74,022
54,632
59,149
- Stabilization
278,230
1,951,053
3,743,833
- Disposal
22,255
124,431
233,797
Total
690,467
2367,262
4,291,983
Post-Rule
- Neutralization
265,186
217,080
229,012
- Precipitation
57,739
23,841
30,265
- Dewatering
75,646
55,574
60,175
- Stabilization
290,196
1,972,119
3,783,405
- Disposal
22,859
125,686
236,182
Total
711,626
2.394300
4339,039
Total titanium sector pre- and post-rule treatment costs are calculated by summing the
annualized neutralization, precipitation, dewatering, stabilization, and disposal costs from Exhibit G-16
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
9 Derivation of the CRF may be found on page D-2 of Appendix D.
10 For more information, see pages D-l and D-2 of Appendix D.
11 Surge tank costs are also added to the annualized capital, O&M, and annualized closure costs in the
calculation of the total annualized neutralization cost.
April 15,1997
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G-15
expected value case pre-rule treatment cost in this example is equal to (($214,521 + $22,625 + $54,632 +
$1,951,053 + $124,431 = $2,372,235) x 7), or $16,570,834. Similarly, the total titanium sector expected
value case post-rule treatment cost in this example is equal to (($217,080 + $23,841 + $55,574 +
$1,972,119 + $125,686 = $2,399,311) x 7), or $16,760,100.
G.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 $42,318 in the minimum value case, $189,266 in the expected value
case, and $329,392 in the maximum value case.
G.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
for each waste stream; (3) a total sector storage cost is calculated; and (4) a total sector incremental
storage cost is calculated. Note that until die total sector storage cost is calculated at the end of this
section, all calculations in this section are performed on an average facility basis.
G.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 the range of quantities over which each type of unit is the least costly storage unit available.
Exhibit G-17 shows these cost functions for the various storage units available for use in the Modified
Prior Treatment baseline and Option 3, as well as the range of quantities for which that unit would be
employed.12 In each of these equations, Q is the annual quantity requiring storage prior to recycling.
12 For a full list of storage unit functions, refer to Exhibit D-21.
April 15, 1997
-------
G-16
Exhibit G-17
Storage Cost Equations
Modified Prior Treatment Baseline
Waste
Type
Storage Unit
Quantity Range
(mt/yr)
Cost Equation
Liquid
Drum
0-220
Y = -0.0074 Q2 + 9.4798 Q + 189.34
Tank
220-500
Y = -9xl0'7 Q2+ 0.55 Q + 1,795.7
Unlined S.I.
2 500
Y= 1,000
Solid
Drum
0-200
Y = 24.589 Q+ 132.23
Roll-Off
200 - 935
Y = -0.0022 Q2 + 29.272 Q + 4,840.9
Unlined Pile
a 935
Y = 4.0207 Q +26,271
Option 3 (PT)
Waste
Type
Storage Unit
Quantity Range
(mt/yr)
Cost Equation
Liquid
Drum
0-220
Y = -0.0074 Q2 + 9.4798 Q + 189.34
Tank
220 - 1 million
Y = -9xl0"7 Q2+ 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 Q2 + 29.272 Q + 4,840.9
Building
1343.1-45,000
Y = 0.00002 Q2 + 3.2395 Q + 35,800
Lined Pile
>45,000
Y = 4.0924 O + 27,676
SL = Sludge, BP = By-Product, SM = Spent Material
Exhibit G-18 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 unlined surface impoundment in the pre-nile maximum value case because it is a liquid waste
(a wastewater), classified as a sludge, and the quantity stored prior to recycling (1200 mt/yr) exceeds the
threshold quantity of 500 mt/yr needed to store liquids in an unlined surface impoundment.
G.4.2 Storage Costs
Exhibit G-19 shows the storage costs for each of the eight titanium waste streams. Exhibit G-19
is created by plugging the quantity of waste stored prior to recycling (Exhibit G-l 1) into the appropriate
cost function from Exhibit G-17. 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 are as foEows:
Cost = -9xl0"7 Q2+ 0.55 Q + 1,795.7
Inserting 28,500 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, $20,429 in the
expected value case, and $24,018 in the maximum value case.
April 15,1997
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G-I7
Exhibit G-18
Storage Units Used in the Modified Prior Treatment Baseline and Option 3
Titanium Waste Stream
Storage Unit
'Minimum
Expected
Maximum
Pre-Rule
Pickle Liquor and Wash Water
Not Recycled
Drum
Drum
Scrap Milling Scrubber Water
Not Recycled
Unlined S.I.
Unlined S.I.
Smut from Mg Recovery
Dram
Unlined Pile
Unlined Pile
Leach Liquor and Sponge Wash Water
Unlined S.I.
Unlined S.I.
Unlined S.I.
Spent Surface Impoundment Liquids
Not Recycled
Drum
Unlined S.I.
Spent Surface Impoundment Solids
Not Recycled
Not Recycled
Not Recycled
Waste Acids (Sulfate Process)
Not Recycled
Not Recycled
Not Recycled
WWTP Sludges/Solids
Not Recycled
Not Recycled
Not Recycled
Post-Rule
Pickle Liquor and Wash Water
Not Recycled
Drum
Drum
Scrap Milling Scrubber Water
Not Recycled
Tank
Tank
Smut from Mg Recovery
Drum
Building
Building
Leach Liquor and Sponge Wash Water
Tank
Tank
Tank
Spent Surface Impoundment Liquids
Not Recycled
Drum
Tank
Spent Surface Impoundment Solids
Not Recycled
Not Recycled
Not Recycled
Waste Acids (Sulfate Process)
Not Recycled
Not Recycled
Not Recycled
WWTP Sludges/Solids
Not Recycled
Not Recycled
Not Recycled
Exhibit G-19
Average Facility Storage Costs
Titanium Waste Stream
Average Facility Storage Cost ($)
Minimum
Expected
Maximum
Modified Prior Treatment Baseline
Pickle Liquor and Wash Water
Not Recycled
983
1,873
Scrap Milling Scrubber Water
Not Recycled
1,000
1,000
Smut from Mg Recovery
1,190
63,865
103,167
Leach Liquor and Sponge Wash Water
1,000
1,000
1,000
Spent Surface Impoundment Liquids
Not Recycled
1,828
1,000
Spent Surface Impoundment Solids
Not Recycled
Not Recycled
Not Recycled
Waste Acids (Sulfate Process)
Not Recycled
Not Recycled
Not Recycled
WWTP Sludges/Solids
Not Recycled
Not Recycled
Not Recycled
Option 3 (PT)
Pickle Liquor and Wash Water
Not Recycled
780
1,517
Scrap Milling Scrubber Water
Not Recycled
2,002
2,290
Smut from Mg Recovery
1,067
63,887
96,162
Leach Liquor and Sponge Wash Water
16,740
20,429
24,018
Spent Surface Impoundment Liquids
Not Recycled
1,670
2,190
Spent Surface Impoundment Solids
Not Recycled
Not Recycled
Not Recycled
Waste Acids (Sulfate Process)
Not Recycled
Not Recycled
Not Recycled
WWTP Sludges/Solids
Not Recycled
Not Recycled
Not Recycled
April 15,1997
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G-18
G.4.3 Total Sector Storage Cost
To obtain a total sector storage cost, pre-rule (Modified Prior Treatment baseline) and post-rule
(Option 3) total sector storage costs must be calculated for each waste stream and summed. Total sector
pre- and post-rule storage costs are calculated by multiplying the minimum, expected, and maximum
average facility storage cost for each titanium waste stream (Exhibit G-19) by die number of facilities
generating the waste stream. Using leach liquor and sponge wash water as an example, the Option 3 total
sector storage cost is $42,792 ($21,396 x 2 facilities) in the minimum value case, $52,244 ($26,122 x 2
facilities) in the expected value case, and $60,916 (30,458 x 2 facilities) in the maximum value case.
Exhibit G-20 shows the total sector storage cost for each waste stream and the total sector storage cost for
the entire sector.
Exhibit G-20
Total Sector Storage Costs
Baseline or Option
Number
of
Facilities
Storage Cost
($)
Minimum
Expected
Maximum
Modified Prior Treatment Baseline
-
Pickle Liquor and Wash Water
3
0
2,949
5,619
Scrap Milling Scrubber Water
1
0
1,000
1,000
Smut from Mg Recovery
2
2,380
127,730
206,334
Leach Liquor and Sponge Wash Water
2
2,000
2,000
2,000
Spent Surface Impoundment Liquids
7
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
4380
146,475
221,953
Option 3 (PT)
-
Pickle Liquor and Wash Water
3
0
2,340
4,551
Scrap Milling Scrubber Water
1
0
2,002
2,290
Smut from Mg Recovery
2
2,134
127,774
192,324
Leach Liquor and Sponge Wash Water
2
33,480
40,858
48,036
Spent Surface Impoundment Liquids
7
0
11,690
15,330
Spent Surface Impoundment Solids
7
0
0
0
Waste Acids (Sulfate Process)
2
0
0
0
WWTP Sludges/Solids ,
7
0
0
0
Post-Rule Total Sector
35,614
184,664
262,531
G.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-role scenario is Option 3), 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.13
,J In the minimum value case, there is a saving in storage cost due to a slight decrease in the amount of material
recycled.
April 15,1997
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G-19
G.5. 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 G.3), the total sector incremental storage cost (calculated
in Section G.4), and a recordkeeping cost of $1,411 per facility generating waste in the sector. The
recordkeeping cost of $1,411 per facility translates to a total sector recordkeeping cost of $2,822 ($1,411
x 2 facilities) in the minimum value case, and $9,877 ($1,411 x 7 facilities) in the expected and maximum
value cases. Thus, for the titanium and titanium dioxide sector, the incremental cost of this rulemaking is
equal to $76,374 ($42,318 incremental treatment cost + $31,234 incremental storage cost + $2,822
recordkeeping cost) in the minimum value case, $237,232 ($189,266 incremental treatment cost +
$38,189 incremental storage cost + $9,877 recordkeeping cost) in the expected value case, and $379,847
($329,392 incremental treatment cost + $40,578 incremental storage cost + $9,877 recordkeeping cost) in
the maximum value case.
The total cost incurred by an average facility in this sector is $38,248 in the minimum value
case, $33,943 in the expected value case, and $54,375 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 ($38,248) is larger
than the average facility cost in the expected value case ($33,943). This is due to the fact that there are
only two facilities producing waste 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 15,1997
-------
RISK AND BENEFITS ASSESSMENT FOR THE STORAGE OF
RECYCLED MATERIALS
APPENDIX H
This appendix presents a brief summary of the groundwater (Section H.l) and the multipathway
(Section H.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
19962 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, 19963.
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 with 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 die 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 H.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
1 ICF Incorporated, Regulatory Impact Analysis of the Supplemental Proposed Rules Applying Phase IV Land
Disposal Restrictions to Newly Identified Mineral Processing Wastes, Submitted to the Office of Solid Waste, US
Environmental Protection Agency, December 1995.
2 ICF Incorporated, Regulatory Impact Analysis of the Application of Phase IV Land Disposal Restrictions to
Newly Identified Mineral Processing Wastes, Submitted to the Office of Solid Waste, US Environmental Protection
Agency, August 1996.
3 ICF Incorporated, Revised Results of 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 15, 1997
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H-2
from surface impoundment ranon events and inlet/outlet 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.
H.l risk Assessment Methods and Results for the Groundwater Pathway
This section of Appendix H 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 H.2.
H.l.l Methods and Assumptions
H.l.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 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 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
RIA and in Appendix D of this RIA.
H.l.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 streams
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 H-l. Two of the waste streams (aluminum and alumina cast house dust and zinc waste
ferrosilicon) are nonwastewaters, and the remainder are wastewaters or liquid nonwastewaters.
Although groundwater pathway risks were calculated for only 14 of the 118 total mineral processing
waste 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 generation is used
(minimum, expected, or maximum), the 14 recycled streams included in the risk analysis represent
between 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 summarized in Attachment H.A to this appendix.
April 15,1997
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H-3
H.l.l J 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 for 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 H-l. RECYCLED STREAMS INCLUDED IN THE STORAGE RISK ANALYSIS
Commodity
Recycled Stream
Aluminum and Alumina
Cast House Dust
Beryllium
Chip Treatment Wastewater
Copper
Acid Plant Slowdown
Elemental Phosphorus
AFM Rinsate
Elemental Phosphorus
Furnace Scrubber Slowdown
Rare Earths
Process Wastewater
Selenium
Plant Process Wastewater
Tantalum, Columbium, and
Ferrocolumbium
Process Wastewater
Titanium and Titanium Oxide
Leach 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
Constituent data from 187 waste samples were used to develop DAF values and to evaluate risks from
land storage. Exhibit H-2 presents a breakdown of the samples by facility and types of analysis. It can be
seen that the large majority of the data come from bulk samples, and the majority of the samples are from
facilities whose identities and locations are unknown. Only three of the 185 samples are from
nonwastewater streams managed in waste piles, with the remainder from wastewater and liquid
nonwastewater streams managed in surface impoundments.
April 15,1997
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H-4
EXMBIT H-2. distribution of samples by waste, sample, and facility type
Waste Type
Bulk
EP Extraction
Known
Unknown
Samples
Sample
Facilities
Facilities
Nonwastewater
2
1
0
3
Wastewater
92
25
63
54
Liquid Nonwastewater.
51
16
12
55
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
RfDs were available for 135 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 LNWW
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 bulk analytical result for selenium (100,000 mg/1) 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.
H.l.1.4 Exposure Assessment
Analogous to the procedures used in previous risk assessments, two sets exposure of exposure
estimates were developed. Central tendency (CT) exposure concentrations were estimated by dividing the
release concentrations of each constituent from each waste stream by the 75th percentile DAF value
derived for that constituent. High-end (HE) 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
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 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
the 50th percentile. 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. 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 nonwastewaters/wastewaters, respectively.
The DAF values derived by EPA for use in the mineral processing recycled materials storage risk
assessment are shown in Exhibit H-3.
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
surface impoundments. This is due primarily to the lower leachate volume generated by the waste piles
than by surface impoundments. In the waste piles, leachate generation is limited by rainfall (and a large
April 15,1997
-------
H-5
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 are much lower for
most constituents (in the range of 104 to 106), 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 H-3. DAF VALUES USED IN THE STORAGE RISK ASSESSMENT
Constituent
Waste Pile DAF
Surface Impoundment DAF
75th Percentile
95th Percentile
75th Percentile
95th Percentile
Antimony
>1012
2.0X106
2.7X103
5.3X10'
Arsenic
>10u
1.8X105
1.1X105
3.37X10'
Barium
>1012
1.2X104
I.5X102
2.9
Cadmium
N
o
A
2.4X106
2.1XI03
1,3X10'
Chromium (+6)
>101J
9.9X104
6.3X102
2.4X101
Cyanide
NA*
NA
2.9X109
1.8X103
Lead
•>1012
>1012
>1012
1.2X103
Mercury
>1G12
3.3X106
1.5X103
2.6X101
Nickel
>I012
3.4X10s
1.6X103
1.2X10'
Selenium
>10"
2.4X104
1.9X102
6.2
Silver
>1Q12
2.5X104
4.3X102
4.2
Thallium
NA
NA
3.5X103
9.0X10'
Vanadium
NA
NA
>1012
>1012
Zinc
>1012
5.8X106
6.7X102
3.9
* DAFs were not derived for these constituents because no analytical data were reported for these constituents in any
of the wastes disposed in waste piles.
April 15,1997
-------
H-6
H.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 only 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 are 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)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 EPA's IRIS database, and are current as of December 1996.
H.1.2 Estimation 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 noted 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.
H.l.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 H-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 sector, which is exactly analogous to the
approach taken in the analysis of the risks 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 15,1997
-------
H-7
H. 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 1Q 6 and one with an estimated risk of 10*2, half the facilities in the
commodity sector would be placed in the "<10'5" category, and half would fall into the "103 to 10"2"
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.
H.1J Results of the Groundwater Risk Assessment
H.U.I Risk Assessment Results by Sample
Exhibit H~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 49 of these samples were less than 10 s, the level of
regulatory concern, and the risks for 26 of the samples exceeded this value. Cancer risks exceeded 10 s for
one or more samples from only four waste streams; copper acid plant blowdown, elemental phosphorous
furnace scrubber blowdown, tantalum, columbium, and ferrecolumbium process wastewater, and zinc
spent surface impoundment liquids. The highest risks cancer risks were associated with three samples of
copper acid plant blowdown (10 3 to 10"2). This waste stream accounted for 14 of the 16 samples with the
highest CT cancer risks. The next highest risks (in the 10"4 to 10'3 range) were associated with one sample
each from tantalum process wastewater and zinc spent surface impoundment liquids.
Using the high-end (CT) DAF values, cancer risks calculated for the groundwater pathway exceeded
10"5 for 50 of the 75 samples. Under this set of assumptions, risks for at least one sample exceeded 10 s for
10 of the 14 waste streams evaluated. The highest risks (25 of 30 samples > 10'5, highest risk category
>10-1) were again associated with copper acid plant blowdown, with the next highest risk (10 2 to 10"')
being associated with the single sample of zinc spent surface impoundment liquids. Of the wastes whose
CT cancer risks were below 10"' for all samples, six (elemental phosphorous AFM rinsate, 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 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
April 15,1997
-------
H-8
EXHIBIT H-4
Distribution of Samples by Groundwater Risk Category: Cai
Central Tendency
Number
of Samples
10-5
10-4
10-3
10-2
with
to
to
to
to
Commodity
Waste Stream
Cancer Risk
<10-5
10-4
10-3
10-2
10-1
>10-1
<10-5
Aluminum and Alumina
Cast house dust
2
2
0
0
0
0
0
2
Beryllium
Chip treatment WW
1
1
0
0
0
0
0
1
Copper
Acid plant blowdown
30
9
7
8
3
3
0
5
Elemental Phosphorus
AFM rinsate
2
2
0
0
0
0
0
0
Elemental Phosphorus
Furnace scrubber blowdown
8
7
1
0
0
0
0
3 ,
Rare Earths
PWW
2
2
0
0
0
0
0
0
Selenium
Plant PWW
2
2
0
0
0
0
0
0
Tantalum, Columbium, and
PWW
13
10
2
1
0
0
0
7
Ferrocolumbium.
Titanium and Ti02
Leach liquor & sponge wash water
2
2
0
0
0
0
0
0
Titanium and TiO,
Scrap milling scrubber water
1
1
0
0
0
0
0
0
Zinc
Waste ferrosilicon
0
0
0
0
0
0
0
0
Zinc
Spent s.i. liquids
1
0
0
1
0
0
0
0
Zinc
WWTP liquid effluent
0
0
0
0
0
0
0
0
Zinc
Process wastewater
II
11
0
0
0
0
0
7
Totals
75
49
10
10
3
3
0
25
April 15, 1997
-------
H-9
impoundments. In the case of the NWW waste streams managed in piles, both the CT and HE cancer risks
for all samples were below 10'5. For aluminum/alumina cast house dust, this reflected the much higher CT
and HE DAP 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 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 10"5 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 H-5. Using the CT DAF values, hazard quotient values exceeding 1.0
were calculated for 43 of 135 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 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 100 of the
135 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 for waste piles for all of 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 quotients exceeding 1.0 in either the CT or HE case. Hazard quotient values for five waste streams
which were all below 1.0 in the CT case exceeded 1.0 in the HE case for at least one sample (elemental
phosphorous AFM rinsate, rare earth process wastewater, selenium process wastewater, and titanium/TiO,
leach liquor and sponge wash water and scrap milling scrubber sludge).
H.U.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
H-6.
Overall, cadmium was the most common driving constituent, having the highest hazard quotient for
one-half (50/100) of the samples with hazard quotients above 1.0. Arsenic and zinc (16 samples each)
were the next most common drivers, followed by thallium (8 samples), and chromium (6 samples). None
of the other constituents were noncancer risk drivers for more than one sample. Among the recycled
streams with the highest numbers of samples, arsenic and cadmium were the predominant risk drivers for
copper acid plant blowdown (26 out of 30 samples), cadmium was the dominant driver for elemental
phosphorous furnace scrubber blowdown (8 of 10 samples), and cadmium and zinc were the predominant
risk drivers for the three liquid recycled streams from zinc production.
April 15,1997
-------
H-10
EXHIBIT H-5
Distribution of Samples by Groundwater Hazard Category: Non-Cancer Hazards
Central Tendency
High End
Number of
Samples with
1
10
100
lk
1
10
100
lk
Non-cancer
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 and 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
I
0
Copper
Acid plant blowdown
35
17
10
4
4
0
0
3
7
12
7
4
2
Elemental Phosphorus
AFM rinsate
2
2
0
0
0
0
0
0
0
2
0
0
0
Elemental Phosphorus
Furnace scrubber blowdown
14
13
1
0
0
0
0
4
4
5
1
0
0
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, Columbium,
PWW
21
18
3
0
0
0
0
13
3
0
5
0
0
and Ferrocolumbium
Titanium and TiOa
Leach liquor & sponge
2
2
0
0
0
0
0
0
1
1
0
0
0
wash water
*
Titanium and Ti02
Scrap milling scrubber
1
1
0
0
0
0
0
0
1
0
0
0
0
water
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
134
91
26
10
7
0
0
34
28
28
28
9
7
April 15, 1997
-------
H-ll
EXHIBIT H-6
Constituents Driving Non-Cancer Hazard Quotients in Recycled Streams
Commodity
Waste Stream
Driving Constituent (number of samples)
Aluminum and Alumina
Cast house dust
2 samples total; no hazard quotients greater than 1
Beryllium
Chip treatment WW
Beryllium (1/1)
Copper
Acid plant blowdown
Arsenic (15/35), Cadmium (11), Chromium (1), Lead (1), Selenium (1), Thallium (1), Zinc (2)
Elemental Phosphorus
AFM rinsate
Cadmium <2/2)
Elemental Phosphorus
Furnace scrubber blowdown
Cadmium (8/14), Chromium (1), Thallium (1)
Rare Earths
PWW
Thallium (2/4)
Selenium
Plant PWW
Arsenic ('/*), Thallium (1)
Tantalum, Columbium, and
PWW
Antimony (1/21), Cadmium (3), Chromium (4)
Ferrocoiumbium
Titanium and Ti02
Leach liquor & sponge wash water
Thallium (2/2)
Titanium and Ti02
Scrap milling scrubber water
Thallium (1/1)
Zinc
Waste ferrosilicon
1 sample total; no hazard quotients greater than 1
Zinc
Spent s.i. liquids
Cadmium (12/22), Zinc (6)
Zinc
WWTP liquid effluent
Cadmium (2/3), Zinc (1)
Zinc
Process wastewater
Cadmium (12/24*). Zinc (7)
* A sample wilh a selenium concentration of 100,000 ppm was excluded from the analysis
April 15, 1997
-------
H-12
H. 1.23 Risk Assessment Results by Facility
The cancer risk results for the individual samples, distributed across the numbers of facilities
generating and storing the wastes, are summarized in Exhibit H-7. Using the methods described in Section
H. 1.1.2, it was estimated that CT groundwater pathway cancer risks would exceed 10'5 at 11 of the 57
waste stream-facility facilities4. All of these waste stream-facility combinations were managing either
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 streams, findings of one
or more sample with greater than 10"5 risks did not translate into any facility-waste combinations above 10 s
risks. In the case of elemental phosphorous furnace scrubber blowdown, only one of seven samples had a
cancer risk of just above 10"5. Distributed across two facilities estimated to be storing this waste, this result
(one-seventh of the samples having risks above 10'5) was rounded down to zero. Similarly, in the case of
tantalum, etc., process wastewater, three of thirteen samples with risks above 10'5 was again rounded
downward to zeiu 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 10'5.
When HE DAF values are used, the number of facility-waste stream combinations with cancer risks
above 1Q'5 increases to 24 of 57 facilities. Under HE assumptions, most of the waste streams show one or
more facilities at risk levels above 10 s, the exceptions being the four low-risk waste streams identified in
Exhibit H-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 H-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 of the facility-waste stream
combinations are associated with the management of zinc spent surface impoundment liquids.
