DRAFT DEVELOPMENT  DOCUMENT
          Including the  Data Base for
EFFLUENT LIMITATIONS GUIDELINES (BATEA),
 NEW SOURCE PERFORMANCE STANDARDS,
                      and
        PRETREATMENT STANDARDS
                    for the
  INORGANIC CHEMICALS MANUFACTURING
          POINT SOURCE CATEGORY
                   Prepared for

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

               Robert B. Schaffer. Director
               Effluent Guidelines Division

               G. E. Stigall, Acting Branch Chief
               Inorganic Chemicals Branch

               E. E. Martin
               D. Hlustick
               Project Officers

            CONTRACT  NO. 68-01-4492

                       BY

        JACOBS ENGINEERING GROUP INC
        JACOBS ENVIRONMENTAL DIVISION
            251 SOUTH  LAKE AVENUE
          PASADENA  CALIFORNIA 91101
                   APRIL 1979

-------
     DRAFT DEVELOPMENT DOCUMENT
          Including the Data Base for
EFFLUENT LIMITATIONS GUIDELINES (BATEA),
 NEW SOURCE PERFORMANCE STANDARDS,
                    and
        PRETREATMENT STANDARDS
                   for the
  INORGANIC CHEMICALS MANUFACTURING
         POINT SOURCE CATEGORY
                 Prepared for

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

               Robert B. Schaffer, Director
               Effluent Guidelines Division

               G. E. Stigall, Acting Branch Chief
               Inorganic Chemicals Branch

               E. E. Martin
               D. Hlustick
               Project Officers

           CONTRACT NO. 68-01-4492

                     BY

       JACOBS ENGINEERING GROUP INC.
       JACOBS ENVIRONMENTAL DIVISION
            251 SOUTH LAKE AVENUE
          PASADENA, CALIFORNIA 91101

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                             NOTICE

     This document is  a DRAFT CONTRACTOR'S REPORT.   It  includes
technical information  submitted by the Contractor to the  United
States  Environmental  Protection  Agency  (EPA)   regarding   the
subject industry.  It is being distributed for review and comment
only.  The report is not an  official EPA publication and it  has
not been reviewed by the Agency.

     The report  will  be  undergoing  extensive  review  by EPA,
Federal  and State  agencies, public interest organizations,  and
other interest groups and persons during the coming  weeks.

     The regulations  to  be  published  by  EPA  under  Sections
301 (d) , 304 (b), and 306 of the  Federal  Water Pollution  Control
Act,  as amended,  will be  based in part, on the  report and the
comments received on it.  EPA will also  be  considering economic
and  environmental  impact information  that  is being developed.
Upon completion of  the  review and evaluation of  the technical,
economic, and  environmental information, an EPA  report  will be
issued at the time of proposed rule-making  setting   forth  EPA's
preliminary  conclusions regarding  the  subject industry.  These
proposed  rules  will include  proposed effluent  guidelines  and
standards, standards of performance,  and  pretreatment standards
applicable   to  the   industry.    EPA  is  making    this  draft
contractor's  report   available   to   encourage  broad,  public
participation, early in the rule-making process.

     The report  shall  have  standing in  any  EPA  proceeding or
court proceeding only to the extent that it represents  the views
of the Contractor who  studied the subject industry  and  prepared
the information.  It cannot be cited, referenced, or  represented
in any  respect  in any such  proceedings as a statement of EPA's
views regarding the subject industry.
                  U.S.  Environmental Protection Agency
                  Office of Water and Hazardous Materials
                  Effluent Guidelines Division
                  Washington, D.C.  20460

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                     TABLE OF CONTENTS
                                                           Page
      LIST OF FIGURES                                       xiv
      LIST OF TABLES                                       xxii
1.0   CONCLUSIONS AND SUMMARY                                  1
      1.1   PRIORITY POLLUTANTS                                1
      1.2   CONTROL AND TREATMENT TECHNOLOGY                   1
      1.3   COSTS OF ADDITIONAL IN-PLANT TREATMENT             2
      1.4   SUBCATEGORIZATION                                  2
      1.5   RESTUDY OF REMANDED REGULATIONS                    3
2.0   RECOMMENDATIONS                                          4
3.0   INTRODUCTION                                             5
      3.1   AUTHORITY                                          5
            3.1.1   The Federal Water Pollution Control        5
                     Act Amendments
            3.1.2   Court Remand of Regulations                6
            3.1.3   The Settlement Agreement                   8
      3.2   GENERAL APPROACH AND METHODOLOGY                  16
            3.2.1   Industry Data Base Development and        16
                     Subcategorization Review
            3.2.2   Screening and Verification Sampling       17
                     Programs
            3.2.3   Engineering Evaluations                   17
            3.2.4   Treatment Systems Cost Estimates          17
4.0   SUBCATEGORIZATION REVIEW                                18
      4.1   BASIS FOR SUBCATEGORIZATION                       18
            4.1.1   Factors Considered                        18
            4.1.2   General Conclusions                       21
      4.2   SECONDARY SUBCATEGORIZATION                       21
            4.2.1   Chlor-Alkali                              21
            4.2.2   Titanium Dioxide                          22
            4.2.3   Hydrogen Cyanide                          23
                             111

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                 TABLE OF CONTENTS (continued)
      4.3   INTEGRATION OF SUBCATEGORIES                      23
            4.3.1   Hydrofluoric Acid and Aluminum            23
                     Fluoride

      4.4   SUMMARY                                           24

5.0   SCREENING AND VERIFICATION SAMPLING PROGRAMS            25

      5.1   SCOPE AND METHODOLOGY                             25
            5.1.1   Selecting Plants and Making               26
                     Preliminary Contacts
            5.1.2   Screening and Verification Sampling       27
            5.1.3   Analytical Methodology for Priority       28
                     Pollutants
            5.1.4   Quality Assurance Provisions              35

      5.2   THE BASIS FOR VERIFICATION SAMPLING               36

      5.3   THE VERIFICATION PROGRAM                          37

6.0   PROCESS AND WASTE TREATMENT INFORMATION DEVELOPMENT     38
      AND EVALUATION

      6.1   INDUSTRY DATA BASE DESCRIPTION                    38

            6.1.1   Data Acquisition                          38

      6.2   PROCESS WASTE SOURCES AND CURRENT TREATMENT       41
            PRACTICES

            6.2.1   Data Acquisition                          41
            6.2.2   Evaluation of Data                        41
            6.2.3   Model Plant and BPT Treatment System      42
                     Specification
            6.2.4   Dissolved Solids in Waste Water           43
                     Effluents

7.0   TREATMENT AND CONTROL ALTERNATIVES FOR ADVANCED         44
      LEVEL APPLICATIONS

      7.1   TREATMENT TECHNOLOGY ASSESSMENT                   44

            7.1.1   Introduction                              44
            7.1.2   Hydroxide Precipitation                   45
            7.1.3   Ferrite Co-precipitation                  50
            7.1.4   Sulfide Precipitation                     50
            7.1.5   The Xanthate Process                      52
            7.1.6   -Ion Exchange                              54
            7.1.7   Reduction Processes                       55
            7.1.8   Oxidation Processes                       57
                              IV

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                 TABLE OF CONTENTS  (continued)
            7.1.9   Membrane Processes                        59
            7.1.10  Adsorption                                62
            7.1.11  Fluoride Removal                          64

8.0   TREATABILITY ESTIMATES AND LONG TERM DATA ANALYSIS      66

      8.1   THE DEVELOPMENT OF TREATABILITY ESTIMATES         66

      8.2   THE USE OF HISTORICAL POLLUTANT DATA              80

            8.2.1   Determination of Enforcement Guide-       80
                     lines Based Upon Historical
                     Performance
            8.2.2   Assumptions Concerning 30-Day Average     81
                     Pollutant Level Measurements
            8.2.3   Variability Factor for Daily Samples      81
            8.2.4   Variability Factor for 30-Day Averages    82

9.0   TREATMENT TECHNOLOGY APPLICATIONS FOR PRIORITY          84
      POLLUTANT REMOVAL

      9.1   SELECTION OF POLLUTANTS TO BE CONTROLLED          84

      9.2   APPLICATION OF ADVANCED LEVEL TREATMENT AND       84
            CONTROL ALTERNATIVES

            9.2.1   General Design Objectives                 84
            9.2.2   Pretreatment Technology                   87
            9.2.3   New Source Performance Standards          87

      9.3   ESTIMATED ACHIEVABLE PERFORMANCE CHARAC-          87
            TERISTICS FOR ADVANCED LEVEL APPLICATIONS

            9.3.1   Advanced Level Removal of BPT             88
                     Pollutants
            9.3.2   Advanced Level Removal of Priority        88
                     Pollutants

10.0  COSTS OF TREATMENT AND CONTROL SYSTEMS                  89

      10.1  INTRODUCTION                                      89

            10.1.1  Purpose of Cost Data                      89
            10.1.2  General Approach                          90
            10.1.3  Cost References and Rationale             90
            10.1.4  Definition of Levels of Treatment         91
                     and Control Cost Development
            10.1.5  Treatment and Disposal Rationale          91
                     Applied to Cost Development
            10.1.6  Expression of Costs                       92

      10.2  COST ESTIMATES FOR EACH SUBCATEGORY               99
                               v

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                   TABLE OF  CONTENTS  (continued)

                                                             Page


 11.0   CHLOR-ALKALI  INDUSTRY                                 10°

        11.1  ASSESSMENT OF  THE WATER POLLUTION POTENTIAL -
              MERCURY CELL                                    10°
              11.1.1   Industry Profile and Analytical         100
                       Results
              11.1.2   Process Waste Sources and Waste Water   100
                       Treatment Data

        11.2  TECHNOLOGY BASED POLLUTION ABATEMENT            127

              11.2.1   Advanced Level  Treatment                127
                       Applications
              11.2.2   Estimated Performance of BPT Systems    131
              11.2.3   Estimated Performance of Advanced       135
                       Level Systems
              11.2.4   Cost Estimates                           138

        11.3  ASSESSMENT OF  THE WATER POLLUTION POTENTIAL -   145
              DIAPHRAGM CELL
              11.3.1   Industry Profile and Analytical         145
                       Results
              11.3.2   Process Waste Sources                   154

        11.4  TECHNOLOGY BASED POLLUTION ABATEMENT            174

              11.4.1   Advanced Level  Treatment Applications   174
              11.4.2   Estimated Performance of BPT Systems    179
              11.4.3   Estimated Performance of Advanced       181
                       Level Systems
              11.4.4   Cost Estimates                           184

12.0    HYDROFLUORIC  ACID INDUSTRY                            194

        12.1  ASSESSMENT OF  THE WATER POLLUTION POTENTIAL     194

              12.1.1   Industry Profile and Analytical         194
                       Results
              12.1.2   Process Waste Sources and Waste Water   197
                       Treatment Data

        12.2  TECHNOLOGY BASED POLLUTION ABATEMENT            219

              12.2.1   Advanced Level  Treatment Applications   219
              12.2.2   Estimated Performance of BPT Systems    226
              12.2.3   Estimated Performance of Advanced       233
                       Level Systems
              12.2.4   Cost Estimates                           237

13.0    HYDROGEN PEROXIDE INDUSTRY                            253

        13.1  ASSESSMENT OF  THE WATER POLLUTION POTENTIAL     253

              13.1.1   Industry Profile and Analytical         253
                       Results

                               vi

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                  TABLE OF CONTENTS  (continued)

                                                            Page

14.0   TITANIUM DIOXIDE INDUSTRY                             256

       14.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     256
             OF THE CHLORIDE PROCESS

             14.1.1  Industry Profile and Analytical         256
                      Results
             14.1.2  Process Waste Sources and Waste         259
                      Water Treatment Data
       14.2  TECHNOLOGY BASED POLLUTION ABATEMENT            275

             14.2.1  Advanced Level Treatment                275
                      Applications
             14.2.2  Base Level Performance Character-       280
                      istics for BPT Pollutant Removal
             14.2.3  Estimated Performance of Advanced       283
                      Level Systems
             14.2.4  Cost Estimates - Chloride Process       286
       14.3  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     293
             OF THE SULFATE PROCESS
             14.3.1  Industry Profile and Analytical         293
                      Results
             14.3.2  Process Waste Sources and Waste         296
                      Treatment Data

       14.4  TECHNOLOGY BASED POLLUTION ABATEMENT            310
             14.4.1  Advanced Level Treatment                310
                      Application
             14.4.2  Base Level Performance Character-       311
                      istics for BPT Pollutant Removal
             14.4.3  Estimated Performance for               318
                      Advanced Level System
             14.4.4  Cost Estimates - Sulfate Process        321

15.0   ALUMINUM FLUORIDE INDUSTRY                            328

       15.1  ASSESSMENT OF THE WATER POLLUTION
             POTENTIAL                                       328
             15.1.1  Industrial Profile and Analytical       328
                      Results
             15.1.2  Process Waste Sources and Waste         333
                      Water Treatment Data

       15.2  TECHNOLOGY BASED POLLUTION ABATEMENT            347

             15.2.1  Advanced Level Treatment                347
                      Applications
             15.2.2  Estimated Performance of BPT            353
                      Systems

                               vii

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                  TABLE OF CONTENTS  (continued)

                                                            Page

             15.2.3  Estimated Performance of Advanced       355
                      Level Systems
             15.2.4  Cost Estimates                           359

16.0   CHROME PIGMENTS INDUSTRY                              376

       16.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     376
             16.1.1  Industry Profile and Analytical         376
                      Results
             16.1.2  Process Waste Sources and Waste         380
                      Water Treatment Data
       16.2  TECHNOLOGY BASED POLLUTION ABATEMENT            400
             16.2.1  Advanced Level  Treatment                400
                      Applications
             16.2.2  Estimated Performance of BPT Systems    403
             16.2.3  Estimated Performance of Advanced       407
                      Level Systems
             16.2.4  Cost Estimates                           407

17.0   HYDROGEN CYANIDE INDUSTRY                             417

       17.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     417
             OF THE ANDRUSSOW PROCESS
             17.1.1  Industry Profile and Analytical         417
                      Results
             17.1.2  Process Waste Sources and Waste         422
                      Water Treatment Data

       17.2  TECHNOLOGY BASED POLLUTION ABATEMENT            434
             17.2.1  Advanced Level  Treatment                434
                      Applications
             17.2.2  Estimated Performance of BPT Systems    435
             17.2.3  Estimated Performance of Advanced       444
                      Level Systems
             17.2.4  Cost Estimates                           447

18.0   SODIUM DICHROMATE INDUSTRY                            454

       18.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     454
             18.1.1  Industry Profile and Analytical         454
                      Results
             18.1.2  Process Waste Sources and Waste         459
                      Water Treatment Data

       18.2  TECHNOLOGY BASED POLLUTION ABATEMENT            470
             18.2.1  Advanced Level  Treatment                470
                      Applications

                             viii

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                  TABLE OF CONTENTS (continued)

                                                            Page

             18.2.2  Estimated Performance of BPT Systems    474
             18.2.3  Estimated Performance of Advanced       478
                      Level Systems
             18.2.4  Cost Estimates                          478

19.0   CARBON DIOXIDE INDUSTRY                               487

       19.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     487

             19.1.1  Industry Profile and Analytical         487
                      Results

20.0   CARBON MONOXIDE AND BY-PRODUCT HYDROGEN               490
       INDUSTRY

       20.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     490
             20.1.1  Industry Profile and Analytical         490
                      Results

21.0   COPPER SULFATE INDUSTRY                               493

       21.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     493
             21.1.1  Industry Profile and Analytical         493
                      Results
             21.1.2  Process Waste Sources and Waste         497
                      Water Treatment Data

       21.2  TECHNOLOGY BASED POLLUTION ABATEMENT            503
             21.2.1  Advanced Level Treatment                503
                      Applications
             21.2.2  Estimated Performance of BPT Systems    507
             21.2.3  Estimated Performance of Advanced       509
                      Level Systems
             21.2.4  Cost Estimates                          512

22.0   NICKEL SULFATE INDUSTRY                               515

       22.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     515

             22.1.1  Industry Profile and Analytical         515
                      Data
             22.1.2  Process Waste Sources and Waste         520
                      Water Treatment Data

       22.2  TECHNOLOGY BASED POLLUTION ABATEMENT            529

             22.2.1  Advanced Treatment Applications         529
             22.2.2  Estimated Performance of BPT Systems    533

                              ix

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                  TABLE OF CONTENTS (continued)

                                                             >age
             22.2.3   Estimated Performance of Advanced       533
                      Level  Systems
             22.2.4   Cost Estimates                           536

23.0   SILVER NITRATE INDUSTRY                               544

       23.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     544

             23.1.1   Industry Profile and Analytical         544
                      Results

24.0   SODIUM BISULFITE INDUSTRY                             547

       24.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     547
             24.1.1   Industry Profile and Analytical         547
                      Results
             24.1.2   Process Waste Sources and Waste         552
                      Water  Treatment Data
       24.2  TECHNOLOGY BASED POLLUTION ABATEMENT            560
             24.2.1   Advanced Level  Treatment                560
                      Applications
             24.2.2   Estimated Performance of BPT            565
                      Systems
             24.2.3   Estimated Performance of Advanced       567
                      Level  Systems
             24.2.4   Cost Estimates                           571

25.0   SODIUM HYDROSULFITE                                   578

       25.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     578

             25.1.1   Industry Profile and Analytical         578
                      Results
             25.1.2   Process Waste Sources and Waste         581
                      Water  Treatment Data
       25.2  TECHNOLOGY BASED POLLUTION ABATEMENT            590

             25.2.1   Advanced Level  Treatment                590
                      Applications
             25.2.2   Estimated Performance of BPT Systems    595
             25.2.3   Estimated Performance of Advanced       598
                      Level  Systems
             25.2.4   Cost Estimates                           598

26.0   HYDROCHLORIC  ACID INDUSTRY                            602

       26.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     602
             26.1.1   Industry Profile and Analytical         602
                      Results
                              x

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                  TABLE OF CONTENTS  (continued)

                                                             Page

27.0   NITRIC ACID INDUSTRY                                   605

       27.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      605
             27.1.1  Industry Profile and Analytical          605
                      Results

28.0   SODIUM CARBONATE INDUSTRY  (SOLVAY PROCESS)             608

       28.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      608
             28.1.1  Industry Profile and Analytical          608
                      Results

29.0   SODIUM METAL INDUSTRY                                  611

       29.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      611
             29.1.1  Industry Profile and Analytical          611
                      Results

30.0   SODIUM SILICATE INDUSTRY                               614

       30.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      614
             30.1.1  Industry Profile and Analytical          614
                      Results

31.0   SULFURIC ACID INDUSTRY                                 617

       31.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      617
             31.1.1  Industry Profile and Analytical          617
                      Results

32.0   AMMONIUM CHLORIDE INDUSTRY                             620

       32.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      620
             32.1.1  Industry Profile and Analytical          620
                      Results

33.0   AMMONIUM HYDROXIDE INDUSTRY                            623

       33.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      623
             33.1.1  Industry Profile and Analytical          623
                      Results
                             XI

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                  TABLE OF CONTENTS  (continued)
                                                             Page

34.0   BARIUM CARBONATE INDUSTRY                              626
       34.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     626
             34.1.1  Industry Profile and Analytical          626
                      Results
35.0   BORIC ACID INDUSTRY                                    629
       35.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     629
             35.1.1  Industry Profile and Analytical          629
                      Results
36.0   CALCIUM CARBONATE INDUSTRY                             632
       36.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     632
             36.1.1  Industry Profile and Analytical          632
                      Results
37.0   CUPROUS OXIDE INDUSTRY                                 635
       37.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     635
             37.1.1  Industry Profile and Analytical          635
                      Results
38.0   MANGANESE SULFATE INDUSTRY                             638
       38.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     638
             38.1.1  Industry Profile and Analytical          638
                      Results
39.0   STRONG NITRIC ACID INDUSTRY                            641
       39.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     641
             39.1.1  Industry Profile and Analytical          641
                      Results
40.0   OXYGEN AND NITROGEN INDUSTRY                           644
       40.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL     644
             40.1.1  Industry Profile and Analytical          644
                      Results
                             Xll

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                  TABLE OF CONTENTS  (continued)

                                                             Page

41.0   POTASSIUM IODIDE INDUSTRY                              647

       41.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      647

             41.1.1  Industry Profile and Analytical          647
                      Results

42.0   SODIUM HYDROSULFIDE INDUSTRY                           650

       42.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      650
             42.1.1  Industry Profile and Analytical          650
                      Results

43.0   SODIUM SILICOFLUORIDE INDUSTRY                         653

       43.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      653
             43.1.1  Industry Profile and Analytical          653
                      Results

44.0   SODIUM THIOSULFATE INDUSTRY                            656

       44.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      656
             44.1.1  Industry Profile and Analytical          656
                      Results

45.0   SULFUR DIOXIDE INDUSTRY                                659

       45.1  ASSESSMENT OF THE WATER POLLUTION POTENTIAL      659
             45.1.1  Industry Profile and Analytical          659
                      Results
       REFERENCES                                            662

       BIBLIOGRAPHY                                          667

       ACKNOWLEDGEMENTS                                      671

       APPENDIX A                                            A-l
                               XI11

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                         LIST OF FIGURES

                                                            Page

5-1    Sample flow sheet for metals                           30

7-1    Solubility of metal hydroxides and sulfides            47

7-2    Electrodialysis process                                61

11-1   General process diagram for production of chlorine/   108
       caustic by mercury cells

11-2   General process flow diagram at Plant #299 showing    112
       the sampling points.  Chlorine/Caustic (Mercury
       Cell)  Manufacture

11-3   General process flow diagram at Plant #747 showing    115
       the sampling points.  Chlorine/Caustic (Mercury
       Cell)  Manufacture

11-4   General process flow diagram at Plant #167 showing    117
       the sampling points.  Chlorine/Caustic (Mercury
       Cell)  Manufacture

11-5   General process flow diagram at Plant #317 showing    118
       the sampling points.  Chlorine/Caustic (Mercury
       Cell)  Manufacture

11-6   Waste water treatment Level 1 for chlorine-           129
       mercury cell subcategory

11-7   Waste water treatment Level 2 for chlorine-           130
       mercury cell subcategory

11-8   Annual treatment cost vs. production for the          142
       Chlorine Subcategory (Mercury Cell Process)

11-9   Annual unit treatment cost vs. production for the     143
       Chlorine Subcategory (Mercury Cell Process)

11-10  General process flow diagram for production of'        156
       chlorine/caustic by diaphragm cells

11-11  General process flow diagram at Plant #001 showing    159
       the sampling points.  Chlorine/Caustic (Diaphragm
       Cell)  Manufacture

11-12  General process flow diagram at Plant #261 showing    162
       the sampling points.  Chlorine/Caustic (Diaphragm
       Cell)  Manufacture
                               xiv

-------
                   LIST OF FIGURES (continued)


11-13  General process flowsheet at Plant #738 showing       164
       the sampling points.  Chlorine/Caustic
       (Diaphragm Cell)  Manufacture

11-14  General process flow diagram at Plant #738 showing    165
       the sampling points.  Chlorine/Caustic
       (Diaphragm Cell)  Manufacture

11-15  General process flow diagram at Plant #967 showing    167
       the sampling points.  Chlorine/Caustic
       (Diaphragm Cell)  Manufacture

11-16  General process flow diagram at Plant #736 showing    168
       the sampling points.  Chlorine/Caustic
       (Diaphragm Cell)  Manufacture

11-17  Waste water treatment Level 1 for chlorine -          176
       diaphragm cell subcategory

11-18  Waste water treatment Level 2 for chlorine-           177
       diaphragm cell subcategory

11-19  Waste water treatment Level 3 for chlorine -          178
       diaphragm cell subcategory

11-20  Annual treatment cost vs. production for the          190
       Chlorine Subcategory (Diaphragm Cell Process)

11-21  Annual unit treatment cost vs.  production for the     191
       Chlorine Subcategory (Diaphragm Cell Process)

12-1   General process flow diagram for production of        202
       hydrofluoric acid

12-2   General process flow diagram at Plant #705 showing    208
       the sampling points.  Hydrofluoric Acid Manufacture

12-3   General process flow diagram at Plant #251 showing    211
       the sampling points.  Hydrofluoric Acid Manufacture

12-4   Production versus waste flow data for HF plants       213

12-5   Waste water treatment Level 1 for hydrofluoric        221
       acid subcategory

12-6   Waste water treatment Level 2 for hydrofluoric        222
       acid subcategory

12-7   Waste water treatment Level 3 for hydrofluoric        223
       acid subcategory

-------
                   LIST OF FIGURES (continued)

                                                            Page

12-8   Waste water treatment Level 4 for hydrofluoric        224
       acid subcategory

12-9   Waste water treatment new source performance          225
       standard for hydrofluoric acid subcategory

12-10  Annual treatment cost vs. production for the          242
       Hydrofluoric Acid Subcategory

12-11  Annual unit treatment cost vs. production for the     243
       Hydrofluoric Acid Subcategory

12-12  Annual treatment cost vs. production for the          250
       Hydrofluoric Acid Subcategory (NSPS)

12-13  Annual unit treatment cost vs. production for the     251
       Hydrofluoric Acid Subcategory (NSPS)

14-1   General process diagram for production of titanium    264
       dioxide (chloride process)

14-2   General flow diagram at Plant #559 showing the        267
       sampling points.  Titanium Dioxide  (Chloride
       Process)  Manufacture

14-3   General flow diagram at Plant #172 showing the        270
       sampling points.  Titanium Dioxide  (Chloride
       Process)  Manufacture

14-4   Waste water treatment Level 1 for titanium dioxide -  277
       chloride process

14-5   Waste water treatment Level 2 for titanium dioxide -  278
       chloride process

14-6   Waste water treatment Level 3 for titanium dioxide -  279
       chloride process

14-7   Annual treatment cost vs. production for the          290
       Titanium Dioxide Subcategory, Chloride Process

14-8   Annual unit treatment cost vs. production for the     291
       Titanium Dioxide Subcategory, Chloride Process

14-9   General process flow diagram for production of        299
       Titanium Dioxide by sulfate process

14-10  General flow diagram at Plant #559 showing the        303
       sampling points.  Titanium Dioxide  (Sulfate Process)

                               xv i

-------
             LIST  OF  FIGURES  (continued)
14-lte water  treatment  Level  1  for titanium dioxide -  312
    fate  process

14-lte water  treatment  Level  2  for titanium dioxide -  313
    fate  process

14-lual treatment  cost  vs.  production for the          325
    anium Dioxide  Subcategory,  Sulfate Process

14-Jual unit  treatment  cost vs.  production for the     326
    anium Dioxide  Subcategory,  Sulfate Process

15-Jeral  process flow diagram for  production of        334
    minum fluoride

15-2eral  process flow diagram at Plant #705 showing    339
     sampling points.   (Aluminum Fluoride Manufacture)

15-^eral  process flow diagram at Plant #605 showing    341
     sampling points.   Aluminum Fluoride Manufacture

15-^duction vs. Unit Waste  Flow for Aluminum           343
    oride Manufacture

15-fte water  treatment  Level  1  for aluminum fluoride   349
    -category

15-(te water  treatment  Level  2  for aluminum fluoride   350
    >category

15-ite water  treatment  Level  3  for aluminum fluoride   351
    >category

15-;te water  treatment  Level  4  for aluminum fluoride   352
    >category

15-mal treatment  cost  vs.  production for the          363
    uninum Fluoride Subcategory

15-iual unit  treatment  cost vs.  production for the     364
   iminum Fluoride Subcategory

15-cect of variation of pollutant  load on treatment    367
   3t at  level 1 technology

15-Eect of variation of pollutant  load on treatment    368
   st at  level 4 technology
                        xvi i

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                   LIST OF FIGURES (continued)

                                                            Page

15-13  Effect of variation of hydraulic load on treatment    371
       cost at level 2 technology

15-14  Effect of variation of hydraulic load on treatment    372
       cost at level 3 technology
      •

15-15  Effect of variation of hydraulic load on treatment    373
       cost at level 4 technology

16-1   General process diagram for production of anhydrous   383
       chrome oxide

16-2   General process diagram for production of hydrated    384
       chromic oxide

16-3   General process diagram for production of chrome      385
       yellow

16-4   General process diagram for production of molybdate   387
       orange

16-5   General process diagram for production of chrome      388
       green

16-6   General process diagram for production of zinc        390
       yellow

16-7   General process diagram for production of chrome      392
       pigment complexes

16-8   General waste water treatment process flow diagram    395
       at Plant #894 showing the sampling points.  (Chrome
       Pigment Manufacture)

16-9   General waste water treatment process flow diagram    397
       at Plant #002 showing the sampling points.  (Chrome
       Pigment Manufacture)

16-10  Waste water treatment Level 1 for chrome pigments     401

16-11  Waste water treatment Level 2 for chrome pigments     402

16-12  Annual treatment cost vs. production for the Chrome   414
       Pigments Subcategory

16-13  Annual unit treatment cost vs. production for the     415
       Chrome Pigments Subcategory
                              xvi 11

-------
                   LIST OF FIGURES (continued)

                                                            Page

17-1   General process flow diagram for production of        424
       hydrogen cyanide by the Andrussow Process

17-2   General waste water treatment process flow diagram    427
       at Plant #765 showing the sampling points.  (Hydrogen
       Cyanide Manufacture)

17-3   General waste water treatment process flow diagram    430
       at Plant #782 showing the sampling points.
       (Hydrogen Cyanide Manufacture)

17-4   Waste water treatment Level 1 for hydrogen cyanide    436
       subcategory

17-5   Waste water treatment Level 2 for hydrogen cyanide    437
       subcategory

17-6   Annual treatment cost as a function of production for 451
       the Hydrogen Cyanide Subcategory

17-7   Annual unit treatment cost as a function of produc-   452
       tion for the Hydrogen Cyanide Subcategory

18-1   General process diagram for production of sodium      461
       dichromate

18-2   General waste water treatment process flow diagram    464
       at Plant #493 showing the sampling points.
       (Sodium Dichromate Manufacture)

18-3   General waste water treatment process flow diagram    466
       at Plant #376 showing the sampling points.  (Sodium
       Dichromate Manufacture)

18-4   Waste water treatment Level 1 for sodium dichromate   472
       subcategory

18-5   Waste water treatment Level 2 for sodium dichromate   473
       subcategory

18-6   Relationship of annual treatment cost to production   483
       for the Sodium Dichromate Subcategory

18-7   Relationship of annual unit treatment cost to         484
       production for the Sodium Dichromate Subcategory

21-1   General process flow diagram at Plant #034 showing    501
       the sampling points.   Copper Sulfate Manufacture


                               xix

-------
                   LIST OF FIGURES (continued)
21-2   Waste water treatment Level 1 for copper sulfate      505
       subcategory - batch process

21-3   Waste water treatment Level 2 for copper sulfate      506
       subcategory - batch process

22-1   General waste water treatment process flow diagram    523
       showing the sampling points.   (Nickel Sulfate
       Manufacture)

22-2   General process flow diagram at Plant #572 showing    525
       the sampling points.  Nickel Sulfate Manufacture

22-3   General process flow diagram of Plant #120.  Nickel   526
       Sulfate Manufacture

22-4   General waste water treatment process flow diagram    527
       at Plant #120 showing the sampling points.  (Nickel
       Sulfate Manufacture)

22-5   Waste water treatment Level 1 for nickel sulfate      531
       subcategory - batch process

22-6   Waste water treatment Level 2 for nickel sulfate      532
       subcategory - batch process

22-7   Relationship of annual treatment cost to production   541
       for the Nickel Sulfate Subcategory

22-8   Relationship of annual unit treatment cost to         542
       production for the Nickel Sulfate Subcategory

24-1   General process flow diagram at Plant #282 showing    556
       the sampling points.  Sodium Bisulfite Manufacture

24-2   General flow diagram at Plant #586 showing the        557
       sampling points.   Sodium Bisulfite Manufacture

24-3   General process flow diagram at Plant #987 showing    559
       the sampling points.  Sodium Bisulfite Manufacture

24-4   Waste water treatment Level 1 for sodium bisulfite    562
       subcategory - batch process

24-5   Waste water treatment Level 2 for sodium bisulfite    563
       subcategory - batch process

-------
                   LIST OF FIGURES (continued)

                                                            Page
24-6   Waste water treatment Level 3 for sodium bisulfite    564
       subcategory

24-7   Variation of annual treatment cost with production    575
       for the Sodium Bisulfite Subcategory

24-8   Variation of annual unit treatment cost with          576
       production (Sodium Bisulfite Subcategory)

25-1   General process flow diagram at Plant #672            584
       Sodium Hydrosulfite Manufacture

25-2   General process flow diagram at Plant #771 showing    586
       the sampling points.  Sodium Hydrosulfite
       Manufacture

25-3   Waste water treatment level 1 for sodium              593
       hydrosulfite

25-4   Waste water treatment Level 2 for sodium              594
       hydrosulfite

-------
                          LIST OF TABLES

                                                            Page

3-1    Recoinmended List of Priority Pollutants                 8

5-1    Analytical Detection Limits for Metals                 33

7-1    Solubility Products of Trace Metals                    48

7-2    Comparison of Reverse Osmosis Concepts                 63

8-1    Waste Water Treatment Options and Performance          67
       Data Summary - Antimony and Arsenic Removal

8-2    Waste Water Treatment Options and Performance          68
       Data Summary - Beryllium and Cadmium Removal

8-3    Waste Water Treatment Options and Performance          69
       Data Summary - Copper Removal

8-4    Waste Water Treatment Options and Performance          70
       Data Summary - Chromium III and Chromium VI
       Removal

8-5    Waste Water Treatment Options and Performance          71
       Data Summary - Lead Removal

8-6    Waste Water Treatment Options and Performance          72
       Data Summary - Mercury II Removal

8-7    Waste Water Treatment Options and Performance          73
       Data Summary - Nickel Removal

8-8    Waste Water Treatment Options and Performance          74
       Data Summary - Silver Removal

8-9    Waste Water Treatment Options and Performance          75
       Data Summary - Selenium and Thallium Removal

8-10   Waste Water Treatment Options and Performance          76
       Data Summary - Zinc Removal

8-11   Estimated Achievable 30-Day Averages for the Applied   78
       Technologies

9-1    Prioritization of Pollutant Metals Found in Each       85
       Subcategory

11-1   Subcategory Profile Data Summary - Chlorine Mercury   101
       Cell

11-2   Existing Regulations - Effluent Limitation            102
       Guidelines

                              xxii

-------
                    LIST OF TABLES (continued)
11-3   Summary of Raw Waste Loadings Found in Screening      104
       and Verification Sampling

11-4   Priority Pollutant Raw Waste Loads (in kg/kkg of      105
       Product)

11-5   Tail Gas Scrubber Flow Data for Chlorine/Caustic      110
       Subcategory

11-6   Flow and Pollutant Concentration Data of the Sampled  113
       Waste Streams for Plant #299 Producing Chlorine by
       Mercury Cells

11-7   Flow and Pollutant Concentration Data of the Sampled  116
       Waste Streams for Plants #747, #167 and #317
       Producing Chlorine by Mercury Cells

11-8   Waste Flow Data for Chlorine/Caustic Subcategory      124
       Using Mercury Cells

11-9   Residual Chlorine Effluent Loadings at Selected       132
       CHlor-Alkali Plants

11-10  Effluent Loadings from Selected Chlor-Alkali Mercury  133
       Cell Plants

11-11  Effluent Priority Pollutant Loads following Mercury   134
       Treatment

11-12  Control Parameter Limitations                         136
       Subcategory: Chlorine - Mercury Cell

11-13  Control Parameter Limitations                         137
       Subcategory: Chlorine - Mercury Cell

11-14  Model Plant Treatment Costs                           139
       Subcategory: Chlorine Mercury Cell

11-15  Model Plant Treatment Costs                           140
       Subcategory: Chlorine Mercury Cell

11-16  Model Plant Treatment Costs                           141
       Subcategory:  Chlorine Mercury Cell

11-17  Model Plant Treatment Costs                           144
       Subcategory: Chlorine Mercury Cell

11-18  Subcategory Profile Data Summary                      146
       Subcategory: Chlorine Diaphragm Cell

                              xxiii

-------
                    LIST OF TABLES (continued)
                                                             Page

11-19  Summary of Raw Waste Loadings Found in Screening      148
       and Verification Sampling

11-20  Priority Pollutant Raw Waste Loads                    149

11-20A Results of Asbestos Sampling at Diaphragm Cell        150
       Plants

11-21  Metal Priority Pollutant Raw Waste Loadings Found     152
       in Sampling at a Chlorine-Diaphragm Cell Plant with
       Graphite Anodes

11-22  Organic Priority Pollutant Raw Waste Loadings Found   153
       in Sampling at a Chlorine - Diaphragm Cell Plant
       with Graphite Anode

11-23  Data of Water Usage for Barometric Condenser in       157
       Chlorine/Caustic Plants Using Diaphragm Cells

11-24  Flow and Pollutant Concentration Data of the Sampled  160
       Waste Streams for Plants #277, #261, and #738
       Producing Chlorine/Caustic by Diaphragm Cells

11-25  Flow and Pollutant Concentration Data of the Sampled  166
       Waste Streams for Plants #967 and #736 Producing
       Chlorine by Diaphragm Cell

11-26  Waste Flow Data for Chlorine/Caustic Subcategory      172
       Using Diaphragm Cells

11-27  Effluent Loadings from Selected Chlor-Alkali          180
       Diaphragm Cell Plants

11-28  Priority Pollutant Removal at Lead Treatment          182
       Facility Plant #967

11-29  Control Parameter Limitations                         183
       Subcategory: Chlorine - Diaphragm Cell

11-30  Control Parameter Limitations                         185
       Subcategory: Chlorine - Diaphragm Cell

11-31  Control Parameter Limitations                         186
       Subcategory: Chlorine - Diaphragm Cell

11-32  Model Plant Treatment Costs                           187
       Subcategory: Chlorine Diaphragm Cell

11-33  Model Plant Treatment Costs                           188
       Subcategory: Chlorine Diaphragm Cell

                               xxiv

-------
                    LIST OF TABLES (continued)

                                                            Page

11-34  Model Plant Treatment Costs                           189
       Subcategory:  Chlorine Diaphragm Cell

11-35  Model Plant Treatment Costs                           192
       Subcategory:  Chlorine Diaphragm Cell

12-1   Subcategory Profile Data Summary                      J-95
       Subcategory:  Hydrofluoric Acid

12-2   Existing Regulations - Effluent Limitation            196
       Guidelines

12-3   Summary of Raw Waste Loadings  Found in Screening      198
       and Verification Sampling

12-4   Priority Pollutant Raw Waste Loads                    199

12-5   Water Usage in the Hydrofluoric Acid Subcategory      203

12-6   Waste Flow from Hydrofluoric Acid Manufacturing       205
       Plants, m^/kkg of Hydrofluoric Acid

12-7   Flow and Pollutant Concentration Data of the Sampled  209
       Waste Streams of Plant #705 Producing Hydrofluoric
       Acid

12-8   Flow and Pollutant Concentration Data of the Sampled  210
       Waste Streams for Plants #705  and #251 Producing
       Hydrofluoric  Acid

12-9   Waste Water Influent Data to Treatment Facility       212
       in the Hydrofluoric Acid Subcategory

12-10  Summary of Solid Waste Generated from the HF          215
       Manufacturing Processes and Treatment Facilities
       at Plants #705 and #251

12-11  Gypsum Solids Production in the Hydrofluoric Acid     216
       Subcategory

12-12  Summary of Waste Water Control and Treatment          227
       Technology Employed at Hydrofluoric Acid Plants

12-13  Summary of Effluent Quality Attained and Variability  230
       Observed at Four Representative Hydrofluoric Acid
       Plants
                               xxv

-------
                     LIST OF TABLES (continued)

                                                            Paqe
12-14  Control Parameter Limitations                         231
       Subcategory:  Hydrofluoric Acid

12-15  Priority Pollutant Removal at Hydrofluoric Acid       232
       Plants

12-16  Control Parameter Limitations                         234
       Subcategory:  Hydrofluoric Acid

12-17  Control Parameter Limitations                         235
       Subcategory:  Hydrofluoric Acid

12-18  Control Parameter Limitations                         236
       Subcategory:  Hydrofluoric Acid

12-19  Control Parameter Limitations                         238
       Subcategory:  Hydrofluoric Acid

12-20  Model Plant Treatment Costs                           239
       Subcategory:  Hydrofluoric Acid

12-21  Model Plant Treatment Costs                           240
       Subcategory:  Hydrofluoric Acid

12-22  Model Plant Treatment Costs                           241
       Subcategory:  Hydrofluoric Acid

12-23  Model Plant Treatment Costs                           245
       Subcategory:  Hydrofluoric Acid

12-24  Model Plant Treatment Costs                           246
       Subcategory:  Hydrofluoric Acid

12-25  Model Plant Treatment Costs                           247
       Subcategory:  Hydrofluoric Acid

12-26  Model Plant Treatment Costs                           248
       Subcategory:  Hydrofluoric Acid

12-27  Model Plant Treatment Costs                           252
       Subcategory:  Hydrofluoric Acid

13-1   Subcategory Profile Data Summary                      254
       Subcategory:  Hydrogen Peroxide

13-2   Existing Regulations - Effluent Limitation            255
       Guidelines
                               xxvi

-------
                       LIST OF TABLES (continued)

                                                              Page

14-1     Subcategory Profile Data Summary                      257
         Subcategory:  Titanium Dioxide Chloride Process

14-2     Existing Regulations - Effluent Limitation            258
         Guidelines

14-3     Summary of Raw Waste Loadings Found in Screening      260
         and Verification Sampling

14-4     Priority Pollutant Raw Waste Loads                    261

14-5     Water Usage in Titanium Dioxide - Chloride Process    265
         Subcategory

14-6     Flow and Pollutant Concentration Data of the Sampled  268
         Waste Streams for Plant #559 Producing Titanium
         Dioxide (Chloride Process)

14-7     Flow and Pollutant Concentration Data of the Sampled  271
         Waste Streams for Plant #172 Producing Titanium
         Dioxide (Chloride Process)

14-8     Solid Waste Produced in Titanium Dioxide - Chloride   273
         Process Subcategory

14-9     Waste Water Flow for Titanium Dioxide - Chloride      273
         Process Subcategory

14-10    Raw Waste and Treated Effluent Quality at Titanium    231
         Dioxide - Chloride Process  Plants

14-11    Control Parameter Limitations                         282
         Subcategory: Titanium Dioxide - Chloride Process

14-12    Control Parameter Limitations                         284
         Subcategory: Titanium Dioxide - Chloride Process

14-13    Control Parameter Limitations                         285
         Subcategory: Titanium Dioxide - Chloride Process

14-14    Model Plant Treatment Costs                           287
         Subcategory:  Titanium Dioxide - Chloride

14-15    Model Plant Treatment Costs                           288
         Subcategory:  Titanium Dioxide - Chloride

14-16    Model Plant Treatment Costs                           289
         Subcategory:  Titanium Dioxide - Chloride

                               xxv ii

-------
                       LIST OF TABLES (continued)
                                                              >aqe
14-17    Model Plant Treatment Costs                           292
         Subcategory:  Titanium Dioxide - Chloride

14-18    Subcategory Profile Data Summary                      293A
         Subcategory:  Titanium Dioxide Sulfate Process

14-19    Summary of Raw Waste Loadings Found in Screening      294
         and Verification Sampling

14-20    Priority Pollutant Raw Waste Loads                    295

14-21    Analysis of Ilmenite Ores                             297

14-22    Water Usage in Titanium Dioxide - Sulfate Process     300
         Subcategory

14-23    Flow and Pollutant Concentration Data of the Waste    304
         Streams Sampled for Plant #559 Producing Titanium
         Dioxide (Sulfate Process)

14-24    Effluent Flow at Plants #555, #605 and #559           306
         Producing Titanium Dioxide (Sulfate Process)

14-25    Raw Waste Characteristics (Industry Data)  for Plant   307
         #555 (Production of TiO. by Sulfate Process)

14-26    Summary of Existing Control and Treatment Technology  315
         for Sulfate-Process Titanium Dioxide Plants

14-27 .   Summary of Daily Effluent Monitoring Data for         316
         Combined Waste Water Treatment Discharge at Sulfate-
         Process Titanium Dioxide Plant #559

14-28    Verification Results Titanium Dioxide Plant #559      317

14-29    Control Parameter Limitations                         319
         Subcategory:  Titanium Dioxide - Sulfate Process

14-30    Control Parameter Limitations                         320
         Subcategory:  Titanium Dioxide - Sulfate Process

14-31    Model Plant Treatment Costs                           322
         Subcategory:  Titanium Dioxide Sulfate

14-32    Model Plant Treatment Costs                           323
         Subcategory:  Titanium Dioxide Sulfate
                                 xxvi11

-------
                       LIST OF TABLES (continued)

                                                              Page

14-33    Model Plant Treatment Costs                           324
         Subcategory: Titanium Dioxide Sulfate

14-34    Model Plant Treatment Costs                           327
         Subcategory: Titanium Dioxide Sulfate

15-1     Subcategory Profile Data Summary                      329
         Subcategory: Aluminum Fluoride

15-2     Existing Regulations - Effluent Limitation            330
         Guidelines

15-3     Summary of Raw Waste Loadings Found in Screening      331
         and Verification Sampling

15-4     Priority Pollutant Raw Waste Loads                    332

15-5     Water Usage in the Aluminum Fluoride Subcategory      335

15-6     Waste Water Flow at Plants #837,  #705 and #605        337
         for Aluminum Fluoride Subcategory

15-7     Flow and Pollutant Concentration Data of  the Sampled  340
         Waste Streams for Plant #705 Producing Aluminum
         Fluoride

15-8     Flow and Pollutant Concentration Data of  the Sampled  342
         Streams for Plant #605 Producing Aluminum Fluoride

15-9     Solids Generated at Plant #705 and #605 Producing     345
         Aluminum Fluoride

15-10    Control Parameter Limitations                         354
         Subcategory: Aluminum Fluoride

15-11    Control Parameter Limitations                         356
         Subcategory: Aluminum Fluoride

15-12    Control Parameter Limitations                         357
         Subcategory: Aluminum Fluoride

15-13    Control Parameter Limitations                         358
         Subcategory: Aluminum Fluoride

15-14    Model Plant Treatment Costs                           360
         Subcategory: Aluminum Fluoride

15-15    Model Plant Treatment Costs                           361
         Subcategory: Aluminum Fluoride

                                 xx ix

-------
                       LIST OF TABLES (continued)

                                                              Page
15-16    Model Plant Treatment Costs                           362
         Subcategory:  Aluminum Fluoride

15-17    Model Plant Treatment Costs                           365
         Subcategory:  Aluminum Fluoride

15-18    Model Plant Treatment Costs                           366
         Subcategory:  Aluminum Fluoride

15-19    Model Plant Treatment Costs                           369
         Subcategory:  Aluminum Fluoride

15-20    Model Plant Treatment Costs                           370
         Subcategory:  Aluminum Fluoride

15-21    Model Plant Treatment Costs                           374
         Subcategory:  Aluminum Fluoride

16-1     Subcategory Profile Data Summary                      377
         Subcategory:  Chrome Pigments

16-2     Existing Regulations - Effluent Limitation            378
         Guidelines

16-3     Summary of Raw Waste Loadings Found in Screening      379
         and Verification Sampling

16-4     Priority Pollutant Raw Waste Loads                    381

16-5     Water Usage in the Chrome Pigments Subcategory        391

16-6     Aqueous Process Waste Effluents in Chrome             393
         Pigments Subcategory

16-7     Flow and Pollutant Concentration Data of the Sampled  396
         Waste Streams for Plant #894 Producing Chrome
         Pigments

16-8     Flow and Pollutant Concentration Data of the Sampled  396
         Waste Streams for Plant #002 Producing Chrome
         Pigments

16-9     Monitoring and Verification Sampling of Chrome        405
         Pigments Plant #894

16-10    Control Parameter Limitations                         406
         Subcategory:  Chrome Pigments
                                xxx

-------
                       LIST OF TABLES  (continued)

                                                              Page

16-11    Control Parameter Limitations                         408
         Subcategory:  Chrome Pigments

16-12    Model Plant Treatment Costs                           409
         Subcategory:  Chrome Pigments

16-13    Model Plant Treatment Costs                           410
         Subcategory:  Chrome Pigments

16-14    Model Plant Treatment Costs                           411
         Subcategory:  Chrome Pigments

16-15    Model Plant Treatment Costs                           412
         Subcategory:  Chrome Pigments

16-16    Model Plant Treatment Costs                           416
         Subcategory:  Chrome Pigments

17-1     Subcategory Profile Data Summary                      418
         Subcategory:   Hydrogen Cyanide

17-2     Existing Regulations - Effluent Limitation            419
         Guidelines

17-3     Summary of Raw Waste Loadings Found in Screening      420
         and Verification Sampling

17-4     Priority Pollutant Raw Waste  Loads                    421

17-5     Water Usage in Hydrogen Cyanide - Andrussow           425
         Process Subcategory

17-6     Flow and Pollutant Concentration Data of the Sampled  428
         Waste Streams for Plant #765  Producing Hydrogen
         Cyanide

17-7     Flow and Pollutant Concentration Data of the Sampled  431
         Waste Streams for Plant #782  Producing Hydrogen
         Cyanide

17-8     Waste Flow Data for HCN Production by the Andrussow   432
         Process

17-9     Verification Sampling of Hydrogen Cyanide Plant #782  439

17-10    Verification Sampling of Hydrogen Cyanide Plant #765  440

-------
                       LIST OF TABLES  (continued)

                                                              Page

17-11    Control Parameter Limitations                          442
         Subcategory:  Hydrogen Cyanide

17-12    Control Parameter Limitations                          443
         Subcategory:  Hydrogen Cyanide

17-13    Control Parameter Limitations                          445
         Subcategory:  Hydrogen Cyanide

17-14    Control Parameter Limitations                          446
         Subcategory:  Hydrogen Cyanide

17-15    Model Plant Treatment Costs                           448
         Subcategory:  Hydrogen Cyanide

17-16    Model Plant Treatment Costs                           449
         Subcategory:  Hydrogen Cyanide

17-17    Model Plant Treatment Costs                           450
         Subcategory:  Hydrogen Cyanide

17-18    Model Plant Treatment Costs                           453
         Subcategory:  Hydrogen Cyanide

18-1     Subcategory Profile Data Summary                      455
         Subcategory:  Sodium Bichromate

18-2     Existing Regulations - Effluent Limitation            456
         Guidelines

18-3     Summary of Raw Waste Loadings  Found in Screening      457
         and Verification Sampling

18-4     Priority Pollutant Raw Waste Loads                     458

18-5     Water Usage in Sodium Bichromate Subcategory          462

18-6     Flow and Pollutant Concentration Bata of  the Sampled  465
         Waste Streams for Plant #493 Producing Sodium
         Bichromate

18-7     Flow and Pollutant Concentration Bata of  the Sampled  467
         Waste Streams for Plant #376 Producing Sodium
         Bichromate

18-8     Flow and Pollutant Concentration Bata of  the Sampled  468
         Waste Streams for Plant #398 Producing Sodium
         Bichromate

                                xxxii

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                        LIST OF TABLES  (continued)

                                                              Page

18-9     Effluent Control and Treatment Practices and          475
         Achievements at Sodium Bichromate Plants

18-10    Verification Sampling of Sodium Bichromate Plants     476

18-11    Control Parameter Limitations                          477
         Subcategory: Sodium Bichromate

18-12    Control Parameter Limitations                          479
         Subcategory: Sodium Bichromate

18-13    Model Plant Treatment Costs                            480
         Subcategory: Sodium Bichromate

18-14    Model Plant Treatment Costs                            481
         Subcategory: Sodium Bichromate

18-15    Model Plant Treatment Costs                            482
         Subcategory: Sodium Bichromate

18-16    Model Plant Treatment Costs                            486
         Subcategory: Sodium Bichromate

19-1     Subcategory Profile Bata Summary                      488
         Subcategory: Carbon Bioxide

19-2     Existing Regulations - Effluent Limitation            489
         Guidelines

20-1     Subcategory Profile Bata Summary                      491
         Subcategory:  Carbon Monoxide  and By-Product
         Hydrogen

20-2     Existing Regulations - Effluent Limitation            492
         Guidelines

21-1     Subcategory Profile Bata Summary                      494
         Subcategory:  Copper Sulfate

21-2     Existing Regulations - Effluent Limitation            495
         Guidelines

21-3     Summary of Raw Waste Loadings  Found at Copper         496
         Sulfate Plant #034

21-4     Water Usage in Copper Sulfate  Subcategory             498

21-5     Flow and Pollutant Concentration Bata of the Sampled  502
         Waste Streams for Plant #034 Producing Copper Sulfate

                                xxxiii

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                       LIST OF TABLES  (continued)

                                                             Page

21-6    Verification Sampling of Copper Sulfate Plant #034    508

21-7    Control Parameter Limitations                          510
        Subcategory: Copper Sulfate

21-8    Control Parameter Limitations                          511
        Subcategory: Copper Sulfate

21-9    Model Plant Treatment Costs                           513
        Subcategory: Copper Sulfate

21-10   Model Plant Treatment Costs                           514
        Subcategory: Copper Sulfate

22-1    Subcategory Profile Data Summary                      516
        Subcategory: Nickel Sulfate

22-2    Existing Regulations - Effluent Limitation            517
        Guidelines

22-3    Summary of Raw Waste Loadings  Found in Screening      518
        and Verification Sampling

22-4    Priority Pollutant Raw Waste Loads                    519

22-5    Water Usage in the Nickel Sulfate Subcategory         521

22-6    Flow and Pollutant Concentration Data of the Sampled  524
        Waste Streams for Plants Producing Nickel Sulfate

22-7    Waste Characteristics of Nickel Sulfate Plant #120    534

22-8    Control Parameter Limitations                          535
        Subcategory: Nickel Sulfate

22-9    Control Parameter Limitations                          537
        Subcategory: Nickel Sulfate

22-10   Model Plant Treatment Costs                           538
        Subcategory: Nickel Sulfate

22-11   Model Plant Treatment Costs                           539
        Subcategory: Nickel Sulfate

22-12   Model Plant Treatment Costs                           540
        Subcategory: Nickel Sulfate

22-13   Model Plant Treatment Costs                           543
        Subcategory: Nickel Sulfate

                               xxx iv

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                       LIST OF TABLES (continued)

                                                             Page

23-1    Subcategory Profile Data Summary                      545
        Subcategory:  Silver Nitrate

23-2    Existing Regulations - Effluent Limitation            546
        Guidelines

24-1    Subcategory Profile Data Summary                      548
        Subcategory:  Sodium Bisulfite

24-2    Existing Regulations - Effluent Limitation            549
        Guidelines

24-3    Summary of Raw Waste Loadings Found in Screening      550
        and Verification Sampling

24-4    Priority Pollutant Raw Waste Loads                    551

24-5    Water Usage in the Sodium Bisulfite Subcategory       553

24-6    Flow and Pollutant Concentration Data of the Sampled  555
        Waste Streams for Plant #282 Producing Sodium
        Bisulfite

24-7    Flow and Pollutant Concentration Data of the Sampled  555
        Waste Streams for Plant #586 Producing Sodium
        Bisulfite

24-8    Flow and Pollutant Concentration Data of the Sampled  558
        Waste Streams for Plant #987 Producing Sodium
        Bisulfite

24-9    Treatment Practices and Verification Sampling at      566
        Sodium Bisulfite Plants

24-10   Control Parameter Limitations                         568
        Subcategory:  Sodium Bisulfite

24-11   Control Parameter Limitations                         569
        Subcategory:  Sodium Bisulfite

24-12   Control Parameter Limitations                         570
        Subcategory:  Sodium Bisulfite

24-13   Model Plant Treatment Costs                           572
        Subcategory:  Sodium Bisulfite

24-14   Model Plant Treatment Costs                           573
        Subcategory:  Sodium Bisulfite


                               xxxv

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                       LIST OF TABLES  (continued)

                                                             Paqe
24-15   Model Plant Treatment Costs                           574
        Subcategory:  Sodium Bisulfite

24-16   Model Plant Treatment Costs                           577
        Subcategory:  Sodium Bisulfite

25-1    Subcategory Profile Data Summary                      579
        Subcategory:  Sodium Hydrosulfite (Formate Process)

25-2    Existing Regulations - Effluent Limitation            580
        Guidelines

25-3    Summary of Raw Waste Loadings Found at a Sodium       582
        Hydrosulfite Plant (Formate Process)

25-4    Flow and Pollutant Concentration Data of the Sampled  587
        Waste Streams for Plant #672 Producing Sodium
        Hydrosulfite

25-5    Influent and Effluent Quality and Efficiency for      589
        Plant #672 Waste Water Treatment System Found
        During Screening Sampling

25-6    Screening Results from Sodium Hydrosulfite Plant      596
        #672

25-7    Control Parameter Limitations                         597
        Subcategory:  Sodium Hydrosulfite

25-8    Control Parameter Limitations                         599
        Subcategory:  Sodium Hydrosulfite

25-9    Model Plant Treatment Costs                           600
        Subcategory:  Sodium Hydrosulfite

25-10   Model Plant Treatment Costs                           601
        Subcategory:  Sodium Hydrosulfite

26-1    Subcategory Profile Data Summary                      603
        Subcategory:  Hydrochloric Acid

26-2    Existing Regulations - Effluent Limitation            604
        Guidelines

27-1    Subcategory Profile Data Summary                      606
        Subcategory:  Nitric Acid

27-2    Existing Regulations - Effluent Limitation            607
        Guidelines
                             xxxvi

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                       LIST OF TABLES (continued)

                                                             Page

28-1    Subcategory Profile Data Summary                      609
        Subcategory:  Sodium Carbonate

28-2    Existing Regulations - Effluent Limitation            ,610
        Guidelines

29-1    Subcategory Profile Data Summary                      612
        Subcategory:   Sodium Metal

29-2    Existing Regulations - Effluent Limitation            613
        Guidelines

30-1    Subcategory Profile Data Summary                      615
        Subcategory:  Sodium Silicate

30-2    Existing Regulations - Effluent Limitation            616
        Guidelines

31-1    Subcategory Profile Data Summary                      618
        Subcategory:  Sulfuric Acid

31-2    Existing Regulations - Effluent Limitation            619
        Guidelines

32-1    Subcategory Profile Data Summary                      621
        Subcategory:  Ammonium Chloride

32-2    Existing Regulations - Effluent Limitation            622
        Guidelines

33-1    Subcategory Profile Data Summary                      624
        Subcategory:  Ammonium Hydroxide

33-2    Existing Regulations - Effluent Limitation            625
        Guidelines

34-1    Subcategory Profile Data Summary                      627
        Subcategory:  Barium Carbonate

34-2    Existing Regulations - Effluent Limitation            628
        Guidelines

35-1    Subcategory Profile Data Summary                      630
        Subcategory:  Boric Acid

35-2    Existing Regulations - Effluent Limitation            631
        Guidelines
                              xxxvn

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                        LIST OF TABLES  (continued)

                                                             Page

36-1    Subcategory Profile Data Summary                      633
        Subcategory:  Calcium Carbonate

36-2    Existing Regulations - Effluent Limitation             634
        Guidelines

37-1    Subcategory Profile Data Summary                      636
        Subcategory:  Cuprous Oxide

37-2    Existing Regulations - Effluent Limitation             637
        Guidelines

38-1    Subcategory Profile Data Summary                      639
        Subcategory:   Manganese Sulfate

38-2    Existing Regulations - Effluent Limitation             640
        Guidelines

39-1    Subcategory Profile Data Summary                      642
        Subcategory:  Strong Nitric Acid

39-2    Existing Regulations - Effluent Limitation             643
        Guidelines

40-1    Subcategory Profile Data Summary                      645
        Subcategory:  Oxygen and Nitrogen

40-2    Existing Regulations - Effluent Limitation             646
        Guidelines

41-1    Subcategory Profile Data Summary                      648
        Subcategory:  Potassium Iodide

41-2    Existing Regulations - Effluent Limitation             649
        Guidelines

42-1    Subcategory Profile Data Summary                      651
        Subcategory:   Sodium Hydrosulfide

42-2    Existing Regulations - Effluent Limitation             652
        Guidelines

43-1    Subcategory Profile Data Summary                      654
        Subcategory:  Sodium Silicofluoride

43-2    Existing Regulations - Effluent Limitation             655
        Guidelines
                           XXXVlll

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                        LIST OF TABLES (continued)

                                                             Page

44-1    Subcategory Profile Data Summary                      657
        Subcategory:  Sodium Thiosulfate

44-2    Existing Regulations - Effluent Limitation             658
        Guidelines

45-1    Subcategory Profile Data Summary                      660
        Subcategory:  Sulfur Dioxide

45-2    Existing Regulations - Effluent Limitation             661
        Guidelines
                             xxx ix

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                           SECTION 1.0
                     CONCLUSIONS AND SUMMARY
1.1 PRIORITY POLLUTANTS
     This study  has  shown  that  certain  priority  pollutants,
particularly the 13  metals, cyanide and asbestos are present  in
significant amounts in process  waste waters  generated by plants
in  11  of  the  35  inorganic  chemical  product   subcategories
screened.  Very  few of  the  listed  organic priority pollutants
were  found  in  process  waste  streams  and  those   that  were
identified,  in  most  cases,  were  not present  in  significant
amounts.
     The results of the screening  sampling program are  given in
support of 24 candidate subcategory exclusions in accordance with
the provisions of Parag'raph  8  of the  Settlement  Agreement  in
Natural Resources Defense  Council,  et  al. v.  Train  (June  8,
1976).  Those screening results  which indicated the presence  of
priority pollutants in significant amounts were largely confirmed
by  the  results  of  the  verification  program.    Verification
sampling accounted for 50  to 75 percent of the current inorganic
chemical production rate in the subcategories'covered.


     The sources of most of the priority  pollutants found in the
raw wastes  and  treated  effluents  can  be traced  to  specific
process   related  raw  materials  and  chemicals   used  in  the
manufacturing  operations.   In  the  case  of  certain pollutants
found in  widely varying amounts or  with erratic frequencies  of
occurrence, the  precise identities of the sources remain unknown
at this time, but are suspected to be process-related.
1.2 CONTROL AND TREATMENT TECHNOLOGY


     A considerable  amount  of  priority  pollutant  removal  is
presently  achieved in the industry  by  the existing control and
treatment practices.   Additional removal can be accomplished  by
the application of available and demonstrated  technologies which

                               1

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would add to or  modify existing  treatment systems.
the heavy metals for value or reuse in a process does not  appear
to be  an  attractive alternative in  those  industries where the
product   recovery  practices  now   in  effect  do  not  already
accomplish this.


     The treatment  of  priority   metal-bearing  waste   streams
results  in the production  of  sludges  or  residues  which  are
potentially hazardous and may require special means  for handling
and disposal.  The massive sludges  composed  of  calcium sulfate
with relatively low concentrations  of priority metals can safely
be  handled  in on-site  disposal areas with  proper  runoff  and
leachate control;  however, the smaller volume wastes having high
concentrations of  metals would  require storage  in a lined pond
and/or removal to a safe chemical landfill site.


1.3 COSTS OF ADDITIONAL IN-PLANT  TREATMENT


     The estimated incremental costs  of applying  the  candidate
BAT treatment options represent a relatively  small proportion of
the  investment  and  operating  and  maintenance  costs  already
committed  to  the  existing BPT  level treatment systems.   These
costs,  however, vary widely  from  industry to  industry and are
highly dependent on site-specific factors.


1.4 SUBCATEGORIZATION
     A review of the  product/process basis for subcategorization
of  the  15  inorganic  chemicals  designated for  initial  study
revealed that certain  modifications may  be  appropriate  in the
interest  of  developing  effective  regulations.   The  priority
pollutant problem per se impacts  subcategorization directly only
in the  Chlor-Alkali  Industry  where the use of  graphite anodes
contributes  to the generation  of chlorinated hydrocarbons.   In
the Titanium  Dioxide Industry,   major  process  and raw material
differences  may justify  the  creation of a separate segment for
the  chloride  process  using ilmenite  ore.   The  rationale  is
presented for creating a subcategory for  the combined production
of  hydrofluoric acid  and  aluminum fluoride in  view  of  their
similar  waste  characteristics  and  the  current   practice  of
combined   treatment  at   several   plants.    Hydrogen  cyanide
production may be logically subdivided into segments on the basis
of the major process differences related to the Andrussow Process
and  HCN  production  as  a  by-product  in  the  manufacture  of
acrylonitrile.

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1.5 RESTUDY OF REMANDED REGULATIONS
     In response to the issues raised by the  Fourth Circuit,  U.S.
Court of  Appeals in remanding  effluent  limitations  guidelines
promulgated for 11  major  inorganic  chemical   products,  factors
affecting  the control  and treatment of pollutant  discharges in
those industries have been  studied.  It has  been concluded   that
alternative   control   and   treatment  technologies  to    those
originally considered  for BAT and NSPS may be  appropriate and  a
reunion of the  corresponding effluent limitations guidelines and
new source performance standards should be considered.

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                           SECTION 2.0
                         RECOMMENDATIONS
     On the  basis  of  the  priority  pollutant  screening  and
verification   results   and   the   evaluation   of   applicable
technologies  for   discharge  control  and   treatment,   it  is
recommended  that  effluent  limitation  guidelines,  new  source
performance  standards  and pretreatment standards  for  new  and
existing  sources  be   proposed   for   11   inorganic  chemical
manufacturing subcategories.  These include:


         Chlor-alkali
         Hydrofluoric Acid
         Titanium Dioxide
         Aluminum Fluoride
         Chrome pigments
         Hydrogen Cyanide
         Sodium Dichromate
         Copper Sulfate
         Nickel Sulfate
         Sodium Bisulfite
         Sodium Hydrosulfite


     In addition,  it  is  recommended  that alternative effluent
limitations guidelines and  standards  of  performance  to  those
which had  been promulgated and subsequently remanded for restudy
be proposed  for seven inorganic chemical  subcategories.   These
are industries in which  priority pollutant  discharges  have not
been  found in significant  quantities,  but require  appropriate
regulations  on the discharge of conventional and nonconventional
pollutants.  The subcategories included are:


         Hydrogen Peroxide
         Hydrochloric Acid
         Nitric Acid
         Sodium Carbonate
         Sodium Metal
         Sodium Silicate
         Sulfuric Acid

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                            SECTION  3


                          INTRODUCTION
3.1 AUTHORITY


3.1.1 The Federal  Water  Po11ution Control  Act Amendments

     The Federal  Water  Pollution Control Act (the Act)  Amendments
of 1972 stated the national  goal of attaining by, July 1,  1983,  a
water  quality which provides for the   protection and propagation
of fish and shellfish,  for  recreation  in or on the water,  and the
goal of  eliminating  the discharge of pollutants into  navigable
waters by 1985.

     The Act provides for the achievement  of these goals in three
steps by requiring the  estblishment of technology-based effluent
limitations and standards of performance.   Section 301 (b)  of the
Act requires,  as the  first step attainment by July  1,  1977, of
effluent limitations for point  sources, other than publicly owned
treatment works (POTW),   based  on  the application of  the  best
practicable control  technology   currently available  (BPCTCA, or
simply  BPT) as defined  by the  Administrator  pursuant to  Section
304   (b).  As the second step,   the  Act   as amended an 1977  now
requires  the  application  of   effluent   limitations  for  point
sources,  other  than  POTW's,  of  the best  available technology
economically achievable (BATEA,  or simply  BAT)  by July 1,   1984,
for  the  control of specific toxic pollutants as  identified  in
accordance  with Section 307 (a) .  The  third  and final  step in
achievement of the goal  to   eliminate  all  discharge of pollutants
into navigable waters by 1985.

     The United  States  Environmental  Protection  Agency  (the
Agency)  entrusted  with  the responsibility  to  carry  out  the
requirements of the Act, initiated an  intensive effort to  develop
the necessary regulatory  means  which  would achieve the  stepwise
reduction and elimination of pollutant discharge practices in all
major   U.S.    Industries.     For   the    Inorganic    Chemicals
Manufacturing  Point  Source  Category,  the  Agency  designed   a
comprehensive,  two   phase  program  to   identify  the   control
parameters and establish the technological  basis for regulations
development.   Phase  I  covered  22  Major  Inorganic   Chemical
Products,   (1)  and the final   regulations  for these  industrial

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subcategories were published in the Federal Register on
1974.    The  regulations  included  specific  numerical
limitations and standards of performance  applicable to
steps   of  pollutant control for  both existing and new
Zero-discharge   requirements   specified   for
subcategories were to be applied  either at the
later.   Phase  II  of  the   Agency's  effort
promulgation of BPT based  effluent limitations
group  of  27 subcategories referred to
Chemical  Products  (2).   The  interim
                                  March 12,
                                   effluent
                                  the three
                                   sources.
                            many   of   the
                          1977 BPT  step or
                          resulted  in  the
                          for an additional
                  as Significant  Inorganic
                   final  regulations  were
published on May  22,   1975.  Taken together,  the two  groups of
regulations  cover 49  inorganic chemical  subcategories  many  of
which include more than one specific chemical product.   Although
some toxic  pollutant  parameters  were  covered  in cases where a
direct  relationship to  the process  was obvious  (e.g., mercury
and/or lead in the Chlor-alkali Industry), the main thrust of the
regulations  was  the  control of  the  bulk  pollutant parameters
which accounted, in terms of quantity, for  most of the pollution
loading of  navigable  waters  attributable  to the manufacture of
inorganic chemicals.
3.1.2 Court Remand of Regulations

     On March 10,  1976,  the United States Court of Appeals  for
the Fourth  Circuit decided in E.I. DuPont de Nemours &  Company,
et al.  v.  Train  No.  74-1261, to  set  aside  and   remand for
reconsideration  a  number of  general  definitions  and specific
discharge regulations promulgated in 1974.  These regulations are
all within  Title 40, Parts 401 and 415 of  the  Code of  Federal
Regulations and are listed below:
     General Provisions
          401.11 (i)   -
          401.11 (q)   -
          401.11 (r)
   Definition of
   Definition of
   Definition of
      pollutant
effluent limitations
process waste water
process waste water
     Chlor-Alkali
          415.63
- 1983 step
     Hydrochloric Acid
          415.72
          415.73
          415.75
   1977 step
   1983 step
   New sources
     Hydrofluoric Acid
          415.82
   1977 step

         6

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     415.83
     415.85
          1983 step
          New sources
Hydrogen Peroxide
     415.93
     415.95
          1983 step
          New sources
Nitric Acid
     415.102
     415.103
     415.105
          1977 step
          1983 step
          New sources
Sodium Carbonate
      415.152
      415.153
      415.155
          1977 step
          1983 step
          New sources
 Sodium Bichromate
      415.173
       -  1983 step
 Sodium Metal
      415.182
      415.183
      415.185
          1977 step
          1983 step
          New sources
 Sodium Silicate
      415.192
      415. 193
      415.195
          1977 step
          1983 step
          New sources
 Sulfur ic
      415.
      415.
      415.
Ac id
210
212
213
      415.215
Applicability
1977 step
1983 step
New sources
 Ti tanium
      415.
      415.
      415.
Diox ide
220
222
223
      415.225
Applicability
1977 step
1983 step
New sources

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     In the  majority  of cases the main target of the remand was
the   zero   discharge  regulations  from   which   the  industry
petitioners   sought   relief   on   grounds   of   technological
infeasibility.   During 1975, the Agency funded a special study of
the  remand  issues (3)   and  was  prepared  to  propose  amended
regulations.   Where appropriate,  the results of that  study are
included  in an Addendum  to  the present  report covering  those
remanded  regulations for  subcategories which have been excluded
from the present study.

     Following  the  court  remand of  the above indicated Phase I
final regulations, the  Agency revoked the Phase II interim final
and proposed  regulations published  in May, 1975,  for  Aluminum
Fluoride,  Chrome  Pigments,   Hydrogen   Cyanide,   and   Sodium
Silicofluoride.  In this instance,  the  Agency's  intent was  to
reconsider  the  specific effluent  limitations  established  for
these industries  (1977   step)  in the  light  of information made
available on  process  differences between plants and  additional
data  on  the  actual  concentrations  and  treatability  of  the
regulated discharge  constituents.  The information was presented
to  the Agency  in the  form  of various  documents  prepared  by
members  of the  industries concerned.  These  sources  are  also
cited in the appropriate sections of this report.


3.1.3 The Settlement Agreement

     Following  legal action brought by four environmental  groups
in  Natural  Resources Defense  Council  v.   Train,  the  Agency
entered into an agreement dated June 8, 1976.  In this Settlement
Agreement,  the  Agency  agreed to regulate  65 toxic  pollutants
under  Sections 301,  304, 306 and  307 of the  Act in accordance
with the  schedule  and  provisions stipulated.  The original list
of  65  chemicals  and  classes  of  chemicals  attached  to  the
Settlement   Agreement   was  redefined  to  cover  129  chemical
substances, including specific  organic compounds, pesticides and
their metabolites, polychlorinated biphenyls (PBC's), cyanide, 13
heavy  metals and asbestos.  These substances are listed in Table
3-1.
        Table 3-1 Recommended List of Priority Pollutants


Compound Name
  1.  *Acenaphthene
  2.  *Acrolein
  3.  *Acrylonitrile
  4.  *Benzene
  5.  *Benzidine

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     *Carbon tetrachloride (tetrachloromethane)


     *Chlorinated benzenes (other than dichlorobenzenes)
 7.   *Chlorobenzene
 8.   1,2,4-Trichlorobenzene
 9-   Hexachlorobenzene
     *Chlorinated ethanes (including 1, 2-dichloroethane,
          1,1,1,-trichloroethane and hexachloroethane)
10.       1.2-Dichloroethane
11.       1,1,1-Trichloroethane
12.       Hexachloroethane
13.       1,1-Dichloroethane
14.       1,1,2-Trichloroethane
15.       1,1,2,2-Tetrachloroethane
16.       Chloroethane
    *Chloroalkyl ethers (chloromethyl, chloroethyl  and
          mixedethers)
17.       Bis(chloromethyl)  ether
18.       Bis(2-chloroethyl) ether
19.       2-Chloroethyl vinyl ether (mixed)
    *Chlorinated naphthalene


20.       2-Chloronaphthalene
    *Chlorinated phenols (other than those listed
          elsewhere;includes trichlorophenols
          and chlorinated cresols)
21.        2,4,6-Trichlorophenol
22.        Parachlorometa cresol
23.   *Chloroform (trichloromethane)
24.   *2-Chlorophenol

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     *Dichlorobenzenes
25.        1,2-Dichlorobenzene
26.        1,3-Dichlorobenzene
27.        1,4-Dichlorobenzene
      *Dichlorobenzidine
28.   3,3'-Dichlorobenzidine
    *Dichloroethylenes (1,1-dichloroethylene and
          1,2-dichloroethylene)
29.  1,1-Dichloroethylene
30.  1,2-Trans-dichloroethylene
31.  *2,4-Dichlorophenol
     *Dichloropropane and dichloropropene
32.       1,2-Dichloropropane
33.       1,2-Dichloropropylene  (1,3-dichloropropene)
34.  *2,4-Dimethylphenol
     *Dinitrotoluene
35.       2,4-Dinitrotoluene
36.       2,6-Dinitrotoluene
37.  *1,2-Diphenylhydrazine
38.  *Ethylbenzene
39.  *Fluoranthene
     *Haloethers (others than those listed elsewhere)
40.       4-Chlorophenyl phenyl ether
41.       4-Bromophenyl phenyl ether
42.       Bis(2-chloroisopropyl)  ether
43.       Bis(2-chloroethoxy) methane
                              10

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     *Halomethanes (other than those listed  elsewhere)
44.       Methylene chloride (dichloromethane)
45.       Methyl chloride (chloromethane)
46.       Methyl bromide (bromomethane)
47-       Bromoform (tr ibromomethane)
48.       Dichlorobromomethane
49.       Tr ichlorofluoromethane
50.       Dichlorodifluoromethane
51.       Chlorodibromomethane
52.   *Hexachlorobutadiene
53.   *Hexachlorocyclopentadiene
54.   *Isophorone
55.   *Naphthalene
56.   *Nitrobenzene
      *Nitrophenols (including 2,4-dinitrophenol and
           and dinitrocresol)
57.        2-Nitrophenol
58.        4-Nitrophenol
59.        2,4-Dinitrophenol
60.        4,6-Dinitro-o-cresol
       *Nitrosamines
61.        N-nitrosodimethylamine
62.        N-nitrosodiphenylamine
63.        N-nitrosodi-n-propylamine
64.    *Pentachlorophenol
65.    *Phenol
       *Phthalate esters
66.        Bis(2-ethylhexyl)  phthalate
67.        Butyl benzyl phthalate
68.        Di-n-butyl phthalate
69.        Di-n-octyl phthalate
70.        Diethyl phthalate
71.        Dimethyl phthalate
                              11

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       *Polynuclear aromatic hydrocarbons
12.        Benzo(a)anthracene  (1,2-benzanthracene)
73.        Benzo (a) pyrene  (3,4-benzopyrene)
74.        3,4-Benzofluoranthene
75.        Benzo(k)fluoranthane  (11,12-benzofluoranthene)
76.        Crysene
77.        Acenaphthylene
78.        Anthracene
79.        Benzo(ghi)perylene  (1,12-benzoperylene)
80.        Fluorene
81.        Phenanthrene
82.        Dibenzo  (a,h)anthracene  (1,2,5,6-dibenzanthracene)
83.        Indeno  (1,2,3-cd)pyrene  (2,3,-o-phenylenepyrene)
84.        Pyrene
85.     *Tetrachloroethylene
86.     *Toluene
87.     *Trichloroethylene
88.     *Vinyl chloride (chlorethylene)
    *Pesticides and Metabolites
89.        *Aldrin
90.        *Dieldrin
91.        *Chlordane  (technical mixture  &  metabolites)
    DDT and metabolites
92.        4,4'-DDT
93.        4,4'-DDE  (p,p'-DDX)
94.        4,4'DDD  (p,p'-TDE)
     *Endosulfan and metabolites
95.        A-endosulfan-Alpha
96.        B-endosulfan-Beta
97.          Endosulfan  sulfate
    *Endrin and metabolites
98.        Endrin
99-        Endrin aldehyde

                              12

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      *Heptachlor  and  metabolites
 100.         Heptachlor
 101.         Heptachlor  epoxide
      *Hexachlorocyclohexane  (all  isomers)
 102.         A-BHC-Alpha
 103.         B-BHC-Beta
 104.         R-BHC  (lindane)-Gamma
 105.         G-BHC-Delta
      *Polychlorinated  biphenyls  (PCB's)


 106.         PCB-1242  (Arochlor 1242)
 107.         PCB-1254  (Arochlor 1254)
 108.         PCB-1221  (Arochlor 1221)
 109.         PCB-1232  (Arochlor 1232)
 110.         PCB-1248  (Arochlor 1248)
 111.         PCB-1260  (Arochlor 1260)
 112.         PCB-1016  (Arochlor 1016)
 113.  *Toxaphene
 114.  *Antimony  (Total)
 115.  *Arsenic  (Total)
 116.  *Asbestos  (Fibrous)
 117.  *Beryllium  (Total)
 118.  *Cadmium  (Total)
 119.  *Chromium  (Total)
 120.  *Copper  (Total)
 121.  *Cyanide  (Total)
 122.  *Lead  (Total)
 123.  *Mercury  (Total)
 124.  *Nickel  (Total)
 125.  *Selenium  (Total)
 126.  *Silver  (Total)
 127.  *Thallium  (total)
 128.  *Zinc  (Total)
 129.  **2,3,7,8-Tetrachlorodibenzo-p-dioxin  (TCDD)


 *Specific  compounds  and  chemicals  classes  as  listed  in  the
Consent Decree.


**This compound was specifically listed  in   the   Consent  Decree.
Because of  the extreme toxicity of  TCDD, the Agency recommended
tnat  laboratories not  acquire  analytical  standards  for  this

                               13

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compound.