Using HE DAF values, 28 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
chip treatment wastewater, tantalum, etc., process wastewater, and zinc spent waste ferrosilicon.
4 Note that the totals in the risk categories do not sum exactly due to rounding. This is true for the following
exhibit as well.
April 15,1997
-------
H-13
EXHIBIT H-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
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 and 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
Copper
Acid plant blowdown
10
10
3
2
3
1
1
0
2
1
2
2
2
2
Elemental Phosphorus
AFM rinsate
2
'2
2
0
0
0
0
0
0
I
1
0
0
0
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, Columbium, and
PWW
2
2
2
0
0
0
0
0
1
I
0
0 .
0
0
Ferrocolumbium
Titanium and TiOj
Leach liquor & sponge wash water
2
2
2
0
0
0
0
0
0
1
1
0
0
0
Titanium and TiO,
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
3
0
0
3
0
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
TOTALS*
57
57
42
3
6
1
1
0
30
8
6
3
5
2
* Sums by risk category may not add to the number of central or high-end waste stream/facility combinations due to rounding,
# Includes waste stream/facility combinations with no cancer risk (but with an associated non-cancer hazard)
April 15, 1997
-------
H-14
EXHIBIT H-8
Distribution of Waste Stream-Facility Combinations by Groundwater Hazard Category:
Non-Cancer Hazards
Number of
Waste Stream/
Central Tendency
Hiiih End
Facility
Combinations*
1
10
too
Ik
1
10
100
lk
Central
High
to
to
to
to
to
to
to
to
Commodity
Waste Stream
Tendency
End
<1
10
100
Ik
10k
>10k
<1
10
100
lk
10k
>10k
Aluminum and 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
2
0
Copper
Acid plant blowdown
10
10
4
3
1
1
0
0
1
2
3
2
1
1
Elemental Phosphorus
AFM rinsate
2
2
2
0
0
0
0
0
0
0
2
0
0
0
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, Columbium, and
PWW
2
2
2
0
0
0
0
0
1
0
0
0
0
0
Perrocolumbium
Titanium and TiOj
Leach liquor & sponge wash water
2
2
2
0
0
0
0
0
0
1
1
0
0
0
Titanium and TiOj
Scrap milling scrubber water
1
1
1
0
0
0
0
0
0
1
0
0
0
0
Zinc
Waste ferrosilicon
1
1
1
0
0
0
0
0
1
0
0
0
0
0
Zinc
Spent s.i. liquids
3
3
2
0
1
1
0
0
0
0
0
1
0
1
Zinc
WWTP liquid effluent
3
3
2
0
0
1
0
0
0
1
1
0
0
1
Zinc
Process wastewater
3
3
2
1
0
0
0
0
1
1
1
1
0
0
TOTALS*
57
57
45
5
4
3
0
0
29
9
9
4
4
2
* Sums by hazard category may not add to the number of central or high-end waste stream-facility combinations due to rounding.
April 15, 1997
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H-15
H.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 10'5 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 for 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 10'5 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 (beryllium 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 HE assumptions, 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 80 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.
H.1.5 Uncertainties/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 15,1997
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H-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 hydrogeological 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.
H.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 prior treatment baseline.
H.2.1 Methods and Assumptions
H.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 proposal risk-based exit levels for die Hazardous
Waste Identification Rule (HWTR-Waste). The HWIR-Waste Technical Support Document5 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 algorithms and
equations from'HWIR-Waste are 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 soil depletion
algorithms related to leaching and runoff. Thus, all soil contaminants were assumed to be fully conserved
5 USEPA, Technical Support Document for the Hazardous Waste Identification Rule: Risk Assessment for Human
and Ecological Receptors, Office of Solid Waste, August 1995.
April 15, 1997
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H-17
for the entire exposure period. Finally, particulate release and transport models were used which differed
slightly from those used in HWIR-Waste, and generic climatic assumptions were used in the evaluation of
air transport. These methods are described in detail in Attachment H-B.
The same general assumptions regarding receptors and receptor behavior were employed in this
analysis as were used in HWIR-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 die release models come from the database of waste constituent concentrations
developed in support of the RIA (see Section H.l.1.3). In this case, however, only those streams are
included which EPA 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 are 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 HE 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 aid exposure
pathways. Risks are not summed across exposure pathways, unless it clear that exposure through one
pathway would reasonably be 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
H.2.2, no individual events were found that release substantial portions of the annual recycled volumes
from any of the management units.
H2.12 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 be 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
April 15,1997
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H-18
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' 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.
H.2.1.3 Identification of Recycled Waste Streams
The same 14 waste streams were evaluated as in the groundwater pathway assessment. As noted
previously, the 14 streams which are evaluated account for between approximately 32 and 42 percent of
the total waste generated, and for between about 57 and 68 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
H.A to this appendix.
H.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 H. 1. 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 HWIR-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 H.B.
H.2.1.5 Facility Characterization Data
As noted above, facility size and configuration were determined for each recycled waste stream as part
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 impoundments. The management units
were assumed to 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 in 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 15,1997
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H-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/vear 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 H-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/Ti02 scrap milling scrubber water) to extremely large (99,167 cubic meters for zinc
process wastewater).
H.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 from the HWIR-Waste Technical Background Document The results of the screening
are summarized in Exhibit H-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 runon events during large storms. Groundwater releases from these units have been addressed
previously and are not further evaluated here.
H.2.1.7 Transport and Exposure Pathways
After releases from the land storage units, waste constituents may be 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 HWIR-
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 H-l 1 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.
April 15,1997
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H-20
EXHIBIT H-9. FACILITY SIZES FOR THE RECYCLED WASTE STREAMS
Commodity
Recycled Stream
Facility
Type1
Facility
Volume
(m3)
Facility
Area
Cm1)
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
Elemental Phosphorous
AFM Rinsate
SI
167
415
Elemental Phosphorous
Furnace Scrubber Blowdown
SI
17,500
8,429
Rare Earths
Process Wastewater
SI
117
385
Selenium
Plant Process Wastewater
SI
550
631
Tantalum, Columbium, and
Ferrocolumbium
Process Wastewater
SI
4,375
2,517
Titanium and Titanium Oxide
Leach Liquor and Sponge Wastewater
SI
4,000
2,341
Titanium and Titanium Oxide
Scrap Milling Scrubber Water
SI
42
340
Zinc
Waste Ferrosilicon
WP
1,093
509
Zinc
Spent Surface Impoundment Liquids
SI
10,500
5,319
Zinc
Waste Water Treatment Plant Liquid
Effluent
SI
7,250
3,850
Zinc
Process Wastewater
SI
99,167
43,384
Notes: I. SI = Surface Impoundment, WP = Waste Pile
EXHIBIT H-10. RELEASE EVENTS RETAINED IN THE MINERAL PROCESSING
SCREENING RISK ASSESSMENT
Management Unit
Release Events
Waste Pile
Particulate Generation by Wind
Particulate Generation by Materials Handling
Surface Runoff due to Rain Events
Surface Impoundments
Releases Due to Inlet/Outlet Failures
Releases Due to Runon Events
April 15,1997
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H-21
EXHIBIT H-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)
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-steady-state
conditions (concentration
in crops, vegetable
intake, risk)
Air
Soil/Water
Surface
Water/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)
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
Bounding analysis; 100
percent deposition to
surface water; HWIR-
Waste
Surface
impoundment
Control/
Betm
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)
April 15,1997
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H-22
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.
H.2.1.8 Release, Transport, and Exposure Modeling
H.2.I.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 hot 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 ISCST3 for use in screening level analyses. High-End
(HE) 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 248 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 H-B.
As was the case for the meteorological data, very 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 wastes6 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 H-l 1,
along with the other parameter values used to estimate exposure concentrations in soil resulting from
particulate deposition.
Accumulation of particulate materials in soils was assumed to occur for the entire 20-year lifespan of
the waste piles. Exposure to the contaminated soil was assumed to 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 die mixed layer. Consistent with HWIR-Waste, shallow mixing depths (I 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
6 USEPA, Risk Screening Analysis of Mining Wastes, Appendix F: Development of Particulate Emission
Factors, (Draft), Office of Solid Waste, October 25,1987.
April 15, 1997
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H-23
for the root vegetable consumption pathway. All other parameter values were the same as those to
calculate soil concentration in the HWIR-Waste assessment.
H.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
are summarized in Exhibit H-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 soils onto a watershed, followed by
overland transport to surface water bodies. Given the lack of knowledge about the locations of the storage
piles relative to watersheds and surface water bodies, the relatively small size of the piles, and the
relatively small mass of particulate that is generated, we have employed a much simpler screening
approach to estimate the maximum long-term surface water concentrations that could result from the
deposition of airborne particulates.
The methods simply assumes that, ultimately, all of the particulate emitted from the storage piles will
end up in surface water. This is equivalent to making the conservative assumption that all of the
particulates will either be directly deposited onto a surface water body, or that for that fraction of
particulates that are initially deposited to soil, the sediment delivery ratio for the watershed will be equal to
1.0.
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 be 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 particulate generation rate (in kg) from the waste pile, and DV is the surface water
annual dilution volume as defined in Exhibit H-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.
April 15,1997
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H-24
EXHIBIT H-12. PARAMETER VALUES USED IN PARTICULATE PATHWAY EMISSIONS
AND TRANSPORT MODELING
Variable
Description
CT
Value
HE Value
Units
Source
SC
Silt Content
(both streams)
1.6
9.1
percent
Footnote 5
Paniculate Size
Distribution
66
49
32
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<^)
Acha
Area of Waste
Pile (Cast House
Dust)
108
108
m *
Waste data base,
cost/economic impact
methodology
Afesi
Area of Waste
Pile
(Ferrosilicon)
509
509
m2
Waste data base,
cost/economic impact
methodology
Z
Soil Mixing
Depth (Dermal
and Ingestion
Exposures)
2.5
1
cm
Typical values for
untitled soils
Z
Soil Mixing
Depth (Root
Vegetable
Ingestion)
20
10
cm
Typical tillage depths
BD
Soil Bulk
Density
1.5
1.2
gm/cm3
Typical for U.S. soils
ks
Soil Loss
Constant
0
0
years'1
Assumes no soil
depletion of deposited
materials
t
Deposition
Period
20
20
years
Assumes unit lifespan
of 20 years
DV
Surface Water
Dilution Volume
3.0X108
1.3X107
m3/year
Third- and Fifth-
Order Stream Flow,
respectively, HWIR-
Waste Equation 7-69
April 15,1997
-------
H-25
H.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
releases, 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 H-13. In calculating
runoff releases, in the absence of data related to the specific wastes and pile configurations being
evaluated, we used the same values for soil erodability (k) and length-slope factors (LS) as were used for
Subtitle D waste piles in HWTR-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 USLE 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.
x A very simple sediment delivery 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 no 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 ncg/m2-veart * Achd for Afesi¥m2 )* Cwaste tog/kg)* t (years) (2)
BD (gm cm3) * Z (cm) * X * r2 (cm2)* 0.001 kg/gm
where the variable definitions and values are given in Exhibit H-13.
April 15,1997
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H-26
EXHIBIT H-13
PARAMETER VALUES USED IN RUNOFF RELEASE AND TRANSPORT
MODELING FROM WASTE PILES
Variable
Description
CT Value
HE Value
Units
Source
Xe
Runoff loss from
waste pile
calculated
calculated
kg/m2-
year
HWIR-Waste equation 7-52
Achd
Area of Waste Pile
(Cast House Dust)
108
108
m2
Waste data base,
cost/economic impact
methodology
Afesi
Area of Waste Pile
(Ferrosilicon)
509
509
m2
Waste data base,
cost/economic impact
methodology
R
USLE Rainfall
Factor
50
110
years"1
CT= Typical of western US
HE = US Median value
LS
Length-Slope Factor
1
3
HWIR-Waste value for
Subtitle D ash piles
K
Soil Erodability
Factor
0.25
0.25
unitless
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
I
1
unitless
Assumes no measures to
control runoff
r
Radius of area
contaminated by
runoff
5,000
10,000
cm
Contamination is assumed
to be distributed uniformly
in a circular area around the
conical piles
DV
Surface Water
Dilution Volume
3.0X108
1.3X107
mVye31"
Third- and Fifth-Order
Stream How, respectively,
HWIR-Waste Equation 7-
69
April 15,1997
-------
H-27
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 runoff
contamination. It is intended only as a conservative screening tool to provide indications 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.
H.2.1.8.4 Runoff To Surface Water
The deposition 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-borne constituents in
surface water during the operation of the storage piles is:
Csw (mg/1) = Xe fkg/m2-vear) * Achd (or Afesi¥m2 )* Cwaste frog/kg) (3)
DV (m3/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 H-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
H.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 water 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 and HE streams, without partitioning to sediment. The major variables used to estimate surface
water concentrations of constituents from impoundment failure are summarized in Exhibit H-14.
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.7 It is likely
7 DPRA, Surface Water Control Bermsfor Pulp and Paper Mill Sludge Landfills and Surface
Impoundments, Memo to Priscilla Halloran, OSW, July 18 1991.
April 15, 1997
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H-28
EXHIBIT H-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
m3/year
HWIR-Waste, equation 7-
70
Prunon
Probability of
runon event
2X10"
2X10"
years'5
DPRA, 1991 (see text)
Tflood
Duration of
Flooding
21,600
21,600
seconds
DPRA, 1991
Vrunon
Runon velocity
0.5
0.5
m/sec
DPRA, 1991
-h
Difference in height
between flood and
berm
0.0127
0.0127
m
DPRA, 1991
A
Area of surface
impoundment
Waste-
specific
Waste-
specific
m2
Mineral Processing data
base, cost/economic
analysis
Pio
Probability of
inlet/outlet control
event
0.0107
0.0107
years"1
DPRA, 1991
h
Berm height
0.457
0.457
m
DPRA, 1991
that the designs, sizes and operating parameters for impoundments in the mineral processing industry are
substantially different, and the expected releases could also he 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, lowering the concentration of released materials.
H.2.1.9 Exposure and Risk Characterization
H.2.1.9.1 Toxicological 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 are current as of December 1996. These
values are summarized in Exhibit H-15.
April 15,1997
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H-29
EXHIBIT H-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
(ug/nr5)'1
Chronic Ingestion
Pathway Reference
Dose
(mg/kg-day)
Chronic Inhalation
Pathway Reference
Concentration
(me/m3)
Antimony
t
4X10"4
Arsenic
1.5
4.3x10"3
Barium
7X10-2
5X10"1
Beryllium
4.3 1
2.4X10°
5X1Q"3
Cadmium
1.8X10"3
5X10"4
Chromium (VD
1.2X1G"2
5X10'3
Lead
0.015 mg/L2
Mercury
3XW4
3X10-4
Nickel
4.8X10"4
2X10'2
Selenium
5X10'3
Silver
5X10-3
Thallium
8X10-5
Vanadium
7X10-3
Zinc
3X10-1
Notes:
1, Not used in risk assessment because of low weight of evidence
2. Based on the Safe Drinking Water Act MCL for inorganic lead.
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
for these pathways.
April 15,1997
-------
H-30
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.
H.2.1.9.2 Inhalation
Risks associated with inhalation pathway exposure to particulates released from waste piles are
calculated directly from the estimated particulate concentrations in air generated by the ISCST3 model.
Lifetime cancer risks associated with exposure to airborne particulates are calculated as:
Risk = (ug/m3) * Cwa$U! (mg/kg) * 10-6 kg/mg * UR (ug/m3)"1 (4)
where is the particulate concentration from the ISCST model, Cwaae 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 = (ug/m3) * Cwane (mg/kg) * 10 6 kg/mg * IP'3 mg/ug (5)
RfC (mg/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 m of the facility (CT
estimate). For screening purposes, exposure is assumed to be continuous for 365 days per year, and for
carcinogenic constituents, the exposure duration is assumed to be the 20-year operating lifespan of the
facility. As will be seen in Section H.2.1, in both the CT and HE cases, cancer risks were all below 10"5
and inhalation hazard quotients were all below 1.0 under these very conservative screening assumptions, so
more refined modeling scenarios were not developed for this pathway.
H.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 H.2.1.9.3) and by deposition of surface runoff
(Section H.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 deraial and ingestion pathways, the shallower soil mixing depths (1.0 and
2.5 cm) were used to estimate soil concentrations of constituents consistent with the assumption of no
tillage or soil disturbance.
Risks associated with soil ingestion were calculated using Equation 5-6 from die 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 and risks from soil
ingestion are summarized in Exhibit H-16.
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).
April 15,1997
-------
H-31
EXHIBIT H-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 full life span
EF
Exposure
frequency
- 350
350
days/year
Worst-case assumption of
year-round residency
IRc
Soil ingestion rate
(child)
200
200
mg/day
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 Equation 5-6
BWa
Body weight
(adult)
70
70
kg
HWIR-Waste Equation 5-6
EDc
Exposure duration
(child)
6
6
years
HWIR-Waste Equation 5-6
EDa
Exposure duration
(adult)
3
24
years
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
density
2.65
2.65
gm/cc
HWIR-Waste Equation 5-14
AF
Adherence factor
0.2
1.0
gm/cm2
HWIR-Waste Equation 5-23
Tevent
Event Duration
5
12
hours
HWIR-Waste Equation 5-23
Risks from dermal exposures 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 nmoff or air particulate deposition. As was the case 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 H-16. All of the values for body weights, exposure duration, and exposure
frequency are the same as those used for the ingestion pathway.
April 15,1997
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H-32
H.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 farmer on soils contaminated
either by 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 factor values used to estimate intake and risks for this pathway are summarized in Exhibit H-
17. These values are essentially the same as those used on HWIR-Waste, the primary exception being the
use of an HE exposure duration of 20 years, corresponding to the assumed life of the storage units, rather
than the 40-year value used in HWIR-Waste.
H.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 are calculated as follows:
Risk = C...m fmg/n * WI (1/dav'i * EF fdavs/vear) * ED (years) * CSF fmg/kg-davV1 (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 fmg/n * WI (1/dav) * EF fdavs/vear) (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 10"5
or hazard quotients 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 HE assumptions, so that more detailed analysis
could be confined only to those wastes posing significant risks.
April 15,1997
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H-33
EXHIBIT H-17. EXPOSURE FACTOR VALUES USED FOR CROP INGESTION PATHWAY
Variable
Description
CT Value
HE Value
Units
Source
t
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
constituent-
specific
constituent-
specific
mg/kg (veg.)
mg/kg (soil)
HWIR-Waste data base
Vg
Surface
correction factor
for voiatiles
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
0.05
0.05
unitless
HWIR-Waste Equation 6-48
kp
Plant surface loss
coefficient
18
18
years'1
HWIR-Waste Equation 6-48
tp
Plant exposure to
deposition
0.16
0.16
years
HWIR-Waste Equation 6-48
Yp
Crop yield
1.7
1.7
kg/m2 (DW)
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
Fanner
Cra
Consumption of
above-ground
vegetables
19.7
19.7
gm/day
HWIR-Waste Subsistence
Fanner
Crr
Consumption of
root vegetables
28
28
gm/day
HWIR-Waste Subsistence
Fanner
EF
Exposure
Frequency
350
350
days/year
HWIR-Waste Subsistence
Fanner
ED
Exposure
duration
9
20
years
HWIR-Waste (CD, =
deposition period (HE)
AT
Averaging time
70
70
years
full life span
H.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
April 15,1997
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H-34
various release pathways. The concentrations of toxic constituents in fish tissue were calculated as
follows:
Cfi5h (mg/kg) = Cw3Bf (mg/1) * max (BCF, BAF) (1/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 HWTR-
Waste, but the values from that source were supplemented by values from other literature sources, as
summarized in Attachment H-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 (CT) or 130 gms (HE) of fish per day for 350 days per year, using a target cancer risk level of 105
and a target hazard quotient value of 1.0. These HBLs were then used to screen the surface water
concentrations resulting from air deposition, runoff, and surface impoundment failures.
H.22 Results of Multipathway 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.
H.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 thai 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 die storage units by the different release events.
The masses of recycled materials released from the various storage units are summarized in Exhibit H-
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.
April 15,1997
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H-35
fYTITDTTU Ifi
x-^^JTzUdI X *1-15
MASSES AND PROPORTIONS OF RECYCLED STREAMS RELEASED BY SPECIFIC
RELEASE EVENTS
Commodity
Recycled Stream
Management
Unit
Annual
Recycled
Volume
(kg/year)
Release Event
HI 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
C.CS%
Copper.
Acid Plant
Slowdown
Surface
Impoundment
265,000,000
Runon, Inlet/Outlet
Control Failure
28,330
0.01%
Elemental
Phosphorous
AFM Rinsate
Surface
Impoundment
2,000,000
Runon, Inlet/Outlet
Control Failure
1,573
0.08%
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/Oudet
Control Failure
1,480
0.21%
Selenium
Plant Process
Wastewater
Surface
Impoundment
3,300,000
Runon, Inlet/Oudet
Control Failure
2,232
0.07%
Tantalum,
Columbium,
Ferrocolumbium
Process Wastewater
Surface
Impoundment
37,500,000
Runon, Inlet/Oudet
Control Failure
7,530
0.02%
Titanium, Ti02
Leach Liquor,
Sponge Wash Water
Surface
Impoundment
24,000,000
Runon, Inlet/Outlet
Control Failure
7,050
0.03%
Titanium, TiOj
Scrap Milling
Scrubber Water
Surface
Impoundment
5,00,000
Runon, Inlet/Outlet
Control Failure
1,337
0.27%
Zinc
Spent 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
43,500,000
Runon, Inlet/Oudet
Control Failure
11,115
0.03%
Zinc
Process Wastewater
Surface
Impoundment
850,000,000
Runon, Inlet/Oudet
Control Failure
111,784
0.01%
April 15,1997
-------
H-36
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 are 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 that, 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.
H.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 H-19. 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 ferrosilicon (lead and zinc), no inhalation pathway risks could be calculated for
that waste.
Exhibit H-19
Estimated Inhalation Pathway Risks for
Aluminum Cast House Dust
Constituent
CT Constituent
Concentration
in Air (ue/m3)
HE Constituent
Concentration
in Air (ug/m3)
CANCER RISK HAZARD
QUOTIENT
CT
HE
CT
HE
Antimony
1.73E-05
2.42E-04
Arsenic
7.36E-05
1.03E-03
3.90E-13
1.22E-11
Barium
2.30E-05
3.23E-04
1.92E-01
1.92E-01
Cadmium
1.66E-05
2.33E-04
3.67E-14
1.15E-12
ChromiumCVD
2.53E-04
3.55E-03
3.74E-12
1.I7E-10
Lead
3.91E-05
5.49E-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
4.37E-06
6.14E-05
Zinc
2.76E-04
3.88E-03
April 15,1997
-------
H-37
In the case of aluminum cast house dust, die 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 1012 to 10"'°, far below the 10'5 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 hexavalent is very conservative, and risks for chromium exposures are likely to substantially
overestimated for 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 HE hazard quotient value (for
barium) is 0.2, while for mercury the HE hazard quotient is less than 10"5. 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.
H.2.2J 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.
H.2.2.3.1 Incidental Ingestion and Dermal Contact Pathways
Risk results for the incidental ingestion and dermal contact pathways for soils contaminated by
particulate deposition are summarized in Exhibit H-20. As was the case for the inhalation pathway,
estimated cancer risks and hazard quotients for all of die 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 with soil ingestion exposures to arsenic in aluminum cast house
dust is 7X10"7, while the CT value is 4X10"8. In comparison, the HE and CT cancer risk estimates for
dermal exposures are 1X10*6 and 1X10"8, respectively. The highest HE hazard quotient for ingestion
exposures (again associated with exposures to arsenic) is 1X1Q"2, while the highest HE hazard quotient for
dermal exposures is 4X10"2 (for arsenic). Hazard quotients for the remaining constituents range downward
by many orders of magnitude from these values.
Zinc is the only constituent in zinc waste ferrosilicon for 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 1Q"4 to 10'2, 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.