     The Settlement  Agreement  also  identified 21 point  source
categories  and specified  the scope  of application of  effluent
limitations, new source performance  standards, and  pretreatment
standards   within   each  category  in  terms  of  the   Standard
Industrial Classification (SIC)  code numbers.  For  the Inorganic
Chemicals    Manufacturing  Point   Source  Category,   the  major
industries included are:
          SIC 2812  - Alkalies and Chlorine
          SIC 2813  - Industrial Gases
          SIC 2816  - Inorganic Pigments
          SIC 2819  - Industrial Inorganic Chemicals,
                        Not Elsewhere Classified

     Within these  industries,  the  Agency  has  identified  63
subcategories  listed in  Table 3-2 for  the initial study of the
priority toxic  pollutant  problem.  Most of these subcategories,
49 in all, had  already  been covered  by BPT  and  BAT discharge
regulations promulgated  in  1974  and  1975.  Those  regulations
established   point  of   discharge   control   levels   for  the
conventional  parameters such as  pH, TSS, TOC,  BOD,  and oil and
grease.   In  many  cases,  specific  chemical  parameters   were
regulated,  particularly  As , Cr ,  Cu , Hg ,  Ni ,  Pb ,  Se , Zn ,  and
cyanide, which are  now included in  the  list of priority  toxic
pollutants.   Other  regulated  parameters  such  as Al, Ba,  Fe,
ammonia, fluoride and sulfide are not presently  listed  as toxic
chemicals but are to  be  treated  as  nonconventional pollutants
under future discharge limitations and standards of performance.

     Nearly half  of  the  initial  63  subcategories  have  been
recommended  for  exclusion  from  this study  on  the  basis  of
specific provisions for such  exclusion under Paragraph 8 of  the
Settlement  Agreement.  The bases  for these  exclusions  are  as
follows:
      No. 63, Ferrous Sulfate, is already covered by the
      Titanium Dioxide - Sulfate Process subcategory and
      does not require separate consideration.

      Nos. 60, 61, and 62 have only one plant each
      (or one plant with a wet process discharge) , and
      represent nonsignificant discharges of toxic
      pollutants.  Nos. 27 and 28 are also single
      plants, but were covered in screening.

      Nos. 36 through 56 have existing BPT regulations
      requiring zero discharge of process waste water to
      navigable water and there are no known discharges

                               14

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      to a POTW.   Continued enforcement of the existing
      regulations will provide adequate control of toxic
      pollutants.
     The remaining 35 nonexcluded subcategories  (Table 3-2,   Nos.
1 through  35)   are  covered  in this report.   This  group   also
includes  the  11  subcategories  whose  final  regulations   were
remanded for  restudy  in E.I.  DuPont de Nemours and Company, et^
al. v. Train, and the four additional subcategories whose  interim
final or proposed  regulations  were revoked and reserved  by  the
Agency.

     It was anticipated by  the Agency that  a substantial number
of the  35 industries  to  be  screened would  also  qualify  for
exclusion under  Paragraph  8  on  the  basis  of  the analytical
results obtained from  the process waste water priority pollutant
screening program.  A preliminary  prioritization  indicated  that
the initial detailed study and regulation development would focus
on the first 15 subcategories.

     This judgment  has  been  substantially  supported  by   the
analytical results of  the screening  programs  and a  number  of
additional  exclusions are being recommended for subcategories in
which  nonsignificant priority  pollutant  discharges  have   been
determined. A detailed presentation of the analytical  results is
given under the  individual subcategory sections of  this  report.
The additional  recommended exclusions include the following:


     No.        Subcategory


      1.    Hydrogen Peroxide
      2.    Carbon Dioxide
      3.    Carbon Monoxide/Hydrogen
      4.    Hydrochloric Acid
     17.    Nitric Acid
     19.    Sodium Metal
     21.    Sulfuric Acid
     22.    Ammonium Chloride
     23.    Ammonium Hydroxide
     24.    Barium Carbonate
     26.    Calcium Carbonate
     27.    Copper Oxide (one plant)
     28.    Manganese Sulfate (one plant)
     29.     Strong Nitric Acid
     30.    Oxygen and Nitrogen
     31.     Potassium Iodide
     32.    Sodium Hydrosulfide
     34.     Sodium Thiosulfata

                              15

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     35.     Sulfur Dioxide
     In addition, Sodium Carbonate  (No. 18) and Boric acid   (No.
25)   are  being  considered  as  candidates   for  exclusion  and
recommendations   will  be  made   following  the  evaluation  of
additional process waste sampling results.

     The four  remaining  subcategories  will  be  included   for
screening under Phase II of the inorganic chemicals study.  These
are:
     13.    Silver Nitrate (to be combined with silver bromide,
            silver chloride, and other inorganic silver compounds)
     57.    Calcium chloride
     58.    Sodium Chloride
     59.    Sodium Sulfite
3.2 GENERAL APPROACH AND METHODOLOGY

     Initiating and  undertaking  a comprehensive  study  of  the
priority  pollutant problem  in the Inorganic  Chemicals Industry
was necessarily preceded by an intensive evaluation by the Agency
of  the kinds  of data and supporting information  that should be
assembled  as a  basis  for the development  of regulations.  All
major  decisions  on   the   identity  of  pollutants   and   the
establishment   of   effluent   limitations   and   standards  of
performance  for  each  subcategory  had  to  be  supportable  by
documented   evidence   collected   from   operating   production
facilities.   Similarly,  the necessary information on production
rates, processes,  raw  materials, water use, waste sources,  and
treatment  technologies  in  practice  had to  be  acquired  with
sufficient detail  and breadth  of coverage to permit an analysis
of the engineering and economic variables that are characteristic
of  each  subcategory.   Priority pollutant  control  regulations
would be based on the  application of best  available  technology
for  treatment  and  reliable  performance  evaluations  for  the
removal of specific waste substances.

     The following  paragraphs briefly  describe the  major study
tasks and their results as they are presented in this report.


3.2.1 Industry Data Base Development and Subcategorization Review

     Information from individual manufacturers and previous study
documents  were  reviewed  in detail and  an  evaluation  of  the
appropriateness of  subcategorization  was  performed.  Section  4
presents   a   discussion   of   the   factors   considered    in

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subcategorization and  presents  rationale  for  maintaining   the
present scheme of subcategorization for the industries  studied.


3.2.2 The Screening and Verification Sampling Programs

     The collection of detailed analytical data on  conventional,
nonconventional and priority pollutant concentrations  in   raw and
treated  process  waste  streams was  completed  in  a  two-phase
sampling program.  The first phase, for  screening,  was  designed
to provide a representative, one-time 72-hour sampling  of a  plant
in  each  subcategory  in  order  to  determine  the   presence of
priority pollutants and to evaluate their potential environmental
significance.   The   sampling  and  analytical  methodology   is
described  in  Section 5,  along  with  the basis  for  making  a
decision  on   the   need  for  verification   sampling   in   each
subcategory.


3.2.3  Engineering Evaluations

     Section 6  describes  the procedures  and  sources   used in
developing  the industry  productions  and  wastewater  generation
characteristics that form the  basis of the model plant   concept.
The sources of detailed process  and waste treatment   information
are  also  presented.   Section   7  contains  an  evaluation of
treatment  technology   presently  applied  in  BPT  systems   and
advanced technologies that  may be recommended  for BAT and   NSPS
applications.  Section 8  provides  estimates of the treatability
of selected priority and nonconventional pollutants to  be applied
in the development of achievable  performance characteristics for
specific technologies.  Section 8  also presents  a discussion of
the approach  taken  in  the  statistical  analysis  of long  term
monitoring data.  The statistically derived parameters, including
variability factors for 24-hour  maximum and 30-day  averages are
presented in  Appendix  A.  Section 9 lays the groundwork for the
estimation of pollutant removal performances for each  nonexcluded
subcategory-  The  candidate priority pollutants to be controlled
in each subcategory  are identified on the basis of the screening
and verification data  and  the rationale for the application of
advanced level technologies is presented.


3.2.4 Treatment System Cost Estimates

     Section 10 presents the general approach to cost  estimating,
discusses  the  assumptions  made, and  gives   the  detailed  cost
estimates  for alternative levels of  treatment and   control. For
each  subcategory verified, the total estimated  installed cost of
a typical BPT treatment system  is developed on  the  basis   of  the
model plant design specifications and estimated  incremental  costs
are given for each of the advanced level  treatment  alternatives.

                              17

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                            SECTION  4
                    SUBCATEGORIZATION  REVIEW
4.1 BASIS FOR SUBCATEGORIZATION


4.1.1 Factors Considered

     The inorganic   chemicals  industry   is    very   large   and
diversified and therefore has been  segmented   into  subcategories
for  the  purpose of establishing  effluent guidelines.   Factors
taken  into consideration  for  subcategorization  include:    raw
materials used, product produced, manufacturing  process employed,
geographical  location, size and  age of  equipment  and  facility
involved,  nonwater  quality  aspects  of  waste characteristics,
water  pollution  control  technology,  treatment  costs,  energy
requirements and solid waste disposal.  Following is  a discussion
of each of the general factors considered for  this  industry.

Raw Material

     Different raw  materials are  used  to manufacture   a   wide
variety  of products, and  vary  from raw brines   and  ores  to  pure
reagent chemicals.  Some proceses use waste or by-product  streams
from  other plants or from other processes within the same plant.

     Because of    this    diversification,   raw     material
characteristics do not  generally constitute a logical  basis for
subcategorization.  Variations in raw material  quality or purity
are not normally sufficient to cause a great difference in waste
water  treatment  needs,  except  in  the  case   of  trace toxic
materials which may occur in some sources but  not in  others.

Dominant Product

     Subcategorization by chemical name of the dominant inorganic
chemical  produced  involves  the  least  ambiguity  in   applying
standards  to a given point source.   This is critical because  of
the great  variety of product mix, manufacturing processes, waste
water  constituents,  and  other  factors  at    existing   plants.
Subcategorization by  product becomes less useful  as product mix
increases in complexity  because  multi-product  waste water   also
becomes  more  complex  and  less  susceptible to simple   uniform

                              18

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treatment.

     A subcategory   established    on  the   basis  of   product
manufactured might have two  or more  different  processes but, in
the majority of cases,  the characteristic of the waste  waters is
similar and  the  same  treatment   technology can be  applied  for
different  process  waste  waters.    If two   or  more  dissimilar
processes produce waste water of  different quality, and different
treatment technologies   have to be  used,  then the subcategory has
to   be  further   classified  or  segmented,  for  example,  the
Chlor-alkali Industry.

Manufacturing Process

     Typically.- inorganic chemicals are  manufactured for captive
or merchant use in  four or  more  steps starting from raw material
to final product.  Two   or  more  different products might use the
same  process but then  the  raw materials used, process sequence,
control,  recycle potential,  handling, and   quality control will
vary,   producing   wastes   of   different    quality.    Primary
subcategorization,  therefore, by  process   is  unlikely  to  be
useful.  However, secondary subcategorization by process has been
necessary in some cases.

Geographical Location

     Inorganic chemical plants exist in  all parts of  the United
States but subcategorization  on   this basis  is not appropriate.
Geographical  location  is important in analyzing the  feasibility
of  various   treatment  alternatives.   Evaporation  ponds   are
functional  only  in areas  where  evaporation  exceeds rainfall.
Ocean dumping and deep  well  disposal are possible only in certain
areas,    and  must  be consistent with local, State and  Federal
laws.  The possibility  of ground  water contamination may preclude
the use of unlined holding and settling ponds in many  locations.

     Thus the influence of  geography, climate, geology,  etc. is
reflected  in  waste  treatment  modifications  and is  primarily
manifest  in the cost  of treatment.   This, of  itself, is not a
good basis for subcategorization.

Plant Size

     Plant size  and production capacity were not found to affect
the  characteristics of the   waste  produced.  Although plant size
can  affect treatment  cost, this  variability  can  be expressed
graphically  or  mathematically  without  the  need  for  further
segmentation of the category.
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Plant Age

     Plant age is not related to waste water volume and  it is not
a  factor in terms of  waste water  quality.  Because most plants
have been enlarged or modified  from their original status,  plant
age is not easily calculated and therefore not a reasonable  basis
for subcategorization.

Nonwater Quality Characteristics

     Airborne emissions from manufacturing operations can be kept
within air quality  control  limits through the use  of  cyclones,
wet scrubbers and other methods.  The nature of the air  pollution
is  related  to  the  products(s)   manufactured  and/or   the  raw
material used.  Since both of these  elements vary widely within
the  inorganic   chemicals  industry,  there   is  no logic   in
subcategorization   on   the   basis    of    nonwater    quality
characteristics.

Treatment Cost

     From a  technical  viewpoint,  subcategorization by common
technological  requirements for treatment processes could provide
a  logical basis  for selecting  one or  more unit  processes  to
accomplish the same treatment function, regardless of the source.
For example, residuals  of dissolved heavy metals will respond to
lime  precipitation  and sedimentation at high pH without respect
to  the specific  origin  of  the metals.  This  "building block"
concept   could   conceivably   result   in   selecting    various
combinations   of  unit   processes   to   meet   the   treatment
requirements. However, if the treatment cost must be expressed in
terms   of   dollars   per  unit   production,   this method  of
subcategorization  crosses  product  lines  and  interferes   with
comparison  of treatment  costs  based  on the  production  of  a
specific chemical.   Even  if  the  unit  operation  is   commonly
applicable for treating  waste  flows of different products,  the
cost of treatment will vary due to variations in quality, loading
and flow rates  and therefore  subcategorization on  the basis of
treatment cost is not recommended.

Energy Cost

     Manufacturing processes  in the Inorganic Chemicals Industry
typically  have  large energy requirements.  In  contrast,  waste
water  treatment processes consume a small fraction of the  total
energy  used.  There appears  to be  no major energy requirements
for  the waste  water treatment  facility  and  subcategorization
on the basis of energy cost is not justified.
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Solid Waste

     Not all  inorganic  manufacturing   processes  produce  solid
wastes. Those that do practice various  disposal  methods, such as
on-site landfills,  contract hauling   to  approved  dump sites or
incineration.   Solid waste  disposal   becomes very site specific
and    exhibits a wide range  of  costs.   Due  to  the  lack  of
uniformity  within  the industry,   solid  waste   generation  and
disposal  practices are not considered  to  be a satisfactory basis
for subcategorization


4.1.2 General conclusions

     If effluent  limitations   are  to be  tied  to  units  of
production,  only  one  method  of  primary  subcategorization is
broadly  applicable  to  the  inorganic chemicals  point  source
category;  that  is,  subdivision   by  dominant product.  However,
there are two subcategories, chlorine  and  titanium dioxide, which
need further subdivision based on  the  difference in the  quantity
and quality of the waste water from the processes.


4.2 SECONDARY SUBCATEGORIZATION


4.2.1 Chlor-Alkali

     Mercury and diaphragm cells are   the   two distinct types  of
electrolytic cells that  are currently used in  the production of
chlorine  and  caustic soda.   Major  process differences  between
mercury  cell and diaphragm  cell   plants   produce  corresponding
differences in the volume and nature  of waste water generated.  A
principal difference is the presence   of mercury as a contaminant
in the waste waters from the mercury  cell  process and asbestos in
the  diaphragm  cell  plant  wastes.    In   addition,   the  total
suspended solids  (TSS) discharges  from  the  two  processes are
significantly different.  The  TSS discharges from diaphragm cell
plants are generally larger than from  mercury cell plants, due to
the higher  volumes of  contact and noncontact water used.  Also,
in diaphragm  cells a large  amount  of water  is  used  and  an
appreciable  quantity of  waste water is  produced in the caustic
evaporation process.  Such water is not produced  in mercury cell
plants.  The quantity of waste water  generated from the diaphragm
cell plants is  almost double that of  the  mercury cell plants for
the same chlorine production capacity.  Based on the quantity and
characteristics of the waste water,  further subcategorization is
j ustified.
                             21

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4.2.2 Titanium Dioxide

     Two major  ores, rutile  and  ilmenite,  are  used  for  the
manufacture of titanium dioxide.  The ilmenite ore contains 40-70
percent titanium dioxide  (Ti02), up to 35 percent ferrous oxide,
and 25 percent  ferric oxide.   Rutile ore  contains  90  percent
Ti02.  Two processing  techniques,  the sulfate process  and  the
chloride process, are used to extract  titanium dioxide  from the
ores.

     The sulfate process  uses ilmenite  ore and sulfuric acid as
raw  materials.   The  chloride  process  uses  rutile  ores  and
chlorine.   The  high  grade  rutile  ore  is  expensive and  its
availability is declining.   New technological advances in recent
years  have alleviated  the  raw  material shortage  problem.  By
upgrading the  ilmenite ore quality,  the chloride process can be
used to produce titanium dioxide of high purity.   Because of the
difference in quality and quantity of waste waters generated from
the sulfate and chloride processes using the  two different ores,
the titanium dioxide industry  may  be  further  subdivided  into
three segments as follows:

     a)  Sulfate process

     b)  Chloride process using rutile ore

     c)  Chloride process using ilmenite ore

     The sulfate process  generates large  amounts of  strong and
weak sulfuric acid water-borne wastes.  Application of  pollution
control technology  to the acid wastes generates about five times
as much gypsum as product.  The chloride process generates  large
amounts of dissolved metal chlorides and the treatment technology
is expensive.  Solid waste  from both processes present difficult
disposal problems.  These solids  include  ferrous sulfate and  a
hydrated by-product  from the  sulfate  process and  heavy  metal
sludges from  the  chloride  process.   Ilmenite  ore  has  to be
upgraded  before it is  used to extract  titanium dioxide  by the
chloride  process, and this beneficiation process step  generates
additional wastes.

     Ilmenite ore  is  a low-grade ore  containing  40-70 percent
Ti02  before  the  use of  chloride  process.   The beneficiation
process  creates  some additional wastes streams.  There  is more
than one patented beneficiation process  and one of the processes
claims  that no waste water is generated and only  a  solid waste
needs to  be  treated  or disposed of  separately.  Thus the same
treatment technology can be used for both the rutile and upgraded
ilmenite  ore for  the process waste water except the  additional
treatment of some streams generated from the beneficiation  step.

     Therefore, further subclassification based on the amount and

                              22

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characteristics  of the waste water appears to  be justified,_and
the  three process  subdivisions indicated above are  appropriate
for this purpose.


4.2.3 Hydrogen Cyanide

     Hydrogen cyanide  is made from  two different processes, the
Andrussow  process   and   as  a   by-product  of _  acrylonitrile
manufacture.  In the Andrussow process,  air, ammonia, and natural
gas are reacted to produce the dominant  product hydrogen cyanide.

     Water-borne wastes from the process  consist  principally of
ammonia and sulfates in addition to cyanide and nitriles.

     The dominant product in the other process is  acrylonitrile.
The  required  treatment technology for  the Andrussow process  is
not applicable to the HCN  by-product stream in  an acrylonitrile
plant since neither solid nor water borne wastes  are  generated.
All tail gas streams are burned  to destroy any unrecoverable HCN
before venting  to the  atmosphere.  Further subclass!fication by
process seems logical.


4.3 INTEGRATION OF SUBCATEGORIES
4.3.1 Hydrofluoric Acid and Aluminum Fluoride

     Aluminum fluoride  is predominantly produced by the reaction
of hydrated  alumina with hydrogen fluoride,  although  one plant
produces aluminum fluoride from fluorosil icic acid, a  by-product
of  phosphoric  acid.   With  one  exception,  all  the  aluminum
fluoride  plants   are  integrated  with  hydrogen  fluoride  (or
hydrofluoric acid)  production.

     The two  major  uses   of  hydrogen  fluoride  are  in  the
fluorocarbon industry  and as raw  material in the manufacture of
aluminum  fluoride.   A ban on  the  fluorocarbon propellants has
curtailed  the use of hydrogen  fluoride in that  industry and it
will  be  completely  stopped in 1978.    The selling  of hydrogen
fluoride in the  merchant  market will  decline in the  future and
the  primary  use will be limited  to  the production of aluminum
fluoride  and fluorocarbon plastics (e.g., Teflon,  Kel-F,  etc.)
until some other major use is found.

     For both products  (HF  and  A1F3), process waste waters are
generated by the  various gas scrubbers and by leaks and  spills.
In  both cases, air pollution control  scrubber effluents contain
mainly fluoride, acidity and sulfate.  The fluoride is present as
the  free  ion  as well as various complex fluoro anions. Calcium
fluoride, generated  as a solid  waste, is a disposal problem for

                              23

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both  the  subcategories because of its moderate  toxicity.  Only
one   additional  solid   waste,  gypsum  (calcium  sulfate),  is
generated from  the hydrogen fluoride  manufacture  alone, and it
can be treated and handled independently-

     Combining hydrofluoric acid  and aluminum  fluoride  into  a
single  subcategory  does not  appear  to  offer  any  regulatory
advantages when  the two products are  manufactured  at  the same
plant  location.   The  waste  waters  associated  with  the  two
products are similar and a common treatment  facility is normally
utilized.     However,      the   combined  manufacture  of  these
products does not in itself create a unique or unusual situation,
either with regard to the waste water treatement requirements  or
the  compliance with  discharge regulations.  Although  the waste
gypsum  produced at  an  HF  plant supplies enough  calicium  for
adequate  fluoride removal from neutralized scrubber waste waters
generated  by both HF and AIF3 production,  the applied treatment
technology  is   essentially   the  same  as   that  applied   by
manufacturers of  either product alone.  Therefore,  the effluent
water  quality and the mass  emission limitations would  also  be
expected  to be  the same.   Further,  the opportunities for drip
acid recycle  (or the  hydrolysis  of complex fluorides prior  to
treatment) and scrubber  water recycle are  a function  of  plant
design and age, rather than product mix.

     In view  of these considerations,  a recommendation for  the
creation of an HF/AIF3 combined  product subcategory is not being
made at this time.
4.4 SUMMARY

     The recommended subcategorization  with process subdivisions
include the following:


     Subcategory                      Process Subdivisions
     Chlor-Alkali                   Mercury Cell
                                    Diaphragm Cell
     Titanium Dioxide               Sulfate
                                    Chloride-Rutile
                                    Chloride-Ilmenite
     Hydrogen Cyanide               Andrussow Process
                                    Acrylonitrile By-Product
                             24

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                            SECTION 5
          SCREENING AND VERIFICATION  SAMPLING PROGRAMS
5.1 SCOPE  AND METHODOLOGY
     The specific   objective  of  the   sampling  programs  was   to
establish  the  extent  of the  need  for  regulation  of priority
pollutant discharges in the inorganic  chemicals  industry in  terms
of  factual  information derived from  the chemical   analysis  and
flow  measurement   of  representative   process  raw  waste  water
streams and treated effluents.  Prior  to this study, most of  the
information available on priority pollutants in  this industry  has
been  concerned    with  a  relatively   small  number   of   known
process-related  substances  contaminating a  variety of direct  and
indirect contact process waters  which  may  be discharged from  a
production facility.  There had been no previous requirement  for
a comprehensive  survey of  waste water  chemistry addressing  the
possibility that  a  large  number  of  other potentially  toxic
substances   could   be   present,  albeit    at   extremely  low
concentrations.

     The screening phase of the sampling program was  designed to
ascertain  the presence in  each  subcategory of any of  the  129
listed priority  pollutants at raw  waste concentrations  or  daily
loadings   which,    if   untreated,   could    be environmentally
significiant.  Screening is based on  the sampling  of one or more
typical  manufacturing  operations  in each   subcategory.   Where
such  pollutant  concentrations were found, additional plants were
sampled  during   the  verification  phase  for  confirmation  and
further  quantification  of  data  on   the  particular   priority
pollutants in  question.  As a goal,   screening  and  verification
sampling,  in  each  subcategory where  priority pollutants were
found in significant  concentrations,   would cover   a  sufficient
number of plants to account for 75 percent or more  of the current
total U.S.  Production.

     A detailed   description of the  screening  and  verification
programs is presented in the paragraphs below.
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5.1.1 Selecting Plants and Making Preliminary Contacts

     In each subcategory,   plants  were selected for screening on
the basis of the following general criteria:

     1.   Minimal product  mix and no organic  product lines
          which could increase the potential  for inter-
          process cross contamination of waste waters.


     2.   Presence of a physical  chemical treatment facility
          rather than a biological one, or no treatment system.
          (Biological systems are neither widely used nor generally
          applicable in the inorganic chemicals industries.)


     3.   Manufacture of industrial grade products in volume,
          rather than low  volume  reagent grade products.


     4.   Median production capacity within the subcategory.


     5.   Segregated waste streams to facilitate sampling.


     6.   NPDES discharges rather than POTW discharges,
          since treatment  for a NPDES discharge is usually
          more extensive.
     7.   Geographical clustering  of selected plants to
          facilitate field logistics.
     Plants were  identified   which  satisfied  as  many  of  the
criteria as  possible,   and  preliminary contacts  with corporate
representatives  were made by phone.   If requested, a letter  was
written to describe the objectives of the sampling program and to
cite  the   legal  authority   of  the  Agency  and  its  sampling
contractor  under  Section 308  of  the Federal  Water Pollution
Control  Act  Amendments  of   1972.    Secrecy  agreements,  when
required, were executed at this time for  the protection of  any
company proprietary  information which might be disclosed to  the
sampling contractor.

     Prior to  the actual  sampling of waste streams, a lead visit
to the selected  plant  was made to gather background information,
confirm  and update any 308 Questionaire responses, and to obtain
additional  technical information regarding processes  and  waste
treatment practices.   Sampling sites  were selected and  described

                              26

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in  relation  to a  detailed waste  source inventory  and a  flow
diagram of the process and waste treatment system.   Arrangements
were made  for  the  subsequent sampling visit and the details of
the lead visit and sampling point descriptions were documented in
an interim report to the Agency.


5.1.2 Screening and Verification Sampling


Collection of Samples for Screening

     In the screening phase of the sampling program, the specific
objective was the  detection  and  quantification of  water-borne
waste   constituents  included  on  the  list  of  129   priority
pollutants (Table 3-2).  Each  sample of an individual  raw waste
stream, a  combined  waste stream,  or  a  treated  effluent  was
collected where possible by an automatic, time series, compositor
over   a  single  72-hour  sampling   period.    Where  automatic
compositing  was  not   possible,  grab  samples  were  taken  at
intervals  during  the  same   sampling   period  and  composited
manually-

     Each sample was divided into several portions and preserved,
as required  for different types of analysis, in accordance  with
the procedure established  by  EPA  (4)  for the  measurement  of
priority pollutants.

     Samples were   also  taken   from  the  composites,  or  as
individual  grabs,  for  the  analysis  of  the  classical  (BPT)
pollutants.


Collection of Samples for Verification

     The objective of  verification sampling  was to  confirm the
presence  and  further  quantify  the  concentrations  and  waste
loadings of the priority pollutants found  at significant  levels
during the screening phase of the program.


     The established protocol  for verification sampling required
the  collection of  three  24-hour  composites  at  each sampling
point.  Again, where composites could not be taken with automatic
samplers, grab samples were taken periodically over the same time
period and composited manually.


Sample Shipping

     All samples,  individually  labeled,  were  placed  in large
plastic bags, which were  then  placed in a waterproof  insulated

                              27

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shipping  container.   Enough  ice  was  included  to  maintain  a
temperature of approximately 4  degrees C.  during shipment to the
laboratory.

     Containers were  shipped by the best available route, usually
air freight, arriving at the laboratory on  the same or  the  next
day.

     In order to maintain the chain of custody and  to keep track
of samples, sampling  personnel kept logs of samples taken in  ink
in page numbered  hard-bound books.  The data recorded included:
date, time,  plant code, number, sample  type, and sampler.  This
information was also  included on the label  of individual samples.
Prior to  their arrival at  the  laboratory, a  list  of  samples
shipped,  including number,   type of samples,  and analysis to be
performed, was  sent  to each department supervisor  to alert them
of incoming work.

     A master  analytical  control  chart  was  maintained  which
included: date sample was received, date due, number and type  of
each sample, and the  analysis required.

     At time of analysis, the individual samples were distributed
to the  analytical  chemists along  with a list which  included:
I.D. number of sample,  type  of sample, analysis  required, date
samples received, due dates.

     Upon completion  of analysis, the sample was sent back to the
refrigerator  and placed in  identified bins.   All  samples  were
kept in the refrigerator at  4 degrees C. when not being analyzed.
A list  of  completed  samples was then sent  to  the EPA  Sample
Control Center.


5.1.3 Analytical Methodology for Priority Pollutants

     The analytical protocol  for the screening and  verification
of priority pollutants was established by the EPA in April  1977.

     The specified analytical methodologies were employed without
modification except where noted below in connection with priority
metals analysis during verification.

     Implementation of  the   methodology and  quality  assurance
provisions required  the establishment of special sample handling
and  control  procedures  specifically  suited  to  each  type of
analysis.  These  procedures,  together  with a discussion of the
achievable  detection  limits  for  each parameter  or  group of
similar parameters are presented in the following paragraphs.
                             28

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Trace Metal Analysis

     Figure 5-1 shows a data flow diagram for metals analysis.   A
set  procedure  was followed in the  laboratory to  generate  the
analytical  values and the quality  control  data. The data  flow
diagram  shows  the  actual  sequence  employed  in  verification
analysis and the following notes, which are keyed to the diagram,
provide additional information on the procedures:

     (1)  Blanks - two for each set of analyses digested.
          Duplicates - one every seventh sample.

     (2)  Quality Control at AA Operator Level:

            Blanks - These were run at the beginning and the
                     end of every set analyzed for each metal.
                     Also, air blanks were run on furnace, or
                     heated graphite atomizer, (HGA),  after any
                     sample with a large positive value.

            Standards - Three different concentrations were
                     run at the beginning and end of every set
                     analyzed for each metal.  Standards were
                     also run every tenth sample during the
                     analysis of a set.

            Spikes - These were run every seventh sample,
                     and were made by taking a mixture of equal
                     parts of a sample and standard and comparing
                     the resulting absorbance with individual
                     sample and standard absorbances.

            Duplicates - For furnace analysis, the sample
                     was run twice when the absorbance was low
                     to identify errors.
                     The average of the two values was used as
                     the determinate value.

     (3)  UTD = Unable To Determine due to matrix
          interferences.

     (4)  Criteria Employed in Spike Selection:

          (a)   Samples were chosen to be spiked
          based upon the following criteria:
               - those which were not subject to interference
                 effects.
               - those that had a measurable concentration of the
                 metal being determined.
               - those whose concentration was in the linear
                 range of the instrument.
               - approximately every seventh sample.

                                29

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                                                       FIELD SAMPLING
                                                     PRESERVATIVE ADDED
                                                        ICED, AND AIR
                                                     	SHIPPED
                                                   RECEIPT, LOG IN SAMPLES
                                                       AND REFRIGERATE
                                                  QUALITY CONTROL BLANKS AND
                                                    DUPLICATES CREATED  (1)
to
O
PREPARATION
BY
ACID DIGESTION








:^^ 	 1 ATOMIC ABSORPTION ANALYSIS (2) I

1

RNACE FLAME
Pb.Sb.Tl) [* (Ag,Be,Cr,Cu,Ni
1
1
DETERMINATE OFF-SCALE
VALUE RESULT
i
|_ DILUTE
LYSIS 1 SAMPLE
\^
^\^
1 ^"^-A.
DETERMINATE _
VALUE ^


,Zn)

1


DETERMINATE
VALUE
1



CALCULATIONS &
ANALYSIS OF
RESULTS
^


f-

r*


^



VAPOR GENERAT
-(Hg)
1
1
OFF-SCALE DET1
RESULT i
1
DILUTE
SAMPLE



SELECTION OF
SPIKED (4)


ICN

|
EBMINATE
UAIJUE




                                                                                                                           HYDRIDE GEI^ERATION
                                                                                                                                (As,Se)
                            ANALYSIS
                                                                                  Figure 5-1  .  Sanple flow  sheet for nefcals.

-------
          (b)   The  level  of spike chosen was
               controlled by the following factors:
               - it should be approximately 40-60 percent
                 of the  determinate value.
               - the determinate value absorbance + spike
                 absorbance must give total absorbance
                 that was within the linear range.
          (c)
A reagent blank was run with each set of spiked
samples prepared.
     During  the  screening  phase  of  the  sampling program, the
standard protocol followed for metals analysis was:


     1.   Twelve elements were determined by AA  spectrophotometry
in the furnace (HGA)  mode.

     2.   If  subject to matrix  interference (UTD),  they were then
determined in the flame mode.

     3.   Mercury  was  determined  by  the  standard  cold  vapor
method.

     Certain changes   in  analytical  protocol  were  instituted
during verification  analysis  in  order to  avoid  the  excessive
matrix interference experienced  during screening  when the heated
graphite atomizer (HGA)  was the primary method  applied  to  the
analysis  of 12 of the metals.  The modified  protocol for metals
was:

     1.   Six elements were determined by flame only,
         namely, Ag ,  Be, Cu, Cr, Ni and Zn.
     2.   Four elements were determined by furnace  (HGA),
         namely, CD,  Pb , Tl and Sb.  If interference
         occurred, Cd, Pb, Tl and Sb were determined
         by  flame.
     3.   Hg  was still analyzed by the cold vapor method.


     This modification reduced  the number  of  preparations  per
sample from  three to  two and  achieved adequate detection limits
which were still well below the verification criteria levels.

     Additional modifications  were made  during the verification
program  to improve the reproducibility  and  detection limits for
Hg,  As and Se.  These were:

     1.   The cold vapor procedure for Hg was modified to
         eliminate the pump and allow dilution and  rerun
         from the same sample.  This saved time and increased

                               31

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         reproducibility.


     2.   Selenium and  arsenic  were determined
         by hydride generation using  sodium borohydride
         (NaBH4).  This greatly minimized problems associated
         with matrix interference.  The  method is very
         reproducible  and  the  detection  limits were at
         levels well below the verification criteria for
         these two elements.

     After the  above   modifications   were  adopted,  screening
samples which  originally   were unable to be  analyzed, or  which
were recorded  at excessively  high "less than" values  due to the
effects  of  matrix  interferences  on  the  achievable detection
limits,   were rerun.  Satisfactory results  were then obtained in
nearly all cases due  to the   greatly improved  sensitivity  and
reproducibility.

     Table 5-1  presents  a  summary   of the analytical detection
limits for  each  of  the  13   priority metals using  the original
protocol and the two subsequent modifications which were applied.

     The detection  limits shown  reflect the maximum sensitivity
that  can  be  consistently  obtained in  the absence  of  matrix
interferences.
Organic Compound Analysis

     The organic  priority  pollutants  were  determined  by  the
standard protocol which includes sample preparation,  extraction,
and analytical methodologies.   Extractions were carried out using
methylene chloride  in the  case  of  the  acid and  base/neutral
organic fractions  and  with  hexane/methylene chloride to obtain
the  pesticide containing fractions.  The  acid and  base/neutral
fractions  were   reduced   in   volume  and   analyzed  by   gas
chroraatography-mass  spectrometry  (GC/MS).  The  pesticides were
analyzed by electron capture gas chromatography followed by GC/MS
confirmation  of   positive  results.    Volatile   organics  were
analyzed by the purge and trap method  of introducing the material
into the GC/MS inlet system.


Analysis of Cyanide and Chromium VI

     The standard  methods for the wet chemical analysis of total
cyanide and  cyanide  amenable  to  chlorination  were  utilized.
Cyanide analysis is subject to several  sources  of  interference
including:
                               32

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TABLE 5-1
ANALYTICAL DETECTION LIMITS FOR METALS
 (assuming no matrix interferences requiring dilution
 of sample)

Element
Antimony, Sb
Arsenic, As
Beryllium, Be
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni
Selenium, Se
Silver, Ag
Thallium, Tl
Zinc, Zn
Original Screening
Protocol
(ng/l)
HGA *
EGA.
HGA
HGA
HGA
HGA
HGA
Cold Vapor
HGA
HGA
HGA
HGA
HGA
10
3
0.2
1
1
1
10
0.5
1
9
0.5
2
1
First Modification
of Protocol
(vg/1)
HGA
HGA
Flame
HGA
Flame
Flame
HGA
Cold Vapor
Flame
HGA
Flame
HGA
Flame
10
3
15
1
25
20
10
0.5
25
9
15
2
25
Second Modification
of Protocol
(yg/D
HGA
Hydride
Flame
HGA
Flame
Flame
HGA
New Cold
Flame
Hydride
Flame
HGA
Flame
10
10
15
1
25
20
10
Vapor 0.5
25
10
15
2
1
 Heated Graphite Atomizer
                                    33

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     Metals - The  presence of  Fe ,   Cd,   Ca,  Ni, Ag, and  Zn may
causelow results due to the  formation  of stable complexes with
cyanide.   The iron  complexes  may  form   insoluble  precipitates
which are  particularly difficult to break up  both at the time of
alkaline  chlorination of the  sampled  waste water and during the
chemical  analysis for cyanide.

     Oxidizing agents  -  The  presence of free chlorine  in _ the
waste "water  sample will destroy cyanide  and cause low analytical
results.   The addition of ascorbic  acid   to destroy chlorine  at
the time  of sampling is intended to  mitigate this problem.  Other
oxidizing agents such as  peroxides  and  chromates may also react
with cyanides over a period of time  and cause  low results.

     Sulfides -  Sulfide  or  bisulfide  will   interfere  in  the
analysis  of cyanide by reacting with the  colorometric reagents.

     The  presence of sulfur  dioxide  or  bisulfite  in the  waste
water  sample  should  have  no  appreciable  effect  on  cyanide
results.    Detection  limits  on  the  order  of 1-4 ug/1 can  be
achieved  by the analytical  method employed, but the results have
to  be  interpreted  with  regard  to  the  possible  interfering
components of the sample.

     The  determination of chromium VI  in waste  water samples  is
also subject to  a  number of interferences which can take effect
either during sampling and storage or during analysis.

     Acids -  Samples  taken  and held at  a   very  low  pH can
experience the conversion of  other  forms of  chromium into Cr  VI
causing a positive interference.

     Reducing agents   -  Samples   containing  sulfur  dioxide,
bisulfite, bisulfide, sulfide,  ferrous  iron, and other reducing
agents will result in low values of  Cr VI by converting it to  Cr
III.   Under  these  conditions  the chromates originally present
would be   included in the  total  chromium determination but the
analytical   results   for   hexavalent   chromium    would    be
proportionately low.

     The  detection limits  for  Cr VI using the diphenylcarbazide
colorometric method are  on the order of  1-3 ug/1 in the  absence
of substances which interfere with color  development.


Asbestos  Fiber Analysis

     The_analysis  of   selected  samples  for  asbestos   fiber
(cnrysotile)   was conducted by the  recommended  method utilizing
transmission election microscopy with selected
                               34

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area electron  diffraction as described by Dr.   Charles Anderson
(EPA,   Athens,   Georgia)   at the Analytical  Protocol  Meeting in
Denver (November,  1977).
Conventional and Nonconventional Pollutants

     All techniques  used  for   the  analysis  of  BPT  control
parameters  (conventional  and nonconventional  pollutants)   were
those  recommended  by  the  Agency.  The list  of approved   test
procedures was  published in  the Federal Register on October 16,
1973 (38 FR 28758) and  may be also found in Title 40 of the Code
of Federal Regulations (40 CFR 136).

5.1.4 Quality Assurance Provisions

     The Agency  and  the  contractor's  analytical  laboratories
maintain consistently  high  standards for  accuracy  and quality
control.  As an in-house requirement,  a minimum of ten percent of
all  samples are  routinely  run  in duplicate.   Quantitation is
based on standards that are prepared  in  the same matrix as  the
samples.  The  standards are also checked by participation in the
EPA  Reference  Sample  Program  that  utilizes  a  double  blind
technique.

     Additionally, outside  laboratories are retained for  checks
on  quality  by  analyzing split  samples and  running  submitted
standards.  Accuracy is also  insured by analysis of a minimum of
fifteen  percent  of all samples  with  spikes  by the method  of
standard  additions.   The  spikes  are  added  prior  to  sample
preparation and are carried  through  the  entire sample analysis
procedure.

     The contractor's  laboratories have consistently  maintained
the  standards for laboratory certification which are imposed  by
the  State of California.   Certification  is dependent upon  the
accurate  performance   of  routine  analyses  on  check  samples
submitted by  the State, as  well as on-site inspections  by  the
State  of   California's  Sanitation  and  Radiation  Laboratory,
Department  of  Fish  and  Game, and  the  U.  S.   Environmental
Protection Agency, NEIC, Denver, Colorado.

     The quality  assurance  provisions  outlined  in  the   EPA
Protocol for GC/MS Analysis of Priority Pollutants are rigorously
adhered to with one added precaution,  namely, the use of internal
standards  as  a  means  of  measuring  recovery.   Although  not
required  by  the protocol for pesticide analysis, this technique
is utilized as an  in-house quality control requirement to insure
the accuracy of results in this analysis.

     The high  sensitivity  of  instrumentation  used  in  trace
organic  chemical  analysis  dictates that contamination  of  the

                               35

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samples from  any  possible  source must  be  diligently  guarded
against.    Accordingly,   only   glass   sample  containers  with
Teflon-lined lids were used and these  were subjected to a three-
step cleaning procedure prior to use, even though only new liners
and glass containers  were  used.   All glassware used_for sample
preparation and analysis was subjected to a dual cleaning system.

     The sample extraction and  preparation  rooms were dedicated
solely  to  priority  pollutant  analysis,  and  have  their  own
ventilation  systems  that  are isolated  from^ the other  sample
preparation and receipt areas of the laboratories.

     A documented   system  of   existing  practices,  including
calibrations  and  operational  checks  is maintained  to  assure
uniformity of performance and to serve  as a basis for alteration
of standardization intervals.  A chemist is assigned full time to
maintain  this  system,  assure  strict  record   formating   and
controls,  and  to  direct  the  quality  control  program of the
laboratories.  The primary vehicle of this system is the  quality
assurance  manual  containing the  detailed  procedures  used  in
sample preparation and analysis, and the complete  records of all
quality control standards, blanks, spikes and duplicates.
5.2 THE BASIS FOR VERIFICATION SAMPLING

     The screening  program  results were  evaluated to  identify
those  priority  pollutants  that  were  present  at  significant
concentration  or significant  daily loadings.  Concentrations or
loadings which could be reduced by the  highest quality treatment
systems were considered significant.


     1.  A subcategory which had a significant raw waste
         concentration of any priority pollutant(s)
         would be subject to verification sampling,  and BAT-
         based regulations would likely be proposed  by the
         Agency for the treatment and control of that
         priority pollutant.

     2.  A subcategory which had no significant raw waste
         concentration of any priority pollutant
         would not be subject to verification
         sampling and would likely be excluded from
         regulatory coverage at this time in accordance
         with the provisions for exclusion under
         Paragraph 8 of the Settlement Agreement.
                               36

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     In analyzing    screening   data,   only   those   pollutants
attributable  to  process  sources were  considered.   Pollutants
which  result  from   cooling  tower  operations,  corrosion   or
corrosion control,   control  of biological growth,  or any  other
operation not directly tied  to the  production  process were not
used as a basis for verification.
5.3 THE VERIFICATION PROGRAM

     After the  decision  was  made  to  verify  the  presence of
priority  pollutants found  in  the  screening of  a subcategory,
verification plants were selected.   The  basis for selection was
essentially the same as that used in selecting screening  plants.

     In some  subcategories, plants which  had been screened were
also sampled again in verification.

     The number  of plants  selected  for  verification  in  each
subcategory was roughly proportional  to the  number of  existing
plants  in  that  subcategory  with  a  maximum  of  five  plants
selected.   In  small  subcategories (relatively  few  production
facilities), an  effort was made to select a sufficient number of
plants to account for the majority of the total U.S.  Production.
Very small producers were not selected.

     The sampling   methods  and  analytical  protocol  used  in
verification have been described in Sections 5.1.2 and 5.1.3.

     When the verification phase of the program was initiated, an
important  decision  was made  with  regard to  metals  analysis.
First, in view of the frequent presence of metal contamination in
the  wastes screened,  and the inability in some cases to show  a
direct relationship  between certain metals  found  and the known
process  chemicals  or the  materials  of  construction,  it  was
decided that all 13 of the priority metals  should be  determined
again during verification, regardless of whether  they were found
in screening.  This was intended to provide a much more  complete
data base than would be obtained by running verification analyses
for  only  those   metals  found  in  screening  to  exceed   the
verification criteria levels at the time of sampling.
                               37

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                           SECTION 6
                   PROCESS AND WASTE TREATMENT
             INFORMATION DEVELOPMENT AND EVALUATION
6.1 INDUSTRY DATA BASE DESCRIPTION
6.1.1   Data Acquisition

     Information and  data  on  the  inorganic chemicals industry
were obtained from  a number of sources.  These sources  included
literature reviews,  plant  visits and data collection, telephone
contacts,   and   industry   responses   to   the   Section   308
Questionnaires. The type of material gathered from these  sources
is briefly discussed below.
Literature Review

     A review of the literature has been  conducted  to  identify
and collect information  related to manufacturing  processes, raw
materials, water use and wastewater sources, wastewater treatment
technology,  raw  waste  characteristics,  and   economic   data.
Relevant  articles  in  the  form  of  reports,  books,   papers,
conference  presentations  and  periodicals  were  identified  by
computer search  and are  presented in the reference  section  of
this  report.    This   information   was  incorporated  into   a
broad-based  assessment of process and technology practices aimed
at  selecting the best  available  treatment technology  and best
demonstrated technology for the  various  industry subcategories.
It also  provided  the  background  required  for  evaluating the
subcategorization of the industries.


Plant Visits

     During the screening and verification phase of this project,
much information was gathered  from individual plants relating to
production capacity, manufacturing processes, waste flows,  water
reuse, waste water  treatment systems and performance,  and  best
management practices  (BMP).   The  lead visits  also provided  an
opportunity to update and clarify  some  of the information given
in the 308 responses.

                               38

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Telephone and Direct Contact

     Numerous contacts were  made with knowledgeable  persons  in
both industry and government to gather and  exchange  information
concerning all  phases of this study.   These sources are cited in
the text as personal communications.


308 Questionnaire Responses

     The basis for  much of the  work  in this study is the set of
responses  from industrial inorganic   chemical  firms  to the 308
data requests.
     Data from 284 manufacturers'  responses were
project team  for the development  of appropriate
the inorganic  chemicals subcategory.  Industrial
their  compliance  with  the  needs  of  the  308
provided  a valuable industry-wide data base used
this analysis.
        utilized by  the
         guidelines  for
         firms,  through
          Questionnaire,
         extensively  in
     Essential data  elements  from  each   questionnaire   were
extracted  for the purpose  of creating a  working data  base for
this  report.   Specific  elements  selected  for  this  smaller,
more-manageable  data  base  are  given  in  the  outline  on the
following page.
     These data  provided  the basis for
through  a profile of  each  industry.
questionnaire  data,  industry totals for
(for  the  respondents)  were available.
the  subcategory  review
After compilation of the
capacity and  production
 In addition, derivative
quantities  such  as  percent  utilization,  effluent per  ton  of
product, conversion to metric units,  were compiled from the  data
elements listed below:
                               39

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                 308 Questionnaire Response Data
                    Data Elements used in this
               Inorganic Chemicals Guidelines Study
  Datum Reference

Manufacturer



Product
     Description
Plant
Process
Effluent Treatment
Name
Location
EPA Region

Name
Subcategory

Number of other
Products

Capacity
Production
Age

Name
Volume of Process
Effluent
Volume of Noncontact
Effluent

Type
Permit
Major Pollutants
     Comments

Confidential
                                                 Inorganic
                                                 Chemicals
1976
1976
1976
                                40

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6.2 PROCESS WASTE SOURCES AND CURRENT TREATMENT PRACTICES

6.2.1 Data Acquisition

     The information presented  in this section was obtained from
a  variety  of  published  sources  and  the  available  industry
responses to the 308 Questionnaires as well  as from plant visits
and interviews with  industry personnel  conducted by  the Agency
and its contractor  during the  priority pollutant _screening and
verification program.  The  results of  visits and interviews are
documented in field notebooks,  interim  plant visit reports, and
telephone communication records which are  part of  the permanent
project file.

     Plant visits were  particularly  useful  for  confirming and
updating the  detailed technical information contained in the 308
Questionnaire responses.  The cooperative and helpful attitude on
the  part  of industry greatly  facilitated  the  acquisition  of
reliable operating data and meaningful sampling results.


6.2.2 Evaluation p_f Data

     Each of  the  subcategories  which  were carried through the
verification  sampling program  as  the  result  of  the priority
pollutant  levels found  during screening,  is the subject of  an
extensive review and evaluation intended to provide the technical
basis for selecting candidate advanced treatment technologies and
developing the related base and incremental cost estimations.  In
the subsections  which  follow, individual plant descriptions are
presented  in   accordance  with  the  general  format  for  each
subcategory:

     General Process Description
       Description of process reactions and unit operations.
       Inventory of raw materials used.
       Typical process flow diagram.

     Water Use and Waste Source Inventory
       Description of individual plants visited, sampled
         and plant information from other sources.
       Inventory of water uses for contact and noncontact
         purposes.
       Inventory of raw process waste water sources and
         identification of sampling points.
       Process waste water quality and flow data.
       Solid waste generation and disposal.

     Control and Treatment Practices
       Description of specific treatment technologies
         and operating facilities.

                               41

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       Description  of  the  total  input  to  the  treatment system
         including  sources attributed  to  other  production
         operations and  noncontact water  (e.g.,  cooling water,
         etc.) .

     Evaluation  of  Production and  Waste  Flow  Data
       Tabular  summary of  plant-specific  data.
       Waste  flows  per unit of production (unit  waste  flows)
         with the  range  and average values.
       Solid  waste  quantities.
       Treatment chemical  requirements.

     Process  Modifications and Technology Transfer Options

     Best Management Practices (BMP)
       Plant  area  operations and housekeeping.
       Runoff control.
       Solid  waste  handling (e.g., fugitive dust and
         leachate  control, etc.).


6.2.3 Model  Plant  and  BPT  Treatment System Specification

     The model   plant   concept  plays  a  central  role  in both  the
development  of alternative  treatment  system  designs for priority
pollutant removal  and  for  estimating the   related  internal  costs
of  such   treatment  in  each  subcategory.     In  order  to   be
representative   of  a  subcategory,  each set of model  plant
specifications was  composited from a profile  data  summary derived
from the available  information on production  and waste flow.

     Based on  the  typically  achievable  waste  flow rate per  unit
of production/   the model  plant  was used as  a  starting point  for
laying  out  an appropriately designed  and  sized BPT  level waste
water  treatment system.   Certain  assumptions had to  be made
regarding the possible process  variations and  the specific  raw
waste sources incorporated into each model  and  in most  cases it
was found appropriate  to assume that  the waste  flow per unit   of
production did not vary over  the particular   range of production
capacities to be covered.   Production  rates were selected in most
subcategories to represent the  small, mid-range and  large  size
plants  presently    in   operation.   Small   subcategories   were
represented  by single  mid-range production  rates   for the  model
plants.  Cost estimates were developed for each set of base level
(BPT) and  advanced  level  (BAT/NSPS)  treatment   system  design
specifications.

     In Sections  11-25,  the   model plant  and   BPT  level treatment
system  descriptions  and   specifications  for   each  subcategory
include the  following  information:
                               42

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         Production rates  and  mode of operation.
         Specific  process  type and waste sources.
         Waste flow per  unit of production.
         Solid waste generation and handling.
         Treatment chemical  requirements.


     If applicable,  the new source model  plant is also described
and  the  design specifications  given  for  its  waste  treatment
system.


6. 2.4  Dissolved Solids  _in Waste Water Effluents

     Many waste  treatment plants discharge   final  effluent into
watercourses which feed  fresh  water  streams used  as sources  of
water supply by  downstream  agencies or  industries.  Groundwater
aquifers  which underlie large portions of the country are tapped
to supply fresh water through  wells serving  public and industrial
water needs.  In both cases  saline wastes  discharged into streams
or into unlined lagoons  can  significantly  alter  the salt content
(total  dissolved  solids)   of  the fresh  water.  Although Federal
regulations  seldom  limit  the  total  dissolved  solids  or the
various ions such  as chloride, sulfate, bicarbonate, and nitrate,
these  constituents can  be  of  serious concern to  local  water
users.

     To protect the  mineral quality of ground and surface waters
State  and  local   water  pollution  control  agencies  typically
establish limits on the  discharge of substances which contribute
sodium, potassium, hardness, chloride, sulfate, and conductivity,
which is a measure of total  solids in solution.  This restriction
can  play an  important  part  in  choosing  chemicals  for  waste
treatment.    For    example,   alkaline   precipitation  can   be
accomplished by  using  lime,   which  forms  an insoluble  calcium
sludge, or by adding caustic soda, forming a soluble sodium salt.

     In choosing an acid  for  neutralization of  alkaline wastes,
it is important to  weigh   the overall  effects of chloride (from
hydrochloric acid)  and sulfate (from sulfuric acid) , particularly
with respect to irrigational use of the receiving water.

     Chemicals used in the model plant processes were selected on
the basis of best  performance, including consideration of scaling
problems, which  can  be severe when  calcium and sulfate are  at
saturation levels.  It may  be  necessary to alter  the nature of
chemicals used at  a specific plant, in order to  meet local water
quality requirements.
                               43

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                            SECTION 7


TREATMENT AND CONTROL ALTERNATIVES FOR ADVANCED LEVEL APPLICATIONS



7.1 TREATMENT TECHNOLOGY ASSESSMENT


7.1.1 Introduction

     In the  inorganic chemicals  industry,  pollution  abatement
practices vary and a  wide range of treatment technologies can be
found, ranging  from no  treatment to the  application  of highly
advanced techonolgies for the removal of specific pollutants.

     Until the  NRDC  Consent  Decree,  industry  attention  was*
primarily  directed towards general  pollution problems including
removal  of trace  metals, but  not towards treatment of over  100
individual specific organic  compounds  now  listed  as  priority
pollutants.   Even   with   the   classical   (conventional   and
nonconventional)    pollutants,  treatment  technology   has  been
directed to removal down  to the  part per million level, whereas
now the  thrust  is towards part per  billion level requirements.
For both these reasons,  suitable  BAT  technologies  are  not in
place in the inorganic chemicals industry, and it is necessary to
look into technologies that have been applied in other industries
or developed at the laboratory or pilot plant  scale specifically
for the removal of these  toxic substances  from industrial waste
water, and  determine  whether  they can  be  adopted  as  viable
technological options.

     A list of  candidate  technologies  was  compiled  from  the
literature, in-house expertise,  and  industry  contacts.   These
were evaluated with respect to:

     1.  Treatment effectiveness

     2.  Cost

     3.  Nonwater pollution environmental effects

     4.  Applications in the inorganic chemicals industry
         or on other industrial wastes with similar waste
         water characteristics.

                               44

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     The anticipation that few of the organic priority pollutants
would be found in inorganic  chemical wastes was justified by the
results  of  the   analytical  programs.   Only  one   industrial
subcategory,  namely,  Chlor-Alkali  production   using  graphite
anodes had potentially  significant  levels of  organic  priority
pollutants.  As a  result, the  initial search for  candidate BAT
technologies became limited  to  treatment technologies  for  the
thirteen metals, cyanide,  and asbestos.

     The technologies finally  adopted  were  not  new or untried
technologies since  it was found that most treatment requirements
could  be met by  taking  conventional  techniques—for  example,
chemical precipitation—and developing them to a higher degree of
engineering and  design sophistication, so  that  optimum removal
efficiencies could be achieved.

     The following  pages   describe  the  theoretical  basis  for
treatment systems adopted  for BAT application.


7.1.2  Hydroxide Precipitation

     Hydroxide precipitation  is  the most widely used technology
for removing trace metals  from waste waters, with lime or caustic
soda commonly used to supply the hydroxide  ions.  Under suitable
conditions the  metals form insoluble metal hydroxides which  can
be separated from solution.

     The chemistry of  the  process  is  not simple,  and must be
understood  for  each  metal.  Many  metals  are  amphoteric, the
optimum  pH for precipitation  varies, and  organic complexes can
interfere.  The simple reaction may be written as:


     M++ + Ca(OH)2 = M(OH)2 + Ca++                (1)

     If the pH  is  below  the optimum for hydroxide precipitation
soluble complexes form:


     M++ + OH- = M(OH)+                           (2)

     Since most metals have  the capability of coordinating  with
other  ions or molecules,   these simple equations assume that the
hydroxonium ion is  the coordinated species.  However, if organic
radicals are present, they can form chelates and mask the typical
precipitation reactions:
     M++ +OH- +nR = M  + (R)nOH+                 (3)
                               45

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     Such complexes  may require unusual   treatment  to  hydrolyze
them,  and  their   presence often  explains  why  some  treatment
practices yield relatively poor results.

     Assuming  the   absence  of  organic   complexing  agents,   the
treatment  levels  attainable by hydroxide  precipitation  can  be
forecast from  a knowledge  of the  pH of  the  system.    Figure 7-1
shows  the  theoretical  solubility  of those metals   which  form
insoluble  hydroxides,   while  Table  7-1  shows  the  solubility
product constants.  For   comparison, the  values for sulfides   are
also given.

     It is clear from the range of optimum pH's  illustrated  that
for  waste waters   containing  more  than one  metal,  no   single
optimum  pH exists,  and  problems arise  at the threshold  of   the
alkaline  range  (circa  pH  10)  where some   metals   have least
solubility,  while  others are at the point of redissolving as an
anionic  species.    For  successful application  as  a waste water
treatment technology, careful control of  pH must  be  practiced if
the best removals  are to be achieved.

     In practice  these   problems,  the   solubility  of  metallic
hydroxides, and  the  tendency for  fine   insolubles  to  remain in
suspension, tend to  yield effluents  which  will not  meet  ug/1
standards, and so  hydroxide  precipitation  is often  supplemented
by  the use of coagulating  agents to improve solids   removal, or
sulfide co-precipitation to reduce ultimate solubilities.

     In practice the technology uses unit process steps  which are
simple, well established, and well understood by the  industry.

     Depending on  the  quantity of waste  flow, the  treatment can
either  be a  batch or continuous operation,  with batch treatment
being favored when waste flows are small. In  batch treatment   the
equipment usually   consists of two tanks, each with a capacity to
treat the  total waste water volume expected  during the  treatment
period.  These systems can be  economically designed  for flows up
to 50,000 gallons  per day (5).

     The treatment  tanks   serve  the multiple  functions   of
equalizing  the  flow,  acting  as  a reactor   and  as a   settler.
During  operation  the  waste water is stirred,  and a homogeneous
sample  is taken and analyzed  to determine the  chemical   dosage
requirements.   The chemicals are  then added, mixed  and  stirred
for  about 10 minutes.    After  the  reaction has  completed, the
solids are  allowed to settle for a few hours.  The clear   liquid
is then  decanted  and discharged.   Settled sludge is retained to
serve  as a seed for crystal growth for  the  next batch, but  must
be  periodically drawn off and disposed of, usually in a chemical
landfill.
                               46

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10
10
10
  -2
10
  -4
      CO
      H
      Q
10
  -6
 10
   —8
 10
   -10
 10
   -12
                                                             Pb(OH)
                                         2
                                       Cr (OH)
                                      Zn(OH)0
                                       -Ag (OH)
                                     Cu(OH)2

                                     Ni(OH)2
                                         Cd(OH)
         0123
            Figure  7-1.
 45    67    8    9   10   11  12   13
Solubility of metal hydroxides and sulfides.
14
                                         47

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TABLE 7-1     -     SOLUBILITY PRODUCTS OF TRACE METALS

Metal
Cadmium, Cd
Copper, Cu
+2
Ferrous, Fe
Lead, Pb
Mercury, Hg
Nickel, Ni
Zinc, Zn
+6
Chromium (IV) ,Cr
Solubility Product
Hydroxide
13.6
18.6
15.3
16.1
25.4
14.8
15.7
8.9
Constant (1
Sulfide
26.1
35.2
16.9
26.6
52.2
25.7
25.2
°*V
. . Ethyl Xanthate
13.6
7.1
16.9
37.8
11.9
8.3
                                   48

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     A typical continuous  flow treatment  scheme  consists of  a
flash mixer, flocculator, settling unit with sludge storage tank,
and in some cases a filtration system.

     The ability to separate the solids from the  waste  water is
important.   Metallic  hydroxides  tend  to  be  gelatinous   and
separate poorly in  gravity  separators.  Finely suspended solids
tend to pass  out with the effluent and increase the total  metal
content.  Thus,  improvements in precipitation applications  have
been concentrated on fine  solids  removal, and this is reflected
in  the addition  of various filtration  systems
flocculant aids as improved levels of treatment.
   and  the  use of
     Lime is  more  commonly  used  than  caustic  soda  as  the
hydroxide source because  it  is cheaper.   However, if there  is
sulfate ion present in the waste water, gypsum will be formed:
       Ca(OH)2 + (S04)—  =  CaS04 + 20H-
(4)
     This increases  the  sludge  produced,  may  cause  scaling
problems  in pipelines, and may clog a  dual media filter.  Using
caustic soda is more expensive,  but it generally  eliminates the
scaling problem.  Total dissolved  solids in the  form of  sodium
salts are increased in the caustic treated waste waters. Although
low concentrations of sodium are not regarded as polluting,  high
levels can make  drinking water unpalatable,  limit  the  use  of
water for agriculture,  and promote degradation  of the structure
of arable soils.   Thus, where high total dissolved solids are of
concern, lime would be the preferred neutralizing agent.

     This treatment  technology  is  widely  applied  in treating
industrial  waste waters.   Industries  that are using  hydroxide
precipitation include:

     Inorganic Chemicals
     Plating and Metal Finishing
     Mining
     Textiles
     Steel and Iron
     Non Ferrous Metal Processing and
     Electronics

     Better than  99 percent  removal  of trace  metals have been
reported  in  the  literature  with  final concentrations in  the
treated effluents ranging from sub ppm to low ppm (see Tables 8-1
through 8-10).
                               49

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7.1.3  Ferrite Copr ec ip i. tat ion

     An interesting  variation  on   the  theme   of   hydroxide
precipitation is a  process developed in Japan for the removal of
heavy metals from  acidic  waste water.    The process,  known  as
ferrite  coprecipitation,  has  the  potential  for  producing  a
marketable residual by converting the metal ions in solution into
insoluble ferromagnetic oxides or  ferrites which can be  removed
magnetically or by  filtration (5).  The treatment  is applied by
adding a ferrous  salt to the  metal-bearing  waste  water,   then
neutralizing  and  oxidizing  the   complex  heavy  metal-ferrous
hydroxide precipitate  by  aeration  to   form  the stable ferrite
coprecipitate. Particle sizes are reported to be relatively  large
and sludges formed can be safely disposed of by landfilling.

     Although extensive performance data have not been developed,
the  information  available  indicates  that  very  high  removal
efficiencies can be achieved for most of the common heavy metals,
including  mercury  and hexavalent  chromium.  The method has not
been  considered here as an  available technology due to the lack
of sufficient information on chemical dosing requirements, energy
requirements,  and  performance in  situations similar  to  those
found  in the  inorganic chemicals  industry.   It will be  noted
later, in connection with the discussion of waste water treatment
in the Titanium Dioxide Subcategory for  the sulfate process, that
the wastes contain considerable amounts  of  ferrous iron from the
processing  of  ilmenite  ore   and   the  current   practice  of
neutralization and aeration may  well  involve the same chemistry
as the ferrite coprecipitation process.


7.1.4 Sulfide Precipitation

     The basic  principle  of  sulfide  treatment  technology  is
similar to that of hydroxide  precipitation.  Sulfide is added to
precipitate the metals as metal sulfides and the sludge formed is
separated  from  solution  by  gravity  settling  or  filtration.
Sodium  sulfide  and  sodium  bisulfide   are  the  two  chemicals
commonly used, with  the  choice  between these two precipitation
agents being strictly an economic consideration.

     Metal sulfides form according to the following equation:


     M++ + Na2S = MS + 2Na+          (5)

     Figure 7-1 shows the theoretical solubility product constant
of the metals that form insoluble sulfides.

     The major   problem  in   applying   sulfide   precipitation
techniques  is associated with the toxicity  of  sulfides.   This
warrants both  care in  application and  post treatment systems to

                               50

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remove  excess sulfide.   Pretreatment involves  raising_the pH of
the waste stream to minimize evolution of hydrogen sulfide gas.

     A recently developed and patented process to  eliminate  the
potential  hazard  of  excess sulfide  in  the effluent  and  the
formation of gaseous hydrogen sulfide uses ferrous sulfide as the
sulfide source  (6).   The fresh  ferrous sulfide is  prepared by
adding  sodium  sulfide to  ferrous sulfate.   The ferrous sulfide
slurry  formed  is added  to a waste  water to  supply sufficient
sulfide  ions  to  precipitate metal  sulfides  which  have lower
solubilities than FeS.   Typical reactions are:

      FeS + Cu++ = CuS + Fe++             (6)

      FeS + Ni (OH)2 = Fe(OH)2 + NiS      (7)

     A detention time of 10-15 minutes is sufficient to allow the
reaction to go to completion (7).  Ferrous sulfide itself is also
a   relatively   insoluble  compound.   Thus    the   sulfide  ion
concentration is limited  by  its  solubility, which  amounts  to
about  0.02  ppb,  and  the  inherent  problems  associated  with
conventional sulfide precipitation are minimized (8).

     One other advantage of this process is that if chromium (VI)
is present, it will also be reduced at  a normal  operation pH of
8-9 and precipitate as the trivalent hydroxide.

     Treatment systems  for  sulfide precipitation are similar to
those used for hydroxide  precipitation.   A continuous treatment
scheme generally consists  of a pH adjustment  tank, flash mixer,
flocculator, settling units with sludge storage, and a dual media
filter.

     Before the addition of sodium sulfide or bisulfide the pH of
the incoming wasteflow  is adjusted to  pH of  7-8  in  the first
reaction tank to  prevent  the  formation of  obnoxious  hydrogen
sulfide  gas.   The  chemicals are then added  to the flash mixer
where they are thoroughly mixed with the waste water.

     After the  flash  mix,  the  waste  water  passes  through a
flocculating basin where the floe agglomerates and settles in the
settling unit.  The overflow  from  the settling  unit  generally
passes  through  a  filter to remove any fine  precipitates.  Any
excess sulfide will  need to  be removed before final  discharge.
This  can  be  achieved  either by  aeration  or  other  chemical
oxidation techniques.

     Sulfide precipitation is being  practiced  in  the inorganic
chemicals   industry,  mining  industry,  textile  industry,  and
nonferrous metal processing  industry.  Most  of the Chlor-Alkali
industry  is  applying this technology to  remove lead or mercury
from its waste streams.
                               51

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     Literature  citations   on   the   efficiency   of   sulfide
precipitationn (9,  10,  11)  indicate that  most results are in the
sub  ppm  range,  and   that  sulfide  treatment  is  superior  to
hydroxide  treatment for  the removal of several trace metals.   A
recent  report concluded  that,  with no complexing  agents in the
waste, the following effluent quality can be achieved (11).

                 Metals    Concentration

                   Cadmium          0.01 mg/1
                   Copper          0.01  "
                   Zinc            0.01  "
                   Nickel          0.05  "
                   Chrome total     0.05  "

     Adding ferrous  sulfide  as  a  polishing  step  to  remove
residual metals  appears to  be a  promising, economical technology.
Although there is no full-scale  treatment system operating in the
inorganic  chemicals industry,  pilot  studies on chrome  pigment
waste indicate  that this process is superior  to  sulfur dioxide
reduction followed by hydroxide  precipitation (12).


7.1.5  The Xanthate Process

     The use of  xanthates  for  the  removal of metals from waste
streams appears  to be a  new, promising  technology for treating
metal-bearing waste waters.  Xanthates  contain functional groups
capable  of  forming  insoluble   complexes with metals,   and  the
sludge so formed can be separated by conventional means.

     Xanthates can be  generated  by  mixing starch or  cellulose
with carbon  disulfide  in  a caustic  medium.   Three  types  of
xanthates  have  been proven  in   bench pilot  scale studies to be
effective  in removing  cadmium, chromium  (III),  copper,  iron,
lead, mercury,  nickel,  silver  and zinc  from  industrial  waste
waters (13-20).    These are:


     Soluble starch xanthate with a cationic polymer,

     Insoluble starch xanthate,  and

     Fibrous cellulose xanthate

The general removal mechanism is as follows:


     2[ROCS(=S)Na]  + M++ = [ROCS(=S)2M] + 2Na+    (8)

     where R = starch or cellulose


                               52

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     Unlike hydroxide precipitation, this process  is reported to
be effective in removing metals over a wide pH range of  3  to 11,
with an optimum range between 7 and 9.

     Brass mill  waste  waters,  lead  battery  effluent, circuit
board rinse  waters,  electroless copper  plating  rinse  waters,
pyrophosphate  electroplating rinse  waters,  and copper  etching
rinse waters were studied in a pilot plant with insoluble  starch
xanthate  as  the  complexing   agent  (20).   This  pilot  study
demonstrated that the xanthates  can either be added to  a reactor
to mix with the  waste  waters  or be applied  as a precoat  on a
pressure filter (20).  Results of these pilot studies showed that
metals were reduced to below 50 ug/1 (ppb).

     Another study  indicated cellulose xanthate is as   effective
as starch xanthate in removing trace metals.  The following table
summarizes the result  of  the study with  a  cellulose  xanthate
dosage of 90 mg/1 and a contact time of 30 minutes (18-19):
             Metals
  Concentration, mg/1

Influent            Effluent
             Cadmium
             Chromium
             Copper
             Iron
             Lead
             Nickel
             Zinc
1.35
0.30
1.6
3.1
3.9
2.4
1.0
0.027
0.022
0.06-0.14
0.08-0.36
0.008-0.021
0.077
0.03-0.04
     This study  also  concluded  that  cellulose  xanthate   is
superior  to  starch  xanthate  in   terms  of  sludge   settling
characteristics, filterability,  and handling.
     Xanthate may  also be used as a complexing
the formation  of soluble anions from insoluble
hyd roxides.
                    agent  to prevent
                     amphoteric metal
     The xanthate  process is  a  new technology, and the reagent
compounds   are not available  in  commercial  quantities.   More
information is needed on how to  feed the xanthate in  continuous
flow operations. Potentially  the  metals  can  be  recovered  by
leaching the  xanthate  complex  with  nitric  acid,   but  metal
recovery has not been  demonstrated yet. Sludge disposal problems
may arise if the sludge complex is unstable and, if xanthates are
to  be generated on site,   care  will be  needed  in handling the
hazardous carbon bisulfide.
                               53

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7.1.6 Ion Exchange

     Ion exchange is  a   chemical  reaction  between the ions  in
solution and  the ionic sites on an exchange resin.   Many  natural
solids  (e.g.,    soils,   proteins,  and  zeolites)   exhibit  such
exchange  characteristics.    However,   synthetic  resins  are the
predominant  ones  used  for  ion  exchange applications in modern
industrial  technology.   These resins   contain  functional groups
that can react  with  the  ions in  solution.  Depending on these
functional groups, the resins can be classified into:

         Strongly acidic cation exchanger,
         Weakly acidic cation exchanger,
         Strongly basic  anionic exchanger, and
         Weakly basic anionic exchanger.

     Cation exchangers are  capable of  exchanging with cations  in
solution.  Strongly acidic   cation exchangers contain  functional
groups  such  as  sulfonates,  (-S03H   and -S03Na) ,  while  weakly
acidic exchangers have functional  groups derived from carboxylic
acids, (-COOH and -COONa) .

     Anionic exchangers  are used to exchange  with   the anions in
solution.  In general,  strongly basic exchangers  contain  amine
functional   groups   (-R3NOH  and  -R3NC1) ,   and   weakly  basic
exchangers contain ammonia  functional  groups (-NH30H and -NH3C1) .

     When the functional groups  are used up in the  reaction, the
resins can  usually  be   regenerated.    Cationic  resins  can  be
regenerated by sodium chloride, hydrochloric  acid,  sulfuric acid
or  sodium hydroxide.  Anionic resins  are  regenerated  by sodium
hydroxide, ammonium hydroxide, sodium  carbonate, sodium chloride,
or hydrochloric acid.

     The exchanger can either be added to  the  waste  waters  in
batch operations or be packed in a fixed  bed or column. Fixed bed
is  by  far  the  more  effective and  hence  more  popular.   The
operation  generally   follows   a   four-step  cycle:   exchange
(service), backwash, regeneration, and rinse.

     During the  exchange step, the reaction between  the ions in
solution  and  the  ionic  sites in the resin  takes place as the
waste  water passes down  the  bed.   The  reaction  is  generally
regarded   as   a  result   of   electrostatic  attraction  (20).
Therefore, the size of the  hydrated ion and the charge on the ion
are  the  determining  factors  for  the   exchange   reaction.   A
trivalent ion  is  attracted  more strongly  than a  divalent  ion
which is in turn  attracted more strongly than a monovalent  ion.
For ions  with  the  same  charge, the  smaller  hydrated ion  is
capable of  moving closer  to the  exchange  site,   and  is  thus
favored.

                               54

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                              with
     Many synthetic  resins contain  functional  groups that  are
selective to certain metals.  For  example, a resin  manufactured
by  a European company  reacts  preferentially  with  HgCl+   ions
according to the following equation:

          2RSH + Hg++ = RSHgSR + 2H+         (9)
          RSH + HgCl+ = RSHgCl + H+         (10)

     The exchange reaction is governed by the law of mass action.
During the  reaction, the affinity of the resin for  the two  ions
is so great  that essentially  all the mercury  chloride  complex
formation equalibria are shifted toward the formation of Hg++ and
HgClH-  which  are  rapidly  removed.   A  5 ppb  residual mercury
concentration in the effluent is achieved by this process  (22).

     After all the exchangeable sites in  the resin  are used up,
the bed  is backwashed by passing clean water through to loosen up
the  bed and to  remove any fine  particulates  that  are trapped
inside the bed.

     After the backwash cycle  the resins can be regenerated
the appropriate regenerant.


     RSHgCl + HC1  =  RSH + HGC12           (11)

     One attractive  feature of the ion exchange  process  is that
it concentrates  the metals in  the regeneration  step, and  thus
provides a potential for their recovery.  However, if recovery is
not feasible, this creates  a secondary stream which needs  to be
treated.

     A recent  study  found   that   sodium   alumino  silicates
(zeolites) might be  a low-cost  exchanger  that can be  discarded
after a  one-time use (22).  This would eliminate the regeneration
step.  On a batch study with a  five-minute contact time, cadmium
and  mercury  were   removed  to  below  10  ppb.   Thermodynamic
considerations show  this exchanger to have  a high affinity  for
cadmium,  copper,  mercury,  nickel,  silver,  zinc,  cesium, and
bar ium.

     Ion exchange is a proven technology  that can  reduce metals
down  to  low  concentration levels.   However this technology is
used only in limited industrial  pollution  abatement applications
because  of   the    high  cost  associated   with  the   process.
Consequently, ion  exchange  has  not been  recommended  in   this
report for BAT technology.
55

-------
7.1.7 Reduction Processes

     Many metals  can  exist in  solution  in  several  oxidation
states,  and it  may be necessary to convert from a higher valency
state  to  a  lower  one  in  order  to  apply  a  given chemical
reaction.The  classic example is chromium, which as the trivalent
chromic   ion  will  precipitate  as  the  hydroxide  in  alkaline
solution,  while the  hexavalent chromate  or dichromate ion will
not.  The latter  needs  to  be  reduced if precipitation  is  to
occur.

     Hexavalent chromium (e.g., Cr04=  and  Cr207=)  is toxic and
soluble.  The most efficient way of removing  this  from solution
is a two-step process of reduction followed by precipitation.

     Chromium (III)  is much less toxic than  chromium  (VI), and
forms  an insoluble hydroxide which can be removed from  solution
by settling and filtration.

     A number  of  chemicals  are  used  for  the  reduction  of
chromium. Most common are sodium bisulfite, sodium metabisulfite,
sulfur dioxide and ferrous salts.  The reduction  is accomplished
readily  at  low  pH  with  these  reagents.   Typical  reduction
reactions are:
     3S02 + Cr207= + 2H+ = 2Cr+++ + 3304= -t- H20            (12)

     3303= + Cr207= + 8H+ = 2Cr+++  + 3304 = +4H20         (13)

     6Fe++  -)- Cr207= + 14H+  = 2Cr+++ + 6Fe+++ + 7H20      (14)


     The reduced  chromium  and the ferric ions produced  in  the
third equation will exist as the soluble sulfate at acid pH's.  If
the pH  is above 5, the reaction rate is drastically reduced, and
although dithionite will effect reduction at neutral pH's, it  is
very costly and may be contraindicated.

     After the reduction step, lime  or caustic soda is  added  to
raise   the  pH  to  8.5  -  9.0.   Trivalent  chromium  will  be
precipitated.


     Cr+++  + 30H-  = Cr(OH)3                 (15)

     The theorectical solubility  limit of  chromium hydroxide  is
above 0.02 mg/1 (8).  It is reported that applying sulfur dioxide
to a  pigment waste consistantly reduces Cr(VI)  and Cr(T)  to 0-5
mg/1 and 15 mg/1 respectively as 30-day averages  (8). By applying
ferrous  sulfide  to  a  plating  waste  with  an initial  Cr(VI)
concentration of 128 mg/1 and Cr(T) concentration of 153 mg/1,  an

                               56

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effluent quality of  less than 0.05  mg/1  of either  species  is
achieved (12).

     A one-step  precipitation-reduction  process  using  _sodium
bisulfide is used in  a dichromate plant to  remove chromium from
its waste water.  An effluent quality with less than 1  microgram
per liter Cr(VI), and  less than 5 micrograms per liter Cr[T] was
reported , (3 ) .

     One other   common reduction process is  the  application _of
sodium  borohydride to reduce  metals in waste  streams.   Sodium
borohydride is  a mild  but effective reducing  agent (3), and  is
currently used  in some chlor-alkali plants to reduce  the soluble
mercury ion to  metallic mercury which is removed from solution by
carbon adsorption:


     4Hg++  + BH4-  + 80H-  = 4Hg + B(OH)4-  + 4H20       (16)

     A mercury  level of 0.01 mg/1 in the final effluent has been
reported, (3 ) .

     Sodium borohydride  is  also  reported  to  be effective  in
removing  silver, mercury, gold, lead, and cadmium (5).  However,
this technology is only being applied in limited cases,  the cost
of the chemical being  the major drawback.  The  current cost for
sodium borohydride is $16.00 per pound (23).


7.1.8  Oxidation Processes

     The oxidation of organic substances is generally carried out
by thermal processes  such as wet oxidation and incineration,  or
by biological  processes  such as  the activated sludge  process,
trickling filters, biodiscs, and aerated lagoons.

     Incineration  is  actually  a combination  of  oxidation  and
pyrolysis.  Both   involve chemical changes resulting  from  heat.
Oxidation involves  actual reaction with oxygen, while  pyrolysis
refers to rearrangement or breakdown of molecules. There are five
types of  incinerators  available commercially.  These are rotary
kiln,  multiple  hearth,  liquid  injection,  fluidized,  bed and
pyrolysis,  (24).  A minimum temperature of 1000  degrees C. and a
residence time of  two seconds is  required for the  reaction  to
proceed. This process has been shown to be successful in  reducing
pesticides to harmless modecules  (25).

     Wet oxidation is a process in which an aqueous waste can  be
oxidized in the liquid phase in a closed, high-temperature, high-
pressure vessel.  This reduces some  of the problems  (such as air
pollution from  exhaust  gas),  inherent  in  incineration.   Wet
oxidation has been used for a variety of wastes including pulping

                               57

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waste and  acrylonitrile liquor  (26).   A 99.8 + percent reduction
of some of the priority toxic pollutants has been reported (27) .

     Thermal  oxidation  processes are  not expected  to have  much
application in  the inorganic chemicals  industry, mainly because
of the  high   energy cost  required  and the low level  of  organic
contamination found in the wastes.

     The application  of chemical oxidation  to industrial wastes
is  well established for  cyanides,  sulfite,  ammonia, and  other
harmful species  in dilute  waste  streams  (phenols,  mercaptans,
polysulfides,  etc.).  Common chemicals used  as oxidizing agents
included chlorine,   hypochlorite,  hydrogen  peroxide,  potassium
permanganate,  ozone, and chlorine  dioxide.  Air and   oxygen are
also used.

     The most   widely  used   chemical   oxidation   technology
applicable to the  inorganic  chemicals industry is the oxidation
of cyanide.  The oxidation reaction between chlorine and  cyanide
is believed to proceed as follows:


     CN- + C12  =       CNC1  +  Cl-     (17)

     CNC1 + 20H- =   CNO-  + Cl- + H20   (18)

     The formation  of cyanogen  chloride  (CNC1) is  essentially
instantaneous.  The second reaction, the formation of cyanate, is
accomplished  most rapidly and completely at a pH of 10 or higher,
(9,  28).  A detention time of 30 minutes to two hours is usually
allowed.

     The cyanates  can be  further decomposed  into nitrogen  and
carbon dioxide by excess chlorination  or acid hydrolysis:


     2CNO-  + 40H- + 3C12 =    6C1- +  2C02  + N2  + 2H20 (19)

     CNO-  +  2H20  =      C02  + NH3  + OH-              (20)

     The first  reaction can be  accomplished in about an hour if
the pH  is  adjusted to 8.0-8.5.   Acid hydrolysis usually  takes
place at pH 2-3 and care must be taken to avoid the liberation of
the toxic cyanogen chloride as a gas.    Hydrolysis is not usually
the chosen option.

     Other common  chemicals  used  to  oxidize  cyanide  include
sodium hypochlorite, ozone, and hydrogen peroxide.  The  reaction
for  sodium   hypochlorite  is   essentially  the  same  as   for
chlorination. For ozone and hydrogen peroxide, the oxidation step
proceeds as follows:


                               58

-------
     0;  CN-     02  +  CNO-      (21)

     H;+ CN- =   CNO- + H20      (22)

     THvantage of using these two oxidizing reagents  is_  that
no dissd solids are added to the waste  water.   In  addition,
excess>rine is not discharged.

     A nted process uses  hydrogen  peroxide and  formaldehyde
to decoe cyanide at about 120 Deg. F.  This has  the advantage
of precating cadmium and zinc simultaneously (9).

     Alne chlorination is  currently being  practiced   in one
hydrogeyanide  production plant.   Laboratory  studies  in the
plant  cated  that the presence of ammonia in the waste water
reduces efficiency of cyanide removal.  It is well known  that
ammoniacts with chlorine to form chloramines:
     NH HOC1  = NH2C1  +  H20              (23)

     NH + HOC1  = NHC12  + H20             (24)

     NH+ HOC1  =  NC13  +  H20             (25)

     Ifess  chlorine is added,  chloramines can  be converted
into nien oxide(s):


     2N+ 4HOC1  = N20  + 4HC1 + 3H20       (26)

     Thquation  is  not  exact  because  the  final   form  of
nitrogexide  is believed  to be a mixture of  nitrous  oxide,
nitrogeoxide and nitric oxide.

     Theatment of cyanide by chemical  oxidation is currently
practicn the following industries:

     Innic Chemicals (Hydrogen Cyanide Production)

     Mi

     Pig

     Thee cyanide level  after  treatment  is  generally below
0.1 mg/) .


7.1.9 Mane Processes

    _Mene processes have emerged in the last decade as a  new
promisiechnology for  the treatment of saline water and waste


                           59

-------
waters.  A membrane is a semi-permeable barrier  which allows  the
transport  of some  molecules (ions)   and  retains  others.    The
driving   force  can   either   be  electropotential   differences
(electrodialysis)   or  pressure difference  (reverse osmosis  and
ultrafiltration).  The major  application of  these  processes has
been the desalination  of brackish  water and  sea  water.    More
recently, these  have  also  found  application  in  a  number of
industries, including:
     Mining
     Electroplating
     Metal Finishing
     Printed Circuit Board Manufacturing
     Battery Manufacturing
     Pulp and Paper
     Food Processing
     In electrodialysis, an even number of alternating anion  and
cation selective  membranes  are placed  between  two electrodes.
When current is applied the anions  are  attracted to  the anode,
and  cations are attracted  to  the cathode.   In  the  process of
migration, the cations pass through the cation-permeable membrane
and  are blocked by the anion-permeable  membrane.  Likewise,  the
anions pass through the anion-permeable membrane  and are blocked
by  the cation membrane.  This results  in  alternating  paths of
purified water and concentrated reject (Figure 7-2).

     The electrodialysis membranes are made  very  thin  and  are
assembled in  stacks.  The flow path is the active portion of  the
cells.  Pretreatment to remove suspended  materials is absolutely
essential.  Other materials in the waste  feed  that  may lead to
membrane  fouling include high  organic content, calcium sulfate,
and  certain  complex ions  such  as  ZnCl- which  can  partially
convert the anion membrane to  the cation form,  with significant
loss in system performance (28).

     As ionic concentration decreases, the electroconductivity of
the water also decreases, making it less efficient  to remove  the
remaining salt.  Most operations do not produce  a  product water
of less than 500 mg/1 total dissolved solids.

     Reverse osmosis (RO) and ultrafiltration (UF) are similar in
basic  concepts.   Both are pressure-driven separation  processes
that employ  high-flux  semi-permeable membranes operating  under
dynamic flow conditions (29).   In  contrast  to electrodialysis,
these involve  the transport  of  solvent, not solute, across  the
membrane.

     Osmosis is a process in which solvent from a dilute solution
is  transported spontaneously  across  a  semi-permeable membrane
into a  concentrated solution.  By  applying  enough  pressure to
overcome  this  osmotic  pressure,  reverse  osmosis,  i.e.,  the

                               60

-------



a
8
1
6

i





?
t

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(


i




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— JL


/T~\
X ^
(^
r
tk.





©

a



1
I
©

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t
~" 1

PRODUCT
WATER
              I
       CONCENTRATE WASTE
Figure 7-2.  Electrodialysis process.
                 61

-------
passage  of  solvent  from  a  concentrated   solution  to  a dilute
solution   through  a   semi-permeable  membrane,    occurs.    The
operating  pressure  of reverse  osmosis units   is usually between
350 and 600 psi.  Ultrafiltration usually operates at a much lower
pressure (5  to  100  psi).  The  predominant transport mechanism   is
selective  sieving  through pores.    The  membrane  retains high
molecular weight  dissolved solids   such  as   synthetic   resins,
colloids, and proteins.  The  upper  and  lower  molecular  weight
limit is generally defined as  500,000 and 500  respectively.

     Membranes are usually  fabricated  in  flat sheets or tubular
forms. The most   common material is  cellulose  acetate  but  other
polymers such as polyamides are  also used.   There are four  basic
module  designs:   plate-and-frame,    tubular,   spiral-wound,  and
hollow  fiber.  Table   7-2 is   a comparison between the   various
reverse osmosis   modules.   Membrane   processes  are  effective in
removing (concentrating)  inorganic and organic  substances from  a
wastestream.  Usually  extensive  pretreatment  is   required  among
others to reduce the suspended solids  and   control  pH.  Even  so,
there are still   uncertainties  about the  operation  efficiency,
membrane lifetime, rejection specificity, and  other factors.   If
recovery  is  not  feasible,  the concentrated  reject  must   be
disposed or  treated by  other methods.   The  high  operation  and
capital  cost   limits   the  widespread  application  of   these
technologies.  For  these   reasons   membrane  technique   is  not
recommended as a BAT technology  for  this industry.


7.1.10 Adsorption

     Adsorption  is a surface  phenomenon  in which a substance is
accumulated  on  the  surface of another substance.  Sorption of  a
solute on a solid surface  is  widely used in pollution  abatement
practices. The  term "adsorbate" refers  to the  substance  being
concentrated, and  the  term "adsorbent"  refers  to the  material
that provides the surface.

     Activated carbon   is  the prevalent  adsorbent  used.   Both
inorganic  and  organic  substances   are  known   to  be   removed
effectively by activated carbon.  Certain chlor-alkali plants  are
currently  using activated carbon as a polishing step to  remove
mercury.

     Activated carbon   is made by charring  basic  substrates, such
as wood, coke, coal, shell, husks, etc.,  at  600 degrees C. in a
controlled atmosphere, where oxygen  is kept low by adding  carbon
dioxide or steam.  This  process  drives out volatiles, leaving a
porous carbon lattice   in  an "activated" state.

     Activated carbon   can  be obtained in   powdered and  granular
form. Powdered carbon  is about 50-70  microns  in  diameter, and 90
percent should pass  through a  300-mesh screen.

                               62

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      TABLE 7-2
                                       COMPARISON OF REVERSE OSMOSIS CONCEPTS
                        Packing
                        Density

                       (ft2/ft3)
                               Water Flux  Water Output
                               at 600 psi   Per Unit
                                 (gal/     Volume(gal/
                                ,3  /.p.i-2\      j  /jro-2x
                                day/ft )      day/ft )
           Parasitic Pressure
  Sodium       Losses(psi)   Useful
 Chloride    Feed    Product   pH    Ease of
Rejection   Channel  Channel  Range  Cleaning
Plate-and-Frame
Large tubes
Spiral
150
50
250
10
10
10
1500
500
2500
Very good
Very good
Very Good
30
50
10
30
10
50
2-8
2-8
2-8
Fair
Very good
Good to
very good
CTl
CO
Polyamide hollow
  fine fibers        5000      1(400 psi)      5000

Cellulose acetate
  hollow fine
  fibers             2500      3(250 psi)      7500
                                                               Fair
                                                               Good
               10
               10
50
50
0-12  Fair
3-7   Fair
     Source:  Weber, Physicochemical Processes, 1972,

-------
     Granular  carbon  is  about  0.1-1  mm  in  diameter,  this  is  three
times  more  expensive   than   powdered  carbon.    The  application
involves  the passage  of  the waste  waters through a contact bed.

     When the  bed   is exhausted, the carbon  is  either  regenerated
or sent  to  landfill.    It   is  economical for   large   plants   to
regenerate  the  carbon.    This  can be   done  either   by thermal
regeneration in  a  rotary kiln  or   multihearth  incinerator, or   by
chemical  regeneration by using oxidizing agents such as  hydrogen
peroxide  or  acids  and bases.

     The  application  of  carbon adsorption  has been mainly in
organic waste  treatment.   Recently,  there  are  studies   indicating
this  is  also  effective   in removing mercury,   cadmium,  cyanide,
chromium, lead,  nickel,  zinc,  arsenic,  and copper (30,  31).

     An interesting development  in carbon  technology  is   its  use
after  the waste water  is ozonized.   This   combination (known   as
Bacteriologically  Activated Carbon or BAG)   has  proved effective
in  treating otherwise   biologically inactive   organic compounds.
The process  involves  chemical  modification of  the organics by  the
ozone.   Maintenance  of  an aerobic region  on the carbon allows  a
biologically activated  film to develop  and the  modified  organics
are further  treated  by   a mixed   process  of biological oxidation
and carbon absorption.

     The  system  has the  advantage  of being a potential add-on   to
existing  BPT systems, and should be  cost effective since   it  has
been found that  the carbon only  needs  regeneration  at infrequent
intervals.

     No industrial  applications  of this   technology   are known,
although  research  is  under way (32) .

     Bacteriologically  Activated   Carbon   is  a  very   attractive
potential  BAT technology for  the  removal  of  organic  priority
pollutants  from waste  streams,  although no  application   to  the
industry  subcategories  studied in  this  report  was found.


7.1.11 Fluoride  Removal

     The  conventional method   of treating  fluoride-bearing wastes
is  to  precipitate  the  fluoride as  calcium   fluoride   by  the
addition  of  lime.  The reaction is:

     Ca(OH)2   +  2F-      = CaF2  +  20H-        (27)

     Using this  process  alone, it  is difficult to remove  fluoride
to below  8 mg/1  due   to the  solubility of calcium   fluoride  (9,
33). Adding  alum with  the lime  generally improves the   removal
efficiency.  Fluoride  ions are  removed as follows:

                               64

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     A1(OH)3  + F-   =  A1(OH)2F  + OH-

     A1(OH)2F + F-   =  A1(OH)F2  + OH-

     A1(OH)F2 + F-   =  A1F3      + OH-
(28)

(29)

(30)
     Complexed fluorides are also adsorped to some extent  on   the
aluminum hydroxide surface and removed in the coagulation  process
(33).  Large amounts of alum (5000 mg/1)  are  required  to   reduce
the fluoride concentration to below 1 ppm.

     Activated alumina has been shown to be effective in removing
fluoride and  arsenic  in  waste water,  (34), and   from drinking
water  in municipal water treatment practice  (35-38) .   Typically,
the fluoride content of raw water can be reduced from about 8  to
1 ppm  (38).   Application of activated  alumina to  high fluoride
industrial wastes  shows that a low ppm effluent  can be achieved
(39), although  high capital and operation costs  generally limit
the wide application of this process.

     Certain process  operations  used  in  the  manufacture  of
inorganic fluoride compounds involve the use of sulfuric acid and
starting materials which  contain  silicate or borate impurities.
This   may   lead   to  the   formation  of   wastes    containing
fl uorosul fonate,   hexafluorosil icate or tetrafluoroborate  complex
ions.  Although  tetrafluoroborate  is  usually  a   very   minor
constituent  and  the  hexafluorosilicate is readily  hydolyzed in
treatment systems, the  fluorosulfonate ion is fairly   stable and
presents a serious problem where low levels of total fluoride are
required.   The lime  precipitation method  is  not  effective in
removing  the fluorosulfonate and the effectiveness  of  adsorption
techniques is not known.
                               65

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                            SECTION  8
       TREATABILITY  ESTIMATES AND LONG TERM DATA ANALYSIS
8.1 THE  DEVELOPMENT  OF  TREATABILITY ESTIMATES

     The review of technological  treatment options applicable  to
the removal   of  priority pollutants  has lead  to   the conclusion
that the particular  contaminants  found in the raw   process  waste
waters of the subject industries  can be effectively controlled  by
the proper application   of  fairly  well-known   and  demonstrated
techniques.   In order to  proceed  from  a general discussion and
description   of techniques  to  a   detailed  evaluation  for  each
subcategory   of the  levels  of   removal that can  be  expected, a
summary  is now presented of selected treatability  data for the  13
priority metals.

     The treated  waste  concentrations and removal  efficiencies
reported  in the literature  are  assumed  to represent  the  best
performance   characteristics  that  can  be  obtained  under  the
specified  operating  conditions.    The  treatment  technologies
considered can thus  be   assigned  a set  of optimum conditions and
best performance estimates for  removal of the particular priority
metals that   are amenable  to treatment.   Taking   each metal  in
turn,  Tables  8-1  through  8-10  give  the  initial  and  final
concentrations, the  removal efficiencies,  and   the pH conditions
for  different  treatment  technologies.   The   best  performance
estimates for metal   removal are  derived  from  the tabulated data
and  are  utilized in turn  as   the  bases  for making long-term
achievable performance   estimates.   The  sequence  of analytical
steps is:


     1.   Review and  analyze applicable performance data.


     2.   Estimate best  performance  under  optimum   treatment
conditions.


     3.   Estimate   achievable    performance   under   expected
industrial operating conditions.

     The third  step  involves   the  consideration  of  treatment

                               66

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TABLE 8- 1.     WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY
               ANTIMONY AND ARSENIC REMOVAL.
Treatment Technology Initial pH Removal
Concen- (%)
tration
(mg/1)
Antimony
Lime/Filter 0.6 11.5 28
Ferric chloride/Filter 0.5 6.2 65
Alum/Filter 0.6 6.4 62
Arsenic
Lime Softenin 0.2 - 85
Sulfide/Filter - 6-7
Lime (260 mg/1) /Filter 5.0 10.0 80
Lime (600 mg/1) /Filter 5.0 11.5 72
Ferric sulfate 0.05 5-7.5 90
Ferric sulfate 5.0 6.0 90
Lime/Ferric Chloride/ 3.0 10.3 98
Filter
Activated alumina 0.4-10 6.8 96-99+
Activated carbon 0.4-10 3.1-3.6 63-97
(3 mg/1)
Ferric Chloride 0.3 - 93
Ferric Chloride 0.6-0.9
Final
Concen-
tration
(mg/1)

0.4
0.2
0.2
0.03
0.05
1.0
1.4
0.005
0.5
0.05
<0.4
<4.0
0.05
<0.13
References

40
40
40
9, 10
9,10
41
41
42
.41
9,10
43
43
9,10
9,10
                                   67

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TABLE 8-2.    WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY
              BERYLLIUM AND. CADMIUM" REMOVAL -

Treatment Technology



Beryllium
Lime/Filter
Cadmium
Lime (260 mg/1) /Filter
Lime (600 mg/1) /Filter
Lime Softening
Lime/Sulfide
Ferrous Sulfide (Sulfex)
Ferrite coprecipitation/
Fil i-or
Initial
Concen-
tration
(mg/D

0.1

5.0
5.0
0.44-1.
0.3-10
4.0
240
pH




11.5

10.0
11.5
0 5-6.5
8.5-11.3
8.5-9.0
neutral
Removal
(%)



99.4

95
98
92-98
98+
99+
99+
Final References
Concen-
tration
(ng/1)

0.006 40

0.25 41
0.10 41
0.008 8
0.006 44
<0.01 7,8,11,12
0.008 5
                                   68

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TABLE 8-3.     WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY -
               COPPER REMOVAL
Treatment Technology



Lime/Filter
Lime (260 mg/1) /Filter
Line (600 mg/1) /Filter
Ferric sulfate/Filter
Lime
Lime
Alum
Lime/Sulfide
Ferrous sulfide (Sulfex)
Ferrous sulfide (Sulfex)
Ferrite coprecipitation/
F-il i-a-r-
Initial
Concen-
tration
(mg/D
3.2
5.0
5.0
5.0
10-20
3.0
3.0
50-130
3.2
4.0

pH



8.5-9.0
10.0
11.5
6.0
>8.5
9.5
6.5-7.0
5.0-6.5
8.5-9.0
8.5-9.0
-
Removal
(%)


98
92
91
95
90
93
93
-
99
99+
99+
Final
Concen-
tration
(mg/1)
0.07
0.4
0.5
0.3
1-2
0.2
0.2
<0.5
0.02
0.01
0.01
References



8
41
41
41
9,10
45
45
44
8, 12
7,8,U
5
                                   69

-------
TABLE
8-4.      WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY
         CHROMIUM III AND CHROMIUM VI .REMOVAL

Treatment Technology
Chromium III
Lime (260 mg/1) /Filter
Lime (600 mg/1) /Filter
Reduc tion/Lime
Reduction/Lime
Lime Softening
Lime/Filter
Lime
Lime
Ferrite coprecipitation/
Filter
Ferric sulf ate
Ferric sulfate/Filter
Chromium VI
Activated carbon
(pulverized, Pitts-
burgh type RC)
Same as above
Activated carbon
(granular)
Ferrite coprecipitation
Sulfur dioxide reduction
Bisulfite reduction
Initial pH Removal
Concen- (%)
tration
(mg/1)
5.0 10.0 98
5.0 11.5 98
140 (as 7-8
Cr VI)
1300 (as 7-8
Cr VI)
10.6-11.3 98+
7-9
15 9.5
3.2 9.5
10 - -
6.5-9.3 98+
5.0 - 99
10 3.0 85
10 2.0 96
3 6.0 98
0.5
- - -
Final
Concen-
tration
(mg/1)
0.1
0.1
1.0
0.06 CrIII
0.15
0.05
0.1
< 0.1
<0.01
-
0.05
1.5
0.4
0.05
not
detectable
0.01-0 ,1
0.05-1.0
References
41
41
9,10
3,9,10
46
47
45
45
5
46
41
48
48
41
5
9,10
9,10
                                   70

-------
TABLE 8-5.     WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY
               LEAD REMOVAL

Treatment Technology



Lime/filter
Lime (260 mg/1) /Filter
Lime (600 mg/1) /Filter
Ferrous sulf ate/Filter
Sodium hydroxide/Filter
Sodium carbonate/Filter
Sodium carbonate/Filter
Ferrous sulfide (Sulf ex)
Ferrite coprecipitation/
Initial
Concen-
tration
(mg/1)
189
5.0
5.0
5.0
1700
1260
5.0
189
475
pH



8.5-9.0
10.0
11.5
6.0
10.5
10.1
9.0-9.5
8.5-9.0
-
Removal
(%)


99.9
98.5
98.0
98.5
99+
99+
99+
99.9
99.9
Final
Concen-
tration
(mg/1)
0.1
0.075
0.10
0.075
0.60
0.60
0.01-0.03
0.1
0.01
References



5
41
41
41
49
49
9,10
8,12
5
                                  71

-------
TABLE 8-6.    WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY -
              MERCURY II REMOVAL

Treatment Technology
Sulfide
Sulfide
Sulfide/Filter
Sulfide/Filter
Sulfide/Filter
Ferrite coprecipitation/
Filter
Activated Carbon
Activated Carbon/Alum
Activated Carbon
Initial pH Removal
Concen- (%)
tration
Crag/1)
0.3-50.0
10.0 10.0 96.4
16.0 5.5 99
36.0 4.0 99.8
0.3-6.0 5.8-8.0 87-99.2
6.0-7.4 - 99.9
0.01-0.05
0.02-0.03
0.06-0.09
Final References
Concen-
tration
(mg/1)
0.01-0.12
1.8
0.04
0.06
0.01-0.125
0.001-0.005
<0.0005
0.009
0.006
9,10
50
50
50
50
5
9, 10
46
50
                                   72

-------
TABLE 8-7.     WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY
               NICKEL REMOVAL

Treatment Technology



Lime
Lime (260 mg/1) /Filter
Lime (600 mg/1) /Filter
Caustic Soda/Filter
Ferrous sulf ide (Sulfex)
Initial
Concen-
tration
(mg/1)
75
5.0
5.0
-
75
pH



8.5-9.0
10.0
11.5
11.0
8.5-9.0
Removal Final
(%) Concen-
tration
(mg/1)
98 1.5
94 0.3
97 0.15
0.3
99.9 <0.05
References



8
41
41
49
8,11, 12
                                  73

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TABLE 8*8.     WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY -
               SILVER REMOVAL

Treatment Technology



Sodium hydroxide
Ferric sulfate (30 mg/1)
Lime Softening
Chloride precipitation
(alkaline chlorination
in the presence of
cyanide)
Ferric chloride/Filter
Sulf ide precipitation
Initial
Concen-
tration
(mg/1)
54
0.15
0.15
105-250

0.5
-
pH Removal
(%)


9.0 72
6-9 72-83
9.0-11.5 80-93
97+

6.2 98.2
5-11 very high
Final
Concen-
tration
(rag/1)
15
0.03-0.04
0.01-0.03
1.0-3.5

0.04
—
References



13
46
46
9,

40
9,






10


10
                                   74

-------
TABLE 8-9.     WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY
               SELENIUM AND THALLIUM' REMOVAL

Treatment Technology
Selenium
Ferric chloride/Filter
Ferric chloride/Filter
Alum/Filter
Ferric sulfate
Ferric sulfate
Lime/Filter
Lime/Filter
Thallium
Lime/Filter
Ferric chloride/Filter
Alum/Filter
Initial
Concen-
tration
(mg/D
0.1
0.05
0.5
0.10
0.10
0.5
0.06
0.5
0.6
0.6
pH
6.2
6.2
6.4
5.5
7.0
11.5
11.5
11.5
6.2
6.4
Removal
(%)
75
80
48
82
75
35
38
60
30
31
Final
Concen-
tration
(mg/1)
0.03
0.01
0.26
0.02
0.03
0.3
0,04
0.2
0.4
0.4
References
40
40
40
51
51
40
40
40
40
40
                                    75

-------
TABLE 8-10.   WASTE WATER TREATMENT OPTIONS AND PERFORMANCE DATA SUMMARY -
              ZINC REMOVAL

Treatment Technology



Lime/Filter
Lime (260 mg/1) /Filter
Lime (600 mg/1) /Filter
Lime/Filter
Sodium hydroxide
Sulfide
Ferrous sulfide (Sulfex)
Ferrite coprecipitation
Initial pH
Concen-
tration
(n*g/D
3.6 8.5-9.0
5.0 10.0
5.0 11.5
16
33 9.0
42
3.6 8.5-9.0
18
Removal
(%)


93
84
77
-
97
97
99+
99+
Final
Concen-
tration
(mg/1)
0.25
0.8
1.2
0.02-0.23
1.0
1.2
0.01-0.02
0.02
References



8
41
41
5
13
5
8, 11, 12
5
                                  76

-------
system  variables   under  full-scale  operating  conditions   in
industrial situations where  the  design  objective  would be the
simultaneous  removal of several  waste load  constituents.  Each
industry designs for maximum removal and/or recovery of the major
process-related  waste  substances and  utilizes  an  appropriate
technology which is both reliable and  cost  effective.   Optimum
treatment conditions  for the removal of  a particular  pollutant
can  rarely  be  achieved  consistently  and  any  given  set  of
conditions will  be somewhat less than  optimum for most,  if not
all,  of  the  treatable  constituents.    In  any  well-operated
production facility the  normal variations in  product rates, raw
material quality,  the  desired product  mix in some  cases,  and
contact  water  use  requirements  may cause severe hydraulic and
pollutant load input excursions which at best can be moderated by
effective  equalization  in  the  treatment  system.    This   is
considerably less of  a  problem  in batch treatment than with  a
continuously operating  system.  The latter  requires  continuous
feedback  monitoring for pH control and  chemical dosage in order
to  maintain the effluent quality within acceptable limits for  a
number  of   parameters.   Under  these  conditions,  the  30-day
averages derived from the actual treated effluent monitoring data
(NPDES, etc.) would equate to what has  been identified in Step 3
above as  the estimated  30-day achievable performance using  the
same general treatment technology.

     The estimated long  term  achievable performance values  are
presented in Table 8-11.

     A statistical  evaluation  of long-term  monitoring data  is
described below and the results are presented in Appendix A where
various  derivative quantities  such as  long term  averages  and
standard  deviations are tabulated and the bases for  formulating
the  variability  factors  applicable  to  each  subcategory  are
explained in detail.

     For each nonexcluded subcategory, a tabular  presentation of
the logic used to develop effluent limitations is given, based on
performance  estimates  for  30-day  average  concentrations  for
specific pollutants.   When  available,  these concentrations are
based on industry monitoring data.  When  long-term  data are not
available  from  industry, as  is  the  case  with  most priority
pollutants,   achievable   concentrations   are   based   on  the
treatability of these  pollutants as  discussed in Section 8  and
summarized in Table 8-11.

     Variability factors applied to these concentrations for  the
development of monthly average and daily  maximum limitations are
based  on  statistical  analysis of long-term  data as  presented
below  and in Appendix  A.  In  many  cases, due  to  the limited
amount of long-term data available, variability factors  observed
in  one  subcategory are  applied  in  other subcategories  where
similar treatment technologies are practiced.

                               77

-------
TABLE 8-11.  ESTIMATED ACHIEVABLE 30-DAY AVERAGES FOR THE APPLIED
	TECHNOLOGIES	

                              Final Concentrations (mg/1)
                                      Ferrite
               Lime    Lime   Sulf ide Coprecip-  Soda Ash Soda Ash  Alum
             Settling  Filter   Filter itation    Settling  Filter
                                       Filter


Antimony, Sb  0.8-1.5  0.4-0.8

Arsenic V     0.5-1.0  0.1-0.5  0.05-0.1

Beryllium, Be 0. 1-0.5  0.01-0.1

Cadmium,  Cd  0.1-0.5  0.05-0.1  0.01-0.1  <0.05

Copper, Cu    0.5-1.0  0.1-0.7   0.05-0.5  <0.05

Chromium III, 0. 1-0. 5  0.05-0.5           <0.05
 Cr+3
Lead,  Pb      0.5-1.0  0.1-0.8   0.1-0.4  <0.05    0.4-0.8  0.1-0.6

Mercury II ,                     0. 01-0.05<0. 01
 Hg

Nickel, Ni    0.5-1.0  0.1-0.5   0.1-0.5

Silver, Ag    0.4-0.8  0.2-0.4   0.05-0.2

Selenium, Se  0.2-1.0  0.1-0.5

Thallium, Tl  0.2-1.0  0.1-0.5                                        0.2-0.5

Zinc,  Zn      0.5-1.0  0.4-0.8   0.2-0.5   0.2-0.5

Fluoride  (Free),25     15
 F
                                  78

-------
TABLE 8-11   continued
                              Final Concentrations (mg/1)
               Ferric  Activated     S02     Bisulfite  Lime/FeCl2  Akaline
              Chloride    Carbon   Reduction  Reduction    Filter    Chlor-
                                                                    ination


Arsenic V, As  0.05-0.5    0.3                             0.02-0.1

Chromium VI,               0.1    0.05-0.1  0.05-0.5
 Cr+6

Mercury II,                0.01
 Hg

Silver, Ag     0.05-0. 1

Selenium, Se   0.05-0.1

Thallium, Tl     0.7

Cyanide (Free),                                                     0105
 CNA                                                                  '   '
                                  79

-------
8.2 THE  USE OF HISTORICAL  POLLUTANT  DATA


8.2.1  Determination    o_f   Enforcement    Guidelines  Based   Upon
Historical Performance

     In  cases where   there has  been  long  term monitoring  of the
pollution levels  in the effluent  stream  discharged  by a  plant, it
is  possible  to   assess  plant   pollution  performance  through
analysis of  historical data   that  has  been collected  for  this
purpose. The appropriateness of  standards constructed from  data
collected  from   a single  plant performance  is,  of    course,
dependent on the  plant's current  performance in relation  to  the
performance of other  plants in  the manufacturing subcategory.  As
economically  feasible  alternative  waste treatment  technologies
become available,  pollutant discharge guidelines need be reviewed
and revised to reflect  these advances.   Recommendations  for using
methods  presented  in  this  section should, therefore,  be  construed
as useful for  "monitoring" situations   rather than  those  which
require  "normative"   ones.  These  methods serve  to insure that
proper  maintenance  of   treatment  facilities   preserves  the
capability to effectively  reduce  waste  pollutant levels.

     Statistical  analysis   of   historical  monitoring data   is
required to  assess  a   plant's  ability to discharge within set
guidelines.  To  perform this analysis certain assumptions must be
made  regarding    the   nature    of   applicable  statistical   or
probabilistic  models,   the constancy   of  the operation of  the
treatment facility,   and  the quality of the monitoring   methods.
Assumptions made   in  this   report are outlined  in   the  following
sections.
Assumptions Concerning  Daily Pollutant Level  Measurements

     In the  formulation  and   calculation  of   the  following
performance  standards,    individual    sample   measurements   of
pollutant   levels    were    assumed    to  follow   the  lognormal
distribution,  a   well  known and  generally accepted  statistical
probability model used  in  pollution  analyses.   It follows, then,
that  the  logarithms  of   these  measurements  follow  a  normal
probability model.    It  was  also   assumed  that monitoring  at a
given  plant  was conducted responsibly  and   in such a  way that
resulting   measurements   can  be    considered    statistically
independent and  amenable to standard  statistical  procedures.   A
final  assumption  was  that  treatment facilities and  monitoring
techniques   had  remained substantially  constant  throughout  the
monitoring   period.   Summaries of the data  extracted  from  308
Questionnaires are  presented in the  tables Addendum A.   In these
tables,  the minima  (min) ,  arithmetic  averages  (aver) ,    maxima
(max),  and  standard  deviations, (st  dev),   were computed  directly
from   the   data    using  standard   statistical   formulae.   No

                               80

-------
logarithmic  transformations  were necessary  to  accomplish  the
calculations.    The  tables  are  representative  of   currently
achieved pollutant discharge performance  levels  in  the several
plants presented.


8.2.2  Assumptions  Concerning  30-Day  Average  Pollutant  Level
Measurements.

     While individual  pollution  level  measurements  should  be
assumed  lognormally   distributed,  that same assumption  is not
appropriate  when studying 30 day averages.   These  averages are
generally not distributed as lognormal quantities.  However,  if,
averages are  taken over  a reasonably  large number  of days,  a
statistical principle, the  "Central Limit Theorem",  states that
procedures  which are  appropriate  for a  normal (not lognormal)
probability model should be applied.  Therefore, the methods used
in  computing  historical  performance characteristics for 30-day
averages  differ somewhat from those  used  for daily samples  in
that the  coefficient  of variation*  as  defined  below,  is the
primary  determinant  of  the variability factor  for  the normal
probability model.

[* Coefficient of variation is defined as the ratio of a
statistical populations standard deviation to its average value.]


8.2.3 Variability Factor for Daily Samples.

     Since 30 day average and daily sample data require different
approaches, separate presentation  of  their  methods  are  given
here.  Variability factors  for  daily observations are presented
initially.    In  the  analysis  of   daily   data  the  inherent
variability  of measured pollutant levels  in the effluent stream
from   inorganic   chemical  manufacturing   processes   must  be
incorporated  in  calculating  upper  limits  for daily pollutant
discharge  levels.   Even well treated and controlled plants  may
experience  some days  when an atypically high level of pollutant
discharge is present in their waste stream.  Such high variations
may  be  due  to  a  variety  of  factors,  such  as  short  term
maladjustments   in treatment  facilities,  variation in  flow  or
pollutant load, or changes in the influent stream.  To allow  for
this  variability,  performance standards must necessarily be set
above the plant's long term average  performance  and occasional,
infrequent  excessive  discharges   permitted.   Since  pollutant
discharge  is often expressed in terms of  average level,  it  is
convenient  to   describe  standards  of  performance  and  allow
variability in term of multiples  of this average.  Such a method
of computing standards as functions of multiples of average level
performance is  explained  below.   The ratio  of  the  pollutant
standard level to  the  estimated  long  term average is commonly
called  the "variability  factor".   This  factor  is  especially

                               81

-------
useful  with  lognormally distributed  pollutant   levels  because  its
value depends   upon   the   expected number  of excessive  discharge
periods and  upon  the  day  to day variation  of the   process,  but is
independent  of  the   long  term  average,  so  that  variations in
average discharge do  not  affect its  value.

     For a lognormal  population,  the   relationship  between   the
pollutant standards,  P, and   the estimated  long term average,   A,
can be  shown to be:

        ln(P/A) = S(Z-0.5S)
where
    1)  S is  the estimated standard deviation
       of the  logarithms  of pollutant  level measurements.
       In the  calculations which follow, S  is computed by  the
       statistical  procedure  known as  the  "method  of moments".
       This  procedure requires that  S  be computed  as the
       square  root  of the natural logarithm of  one plus
       the  square of  the  estimated coefficient  of  variation.
and
    2)  Z is  a  factor  derived  from the  standard  normal
       distribution.   Z  is chosen to give  enforcement
       limitations  which  provide a balance  between appropriate
       consideration  of day to day variation in a  properly
       operating  plant and the necessity to insure that a
       plant is operating properly.   If the Z value  is too high,
       a treatment  facility may deteriorate appreciably without
       triggering an  enforcement action.    If it  is  too low,
       unneeded enforcement actions  will occur.
    3)  "In"  represents the natural logarithm  (base e)  of a
        numerical quantity.


     The value chosen  for Z is  very highly  dependent   on  the
conditions which  trigger  an enforcement action  and the nature   of
the surveillance   (monitoring)  of   a  plant.  If   there is daily
sampling, and  if  an enforcement  action is  triggered  by frequent
violations,  and  if "frequent violations"  are   "...  those which
occur more  than once   in  any  four quarters.",   then  a  choice of Z
=  2.78 is   appropriate.   Using the  limitations computed for this
value of Z,  one  expects  that only one violation  will  occur among
365  daily measurements,  that is, one  expects that 364/365ths   or
99.73%  of a  years measurements will  not exceed  the limitation. An
alternative  criterion for which one  expects that  only 1%  (5%) of
the daily observations of a  properly operating  plant exceed  the
limitation would  be to choose Z = 2.33 (Z  = 1.64).


8.2.4 Variability Factor  for  30-Day  Averages

     Using  averages of 30 lognormally  distributed  measurements to
ascertain   conformance   to   effluent  limitations   introduces

                               82

-------
complications in the computation  of variability factors. As  has
been noted before,  the  statistical distribution  of 30  day (or
"calendar   monthly")    averages   is  the  well   known   normal
distribution.  The variability factor  for this distribution is a
different function of  the  underlying coefficient  of  variation
than previously given for daily maxima.

     For the normal distribution appropriate to 30 day  averages,
the  relationship between  the  discharge  standard,  P, and  the
estimated long term average, A, may be demonstrated to be:
           P/A = 1.00 + Z(CV)
where
     1) Z is determined in the same manner as for daily data
        above except that Z values differ because only 11 of 12
        measurements in one year must meet standards,
and
     2) CV is the estimated coefficient of variation computed
        from the sample of historical monthly averages;
        i.e. CV = S/A. In this case A and S are computed directly
        from the monthly averages.  No logarithmic transformations
        are involved.

The  results   of  computations  on  historical  data  under  the
assumptions  outlined  above are  presented  in Appendix  A.  The
variability  factors  for daily  maxima  are computed  using  A  =
average of daily  measurements and,  as  the  method  of  moments
stipulates, S = the square  root of the natural logarithm  of one
plus  the square of the estimated coefficient of variation of the
untransformed   (not   logarithmic)   daily  measurements.    The
variability factors for monthly  averages are computed using  A  =
average  monthly average  and S  = standard  deviation of monthly
averages (untransformed).
                               83

-------
                           SECTION  9
              TREATMENT TECHNOLOGY APPLICATIONS
                FOR  PRIORITY  POLLUTANT  REMOVAL
9.1 SELECTION  OF  POLLUTANTS TO BE CONTROLLED

     In  order  to  determine which priority  pollutants,  if  any,  may
require   effluent limitations, the   pollutants  observed   in   each
subcategory  were  evaluated with regard  to   their  treatability and
potential environmental   significance on   the   basis of   the   raw
waste concentrations  and  mass loadings  found during screening  and
verification.

   Group 1 - Those metals which appear  at  concentration levels that
            are  readily  treatable  using available technology and
            which have environmentally significant mass  emission
            rates.

   Group 2 - Potentially  significant metals observed  in the
            subcategory

     Table 9-1 presents the significant priority  pollutant metals
found in  each subcategory, and  divides   these  metals   into  two
groups.   In  general,  those metals occuring in  the first group are
of  prime concern   and  may  require  regulation,  while  those
occurring in the  second group are of somewhate less   concern and
are not  expected  to require regulation.
9.2  APPLICATION   OF
ALTERNATIVES
ADVANCED  LEVEL   TREATMENT  AND   CONTROL
9.2.1 General  Design  Objectives

     Beginning  with   Section  11  of  this   document,   the  selection
and  application  of   priority pollutant   treatment  and  control
technology  for  model  plant  systems  for each  of   the subcategories
proposed  for   regulation   are   described.    Level   1  represents
existing  BPT treatment  systems and  the advanced  levels  (Level  2,
3,  etc.)  are the  selected technologies for step-wise improvements
in   priority pollutant  removal   over  that achieved  by   the  BPT
system.   Flow  diagrams   show  BPT components   as   a  starting point
for  advanced   level  treatment  additions and   incremental  cost
estimates.
                               84

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TABLE 9-1.   PRIORITIZATION OF POLLUTANT METALS FOUND IN EACH SUBCATEGOKY
SUBCATEGORY
Group 1
Group 2
Chlorine-diaphragm cell


Chlorine-mercury cell



Hydrofluoric Acid




Titanium Dioxide -
Chloride Process


Titanium Dioxide -
Sulfate Process





Aluminum Fluoride
Antimony
Arsenic
Chromium
Copper
Lead
Nickel
Arsenic
Mercury
Thallium
Zinc


Arsenic
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Zinc
Chromium
Lead
Nickel
Zinc
Arsenic
Cadmium
Chromium
Copper
Lead
Nickel
Thallium
Zinc
Copper
Selenium
Cadmium
Mercury
Selenium
Thallium
Zinc

Antimony
Cadmium
Chromium
Copper
Lead
Nickel
Silver
Antimony
Cadmium
Thallium







Antimony





Arsenic
Cadmium
                                                             Chromium
                                                             Mercury
                                                             Nickel
                                   85

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TABLE 9-1 -  continued
SUBCATEGORY
  Group 1
  Group 2
Chrome Pigments
Hydrogen Cyanide

Sodium Dichromate
Copper Sulfate
Nickel Sulfate
Antimony
Cadmium
Chromium
Cyanide
Lead
Nickel
Zinc

Cyanide

Chromium
Nickel
Zinc
Arsenic
Cadmium
Copper
Nickel
Zinc

Nickel
Sodium Bisulfite
Zinc
Arsenic
Copper
Selenium
Silver

Antimony
Lead
Cadmium
Chromium
Copper
Lead
Mercury
Selenium
Thallium

Antimony
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
                                   36

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     For both  existing  and  new  sources,  the   advanced  level
technology  options  are  selected  as  candidates for   BAT  with
priority pollutant  removal as  the primary objective.    Although
the advanced level systems  chosen also give improved performance
over the Level 1  (BPT)  systems for the  removal  of conventional
and nonconventional pollutants,  this is regarded  as a   secondary
design objective.

9.2.2 Pretreatment Technology

     Since untreated heavy  metal ions will usually  pass  through
the treatment provided in a typical POTW, or will  be precipitated
with the POTW solid residue,  pretreatment  of  wastes  containing
significant amounts  of heavy metals is necessary-  As  a   general
rule, alkaline precipitation, followed by settling  and  removal of
the solids, will suffice.  In certain subcategories, such   as the
chlorine industry, specific treatment will be required  for highly
critical  constituents (mercury,  lead, chlorinated  organics and
asbestos) .  Normally the Level 2  model treatment  processes shown
in the following subsections will be appropriate for pretreatment
prior to discharge to a POTW.
9.2.3 New Source Performance Standards

     In only one subcategory,  hydrofluoric acid,  is a  technology
proposed for  new sources.  For the remaining subcategories,  the
Level  2   model  treatment  process  is  considered  appropriate
technology for new sources.
9.3 ESTIMATED ACHIEVABLE PERFORMANCE CHARACTERISTICS FOR ADVANCED
LEVEL APPLICATIONS

     Advanced level  control  and  treatment  alternatives   for
reduction of pollutant discharges and their applicability to each
subcategory are presented in the sections dealing with  individual
products.  With few exceptions,  these alternatives were selected
specifically for removal of priority pollutants and were designed
for end-of-pipe treatment.

     Treatment technologies practiced  outside  the industry  are
recommended when  appropriate and, in  most cases,  apply   to the
removal of  priority  pollutant  metals.   The  estimated   30-day
average treatability levels (Sections 8,  Table 8-11),  long  term
data parameters,  and the screening and verification results  are
all  utilized  in   the   development  of  estimated  performance
characteristics for  the  recommended  treatment  applications in
each subcategory.


                               87

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9.3.1  Advanced  Level  Removal  of  BPT  Pollutants

    Performance  estimates  for these systems, when possible,  were
based  on  effluent quality achieved at plants currently practicing
thes technologies.    However,  in most cases, the  advanced  levels
are not currently being  practiced within  the specific  subcategory
of concern,   and  performance  information   from  other   appropriate
sources is necessarily utilized.

    When established waste  water   treatment practices,  such  as
clarification or  filtration,   form a  part of advanced  treatment
alternatives, the specified achievable  effluent quality has  been
based  on concentrations accepted as  achievable  through  proper
design and   control. The  prime  example of  this  is suspended
solids reduction  by  filtration.


9.3.2  Advanced  Level  Removal  of  Priority  Pollutants

    Performance  estimates  for  priority  pollutants   were  also
based, when possible,  on  effluent  quality achieved at  plants
currently practicing these   technologies.   However,  in    most
subcategories,  priority pollutant   analyses  are   not  conducted
unless a  specific pollutant is regulated  and requires  monitoring.
Where   transfer   of   technology  is  applied   as  a    treatment
alternative, performance   estimates  for  priority    pollutant
removals  were based  on   the  demonstrated  performances  in other
industries    while   incorporating    allowances   for     specific
differences   in  process waste  characteristics  and    operating
conditions.   Statistically  derived  long-term monitoring  data
parameters   were   described  in  Section   8 and are compiled  in
tabular  form in  Appendix A.   The screening and verification  data
are used  to  supplement the  available  long-term data  applied  to
each subcategory. A  judgment is made as  to whether the screening
and verification  data represent a  well  performing system  or one
which   is not  performing at  its technological   potential.   For a
well  performing  system, the   data are regarded as representative
of   30-day   averages   and  are compared with  the    estimated
treatability ranges  from   Table 8-11,   as well   as   the  30-day
averages  developed from  the long-term data.  In this manner,   the
performance  estimates for each pollutant, at each  treatment level
for the nonexcluded  subcategories, are developed and  presented in
tabular   summaries.   By  starting with  the  estimated achievable
30-day averages,   the specific  variability factor ratio derived
for each  pollutant is used  to estimate the daily  maximum values.

    The  model  plant waste  flow per unit of  production is  then
taken  to  calculate  the  estimated   mass   emission values of   the
30-day average  and daily maximum limits for each pollutant to  be
controlled.
                               88

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                          SECTION  10
            COSTS  OF  TREATMENT AND CONTROL  SYSTEMS
10.1 INTRODUCTION
10.1.1  Purpose of  Cost Data

     More  complex    treatment   methods  and   higher   levels  of
pollutant  removal  are reflected   in  increased  costs of equipment,
energy,  labor and  chemicals.   At  some  point, the  increasing costs
of  treatment  will  outweigh  the benefits  of   such   treatment.
Therefore,   it is  important  that  for each  subcategory  the  Agency
know the   base cost and  he  incremental  costs  of  each  level of
treatment  which it might prescribe.   These "options"  of internal
costs,  which are  the industry's   annual costs of providing  the
necessary  waste treatment, will result in  related  increases   in
product costs,  which are  termed external costs.   Thus  annual
costs of waste treatment   are  expressed  in terms of dollars  per
unit of annual production of the  principal product.
     Because  plant  visits   revealed   very   few   t
serving  a   single product manufacturing  line, it
to seek  actual  waste  treatment   facilities   which
real models for estimating  purposes.   Accordingly
were taken  from similar  construction  projects by
and from unit  process equipment costs assembled
other commercial sources. Because the model  costs
range of   climate,   material   sources  and  labor
should  be  considered as preliminary estimates
minus 15 to 25  percent.
reatment  plants
was not feasible
 could serve  as
, the cost  data
the  contractor,
from vendors and
 apply to a wide
 conditions they
 within  plus or
     Actual  costs  incurred   by  individual  plants  may   be more  or
less than  the  presented model plant  costs.   The  major   causes  of
variability  are:
         Waste  water  treatment  combined  with  the  treatment  of
         other  product  effluents.

         Site dependent conditions,  as  reflected  in  piping
         lengths,  climate,  land availability,  water  and  power
         supply and  the location of  the  points of final

                               89

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         discharge and solids disposal.

     3.   Material (reagent)  costs, due to variation  in
         availability and distance from the source.


     The construction costs  are  based  on the Engineering  News
Record Construction  Index for  July 1978 (ENRCI=2800) , and other
costs are expressed in mid-1978 dollars.


10.1.2 General Approach

     Since few  single  product  waste  treatment  plants   were
available for detailed study, the costs presented in  this section
are  based on model  plants  which closely resemble  the types and
capacities of waste treatment facilities needed for  each separate
product subcategory.  The  model  plant selections are  based  on
review of  Section  308  Questionnaire  responses, plant  visits,
development documents,  contacts  with  the industries  to verify
treatment practices and to obtain data on size, waste water flow,
and  solid  waste  disposal   systems.   Thus,   each   model  is
synthesized   from  actual  data  as   a  typical  plant  in  its
subcategory with  a  level of  waste treatment equivalent to BPT.
Variations  in  treatment  plant  capacity  are accounted  for by
selecting sets of models which represent  the  range of  existing
production plant capacities in the subcategory; large, medium and
small.  Thus the model plants are not set up as exemplary plants,
but  as  typical plants  of adequate  design which represent  the
range   of  plants  and  treatment   facilities   found  in   the
subcategory.
10.1.3 Cost References and Rationale

     Cost information  contained  in  this  report  was  obtained
directly  from industry,  engineering firms, equipment  suppliers
and  current  experience  of  the contractor.  Whenever possible,
costs are based on actual industrial installations or engineering
estimates for  projected  facilities as  supplied  by  industries
consulted during  the study.  In the absence of such information,
cost estimates have been developed from either current costs  for
similar  waste  treatment installations  at plants  making  other
inorganic  chemicals or from general  cost estimates for specific
treatment technologies.

     Treatment costs  are  based  on  model   production   plant
characteristics  which determine the treatment processes selected
for  each operation.  Under set  effluent limitations,  treatment
costs are primarily functions of the pollutant load  (i.e., kg/kkg
of  product),  waste  water flow  rate  (i.e.,  cubic meters/day).
Available data indicate that both pollutant loads and flow  rates

                               90

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can   vary  significantly  among   plants   manufacturing  the  same
product.


10.1.4  Definition  of  Levels   of   Treatment  and  Control  Cost
Development

     For  the   purpose of  establishing  the  base  level  treatment
costs,  each  industry is assumed  to  be practicing Best Practicable
Control  Technology  Currently   Available (BPT),  which  the  EPA
Effluent   Limitations  Guidelines  required by 1977   for  certain
pollutants (conventional  and  nonconventional, as well as  some of
the  priority toxic  pollutants)   specified  for each   subcategory.
The  investment costs and  annual costs   of  such  BPT systems  are
shown in  this report as the base level  or Level 1.  This level of
treatment may also  provide   incidental  removal  of  additional
priority   toxic  pollutants   not  previously  specified   in  the
regulations.

     The  advanced treatment levels  (Level 2, Level  3,  etc=)  are
aimed primarily  at  reduction of  priority  toxic  pollutants to
levels considered acceptable  for   July  1,  1984,   performance,
utilizing Best Available  Technology Economically Achievable (BAT)
at incremental investment and annual costs  beyond those shown for
Level 1.  For example, for Level  3 treatment, the incremental cost
as given  in  the table is  directly added  to  base or 1st Level cost
to obtain the  total  cost of the treatment system.   The addition
of the Level 2  incremental   cost is not  required to  obtain the
Level 3 total.  The waste water  treatment flow diagram for Levels
2, 3, etc.,  as given under Section  8 of  this report, includes the
flow  diagram for base or Level  1 of treatment.  This is  because
increment  levels of treatment  are  always added to the 1st  level
of treatment.
10.1.5   Treatment  and   Disposal  Rationale   Applied   to  Cost
Development

     The following   assumptions  are   employed  in   the  cost
development:

1.  All  noncontact cooling  water is excluded from treatment
    (and treatment costs)  provided that no pollutants are
    introduced.

2.  Water treatment,  cooling tower and boiler blowdown discharges
    are  not considered process waste water unless such flows
    contain significant  amounts of pollutants.

3.  Sanitary sewage flow is excluded.

4.  The  plants  are assumed  to operate 24-hours per day, 350 days

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    a year,  except where noted otherwise.

5.   Manufacturing plants are assumed to be single product plants.

6.   The inorganic chemical industry has generally found and
    extensively uses in-plant control techniques such as
    in-process abatement measures,  housekeeping practices, and
    recycling of process waste waters to recover valuable
    materials or use these materials as feed for other
    by-products.  Segregation of uncontaminated cooling and
    other waters prior to treatment and/or disposal, and similar
    other measures can contribute to waste load reduction.  All
    such costs have not been included in the cost estimates.

7.   Excluded from the estimates are any costs associated with
    permits, reports or hearings required by regulatory agencies.


10.1.6 Expression of Costs
                          j*
     Investment costs for Level 1 treatment systems are expressed
in mid-1978   dollars to  construct base level facilities for each
single  product manufacturing subcategory  at  various production
rates.

     Similarly, operation,  maintenance and  amortization of  the
investment  are expressed as  base level annual costs for Level 1
and as incremental annual  costs for  Level 2 and above.  Where a
single   product  plant  produces  more  than  one  waste  stream
requiring treatment, the respective investment  and annual  costs
are the combined costs of all treatment.

     Total annual costs  per metric  ton  of product are shown in
the summaries for each product subcategory.


Direct Investment Costs for Land and Facilities

     Types of  direct   investment  costs  for  waste  treatment
facilities and  criteria for estimating major  components  of the
model plants are contained in the following subsections:

     Construction costs  -  Construction  costs,  including  site
preparation,   grading,   enclosures,   buildings,   foundations,
earthwork, roads, paving and concrete.

     The costs of constructing lagoons can vary widely, depending
on local topographic and soil conditions.  The required areas of
lagoons  and  settling  ponds  and  their  consequent  costs  are
developed as a function of volume (capacity).  It is assumed that
reasonably level  sites  are available, consisting of sandy  loam
with high  clay content   and no large rocks or rock  formations.

                               92

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It  is assumed that  two  rectangular    lagoons  are   furnished  in
parallel, with one common dike  to  permit alternate dewatering  for
sludge removal by the clamshell method.   Using balanced   cuts  and
fills, earth  dikes with 2:1  slopes provide  liquid   depths  from
three  to   five  meters.    Earth moving   costs are   significantly
affected  by  site conditions and  quantities.  To  express   these
variations  for a  range  of sizes at  three depths,  the   cost   of
clearing, excavation,  dewatering,  compaction,  finish   grading,
riprap and  associated indirect  expenses  for   earthen lagoon  were
plotted against liquid volume.   Piping, valving and dike   roads
not included  are added separately  in the cost summaries.  Lagoons
are unlined unless the contents are highly pollutional or acidic.
The liner material employed  for   impervious  lagoons is  Hypalon.
The installed cost of the liner is $11.00 per square meter  ($9.20
per square  yard), which  includes  the trenching and backfilling
necessary for anchoring  the liner.   In some   subcategories,  in
place of Hypalon,  clay  lining  has been used at a  cost  of  $5.40
per square  meter  ($0.50 per square foot) .

    Costs  of buildings may vary from  $25.00  to  $45.00 per  square
foot.  For  the purpose of this  study,  building cost  is  estimated
at $377.00  per square meter  ($35.00 per  square foot).

    Concrete construction  for  miscellaneous work   varies  from
$260.00 to  $785.00 per cubic meter ($200.00 to $600.00  per  cubic
yard).   For  foundations   and  flat   slabs,  concrete  has  been
estimated   at $395.00 per cubic meter  ($300.00 per cubic  yard)  in
place.   Asphalt paving which has  been  used  on  lagoon dikes  and
for miscellaneous  roads,  is  installed at a  cost   of $9.70  per
square meter  ($0.90 per square  foot).  A   width of three meters  is
generally assumed.

    Equipment costs -  Depending  upon  the method   of treatment,
equipment  for waste water treatment consists  of  a combination   of
items such  as pumps, aerators, chemical feed systems, agitators,
flocculant  feed  systems, tanks, clarifiers, thickeners,   filters,
etc.  Cost tables for these items were  developed  from   vendors'
quotations  on a  range of sizes, capacities and motor horsepowers.
Except  for  large size tanks and chemical storage bins, the  cost
represents    packaged,   factory-assembled    units.    Mechanical
components  are generally skid mounted, prepiped  and  prewired;  and
include associated  pumps,  meters  and  instrumentation.   Critical
equipment   is  assumed  to  be  installed  in   a  weather   proof
structure.    Chemical  storage,  feeders and  feedback equipment
include   such    items   as    probes,   instruments,  controls,
transmitters, valves,   dust   filters  and   accessories.   Bulk
chemical storage bins are designed to  hold  a standard bulk  truck
load,  plus   five  days  needs,  between ordering   and delivery.
Critical pumps are furnished in duplicate and when clarifiers  are
used, the flow is  split between two units,   permitting one  to  be
bypassed for  repairs.   Single  units  are used  for  small  flows,
batch treatment and intermittent service.

                               93

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     Installation cost  - Installation is  defined  to  include all
services,activities, and  miscellaneous material   necessary  to
implement  the  described  waste  water  treatment   and    control
systems, including  piping, fittings,  and electrical  work.  Many
factors  can  impact  the  cost  of installing equipment modules.
These include wage rates, manpower  availability, whether  the job
is performed  by  outside contractors  or regular   employees, new
construction  versus  modification  of   existing    systems,  and
site-dependent  conditions (e.g.,  the availability of sufficient
electrical service) .  In these estimates, installation costs were
chosen for  each application,  based upon average site conditions
and taking  into consideration the complexity of the system being
installed.   An appropriate cost is  allowed for  interconnecting
piping, power circuits and controls.


     Monitoring equipment - In this  report, it is   assumed  that
monitoring equipmentwTTl  be installed at the treated  effluent
discharge point.   It will consist of  an indicating,  integrating
and recording type flow meter, pH meter with sensor  and recorder,
alarms and controls and an automatic sampler.

     Land -  Land  availability  and  cost  of   land  can  vary
significantly, depending upon geographical  location,  degree  of
urbanization and the  nature of adjacent development.   Land  for
waste treatment, and in some cases for inert solids  disposal,  is
assumed to  be  contiguous  with the  production plant site  and
reasonably convenient to a water way which can receive permitted
discharges of waste water.  Where  inert  solids  are  retained at
the plant site, enough land is included in the  base level  model
plant investment  cost  to  accept residual  solids  for  a normal
operating period of  ten years at  the same  production  rate for
which the plant is sized.

     For the purpose  of this report, land for lagoons, treatment
facilities  and on-site  residual  waste  disposal  is  valued  at
$30,000 per hectare ($12,000 per acre) .

     Investment costs  for  supporting  services  -  Engineering
design andinspection are  typicalservices necessary to bring a
project  from a concept  to an  operating  system.   Such services
broadly include laboratory  and  pilot  plant  work to establish
design  parameters,  site  surveys to  fix elevations  and  plant
layout, foundation and ground water investigations,  and operating
instructions; in  addition to design  plans,  specifications  and
inspection during construction.  These costs, which vary with job
conditions, are  often estimated as percentages  of construction
cost, with typical ranges as follows:
                               94

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     Preliminary survey and construction  surveying   1  to  2%

     Soils and ground water investigation            1  to  2%

     Labortory and  pilot process work                2  to  4%

     Engineering design and specifications           7  to  12'

     Inspection during construction                  2  to  3%

     Operation and  maintenance manual                1  to  2%
     From  these  totals  of  14  percent  to  25   percent,  a  mid-value
of 20 percent of in-place  construction  (installed   equipment   and
construction)  costs  has been  used  in  this study  to  represent   the
engineering   and  design  costs  applied to model   plant    cost
estimates.

     The  contractor's fee  and contingency,  usually  expressed  as  a
percentage   of in-place construction  costs,  includes  such general
items as   temporary  utilities,  small   tools,   dewatering, field
office overhead  and  administrative expense. The   contractor  is
entitled  to  a reasonable profit  on his activities and to the  cost
of interest  on capital  tied up during construction.   Although not
all of the   above  costs  will  be incurred on every  job, an
additional 20 percent of the  in-place construction  costs has  been
used  to   cover  related costs broadly described as  contractor's
fees, incidentals, overhead and  contingencies.


Operation  and Maintenance  Costs

     Annual  operation   and maintenace costs are   described   and
calculated as follows:

     Labor and  supervision   costs -  Plant  operations are assumed
to  be conducted 24-hours   per  day  350   days per year,  with
attendance   for  only part  of  each   working  day.   For batch waste
water treatments systems adjustment are  made for   the number  of
working days in  a year. Personnel costs are based  on  an hourly
rate of $20.00.   This   includes  fringe benefits  and an  allocated
portion  of  costs for management,  administration and  supervision.

     Personnel are assigned   for  specific  activities as required
by the complexity of the system, usually 4  to 12 hours per day.

     Energy  costs - Energy  (electricity) costs  are  based on the
cost of $306.00  per  horsepower operating 24  hours per day and 350
days per  year.  For  batch  processes,  appropriate adjustments are
made to suit the  production  schedule.   The cost  per horsepower

                               95

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year is computed as follows:

     Cy= 1.1  (0.7457HP x Hr x Ckw)/(E x  P)            (1)

  where

     Cy = Cost per year

     HP = Total horsepower rating of motor  (1  hp =  0.7457 kw)

     E  = Efficiency factor (0.9)

     P  = Power factor (1.00)

     Hr = Annual operating hours  (350 x  24  = 8400)

     Ckw = Cost per kilowatt-hour of electricity ($0.040)


     Note:  The 1.1  factor  in equation (1) represents allowance
for incidental energy used such as lighting, etc.

     It is assumed that no other  forms of energy are  used  in  the
waste treatment system.

     Chemicals -  Prices for  the  chemicals   were  obtained  from
vendorsandthe  Chemical Marketing  Reporter.    Unit   costs  of
common  chemicals  delivered  to  the plant site   are   based  on
commercial  grade   of   the   strengths or   active    ingredient
percentages as follows:

     Hydrated Lime (Calcium Hyroxide) Bulk       $  80/metric ton
                                      Bag        $  85/metric ton

     Quick Lime                       Bulk       $  70/metric ton

     Ground Limestone                            $  13.20/metric ton

     Soda Ash  (58% Bulk)                          $  85/metric ton

     Caustic  Soda (58% NaOH)                     $200/metric ton

     Sodium Sulfide (60-62%)                     $435/metric ton

     Sulfuric Acid                               $  75/metric ton

     Hydrochloric Acid (32%)                     $  70/metric ton

     Aluminum Sulfate  (56% Alumina)              $250/metric ton

     Flocculant (Polymer)                        $2.00/kg


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     Sulfur Dioxide  (Ton Containers)             $335/metric  ton

     Chlorine  (ton Containers)                   $220/metric  ton

     Sodium Bisulfide  (72-74%)                    $385/metric ton

     Ferrous Sulfate                             $  70/metric  ton

     Diatomaceous Earth                          $   0.30/kg

     Activated  Carbon                            $   2.00/kg


     Maintenance - The annual cost  of maintenance  is  estimated as
10 percent of  the investment cost,  exluding  land.

     Taxes and   insurance  - An  annual provision   of three  percent
of the   total   investment  cost has been  included  for  taxes and
insurance.

     Residua1  waste  disposal   - Sludge disposal  costs can vary
widely"!  Chief  cost  determinants include  the amount and type of
waste,   and  the  choice   of either on-site disposal or contract
hauling  which   depends on  the   size of the disposal operation and
transport distances.   Off-site   hauling   and  disposal costs are
taken as $13.00 per  cubic  meter ($10.00 per  cubic  yard)  for bulk
hauling, with  appropriate  increases for small quantities in  steel
containers.  For  on-site  disposal from   lagoons, a  clamshell at
$600.00  and frontend loader at  $300.00 per disposal day are  used.
For very  large sludge  quantities, lower unit  costs  have   been
assumed.  The  computed sludge   quantities   are   spread on   land
valued  at  $12,000 per  acre.

     Monitoring, analysis   and   reporting    -    The  manpower
requirements covered  by the annuallabor and  supervision  costs
include  those   activities associated  with  the   operation and
maintenance of  monitoring instruments, recorders, and automatic
samplers  as   well   as  the  taking of   periodic   grab samples.
Additional  costs for  analytical  laboratory services have been
estimated  for  each subcategory  assuming that sampling takes  place
three  times a   week  at   the   point of  discharge  and   that an
analytical   cost  of  $20.00   per   constituent   is  incurred.
Approximately  10 percent of  the total  analytical cost has been
added  for  quality  control  and  water   supply samples.   Unless
otherwise   stated,  continuous  discharge   is  assumed and  the
analytical costs associated with compliance  monitoring at  the BPT
level  are based on  the determination  of four  constituents. At
the advanced  (BAT) levels, the   determination of six  constituents
is  assumed.   A reporting  cost  of $1,500  per year   is  added  for
clerical support.  Monitoring costs for periodic batch treatments
are  reduced in proportion to the number  of   days   per year   when
discharges occur.

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Amortization

     Annual depreciation  and  capital  costs   are   computed  as
follows:
                      n        n
         CA = B[r(l+r) ]/[ (1+r)  -1]              (2)

   where

     CA = Annual cost

     B  = Initial amount invested excluding cost of  land

     r  = Annual interest rate (assumed 10%)

     n  = Useful life in years

     The multiplier for B in equation  (2)  is often  referred to as the
capital recovery factor, and is 0.1627 for the  assumed  overall useful
life of 10 years.  No residual or salvage value is assumed.


Items not Included in Cost Estimates

     In some  subcategories,  a  portion  of the  waste water  is
returned  to  process  from an intermediate  treatment  step.   In
these  cases,   the  costs  of  return  piping  and,  pumping  are
considered  as  water  development  and  not as waste  treatment.
Costs for subsequent  treatment are  based on   the  remaining flow
after diversion of the return-to-process flows.

     Although specific plants may encounter  extremes of  climate,
flood hazard and availability of water, the costs of model  plants
have  been  estimated  for  average  conditions of   temperature,
drainage and natural  resources.  It is assumed  that  any necessary
site drainage, roads, water development, security,   environmental
studies  and  permit  costs  are already included   in  production
facilities  costs.   Therefore,  the  model  costs   are only  for
facilities,  supplies   and  services  directly related   to  the
treatment  and  disposal  of  waterborne   wastes, including  land
needed for treatment  and on-site sludge  disposal.   Air pollution
control  equipment  is not  included,  except for dust  collectors
associated with  treatment,  chemical  transfer and  feeding.  Raw
wastes  from various sources are assumed   to be delivered  to the
treatment  facility  at  sufficient  head  to   fill   the  influent
equalization basin, and final effluent is discharged by  gravity.
Costs  of pumps, pipes lines etc., necessary to deliver raw waste
water to the treatment plant  or to deliver the treated  effluent
to the point of discharge are not included  in  the cost  estimates.

     Since the  treatment models  are  designed to   serve  single
product  manufacturing  plants,  no  emergency holding basins or

                               98

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internal bypasses are  provided.   Any   such   necessary  facilities
are  more   appropriately  furnished  as   part   of   a  combined  waste
treatment  system serving  several  product  lines.
10.2 COST  ESTIMATES FOR  EACH  SUBCATEGORY
     Estimated  costs  for  the  waste  water  treatment  plants  for  the
different   annual  productions  and  at  various  levels  of  treatment
are calculated  in  terms of  total  annual costs.   The  total  annual
cost  is   the   summation  of   the  annual   amortization  of   the
investment costs and  the  annual operation  and  maintenance  costs.

     The  types  of  costs shown for each model plant  are:

     (a)   Investment

     (b)   Annual operation  and maintenance

     (c)   Annual amortization of  investment costs  (excluding  land)


The total  annual   costs   per   metric   ton   of  product have  been
calculated.

     For  the  purpose  of   the  cost  estimate, the  first  level of
treatment  represents  the  base cost  of  the  treatment system  (BPT).
The other  levels  (second,  third, etc.)  represent  the incremental
cost above the  base   cost.  The actual  additional   costs  a plant
would incur  in implementing   the  described   treatment  processes
depend on  current  treatment  practices, and to some extent on  the
availability  of land.

     In some  cases   land for economical   on-site  sludge disposal
for a ten  year  period has  been  provided  in the BPT  model   plant
costs.   Since  land cost  is  not  amortized, its value appears   in
the initial investment cost but  not  in   the total  annual   costs.
Where land  is   a  major   factor  in  the  BPT estimated costs,  its
significance  will be mentioned  in the separate  reviews  of  each
subcategory.
                               99

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                           SECTION  11
                     CHLOR-ALKALI  INDUSTRY
11.1  ASSESSMENT OF THE WATER  POLLUTION  POTENTIAL -  MERCURY CELL
11.1.1  Industry  Profile  and  Analytical  Results

     Chlorine, hydrogen  and  caustic  soda  (NaOH)  or caustic potash
(KOh) are   produced  together by  electrolysis of  brine.    Chlorine
is used in  pulp  and  paper  industry,  plastics,  water treatment,  as
an input  in   the  manufacture   of   vinyl   chloride,   chlorinated
ethers, and   other   inorganic   and    organic   chemicals.    About
two-thirds  of  the  production is  for  captive uses.
Chlorine  -  Mercury  Cell  Plants
     The  industrial
Table 11-1,  and  the
  profile data for  this industry is
 existing regulations in Table 11-2.
              given in
     The  priority   pollutants  found  in siginficant concentrations
in  the   raw  waste  during   sampling   at  Chlorine - Mercury  Cell
Plants were as  follows:
     Pollutant
Maximum Concentration
         ug/1
       Screening
                                         Observed
Verification (5 Plants)
Mercury
Copper
Chromium
Antimony
Arsenic
Cadmium
Lead
Nickel
Zinc
Thallium
Silver
150
350
7
<200
< 10
0
1
<100
230
<250
0
.7

.4




.6
27600
1480
235
950
400
787
1900
2450
34830
650
1455
     A  summary  of  daily  and  unit product raw waste loads for  all

                               100

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TABLE 11-1
SUBCMEGORY PROFILE DATA .SUMMARY
SUBCATEGORY
CHLORINE MERCURY CFT,T,
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                         3,545,000 kkg/year
                         2,750,000 kkg/year
                                32
                                15
                         1,280,600 kkg/year
                         1,090,000 kkg/year
                                36 percent
                                40 percent

                            19,100 kkg/year
                           198,000 kkg/year
                            77,900 kkg/year
                            70,400 kkg/year
                                75 percent

                                2 years
                                26 years

                                4 cubic meters/day
                            2,100 cubic meters/day

                               < 1 cubic meters/kkg
                                11 cubic meters/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Contnerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.;  Draft
Report, "Preliminary Economic Assessment of Effluent Limitations  in the
Inorganic Chemical Industry."
                                    101

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TABLE 11-2 -     EXISTING REGULATIONS  -  EFFLUENT LIMITATICN GUIDELINES
SUBCATEGORY Chlorine and Sodium or Potassium Hydroxide
SUBPART F (40CFR 415.60, 3/12/74)
STANDARDS
Product Para-
Process meters
Mercury
Cell TSS
Process
*
BPCTCA BATEA" NSPS
1 2
Max. Avg. Max. Avg. Max. Avg.
kg/kkg k/kkg k/kkg k/kkg k/kkg k/kkg
(mg/1) (mg/1) (mg/1) (mg/1) (mg/1) (mg/1)
0.64 0.32 No discharge ^ Q>32
or pwwp-
           Hg

Diaphragm
Cell       TSS
Process

           Pb
                      0.00028   0.00014
                      n , .
                      °-64
n ,0
°'32
                      0.005     0.0025
No discharge
ofpwwp
                                           of pwwp
0.00014  0.00007


0.64     0.32


0.00008  0.00004
 *
   Section 415.63 was remanded and is presently reserved C41 FR 51601,
   November 23, 1976).
  wax. = Maximum of any one day.
 2
  Avg. = Average of daily values  for thirty consecutive days shall not exceed.

  pwwp = Process wastewater pollutants.
                                    102

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plants sampled can be found in Table 11-3.    Individual  plant  raw
waste loads per unit product  (units kg/kkg)  found  in  sampling  can
be found in Table 11-4.

     Based on the total annual production  of  this  subcategory  and
the average  waste load generated per unit product, the  estimated
total priority pollutant  raw waste loads  generated each year  for
this subcategory are as follows:


          Pollutant       Waste Load (kg/year)
Mercury
Copper
Chromi urn
Antimony
Arsenic
Cadmium
Lead
Nickel
Zinc
Thallium
Silver
44000
910
250
1200
830
140
880
720
6300
830
610
11.1.2  Process Waste Sources and Waste Water  Treatment  Data


General Process Description

     Currently almost all of the caustic  soda  and   95   percent of
all  the chlorine produced  in  the United   States  is  made  by the
electrolysis  of sodium or  potassium  chloride.    Sodium chloride
is  obtained   by  mining  underground    deposits    or  from  the
evaporation of brine or sea water.  Two types  of   cells  are used
for the production of chlorine and caustic—mercury and  diaphragm
cells.  Mercury cells account for approximately  30  percent  of the
production while the diaphragm cell accounts for  65 percent.  The
Downs cell is another electrolytic process  for producing chlorine
and  sodium  from  fused  salt.  However, the  amount  of chlorine
produced  by  this   process  is  relatively  small.    Since  the
predominant method  of making chlorine and  by-product   caustic is
by the use  of  mercury and diaphragm  cells,  this study of  the
chlor-alkali subcategory  is  restricted  to these  two processes.
Because of  the difference in  cell  design and  the  quality  and
quantity of waste  water produced, the  chlorine   subcategory has
been subclass!fied into two divisions;  the mercury  cell process
and  the  diaphragm  cell  process   (See  Section   4).    Both  the
processes  are  described  later  using sodium  chloride  as  the
starting  material.   The  same  description  holds   true when
potassium  chloride  is  the  starting  material,   but  with  one
difference  -  the  by-product  produced  in the   latter  case  is

                               103

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TABLE  11-3.   SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING

SUBCATEGORY
Pollutant
Priority
Antimony, Sb
Arsenic, As
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni
Silver, Ag
Thallium, Tl
Zinc, Zn
Conventional
TSS
CHLORINE-MERCURY CELL
Minimum

0.0059
0.00045
0.00032
0.0014
0.029
0.034
0.086
0.018
0.00036
0.0027
0.11
6.76
kg/day
Average

0.15
0.086
0.0091
0.028
0.11
0.068
2.84
0.046
0.058
0.071
0.42
307
Loadings
Maximum Minimum

0.29
0.27
0.025
0.094
0.020
0.13
6.71
0.072
0.22
0.14
1.10
1199

0.00001
0.000001
0.0000008
0.000004
0.0001
0.000089
0.0002
0.00003
0.00001
0.00002
0.0003
0.018
kg/kkg
Average

0.00045
0.0003
0.00005
0.00009
0.00033
0.00032
0.016
0.00026
0.00022
0.0003
0.0023
2.19
No. of Plants
Maximum Averaged

0.00074
0.01
0.0002
0.0004
0.0006
0.0007
0.063
0.0007
0.0008
0.001
0.01
10.8

3
5
5
6
6
5
6
4
4
4
6


-------
TABLE  11-4.    PRIORITY POLLUTANT RAW WASTE LOADS (in kg/kkg of Product)
SUBCATEGORY
POLLUTANT

Mercury, Hg
Chronium, Cr
Thallium, Tl
Arsenic, As
Nickel, Ni
Cadmium, Cd
Copper, Cu
Lead, Pb
Zinc, Zn
Antimony, Sb
Silver, Ag
CHLORINE - MERCURY (TILL
PLANT *
#299 #167 #106
0.0002 0.013 0.006
0.000004 0.0004 0.00001
0.0001 0.0006
0.001 0.000002
0.0001 0.0002
0.0000008 0.00004
0.0005 0.0001 0.0001
0.0002 0.0005
0.0003 0.0006 0.001
0.0006
0.00001 0.0008

#747
0.0044
0.00004

0.000001
0.00003
0.00001
0.0002
0.0001
0.0005
0.00001
0.00002

#317
0.063
0.000048
0.00014
0.0003
0.0007
0.0002
0.0006
0.0007
0.010

0.00005

#299
.
0.008
0.00009
0.00029
0.0003

0.000004
0.00047
0.000089
0.0015
0.00074

*Does not include brine muds except for Plant #317.
                                  105

-------
caustic  potash  (KOH)  instead  of  caustic soda (NaOH) .

     Mercury  cell  process  -  In  the case  of mercury cells, the 26
percent  brine  is   reduced to  only 22 percent NaCl for each pass
through  the mercury cells.  The  spent brine is acidified with HC1
to  ph3  and then blown  with  air  or steam for dechlorination.  The
residual traces of  chlorine  and chlorate ions are  decomposed by
treatment with  sodium  bisulfite,  and the brine is saturated  by
the addition  of salt for  re-use.

     As  in the  diaphragm  cell  process, the  brine is purified by
the addition  of caustic soda  and sodium hydroxide to  eliminate or
reduce  the   calcium,  magnesium   and  iron  impurities.    The
precipitated  waste is known   as  the brine mud  and is  similar to
the one  produced  from the  diaphragm cell except that   it contains
small amounts of  ionic   and  metallic mercury from  the  re-cycled
brine.    The  precipitate    is   removed   by   filtration   or
clarification.    The  final   pH  of the purified  saturated  brine
solution is   adjusted to  3 to 4  by  the addition of  HCl.  It  is
then fed to  the mercury cells.

     The mercury  cell,  in  general, consists of two sections;  the
electrolyzer  and  the decomposer  or denuder.  The electrolyzer  is
an  elongated  steel trough   that  is  inclined slighty  from the
horizontal and  the mercury flows in  a thin layer at  the  bottom.
This  forms   the   cathode   of  the  cell,  and  the  brine  flows
concurrently  on top  of  the mercury.  Parallel graphite or metal
anode plates  are   suspended  from the cover of the cell.  Electric
current  flowing through the  cell decomposes the brine, liberating
chlorine at  the  anode   and   sodium  metal at the  cathode.   The
metallic sodium forms an  amalgam with mercury.


     2 NaCl(aq) +  Hg =  C12(aq)  + 2 Na(Hg)    (2)


     The amalgam  from the  electrolyzer flows to the denuder.  The
spent brine  is   recycled  to   the brine  purification  process.  In
the  denuder, the  amalgam  becomes an  anode to  a short-circuited
iron  or  graphite  cathode.   Deionized  water  is added  to  the
denuder   which  reacts with  the  amalgam  to  form  hydrogen  and
caustic.  In  modern mercury  cells, the denuder or decomposer is a
horizontal  or  vertical  laid graphite-packed bed.  The water and
the  amalgam  flow  countercurrently.   The mercury is returned to
the electrolyzer.   The  caustic  formed has  a concentration of  50
percent  NaOH.  Some of  the impurities  present in the caustic are
removed  or reduced by the  addition of certain chemicals, and  the
caustic  is then filtered.    It   is,  in  most  cases, sent to the
storage  tank  or  is evaporated  if  73 percent NaOH  is the  final
required   concentration.     The  hydrogen  gas   is    cooled  by
refrigeration to  remove  water  vapor and mercury.  The processing
of chlorine gas is similar  to   the  one  practiced for diaphragm

                               106

-------
cell.   Figure  11-1   is  a  flow  diagram   of   chlorine/caustic
production using mercury cells.


Water Use and Waste Source Inventories

     Water usage -  The  water  uses   common   to  both mercury  and
diaphragm cells include  noncontact   cooling,  cell washings, tail
gas   scrubbing,  equipment   maintenance    and    area  washdown.
Noncontact  cooling   water   is  used  in  cooling   brine,  caustic,
chlorine, rectifiers and compressors.  Large amounts of water are
also introduced into the process  through the salt solution.

     One water application unique to  the mercury cell  process is
in the decomposition of mercury-sodium amalgam to form caustic in
the denuder.  In mercury cell plants, the  quantity of water  usage
was found to range from 7.6 to  204 cubic meters  per metric ton of
chlorine   produced  with        noncontact   cooling   comprising
approximately 70 percent of the  total.

     Waste sources - Some of  the  waste   sources   produced  during
the manufacture  of chlorine  and  caustic by  diaphragm and mercury
cells are similar with  the notable   exception of the presence of
mercury  in the  waste  waters   from  mercury  cells and  asbestos
fibers  in  the  waste  waters  from   the  diaphragm  cell plants.
Following  is  a  brief  description  of  the  common waste  water
stream,  followed by the  individual  streams specific to  mercury
and diaphragm cells.


     A.  Common Wastes (Mercury  Cell  and Diaphragm Cell)

     Br ine mud   -  This  is  the  waste  produced  during   the
purification of brine using soda  ash  and small amounts of caustic
soda before it is introduced  into the cell for electrolysis.  The
metals  commonly  removed  during  purification   are   magnesium,
calcium,  iron  and   other   trace   metals   such  as   titanium,
molybdenum, chromium, vanadium  and  tungsten.   Calcium  and   iron
are  removed  as carbonates and  magnesium  and   small  amounts  of
trace rnetals are removed as   hydroxides.  Brine  mud is the  major
portion  of  the waste  solids   produced from   the  process.  The
solids content  of the  stream  varies from 2  to  20 percent  and
amount in volume to  0.04 to  1.5  cubic meters  per ton of chlorine
produced.  The waste is either   sent  to a pond  or filtered.  The
overflow  from the pond,  or  the filtrate,   is   recycled  to the
process  as  makeup  water for  the  brine.   In  the  mercury cell
process, only  16 percent of  the  NaCl  solution is decomposed in
the   cell  and   the  unconverted  brine   is   recycled  to   the
purification  unit after  dechlorination.  This  recycled brine is
contaminated with mercury arid,  therefore,  the  resulting brine mud
contains small amounts of mercury.