April 15,1997
-------
H-38
Exhibit H-20
Soil Ingestion and Dermal Contact Pathway Risk Assessment Results for Particulate Deposition
Constituent
CT Soil
Concentration at
20 Years (me/kg)
HE Soil
Concentration at
20 Years (me/ke)
Ingestion
Dermal Contact
CANCER RISK
HAZARD QUOTIENT
CANCER RISK
HAZARD QUOTIEN T
CT
HE
CT
ilE
CT
HE
CT
HE
Aluminum Cast House Dust
7.12E-02
1.75E-04
2.37E-03
2.98E-04
2.01E-02
Antimony
5.26E-03
Arsenic
2.24E-02
3.04E-01
3.88E-08
7.I3E-07
9.97E-04
1.35E-02
I.34E-08
1.44E-06
9.79E-04
3.89E-02
Barium
7,01 E-03
9.49E-Q2
1.33E-06
1.81E-05
1.05E-07
3.44E-06
Cadmium
5.05E-03
6.83E-02
1.35E-04
I.82E-03
3.31E-05
1.12E-03
Chromium(VI)
7.71E-02
1.Q4E+00
2.06E-04
278E-03
2.62E-04
1.15E-02
Lead
1.19E-02
1.61E-01
Mercury
7.01E-08
9.49E-07
3.11E-09
4.22E-08
1.39E-12
4.53E-11
Nickel
1.82E-01
2.47E+0Q
1.21E-04
1.64E-03
5.43E-05
1.90E-03
Selenium
6.45E-04
8.73E-03
1.72E-06
2.33E-05
2.91E-06
1.86E-04
Silver
1.33E-03
1.80E-02
3.55E-06
4.81E-05
6.04E-06
4.09E-04
Zinc
8.41B-02
I.I4E+00
3.74E-06
5.06E-05
2.95E-06
1.12E-04
Zinc Waste
3.50E+00
4.75E+01
Ferrosilicon
Lead
Zinc
2.80E+01
3.80E+02
1.25E-03
1.69E-02
9.84E-04
3.72E-02
April 15, 1997
-------
H-39
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 10'5 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.
H.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
H-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 3X10'8.
The highest HE noncancer hazard quotient for this pathway is 6X10'3, again associated with arsenic
exposures, and die CT value for arsenic is one order of magnitude lower (5X10"4). Hazard quotient values
for the other constituents through the ingestion of home-grown crops are all much lower than the
corresponding values for arsenic.
H.2.2.3.5 Particulate Deposition to Surface Water
Because the releases to air are so small and the surface water dilution volumes are 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 H.2.1 were used
to calculate concentrations in surface water that corresponded to calculated cancer risk levels of IX10'5 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 H-22.
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 10'5 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 fenosilicon, 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
conservativeness of the exposure assumptions (e.g., 100 percent of the particulate is deposited in surface
water).
April 15, 1997
-------
H-4G
Exhibit H-21
Home-Grown Crop Ingestion Pathway Risk Assessment Results for Particulate Deposition
Constituent
CT Soil
Concentration at
20 Years
(me/kg)
HE Soil
Concentration at
20 Years
(nig/kg)
CT Concentration
in Above-Ground
Vegetables (nig/kg)
IIE Concentration
in Above-Ground
Vegetables (mg/kg)
CT
Concentration in
Root Vegetables
(me/kg)
HE
Concentration in
Root Vegetables
(mg/kg)
CANCER RISK
HAZARD
QUOTIENT
CT
HE
CT
HE
Aluminum Cast House Dust
7.12E-03
4J5E-Q4
2.74E-03
9.86E-Q6
1.07E-04
1.26E-04
I.83E-03
Antimony
6.57E-04
Arsenic
2.80E-03
3.04E-02
I.40E-03
6.71E-03
7.73E-07
8.38E-06
2.9IE-08
7.00E-07
5.25E-04
5.67E-03
Barium
8.76E-Q4
9.49E-03
5.36E-Q4
3.18E-03
2.48E-08
2.69E-07
8.63E-07
1.I5E-05
Cadmium
6.31E-04
6.83E-03
5.19E-04
3.72E-03
2.52E-07
2.73E-06
1.I7E-04
1.89E-03
Chromium(Vl)
9.64B-03
1.04E-01
4.53E-03
2.01E-02
2.41E-06
2.61E-05
I.02E-04
1.G2E-03
Lead
I.49E-03
I.6IE-02
6.89E-04
2.98E-03
4.79E-11
5.19E-10
Mercury
8.76E-09
9.49E-08
4.12E-09
1.83E-08
1.29E-15
I.40E-14
1.55E-09
I.55E-08
Nickel
2.28E-02
2.47E-01
1.13E-02
5.35E-02
2.22E-06
2.4IE-05
6.34E-05
6.78E-04
Selenium
8.06E-05
8.73E-04
3.86E-05
I.75E-04
4.12E-07
4.47E-06
8.81E-07
9.21E-06
Silver
1.66E-04
I.80E-03
1.44E-04
1.05E-03
416E-05
4.5IE-04
4.56E-06
8.59E-05
Zinc
1.05E-02
1.14E-01
7.49E-03
4.95E-02
I.16E-05
1.25E-04
2.82E-06
4.20E-05
Zinc Waste
4.38E-01
4.75E+Q0
2.03E-0I
8.78E-01
1.41E-08
1.53E-07
Ferrosilkon
Lead
Zinc
3.50E+00
3.80E+0I
2.50E+0Q
1.65E+0I
3.85E-03
4.I8E-02
9.39E-04
I.40E-02
April 15, 1997
-------
H-41
EXHIBIT H-22
Screenin
e Results for Particulate Deposition to Surface Water
Constituent
Concentrations Resulting from Releases of
Aluminum Cast House Dust
Concentrations Resulting from Releases of Zinc
Waste ferrosilicon
Surface Water HBL Concentrations (mg/L)1
Maximum
Concentration in
Waste (mg/kg)
CT Water
Concentration
(mg/L)
HE Water
Concentration
(mg/L)
Maximum
Concentration
in Waste
(mg/kg)
CT Water
Concentration
(mg/L)
HE Water
Concentration
(mg/L)
Fish-
Noncancer
Fish-
Cancer
Drinking
Water -
Noncancer
Drinking
Water -
Cancer
Antimony
7.5
8.10E-09
8.77E-07
1.40E-02
Arsenic
32
3.46E-08
3.74E-06
7.40E-04
8.40E-04
Barium
10
I.08E-08
I.17E-06
3.77E-01
2.45E+00
Beryllium
2.84E-02
1.75E-0I
Cadmium
7.2
7.78E-09
8.42E-07
7.35E-05
3.50E-02
Chromium(Vl)
no
1.I9E-07
1.29E-05
9.00E-01
1.75E-0I
Lead
17
I.84E-08
I.99E-06
5000
5.40E-06
5.85E-04
1.50E-02
Mercury
0.0001
1.08E-13
1.17E-11
I.05E-02
Nickel
260
2.81E-07
3.04E-05
1.02E-0I
7.00E-01
Selenium
0.92
9.94E-10
1.08E-07
8.40E-03
1.75E-01
Silver
1.9
2.05E-09
2.22E-07
1.80E-02
I75E-01
'
Thallium
3.02E-05
2.80E-03
Vanadium
2.45E-0I
Zinc
120
- 1.30E-07
1.40E-05
40000
4.32E-05
4.68E-03
3.12E-0I
1.05E+01
1 HBLs correspond !o an eslimaled lower risk of 10 s, a noncancer hazard quolient of 1.0; or for lead, the MCL,
April 15, 1997
-------
H-42
H.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 H.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 H-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 thkt would be associated with an HE cancer risk of
10 s. 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 ferrosilicon, 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.
H.2.2.5 Risk Results for Runoff 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.
The results of that analysis are summarized in Exhibit H-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.
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 1G"6 to 10"s 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 15,1997
-------
H-43
EXHIBIT H-23
COMPARISON OF SOIL CONCENTRATIONS FROM RUNOFF RELEASES TO HEALTH-BASED LEVELS
Constituent
Soil
Ingestion
Health*
Based
Level
(mg/kg)
Soil Dermal
Contact
Health-
Based Level
(mg/kg)
Home-Grown
Vegetable
Consumption
Health-Based
Level (mg/kg)
Aluminum Cast House Dust
Zinc Waste Ferrosilicun
CT Soil
Concentration
(Ingestion and
Dermal)
(mg/kg)
HE Soil
Concentration
(Ingestion and
Dermal Contact)
(mg/kg)
CTSoil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
HE Soil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
CTSoil
Concentration
(Ingestion and
Dermal)
(mg/kg)
HE Soil
Concentration
(Ingestion and
Dermal Contact)
(mg/kg)
CTSoil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
HE Soil
Concentration
(Ingestion of
Home-Grown
Vegetables)
(mg/kg)
Antimony
30
3.54
74.1
I.92E-03
1.58E-01
2.39E-04
I.58E-02
Arsenic
4.26
2.11
24.5
8.I7E-03
6.74E-0I
I.02E-03
6.74E-02
Barium
525
27,600
>1,000,000
2.55E-03
2.IIE-01
3.19E-04
2.11E-02
Beryllium
NA
NA
NA
Cadmium
37.5
61.1
3470
I.84E-03
I.52E-0I
2.30E-04
I.52E-02
Chfomium
375
90.7
55600
2.81E-02
2.32E+00
3.5IE-03
2.32E-0I
Cyanide
NA
NA
NA
Lead
NA
NA
NA
4.34E-03
3.58E-0I
5.43E-04
3.58E-02
6.02E+00
4.97E+02
7.52E-01
4.97E+01
Mercury
22.5
21,000
>1,000,000
2.55E-08
2.1 IE-06
3.I9E-09
2.1-1 B-07
Nickel
1,500
1,300
569,000
6.64E-02
5.48E+00
8.30E-03
5.48E-0I
Selenium
375
47
2,710
2.35E-04
I.94E-02
2.94E-05
I.94E-03
Silver
375
44.1
55.6
4.85E-04
4.Q0E-02
6.07E-05
4.00E-03
Thallium
NA
NA
NA
Vanadium
NA
NA
NA
Zinc
22,500
10,200
758.000
3.07E-02
2.53E+QO
3.83E-03
2.53E-OI
4.82E+0I
3.97E+03
6.02E+00
3.97E+02
April 15, 1997
-------
H-44
EXHIBIT H-24
COMPARISON OF SURFACE WATER CONCENTRATIONS DUE TO SOIL RUNOFF RELEASES TO
Hi? at tu racirn r rirci c
ntAL 1 n«DAoLU LE¥tL3
Constituent
Drinking
Water
Health-
Based Level
(mg/1)1
Fish Ingestion
Health-Based
Level (mg/1)
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-03
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
Cyanide
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
1.0GE-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
0.0000302
Vanadium
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 10 s, a noncancer hazard quotient of 1.0, or, for lead, the MCL value.
~
H3.2.6 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.
H.2.2.6.1 Ingestion of Surface Water
Exhibit H-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
April 15,1997
-------
H-45
EXHIBIT H-25
COMPARISON OF SURFACE WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO IIEALTH-BASED LEVELS
DRINKING WATER
Maximum High-End
Surface Water
Concentration, Bulk
Samples
Maximum High-End
Surface Water
Concentration, EP Samples3
Central Tendency
Surface Water
Concentration, Bulk
Samples
Central
Tendency
Surface Water
Concentration,
EP Samples2
Compared to HBL'
Compared to HBL
Compared to HBL
Compared to
HBL
Constituent
Commodity
Wastestream
Total No.
Samples
1-I0x
10-100x
1-IOx
10-lOOx
lOO-IOOOx
1-IOx
10-lOOx
l-10x
10-
lOOx
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
NOTES:
1. HBLs correspond to a lower risk of 10"', a noncancer hazard quotient of 1.0, or, for lead, the MCL value.
2. EP samples are adjusted (i.e., have been multiplied by 1.95) to extrapolate to bulk concentrations.
April 15, 1997
-------
H-46
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 10"5 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 of ten 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.
H.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 H-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.
April 15,1997
-------
H-47
EXHIBIT H-26
COMPARISON OF SURFACE WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO HEALTH-BASED LEVELS
FISH INGESTION .
Maximum High-End Surface
Water Concentration, Bulk
Samples
Central Tendency
Surface Water
Concentration,
Bulk Samples
Maximum High-End Surface
Water Concentration,
EP Samples1
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
1-10X
10-lOOx
lOO-lOOOx
1-lQx
10-lOOx
I-lOx
10-lOOx
lOO-lOOOx
1-lGx
10-lOOx
Arsenic
Copper
Acid plant blowdown
40
2
, 2
I
1
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
6
3
1
1
1
Zinc
WWTP liquid effluent
5
1
1
Mercury
Copper
Acid plant blowdown
40
2
I
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
Copper
Acid plant blowdown
40
I
Zinc
Zinc
Spent surface
impoundment liquids
24
5
Zinc
WWTP liauid effluent
5
1
NOTES:
1, HBL = health-based level derived for fish ingestion based on worst-cast subsistence fisher,
2. EP samples are adjusted (i.e., have been multiplied by 1.95) to extrapolate to bulk
concentrations.
April 15, 1997
-------
H-48
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.
H.2.2.7 Summary of Non-Groundwater 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.
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 die 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
April 15,1997
-------
H-49
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 titanium/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.
H.2.2.8 Uncertainties/Limitations of the Analysis
As discussed in Section H.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.
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 die 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 die 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
April 15,1997
-------
H-50
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 die 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.
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, rafter 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 die highest risks for several of the
constituents.
April 15,1997
-------
ATTACHMENT H.A
Proportion of Mineral Processing Wastes Covered by the Storage Risk
Assessment
-------
ATTACHMENT H.A-1
PROPORTION OF RECYCIED MWERAL PROCESSING WASTE STREAMS ADDRESSED
N THE RISK ASSESSMENT FOR RECYCLED MATERIALS STORAGE
Cofnmodtty
Waste Stream
Total Recycled Volume
Recycled
Volume
Analyzed In Risk
Assessment
Percent Analyzed In Risk Assessment
Mn.
Ave.
Max.
Exp AH n.
EipectJAve.
AJuminum.
Alumina
Cast House Dust
16.22?
16,227
16.227
16.227
100.00%
100.00%
100.00%
Electrolysis Waste
24.438
48.875
Sector
16.227
40.665
65.102
16.227
100.00%
39.90%
24.93%
Boryliium
Chip Treatment Wastewater
10.000
400.000
10.000
100.00%
2,50%
Sector
10.000
400.000
10.000
100.00%
2.50%
Copper
Acid Plant Slowdown
3.975,000
3.975,000
3,975.000
3.975,000
100.00%
100.00%
100.00%
WWTP SMoe
2.250
4.500
Sector
3.975.000
3.977.250
3.975.000
100.00%
99.94%
99.89%
Elemental
Phosphorus
AFM Rinsate
4,000
4.000
4,000
4,000
100.00%
100.00%
100.00%
Furnace Scrubber Slowdown
420.000
420.000
420.000
420.000
100.00%
100.00%
100.00%
Furnace Building Washdown
700.000
700.000
700.000
Sector
1J24.O0O
1.124.000
1.124.000
37.72%
37.72%
37.72%
Rare Earths
Electrol. Cell Caustic Wet APC
Slud.
3SO
7,000
Process Wastewater
1.400
1.400
1,400
1,400
100.00%
100.00%
100.00%
Spent Screbber Uouor
20
100,000
200.000
Wastewater from APC
50.000
200.000
Sector
1.420
151.750
408.400
1.400
98.59%
0,92%
0,34% -
Selenium
Spent Filter Cake
217
4.335
Plant Process Wastewater
13.200
13.200
13.200
13.200
100.00%
100.00%
100.00%
Siao
51
1.020
Tellurium Slime Wastes
217
4.335
Sector
13.200
13.685
22.890
13.200
100.00%
96.48%
57.57%
Tantalum,
FtHTOCOfum-
bium, etc.
Process Wastewater
127.500
127,500
127,500
127,500
100.00%
100.00%
100.00%
Sector
127.500
127:500
127.500
100.00%
100.00%
100,00%
Titanium,
Titanium Oxide
Pickel Liquor and Wash Water
270
660
Scrap Millino Scrubber Water
500
1.200
500
100.00%
41.67%
Smut from Ma Recovery
85
18.700
39.100
Leach Liquor, Soonoe Wash Water
78.000
96.000.
116.000
96.000
126.32%
100.00%
82.76%
Spent Surface Impoundment
Ltauida
1,45a
5.712
jtctor
116.928
162.872
96.500
126.83%
82.53%
59 32%
Zinc
Acid Pfam itowdown '
130.000
130.000
130.000
Waste Femsilieem
7.225
14.450
7.225
100.00%
50.00%
Process Wastewater
4.33S.Q00
4,335.000
4.335,000
4.335,000
100.00%
100,00% '
100 00%
Spent Domes. Baos. Mid Filters
75
150
Spent Qoethite, leach Cake
Residues
1S.OOO
15.000
15,000
Spent Surface Impoundment
Liquids
378.000
378.000
378.000
378.000
100.00%
100.00%
100.00%
WWTP Solids '
' 281
563
TAC Tower Slowdown
94
188
c
1
i
I
261.000
522.000
261.000
100.00%
50.00%
JtCtOf
4.858.000
5 395 3S1
4.981.225
102.54%
97.18%
All Sectors
14,099.602
14,843,809
18.S0U23
9,845,082
$841%
64.98%
fr.3»%
Notts:
Proportkmof strsamseov»red» 14/73 »19.2 percent
Commodities not covered ¦ Antimony, Bismuth. Cadmium. Calcium, Coal Sax. Fluorspar and Hydrofluoric Add, Germanium. Lead, Mayiesium and
Magnesia. Mercury. Platinum Group Matais, PyroMumana, Rhenium, Scandkm. Synthetic Rutile, Tellurium, Tungsten, Uranium, Zirconium and Hafnium
-------
ATTACHMENT H.A-2
PROPOfmONGFftl
wmm, paoecsswa str£«« aoqrsssso m im nmx tsmssmxr *©* m>«lHy»a(Xiui«.*^«»ini«afc
-------
ATTACHMENT H.B
Summary of Particulate Generation, Air Transport, and Deposition
Modeling
t
-------
ATTACHMENT H.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 CHI 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 are 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
ferrosilieon waste from zinc production) were estimated to occur from the aggregate handling of the waste
materials and from the wind erosion of die waste piles. Emissions from the aggregate handling of the
waste piles vary in proportion to die 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 die 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 die waste piles is the same as the threshold friction velocity for
fine coal 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 wind 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. RAMMET 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 die 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 anay of polar receptors, at 45
degree intervals, from 200 to 3,000 meters was used to estimate area average concentrations.
-------
ATTACHMENT H.C
Fish Bioconcentration and Bioaccumulation Factor Values and Data
Sources
-------
Attachment H.C
Fish BCF, and Toxicity Values
Chemical
Cm
Number
BAFfistt(L%g
body weight)
(total)
Source
BCF fish (L/kg)
(dissolved)
Source
Rll>
(mg/kg/day)
Source
Oral CSF
(mg/kg/day)-l
Source
RfC (mg/ni3)
Source
Inhal CJRF
(ug/m3)-l
Source
Antimony
7440-36 0
NA
not significant
Barrows el. al 1980 (in
EPA 1988)*
4.00E-04
IRIS
NA
NA
NA
Arsenic
7440-38-2
NA
4
Barrows et al. 1978*
3 00E-04
IRIS
I.50E+00
IRIS
NA
4.30E-03
IRIS
Barium
7440-39-3
NA
100
Schroeder 1970*
7.00E-02
IRIS
NA
5.00E-04
HEAST
NA
Beryllium
7440-41-7
NA
19
Barrows etal. 1978*
5.00E-03
IRIS
4.30E+00
IRIS
NA
2.40E-03
IRIS
Cadmium
7440-43-9
NA
3-7,440
Benoit et al. 1976 (in EPA
1985a)*; Ciesy et al. 1977
(in Eisler 1985)*
5.00E-04
IRIS
NA
NA
1.80E-03
IRIS
Chromium
(VI)
18540-29-9
NA
3
EPA 1985b
5.00E-03
IRIS
NA
NA
I.20E-02
IRIS
Cyanide
57-12-5
0.3
Kenaga 1980 (KCN)*
2.00E-02
IRIS
NA
NA
NA
Lead
7439-92-1
8
1-726
Maddock and Taylor 1980
(in Eisler 1988)*; Wong el
al. 1981 (in Eisler 1988)*
NA
NA
NA
NA
Mercury
7439-97-6
6.00E+04
EPA 1993b
129-10,000
(mercury(ll));
10,000-85,700
(methylmercury)
Various refs. in EPA
1985c*
3.00E-04
IRIS
(HgCI2)
NA
3.00E-04
IRIS
NA
Nickel
7440-02-0
NA
47-106
Lind et al. manuscript {in
EPA 1986)*
2.00E-02
IRIS
(soluble
salts)
NA
NA
NA
Selenium
7482-49-2
0,5-1.0
Cleveland
et. a» 1993
5-322
Cleveland et. 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
Zitkoet al. 1975; Barrows
et al. 1978*
8.00E-05
IRIS
(TI2Ch2
03.T1CI,
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*
3.00E-0I
IRIS
NA
NA
NA
-------
ATTACHMENT H.D
Risk Characterization and Screening Spreadsheets
H.D-1 Inhalation Pathway
H.D-2 Particulate Depostion Soil Ingestion and Dermal Contact
H.D-3 Particulate Deposition to Surface Water Risk Screening Results
H.D-4 Runoff Deposition to Soils Screening Results
H.D-5 Runoff Deposition to Surface Water Screening Results
H.D-6 Surface Impoundment Releases to Surface Soils Screening Results
-------
Exposure and Risk Calculation* for Particulate
Deposition
ATTACHMENT H.D-1
Inhalation Pathway
COMMODITY:
WASTE
STREAM;
CTFM10
Concantration
HEPM10
Concantration
Alumina and Aluminum
Cast house dust
2.3 ug/m3
32.3 U0fa)3
Constituent RIC (mg/m3) Unit Risk (ugfm3)-1 Maximum CT Constituent HE Constituent CT Cancer Risk
Concentration In Concentration in Concentration In
Waste (mg/kg) Paniculate (ugftn3) Particulate (ug/m3)
HE Cancer Risk
CT Noncancer HE Noncancer
Hazard Quotient Hazard Quotient
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium(VI)
Lead
Mercuiy
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
5.00E-04
3.00E-04
4.30E-03
2.40E-O3
180E03
1.20E-02
4.80E-04
7.5
32
ia
o
7.2
110
17
0.0001
260
0.92
1.9
0
0
120
1.73E-05
7.38E-05
2.30E-05
Q.00E+0Q
1.66E-05
2.53E-04
3.91E-05
2.30E-10
5 98E-04
2.12E06
4.37E-06
O.OOE+OO
O.OOE-tOO
2.76E-04
2.42E-04
1.03E-03
3.23E-04
0.00E+00
2.33E-Q4
3.5SE-03
5.49E-04
3.23E-09
0.4OE-O3
2.97E-05
6.14E-05
O.OOE+OO
O.OOE+OO
3.88E-03
O.OOE+OO
3.90E-13
O.OOE+OO
O.OOE+OO
3.67E-14
3.74E-12
O.OOE+OO
O.OOE+OO
3.54E-13
O.OOE+OO
O.OOE+OO
O.OOE+OO
O.OOE+OO
O.OOE+OO
O.OOE+OO
1.22E-11
O.OOE+OO
O.OOE+OO
1.15E-12
1.17E-10
O.OOE+OO
O.OOE+OO
I.IOE-tl
O.OOE+OO
O.OOE+OO
O.OOE+OO
O.OOE+OO
O.OOE+OO
1.92E-01
3.20E-06
t.92E-0t
3.20E-06
Expotun
Varlabkn
CT
HE
Unit*
EF
EDa
Exposure
Frequency
Exposure
Duration
(AM)
350
9
350 days/year
20 years
Cancer Risk = U.R. * PM10 * Max Cone.* 10*-6' (EF/365) * (ED/70)
Hazard Quollent = (EF/365) * (Ma*. Cone.* 10^6) I RtC
-------
ATTACHMENT H.D-2
Particulate Deposition - Soil Ingestion and
Dermal Contact
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-------
ATTACHMENT H.D-2 (Continued)
Particulate Deposition - Vegetable Ingestion
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-------
ATTACHMENT H.D-3
Air Emissions to Surface Water - Risk Screening Results
Exposure and Risk Calculations for Air Emissions
COMMODITY: Alumina and
Aluminum
WASTE STREAM;
Cast house dust
PI9W Rfrtf
CT Long-Term
Emissions
3.24E+08
mg/year
3.00E+11
L/year
HE Long-Term
Emissions
1.52E+09
mg/year
1.30E+10
L/year
Constituent
Maximum
Concentration In
Waste (mg/kg)
CT Water
Concentration
-------
ATTACHMENT H.D-4
Runoff Deposition to Soils Screening Results
Ezpodjm Kik Cdeutellom for WatM Mm
1. Aluminum Cut Mouse Dint
Constituent Ingestion Pathway Ingestion Pathway Maximum Sulk
Cancer Slope Factw BID (mg/kg-day) Concentration in
(mg-kg-day)-l Waits (mgfcg)
CT Soil HE Soil CT Soil HE Soil
Concentration Concentration Concentration Concentration
(Ingestion and (Ingestion and (Ingestion of Home- (Ingestion of Home-
Oermai) (mg/kg) Deiwiat Contact) Grown Vegetables) Grown Vegetables)
(mg/ks) (mgfcg} (wgrtsg)
Antimony
A/senic
Barium
Beryllium
Galium
Chromium(VI)
Lead
¦ Mercury
Nickel
Selenium
Shrer
Thallium
Vanadium
Zinc
1.5
0.0004
0.0003
0.07
0.0?