                                107

-------
O
00
BRINE -**
I
CC
C
CHLORINE 1 f
PURIFICATION
SYSTEM
1
BRINE
MUDS
I
TO WASTE
1ONCONTACT
(CONTACT* )
K3LING WATER
JL
c
o
L
E
R
* .
:ONDENSATE
TO W
PURIFIED MFRPIIHY 	 ^ -»_
"BRINE •*" MtKCUKY _ AMALGAM 	 ^> DECOMPOSER *~ DEMINERALIZED
CELL WATER COOLER
fA A MUBfMinv 1 1 ~^~ *AND TO ATMOSPHERE
1 SO* SODIUM NUw«-vini««-i o^nuuuun, QJJ USE
SSUr?^ ,,Tm™ HYDROXIDE SOLUTION COOLING _^
COOLING WATER _L WRTPH ^^ ••- —

— ' T 1
^ "' COOLER CONDENSATE
tl ^^ TO WASTE
(SCRUBBING WASTE*) "~
	 1 COOLING
WATER — ». FILTER -5°* SODIUM 	 PACKAGING 	 ^- TOWER
^ HYDROXIDE . ... | TO SALES
BACKWASH SOLUTION TO
* ATMOSPHERE
BACKWASH RECYCLE _ BACKWASH 4 i
^ ^" FILTER CAUSTIC (LIME) | f
SOLIDS TQ INERTS
[~ LANDFILL
r~ ~i — —
L _,.__ rJ R
SULFURIC RECYCLED ^ 	 	 1 ' 	 SOLIDS - -^.TO WASTE g

D R SOLUTION
y LIQUID .^TO SALES TO USE' SALES«
n i , , PRODUCT

' REFRIGERATION
EAK SULFURIC SYSTEM
ACID '"" i " 	 " - -• 1 ' •
f NONCONTACT
RSTE COOLING
WATER
                      USED AT  SOME PLANTS ONLY
                                                   Figure  11 -1.  General  process diagram for production of chlorine/caustic by mercury cells.

-------
     Cell Room  wastes -  Tnis  is  another  common  waste  stream
produced from both diaphragm and  mercury  cell  but the volume  and
characteristics are different in each case.   The  major components
of this stream include leaks, spills, and  cell  wash  waters.   The
amount  varies  from  plant  to  plant  and   depends  laryely  on
housekeeping practices.  The amount of cell  room  waste  generated
per  metric ton  of  chlorine,  as  a general  rule, is higher  for
diaphragm cell plants, and the waste  water   from the washing  and
rebuilding  of the cathode contains  asbestos   fibers,  dissolved
chlorine,  and brine solution.  Every diaphragm cell is washed at
regular intervals  with the washing period varying  from plant to
plant.  In mercury cell  plants,  the  cell  room   wastes  contain
mercury, dissolved hydrogen,  chlorine, and  some  sodium chloride.

     Cell  room  waste constitutes one of  the  major streams that
has to be treated  for mercury.   If graphite   anodes are used in
either the  mercury  or  diaphragm cells,  the  cell room  wastes
contain lead and chlorinated organic compounds  in addition to  the
pollutants  already  mentioned.   The  majority  of  plants have
converted the cells from graphite anodes to  metal anodes and   few
plants are still operating with graphite anodes.

     Chlorine Condensate  - Condensation from   the  cell  gas  is
contaminated with chlorine.   At some plants,  the condensates are
recycled  to  the process  after chlorine  recovery.  Both contact
and noncontact water is used for chlorine  cooling and for removal
of water vapor and so the amount of waste  water varies from plant
to   plant.    When   graphite  anodes   are  used,   chlorinated
hydrocarbons,  lead,  and   other  impurities   carried  with   the
chlorine  condenses in the  first-stage cooler.  The  chlorinated
organic  compounds chat have  been detected  when  graphite  anodes
are used are:  chloroform, methylene chloride,  hexachlorobenzene,
hexachloroethane and hexachlorobutadiene  (3) .

     Spent Sulfur ic Ac id - Concentrated  sulfuric acid is used to
remove the residual water from the C12 gas after  the  first stage
of  cooling.   In  most  cases,  sulfuric  acid  is used  until a
constant  concentration of  50-70 percent  is  reached.  The spent
acid  might  contain  mercury, asbestos  fibers,   or  chlorinated
hydrocarbons  (depending  on  the  type of   cell)   in addition to
chlorine.  The volume of waste acid is typically  of  the order of
0.01 cubic meters per metric ton of chlorine.

     Tail Gas Scrubber  Liquid -The uncondensed chlorine gas from
the  liquefaction stage, containing some air and  other gases,  is
scrubbed  with  sodium/calcium  hydroxide  to form  sodium/calcium
hypochlorite.  When the equipment  is purged for  maintenance,  the
"sniff"  gas,  or tail  gas,  is absorbed  in  calcium  or  sodium
tiydroxide, producing the corresponding hypochlor i tes.  The amount
of tail gas scrubber water  varies from 0.04 to 0.58 cubic meters
per metric ton of chloride for  botn diaphragm and  mercury cell
plants, as shown in Table 11-5.

                               109

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TABLE  11-5.   TAIL GAS SCRUBBER FLOW DATA FOR CHLORINE/CAUSTIC SUBCATEGORY
«-
#858
#967
#967
#317
#299
#674
Type of Cell Used
Diaphragm
Diaphragm
Diaphragm
Mercury
Mercury
Mercury
Tail Gas Scrubber Flow
m /kkg of Cl-
0.16
0.28
0.104
0.045
0.108
0.578
                                    110

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     Caustic Filter Washdown  - The   50  percent caustic  produced
from both mercury and diapnragm  cells  is  treated  with chemicals
and filtered to remove  salt and other   impurities.  The  filters
are back-washed periodically as needed,  the  waste water volume  is
variable,  and  usually  contains  small  amounts  of  mercury  or
asbestos fibers in addition to the salt.
     B.  Process Specific Wastes

     Condenser Drainage - In mercury  cells,  the hydrogen produced
is cooledin surface condensers to  remove  mercury  and water that
is carried over with the gas.  The  waste water is  either sent  to
the  waste  water  treatment   facility  or  sent  to  the mercury
recovery facility.   After mercury  recovery,   the water  may  be
discharged to the treatment  facility or returned  to the denuder
after  deionization.   Information  on  the volume  of this  waste
stream is not available.
Control and Treatment Practices

     Mercury Cell Plants Visited and  Sampled

     Plant #299  was  visited  in the   screening  and verification
phase of  the program.   The   mercury-contaminated waste  streams
include  outlet  end-box  wash water,   spills and cleanup  water,
brine  mud saturator sludge,   and   pump seals  waste  water.   The
combined  waste  water  is  sent   to   settling  ponds  where   the
suspended solids  are separated.   The  effluent  from the ponds is
treated  with sodium sulfide and   the   phi  adjusted.  The reactor
solution is filtered in a filter   press and the  filtrate  passed
through activated carbon before discharge.   Figure 11-2 gives the
general process diagram  and   shows the  streams sampled.   Table
11-6  gives  the  unit  flow   data and the  important  pollutant
emissions.

     Three more   plants  (#747,   #167,   and   #317)  producing
chlorine/caustic  by  mercury  ceils  were visited and waste water
sampled in the verification program.

     At Plant  #747, the  brine  dechlorination  system has  been
converted from barometric condensers  to  a steam ejector  system.
The  conversion  resulted   in   increased  chlorine  recovery  and
reduced contact waste water.   oy providing settling and secondary
filter facilities, tne brine filter backwash has been eliminated.
The  tail gas scrubber liquid   is  offered  for sale  and  if  not
marketed, is decomposed.  The  mercury bearing waste  waters  are
collected  and  treated  with  Na2S.    The  reacted  solution  is
riltered  and  the  filtered   solids   are  retorted  for  mercury
recovery.  The filtrate is mixed   with  the  other  process waste
waters and  the pd adjusted before discharge. The flow diagram of

                               111

-------
WELL WATER

<*4) $f #4 <»!> ^
BRINE MUD
SALT ^ BRINE ^ RRTME BRINE ^ CCLL
""" SATURATION PURIFICATION *"~
t t
Naai Na2C03
NfiflH TY> ^^
STORAGE
^ 13
/

v^/^
*1

HOUSE
H20
H2

i^\ te. -nrrrnrn 2 te. DEMINERALJZER
^*^ IMAKE-UP HZO
I
H2° °£^ H20 TO PROCESS
BACKmSH FROM PROCESS
1 > 1 SLOWDOWN 1


[•E
^—


REGENERATION
I




	 " y«2, MKtA'i'bU W/to'lli
Hfj PDND (jf) ^*
TREAIMEOT ^^^ TO A1MDSPIIERE
* ?
1 	 	 1 (II 3)
TAIL GAS (ffi\ ^ WASTE TO
SCRUBBER N^S^ RJVKK
»5
t
C12 _ C12COMP.
AND *"
LIQUEFACTION STORAGE
H2 PURIFICATION H
1
UTILITy
BLOWDOWN
1
SURGE TANK H_O TO RIVER • !»•

                          e
Waste streams sampled.
Numbers in ( )  were sampled in
screening, others during verification.

        Figure  11-2.  General process flow diagram at Plant 0299 showing the sampling points.

                                  Chlorine/Caustic (Mercury Cell)  Manufacture

-------
TABLE  11-6. FLOW AND POLLUTANT CONCENTPATION DATA OF  THE SAMPLED WASTE STREAMS
            FOR PLANT#299 PRODUCING CHLORINE BY MERCURY CELLS
________________________^_^^____ 	 . _ . 	 ___
Stream
No.
1
2
3
4
Stream
Description
Cell Waste
Mercury Treatment
Effluent
Tail Gas Scrubber
Brine Mud
Unit Flow
m3/kkg
of C12
1.416
1.475
0.128
NA
TSS
kg/kkg
of C12
0.016
0.007
NA
NA
Mercury
kg/kkg
of C12
0.0002
0.00004
NA
NA
Lead
kg/kkg
of ci
0.000001
0.000006
<0. 000006
NA
Verification Phase
   3

   4

   5
Inlet to Mercury
Treatment

Mercury Treatment
Effluent

Cell Waste

Brine Mud

Tail Gas Scrubber
                                1.475
                                1.475
0.276
0.026
0.173
 *
1.416

  NA     12874

0.128        0.022
0.00831   <0.00008


0.0003    <0.00007


0.0145     0.0002

0.545*     0.663*

0.00002    0.00001
NA   =  Not Available
 mg/1
                                    113

-------
the  manufacturing   process,   including  the waste water  treatment
facility,  is  given in  figure 11-3.   Table 11-7  gives  the  flow
data for  the  sampled  streams.

     At Plant #167,  the waste water  streams, consisting of filter
backwash,  cell   rooia  wash,   rain  water  runoff,  and  leaks  and
spills, are combined  and treated for mercury removal.  The  water
is  sent  to   a   holding  lagoon and   tne  overflow  is reduced by
reaction  with ferrous chloride, which  precipitates mercury.  The
reacted solution  is  sent  to a clarifier and the underflow  from
the   clarifier  is   disposed   of in a landfill.   The overflow  is
filtered  and  the  filtrate  is passed through activated carbon and
an  ion exchange  column prior,   to  discharge to a  lagoon.   Tne
effluent  from the  lagoon is  pti  adjusted and  discharged.   Figure
11-4 shows the  simplified  process  flow  diagram for Plant #167,
including  the sampling  locations.   Table 11-7 gives the flow data
and  pollutant emissions for  the sampled streams.

     At Plant  #317,  the brine purification  mud is  mixed  with
spent  sulfuric  acid   and   sodium   hypocnlorite  solution.  The
treatment  removes mercury  from the  mud  and transfers  it to the
solution.   The  solution  is  filtered and  the  solids landfilled.
The   filtrate  is   mixed  with   other mercury-contaminated  waste
waters,   which  includes  tne brine purge, cell room liquid wastes
and   plant area  wash   water.   This is  then reacted with sodium
hydrosulfide  to precipitate tne mercury  as mercury  sulfide and
then filtered.    The  solids  are  sent to a  mercury recovery unit
and  the filtrate is  sent to  a holding tank.  The effluent  from
the   holding  tank   is mixed   with de-ionizer waste and noncontact
cooling water before  discharge.  The process flow diagram showing
the  waste  streams  sampled  art; given in Figure 11-5.  Table 11-7
is a summary  of flow data and pollutant emissions for the sampled
streams.

     Treatment  Practices-Mercury Cell  - Treatment  practices  at
other  mercury   cell  chlorine producing  plants not  visited  and
sampled are discussed in tiie next few pages.

     At Plant #261, the cell  waste   water  is filtered  and  the
rilter cake  and other  asbestos solids  are  disposed  of  at  an
off-site  landfill  after  being   placed in  plastic bags which, in
turn,  are packed  in   drums.   brine pur ificiation  muds at this
facility   are utilized  for  their alkalinity on-site and then they
are   settled  prior  to  discharge  of  the  supernatant.   Spent
sulfuric  acid  is  used  for  neutralization of  tne  waste  waters.
Uechlorination   of  the  drying  acid  by  reaction  with  sodium
bisulfite is  planned  in the  near future.

     At Plant  #589,  the  waste  water  going  to  tne  mercury
treatment  system   consists   of cell room washdown, brine  filter
backwash,  leaks,  spills,  cleanup  water,  and  hydrogen cooling
condensate.   The waste   waters  are reacted witn hydrochloric acid

                               114

-------
                                                                                                                                 ALKALI
RECIRC.

COOLER
fttfa 16
ci2

E»>«S3
DRYING
ci2




COMPRESSION
AND
LIQUEFACTION

SClflJbWER ^N^ ^
§7
	 1^- CHLORINE
PRODUCT
                                                                                           65% H2SO. WASTE
                                                                                               TO PONDS
                                                                                                                                                          •HYPoaiLORjTE
                                                                                                                                                            SOLUTION
                                                                                                                   NaOH
                      Waste streams sanpled.
                                                                                                                               DISCHARGE
                                                            SOLIDS TO
                                                            LANDFILL
                                                                        MERCURY TO PROCESS
                     Figure 11-3.   General process flow diagram  at Plant 1747 showing the sampling points.
                                               Chlorine/Caustic  (Mercury Cell) Manufacture

-------
TABLE  11-7.  FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE STREAMS
            FOR PLANTS #747, #167 AND #317 PRODUCING CHLORINE BY MERCURY CELLS
Plant
#747

#167







#317












Sampled
Stream
No.
1
2
3
4
5
6
7
5

6
7

8

9
1
2

3
4

5

6

7

8
Stream
Description
Cell Waste
Treated Waste
Input C12
Drying Tower
Output C12
Drying Tower
Dechloro
System
C12 Condensate
Tail Gas-Hypo
All Chlorine
Wastes
Cell Wash
Brine Process
Water
Treated
Chlorine Waste
Brine Mud
Cell Waste
Brine Mud
Filtrate
Tank Car Wash
Collection
Tank (H2+3)
Treated
Effluent
Deionizer
Effluent
Flow
nrVkkg
of C12
0.23
0.23
0.15
0.24
0.43
0.0067
0.022
3.35

0.0093
1.78

5.58

0.67
0.29
0.54

0.11
0.41

0.41

0.29

N-C Cooling 135
Water
Final Effluent

136
Pb
Load
kg/kkg
of C12
7.3 x 10~5
1.7 x 10~5
4.1 x 10~4
1.4 x 10~5
4.3 x 10~6
8.7 x 10~7
3.1 x 10"5
2.4 x 10~4

2.6 x 10~6
1.8 x 10"5

6.5 x 10~4

6.96x 10~3
3.98x 10~3
6.3 x 10~5

1.1 x 10~5
2.8 x 10~2

6.8 x 10~5

3.8 x 10~6

1.4 x 10~3

3.2 x 10~3
SS
Load
kg/kkg
of C12
0.16
0.014
NA
NA
0.0037
2.7 x 10~5
NA
1.89

5.7 x 10~4
7.1 x 10~3

1.3 x 10~2

3.99
0.013
0.28

1.98x 10~3
8.67

4.4 x 10~2

5.2 x 10~3

2.16

2.45
Hg
Load
kg/kkg
of C12
4.3 x 10"3
2.3 x 10~5
3.5 x 10~6
7.2 x 10~7
1.5 x 10~5
1.8 x 10~6
8.0 x 10~7
1.3 x 10~2

6.7 x 10~6
9.0 x 10"6

1.8 x 10~3

8.7 x 10~5
1.4 x 10~5
1.9 x 10~2

3.6 x 10~6
5.6 x 10~4

4.3 x 10~5

2.9 x 10~7

1.4 x 10~4

3.6 x 10~4
 NA = Not Analyzed
                                    116

-------
                             SALT
I—
NONCONTACT ll-O
  TO WASTE          I1,O  NaOlI
                                                                                                                                                     Waste streams  sampled
                                                                                                        »7
                    TO pH ADJUST- •*
                    MENT AM) FINAL
                    DISCHARGE
LAGOON

<«&}
«8
ION
EXCHANGE



ACTIVATED
CARBON


•^ 	 • —
SAND FILTER

«*—
CLARIFIER
^
M i
1 Ut
                                                                                                                                       UNDERFLOW TO
                                                                                                                                         LANDFILL
                                                      Figure  11-4.   General process flow diagram at Plant #167 slrawing the sampling points.
                                                                                 Chlorine/Caustic (Mercury Cell) Manufacture

-------
                  SALT
I—
CO
                                   e
                                                                                                                                              OFF GAS
                                                                                                                                                 t
Haste streams sampled.
                                                                                                            DE-IONIZED    NOMXNTACT
                                                                                                           WATER WASTE      COOLING
                                                                                                                                tin
                                                                                                                                              TANK CAR WASH
                                                                                                                                              TO WASTE TREATMENT
                                                                                                                                               TO DISCHARGE
                                                                                                                                     «8
                                                    Figure  1 1-5.   General process flow diagram at Plant H317 showing the sampling points.

                                                                              Chlorine/Caustic (Mercury Cell)  Manufacture

-------
and  sodium  bisulfiue  and  then  sent  to   a  settling oasin where
mercury  sulfide precipitates.  The  overflow  is passed through a
series of effluent filters before discharge.

     At Plant  #343, the cell  room wash  water,  brine purification
sludge, and cnlorine cooling condensate  are combined and sent to
a  pond.  The suspended solids  settle  in  the pond and are dredged
out once a year.  The dredged  sludge is  "Chein Fixed" and disposed
of  iii an appropriate  landfill.   The  overflow from the pond is
reacted  with  Na2S  and  the   reacted  solution  is  sent  to  a
clarifier.  The clarifier underflow, consisting mainly of mercury
sulfide,  is returned  to  the  pond.  The  clarifier overflow is
d ischarged.

     All contact waste water at Plant  #907 is treated for mercury
removal in  a patented process  involving  reduction  of mercury to
the metallic state by use of sodium  borohydrate. All contaminated
wooden  rlooring in  the cell  room  has  been removed and replaced
with fiberglass gratings to  reduce  the  amount  of mercury  in the
effluent treatment system and  for better  waste  control. Molecular
sieves  have  been   installed   on cell   end  boxes to reduce the
mercury  content in  the air  vented from  tne cells.  The treatment
not only cleans the  air but  is  also  believed to reduce mercury in
the plant area runoff.

     In the  treatment  system,   the  mercury-contaminated  waste
water  is reacted with  sodium  borohydride  to   reduce  dissolved
mercury to  the metallic form.  The   reacted solution is filtered
prior to delivery to one  of   tne banks  of  three columns packed
with  antnracite  coal.  After  passing  through  tiiree absorption
columns in  series,  tne treated waste  water is  delivered to large
holding tanks,  from whicli   it  may  be discharged or  returned to
treatment,  depending  on  its  mercury   content.   Filter  cake,
resulting  from  the filtration of  the  waste prior  to the  coal
absorption step, is  retorted for  mercury  recovery.

     Waste solids at this  facility, including  mercury  treatment
sludges  and brine muds,  are  deposited   in  an  on-site disposal
area.  Chlorine  discharges  are  essentially eliminated by  three
significant  practices: the  chlorine  condensate is collected and
returned to  the brine  system, tail gas  scrubbing effluents are
used in the manufacture  of  another product,  and spent sulfuric
acid from chlorine drying is dechlorinated in an air stripper and
snipped  off-site  for the manufacture of another product.  Gases
from tne air stripper are  returned  to  the chlorine purification
header.

     At Plant  #324,  tne  barometric   condenser  on  the  brine
dechlorinator  was replaced  with  an  indirect cooler, resulting  in
a  reduction of chlorinated waste   water.    The   tail gas scrubber
effluent is used for the manufacture of  anotrier  product, and the
brine muds are sent  to a  pond.  Small amounts   of  mercury, when

                                119

-------
detected   in  the   brine  mud,  are ieacned  with water  and treated
with other mercury-contaminated  waste waters  which include  the
cell room  wash water, caustic filter  DacKwasn, and brine leaks.
The combined  waste water  is  sent  to  a sump and then mixed with
nyarogen processing waste water before introduction into a second
sump.  The waste  water   from   the second  sump  is  reacted  with
sulfuric   acid, sodium   boronydride,  and  sodium  sulfide.   The
reacted solution  is filtered. The filtrate is pH adjusted and the
caKe slurry  is  sent to a brine recovery sump.  The underflow from
ttie sump is   sent  to  a   pond  and the overflow recycled  to  the
process.

     The mercury-bearing waste waters are  combined and  sent  to
trie  treatment  facility.   The  streams  sent to  the  treatment
facility include  the caustic  filter backwash, cell outlet end-box
wasn  water,  spills  and  cleanup,  clarifier  sludge, saturation
sludge, and  pump  seals.   The  waste  waters  are sent  to  the
settling   pond  where  the  suspended  solids are  removed.   The
overflow   from  the  pond is   reacted with NariS, ptt adjusted, and
then  filtered.   The filtrate passes  through an activated carbon
column  before  discharge.   The depleted tail gas scrubber liquor
is discharged at  this  plant witnout treatment.

     At Plant #385, the  brine mud sludge is sent  to  a retention
pond  where  it  accumulates.  All process contact  waste water  is
collected  in  an unlined  pond  wtiere it is  treated and the treated
effluent   is  used  as  the  scrubber  liquid  for tail gases.  The
spent  scrubber  solution is  sent  to an adjacent paper plant for
use.

     At Plant  #416, the ceil room  wastes are  used  for  bleach
manufacture.   The waste  wacer streams  from  the chlorine/caustic
plant are  sent  to an adjacent paper company.

     At Plant  #784,  the  waste  water, consisting of  KC1 brine
filter backwash and area wasndown and spills, is sent to a basin.
The basin   equalizes the now  and the overflow is  treated  with
sulfuric acid  prior to  reaction witn NahS and clarification. The
clarifier   overflow passes through an activated carbon filter and
co a final tan*, where  it is given pH adjustment before discharge.

     The wastes are segregated  at Plant #674.   A  clarification
pond is used for waste  streams containing suspended solids.  The
streams going  to  tiie pond include  brine purification muds  and
spent chlorinated lime.   The  mercury-contaminated  waste  waters,
which include tiie brine  saturation waste, brine filter  backwash,
cell room   sumps, and  tank car  wasiies, are combined and  treated
for mercury   separately.  The  combined mercury-laden waste water
is sent to a  collection  pond  and the overflow from the pond is pH
adjusted before tiie  addition of  Na2S.  The reacted  solution is
sent to a   another pond  and the pond overflow is passed through  a
carbon absorption column before final  discharge.  A  part of the

                               120

-------
treated effluent is re-injected  into  the  brine well.

     At Plant 4012, the brine treatment  area is paved to trap all
spills,  leaks, and rain  runoff   from that a'rea.    The recovered
waste is recycled to the weak brine   reservoir.  The contaminated
waste waters from the plant are   re-injected into  the brine wells
to  keep the hydraulic balance and maintain pressure  in the salt
deposits.

     At Plant #106,  the  tail   gases are  scrubbed  with  sodium
hydroxide and the sodium hypochlorite solution  formed is sold to
an  adjacent  pulp  and  paper   plant.    When  not marketed,  the
hypochlorite solution is thermally  decomposed  by  discontinuing
the flow  of  cooling  water to   the  tail gas absorption  system.
Without  cooling,  the unit attains the   temperature required for
decomposition.  The brine mud is   sent to  a hypalon-lined lagoon
for  sedimentation  and  tiie  overflow   is  returned  to process.
molecular  sieves are  used to remove mercury from  the  hydrogen
gas.

     Mercury-bearing wastes  are   segregated  from  other  waste
waters   and  combined  for  treatment.    Mercury-bearing  leaks,
spills, and precipitation  are contained  and collected by curbing
around  the  cell room and are pumped to  treatment  from a common
sump.  In the treatment  system,  the  ph  is     initially adjusted
using  waste  sulfuric  acid and   20  percent caustic solution  as
required.  Sodium sulfide and filter  aid   are added and the waste
agitated in fiberglass reaction  tanks.    The  effluent  from  the
tanks is filtered and  the filter  caKe  is retorted  for  mercury
recovery. The  residual waste, after  mercury recovery, is  placed
in a lined solid waste disposal  area.  The  filtrate  is  sent to
the first  of  the  two lined lagoons.    Primary ph adjustment is
made  using waste sulfuric  acid  and  20   percent  caustic  before
entry into tiie first lagoon; final pa adjustment is made  between
the first and tne second lagoons.

     Ta il gas emission control -  when chlorine gas produced  from
the cell is  compressed and cooled,   chlorine separates as liquid
chlorine and  noncondensable  gases,  known  as tail  or sniff gas
containing chlorine vapor,  are  produced  at the discharge  end of
the condenser.  The  tail gas is  scrubbed  to remove the chlorine
and  the  amount  escaping in the  atmosphere  with  the  tail gas
depends  on  the operating  conditions   and the  removal/recovery
method  employed.   Emissions    vary,    depending   on  the  plant
capacity, presence of inerts in  the gas  and also on the injection
of air  into  the  chlorine  condenser   to prevent  an  explosive
mixture in the vent gas.  The  amount of chlorine  present in the
tail gas is  significant and the chlorine has to be  removed  and
treated  or recovered before venting   into the  atrnospnere.   The
common industrial  practice is to  scrub  with caustic soda or 1 irae
solution  thus  producing  the corresponding  hypochlorite.   The
nypochlorite is either soid, used  on-site,  sent  to  the  waste

                               121

-------
water    treatment    plant,    or   discharged  without   treatment.
Treatment  of   tiiis   waste    is   a   relatively  recent  practice.
Decomposition  is a common method   of  treatment  using catalytic,
thermal, and chemical  methods.

     Catalytic  decomposition  involves  the  addition  of  small
quantities  of  cooalt,  nickel,  and  iron chloride to  the  waste
streams, followed  by   retention  in reaction tanks for periods up
to several days.   Of the  two  plants employing this  technology,
one reports  zero  discharge of   chlorine, and the  other  reports
average and maximum  chlorine discharge rates of 0.015 and 0.14 kg
per metric ton  of  chlorine  produced.

     Thermal decomposition   takes place when the  temperature  of
the solution containing  hypochlorite reaches 175 degrees F.   When
lime is reacted with   chlorine,   it  results  in  an  exothermic
reaction  producing    heat   and   calcium  hypochlorite.   If  the
hypochlorite   solution  is   not   cooled,  it  results  in thermal
decomposition.  One chlorine/caustic plant is using this treatment
method  arid  another is   planning to  use it.   The  plant  using
thermal decomposition  reports complete conversion of hypochlorite
to chloride.

     Chemical  decomposition   takes   place   by   reacting   the
hypochlorite solution  with   a chemical reactant which  is usually
sodium  sulfite or hydrogen peroxide.  Chemical decomposition  is
expensive  but  complete and  rapid.

     When  chlorine is  present in  a dissolved  form in  water,  a
stripping  technique  is applied  to recover the chlorine.  Chlorine
condensate   streams   and  spent   chlorine-drying  acid  are   most
commonly treated  by  steam  or vacuum stripping, with  the chlorine
frequently returned  to the   process for purification and recovery
as a product.   The tail  gas is   not generally scrubbed with  water
because water  does not  effectively  remove  chlorine  and  the
chlorine  concentration  in  the exhaust  will reach 0.1  to  4.5
percent by  volume  after   scrubbing with  water.   One effective
method of  chlorine recovery  from the tail gas is by the  passage
of  the gas    through  an   absorbing  material  such  as  carbon
tetrachloride   and  subsequent  recovery  of  the  chlorine.    The
process is proprietary and  little information is available on its
design or  operation.


Evaluation of  Industry Production and Waste Flow Data

     Chlorine/caustic  manufacture   with   either   mercury   or
diaphragm  cells  yields  a  number  of  distinct  effluent streams
wnich   differ    appreciably  in   their   volume  and   chemical
composition.   Segregation   of tnese waste  streams is  a  primary
control practice  in  the industry, and allows effective  treatment
at acceptable  cost levels.
                               122

-------
     In the  plants  producing  chlorine   via   mercury cells,  the
contact  waste waters are segregated  into  three different streams
ror   effective  treatment.   One   is   the  brine  mud,  contains
appreciable amounts of suspended solids. The solids are the metal
precipitates and other contaminants present  in brine and  removed
during  purification of brine.  It may  contain  small  amounts of
mercury.      The     second    segregated    stream    is    the
chlorine-contaminatea  waste water.   It   is  similar to  the  one
discussed under diapnragra cells.  The last   segregated stream is
the mercury contaminated waste wacer.   It  consists  of the brine
and caustic filter oackwasn, cell   room wastes,  hydrogen cooling
condensate,  etc.   Table  11-8  gives  the   unit  flows  of  the
segregated streams for plants whose data is  available.


Process Modifications and Technology Transfer  Options

     Anode Mater ial  - In the majority  of  cases,  in botli  mercury
and  diapnragm cells, tne  anodes have  been  changed from graphite
to  metal.  The use of metal anodes   increases  the  cell current
efficiency and eliminates or reduces considerably the chlorinated
organic compounds and lead in tiie waste waters.  The metal anodes
consist  of an  expanded  titanium metal   substrate  coated with
precious metal and rare earth oxides.

     Liquefaction of Calorine - Utilization  of refrigeration  and
high  pressure  for chlorine  recovery  will reduce the  chlorine
content in the  tail gases.   This  technology   is presently being
practiced at a number of production facilities.
Best management Practices

     Area runoff - Storm runoff  from  the  plant area for  chlorine
plants using mercury cells can be  collected  and sent to the waste
water treatment plant.

     Mercury emissions - Hydrogen  gas produced from the  cell  can
be passed through molecular  sieves to remove the mercury escaping
with the gas.  This will reduce  the mercury  emissions and  reduce
atmospheric fallout in  the  neighborhood of the  plant.  This in
turn will reduce  mercury  concentrations  in storm  runoff.  Two
plants are practicing this control treatment.

     Leaks and spills -   The brine treatment area  and the cell
room  areas,  especially in  the mercury   cell plants,  should be
paved with fiberglass  gratings, and  provision should  be made to
collect the leaks and spills from  the operation.

     Mercury contaminated solids - The precipitated mercury waste
should  be  stored in a lined pond or disposed of  in  a  secured
landfill.  in tne  mercury   ceil  plant,  tiie brine mud should  be

                                123

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TABLE 11-.8.   WASTE FLOW DATA FOR CHLORINE/CAUSTIC SUBCATEGORY USING
              MERCURY CELLS



Stream Description        Plant         Unit Flow  m /kkg of chlorine
Brine mud                   # 589                    0.651

                           # 674                    0.874

Tail gas scrubber           #317                    0.046
(hypochlorite solution)
                           # 299                    0.109

                           # 385                    3.39

                           # 674                    0.58

                           # 167                    2.25

Mercury contaminated        # 343                    1.57
waste waters
                           # 907                    0.357

                           # 317                    0.529
                                   124

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placed in lined pond  or disposed  of  in   a  secure  landfill  after
filtration.   The  brine  mud contains  small  amounts  of mercury
which  can  leach  into  the  ground   water    if   proper  safety
precautions are not taken.

     Tail gas emissions - The tail gases,  after  the  liquefaction
or recovery of chlorine, should be scrubbed  with lime or   caustic
soda  to  remove  residual  chlorine   from  the vented   gases.
Scrubbing with water  is not efficient as  shown  by  the  following
data:
                                                Emissions Factor,
       Type of      Chlorine Concentration      kg  chlorine/kkg
       Control      In hxhausc, vol.  'a          Chlorine  Liquefied
       None20 to 50                    10  to  80
  water Absorber    0.1 to 4.5                  0.125  to  5.45
  Caustic or Lime   0.0001                      0.000125
  Scrubber

     Transportation, handling   and   abnormal   operations
Prpvisions should be" made to remove chlorine   from air  emissions
resulting from abnormal operating conditions  such  as  start up and
shut  down,  or  from  vents  on  returned  tank   cars,   and  ton
containers, cylinders, storage tanKs,  and  process transfer tanks
during handling and loading of liquid chlorine.


Model Plant and BPT Treatment System  Specifications

     Mercury Cell Plants  - The recommended BPT treatment for the
waste waters from chlorine  plants  using   mercury cells consists
of:

     A.  filtration of the process waste  flow to remove
precipitated heavy metals.

     b.  Lagoon settling of brine mud and long  term storage
at site.

     C.  Partial recycle of the brine waste stream to process.

     D.  Precipitation of mercury as  mercury  sulfide  from
the mercury-contaminated waste water  streams  for
recovery or disposal.

     Approximately 50 percent of  the production data for all the
chlorine/caustic plants using mercury cells is  available on  file.
Production  ranges  from 19,000 to 1^8,000  kkg  of  chlorine  year.
Three  model  plants with  productions   of   25,300,  126,000  and
253,000  kxg/yr  were  selected   to  represent  the   subcategory
production range.  The flow per unit  of  production is assumed  to

                                125

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be the  same  for  each  size  of  model plant.

     A.   ^vaste water  flow:   tor model plants,  the  contact waste
waters   from  the  mercury  cell  process are  segregated into  two
streams.   The  brine mud  produced during the purification of brine
is segregated  to remove   the  suspended solids present in it.  The
clear liquid,  after  settling, is recycled to the process.  A unit
flow of 0.42 m3/kkg  of  cnlorine was  taken for the model  plant,
with a   suspended   solids   content  of  10  percent.   Trie  other
segregated waste water  is process  waste  effluent  contaminated
with raercury.  It  includes the orine and caustic filter backwash,
cell room waste  water, hydrogen cooling condensate and decomposed
scrubber  waste  water.  A  unit tlow of 1.2 ia3/kkg of cnlorine was
taken for the  second  segregated stream.

     B.  Chemicals used:  Sodium bisulfide was used  in an amount
equivalent to  0.025  kg/kkg  chlorine to  precipitate mercury  and
other metals.

     C.  Solid waste   produced:  The  brine  rnud  constitutes the
major source of  solid waste produced  from  the process/treatment
facility.   Mercury  sulfide  and  small  amounts of  other  metal
sulfide constitute the  residual solid waste.  The total quantity
is 41.7 kg/kkg of  chlorine produced.

     General assumptions  on  chlor ine  bear ing  wastes  - In the
selection of model  plants, the  following assumptions have  been
made for the chlorine  contaminated  waste  streams. The chlorine
condensate  waste   stream   has not  been  included  in  the waste
streams going  to the  treatment facility.  In  the majority of the
chlorine/caustic plants, this streaw  is  stripped of chlorine by
steam  or vacuum and  the chlorine is recycled to the purification
operation.  The  waste  water is  then returned to the process and
introduced  to  the   brine  purification  unit  or  sent  to  the
treatment unit.    The quantity  of waste water  generated by this
operation is small.  In soiae cases the chlorine gas from the cells
is contact cooled  with water and the scrubbed liquid, after steam
stripping, is  reused.  The stripping operation in the recovery of
chlorine is part of  the process  and, therefore, its cost is  not
included in the   treatment  cost.   In  tiie case of plants  using
grapnite anodes, the   chlorine  condensate  contains  chlorinated
organic compounds  and some  lead in tiie waste waters.  This waste
is sealed  in  drums   and  disposed of in  a secure  landfill.  At
present,  very few  plants  are  using  graphite anodes and  land
disposal is a  good disposal method.

     The spent  tail   gas   scrubber  solution,  which  is  mainly
calcium/sodiurn hypocnlorite,  is assumed to  be decomposed  before
it is  discharged.  Tnermal decomposition can  be practical at no
additional cost, while anotiier efficient method of  decouiposition
is catalytic decomposition.  (its costs are given separately under
Estimaced Control   and Treatment Costs for tiiis industry and have

                               126

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not been  included  in the model  plant costs.)   The  reason  for
excluding this cost is that in many plants  the  hypochlorite waste
stream is  either sold or used cm-site.    If  neither of these  two
alternatives is available, then it is decomposed  and discharged.

     The hypochlorite  stream is thus not  continuously treated at
all plants and the cnoice between nandling   it  as a  by-product or
a waste is largely dependent on the local  marKet  demand.


11.2  TECHNOLOGY BASED POLLUTION ABATEMENT


11.2.1  Advanced Level Treatment Applications


Priority Pollutants to be Controlled

     Existing chlorine  plants using mercury  cells   are   already
controlling mercury  in their waste waters  in response to  current
regulations wiiich  call  for  a  discharge   of  less than  0.00014
Kg/kkg of product as a 30-day average.   Potential candidates for
control  are  the  common heavy metals:  chromium,   nickel,  zinc,
copper,  and antimony, as  well  as thallium  and  arsenic,  most of
which respond to the sulfide process for mercury  precipitation.


Inventory of Priority Pollutants Present in  Process  Operations

     In addition to mercury, lead and asbestos, waste waters from
the  chlorine  industry   may  contain  chromium, copper,   zinc,
thallium,  nickel,   arsenic,   and  antimony,    some  of   which
undoubtedly  represent corrosion  products  from  reaction  between
chlorine  and  the  plant  materials  of construction.  With the
pnasing  out  of graphite anodes,  cnlorinated  organics are not
common  constituents of mercury cell plant  waste  waters, although
some may originate by the contact of chlorine with rubber  linings
and F.R.P. components.  Traces of certain  priority   organics were
found but none in significant concentrations.


Removal Mechanisms Available

     wost of  the  above listed  pollutants,  will be  essentially
removed by  sulfide precipitation and filtration. The exceptions
are cnromium  and  asoestos.   All  of  the  heavy metals   can  be
controlled by alkaline precipitation and filtration, witii  varying
degrees of specific metal removal at a given  ph.

                               127

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Selection of Appropriate  Technology

     mercury Cell  -   BPT  (Level   1)   -  Sulfide  precipitation
followed  by pressure  fiftration is  chosen as the best available
technology  for  separating mercury  and  other heavy metals  (except
chromium) .  Hexavalent cnromium  will be reduced to its less toxic
trivalent form, but  may  remain  in solution,  depending on  final
pH.

     Mercury Cell  -  Level  2  -  The filtered Level 1 effluent  is
passed   tnrough a  granular  activated  carbon bed, wnere  residual
metal sulfides  and  any metallic mercury will be  adsorbed.  This
treatment   was  cnosen  over ion exchange because at low  pollutant
levels  tne  carbon  bed  need not be  regenerated but can be replaced
with  new   carbon  at  approximately one-year intervals.  Although
ion exchange resins  could  be  similarly replaced,  they would not
adsorb    reduced   metallic    mercury.    There  is  insufficient
performance data  to  recommend   the xanthate process at this  time
as an alternative  to sulfide precipitation.
Flow Diagrams

     Treatment process components for the multiple waste  streams
of the mercury cell   process are shown in Figure  11-6   (Level 1)
and Figure 11-7 (Level 2).


Description of Each  Treatment Level

     Equipment functions  -   In   both  processes   the  metal-
contaminated wastes  are equalized in  a surge tank.  In  the Level
1 mercury process,   mercury sulfide precipitate is  removed in  a
conventional  plate   and  frame  filter  press.   At Level  2 the
mercury  process  metal-bearing  wastes  are   passed  through  a
conventional granular activated carbon filter  for  adsorption of
any residual mercury.

     Chemicals arid  handling - In tiie mercury cell process, sodium
bisulfide is used  for mercury sulfide precipitation at pH 5 to 7.
Care is needed to  prevent  escape of toxic and obnoxious  H2S fumes
at  ph levels  below  7.   At  Level  2 no additional chemicals are
used  since the  activated carbon bed is not regenerated but  is
periodically  removed and   replaced.   The  handling  of granular
carbon may cause temporary dust probleias but it causes no special
hazards.

     Separation and   removal  or  sol ids  -  In  all   processes
conventional settling and  filtration are used to separate solids.

     because hazardous asoestos, mercury, and toxic metals remain
in the  solids, all  sludge (except brine mud) snould be  disposed

                               128

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                                                                       LAGOON
                               BRJNE
                             MUD STREAM"
                                                                       LAGOON
    RECYCLE
-*.TO PROCESS
tsj
        MERCURY
     CONTAMINATED-
     WASTE STREAM
                                                SULFURIC ACID
                                                                                    FILTER
                                                                                     AID
                                                                    *	
                                                                                                                                 ADJUSTMENT
                                                                                            SODIUM  BISULFIDE

                                                                                             D
                                                                                                                                 FILTER

                                            HOLDING TANK           MIXING
                                                                                                   MIXING
                                                                                                                          SOLIDS          '
                                                                                                                      TO MERCURY       I
                                                                                                                        RECOVERY        i
                                                                                                                      OR LANDFILL       I
                                                                         EMERGENCY RETURN LINE
                                             -». EFFLUENT
                                  Includes pH monitoring, flow monitoring and sampler
                                              Figure 11- 6 • Vfeste watar treatment level 1 for chlorine - mercury cell subcategory.

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               BRINE
             MUD STREAM
CO
o
   MERCURY
  CONTAMINATED
  WASTE  WATER
                                               LAGOON
                                               LAGOON
    RECYCLE
_^. TO PROCESS
                        r
                                CZr
                                                                BACKWASH


                                                      FILTER AID
                            SULFURIC ACID
                                                            I  I SODIUM
                                                            L--' BISULFIDE
                        HOLDING TANK
                                               MIXING
                                                                MIXING
                                                                                    FILTER
                      pH ADJUSTMENT
                                                                               SOLIDS
                      I                                                    TO MERCURY      '
                      I                                                  RECOVERY QR       |
                      I	E_MERGE::CY RETURN Li:'E              LANDFILL          |
                       |
                      ACTIVATED
                        CAREOI!
1
                                                    -Q
                -*~ EFFLUENT
                           Includes pH monitoring, flow monitoring and sampler
                                           Figure 11-7 . Haste hater treatment Level 2 for chlorine - mercury cell subcategory

-------
of in a safe cnemical waste area.
     Monitoring requirements   -  Monitoring   of   heavy  metals
including mercury, is done by atomic  absorption  methods, usually
at  a  qualified commercial laboratory.   Simple  field  tests  for
heavy  metals as  a  group  are  available   for  routine  process
control .
11.2.2 Estimated Performance of BPT  Systems

     waste water control and treatment  practices at  chlor-alkali
plants involve waste segregation since  specific  pollutants  arise
in  separate  waste streams.  Examples   of   these  are pollutants
common to both  mercury cell  and  diaphragm  cell plants, mainly
suspended solids and chlorine.

     Chlorine, as  hypochlor i te , primarily arises  from  alkaline
scrubbing of  noncondensibles   following product  recovery.  The
resultant hypochlorite stream is often  used  in another process or
sold.   A few  plants  now remove  the   chlorine  by  thermal  or
catalytic decomposition or  by  stripping  before  discharge, but
many plants discharge  the  waste  without treatment.   Table  11-9
presents residual chlorine effluent  loadings at  plants which  use,
sell, or treat chlorine-bearing waste waters.

     Mercury Cell  Plants  -  Because   it  has  been  limited  in
discharge permits  for some time,  mercury  removal  technology is
employed at almost  all  mercury
mercury-contaminated  streams are
precipitated   as   the  sulfide
filtration.  Mercury recovery is
shown  iii Table  11-10, this  technology  is   highly
reducing mercury discharges.
                                  cell   plants.    Most  commonly,
                                    segregated  and  the mercury  is
                                    and   removed   by  settling  or
                                  practiced   at  some plants.   As
                                                      effective in
     BPT technology for  waste  water   treatment  and control  at
mercury  cell chlorine plants  has   been  specified  and  includes
containment of mercury-bearing waste  waters  followed  by sulfide
precipitation and filtration before  discharge.

     The pollutants previously regulated  at mercury cell chlorine
plants  are  suspended solids  and mercury.  Priority  pollutants
other than mercury that were found   at significant concentrations
in the  screening and  verification   programs were identified  as
arsenic, thallium, and zinc.

     Sultide precipitation   is  Known   to  be effective  for many
trace metals and a discussion  of  the  treatability of  priority
pollutant metals with sulfide  is  presented in Section  8.  During
screening and verification,  five  plants employing mercury removal
systems  were  sampled.   Table    11-11  presents   the  priority
pollutant loads found in the   treated  effluents at  four of these
                                131

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TABLE H-9.
RESIDUAL CHLORINE EFFLUENT LOADINGS AT SELECTED CHLOR-ALKALI
PLANTS*

Plant
#207
#014
# 819
# 747
# 106
# 589
# 747**
# 324* *
Average
0.33
0.04
ND
0.002
0.001
0.003
0.0025
3.72
Chlorine Waste Load kg/kkg
Range

1.4 maximum
0 to 1.29
0.016 to 0
0 to 0.006
0 to 0.14
0.001 to 0
ND
0.38 to 12

.14


.011

.2
  *See Reference 3
 * *From Plant Long Term Monitoring Data
                                    132

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TABLE  11- 10.     EFFLUENT LOADINGS FROM SELECTED 'CHLOR-ALKALI MEPCURY CELL
                 PLANTS*
	 — — — — — 	 • 	
Plant
#343
#907
#898
#195
#106
#747
#589
#299
#747**
#317**
#195'**
#324**
Average
0.000025
0.00002
0.00006
0.00004
0.000065
0.000055
0.000055
0.00004
0.000055
0.000006
0.000022
0.00086
Mercury Waste
Maximum Daily
0.00094
0.00026
0.0025
0.00073
0.00022
0.00008
0.00086
0.00019
0.000083
0.000048
0.00066
0.0022
Load kg/kkg
Maximum 30-day Average
0.00029
0.00003
0.00043
0.00015
0.000096
0.000067
0.00049
0.000056
0.000065
0.00001
0.0001
0.0018
 *See Reference 3
**From Plant Long Term Monitoring Data
                                  133

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TABLE 11-11.    EFFLUENT  PRIORITY POLLUTANT LOADS FOLLOWING MERCURY

                TREATMENTT   k.g/kkg*
POLLUTANT
Antimony, Sb
Arsenic, As
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Nickel, Ni
Silver, Ag
Thallium, Tl
Zinc, Zn
Flow (m /kkg)
#747
< 0.059
< 0.002
0.032
< 0.011
< 0.006
0.016
< 0.011
< 0.0035
< 0.01
< 0.006
0.23
PLANT
#106
1.6
< 0.015
< 0.039
< 0.028
0.15
1.052
0.40
0.72
0.71
< 0.23
2.8
#317
< 0.10
< 0.008
< 0.01
< 0.02
< 0.012
0.07
< 0.028
< 0.006
< 0.1
0.21
0.41
# 299
0.22
0.092
0.11
0.09
0.055
< 0.074
< 0.074
0.022
0.3
0.15
1.5
  tesults of verification sampling 3 days.
2
 Indicates effluent load higher than influent load.

* Note:  loads are  in g/kkg.
                                    134

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plants.
Base Level Performance Characteristics  for  BPT  Pollutant Removal
     Table 11-12  presents effluent
implementation  of  BPT  or Level 1
mercury cell chlorine plants.
                        quality  achievable   through
                        treatment   technologies  for
Base  Level
Removal
Performance  Characteristics  for  Priority  Pollutant
     Also presented
effluent qualities
Not  included  are
organics.  Although
anticipated   that
        in Table 11-12  is  the  estimated  achievable
       for priority pollutants with  BPT  technology.
       estimates  for  tne  removal   of  chlorinated
       only limited data are  available,   it   is not
        chlorinated   organics    will   be   reduced
significantly with BPT treatment,
Pretreatment Applications

     Several chlor-alkali plants  presently
of their process waste  water  to   POTWs.
chlorine  process  wastes  which   require
mercury, lead, and cnlorine.   In  addition,
suspended solids is required.
                               discharge  all  or part
                               Pollutants  present  in
                               pretreatment    include
                               some  control  of pH and
     On the basis
application of BPT
is also recommended
      of the effluent quality achievable  tnrough the
      technology, as presented  above,  BPT technology
       for pretreatment.
11.2.3 Estimated Performance  of  Advanced  Level Systems

Advanced  Level   Performance Estimates   for  BPT  and  Priority
Pollutant Removal

     The advanced treatment performance  estimates presented below
include  estimates   for  chlorine   discharges.    Although   this
parameter was not regulated   in  previous  guidelines,  and  most
chlorine plants  reuse or  sail their  chlorine-ladenxwaste  water,
the  technology for  chlorine removal has  recently been established
tor  tiiis  subcategory and  therefore   achievable  limitations are
recommended.  Table  11-13  presents estimated achievable effluent
quality through  implementation or  Level  2 advanced technologies.
                                135

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          TABLE  11-12  CONTROL  PARAMETER LIMITATIONS
             SUBCATEGORY:  Chlorine - Mercury Cell
                     Level  of Treatment: 1
                  Waste  Water Flow:  2 m3/kkg
Pollutant
Subcategory
Performance
  (mg/1)
      Quality Limit
  (1)      (mg/1)
VFR   	
      30 day  24 hr
       Aver    Max
                                                   Emission Limit
                                                       (kg/kkg)
                                                   30 day  24 hr
                                                    Av e r    Ma x
BPT Pollutants:

Total  Suspended
Solids,  TSS

Mercury,  Hg

Proposed  Priority
     12
 2.0    15
      30
      0.02
 2.0
0.05   0.10
0.03    0.06


0.0001  0.0002
Pollutants:

Arsenic, AS

Thallium, Tl

Zinc, Zn

(2)
0.04 2.0 0.05 0.10 0.0001 0.0002
(2)
0.3 4.0 0.2 0.8 0.0004 0.0016
(2)
0.5 4.0 0.2 0.8 0.0004 0.0016
  (1)  -  VFR:  ratio  of  the  24  hour variability factor to the
            30  day  variability factor.

  (2)  -  Verfication Sampling
                               136

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           TABLE 11-13  CONTROL PARAMETER  LIMITATIONS
              SUBCATEGORY: Chlorine - Mercury Cell
                      Level of Treatment:  2
                   Waste Water Flow:  2  m3/kkg

Poll utant

Tr eatabil ity
(mg/1)
(1)
T rrri n
Vr K
Quality Limit
(mg/1)
30 day 24 hr
Av e r Ma x
Emission Limit
(kg/kkg)
30 day 24 hr
Aver Max
BPT Pollutants:

Total Suspended
Solids, TSS

Mercury, Hg

Total Residual
Chlorine, C12
15
2.0
 0.02   2.0


 0.2    2.0
15
        0.2
30    0.03    0.06
        0.01    0.02  0.00002  0.00004
         0.4  0.0004  0.0008
Proposed Priority
Pollutants

Arsenic, As

Thallium, Tl

Zinc, Zn
 0.04   2.0

 0.3    4.0

 0.5    4.0
        0.05    0.10   0.0001  0.0002

        0.2     0.8    0.0004  0.0016

        0.2     0.8    0.0004  0.0016
   (1) - VFR: ratio of the  24 hour variability factor to the
            30 day variability  factor.
                                137

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New Source Applications

     Examination  of   the   waste  water   control  and  treatment
alternatives  applicable  to new chlor-alkali facilities has led to
the following  conclusions:

     All  new  sources  should  incorporate metal anodes rather than
grapnite  anodes.   All new sources should  provide for alternative
uses or  provide  for decomposition of chlorine-bearing wastes.

     mercury  cell  plants should provide treatment equivalent  to
BPT.
Response to  Remand  Issues

     Zero-discharge limitations    originally    proposed   for
Ciller-alkali plants  were remanded primarily because no plant was
snown  to  achieve   zero  discharge.   The  proposed  alternative
advanced treatment  levels provide for waste water discharge.
11.2.4  Cost Estimates
Discussion

     On the basis of the model plant specifications and treatment
system design concepts presented  earlier, the  estimated control
costs  for  three  production  rates at  both  mercury  cell  and
diapnragm cell plants  are given in Tables  11-14  through 11-16.
Tne  costs  shown  at eacn  level of  treatment correspond to the
raodel  plant BPT system (Level 1) and one or more alternative BAT
systems  (Level 2,   3, etc.)   which  may  add  to  or  modify the
existing BPT  system  to  meet more stringent  priority pollutant
removal requirements.  The  BAT  systems  also  provide  a higher
effluent water quality  with  respect  to  the  conventional  and
nonconveritional parameters.

     Annual treatment cost  as  a function of production  rate is
shown graphically in Figure  11-8.   Similarly  presented  is the
relationship  of  unit  cost (treatment  cost per metric  ton  of
product) to production rate Figure 11-y.  The estimated ranges of
total unit costs are shown ana Table 11-17 presents a summary  of
the unit cost distribution between amortizacion and operation and
maintenance components.


Summary

     Although chlorine manufacture  usually produces  three wasce
streams, only tiie brine mud aud  metal  or asbestos  contaminated

                               138

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                    TABLE 11-14 MODEL PLANT TREATMENT COSTS

   Subcategory  CHLORINE  Mercury cell               Type of  Regulation  BAT

   Production        19,100 metric tons per year  (  21,057 tons  per  year)
                         54 metric tons per day   (      60 tons  per  day )
   Waste water flow      91 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	               $49,100              $500
    Equipment in place,
    i ncl ud ing pi pi ng,
    fittings, electrical
    work and controls	                68,100            15,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	                25,240              3,100
    Incidentals, overhead,
    fees, contingencies...                25,240              3,100
    Land	                21,000

    TOTAL INVESTMENT COST               $197,680           $21,700

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.              $112,000           $14,000
    Energy	                 1,250
    Chemicals	                   500              1,400
    Maintenance	                17,668              2,170
    Taxes and insurance...                 5,930               651
    Residual waste
    disposal	                 4,400
    Monitoring, analysis
    and reporting	                15,000              7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $156,748           $25,721

C.  AMORTIZATION OF
    INVESTMENT COST                      $28,745            $3,530

    TOTAL ANNUAL COST                   $185,493           $29,251


    *First level represents the base cost of treatment  system.
    Other levels represent the incremental cost above base cost.

                                     139

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                   TABLE 11-15 MODEL PLANT TREATMENT COSTS

   Subcategory  CHLORINE  Mercury cell               Type of Regulation  BAT

   Production        95,500 metric tons per year ( 105,288 tons per year)
                       272 metric tons per day  (     300 tons per day )
   Waste water  flow    455 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT  COST

    Construction  	               $134,500            $1,000
    Equipment in  place,
    including piping,
    fittings, electrical
    work and controls	                141,300            61,000
    Monitoring  equipment
    in place	                  9,000
    Engineering design
    and inspection	                 56,960            12,400
    Incidentals,  overhead,
    fees, contingencies...                 56,960            12,400
    Land	                 63,000

    TOTAL INVESTMENT COST               $461,720           $86,800

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $112,000           $14,000
    Energy	                  3,700
    Chemicals	                  2,500             7,000
    Maintenance	                 39,872             8,680
    Taxes and  insurance...                 13,851             2,604
    Residual waste
    disposal	                 21,400
    Monitoring, analysis
    and reporting	                 15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                     $208,323           $39,784

C.  AMORTIZATION  OF
    INVESTMENT  COST                      $64,871           $14,122

    TOTAL ANNUAL  COST                    $273,194           $53,906


    *First level  represents  the base cost of treatment system.
    Other levels  represent  the incremental cost above base cost.

                                      140

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                    TABLE H-16 MODEL PLANT TREATMENT COSTS

   Subcategory  CHLORINE  Mercury cell               Type of Regulation  BAT

   Production       191,000 metric tons per year ( 210,577 tons per year)
                        545 metric tons per day  (     601 tons per day )
   Waste water flow     910 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	              $257,700            $2,000
    Equipment in place,
    including piping,
    fittings, electrical
    wrk and controls	               213,200           115,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and  inspection	                95,980            23,400
    Incidentals, overhead,
    fees, contingencies...                95,980            23,400
    Land	               123,000

    TOTAL INVESTMENT COST               $794,860          $163,800

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.              $112,000           $14,000
    Energy	                 6,400
    Chemicals	                 5,000            14,000
    Maintenance	                67,186            16,380
    Taxes and insurance...                23,845             4,914
    Residual vaste
    disposal	                42,600
    Monitoring, analysis
    and  reporting	                15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $272,031           $56,794

C.  AMORTIZATION OF
    INVESTMENT COST                     $109,311           $26,650

    TOTAL ANNUAL COST                   $381,342           $83,444


    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.

                                      141

-------
   500
   400
                                  2 I  /
                                   JZL
 o
 o
 o
X

•w-

H


O
                                        JSL
                          \A
                     JXl  LBV:CLJ ffi i
          I  i  i
                               17
   300
                            M7T
           M.
                                                                  i  i
                     z
          zz:
          z
   zoo
                                   J	u
   100
               _L
Figure 11-8.
50       100       150      ZOO


    PRODUCTION, METRIC TONS/YEAR X 1000



Annual treatment cost vs. production for the Chlorine

  Subcategory (Mercury Cell Process)
                              142

-------
  12
  10
2
O
H  8
W
                  i\
                        #2!
              50       100      150        200

                 PRODUCTION, METRIC TONS/YEAR X 1000
                                                              i  i  !
Figure 11-9.  Annual unit treatment cost vs.  production for the Chlorine
                 Subcategory (Mercury Cell  Process)
                              143

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                 TABLE 11-17   MODEL PLANT TREATMENT COSTS
Subcategory  CHLORINE  Mercury cell
Type of Regulation  BAT
                                           Annual Treatment Costs  ($/kkg)
                                                 LEVEL OF TREATMENT

                  PRODUCTION  FLOW      FIRST     SECOND    THIRD    FOURTH
                  (kkg/yr)  (m3/day)      $         $         $         $
Annual Operation
and Maintenance
Annual
Amortization
Total Cost
19,100
95,500
191,000
91
455
910
8.21
2.18
1.42
1.35
0.42
0.30
19,100
95, 500
191,000
19,100
95,500
191,000
91
455
910
91
455
910
1.50
0.68
0.57
9.71
2.86
2.00
0.18
0.15
0.14
1.53
0.56
0.44
              Applicable
                                144

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wastes  are  considered  as  contributing   to    waste  flows and
treatment costs.  Tail gas  scruDber   wastes,   typically high  in
sodium hypochlorite, are usually sold  or  returned  to process, and
are therefore excluded from waste flows and  waste  treatment costs
for  tne  model  plants.   however,  for    the   range  of  annual
production in metric tons from 31,850  to  190,750,  the annual cost
of decomposition of  sodium  hypochlorite   varies   from  91.26 to
$4.30 per metric ton of product  (3).

     The chlorine subcategory is  a multi-product  industry, since
caustic soda  is  a by-product  of chlorine  manufacture by either
process.  In this report investment costs   and  annual  costs are
expressed  in terms  of treatment cose per  metric  ton of chlorine
production,  without  considering tne  production  or value of the
by-product caustic soda.

     In this report brine mud  is  presumed  to  be  left on-site in
accordance  witii current practice at many chlorine  plants.  For
neutralization,   it  is  assumed tnat  waste   sulfuric  acid  is
available at the plant at no cost.

     mercury cell  base level  bPT costs  -   waste   treatment cost
summary sheets for three chlorine production rates by the mercury
cell  process  are  included  as  Tables  11-14,   11-15 and 11-16
respectively.  Base  level costs are shown  as the  fcirst  Level of
treatment.  Tne unit  costs of  BPT treatment   per  metric ton of
chlorine  production are stiown in figure  11-19  as  the lower curve
marked Level 1, Mercury Cell,  varying from   $1.92  to  $9.44 per
metric ton.

     Mercury cell advanced level  coses -   waste  treatment cost
summary Tables 11-14,  11-15 and 11-16  show incremental advanced
level costs in  the  column marked  •'second".   The unit costs  of
advanced  treatment per metric   ton of cnlorine production, which
includes both first  and  second level  costs,  are  shown by the
middle curve  (Level 2)  of Figure 11-9,  varying   from $2.25  to
$10.84 per metric ton.


11.3 ASSESSMENT OF THE WATER POLLUTION POTENTIAL - DIAPHRAGM CELL
11.3.1 Industry Profile and Analytical  Results
Chlorine - Diaphragm Cell Plants  (Metal  Anode)

     Tne industrial profile data  tor   this   industry is given   in
Taule 11-18 and existing regulations  in  Table 11-2.

     Tne priority  pollutants   found   in  the  raw  waste  during
sampling at Chlorine-Diaphragm  Cell -  Metal  Anode plants were  as
                                145

-------
TABLE 11-18   -
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
GHLORTNE DIAPHRAGM CELL
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                         8,272,600 kkg/year
                         6,427,000 kkg/year
                                45
                                19
                         6,397,000 kkg/year
                         4,200,000 kkg/year
                                77 percent
                                66 percent

                            14,700 kkg/year
                         1,500,000 kkg/year
                           221,000 kkg/year
                           103,000 kkg/year
                                67 percent

                                 4 years
                                74 years

                             1,100 cubic ineters/day
                             7,100 cubic meters/day

                                 1 cubic meters/kkg
                                23 cubic meters/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A.,  1977,  U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report,  "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical  Industry."
                                   146

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follows:
                   Maximum Concentration  Observed
   Pollutant
Screening
                  Verification  (4 Plants)
Chromium
Copper
Lead
Nickel
Mercury
Thall ium
Antimony

Arsenic
Cadmium
Selenium
Zinc
940
525
255
54400
9
14
20

10
2
<9
24
18750
16650
2000
22100
347
<2
43 Found at one
plant only
660
62
93
4290
     A summary of daily and unit  product  raw waste  loads for all
plants sampled can be found in Table  11-19.   Individual plant raw
waste loads per unit product  found   in  sampling can  be found  in
Table 11-20.   Table 11-20A summarizes  asbestos  sampling results
at three facilities.

     Based on the total annual production of this subcategory and
the  average waste load generated per  unit product, the estimated
total  priority pollutant raw waste  loads generated each year for
this subcategory are as follows:
          Pollutant
Vvaste load  (kg/year)
Chromium
Copper
Lead
Nickel
Me r c u r y
Arsenic
Cadmium
Selenium
Zinc
6100
2600
270
4100
8.
36
21
26
1500




4




                                147

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 TABLE 1 1- 19.   SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING

SUBCATEGORY
Pollutant
Priority
Arsenic, As
Cadmium, Cd
Chromium, Cr
I-
^
oo Copper, Cu
Lead, Pb
Nickel, Ni
Zinc, An
Mercury, Hg
Selenium, Se
Antimony, Sb
Thallium, Tl
Classical
CHLORINE-DIAPHRAGM CELL WITH METAL ANODES
Minimum

0.000038
0.00034
0.0036
0.0037
0.00086
0.013
0.017
0.00018
0.00023


7.39
Loadings
kg/day
Average Maximum Minimum

0.0021 0.0033 0.00000015
0.0015 0.0029 0.000001
0.58 2.81 0.000015
0.12 0.27 0.000011
0.021 0.064 0.0000037
0.28 0.88 0.00004
0.08 0.17 0.000057
0.00053 0.00082 0.0000003
0.0016 0.003 0.000003
0.00064
0.000045

kg/kkg
Average

0.0000056
0.0000033
0.00095
0.00041
0.000042
0.00064
0.00024
0.0000013
0.000004
0.000003
0.0000002

No. of Plants
Maximum Averaged

0.000014 5
0-000006 5
0.0046 5
0.0012 5
0.000095 5
0.0014 5
0.0007 4
0.0000025 3
0.000005 2
1
1

TSS
23.8
53.9
0.026
0.069
0.18

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TABLE  11-20.   PRIORITY POLLUTANT RAW WASTE LOADS  (in kg/kkg of Product)
SUBCATEGORY
                CHLORINE - DIAPHRAGM
POLLUTANT
               #014
           #261
  PLANT
#736
#?38Cold) #738(new)
Chromi-um, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni
Selenium, Se
Thallium, Tl
Zinc, Zn
Antimony, Sb
Arsenic, As
Cadmium, Cd
0.000015    0.000073   0.000044
0.000011    0.00064    0.0012
0.000004    0.000077   0.0000037
                       0.0000025
0.00083     0.00085    0.000056


0.0000002
            0.000057   0.0007
                       0.000003
0.00000015  0.000006   0.000014
0.0000014   0.000001   0.000006
                       0.0046    0.00004
                       0.00011   0.0001
                       0.00003   0.000095
                       0.000001  0.0000003
                       0.0014    0.00004
                       0.000005  0.000003


                       0.00009   0.0001


                       0.000004  0.000004
                       0.000004  0,000004
*Does not include brine muds.
                                    149

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TABLE  11-20A.    RESULTS OF ASBESTOS  SAMPLING AT DIAPHRAGM CELL PLANTS
Plant Stream
#261 Supply
Cell Wash
Filtered Discharge
Barometric
Condenser
#736 Supply
Cell Wash
Cell Room Waste
Barometric
Condenser
Barometric
Condenser
Barometric
Condenser
# 967 Supply
Cell Waste
Pond Effluent
Caustic Wash
Brine Filter
Backwash
Cathode Wash Waste
Condensate & Spent
Acid
Neutralizer Waste
Total Asbestos
Fibers (MFL)*
8.0
2.1 X 108
1.6 X 103

0.4
0.7
2.0 X 107
2.9 X 102

1.8

5.3
1.4 X 102
9.7 X 102
2.4 X 104
2.4 X 103
7.8 X 103
8.0 X 102
3.2 X 105
2.7 X 102
2.1 X 103
Chrisotile
MFL
7.5
2.1 X 108
1.6 X 103

0.4
0.7
2.0 X 107
2.8 X 102

0

5.3
1.4 X 102
9.7 X 102
2.4 X 104
2.4 X 103
7.8 X 103
6.2 X 102
3.2 X 105
1.8 X 102
2.1 X 103
Amphibole
MFL
0.4
0
0

0
0
0
8

1.8

0
0
0
8 X 102
0
0
1.8 X 102
0
8.9 X 10
0
*Million fibers per liter
                                    150

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Chlorine-Diaphragm Cell Plants  (Graphite Anode)

     The industrial  profile data is included
existiny regulations in Table 11-2.
                                   in Table  11-5 and
     The priority pollutants found in significant   concentrations
in the raw  waste during  screening at Ciilorine-Diaphragm   Cell -
Graphite Anode Plant #967 were as follows:
                                       maximum
     Pollutant
                                   Concentration
                                   ug/1
     Lead
     Antimony
     Chromium
     Zinc
     Copper
     Mercury
     Arsenic
     Cadmium
     Nickel
     Qrganics
     benzene
     Carbon Tetracnloride
     1,2-Dichloroethane
     Hexachloroethane
     Chloroform
     Dichlorobromomethane
     Bis(2-ethylhexyl) phtnalate
     Tetrachloroethylene
                              1,631,000
                                   1910
                                    300
                                   3204
                                   7450
                                     74
                                    680
                                     46
                                    640

                                     15
                                    197
                                    621
                                     90
                                    691
                                    309
                                    120
                                    196
     A list  of daily  and unit product   raw   waste  loads  for the
priority metals found at Plant #967 can be  found  in  Table   11-21.
     A list of daily  and unit product   raw   waste  loads  for
organics found at Plant #967 can be  found  in  Table  11-22.
                                                  the
     The major waste stream source of  organic  priority  pollutants
was the chlorine header condensate stream.   The  neutralizer waste
stream was the second largest contributor  of organics.
     All of
0.45 kg/day
at nonsignificant levels.
the  organic priority pollutants  found greater  than
 were volatile organics. The remaining organics  were
     Total priority pollutant  waste   loads   for  this subcategory
division cannot  be calculated at  this  time  because  it  is  not
known how many  graphite anode   plants there   are,   and the total
annual production value  is also  not available.
                                151

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TABLE 11-21,
METAL PRIORITY POLLUTANT RAW WASTE LOADINGS FOUND IN SAMPLING
AT A CHLORINE-DIAPHRAGM CELL PLANT WITH GRAPHITE ANODES


Pollutant
Priority
Chromium, Cr
Copper, Cu
Cadmium, Cd
Lead, Pb
Mercury, Hg
Nickel, Ni
Zinc, Zn
Antimony, Sb
Arsenic, As

kg/day
Average

0.057
0.42
0.00091
60.0
0.005
0.12
0.12
0.058
0.60
PLANT #967
Loadings
kg/kkg
Average

0.00026
0.0019
0.000004
0.273
0.000022
0.00054
0.00054
0.00026
0.0028
                                   152

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TABLE H-22.
ORGANIC PRIORITY POLLUTANT RAW WASTE LOADINGS FOUND  IN
SAMPLING AT A CHLORINE - DIAPHRAGM rET.L PLANT WITH GRAPHITE
ANODE
Pollutant
Benzene
Carbon Tetrachloride
1, 2-Dichloroethane
Hexachloroe thane
Chloroform
Dichlorobromomethane
Hexachlorobutadiene
Bis ( 2-ethylhexyl) phthalate
Tetrachlorothylene
PLANT #967
Loadings
kg/day
Average
0.00091
0.066
0.23
0.03
0.24
0.10
0.011
0.0023
0.10
kg/kkg
Average
0.000004
0.0003
0.001
0.00014
0.0011
0.00046
0.00005
0.00001
0.00046
                                  153

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11.3.2 Process Waste  Sources
General  Process Description

     Diaphragm Cell  Process - The sodium chloride  (uJaCl) solution
(brine or  salt dissolved  in water)  is purified before   it is sent
to  the  diaphragai   cell    for  chlorine,  caustic  and  hydrogen
production.   This  is done by the addition  of  soda ash  (Na2C03)
and small  amounts  of caustic soda until the ph increases to 10 or
11.  Tue calcium and  iron present in the brine and trace amounts
of otner metals are  precipitated as hydroxides or carbonates, and
tne brine  is  sent   to a  clarifier for  solids  separation.   The
underflow  from the  clarifier,  Known as brine mud, is   sent  to  a
layoon or  is  filtered.   The overflow from the ciarifier, which is
brine,  is   neated   and  brought  to saturation by the  addition of
salt  recovered  from the   caustic  evaporation.  The  pH is  then
lowered   to 6 by addition  of HC1 before  introducing   it  to the
diaphragm  cell.

     The saturated  salt solution  (26 percent  concentration)  is
electrolyzed  in  the diaphragm cell  to form  chlorine, hydrogen,
and sodium hydroxide according to the reaction:
     2NaCl  + 2H20  = C12 + 2NaOti + i-i2       (1)


     In one  pass   tnrough   the  cell,  the  salt  solution   is
decomposed  to  approximately naif of its original  concentration.
The   diaphragm  cell   contains  a  porous   asbestos  diaphragm
separating  the anode  from the cathode. Chlorine is liberated  at
the  anode  and  the  hydrogen  and  caustic  are produced at   the
catiiode.   In tiie past,   the predominant material  used  for anodes
was graphite with   lead used to provide an electrical contact  and
support.    The lead is  joined to the graphite anode by  an organic
binder.  In recent years,  the majority  of graphite  anodes have
been changed to stabilized metal anodes,  made of titanium with a
platinum  or  rubidium  oxide  coacing.  The advantages  of  using
metal anodes compared  to grapnite anodes  are  increased current
efficiency,   dimensional  stability   and   a   lower   chlorine
overvoltage, as  well as a reduction  in  the  quantity of waste
water  produced.   The   use  of  aietal  anodes  also  reduces  or
eliminates  the chlorinated orgauics  and lead impurities  in   the
wasce waters.   The  cathodes in the  diaphragm cells are usually
Hollow steel screens witii a coauing of asbestos deposited  on  the
outside.

     The  hydrogen  from  tne top of the cathode is cooled to remove
water and  other impur isies,  and  it either sold, vented  to  tiie
atmosphere  or burned to produce steam. Tne  caustic  leaving   the
catnode has  a  concentration  oi;  11-12  percent  iMaUti.   It   is

                               154

-------
concentrated  by multiple  effect   evaporation  to  increase  the
concentration  to  50 percent.  Tiie   vapor   evolved from the last
effect of the evaporator is air  condensed  in direct contact with
water  using barometric  condensers,   or   in surface  condensers,
using noncontact cooling waters.    when  barometric condensers are
used,  the amount  of  waste water  produced by  this operation is
large.  During evaporation, salt crystallizes and is removed from
all  the evaporators.  The concentrated  caustic is  then  settled
and  filtered to remove the  residual  salt   wnich is recycled to
tne brine preparation stage.

     The chlorine from  tne  cell  is  cooled  to  remove water and
other  impurities.  The condensates are  eitiier discharged without
treatment or recycled to the brine  purifier after steam stripping
for  chlorine  recovery.   The chlorine   gas,  after cooling, is
scrubbed  with concentrated sulfuric  acid to  remove water.   This
is done in  a series of towers wnere  tne   acid flow is counter to
that  of the  cnlorine  gas.  Tne  acid is  used until a  constant
dilution is reached.  The  spent acid  is  either regenerated, used
on site or is sold.  Figure 11-10  is   a  general flow  diagram for
tne manufacture of chlorine/caustic using diapnragm cells.
Water Use and Waste Source Inventories

     In the diaphragm cell, a large  quantity  of  water is used in
tne  barometric  condensers   if  the   vapors  from  the  caustic
evaporators are  contact cooled.  Table 11-23 is a summary of the
water usage  in  the barometric condensers  for a few plants where
data  are  available.   tor  plants   practicing  contact  cooling
through barometric condensers, tne average  amount of water  usage
is  twice  that  of  tne  mercury  cell plant per  metric  ton of
cnlorine produced.  The range  of water usage in a diapnragrn cell
is 15 to  492 cubic  meters per metric   ton  of chlorine.  Of the
total  water usage  in diaphragm  cell   plants,  approximately 50
percent is used for noncontact cooling.  In addition, the  amount
of water used for cleaning  diapnragm cells is higher  than that
of mercury cells.

     Barometric Condenser Water - The waste water specific to the
diapnragm cell  process  is  the barometric  condenser water.   A
significant amount of water is used  in  contact cooling the valors
from the evaporators  used  to  concentrate the caustic.   In the
mercury cells,  the  caustic comes out  at  a  concentration  of 50
percent and does not require evaporators unless a caustic of high
concentration (e.g.,  73 percent)  is required.   Tne  barometric
condenser waste  water ranges from d9   to 191  cubic  meters per
metric  ton of chlorine.  Tne barometric condenser waste water is
either discharged  without treatment, or recycled and  a bleed is
discharged with or without ph adjustment.


                               155

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                          LIME
                               BRINE

1
SULFATE SAL
PURGE

NC

NCONTACT
COOLING -^
WATER ^
11%
i
T RECYCLE



Ln
Ch COOLING
TOWER**
t
BLOWDOWN
TO WASTE
WATER
LEAKS,
SPILLS
WASIIDOWN
ETC.
t
TO WASTE


PURIFICATION
SYSTEM
1
DIAPHRAGM
CELL

DRINE MUDS ^TO HA^TE NONCONTACT COOLING WATER
i *
COOLER OR USE
CHLORINE ^— ^— —

TO 12% SODIUM *
HYDROXIDE
SOLUTION
t
EVAPORATOR
COOLING
WATER
WATER _ ^
, 1^™"^^^^
BAROMETR TC" ^^^
CONDENSER COOLER ^" (JIll^UKlNATKU WATHK CONDENSATE
t t *

-
SALT
REMOVAL
1
SODIUM
HYDROXIDE
SOLUTION
1
FILTER


^ (LIME) ^ j|k
	 1 	 AND WATER SODIUM
SOLUTION SALES, OR WASTE
*

REFRTfifiP- TAIL GAS 	 wm-r-n
ATION LIQUEFIER «
SYSTEM "* 	 i 	 * 	 1
¥ t 4 1 DIAPHRAGM
PACKAGING
TO USE
OR SALES
NONCONTACT LIQUID WASHING
COOLING CHLORINE &
WATPP WATFD DEPOSITION

TO SALES
OR USE T0 WASTE
USED SOME PLANTS  ONLY
 DEPENDS UPON PLANT  DESIGN
                       Figure 11-10General process flow diagram for production  of  chlorine/caustic by diaphragm cells.

-------
TABLE 11-23. DATA OF WATER USAGE FOR BAROMETRIC CONDENSER IN CHLORINE/
             CAUSTIC PLANTS USING DIAPHRAGM CELLS
Plant                         Water usage  ra /kkg of Cl~
  #207                                     115

  #858                                      89

  #736                                     191
                                 157

-------
     Discharges from  the  barometric  condensers contain some  salt
and   caustic  as  a   result  of   the   carryover  from the  caustic
solution.   when   grapnite   anoo.es    are  used,  the  barometric
condenser waste water contains  lead.

     Sulfate Purge waste   Water  - During  concentration  of  the
caustic  by evaporation,  sodium chloride  precipitates  out.  The
salt  is  removed  and   is washed with  water to  remove  sodium
suifate.   A portion  of  wash water  is recycled and  the  rest  is
purged to waste   in order to stop the buildup of  sulfates.  The
stream  is  one   of   the   major  sources   of  waste  water  from
chlorine/caustic  plants  using diaphragm cells.


Control  and Treatment Practices

     Diaphragm Cell Plants  Visited  and Sampled

     Waste water  streams were  sampled and  analyzed for priority
pollutants  in  the   screening   and   verification  phase  of  the
sampling  program. Tne   waste water  streams  at  Plant  #014 were
sampled  during screening, while Plants #261, #738, #967 and  #736
were sampled  in tiie verification phase.

     At  Plant #014,   the   chlorine   condensate  is  stripped with
steam to  remove  and   recover  chlorine.  The  brine precipitates
(muds)  are   land  disposed, while  the  spent  sulfuric acid  and
scrubber  solutions are  used  at  an adjacent plant.  The condensate
from the  hydrogen     cooler  is  used  as makeup water for a cooling
tower   system,   and   the    condensate   from  the  evaporative
concentration  of  sodium hydroxide is  used  to  dissolve  salt
reclaimed     from the  concentration process.   The cell washings
are sent  to a collection pond  where asbestos and otner suspended
solids are  removed.    In Figure 11-11 the general  process  flow
sheet  is presented.    The waste streams sampled and their  waste
loadings  are  given  in Table  11-24.

     At  Plant #261, the   cathode wash  water  is passed through a
filter and  the asbestos  is disposed  of  in a  landfill while  the
filtrate  goes to  the  sewer.    The caustic  liquor  from the cells
goes to  multiple-effect   evaporators.   The water vapor from  the
evaporators is  sent  to  a barometric condenser  from  wnich waste
water  is produced.   The caustic and salt  are botn  concentrated
further.  irigure  11-12  shows the  process  flow  diagram  and all
sampling  points.   Table  11-24  gives  waste stream  flows  arid
loadings.

     Plant  #738 has  two  production lines, 738A and 738b, that are
almost  identical.    At   the  new  plant  (73Uc>),   tiiere   is  no
concentration of  the  NaUH to 73 percent strengta nor is the waste
from tiie  chlorine disposal  system  scrubbed.   Also,  the  inert
gases  from   the  liquefaction  step are put through the chloride

                               158

-------
                                                                       VENT GAS
U1
                                                                                                                                    TAIL GASES
                                              a
BRINE ~_
1
RINE MJD
1
SALT
RETURN


CELL ROOM
i
ci2

1C
WASTE COOLING
WATER »3
Naai
NaOH
EVAPORATION
1
!
\.&*J ^ ChJ .1 1 WftbH
Hqy*'
14
ran


1
(XOLING




«
!

1
50

^ REUSE 75% H2SO4 COOLING WATER
CONDENSATE
NaOH FUSION


                                                                                                                                                                ^"REUSED
                                                                                                                                                                   C12 IN

                                                                                                                                                                   PIAOT
                                                                                                                                                     Cl^
BAROMETRIC
CONDENSER
WATER TO
WASTE.
                                                                                                NaOH
                                                                                TO WASTE
t
                                             CMNDENSER
                                             WATER TO
                                                   HASTE
                                                                                                                 •

                                                                                                                f

                                                                                                                          B^M
                                                                                                                               Sampling points.
                                                                                                                                                           NaOH
                                                   Figure 11-11. General  process flow diagram at Plant iOOl. showing the sanpling points.
                                                                            Chlorine/Caustic (Diaphragm Cell) Manufacture

-------
H-24 FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE STREAMS
      FOR PLANTS #277, #261, AND #738  PRODUCING CfflLORINE/CAUSTIC
      BY DIAPHRAGM
Plant
#277




#261




#738





#738




Sampled Stream
Stream Description
NO.
3
4
5
6

1
2
3
4
5
1

2
3
4

5
6

7
8
9
Chlorine
Condensate
Cell Wash
Brine Mud
Flow
nP/kkg
of C12
0.9
0.015
0.018
Barometric 306
Condensate
Brine Mud
Cell Wash
Asbestos
Filtrate
Asbestos
Filtrate Cake
Barometric
Condenser
Cell Room
Waste
Asbestos Wash
Scrubber (Hypo)
Chlorine
Cooling
Water (H2SO4)

0.832
0.384
NA
NA
NA
0.0682

0.165
0.124
0.478

Caustic 249.1
Cooling Tower
Cell Room
Waste
Asbestos Wash
Scrubber (Hypo)
Chlorine
0.0589

0.142
0.107
0.413
SS
Load
kg/kkg
of C12
1.35 x 10~3
0.024
NA
3.64

NA
0.183
(9 mg/1)*
NA
(6 mg/1) *
1.4 x 10"3

8.4 x 10~3
3.5 x 10"2
1.4 x 10~2

10.48
5.3 x 10~3

9.4 x 10~3
1 x 10~2
5.7 x 10~3
Pb
Load
kg/kkg
Of C12
4.95 x 10~6
3.9 x 10~6
1.3 x 10~5
1.5 x 10~3

2.88 x 10~4
0.100
(0.075 mg/1)*
(42.4 mg/1)*
(<0.01 mg/1)*
5.25 x 10~6

5.15 x 10~6
1.88 x 10~5
9.9 x 10~6

0.127
1.97 x 10~6

1.62 x 10~5
2.4 x 10~5
8.04 x 10~5
Asbestos
Load
kg/kkg
of C12
NA
NA
NA
NA

0.117
0.07
(0.14 mg/1)*
NA
NA
NA

NA
NA
NA

NA
NA

NA
NA
NA
       Cooling
       Water (H2S04)
                              160

-------
TABLE 11-24  continued
Plant Sampled Stream
Flow
Stream Description rn^/kkg
No

#738 10

11
12

13


14
.

Caustic
Cooling Tower
Chlorate Sump
Plant Effluent

Final Effluent
(Total)

Brine Mud
of C10
£
215.1

0.28
0.46

NA


NA
SS
Load"
kg/kkg
of C12
1.0

0.009
0.028
*
(64 mg/1)

c
(2.70 x 10*
PB"~
Load
kg/kkg
of C12
<2.2 x 10~3

<2.8 x 10~6
5.3 x 10~5
*
(1078 mg/1)

*
(<0.01 mg/1)
Asbestos
Load
kg/kkg
of C12
NA

NA
NA

NA


NA
  A = Not Available


  Flow of the sampled stream is not available so the concentration is given
  in mg/1.
                                  161

-------
                   SODIUM
                 CARBONATE
   RAW
  BRINE
CTl
NJ
                                       NaOlI
                                                                                SALT
                                                                               WDROGEN TO BOIU5R

                                                                             ILING WATER
MIXERS


CLARI-
FLOCCULATORS


SAND
FILTERS
                                    BRINE MUDS
                                  ADJACENT HANT
                                           H2S04
r
                                                    SLUDGE TO LANDFILL
                                                             COOLING WATER
    FILTRATE TO
PROCESS SEWER

    ASBESTOS TO
     LANDFILL
       TO
       EJECTOR




*
SPENT H2S04



C12
WRTE
H

r^
RJRIFICATION
BOTTOM TOWER
(


HJRIFICATION
TOWER




LIQUEFIER
1

                      RIRGE FOR DISPOSAL
                         BY CONTRACT
                                                                          BRINE RECYCLED
                                                                            TO PROCESS
                                                                                                   HYPOCHLORITE
                                                                                                   SOLUTION TO
                                                                                                   ADJACENT PLANT
                                                                     CHLORINE     AND RAILROAD CAR
                                                                    TO STORAGE        WASHDOWN
                                                 IWaste streams sampled.
                                                                                                                         NaOH
                                                                                                                                                                        TO BOII.KR
                                                                                                                                                                        FEED WATER
                                                                                                                 . TO SLAKE LIME
                                                                                                                 (FOR LIME PLANi
                                                                                                               -*• PROCESS SEWEB


                                                                                                         It) EJECTOR
                                                                                                          PROCESS
                                                                                                          SEWER
                           Figure 11- 12.    General process flow diagram at Plant 0261 showing the sanpling points.
                                                        Chlorine/Caustic  (Diaphragm Cell) Manufacture

-------
disposal system.  Table 11-24  shows  the sampled waste streams and
their  loadings for both   plants.    The  process  flow sneets are
shown in figure 11-13 and  11-14.

     Plant #967 uses graphite  anodes in its diaphragm cells.  The
cell washings at this plant  are  sent to an asbestos pond that has
a  continuous cover of water.    Periodically,  the settled solids
are removed, sealed in drums and  disposed of in a landfill.   The
overflow  from the  pond  is  treated   with soda asn to precipitate
lead, and then with sulfuric acid  to  bring the  pri  down to  6-9
range. It is then finally  settled.   Table 11-25  shows the  waste
streams sampled and waste  loadings  for  this plant.  figure 11-15
is a general process flow  diagram  for Plant #967.

     Plant #736 has installed  de-raisters to  control the  vapors
evolved  from  the  last   stage   of   the  evaporator  during  the
concentration of caustic.  In  this   treatment,  the steam evolved
from the concentration of  cell liquors passes through metal  wool
filters to reduce  entrained solids.  The cell room  washings are
sent to  a settling chamber  and  the  settled asbestos is sent to a
landfill.    The  other  waste   waters,  consisting  of   caustic
evaporator  washings  and  wastes   from  salt  separation,  brine
purification operations, and caustic filtration  backwash waters,
are  combined  and  sent to  one  of   two settling  ponds.  Skimming
devices on the  settling   ponds  remove  any oil  that  separates,
while the settled solids in  the  ponds are dredged and disposed of
in an  abandoned brine well.   Figure 11-16 shows the process flow
diagram and  sampling  points.    Table 11-25 gives  the pollutant
loadings of the streams sampled.

     Treatment Practices-Diaphragm   cell - Waste water  treatment
practices   are  available  for   few  plants.   Unless  otherwise
specified, the plants described  use   metal anodes in their cells.

     At Plant #999,  the   brine   mud and  other  suspended  solid
streams  are collected and filtered  in leaf filters.  The cake is
disposed of in  a landfill and the  brine filtrate returned to the
brine system.

     At Plant  #326, the waste water from chlorine diaphragm cell
plants is combined with other  process waste waters.  The combined
waste water is sent to the first  of  two settling tanks in series.

     In one  of the settling tanks,  skimmers have been  installed
to remove oil and the overflow from  the second is filtered before
di scharge.

     At Plant #589, the brine  mud  from the clarifier underflow is
sent to a brine mud settling pond.   The overflow, which is mostly
brine, is returned to the  process.    The cell  room  washings are
sent  to  a  settling pit  and  the   settled  asbestos  fibers are
removed  by the  use of  a  vacuum   truck, and  disposed of  in  a

                               163

-------
1-
cn
                     BRINE
        73% NaOH
                                                                                  HJRIFICATION
                                                                                      AND
                                                                                  COMPRBSSION
                                                                                                                                      LIQUEFACTION
                                                                                                                                                         "Cl.
                                                                                                                                   •-WASTE HYDROCARBONS
                                                                                                      SPENT
                                                                                                      H2S04
                       O
                                 BAROMETRIC H2O
Sampling points.
                                                                                WASTE SUMP
                                                                                                                                               VENT
                                                                                                                                     WASTE WATER
                                                                                                                                   (NaOCl +
                                                                                                      (Point 112 - waste  soap  (combination of all wastes).)
                                                Figure  11-13. General process flowsheet at Plant ((738 showing the sanpling points.
                                                                          Chlorine/Caustic (Diaphragn Cell)  Manufacture

-------
cn
                    BRINE
H2° H2°
* I
COOLING
WASTE-*— TOWER -|
t r
r „„ Y
BRINE - • •
PURIFICATION BRINE p^j.
AND ROOM
** RESA1URATION 	
H
BRINE u fTT.|.
MUD WASH

AND


COOLING
AND
COMPRESSION
'S*
WASTE H-O
C12 _

16



	 _., _.J go
n
H2 LUIE to, 2 f^) to» WASTE
— fi» (CAUSTIC)"" DISPOSAL V^/ HYPOCIBjORITE
H20 H2S04 , , .^^^^

i *
COOLING AND ^-^to» PURIFICATION ^2^ LIQUEFACTION
DRYIN3 COMPRESSION
1 ' H2SO4 HYDROCARBONS
WASH H2°
	 	 . *7


ASBESTOS f&\ fa&
PANEL ^^/ v3*

M
COOLING i r V -^
4 ' '



V"W Sampling points.
                                            WASTE
                                                       Figure 11-14. General process flow diagram at Plant 1738 showing the sampling points.
                                                                                Clilorine/Caustic (Diaphragm Cell) Manufacture

-------
T3\ELE 11-25 FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
           STREAMS FOR PLANTS #9 6 7  AND #7 3 6  PRODUCING CHLORINE BY DIAPHRAGM CELL
Plant Sampled Stream Flow
Stream
No.


1967 1

2

3


4

5

6

#736 1
2
Description nrykkg
of Cl,,
^

Cell Building 0.18
Wastes
Lead Pond 0.55
Effluent
Caustic Plant 5.38
Effluent

Brine Filter 0.45
Back Wash
Cell Wash 0.18

Condensate And 0.79
Spent H2S04
Cell Wash 0.652
Cell Room 0.0163
SS
Load
kg/kkg
of Cl,
2
0.187

0.03

0.841


5.75

0.05

0.85

0.06
4.62 x 10~3
Pb
Load
kg/kkg
of Cl,
2
0.12

0.016

0.014

-4
2 x 10

8,6 x 10~3
-4
7.3 x 10

9.1 x 10~7
2.75x 10~6
Asbestos
Load
kg/kkg
of Cl,
2
7.5 x 10~5

1.56x 10~5

7.6 x 10~4

-6
1.8 x 10

6.6 x 10~4
-6
9.8 x 10

NA
0.085xlO~6
            Drain

         3   Brine Mud
1.631     32.621
3.1 x 10"
NA
         4   50%  Barometric    NA   (32 mg/1)
             Condenser

         5   70%  Barometric    NA   (20 mg/1)
             Condenser

         6   95%  Barometric    NA   (90 mg/1)
             Condenser
         7   Chlorine
            Condenser
0.163   3.9 x 10"
                       (<0.01 mg/1)*  (1 x 10~4mg/l)*
                       (<0.01 mg/1)*  (1 x 10~4mg/l)*
                       ( 0.01 mg/1)   (4 x


                               ,-6
1.63 x 10"
NA
  Flow of  the  sampled  stream is  not available so the pollutant concentration
  is given as  mg/1.
  NA =  Not Analyzed.

                                    166

-------
BRINE
SALT
                                                                    DRY SALT
i
                                                                                                                                       H   TO POWER HOUSE
                    SALT TO RECOVERY
COOLING
EQUIPMENT
f
41

FILTERS
£
1
^ 13
                                                SALT TO SEMER
                         Sampling points.
                                                  DISCHARGE
                                                                                                                    TO  ADJACENT
                                                                                                                        PLANT
                                       Figure 11-15. General process flow diagram at Plant 1967 shewing the saiiplang points.
                                                                Chlorine/Caustic (Diaphragm Cell)  Manufacture

-------
CLMUFIER


                                                         T
                                            13

                                   BRINE MID TO
                                     DEEP WELL
                                      DISPOSAL
                 FILTER BACKWRSH
                   TO nRKP WELL
                     DISPOSAL
                                                                                            HYDROGEN TO ATMOSPHERE
                                                                                            OR CAPTIVE USE
                                                                                                                 LIQUID
                                                                                                                 CHLORINE
                                                                                                                 TO STORAGE
                                                                                                                                                  CONTACT WWER
                                                                                                                                                     TO RIVER
                                                              CONTACT   ASBESTOS
                                                               WATER    TO SOLID
                                                             TO RIVER   WASTE
                                                                        DISPOSAL
00
                                                                                        COOTACT
                                                                                      WASTE "WATER
                                                                                       TO PONDS
                                                                                                            CHEMICALS
                            e
Waste streams sampled.
                                                                                                        FLAKER
SULFATE
| CEWTRIGUGE
t


	 	 t-*-w;
FTTiTRATTrN ... .

t
EULFATE CONTACT WATER
BRINE SLURRY TO SETTLING POND
TO DEEP WELL
DISPOSAL
— ANHYDROUS
•• . \ 7
^TER





0% ^_
                                                                                   CONTACT V1ATER
                                                                                  TO SETTLING PONDS
                                                                                                      T
                                                                  CAUSTIC
                                                                   SODA
                                                                  FLRKES
                                                                                                                            CONCENTRATOR
                                                                                                   TOR p    n

                                                                                                   *6    CAPTIVE
                                                                                                                                                         CONCEOTRATOR
       USE
(70%  CAUSTIC)
                                                                                                                 ANHYDROUS
                                                                                                                   CAUSTIC  CONTACT WATER
                                                                                                                   SODA   TO SETTLING POND
                                                          Figure 11- 16. General process flow diagram at Plant J736showing the sampling points.
                                                                                   Chlorine/Caustic (Diaphragm Cell) Manufacture

-------
landfill.  The chlorine from  the  cells  is contact cooled with the
tail  gas  scrubber water.    The   resulting  waste water is  steam
stripped for chlorine recovery  before discharge.

     At Plant  #741,   chlorine,   caustic  soda,  and  potassium
hydroxide  are  produced using  both  mercury  and diaphragm  cells.
Mercury-bearing  effluent at  this  facility is treated by  sulfide
precipitation.  Tail   gas  absorption    wastes  are  treated by
catalytic  decomposition   by  a  process   which  consists  of
scrubbing with caustic soda treating solution  and  treating  the
resulting  hypochlorite solution   with  nickel  chloride  and iron
chloride  catalysts.  Decomposition   proceeds relatively  slowly.
Consumption of iron and nickel  chloride  is   approximately  equal
and  consists  of  0.01  kilogram  per   metric  ton  of  chlorine
produced.   Wastes  are  retained  in   the  treatment  tanks  for
approximately  three days, after  which   time no residual chlorine
is reported to be present in  the  discharge (3).

     Chlor inated organic  hydrocarbons   - The  use  of  graphite
anodes,  in either mercury cell or diaphragm cell plants,  results
in the  generation of a variety of simple chlorinated hydrocarbon
compounds as a result of  the  attack of chlorine on the  anodes.
These compounds are carried out of the  cell  with the chlorine and
find tneir way into the  various  waste   streams  which  originate
from the  chlorine  cooling,  drying, compression and liquefaction
steps.  In cases  such as  Plant   #967   where  the end use of the
product chlorine  is  captive involving its  direct application to
the manufacture of a  chlorinated  organic product, the  bulk of
chlorinated organic impurities  are not  removed from the chlorine.
Table  11-22 shows  the raw   waste  loadings of organic compounds
found in the chlorine condensate  waste  stream at Plant #967. In a
flow of  approximately 320  m3/day,  the  total organic  raw waste
load  was  found  to  be  0.78  kg/day.   The  amount  of  carbon
tetrachloride  alone  was  0.066   kg/day  at a  concentration of
approximately 0.2 mg/1.  At Plant  #195, where  a purified product
is required,  the chlorinated organics   are   accumulated  in  the
reboiler of  the  chlorine  tracifier  (chlorine  scrubber).   The
tracifier  residues  are  treated  batchwise  for separation  and
recovery of the organic phase materials  which are sold  as  feed
stock  for  the  manufacture   of   related  products.   Prior  to
discharge, the aqueous  phase  is vacuum  stripped to remove and
recycle additional chlorinated  organics  and chlorine.  Normally,
one batch of organics  is treated  per week.  After separating each
batch of  organics and stripping   the  residual aqueous phase, the
quantity  of waste water  discharged is approximately 5.7 m3/week
or 0.8 m3/day-  The  organic  loading  in this waste is not known,
however,  if  the  assumption  is made  that  the  discharge is
saturated with CC14 (800 mg/1  @   20 degrees  C) ,  the waste load
would be 0-5 kg/day.

     Although the daily  mass emissions from  the two  plants are
likely to be similar and  both would require additional treatment

                                169

-------
to   achieve  acceptable discharge  levels,  the  wide difference  in
concentrations of the chlorinated  organics as  well as  the manner
in  which they  are handled, would  necessitate  the application  of
an   advanced treatment  technology  specifically  suited  to each
case.

    Where the flow is large  and the concentrations are low,  the
application  of  activated  carbon  adsorption  to  the collected
organic-bearing waste stream  at  Plant  #967 would  be capable  of
reducing a  CC14 mass emission from  0.066  kg/day to approximately
0.03 kg/day, assuming a treatability level of  0.10 mg/1.

    In the  case  of Plant #195,  where the volume of waste water
is  small but  the concentrations of  residual chlorinated organics
can be  in the order  of several  hundred  ppm, a more appropriate
final   removal  technology  would   be  steam  stripping  with  an
overhead return to the process.  Assuming  a treatability level of
10  mg/1 for  CC14 using this  technology,   its  mass emission could
be  reduced to approximately 0.01 kg/day.

    The additional costs for steam  stripping  in a plant (such as
Plant  #195) which already has a vacuum  vaporizer, would be  under
$10,000 for modification of the existing  equipment.  Steam  costs
could  vary from $1,000 to $5,000 per year.  If a vaporizer is not
in  place, a steam stripper to process 5 to 30  m3/week would  cost
roughly   $50,000   to   $100,000,   depending   on   the   input
concentrations  to be  handled.    The  corresponding steam  costs
would  range from $2,000 to $10,000 per  year.

    The capital costs of an  activated  carbon  adsorption unit for
handling the  relatively high volume wastes with a  low influent
organic  loading  (as  found at Plant  #967)  cannot  be  reliably
estimated in the  absence of  specific   treatability data  on the
waste  streams in question.

    A process evaluation  should   be made  to determine the most
efficient means of  isolating and collecting  the organic bearing
waste  streams prior to treatment.

    Alternatively, incineration    of  the  chlorinated  organic
residuals  is an  effective means  of destroying and disposing  of
this  material  provided  that  adequate   measures are  taken  to
control the release of HC1 to the  atmosphere.


Evaulation of Industry Production  and Waste Flow Data

    In the diaphragm  cell plants,   the  waste in many  plants is
segregated  into four different  streams.    The brine  mud  wnich
contains a large amount  of suspended solids is either sent to  a
lagoon or filtered and  the  clear   liquid  recycled  for  brine
recovery.  The solids content in the brine mud was found to  vary

                              170

-------
from 2 to 20 percent.   The second  segregated waste stream is the
chlorine-contaminated waste water.   The  third segregated waste is
the cell  wash.   It includes  the   waste  water  from washing  Of
cells, cathode wash and diaphragm  rebuilding  areas, and leaks and
spills  in the chlorine cell room.   This stream contains asbestos
either  in fiber form or  stabilized  sheets  in the waste  water.
The last segregated waste stream is  Known as   the  process  waste
water.   Metals  like  lead  and nickel  may  'oe  found  in  small
quantities in this stream.  It  is  a  combined  waste which consists
of streams like brine and caustic  filter backwash, sulfate purge,
etc.   A further breakdown  of  the   individual  segregated waste
streams is not available.  In  plants  using graphite anodes,  this
waste stream contains a significant  amount of lead.   Table 11-26
gives the  flow of the  segregated  waste streams for plants whose
data are available.
Process Modifications and Technology  Transfer Options

     Cooling Water   -   The   vapors   from   the   evaporative
concentration  of  caustic  soda  (in diaphragm  cells)  are either
contact   cooled  or  cooled   in   surface   condensers.   Plants
practicing contact cooling  through barometric condensers generate
large amounts  of waste water.   The barometric condenser water is
subject to contamination with caustic and  salt.   By changing  from
contact cooling of  the  vapors  to noncontact cooling, the amount
of waste water generated can  be reduced    considerably.  If the
change  is  expensive  or   is not  feasible,  then  de-misters or
similar control devices need to  be  installed to  reduce the  salt
and caustic carryover in the vapors.   Similarly, if a plant has a
barometric  condenser  on   the   brine  dechlorinator,  it can  be
replaced with  an  indirect condenser to achieve  a  reduction of
waste water and recovery of mercury in a mercury cell plant.

     Anode Material - In the  majority of  cases, in both  mercury
and  diaphragm cells,  the  anodes have been  changed from graphite
to metal.  The use  of metal  anodes  increases  the  cell current
efficiency and eliminates or reduces  considerably the chlorinated
organic compounds and lead  in the waste waters.   The metal anodes
consist  of  an expanded titanium  metal  substrate  coated  with
precious metal and rare earth oxides.

     Diaphragm Material - The use of  modified diaphragms produces
beneficial  effects   in    power consumption  and  environmental
controls.   The  three  modified diaphragms  available,  polymer
modified asbestos, polymer  membrane,   and ion exchange  membrane,
are discussed briefly below.

     A.  Polymer Modified Asbestos:    This consists of a polymer-
treated asbestos diaphragm  baked into  place on  the cathode.  Its
usage  results  in power  savings and has  a  minor  environmental
benefit,  since, at the time  of rebuilding   of the cathodes,  the

                               171

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      11-26.  WASTE FLOW DATA FOR CHLORINE/CAUSTIC SUBCATEGORY USING
             DIAPHRAGM CELLS
Stream Description        Plant       Unit Flow         m /kkg of chlorine


Brine mad                   #858                    0.417

                           #967                    0.277

                           #736                    1.68

Cell wash                   #858                    0.084

                           #736                    0.0168

                           #589                    0.05

Tail gas scrubber effluent  #858                    0.167
(hypochlorite solution)
                           #967                    0.29

                           #967                    0.105
                                  172

-------
discarded material is produced   in   stabilized pieces  instead of
loose asbestos fibers.  The disposal  is  thus safer and easier.

     B.  Polymer Membrane:  This  consists of  raicroporous teflon-
type   polymer,   and   its   operation   has  been   demonstrated
successfully  in  laboratory  and   pilot  plant scale cells.   in
addition  to  the benefits of  cost   savings  through  energy use
reduction and longer life,  its  use  eliminates  the handling  and
disposal problems associated with asbestos.

     C.  Ion  Exchange  Membrane:    These  membranes  allow  the
transfer of  positive   ions  to   the   cathodes  and  prevent  the
transfer of negative ions to the  anodes, thus allowing production
of a concentrated caustic  similar   to  that  produced by mercury
cells.   The  production of salt-free concentrated caustic  will
reduce the waste water  associated with  the   caustic  evaporation
process.  Dupont's   Nafion  is   the   most   successful  membrane
available in  the United States,  and  a  pilot plant  producing 12
tons  per  day of chlorine is  operating successfully using  this
membrane.  Like the  polymer  membranes, the  problems associated
with  the handling and  disposal   of  asbestos are eliminated.  Use
and commercialization of the membrane  is anticipated in the  near
future.   The longer  life of the membrane  will reduce the waste
waters associated with  the rebuilding operation.
Model Plant and BPT Treatment  Systems  Specifications

     Diaphragm Cell Plants  -  The  specified BPT treatment for  the
chlorine/caustic plants  using  diaphragm cells consists of:

     A.  Asbestos removal  (from  cell washing)  by alum
         coagulation and settling,  followed by filtration
         and land disposal of  the  solids.

     B.  Partial recycle of the  Drine  waste stream to process.

     C.  Lagoon settling of the  brine  mud  and long-term
         storage at site.

     D.  Incidental heavy metal  removal resulting from use
         of soda ash to  promote  flocculation.

     Currently, about  65 percent  of the total chlorine  produced
in the United States   is made  by  diaphragm production.  Data  is
available  for   62    percent    of   the  total  diaphragm  cell
chlorine/caustic producers.  The production at industrial  plants
ranges from  a minimum  of about 15,000  kkg of chlorine/yr to a
maximum of 1,500,000   kkg of chlorine/yr.   Because  of the  large
number of  plants in tiie subcategory and wide range of production
levels, three model plants  with production capacities of 19,100,
95,500  and 191,000 kkg  of chlorine/yr were selected to represent

                               173

-------
the  production range  of plants  for
flow per unit of production  remains
                   which data  is available.   The
                   the same for each model.
    A.  Waste Water Flow:   The  waste  streams are segregated into
brine mud,  cell  wash  and   process   waste.   The  brine  waste is
settled  in  ponds and  the  overflow   is  recycled to the process.
Tne unit brine mud  flow  was  taken   as 0.42 m3/KKg  of  chlorine
containing  10 percent  suspended  solids.   The  cell wash,  which
includes the  wash waters,  leaKs and  spills from the cell  rooms,
is sent to a  holding   tank and is   mixed with the other process
waste water for metal treatment  and pH adjustment.  Tne cell wash
is segregated  because  it   has asbestos  as suspended material in
it. The asbestos content was  taken as  0.825 kg/kkg in the  cell
wash. A unit cell wash  flow of 0.07 m3/kkg of chlorine was  taken
for the  model plants.   The  process  waste water stream, which
includes  the  brine and caustic  filter  backwash, sulfate purge
liquid, etc., was taken as  0.77  m3/kkg of chlorine produced.

    B. Chemicals   used:    Soda and  alum   are   added   for
flocculation  and metal precipitation (as basic carbonates).  The
metals  treated or  removed  include nickel,  chromium, copper, and
lead.   The soda ash dosage  was assumed to be 100 ppm on the waste
flow which is equivalent to 0.084 kg  of soda asn/kkg of chlorine.
     Alum  was  assumed
chlorine product  as  a
     to be added in the
     flocculating agent
amount of 0.14 kg/kkg of
     C.   Solid  waste
of solid  wastes
source of  solid
cells  and   the
hydroxides.   The
treatment plants
      The brine mud constitutes  the major  source
from  the  process/treatment  system.   The   other
wastes includes the asbestos   froia  the diaphragm
metals  precipitated  as  basic   carbonates  and
total quantity of solids produced from the model
is 42.5 kg/kkg of chlorine.
11.4 TECHNOLOGY  BASED  POLLUTION ABATEMENT
11.4.1  Advanced  Level  Treatment Applications
Priority  Pollutants  to  be  Controlled

     Existing  regulations   on   diaphragm  cell  graphite  anode
chlorine   plants  call  for  lead to be less than 0.0025 kg/kkg as a
30-day average.   Other priority  pollutants  to  be  controlled
include asbestos,  trace metals,  and chlorinated organics.
                               174

-------
Removal Mechanisms Available

     Asbestos particles  can  be   trapped   in  a  chemical  floe,
settled  and filtered.  Possible  alternate  metal removal  methods
include  ion  exchange  and   xanthate   precipitation.   Membrane
separation is not a viable alternative.


Selection of Appropriate Technology

     Diaphragm Cell - BPT   (Level  !_)_ -  Chemical coagulation  with
alum is used to trap and settle suspended  asbestos.  Other wastes
containing  toxic  metals are then added,  and soda ash is used to
precipitate  the  metals  as metallic  carbonates and hydroxides,
followed by settling and sludge separation.  This two-stage Level
1 process provides gravity settling  of   asbestos-containing waste
and broadly controls heavy metals.

     Diaphragm Cell - Level 2^ - Dual  media  filtration is added to
the BPT system.     ~

     Diaphragm Cell - Level _3 -   A higher  degree of metal removal
is provide provided By introducing sulfide  precipitation ahead of
dual  media  filtration.   This    process    involves  only  minor
equipment  and chemical costs  to  achieve   best available  heavy
metal removal  technology  at  reasonable   cost.   Ion  exchange,
xanthate  and  membrane processes  were   not  chosen for the  same
reasons given under the mercury cell  process.


Flow Diagrams

     Flow diagrams  for  treatment of multiple waste streams from
the  diaphgram cell process  are  shown  by  Figure 11-17 (Level 1),
Figure 11-18 (Level 2) , and Figure 11-19 (Level 3) .


Description of Each Treatment Level

     Equipment Function  -  In  the   diaphragm  cell waste  water
treatment process conventional alum   flocculation, settling, and
dual  media   filtration  are  used   for   asbestos   separation.
Conventional sludge dewatering by filter press is used to dewater
the asbestos sludge  before  hauling, and   the dual  media filter
back wash is returned to the influent surge tank.

     Level 2 treatment requires the  addition  of a reagent mixing
tank and chemical  solution feeder  to  introduce  ferrous sulfide
ahead of the Level  1  multi-media filter.   All the  equipment is
conventional and readily available.

                               175

-------
  DKINE
                                LAGOON
                                LAGOON
                                                                       TO PROCESS
                                 I  I SODA ASH

                                 j:	__
WASTE WATER
(METAL
CONTAMINATED)
                                            ALUMpl

                     HOLDING TANK
                                     ALUM
 CELL ROOM
• WASTES      '
|(ASBESTOS
 CONTAMINATED)
                                                       MIXING
                                                              FILTER AID
                                                                   ,
                                         (BATCH)
                                         HOLDING TANK
                                                                 SLUDGE
                                                                HOLDING
L-
                                                                SETTLING
                                                                  TANK
                                                                                            IpH ADJUSTMENT
                                                                                           %	
                                                                                                            ftf]
                                                                                                            r
                                                                                                             i
                                                                                                            FILTER
                                                                                                           LANDFILL
                                                   		r
                                                                                                                                       •D-
                                                                                                                                        *
-^- EFFLUENT
                                                                                                             Includes pH monitoring,  flov/ monHurinp
                                                                                                             and sampler
                                           Finure ll-17.Wastr water treatment Level 1 for chlorine - diaphragm cell subcalegory.

-------
  BRINEi
    MUD
                                   LAGOON	/"
                                                                     RECYCLE
                                                                    TO PROCESS
                                   LAGOON
                                  n
                                     SODA ASK
 WASTE WATER
(METAL
 CONTAMINATED
                                          ALUMfl
                                                *-!
^J
^J
                  j HOLDING TANK

                  I
                                       ALUM
                        CELL ROOM
                         WASTES
                        (ASBESTOS
                     I CONTAMINATED)
                                                                                                      BACKWASH
                                                              FILTER AID
      I
      I
SETTLING

   TANK
                                                                                                              SUMP
                                                                                                          FILTER
                                                                                                        TO LANDFILL   [
                                                                                                                                         pH
                                                                                                                                 DUAL
                                                                                                                                 MEDIA
                                                                                                                                FILTER
                                                                                                                                   *Include8 pH monitoring,  flow monito
                                                                                                                                   and sampler
                                                       Figure 11-18. Waste water treatment Level 2 for chlori
                                                                                                        - diaphra^n cell eiix:ategory

-------
                                                                           RECYCLE
                                                                           TO PROCESS
                                 LA GOO:-.
                                      SODA ASH
                     r
WASTE WATER
(METAL
 CONTAMINATED
    00
                                                                        BACKWASH
                                            ALUM
                    1 HOLDING TANK
                                      ALUM
                       CELL
                    '   ROOM   	
                    I  WASTES
                    '(ASBESTOS
                    I CO N TA M1N A TED)
 (BATCH)
HOLDING
  TANK
——~—
              MIXING
                       FILTER AID
                                                                    SLUDGE
                                                                   HOLDING
                                                                     TANK
                                                    I

                                             SETTLING

                                                TANK
                                                                                                                 FERROUS
                                                                                                                 SULFATE
                                                                                                              ADJUSTMENT
                                                                              SUMP
                                                                                                                 FILTER
                                                                                           SODIUM
                                                                                          BISULFIDE
                                                                                                                 ANDFILL      I
DUAL
MEDIA
FILTER
                                                                                                                                                                      EFFLUENT
                                                                                                    Includes pH monitoring, flow monitoring
                                                                                                    and sampler
                                                     Figure 11-19. Waste water treatment Level 3 for chlorine - diaphragm cell  aubcategory.

-------
     Chemicals and handling  -   In  the  diaphragm cell waste water
treatment  process  solutions   of   aluminum  sulfate  and  sodium
carbonate are fed with conventional  equipment.   Inert filter aid
is  used in  the  alum  sludge  filter   process,  and there  ar no
unusual hazards  in  the  Level  1   treatment.   At  Level  2 the
potential  hazard  in  handling  sodium   sulfide  is  nullified by
reacting it with  ferrous sulfate  to form  ferrous sulfide, which
then reacts with other residual  heavy metals,  leaving only excess
ferrous sulfide in solution, which  oxidizes to ferric sulfide and
precipitates.   At the point where  sodium sulfide is reacted with
ferrous  sulfate good ventilation  is essential, but with a proper
excess  of  iron there is  no   subsequent hazard  in handling the
ferrous sulfide at ph levels involved  in the process.
11.4.2 Estimated Performance of  BPT  Systems

     Diaphragm Cell  Plants  -   Asbestos,   used  as  a  diaphragm
separating the cell anode and cathode,   is  the  major  pollutant
consistently found in process wastes from  diaphragm cell  plants.
It  occurs primarily in  wastes  resulting  from activities such as
cell  room  washdown  and  cathode   repairing.   Because  of the
relatively  recent  concern  about asbestos in waste  waters, and
because of uncertainties in  analytical  procedures, asbestos has
not been  regulated in plant discharges.    The  only  control has
been with suspended solids limitations.

     Asbestos control is practiced at several plants.  Generally,
control consists of settling and/or  filtering the waste water and
disposing  of  the solids  in  sealed  containers  or  simply  by
landfilling.

     Lead, used as the electrical contact  for graphite anodes, is
the major pollutant  found in process waste waters from diaphragm
cell plants where  graphite anodes are  used.   Conversion to metal
anodes has largely eliminated  the source  of  lead  in raw wastes.
Although not all diapnragm cell  plants  treat   for  lead  removal,
treatment  usually consists of sulfide  or  carbonate precipitation
and  settling.   Table  11-27 shows   lead   and  suspended  solids
effluent  loadings  at  several   diaphragm  cell  plants.   Both
graphite and metal anode plants  are  shown.

     BPT technology for  waste water  treatment  and  control  at
diaphragm cell  chlorine plants   has  been specified  as asbestos
removal from wastes and containment   of  lead-bearing waste waters
followed   by   carbonate  precipitation   and   settling  before
di scharge.

     The pollutants  previously   regulated   at  diaphragm  cell
chlorine   plants  are  suspended  solids   and   lead.   Priority
pollutants  other  than  lead  that   were   found  at  significant
concentrations  in  the  screening and  verification programs were

                               179

-------
 1ABLE 11-27.     EFFLUENT LOADINGS FRCM SELECTED  CHLOR-ALKALI DIAPHRAGM CELL
                 PLANTS*

Plant
#589 **
# 738 **
#261 **
#014 **
#967
#207

Plant
#014 **
# 207
Lead
Average
0.002
0.001
0.0025
0.006
0.0085
0.021
Suspended
Average
2.81
0.30
Waste Load kg/kkg
Maximum
0.030
0.015
0.019
-
0.024
0.054
Solids Waste Load kg/kkg
Maximum
-
0.57
 * See Reference 3
** Plants using metal anodes.
                                    180

-------
identified as antimony, arsenic, chromium,  copper, and nickel.

     Carbonate precipitation  is known  to  be effective for removal
of  some  trace metals. During  the  sampling   programs,  only one
diaphragm  cell  plant employing   this  treatment  for  lead  was
visited.  Table 11-28  presents  the   priority  pollutant removal
efficiencies and effluent loads observed   during  the sampling of
that plant.

Base Level Performance Characteristics for  BPT Pollutant  Removal

     Table 11-29  presents  effluent   quality  achievable   through
implementation  of BPT or Level 1  treatment technologies   for and
diaphragm cell chlorine plants.


Base  Level Performance  Characteristics  for  Priority  Pollutant
Removal

     Also presented  in Table  11-29 is  the estimated  achievable
effluent  qualities for priority pollutants with  BPT technology.
Not  included  are  estimates  for  the   removal  of  chlorinated
organics or asbestos.  Although only limited data  are available,
it is not anticipated  that chlorinated  organics will be   reduced
significantly  with  BPT  treatment.    Due   to  uncertainties  in
analytical   procedures,  achievable   asbestos  loads  using  BPT
technology are being reserved at this  time.


Pretreatment Applications

     Several chlor-alkali  plants  presently discharge all or part
of  their process  waste water  to POTWs.   Pollutants present  in
chlorine  process  wastes  which   require   pretreatment   include
mercury, lead, and chlorine.  In addition,  some control of pH and
suspended solids is required.

     On the basis of the effluent  quality  achievable through  the
application of BPT technology, as  presented above, BPT technology
is also recommended for pretreatment.


11.4.3 Estimated Performance  o_f Advanced  Level Systems

Advanced  Level   Performance  Estimates   for   BPT  and  Priority
Pollutant Removal

     The advanced treatment performance estimates presented below
include  estimates   for  chlorine discharges.   Although   this
parameter  was  not regulated in   previous guidelines,  and  most
chlorine  plants reuse or  sell their  chlorine-laden waste water,
the technology for chlorine removal has recently been established

                               181

-------
TABLE  H-28.    PRIORITY POLLUTANT REMOVAL AT LEAD TREATMENT FACILITY
                PLANT*967
Pollutant   o
£low =1.0 mVkkg
     Pollutant Loads  kg/kkg
Influent                Effluent
Average                 Average
Removal
Antimony, Sb
Arsenic, As
Qiromium, Cr
Copper, Cu

Mercury, Hg
Nickel, Ni
Zinc, Zn
Lead, Pb
Thallium, Tl
0.00078
0.00032
0.00016
0.0049

0.000026
0.00069
0.0016
0.733
< 0.00004
0.00005
0.00037*
0.00005
0.00003
*
0.00005
< 0.00005
< 0.0001
0.029
0.00015*
93.6
—
68.7
99.4

—
>92.8
>93.8
96.0
__
 Effluent is greater than influent.
                                  182

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           TABLE 11-29  CONTROL PARAMETER  LIMITATIONS
             SUBCATEGORY: Chlorine - Diaphragm Cell
                      Level of Treatment:  1
                  Waste Water Flow: 12.8 m3/kkg
                                   Quality  Limit   Emission Limit
               Subcategory     (1)      (mg/1)           (kg/kkg)
Pollutant      Performance   VFR   	   	
                  (mg/1)            30  day   24  hr   30 day  24 hr
                                    Aver     Max      Aver    Max
BPT Pollutants:
Total Suspended              2.0    37.5     75        0.48    0.96
Solids, TSS

Lead, Pb                     2.0      0.6     1.2       0.008   0.016

Proposed Priority
Pollutants
Antimony, Sb
Arsenic , As
Chromium, Cr
Copper, Cu
Nickel, Ni

<0.
0.
0.
0.
0.

05(2)
25(2)
04(2)
03(2)
05(2)

2.
2.
2.
2.
2.

0
0
0
0
0

0.
0.
0.
0.
0.

8
5
1
5
5

1.
1.
0.
1.
1.

6
0
2
0
0

0.
0.
0.
0.
0.

01
006
0013
006
006

0.02
0.012
0.0026
0.012
0.012
   (1) - VFR: ratio of the  24 hour variability factor to the
            30 day variability  factor.
   (2)  Verification Sampling
                               183

-------
for  this  subcategory  and   therefore   achievable limitations are
recommended .

     Tables 11-30 and 11-31  present  estimated  achievable effluent
quality through implementation  of  advanced  technologies.

New  Source Applications

     Examination of  the   waste   water  control  and  treatment
alternatives applicable to new  chlor-alkali facilities has led to
the  following  conclusions:

     All  new   sources should incorporate metal anodes rather than
graphite  anodes.  All new sources  should provide for  alternative
uses or provide for decomposition  of chlorine-bearing wastes.

     Diaphragm cell plants should  provide treatment equivalent to
level 2 technology, providing better control of solids and lead.

Response  to Remand  Issues

     Zero-discharge limitations    origin-ally    proposed   for
chlor-alkali   plants were remanded primarily because no plant was
shown  to  achieve  zero  discharge.   The   proposed  alternative
advanced  treatment  levels provide  for  waste water discharge.


11.4.4 Cost Estimates
Discussion

     On  the  basis  of  the  model  plant specifications and treatment
system design   concepts presented  earlier,  the  estimated control
costs for three production  rates  at  diaphragm cell  plants  are
given  in Tables 11-32  through 11-34.   The  costs shown at  each
level of  treatment correspond   to  the  model  plant  BPT system
(Level 1)  dnd  one or more  alternative  BAT systems (Level 2, 3,
etc.)  whicn  may add to or modify the existing BPT system to  meet
more  stringent priority  pollutant  removal requirements. The BAT
systems  also provide  a higher  effluent water quality with respect
to the conventional and nonconventional parameters.

     Annual  treatment cost  as   a  function of production rate  is
shown graphically  in  Figure  11-20.   Similarly  presented is  the
relationship of   unit  cost  (treatment cost per  metric  ton of
product) to  production rate   Figure 11-21.    The estimated ranges
of total unit costs are shown  and  Table 11-35  presents a summary
of the unit  cost   distribution  between amortization and operation

-------
           TABLE 11-30  CONTROL  PARAMETER LIMITATIONS
             SUBCATEGORY: Chlorine  -  Diaphragm Cell
                      Level of Treatment:  2
                  Waste Water Flow:  12.8  m3/kkg
Pollutant
Treatability
    (mg/1)
                                   Quality Limit
                                 (1)     (mg/1)
VFR
                                       Emission  Limit
                                           (kg/kkg)
                                    30  day   24 hr   30 day  24 hr
                                    Aver     Max     Aver    Max
BPT Pollutants;

Total Suspended   15
Solids, TSS

Lead , Pb           0.3

Total Residual

Chlorine, C12      0.2

Proposed Priority
                2.0    15    30
                      0.19    0.38
                2.0     0.3     0.6    0.004    0.008
                2.0     0.2     0.4    0.0026   0.0052
Pollutants
Antimony, Sb
Arsenic , As
Chromium, Cr
Copper , Cu
Nickel, Ni

0.
0.
0.
0.
0.

4
1
05
1
1

2.
2.
2.
2.
2.

0
0
0
0
0

0.
0.
0.
0.
0.

4
1
05
1
1

0.
0.
0.
0.
0.

8
2
1
2
2

0.
0.
0.
0.
0.

005
0013
0006
0013
0013

0.01
0.0026
0.0013
0.0026
0.0026
  1 - VFR: ratio of the 24 hour variability factor to the
            30 day variability factor.
                               185

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          TABLE 11-31  CONTROL  PARAMETER LIMITATIONS
            SUBCATEGORY: Chlorine  -  Diaphragm Cell
                     Level  of Treatment: 3
                 Waste Water  Flow:  12.8  m3/kkg

Poll utant

ireataoii icy
(mg/1)
Quality Limit
(1) (mg/1)
30 day 24 hr
Av e r Ma x
Emission Limit
(kg/kkg)
30 day 24 hr
Av e r Max
BPT  Pollutants;

Total  Suspended   15
Solids, TSS

Lead,  Pb           0.2

Total  Residual

Chlorine,  C12      0.2

Proposed Priority
2.0    15
30    0.19    0.38
2.0     0.2     0.4  0.0026   0.0-052
2.0     0.2     0.4   0.0026   0.0052
Pollutants
Antimony, Sb
Arsenic, As
Chromium, Cr
Copper, Cu
Nickel, Ni

0.
0.
0.
0.
0.

4
05
05
05
1

2.
2.
2.
2.
2.

0
0
0
0
0

0.
0.
0.
0.
0.

4
05
05
05
1

0.8
0.1
0.1
0.1
0.2

0.
0.
0.
0.
0.

005
0006
0006
0006
0013

0.
0.
0.
0.
0.

01
0013
0013
0013
0026
  1 -  VFR:  ratio  of  the  24 hour variability factor to the
            30  day variability factor.
                               186

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               TABLE 11-32 MODEL PLANT TREATMENT COSTS
Subcategory CHLORINE Diaphragm cell
Production 19,100 metric tons per year
54 metric tons per day
Waste water flow 68 cubic meters per day.
A.
B.
C.
INVESTMENT COST
Equipment in place,
including piping,
fittings, electrical
Monitoring equipment
Engineering design
Inc identals , overhead ,
fees, contingencies...
TOTAL INVESTMENT COST
OPERATION AND
MAINTENANCE COST
Labor and supervision.
Chem ical s 	

Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis
TOTAL OPERATION AND
MAINTENANCE COST
AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
FIRST
$57,100
106,850
9,000
34,590
34,590
21,000
$263,130
$112,000
2,200
1,500
24,213
7,893
5,800
15,000
$168,606
$39,394
$208,000
Type of Regulation BAT
( 21,057 tons per year)
( 60 tons per day )
LEVEL OF TREATMENT*
SECOND THIRD
$1,800 $2,250
17,900 20,400
3,940 4,530
3,940- 4,530
$27,580
$14,000
300
2,758
827
7,500
$25,385
$4,487
$29,872
$31,710
$14,000
300
100
3,171
951
7,500
$26,022
$5,159
$31,181
*First level represents the  base  cost  of  treatment  system.
Other levels represent the  incremental cost  above base  cost.
                                187

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               TABLE 11-33 MODEL PLANT TREATMENT COSTS
Subcategory CHLORINE Diaphragm
Production 95,500 metric
272 metric
Waste water flow 340 cubic m
A. INVESTMENT COST
Equipment in place,
including piping,
fittings, electrical
work and controls.....
Monitoring equipment
Engineering design
Incidentals , overhead ,
fees , contingenc ies . . .

TOTAL INVESTMENT COST
B. OPERATION AND
MAINTENANCE COST
Labor and supervision.
Enerqy 	


Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis

TOTAL OPERATION AND
MAINTENANCE COST
C. AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
cell
tons per year
tons per day
eters per day.
FIRST
$148,100
219,700
9,000
75,360
75,360
63,000

$590,520
$112,000
4,900
7,500
52,752
17,715
29,000
15,000

$238,867
$85,827
$324,694
Type of Regulation
( 105,288 tons per yea:
( 300 tons per day
LEVEL OF TREATMENT*
SECOND
$2,900
27,000

5,980
5,980

$41,860
$14,000
600

4,186
1,255
7,500

$27,541
$6,810
$34,351
BAT
r)
)
THIRD
$3,350
29,500
9
6,571
6,571

$46,002
$14,000
600
500
4,600
1,380
7,500

$28,580
$7,484
$36,064
*First  level  represents the base cost of treatment  system.
Other levels  represent the  incremental cost above base cost.

                                188

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                    TABLE U-34 MODEL  PLANT TREATMENT COSTS
   Subcategory  CHLORINE  Diaphragm  cell

   Production
                                                   Type of Regulation  BAT
                  191,000  metric tons per year ( 210,577 tons per  year)
                      545  metric tons per day  (     601 tons per  day )
Waste water flow      680  cubic  meters per day.
A.  INVESTMENT COST

    Construction  	
    Equipment in  place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals,  overhead,
    fees, contingencies...
    Land	
B.
 TOTAL  INVESTMENT  COST

 OPERATION AND
 MAINTENANCE COST

 Labor  and supervision.
 Energy	
 Chemicals	
 Maintenance	
 Taxes  and insurance...
 Residual waste
 disposal	
 Monitoring, analysis
 and  reporting	
    TOTAL OPERATION AND
    MAINTENANCE COST

C.  AMORTIZATION OF
    INVESTMENT COST

    TOTAL ANNUAL COST
                                                   LEVEL OF TREATMENT*

                                          FIRST          SECOND           THIRD
$271,900



 295,500

   9,000

 115,280

 •115,280
 123,000

$929,960
$112,000
   8,000
  15,000
  80,696
  27,898

  58,000

  15,000


$316,594


$131,292
                                    $447,886
 $4,800



 43,500



  9,660

  9,660


$67,620
                                                        $14,000
                                                            600

                                                          6,762
                                                          2,028
  7,500


$30,890


$11,001
                  $41,891
    *First level  represents  the base cost of treatment system.
    Other levels  represent the incremental cost above base cost,
                                                                      $5,250



                                                                      46,000



                                                                      10,250

                                                                      10,250
                                                                        $71,750
                $14,000
                   600
                  1,000
                  7,175
                  2,152
  7,500


$32,427


$11,673

$44,100
                                     189

-------
   500
   400
o
o
o
H
g'  300

U
D
2
2
   200
   100
         !V
                     1  1
                   I/
                  /I
                 /
                /   /
                             A
                                        *
LEyELS #2
                                     X
                                         LEVEL;
                                      r
                                     A
                                                      #3
               50       100       150       200

                  PRODUCTION, METRIC TONS/YEAR X 1000



Figure 11-20.  Annual treatment cost vs. production for the Chlorine

                  Subcategory (Diaphragm Cell  Process)
                                190

-------
   12
   10
U
w
ft
CO
              50       100        150       200

                  PRODUCTION,  METRIC TONS/YEAR X 1000


  Figure 11-21.  Annual unit treatment cost vs.  production for the

               Chlorine Subcategory (Diaphragm Cell Process)
                               191

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                TABLE  11-35   MODEL PLANT TREATMENT COSTS
Subcategory  CHLORINE   Diaphragm  cell
                              Type of Regulation  BAT
                                           Annual Treatment Costs ($/kkg)
                                                 LEVEL OF TREATMENT

                  PRODUCTION  FLOW      FIRST     SECOND    THIRD    FOURTH
                  (kkg/yr)  (m3/day)      $         $         $         $
Annual Operation
and Maintenance
Annual
Amortization
Total  Cost
 19,100
 95,500
191,000
 19,100
 95,500
191,000

 19,100
 95,500
191,000
 68
340
680
 68
340
680

 68
340
680
 8.83
 2.50
 1.66
 2.06
 0.90
 0.69

10.89
 3.40
 2.34
1.33
0.29
0.16
0.23
0.07
0.06

1.56
0.36
0.22
1.36
0.30
0.17
0.27
0.08
0.06

1.63
0.38
0.23
  Not
Applicable
                                 192

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Summary

     Although chlorine  manufacture  usually produces  three waste
streams, only the brine  mud and metal   or  asbestos  contaminated
wastes  are   considered  as  contributing   to  waste  flows and
treatment costs. Tail  gas  scrubber  wastes,   typically  high  in
sodium hypochlorite, are usually sold or returned to process, and
are therefore excluded from waste  flows  and waste treatment costs
for  the  model  plants.   however,   for the    range  of  annual
production in metric tons from 31,850 to 190,750, the annual cost
of  decomposition  of  sodium hypochlorite   varies from  $1.26 to
$4.30 per metric ton of product  (3).

     The chlorine subcategory is a multi-product  industry, since
caustic  soda is a by-product  of  chlorine  manufacture by  either
process.   In  this  report investment costs and annual costs are
expressed in  terms of treatment cost per metric ton  of chlorine
production,  without considering the  production or  value  of the
by-product caustic soda.

     In this  report brine mud   is presumed to be left on-site in
accordance with  current practice  at  many   chlorine plants.  For
neutralization,   it  is  assumed  that   waste  sulfuric acid is
available at the plant at no cost.

     Diaphragm eel 1 base  level BPT  costs   - Waste treatment cost
summary  sheets  for  three  chlorine  production  rates by the
diaphragm  cell  process are included as Tables 11-32, 11-33 and
11-34 respectively. Base level costs  are shown as the First Level
of treatment.   The unit costs of  BPT treatment per metric  ton of
chlorine production in Figure 11-21  are  shown  as the upper  curve,
varying from $2.19 to $9.97 per metric ton.

     Diaphragm cell  advanced ley_e_l  costs - Waste treatment cost
summary Tables  11-32,  11-33,   11-34  show  incremental advanced
level  costs in the column marked  "second"  and "third".  The unit
costs per  metric ton  of chlorine production,  at first, second,
and third level costs, are shown by  the   curve (Level 1, 2, and 3
Diaphragm Cell on Figure 11-21).

     At the second level, the incremental cost  varies from $2.37
to  $11.36.   There is insignificant  difference in  cost between
second  and third levels. Hence, these two  levels are represented
by the same curve on Figure 11-21.
                                193

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                          SECTION  12
                  HYDROFLUORIC ACID  INDUSTRY
12.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL
12.1.1 Industry Profile and Analytical  Results

    Hydrofluoric acid  (Hydrogen  fluoride-HF)  is produced both as
anhydrous and aqueous products.   It  is  used  in the manufacture of
fluorocarbons  which  are  used   as    refrigerating  fluids,  and
plastics, for pressurized packing  and   as  dispersants in  aerosol
sprays.   It  is used   in  the  production of   aluminum,  in  the
refining and enriching  of  uranium  fuel,   pickling of  stainless
steel, in  petroleum  alkylation,  and   for   the  manufacture  of
fluoride salts.

    The industry data  profile  is  given in  Table 12-1,  while the
existing regulations are given  in  Table 12-2.

    The priority pollutants  found   at  significant concentrations
in the raw waste during sampling   at hydrofluoric acid Plant #705
were later verified at  three  other plants.  The results  were:


                  Maximum Concentration Observed
                                 ug/1
         Pollutant           Screening       Verification
                                              (3 Plants)
Copper
Lead
Selenium
Zinc
Antimony
Arsenic
Cadmium
Chromium
Mercury
Nickel
Thallium
770
5190
25
8120
70
10
2
73
2
150
5.5
595
199
234
11313
2805
158
20
1180
43
2005
63
                              194

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TABLE  12-1
SUBCATEGORY PROFILE DATA .SUMMARY
SUBCATEGORY
HYDROFLUORIC ACID
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           363,000 kkg/year
                           261,800 kkg/year
                                14
                           177,000 kkg/year

                                68 percent

                             7,300 kkg/year
                            62,000 kkg/year
                            22,100 kkg/year
                            15,800 kkg/year
                                83 percent

                                 7 years
                                58 years

                                 0 cubic rasters/day
                             4,700 cubic meters/day

                                 0 cubic meters/kkg
                                86 cubic meters/kkg
Sources of data are Stanford Research Institute,  Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Conmerce,  Current Industrial
Reports, December 1977; Energy and Environmental  Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   195

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12-2  -
                 EXISTING REGULATIONS  -  EFFLUENT .LIMITATION GUIDELINES
SOT3CATEGORY       Hydrofluoric Acid

SUBPAKT           H  (40 CFR  415.80, 3/12/74)
STANDARDS
Product
Process
Hydro-
fluoric
Acid
BFCTCA*
1 2
Max. Avg.
Para- kg/kkg k/kkg
meters (mg/1) (mg/1)
Fluoride (30)
(15)
BATEA*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp 3
NSPS*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
, No discharge
of pwwp
TSS
                (50)
                                (25)
No discharge
of pwwp
No discharge
of pwwp
 Sections 415.82,  415.83,  and 415.85 were remanded and are presently
 reserved (41 FR 51601, November 23, 1976) .
 Max, = Maximum of any one day.
 2
 Avg. = Average of daily values for thirty consecutive days shall not exceed.

 pwwp = Process wastewater pollutants.
                                    196

-------
     A summary of  daily and unit  product  raw waste loads for all
plants sampled can be  found in Table  12-3.   Individual plant raw
waste  loads per  unit product found  in  sampling can be  found in
Table 12-4.

     Based on the total annual production  of  this subcategory and
the average waste load generated   per  unit product, the estimated
total priority pollutant raw waste loads   generated each year for
this subcategory are as follows:


          Pollutant       Waste Load  (kg/year)
Copper
Lead
Selenium
Zinc
Antimony
Arsenic
Cadmi urn
Chromium
Mercury
Nickel
Thallium
7300
2000
260
11000
7900
1500
71
6300
170
113000
550
12.1.2 Process Waste Sources and Waste Water  Treatment Data
General Process Description

     Raw mater ial and  process - Hydrogen   fluoride   is  the most
important manufactured compound of  the   fluorine  family in  volume
of production.  Fluorspar  (mainly CaF2)  and  sulfuric  acid are the
raw materials used for its manufacture.  The  reaction  is given as:
     CaF2 + H2S04 +  heat = CaS04  +  2HF         (1)


     Crude fluorspar, as mined, varies  in  CaF2  content from  50 to
90 percent.  The ore is upgraded by  flotation which results  in 98
percent calcium fluoride being  available   for  the production  of
hydrofluoric acid.

     The reaction kinetics and  the  yield   of  product depends on
the purity and  fineness  of  the fluorspar.   The concentration of
sulfuric acid, the temperature  of the  reaction, and the ratio of
sulfuric acid  to fluorspar,  are  among the  important variables.
The analysis of the fluorspar  (average)  is given as:


                               197

-------
     TABLE  12-3 .   SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING
00

SUBCATEGORY
Pollutant
Priority
Antimony, Sb
Arsenic, As
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel , Ni
Selenium, Se
Thallium, Tl
Zinc, Zn
Conventional
TSS
Fluorine, F
HYDROFLUORIC ACID
Minimum

0.015
0.012
0.0036
0.14
0.60
0.10
0.0027
0.14
0.016
0.0054
0.49
13587
497
kg/day
Average

1.63
0.46
0.011
1.73
1.42
1.74
0.056
3.90
0.066
0.084
21.1
132789
2971
Maximum

6.44
1.12
0.017
5.49
2.80
5.62
0.20
13.0
0.12
0.16
72.1
247438
7891
Loadings
Minimum

0.0003
0.0003
0.0001
0.0043
0.015
0.003
0.00008
0.0004
0.0005
0.00016
0.014
170
14.6
kg/kkg
Average

0.03
0.0056
0.00027
0.024
0.028
0.046
0.00065
0.051
0.001
0.0021
0.41
2711
45.4
No. of Plants
Maximum Averaged

0.12 4
0.012 3
0.00031 3
0.06 4
0.051 4
0.165 4
0.002 4
0.14 4
0.002 3
0.003 2
1.33 4
5702
86.9

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TABLE 12-4 .    PRIORITY POLLUTANT RAW WASTE LOADS (in kg/kkg of Product)

SUBCATEGORY
POLLUTANT

Arsenic, As
Copper, Cu
Lead, Pb
Nickel, Ni
Selenium, Se
Zinc, Zn
Cadmium, Cd
Chromium, Cr
Mercury, Hg
Antimony, Sb
Thallium, Tl




HYDROFLUORIC ACID

#705
0.003
0.027
0.003
0.004
0.0005
0.269
0.0001
0.0043
0.00008
0.0016

PLANT
#705

0.018
0.0075
0.032

0.014
0.0004
0.018
0.0004
0.0004


# 251
0.012
0.015
0.0098
0.143
0.0013
0.031

0.06
0.002
0.0003


# 167
0.0045
0.051

0.025
0.0012
1.33
0.00031
0.012
0.00011
0.118
0.003
                                  199

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            CaF2      Minimum 97.5-98%
            S102      Maximum 1.0%
            S           "     0.05%
            H20         "     0.1%
            CaCOS     Principal  remainder


    Sulfuric acid with  a concentration  as  low as 93 percent  or
as high  as 99 percent  is generally  used.    Dilute sulfuric acid
enhances  better  mixing and liberation   of   fluoride but has two
disadvantages. The first disadvantage  is  that the dilute acid  is
very  corrosive  and  the second  disadvantage is  that  the water
present in the acid evaporates and distills  off with the hydrogen
fluoride  gas, thus reducing product  concentration.  Concentrated
sulfuric   acid   (greater  than   98  percent)    offsets   these
disadvantages but  creates  new problems.  The vapor pressure  of
concentrated sulfuric  acid is  sufficiently high  to cause large
amounts of  sulfuric acid  to be  carried  away by the hydrofluoric
acid.   Excess  sulfuric  acid,   when  used,  will leave with the
gypsum as part of the residue.

    The reaction   between  fluorspar and   sulfuric   acid  is
endothermic.  The  reaction time  varies   and  is  usually between
20-60 minutes with the temperature of  the reaction around 200-250
degrees C.

    Hydrogen fluoride  generators are, in the majority of cases,
externally  fired  rotary  kilns  with acid  and  fluorspar  fed
continuously  (through a screw conveyor)  at  the  forward end  and
calcium   sulfate (gypsum) removed from   the other end through an
air lock.   The  product also  leaves  this end,  at the top, as a
gas.   The theoretical amount of  calcium  sulfate produced is  3.4
kg/kg of HF produced,  but  because   of   the  impurities  in  the
fluorspar the actual  amount  produced is higher and varies from
3.6 to 4.0 kg of crude calcium sulfate per kg of HF produced.

    Silica is  a highly  objectionable contaminant,  since  each
pound consumes 2.0 pounds of fluorspar and 3.3 pounds of sulfuric
acid by the following reaction:


    Si02 + 2CaF2 + 2H2S04 = SiF4 +  2CaS04 + 2H20       (2)
     One manufacturer  uses  a   patented  process to supply internal
heat  to  the reactor.  The  heat  is  supplied by introducing sulfur
trioxide   (S03)  and   water   (as   steam).    The  exothermic  heat
liberated  by the reaction of  S03   and water is used for the  heat
required for  HF generation.   Thus  a  part  of the sulfuric acid is
supplied as S03.


                               200

-------
     The hydrogen fluoride gas  leaving  the reactor is cooled in a
precooler to condense high  boiling  compounds.   The condensables
are known as drip acid and largely  consist of fluorosulfonic acid
(HS03F) and unreacted  sulfuric  acid.   Nine plants out of a total
of eleven return  the drip  acid  to  the reactor, while the  other
two send the drip acid to the waste  treatment plant.  The HF gas
from  the   precooler  is  further   cooled  and  condensed  in  a
cooler/refrigeration unit.  The  uncondensed gas containing the HF
is  scrubbed  with sulfuric acid  and  refrigerated to recover the
product.  The scrubbed acid  liquor  is  returned to  the kiln, and
residual vent gases are  further  scrubbed  with water to remove HP
and  other  fluoride  compounds   before  they  are  vented to the
atmosphere.  The  scrubber  water   is   sent  to the  waste  water
treatment plant.   Figure  12-1   is  a  block  flow diagram  of the
manufacturing process.

     The crude  hydrofluoric acid is then  distilled to remove the
residual  impurities,  and  the  condensate,  which  is  anhydrous
hydrofluoric,  is stored in  tanks.  If aqueous  hydrofluoric  is
desired, this is then diluted with  water to form a 70 percent  HF
solution as the final product.


Water Use and Waste Source Inventory

     Water Use - Water is used  in hydrofluoric acid production in
noncontact  cooling,  air  pollution  control,  product dilution,
seals on pumps and kilns,  and   for  equipment and area washdown.
Although noncontact  cooling  constitutes  the major use of water,
water  is  also used, in a majority  of  cases, in the transport of
gypsum as  a  slurry to the waste water  treatment  facility. The
water for gypsum transport is provided  by   either  recycling the
water from  the  treatment  facility  or  by  using  once-through
cooling  water.  Table 12-5  summarizes the  water usage found in
this study.

     Waste Sources

     A.  Gypsum  solids:   Gypsum   solids   are  generated  as  a
by-product.  The  amount  produced  is  in the range of  3.6  - 4.0
kg/kg of HF  produced.  The gypsum  also contains small amounts of
sulfuric acid,  hydrofluoric  acid  and   calcium fluoride.   Minor
amounts of other impurities present  in  fluorspar are also removed
with  the  gypsum.  In  seven   out   of   eleven  plants  producing
hydrofluoric acid, the gypsum is  slurried   with water and sent to
the waste  water treatment facility.  Three  plants transport the
gypsum as  a dry solid and  dispose  of  it   as a solid waste after
mixing with lime for neutralization.  The  disposal method of one
plant is not known.

     B.  Drip acid:  This is  formed in  the first  stage of the
cooling (i.e., in  the precooler) of  the  gases emitted from the

                                201

-------
                         SOLFURIC
                           ACID
                        FLOORSPAR
SLURRY WATER
                   	 CALCIUM
                    SULFATE  (GYPSUM)
                         SOLIDS
            TO WASTE
NON-CONTACT
  COOLING
   WATER
                     NONCONTACT
                     COOLING OR
                   REFRIGERATION
                       SYSTEM
 WATER'
            EJECTOR
               "I
            WASTE WATER

               TO
           TREATMENT
                                                                                     WATER
                                                          WATER
                                                        SCRUBBER
                                                                                  WASTE WATER
                                                         TO STORAGE (OR
                                                         RECYCLED TO KILN)
                                                       LEGEND
                                                       COMMON  PRACTICE

                                                       INTERMITTENT
                                                       PROCESS (OR PRO-
                                                       CESS AT ONLY
                                                       SOME PLANTS)
               Figure 12-1.   General process flow diagram for production of hydrofluoric acid.
                                               202

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TABLE  12-5. WATER USAGE  IN THE HYDROFLUORIC ACID SUBCATEGORY


                                 Water Usage at Plant
                                    fm /kkg of HF)

Source          #987  #251    #753  #426  #120    #722    #167   #705
Non-contact       NA    154     63.5    110    NA     13.6   116.5    30
  Cooling

Gypsum Slurry     64             NA      -     NA     22.5    41.6    30
  Transport

Maintenance,       2.4   NA      2.11    NA   0.1     12.2     5.0    16.9
  Equipment and
  Area Washdown

Air Pollution     14.4     7.9   4.23    -    0.586   14.45   19.31    11.25
  Control
NA = Not Available.
                                   203

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                                                       consisting
                                   fluorosulfonic  acid,  and small
                                   sulfuric   acid,    and   water.
                                   reaction   between hydrofluoric
                                   The   quantity   of  drip  acid
kiln. Drip acid mostly contains high  boiling  compounds
of  complex  fluorides, especially
amounts  of  hydrofluoric   acid,
Fluorosulfonic acid  is formed by
acid  and strong  sulfuric  acid.
produced is relatively small. Nine  out  of  eleven plants producing
HF  recycle the drip acid  back to the reactor.   In most cases, it
is  mixed with the sulfuric acid feed   stream  before it enters the
kiln  where  it   is  hydrolyzed    to   form   sulfuric  acid  and
hydrofluoric  acid.  The  critical   factors  for  hydrolysis  are
temperature and  retention time  and   enough   water  is  normally
present  in the kiln for the reaction.

     C.  Noncontact cooling  water:    Noncontact  cooling water is
used  for precooling the product gases emitted from the kiln.  The
possibility of product or other process compounds leaking into it
is  very  small, and this stream is relatively  unpolluted.  In some
plants the cooling water  is used to transport the waste gypsum.

     D.  Scrubber  waste  water: Scrubber  water is another  waste
water source, and  in  plants  which  practice  dry  disposal of
gypsum,  scrubber  water  constitutes  the  predominant and major
source   of    waste water.  It  contains  fluoride, sulfate,  and
acidity.   The fluoride is present  as hydrogen fluoride,  silicon
tetrafluoride  (SiF4),  and hexafluosilicic acid (H2SiF6).  Silica
present  in the ore as an  impurity reacts with HF  forming silicon
tetrafluoride as shown in Equation  3.
     Si02 + 4HF  =
                      SiF4   +  2H20
(3)
     In  the scrubber, a part of  the  tetrafluoride is converted to
hexafluosilicic acid according to  Equation 4.
     SiF4 + 2HF(aq)
                           H2SiF6  (aq)   (4)
The   scrubber  water consequently   needs   treatment  for fluoride
before discharge.

     E.  Distillation  wastes:   The distillation waste  generally
contains HF and water.     In  some  cases  the vent gases  from  the
distillation column are   scrubbed  before  they are  emitted to the
atmosphere, and the resulting  scrubber water requires treatment.
     The range of waste  water  quality of the  different
generated from the production of  HF  is summarized  in ^
The   data  are taken   from  the  prior development
Questionnaire responses, and  industry visits.
                                                          streams
                                                      Table 12-6.
                                                  documents,  308
                              204

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    TABLE  12-6.  WASTE FLOW FROM HYDROFLUORIC ACID MANUFACTURING PLANTS, m3/kkg OF HYDROFLUORIC ACID
                                                          Plants
    Source of
    Waste water          #251     #987      #753   #426      #120      #722     #167     #705   #837


    Gypsum Slurry         64.0     Dry        NA   Dry       Dry       (Total    41.6    (Total   6.5
                                   disposal        disposal  disposal  Recycle)          Recycle)

    Drip Acid              0.049    -         -     -         -          -        -       0.018


    Scrubber Waste water  14.4     8.3       2.3    -        0.624     (Total    40      11.25    1.12
                                                                      Recycle)

o   Other                  0.53    0.53      8.4    NA       5.55        NA       5.2    22.52     NA
    NA = Not Available

-------
Control and Treatment Practices

    Plant #705  combines  the  hydrofluoric acid wastes, including
the  gypsum slurry, with aluminum   fluoride waste.   The combined
waste  water, after neutralization,  is  sent to  settling lagoons
before discharge.  This  plant was  visited in  both the screening
and  verification phases of the  project and a  fuller description
of waste treatment practice  is given below.

    Plant #837  combines   the  gypsum  slurry  and  plant  area
hosedown waste  water  with  the   equipment washings,  leaks,  and
spills etc. from the aluminum  fluoride plant and neutralizes them
with lime.   The  solids are removed  in  settling  ponds  before
discharge.  The waste  water from  scrubbers of  both hydrofluoric
acid and aluminum  fluoride  plants  is  sent  to  an  adjoining
facility for use.

    Plant #251  also combines the  hydrofluoric acid and aluminum
fluoride waste water.  The suspended solids in the combined waste
water are  removed  in the  gypsum  ponds.   The  overflow from the
gypsum ponds is neutralized  and the  pH adjusted with the  waste
water  from  other products  which  are  manufactured  on the site.
The  plant  is  in  the process  of  installing  a  new proprietary
treatment  process to  further  reduce  the fluoride in its waste
waters.

    Two plants, #120 and  #987,   dispose of the kiln residue as a
solid waste after lime addition.  The waste water in  both  cases
is treated with lime and the solids are separated; in one case in
a clarifier  followed  by   a  filtration,   and  in  the other  by
lagooning.

    At Plant  #167,  the  combined   waste   water  (including  the
gypsum)  is  neutralized with  lime   and  then settled in  lagoons
before discharge.

    Plant #722 practices  complete  recycle.   The gypsum  slurry,
scrubber  water, and other  waste  waters are combined and treated
with caustic soda for neutralization.  The neutralized  solution
is settled in  lagoons and the overflow is treated with  muriatic
acid before being recycled  to the   scrubbers arid  to the kiln to
slurry the gypsum.

    Plant #426 disposes of  the  gypsum  solids from the kiln as a
solid  waste after lime addition.   The  scrubber water is used to
make another   product.     The   noncontact   cooling  water   is
neutralized when  required with   caustic soda and settled  before
discharge.
                               206

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Description of Plants Visited  and  Sampled

     Screening - Plant   #705 was visited and process waste  water
samples were collected   and  analyzed  for  classical and priority
pollutants.   The process  used  at  this site is similar to  the
conventional  HF  manufacturing process  described earlier.   The
drip acid  is sent to the waste water  treatment  facility  and the
gypsum produced from  the  reactor  is  slurried with water and also
sent  to the  treatment  facility.   The waste waters  from  the HF
production facility are  combined with  the aluminum fluoride plant
waste waters.  The combined  raw waste  water  is treated with lime
and sent   to settling  ponds before discharge. Figure 12-2  shows
the  general process  and  the locations of  the sampling points.
Table 12-7 gives  the flow  data and  the total   suspended solids
(TSS) and  fluoride emissions.

     Verification -   Plant  #705   was  repeat  sampled  in  the
verification phase  and  the  same streams sampled.  The  variation
in  the  flow  of  the   streams in the  two  sampling  phases was
negligible. Table 12-8 gives the TSS  and fluoride load summary of
the sampled streams.

     One more  HF   plant    (Plant 1251)   was  sampled  in  the
verification phase.  The drip  acid at  this facility  is also sent
to  the  waste  treatment  plant   and  the hydrofluoric acid waste
waters  are combined  with  aluminum   fluoride  plant  waste  for
treatment.   In  addition  to  drip acid,  the  plant waste water
consists of scrubber  water, gypsum slurry,  and  plant area hose
down.  The treatment consists  of gypsum ponds where the suspended
solids are  removed.  The  overflow from  the  last gypsum pond is
neutralized  and  the  pH  adjusted with wastes from other product
lines.  Figure 12-3 is a block diagram of the process showing the
sampling locations.  Table  12-8   gives  the summary of the waste
flow  data  and the  concentration and  loads  of  the important
classical  pollutants.


Evaluation of Production and Waste Flow Data

     When  gypsum solids  from the kiln  are slurried with water for
treatment, the  resulting  stream constitutes the  major source of
waste water.  When kiln  residue is disposed of as a  solid waste,
scrubber   waste water  is  the  major  source  of waste. Table 12-9
gives  the data for the  direct and .indirect process contact waste
water going to treatment facilities.  Noncontact cooling water has
not  been  included in the  figures given  in Table  12-9.  Figure
12-4 is  a graphical  representation   of production  versus waste
water flow going to  treatment  facility for plants whose  waste
water  includes  the  gypsum   slurry   and  for  those  practicing
disposal of kiln residue as  a  solid waste.
                                207

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                                                                 VENT
            FLUORSPAR
O
CO
                                                                  t         f
                                                        SCRUBBER
                           KILN
                                         FRESH
                                         WATER
                                       DRIP ACID
                            LL
                                                LIME
                                     e
                                         SURFfiCE DRAINS
                                         COOLING TCWER
                                            BLOWDOWN ,ETC.
&
                                                                                     Al(OH)
                                                                        PH3DUCT
                                                                           SETTLING PONDS
                                               VENT
                                       FRESHWATER  "
                                              e
Waste streams sanpled
                                             Figure  12-2.  General process flow diagram at Plant 5705 showing the sampling points.
                                                                            Hydrofluoric Acid Manufacture

-------
TABLE  12-7  FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
             STREAMS OF PLANT #705  PRODUCLNG HYDROFLUORIC ACID
Stream      Sampled        Unit Flow     Unit Fluoride     Unit SS
  No.       Stream        m3/kkg of HF    kg/kkg of HF   kg/kkg of HF
          Description
   1      Kiln Slurry      26.6               14.63          1360

   2      Scrubber Waste   10                  9.6              0.07
          Water

   3      Surface Drains   20                  6.9              3.92
          Cooling Tower
          Slowdown

   4      Treated Effluent  23.3                1.58             1.91
                                   209

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TABLE 12-8.  FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE STREAMS
            FOR PLANTS #705 AND #251 PRODUCING HYDROFLUORIC ACID
— —— — ~~~
Plant Stream Sampled Unit Flow
No. Stream m3/kkg of HF
Description
#705 1 Kiln Slurry 26.6
2 Scrubber Waste 10
Water
4 Surface Drains 20
Cooling Tower
Slowdown
5 Treated Effluent 23.3
#251 5 AHF Plant 1.2
Hosedown
6 S09 Scrubber 14.37
Waste
2 Gypsum Pond 82.3
Inlet
3 Gypsum Pond 82.3
Outlet
Unit Fluoride Unit SS
kg/kkg of HF kg/kkg of HF
3.8 4731
1.52 0.023
3.38 4.02
0.54 0.04
1.9 0.26
0.31 0.1
54 1533
26.5 0.8
                                   210

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I\J
H
                           VENT
                                                                                                                                                       I	WATER
                                                                                                         15 (J^^l HOSK DOWN WATER
                                                                                                                    NIF
                                                                                                            NEUTRALIZATION
                                                                                                                SYSTIM
EFFLUENT
                                                                                                                                                       Waste streams sampled.
                                                                                                            ALKALINE STREAMS
                                                                                                       AND ACID FRCM OfHER PLANTS
                            Figure 12-3.   General process flew diagram at Plant 1251  showing die sampling points.
                                                              Hydrofluoric Acid Manufacture

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TABLE 12-9.      WASTE WATER INFLUENT DATA TO TREATMENT FACILITY IN THE
                HYDROFLUORIC ACID SUBCATEGORY
Plant
#837
#705
#167
#722
#120
#426
#753
#987
#251
Kiln Residue
A
A
A
A
D
D
NA
D
A
Unit Waste Water Influent
to Treatment Facility
m /kkg of HF
120.6
58.2
166.4
49.4
9.08
0
11.1
13.61
82.4
A = Slurried with water.
D = Dry disposal.
NA = Not Available.
                                   212

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   15,000 t
  12,500 H
  10,000 -f
   7,500 4-
r-H
fa

(-1
to
   5,000 +
   2,500
   2,000


   1,000 -I-
                          O
                                                   0
                                                Dry Kiln Waste
                                          Slurrying Kiln Waste
      Figure  12-4.
          75      100             150            200
           HF Production,  kkg/day

Production versus waste flow data for HF plants.

             213

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Solid Waste Generation

    The  total  solids    generated   from  the  process  and  the
treatment  system  consist  of   gypsum  (CaS04)   and  the fluoride
precipitated as calcium  fluoride.   Table  12-10  gives the amount
of suspended  solids  going  to   the  treatment  facility (generated
from  the  process) and  the  quantity  of total suspended  solids
generated  at the  waste  water  treatment plant for  the HF  plants
visited  in screening  and verification.  It can be  seen from the
data that the gypsum  waste  is  the major source of solids produced
and constitutes   more   than   95 percent  of  the  total  solids
produced. Table 12-11 gives  the amount of gypsum solids produced
at different HF manufacturing  facilities.  It can  be  seen  from
the table  that the   gypsum solids  vary from 3.6 to 4.1 kg solids
per kg of product.


Process  Modifications and Technology Transfer Options

    1.   Gypsum  produced  in   the   kiln can be disposed of as  a
solid waste  instead   of  being  slurried with water and sent to the
waste water  treatment  facility. The  solids  in  this case  are
stored   in piles on   the land  surface  until alternative disposal
methods   are found or  the   site  abandoned.   Although  the  dry
disposal  method   is  labor  intensive (involving transporation and
landfill  operating cost), it  has been  found to be less expensive
due to  the  reduced   initial   capital  requirement and operating
costs relative to  the  wet   slurry  method which  requires  a more
extensive system of pipes,  pumps and on-site impoundments.

    2.   The use of   soda ash  in place of lime for neutralization
has some  advantages.   It eliminates or  reduces  the  problem  of
scale formation in the   pipelines and scrubbers when  the treated
waste water  is recycled.  It  offers a  faster reaction  time and
better control of  pH  than lime.  Even though the cost of soda ash
is higher  than  lime,  soda ash  has found to be a less expensive
alternative  at some  plants overall.  After the use of  soda ash,
the treated  effluent  water  can be  totally recycled, either to the
scrubber  or  to the kiln for  transportation water for the gypsum.
Soda ash  when added  to  raw waste  water, increases the pH  of the
stream.   As  the pH approaches  6, sodium  replaces calcium present
in  the   gypsum   waste.    This  frees  enough  calcium  ion  to
precipitate  fluoride  as calcium  fluoride.   Where the  scrubber
water is  the predominant source of   waste water, the water has to
be first  treated   with   enough  lime to  precipitate fluoride  as
calcium  fluoride.  Soda  ash can then  be added to the supernatant
to  precipitate calcium  followed  by  neutralization with HC1  to
reduce scaling problems.

    3.   Two   out of   a  total of  11  plants   manufacturing
hydrofluoric acid  send  the  drip acid to the waste water treatment
facility.   The  rest of the  plants  recycle  it to the  reactor.

                               214

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TABLE 12- 10.  SUMMARY OF SOLID WASTE GENERATED FROM THE HF MANUFACTURING
              PROCESSES AND TREATMENT FACILITIES AT PLANTS f 705 Aid #251
Plant         Gypsum Solids Going To        Total Solids Produced
                Treatment Facility               kg/kkg of HF
                   kg/kkg of HF
   #705               3300                          3377

   #251               1533                          1647
                                   215

-------
      '12-11.  GYPSUM SOLIDS PRODUCTION IN THE HYDROFLUORIC ACID SUBCATEGORY
                 Unit Kiln Residue Produced              Kiln Residue
Plant                     kg/kkg of HF             Disposal/Treatment Method
  #837                       3.86                              A
  #705                        NA                               A
  #167                       3.93                              A

  #722                        NA                               A
  #120                        NA                               D
  #426                       4                                 D
  #987                       4.13                              D

  #251                       4.0                               A
A = Slurried with water and  sent to wastewater treatment facility.
D = Dry disposal.
NA = Not Available.
                                   216

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When discharged to the waste  treatment system, the f 1 uorosulfonic
acid does not hydrolyze and leaves  with the treated effluent as a
complex  fluoride    in    soluble   form.    The   total   fluoride
concentration of  the effluent  will  be  higher  for  the  plants
discharging drip acid compared  to  those which do  not,  after the
same  neutralization treatment.    The two plants discharging drip
acid to waste, looked into the  feasibility of returning it to the
kiln, but because  of the unique design of the kilns, they  found
it to  be  economically unattractive.  Bench  scale studies  have
shown that the drip acid  can  be hydrolyzed to free the HF.