0.0005
0.005
0.0003
0.02
0.005
0.005
0.00008
0.009
0.3
T.S
32
10
72
110
17
0.0001
260
0.92
1.9
120
1.92E-03
8.17E-03
2.55E-03
1.84&03
2.81 E-02
4.34E-03
2.55E-08
6.64E-02
2.35E-04
4.8SE-04
3.07E-02
1.5BE-01
6.74E-01
2.11E-01
1.52E-01
2.32E+00
3.58E-01
2.11E-06
5.48E+00
1.94E-02
4.00E-02
2.53E-t00
2.39E-04
1.02E-03
3.19E-04
2.3OE-04
3.51E-03
5.43E-04
3.19E-09
8.30E-03
2.94E-05
8.07E-05
3.83E-03
1.58E-02
6.74E-02
2.11E-02
1.52E-02
2.32E-01
3.586-02
2.11E-07
5.48E-01
1.94E-03
4.00E-03
2.53E-01
Pathway Variables
CT
HE
Units
ustemmsa utxumg p-sz)
AWPd
Area of Waste Pile (Dun)
108
10S m2
AWPf
Ana of Waste Pile (Fenosilicon)
509
509 m2
R
Rainfall factor
50
110 1/year
K
Soil Erodability
Factor
0.25
0.25 tfyear
LS
Longtt-Slope Factor
1
3 uniMss
C
Cover Factor
1
1 unMsss
P
Control Practices
Factor
1
1 unittass
SL
- Total Soil Loss
(Dust)
301
1988 kg/ysar
SI
Total Soil Loss (Fanosilicon)
1418
9360 kgfyaar
SoiCMrmy
r
Radius of eontamioatsd araa
10000
5000 an
Sol ConcantraSan 4m » Oepcsion. Dtimat am» IngmSon (S-
1)
Z
BO
kt
t
SM
MMngDqMh .
So* Bulk Density
Soi Lots Contttnt
¦». ^-»
mpocnan mm
MM SoR Mas* (Dermal and Ingestion)
2.5
1.5
0
20
1.18E+06
1 cm
1-2 gmtoc
0 1/yaais
20 yaw*
9.42E+04 kg
SoiCanctntnttBndwtoDipot*on:RoMV»gmt>lM(6-5a)
Z
BD
ka
t
SM
MsongOapth
SoH Buk Density
Soil Lots Constant
Deposition Period
Mixed Soil Maas (Root Vegetable)
20
1,5
0
20
9.42E+06
10 Ml
1.2 grrVce
0 1 /years
20 years
9.42&05 kg
-------
ATTACHMENT H.D-4 (Continued)
Runoff Deposition to Soils Screening Results
Release, Exposure Bisk Calculations (or Wast* Piles
2. Zinc Wast* Ferrosilicon
Constituent
Ingestion Pathway
Ingestion Pathway
Maximum Sulk
CT Soil
Hi Soil
CT Soil
HE Soil
Cancer Slope Factor
RIO (mg/kg-day)
Concentration in
Concentration
Concentration
Concentration
Concentration
(mg-kg-dayH
Waste (mg/kg)
{Ingestion and
(Ingestion and
(Ingestion of Home-
(Ingestion of Home-
Dermal) (mg/kg)
Dental Contact)
Grown Vegetables)
Grown Vegetables)
(mgfkg)
(mgfcg)
(mg/kg)
Antimony
0.0004
Arsenic
1.5
0.0003
Barium
0.0?
Beryllium
0.07
Cadmium
0.0005
Chromium(VI)
0.005
lead
5000
6.018874429
436.5571404
0.752359304
49.65571404
Mercury
0.0003
Nickel
0.02
Selenium
0.005
Silver
0.005
Thallium
0.00008
Vanadium
0.009
Zinc
0.3
40000
48.15099543
3972.457123
6.018874429
397.2457123
PiUwny Variables
USl£ Sefaase UoatHng (7-52)
CT
he
umts
AWP0
Area of Waste Pile (Dust)
108
108 m2
AWPf
Area ot Waste Pita (Fenosilicon)
509
509 m2
R
Rainfall factor
50
110 1/yaat
K
Soil ErodaWrty
Factor
0.2S
0.25 tfyear
IS
Length-Slope Factor
1
3 unitless
C
Cover Factor
1
1 unitless
p
Control Practices
Factor
1
1 unitless
SL
Total Soil Loss
(Oust)
301
1988 kg^ear
SL
Total Soil Loss (Ferresilieon)
1418
9380 k^year
SotDHimy
i
Radius of contaminated area
10000
5000 en
Sail Coaeantmtion dm to DaposGom Dmmal mxi togmSon (&¦
1)
Z
MkdngDeptfi
2,5
1 cm
BO
Soi Buk Density
1.5
12 gnvee
ks
Sol Ijosa Constant
0
0 ifymn
t
OfPfUftfofl PjfWtl
20
20 years
SM
Mixed Soil Masa (Dermal and Ingestion)
1.18£*08
9.42E+04 kg
Sol CancmitmtionduatoDapostkn: Root VagHMUm {6-581
Z Mixing D«*i 20 10 cm
BO Soil Bulk Density 1.S 1.2 gmfco
Its Soil Loss Constant 0 0 1/ywn
t Deposition Period 20 20 yearn
SM Mixed Soil Mass (Root Vegetables) 9.42&0# 9.42E«os kg-
-------
ATTACHMENT H.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 Maximum Bulk CT Waterbody HE Waterbody
Cancer Slope Factor RfD (mg/kg-day) Concentration in Concentration Concentration
(mg*kg-day)-1 Waste (mg/kg) (mg/I) (mg/l)
Antimony 0.0004 7.5 7.52E-09 1.15E-06
Arsenic 1.5 0.0003 32 3.21 E-08 4.89E-06
Barium 0.07 10 1.00E-08 1.53E-06
Beryllium 0.07
Cadmium 0.0005 7.2 7.22E-09 1.10E-06
Chromium(VI) 0.005 110 1.10E-07 1.68E-05
Lead 17 1.71 E-08 2.60E-06
Mercury 0.0003 0.0001 1.00E-13 1.53E-11
Nickel 0.02 260 2.61 E-07 3.97E-05
Selenium 0.005 0.92 9.23E-10 1.41 E-07
Silver 0.005 1.9 1.91E-09 2.90E-07
Thallium 0.00008
Vanadium 0.009
Zinc 0.3 120 1.20E-07 1.83E-05
Pathway CT HE Units
Variables
USLE Release Modeling (7-52)
AWPd
Area of Waste Pile (Oust)
108
108 m2
AWPf
Area of Waste Pile (Ferrosilicon)
509
509 m2
R
Rainfall factor
50
110 1/year
K
Soil Erodability
0.25
0.25 t/year
Factor
LS
Length-Slope Factor
1
3 unitiess
C
Cover Factor
1
1 unitiess
P
Control Practices
1
1 unitiess
Factor
SL
Total Soil Loss
301
1986 kg/year
(Dust)
Si-
Total Soil Loss (Ferrosilicon)
1418
9360 kg/year
Surface Water Characteristics
Flow Rate
3.00E+11 1.30E+10 liter/year
-------
ATTACHMENT H.D-5 (Continued)
Runoff Deposition to Surface Water Screening Results
Release, Exposure Risk Calculations (or Waste Piles
2. Zinc Waste Ferrosilicon
Constituent
Ingestion Pathway
Cancer Slope Factor
(mg-kg-day)-l
Ingestion Pathway
RfD (mg/kg-day)
Maximum Bulk
Concentration in
Waste (mg/kg)
CTWatertoody
Concentration
(mg/1)
HE Watertoody
Concentration
(mgfl)
Antimony
Arsenic
Barium
Berytlium
Cadmium
Chromium(VI)
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
1.5
0.0004
0.0003
0.07
0.07
0.0005
0.005
0.0003
0.02
0.005
0.005
0.00008
0.009
0.3
5000
2.36361 E-05
0.003599954
40000
0.000189089
0.028799636
Pathway
Variables
CT
HE
Units
USLE Release Modeling (7-52)
AWPd
Area of Waste Pile (Oust)
108
108 m2
AWPf
Area of Waste Pile (Ferrosilicon)
509
509 m2
R
Rainfall factor
50
110 1/year
K
Soil Erodabilrty
0.25
0.25 Vyear
Factor
LS
Length-Slope Factor
1
3 unWess
C
Cover Factor
1
1 unit! ess
P
Control Practices
1
1 unWess
Factor
SL
Total Soil Loss
301
1988 kg/year
(Dust)
SI
Total Soil Loss (Ferrosilicon)
1418
9360 kg/year
Surface Water Characteristics
Flow Rate 3.00E+11 1.30E+10 liter/year
-------
ATTACHMENT H.D-6
Surface Impoundment Releases to Surface Water Screening Results
COMPARISON OF SURFACE WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO HEALTH-BASED LEVELS
F19H1NQE8TION
1
Maximum High-End Surfaca
Walar Concantratlon, Bulk
Samplat
Canual Tandaney Surfaca
Water Concentration, Bulk
Samnlaa
Maximum High-End Surfaca Watar
Concantrallon, EPSamplaa
Cantral Tandancy Surfaca
Walar Concafltntlon, EP
Samnlaa
Compared to HBL
Compared to HBL
Comoarad to HBL
Comoarad to HBL
Conitttutnt
Hutfd-iiiK)
UvaHmgA)
Commodity
WMMM.
Facility
Stat*
1-10*
10-1001
1-lOx
10-100X
1-10*
KMOOx
100-IQMx
1-10*
10-100*
Araanio
6.00084
Coppw
Add plant
blowdown
Unknown
Unknown
X
Copper
Add plant
blowdown
Unknown
Unknown
X
Coppat
Add plant
blowdown
Unknown
Unknown
X
Coppar
Acid plant
blowdown
Unknown
Unknown
X
Coppar
Add ptanl
btowdown
Magma, San
Manual
AZ
X
X
Cadmium
0.035
Zinc
Spantturiaca
Impoundment
Ikwld*
Zinc Corp oi
Amarica,
Monaca
PA
X
Lead
0.015
Zinc
Span! «urt»ca
Impoundment
Uoukh
ZitwCoipoi
Amartca,
Monaca
PA
X
Coppat
Add plant
btowdown
Unknown
Unknown
X
2 mo
Span)luriaca
hnpoundmanl
Uoukla
Big Rival Zinc
IL
X
-------
ATTACHMENT H.D-6 (Continued)
Surface Impoundment Releases to Surface Water Screening Results
fiOliPAMSON OF SURFACE WATER CONCENTRATIONS FROM SURFACE IMPOUNDMENT RELEASES TO HEALTH-BASED LEVELS
FISH INGESTION
1 1
»
Hazard-
Maximum High-End Surface Water
Concentration, Bulk Samples
Central Tendency
Surface Wafer
Concentration, Bulk
Samples
Maximum High-End Surface
Water Concentration, EP
Samples
Central Tendency
Surface Water
Concentration, EP
Samplaa
Baaed
Compared to HBL
Compared to HBL
Compared to HBL
Compared to HBL
Constituent
(man)
Source
Commodity
WMlMtraam
Facility
Stat*
1*10*
10-IOOx
IMMQOOx
MO*
ID-IOOx
1-IOx
10-IGOx
1OO-1O0OX
1-IOx
1
-------
METHODOLOGY
APPENDIX I
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 1-1.
EXHIBIT 1-1
Overview of the Agency's Methodology for Defining the Universe of Potentially
Affected Mineral Processing Waste Streams
STEP 1
STEP 2
STEP 3
STEP 4
STEPS
STEP 6
Conduct Exhaustive
Information Search on Mineral
Commodity Sectors of Interest
Prepare Mineral Commodity
Analysis Reports on
Each Sector
Define Universe of Mineral
Processing Waste Streams
Potentially Affected by
The Phase IV LDRs
Prepare Final Estimates of the
Volume of Mineral Processing
Waste Streams Potentially
Affected bv the Phase IV LDRs
Identify Mineral
Commodity
Sectors of Interest
Define Universe of Mineral
Processing Facilities Potentially
Affected by the Phase IV LDRs
April 15,1997
-------
1-2
Step One
LI Identify Mineral Commodity Sectors of Interest
Identify Mineral Commodity
Sectors of Interest
T
Conduct Exhaustive Information Search
on Mineral Commodity Sectors of Interest
t
f
~
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.1 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
are listed below in Exhibit 1-2.
The Agency notes that Exhibit 1-2 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.
L2 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 1-2. 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 die 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
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 mineral processing operations
(e.g.. smelting or acid digestion) are unaffected by the proposed Phase IV LDRs.
April 15,1997
-------
1-3
EXHIBIT 1-2
Mineral Commodities Of Potential Interest
1)
Alumina
32)
Lightweight Aggregate
2)
Aluminum
33)
Lithium (from ores)
3)
Ammonium Molybdate
34)
Lithium Carbonate
4)
Antimony
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)
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 Phosphorus
49)
Soda Ash
19)
Ferrochrome
50)
Sodium Sulfate
20)
Ferrochrome-Silicon
51)
Strontium
21)
Ferrocolumbium
52)
Sulfur
22)
Ferromanganese
53)
Synthetic Rutile
23)
Ferromolybdenum
54)
T antalum/Columbium
24)
Ferrosilicon
55)
Tellurium
25)
Gemstones
56)
Tin
26)
Germanium
57)
Titanium/Ti02
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 15,1997
-------
1-4
Step Two
Identify Mineral Commodity
Sectors of Interest
i
Conduct Exhaustive Information Search
on Mineral Commodity Sectors of Interest
Prepare Mineral Commodity Analysis
Reports on Each Sector
t
i
capitalize on information collected through past efforts, as well as
to collect more recent data, the Agency conducted the following
activities:
• Reviewed the National Survey of Solid Wastes From
Mineral Processing Facilities (NSSWMPF) 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 (e.g., Bureau 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 Toxicity 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.
April 15,1997
-------
1-5
• Conducted an electronic literature search for information related to mineral processing and
waste treatment technologies contained in numerous technical on-line databases,
including: NTIS, Compendex Plus, METADEX, Aluminum Industry Abstracts,
ENVEROLINE, Pollution Abstracts, Environmental Bibliography, and GEOREF.
EPA focused its search for relevant information (published since 1990) on the mineral
commodities listed in Exhibit 1-2. 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
mineral 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 by mineral commodity
sector.
1-3 Prepare Mineral Commodity Analysis Reports on Each of the Identified Sectors
Step Three
Conduct Exhaustive Information Search
on Mineral Commodity Sectors of Interest
i
Prepare Mineral Commodity Analysis
Reports on Each Sector
t
Define Universe of Mineral Processing Waste
Streams Potentially Affected by
The Phase IV LDRs
Y
As discussed above, EPA embarked on a very
ambitious information collection program to collect current
information on relevant mineral processes, salient statistics,
waste characteristics, waste generation rates, and waste
management information. All of the publicly available
information was collected, evaluated for relevance (both
applicability and age), and compiled to prepare 49 analyses
covering 62 mineral commodities. Each mineral commodity
analysis report consists of:
• A commodity summary describing the uses
and salient statistics of the particular mineral
commodity.
• A process description section with detailed,
current process information and process flow
diagram(s).
• A process waste stream section that identifies
~ to the maximum extent practicable -
individual waste streams, sorted by the nature
of the operation generating the waste stream
(i.e., extraction/beneficiation or mineral
processing).2 Within this section, EPA also
identified:
2 EPA strongly cautions that the process information and identified waste streams presented in the commodity analysis
reports should not be construed to be the authoritative list of processes and waste streams. These reports represent a best effort,
and clearly do not include every potential process and waste stream. Furthermore, the omission of an actual waste stream (and
thus its not being classified as either an extraction/beneficiation or mineral processing waste in this report) does not relieve the
generator from its responsibility of correctly determining whether the particular waste is covered by the Mining Waste Exclusion.
April 15,1997
-------
1-6
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-Exclusion status of the waste stream (i.e., extraction/beneficiation waste
stream, mineral processing waste stream, or non-uniquely associated waste
stream).
waste stream characteristics (total constituent concentration data, and statements
on whether the waste stream exhibited one of the RCRA hazardous waste
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 EPA. 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 recyclability is described below.
Waste Stream Sources and Form
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 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 LDR standards. EPA decisions 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 1-3:
April 15,1997
-------
1-7
• 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 tod hence, not subject to RCRA;
(2) the material is a solid waste but is exempt from RCRA Subtitle C because of the Mining
Waste Exclusion; 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 document
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 characteristic(s) was
designated with a Y. However, despite more than ten years of Agency research on mineral processing
operations, EPA was unable to find waste characterization
3 RCRA Subtitle C regulations define toxicity as one of the four characteristics of a hazardous waste. EPA 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 15,1997
-------
1-8
EXHIBIT 1-3
Process Summary for Exclusion Determinations
No
Solid
Wasta?
Hot Subject
toRCRA
No
GanaraMdby
¦rimtfy Mlnwal
Production? ^
NotCovared
by Om Mining
Wasta Excluaion
No
;«.g_ tpant sotvarrta,
uaad oil, lab waataa)
Ym
Ho
(e.g. alloying waataa,
chafflieal manufacttving
waataa)
Yaa
Downstream of
Initial ProcMaing
v. Operation?
No
No
Yaa
Yaa
OnaofttM
20 Spatial Minora!
Procaaaing
Waataa? ^
Ewnpttrom
RCRASuMtiaC
Yaa
No
April 15,1997
-------
1-9
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).
To determine whether a waste might exhibit the characteristic of toxicity, EPA first compared
1/204 of the total constituent concentration of each TC metal to its respective TC level.4 In cases where
total constituent data were not available, EPA 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 teachable) 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, step-wise
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 RCRA 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) Ieachate data
reported by various sources are greater than 1/2# of the total constituent concentration. Generally one
would expect, based on the design of the EP testing procedure, the total constituent concentrations to be at
least 20-times the EP concentrations. This apparent discrepancy, however, can potentially be explained if
the EP 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 the 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
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 l/20th of the total constituent concentration.
April 15,1997
-------
1-10
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, EPA 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.
A key element in developing waste generation rates was the fact that by definition, average facility
level generation rates of 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
generation 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. EPA 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 (45,000 metric tons/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.
April 15,1997
-------
1-11
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, EPA 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
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 managed. For example, EPA 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 it 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 Recvclabilitv and Classification
As was the case for the other types of waste stream-specific information discussed above, EPA was
unable to locate 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 recyclability 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 a method for determining whether a particular mineral processing waste stream was
expected to be either fully or partially recycled, designated by Y? and YS?, respectively. This method was
designed to capture the various 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 EPA determined that the waste stream was or could be fully/partially recycled, it used the
definitions provided in 40 CFR §§ 260.10 and 261.1 to categorize the waste stream as either a by-product,
sludge, or spent material.
EPA, through the process of researching and preparing mineral commodity analysis reports for the
mineral commodities listed in Exhibit 1-2, identified a total of 526 waste streams that are believed to be
generated at facilities involved in mineral production operations.
April 15,1997
-------
1-12
1-4 Define the Universe of "Mineral Processing" Waste Streams Potentially Affected bv the Phase IV
LDRs
Step Four
The Agency then evaluated each of the waste streams
using the process outlined in Exhibit 1-4, 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;
i
Prepare Mineral Commodity Analysis
Reports on Each Sector
Define Universe of Miners] Processing Waate
Streams Potentially Affected by
The Phase IV LDRs
J
Define Universe of Mineral
Processing Facilities Potentially
Affected by the Phase IV LDRs
t
• The "Special 20" Bevill-Exempt 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 this evaluation process, EPA narrowed the
potential universe of waste streams that could potentially be
affected by the proposed Phase IV LDRs to the 118 hazardous
mineral processing waste streams presented below in Exhibit I-5.s
5 EPA strongly cautions that the list of waste streams presented in Exhibit 1-5 should not be construed to be the authoritative
list of hazardous mineral processing waste streams. Exhibit 1-5 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 15,1997
-------
1-13
EXHIBIT 1-4
Schematic of the Agency's Process for Defining the Universe of Mineral Processing Waste Streams
Potentially Affected by the Phase IV LDRs
Universe of all
Mineral Production
Waste Streams
/ Is the
Material Covered
by the Bevill
s\Exclusion?5^
YES
NO
f Does \
Material Exhibit
Hazardous
Characteristics?^
NO
No
Further
Analysis
Not a Hazardous
Waste
YES
YES
YES
Material a Sludge
or By-product?/
Not a Solid
Waste
Material
Recycled?
NO
NO
Is it
Managed on
Land?