     HS03F + H20 +   heat =     H2S04   +  HF       (5)


     The two  plants  not  returning  the drip  acid  to  the kiln
should be able to  hydrolyze  the   material  in a  separate  unit
before  commingling  it   with  other   wastes, thus  avoiding  the
treatability problem associated with  complex fluorides.


Best Management Practices

     1.  Provision  can   be   made   to  collect  runoff  from  raw
material and product storage, process, and impoundment areas. It
should be treated  with   other  process waste  at the  waste water
treatment  facility.  Leachate  and   permeate  control needs to be
practiced  on  the solid  waste  stored in many plant  premises as
gypsum piles.  There is a risk  that uncontrolled stockpiling may
contaminate the local ground  water.

     2.  Ponds designed for solids  removal must be deep enough to
have a minimum of disturbance from  wind and rain.  Baffles can be
used to reduce the frequency  of wind-induced mixing, and episodes
of solids being  resuspended  and  passing  into the  effluent be
reduced.

     3.  Performance  evaluation and  review of discharge  quality
has  been  complicated    by   problems  associated  with  chemical
analysis.  Prior to  July 1976, the method generally used for the
analysis of fluoride in industry was   the specific ion  electrode
or  colorimetry.  This method  did  not detect the soluble complex
fluoride  species present in  the waste water.  The best method of
total  fluoride   detection    (free  as   well   as  complex) is
distillation  followed  by  analysis   using   the  specific   ion
electrode.  Using the distillation  method,  the complex fluorides
are hydrolyzed  and  the   resulting   HF  is  carried over with the
distillate  along  with any   free   HF  in the  sample.  Thus, the
method of total fluoride  analysis  used for effluent monitoring is
capable of  measuring free fluoride and  the fluoride  present in
the form of complex  ions  which  are  not removed by lime treatment.
Monitoring data on   effluent  fluoride levels  using the  revised

                                217

-------
method  are  likely  to  be higher   than   the  levels  previously
reported under the same treatment conditions.


Model Plant and BPT Level Treatment  System Specifications Process


    The proposed BPT model treatment  consists of:

A.   Slurry transportation of  kiln solids  to an equalization basin,
B.   Application of lime to precipitate CaF2,  followed by lagoon
    settling.
C.   PH adjustment before final  discharge.
D.   Scrubber, cooling and distillation wastes enter the
    equalization basin.
It is  assumed that drip  acid  is  recycled  to   the process
and does not appear directly  in the  waste  stream.
reactor
     For new  or   remodeled  production  facilities,  the NSPS model
treatment system  is based  on hauling  dry kiln residue directly to
a landfill. Miscellaneous  liquid   wastes in  the  NSPS model  are
subjected      to        two        stage       lime-soda       ash
neutralization/precipitation,  followed  by  filtration and partial
recycling of effluent  for  use  in  scrubbers.

     Waste water  flow  -  The   data   in  Table  12-9  for  plants
sending the gypsum solids  to the  treatment facility indicate that
the unit flow varies from  49.3 m3/kkg  of HF  to  166.4 m3/kkg of
HP.  For the model plants,   a  constant  unit flow of 43 m3/kkg  of
HF was assumed.

     HF production   - In   the HF subcategory, production  ranges
from a minimum of  7,300 kkg/year to  a  maximum of 62,000 kkg/year
with a mean  of 22,100 kkg/year and  a median of 15,800  kkg/year.
For waste water treatment  cost estimates, three production levels
were selected as  model plants. These are 19,000 kkg/year, 41,000
kkg/year, and 57,000 kkg/year.

     Waste water  pollutant  load     -  The amount of kiln residue
varies  from  3.6  to   4.1  kg/kg  of  HF  produced.  The waste water
going to treatment model plants is  assumed to contain 3.8 kg  of
solid kiln residue per kg  of HF.   Fluoride levels  in waste water
have shown to vary as  indicated below:
                               218

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12.2 TECHNOLOGY BASED POLLUTION ABATEMENT


12.2.1 Advanced Level Treatment Applications


Priority Pollutants to be Controlled

     Priority pollutants in  raw waste  waters and slurries typical
of the  HF industry  include   the   heavy  metals  often  found  as
impurities in fluorspar.   These  metals  are  zinc,  lead, nickel,
mercury,  chromium,  arsenic,  copper,   and  selenium.    Raw  waste
waters from plants practicing  dry  disposal of kiln   wastes may
include some  of  the  same  heavy  metals   in scrubber and  area
washdown  wastes, but in considerably  smaller  amounts, since the
spent ore is hauled as a solid waste and  bypasses the waste  water
treatment  facilities.  Although the fluoro-sulfonate complex  is
found in  HF wastes  containing drip   acid,  organic  compounds are
not anticipated in waste waters from this industry.


Removal Technologies Available

     Although alkaline  precipitation, sulfide precipitation, the
xanthate process, and ion exchange  might  be   applied  to clarified
solutions for control of metal ions, only alkaline  precipitation
can be readily used for slurried kiln  wastes from HF   production.
Sulfide  precipitation from  cleared solutions will  control  zinc,
lead, nickel, and copper and to a lesser  extent, antimony.


Selection of Appropriate Technology

     BPT (Level 1) - Neutralization with  lime, used  widely in the
HF  industry,  is  shown  as   the   BPT treatment,  principally to
control pH and the nonconventional  pollutant  - fluoride -  which
is precipitated as calcium fluoride.   Sufficient settled effluent
is recycled to transport kiln  waste to the  treatment facility as
a  slurry, and the remainder is adjusted  to  a pH between 6 and  9
before discharge.

     Level 2_  -  Treatment   is  alkaline   precipitation,  using
additional   lime  and  close  control of   pH  in   second-stage
neutralization,  followed by lagoon settling.  Sufficient lagoon
effluent  is recycled to  transport kiln   waste  to  the treatment
facility  as a slurry and the  remainder  is   filtered  to remove
finely divided metal hydroxides.

     Level 3_ -  It  is assumed  that 65 percent  of   the Level  2
effluent is  recycled for  transporting spent kiln  waste to the
treatment facility.  For  the  remaining 35  percent,  pH adjustment
and  sulfide precipitation are used ahead   of  the   Level 2 dual

                                219

-------
media filter, to react witn residual  lead,   copper,  nickel, zinc,
and  antimony which may not  nave  reached  their  optimum pH  levels
for  alkaline precipitation.

    Level 4_  - An alternative  for  Level  2,  Level 4  employs  soda
ash  instead  of lime for neutralization,  depending  on  the spent
ore  to contain enough  calcium to  precipitate calcium fluoride.
Use  of  soda  ash permits  increased   effluent   recycling without
scaling problems  associated  with  calcium  sulfate.  To  control
salinity  and sodium alkalinity  a  final effluent blowdown of at
least 10 percent of the  influent rate is maintained.   The common
heavy metals will be  precipitated  as carbonates  and hydroxides
with varying  degrees  of   effectiveness   at pH levels attainable
with soda ash.   The effluent  is  filtered  and adjusted to a  pH
between 6 and 9 before discharge  or process  recycling.

    New sources -  The chosen  NSPS treatment is dry handling and
off-site  chemical landfill   for  the  kiln   waste  and two-stage
alkaline precipitation with clarification and filtration for  the
liquid process wastes.  Heavy metal precipitation  with soda  ash
permits partial recycling  for uses  other  than slurry transport.


Flow Diagrams

    Flow sheets for the various  levels of treatment are:

    Level 1  (BPT)          Figure 12-5


    Level 2  (BAT)          Figure 12-6


    Level 3  (BAT)          Figure 12-7


    Level 4  (BAT)          Figure 12-8


    NSPS                   Figure 12-9


    Equipment functions -  Level  1, typical  of  existing treatment
facilities,  utilizes very   little equipment, but depends  on lime
neutralization in settling  lagoons, with  final  ph adjustment.

    In Level 2,  conventional  dual media filtration is  added to
the  Level   1  system.  In  Level  3,   standard  reagent mixing and
solution feeding units are  added  to the Level 2 system.  In Level
4/ which is  an alternate for  Level  2, the same  type of chemical
feed equipment is used for  soda ash as was used for lime in Level
2.   Conventional lagoons and  dual media filters are used in Level

                               220

-------
K)
NJ
H
                        LIME
                    RAW
              WASTE WATER
                                 EQUALIZATION
                                                                      RECYCLE FOR SLURRY TRANSPORT
                                                                                               LAGOON
                                                                       MIXING
                                                                                                LAGOON
                                                                                                                           pH ADJUSTMENT
T~^
                                                                                                                                     EFFLUENT
                                                                                                                                    	*-
            Includes flow monitoring, pH monitoring and sampler
                                                      Figure 12-5. vtaste water treatment Ijevel 1 for hydrofluoric acid subcategory.

-------
                                                          r
                                                                                  BACKWASH
        LJME
 NJ
 K)
 K)
RAW
                                    I
                                    I
                                   -cb-
WASTE WATER
                 EQUALIZATION
                                      •a-*1
^UXING
                                                                      RECYCLE FOR
                                                                  SLURRY TRANSPOR
                                                                    LAGOOK
         u
                                                                    LAGOON
                                                                                Q
ADJUSTMENT
                                                                                                                       FILTER
                                                                                                                                                        EFFLUENT
                    Includes flow monitoring,  pH monitoring and sampler
                                Figure 12-6. waste water treatment Level 2 for hydrofluoric acid subcategory.

-------











to
K)
(^j RAW


x-— -^


\ 	 '










LIME
1— Oh











1 	 © 	
1
1
1
1



?

\ /
A 1 Z_
WAbTK WATKH * 	 ' 1


EQUALIZATION 1
1 ^/->T 	











	

9
1
MIXII










1


M
r,





FEKI
SULI

__. BACKWASH
r

i .


1
1
1
1
1


V
/\


FILTEI




                                                                                                                                                      •EFFLUE
Includes flow monitoring, pH monitoring and sampler
               Figure 12-7- Waste water treatment Level 3 for hydrofluoric acid subcategory.

-------
              SODA ASH
      RAW
K)
     WASTE

      WATER
                                        •{*}-
                        EQUALIZATION
                                                                        LAGOOM
                                           "S—^
                                                    MIXING
                                                                        LAGOON
  RECYCLE: FOR   |
SLURRY TRANSPORT  RECYCLE TO
    I              I   SCRUBBER
                                                                                                        SUMP


, FILTER

X




1
V EFFLUENT
                              Includes flow monitoring, pH monitoring and sampler
                                          Figure  12-8.  Waste water treatment Level 4 for hydrofluoric acid subcategory.

-------
                                                                                                                                              IpH ADJUSTMENT
        LIME
Ln
                                                                                                                                            LAGOON     /
                         (SOLID WASTE)
                                                                                                                                                                      RECYCLE TO
                                                                                                                                                                        SCRUBBER
                                                                                                                                                                     *   EFFLUENT
                                  Includes flow monitoring, pH monitoring and sampler.
                                    Figure  12-9.  Waste water treatment new source performance  standard for hydrofluoric acid subcategory.

-------
4,  but special  attention to.   selection  of   materials is required
because of the high salinity of  recycled  effluent.   In the  NSPS
model, dry kiln waste disposal   is  recommended with   conventional
dry solids  handling  equipment.  Lagoons,  clarifiers, and filters
are  used  for   scrubber,    noncontact   cooling,    and   other
miscellaneous liquid wastes.   In  this  case,  equipment for storing
and handling the dry  Kiln  waste is   not  considered to  be waste
water  treatment, and  tne  cost   is   not   included   in  .the cost
estimates.

    Chemical handling - Lime  (as CaO)  is  the major  chemical used
in Levels 1 and  2, along with minor  amounts of hydrochloric acid
for final  pH  adjustment.    With  normal    precautions,   these
chemicals  pose  no special hazards.   In Level 3,  ferrous sulfide
is  prepared  on-site  by  mixing  sodium   bisulfide  and ferrous
sulfate.  Although sodium bisulfide  can release toxic H2S at  pH
levels below  7, the  hazard can   be  mitigated by   avoiding  acid
conditions  and by  providing  adequate ventilation.   After mixing
its components, the ferrous sulfide solution  is stable at the pH
levels employed  in the  process.  In  Level 4, only  the common
chemicals  sodium  carbonate   and  hydrochloric  acid  are  used,
without unusual safety hazards or special  handling problems.   In
the NSPS system  only  the  common chemicals lime,   soda ash and
hydrochloric acid are used,  introducing no   special problems  of
safety or handling.

    Separation and removal of sol ids  -  Solids are accumulated in
unlined   settlinglagoons.  ~Tn  Level  4,  calcium   fluoride  will
still precipitate  in the lagoons but  the  total sludge quantities
will be less  than in Levels   1,   2,  and 3   where   lime is  used.
Solids from  Level 4 treatment will be alkaline, very saline, and
difficult to consolidate.  Dry solids  from  the NSPS  model are not
subjected to treatment,  except  for  nominal  application of lime
before hauling in dry form to  an  approved  chemical landfill.

    Monitoring requirements   -   All  levels   of treatment  except
Level 4 require  monitoring  of  the  effluent  for  TSS, pH,  and
fluoride. Levels 2 and 3 should  be  monitored  in addition for the
toxic heavy metals, zinc,  lead,   copper,  chromium,  and antimony.
At the metal concentrations being  considered,  these  tests will
not be   field tests made  on  routine operational  samples.   To
achieve   desired accuracy, the   sampling should be  done  by "new
condition  equipment"  and  delivered   promptly  to   a  qualified
laboratory for anaysis by atomic  absorption  methods.


12.2.2 Estimated Performance o_f  BPT Systems

    Control and treatment practices  for  eleven plants producing
hydrofluoric acid are presented   in Table   12-12.  Also  indicated
are other product-related waste  water  sources and  pollutant loads
discharged.

                               226

-------
  TABLE 12-12.     SUM-1ARY CF WASTE WATER CCNTH3L AND TREATMENT TECHNOLOGY EMPLOYED AT ffifflRCFlLDEIC ACID HAN1S *
Plant    Product-Related
      Waste Water Sources
                               Control and Treatment  Amount of
                                Technology Employed    Treated
                                                    Waste Water
                                                       Recycled
                                                                  Cooler Bottoms  Effluent Volume    Average RDllutaut
                                                                                  in mVmetric ton   ^J5^ DisiaigaJ
                                                                                  (gal/short ton) of     >«5/™tric ton)
                                                                                  Actual Production  _  W««> lb)
                                                                                                     Fluoride    TSS
*426





Hydrofluoric acid
fluosilicic acids
production



Dry residue hauling 0
and duitping; neutrar
lization with caustic
of roncontact cooling
water and floor
drainage
Yes 465 (111,397) 1.2 ^
includes noncon-
tact cooling
water


  664    Hydrofluoric acid
         production
* 167    Hydrofluoric acid,
         fluorocarbon,
         Chlorine/sodium
         hydroxide, and
         hydrochloric acid
         production

* 120    Hydrofluoric acid
         production
  967    Hydrofluoric acid,
         fluorocarton,  and
         sulfuric  acid
         production
#928    Hydrofluoric  acid
         and aluminum
         fluoride production
  837    All hydrofluoric
         acid generated as
         used captively for
         aluminum fluoride
         production

  753    Hydrofluoric  acid
         production
* 251    HP, AlFj, chlorine/

         sodium hydroxide,
         aluminum oxide, and
         fluorocarton
         production

 f 705    Hydrofluoric acid
         and aluminum
         fluoride production
Residue slurry, neutra-   94%
lization with  sodium
carbonate, settling,
recycle
                                                                        Yes
Residue slurry, lime
treatment, settling,
recycle
                             Planned dry residue
                             handling, lime
                             treatment, clarification
                                                         47%
                                     slurry, settling  Present:  0
                             (Recycle and pH           Planned:  70%
                             polishing facilities            to  75%
                             under construction.)
                             Residue slurry, settling, 83%
                             recycle (Flocculation,
                             line treatment, and
                             clarification facilities
                             under construction.)

                             Residue slurry, lime       0
                             treatment, settling
                              Residue slurry, lime       65%
                              treatment, settling,
                              recycle, pH polishing
                                                                        Yes
                                                                        Yes
                                                                        Yes
                                                                        Yes
                                                                      Yes
                                     slurry, settling,  0
                             neutralization
  722    Hydrofluoric  and,
         in recent past,
         fluoboric,
         acid production
Residue slurry, lime  30% to  35%
treatment, settling,
recycle, pH polishing

Residue slurry, lime  92% to  100%
treatment, settling,
recycle, pH polishing
                                                                     Yes
                                                                                   5.78  (1,360)
                                                                        Yes       103  (24,200)
                                                                                       ND
                                                                                 11.0 (2,650)
                                                                   1 Kiln:  Yes    22.2 x 10
                                                                   3 Kilns: No    (553 x ^
                                                                                 25.9 (6,204)
                                                                                                         0.10    0.27
                                                                                                        18       0.45
                                                                                                          ND      ND
                                                                                  125 (30,000) •   Present:  24    16
                                                                                                  Expected
                                                                    additional1'8   2l1
                                                                    facilities

                                                    9.44 (2,260)    Present:  1     1.7
                                                                    Expected
                                                                    with .    o.65  0.75

                                                                    facilities

                                                    134 (32,200)           2.3     4.1
                                                                                                         0.64    0.3S
                                                                                                         46
                                                                                                                530
                                                                                                         3.2     O.M
                                                                                  0-10.3 (0-2,460)      0-0.81   0 to 0.54
  See Reference 3
                                                       227

-------
    It is clear from the table that a wide  variation in effluent
quality exists within this subcategory.   The  factors believed to
cause these variations are the following:

Dry Residue Handling

    The disposal  of  kiln  waste  by  dry  handling  rather  than
slurrying  is practiced  currently  at two   plants.   This process
eliminates the major  source of  waste  water  generated   at  most
plants,  greatly reducing the raw waste loads  to  be  treated.   The
only  sources of  waste water  remaining  are  from air  pollution
control and wasndown.

Effluent Recycle

    Recycle of treated  waste water for  slurry transport of  kiln
wastes is commonly practiced to varying degrees and  clearly has a
major effect on pollutant loads discharged.  Although  four  plants
do not  practice recycle,  it has been demonstrated   sufficiently
that  this  practice  is  both  technologically  and  economically
feasible.

Recycle of Condensables

    Recycling of drip acid or condensable cooler bottoms reduces
the  loading  of  fluoride  in  the  treated  effluent  since the
fluoride  species   (fluorosulfonic acid)  in  this  material  is not
removed by conventional lime  treatment.  Only two plants do   not
recycle drip acid .

Other Related Products

    Most hydrofluoric acid plants  also  discharge   wastes  from
related  products  such  as   aluminum  fluoride,  f luo rocarbons,
hexafluorosilicic and tetrafluoroboric acids to treatment.  These
other product wastes can account  for higher  raw  waste loadings
and increase the  potential for complex   fluorides  formation and
can also impact treatment efficiency  by  diluting  the raw waste.
In addition,  commingling of other product   wastes will  limit the
percentage of recycle of the total plane  treated  effluent.

    In addition  to the above factors,   the design  and  operation
of the  treatment  facilities affect  effluent quality.   Solids
removal  depends   on   retention   time   and   surge  capacity-
Precipitation of fluoride  requires careful   pH  control  and  in
areas of heavy rainfall or winds, adequate freeboard  or   multiple
ponds  are  necessary to  limit  the  discharge of high  pollutant
loads due to unfavorable climatic conditions.

    On the basis  of the preceeding discussion,   BPT  technology
for the Hydrofluoric Acid Subcategory is:
                               228

-------
     1.   In-process recycle of condensables  (drip acid).

     2.   Chemical treatment (with lime or  soda  ash)  of the
         waste waters for precipitation  of  fluoride.

     3.   Settling and retention of solids.

     4.   Recycle of at least 65 percent  of  treated waste  water
         for kiln waste slurry and transport.

     5.   pH adjustment of final effluent.


     Data from four plants practicing effective effluent  control
are summarized in Table 12-13.

     An alternative to the above is dry  handling  of  kiln  residues
and  lime  treatment   of  scrubber  and    washdown    wastes  for
precipitation of fluorides.


Base Level Performance Characteristics for  BPT  Pollutant  Removal

     Table 12-14 presents effluent•quality  achievable  through the
implementation  of  BPT  or  Level  1  treatment   technology  for
hydrofluoric acid plants.


Base  Level   (BPT)  Performance  Characteristics   for  Priority
Pollutant Removal

     Raw waste  loadings  of  priority   pollutants  observed  in
significant  concentrations  at  hydrofluoric   acid  plants  were
presented.

     Two of the  plants  visited  and sampled   are practicing BPT
technology.   Plant  #705  was  sampled  for  both  screening and
verification  and Plant  #167  was  sampled during  verification.
Although  Plant #705 does  not recycle drip acid, the  performance
for priority pollutant removal can be considered  BPT.

     Table 12-15 indicates the  performance  characteristics  for
priority pollutant removal at Plants #705  and 1167.  It is  clear
that the effluent concentration in the discharge  at  Plant #705 is
well below the significant level and in  many cases  are below the
predicted treatability concentration  with  lime  treatment.  This
high performance is likely the  result of   the  fact  that  many  of
the  metals found in the kiln slurry  raw  waste were   in  the  ore
residue as solids and were simply settled  out during treatment.

     Table 12-14 also  presents  the achievable effluent  quality
for priority pollutants using BPT technology.


                                229

-------
1ABLE  12-13.
SUMMARY OF EFFLUENT QUALITY ATTAINED AND VARIABILITY
OBSERVED AT FOUR  REPRESENTATIVE HYDROFLUORIC ACID PLANTS
Treated Waste

Parameter


*
PH
Fluoride
TSS
Flow in
m3/kkg "
(gal/short ton)

*
PH
Fluoride
TSS
Flow in
3,
m /kkg
(gal/short ton)

*
PH
Fluoride
TSS
Flow in
m3/kkg
(gal/short ton)

Fluoride
TSS
Flow in
m3/kkg
/ -, , .

Average


6.8
0.10
0.29
5.6
(1,340)


ND
0.72
0.38
ND




9.0
0.81
0.54
10.2
(2,450)


ND
ND
ND

Daily
Standard
Deviation

1.1
0.09
0.16
3.8
(920)


ND
0.27
-
ND




2.8
0.52
0.37
5.5
(1,316)


ND
ND
ND

Load (kg/metric ton) (lb/1000 Ib)

Maximum

Plant
2.9 to 7.7
0.34
1.1
16
(3,760)

Plant
ND
2.0
-
ND


Plant

2.8 to 12.
2.6
1.2
24
(5,760)

Plant
ND
ND
ND


Average

#664**
6.8
0.10
0.27
5.6
(1,340)

#753**
ND
0.64
ND
11
(2,650)

#722**

2 ND
ND
ND
ND


#705**
0.49
0.84
26.8
(6,433)
Monthly
Standard
Deviation


Maxiinuni


0.7 5.0 to 7.5
0.04
0.18
2.1
(500)


ND
0.15
ND
ND




ND
ND
ND
ND



0.22
0.37
__

0.16
0.63
10.5
(2,500)


ND
0.76
ND
ND




ND
ND
ND
ND



0.8
1.53
139
(33,350)
(gal/short ton)

*Value in pH units.
ND = No data available.
** See Reference 3.
                                   230

-------
           TABLE 12-14  CONTROL  PARAMETER LIMITATIONS
                 SUBCATEGORY:  Hydrofluoric Acid
                      Level  of Treatment: 1
           Waste Water  Flow:  14.7  m3/kkg (65% Recycle)
Pollutant
Subcategory
Performance
  (mg/1)
      Quality  Limit
  (1)     (mg/1)
VFR   	
      30  day   24 hr
       Av e r    Ma x
                                                    Emission Limit
                                                       (kg/kkg)
                                                    30 day  24 hr
                                                     Aver    Max
BPT Pollutants:

Total Suspended    21
Solids, TSS
Fluoride, F
    35
2.0    37.5


3.0    37.5
 75    0.55     l.i


112    0.55     1.6
Proposed Priority
Pollutants
Arsenic , As
Chromium, Cr

Copper, Cu
Lead, Pb

Mercury, Hg

Nickel, Ni

Selenium, Se
Zinc, Zn

0.
0.

0.
0.

0.

0.

0.
0.

06
05
(2)
06
3
(2)
01
(2)
09
(2)
01
3

2.
2.

2.
2.

2.

2.

2.
2.

0
0

0
0

0

0

0
0

0.
0.

0.
0.

0.

0.

0.
0.

5
1

5
5

1

5

2
5

1.
0.

1.
1.

0.

1.

0.
1.

0
2

0
0

2

0

4
0

0.
0.

0.
0.

0.

0.

0.
0.

0074
0015

0074
0074

0015

0074

0029
0074

0.015
0.003

0.015
0.015

0.003

0.015

0.0058
0.015
  (1) - VFR: ratio of the  24 hour  variability factor to the
            30 day variability  factor.

  (2) - Verification Sampling
                               231

-------
12-15.
                PRIORITY POiLLUTANT REMOVE AT HYDROFLUORIC ACID PLANTS kg/kkg
Plant

Pollutant
Antimony, Sb
Arsenic, As
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni

Selenium, Se
Thallium, Tl
Zinc, Zn
#705
Influent
0.00065
0.0025 <
0.0006
0.024
0.018
0.0031
0.00036
0.035 <


0.00016
0.015

Effluent
0.00012
0.0006
0.0001
0.0029
0.0012
0.0014
0.00003
0.0006

0.0003
0.00007
0.0033
#
Influent
0.0058
0.019
-
0.060
0 .015
0 .011
0.0034
0.14

0.008
-
0.031
167
Effluent
<0.026*
< 0.003
< 0.0003
0.032
0.010
0.0047
< 0.00015
0.077
*
0.011
0.0010
0.023
Flow (m3/kkg)2
                 62.1
127
*Effluent is greater than influent.


  Values are for combined wastes from HF and AlF-


2
  Values are for total raw waste from HF only
                                  232

-------
Pretreatment Applications

     No hydrofluoric   acid    manufacturing  facility  presently
discnarges  to a  POTW;  consequently,   no  specific pretreatraent
technology has been proposed.


Response to Remand Issues

     The original   BPCTCA   limitations  for  this   subcategory
required  zero pollutant disciiarge   except in the event of excess
rainfall. Objections to  the zero-discharge limitations concerned
the feasibility  of using  gypsum-saturated  water for recycle to
air pollution control scrubbers.

     The proposed  BPT   waste water   control   and   treatment
technology allows for the discharge  of  process  waste water after
appropriate treatment and recycle for  kiln waste transport.  This
technology is widely practiced in the  industry and should pose no
technical problems.  Implementation  of BPT  at all sites  in the
industry will achieve the indicated  pollutant discharge levels.


12.2.3 Estimated Perfo rmance of Advanced Level Systems


Advanced  Level  Performance   Estimates  for  BPT  and  Priority
Pollutant Removal

     Tables 12-16, 12-17 and 12-18   present estimated  achievable
effluent quality through implementation of advanced technologies.
Pretreatment Applications

     No hydrofluoric  acid   manufacturing   facility   presently
discharges to a POTW.
New Source Performance Application

     Examination of   raw   waste  loads  indicates  that  the prime
source  of  pollutants at  hydrofluoric  acid plants  is the  kiln
waste.  Currently, two plants  handle their kiln waste as a  solid
greatly  reducing  the  total    raw  waste  load  and  subsequent
effluent.   Based  on this  and an  examination  of  control and
treatment  alternatives available  to  this industry, it has been
determined that  new  hydrofluoric acid facilities should  achieve
effluent quality at   least  equivalent  to BAT.  The  recommended
treatment technology  for   new  sources as described  in Section 8,
is dry handling of kiln wastes and  chemical treatment, filtration
and   recycle  of  other   wastes.   The  use  of  soda  ash

                               233

-------
          TABLE 12-16  CONTROL  PARAMETER LIMITATIONS
                SUBCATEGORY:  Hydrofluoric Acid
                     Level of Treatment: 2
          Waste Water Flow:  14.7 m3/kkg  (65% Recycle)
Pollutant
Treatability
  (mg/1)
     Quality Limit
  (1)    (mg/1)
 VFR   	
       30 day  24 hr
       Av e r    Ma x
                                                   Emission Limit
                                                      (kg/kkg)
                                                     30 day
                                                     Aver
                         24 hr
                         Max
BPT  Pollutants;

Total Suspended   15
Solids, TSS
Fluoride, F

Proposed Priority
   25
               2.0
3.0
       15
25
        30
75
        0.22
0.37
  (1) - VFR: ratio of the  24 hour  variability factor to the
           30 day variability  factor.
          0.44
1.1
Pollutants
Arsenic, As
Chromium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni
Selenium, Se
Zinc, Zn

0.
0.
0.
0.
0.
0.
0.
0.

1
05
1
1
05
1
1
4

2.
2.
2.
2.
2.
2.
2.
2.

0
0
0
0
0
0
0
0

0.
0.
0.
0.
0.
0.
0.
0.

1
05
1
1
05
1
1
4

0.
0.
0.
0.
0.
0.
0.
0.

2
1
2
2
1
2
2
8

0.
0.
0.
0.
0.
0.
0.
0.

0015
0007
0015
0015
0007
0015
0015
0059

0.003
0.001
0.003
0.003
0-0015
0.003
0.003
0.012
                             234

-------
           TABLE 12-17  CONTROL  PARAMETER LIMITATIONS
                 SUBCATEGORY:  Hydrofluoric Acid
                      Level  of Treatment: 3
           Waste Water Flow:  14.7  m3/kkg  (65% Recycle)
Pollutant
Treatability
   (mg/1)
                                    Quality Limit
                                 (1)     (mg/1)
VFR
                                      Emission Limit
                                          (kg/kkg)
                                    30  day  24 hr   30 day  24 hr
                                     Aver    Max     Aver    Max
BPT Pollutants:

Total Suspended   15
Solids, TSS
Fluoride, F

Proposed Priority
    25
               2.0
2.0
       15
25
        30
75
       0.22
0.37
         0.44
1.1
Pollutants
Arsenic, As
Chromium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel , Ni
Selenium, Se
Zinc, Zn

0.
0.
0.
0.
0.
0.
0.
0.

05
05
05
1
01
1
1
2

2.
2.
2.
2.
2.
2.
2.
2.

0
0
0
0
0
0
0
0

0.
0.
0.
0.
0.
0.
0.
0.

05
05
05
1
01
1
1
2

0.
0.
0.
0.
0.
0.
0.
0.

1
1
1
2
02
2
2
4

0.
0.
0.
0.
0.
0.
0.
0.

0007
0007
0007
0015
00015
0015
0015
003

0.0015
0.0015
0.0015
0.003
0.0003
0.003
0.003
0.006
   (1) - VFR: ratio of the  24  hour  variability factor to the
            30 day variability factor.
                              235

-------
          TABLE  12-18  CONTROL PARAMETER LIMITATIONS
                 SUBCATEGORY:  Hydrofluoric Acid
                     Level  of Treatment: 4
          Waste  Water  Flow:  4.2 m3/kkg  (90% Recycle)
Pollutant
Treatability
   (mg/1)
  (1)
VFR
                                   Quality Limit
                                      (mg/1)
                                      Emission Limit
                                         (kg/kkg)
                                   30 day  24 hr   30 day  24 hr
                                    Aver    Max     Aver    Max
BPT Pollutants:

Total  Suspended    15
Solids,  TSS
Fluoride,  F

Proposed Priority
    25
               2.0
3.0
       15
25
        30
75
       0.063
0.1
         0.13
0.32
Pollutants
Arsenic, As
Chromium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni
Selenium, Se
Zinc, Zn

0.
0.
0.
0.
0.
0.
0.
0.

1
05
1
1
05
1
1
4

2.
2.
2.
2.
2.
2.
2.
2.

0
0
0
0
0
0
0
0

0.
0.
0.
0.
0.
0.
0.
0.

1
05
1
1
05
1
1
4

0.
0.
0.
0.
0.
0.
0.
0.

2
1
2
2
1
2
2
8

0.
0.
0.
0.
0.
0.
0.
0.

0004
0002
0004
0004
0002
0004
0004
0017

0.0008
0.0004
0.0008
0. 0008
0.0004
0.0008
0.0008
0.0034
  (1) - VFR: ratio of  the  24  hour  variability factor to the
           30 day variability factor.
                             236

-------
precipitation  of fluorides  will  allow recycle to air  pollution
control scrubbers, the  second major  source of waste water.

     Assuming 60 percent  recycle,  the  achievable effluent quality
through implementation  of this  technology is indicated in  Table
12-19.

     Raw waste  priority  pollutant  metals  loadings from sources
other  than  kiln  wastes  were  minimal   and  only  occasionally
observed at potentially significant  levels.   it is  assumed  that
following  chemical  precipitation  for   fluoride  removal,  the
effluent loads discharged  will  be insignificant  with regard to
these metals.
12.2.4 Cost Estimates
General Discussion

     The costs shown at each  level  of  treatment correspond to the
model plant BPT system  (Level  1)  and one or  more alternative BAT
systems (Level  2,  3, and  4)  which   may add to  or  modify the
existing  BPT  system to meet  more  stringent priority  pollutant
removal  requirements.  The BAT  system also  provides  a  higher
effluent  water  quality  with  respect to the  conventional and
nonconventional parameters.

     The estimated  costs  for  three   models  having  different
production  levels are given   in  Tables 12-20, 12-21  and 12-22.
For these  models, both the hydraulic  and the pollution loads per
unit of  production  are held   constant over the entire  range of
production. Annual treatment  cost as   a function of production is
shown graphically in Figure 12-10.  Similarly, treatment cost per
metric ton of product is given in Figure 12-11.

     To indicate the  effect  on  costs of an increased  pollution
load  per unit  of  production  for a  medium  level of production
model plant, the pollution load was increased by 100 percent and
trie  hydraulic  load  was  held  constant.   The  cost   estimate
indicated that the  annual unit cost per metric ton of product at
first  and  fourth  (incremental)   levels of treatment  increased
approximately 40 percent  and  90  percent respectively  over the
original  model unit cost.  The  increased cost is mostly due  to
the additional  cost of chemicals.  Increase of pollutant loading
had no effect on the unit cost  of  treatment at  other levels  of
t reatment.

     Similarly, for  one  model plant,  the  hydraulic  load was
increased  by  100  percent   and  the   pollutant  load  was held
constant.  The  cost estimate  indicated that the annual unit cost
per metric ton  of product at  the  second and  fourth  levels  of
i-
                               237

-------
        TABLE 12-19  CONTROL PARAMETER LIMITATIONS
              SUBCATEGORY: Hydrofluoric Acid
                 Level of Treatment: NSPS
               Waste Water Flow: 5.9 m3/kkg
Pollutant Treatability
(mg/1)
BPT Pollutants:
Total Suspended 15
Solids, TSS
Fluoride, F 25
Proposed Priority
Pollutants
Arsenic , As 0.1
Chromium, Cr 0.05
Copper, Cu 0.1
Lead, Pb 0.1
Mercury, Hg 0.05
Nickel, Ni 0.1
Selenium, Se 0.1
Zinc, Zn 0.4
(1
VFR

2.

3.


2.
2.
2.
2.
2.
2.
2.
2.

0

0


0
0
0
0
0
0
0
0
Quality Limit
) (mg/1)
30 day
Aver

15

25


0.1
0.05
0.1
0.1
0.05
0.1
0.1
0.4
24 hr
Max

30

75


0.
0.
0.
0.
0.
0.
0.
0.






2
1
2
2
1
2
2
8
Em
ission Limit
(kg/kkg)
30 day
Aver

0.

0.


0.
0.
0.
0.
0.
0.
0.
0.

088

22


0006
0003
0006
0006
0003
0006
0006
0024
24 hr
Max

0.

0.


0.
0.
0.
0.
0.
0.
0.
0.

18

66


0012
0006
0012
0012
0006
0012
0012
0048
(1) - VFR: ratio of the 24 hour variability  factor  to  the
         30 day variability factor.
                           238

-------
                    TABLE 12-20.MODEL PLANT  TREATMENT COSTS
   Subcategory  HYDROFLUORIC ACID

   Production
                                                   Type of Regulation  BAT
                  19,100 metric tons per year  (   21,057 tons per year)
                      54 metric tons per day  (       60 tons per day )
Waste water flow    5220 cubic meters per day.
A.  INVESTMENT COST

    Construction 	
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals, overhead,
    fees, contingencies...
    Land	
                                          LEVEL  OF  TREATMENT*

                                FIRST      SECOND       THIRD     FOURTH


                             $877,500     $24,500     $25,000    $24,500
                                                        92,000      89,500



                                                        23,400      22,800

                                                        23,400      22,800
386,
9,
254,
254,
1,020,
000
000
500
500
000
89,500

22,800
22,800
B.
 TOTAL INVESTMENT CC6T

 OPERATION AND
 MAINTENANCE COST
                              $2,801,500     $159,600     $163,800    $159,600
Labor and supervision.
Enerqy 	 	
Chemicals 	
Maintenance 	
Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis
and reporting 	

TOTAL OPERATION AND
MAINTENANCE COST
C. AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
$56,000
15,000
534,800
178,150
84,045

350,000

15,000


1,232,995

$289,850
$1,522,845
$14,000
1,500

15,960
4,788



7,500


$43,748

$25,966
$69,714
$14,000
1,800
3,400
16,380
4,914



7,500


$47,994

$26,650
$74,644
$14,000
1,500
367,700
15,960
4,788



7,500


$411,448

$25,966
$437,414
    *First level represents the base cost  of treatment system.
    Other levels represent the  incremental cost above base cost.
                                    239

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                   TABLE 12-21. MODEL PLANT TREATMENT COSTS
   Subcategory  HYDROFLUORIC ACID

   Production
                                                  Type of Regulation  BAT
                 38,200 metric  tons per year (  42,115 tons per year)
                    109 metric  tons per day  (     120 tons per day )
Waste water  flow   10450 cubic meters per day.
A.  INVESTMENT COST

    Construction 	
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals, overhead,
    fees, contingenc ies...
    Land	

    TOTAL INVESTMENT COST

B.  OPERATION AND
    MAINTENANCE COST
                                          LEVEL OF TREATMENT*

                                FIRST      SECOND       THIRD      FOURTH


                           $1,354,500     $35,000     $35,500     $35,000



                              533,500     131,000     137,500     131,000

                                9,000

                              379,400

                              379,400
                            1,944,000

                           $4,599,800    $232,400    $242,200    $232,400
33,200
33,200
34,600
34,600
33,200
33,200
Labor and supervision.
Energy. 	 	
Chemicals 	
Maintenance 	 	
Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis
and repo rting 	

TOTAL OPERATION AND
MAINTENANCE COST
C. AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
$56,000
21,500
1,069,600
265,580
137,994

700,000

15,000


2,265,674

$432,098
$2,697,772
$14,000
3,100

23,240
6,972



7,500


$54,812

$37,811
$92,623
$14,000
3,400
6,700
24,220
7,266



7,500


$63,086

$39,405
$102,491
$14,000
3,100
735,350
23,240
6,972



7,500


$790,162

$37,811
$827,973
    *First level represents  the  base  cost  of treatment system.
    Other levels represent the  incremental cost above base cost.
                                   240

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                    TABLE 12-22. MODEL  PLANT  TREATMENT COSTS

                                                      Type of Regulation BAT
Subcategory  HYDROFLUORIC ACID

Production        57,300 metric tons per  year  (   63,173 tons per year)
                     163 metric tons per  day  (      180 tons per day )
Waste water flow   15700 cubic meters per day.
A.  INVESTMENT COST

    Construction 	
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals, overhead,
    fees, contingencies...
    Land	
B.
                                          LEVEL OF TREATMENT*

                                FIRST      SECOND       THIRD     FOURTH


                           $1,755,500     $49,000     $50,000     $49,000
898,000
9,000
532,500
532,500
2,880,000
203,500

50,500
50,500
 TOTAL INVESTMENT COST

 OPERATION AND
 MAINTENANCE COST
                            53,100      50,500

                            53,100      50,500


$6,607,500    $353,500    $371,700    $353,500
Labor and supervision.
Energy 	
Chemicals 	

Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis
and reporting 	

TOTAL OPERATION AND
MAINTENANCE COST
C. AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
$56,000
30,600
1,604,400
372,750
198,225
1,050,000
15,000

3,326,975
$606,464
$3,933,439
$14,000
4,600

35,350
10,605
7,500

$72,055
$57,514
$129,569
$14,000
4,900
10,070
37,170
11,151
7 500

$84,791
$60,475
$145,266
$14,000
4,600
1,103,025
35,350
10,605
7,500

$1,175,080
$57,514
$1,232,594
    *First level represents the base cost  of  treatment system.
    Other levels represent the  incremental cost  above base cost.
                                    241

-------
  o
  o
                              X
                                ^
                             i
                                     X
                                  X
                                               I  ! !
                                             ILEVIEIL #4
                                             X
                                                      \z.
                                                            J£>
•H~T
m
 i !  i
                10       20      30        40       50



                   PRODUCTION,  METRIC TONS/YEAR K 1000
                                                            60
Figure 12-10.   Annual treatment cost vs.  production for the Hydrofluoric

                           Acid Subcategory
                              242

-------
   110
u
•to-

I
o
   100
    90
   80
    70
    60
Figure 12-11.
10        20        30        40         50
    PRODUCTION, METRIC TONS/YEAR X 1000

 Annual unit treatment cost vs. production for the
   Hydrofluoric Acid Subcategory
                              243

-------
treatment increased  approximatley   70   percent   and   10   percent
respectively over the  original model   unit  cost.    There was  no
significant impact on the unit cost  at  other levels  of treatment.

    Table 12-23 presents a summary  of  the  unit  cost  distribution
between amortization, operation  and  maintenance  cost components
at various production and levels of  treatment.

    At the second,  third and  fourth   levels of  treatment,   the
cost estimates  are based on part of the  waste   water flow being
recirculated  and  the  remaining  flow  being treated,   thus the
subsequent  treatment units  are sized   and  estimated  for  lower
flows  than if recycling were not practiced.

    As explained under General Approach  in  Section  10,  the costs
of  recirculation  have  been excluded   from the  cost  estimates
presented here.

    For the model  plant, the  primary source of  waste  water is
the kiln waste,  a  slurry formed when  water is  used  to  transport
the solid residue   (CaS04) after  the  reaction  of fluorspar   and
sulfuric acid.   Other sources  of process  waste  result  from air
pollution control  (scrubbers) and leaks,  spills  and  washdown.


Model  Plant Control Costs for Existing  Sources

    For the  model plant control  costs  at the  first  level  of
treatment, the  disposal  of the sludge  is  on-site  and  hence the
land   requirements  are  fairly large.   Chemicals, sludge hauling
and disposal costs have  a significant  impact on the  total annual
costs.  At  the second  and  third levels of treatment   however,
amortization,  labor and  supervision   costs constitute   a  major
portion of the additional annual costs.

    The fourth  level of treatment  is  designed  for  recirculation
of the  major portion of the treated effluent and  therefore,  soda
ash is used for  neutralization in  place   of lime.   Due to  this
change, chemical cost has a significant impact on the  additional
annual costs.


Model  Plant Control Costs for New Sources

    The basis of the selection of the  model plant representing a
new source is described earlier in  this  section.  The  estimated
costs   for  three  different   models,   having   three  different
production levels  are given in  Tables  12-24,   12-25 and 12-26.
Both the hydraulic and pollutant loads  are  directly   proportional
to  the production, i.e., the  waste flow per unit of  production
and the  pollutant  loading  per  unit   of   production  are  held
constant.

                              244

-------
                 TABLE 12-23   MODEL  PLANT TREATMENT COSTS
Subcategory  HYDROFLUORIC ACID
Type of Regulation BAT
                                            Annual Treatment Costs ($/kkg)



PRODUCTION FLOW
(kkg/yr) (m3/day)
Annual Operation
and Maintenance
Annual
Amortization
Total Cost
19,100
38,200
57,300
19,100
38,200
57,300
19,100
38,200
57,300
5,220
10,450
15,700
5,220
10,450
15,700
5,220
10,450
15,700

FIRST
$
64.55
59.31
58.06
15.18
11.31
10.58
79.73
70.62
68.65
LEVEL OF
SECOND
$
2.29
1.43
1.26
1.36
0.99
1.00
3.65
2.42
2.26
TREATMENT
THIRD
$
2.51
1.65
1.48
1.40
1.03
1.06
3.91
2.68
2.54
FOURTH
$
21.54
20.68
20.51
1.36
0.99
1.00
22.90
21.67
21.51
                                 245

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                   TABLE 12-24. MODEL  PLANT  TREATMENT COSTS
  Subcategory  HYDROFLUORIC ACID                     Type of Regulation  NSPS

  Production        19,100 metric tons  per  year (   21,057 tons per year)
                        54 metric tons  per  day  (       60 tons per day )
  Waste water flow     680 cubic meters per day.
A.   INVESTMENT COST
                                               LEVEL OF TREATMENT*

                                                      FIRST
   Construction 	                           $64,000
   Equipment in place,
   including piping,
   fittings, electrical
   work and controls	                           327,000
   Monitoring equipment
   in  place	                             9,000
   Engineering design
   and inspection	                            80,000
   Incidentals, overhead,
   fees, contingencies...                            80,000
   Land	                            30,000
    TOTAL INVESTMENT COST                           $590,000

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.                           $56,000
    Energy	                             6,100
    Chemicals	                            44,000
    Maintenance	                            56,000
    Taxes and insurance...                            17,700
    Residual waste
    disposal	                           742,000
    Monitoring, analysis
    and  reporting	                            15,000

    TOTAL OPERATION AND
    MAINTENANCE COST                                $936,800

C.  AMORTIZATION OF
    INVESTMENT COST                                  $91,112
    TOTAL ANNUAL COST                             $1,027,912
    *First level  represents the base cost of treatment  system.
    Other levels  represent the incremental cost above base  cost.

                                    246

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                    TABLE 12-25. MODEL PLANT TREATMENT COSTS
   Subcategory  HYDROFLUORIC ACID                    Type of Regulation NSPS

   Production        38,200 metric tons per year  (  42,115 tons per year)
                        109 metric tons per day   (     120 tons per day )
   Waste water flow    1370 cubic meters per day.
A.  INVESTMENT COST
                                               LEVEL OF TREATMENT*

                                                      FIRST
    Construction 	                          $94,500
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	                          468,500
    Monitoring equipment
    in place	                            9,000
    Engineering design
    and inspection	                          114,400
    Incidentals, overhead,
    fees, contingencies...                          114,400
    Land	                           60,000
    TOTAL INVESTMENT COST                          $860,800

B.  OPERATION AND
    MAINTENANCE CCST

    Labor and supervision.                          $56,000
    Energy	                            8,300
    Chemicals	                           88,000
    Maintenance	                           80,080
    Taxes and insurance...                           25,824
    Residual waste
    disposal	                        1,480,000
    Monitoring, analysis
    and reporting	                           15,000

    TOTAL OPERATION AND
    MAINTENANCE COST                             $1,753,204

C.  AMORTIZATION OF
    INVESTMENT COST                                $130,290
    TOTAL ANNUAL COST                            $1,883,494
    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.

                                    247

-------
                   TABLE 12-26. MODEL  PLANT TREATMENT COSTS
   Subcategory  HYDROFLUORIC ACID                     Type of Regulation  NSPS

   Production        57,300 metric  tons  per year (   63,173 tons per year)
                       163 metric  tons  per day  (      180 tons per day )
  Waste water flow    2030 cubic meters per day.
A.   INVESTMENT COST
                                               LEVEL OF TREATMENT*

                                                      FIRST
    Construction 	                          $120,700
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	                           601,000
    Monitoring equipment
    in  place	                             9,000
    Engineering design
    and inspection	                           146,140
    Incidentals, overhead,
    fees, contingencies...                           146,140
    Land	                            84,000
    TOTAL INVESTMENT COST                         $1,106,980

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.                           $56,000
    Energy	                            12,250
    Chemicals	                           132,000
    Maintenance	                           102,298
    Taxes and insurance...                            33,209
    Residual waste
    disposal	                         2,226,000
    Monitoring, analysis
    and  reporting	                            15,000
    TOTAL OPERATION AND
    MAINTENANCE COST                              $2,576,757

C.   AMORTIZATION OF
    INVESTMENT COST                                 $166,438
   TOTAL ANNUAL COST                             $2,743,195
    *First level represents  the  base cost of treatment system.
    Other levels represent the  incremental cost above base cost,

                                    248

-------
     Annual treatment  cost as   a  function of production is shown
graphically in figure 12-12.  Treatment   cost  per metric ton  of
product is given in Figure 12-13.

     Table 12-27 presents a summary  of the unit cost distribution
between amortization and operation and maintenance components.

     For the model plant, the  dry   solids generated in the kiln,
are  nauled  to approved chemical  dump  sites,   eliminating kiln
waste slurry.  The  waste water  sources  are air pollution control
(scrubbers), leak, spills and washdowns.

     The cost of  transporting   dry   kiln  waste  sludge  to  the
approved  chemical  dump  site   has   been  included in  the cost
estimates.  The cost of conveying  the dry solids  from  the kiln
operation  to the  trucks (for transporting to   the dump site)  is
not included in  the cost estimate.   Such costs,  which  can vary
widely  with site conditions, are  considered to be process costs
and  not  part  of treatment.  A new plant would undoubtedly  be
designed for direct loading of dry kiln  waste.

     Since the sludge disposal is  not on site,  the land cost has
negligible  impact  on total  annual  cost.    However,  the cost of
transporting the dry solids to the dump  site constitutes about 75
percent of the annual costs.
                               249

-------
                                                            I  i  '  I
        I  !
                                          I  I
          I  !
o
o
o
 ^
o
o
o
X

co-
u
                             ZL_L
                                                                I  I
          I  i
                ! 1
                                                   I !  !
                                                              \  i
                                                              I  I
                                                          60
    Figure
  10        20       30        40        50

      PRODUCTION, METRIC TONS/YEAR X 1000



12-12.  Annual treatment cost vs. production for the

     Hydrofluoric Acid Subcategory  (NSPS)
                            250

-------
                                              i I
    60
U
    50
                             I  1
i
u
                                               IT
LJE
EIL '#
                                               \  \
    40
                                   i !  I
    30
                                            I
             10        20       30        40       50

                  PRODUCTION,  METRIC TONS/YEAR X 1000
    60
      Figure 12-13.  Annual unit treatment cost vs. production for
                the Hydrofluoric Acid Subcategory  (NSPS)
                             251

-------
                 TABLE 12-27   MODEL PLANT TREATMENT COSTS
Subcategory  HYDROFLUORIC ACID
                              Type of  Regulation   NSPS
                                           Annual Treatment Costs  ($/kkq)
                  PRODUCTION  FLOW      FIRST
                  (kkg/yr)  (m3/day)      $
                                                 LEVEL OF TREATMENT
                              SECOND
                              $
                               THIRD
                               $
                              FOURTH
                               $
Annual Operation
and Maintenance
Annual
Amortization
Total Cost
19,100
38,200
57,300
  680
1,370
2,030
49.05
45.90
44.97
19,100
38,200
57,300
19,100
38,200
57,300
680
1,370
2,030
680
1,370
2,030
4.77
3.41
2.90
53.82
49.31
47.87
                                 252

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                          SECTION  13
                  HYDROGEN PEROXIDE  INDUSTRY
13.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL
13.1.1 Industry Profile and Analytical  Results

    The organic process is  tne most commonly  employed method in
the  manufacture of Hydrogen Peroxide.   Hydrogen Peroxide  is used
as a bleaching agent in  the textile,   pulp  and paper industries.
Other  uses  include chemical manufacture   (e.g.  plasticizers and
glycerine) , waste water treatment, and  as  a  rocket propellant.

    The industrial profile data   is presented  in Table 13-1  and
existing regulations in Table 13-2.

    The priority pollutants  found at  significant concentrations
in the raw waste at screening plant #765 were:
         Pollutant
              Concentration  (ug/1)
         Pentachlorophenol
         Phenol
         Napthalene
                        4850
                          29
                          11
    Dur ing
discovered
killer used
the  basis
recommended
verification  sampling of  the   same   plant,   it   was
that  the presence of  organics  were   due  to  a   weed
at the plant  site, and were not process  related.   On
of  these  findings,   this   subcategory  has   been
for exclusion under Paragraph 8.
                              253

-------
TABLE  13-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
HYDROGEN PEROXIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                            85,700  kkg/year
                                 7
                                 3
                           102,200  kkg/year
                            57,000  kkg/year

                                66  percent

                             5,560  kkg/year
                            28,730  kkg/year
                               15 years
                               27 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  254

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TABLE  13-2  -     EXISTING REFLATIONS   -  EFFLUENT LJMTTATICN
SOBCATEGOKr Hydrogen Peroxide
SUBPAKT I (40CFR 415.90, 3/12/74)
STANDARDS
Product Para-
Process meters
Organic
Process
TOC
Electro-
lytic TSS
Process
BPCTCA
1 2
Max, Avg.
kg/kkg k/kkg
(mg/1) (mg/1)
0.8
(50.0)**
0.44
(27.5)
0.005
0.4
(25.0)
0.22
(13.8)
0.0025
BA1EA*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp^
No discharge
of pwwp
No discharge
of pwwp
NSPS*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/D
No discharge
of pwwp
No discharge
of pwwp
No discharge
of pwwp
            Cyanide    0.0004     0.0002
            (A)
No discharge
of pwwp
No discharge
of pwwp
  Sections 415.93 and 415.95 were remanded and are presently reserved
  (41 FR 51601,  November 23, 1976) .
  Max, = Maximum of any one day,
  Avg. = Average of daily values for thirty consecutive days shall not exceed.

  pwwp = Process wastewater pollutants,

     basis  16,000 1/kkg.
                                  255

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                          SECTION  14
                   TITANIUM DIOXIDE  INDUSTRY
14.1 ASSESSMENT OF THE WATER
PROCESS
POLLUTION POTENTIAL OF THE CHLORIDE
14.1.1 Industry Profile and Analytical  Results
Chloride Process Industry

    Titanium dioxide  is manufactured  by both a  chloride process
and  a sulfate process.  Ti02   is  a   high  volume chemical ranking
within  the first fifty  of  all  U.  S.   chemical production. Over
fifty percent of the titanium  dioxide  produced is used in paints,
varnishes and lacquers.  About one  third is used in the paper and
plastic  industries.   Other uses  are found  in ceramics,  ink and
rubber manufacturing.
    The industrial   profile    data
presented in Table 14-1,  while   the
Table  14-2.
        for  this   subcategory   is
        existing  regulations  are   in
    The raw waste was not   sampled  during   screeing at  Titanium
Dioxide-Chloride  Process Plant  #172.   No  priority  pollutants of
significance were found  in  the  treated  effluent.

    Verification sampling  was  conducted at two plants.  Priority
pollutants   of  significance   found  in  the  raw  waste  during
verification sampling were:
                     Maximum
         Pollutant
Concentration
    ug/1
Observed
         Chromium
         Lead
         Nickel
         Zinc
   15200
    5150
    6320
    3110
                             256

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TABLE 14-1
SUBCATEGORY PROFILE DATA SUMMARY
SUECATEGORY
TITANIUM DIOXIDE  CHLORIDE PROCESS
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           610,000 kkg/year
                           389,000 kkg/year
                                 8
                                 5
                           184,600 kkg/year
                           142,000 kkg/year
                                30 percent
                                37 percent

                            16,900 kkg/year
                            45,200 kkg/year
                            28,400 kkg/year
                            25,600 kkg/year
                                77 percent

                                 6 years
                                15 years

                            1,140 cubic meters/day
                            4,770 cubic meters/day

                                14 cubic meters/kkg
                                99 cubic meters/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                 257

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TABLE  14-2 -     EXISTING REGULATIONS   -  EFFLUENT LZMITATICN GUIDELINES
SUBCATEGOKY Titanium Dioxide
SUBPART
V (40CFR 415
.220, 3/12/74)
STANDARDS
Product
Process
Chloride
Process

Sulfate
Process

BPCTCA*
1 2
Max. Avg.
Para- kg/kkg k/kkg
meters (mg/1) (mg/1)
TSS 4'6
0.72
Iron
TSS 21'° **
ibb (100.0)
Iron -I -IN
2.3
0.36
10.5
(50.0)
0.84
/ A f\\
BATEA*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
2.6 1.3
0.36 0.18
10.6 5.3
0.84 0.42
NSPS*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
2.6 1.3
0.36 0.18
10.6 5.3
0.84 0.42
 Sections 415.220,  415.222, 415.223, and 415.225 were remanded and are
 presently reserved (41 FR 51601, November 23, 19761.
 wax, = Maximum of any one day.
 Avg. = Average of daily values for thirty consecutive days shall not exceed.
**flow basis  210,000 1/kkg.
                                 258

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     A summary of daily and unit  product  raw waste loads  for all
plants sampled can be found in Table   14-3.   Individual plant raw
waste loads per unit product  found  in  sampling can be found  in
Table 14-4.

     Based on the total annual production of this subcategory and
the average  waste load generated  per  unit product, the estimated
total priority pollutant  raw waste  loads generated each year for
this subcategory are as follows:


          Pollutant       Waste Load  (kg/year)
          Chromium               310,000
          Lead                      9300
          Nickel                    9700
          Zinc                      7400
14.1.2 Process Waste Sources and Waste  Water Treatment Data
Chloride Process - General Description

     The chloride process  uses  rutile   or  upgraded ilmenite ores
as  raw  material,  since  the   process  requires  relatively pure
materials  with a  high titanium  and a   low  iron  content.  For
ilmenite ores, a  beneficiation  process   removes a part or all of
the  iron  from the low quality   titanium ore.   Several  patented
processes  exist for the  beneficiation   and two to three are  in
current operation  on a commercial  scale.  It has been claimed by
the industry tiiat the benef iciation  process generates wastes, the
volume and chemical characteristics  of  which  are different from
the  chloride  process   waste   alone,   and  different  treatment
technology has to be used for pollutant  removal before  discharge
or disposal.  One patented beneficiation process  claims that the
only waste generated  is solid waste which  can   be disposed of in
a  landfill,  but data  on  waste  quality  and   quantity  are not
available for  this process.   It is therefore   assumed that  the
wastes   from  the  chloride  process   using   beneficiation  are
different from the process using  pure  high grade  titanium ore.
Therefore, the  subcategory,  titanium  dioxide,  has been further
classified into three separate categories;   sulfate process using
ilmenite ore, chloride process using rutile or  upgraded  titanium
ore;   chloride  process  using  ilmenite  ore.    This section  is
restricted to the chloride process using rutile ore.
     In the chloride process,  the  ore  and coke are dried and then
reacted  with  chlorine   to   form   titanium  tetrachloride.    The
titanium tetrachloride  is  then reacted with oxygen or air to form
titanium  dioxide and chlorine,  the latter being recycled to  the
process.   The chemical  reaction taking  place in the  reactor is
                             259

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TABLE 14-3.
SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING

SUBCATEGORY TITANIUM DIOXIDE - CHLORIDE PROCESS
Pollutant
Minimum
Priority
NO Chromium, Cr 1.76
CTi
Lead, Pb 0.0032
Nickel, Ni 0.14
Zinc, Zn 0.75
Conventional
TSS 442
Iron, Fe 7.57
Loadings
kg/day
Average Maximum Minimum

64.4 127 0.024
2.0 4.0 0.00004
2.04 3.93 0.002
1.47 2.19 0.01
4136 7828 6.06
768 1528 0.10
kg/kkg
Average

0.79
0.024
0.025
0.019
51.0
9.40
No. of Plants
Maximum Averaged

1.55 2
0.049 2
0.048 2
0.027 2
95.9
18.7

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TABLE 14-4.   PRIORITY POLLUTANT RAW WASTE LOADS  (in kg/kkg of Product)
SUBGATEGORY
POLLUTANT
TITANIUM DIOXIDE - CHLORIDE PROCESS
             PLANT
                          #559
                           #120
Chromium, Cr



Lead, Pb



Nickel, Ni



Zinc, Zn
    1.55




    0.049



    0.048



    0.027
0.024




0.00004



0.002



0.010
                                261

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given as:


    3C + 2T102 + 4C12 = 2 T1C14 + C02  +  2CO     (1)


    The reaction  takes place  at a  temperature of   800  -  1000
degrees  C and a  fluidized  bed reactor   is   generally used. The
product  gases   leaving   the  reactor   consist   of   titanium
tetrachloride,  unreacted   chlorine,   carbon    dioxide,  carbon
monoxide and minor amounts of heavy   metal  chlorides.  The  gases
are cooled  initially to 250 degrees  C  to  remove the impurities,
although in some  cases  purification is  accomplished by  washing
the gases  with liquefied titanium tetrachloride.  Iron  chloride
and small amounts of vanadium,  zirconium, and otner   trace  metal
chlorides are removed by  centrifugation  and   the liquid recycled
to the absorber.  Titanium tetrachloride  is  liquefied  from  the
gases  after the  first  stage  of  cooling  by further cooling  to
ambient  temperature. Copper, hydrogen sulfide and,  in some cases,
proprietary organic complexing  agents  are  added for purification
to  the  condensed  solution.   Copper  acts   as  a   catalyst  to
decompose  the  phosgene formed in  the  TiC14  stream.   Organic
complexing  agents aid in  separation  of  the  TiCl4  from other
chlorides such as cupric chloride and silicon tetrachloride.

    The residual   uncondensed  gases    generally   consist   of
hydrochloric acid,  chlorine,   carbon  monoxide, carbon  dioxide,
nitrogen, and some titanium tetrachloride.    They  are treated to
remove acidic materials before  being  vented to the  atmosphere.

    The liquefied  titanium  tetrachloride  contains  impurities
such as  aluminum chloride, silicon tetrachloride, etc., which are
removed  by distillation.  The distillate  is the purified titanium
tetrachloride  and the  impurities  remain   as  a residual  which
becomes  waste.  The tail gases  from  the  distillation  column are
scrubbed  to remove acidic materials.   The  titanium  tetrachloride
product  is then  reacted  with  oxygen, as  air,  forming titanium
dioxide  and chlorine:
     TiC14 + 02 = Ti02 +  2C12     (2)


     The rate of reaction is negligible below 600 degrees  C  but
increases  rapidly  above  this   temperature,  and  is  generally
maintained between 1200 -  1400  degrees C for efficient  reaction
and   conversion.   The  needed heat   is  supplied by  passing the
reactants through heat exchangers, by electric dischargers, or by
use  of fluidized beds. After the oxidation reaction, the titanium
dioxide forms a solid and is separated from  the  gases either in
cyclones,  baghouse  filters,  or Cottrell  precipitators.   The
residual chlorine  is refrigerated and liquefied.  The tail gases


                            262

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are scrubbed with caustic  soda   to  remove chlorine  before  being
vented  to  the  atmosphere.  When   air  is _ used  for oxidation,
chlorine recovery is achieved by absorption in  trichlorethylene,
followed  by  distillation   to   remove  chlorine.   The  titanium
dioxide is  then  sent  to   the   finishing  operation  where it is
vacuum degassed  and then  treated with  alkali,  using a  minimum
amount  of  water  to   remove   traces  of absorbed  chlorine and
hydrochloric acid.  The pigment is  then milled,  surface  treated
for  end-use  application,   dried,   and  packaged  for  sale.   A
generalized process flow diagram, including the waste streams, is
shown in Figure 14-1.


Water Use and Waste Source  Inventory

     Water use  -  Water   is used   in  noncontact  cooling, for
scrubbing the  tail  gases   from the  purification  and oxidation
reactor  to  remove  contaminants,   and  in some  cases,  in the
finishing operation  of  the product. The  total amount  of water
usage varies from 45.3  to   383  m3/kkg of Ti02  produced, as shown
in  Table 14-5.  It can be  seen in  the same  table  that  cooling
water constitutes the major use  of water and varies from 10.7 to
280 m3/kkg of Ti02 produced.

     Waste sources -

     A.  Wastes from cooling chlorinator gas:   The waste consists
of  solid  particles  of unreacted  ore,  coke,  iron,  and  small
amounts of vanadium, zirconium,  chromium, and other  heavy metal
chlorides. They are either   dissolved  in  water  and sent to the
waste  water treatment  facility  or disposed of in landfill  as a
solid waste.

     B.  Chlorinator  process   tail  gas  scrubber  waste:   The
uncondensed   gases,    after   the    liquefaction   of   titanium
tetrachloride,  are  wet   scrubbed   to remove hydrogen  chloride,
chlorine, phosgene,  and   titanium   tetrachloride and chlorine in
the  first stage.   In  the   second  stage, they  are scrubbed with
caustic soda to remove  chlorine as  hypochlorite.

     C.  Distillation   bottom   wastes:   These  contain  copper,
sulfide, and organic  complexing agents added during purification
in addition to aluminum, silicon, and zirconium chlorides.  These
are removed as waterborne  wastes and reaction with water converts
silicon  and  anhydrous aluminum chlorides to  their   respective
oxides.

     D.  Oxidation tail  gas scrubber wastes:  The gases from' the
oxidation unit are cooled  by refrigeration to liquefy and  recover
chlorine.  The uncondensed  off-gases are scrubbed  with water or
caustic soda  to remove residual chlorine.   When caustic  soda  is
used as the scrubbing solution, the resulting  solution of  sodium

                             263

-------
            RUTILE ORE
ORINE
            CHLORINATION
                             COKE
                I
             COOLING
                1
              SOLIDS
            SEPARATION
 SOLID WASTE


     LIQUID
             COOLING
               AND
           CONDENSATION
     COPPER
                 LIQUID Ticl,
       SCRUBBER
            T    ''   f
          PURIFICATION
               AND
           DISTILLATION
                              DISTILLATION
                              BOTTOM WASTE
                                                      TO
                                                         ATMOSPHERE
                                                       -*• SCRUBBER WASTE
                                                     LIME OR CAUSTIC
                                                            SCRUBBER
                                                          HYPOCHLORITE
                                                          DECOMPOSITION
                                                                            TO
                                                           WASTE WATER
               Tio2 PIGMENT
            Figure  14-1.
General  process diagram for  production of
titanium dioxide  (chloride process).

           264

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 TABLE 14-5.  WATER USAGE IN TITANIUM DIOXIDE-CHLORIDE PROCESS
              SUBCATEGORY
Water Use

Non-contact cooling
Direct process contact
Indirect process contact
Maintenance, equipment
cleaning and work area
washdown
Air pollution control
Water .usage at plants
m3/kkg of Ti02
Plant #102
182
10.5
NA
6.65
0.25
Non-contact ancillary uses 11.60
Sanitary & potable water
0.23
Plant #172
10.66
15.53
0.72
0.52
7.14
10.4
0.31
Plant #199
280
57
22.78
2.11
6.97
9.47
5.09
Total                       211.23             45.28             383.42
NA = Not Available
                                265

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hypochlorite is either sold, decomposed,   sent to the waste water
treatment   facility,  or   discharged   without  treatment.   The
scrubber   waste    stream   also    contains   titanium   dioxide
particulates.

    E.  Finishing operations waste:  The  liquid wastes from  the
finishing  operation contains  titanium  dioxide  as  a suspended
solid and  dissolved sodium chloride  formed  by the neutralisation
of residual HCl with caustic soda.


Control and Treatment Practices

    Two plants  were  visited   and  their   waste  waters  sampled
during the screening and verification programs.  Titanium dioxide
is manufactured at Plant #559   using the  conventional chloride
process.   The  solids,  hereinafter  called pit solids,  (mainly
unreacted ore,  coke, iron, and  trace metal  chlorides,  including
TiCl4), separated from the first  stage cooling of the chlorinated
gases,  are  slurried  with  water   and  sent  to the waste water
treatment facility.  The waste water  from  the chloride process is
mixed  with  the  other  product   waste  water  and  treated  in
combination.  A flow diagram of  the  treatment facility, including
the sampling locations,  is shown  in  Figure  14-2.   The  slurried
pit solids and the distillation  column bottom residue are sent to
a large settling pond where they  are  mixed with the other process
waste water.  The  overflow from  the  settling pond is neutralized
with  ground calcium carbonate   in   a reactor.  The  scrubber and
other waste water  from the chloride  process  is mixed with other
product waste water and combined  with the  settling pond effluent.
The combined  solutions  are  neutralized   with lime in  a second
reactor, and then  sent  to  a settling  pond  before  discharge.
Since  the chloride  process waste   waters  are mixed  with other
product  waste  water  prior to   treatment,  the  sampling results
represent the  total  input mixture   rather  than the Ti02 process
raw wastes  alone. Problems were  encountered during the sampling
of the pit  solids  and  the  distillation   bottoms.   The pipes
carrying  the wastes from the process discharged at the bottom of
the settling pond and it was not  possible  to  take the  samples
right at the outlet of the pipe.   The combined sample of the  two
streams was  taken  at the  surface   of  the  discharge.   It  is
probable that some solids settled  before the  stream  reached the
surface. Table 14-6 gives the waste  flows  and pollutant  loadings
for the streams sampled at Plant  #559.

    The second plant sampled, #172,  makes   titanium  dioxide by
the conventional  chloride  process.   The  waste water  from the
process, mainly the scrubber water,  is collected in trenches  and
sent to a central reactor  basin.    Other  discharges, including a
part of the total rain runoff, are also  collected in ditches  and
sent to the reactor basin.  In the reactor basin sodium hydroxide
is used for neutralization,  and  the  resulting effluent  is mixed

                            266

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                                                                               OTHER PRODUCT
                                                                                WASTE WATER
               OTHER PRODUCT
                WASTE WATER
to
CTl
                                        SETTLING POND
ittl
                                    SLURRIED —'
                                    PIT SOLIDS
                                   Sampling points
                                                                                            FINAL EFFIUENT
   -DISTILLATION BOTTOM
        WASTE WATER
                                                                                                    SCIUBBER

                                                                                                WASTE WATER
                                                                                  OTHER PRODUCT
                                                                                   WASTE WATER
                                                 Figure 14-2.   General flow diagram at Plant #559 showing the sampling points.
                                                                       Titanium Dioxide (Chloride Process) Manufacture

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14-6.  FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
       STREAMS FOR PLANT #559  PRODUCING TITANIUM DIOXIDE  (CHLORIDE PROCESS)
Stream Stream
No. Description


Unit Flow
m /kkg
of TiO-
2
SS Load
kg/kkg
of TiO»
2
Iron Load
kg/kkg
of Ti00
2
Chromium Load
kg/kkg
of TiO~
2
   Pit solids and    13.86
   distillation
   bottom waste

   Settling pond     13.86
   overflow

   Ti02(Cl2 process)  90
   scrubber and
   other product
   waste water

   Final effluent   104(1)
                          (1)
                               (1)
95.7



 0.22


28.2(1)
                                                   18.7
38.7
    (1)
 0.45
     (1)
               1.55
                                                                  0.36
                    (1)
                                                                  0.0096
                                                                        (1)
                                                                  0.0026
                                                                        (1)
(2)
The pollutant load was calculated by apportioning the mass emitted
between the two waste streams on the basis of measured flows.  This  is
clearly a very approximate process and the results must be used with
caution.

The effluent value is higher than the influent because of the introduc-
tion of the other product waste water in the pond contributing to
higher load.
                           268

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with the remaining  rain  water  runoff and sent to  the  first of two
retention basins  arranged   in  series.   The  overflow  from the
second  retention   is  ph   adjusted  with  sulfuric   acid  before
discharge.   A  simplified   diagram  of   the  treatment  system,
including the sampling   points,   is shown in Figure   14-3.  Table
14-7 gives  the  waste   flow  and pollutant    loadings  for  the
streams sampled.

     At Plant #199, all  the process waste  waters  are  combined,
including  storm  water  and sanitary waste  water.   The combined
waste water  is sent   to a   four-stage neutralization system, and
the  effluent from  each  of  the four stages  of  neutralization is
sent  to a thickener.  The   thickener overflow is transferred  to
the  first of  three of  settling  ponds,  also   in series.   The
underflow  from the  thickener  is  heated to improve filtration
characteristics  and filtered  in four  rotary drum  filters.  The
thickened solids from  the  filters  are  disposed  of in a landfill
and  the filtrate,  wash  water,   and vacuum  pump seal  water  is
recycled to  the  fourth stage  of the neutralization train.  The
overflow from the last settling  pond is discharged.

     The process waste water streams at Plant  #102   are received
in two tanks, neutralized  with lime, and then sent  to a settling
basin.  The settled solids  are  retained in the settling lagoons.
The  plant  has future plans  for treating  boiler blowdown,  and
cooling tower  blowdown, leaks and spills  with the process waste
water.

     At Plant #605, the  unreacted  ore and coke is disposed of as
a  solid waste  in  the pit.   The waste water from the process is
passed to two tanks for  flow equalization, and the  water is then
reacted with ground limestone   slurried  in water.    The  treated
solution is centr i f ugal ly  treated  to remove  coarse  solids which
are separated and landfilled.   A flocculating agent   is  added to
the  centrate  and  the  solution  is  sent  to a  clarifier. The
clarifier overflow  is degassed  and the pH  adjusted  with caustic
soda (if required)  before  discharge.

     Plant #172 mixes  the  process waste waters and the treatment
consists  of  lime  neutralization and settling.   The  influent and
effluent from the treatment system was sampled and analyzed.

     The distillation  bottoms and the unreactd ore and coke  are
slurried with  water   at Plant  #559  and mixed   with the  other
process waste waters  in  a  settling basin.  The overflow from  the
basin is  neutralized  with  limestone  and then  mixed  with the
scrubber waste water and waste  waters from other products.   The
combined waste water  is  neutralized with 1 irne and sent to a final
settling  pond,  the   overflow  from  which  is   discharged.  The
quantity of waste water  from the titanium  dioxide process, which
is treated at the treatment facility, is quite  small compared to
the amounts from other product processes.

                              269

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                                    PBOCESS WASTE WATER
                                                             RAIN RUNOFF
         Sampling points
                                          DISCHARGE
Figure  14-3.   General flow diagram at plant #172 showing the sanpling points.
                      Titanium Dioxide  (chloride Process) Manufacture
                                           270

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TABLE  14-7.   FLOW AND POIiUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
              STREAMS FOR PLANT  #172' PRODUCING TITANIUM DIOXIDE (CHLOPIDE
Parameter
      Sampled Stream Description
                  Inlet to waste water
                     treatment pond
                          Waste water treatment
                                effluent
Stream no.

Flow, m /kkg

PH

TSS, kg/kkg of TiO-

Zinc, kg/kkg of TiO

Chromium, kg/kkg of
Iron, kg/kkg of TiO

Nickel, kg/kkg of

Ti°2
  2

35.8

 7.9

 7.97

 0.0096

 0.0223


 0.107

<0.0008
   3

 35.8

  7.6

  0.238

  0.003

  0.0006


  0.011

< 0.00036
                                 271

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Evaluation of Industry, Production and Waste  Flow Data

    In most cases, the caustic soda  or   water  used to scrub  the
tail gases is steam stripped before  it is sent  to the waste water
treatment  facility.   The  unreacted  ore  and  coke  is  either
disposed of as solid waste or slurried with  water and sent to the
treatment facility.   The  process waste  water   is  combined  and
treated.  The general -treatment   practice of  the industry is lime
neutralization and settling.  The total   solids generated  at the
treatment facility include the unreacted  ore  and coke, hydroxides
of iron,  titanium and other trace metals,  and titanium dioxide.
The quantity of solids generated  and  the  waste   water flows going
to the  treatment process is available   for  very few plants, but
the data available is given in Tables  14-8 and  14-9-


Process Modification and Technology  Transfer  Options

    1.  Research  to develop economical  techniques to recover the
vanadium and other  metal values  from  the solid wastes  generated
from the process waste  treatment system   would appear  to  be  a
fruitful area of investment.

    2.  New plants can utilize refrigeration and  high pressures
for chlorine liquefaction.   This would  reduce  or eliminate the
chlorine residual  problem in the  tail gases. The capital cost to
modernize  old  plants is  high,  but   these  plants should  have a
caustic soda or  lime scrubber instead   of  a  water   scrubber to
remove  residual chlorine  from  the  tail  gases.  Caustic or  lime
scrubbing removes  a significant portion  of the  chlorine  from the
tail  gases as  seen  from  the analagous  data for  the chlorine
subcategory given  in Section 11.

    3.  When   organic   complexing   agents   are   used   for
purification, they are eventually removed  with the  distillation
bottoms.  The distillation bottom wastes   need  to  be  segregated
from the other  process waste  waters  because  treatment  systems
have not been designed for the removal   of  organic contaminants,
and it would  be  too  expensive to   modify  them.  Distillation
bottoms can be more efficiently disposed  of  by  landfilling.


Best Management Practices

    1.  Provision  should be made at all plants to collect storm
water runoff from  the  plant site and  send it  to  the  treatment
facility.  Three   out of  a  total   of   five existing plants  are
presently treating storm water runoff.

    2.  Solid  wastes  generated  at  the  process  waste  water
treatment facility  may be contaminated  with chromium,  zirconium
and vanadium.   Land disposal of  these   wastes  should be in  a

                             272

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TABLE 14-8.   SOLID WASTE PRODUCED IN TITANIUM DIOXIDE-CHLORIDE PROCESS
Plant                    Amount of solids produced per unit of production
                                         kg/kkg of Ti02


  #102                                       563.4

  #172                                        43.21

  #199                                       552*
   This value includes the waste from the titanium tetrachloride production
   which is sold commercially.   62% of the total TiCl4 produced at this plant
   is used for Ti02 production and the rest marketed for sale.
 TABLE 14-9.   WASTE WATER FLOW FOR TITANIUM DIOXIDE-CHLORIDE PROCESS
               SUBCATEGORY
 Plant              Unit waste water flow going to treatment facility
                                        m /kkg of Ti02
#102
#172
#559
28.87
35.8
95.66
                                   273

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controlled landfill.

    3.  Leachate and permeate control  is  necessary if the solids
from the treatment facility are landfilled  on-site.


Model Plants and BPT Level Treatment  System Specifications

    The BPT model  treatment selected   for  the chloride process
Ti02 wastes consists of:

    A.  Equalization of all liquid wastes  in first stage lagoons.
    B.  Neutralization with lime  and  settling  in second stage
    lagoons.

    Chlorine-bearing tail gases are  reacted with caustic soda or
caustic potash, and all such chlorinous  liquids are considered to
be decomposed as part  of the production  process, with  only the
chlorine free residual  products going  to  the treatment facility.

    The costs of  thermal  decomposition,   which  are relatively
insignificant,   are   discussed    under   the    chlorine/caustic
subcategory  of Section  11.  Thermal   decomposition  consists of
cutting  off  the  cooling  water   source   after  the  exothermic
hypochlorite reaction,  and addition  of  small   amounts of nickel
and  ferric  chloride as catalysts.   The solution  is  kept  in a
closed, insulated tank  foe four   to  five  days  for decomposition.

    The rationale for selecting the  model  plants is discussed in
the  following paragraphs.

    Production -  Five  plants  produce  titanium  dioxide  from
rutile ore using the chloride process  at  a total production rate
of  142,000  metric  tons per  year.    Production  ranges  from a
minimum of 16,900 kkg/year to a maximum  of  45,200 kkg/year with a
mean of 28,400  kkg/year and a  median  of   25,600 kkg/year.  For
waste  water  treatment  cost  estimates,  three production levels
were selected  as  model plants.   These  are 16,900 kkg/yr, 25,500
kkg/yr, and 45,200 kkg/yr.  This range of  production includes all
United States plants.

    Waste water flow - As discussed  earlier and  shown in  Table
14-9, the unit acid waste water flow  varies from 29 to 96  M3/kkg
of Ti02  produced.   The main  reason for  variation in the  waste
water  flow is  the  difference in the  chlorine recovery process
from the tail gases and the amount of scrubbing liquid used.  The
waste water from the finishing operation is a significant portion
of  tiie total  waste  water and  depends on the  type of titanium
dioxide end product desired.  For  model  plants, a unit flow of 31
M3/kkg was used.
                             274

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     Pollucant load -  The   primary pollutants occurring  in the
waste "water a're suspended solids,  acidity and chlorides of ferric
iron and other trace metals.   The  suspended solids  (TSS)  loading
as seen in Table 14-3 varies  from  43  to 563 kg/kkg  of Ti02, but
tiie  low  value  represents  a  plant that  hauls untreated ore and
coke,  while  the  second   value   is  based  on  unrepresentative
sampling.  Consequently, a  higher  suspended solids  loading of 800
kg/kkg of Ti02 is assumed for  the  model plants.