NO
Not Subject
to LDRs
Spent Material
YES
Solid Hazardous Waste
Potentially Subject to
LDRs
* Includes Extraction/Beneficiation and the "Special 20" Waste Streams
** Listed hazardous wastes are excluded from further analysis because they are already subject to all relevant
Subtitle C requirements
April 15,1997
-------
1-14
EXHIBIT 1-5
Potentially Hazardous Mineral Processing Waste Streams by Commodity Sector
Alumina and Aluminum
Copper
Cast house dust
Acid plant blowdown
Electrolysis waste
WWTP sludge
Antimony
Elemental Phosphorus
Autoclave filtrate
-—
Andersen Filter Media
Slag and furnace residue
AFM rinsate
Stripped anolyte Solids
Furnace building washdown
Beryllium
Furnace scrubber blowdown
Chip treatment wastewater
Fluorspar and Hydrofluoric Acid
Filtration discard
Off-spec fluosilicic acid
Bismuth
Germanium
Alloy residues
Waste acid wash and rinse water
Spent caustic soda
Chlorinator wet air pollution control
Electrolytic slimes
sludge
Lead and zinc chlorides
Hydrolysis filtrate
Metal chloride residues
Leach residues
Slag
Spent acid/1 eachate
Spent electrolyte
Waste still liquor
Spent soda solution
Lead
Waste acid solutions
Acid plant sludge
Waste acids
Baghouse incinerator ash
Cadmium
Slurried APC dust
Caustic washwater
Solid residues
Copper and lead sulfate filter cakes
Spent furnace brick
Copper removal filter cake
Stockpiled miscellaneous plant waste
Iron containing impurities
Wastewater treatment plant liquid effluent
Spent leach solution
Wastewater treatment plant sludges/solids
Lead sulfate waste
Magnesium and Magnesia from Brines
Post-leaeh filter cake
Cast house dust
Spent purification solution
Smut
Scrubber wastewater
Mercury
Spent electrolyte
Dust
Zinc precipitates
Furnace residue
Calcium
Quench water
Dust with quick lime
Molybdenum, Ferromolybdenum, and Ammonium
Coal Gas
Molybdate
Multiple effects evaporator concentrate
Flue dust/gases
Liquid residues
April 15,1997
-------
1-15
EXHIBIT 1-5 (Continued)
Platinum Group Metals
Titanium and Titanium Dioxide
Slag
Pickle liquor and wash water
Spent acids
Scrap milling scrubber water
Spent solvents
Smut from Mg recovery
Pyrobitumens, Mineral Waxes, and Natural
Leach liquor and sponge wash water
Asphalts
Spent surface impoundment liquids
Still bottoms
Spent surface impoundments solids
Waste catalysts
Waste acids (Sulfate process)
Rare Earths
WWTP sludge/solids
Spent ammonium nitrate processing
Tungsten
solution
Spent acid and rinse water
Electrolytic cell caustic wet APC
Process wastewater
sludge
Uranium
Process wastewater
Waste nitric acid from UOz production
Spent scrubber liquor
Vaporizer condensate
Solvent extraction crud
Superheater condensate
Wastewater from caustic wet APC
Slag
Rhenium
Uranium chips from ingot production
Spent barren scrubber liquor
Zinc
Spent rhenium raffinate
Acid plant blowdown
Scandium
Waste ferrosilicon
Spent acids
Process wastewater
Spent solvents from solvent extraction
Discarded refractory brick
Selenium
Spent cloths, bags, and filters
Spent filter cake
Spent goethite and leach cake residues
Plant process wastewater
Spent surface impoundment liquids
Slag
Spent synthetic gypsum
Tellurium slime wastes
TCA tower blowdown
Waste solids
Wastewater treatment plant liquid effluent
Synthetic Rutile
WWTP solids
Spent iron oxide slurry
Zirconium and Hafnium
APC dust/sludges
S|*nt acid leachate from zirconium
Spent acid solution
alloy production
Tantalum, Columbitim, and Ferrocolumbium
Spent acid leachate from zirconium
Digester sludge
metal production
Process wastewater
Leaching rinse water from zirconium
Spent raffinate solids
alloy production
Tellurium
Leaching rinse water from zirconium
Slag
metal production
Solid waste residues
Waste electrolyte
Wastewater
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 15,1997
-------
1-16
L5 Define the Universe of "Mineral Processing" Facilities Potentially Affected bv the Phase IV
LDRs
Step Five
t
Define I'mvene of Mineral Processing Waste ,
Streams Potentially Affected by
The Phase IV LDRs
i
Define Universe of Mineral
Processing Facilities Potentially
J
Prepare Final Estimates of the Volume of .
Mineral Processing Waste Streams '
Potentially Affected by the Phase IV LDRs _j
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 1-5. As discussed earlier, the
individual 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/beneficiation 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 B presents a summary of the mineral processing facilities by mineral commodity
sector that generate hazardous mineral processing wastes. Appendix B also indicates whether the
mineral processing facilities are collocated and/or generate one (or more) of the "Special 20" waste
streams.
1-6 Prepare Final Estimates of the Volume of Mineral Processing Waste Streams Potentially
Affected bv the Phase IV LDRs
The Agency compiled the information in the previous steps to arrive at the final data set.
Exhibit 1-6 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 15,1997
-------
1-17
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Commodity
Waste Stream
Reported
Generation
(1000mt/yr)
EaUReported
Generation (lOOOmt/yr)
Number
of Facilities
with Process
Average Facility Generation (mt/yr)
Min
Max
Minimum
Expected
Maximum
Alumina and Aluminum
Cast house dust
19
19
19
19
23
830
830
830
Electrolysis waste
58
58
58
58
23
2.500
2,500
2.500
Antimony
Autoclave filtrate
NA
0.32
27
54
6
53
4,500
9,000
Stripped anolyte solids
0.19
0.19
0.19
0.19
2
95
95
95
Slag and furnace residue
21
21
21
21
6
3,500
3,500
3,500
Beiyllium
Chip treatment wastewater
NA
0.2
too
2000
2
100
50,000
1,000,000
Filtration discard
NA
0.2
45
90
2
100
23,000
45,000
Bismuth
Alloy residues
NA
0.1
3
6
1
100
3,000
6,000
Spent caustic soda
NA
0.1
6.1
12
1
100
6,100
12,000
Electrolytic slimes
NA
0
0.02
0.2
1
0
20
200
Lead and zinc chlorides
NA
0.1
3
6
1
100
3,000
6,000
Metal chloride residues
3
3
3
3
3,000
3.000
3,000
Slag
NA
0.1
1
10
1
100
1,000
10,000
Spent electrolyte
NA
0.1
6.1
12
1
100
6,100
12,000
Spent soda solution
NA
0.1
6.1
12
1
100
6,100
12,000
Waste acid solutions
NA
0.1
6.1
12
1
100
6,100
12,000
Waste acids
NA
0
0,1
0.2
1
0
100
200
Cadmium
Caustic washwater
NA
0.19
1.9
19
2
95
950
9,500
Copper and lead sulfate filter cakes
NA
0.19
1.9
19
2
95
950
9,500
Copper removal tiller cake
NA
0.19
1.9
19
2
95
950
9,500
Iron containing impurities
NA
0.19
1.9
19
2
95
950
9,500
Spent leach solution
NA
0.19
1.9
19
2
95
950
9,500
Lead sulfate waste
NA
0.19
1.9
19
2
95
950
9,500
Post-leach filter cake
NA
0.19
1.9
19
2
95
950
9,500
Spent purification solution
NA
0.19
19
19
2
95
950
9,500
Scrubber wastewater
NA
0.19
1,9
19
2
95
950
9.500
Spent electrolyte
NA
0 19
1.9
19
2
95
950
9,500
Zinc precipitates
NA
0.19
19
19
2
95
950
9,500
Calcium
Dust with quicklime
0.04
0.04
0.04
0,04
1
40
40
40
Coal Gas
Multiple ellects evaporator concoritrate
NA
0
0
65
1
0
0
65.000
Copper
Acid plant blowdown
5300
5300
5300
5300
10
530,000
530,000
530,000
WWTP sludge
6
6
6
6
10
600
600
600
April 15, 1997
-------
I - 18
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Commodity
Waste Stream
Reported
Generation
(lOOOmt/yr)
EatyReported
Generation (lOOOmt/yr)
Number
of Facilities
with Process
Average Facility Generation (mt/yr)
Mln
Avg.
Max
Minimum
Expected
Maximum
Elemental Phosphorus
Andersen Filter Media
0.46
0.46
0.46
0.46
2
230
230
230
AFM rinsate
4
4
4
4
2
2,000
2,000
2,000
Furnace scrubber blowdown
410
410
410
410
2
210,000
210,000
210,000
Furnace Building Washdown
700
700
700
700
2
350,000
350,000
350,000
Fluorspar and
Hydrofluoric Acid
Off-spec fluosillcic acid
NA
0
15
44
3
0
5,000
15,000
Germanium
Waste acid wash and rinse water
NA
0.4
22
4
4
100
550
1,000
Chlorinator wet air pollution conlrol sludge
NA
0.01
0.21
0.4
4
3
53
100
Hydrolysis fillrate
NA
0.01
0.2 f
04
4
3
53
100
Leach residues
0.01
0.01
0.01
0.01
3
3
3
3
Spent acid/leachate
NA
0,4
22
4
4
100
550
1,000
Waste still liquor
NA
0.01
021
0.4
4
3
53
100
Lead
Acid plant sludge
14
14
14
14
3
4,700
4,700
4,700
Baghouse incinerator ash
NA
0.3
3
30
3
100
1,000
10,000
Slurried APC Dust
7
7
7
7
3
2,300
2,300
2,300
Solid residues
0.4
0,4
0.4
0.4
3
130
130
130
Spent furnace brick
t
1
1
1
3
330
330
330
Stockpiled miscellaneous plant waste
NA
0,4
88
180
4
100
22,000
45,000
WWTP liquid effluent
3500
3500
3500
3500
4
880,000
880.000
880,000
WWTP sludges/solids
380
380
380
380
4
95,000
95,000
95,000
Magnesium and
Magnesia from Brines
Cast house dusl
NA
0.076
0,76
7.6
1
76
760
7,600
Smut
26
26
26
26
2
13.000
13,000
13,000
Mercury
Dust
0.007
0.007
0.007
0.007
7
1
1
1
Quench water
NA
63
77
420
7
9,000
11,000
60,000
Furnace residue
0.077
0.077
0,077
0,077
7
11
11
11
Molybdenum,
Ferromolybdenum, and
Ammonium Molybdate
Flue dust/gases
NA
1.1
250
500
11
too
23,000
45,000
Liquid residues
1
1
1
1
2
500
500
500
Platinum Group Melals
Slap
NA
0.0046
0.046
0.46
3
2
15
150
Spent acids
NA
0.3
1,7
3
3
100
570
1,000
Spent solvents
NA
0.3
1.7
3
3
100
570
1,000
April 15, 1997
-------
I - 19
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Commodity
Waste Stream
Reported
Generation
(tOOOmt/yr)
EstJReportod
Generation (lOOOmt/yr)
Number
of Facilities
with Process
Average Facility Generation (mt/yr)
Min
Avg.
Max
Minimum
Expected
Maximum
Pyrobitumens, Mineral
Waxes, and Natural
Asphalts
Still bottoms
NA
0.002
45
90
2
1
23,000
45.000
Waste catalysts
NA
0.002
10
20
2
1
5,000
10,000
flare Earths
Spent ammonium nitrate processing
solution
14
14
14
14
1
14,000
14,000
14,000
Electrolytic call caustic wet APC sludge
NA
0.07
0.7
7
1
70
700
7,000
Process wastewater
7
7
7
7
1
7,000
7,000
7,000
Spent scrubber liquor
NA
0.1
500
1000
1
100
505,000
1,000,000
Solvent extraction crud
NA
0.1
2.3
4.5
1
100
2,300
4,500
Wastewater Irom caustic wat APC
NA
0.1
500
1000
1
100
500,000
1,000,000
Rhenium
Spent barren scrubber liquor
NA
0
01
02
2
0
50
100
Spent rhenium rallinate
88
88
88
88
2
44,000
44,000
44,000
Scandium
Spent acids
NA
0.7
39
7
7
100
560
1.000
Spent solvents Irom solvent extraction
NA
0.7
3.9
7
7
100
560
1.000
Selenium
Spent filter cake
NA
0.05
0.5
5
3
17
170
1,700
Plant process wastewater
66
66
66
66
2
33,000
33,000
33,000
Slag
NA
0.05
0,5
5
3
17
170
1,700
Tellurium slime wastes
NA
0.05
0,5
5
3
17
170
1.700
Waste solids
NA
0.05
0.5
5
3
17
170
1,700
Synthetic Rutile
Spent Iron oxide slurry
45
45
45
45
1
45,000
45,000
45,000
APC dust/sludges
30
30
30
30
1
30,000
30,000
30,000
Spent acid solution
30
30
30
30
1
30,000
30,000
30,000
Tantalum, Columblum,
and Ferrocolumbium
Digester sludge
1
1
1
1
2
500
500
500
Process wastewater
150
ISO
150
150
2
75,000
75,000
75,000
Spent rallinate solids
2
2
2
2
2
1,000
1,000
1,000
Tellurium
Slag
NA
0.2
2
9
2
100
1,000
4,500
Solid waste residues
NA
0,2
2
9
2
100
1,000
4,500
Waste electrolyte
NA
0.2
2
20
2
100
1,000
10,000
Wastewater
NA
02
20
40
2
too
10.000
20.000
April 15, 1997
-------
1-20
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Commodity
Waste Stream
Reported
Generation
(lOOOmt/yr)
Eat/Reported
Generation (1 OOOmtfyr)
Number
of Facilities
with Process
Average Facility Generation (mt/yr)
Mln
Avg.
Max
Minimum
Expected
Maximum
Titanium and Titanium
Dioxide.
Pickle liquor and wash water
NA
2.2
2.7
3.2
3
730
900
1,100
Scrap milling scrubber water
NA
4
5
6
1
4,000
5,000
6,000
Smut Irom Mg recovery
NA
0.1
22
45
2
50
11,000
23,000
Leach liquor and sponge wash water
NA
380
480
580
2
190.000
240.000
290,000
Spent surface impoundment llgulds
NA
0.63
3.4
6,7
7
90
490
960
Spent surface Impoundments solids
36
36
36
36
7
5,100
5,100
5,100
Waste acids (Sulfate process)
NA
0.2
39
77
2
100
20,000
39,000
WWTP sludge/solids
420
420
420
420
7
60,000
60,000
60,000
Tungsten
Spent acid and rinse water
NA
0
0
21
6
0
0
3,500
Process wastewater
NA
2.2
4.4
9
6
370
730
1,500
Uranium
Waste nitric acid Irom U02 production
NA
1.7
2.5
3.4
17
100
150
200
Vaporizer condensate
NA
1.7
9.3
17
17
100
550
1,000
Superheater condensate
NA
1.7
9.3
17
17
100
550
1,000
Slag
NA
0
8.5
17
17
0
500
1,000
Uranium chips Irom ingot production
NA
1.7
2.5
3.4
17
100
150
200
Zinc
Acid plant blowdown
130
130
130
130
1
130.000
130,000
130.000
Waste ferrosilicon
f7
17
17
17
1
17,000
17,000
17,000
Process wastewater
6000
5000
5000
5000
3
1,700,000
1,700,000
1,700,000
Discarded refractory brick
t
t
1
1
1
1,000
1.000
1,000
Spent cloths, bags, and filters
0.15
0.15
0.15
0.15
3
50
50
50
Spent goethite and leach cake residues
15
15
15
15
3
5,000
5.000
5,000
Spent surface impoundment liquids
1900
1900
1900
1900
3
630.000
630.000
630,000
WWTP Solids
0.7S
0.75
0.75
0.75
3
250
250
250
Spent synthetic gypsum
16
16
16
16
3
5,300
5,300
5,300
TCA tower blowdown
0.25
025
0.25
0.25
1
250
250
250
Wastewater treatment plant liquid effluent
2600
2600
2600
2600
3
870,000
870,000
870,000
Zirconium and Halnium
Spent acid leachate Irom Zr alloy prod.
NA
0
0
850
2
0
0
430,000
Spent acid leachate from Zr metal prod.
NA
0
0
1600
2
0
0
800,000
Leaching rinse water from Zr alloy prod.
NA
34
42
51
2
17,000
21,000
26,000
Leaching rinse water Irom Zr metal prod.
NA
0.2
1000
2000
2
100
500,000
1,000,000
*** EPA does not have enough information to determine whether Bromine, Gamstones. Iodine, Lithium and Lithium Carbonate, Soda Ash, Sodium Sulfate, and Strontium
produce mineral processing wastes
April 15, 1997
-------
1-21
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Commodity
Wast* Stream
TC Metals
Corr
Ignlt
Rctv
Recycled
to BevlH
Unit
Haz?
Current
Recycle
RCRA Waste Type
Treatment Type
By-
Prod.
Spent
Mat'l
Slud-
Waste
Water
1-10%
Solids
Solid
As
B«
Cd
Cr
Pb
Hg
Se
ab
Alumina and Aluminum
Cast house dust
Y
Y
N?
N?
N?
0
1
Y?
t
0
0
1
Electrolysis waste
Y?
N?
N?
N?
0
0.5
Y?
1
0
0
t
Anlimonv
Autoclave filtrate
Y?
Y?
Y?
Y?
Y?
N?
N?
0
0.5
YS?
1
1
0
0
Stripped anolyte solids
y?
N?
N?
N?
0
0.5
Y
1
0
0
1
Slaq and lumace residue
Y?
N?
N?
N?
0.5
N
0
0
1
Beryllium
Chip treatment wastewater
Y?
N?
N?
N?
0
0.5
YS?
1
1
0
0
Filtration discard
Y?
N?
N?
N?
0.5
N
0
0
t
Bismuth
Alloy residues
Y?
N7
N?
N?
0.5
N
0
0
t
Spent caustic soda
Y?
N?
N?
N?
0
0.5
Y?
1
0
1
0
Electrolytic slimes
Y?
N?
N?
N?
0
0,5
Y?
t
0
0
1
Lead and zinc chlorides
Y?
m
N?
N?
0.5
N
0
0
1
Melal chloride residues
Y?
N?
N?
N?
05
N
0
0
1
Slaq
Y?
N?
N?
N?
0,5
N
0
0
1
Spent electrolyte
Y?
N?
N?
N?
0.5
N
0
1
0
Spent soda solulion
Y?
Y?
N?
N?
0
0.5
Y?
1
1
0
0
Waste acid solutions
Y?
N?
N?
0.5
N
1
0
0
Waste acids
Y?
N?
N?
0
0.5
YS?
1
1
0
0
Cadmium
Caustic washwaler
Y?
Y?
N?
N?
0
05
Y?
1
1
0
0
Copper and lead sullale filter cakes
Y?
Y?
N7
N?
N?
0
0.5
Y?
1
0
0
!
Copper removal filter cake
Y?
N?
N?
N?
0
05
Y?
1
0
0
t
Iron containing impurities
Y?
N?
N?
N?
0.5
N
0
0
1
Spent leach solution
Y?
Y?
Y?
Y?
N?
N?
2
0.5
Y?
1
0
t
0
Lead sullale waste
Y?
Y?
N?
N?
N?
0
0.5
Y?
1
0
0
1
Post-leach tiller cake
Y?
N?
N?
N?
0.5
N
0
0
1
Spent purification solulion
Y?
Y?
N?
N?
0.5
N
1
0
0
Scrubber wastewater
Y?
Y?
N?
N?
2
0.5
Y?
t
t
0
0
Spent electrolyte
Y?
Y?
N?
N?
0.5
N
0
t
0
Y?
N?
N?
N?
0
0.5
Y?
1
0
0
1
Calcium
Dust wilh quicklime
Y?
N?
N?
1
0,5
Y
t
0
0
1
Coal Gas
Multiple effects evaporator concentrate
Y
Y
N?
N?
N?
1
1
YS
1
0
t
0
Copper
Acid plant blowdown
Y
Y
Y
Y
Y
Y
Y
Y
N?
N?
1
1
YS
t
0
1
0
WWTP sludge
Y?
Y?
N?
N?
N?
0
05
YS
1
0
0
1
April 15, 1997
-------
1-22
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Commodity
TC Metals
Corr
Ignlt
Rctv
Recycled
to Bevllt
Unit
Haz?
RCRA Waste Type
Treatment Type
Current
Recycle
By-
Prod.
Spent
Mali
Slud-
ge
Waste
Water
1-10%
Solids
Solid
Waste Strum
As
Ba
Cd
Cr
Pb
Hg
St
Ag
Elemental Phosphorus
Andersen Fitter Media
Y
N?
N?
N?
1
N
0
0
1
AFM rinsate
Y
Y
N?
N?
N?
2
t
Y
1
0
t
0
Furnace scrubber blowdown
Y
Y
N?
N?
2
t
Y
1
1
0
0
Furnace BulldinQ Washdown
Y
N?
N?
N?
2
1
Y
1
1
0
0
Fluorspaf and
Hydrofluoric Acid
Oil-spec lluosillctc acid
Y?
N?
N?
0
O.S
YS
1
1
0
0
Germanium
Waste acid wash and rinse water
Y?
Y?
Y?
Y?
Y?
Y?
Y?
N?
N?
0
0.5
YS?
1
1
0
0
Chlorinator wet air pollution control sludge
Y?
Y?
Y?
Y?
Y?
Y?
N?
N?
N?
0
0.5
YS?
1
0
0
1
Hydrolysis filtrate
Y?
Y?
Y?
Y?
Y?
Y?
N?
N?
N?
0.5
N
0
0
1
Leach residues
Y?
Y?
N?
N?
N?
0.5
N
0
0
t
Spent acld/leachate
Y?
Y?
Y?
N?
N?
0
0.5
YS?
1
1
0
0
Waste still liquor
Y?
Y?
Y?
Y?
Y?
Y?
N?
Y?
N?
0.5
N
0
0
1
Lead
Acid plant sludge
Y?
N?
N?
1
0.5
Y?
1
0
0
1
Baghouse incinerator ash
Y
Y
N?
N?
N?
1
N
0
0
1
Slurried APC Oust
Y
Y
N?
N?
N?
t
1
Y
1
0
0
1
Solid residues
Y?
N?
N?
N?
1
0.5
Y?
1
0
0
1
Spent furnace brick
Y
N?
N?
N?
1
1
Y
1
0
0
1
Stockpiled miscellaneous plant waste
Y
Y
N?
N?
N?
1
1
YS?
1
0
0
t
WWTP liquid effluent
Y?
Y7
N?
N?
1
0.5
Y
1
1
0
0
WWTP sludaes/solids
Y?
Y?
Y
N?
N?
1
t
Y
1
0
0
1
Magnesium and
Maonesla from Brines
Cast house dust
Y?
N?
N?
N?
0
0.5
Y?
t
0
0
1
Smut
Y
N?
N?
N?
I
N
0
0
1
Mercury
Oust
Y?
N?
N?
N?
0.5
N
0
0
1
Quench water
Y?
Y?
N?
N?
m
1
0.5
Y?
1
1
0
0
Furnace residue
Y?
N?
N?
N?
0.5
N
0
0
1
Molybdenum,
Ferromolytodanuin, and
Ammonium Molybdate
Flue dust/gases
Y?
N?
N?
N?
0,5
N
0
0
1
Liquid residues
Y7
Y?
Y?
Y?
N?
N?
N?
0.5
N
t
0
0
Platinum Group Metals
Slag
Y?
Y?
N?
N?
N?
0
0,5
Y?
1
0
0
t
Spent acids
Y?
Y?
Y?
M
N?
0,5
N
1
0
0
Spent solvents
Y?
Y?
N?
Y?
N?
0.5
N
!
0
0
April 15, 1997
-------
1-23
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Recycled
RCRA Waste Type
Treatment Type
•
TC Metals
to Bevlll
Current
By-
Spent
Waste
1-10%
Commodity
Watt* Stream
As
Ba
Cd
Cr
Pb
Hg
Se
Ag
Corr
tgnlt
Rctv
Unit
Hai?
Recycle
Prod.
Mat'l
Slud-
Water
Solids
Solid
Pyrobitumens, Mineral
Waxes, and Natural
Asphalts
Still bottoms
N?
Y?
N?
. 0,5
N
0
0
1
Waste catalysts
y?
Y?
N?
N?
N?
0
0.5
Y?
1
t
0
0
Bare Earths
Spent ammonium nitrate processing
solution
Y
N?
N?
1
N
1
0
0
Electrolytic cell caustic wet APC sludge
Y?
N?
N?
0
0,5
Y
1
0
0
1
Process wastewater
Y
Y?
N?
N?
1
1
YS?
1
1
0
0
Spent scrubber liquor
Y?
n?
N?
1
0.5
YS?
1
t
0
0
Solvent extraction crud
N?
Y?
N?
0.5
N
0
1
Wastewater from caustic wet APC
Y?
Y?
Y?
N?
N?
1
0.5
YS?
1
1
0
0
Rhenium
Spent barren scrubber liquor
Y?
N?
N
N
2
0.5
Y?
t
1
0
0
Spent rhenium ralffnate
Y?
N?
N?
N?
0,5
N
0
1
Scandium
Spant adds
Y?
N?
N?
0.5
N
t
0
0
Spent solvents Irani solvent extraction
N?
Y?
N?
0
0.5
Y?
1
1
0
0
Selanium
Spent filter cake
Y?
N?
N?
N?
0
0.5
Y?
1
0
0
1
Plant process wastewater
Y
Y
N?
N?
2
1
YS?
1
1
0
0
Slan
Y?
N?
N?
N?
0
0.5
YS?
1
0
0
1
Tellurium slime wastes
Y?
N
N?
N?
0
0.5
Y?
1
0
0
t
Waste solids
Y?
N?
N?
N?
0.5
N
0
0
1
Synthetic Rutile
Spant iron oxide slurry
Y?