     Treatment Chemicals  -   At  the BPT  treatment  level, lime is
used  for  neutralization and  precipitation.   Based on  the data
available for one plant, the  rate  of lime addition  is assumed  to
be 337 kg/kkg of Ti02.

     Generation of Solids -   Using a unit waste flow of 31  ra3/kg
(7,400  gallons per  ton  of   product), the  solids generated are
those present in the influent  (5%  by weight = 1.55  kkg/kkg)  plus
the  lime added for neutralization  (.337 kg/kkg)  or  a total  of
1.89 kkg solids per kkg of  product.   Solids are considered  to be
accumulated  in  clay  lined   lagoons,   with periodic  mechanical
removal to on-site storage  piles  in  clay lined areas draining to
the lagoons.


14.2 TECHNOLOGY BASED POLLUTION ABATEMENT


14.2.1 Advanced Level Treatment Applications


Control of Significant Observed Priority Pollutants

     Pollutants to be  controlled   are   the common  heavy  metals
found in  the  ore  (i.e.,   chromium,  lead,  nickel,  and  zinc).
Although coke  and certain  proprietary   organic complexing agents
are used in the  chloride process, the  production of  chlorinated
organic priority pollutants  is insignificant and does not warrant
specific treatment.

     Not all of the priority  pollutants listed above are found in
all ores of the  same general   type,  nor are  they  found in all
plants   utilizing  the  same   process.   However,   the   chosen
technologies at  the various  levels will be reasonably  effective
in removing the heavy metal  group.


Removal Technologies Available

     Alkaline substances  and   sulfide   compounds   are  used to
control tne heavy metals by precipitation as metallic hydroxides,
carbonates or  sulfides.  Ion  exchange  can  remove metals  from
clarified solutions, but is seluom specific enough  to remove only

                               275

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the  trace metals, and in  solutions  saturated  with  calcium  and
other metals  is  not effective.   Lime  neutralization appears  to
reduce the level of arsenic  in actual plant waste waters, but the
reaction of sulfide with arsenic  is too slow  to be of  practical
value in  waste water  treatment.   Liuie treatment comoined  with
ferric iron (added or already present in the waste stream)  may be
the most effective means of  controlling arsenic.


Selection of Technology to be Applied at Each Level

    Chloride process - BPT  (Level 1) The chloride process wastes
are equalized, neutralized with lime  to a ph range of 6 to 9, and
settled in lagoons before discharge.

    Level 2_   -  Second-stage  lime    treatment   is  added  to
precipitate metallic hydroxides,   which are  then filtered before
discharge.

    Level 3_ -  Ferrous sulfide treatment  is  added ahead of the
Level 2 filter to precipitate the  heavy metals  more effectively.

    Alkaline precipitation  was   chosen  at Level  2  because  it
readily supplements  existing  lime neutralization by  the simple
addition of filtration  and  increasing   the Level 1 lime  dosage.
Sulfide precipitation was chosen  at Level 3 because it provides a
polishing treatment for  most residual   heavy raetals at a nominal
incremental cost beyond Level 2 treatment.

    Figures 14-4,  14-5,  and  14-6  show  the  model  treatment
systems adopted for the chloride  process.

    Equipment functions - Chlorid_e   Process  - SPT  treatment is
essentially lagooning with lime neutralization, using no  special
equipment except a lime feeder and mixer.

    In Level  2, second stage  lime  treatment  is  followed  by
gravity clarification  and multi-media  filtration, with necessary
pH controls.

    In Level  3, ferrous sulfide  is added ahead of  the Level 2
filter,  to react with residual heavy metals more completely than
in the alkaline precipitation step at Level 2.

    Chemicals and  handling -   Chloride  Process  -  Lime  and
hydrochloric  acid  are  fed with conventional   equipment at  all
levels, and ferrous sulfide  is prepared on-site by mixing ferrous
sulfate with sodium bisulfide.  When  normal dust control and good
ventilation  are  used, there should  be no adverse  effects from
Dandling these chemicals.
                             276

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                                                  LIME
      RAW
WASTE WATER
                        LAGOON
                       LAGOON
                                                            LAGOON
                                              MIXING
                                                        -\  LAGOON
                                                                                                                EFFLUENT
                       Includes flow monitoring, pH monitoring and sampler.
                    Figure 14-4.  Waste water treatment Level 1 for titanium dioxide - chloride process.

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   RAW
WASTE WATEB
 CO
                       LAGOON/—*!
                       LAGOON
                                                                              BACKWASH
                                                LIME
I
                  J
                LAGOON
n
                                                                                 LIME
          -\    LAGOON  /—
                                                           FILTER PRESS
                                                                            SUMP
                                                         TO LANDFILL
                      Includes flow monitoring,  pH monitoring and sampler.
                                                                                                 SUMP
                                                                                           CLARIFIER
                             DUAL
                             MEDIA
                             FILTER
                                                                                                                       pH ADJUSTMENT
                                                                                                                              *   EFFLUENT
                                       Figure  14-5.  Waste water treatment Level 2 for titanium dioxide - chloride process.

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                                                                               FERROUS
                                                                               SULFATE
                                                                                  SODIUM
                                                                                 BISULFIDE
                                                           r
                                                                     BACKWASH
                                             LIME
p\    LAGOON   /-*|      Y   i   rA
   KAW
WASTE WATER
              U\   LAGOON

                                                      LAGOON
                                        MIXING
                                          LAGOON
                                                      FILTER PRESS

                                                                        SUMP
                                                      TO LANDFILL

                      Includes flow monitoring, pH monitoring and sampler.

                                                                                         SUMP
                                                                                     CLARIFIER
                                                                                                         * EFF-
MEDIA
FILTER
                 Figure 14- 6.   Waste water treatment Level 3 for titanium dioxide - chloride process.

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    Separation and removal of  solids  -  Chloride Process - Inert
ore  fractions   and  precipitated   solids    are  accumulated  in
clay-lined  lagoons,  which  are alternately drained.   Solids are
mechanically  removed to self-draining  18 ft.   High storage piles
on land provided at the site for a  10  year  operating  period.  At
Levels 2 and 3,  small  amounts  of  heavy metal  precipitates in
clarifier underflow  are filter pressed  and hauled  to a  secure
landfill.

    Monitoring requirements  -  Chloride Process  - Simple field
tests for oti and  dissolved sulfide  are used for internal process
monitoring.  It should not be necessary to perform frequent tests
for  the  various  heavy  metals,  except for compliance testing
required    by    agency    permits.      Samples    are   usually
flow-proportioned   24  hour   composites,   analyzed   by  atomic
absorption at a commercial laboratory.
14.2.2 Base Level Performance Characteristics for  BPT  Pollutant
Removal
Chloride Process

    toaste waters   from   chloride   process   titanium  dioxide
manufacture are similarly  treated  at  all  facilities.  Treatment
typically consists of  neutralization,   final   clarification  and
ponding.   Two plants dispose   of  unreacted ore and  coke residue
(pit solids) as  solid  waste   and   treat  all  other wastes with
neutralization and settling.

    BPT technology   has  been specified   as  solids  settling
followed by  neutralization  of all  wastes   and  clarification to
remove suspended solids.

    Treated effluent quality data  from Plant  #172 and Plant #559
are presented in  Table   14-10.    Plant #172  disposes of its pit
solids as solid waste and  hence does not have  a raw waste load as
great as Plant #559.

    Raw waste   priority    pollutants    found   in  significant
concentrations   during  verification  sampling  were   presented
earlier.  The  following were   selected  pollutants  which  might
require   regulation:    chromium,    lead,    nickel,   and  zinc.
Verification  sampling  results for  Plant  #559  and  #172  are
presented in Table 14-10.


Base Level Performance Characteristics  for  BPT Pollutant Removal

    Table 14-11  presents  effluent  quality  achievable  through
implementation  of  BPT  or  Level   1  treatment  technology  for

                               280

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TABLE 14-10.   RAW WASTE AND TREATED EFFLUENT QUALITY AT TITANIUM DIOXIDE -
               CHLORIDE PROCESS PLANTS
Verification Sampling:
i>Iant
Pollutant Raw Waste
kg/kkg
Total Suspended 6.06
Solids
Iron, Fe 0.104
Chromium, Cr 0.024
Lead, Pb 0.00004
Nickel, Ni 0.002
Zinc, Zn 0.010
Avg. Flow (m /kkg)
.#172
Treated Effluent
mg/1 kg/kkg
6.67 0.245
0.327 0.012
0.017 0.00062
<0.0023 <0. 000084
<0.010 <0. 00037
0.090 0.0033
35.9
Plant
Raw Waste
kg/kkg
95.9
18.7
1.55
0.049
0.048
0.027
13.9
#559*
Treated Effluent
mg/1
23.0
4.4
0.025
<0.0023
0.005
0.0617
Monitoring Data - Plant #172 Treated Effluent
Pollutant (Average)
mg/1
Total Suspended Solids, TSS 3.14
Chromium, Cr
Copper, Cu
Zinc, Zn
0.004
0.010
0.012
kg/day
8.34
0.013
0.027
0.028
kg/kkg
0.114
0.00018
0.00037
0.00038
 Loads in effluent not included because it includes other process wastes.
                                    281

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        TABLE 14-11  CONTROL PARAMETER  LIMITATIONS
     SUBCATEGORY:  Titanium Dioxide - Chloride  Process
                   Level of Treatment:  1
                Waste Water Flow:  31 m3/kkg
Pollutant
BPT Pollutants:
Total Suspended
Solids, TSS
Iron, Fe
Proposed Priori
Pollutants
Chromium, Cr
Lead, Pb
Nickel, Ni
Zinc, Zn
Subcategory
Performance
(mg/1)
6. 2
(2)
0.3
ty
0.01
(2)
<0.004
(2)
<0.01
0. 02
Quality Limit
(1) (mg/1)
WtTR _ _
30 day 24 hr
Av e r Max
2.0 37.5 75
3.0 2.0 6.0
2.0 0.1 0.2
2.0 0.5 1.0
2.0 0.5 1.0
2.0 0.5 1.0
Emission Limit
(kg/kkg)
30 day
Aver
1.2 2
0.062 0
0.003 0
0.016 0
0.016 0
0.016 0
24 hr
Max
.4
.19
.006
.031
.031
.031
(1) - VFR: ratio of the 24 hour variability  factor  to  the
         30 day variability factor.

(2) - Verfication Sampling
                            282

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titanium dioxide manufacture by  the  chloride process.


Base Level  Performance Characteristics   for  Priority  Pollutant
Removal

     Also presented in  Table  14-11  is   the  achievable effluent
quality  through implementation  of BPT technology for  additional
priority  pollutants  found to   be   significant  in screening and
verification of titanium dioxide plants.


Pretreatment Applications

     Chloride Process

     Presently no chloride  process  plant  is  discharging   to  a
POTW, however, BPT technology would  be applicable to pretreatiaent
should such a discharge occur in the  future.


Response to Remand Issues

     Chlor ide Process

     The effluent limitations  for titanium dioxide  by  chloride
process were remanded as they applied to   a process that combines
beneficiation of a low grade ilmenite ore and chlorination.   The
original  guidelines were only applicable to discharges resulting
from  chloride  process wastes,   and  did  not  include wastes from
benef iciation.   Only  two  plants   presently  use  the  cnloride
ilmenite process.  However, the  benef ic iation step is  integrated
with the  manufacturing process  in   such  a way at each plant that
waste loads cannot be separately measured.

     As a result of the remand an additonal subcategory, titanium
dioxide  by  chlor ide-ilmenite    process,   has   been  assigned.
However, further studies are necessary  before limitations  can be
developed for this subcategory.


14.2.3 Estimated Performance p_f  Advanced  Level Systems


Advanced  Level  Performance  Estimates   for   BPT  and  Priority
Pollutant Removal

     Tables 14-12 and 14-13 present  estimated achievable effluent
quality through implementation of advanced technologies.
                               283

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          TABLE 14-12  CONTROL  PARAMETER LIMITATIONS
       SUBCATEGORY: Titanium  Dioxide - Chloride Process
                     Level  of Treatment: 2
                  Waste Water Flow:  31 m3/kkg
Qual ity

Pollutant


Treatability
(mg/1)
(1)
VFR




30
(mg/


day
Aver
Limit
1)


24
Emission Limit
(kg/kkg)


hr
Max


30


day
Aver


24


hr
Max
BPT  Pollutants;

Total Suspended
Solids, TSS

Iron, Fe

Proposed Priority
15
 2.0
2.0
3.0
15
30
0.46
  2.0
 6.0  0.062
0.93
        0. 19
Pollutants
Chromium, Cr
Lead, Pb
Nickel, Ni
Zinc, Zn

0.05 2.0 0.05 0.1 0.0016 0.0031
0.1 2.0 0.1 0.2 0.0031 0.0062
0.1 2.0 0.1 . 0.2 0.0031 0.0062
0.4 2.0 0.4 0.8 0.0012 0.0024
  (1) - VFR: ratio of the  24  hour  variability factor to  the
           30 day variability  factor.
                              284

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           TABLE 14-13  CONTROL  PARAMETER LIMITATIONS
        SUBCATEGORY: Titanium  Dioxide  -  Chloride Process
                      Level of Treatment: 3
                   Waste Water Flow:  31  m3/kkg
Pollutant
Treatability
   (mg/1)
      Quality  Limit
  (1)    (mg/1)
VFR   	
      30 day   24 hr
       Av e r    Max
                                                    Emission Limit
                                                      (kg/kkg)
                                                    30 day  24 hr
                                                     Aver    Max
BPT Pollutants:
Total Suspended 15
Solids, TSS
Iron, Fe 2.0
Proposed Priority
Poll utants
Chromium, Cr 0.05
Lead, Pb 0.1
Nickel, Ni 0.1
Zinc, Zn 0.2
2.0 15 30 0.46 0.93

3.0 2.0 6.0 0.062 0.19


2.0 0.05 0.1 0.0016 0.0031
2.0 0.1 0.2 0.0031 0.0062
2.0 0.1 0.2 0.0031 0.0062
2.0 0.2 0.4 0.0062 0.012
  (1)  - VFR: ratio of the 24 hour  variability factor to the
            30 day variability  factor.
                               285

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New Source Applications

    The control   and  treatment   alternative    considered  as
applicable to new chloride process titanium  dioxide facilities is
BPT technology.   An in-plant control  alternative   is the disposal
of pit solids as solid wastes, as is  presently  practiced at  one
plant.  This will substantially  reduce   the raw  waste  pollutant
loads requiring  treatment.
14.2.4 Cost Estimates - Chloride Process
Discussion

    The costs shown at each level  of  treatment correspond to the
model plant BPT (Level 1) system and one  or  raore alternative  BAT
systems  (Level  2, 3)  which may  add  or   modify the existing BPT
system   to  meet  more  stringent  priority  pollutant   removal
requirements.  The BAT also furnishes  a   higher effluent  quality
with respect to the conventional and nonconventional parameters.

    For the  chloride process, the cost  estimates  are developed
at 1st,  2nd and 3rd levels of treatment.
Summary

    The estimated   costs  of   three   models  having  different
production  levels  are  given  in  Tables  14-14,   14-15 and 14-16.
Annual  treatment costs  as  a  function of   production  are shown
•jraphically  in  Figure  14-7.   Similarly,   treatment costs  pec-
metric ton of product are given  in Figure 14-8.

    Table 14-17 presents a summary of  the  unit  cost distribution
between  amortization  and  the  operation   and   maintenance cost
components at various production and levels  of treatment.

    In model plant costs for existing  sources at the base  level
of  treatment,  amortization, chemicals  and  the  residual waste
disposal costs have a significant  inpact  on  the  annual costs.  At
treatment  Levels  2  &  3,  amortization,   chemicals  and  labor
constitute a major portion of the  additional annual costs.
                              286

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                    TABLE 14-14.  MODEL PLANT TREATMENT COSTS

   Subcategory  TITANIIM DIOXIDE  Chloride           Type of Regulation BAT

   Production        16,900 metric tons per year (  18,632 tons per year)
                         48 metric tons per day  (      53 tons per day )
   Waste water flow    1485 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	              $368,500           $49,000
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               209,000           389,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	               117,300            87,600
    Incidentals, overhead,
    fees, contingencies—               117,300            87,600
    Land	               192,000             6,000

    TOTAL INVESTMENT COST             $1,013,100          $619,200

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $56,000           $84,000
    Energy	                 3,700             4,300
    Chemicals	               140,000            34,100
    Maintenance		                82,110            61,320
    Taxes and insurance...                30,393            18,576
    Residual waste
    disposal	               108,000             9,000
    Monitoring, analysis
    and reporting	                15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $435,203          $218,796

C.  .AMORTIZATION OF
    INVESTMENT COST                     $133,592           $99,767

    TOTAL ANNUAL COST                   $568,795          $318,563


    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.

                                     287

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                   TABLE 14-15.  MODEL PLANT TREATMENT COSTS
                                                     Type  of Regulation  BAT
  Subcategory  TITANIIM DIOXIDE  Chloride

  Production        25,500 metric tons per year  (   28,113 tons per year)
                        72 metric tons per day   (       80 tons per day )
  Waste water flow    2240 cubic meters per day.


                                            LEVEL  OF  TREATMENT*

                                          FIRST             SECOND
A.   INVESTMENT COST

    Construction 	              $525,000            $50,800
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               228,000            450,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	               152,400            100,160
    Incidentals, overhead,
    fees, contingencies...               152,400            100,160
    Land	               276,000              6,000

    TOTAL INVESTMENT COST             $1,342,800           $707,120

B.   OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $56,000            $84,000
    Energy	                 4,000              5,500
    Chemicals	               211,000             51,000
    Maintenance	               106,680             70,112
    Taxes and insurance...                40,284             21,213
    Residual waste
    disposal	               164,000             11,000
    Monitoring, analysis
    and reporting	                15,000              7,500
   TOTAL OPERATION AND
   MAINTENANCE COST

C.  AMORTIZATION OF
   INVESTMENT COST

   TOTAL ANNUAL COST
                                        $596,964


                                        $173,568

                                        $770,532
$250,325


$114,072

$364,397
   *First level represents the base cost of  treatment system.
   Other levels represent the incremental  cost  above base cost.
                                    288

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                    TABLE 14-16.  MODEL PLANT TREATMENT COSTS

   Subcategory  TITANIUM DIOXIDE  Chloride           Type of Regulation BAT

   Production        45,200 metric tons per year (  49,833 tons per year)
                        129 metric tons per day  (     142 tons per day )
   Waste water flow    3980 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	              $815,500           $76,800
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               283,000           590,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	               221,500           133,360
    Incidentals, overhead,
    fees, contingencies...               221,500           133,360
    Land	               504,000             6,000

    TOTAL INVESTMENT COST             $2,054,500          $939,520

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $56,000           $84,000
    Energy	                 4,600             7,650
    Chemicals	               374,000            95,000
    Maintenance	               155,050            93,352
    Taxes and insurance...                61,635            28,185
    Residual waste
    disposal	               294,000            20,000
    Monitoring, analysis
    and reporting	                15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $960,285          $335,687

C.  AMORTIZATION OF
    INVESTMENT COST                     $252,266          $151,883

    TOTAL ANNUAL COST                 $1,212,551          $4 87,570


    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.

                                     289

-------
   2.0
O
o
o
      \ f VFT . Jt? «r
iiL
 I/
o
o
o
X_
 t  1.5
X
8
u
              #1
                  \  I
   i.o
                    i  i
   0.5
              10        20       30       40       50


              PRODUCTION, METRIC TONS/YEAR X 1000



   Figure 14-7.  Annual treatment cost vs. production for the

          Titanium Dioxide Subcategory, Chloride Process
                             290

-------
   60
   50
                                    TT
*  40
                                   'XJ
                                                         #2-8
   30
                                                  LEVEL W.
   20
              10        20        30        40

               PRODUCTION, METRIC TONS/YEAR X 1000

   Figure 14-8.  Annual unit treatment cost vs. production for the
        Titanium Dioxide  Subcategory,  Chloride Process
                             291

-------
                TABLE  14-17   MODEL PLANT TREATMENT COSTS
Subcategory  TITANIUM DIOXIDE  Chloride
                              Type of  Regulation   BAT
                                           Annual Treatment Costs ($/kkg)
                                                 LEVEL OF TREATMENT
                  PRODUCTION   FLOW
                  (kkg/yr)  (m3/day)
FIRST
$
SECOND
$
THIRD
$
FOURTH
$
Annual  Operation
and Maintenance
Annual
Amortization
Total  Cost
16,900
25,500
45,200
16,900
25,500
45,200

16,900
25,500
45,200
1,485
2,240
3,980
1,485
2,240
3,980

1,485
2,240
3,980
25.75
23.41
21.25
 7.90
 6.81
 5.58
33.66
30.22
26.83
12.95
 9.82
 7.43
 5.90
 4.47
 3.36

18.85
14.29
10.79
13.27
10.09
 7.65
 6.
 4.
 3.
07
60
47
19.33
14.68
11.12
        Not
     Applicable
                                 292

-------
14.3 ASSESSMENT OF  THE WATER   POLLUTION POTENTIAL OF THE SULFATE
PROCESS
14.3.1 Industry Pj_o_fjL_l_e and  Analytical Results
Sulfate Process Industry

     The industrial profile   for   this  subcategory is  given  in
Table 14-18 and existing  regulations in Table 14-2.

     Tne priority pollutants  found at  significant levels in  the
raw  waste during  sampling at  Titanium Dioxide - Sulfate Process
plants were as follows:
     Pollutant
Maximum Concentration  Observed  (ug/1)
                     Ver ification
        Screening       (2 Plants)
Cadmium
Chromi urn
Copper
Lead
Nickel
Z inc
Phenol
Silver
Antimony
Arsenic
Thallium
338
123,600
1475
3729
6370
3840
20
64
20
11
19
11.7
30,600
1,000
5,193
1,295
16,610
No Sample Taken
<15
1,400
340
41
     A summary of daily  and  unit  product raw waste loads for all
plants sampled can be found  in  Table  14-19.   Individual plant raw
waste loads per unit  product  found  in sampling can be found  in
Table 14-20.

     Based on the total  annual  production of this subcategory and
the average waste load generated  per  unit product,  the estimated
total priority pollutant raw  waste loads generated each year for
this subcategory are as  follows:
                               293

-------
TAB.	-
SUBCATEGORY PROFILE DATA .SUMMARY
SUH
TITANIUM DIOXIDE   SULFATE PROCESS
Totitegory capacity rate
Totitegory production rate
Numllants in this  subcategory
308. file for
    tal  capacity of
    ital  production of
    nting capacity
    nting production
    reduction range:
     Minimum
     Maximum
     production
    production
     capacity utilization
    ge range:
     Minimum
     Maximum
    ter  flow range:
     Minimum
     Maximum
    per  unit product:
     Minimum
     Maximum
                           401,000 kkg/year
                           259,000 kkg/year
                                 5
                                 5
                           320,000 kkg/year
                           246,000 kkg/year
                                80 percent
                                95 percent

                            31,000 kkg/year
                            74,500 kkg/year
                            49,000 kkg/year
                            43,000 kkg/year
                                76 percent

                                23 years
                                54 years

                            35,000 cubic meters/day
                           125,000 cubic meters/day

                               300 cubic meters/kkg
                               780 cubic meters/kkg
Sou;data are Stanford Research Institute, Directory of Chemical
Prau.S.A., 1977, U.S. Department of Commerce, Current Industrial
Repecenber 1977; Energy and Environmental Analysis, Inc.; Draft
Repreliminary Economic Assessment of Effluent Limitations in the
Inochemical Industry."
                         293A

-------
TABLE 14-19 .   SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING

SUBCATEGORY TITANIUM DIOXIDE - SULFATE PROCESS
Pollutant
Minimum
Priority
Antimony, Sb 7.66
Arsenic, As
Cadmium, Cd 0.091
Chromium, Cr 132
Copper, Cu 8.30
Lead, Pb 3.28
Nickel, Ni 8.30
Thallium, Tl
Zinc, Zn 53.4
Organic s
Phenol 0 . 20
Conventional
TSS
Iiron Fe
Loadings
kg/day
Average Maximum Minimum

18.0 28.3 0.08
1.31
2.40 6.85 0.0009
200 327 1.36
11.6 15.1 0.094
8.56 12.4 0.037
11.5 14.7 0.086
0.76
55.3 57.1 0.55


2O478
58452
kg/kkg
Average

0.21
0.014
0.027
2.11
0.12
0.089
0.12
0.0078
0.57

0.002
211
6O2
No. of Plants
Maximum Averaged

0.32 2
1
0.078 3
3.37 3
0.16 3
0.13 3
0.15 2
1
0.59 2





-------
TABLE).   PRIORITY POLLUTANT RAW WASTE LOADS  CLn kg/kkg of Product)
SUBCA
PQLLU

Cadmi
Chromr
Coppe
Arsen.
Lead,
Nicke.
Zinc,
Antimo
Pheno.
Thalli
TITANIUM DIOXIDE

#559
0.0009
3.37
0.118
0.0135
0.103
0.151
0.55
0.08

0.0078
- SULFATE PROCESS
PLANT
#559
0.003
1.36
0.155

0.128
0.086
0.589

0.002



#555
0.078
1.61
0.094

0.037


0.322


                              295

-------
          Pollutant
                          Waste  Load  (kg/year]
          Cadrai urn
          Chroraiuw
          Copper
          Lead
          Nickel
          Zinc
          Antimony
                               7000
                             548000
                              31000
                              23000
                              31000
                             150000
                              54000
14.3.2 Process Waste Sources  and  Waste Treatment Data
Sulfate Process - General Description

     Among the  various  titanium   ores,  ilmenite is  available in
abundance.  Ilmenite   is  a   low-grade titanium ore with  a  Ti02
content varying from 45  to 60  percent. Ilmenite ore and slag  from
iron production generally comprise the raw materials used for the
preparation of titanium  dioxide  by the  sulfate  process.   Large
amounts of  water and  sulfuric acid are  used in this process, and
the  majority  of  the   plants are co-located with sulfuric  acid
plants. Table  14-21 gives the analysis  of various ilmenite ores.
The  preparation of  Ti02  by  the  sulfate process utilizes  three
important steps:
(1)    Digestion:    FeO.Ti02  +  2H2 S04 =  feS04 + TiO.S04 + 2H20

(2)    Precipitation: TiO.S04  +  21-120 =  Ti02.H20 + H2S04

(3)    Calcination:  Ti02.H20  =    Ti02 +  ti20
     The ore is dried,  ground   and   then reacted  with  sulfuric
acid.  The reaction  takes  place  at   160 degrees C and the reacted
mixture consists of  titanyl,   ferrous, and ferric sulfates.  The
total iron in the reacted  product  is kept in the ferrous state by
the  addition of scrap  iron.  After  the reduction, the product is
dissolved in water   and  clarified  with the aid  of  flocculating
agents to remove insoluble impurities such as silicon,  zirconium
    unreacted ore.   The iron  is removed from the clear  solution
    cooling  the  solution  to   10   degrees  C   when  FeS04.7H20
                  ferrous   sulfate  crystals, commercial copperas,
                  separated   from  the  solution by  filtration or
                  The concentrated   titanyl  sulfate  solution is
                   and  heated  to form  titanium  dioxide  hydrate
                                                              the
and
by
crystallizes. The
are mechanically
centrifugation.
diluted with water
which precipitates  out.   The   suspension  is  filtered  and
filtrate, wnich  is known  as  strong  acid, is separated and either
discharged or recycled.  The  Ti02.H20 filter residue is  slurried
with water and  conditioning  agents  are added to control particle

                                296

-------
             TABLE 14-21 . ANALYSIS OF ILMENITE ORES
-0

Chemical
Constituent
Ti02
FeO
Fe2°3
Si°2
A1203
P2°5
Zr02
MgO
Mrt)
CaO
V2°5
Cr 0
UNITED STATES
Virginia
Piney
River Roseland New York
44.3
35.9
13.8
2.0
1.21
1.01
0.55
0.07
0.52
0.15
0.16
0.27
51.4
37.9
1.6
4.6
0.55
0.17

2.35
0.70
0.59
0.07

44.4
36.7
4.4
3.2
0.19
0.07
0.006
0.80
0.35
1.0
0.24
0.001
Florida
64.1
4.7
25.6
0.3
1.5
0.21

0.35
1.35
0.13
0.13
0.1
California
48.2
39.1
10.4
1.4
0.2

0.05
0.6
0.1
0.1
0.05
0.03
Ivry
42.5
39.1
20.7
0.88
1.05


2.0
0.04
0.1
0.36
0.15
CANADA
Bourget Allard
22.4 37.3
36.9 26.3
31.2 30.0
1.0
6.01
0.93 0.004

1.50
0.10
0.55
0.39

             Constituents expressed as weight percent.

-------
size,  color, dispersibility   and  photochemical  stability.
conditioning agents  include potassium,  zinc, antimony and calcium
compounds, and phosphate  salts.   The solution is filtered and  the
filtrate  is  known  as   weaK   acid.   Residual  acid  and   iron
originally present in  the precipitate  are removed with the water
of hydration by calcination. The  resulting Ti02  pigment is  sent
to finishing operations,  which vary acccording to the end product
requirement  and application.   The wet   finishing operations  may
include some, or all, of  the following  steps; repulping, milling,
surface treatment  with proprietary agents in solution,  washing,
and drying. The alternative dry finishing  operations may include
one or  more milling steps  followed  by packaging.  A simplified
block diagram of the sulfate process is shown in Figure 14-9.
Water use and Waste Source  Inventory

     Water use - Water   is  used   in  the preparation of  titanium
dioxide  by  the sulfate  process  for  noncontact  cooling,  air
emission control and  for  process  reactions. In the process, water
is used to leach the  soluble  sulfate salts from the reaction mass
and to convert  the titanyl sulfate to titanium  dioxide hydrate.
Water  is  also  used   to   wash   the  titanium  dioxide   hydrate
precipitate free   from  residual  acid and iron.  Water is used for
air emission control  during the  drying of ore,  on digester units
and for the cleaning  of  the kiln  gases before they are vented  to
the atmosphere.    In  the  digester  unit,  water seals are used to
maintain a vacuum  on  the  digester  units.  Large amounts of water
are also  used  in the   finishing operations.   Table 14-22 is  a
summary of water   usage  in  the  titanium dioxide subcategory using
the sulfate process.

     Waste sources
     A.  Digester Sludge:   After   the  digestion  of  the  ore in
sulfuric acid, the  resulting  sulfates are dissolved  in water and
the  insoluble   impurities  are  removed in a clarifier or filter.
These  include silica,  alumina,  sulfuric acid and unreacted iron.
The  quality of  this waste  varies and depends on the  type and
quality  of  ore  used.   Data   on  the  quantity of  this  waste
indicates that approximately  210  kkg/kkg is produced.


     B.  Copperas:  The   recovered ferrous sulfate is marketed or
disposed of as a solid  waste.   The amount  of  copperas generated
is about  950 kg/kkg of   Ti02.   The  copperas generally  contains
small amounts of adsorbed sulfuric acid.
                               298

-------
NJ



STRONG-ACID
	 RECYCLE ,_
WATER 	 ••
STEAM *
*
DIGESTER

WATER 	 ^.
WATER 	 *j
CLARIFIER
k
	 EMISSIONS 	 to-
SPRAY CON[
WATER 	 to AND VENTURI £


EVAPORATOR H ™^°»* — '
1 WATER 	 *•
|

STEAM 	 to
PRECIPITATION
t


«. icDoa
JCRUBBERS fc«WJfcWl' *"


.^
^jyEHS El-'fLUENT "" ^"

FLASH 1 CONDENSERS 	 pppr riPNT — >•
COOLER 1 „,„„„ — *• EFFLUENT

WEAK-ACID i 1
RECYCLE ^i 	 " 	 1 J
WATER — to
FIRST MOORE
PTT TPR
STEAM — fcj . j.^..^.. 	 ,
WATER — »>
STEAM *"

WATER 	 *•
STEAM 	 to
DI
SECOND MOORE
FILTER

	 * 	 STRONG AU1U 	
WEAK A^TP


^^ _



CALCINER

WET MILL
—EMISSIONS 	 M. COOLING SPRAYS AND ELEC ; 	 WEAR flCID_
WATER 	 toTROSTATIC PRECIPITATORS "
EMISSIONS
WATER 	 *" MIST ELIM
KPirT.llENT

1

JET MILLS
___t,Mlbb!UWti 	 to
JET MILL C
WATER 	 to
TITANIUM
DXIDE PIGMENT
i
PACKAGING

1NATURS "• EFFLUENT ^ -






WATER 	 ^ JET MILL SCRUBBERS ^, EFFLUENT 	


                                                                                                                                           -WASTO DISPOSAL
                                                 T
                                               TO SALES
                                                      Figure 14-9.   General process flow diagram for production of titaniun dioxide I'jy sulfate process.

-------
TABLE  14-22.  WATER USAGE IN TITANIUM DIOXIDE - SULFATE PROCESS SUBCATEGORY
                          Water Usage  per Unit of Production
Uses                               m3/kkg of Ti02

Non-contact

cooling
Direct process contact
Indirect prc
jcess contact
Plant #555
47.8
390
6
Plant #694
408
588
1.6
Plant #696
149
297
4
 (pumps, seals, leaks,
 spills, etc.)

Maintenance, equipment           3                1.8              4
cleaning and work area
washdown

Air pollution control          258               78               81

Non-contact ancillary           36               33               NA
uses (boilers, utilities,
etc.)
                                    300

-------
    C.  Strong  Acid Waste:   When water   is   added   to  titanyl
sulfate solution after the removal of copperas,  sulfuric acid and
the hydrate of titanium dioxide  are formed.    The  acid contained
in solution is removed by filtration and the  filtrate is known as
strong acid solution.  The  concentration  of  sulfuric acid varies
from 15-30 percent as H2S04.  In  addition to  sulfuric  acid, the
waste  stream  contains  ferrous  sulfate,  titania,  antimony  and
other heavy metal  salts.  A part of the acid  is returned to  the
process and the rest sent to the treatment facility.


    D.  Weak  Acid  Waste  Stream:   The   waste  generated  from
washing the titanium dioxide hydrate precipitate is  known as weak
acid.  The  concentration of sulfuric acid in   this   waste varies
from  two  to   four  percent  as  H2S04   and   contains   various
impurities, including  iron sulfate, titania,  antimony  and other
heavy  metal  salts.   It  also  includes,   in  some   cases,  the
conditioning agents added to the precipitate  prior  to washing, to
control  and  improve the quality of the final product.  The weak
acid may also include tne kiln exhaust  gas scrubber  waste.


    E.  Scrubber Wastes:  Scrubber waste  water  results from the
scrubbing of vapors emitted  during the drying of the ore, during
digestion,  and  during kiln  drying.   The  amount  of waste water
generated  depends on  the  amount  of  water   used  and  type  of
emission   controls  practiced.    The  scrubber  water  contains
titanium  dioxide  particulates, acid mist,   sulfur  trioxide  and
sulfur  dioxide.   Of  all   the  waste produced  from  titanium
dioxide-sulfate  process  manufacture   subcategory,   the scrubber
waste water constitutes the major portion.


    F.  Wet Milling Waste:   These wastes are  generated  during
wet finishing of  the  titanium dioxide pigment.  Wet milling is
used to produce pigment particles of the desired size and surface
character and requires steam and water  for repulping  the pigment.
Caustic soda is also used to remove any residual acidity from the
titanium  dioxide pigment during  the   finishing operation.   The
waste water  from wet  finishing  operations,  therefore, contains
titania, sodium sulfate  and  other  agents  added   to improve or
achieve desired properties  in the final product.


Control and Treatment Practices

    BPT:  The recommended  technology  for  3PT is  neutralization
of the Ti02 sulfate  process  waste  waters with lime or  caustic
soda and  removal  of  suspended  solids   in   settling  ponds  or
clarifier-thickener combinations.

    Plant #559 was sampled  in  the  screening and   verification

                              301

-------
phase. At this  plant  the  strong acid is sent to  a  lined  holding
pond for equalization.   The  effluent from the pond  is  neutralized
with ground  calcium   carbonate  in a reactor;  just a   sufficient
amount is  added   to   raise  the pH  to a level  such that  calcium
sulfate, but  not   ferrous hydroxide, is  precipitated.  The  C02
formed during  the  reaction is vented to the atmosphere and  the
calcium  sulfate slurry  goes to a clarifier.   The  underflow Eron
the clarifier  is   filtered  to produce  pure gypsum crystals at a
concentration of 70-80 percent.

     The weak acid  is   sent  to  a settling  pond,  where  it is
combined with a small  quantity  of other  wastes.   The  effluent
from  the  weak  acid  pond   is mixed  with  the  calcium  sulfate
clarifier  overflow and  neutralized with ground calcium carbonate
in a three-stage reactor.  Pebble  and slaked lime are  also added
to  raise  the  pH  and   precipitate more calcium  sulfate.  Air is
also  introduced to convert the  ferrous  iron to   ferric.   The
effluent  from  the reactor   goes to another  clarifier,  and the
clarifier  underflow is  filtered to concentrate the solids to 70
percent.   The overflow  from the second  clarifier  is mixed with
the  other process  waste  waters.  These  include   the scrubber,
finishing  and  cooling  waste  waters.  The  combined  water is
neutralized with slaked  lime  before  it  is   sent to  a  final
settling pond, the  effluent  from  which  is   discharged. Figure
14-10 gives the  flow  diagram  of the treatment process and shows
the  sampling  locations  for both  screening   and   verification.
Table  14-23  gives the  flow data for  the  waste  streams  and
significant pollutant  emissions.

     At Plant #555, all  the  process  effluent goes   to a settling
basin, the effluent from  which is discharged.   The   solids  are
dredged  and accumulated on  the plant  property.  Future plans are
to dispose of the  solids in  an approved landfill.

     At Plant  #694, the clarification sludge which contains  the
unreacted ore is sent  to  waste disposal.  The  weak acid effluent
from the plant  is  neutralized with slaked liiae  and  the grit is
settled out for landfill disposal.  After the separation of grit,
the aqueous stream  is  discharged to a municipal treatment system.
The other wastes,  together  with  runoff from the plant site, are
collected  and  sent to  a  lagoon  for  solids  removal,  and the
overflow discharges to a river.

     At Plant #696,  the  raw  wastes are sent  to  thickeners to
remove  the  suspended   solids  and the  overflow is  discharged.
Depending  on  the  titanium  content,  the  underflow from  the
thickeners is either recycled or disposed of in a landfill.

     At Plant 4605, the  process raw waste  streams are  combined
and sent to a reactor  for  neutralization with a   water slurry of
finely ground calcium  carbonate. The effluent from  the reactor is
hydrocycloned into  three  fractions. The first  fraction, which is

                                302

-------
                    OTHER PRODUCT
                     WASTE WATER
     WEAK ACID 	1
     WASTE STREAM
-e-
                                        «4
U)
o
U)
    STRONG ACID—^
    WASTE STREAM
                                                                                                       SOLIDS TO
                                                                                                        STORAGE/
                                                                                                        LANDFILL
                                                                                              PRODUCT
                                                                                         WASTE WATER
                                                                                                               TiO, (SULFATE PROCESS)
                                                                                                               SCRUBBER
                                                                                                               WASTE WATER
                                                                                              ) Waste streams sampled.
                                                                    SOLIDS
                                                                     TO
                                                                STORAGE/LMCFILL
                                                    Figure  14-10.  General flow diagram at Plant  1559 showing  the sampling points.
                                                                             Titanium Dioxide (Sulfate Process)

-------
TABLE  14-23 .  FLOW AND POLLUTANT CONCENTRATION DATA OF THE WASTE STREAMS
              SAMPLED FOR PLANT #559 PRODUCING TITANIUM DIOXIDE (SULFATE PROCESS)
Stream
No.


Sampled
Stream
Description

Unit
Flow
m /kkg
of TiO
SS
Load
kg/kkg
of TiO-
Iron
Load
kg/kkg
of TiO_
Chromium
Load
kg/kkg
of TiO~
Weak Acid Pond
Overflow

Strong Acid Pond
Overflow

Scrubber and
other Product
Waste Water

Final Treatment
Effluent
                             107
          305
                                                       <«
                               9.7
  1.94
87.6
0.18
                             583
183
                                             (1)
83.6(1)      0.062(1)
                             700(1)'(2)    16.1
            3.08
             0.017
 (1) = The pollutant load was calculated by multiplying the flow contributed
       by the sulfate process stream times  the concentration of pollutant.
       Pollutant Load =  (total stream flow)x(fraction contributed by sulfate
       process waste) x stream pollutant concentrated.
 (2) = While calculating the unit flow the  contributions to the treatment
       process from precipitation,  the water  in the treatment chemicals,
       losses from evaporation and  from solids leaving the process nave
       not been considered.
                                     304

-------
the coarse gypsum slurry,  is separated  from  the  reactor effluent
at   a   concentration   of  85-90   percent,   and  placed  in  a
self-draining dewatering system.   The   "dry"   solids are finally
trucked  to  a  landfill.  The second   fraction  separated in the
hydrocyclone is a  fine gypsum slurry   which  is  recycled to  the
neutralization reactor.  The residual gel  slurry  forms the  third
fraction, and this is sent to a  thickener  after C02 degassing.  A
flocculating  agent  is added to the  flow to  the  thickener to
oromote solids separation and thickening.   The  underflow (from the
thickener is centrifuged and the solids  landfilied.  The filtrate
from  the  centrifuge   is recycled   to   the  thickener,  and  the
thickener overflow is discharged.


Evaluation of Industry  Production and Waste Flow  Data

    The volume and characteristics  of   waste  water  streams from
different sulfate process titanium dioxide plants do  not differ
yreatly.   Some  variations, however, are  noted  as  a result  of
differences  in ore qualities, in location  and  in  process details.
The majority of the dissolved pollutants in waste water from this
segment  of  the Ti02   industry  consist  of   acidity  and  iron.
Segregation  of  the  waste  water is  important for  control  and
treatment  practices and aids in developing economically feasible
treatment systems. Generally,  weak  and  strong   acid stream are
segregated from each other as well as from the  less  contaminated
waste waters  which include contact  cooling,   scrubbing and  some
finishing operation wastes.  The  unit  flows   for the  segregated
raw  waste streams  at  different  facilities   are shown in Table
14-24.   Waste characteristics for Plant #555  are given in  Table
14-25.
Process Modifications and Technology  Transfer Options

     Specific process  modifications  cannot be  made at  present.
However, several areas  for  further   research suggest themselves.
They  are:

     1.  One of the waterborne   wastes,  the strong  sulfuric acid
produced  from the  Ti02  sulfate  process, has a  sulfuric  acid
concentration   that  varies   from   15-30   percent   as  H2S04.
Currently, only a small  portion of  it  is recycled.  Research is
needed to find cost-effective ways to  concentrate the acid to 90
percent and to eliminate the impurities  (especially iron) so that
it can be reused  in the  digester.    This will eliminate much of
the alkali  requirements for neutralization and relieve  disposal
problems associated with solid  waste  gypsurn.


     2.  Economical methods  need to be developed for the recovery
°f iron oxide, aluminum and  vanadium  from  the waste to the extent

                             305

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TABLE 14-24.  EFFLUENT FLOW AT PLANTS #555, #605  AND  #559 PRODUCING
              TITANIUM DIOXIDE (SULFATE PROCESS)
Waste Stream                    Flow in m /metric ton of TiO  at plant
                            Plant #555       Plant #605       Plant #559

Strong Acid                       8.49              7.8             7.4

Weak Acid                        78.2              93              85

Other process waste water       362               597              NA
NA = Not Available
                                   306

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     14- 25. RAW WASTE CHARACTERISTICS (INDUSTRY DATA) FOR PLANT #555
             (PRODUCTION OF Ti02 BY SULFATE PROCESS)
— • 	 ' 	 '
Waste Source Unit
Flow
m /kkg
of Ti02
Digestion 115
Clarification 3 . 58
Evaporation 113
Cooling 20
Strong Acid from 8.49
first Moore Filtration
Weak Acid from 12.2
first Moore Filtration
Weak Acid from 10.4
second Moore Filtration
Weak Acid from 12.0
first stage
Calcination
Weak Acid from 40.0
second stage
Calcination
Calcination Mist 38.7
Eliminators
Wet Milling Washing 11.1
and Drying
Jet-Mill Condenser 27.0
Jet Mill Scrubbers 18.0
Boiler and Water 16.6
Pollutant Waste Loads, kg/kkg of Ti00
*
PH
3.0
2.5
4.0
6.1
<0.5

2.0

1.7

2.0


2.2


3.0

8.0

6.5
7.4
9.0

Acidity
(as H2S04)
20.8
26.7
18.7
2.49
2.360

88.3

148

20.8


19.2


7.50

_

-
-
-

NH3 Fe
(as N)
0.042
8.42
1.14
0.099
- 139

3.8

0.29

0.22


0.64


0.02

8.6 0.01

0.01
0.13
-.66

TSS
9.3
175
3.2
0.46
0.959

0.23

0.13

2.0


4.92


0.21

2.13

1.1
1.7
5.25
£,
TDS
35.7
40.8
20.2
3.09
2.815

98.8

151

7.50


33.1


27.9

11.0

2.7
3.58
8.92
Plants
 Value in pH units.
                                  307

-------
that markets are available  for  these materials.


     3.  If markets  could   be  developed for the sale of  ferrous
sulfate  (copperas) ,  solid   waste  disposal  problems  would  be
reduced.  Currently, a portion  is   sold  and the rest disposed of
as a solid waste.


Best Management Practices

     1.  Storm water runoff   from  the plant site  and surrounding
areas can be collected and  sent to the treatment facility.


Model Plant and BPT Level Treatment System Specifications

     Model plants  were   selected  to provide  the basis  for cost
estimates.  The  rationale   used   for  their  selection  is given
below.

     Production -   Five  plants produce  titanium dioxide by the
sulfate process at  a total  production rate of 246,000 metric tons
per year.  Production ranges from  a minimum of 31,000 kkg/yr to a
maximum  of 74,500  kkg/yr   with  a  mean  of 49,000 kkg/yr and  a
median  of  43,000  ki

-------
one-third (100  kg/kkg  of  Ti02)  was  soluble ferrous iron.  The
unit sulfate and suspended solid loadings  for  the different waste
,vater streams for the model plant were:


                    Sulfate Loading        T3S Loading
      Stream        kg/kkg of Ti02        Kg/kkg of Ti02
Weak Acid
Strong Acid
Other Waste Water
2,300
1,800
Neglig ible
300
3
25
    Chemicals Us ed:   In the model  BPT  system,  powdered limestone
is  used for first stage neutralization of  mixed strong  and weak
acids, at  the unit  rate  of 3,000  kg/kkg  of  Ti02.   Pebble lime
(CaO)  is  used for second stage   neutralization of the mixed acid
streams and  for final neutralization of the total combined flow,
including the  other  miscellaneous  wastes.   The unit application
of CaO for  all  purposes is  .235  kg/kkg of Ti02.   In  Level  2
(BAT) , soda ash is added to  45%  of  the "other   waste" flow at an
approximate dosage of 130  ug/1,   to  permit partial  recycle  for
miscellaneous purposes.

    Sol ids Produced;   Although   some   existing   plants   have
attempted  to  produce  two grades  of saleable   gypsum  from  the
strong  and  weak  acid  streams,   at   present   there  is  not  a
sufficient market for gypsurn to justify byproduct gypsum recovery
in  the  model plants. The  solids   produced  from  the treatment
facility  consist  of   gypsum,   iron   oxide,  and  the  original
suspended  solids introduced  in the  influent.   The  total solids
produced in  the model  plant  are  assumed  to be  5,500 kg/kkg of
Ti02.

    Additional solids generated   in the soda   ash  treatment of
"other wastes" at Level 2  are only  a few hundred pounds per day,
and   are  considered  a  negligible  increase   in  total  solids
production.  These additional solids are periodically transferred
from the  recycle polishing ponds   to the  main treatment  system
just  ahead of the aeration step.   In   this  way, the  additional
quantity of priority metals  will  be subjected  to the ferric iron
flocculation, lime  treatment  and  settling sequence   in the  BPT
system.
                               309

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14.4 TECHNOLOGY BASED POLLUTION  ABATEMENT


14.4.1 Advanced Level Treatment  Applications


Selection of Technology to  be  Applied

     Sulfate process  - BPT  -  Two  levels  of treatment  are shown
for  the  sulfate  process   model,   utilizing  calcium  carbonate
neutralization for the blended strong  and  weak acid streams. The
priority  pollutants are  precipitated and  together  along with
gypsum  are separated in  first-stage thickeners.    Aeration then
oxidizes any ferrous iron present  and  removes  C02 before  mixing
with miscellaneous plant wastes  containing minor amounts of heavy
metal priority  pollutants.    The  combined stream is  then  given
lime treatment to  pH 9   and   settled  in polishing lagoons before
discharge.   This three-step system  is patterned  after existing
systems which separate the  acid  streams from miscellaneous wastes
in order to make possible the  recovery of pure and impure  gypsum
from   the   relatively   consistent   acid   streams.   Alkaline
precipitation of heavy uietals, and  significant removal of arsenic
occur  during the last  two  stages   of  lime  neutralization, and
settling of precipitated  priority  pollutants occurs in  the final
polishing lagoons.   Because waste  flow rates are  unusually high
in the sulfate  process,  long-term   lagoon settling is more cost
effective  than  dual  media filtration. The  mechanical aeration
step used for oxidizing ferrous  iron may contribute an  important
mechanism  for  the simultaneous removal of  other  heavy  metals
present  very  similar  to   the   ferrite  coprecipi tation  method
described in the Treatment  Technology  Assessment section.

     Although the  Model  Plant  does  not include  equipment for
gypsum recovery, it  is   based on   separation  of  waste streams,
making pure  or  impure  gypsum  recovery possible by intercepting
thickener   underflow(s) .    Recovery  of  gypsum  as  a  saleable
by-product is not possible  since no market exists.

     Level 2_ -  Level  2  for  the   sulfate process  employs the
described BPT treatment for  strong  acid, weak acid and 55% of the
"other  wastes". The  remaining   other  wastes  receive soda ash
treatment and settling, to  permit  recycling a nonscaling effluent
for scrubbers and miscellaneous  uses.   Heavy  metal pollutants in
the  separated  recycle   stream   are  settled  as carbonates and
periodically removed to a secure landfill.

     Equipment functions  -  Treatment   of  waste water  from the
sulfate  process  involves   the   mechanized  handling  of   large
quantities of chemicals and  reaction products,  primarily gypsum.
     The BPT  model   includes   rail  car  deliveries  of
limestone  and  lime,   bucket   elevators, storage  bins, multiple
                                310

-------
feeders,  mechanical feeders, mechanical   aerators  and two-stage
thickening for removal  of pure and  iron-bearing   gypsum from the
treated  acid waste streams. Calcium  saturated  thickener overflow
and  miscellaneous   other  waters  are   subjected  to   alkaline
precipitation and settled in a one-day polishing  pond.   In Level
2, to reduce the mass discharge of  heavy metals,  only 55% of the
BPT  "other waste"  flow joins the treated  acid waste stream, for
BPT  treatment as described above.  However,  the remaining 45%  of
"other wastes" is given  separate treatment  with  soda ash settled
in a lagoon, for recycle to miscellaneous scrubber and noncontacc
cooling purposes.  Treatment of the strong  and  weak acid streams,
including oxidation and  settling  of  ferrous  iron,  remains the
same as in the BPT model.
    Chemicals and  handling -  Sulfate   PfJ^E.6^.  ~  First  stage
neutralization employs ground limestone,  while lime is  used  for
second  stage  and  final  alkaline    precipitation.    Oxygen  is
supplied from  atmospheric ai, and   polymer  is added  to assist in
the  second stage settling of iron hydroxide.   Aside from the bulk
handling of large amounts of these common chemicals,  there are no
special hazards involved in their use.

    Separation and  removal p_f_  solids   -  Large  quantities  of
thickener   underflow   are   pumped   to    spreading    areas  for
consolidation of the  solids, which  are later  pushed  into 18 foot
high piles  on land provided for 10  years of   operation.  Solids
from occasional draining of  the polishing lagoon and the Level 2
recycling lagoon are returned to the  aeration  step  of  the waste
acid streams, after which they  will  be settled out in the second
stage  thickener,  being  handled  as  part  of  the   thickener
underflow.  Although  no  dewatering   equipment  is provided, the
first and  second  stage thickeners  can be  sources of  pure  and
impure gypsum for future by-product  recovery.

    Monitoring requi rements - The   same  monitoring  requirements
apply as for  the  chloride " process, with   the  addition of the
internal process needed to monitor the scaling tendency and total
dissolved solids in the recycled "other wastes", in order to keep
the  recycle stream at a suitable level of mineral content.

    Figures 14-11 and  14-12  show  the   raodel treatment  systems
ohosen for this subcategory.


14.4.2  Base  Level Performance Chajrac t e r 1st i cs for BPT Pollutant
Removal

    The production  of titanium  dioxide by the sulfate  process
generates  extremely  large waste  loads   of  sulfuric  acid  and
ferrous sulfate,  as well as considerable quantities of suspended
solids.    Effective   control    and    treatment    of    these
wastes — comprised of  segregation of  the  most  highly contaminated

                             311

-------
OJ
                             GROUND
                           UWKSTONE
                             CaCO
                                                                                                                                                                                                   EFFLUENT
                  WASTE  WATER
                                                                                                                  SOUDS DISPOSAL
                                                                                                                     ONSITE
                                                      Include* flow monitoring,  pll monitoring and sampler
                                                                Figure  14-11. Han to water treatment Level I for titan Urn d lax tele  - BulfaLe process.

-------
CO
                               GROUND
                             LIMESTONE
                                CaCO
         RAPID MIX AND SETTLING

RECYCLED EFFLUENT
                     WASTE WATEIi
                     WASTE WATEJ
                                »\STRONO ACID/	jQP»-
                                [•EI^	'
                                                                  / monitoring, pH monitoring and aamplcr

                                                                                 figure 14-12.   Waste water treatment Level 2 for titanium dioxide - aulfate proceaa.

-------
effluents,  neutralization,  aeration to oxidize ferrous iron, and
removal of the resulting  precipitates—is presently practiced at
only one of the five  existing  plants and is being implemented at
another.

     Waste water   control    treatment   practices   at   three
sulfate-process titanium dioxide   plants are  summarized in Table
14-26.  Of the two direct discharging facilities, only Plant #559
currently  provides  effective   treatment for  all process  waste
streams.

     At Plant  #605,  implementation  of treatment equivalent  to
that provided  at Plant #559  is  in  progress, but presently only
neutralization and solids   removal   is practiced.   Consequently,
effluent loadings of iron at  that facility are very high.

     Effluent quality  monitoring data  from  plant  4559  are
summarized  in  Table 14-27.  Verification  sampling  results for
this plant are presented in  Table 14-28.

     Raw waste   priority   pollutants   found   in   significant
concentrations  at  Plant #559   which might  require  regulation,
include arsenic, cadmium, chromium,  copper,- nickel, thallium, and
zinc.

     BPT technology  for sulfate  process  titanium dioxide wastes
has  been identified  as multiple stage  neutralization  of acid
wastes with  limestone and   lime, aeration for removal of  ferrous
iron, and settling.  On site  disposal of gypsum sludges generated
in treatment is included.
Chloride-Ilmenite process

     Two plants currently  use   the   chloride ilmenite process for
manufacture  of  titanium   dioxide.    Plant   #550,  sampled   in
screening,  disposes  of   its most   contaminated  acid  waste  by
deep-well   injection   and  treats   the   remaining   wastes  by
neutralization  and settling. Results of analyses indicated  that
treatment  influent  and   effluent   waste  loads  resembled  those
observed  at other  chloride  process  plants, while  the  acidic
ferric  chloride  waste  contained   waste  loads similar to  those
encountered at sulfate process  plants.   Unfortunately, during the
sampling program, the ore  being  used  at the plant was  closer to
the  richer  rutile  ore   and   could not  be  considered  a  true
ilmenite.  Conclusions could therefore not be drawn on the  basis
of this sampling as to the character of  chloride ilmenite  waste
loads.  Company personnel  indicated  that such  variation  in ore
quality is likely for some time  in  the future.

     It can be suggested that until  further studies are conducted
and decisions are  made as to   the   continued  use  of  deep well

                               314

-------
     14-26.    SUMMARY OF  EXISTING CONTROL AND TREATMENT TECHNOLOGY FOR
              SULFATE-PROCESS  TITANIUM DIOXIDE PLANTS
Plant         Process           Control and Treatment Technology     Discharge
          Wastes-breams                                                Status
#559   Strong and Weak Acids;  Waste acids are neutralized,  settled   Direct
      Contact Cooling:         (in stages)  and aerated for iron
      Noncontact Cooling     removal.   Cooling water is mixed with
                             neutralized acid for final neutral-
                             ization and settling before discharge.

1605   Strong and Weak Acids;  Currently, waste acids are adjusted    Direct
      Contact Cooling        to pH 4 and settled, but a system
                             using aeration and further neutral-
                             ization with settling is under
                             construction.  Contact cooling water
                             is neutralized for discharge.

#694   Weak Acid              Weak acid waste water is adjusted      POTW
                             to a pH of greater than and dis-
                             charged to sanitary sewer.
                                  315

-------
TABLE 14-27    SUMMARY OF DAILY EFFLUENT MONITORING DATA FOR COMBINED WASTE
               WATER TREATMENT DISCHARGE AT SULFATE-PROCESS TITANIUM DIOXIDE
               PLANT #559
Parameter
Chromium, Cr
Cadmium, Cd
Iron,Fe
(Total)
Iron,Fe
(Dissolved)
Lead,Pb
Nickel, Ni
Zinc,Zn
Min
0.01
0.001
0.4
0.08
0.002
0.01
0.01
Concentration
(mg/D
Avg Max
0.
0.
3.
0.
0.
0.
0.
021
009
25
279
017
029
027"
0.
0.
19.
4.
0.
0.
0.
119
02
1
98
05
08
3
St. Dev.
0.
0.
4.
0.
0.
0.
0.
027
004
6
562
013
02
057
0.
0.
0.
0.
0.
0.
0.
Waste Load
(kg/kkg) (lbs/1000 its)
Min Avg ifoy
00049
00004
29
04
00008
00057
00049
0.0014
0.00062
2.14
0.194
0.0012
0.0019
0.0019
0.0045'
0.0012
12.99
4.0
0.003
0.0046
0.022
Total Suspended
 Solids, TSS
35.8
61.3
23.9
                                   316

-------
     14-23 .   VERIFICATION RESULTS TITANIUM DIOXIDE PLANT 1559
Pollutant
Total Suspended
Solids (TSS)
Total Iron, Fe
Antimony, Sb
Arsenic, As
Cadmium , Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Nickel, Ni
Thallium, Tl
Zinc, Zn
Raw Waste
kg/kkg
Avg. Max.
310
670
-
0.015
0.008
5.0
0.13
0.16
0.19
0.004
0.72
330
770
-
0.020
0.001
5.6
0.14
0.17
0.22
0.008
0.76
Treated Effluent
mg/1 kg/kkg
Avg. Max. Avg.
23
4.4
<0.015
<0.010
0.0001
0.025
<0.005
0.002
<0.005
<0.005
0.061
38
7.9
<0.015
<0.010
0.0002
0.030
<0.005
0.003
<0.005
<0.005
0.065
19.5
3.7
<0.01
<0.008
0.0001
0.02
<0.004
0.002
0.004
0.002
0.05
Flow  (m3/kkg)                   616"
*
 Includes cooling water and a small part of chloride process waste.
                                  317

-------
injection  for  disposal   of    this    acidic  wastes,   discharge
limitations   be  either    reserved   or  set  similar  to   those
limitations for the sulfate process.
Base  Level  Performance Characteristics  for  BPT  and  Priority
Pollutant Removal

     Table 14-29 presents effluent  quality achievable through the
implementation  of  BPT  or   Level   1   treatment  technology  for
titanium dioxide manufacture  by  the sulfate process.

     Pretreatiaent Applications

     Presently one  sulfate   process   titanium  dioxide   plant
discharges a portion of its waste   water to a POTW.  However, due
to the large volumes of  waste water,  the highly acidic nature oE
the raw  wastes,  and the great  amounts of  solids  generated  in
neutralizing  the  wastes,  it   is  unlikely  that there  will  be
further  POTW discharge of wastes   from titanium  dioxide sulfate
process plants.  If they need  to   be   regulated,  BPT  standards
should be applied.
Responses to Remand Issues

     Effluent limitations originally   promulgated  as  BPCTCA for
sulfate process  titanium  dioxide  plants were  remanded  on the
grounds that an  inadequate  technical  basis was provided for  the
regulations,  and  that  the   technology  was  neither explicitly
identified   nor   in   use    within    the  industry.    Treatment
technologies  have now  been  clearly  identified and demonstrated.
Achievable  levels  of  pollution  control  have  primarily been
derived from results presently achieved  in the industry.

     Treatment cost  estimates  and energy requirements were also
challenged.  Cost  estimates  for the selected technology have been
developed, including  the  costs of solid waste disposal  and all
energy required for waste treatment.


14.4.3 Estimated Performance  for Advanced Level System

     Table 14-30 presents estimated   achievable effluent  quality
through implementation of the recommended advanced  technology of
recycle.
                               318

-------
          TABLE 14-29  CONTROL  PARAMETER LIMITATIONS
       SUBCATEGORY:  Titanium Dioxide  -  Sulfate Process
                     Level of Treatment: 1
                 Waste Water Flow:  700  m3/kkg
                                  Quality Limit   Emission Limit
              Subcategory      (1)     (mg/1)            (kg/kkg)
Pollutant      Performance   VFR   	   	
                (mg/1)            30  day  24 hr   30 day  24 hr
                                    Aver     Max     Aver    Max
BPT Pollutants;

Total Suspended  86          2.0     37.5    75   26      52
Solids, TSS

Iron, Fe          4.6        3.0      5.0    15    3.5    10.5


Proposed Priority
Pollutants
Arsenic, As
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead , Pb
Nickel, Ni
Thallium, Tl
Zinc, Zn

0.
0.
0.
0.
0.
0.
<0.
0.

01(2)
01
04
01(2)
03
05
005 (2)
06

2.
2.
2.
2.
2.
2.
2.
2.

0
0
0
0
0
0
0
0

0.
0.
0.
0.
0.
0.
0.
0.

5
1
1
5
5
5
2
5

1.0
0. 2
0. 2
1.0
1.0
1.0
0.4
1.0

0.
0.
0.
0.
0.
0.
0.
0.

35
07
07
35
35
35
14
35

0.
0.
0.
0.
0.
0.
0.
0.

7
14
14
7
7
7
28
7
  (1) - VFR:  ratio of the  24 hour  variability factor to  the
           30 day variability  factor.
  (2)  Verification sampling

                              319

-------
           TABLE 14-30  CONTROL PARAMETER  LIMITATIONS
        SUBCATEGORY: Titanium Dioxide - Sulfate  Process
                      Level of Treatment:  2
                  Waste Water Flow:  430 m3/kkg


(1)
rPyo = 4-=aJ~,-]T 1 f- \7 VP R
(mg/1)
Quality Limit
(mg/1)
30 day 24 hr
Aver Max
Emission Limit
(kg/kkg)
30 day 24 hr
Aver Max
BPT Pollutants:
Total Suspended
Solids, TSS
Iron, Fe
Proposed Priority
Pollutants
Arsenic , As
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead , Pb
Nickel, Ni
Thallium, Tl
Zinc, Zn
37.

5.


0.
0.
0.
0.
0.
0.
0.
0.
5

0


5
1
1
5
5
5
2
5
2.

3.


2.
2.
2.
2.
2.
2.
2.
2.
0

0


0
0
0
0
0
0
0
0
37.

5.


0.
0.
0.
0.
0.
0.
0.
0.
5

0


5
1
1
5
5
5
2
5
75

15


1.
0.
0.
1.
1.
1.
0.
1.





0
2
2
0
0
0
4
0
16

2.


0.
0.
0.
0.
0.
0.
0.
0.


2


22
043
043
22
22
22
086
22
32

6.4


0.43
0.086
0.086
0.43
0.43
0.43
0.17
0.43
  (1) - VFR: ratio of the 24 hour variability  factor  to  the
            30 day variability factor.
                              320

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14.4.4 Cost Estimates - Sulfate Process
Model Plant Costs

    The estimated  costs  for  three  models   having   different
production  levels  are given in Tables  14-31,   14-32,  and 14-33.
Annual  treatment costs  as  a function  of  production   are  shown
graphically in  figure  14-13.   Similarly,   treatment   cost  per
metric ton of product is given in figure 14-14.

    Table 14-34 presents a summary of the  unit  cost distribution
between   amortization   and  operation   and    maintenance   cost
components at different productions and  at  the  BPT  and  BAT  (2nd)
level of treatment.

    For existing  sources  at the first level  of  treatment,  the
disposal of sludge is on-site, hence land requirements  are fairly
large.  Amortization,  chemicals,  labor, residual  waste disposal
costs have significant impact on the annual  costs.  The   treatment
Level  2 amortization, chemicals  and  labor  constitute a  major
portion of the additional costs.
                             321

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                    TABLE 13-31.  MODEL PLANT TREATMENT COSTS

   Subcategory  TITANIUM DIOXIDE  Sulfate            Type of Regulation BAT

   Production        31,800 metric tons per year (  35,059 tons per year)
                         90 metric tons per day  (     100 tons per day )
   Waste water flow   61600 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	              $701,200          $117,500
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	             2,328,400           233,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	               607,720            70,100
    Incidentals, overhead,
    fees, contingencies...               607,720            70,100
    Land	             1,272,000            12,000

    TOTAL INVESTMENT COST             $5,526,040          $502,700

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.              $504,000           $56,000
    Energy	                96,000             9,000
    Chemicals	             1,589,000           176,000
    Maintenance	               425,404            49,070
    Taxes and insurance...               165,781            15,081
    Residual waste
    disposal	               210,000
    Monitoring, analysis
    and reporting	                15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                  $3,005,185          $312,651

C.  AMORTIZATION OF
    INVESTMENT COST                     $692,132           $79,836

    TOTAL ANNUAL COST                 $3,697,317          $392,487


    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.

                                    322

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               TABLE 14-32.  MODEL PLANT TREATMENT COSTS
                                                 Type of Regulation  BAT
  Subcategory  TITANIW DIOXIDE  Sulfate

  Production        47,700 metric tons per year  (   52,589  tons per year)
                       136 metric tons per day   (      150  tons per day )
  Waste water flow   92600 cubic meters per day.


                                            LEVEL OF  TREATMENT*

                                          FIRST             SECOND
A.   INVESTMENT COST

    Construction	              $958,700           $161,000
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	             2,980,200            278,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	               789,580             87,800
    Incidentals, overhead,
    fees, contingencies...               789,580             87,800
    Land	             1,920,000             18,000

    TOTAL INVESTMENT COST             $7,447,060           $632,600

B.   OPERATION AND
    MAINTENANCE COST

    Labor and supervision.              $672,000            $56,000
    Energy	               138,000             12,000
    Chemicals	             2,384,000            265,000
    Maintenance	               552,706             61,460
    Taxes and insurance...               223,411             18,978
    Residual waste
    disposal	               315,000
    Monitoring, analysis
    and reporting	                 15,000              7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                  $4,300,117           $420,938

C.   AMORTIZATION OF
    INVESTMENT COST                     $899,252            $99,995
TOTAL ANNUAL COST
                                      $5,199,369
$520,933
*First  level  represents the base cost of treatment system.
Other levels  represent the incremental cost above base cost.
                               323

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                    TABLE 14-33.  MODEL PLANT TREATMENT COSTS
   Subcategory  TITANIUM DIOXIDE  Sulfate

   Production
                                                  Type of Regulation BAT
                  74,500 metric tons per year  (  82,136 tons per year)
                     212 metric tons per day   (     234 tons per day )
Waste water flow  144000 cubic meters per day.
A.  INVESTMENT COST

    Construction 	
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals, overhead,
    fees, contingencies...
    Land	

    TOTAL INVESTMENT COST

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.
    Energy	
    Chemicals	
    Maintenance	
    Taxes and insurance...
    Residual vaste
    disposal	
    Monitoring, analysis
    and reporting	
    TOTAL OPERATION AND
    MAINTENANCE COST

    AMORTIZATION OF
    INVESTMENT COST

    TOTAL ANNUAL COST
                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
                                   $1,293,500



                                    3,914,500

                                        9,000

                                    1,043,400

                                    1,043,400
                                    2,940,000
                                  $10,243,800
                                     $672,000
                                      199,000
                                    3,719,000
                                      730,380
                                      307,314

                                      420,000

                                       15,000
                                   $6,062,694


                                   $1,188,328

                                   $7,251,022
$208,000
 322,000
 106,000

 106,000
  24,000

$766,000
 $56,000
  18,000
 412,000
  74,200
  22,980
   7,500
$590,680


$120,723

$711,403
    *First level  represents the base cost of treatment system.
    Other levels  represent the incremental cost above base cost.

                                    324

-------
                                                                   LEVEL ft
                                                                   LEVEL #1
o
o
o
o
o
H
X
                                        7     /
                            /
                   y
              30
                          40         50          60          70
                          PRODUCTION, METRIC TONSAEAR X 1000
80
               Figure  14-13.  Annual treatment cost vs.  production for the
                      Titanium Dioxide Subcategory, Sulfate Process
                                        325

-------



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            PRODUCTION, METRIC TONSAEAR x 1000
Figure 14-14.   Annual unit treatment cost vs. production for the
       Titanium Dioxide Subcategory, Sulfate Process
                       326

-------
                TABLE 14-34   MOEEL  PLANT  TREATMENT COSTS


Subcategory  TITANIUM DIOXIDE  Sulfate             Type of Regulation  BAT




                                           Annual  Treatment Costs ($/kkg)


                                                LEVEL OF TREATMENT

                 PRODUCTION   FLOW      FIRST     SECOND    THIRD    FOURTH
                  (kkg/yr)  (m3/day)      $          $         $         $
Annual  Operation
and Maintenance
Annual
Anortization
Total  Cost
31,800  61,600     94.50      9.83
47,700  92,600     90.15      8.82
74,500 144,000     81.38      7.93
31,800  61,600     21.77      2.51
47,700  92,600     18.85      2.10
74,500 144,000     15.95      1.62

31,800  61,600    116.27     12.34
47,700  92,600    109.00     10.92
74,500 144,000     97.33      9.55
Not Applicable
                                327

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                          SECTION 15
                  ALUMINUM FLUORIDE  INDUSTRY
15.1 ASSESSMENT OF THE WATER POLLUTION POTENTIAL
15.1.1 Industrial  Profile and Analytical Results

    Aluminum fluoride  is  used   as  a   raw   material   in  the
production of cryolite (sodium fluoroaluminate) ,  which  in turn is
used  in the production  of aluminum.  Aluminum  fluoride is used
also as a  metallurgical  flux (for welding  rod  coatings) , as  a
ceramic flux (for  glazes and enamels), and as  a brazing  flux (for
aluminum fabrication) .
    The industry  profile data
Table 15-1,  while the  existing
15-2.
             for  this   subcategory is given in
               regulations   are given in  Table
    Priority pollutants
waste  during  sampling
follows:
       found at  significant  levels in the raw
      at  Aluminum   Fluoride  plants  were  as
   Pollutant
Maximum Concentration  Observed
           (ug/1)
   Screening       Verification (2  Plants)
Arsenic
Selenium
Chromium
Copper
Cadmium
Mercury
Nickel
200
110
77
120
0.85
2
150
475
97
1135
235
33
11
285
    A summary of daily and unit  product  raw waste loads for all
plants sampled can be found in Table   15-3.   Individual plant raw
waste  loads per unit product  found  in  sampling  can be found  in
Table 15-4.
    Based on the total annual production  of  this subcategory and
the average  waste load generated per  unit product,  the estimated
total priority pollutant raw waste loads generated each year  for
this subcategory are as follows:
                              328

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TABLE  15-1
SUBCAIEGORY PROFILE DATA .
SUBCATEGORY
ALUMINUM FLUORIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants  in this  subcategory
308 Data on file  for
    With total capacity of
    With total production of
    Representing  capacity
    Representing  production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                                 7
                                 6
                           204,800 kkg/year
                           143,400 kkg/year
                                38 kkg/year
                            45,600 kkg/year
                            24,300 kkg/year
                            35,500 kkg/year
                                69 percent

                                 5 years
                                21 years

                              539 cubic meters/day
                            2,200 cubic meters/day

                                12 cubic meters/kkg
                                22 cubic meters/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce,  Current Industrial
Reports, December 1977; Energy and Environmental Analysis,  Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   329

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TAELE -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES



SDBCM      Muminum Fluoride


SUBPAJ      W  (40CFR  415.230, 5/22/75)



                                  STANDARDS


                     BPCTCA*            BATEA             NSPS
                     1          2
                Max.      Avg.      Max.   Avg.      Max.     Avg.

 Prcdui Para-     kg/kkg   k/kkg     k/kkg  k/kkg     k/kkg    k/kkg

 Proce meters     (mg/1)     (mg/1)     (mg/1) (mg/1)    (mg/1)    (mg/1)


 A1F-, „-,    .,   0.68      0.34
    3 Fluoride   (40.0)**  (20>0)


                0-86      0.43
                 (50.6)    (25.3)



      Aluminum  0.34      0.17
                 (20.0)    (10.0)
*
 Sectl5.230,  415.231,  and 415.232 were revoked by the Agency
 (4101, November 23,  1976).

 "Maxcimum of any one day.
 2
  Avgarage of daily values for thirty consecutive days  shall not exceed.



**flcs  17,000 1/kkg.
                             330

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      TABLE 15-3.
SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING
UJ
H

SUBCATEGORY
Pollutant
Priority
Arsenic, As
Cadmium, Cd
Chromium^ Cr
Copper, Cu
Nickel, Ni
Mercury, Hg
Selenium, Se
Conventional
TSS
Fluorine, F
Aluminum, Al
ALUMINUM FLUORIDE
Minimum

0.071

0.072
0.02
0.025
0.0013
0.051
751
493
98.4
kg/day
Average

0.078
0.010
0.16
0.16
0.13
0.0041
0.11
2921
727
220
Loadings
Maximum Minimum

0.086 0.0007

0.25 0.0016
0.33 0.0002
0.26 0.00025
0.0095 0.000027
0.17 0.001
5510 16.3
986 9.71
352 0.97
kg/kkg
Average

0.0016
0.0002
0.0035
0.0033
0.003
0.00005
0.0015
53.7
11.9
4.40
No. of Plants
Maximum Averaged

0.002 3
1
0.0054 2
0.0071 3
0.0056 3
0.00009 3
0.002 2




-------
TABLE  15-4.    PRIORITY POLLUTANT RAW WASTE LOADS (in kg/kkg of Product)
— 	
SUBCATEGORY
POLLUTANT
Arsenic, As
Selenium, Se
Chronium, Cr
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni
Zinc, Zn

ALUMINUM FLUORIDE
#705
0.002
0.001
0.0016
0.0027
0.0004
0.000036
0.003
0.008

PLANT
#705
0.002

0.0054
0.0071
0.001
0.000027
0.0056
0.0047
0.0002
#251
0.0007
0.002

0.0002
0.00014
0.00009
0.00025
0.00046

                                  332

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          Pollutant        Waste  Load (kg/year)
          W MMr .• —» —• -» -«• •» — «•» ••"• •" ™ ™" "• "™ ^ "™ •"• "* ™" ™" "™ "™" ^ *™ ^ "™ "" ^ "™ "™ "* "™ *™
          Arsenic                 190
          Selenium                180
          Chromium                420
          Copper                  400
          Mercury                   6
          Nickel                  360
15.1.2 Process Waste Sources  and  Waste Water Treatment Data
General Process Description

     Raw material  and  process   -   In the  dry  process  for the
manufacture  of aluminum   fluoride,  partially  dehydrated alumina
hydrate is reacted with hydrofluoric acid  gas.   The reaction is
given as:
     A1203  + 6HF  =    2A1F3    +    3H20   (1)


     The product, aluminum  fluoride,  is formed as a solid, and is
cooled  with  non-contact cooling   water  before being  sent  for
milling and shipping.   The  gases   from the reactor are  scrubbed
with water  to   remove  unreacted hydrofluoric acid  before being
vented  to  the  atmosphere.    A simplified  flow  diagram of the
process is shown  in Figure  15-1.

     Water uses   -  Water is  used   in  noncontact cooling of  the
product, for seals on vacuum  pumps  and for scrubbing the  reacted
gases before  being vented  to the  atmosphere.   Water is also used
for leak  and spill cleanup and equipment  washdown.   Table 15-5
gives a summary  of water usage in  the aluminum fluoride industry.

     Sources of  waste water

     A.  Noncontact cooling water  -  Noncontact cooling water  is
used to cool  the product coming out  of  the  reactor.   In some
cases it is recirculated and  the blowdown treated separately froai
other process contact wastewater or discharged without treatment.
The  water  can   be  monitored  for  fluoride  and   if   process
contamination  occurs   it   can  be  diverted  to the  waste water
treatment facility for  fluoride removal.

     B.  Floor   and equipment washings - The quantity and quality
of waste water generated from  those   operations is variable  and
depends largely  on the  housekeeping  practices  at the individual
pi an ts.
                                333

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U)
bo
          HYDRATED
          ALUMINA
          HYDROGEN
          FLUORIDE
                                  WATER
                                     j           VENT
                                       SCRUBBER
                              CYCLONE
                             REACTOR
                                              WASTE WATER
                                                      NONCONTACT
                                                      COOLING  WATER

                                                     J	*
                                                        COOLER
  PRODUCT
 COLLECTION
AND STORAGE
 ALUMINUM
•FLUORIDE
 PRODUCT
                                 Figure  15-1.  General process flow diagram for production of aluminum fluoride.

-------
 TABLE 15-5.   WATER USAGE IN THE ALUMINUM FLUORIDE SUBCATEGORY
 Source               Water use per unit of production

                                     m /kkg of AlF.,
                         Plant         Plant         Plant        Plant
                          #  837         #  705        # 188         # 605

 Non-contact cooling      14.45           NA           6.95          NA

 Indirect process         12.21         1.15          NA           NA
 contact  (pumps, seals,
 leaks, spills)

 Maintenance, e.g.         1.13         2.4            NA          1.60
 cleaning and vrork area
 washdown

 Scrubber                               9.52          3.46         19.95
NA = Not Available.
                                  335

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    C.  Scrubber  waste water - This  is  the major  source of waste
water  requiring  treatment before  being   discharged  or recycled
back to the  scrubber.   It is contaminated  with  hydrofluoric acid,
aluminum fluoride  and  aluminum  oxide, and,   in  some  cases, the
presence  of  sulfuric  acid  and  sil icotetraf luo r ide  has  been
detected.  These  originate as impurities  in the hydrofluoric acid
used in the  process.   Table 15-6 gives the range of  waste  water
flows at different facilities.
Treatment System Description

    The Best   Practicable   Technology    -   BPT    consists  of
neutralization  with lime  to  precipitate  fluoride  as  calcium
fluoride,   followed   by   settling   to   remove    suspended  and
precipitated solids.

    Treatment practices   -   Plant    #705   practices    lime
neutralization and settling of the waste  waters.   Since  aluminum
fluoride  production   is   integrated  with   hydrofluoric   acid
production,  the waste  waters from the  two  processes are combined
before treatment.  The  plant  does not   treat noncontact cooling
water.

    At Plant #837  the  tail  gases are  scrubbed   with soda  ash
solution, and  the  resulting  solution is  sent   to  an adjacent
facility  for use.   The  water from   the  wet  scrubbers  on the
hydrated alumina dryers are also sent  to  an adjacent facility for
use.  The waste waters from area washdown are combined with other
product wastewater,  treated with  hydrated  lime  and  sent to  a
settling lagoon before being discharged.

    Plant #188 produces  aluminum  fluoride   in  small quantities
and  in  batches.   The waste water  from  the   batch operation  is
first sent to a  collection pond.  It  then  goes to a second  pond
where lime and alum are added and finally,  to a third pond  where
the  pii is adjusted by recarbonation.

    Plant #605   mixes  the   aluminum   fluoride    waste   with
hydrofluoric acid plant waste.   The combined waste water is sent
to gypsum ponds for suspended solids removal.  The supernatant is
treated with an effluent stream from another  plant product for pH
control and  neutralization.  Because   of  the  presence of  complex
fluorides (from the HF process) in the  waste  waters, the plant is
planning in  the  near future to use a  new proprietary process  to
further reduce fluoride levels in the  final effluent.