Y?
N?
N?
N?
0
0.5
YS?
t
0
0
t
APC dust/sludges
Y?
Y?
N?
N?
N?
0
05
Y
1
0
0
1
Spent acid solution
Y?
Y?
Y?
N?
N?
0
05
Y
1
t
0
0
Tantalum, Cohimblum,
and Ferrocolumbium
Digester sludge
Y?
N?
N?
0.5
N
0
0
1
Process wastewater
V?
Y?
Y?
Y?
Y?
Y
N?
N?
0
1
Y?
1
0
t
0
Spent rallinate solids
Y?
N?
N?
0.5
N
0
0
1
Tellurium
Slaq
Y?
N?
N?
N7
0
0.5
YS?
1
0
0
1
Solid waste residues
Y?
N7
N?
N?
0.5
N
0
0
t
Waste electrolyte
Y?
Y?
m
N?
N?
0.5
N
t
o-
0
Wastewater
Y?
Y?
N?
N?
0
0.5
Y
1
1
0
0
April 15, 1997
-------
1-24
Exhibit 1-6
Final Mineral Processing Waste Stream Database - Baseline Analysis
Commodity
Waal* Stream
TC Metals
Corr
Igntt
Rctv
Recycled
to Bevill
Unit
Haz?
Current
Recycle
RCRA Waste Type
Treatment Type
By-
Prod.
Spent
Mat'l
Slud-
ge
Waste
Water
1-10%
Solids
Solid
As
Ba
Cd
Cr
Pb
Hg
Se
Afl
Titanium and Titanium
Dioxide
Pickle liquor and wash water
Y?
Y?
Y?
Y?
m
N?
0
0.5
YS?
1
f
0
0
Scrap mUlina scrubber water
Y?
Y?
Y?
Y?
N?
N?
N?
0
0.5
YS?
1
1
0
0
Smut from Ma recovery
N?
N?
Y
0
1
Y?
1
0
0
1
Leach liquor and sponge wash water
Y?
Y?
Y
N?
N?
0
1
YS?
f
1
0
0
Spent surface impoundment liquids
Y?
Y?
N?
N?
N?
0
0.5
Y?
1
1
0
0
Span! surface impoundments solids
Y?
Y?
N?
N?
N?
0.5
N
0
0
1
Waste acids (Sulfate process)
Y
Y
Y
Y
Y
N
N
1
N
t
0
0
WWTP sludge/solids
Y?
N
N
N
05
N
0
0
1
Tunqsfen
Spent acid and rinse watar
Y?
N?
N?
2
0.5
YS?
t
1
0
0
Process wastewater
Y?
N?
N?
2
0.5
YS?
1
1
0
0
Uranium
Waste nitric acid from U02 production
Y?
N?
N?
0
0.5
YS?
1
1
0
0
Vaporizer condensate
Y?
N?
N?
0.5
N
1
0
0
Superheater condensate
Y?
N?
N?
0.5
N
t
0
0
Slaq
N?
Y?
N?
0
0.5
Y
t
0
0
1
Uranium chips from ingot production
N?
Y?
N?
0
0.5
Y?
1
0
0
(
Zinc
Acid plant blowdown
Y
Y
Y
Y?
Y?
Y
Y
Y
N
N
0
f
Y
1
1
0
0
Waste ferrosiiicon
Y?
N?
N?
N?
0
0.5
Y?
1
0
0
1
Process wastewater
Y
Y
Y
Y
Y
Y
Y
N?
N?
0
1
Y?
t
t
0
0
Discarded refractory brick
Y?
Y?
Y?
Y?
N?
N?
N?
0.5
N
0
0
1
Spent cloths, bags, and fillers
Y?
Y?
Y?
Y?
Y?
N?
N?
N?
0
0.5
Y
i
0
0
1
Spent goethite and leach cake residues
Y
Y
Y
Y?
Y?
Y
Y
N?
N?
N7
0
1
Y
0
0
f
Spent surface impoundment liquids
Y?
Y
N?
N?
0
1
YS?
1
1
0
0
WWTP Solids
Y?
Y?
Y?
Y?
Y?
Y?
N?
N?
N?
1
0.5
YS
1
0
0
1
Spent synthetic gypsum
Y?
Y
Y?
N?
N?
N?
1
N
0
0
1
TCA tower blowdown
Y?
Y?
Y?
Y?
Y?
N?
N?
0
0.5
YS
1
1
0
0
Wastewater treatment plant liquid effluent
Y?
N?
N?
N?
0
0.5
YS?
1
1
0
0
Zirconium and Hafnium
Spent acid ieachate from Zr alloy prod.
Y?
N?
N?
0.5
N
1
0
0
Spent acid Ieachate from Zr metal prod.
Y?
N?
N?
0.5
N
t
0
0
Leaching rinse water from Zr alloy prod.
Y?
N?
N?
0
05
YS?
1
1
0
0
Leaching rinse water Irom Zr metal prod.
Y?
N?
N?
0
0.5
YS?
t
1
0
0
April 15, 1997
-------
CONSTITUENT CONCENTRATION DATA
FOR RECYCLED MATERIALS APPENDIX J
April 15,1997
-------
J-1
SUMMARY OF BULK AMD EP ANALYSIS RESULTS FOR MINERAL PROCESSING WASTE (RECYCLED PORTION}
Ngvambar, 1996
Bulk Sample*. Nonwastewcters.
Number of
Constituents Detections Commodity
Facility identifier
Stats
Constituent Const*u«nt
Concentration Voium# of Vass Mr
in Waste Wasta Pila Wast* ?m
(mg/kj) (m") (kg)
!i) (2)
Antimony
1
Alumma and Aluminum
Cast nous* dust
Unknown
Unknown
7.5
107
1.08938
Af$en*
1
Alumina and AJgmmum
Cast house dust
Unknown
Unknown
32
107
4L&48
Banum
i
Alumina and Aluminum
Cast house dust
Unknown
Unknown
10
107
1.4525
Cadmium
1
Alumina and Aluminum
Cast house dust
Unknown
Unknown
7.2
T07
1.0458
Chromium
!
Alumina and Alumni**
Casi house dust
Unknown
Unknown
no
107
'5.9775
Luad
2
Alumma and AJummun
Cast house dust
Unknown
Unknown
17
107
2.46925
Load
Zinc
Wasta tanosiiicon
Unknown
Unknown
5000
1093
74375
Mercury
1
AJumma and AJum*um
Cast housa dust
Unknown
Unknown
0.0001
107
0.00001
NtCkei
1
Aiumna and Alumrun
Cast housa dust
Unknown
Unknown
260
107
37.785
Seienmm
1
Alumma and AJummjn
Cast housa dust
Unknown
Unknown
0.92
107
0.13363
Siiver
1
Alumna and Alummitn
Cast housa dust
Unknown
Unknown
1.9
107
0.27598
Zsnc
2
Alumna and Alumni**
Cast housa dust
Unknown
Unknown
120
107
17 43
Ztftc
Ztnc
Wasta ferrosiiicon
Unknown
Unknown
40000
1093
59500.
Area of
W«fe *i«
(m*)
108
108
108
108
ice
108
sos
ICE
108
108
ice
108
509
Bulk Samples. Wastewaters ana uqukJ Nonwast«w*»r»
Constituants
Number of
Dat act ions Commodity
Facility Identifier
Stale
Constituent
Concentration
m Wart
(myi)
Volume of
Surface
Ccnstrftien?
Uus m
Surface
impocnorfiam impoundment
(m*)
(3)
m
(4)
Area 01
Surface
impoundment
(*')
Antimony
31 Beryllium
Chip treatment w&stewatar
One Unnamad Faoiify
Unknown
0.003
417
0.00125
558
Antimony
Gopper
Ac>d plant Slowdown
Unknown
Unknown
140
22063
3091.66667
1044'
Antmony
Copper
Ack! plan? Slowdown
Unknown
Unknown
5
22083
110.41667
1044'.
An am any
Copper
Acid plant Slowdown
Unknown
Unknown
0.5
22083
11.04167
1044*
Antmcry
Copper
Acid olart Slowdown
Unknown
Unknown
0.263
22083
5.80792
1044'
Antimony
Elemental P?K»phorys
Furnace scn^bar slowdown
Unknown Amarican Plant
Unknown
40
17500
84.
8429
Anamcny
EJemantU Phospfxxus
Furnace scrubber Slowdown
Unknown Amarican Plan!
Unknown
2.4
17500
42.
8429
Antimony
Dement*) Phosphorus
Fumec* scrubber Slowdown
FMC. PoctteDo
ID
2
17500
35.
8429
Antimony
Elemental Phosphorus
Fumeee scrubber Slowdown
FMC, PooitaDb
ID
I.1S
17500
203
8429
Annmcny
Sementai Phosphorus
Furnace teruMar Slowdown
Stauftar, Ml Piaasant
TN
0.05
17S00
0.875
8429
Antmony
Elemental Phospnorus
Fumaoa scrubber Slowdown
Suutfar. Mt Piaasant
TN
0.05
t7500
0.875
8429
Antnany
Elemental Phospftofus
Fumaca scrubber bJowdown
Unknown Amaricasn Plant
Unknown
0.016
17500
0.28
8429
Antjmcny
ElamantaJ Phosphorus
Fumaca scrubber blowdown
Unknown Amancwi Plant
Unkncmn
0.016
17500
GJ8
8423
Antimony
Rare Earths
Prooass wastewater
Motycorp. Louv^ars
CO
0.5
117
0.05833
38S
Antimony
Rare Earths
Process wastewater
Mclycorp. Uouvwm
CO
0.5
117
005833
385
Anineny
Selenium
Plant process wastewaters
AMAX, Fort Madison
!A
0-5
550
0.275
63'
Antimony
TantaKim. CoJumbtum. and Ferroeohfmbtufr Process wastewater
Unnamad FacsJtty
Unknown
0.1
4375
0.4375
2517
Ant**cny
Tftamum and Titanium Dioxide
Leach liquid ft sponge wash water Tma*. Henderson
NV
2.5
4000
10,
234i
Anwnony
Titanium and Titanium Oioxtie
Laacn Squid ft sponge waah water Unnamed Psant
Unknown
0.074
4000
0.296
234'
Antimony
Titanium and Titanium OoxxJe
Scrap milling scrubber watar
SCM. Bafcmora
MO
0.5
42
0.02063
340
Annmony
Zinc
Process wastewater
Zinc Corp. BaitiesvUia
OK
0.&33
99187
92 5225
4338*
Anftmony
2inc
Process wastewater
Zinc Corp, Sartlasviiia
OK
0.5
99167
49.58333
43384
Antimony
Zinc
Process wastewater
Zinc Corp. l^onaea
PA
1
99167
49.55333
43384
Antimony
Zinc
Process wastewater
Untewwn
Unknown
0.5
991S7
49 58333
43384
Ansmemy
Zinc
Ffooasa wmitawatf
IMknown
Unkno***
0.5
991S7
49 58333
43384
Antimony
Z«nc
Pnxesa wi itewaier
ZncCorp. Menace
PA
0.155
99167
15.37083
43384
Antimony
Zinc
Proceea wastewater
Zinc Corp. Monica
PA
0.05
99167
4.95833
43384
Antimony
Zmc
wutawttv
Zinc Corp. Monacs
PA
0.05
99167
4 95833
43384
Antmony
Zinc
Prooess wasttwater
Zinc Corp. Baniasvtlia
OK
0.05
99167
4.95833
43384
Antimony
Znc
Prooasa waitawataf
Zsnc Corp. Bartlasvilla
OK
0.05
99167
4.95B33
43384
Anwnany
ZlFiC
f^ocesa wssamew
Zinc Corp, Baitlasvile
OK
0.05
99187
4.95833
43384
Arsene
44 Barytbum
Chip traatmant wastawaiur
Ona Unnamed Faoiiry
Unknown
0.003
*17
000125
558
Arsanie
Coppar
Acid piant bkswetown
Unknown
Unknown
5800
22083
128083.33333
1044"
Arsanic
Coppar
Acid plant bicwOown
Unknown
Unknown
3400
22083
75083.33333
1044?
Arsanie
Coppar
AckJ piam CJowdown
Unknown
Unknown
2410
22083
53220.83333
10441
Arsanc
Coppar
Acid piant biowdown
Unknown
Unknown
700
22083
15458.33333
1044'
Arsenic
Coppar
Acid plant Wowctown
Unknown
Unknown
334
22033
7375.83333
1044-
Arsanc
Coopar
Acid piant biowdown '
Unknown
Unknown
11$
22083
2561.66667
1044'
Arsene
Coppar
Aod piant biowOown
Unknown
Unknown
32.9
22083
726*54167
1044'
Arsanie
Copper
Acid piant ttowdown
Ur*nown
Unknown
30
22083
662.5
1044-
Arsenic
Coppar
Acid piam btowKiown
Unknown
Unknown
5.41
22083
M 9.47083
1044'
Arsene
Copper
Acid piant Wowdown
Unknown
Unknown
3
22083
6625
1044*
Arsanie
Coppar
Acid piant tatowekswn
Unknown
Unknown
3
22083
66 25
1044-
Arcane
Coppar
Acid p^nt Slowdown
Unknown
Unknown
1.5
22083
33125
1044-
Arsanic
Coppar
Acri piant Slowdown
Unknown
Unknown
0.5
22083
11.04167
1044-
Arcane
Coppar
Acid ptant aiowaown
Unknown
Unknown
0.05
22083
1.10417
1044'
Arsenic
Coppar
ptont Slowdown
Unknown
Unknown
0.05
22083
1.10417
1044'
Arsenic
Elemental Phoaphonia
AFM rinaata
Unknown
Unknown
1
167
0.t6667
41!
Afsenie
Elemental Phosphorus
Furnace scfubbar Slowdown
Unlawwn Amancan Plant
Unknown
8.7
17500
152.25
842t
Arsenic
Elemanai Phospnorua
Furnace serubbar Btowdown
Unknown
Unknown
1
17500
17.5
842*.
Arsenc
Elemental Phosphorus
Fumaca scruSber biowqown
Unknown American Piant
Unknown
0501
17500
8-7675
S42S
Arwue
Elemental Phoapnome
Fumaca scrubber btowdown
FMC. Poeatauo
10
0.S
17500
8.75
842:
Arsene
Elemental Ptvaephorus
Furnace scrubber Slowdown
Unknown Amancan P*nt
Unknown
0.4
17500
7.
842«
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Cadmium
Copper
Acad plant blowdown
Unknown
Unknown
to
22083
220.83333
10441
Cad^^ium
Copper
Acid plant Slowdown
. Unknown
Unknown
6
22083
132.5
10441
Cadmium
Copoer
Ac«d plant Slowdown
Unknown
Unknown
5.4
22083
11925
10441
Cadmium
Copper
Acid plant Slowdown
Unknown
Unknown
S
22083
110.41667
10441
Cadmium
Copper
Acid plant biowdown
Unknown
Unknown
1,3
22083
28.70833
10441
Cadmium
Cooo#r
Ac>d plant Slowdown
Unknown
Unknown
1.18
22083
26.05833
10441
Cadmium
Copper
Acid plant Slowdown
Unknown
Unknown
1
22083
22.08333
1G44T
Cadmium
Copper
Aod plant slowdown
Unknown
Unknown
0.52
22083
11.43333
10441
Cadmium
Cooper
Acid plant Wowdown
Unknown
Unknown
0.43
22083
9.49583
10441
Cadmium
Cooper
Acid plant Slowdown
Unknown
Unknown
0.2
22083
4.41667
10441
Cadmium
Elemental Pnosohorus
AFM nnsate
Unknown
Unknown
4
167
0.66667
415
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
FMC. Pocateto
ID
9.6
17500
168.
8429
Cadmium
Elemental Phosphorus
Pumaee scrubber Slowdown
PMC. Pocateito
ID
4.75
17500
83125
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
Unknown
Unknown
4
17500
70.
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
FMC, Poeateiio
ID
3.7
17S00
64 75
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
Unknown American Piant
Unknown
3
17500
52.5
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
Stauffer. Silver Bow
MT
2 86
17500
50.05
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
Unknown American Plant
Unknown
1.9
17$00
33 25
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Moweown
FMC. Poeatefto
ID
1.3
17500
22.75
8429
Cadmium
Elemental Phosphorus
Fgmace scrubber Slowdown
Unknown American Plant
Unknown
0.6675
17500
11.68125
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
FMC. Poeateiio
ID
0.S93
17500
10.3775
8429
Cadmium
Elemental Phosphorus
Fgmace scrubber Slowdown
Stauffer. Mt. Pieasam
TN
0,024
17500 *
0 42
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
Stauffer. Mt. Pleasant
TN
0.005
17500
0 0875
8429
Cadmium
Elemental Phosphorus
Furnace scrubber Slowdown
Unknown American Plant
Unknown
0.001
17500
0.017S
5429
Cadmium
Rare Earths
Process wastewater
D.S. Chemical. Chattanooga
TN
0.054
117
0,0063
385
Cadmium
Rare Earths
Process wastewater
Mofycorp, Louviers
CO
0.05
117
0.00583
3es
Cadmium
Rare Earths
Process wastewater
-Mofycorp. Louviers
CO
0.05
117
0.00583
385
Cadmium
Rare Earths
Procc?* wastewater
D.S. Chemicai. Chattanooga
TN
00005
117
0.00006
385
Cadmium
Selenium
Plant process wastewaters
AMAX. Port Madison
IA
0.05
550
0.0275
631
Cadmium
Selenium
Plant process wastewaters
Cltnax MoTyS.
IA
0.017
550
0.00335
631
Cadmium
Tama turn. Coiumbwm. and FtrrocoJumpmr? Process wastewater
Unnamed FaoJrty
Unknown
0.2
4375
0.875
2517
Cadmium
Titanium and Titanium Dioxide
teach liquid & sponge wash water
Tgnet. Henderson
NV
0-25
4000
t.
2341
Cadmium
Titanium and Titanium Dioiode
Leach liquid & sponge wash water Unnamed Plant
Unknown
0.16
4000
064
2341
Cadmium
Tftanium and Titanium Oowde
Scrap milling sciutfcer water
SCM. Baltimore
MD
0.05
42
0.00208
340
Cadmium
Zinc
Process wastewater
Zinc Corp. Bartiesviile
OK
555
99167
550375
43384
Cadmium
2nc
Process wastewater
Unknown
Unknown
410
99167
40658 33333
43384
Cadmium
Zinc
Process wastewater
Unknown
Unknown
ISO
99167
15866.66667
43384
Cadmium
Zmc
Poxess wastewater
Zinc Corp. Monaca
PA
1T3
99167
11205 83333
43384
Cadmium
Zinc
Process wastewater
Unknown
Unknown
93
99167
9222.5
43384
Cadmium
Zinc
Process waste-water
Unknown
Unknown
71.3
99167
7070.58333
43384
Cadmium
Zinc
Process wastewater
Jersey Mmiere, CiarftsWle
TN
62.5
99T67
6197.91667
43384
Cadmium
Zinc
Process wastewater
Zinc Corp, Bartlesvilie
OK
44
99167
4363.33333
43384
Cadmium
Zmc
Process wastewater
Zsnc Corp, BeniesvUie
OK
38.4
99167
3808.
43384
Caamrum
Zinc
Process wastewater
Jersey Mmiere. Clarttsvtiie
TN
25
99167
2479.16667
43384
Cadmium
Zinc
Process wastewater
Unknown
Unknown
4
99167
396.66667
43384
Cadmium
Z"mc
Process wastewater
ZfK Corp. Monaca
PA
3.09
99167
306425
43384
Cadmium
Zinc
Process wastewater
Zinc Corp. Monaca
PA
2.71
99167
268.74167
43384
Cadmium
Zinc
Process wastewater
Zinc Corp. Bartlesvilie
OK
0.454
99167
45.02167
43384
Cadmium
Zmc
Process wastewater
Zinc Corp. Monaca
PA
0.0562
99167
5.57317
43384
Cadmium
Zmc
Process wastewater
Zmc Com, Qanmv>im
OK
0.0185
99167
1-83458
43384
Cadmium
Zmc
Process wastewater
Unknown
Unknown
0.003
99167
0.2975
43384
Cadm rum
Zmc
Spent surface impoundment liquids Zmc Corp of Ameoca, Monaca PA
40000
10500
420000.
5319
Cadmium
Zme
Spent surface mpoundmertt t
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-------
Mercury
Cocoer
Ac*s plant biowdown
Unknown
Unknown
0 005
22063
011042
10441
Mercury
Copper
Acid plant Wcnwtowm
Unknown
Unknown
0.005
22063
0.H042
1044T
M«n=yry
Copper
Acid plant slowdown
Unknown
Unknown
0.0046
22083
010158
10441
Mercury
Coco#'
Acid plant btowdcmn
Unknown
Unknown
00022
22063
0.04858
10441
Mercury
Copper
Aod plant btawdown
Unknown
Unknown
0.0016
22083
0 03975
10441
Meirury
Elemental Phosphorus
Fumaca scrubber biowdown
Unknown American Plant
Unknown
0.1
17500
1.7S
8429
Mercury
Elemental Phosphorus
Furnace scrubber bkwwSewn
Unknown American Plan?
Unknown
0.05
17500
0.875
842$
Mercury
Elemental Phosphorus
Furnace scrubber biowdown
Unknown American Plant
Unknown
0.0002
17500
0.0035
842S
Mercury
Elemental Phosphorus
Furnace scrubber btowafcwn
Unknown American Plant
Unknown
0.00015
17500
0.00263
8429
Mercury
Elemental Phosphorus
Furnace scrubber bk>w«own
Stauffer, Si^er Bow
MT
0.00012
17500
0.0021
8429
Mercury
Elemental Phosphorus
Furnace scrubber biowdown
FMC. Pocateiio
ID
Q0001
17500
0.00175
8429
Mercury
Elemental Phosphorus
Furnace scrubber btowdewn
Stauffer Mt. Pleasant
TN
0.0001
17500
0.00175
8425
Mercury
Elemental Phosphorus
Furnace scrubber bicwdowr?
Stauffer. Mt. Pleasant
TN
0.0001
17500
0.00175
8429
Mercury
Rare Earths
Process wastewater
Mofycorp. Louviers
CO
0.0001
11?
000001
385
Mercury
Rare Earths
Process wastewater
Mo^coro. Louviers
CO
0.0001
11?
0-00001
365
Mercury
Selenium
Plant process wastewaters
AMAX, Fort Madison
1A
0.00072
550
00004
631
Mercury
Titanium and Titanium Dicwde
Leacn liquid & ^onge wash water Ttnet. Henderson
NV
o.oots
4000
0.0064
2341
Mercury
Titanium and Trtanrum Diowde
Leach liquid & sponge wash watar Unnamed Plant
Unknown
0.0002
4000
0.0006
2341
Mercury
Titanium and Titanium Oioode
Scrap milling scrubber water
SCM. BafMmore
MO
0.0001
42
0.
34C
Mercury
Zrc
Process wastewater
Zinc Corp. Monaca
PA
0
99167
34.51
43384
Mercury
Zinc
Process wastewater
Zinc Corp. Baitiesvilie
OK
0,027*
9916?
2.71717
43384
Mercury
Z*c
Pracmss wastewater
Unknown
Unknown
0.01S
9916?
1 765
43384
Mercury
Zinc
Process wastewater
Zinc Corp. Sartiesvrfie
OK
0.00999
9916?
0.99068
43384
Mercury
Zmc
Process wastewater
Zinc Corp. Monaca
PA
0.00$5
99167
0.64458
43384
Mercury
Zr.c
Preoess wastewater
23nc Corp. Monaca
PA
0.0031
99167
0.30742
43384
Mercury
Zinc
Process wastewater
Zinc Corp. Bartiesviike
OK
0.0019
99167
0.18842
43384
Mercury
Zinc
Process wastewater
Zinc Corp. Bartlesvrile
OK
0.00075
99167
0.07438
43384
Mercury
Z*>c
Process wastewater
Zinc Corp, Monacal
PA
0.0001
9916?
0.00992
43384
Mercury
Zinc
Process wastewater
Zinc Corp. Baitw»«#i»
OK
0.0001
991S?
0.00992
43384
Mercury
Zinc
Process wastewater
Unknown
Unknown
0.0001
99167
0.00992
43384
Mercury
Zinc
Spent surface impoundment Squids 8*g Rwer Zinc
IL
236
10500
2499
S319
Mercury
Zinc
Spent surface impoundment liquids Big Rwer Zinc
IL
3.538
10500
37.149
5319
Mercury
Zinc
Spent surface impoundment liquids Jersey Miniere
TN
1
10500
10.5 •
5315
Mercury
2nc
Spent surface impoundment iJQUKtt 8c
IL
1
10500
tO 5
5319
Mercury
Zne
Spent surface impoundment liquids Big River Zinc
!L
0.1?
10500
1.785
531S
Nickel
43
Beryl Hum
Chip treatment wastewater
One Unnamed Facility
Unknown
0.78
417
0.325
556
Nickel
Cooper
Ae*3 punt Slowdown
Unknown
Unknown
1450
22083
32020.83333
1044*
Nicxei
Copper
Acid plant biowdown
Unknown
Unknown
940
22083
20758.33333
1044-
Nickel
Copper
Acid plant biowdown
Unknown
Unknown
20
22083
441.6666?
1044*
Nickel
Copper
Acid plant Wcwbown
Unknown
Unknown
16
22083
353.33333
1044*
Nickel
Copper
Acid ptam btowdewn
Unknown
Unknown
2
22063
44.1666?
1044"
Nickel
Copper
Acid plant biowdown
Unknown
Unknown
1.95
22083
43.0625
1044-
Nickel
Copper
Acid plant biowdown
Unknown
Unknown
1.8
22083
39.75
1044'
N>c*ei
Copper
Ac«3 piant blcwoown
Unknown
Unknown
1^
22083
26.5
1044"
Nickel
Copper
Acid plant biowdown
Unknown
Unknown
12
22083
265
1C44'
Nickel
Copper
Acid plant biowdown
Unknown
Unknown
0.461
22063
10.62208
1044*
Nickel
Copper
Acid plant biowdown
Unknown
Unknown
0.005
22083
0.11042
1044*
Nickel
Elemental Phosphorus
Fumaoe scrubber biowdown
Unknown Amencan Plant
Unknown
530
17500
9275.
8429
Nj cka<
Elemental Phosphorus
Furnace scrubber biowdown
Unknown Amencan Plant
Unknown
19
17500
3325
842S
Ntckfti
Elemental Phosphorus
Furnace seybeer biowdown
Unknown Amencan Plant
Unknown
1.3
17500
22.75
8429
Nickel
Elemental Phosphorus
Furnace scrubber biowdown
FMC. PocateSo
ID
0.5
17500
8.75
8429
Nickel
Elemental Phosphorus
Fumaoe scrubber biowdown
FMC. Pocateno
10
0.2
17500
35
842S
Nrckei
Elemental Phosphorus
Furnace scrubber btowdewn
Scauffer. Mt. feasant
TN
0.05
17S00
0.875
8429
Nickel
Elemental Phosphorus
Fumase scrubber biowdown
SUuffer, Mt. Pleasant
TN
0.05
17500
0 875
8429
Nickel
Elemental Phosphorus
Fumaoe scrubber btowdewn
Unknown Amencan Plant
Unknown
0009
17500
0.1575
8425
Nickel
Rare Earths
Process wastewater
O.S. Chemical, Chattanooga
TN
4
117
0 4666?
385
Nickel
Rare Earths
Process wastewatar
Morycorp. Lowers
CO
0.5
11?
0.05333
385
Nickel
Rare Earths
Process wastewater
Moiycorp. Louviers
CO
0.5
117
0.05833
38£
Nickel
Rare Earths
Process wastewater
D.S. CNtmeeL Chattanooga
TN
0.006
117
0.00033
385
Nickai
Setenium
Ptam process wastewaters
AMAX. Fort Madwon
LA
0.5
550
0.275 '
63'
Nickel
Selenium
Plant prboeas wastewaters
Climax Mofyb.
IA
0.1
550
0.055
631
Nicked
Tantalum, Coiumbium, and FamreaJumbfunr Process wastewatar
Unnamed Facility
Unknown
1
4375
4,375
25H
Nickel
Titanium and Titanium Dicaode
Uadi fcquid & sponge wash water Unnamed Plant
Unknown
7
*000
•28.
2341
Nickel
Titanium and Titanium Dioxide
Leach Squid A sponge wash water Timet Henderson
W
2.5
4000
10.
2341
Nickel
Titanium and Titanium Dionde
Scrap mlUng scrubber water
SCM. Saitmore
MD
0.5
42
0.02063
34C
Nickel
Zrc
Process wastewater
Znc Corp. Monaca
PA
11
9916?
1041.25
4338*
Nickel
Znc
Process wastewater
Zinc Corp. BartlesviUe
OK
8.12
99167
805.23333
4338*
Nickel
Znc
Prooesa wastewater
Unknown
Unknown
6.3
9916?
624.75
4336*
Nickel
Tmc
Procass wastewater
Zinc Corp, Bartiesvile
OK
1.6
9916?
158.6666?
*338-'
Nickel
Zinc
Procass wastewater
Zinc Corp. BartJesvtfe
OK
0.5
9916?
49.58333
4338*
Nickel
Zinc
Process wastewater
Zinc Corp. Monaca
PA
0.05
99167
4.95833
4338-'
N«kei
Znc
Process wastewater
Zinc Corp. Menace
PA
0.05
9916?
495833
4338<
N»ckei
Zinc
Procass wastewater
Zmc Corp. Monaca
PA
0.05
9916?
495833
4338-
Nicke)
Znc
Procacs wastewater
Zinc Corp. SartlesvfOe
OK
0.05
99167
4.95833
4338-
NrCM)
Zmc
Process wastewater
Zinc Corp. BarttecwUe
OK
0.05
9916?
4.95833
4338-
Ntckei
Znc
Process wastewater
Unknown
Unknown
0.03
99167
2.975
4338-
N«kei
Zinc
Spent surface impoundment liquids Big fliw Zinc
IL
257
10500
26985
5315
N
-------
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Zhe
Zmc
Process wasttwttar Unknown
Unxnown
3
99167
297.5
43384
Zmc
Zjnc
Spent surface mpoundment liquids Zinc Corp o< America. Monaca PA
800000
' 10500
8400000
5319
Zjrc
Zme
Spent surface tnpoundment liquids Zrc Com of A/nenca. Menace PA
650000
1050G
6625000.
53*9
Lnc
Zmo
Spam surface impoundment liquids Big River Zinc
ft
539000
10500
$184500.
5319
Zinc
Z>nc
Spent surfaoe «npoundment liquids Zinc Corp of America. Monaca PA
500000
10500
S250000.
5319
25C
Zinc
Spam surface mpoundmem liquids Zinc Core of Amenca, Monaca PA
300000
10S00
3150000.
5319
Zme
Zmc
Spam surface tnpoundmant liquids Big River Zinc
fl.
52000
10500
546000.
S319
Zm c
Zme
Spent surface moounorrant liquids Zinc Corp of Amanca. Monaca PA
10000
10500
105000.
5319
Zn c
Zinc
Spent surface impeunameri! liquids Jersey Mmiere
TN
6100
10500
64050.
5319
Zmc
Zmc
Spent surface impoundment liquids Jersey Miniere
TN
3400
10500
35700.
5319
Zmc
Zmc
Spent surfaoe mpoundment liquids Zinc Corp of Amehca
OK
2430
10500
25515.
5319
Zmc
Zmc
Spent surfaoe mpgyndmtm liquids Zinc Corp of Amanca
OK
1400
10500
14700,
5319
Z*»c
Zmc
Spent surface mpoundment liquids Zhc Corp at America
OK
t400
10500
14700.
5319
Zinc
Zmc
Spent surfaoe mpoundment iiqum Brines
Smut
Banun
3
Alumina and Aiumnum
Cast house dust
Sam*n
Magna**** and Magnesia from Sanaa
Smut
Barun
Magnesium and Magnesia frc
sm Brines
Smut
Cadmium
3
Alumna and Aluminum
Cast house dust
Cadmium
Magnesium and Magnesia frc
jm Bnnes
Smut
Cadmium
Magnesium and Magnasia from Annas
Smut
Chromium
3
Alumina and Aiumnum
Cast houae dust
Chromium
Magnesium and Magnesia fit
>m Bmes
Smut
Chromium
Magnesium and Magnesia from Brines
Smut
lead
3
Alumna and Aiumnum
Cast house dust
lead
Magnesium and Magnasia fit
*r Bmea
Smut
Laid
Magnesium and Magnesta ft
*n Bnnes
Smut
Mercury
3
AJumina and Aiumnum
Cast house dust
Mercury
Magnesium and Magnasia At
m Bnnes
Smut
Mercury
May>esium and Magnasia frc
im Bmes
Smut
Nickel
1
Alumina and Aiumnum
Cut house dust
Settflium
3
Alumna and Aiumnum
Cast house duet
Selenium
Magnesium and Magna** Ire
im Bnnes
Smut
Selenium
Magnesium and Magnasia fre
m Brinea
Smut
Sifter
3
Alumina and Aluminum
Casthoueedust
Silver
Magnesium and Magnesai from BHnaa
Smut
Silver
Megneeium and Magnesai frc
m Brines
Smut
Zinc
3
Aiumna and AJuminum
Cast houae dust
Zne
Magnesium and Mayes ta from Bmes
Smut
Zinc
Magnesium and Magnesai ho
m Bnnes
Smut
Concentration
Volume of
Mass per
Area of
nLeeehate
Waste Pile
Waste Pile
waste Pile
Facility Identifier
State
(m*)
m
(m3)
SD
(5)
Facilities Surveyed
Unknown
042
107
1.21984
10€
Facilities Surveyed
Unknown
0.001
107
0.0029
10*
Unknown American Plant
Unknown
0.65
1871
29.56881
67£
Unknown American Plant
Unknown
0.1
1671
4.54905
676
Facilities Surveyed
Unknown
0.28
107
0.81323
ICS
Unknown American Plan?
Unknown
140
1871
6778 08037
676
Unknown American Plans
Unknown
14.9
1671
677.80804
676
Facilities Surveyed
Unknown
3.5
107
10.16537
tCf
Unknown American Piam
Unknown
0.027
1671
1.22824
67€
Unknown American Plant
Unknown
0.01
1671
p.4549
676
Facilities Surveyed
Unknown
0.086
107
0.24978
ICE
Unknown American Plant
Unknown
0.054
1671
2.45649
676
Unknown American Plant
Unknown
0.023
1671
1.04628
67C
Facilities Surveyed
Unknown
0.024
107
0.06971
1«
Unknown American Plant
Unknown
3.64
1671
165.58532
676
Unknown American Plant
Unknown
0.0(3
1671
1.95609
67€
Facilities Surveyed
Unknown
084
107
2.43969
10*
Unknown American Plant
Unknown
0.001
1671
0.04549
67C
Unknown Amenean Plant
Unknown
0.0008
167?
0.03639
m
Facilities Surveyed
Unknown
0.74
107
2.14925
106
Facilities Surveyed
Unknown
0.001
107
0.0029
1«
Unknown American Plant
Unknown
0.016
1671
0.72785
cn
Unknown Amencan Plant
Unknown
0.013
1671
0.59138
67<
Facilities Surveyed
Unknown
0.15
107
0.43566
ia
Unknown American Plant
Unknown
0.14
1671
6 36867
6*
Unknown American Plant
Unknown
0.05
1671
2-27452
67-
Facilities Surveyed
Unknown
0.58
107
1.68455
105
Unknown American Plant
Untexswn
0.6®
1671
3138843
674
Unknown American Plant
Unknown
0.02
1671
0.90961
67'
EP Analysis Samples. Wastewaters and liquid P
Constituent Volume o<
Leachable
Constituent
Constituents
Anomcny
Antimony
Aiwrtony
Antimony
Arasmony
AfWony
Antimony
Antimony
Antimony
Antimony
Anamony
Annmony
Concentration
Surface
Mass in Surface
Surface
nLeeehate
Impoundment
impoundment
Impounaner?!
Commodity
Waste Stream
Faolity identifier
State
imgtI)
(m*)
(3)
m
(6)
(»*)
Copper
Acid ptant btowdewn
Cyprus. Cisy Pool
AZ
5
22063
215.3125
1044
Copper
Acid plant totowdown
Karmecotl Bingham Canyon
UT
0.168
22083
7.2345
1044
Elemental Phosphorus
AFM rinsate
Unknown
Unknown
0 2
167
0.06S
4?:
EfemantaJ Phosphorite
Furnace scruOOer Wowdown
Unknown
Unknown
1.8
17500
$46
642
Elemental Phosphorus
Fumaoe aenfcoer WowGown
Unknown
Unknown
1.17
17500
39.92625
842
Elemental Phosphorus
Fumaoe scrubber {slowdown
Unknown
Unknown
0.47
17500
16.03875
842
Elemental Phosphows
Furnace acrufeber Slowdown
Unknown
Unknown
OJ*
17500
5.46
842
Elements) Phoaphoms
Fumaoe scrubber btowdown
Untowwn
Unknown
0.16
17500
5.46
842
Elemental Phosphorus
Fumaoe scrubber btowdown
Unknown
Unknown
0.05
17500
1.70625
842
Elemental Phosphorus
Furnace scrubber btowbawn
Unknown
Unnnewn
0.05
17500
1.70625
842
Rare Earths
Prooess wastewater
Unknown
Unknown
0.5
117
0.11375
3£
Ram Earths
Process wast ewttar
Untexrwn
Unknown
0.5
117
0.11375
38
Apr! 15.1997
-------
Antimony
Rara Earths
Proceas wastewater
Unknown
Unknown
0.5
117
0.11375
382
Antimony
Rare Eanns
Prooess wastewater
Unknown
Unknown
0.5
11?
0.11375
3B£
Antimony
Rare Earths
Process wastewater
Unknown
Unknown
0.5
117
0.U375
38;
Antimony
Rare Earths
Process wastewater
Unknown
Unknown
0.S
117
0.11375
38 £
Antimony
Selenium
Plant process wastewaters
Unknown
Unknown
0.5
550
0.53625
63'
Antimony
Selenium
Plant process wastewater?
Unknown
Unknown
0.5
550
0.53625
631
AfHimorry
Selenium
Plant process wastewaters
Zinc Corp of Amend. Monaca PA
0.5
550
0.53625
63*
Antimony
Tantalum. CotumtHum, and FefToootumbrurr Process wastewater
Unknown
Unknown
0.224
4375
1.911
251?
Antimony
Tantalum, CoJumbiym, and Ferrocaumbiun Process wastewater
Unknown
Unknown
0.05
4375
0.42656
25'-"
Antimony
Tantalum, Coium&iym, and Ferrocoiumbrun Process wastewater
Unknown
Unknown
005
4375
0.42656
251-
Antimony
Tantalum, Cdumb'um, ana Farroooiumbiur? Process wastewater
Unknown
Unknown
0.05
4375
0.42656
2517
Antimony
Tantalum. Cdumfeium, and FtrroeoiomCiurf Process wastewater
Unknown
Unknown
0.06
4375
0.4265$
251?
Antimony
Tantalum. Columbtum, and Ferrocolumeiurr Process wastewater
Unknown
Unknown
0.05
4375
042656
2517
Arsenic
49
Copper
Acid plant biowdown
Magma. San Manuel
AZ
12800
22083
551200.
1044'
Arsenic
Copper
Acid plant biowdown
CBJ
CBl
193
22083
83U 0625
1044?
Arsenic
Copper
Acid plant biowdown
CBJ
CBt
126
22063
5425-875
1044?
Arsenc
Cooper
Acid plant biowdown
Kennecon. Bmgham Canyon
UT
32 8
22063
141245
1044'
Arsenc
Copper
Aod plant Slowdown
Kennecetl Bmgham Canyon
UT
31.1
22083
1339.24375
1044*
Arsenc
Copper
Acid plant Slowdown
Magma. San Manuel
AZ
299
22063
1287.56875
1044'
A/seme
Copper
Acid plant Wowdown
CBl
CBl
21-6
22063
930.15
10441
Arsenic
Copper
Acid plant {slowdown
CBl
CBl
14.1
22083
607.18125
1044'
Arsenc
Copper
Ac*3 plant !>Jowdown
Magma. San Manuel
AZ
11.2
22063
462.3
1044?
Arsenc
Copper
Acid plant wowtJown
Cyprus. Clay Pool
AZ
5
22083
215.3125
10441
A/senc
Copper
Acid plant blowdown
cm
CBl
0.19
22063
8 18168
1044'
Arsenic
Copper
Acid plant slowdown
cm
CBl
0.18
22063
775125
1044*
Arsenc
Copper
Acid plant Wowdown
Magma. San Manuel
AZ
0.05
22083
2.15313
1044*
Arsenc
Copper
Arid plant bto»*Sown
Magma, San Manuel
AZ
0.05
22083
2.15313
1044".
Arsenic
Copper-
Acid plant Biowdown
Magma. San Manual
A2
0.0*
22083
1.7225
1044"
Arsenc
Elemental Phosphorus
AJTM msate
Unknown
UrWnown
0.14
167
0 0455
4'5
Arsenc
Eiementai Phosphorus
Furnace scrubber {slowdown
Unknown
Unknown
0.543
17500
16.S2966
8429
Arsenc
Elemental Phosphorus
Furnace scrubber biowdown
Unknown
Unknown
0.15
17500
5.11675
S42S
Arsenc
Elemental Phosphorus
Furnace scrubber btowdown
Unknown
Unknown
0.0619
17500
2.11234
842?
Arsenc
Elemental Phosphorus
Furnace scrubber biowdown
Unircwn
Unknown
005
17500
1.70625
842S
Arsenc
Elemental Phosphorus
Furnace scrubber Slowdown
Unknown
Unknown
0.05
17500
1 70625
842?
Arsenc
Elemental Phosphorus
Furnace scrubber biowdown
Unknown
Unknown
0.00125
17500
004266
842<
Arsenic
Rare Earths
Process wastewater
Unknown
Unknown
497
117
1.13068
385
Arsenc
Rare Earths
Process wastewater
Unknown
Unknown
1.1
117
0-25025
3S5
Arsenc
Rare Earths
Process wastewater
Unknown
Unknown
0.945
117
0.21499
385
Arsenc
Rare Earths
Process wastewater
Unknown
Unknown
05
117
0.11375
365
Arsenc
Rare Earns
Process wastewater
Unknown
Unknown
0.5
117
0.11375
385
Arsenc
Rare Earths
Process wastewater
UnWiown
Unknown
0.5
117
0.11375
385
Arsenic
Selenium
Plant process wastewater*
Unknown
Unknown
0.S
550
0.53625
63"
Arsenc
Selenium
Ptam process wastewaters
Unknown
Unknown
0.5
550
0.53625
63'
Arsenc
Tantalum. Columbtum. arid Ferrocolumbiurr Process wastewater
Unknown
Unknown
0.5
4375
4 26563
2517
Arsenic
Tantalum. Columbtum, and Ferrooelumbiun Process wastewater
Zinc Corp of America, Moneca PA
0.5
4375
426563
2517
Arsenc
Tantalum, Coium&iym, and Ferreceiumbiun Process wastewater
Unknown
Unknown
0.15
4375
127969
2517
Arsenic
Tantalum. Goturntoum, and Ferrocoiumbturr Process wastewater
Unknown
Unknown
0.132
" 4375
1.12613
251"
Arsenic
Tantaium. CoJumb«jm. and FerrocolumpHar Process wastewater
Unknown
Unknown
005
4375
C.42656
2517
Arsenic
Tantalum. Coium&um. and Fem?oolymb«unr Process wastewater
Unknown
Unknown
0.05
4375
0.42656
2517
Arsenc
Tantalum. CoJumotum. and Ferroeotumpiurt Process wastewater
Unknown
Unknown
0.05
437S
0.42656
2517
Arsenc
Tantalum. Coiumbmm. and Femocofumbtun Process wastewater
Unknown
Unknown
0.05
4375
0.42656
2517
Arsenc
Tantalum. Coium&wm. and Femocotumb«urr Process wastewater
Unknown
Unknown
0.05
4375
042656
2517
Arsenc
Tantalum, Coiumtoum. and Fanoooiumpmn Process wastewater
Unknown
Unknown
0,05
4375
0-42656
251?
Arsenc
Tantalum. Co)umtxum. and Fanocoiumbiurr Process wastewater
AMAX. East SI Louts
1L
0.05
4375
0.42656
2517
Arsenic
Tantalum, CoJumOn*n, and Femscclumonirr Process wastewafar
Unnamed Plant
Unknown
0.027
4375
0.23034
251?
Arsenic
Tilanwm and Titanium DioxXJe
Leach §Quid 4 sponge wash water Unknown
Unknown
0.01
4000
0.078
234*
Arsenc
Titanium and Titanium Dioxide
Leach liquid & sponge wash water
Unknown
Unknown
0.01
4000
0.078
234*
Arsenic
Titanium and Titanium Dioxide
Leach Squid & sponge wash water Unnamed Ptam
Unknown
0.005
4000
0039
234*
Arsenic
Titanium and Titanium Dio&de
Uacfcliqiad 4 sponge wash water Unnamed Plant
Unknown
0.003
4000
00234
234*
Arsenc
Titanium and Titanium Draode
Leach liquid 6 sponge wash waier
Unknown
Unknown
0.002
4000
0.0156
234"
Arsenc
Titanium and Titanium Dioxide
Serap milling scrubber water
Unknown
Unknown
0.02
42
0,00163
m:
Arsenc
Titanium and Taarnum D-canda
Scrap milling scrubber water
Unknown
Unknown
0.0125
42
0.00102
34C
Serum
51
Copper
Acid plant biowdown
CBl
CBl
10.9
22083
469.38125
1044*
Barium
Copper
Acid piant biowdown
CBl
CBl
9.6
22083
413.4
1044-
Barnn
Copper
Ac^ plant biowdown
Cyprva, Gay Pool
AZ
5
22063
215.3125
1044"
Barium
Copper
Acid piant biowdown
Magma. San Manuel
AZ
5
22063
215.3125
1044-
Banum
Copper
Acid ptam biowdown
Magma. San Manuel
AZ
5
22083
215.3125
1044-
Banum
Capper
Acid plant biowdown
CBl
CBl
0.i
22083
34 45
1044*
Barium
Copper
Acid plant biowdown
Magma. San Manuel
AZ
0.4
22063
17225
1044'
Banum
Copper
Acid plant biowdown
CBl
CBl
0.4
22063
17225
1044-
Bantm
Copper
Ac*s plant biowdown
CBl
CBl
0-3
22083
12.91875
1044'
Banum
Copper
Acid plant Wowdown
Magma. San Manuel
AZ
03.
22083
6.6125
1044-
Bangm
Copper
Acid plant biowdown
CBl
CBJ
0 2
22083
8.6125
1044-
Banirn
Copper
Acid plana slowdown
Kenneooit Bingham Canyon
UT
0.136
22083
5.6565
1044
Banum
Copper
Acid plant biowdown
Magma. San Manuel
AZ
0.1
22063
430625
1044
Barium
Copper
Acid plant biowdown
Kennecott. Bingham Canyon
UT
0.05
22063
2.15313
1044
Banum
Copper
Acid pant biowdown
Ma^na. Sar Manuel
AZ
0.05
22083
2.15313
1044
Banum
Elemental Phosphorus
AFM rinsate
Unknown
Unknown
' 1
167
0.325
41:
Barrun
Elamemal Phosphorus
Fumaoe scrubber Wowdown
Unknown
Untewwn
12
17500
40.95
642'
Banum
Elemental Phosphorus
Furnace ScrubOer slowdown
Unknown
Unknown
1
17500
34.125
842
Banum
Elemental Phoephorvta
Furnace aerubber biowdown
Unknown
Unknown
0.81
17500
27.64125
842
Ban^n
Elemental Phosphorus
Fumaoe scrubber biowdown
Unknown
Unknown
0.25
17500
6.53125
842:
Banum
Elemental Pheephonis
Fumeoe scrubber biowdown
Unknown
Unknown
0.2
17500
6.825
642
Banum
Elemental Phosphorus
Fumaoe scrubber biowdown
Unknown
Unknown
0.05
17500
1.70625
842
Banum
ElamemaJ Phosphorua
Fumaoe acruboer bkMtiown
Unknown
Unknown
0.05
17500
1.70625
842
Banum
RareEartfia
Procesa wastewater
UrdcxJwn
Unknown
10
117
2275
38
Banuft
Rare Earths
Process wastewater
Unnamed Plant
Unknown
6
117
t.365
38
Banun
Rare Eanna
Process wastewater
Unknown
Unknown
5
117
1.1375
38
Banum
Rare Eartha
Process wastewater
Unnamed Plant
Unknown
3.7
117
0.84175
3£
Banum
Ram Earn*
Procesa wastewater
Unknown
Unknown
12
117
0273
3£
April IS, 1997
-------
S n t t t t t- J ^ t '• I- M- k M. h K h K K i- r<
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-------
J-11
Cadmium
Titanium and Titanium Oonde
Leach Souid 6 sponge wash wa
iter Unknown
Unknown
0.007
4000
00546
234
Ceomium
Titanium and Titanium OoxKtt
Laaeh uqu«3 6 sponge wash water Unknown
Unknown
0 005
4000
0.039
234
Cadmium
Tttanmm and Titanium Otonda
LMeh liquid 4> sponge wash water Unknown
Unknown
0.003
4000
0.0234
234
Caanium
Titan mm and Titanium Ooad*
Sera? moling scrubber water
Unknown
Unknown
0-03
42
0.00244
34
CMmurn
Titanium and Titanium Dioxide
Scrap milling scrubber water
Unhnown
Unknown
0.025
42
0.00203
3*
Chromium
48
Coco*
Acid plant Slowdown
Cyprus. Clay Poof
AZ
5
22083
215.3125
1044
Chromium
Copper
Ac>d plant btowdown
Kenneoott. Bmgham Canyon
UT
0.254
22083
10.93788
1044
Chromium
Copper
Acid plant biowdown
Magma. Sen Manuel
AZ
0-25
22083
10.76563
1044
Chromium
Coop*
Ac»o plant Slowdown
Kennecoct. Bingham Canyon
UT
0.241
22083
10.37806
1044'
Chromium
Copoer
Ac id plant Slowdown
Magma. San Manuel
A2
0.171
22083
7.36369
1044
Chromium
Cooper
Actd piant btow#down
Magma. Sen Manuel
AZ
0.1
22083
4.30625
1044
Chromium
' Copoer
Acid plant Slowdown
CSl
CBI
0.029
22083
1-24881
1044
Chromium
Copper
Acid plant btowdown
Magma. San Manuel
AZ
0.029
22083
1-24881
1Q44
Chromium
Copper
Actd plant biowdown
C8J
CBI
0.024
22083
1.0335
1044
Chromium
Copper
Acid piant bWwdown
C8I
CBI
0.008
22083
03445
104*
Chromium
Copper
Acid pU^t biewdown
Magma. San Manuel
AZ
0.005
22083
0.21531
1044
Chromium
Copper
Acid piam biewdown
Magma. San Manuel
AZ
0.005
22083
0.21531
1044'
Chromium
Copper
Acid plant Slowdown
CBi
CBI
0.005
22083
0.21531
1044
Chromium
C0PP*f
Acid plant btowdown
CBJ
CBI
o.oos
22083
0.21531
1044-
Chromium
CflOP*
Acid plant (slowdown
CBI
CBI
0.003
22083
0.12919
1044
Chromium
Elemental Phosphorus
AFM msara
Unknown
Unknown
0-278
167
0.09035
41:
Chromium
Elements! Phosphorus
Furnace semt&er btowdown
Unknown
Unknown
09
17500
30.7125
ur
Chromium
Elemental Phosphorus
Furnace scrubber Wowdown
Unknown
Unknown
0.841
17S00
28.69913
842-
Chromium
Elemental Phosphorus
Furnace scrubber Slowdown
Unknown
Unknown
0.5
17500
17.0625
842'
Chromium
Elemental Phosphorus
Furnace scrubPer biowdown
Unknown
Unknown
0.22
17500
7.5075
842
Chromium
Elemental Phosphorus
Fumaoe scrubber Slowdown
Unknown
Unknown
0.05
17500
1.70625
842!
Chromium
Elemental Phosphorus
Fumace scrubber biowdown
Unknown
Unknown
0.05
17S00
1.70625
842;
Chromium
Elwwitii Phosphorus
Furnace scrubber Wowdown
Unknown
Unknown
0.005
17500
0.17063
842-
Chromium
Bar* Earths
Process wmstawtier
Unknown
Unknown
6.45
117
1-46738
38.
Chromium
Rasa Earths
Procesa wastewater
Unknown
Unknown
0.5
117
0.11375
36.
Chromium
Rare Earths
Process wastawater
Unknown
Unknown
0.5
117
011375
38:
Chromium
flam Earths
Process wastewater
Unknown
Unknown
0.5
117
0.11375
38:
Chromium
Selenium
Plant procMi wastewater*
Unknown
Unknown
0-5
550
0-53625
63
Chromium
Seleniurn
Pfant process wastewaters
Unknown
Unknown
0.5
550
0.53625
63
Chromium
Selenium
Plant proms wastewaters
Unknown
Unknown
0.5
550
0.53625
63
Chromium
Tantalum. Coiumbium, and Ferrocolumsiun Procesa wastewater
Snc Corp of Amenca. Monaea
I PA
0.5
4375
4 26563
251"
Chromium
Tantalum, Cdum&wm. and FerocolumbiurT Prooess wastewater
Unknown
Unknown
0 111
4375
0.94697
25''
Chromium
Tantalum, Coiumbium. and Ferrooolumbiurr Process wrastewatar
Unknown
Unknown
0.08
4375 •
0.6825
251
Ch ram rum
TantaJum, Coiumbium, and FenoooiumSiufT Process wastewater
Unknown
Unknown
0.08
4375
0.6825
251"
Chromium
Tantalum. Coiumbium, and Ferroeotumbiurr Procesa wastewater
Unknown
Unknown
0.079
4375
0.67397
25*
Chromium
Tantalum, Coiumbium, and Ferroeefumsiufr Process wastewater
Unirown
Unknown
0.05
4375
0.42656
251
Chromium
Tantalum. Coiumbium, and F*rocoiumb>uff Process wastewater
Unknown
Unknown
0.05
4375
0.42656
25V
Chromrum
Tantalum. Cpiumbium. and Ferroco*umb«urr Process wastewater
Unknown
Unknown
0.05
4375
0.42656
25 V
Chromium
Tantalum. Coiumbium. and Ferroootombiurr Process wastewater
Unknown
Unknown
006
4375
0.42656
25V
Chromium
Tantalum, Coiumbium. and Ferroeolum&urT Process wastewater
Unknown
Unknown
0 05
4375
0.42656
251'
Chromium
Tantalum, Coiumbium, and FerrooolumbtufT Process wastewater
Unknown
Unknown
0.038
4375
0-33272
25V
Chromium
Tantalum, Coiumbium, and FerroooiumbiurT Process wastewater
Unknown
Unknown
003
4375
0.25594
25V
Chromrum
Titanium and Tttmum Ooxxto
Leech liquid & sponge wash wa!
er Unnamed Plant
Unknown
0.012
4000
0.0936
234
Chromium
Titanium and Ttanium Diosde
Leecf) kwd & sponge wash wat
er Unknown
Unknown
0.005
4000
0,039
234
Chromium
Titanium and Titanium Dioxide
Leach Hquid & sponge wash wat
er Unnamed Ptarn
Unknown
0.001
4000
0.0078
234
Chromium
Titanium and Titanium OpwJt
Leach liquid & sponga wesh wait
er Unnamed Plant
Unknown
0.0Q1
4000
0.0078
234
Chromium
Titanium and Taanwm Dwaode
Scrap miting sciubber wetar
Unknown
Unknown
0.027
42
0.00219
34:
Chromium
Titanium and Tianrum Dtoaode
Scrap miiing scrubber water
AMAX. East St. Louis
IL
0.025
42
0.00203
34-
LMd
44
Copper
Acid pant btowdown
Kennecott Bingham Canyon
UT
6.74
22083
290.24125
1044
LMd
Casmm
Actd plant blowdown
Kanoecott. Brgnam Canyon
UT
6.47
22083
278.61438
1044
Uad
CoptW
Ac*3 plant biowdown
Magma. San Manuel
AZ
5.71
22083
24588688
1044
Lead
Copper
Acid plant tttowdo^wn
Magma. San Manuel
AZ
3.8
22083
163 6375
1044
Lead
Copper
Aeid plant btowdown
Magma. Sen Manuel
AZ
3.73
22083
160.62313
1044
uia
Copper
Acid ptont btowdown
C8I
CBI
2.89
22083
12445063
1044
LMd
OPPftef
Acid plant biowdown
CBt
CBI
2.55
22083
10980938
1044
LMd
Copper
Acid plant btowdown
Cyprus, Clay Pool
AZ
2.5
22083
107 65625
1044
lead
Copper
Acid plant btowdown
Magma. San Manuel
AZ
2.5
22083
107.65625
1044-
Lead
Copper
Acid plant btowdown
C8t
CBI
2.49
22083
107 22563
1044
LMd
Oxxm
Acid plant btowdown
C8I
ca
1.74
22083
7492875
1044
LMd
Copper
Ac* plant btowdown
CBJ
ca
0.896
22063
38.584
1044
LMd
Copper
Acid ptent btowdown
Magma. San Manual
AZ
0.25
22963
10.76563
1044
LMd
Copper
Acid plant btowdown
Magma. San Menu*
AZ
02
22083
8 6125
1044
LMd
Cepper
Acid pant btowdown
CBI
CBI
0.042
22083
1.80863
1044
LMd
Elemental Phosphorus
AFM matte
Unknown
Unknown
0.19
167
0.06175
41
LMd
Elements Phoephorue
Furnace scrubber btowdown
Unknown
Unknown
0.42
17500
14.3325
842-
LMd
Elemental Ptwaphoftti
Furnace scrubber btowdown
Unloiown
Unknown
0.42
17500
14.3325
842
LMd
Elemental Phosgftarua
Fymaoa scrubber Slowdown
Unknoiwi
Unknown
0.357
17500
12.18263
842
LMd
Elemental Phoephorue
Furnace scrubber btowdown
Untowwn
Unknown
0.217
17500
7.40513
842
LMd
Elemental Phosphorus
Furnace scrubber btowdown
Unknown
Unknown
0.125
17500
4.26563
842
LMd
Elemental Phosphorus
Fumaoe scrubber btowdown
Unknown
Unknown
0.11
17500
3.75375
842
LMd
Rare Earths
Procesa wastewater
Unknown
Unknown
2.5
117
056875
38
LMd
Rare Earths
Process wastewater
Unnamed Pism
Unknown
236
117
.0.5369
38
LMd
Rare Earths
Process wastewater
Unknown
Unknown
1.99
117
0,45273
38
LMd
Raie Earns
P't^em wastewater
Unknown
Unknown
1
117
0-2275
38
LMd
Selenium
Plant procMS wastewaters
AMAX, East SL Louia
IL
1
550
1.0725
S3
LMd
Selenium
Plant process wastewater!
Unknown
Unknown
0.629
550
067353
63
LMd
Tantalum. Coiumbium. and FernxoturnCMsr Prooasa wastewater
Unknown
Unknown
0.562
4375
4.79456
251
LMd
Tantalum, Coiumbium. and Pvrxckrrtmjr
Procesa wastewater
Unknown
Unknown
0.25
4375
2 13281
251
LMd
TantaJum, Coiumbium. and Femacofamfciurr Process wcstewatar
Unknown
Unknown
0.25
4375
213281
251
LMd
Tantalum. Coiumbium, and Ferroooiumbiurr Process wastewater
Unknown
Unknown
0.25.
4375
2.13281
251
LMd
Tantalum, Coiumbium, and FerrooolumbMr
Procesa wastewater
Unknown
Unknown
0-2S
4375
213281
25*
LMd
Tantalun. Coiumbium, and FerroeoiumtMun
Process wastewater
Unxnown
Unknown
0221
4375
188541
251
LMd
Tamaium. Coiumbium. and FerroooiumbiUT Process wastewater
Unknown
Unknown
0-141
4375
120291
251
LMd
TantaJum. Coiumbium. and Ferroookmbiurt
Process wastewater
Unknown
Unknown
0.1
4375
0.85313
25'
LMd
Tantalum. Cotumbium. end ramscao*umt>iun
Procesa wastewater
Unknown
Unknown
6.098
4375
0.83606
251
April 15,199?
-------
Lead
Tantalum. Cdumbmm. and Femxoiumfaui? Process wastewater
Unknown
Unknown
0.025
4375
021328
2517
L*«CI
Tantalum. Ccxumbmrn. ana FerrocolumbiurT Process wastewater
Unknown
Unknown
0.025
4375
0.21328
2517
Lead
Tamaium. Cdumbmm. and Ferrecdumbiun Process wastewater
Unknown
Unknown
0.02
4375
0ir063
2517
LMd
Titanium and Titanium Dicwde
Leach Squid & sponge wash water Unknown
Unknown
0.01
4000
0.078
2341
LMd
Titanium and Titanium Dioxide
Leach ftjuki 4 sponge wash water Unknown
Unknown
0.005
4000
0.039
2341
L*ld
Tftanium and Titanium Oonde
Scrap milling scrubber water
Unknown
Unknown
0.016
42
00013
340
UMd
Trtanram and Titanium D*o»de
Soap milling scmober watef
Unknown
Unknown
oot
42
0.00081
340
Mercury
47
Cooper
Acid ptant Slowdown
CBI
CBI
0.31
22063
13.34936
10441
Mercury
Copper
Acid plant Stowdowm
CBI
CBI
02$
22083
11.19625
10441
Mercury
Copper
Acid plant blowdown
Magma. San Manuel
A2
0.0223
22083
0.96029
10441
Mereury
Copper
Ac <3 plant blowdown
Kennecott Bingham Canyon
UT
0.0115
22083
0 49522
10441
Mercury
Copper
Acid plant Slowdown
Magma. San Manuel
A2
Q.Qt
22083
0 43063
10441
Mercury
Copper
Acid plant Slowdown
Kennecott BiA^vam Canyon
UT
0.00?
22063
0.30144
10441
Mercury
Copper
Acid plant slowdown
Magma, San Manuel
A2
0.005
22063
0.21531
10441
Mercury
Copper
Acid plant slowdown
Magma. San Manuel
AZ
0.005
22083
0.21531
10441
Mercury
Copper
Acid plant btowdown
Magma. San Manuel
A2
0.005
22063
0.21531
10441
Mercury
Copper
Acid plant blowdown
CBi
CBi
0.0013
22063
0.05596
10441
Mercury
Copoof
Acd plant blowdown
CBi
CBi
0.0013
22083
0 05596
10441
Mercury
Copper
Acid plant stawdown
Magma. San Manuel
AZ
0.0004
22063
0 01723
10441
Mercury
Copper
Acid plant Slowdown
CBI
CBI
0.0003
22083
0.01292
10441
Mercury
Copper
Acid piam Slowdown
CBI
CBI
0.0003
22063
0.01292
10441
Mercury
Copper
Aod plant Blowdown
Cyprus. Clay Pod
A2
0.0001
22083
0.00431
10441
Mercury
Elemental Phosphorus
AFM msaie
Unknown
Unknown
0.0005
167
0.00016
415
Mercury
Elemental Phosphorus
Furnace scrubber blowdown
Unknown
Unknown
0.0005
17500
0.01706
8429
M
Elemental Phosphorus
Futnac* scrubber Slowdown
Unknown
Unknown
0.00015
17500
0.00512
8429
Mercury
Elemental Phosphorus
Fumaoe scrubber blowdown
Unknown
Unknown
0.00015
17500
0.00512
8429
Mercury
Eiememaf Phosphorus
Fumaca scrubber blowdown
Unknown
Unknown
0.0001
17500
000341
8429
Mercury
Elemental Phoephorus
Fumaoe scrubber blowdown
Unknown
Unknown
0.0001
17500
0.00341
8429
Mercury
Elemental Phosphorus
Furnace scrubber blowdown
Unknown
Unknown
0.0001
17500
0-00341
8429
Mercury
Rare Earths
Prooess wastewater -
Unknown
Unkriown
0.0065
117
0.00148
385
Mercury
Rare Earns
Process wastewater
Unnamed Ptant
Unknown
0.0029
117
0.00066
385
Mercury
Rare Earths
Process wastewater
Unknown
Unknown
0.0024
117
0 00055
385
Mercury
Raf» Earths
Process wastewater
Unknown
Unknown
0.0024
117
0.00055
385
Mercury
Rare Earths
Process wastewater
Unnamed Plant
Unknown
0.0023
117
0.00052
385
Mercury
Ram Earths
Prooess wastewater
Unknown
Unknown
0.0011
117
0.00025
385
Mercury
Selenium
Plant process wastewaters
Unknown
Unknown
0.001
550
0.00107
631
Mercury
Selenium
Plant process wastewaters
Unknown
Unknown
0.001
550
0.00107
631
Mercury
Seieruum
Ptart prooess wastewater
Unknown
Unknown
0.00068
550
0.00094
631
Mercury
Tantalum. Coiumbium, and FenocokimbkmPfocw wastewater
Unknown
Unknown
0.00028
4375
0.00239
2517
Mercury
Tantalum, Cotumdum. and FerrecoiumOiun Process wastewater'
Unknown
Unknown
0.0001
4375
0.00085
2S17
Mercury
Tantalum. Cdumbwm, and FerrocolumbiurT Prooess wastewater
Unknown
Unknown
0.0001
4375
0.00085
2517
Mercury
Tantalum. Cdumbnjm, and Feffocdumbtun Prooess wastewater
Unknown
Unknown
0.0001
4375
o.oooas
2517
Mercury
Tantalum, Cdumdum, and Ferroodumdun Process wastewater
Unknown
Unknown
0.0001
4375
0.00065
2517
Mercury
Tantahjm. Cdumbkm. and Ferrcootumpiun1 Process wastewater
Unknown
Unknown
0.0001
4375
000065
251-
Mercury
Tantalum, Commduro, and Ferroodumdunr Process wastewater
Unknown
Unknown
0.0001
4375
000065
251"
Mercury
TamaJum. CoKimdum, and F#rroceiumbiufT Process wastewater
Unknown
Unknown
0.0001
4375
0.00065
251:
Mercury
Tantalum. Cdumdum. and FsfroooJum&wrr Process wastewater
Unknown
Unknown
0.0001
4375
000085
25V
Mercury
Tantalum, CoiumOmm. and FerrocolumbiurT Process wastewater
Unknown
Unknown
0.0001
4375
0.00085
251
Mercury
Tamalum, Cotumb*B"n, and Ferrooofumdun Process wastewater
Unknown
Unknown
0.0001
4375
o.oooas
25'
Mercury
Tantalum. Co*um&»um. ^ FerroooiumduiTPi-Qoess wastewater
Unknown
Unknown
00001
4375
0.00085
251
Mercury
Titanium and Titanium Dioxide
Leach liquid & sponge wash water
Zinc Corp d Amenca, Monad
PA
0.0001
4000
0.00078
234
Mercury
Titanium and Titan rum Decode
leach liquid & sponge wash water
AMAX EastSt. Louie
IL
0.00005
4000
0.00039
234
Mercury
Titanium and Taanium Dionde
Scrap mJSrg scrubber water
Unknown
Unknown
0.0001
42
0.00001
3^
Mercury
Titanium and Tcanium Otoxide
Scrap roiling scrubber vMter
Untowwn
Unknown
0.0001
42
0.00001
34
NiduM
22
Copper
Acid plant biowdowm
Cyprus. City Pod
AZ
5
22083
21513125
104*
Nicket
Copper
Add Mutt blowdown
KenneeotL Bingham Canyon
UT
0.466
22083
20 06713
104*'
Nickel
Copper
Acid plant Slowdown
Magma. San Manuel
AZ
0.02
22083
0.86125
104-
Nickel
Elemental Phosphorus
AFMrinsate
Unknown
Unknown
0.06
167
0.Q26
4
Nickel
Elemental Phosphorus
Furnace scrubber blowdown
Unknown
Unknown
025
17500
8.53125
84
Nickel
Elemental Phasj*orua
Furnace serubbar Slowdown
Unknown
Unknown
0.165
17500
5.63063
84
Nickel
Elemental Phosphorus
Fumaos scrubber blowdown
Unknown
Unknown
0.05
17500
1.70625
84
Nickel
Eiementai Phosphorus
Fumaee seubber Sowdown
Unknown
Unknown
0.05
17500
170625
Bt
Ntcfcel
Elemental Phosphorus
Furnace scrubber blowdown
Unknown
Unknown
0.03
17500
1.02375
8*
Nickel
Elemental Phoephorua
Fumace scrubber Slowdown
Unknown
Unlrown
0.015
17500
Q.51188
Nickel
Rare Earths
nnnw niienssr
Unknown
Unknown
0.5
117
011375
N«*ei
Rare Earths
Process wastewater
Unknown
Unknown
0.5
117
0.11375
Nickel
Rare Earns
Prooees wastewater
Unknown
Unknown
0.17
117
0.03868
Nickel
Rara Earths
Process wastewater
Unknown
Unknown
0.17
117
0.03868
Nickel
Seier>um
PWs prooess wastewaters
Unknown
Unknown
005
550
0 05363
i
Nickel
Sdenium
Plant process wastewaters
Unknown
Unknown
0.05
550
005363
Nickel
Tantalum, CoMndwn, and reraodumbMT Process wastewater
Unknown
Unknown
0.05
4375
042656
2
NduM
Tantalum, Cofcjmdum, and Ferrooofcim&iurr Procesi wastewater
Unknown
Unknown
0.05
4375
0.42656
2
N**ei
Tantalum. Columdum. and Ferroodu
nfrur "i?. ill Tf*f—if*
Unknown
0.05
4375
0.42656
2
N«*ei
Tantalum, Cdumdum, and Perrpodufflbiurr Prooses waste >wuer
Unknown
Unknown
0.05
4375
042656
I
Nk*ei
Tantalum. CoMndum, and Ferroooiumbiuri Process wastewater
Unknown
Unknown
0.031
4375
0.26447
<
Nickel
Tantalum, Cdumdum. and Ferroodumdurr Process wastewater
Unknown
Unknown
0.004
4375
0.03413
Seienrum
4?
Copper
Add plam Slowdown
Magma. San Manuel
AZ
7.63
22063
326.56688
Selenium
Copper
Aeid plant Slowdown
Cyprus, Clay Pod
AZ
5
22063
215.3125
Selenium
Copper
Add plant blowdown
Magma. San Manud
AZ
29
22083
12488125
1
Selenium
Copper
Add plant Slowdown
Karmeooe. Bingham Canyon
UT
0.668
22063
28.76575
1
Selenium
Copper
Add plant blowdown
CBI
CBI
0-61
22063
26.26813
t
Selenium
Copper
Add plant biowaown
KannecoB, Bttgftvn Canyon
UT
0.444
22063
19.11975
1
Setenum
Copper
Addptsmbkaitiown
C8i
CBI
0.28
22063
12.0575
i
Seiemum
Copper
Add plant stowctowt
CBI
CBI
0.18
22063
6.89
Sdenwm
Copper
Add plant blowdown
CBI
CBI
0.16
22063
6.89
Selenium
Copper
Acid plant blowdown
CBI
est
0.068
22063
2.92825
Selenium
Copper
Acid plant HNdow)
Magma, San Manual
AZ
0.05
22063
2.15313
Selenium
Copper
Add plant slowdown
Magma. San Manuel
AZ
0.05
22063
2.15313
SeMnum
Copper
Add plent Slowdown
Magma. San Manuel
AZ
0.05
22063
215313
Selenium
Copper
Add plant Slowdown
CBI
cm
0.028
22063
1.20675
April 15,1997
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