Description  of Plants Visited and Sampled

    Screening - Plant #705 was visited in  the screening phase of
tne  program.  Both hydrofluoric acid   and  aluminum  fluoride are

                              336

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 TABLE 15-6.   WASTE  WATER FLOW AT PLANTS #837, #705 AND #605
               FOR ALUMINUM FLUORIDE SUBCATEGORY
 Source
Flow rate per unit of production

              m /kkg of A1F-
 Scrubber water

 Maintenance equipment
 cleaning and work area
 washdown

 Other (Storm water)
Plant #837

      3.44

      1.13



      7.55
Plant #705

      9.1

      2.39



      NA
Plant #605

     19.95

     1.61



      NA
NA =  Not Available.
                                 337

-------
produced  at   this   facility by  the general   processes described
earlier.  The  waste water from the hydrofluoric  acid  and aluminum
fluoride plants  are mixed and sent to the  treatment facility.   At
the treatment   facility  the combined  wastewater   is neutralized
with lime and  sent   to a series of settling   ponds.  The effluent
from  the  last   pond  is given a final  pH   adjustment  before a
portion of it  is discharged and the rest recycled  to  the process.
Figure  15-2   shows  a simplified block  diagram  of   the process
including  the  waste  water  treatment  facility   and   sampling
locations.   Table  15-7  presents a summary of  flow  data of  the
sampled  streams,  and the emissions data for  important  classical
pollutant parameters.

    Plant #705  was visited again and the  same streams sampled in
the screening  phase were sampled and analyzed in the  verification
phase.   The   variations in  individual stream flows   were  small
during  the  two phases of sampling.   Table   15-7 summarizes the
flow  data and important classical pollutant  emissions.  A second
plant (Plant  #605)  was visited and  sampled   in  the  verification
phase.   Simplified   flow  diagrams  of   the  aluminum  fluoride
manufacturing   plant  and  the  waste  water   treatment  facility
showing the  sampling locations are given   in Figure  15-3.  Table
15-8  gives the   flow of  the waste streams and   the  emissions of
classical  pollutants.  The  aluminum  fluoride  and  hydrofluoric
acid waste streams  are combined and  sent  to   a   gypsum  pond for
suspended solids  removal.  The overflow   from the pond is  mixed
with   alkaline   or   acid   streams   from    other  plants   for
neutralization and  pH adjustment before discharge.


Evaluation of Industry Production and Wastewater Flow Data

    Figure 15-4 shows  the relationship   between  production  and
waste   water  flow   data.   The  data    are   taken   from  308
Questionnaires,    plant   visits   and   development    documents.
Different   wastes   from  the   aluminum   fluoride   process  are
intermixed  before   treatment.   As  mentioned  earlier, scrubber
water constitutes  the- major source of the waste  water stream in
the aluminum  fluoride subcategory.  If the production of aluminum
fluoride  is  integrated  with  hydrofluoric   acid, then the waste
waters from both plants are combined and treated.


Solid Waste Generation

    In aluminum   fluoride  production,   hydrofluoric  gas  and
solids,  such  as  aluminum trihydrate and aluminum fluoride, escape
with the vent gases.  During  scrubbing the   solids are suspended
in the scrubber  water,  while hydrofluoric acid  gas is dissolved.
*n  the   waste   water  treatment  facility   the  wastewater   is
neutralized   with    lime   and  the  calcium   fluoride   formed
Precipitates  out and settles with the other suspended solids.  In

                              338

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                                                                               WATER
CO
U)
                                                                                             VENT
                                                                                                                     'AQUEOUS
                                                                                                                       HF
                                   SCRUBBER]^
                                   WATER

c
$ «3
SCRUBBER



AlF3 PRODUCT -^ 	
REACTOR
^ '
CCXDLER
                                                                                                         -Ai(ai).
                                                                SURFACE DRAINS
                                                                COOLING TOiJER BLOWDOWN,  ETC.
                                                                                 SETTLING POND
                                                             RECYCLED WATER
 FINAL pi I
ADJUS1MENT
                                                                                                                                    TREATED
                                                                                                                                    EFFLUENT
                                                                                                                                    DISCHARGE
                                     Figure 15-2.    General process flow diagram at Plant 0705   showing the  sampling points.
                                                                              (Aluminum Fluoride Manufacture)

-------
     15-7.     FLOW AND  POLLUTANT CONCENTRATION  DATA  OF THE  SAMPLED
              WASTE STREAMS FOR PLANT #705  PRODUCING ALUMINUM FLUORIDE
 Sampling   Sampled    Sampled       Unit
 Phase     Stream     Stream        Flow
            No.    Description
                                          Unit SS
                                           Load
                                          kg/kkg
                                          of AlF.,
                                          Unit
                                        Fluoride
                                         kg/kkg
                                         of AlF,
                                                Unit
                                              Aluminum
                                               kg/kkg
                                               of A1F0
 Screening   3

             4*
                  A1F3 scrubber    8.9    117

                  Surface drains, 17.8      3.5
                  cooling tower,
                  blowdown, etc.

                  Treated waste   24        1.98
                                          4.67

                                          6.14



                                          1.63
                                                6.94

                                                0.76



                                                0.168
Verifica-
tion
3

4*
AlF.. scrubber
                                   8.9
                   Surface drains, 17.8
                   cooling tower,
                   blowdown, etc.

                   Treated waste   24
12.8

 3.57



 0.048
12.32

 3.01



 0.55
4.08

0.475



0.012
*
 This waste is contributed by  both  the HF  and AlF  plants
                                 340

-------
                                                                                                                                                     VENT
                                                                                                                                                      1
                       VENT
                        I
         WET
         SPAR
CO

Al O "3H O
2 3 I 2
A1F,
3
PLANT
REACTOR





WATER ~



i


A1F
SCRUBBER
1















^ S02 SCRUBBER
1
I
£1
M«

                                                                                                                                                           WATER
                                                                                                        HOSE DOWN VCVTER
                                                                                                          AHF  PLANT
                                                           #2
                        Vtoste streams sampled.
                                                                                                                                          EFFLUENT TO RIVER
                                                                                               AIJ

-------
T&BLE 15-8.   FLOW AND POLLUTANT CONCENTRATION DATA  OF THE SAMPLED' STREAMS
            FOR PLANT #605  PRODUCING ALUMINUM FLUORIDE
Stream
No.

4
6
2
3
Sampled
Stream
Description

A1F3 Scrubber Water
SO,, Scrubber Water
Gypsum Pond Influent
Gypsum Pond Effluent
Unit
Flow
m^/kkg
of A1F-

11.86
12.2
24.86
24.8
Unit
Fluoride
Load
kg/kkg
of A1F3
5.53
19.3
16.35
8.00
Unit SS
Load
kg/kkg
of A1F_
j
14.7
2.6
NA
0.232
                                 342

-------
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                50        100
150
200
                   PRODUCTION,  TPD
     1  -  Plant #705

     2  -  Plant #251

     3  -  "Plant #837



See Reference 2.
Figure  15-4.    Production vs. Unit Waste Flow for
Aluminum Fluoride Manufacture.
                         343

-------
the majority  of  cases,  the solids are retained  in  the  lagoon for
periods  up to ten  years.   Table 15-9 gives  a  summary  of  the
amounts of solids generated at two aluminum  fluoride  plants.


Process Modifications and Technology Transfer  Options

    1)  Total  recycle   of  waste  water  to  the   scrubbers  is
feasible if final neutralization is with soda  ash.   The  calcium
in the  waste is  precipitated  as calcium  carbonate  and  scaling
problems in pipes and scrubbers are reduced.

    2)  Passage  of  the vent gases  from  the  reactor through a
cyclone prior to   scrubbing  with  water will  remove  the aluminum
oxide and aluminum fluoride particulates.  The collected material
in the cyclone can be recycled to the reactor.    The  installation
of a  cyclone  will  result  in  material  recovery  and will also
reduce  the  suspended  solids  load going   to  the   waste  water
treatment facility.
Best Management Practices

    1)  Rainfall runoff in  plant areas and  treatment facilities
and other places  susceptible  to  fluoride   contamination can be
collected and sent to the waste water treatment  facility.

    2)  If solid wastes containing fluoride   are  stored  on land,
studies   should   be   conducted   to   ascertain  the  risk  of
contaminating ground water.  Where necessary,  provisions   can  be
made for  collection and  treatment of  leachate,   permeate,   and
r.unof f .

    3)  Settling  ponds  in  the waste water  treatment  facility
should be deep enough (or  provided with baffles)  to eliminate or
reduce  the  stirring effect  of winds  and   rainfall. This  will
reduce  the   incidence  of  weather-related   plant  upsets,   and
suspended solids limitations will be more  consistently met.


Model Plant and BPT Treatment System Specifications

    waste water flow  - The  range  of waste  water data   on  file
shows flow variations from 11.5 m3/kkg of  A1F3 to  21.5 m3/kkg  of
Ali'3   (see Table 15-6) .  Based  on these values,   a unit   flow of
15.2 m3/kkg of A1F3  was taken as the average  for  the waste water
treatment model plant for cost estimation.

    Production - Six  plants  manufacture aluminum fluoride  at a
total  production  rate  of  120,000  kkg/yr.    Individual  plant
production rates range   from a minimum of  38  kkg/yr to a   maximum
of  45600  kxg/yr wi tn   a  mean of 24,309  and  a  median of 35,500

                              344

-------
 TABLE 15-9.   SOLIDS GENERATED AT PLANT #705 AND #605 PRODUCING
               ALUMINUM FLUORIDE
 Plant                        Total Solids Generated  kg/kkg of A1P
#705                                             54

#605                                             69
                                  345

-------
kKg/yr.   For   waste   water   treatment  cost   estimates,   three
production levels  were  selected as  model   plants.    These three
models reflect the production levels of the  plants  for which data
is on file  (excluding  a small batch  operation plant)   and are
17,500 kkg/yr, 39,200 kkg/yr and 50,400 kkg/yr.

    Pollutant loadings - Observed pollutant loadings  varied from
14 to 27 kg/kkg of A1F3 for suspended solids and  from  5.4  to 39.5
Kg/kkg  of A1F3 for fluoride.  The data sources  are  as follows:


      Source  of Data         TSS kg/kkg-AlF3  F  kg/kkg-AlF3

      EPA Document 1974[Ref]          16-20       15-20
      Screening and
      Verification
      Phase - Plant Data              14-27     5.4-39.5


    For model plants pollutant loadings  of 20   kg  of  suspended
solids  and 18  kg of  fluoride per  kkg  of A1F3   were  used  to
establish treatment requirements.

    Treatment chemicals  -  Lime  (CaO powder form)   is  added to
precipitate fluoride  and  to  raise the pH  to the   range   six to
nine.  For each  of the model plants, lime  is added  as 25  percent
in excess  over  the  stoichiometric  requirements  for  fluoride
precipitation.  For advanced treatment,  ferrous  sulfide  is added
to give a concentration of 10 ppm.  This acts as  a  polishing step
to remove additional trace metals from the  effluent.    For  a more
advanced level of treatment,  soda ash  is   added in   addition to
lime  (CaO).  The soda ash dosage was assumed to  be  770 kg/kkg.

    Variation _i_n flow and pollution  loading  -  To  indicate the
effect  on  costs of  higher and  lower pollutant loadings,  cost
estimates were developed for one model plant (35,600  kkg-A!F3/yr)
at 27  kg of  SS/ kkg-AlF3 and 30 kg fluoride/kkg-AlF3  and 14 kg
fluoride/kkg-AlF3.   The  waste  water  flow for  these additional
estimates was  maintained the same  as in the original  mode  (i.e.,
15 m3/kkg-Alf3) .   Unit  flows were  also varied  to   monitor  the
sensitivity of  cost to  plant size.  In this case,  the pollutant
loads were assumed to  be the same as in the original  model.  The
range of flows used were 10.1 m3/kkg to 22.8 m3/kkg.

    Generation ojf  Solids  -  From  the pollutant   loadings  and
treatment chemicals  above, the waste  treatment  residue  consists
of 20 kg/kkg of  suspended  solids  plus  46.2   kg/kkg from added
chemicals.   Thus, the total solids generated are   66.2 kg/kkg of
product.   After  mechanical removal  to self  draining  piles at
site, the combined fluoride  (AsCaF2)  is reasonably  stable  at  the
reaction pH reached during lime treatment.
                              346

-------
15.2 TECHNOLOGY BASED POLLUTION  ABATEMENT


15.2.1 Advanced Level Treatment  Applications


Control of Significant  Observed  Priority Pollutants

     Tne priority pollutants  found  in actual  plant  waste waters
include copper, arsenic,   chromium,  and selenium.  In the case of
selenium,  it  is  apparent that  the  source  was largely  the  raw
water supply   and is  therefore  not  regarded as a process related
pollutant,  but  the control  of  selenium  in the treated effluent
may be required.

     Copper and  chromium   may be  present  as trace impurities in
the hydrofluoric acid used to react  witn bauxite to form aluminum
fluoride.  Arsenic may  originate as   an impurity  in the  bauxite
ore.  Waste  treatment  processes should be  designed  to  control
fluoride, copper, arsenic, and chromium.


Removal Technologies Available

     Copper and  chromium   can be  precipitated  as  hydroxides at
alkaline  pH levels, and   in   clarified  solutions  they  may  be
exchanged  for hydrogen or sodium   ions  by ion exchange.  Copper
and  chromium  at low levels  may  also be controlled  by xanthate
precipitation, although the process  is not  widely used.  Sulfide
precipitation  will reduce   copper  to very low levels but will not
control  chromium  or   arsenic.    Although  the mechanism  is not
clear,  arsenic  levels appear   to    be  reduced   in  the lime
neutralization  process followed   at  most  plants,  perhaps  by
entrapment or  adsorption of the  oxide during the precipitation of
calcium  fluoride.   A  combination  of  lime and  ferric  sulfate
coagulation is  probably the  most  effective practical method  for
reducing arsenic concentrations.


Selection of Appropriate Technology

     BPT  (Level  !_)_ - Lime  is   widely used in  the  industry_ to
remove the primary nonconventional  pollutant as calcium fluoride.
Because  lime  neutralization to  pH  10  results  in significant
incidental  removal of  copper,   chromium, and arsenic,  alkaline
precipitation  was chosen as BPT  (Level 1) technology.

     Level 2_ - Improved removal of  the suspended precipitate  is
achieved by dual media  filtration.

     Level 3_ - Sulfide  precipitation  is  used to attain a higher
level of copper removal.
                               347

-------
    Level  4_  - The technology is similar  to  Level  2,  except that
soda   ash   is  substituted  for  part  of   the   lime   treatment,
permitting  partial  recycling of effluent.


Flow Diagrams

    The facilities to achieve each level  of  treatment are  shown
schematically in the following diagrams:


    Level  1       Figure 15-5
    Level  2       Figure 15-6
    Level  3       Figure 15-7
    Level  4       Figure 15-8
    Equipment functions  Level  !_  -   This   consists  of  flow
equalization with first stage 1 irne application followed by second
stage lime  application and lagoon  settling.    The  final pH  is
adjusted with hydrochloric acid to the  6-9  range before discharge
through an effluent monitoring system.

    Level 2_ - Dual media filtration  is added   to provide  better
control of  suspended solids, including  heavy  metal hydroxides,
which are returned to the lagoons as  filter  backwash.

    Level 3_ - Ferrous sulfide is prepared  on   site from  ferrous
sulfate and sodium bisulfide and is added ahead of the dual media
filter shown in Level 2, to reduce heavy  metals (except chromium)
to lower levels by sulfide precipitation.

    Level 4_  -  A modification  of   Level  2 which allows partial
recycling of final effluent by substituting  soda ash for part  of
the lime  treatment, and settling the resulting calcium carbonate
in a  clarifier before filtration.  This  step  reduces the calcium
saturation  and  permits recycling of   effluent  without  serious
scaling  problems.   Although  a small  blowdown  of  effluent  is
maintained  for  control of salinity  the  total mass discharge of
priority  pollutants is less than that  achieved in Level 2 due to
the lower effluent flow rate.

    Chemicals and  handling  - In BPT  (Level  1)  and in Level  2,
two-stage  neutralization is accomplished   with lime alone, using
conventional  handling  equipment to  deliver milk of lime to  two
points of application.  In Level 3, a mixture  of ferrous  sulfate
and sodium  bisulfide is  prepared in a well-ventilated space and
applied with  a conventional solution   feeder  to the inlet of the
Level 2 dual media filter.  With adequate ventilation and  proper
PH control in this  chemical  preparation,   there are  no unusual
problems in chemical handling.  In  Level 4,   soda ash is used to

                              348

-------
U)
                                                                  I	
                                                                                          "I
                                                                                                               IAGOCN
                             RAW
                           WASTE WATER
                                                                                    MIXING
                                                                                                               IAQOCN
pH ADJUSTMENT







~ T
                                                                                                                                                        EFFUUENT
                                    •Includes flow monltDring, pH monitoring and sampler.
                                                             Figure  1-5-5. Waste water treatment Level  1  for aluminum fluoride subcategory.

-------
                                                                                               BACKWASH
CO
o


^-^







RAW
WASTE

LIME

1







WATER



c





/
_t^ /»,
EQUALIZATION


I--'©
1
1
1
1
>b







.^^^, •_»
r 	

1 , ^>v LAGOON ^^1
J? i
-*J -•-*•
MIXING ^ ^

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. ]





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MpH ADJUSTME2^r




X ; ^,
/ \ 1' 1 ^
•^
FiL'ilSK * j
                                                                                                                                                                          EFFLUENT
                   *Includes  flow monitoring, pH monitoring and sanpler.
                                            Figure 15-6.   Waste vater treatment Level 2 for alvminum fluoride subcategory.

-------
  LIME



U*£>-|
U)
Ln
 RAW
 WASTE WATER

                      EQUAIIZATION
                                           •Q-^
                                                                                        FERROUS  SULFATE
                                                                                                                      SODIUM BISULFIDE
                                                              r
                                                            1
                                                   ii
                                                   i!
                                                     NUXING
                                                                        BACKWASH
                                                                         LAGOON
                                                                         LAGOON
                               Includes flov/ monitoring, pH iTionitoring and sampler
                                                                                                   pH

                                                                                                   ADJUSTMENT

                                                                                                                     r—Q-
                                                                                                                SUMP
                                                                                                                                       T
                                                                                                                                     FILTER
                                                                                                                                            'EFFLUENT
                                             Figure 15-7.  Haste water treatment Level 3 for aluminum fluoride subcabegory.

-------
U)
Ul
NJ
                            WASTE
                             WATER
                                                                                                                                                                                                   EFFLUENT
                                                              Includes flow monitoring,  pll monitoring and Bampler
                                                                                    Figure  15-8.   HaBbawatcr trcatnunl Level 4 far aluminum fluoride Bubcalegory

-------
furnish  part  of  the  alkalinity,   employing  conventional dry
chemical feeding equipment  for  this  non-hazardous chemical.

     Separation and  removal  of   solids  -  At  all  levels of
treatment the precipitated   solids are removed mechanically  from
the  lagoons at regular   intervals and are piled in self-draining
areas near the lagoons, on  land  provided for a ten-year operating
period.  Fluoride and priority  pollutants are in the insoluble or
adsorbed form  and do  not   constitute  a  hazard  to  the  local
environment  when  left   at  the   plant  site  under   controlled
conditions, i.e., with leachate  and  permeate control.

     Monitoring requirements  -   Control of fluoride and  priority
pollutants in the treatment process  can be reasonably  assured by
pH  and fluoride ion field  testing equipment.  At advanced levels
very low  values of toxic metals  and arsenic are best detected by
atomic  absorption  methods,  normally  performed  in  commercial
laboratories on carefully collected  and composited samples.


15.2.2 Estimated Performance  o_f  BPT  Systems

     Raw waste  pollutant loads   found in the  aluminum  fluoride
subcategory  were  presented  earlier.  The     major  pollutants
previously regulated are  suspended solids, fluoride and aluminum.

     The priority pollutants  that  were found  in quantities that
might require control and regulation are selenium and copper.

     BPT has been  identified as  lime  precipitation of fluorides
followed by settling to remove  suspended solids.


Base Level Performance Characteristics for BPT Pollutant Removal

     The three  major manufacturers   of  aluminum  fluoride  also
produce  hydrofluoric  acid at   the  same  facility.   Two of the
plants treat both  sources   of  waste water  together;   the third
uses   the   aluminum   fluoride    wastes   in  other   proceses.
Consequently, no data are available  for the separate treatment of
aluminum  fluoride waste  water.   However, it can be assumed that
the effluent  quality achievable  will be  at least  equivalent to
that of the hydrofluoric  acid subcategory since BPT technology is
the same for the two subcategories.

     Table 15-10 presents effluent quality achievable through the
implementation of BPT or  Level  1  technology for aluminum fluoride
plants.
                               353

-------
          TABLE  15-10  CONTROL PARAMETER  LIMITATIONS
                SUBCATEGORY: Aluminum Fluoride
                     Level of Treatment:  1
                 Waste Water Flow: 15.2 m3/kkg
                                  Quality  Limit    Emission Limit
               Subcategory     (1)     (mg/1)           (kg/kkg)
 Pollutant      Performance   VFR  	    	
                (mg/1)               30 day  24 hr    30  day  24  hr
                                     Aver     Max      Aver     Max
BPT Pollutants:
Total Suspended
Solids, TSS
                   (2)
2.0
37.5
75
0.57  1.1
(2)
Aluminum, Al -
(2)
Fluoride, F
Proposed Priority
Pollutants
(2)
Copper, Cu
(2)
Selenium, Se
3.0 4.0 12 0.06 0.18
3.0 37.5 112 0.57 1.7


2.0 0.5 1.0 0. 008 0. 015
2.0 0.2 0.4 0.003 0.006
  (1) - VFR:  ratio of the 24 hour variability  factor  to the
           30 day variability factor.

  (2) - Specific plant performance data  is  available  only for
       the combined treatment of HF and  A1F3  process wastes.
                             354

-------
Base   Level   (BPT)  Performance   Characteristics   for  Priority
Pollutant Removal
Pretreatment Applications

     No aluminum fluoride manufacturing  facilities  are known to
discharge to a POTW.  BPT technology will be applicable, however,
should such a discharge occur  in  the future.
Response to Remand Issues

     Industry's arguments     regarding    the   regulation   of
hydrofluoric  acid  and aluminum   fluoride waste  discharges have
primarily centered  on  tne  treatability  of fluorides.   Complex
fluorides not amenable to  treatment do  occur in hydrofluoric acid
drip acid waste.  However,   no  complex  fluorides  are known  to
occur in aluminum fluoride waste  waters.

     Industry also recommended  that  the  two  subcategories  be
combined  or  that   a  third   subcategory   be  established  for
facilities where hydrofluoric acid and  aluminum fluoride are both
manufactured.   This subject is  discussed in  Section 4  dealing
with subcategorizations.


15.2.3 Estimated Performance of Advanced Level Systems


Advanced  Level  Performance Estimates  for   BPT  and  Priority
Pollutant Removal

     Implementation of advanced level treatment alternatives  are
estimates to  achieve  the   effluent quality  presented in Table
15-11, 15-12, and 15-13.


New Source Applications-

     Examination of    waste   water   control   and   treatment
alternatives  applicable  to  new facilities  for the production of
aluminum fluoride has  led to the conclusion that the  technology
applicable to NSPS is  80  percent  recycle of treated waste  waters
to air pollution control  scrubbers, identified  as Level 4. This
technology exists in the  hydrofluoric Acid Subcategory.
                               355

-------
          TABLE  15-11  CONTROL PARAMETER  LIMITATIONS
                SUBCATEGORY: Aluminum  Fluoride
                     Level of Treatment:  2
                 Waste Water Flow:  15.2 m3/kkg


                                  Quality Limit   Emission Limit
                              (1)     (mg/1)            (kg/kkg)
Pollutant     Treatability   VFR   	   	
                (mg/1)            30 day   24 hr   30 day  24 hr
                                    Aver     Max     Aver    Max
BPT Pollutants:
Total Suspended    15         2.0      15      30      0.23    0.46
Solids, TSS
Aluminum
Fluoride
Proposed
, Al
, F
Priority
4.0
25
3.
3.
0
0
4.0
25
12
75
0.
0.
06
38
0.
1.
18
1
Pollutants
Copper ,
Selenium
Cu
, Se
0.1
0.1
2.
2.
0
0
0. 1
0.1
0. 2
0.2
0.
0.
0015
0015
0.
0.
003
003
  (1) - VFR: ratio of the  24  hour  variability factor to the
           30 day variability  factor.
                              356

-------
           TABLE  15-12   CONTROL PARAMETER LIMITATIONS
                  SUBCATEGORY:  Aluminum Fluoride
                       Level  of Treatment: 3
                  Waste  Water  Flow: 15.2 m3/kkg
Pollutant
Treatability
   (mg/1)
  (1)
VFR
                                    Quality Limit
                                       (mg/1)
                                      Emission Limit
                                         (kg/kkg)
                                    30 day  24 hr    30 day  24 hr
                                     Aver    Max     Aver    Max
BPT Pollutants;

Total Suspended
Solids, TSS
     15
2.0
15
30
0.23
  (1) - VFR: ratio of  the  24  hour variability factor  to  the
            30 day variability factor.
0.46
Al urn in urn
Fluoride
Proposed
Pollutan
Copper ,
Selenium
, Al
, F
Prior ity
ts
Cu
, Se
4.0
25

0.05
0.1
3.
3.

2.
2.
0
0

0
0
4.0
25

0.05
0.1
12
75

0.1
0.2
0.
0.

0.
0.
06
38

0008
0015
0
1

0
0
.18
.1

.0015
.003
                               357

-------
        TABLE  15-13   CONTROL PARAMETER LIMITATIONS
              SUBCATEGORY:  Aluminum Fluoride
                   Level  of Treatment: 4
         Waste Water  Flow:  3 m3/kkg (80% Recycle)
Pollutant Treatability
(mg/1)
BPT Pollutants:
Total Suspended 15
Solids, TSS
Aluminum , Al 4.0
Fluoride, F 25
Proposed Priority
Pollutants
Copper, Cu 0.1
Selenium, Se 0.1
Quality Limit
(1) (mg/1)
VPP — 	
30 day 24 hr
Av e r Ma x
2.0 15 30
3.0 4.0 12
3.0 25 75
2.0 0.1 0.2
2.0 0.1 0.2
Emission Limit
(kg/kkg)
30 day
Aver
0.045 0
0.012 0
0.075 0
0.0003 0
0.0003 0
24 hr
Max
.09
.036
. 15
.0006
.0006
(1) - VFR:  ratio of the 24 hour variability factor  to  the
         30 day variability factor.
                           358

-------
15.2.4 Cost Estimates
General Discussion

     The estimated  costs   for   models  having  three  different
production  and four   levels  of  treatment are  given in  Tables
15-14, 15-15 and 15-15.  For  these models,  both the hydraulic and
pollution loads per unit of production are  held constant over the
entire range  of production.  Annual  treatment cost as a function
of  production is shown graphically  in Figure  15-9.  Similarly,
treatment  cost per  metric ton  of  product  is given  in  Figure
15-10.

     To indicate  the  effects   on cost of  varying  the pollutant
load per unit of product, cost estimates  were  developed for one
medium size production model  plant at higher solids and pollutant
(fluoride)   loadings.   For these   models the  hydraulic load per
unit of production was held   constant.   The cost -estimates  for
these models are given in Tables 15-17 and  15-18.  The effects on
costs of varying the unit pollutant load are shown graphically in
Figures 15-11  and  15-12   at Levels  1  and  4.   Variation  of
pollutant  loads has a  significant impact  on Level 1, but had no
effect on the  incremental  costs of treatment  at levels 2 and  3
which are not shown.

     To judge the effects on  cost  of   varying the  hydraulic load
per  unit  of  production,  cost  estimates were  developed for one
medium  size  production  model  plant  at  a higher  and a lower
hydraulic loadings.  The pollutant load per  unit  of  production
was held constant for  these models.  Tables 15-19  and 15-20 show
the cost estimates.  At treatment  Levels 2,  3  and 4 the effects
on  costs of  varying  the  per  unit   hydraulic  load  are shown
graphically in Figures  15-13, 15-14, and 15-15.   Hydraulic load
variation had no  significant effect  on the costs of treatment at
Level  1.   Table  15-21  presents a  summary  of  the  unit cost
distribution   between   amortization   and  the   operation  and
maintenance  cost components  at   various production and levels of
treatment.   The  effects   on cost  due  to  variations in unit
pollutant and hydraulic loads are  also shown in Table 15-21.


Summary

     At the  first  level of  treatment,  chemicals,  labor,  and
amortization  have  significant  impact on  the  annual costs.  At
second, third and  fourth levels of treatment,  the operation and
maintenance cost  comprises  of   approximately two-thirds  of the
additional annual costs,  and the remaining one-third  is due to
amortization.

                               359

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                   TABLE 15-14 MOEEL PLANT  TREATMENT COSTS
  Subcategory  ALUMINUM FLUORIDE

  Production
                                                  Type of  Regulation  BAT
                 15,900 metric  tons per year  (  17,529  tons  per  year)
                     45 metric  tons per day   (      50  tons  per  day )
Waste water flow     690 cubic meters per day.
A.   INVESTMENT COST

    Construction	
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals, overhead,
    fees, contingencies...
    Land	

    TOTAL INVESTMENT COST

B.   OPERATION AND
    MAINTENANCE COST

    Labor and supervision.
    Energy	
    Chemicals	
    Maintenance	
    Taxes and insurance...
    Residual waste
    disposal	
    Monitoring, analysis
    and reporting 	
   TOTAL OPERATION AND
   MAINTENANCE COST

C. AMORTIZATION OF
   INVESTMENT COST

   TOTAL ANNUAL COST
                                          LEVEL OF TREATMENT*

                                FIRST      SECOND       THIRD       FOURTH


                              $39,800     $10,000      $14,000      $20,500
                              192,000

                                9,000

                               48,160

                               48,160
                               24,000
 68,000



 15,600

 15,600
74,000     172,000
17,600

17,600
38,500

38,500
                             $361,120    $109,200     $123,200     $269,500
$56,000
3,400
35,000
33,712
10,833
5,400
15,000
$159,345
$54,849
$14,000
600
10,920
3,276

7,500
$36,296
$17,766
$14,000
900
800
12,320
3,696

7,500
$39,216
$20,044
$14,000
2,500
9,800
26,950
8,085

7,500
$68,835
$43,847
                             $214,194
$54,062     $59,260     $112,682
    *First level represents the  base  cost of treatment system.
    Other levels represent the  incremental cost above base cost.
                                     360

-------
                    TABLE 15-15. MOEEL PLANT TREATMENT COSTS
   Subcategory  ALUMINUM FLUORIDE

   Production
                                                   Type of Regulation  BAT
                  35,600 metric  tons per year (  39,249 tons per year)
                     101 metric  tons per day  (     112 tons per day )
Waste water flow    1550 cubic meters per day.
A.  INVESTMENT COST

    Construction  	
    Equipment in  place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals,  overhead,
    fees, contingencies...
    Land	

    TOTAL INVESTMENT COST

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.
    Energy	
    Chemicals	
    Maintenance	
    Taxes and insurance...
    Residual waste
    disposal	
    Monitoring, analysis
    and reporting	
    TOTAL OPERATION AND
    MAINTENANCE COST

    AMORTIZATION OF
    INVESTMENT COST

    TOTAL ANNUAL COST
                                           LEVEL OF TREATMENT*

                                 FIRST      SECOND       THIRD     FOURTH


                               $63,600     $15,000     $19,000     $34,000
                               238,000

                                 9,000

                                62,120

                                62,120
                                42,000
84,000



19,800

19,800
90,500     259,000



21,900     58,600

21,900     58,600
                              $476,840    $138,600    $153,300    $410,200
$56,000
5,500
80,000
43,484
14,305
12,500
15,000
$14,000
900

13,860
4,158

7,500
$14,000
1,300
1,800
15,330
4,599

7,500
$14,000
3,100
18,800
41,020
12,306

7,500
                              $226,789     $40,418     $44,529     $96,726


                               $70,748     $22,550     $24,941     $66,739

                              $297,537     $62,968     $69,470    $163,465
    *First level represents the base  cost  of treatment system.
    Other levels represent the  incremental cost above base cost.
                                      361

-------
               TABLE 15-16. MODEL PLANT TREATMENT COSTS
Subcategory ALUMINUM FLUORIDE Type of Ftegulation BAT
Production 45,800 metric tons per year ( 50,494 tons per year)
130 metric tons per day ( 144 tons per day )
Waste water flow 1990 cubic meters per day.
A. INVESTMENT COST
Equipment in place,
including piping,
fittings, electrical
Monitoring equipment
Engineering design
Incidentals, overhead,
fees, contingencies...
TOTAL INVESTMENT COST
B. OPERATION AND
MAINTENANCE COST
Labor and supervision.
Energy 	
Chemicals 	
Ma intenance 	
Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis
and reporting 	
TOTAL OPERATION AND
MAINTENANCE COST
C. AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
FIRST
$76,500
281,000
9,000
73,300
73,300
60,000
$573,100
$56,000
7,400
100,000
51,310
17,193
16,000
15,000
$262,903
$83,481
$346,384
LEVEL OF
SECOND
$20,500
110,000
26,100
26,100
$182,700
$14,000
1,500
18,270
5,481
7,500
$46,751
$29,725
$76,476
TREATMENT*
THIRD
$24,500
116,500
28,200
28,200
$197,400
$14,000
1,900
2,400
19,740
5,922
7,500
$51,462
$32,116
$83,578
FOURTH
$43,000
317,000
72,000
72,000
$504,000
$14,000
4,300
26,400
50,400
15,120
7,500
$117,720
$82,000
$199,720
*First level represents the base cost of treatment  system.
Other levels represent the incremental cost above base  cost.
                                 362

-------
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              10         20        30        40        50

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   Figure' 15-9.  Annual treatment cost vs. production for the

                 Aluminum Fluoride  Subcategory
                                363

-------
  20
                  ±
  15
•en-
                  JO.
  10
                                                     ii #k i
                                             j	i
                                            i _j  iLEVEE ^
                        j	i
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               !  I
               i	i
                   i  i
             10        20        30       40        50
                 PRODUCTION,  METRIC TON/YEAR X 1000

 Figure 15-10.  Annual unit treatment cost vs. production for the
                 Aluminum Fluoride Subcategory
                              364

-------
                    TABLE 15-17. MODEL PLANT  TREATMENT COSTS
   Subcategory  ALUMINUM FLUORIDE

   Production
                                                   Type of Regulation  BAT
                  35,600 metric  tons per year (   39,249 tons per year)
                     101 metric  tons per day  (      112 tons per day )
Waste water flow     1550 cubic meters per day.
A.  INVESTMENT COST
B.
                                             LEVEL  OF  TREATMENT*

                                   FIRST      SECOND       THIRD      FOURTH

Equipment in place,
including piping,
fittings, electrical
Monitoring equipment
Engineering design
Incidentals, overhead,
fees, contingencies —

TOTAL INVESTMENT COST
OPERATION AND
MAINTENANCE COST
Labor and supervision.
Enerqy 	
Chem icals 	

Taxes and insurance...
Residual vvaste
disposal 	
Monitoring, analysis

TOTAL OPERATION AND
MAINTENANCE COST
AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
$82,000
241,000
9,000
66,400
66,400
66,000

$530,800
$56,000
5,500
130,000
46,480
15,924
19,000
15,000

$287,904
$75,622
$363,526
$15,000
84,000

19,800
'19,800

$138,600
$14,000
900

13,860
4,158
7,500

$40,418
$22,550
$62,968
$19,000
90,500

21,900
21,900

$153,300
$14,000
1,300
1,800
15,330
4,599
7,500

$44,529
$24,941
$69,470
$34,500
270,000

60,900
60,900

$426,300
$14,000
3,100
31,500
42,630
12,789
7,500

$111,519
$69,359
$180,878
    *First level  represents the base  cost  of treatment system.
    Other levels  represent the  incremental cost  above base cost.
                                      365

-------
                  TABLE 15-18. MOEEL PLANT TREATMENT COSTS
  Subcategory  ALUMINUM  FLUORIDE

  Prediction
                                                  Type of Regulation  BAT
                 35,600  metric  tons per year (  39,249 tons per year)
                    101  metric  tons per day  (     112 tons per day )
Waste water flow     1550  cubic meters per day.
                                            LEVEL OF TREATMENT*

                                  FIRST      SECOND       THIRD      FOURTH
A.  INVESTMENT COST

Equipment in place,
including piping,
fittings, electrical
work and controls .....
Monitoring equipment
Engineering design
Inc identals , overhead ,
fees , contingenc ies . . .
Land 	

TOTAL INVESTMENT COST
B. OPERATION AND
MAINTENANCE COST
Labor and supervision.
Energy 	
Chemicals 	
Maintenance 	
Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis
and reporting 	

TOTAL OPERATION AND
MAINTENANCE COST
C. AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
$56,900
221,000
9,000
57,380
57,380
30,000

$431,660
$56,000
5,500
60,000
40,166
12,949
9,000
15,000

$198,615
$65,350
$263,965
$15,000
84,000

19,800
19,800

$138,600
$14,000
900

13,860
4,158
7,500

$40,418
$22,550
$62,968
$19,000
90,500

21,900
21,900

$153,300
$14,000
1,300
1,800
15,330
4,599
7,500

$44,529
$24,941
$69,470
$34,000
259,000

58,600
58,600

$410,200
$14,000
3,100
14,610
41,020
12,306
7,500

$92,536
$66,739
$159,275
   *First level  represents the base cost of treatment system.
   Other levels  represent the incremental cost above base cost.
                                    366

-------
  20
  15
                                                              1  I I
                         3
                                      £L'jn
                                                           T/

  10
                 \\
                         M
                  7-

                    ^gsn POTJ.TITO

TO       20        TO        «50"
 A1F3 PRODUCTION,  METRIC IONS/YEAR X 1000
                                                          60
Figure 15-11.  Effect of variation of pollutant load on  treatment
                    cost at level 1 technology
                              367

-------
  20
                   JsL
                                           Tb POTJJTTMITl LOAD
           I  I
   15
O

s
                                              I S.
ZL
   10
        rn/rT
                    I  I
y-
i  i  i
                                 D   I I
                                   i
              10
                       20
                                30
                                         40
                                                  50
                                                           60
                A1F3 PRODUCTION, METRIC TONS/YEAR X 1000
   Figure 15-12.  Effect of variation of pollutant load, on treatment
                    cost at  level  4  technology
                               368

-------
                    TABLE 15-19. MODEL PLANT  TREATMENT COSTS
   Subcategory  ALUMINUM FLUORIDE

   Production
                                                   Type of Regulation  BAT
                  35,600 metric tons per  year  (   39,249 tons per year)
                     101 metric tons per  day  (      112 tons per day )
Waste water flow    2203 cubic meters per day.
                                             LEVEL  OF  TREATMENT*

                                   FIRST      SECOND       THIRD      FOURTH
A.  INVESTMENT COST
B.

Equipment in place,
including piping,
fittings, electrical
Monitoring equipment
Engineering design
Incidentals, overhead,
fees, contingencies...

TOTAL INVESTMENT COST
OPERATION AND
MAINTENANCE COST
Labor and supervision.
Enerqy 	
Chemicals 	

Taxes and insurance . . .
Residual waste
d isposal 	
Monitoring, analysis
and reporting 	

TOTAL OPERATION AND
MAINTENANCE COST
AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
$66,100
256,000
9,000
66,220
66,220
42,000

$505,540
$56,000
7,400
80,000
46,354
15,166
12,500
15,000

$232,420
$75,417
$307,837
$21,000
117,600

27,720
27,720

$194,040
$14,000
1,500

19,404
5,821
7,500

$48,225
$31,570
$79,795
$25,000
124,000

29,800
29,800

$208,600
$14,000
1,900
1,800
20,860
6,258
7,500

$52,318
$33,939
$86,257
$43,500
321,000

72,900
72,900

$510,300
$14,000
4,700
18,800
51,030
15,309
7,500

$111,339
$83,025
$194,364
    *First level represents the base cost of  treatment system.
    Other levels represent the incremental  cost  above base  cost.
                                      369

-------
                   TABLE 15-20. MOEEL PLANT TREATMENT  COSTS

  Subcategory  ALUMINUM FLUORIDE                     Type of Regulation  BAT

  Prediction         35,600 metric tons per year  (   39,249 tons per year)
                       101 metric tons per day   (      112 tons per day )
  Waste water  flow    1064 cubic meters per day.


                                            LEVEL  OF TREATMENT*

                                  FIRST      SECOND       THIRD      FOURTH
A.   INVESTMENT  COST

    Construction	       $63,600     $14,500     $18,500     $30,000
    Equipment in  place,
    including piping,
    fittings, electrical
    vvork and controls	       237,000      70,300      76,000     206,000
    Monitoring  equipment
    in place	         9,000
    Engineering design
    and inspection	        61,920      16,960      18,900      47,200
    Incidentals,  overhead,
    fees, contingencies...        61,920      16,960      18,900      47,200
    Land...	        42,000
   TOTAL INVESTMENT COST

B.  OPERATION AND
   MAINTENANCE COST

   Labor and supervision.
   Energy	
   Chemicals	
   Maintenance	
   Taxes and insurance...
   Residual waste
   disposal	
   Monitoring, analysis
   and reporting	
$475,440    $118,720     $132,300     $330,400
 $56,000
   5,500
  80,000
  43,344
  14,263

  12,500

  15,000
   TOTAL OPERATION AND
   MAINTENANCE COST

C.  AMORTIZATION OF
   INVESTMENT COST

   TOTAL ANNUAL COST
$226,607


 $70,520
$297,127
$14,000
    600

 11,872
  3,561
  7,500


$37,533


$19,315

$56,848
$14,000
    900
  1,800
 13,230
  3,969
  7,500


$41,399
$21,525

$62,924
 $14,000
   2,500
  18,800
  33,040
   9,912
   7,500


 $85,752


 $53,756
$139,508
   *First level represents the base cost of  treatment system.
   Other levels represent the incremental  cost  above base cost.
                                     370

-------
   20-
                              I  !  ! !
                                                  i   i
 o
 u
                \i\
                               y
                       ^IQREASED
5YDRAHJLIC
               v
              A
           s
                       I'Cv
           A
 £4.
                             LQMD

                                                          I  i
                                                     I     I
         10
Figure 15-13
   20        30        40        50        60
3 PRODUCTION,  METRIC TONS/YEAR X  1000

 Effect of variation of hydraulic load on treatment
     cost at level 2 technology
                            371

-------
  20
                                             TT
u
  15
8
u
  10
           f
\i\T i
                         t:
      N,
                   , I
                                 I  '  !
           I
            10       20  """    30       40        50        60
                A1F3 PRODUC1TCN, METRIC TONS/YEAR X 1000

   Figure 15-14.  Effect of variation of hydraulic load on treatment
                     cost at level 3 technology
                               372

-------
   20
U
   15
u
   10
          i  i
                         \l
                         _L
                                                       .  I  i
                                                                 i  I
              10       20        30        40       50       60
                A1F3  PRODUCTION, METRIC TONS/YEAR X 1000

     Figure 15-15.  Effect of variation of hydraulic load on treatment
                       cost at level 4 technology
                               373

-------
                TABLE 15-21   MODEL PLANT TREATMENT COSTS
Subcategory  ALUMINUM FLUORIDE
Type of Regulation  BAT
                              Annual Treatment Costs/Metric  ton of  Product



Annual Operation
and Maintenance






Annual
Anortization






Total Cost







PRODUCTI01
(kkg/yr)

15,900
35,600
45,800
a 35,600
b 35,600
c 35,600
d 35,600

15,900
35,600
45,800
a 35,600
b 35,600
c 35,600
d 35,600
15,900
35,600
45,800
a 35,600
b 35,600
c 35,600
d 35,600

!J FLOW
(ni3/day)

690
1,550
1,990
1,550
1,550
2,203
1,064

690
1,550
1,990
1,550
1,550
2,203
1,064
690
1,550
1,990
1,550
1,550
2,203
1,064

FIRST
$

10.02
6.37
5.74
8.09
5.58
6.53
6.37

3.45
1.99
1.82
2.12
1.84
2.12
1.98
13.47
8.36
7.56
10.21
7.41
8.65
8.35
LEVEL OF T
SECOND
$

2.28
1.14
1.02
1.14
1.14
1.35
1.05

1.12
0.63
0.65
0.63
0.63
0.89
0.54
3.40
1.77
1.67
1.77
1.77
2.24
1.60
IEATMEN
THIRD
$
2.47
1.25
1.12
1.25
1.25
1.47
1.16
1.26
0.70
0.70
0.70
0.70
0.95
0.60
3.73
1.95
1.82
1.95
1.95
2.42
1.77
T
FOURTH
$
4.33
2.72
2.57
3.13
2.60
3.13
2.41
2.76
1.87
1.79
1.95
1.87
2.33
1.51
7.09
4.59
4.36
5.08
4.47
5.46
3.92
                 a Increased pollutant load
                 b Decreased pollutant load
                 c Increased hydraulic load
                 d Decreased hydraulic load
                                374

-------
     Effects on annual   costs  due   to higher  and lower pollutant
loads per unit of product  for  a  medium level of production model
plant  were studied.   At  high pollutant loading, the annual cost
at   the  first   and  fourth    levels  of  treatment   increased
approximately by 25  and   35   percent respectively  over the base
case cost.  At  the second  and  third levels of treatment,  annual
costs per unit of product  are  the  same as for the original  model.

     At lower pollutant  loading,  annual cost  at first  level of
treatment decreased by 15  percent  below  the base case  cost.  At
other levels, annual costs  per unit of  product  are the same  as
for the original model.

     Effects of annual costs   due  to  higher and lower  hydraulic
load per unit of product   for  a  medium  level of production model
indicated that at first  level  of treatment variation of hydraulic
loads had  an insignificant impact on annual cost compared  to the
original model annual cost.

     In the  second,  third and  fourth  levels of treatment, at a
higher  hydraulic  load,   additional  annual  costs per  unit  of
production increased by  24, 21,  and 18 percent respectively over
the original model costs.

     At a lower hydraulic  load,  additional annual costs per  unit
of production decreased  by  10  percent at second and third  levels,
and by 16 percent at the   fourth  level, compared to the original
model cost.
                                375

-------
                          SECTION 16
                   CHROME PIGMENTS INDUSTRY
16.1 ASSESSMENT OF THE WATER POLLUTION POTENTIAL
16.1.1 Industry Profile and Analytical Results

    Chrome pigments are mostly  sold  in  the  merchant market,  and
consequently captive use is very  low.  They  are  extensively used
in paints, printing ink, floor covering products  and  paper.   They
are also used in ceramics, cement, and asphalt  roofing.

    The industrial profile data for this subcategory is given in
Table 16-1, while the existing regulations are  in 16-2.

    The priority pollutants found  at significant concentrations
in the raw waste during sampling at chrome pigments plants  (209)
were as follows:
    Pollutant
                 Maximum Concentration
            Screening
(ug/1)
     Verification
     (2 Plants)
    Cadmium-                 79
    Cyanide                360
    Chromium             55000-
    Copper                7500
    Lead                 36000
    Zinc                  4100
    Antimony              7700
    Selenium               <10
    Silver                   7
    Nickel                 160
    Phenol*                 73
    Bis (2 ethylhexyl)
    Phthalate*              <0.1
    * from organic pigment process
                                          1,250
                                          8,200
                                        349,000
                                          4,700
                                         69,000
                                        273,000
                                          1,475
                                             28
                                             20
                                            740
    A summary
plants sampled
waste loads
  of daily and unit product  raw  waste  loads for all
  can be found in Table  16-3.    Individual plant raw
per unit product found  in  sampling  can be  found  in
                             376

-------
TABLE  16-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
CHROME PIGMENTS
Total  subcategory capacity rate
Total  subcategory production rate
Number of plants  in this  subcategory
308 Data on file  for
    With total capacity of
    With total production of
    Representing  capacity
    Representing  production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                            63,000 kkg/year
                            64,500 kkg/year
                                11
                                 4

                            19,660 kkg/year

                                30 percent

                             3,500 kkg/year
                             8,800 kkg/year
                             6,300 kkg/year
                             6,400 kkg/year
                                78 percent

                                38 years
                                60 years

                              360 cubic meters/day
                              800 cubic meters/day

                                32 cubic meters/kkg
                                60 cubic meters/kkg
Sources of data are Stanford Research Institute,  Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental  Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                    377

-------
TABLE 16-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES



                 Chrome Pigments


SUBPAET           AH   (40CFR  415.340, 5/22/75)
' " STANDARDS
Product
Process
Chrome
Pigment









BPCTCA* BATEA
1 2
Max. Avg. Max. Avg.
Para- kg/kkg k/kkg k/kkg k/kkg
meters (mg/1) (mg/1) (mg/1) (mg/1)
TSS 5'1
lbb (76.1)*
Cr(T) °-10
^ U} (1.5)
p +6 0.010
^ (0.2)
Pb °'42
(6.3)
Zn °'72
Zn (10.8)
CN °-010
(1.5)
0.10
^J.N V**/ / /\ o \
(0.2)
Fe °'72
(10.8)
1.7
(25.4)
0.034
(0.5)
0.0034
(0.1)
0.14
(2.1)
0.27
(4.0)
0.0034
(0.5)
0.034
(0.1)
0.27
(4.0)
NSPS
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)










 Sections 415.340,  415.341, and 415.342 were revoked by the Agency

 HI FR 51601, November  23, 19761.

 Max, = Maximum of any one day.
 2
 Avg. = Average of daily values for thirty consecutive days shall not exceed.




 * flow basis  67,000 1/kkg.
                                    378

-------
       TABLE 16-3.    SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING
U)
^4

SUBCATEGORY
Pollutant
Priority
Antimony, Sb
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Nickel, Ni
Zinc , Zn
Cyanide, CN
Organic s
Phenols
Phenolics
Conventional
TSS
Iron, Fe
CHROME PIGMENTS
Loadings
kg/day
Minimum Average Maximum Minimum

5.90 51.7 98.0 0.14
0.87 5.44 10.0 0.02
698 1016 1333 11.5
6.08 50.8 95.2 0.14
237 347 458 5.46
1.38 1.71 2.03 0.032
52.2 381 712 0.86
3.11 24.4 45.8 0.072

0.93
8.80
3049
7.03

kg/kkg
Average

0.87
0.16
21.5
0.86
6.49
0.0325
8.63
0.41

0.015
0.14
70.4
O.16

No. of Plants
Maximum Averaged

1.61 2
0.09 2
30.8 2
1.58 2
7.62 2
0.033 2
16.4 2
0.75 2






-------
Table 16-4.

    Based on the total  annual production  and  the   average waste
load  generated  per unit product, the   estimated   total  priority
pollutant   raw  waste  loads   generated   each year    for  this
subcategory
are as follows
         Pollutant
              Waste  Load  (kg/year)
         Cadimurn
         Chromium
         Copper
         Lead
         Zinc
         Antimony
         Nickel
         Cyanide
                   10000
                 1400000
                   55000
                  420000
                  560000
                   56000
                     2100
                   26000
16.1.2 Process Waste Sources and Waste  Water  Treatment Data
General Process Description

    Chrome pigments  are  a   family   of    inorganic   compounds
containing  chromium, lead,  iron, molybdenum,   and  zinc used for
pigments.  They include chrome yellow,  chrome   orange,   molybdate
chrome orange, anhydrous and hydrous chromium  oxide,  zinc  yellow
and  iron blues. At some plants the compounds are made  in the same
facility either simultaneously or sequentially  depending on sales
and  market requirements.  The  general   manufacturing  process for
each of the compounds is given below.

    Chromium oxide  -  This pigment  consists   of  two  compounds,
anhydrous  and hydrated chrome oxide  (Guigets  Green) .   The amount
of  the anhydrous salt oxide produced is approximately  ten  times
the  amount  of hydrated  chromic  produced.  It is  offered  in  a
narrow range of shades from light yellowish  to  dark  bluish green.

    Anhydrous oxide  is  almost  'pure   chromium  oxide  and  the
commercial grade consists of a minimum  of  98.5  percent  Cr203.  It
is prepared by  calcination of sodium dichromate with   sulfur  or
carbon according to the reactions given below:
    Na2Cr207 + S = Cr203 + Na2S04             (1)

    Na2Cr207 + 2C =  Cr203 + Na2C03  +  CO      (2)


    The use of  sulfur as the   reducing agent eliminates C02, CO
                              380

-------
TABLE  16-4.    PRIORITY POLLUTANT RAW WASTE LOADS (in kg/kkg of Product)
SUBCATEGORY
POLLUTANT

Cyanide, Cn
Chromium, Cr
Cadmium, Cd
Copper, Cu
Lead, Pb
Zinc, An
Antimony, Sb
Nickel, Ni
Phenols
Phenolics
CHROME PIGMENTS
PLANT
#894
0.754
11.5
0.165
1.58
7.52
0.855
1.612
0.0334
0.0152
0.1448


#002
0.072
0.020
30.8
0.140
5.46
16.4
0.136
0.032
No data
No data
                                    381

-------
and S02  emissions but increases  the  sulfate  raw  waste.   In the
manufacturing process using sulfur,  the  raw materials  consisting
of sodium  dichromate and  sulfur  are mixed with  water and  the
resultant solution is fed to a Kiln.   The  material is heated and
the  reacted  materials from  the kiln are   slurried with  water,
filtered,  washed,  dried,  ground,  screened,   and  packaged. The
effluent gases from the kiln containing  sulfur dioxide and sulfur
trioxide are wet scrubbed before venting  to the atmosphere.

    A general  process  flow  diagram   of   the  preparation  of
anhydrous chrome oxide is given in Figure 16-1.

    Hydrated chromium oxide, Cr203  2H20  or Cr20(OH)4, also known
as chromium hydrate and  Guignets  Green, is  a  brilliant bluish
green.  It is  made by reacting sodium dichromate with boric acid
as follows:

2Ma2Cr207 + 8H3B03 =  2Cr203.2H20 +  2Na2B407 + 8H20 + 302  (3)

    The raw materials are blended in  a  mixer  and then  heated in
an oven at about 550 degrees C.  The reacted material is slurried
with  water and  filtered.  The filtered  solids  are  washed with
water, dried, ground, screened,  and packaged.  The  filtrate and
the  wash water  are treated with sulfuric   acid to recover boric
acid according to the reaction given below:

 Na2B407 + H2S04 + 5H20 = 4H3B03 + Na2S04                  (4)

    A waste stream containing some  boric acid and sodium sulfate
leaves the boric  acid unit.  Figure 16-2 is  a  generalized flow
diagram of the process.

    Chrome yellow  and chrome  orange -  Chrome yellow  is one of
the more important synthetic pigments.   The chrome yellows  cover
the range of  hues  from light greenish  yellow to reddish  medium
yellow and  consist mainly  of lead   chromate.  They are made  by
reacting sodium dichromate,  caustic soda,  and lead nitrate.  The
reactions are given as:

2HN03 + PbO =  Pb(N03)2 + H20                               (5)

Na2Cr207 + 2NaOH + 2Pb(N03)2 =   2PbCr04  +  4NaN03 + H20    (6)

    Lead chromate  is  formed  as   a  precipitate   during  the
reaction.   it  is   filtered  and   treated with  chemicals  for
development  of  desired   specific   pigment  properties,   dried,
milled, and packaged.  The filtrate  from  the filtration operation
is sent to the waste water treatment facility.  A flow diagram of
the chrome yellow manufacturing process  is  shown in Figure 16-3.

    Molybdenum orange  -  Molybdenum  orange   is  made  by  the
coprecipitation  of  lead  chromate   (PbCr04)  and lead  molybdate

                           382

-------
                                                                   VENT
U>
OO
                                                                    I
	 or
SCRUBBER 	 >»
LICSJUD SCRl
WATER
SnnllJM DTCHRTMATE W
Of,
SULFUR »^


}2
BBER 1
JL
WA.TER WATER
1 1
Tj.] SLURRY FILTER DRYER ^
PACKAGIMG OF

1 CHROME OXIDE
¥ PRODUCT
                                                                                                                     WASH WATER
                                                          Figure  16-1,  General process diagram for production of anhydrous chrome oxide.

-------
SOD
DICHR
BORIC ACID
U>
CO
IUM
:MATE



MIXER




VENT
* WATER WATER
t * r
OVEN
SU

SLURRY
.jj^ F.U.TBK UH^EK
KFU1UC ACID
*
BORIC ACID |f
UNIT
                                                                                                       QIRDME
                                                                                              OXIDE TO GRINDING,
                                                                                              SCREENING AND
                                                                                              PACKAGING
                             WASTE WATER
Figure 16-2.   General process diagram for production of hydrated  chromic oxide.

-------
                             LEAD OXIDE
                             WATER
                             NITRIC ACID
                                               DISSOLVING
LO
CO
                                                                                                                WATER

SODIUM DICHKOMZVTE _
, ,_ ., p*
DISSOLVING

to-k
*»^


REACTION
TANK

^

f
FILTRATION
AND
WASHING
1
                                                                                                                                   CHROME YELLOW
                                                                                                                                   (PbCr04)

                                                                                                                                   TO DRYING,  MILLING
                                                                                                                                   AND PACKAGING
                                                                                                              WASTE WATER
                                                     Figure  16-3.  General process diagram for production of chrome-yellow.

-------
(FbMo04)
oranges.
          The resulting pigments   are  more brilliant than chrome
    The process consists of dissolving  molybdic oxide in aqueous
sodium hydroxide and adding  sodium   chromate.   The  solution  is
mixed  and  reacted  with  a  solution   of    lead  nitrate.   The
precipitate from  the reaction  is  filtered,  washed, dried, milled
and packaged.   The filtrate, is  sent to  the treatment facility.
The reactions  can be given as follows:
 Mo03 + 2NaOH = Na2Wo04 + H20
                                             (7)
 PbO + 2HN03 = Pb(N03)2 + H20                 (8)

 Na2Mo04 + Pb(N03)2 = PbMo04 + 2 NaN03        (9)
 Na2Cr04 + Pb(N03)2 = PbCr04 + 2NaN03
PbMo04
         PbCr04 = PbCr04. PbMo04
                                             (10)

                                             (11)
    A simplified flow diagram for  the  manufacture of
orange is given in Figure 16-4.
                                                       molybdenum
    Chrome green  - Chrome greens  are  a  coprecipi tate of  chrome
           iron blues.  They  include a wide  variety of hues from
              very  dark green.   Iron  blues   are manufactured by
                            of  iron sulfate  and  ammonium sulfate
                                                               is
yellow and
very  light to very  dark
reaction of aqueous. solution
with   sodium  hexacyanof errate.     The   precipitate  formed
separated and oxidized with sodium  chlorate  or sodium chromate to
form  iron  blues (Fe (NH4) [Fe (CN) 6] .    Chrome green is produced by
mechanically  mixing  chrome  yellow  and iron blue  pigments  in
water. The coprecipi tate formation  of  chrome green is given by:

 PbCr04 + Fe(NH4) [Fe(CN)6]  = PbCr04Fe (NH4 ) [Fe (CN) 6]   (12)
    Figure 16-5 gives a
of chrome green.
                        process  flow  diagram for the manufacture
    Zinc yellow - Zinc  yellow, also  called  zinc chromate, is  a
greenish  yellow  pigment.  It  is  a  complex   compound  of  zinc,
potassium,  and  chromium which has  the  approximate  composition
4ZnO.K20.4Cr03.3H20. It is made  by  the   reaction  of zinc oxide,
hydrochloric  acid,  sodium dichroinate,   and   potassium chloride.
Zinc yellow is formed as  a  precipitate  and  is filtered, washed,
dried, milled,  and  packaged for  sale.   The   reactions are given
as:

 2KC1 + 2HC1 + 2Na2Cr207.H20 = K2Cr4013 + 4NaCl + 3H20   (13)

 4ZnO + K2Cr4013 + 3H20 = 4ZnO.K20.4Cr03.3H20            (14)

    A general flow diagram of the manufacturing process is given

                             386

-------
CO
                       MOLYBDIC OXIDE
                            WATER
                       CAUSTIC SODA
                                    *•
                       LEAD OXIDE
                       NITRIC ACID
                                                                        SODIUM
                                                                       CllROMATE   WATER
                                          DISSOLVER
                                                  VENT
                                          DISSOLVER
                                                                                                                                                       4
                                                                                                                                                PRODUCT
                                         Figure 16-4.   General process diagram for production of nolybdate orange.

-------
                                           WATER
              IRON BLUE
                  WAT
LEAD NITRATE ^. 	 ,
U)
?B SODIUM CHROMATE ._
SODIUM SULFATE ..
REACTION

	 	 p»
W \


FILTER
AND
WASH
1


SHADE


TANK








DRYER
V
	 B» GRINDING
BLENDING
AND
PACKING
CHROME GREEN
PRODUCT
                  WASTE WATER
                                                                  WASTE WATER
Figure 16-5.   General process diagram for production of chrome green.

-------
in Figure 16-6.
Water Use and Waste Source  Inventories

     Water uses - In the  chrome   pigment industry water  is used
for noncontact cooling, washing  the  precipitated  product, and as
boiler feed  for  steam  generation.    In  some  cases  water is
introduced into the reactor  along  with the raw materials.

     In anhydrous and hydrated  chrome oxide manufacture, water is
used for slurrying  of the  reaction  product  and in scrubbing the
reactor  vent gases.  Table  16-5  is  a  summary of water usage at
different pigment plants in  the  chrome pigments subcategory.
     WaSte sources  -
                        some
products sequentially in the
different pigment products are manufactured
waste  waters combined  and treated   at   a
generalized flow diagram applicable  to  all
is given in  Figure  16-7.  The waste water
for all pigment products except   that  at
additional  scrubber waste is generated.
plants  produce  different  pigment
same process.  At a   few plants the
               concurrently and the
              single  facility.  A
              chrome  pigment plants
               sources are  similar
            chrome  oxide plants an
            Table
                                                  16-6  gives  the
waste water flow data summary  for  several  plants. The quantity of
waste  water  and  the pollutants  vary for  the different pigment
products since the pollutants  are  dependent on the raw  materials
used.  All  the  waste waters  generated  in  the  chrome pigments
subcategory contain  dissolved  chromium and pigment particulates.
     Additional pollutants  that  can
for each major pigment group.
                                      be   present are given  below
     Chrome yellow  and  chrome
contain  sodium acetate, sodium
sulfate, and lead salts.
                                  orange:    The  raw  waste  waters
                                 chloride,   sodium nitrate,  sodium
     Chromic oxide:  The aqueous  process effluent contains sodium
sulfate. If boric  acid is  used  in  the  preparation  of  hydrated
chromic oxide then the waste  water  will contain sodium borate and
boric acid.

     Chrome yellow  and  chrome   orange:   Additional  pollutants
present  in the  raw waste  water  from  chrome yellow and chrome
orange  manufacture  include   sodium  acetate,  sodium  chloride,
sodium nitrate, sodium sulfate and  lead salts.

     Molybdenum orange:     Process   waste   effluents  from the
manufacture of molybdenum orange  contain  sodium chloride, sodium
nitrate,  sodium sulfate,   chromium  hydroxide,  lead  salts and
silica.

     Chrome green:  The  raw  waste  water contains sodium nitrate.
                               389

-------
                             '3H2°
                    ZnO
}
                                                                     WATER

U)
UD
O
	 ^
IC1 fc
KC1 ^
	 1 	
REACTION TANK


FILTRATION
AND
WASHING


DRYING
                                                                                                                    .MILLING, PACKAGING
                                                                                                                     OF THE ZINC YELLOW
                                                                                  

-------
TABLE 16-5.   WATER USAGE IN THE CHROME PIGMENTS SUBCATEGORY
Pigment
Plant
       Water Usage, m /kkg of Product
Non-Contact     Consumed in      Boiler
  Cooling         Product        Feed
Chrome Yellow
and Chrome Orange


Molybdate Chrome
Orange


Zinc Yellow

Chrome Oxide

#409

#894
#002
#002

#409
#894
#002
#409
#257
#894
6.6

—
3.1
5.0

0
0
0
6.3
0.35
4.7
1.8

3.3
1.0
1.3

8.4
3.5
1.0
0.8
4.2
2.0
__
11

NA
NA
NA

3.5
NA
NA
4.2
1.7
NA
                                    391

-------
                                               WATER

                                                                             WASH VCVTER
                                                                                                                                   WASH DOWN WATER
RAW MATERIALS .^













MILLING AND
SCREENING
NJ
                                                                                                         f
                                T
                      PIGMENT
                      PRODUCTS
                      TO
                      PACKAGING
                                                                            WASTE l-IATER
                                                                            (BY-PRODUCT SALTS,
                                                                            UNREACTED MATERIAI^,
                                                                            ETC.)
NON-COMEACT
   STEAM
  PIGMENT
PARTICUIATE
   WASTE
                                                          Figure 16-7.   General process diagram for production of chrome pignent complexes.

-------
TABLE 16-6.   AQUEOUS PROCESS WASTE EFFLUENTS IN CHROME  PIGMENTS SUBCATEGORY
Pigment
                         Plant
Process Waste Water, m /kkg of Product
Chrome Yellow and
Chrome Orange
                          #409

                          # 894

                          #002

Molybdate Chrome Orange   #002

                          # 409

                          # 894

Zinc Yellow               #002

                          #409

Chrome Green              #894

Chrome Oxide              #257

                          # 894
                   44

                  120

                   35

                   31

                   40

                  110

                   20

                   19

                   48

                   29

                   31
                                    393

-------
If  iron blue  is  manufactured on site  as   part  of  the process for
chrome green  manufacture,  the waste  water   also  contains sodium
chloride,   ammonium sulfate, ferrous sulfate,   sulfuric acid  and
iron blue  pigment particulates.

    Zinc  yellow:   The  raw  wastes  contain hydrochloric  acid,
sodium chloride, potassium chloride, and  soluble  zinc salts.

    As previously discussed, various plants make  several  chrome
pigments sequentially  or concurrently.   Thus the   unit hydraulic
load going to the treatment facility will  be  an   average of  all
the waste  loads  from the different processes.   The raw waste from
a  complex  plant   may  contain  nearly   all   of   the  following
substances:  sodium  acetate,  sodium  chloride,   sodium nitrate,
sodium sulfate,   potassium  chloride; lead,  iron,  and zinc salts,
soluble chromium and pigment particulates.
Control and Treatment Practices

    Plant |894  was visited during the   screening   phase  of the
program. This  plant produces over 100 products  including organic
pigments such as copper  phthalocyanine,  and  all   the wastes  are
combined and treated together.  Treatment consists  of chr-omium VI
reduction,   equalization   and   neutralization,    followed   by
clarification  and filtration.  Sulfur dioxide  is  added to reduce
the hexavalent chromium  to the trivalent state  at  a low ph prior
to hydroxide precipitation. The backwash  from the  sand filters is
recycled  to  the equalization  tank,  while  the  sludge from  the
clarifiers is passed through filter presses and  then hauled to  a
landfill.  The landfill has  a  bottom of two   clay layers  with
gravel in between  to  allow the collection of  leachate drainage.
Any water from the  sludge is trapped in  the  gravel layer, and is
pumped out and returned to the plant  for  retreatment.

    Figure 16-8 shows the treatment  system flow diagram with the
sampling points  indicated.  Table  16-7   gives  waste  flows  and
pollutant loadings.

    Plant #002 was visited during  the verification phase of the
program.  Normally  this  plant  has  a product  mix  of over 100
pigments most of whicn  are produced  in  batch  processes.  At the
time  of sampling,  zinc  chromate  was   being   produced  by  the
continuous production  unit.  During  an   eight   week  cycle  the
continuous unit  produces zinc  chromate  for   one   week  and lead
chromate for seven weeks.  All process contact  wastes are treated
continuously.  The waste is pumped to a treatment  tank where  S02
is added  to convert hexavalent chromium   to  the  trivalent state.
The ph is adjusted to 8.5 and  then the   waste   is  passed through
precoated filters  followed  by discharge to the   sewer.  Figure
16-9 shows the treatment flow diagram and sampling  points.  Table
16-8 shows the  waste  flows  and pollutant   loadings.  At sample

                             394

-------
                                  WASTE
                                                                                                           SLAKED
                                                                                                           LIME
                WASTE
                WATER
                           01
                      (EPA SAMPLE
                       POINT ALSO)
                                                           EQUALIZATION
                                                              TANK
NEUTRALIZATION
     TANK
  pH 6.2-6.5
                                                                                                                          1
NEUTRALIZATION
     TANK
  pH 8.0-8.3
U>
iX>
LT1
                                                                                                                                                             POLYMER
                                                                                                               -e-
                                            CLAR1FIER
                                             EFFLUENT
                                             IDLDING
                                               TANK
                                           (3)  CLARIFIERS
                                                                                                     (EPA SAMPLE
                                                                                                      POINT ALSO)
                                                                                            FINAL
                                                                                          DISCHARGE
                                                                                          TO RIVER
                                                                                                                                           Sample points.
                                                        Figure  16-8.   General waste water treatment process flow diagram at plant #894
                                                                   showing the sampling points. (Chrome Pigment Manufacture)

-------
TABLE 16-7.    FLOW AND  POLLUTANT CONCENTRATION DATA OF  THE SAMPLED
              WASTE STREAMS FOR PLANT  #894 PRODUCING CHROME
              PIGMENTS
Stream
 Flow       TSS       Cr         Fe        Pb        Cu
m3/kkg   kg/kkg    kg/kkg   kg/kkg    kg/kkg    kg/kkg
Treatment
Influent
Treatment
Effluent
Leachate
Sand Filter
100

100

NA
100
78

0


1
.1

.393

NA
.1
7

0

0
0
.93

.032

.258
.060
4

0

0
0
.9

.03

.39
.10
1

0

0
0
.52

.011

.164
.068
0

0

0
0
.356

.004

.008
.000
Feed
TABLE 16-8.     FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
              STREAMS FOR PLANT #002 PRODUCING CHROME PIGMENTS

Stream
Untreated
Waste
Flow
m^/kkg
85.6
TSS
kg/kkg
59.8
Cr
kg/kkg
26.25
Zn
kg/kkg
4.64
Pb
kg/kkg
13.94
 Unfiltered      85.6
 Treated Waste

 Filtered        85.6
 Treated Waste
             N.A.
             82.94
11.14
29.90
0.128    10.02
4.25
14.31
N.A. = Not Analyzed
                                   396

-------
                                                                             PAW WASTE  SO-    ACID
                                                                                 QIRCME TREATMENT
                                                                                       TANK
                                                                                      pH 3.0
                                                              CAUSTIC
LO
^D
--J
                                                                                                              3ACKWASH
                                                                                          | (FILTERS NOT WORKING SO
                                                                                          |  WERE BEING BYPASSED,
                                                                                            tTHIS WOULD BE THE FLOW
                                                                                            PATTERN IF FILTERS WERE
                                                                                            OPERATING.)
8
Sarrpling points.
                                                                     OUTFALL
                                                                     TO SEWER
                                                    Figure  16-9.  General  waste water treatment process flow diagram at Plant #002
                                                                            showing the sampling points.
                                                                           (Chrome Pigment Manufacture)

-------
point #2,   half   the  sample was filtered   through  a   glass fiber
filter on  a  Buechner funnel  to simulate  the  filtration  process
which was  being  bypassed at the time of  sampling.   Analyses  were
carried out done on the filtered and unfiltered  samples in  order
to  make  possible  a  comparison  of  the   total   and  dissolved
concentrations.

    At Plant #464, the chrome pigment process wastes are sent to
a settling basin and an discharged to a  sewer.

    Plant #502  discharges its wastes directly to  the sewer.

    At Plant #409, the waste waters from  the  zinc  yellow process
plant are  collected and passed through   two  ion  exchange  columns
to  recover  chromate  values which are  returned  to  the process.
The effluent  from the ion-exchanger is  treated   with soda ash to
precipitate zinc  salts as zinc  carbonate,  which   is filtered to
recover zinc carbonate.

    At one plant the waste  waters from the zinc   yellow process
are  acidified  to  dissolve the  hexavalent  chromium  and  then
treated with sulfur dioxide to reduce the  hexavalent  chromium  to
the trivalent  state.  The solution is   then reacted  with caustic
soda  for  metal   precipitation. The  reacted solution is filtered
and the filtrate is discharged (52) .

    At another  chrome pigment manufacturing complex, plant waste
waters are  collected and  treated with  sulfur  dioxide  in  acid
solution followed by lime addition  in two  stages  to give a pH  in
the range  7.5-8.5.  The metals are precipitated  by  the treatment.
The slurry is further treated with sodium  sulfide  for  additional
precipitation of metals.  The reacted solution is  flocculated and
sent to a  clarifier.  The  overflow from the clarifier is  passed
through  mixed  media  filters before  discharge.   The clarifier
underflow  is filtered  in  a plate and  frame  filtration unit and
the  solids  are  land filled.  The filtrate is   returned  to the
clarifier   (52) .


Best Management  Practices and Technology Transfer  Options

    1.  All  storm water and surface area  runoff  from the  plant
site can be collected and sent to the treatment  facility-
    2.  If  the solids from the treatment   plant are disposed of
on-site  provision  should  be  made   to  control  leachates  and
permeates,  it is possible to monitor  the metal  concentrations and
when concentrations  approach predetermined   limits,  the leachate
can be pumped bacK to the treatment system  for  further treatment.
                              398

-------
Model Plant and BPT Level  Treatment System Specifications

     The BPT treatment  system  for chrome  pigment wastes consists
of:
     A.  Acifidification  in  a  recirculated holding tank.

     B.  Reduction with sulfur dioxide to convert hexavalent
chromium to its trivalent  state.

     C.  Addition of caustic  soda to precipitate chromium
and other heavy metals.

     D.  Polymer-assisted  clarification to settle metallic
hydroxides.

     E.  Filtration to  remove  fine suspended matter.


     Production in the  industry ranges from 3500 kkg/yr to 20,000
kkg/yr.  For the model  plant   four production rates were  chosen:
1,500,  4,000, 6,000 and  18,000  kkg/yr.   These cover the entire
range  of  production   rates.    Most  plants produce  many chrome
pigment  products  on   a  continuous basis so the operational mode
selected  was continuous  and   assumed to  run 350  days per year.
Chrome  pigments are  usually  produced  in  integrated facilities
with the  necessary flexibility  to  shift from  one  product  or
combination of products to another.  The model plant was selected
to  reflect this type   of  complexity.   The observed waste flows
varied from 19 m3/kkg to  150  m3/kkg.  The value of 105 m3/kkg was
selected as the model plant  waste flow.

     Pollutant loads  - For   the  model plants, the loadings  are
based  on  screening  and  verification  plant  data as  well  as
loadings presented in previous EPA documents.   The loadings used
for the model plant were  8.5  kg chromates as chromium per  kkg of
product and 50 kg suspended  solids per kkg of product.

     Chemicals required -  The  calculated quantity of caustic soda
required to  raise  the  pH  to 8.5 is 400 mg/1.  The unit caustic
soda requirement 45 kg/kkg  of product.  Sulfuric acid and sulfur
dioxide are  used at 67.5  and  40.75  kg per kg  of chrome pigment
respectively.

     Generation p_f  Solids   Sludge   solids   are  composed  of
suspended  solids   (given  above  as  50  kg/kkg) and  the  solids
generated as  reaction  products.   Considering chromium  hydroxide
as the major insoluble  reaction product, the unit quantity is  17
kg/kkg of product.  The total  solids  to  be  hauled  to a secure
landfill is 67 kg/kkg of  product.
                               399

-------
16.2 TECHNOLOGY  BASED POLLUTION ABATEMENT


16.2.1 Advanced  Level Treatment Applications


priority Pollutants to be Controlled

    The priority pollutants found  in  significant amounts are the
heavy metals contained in the chromium ore,   including  chromium,
antimony,  copper, cadmium,  nickel, lead,  and zinc.   In sorae raw
wastes, ferro-  and ferricyanide are found,  presumably from metal
complexing  steps  in  the ore  processing  and the manufacture of
iron blues.   These complex  cyanides  may  pass through  the model
treatment processes  and  could slowly revert to  simple  cyanide
ions.


Removal Technologies Available

    All of the  common heavy metals  (except  hexavalent  chromium)
found in chrome   pigment wastes will be precipitated   by alkaline
substances such  as  lime or caustic  soda,  although the optimum pH
may  differ for  each metal.  Reaction  with  sulfide compounds such
as sodium bisulfide will precipitate the same metals,  except in a
less pH-dependent manner and, with   the exception of  chromium, to
lower co-Fveentrations.  Chromium  in  its  hexavalent   form can be
reduced to  its  trivalent form  and  then precipitated  as chromium
hydroxide at a pH above 10.


Technology to be Applied at Each Level

    BPT  (Level   !_)_ -  Incoming wastes are  acidified  and  reduced
prior  to  alkaline precipitation.   Settling and  filtration are
used to remove suspended solids.

    Level 2_ - For better separation of the  trace metals, sulfide
precipitation is incorporated ahead  of the  BPT dual media filter.


Flow Diagrams


    Level 1                      Figure 16-10

    Level 2                      Figure 16-11

    Equipment Functions - In  both  levels,  the incoming  wastes
are acidified in  a  holding tank   and then  treated with  sulfur
dioxide solution  in a  reactor to  convert hexavalent chromium to
trivalent chromium.  Caustic soda is   added  as a precipitant  and


                             400

-------
r~
                                  BACKWASH
SULFURIC
  ACID
Q CAUSTIC SODA
                                                                  LJ

RAW
L
t .
WASTE' WATER" 1

3
I


SULFUR
DIP

JAIL)
1

h,

P0
f.

 |   HOLDING TANK      REACTION  MIX
                            TANK    TANK
 1
                                                         SUMP
                                                   CLARIFIER
                              SLUDGE
                                TANK
               TO LANDFILL
   Includes flow monitoring, pH monitoring and sampler.
                                                                                ADJUSTMENT
                                                                                         *EFFLUENT
                                                                   FILTER
           Figure 16-10.  Waste water treatment Level 1 for chrane pigments.

-------
                                         FERROUS SULFATE   SODIUM BISULFIDE
                               BACKWASH
                                         CAUSTIC
                                         I  SODA

RAW
LJ SULFUR
\.
WASTE WATERl





DI(
&
D3
•CID
E


1
	 P

  HOLDING TANK
                        REACTION    MIX
                          TANK      TANK
U-
                                                           SUMP

                                                        CLARIFIER
                                                                       FILTER
                               SLUDGE
                 TO LANDFILL
   Includes flow monitoring, pH monitoring and sampler.
EFFLUENT
            Figure 16-11. Waste water treatment Level 2 for chrome pigments.

-------
polymer is  added to help  settle the heavy  metal hydroxides  in a
clarifier.  The settled  effluent is then filtered in a dual media
filter and discharged after  ph   adjustment to the  range  6 to 9.
In Level  2, ferrous sulfide is  added ahead  of the  dual media
filter,  for  more effective precipitation  of all  the residual
heavy metals,  including   antimony.  As  in  Level 1, the  filter
effluent is adjusted to  a  ph between 6 and 9 before discharge.

     Chemicals and  handling - Sulfuric  acid and  caustic  soda
solutions  are common   industrial  chemicals  wnich  are  readily
handled  with  conventional   liquid  feeding  equipment.   Sulfur
dioxide  is  received as a   compressed  gas which is dissolved in
water by  a  modified gas  chlorinator  and fed to the  reactor to
maintain consistent  reducing conditions.   Polymer is  fed  by a
standard package of holding  tank, mixer and feeder.  With  normal
precautions, there are  no  unusual hazards  in handling  chemicals
for treatment of chrome  pigment wastes.

     Separation and  Pi sposal    of  Sol ids  -  Solids  from  the
clarifier, including  recirculated  filter  backwash  solids, are
dewatered in  a filter   press   and hauled to a chemical landfill.
Sludge filtrate is returned  to  the influent holding tank.

     Monitoring Requi rements -   Internal   process  monitoring
consists of maintaining  proper  ph levels in  the holding tank and
final effluent, using   conventional field equipment.  A  reducing
environment   is    maintained    in   the   reactor,   using   an
oxidation-reduction potential   instrument and/or the analysis for
excess  S02.  Periodic   effluent  analyses  for chromium  and the
trace  heavy metals should be made on composite samples by atomic
absorption  methods, for   official  reporting  purposes.  Sulfide
monitoring is  unnecessary because dissolved sulfides should  not
exist in the presence of excess ferrous iron and oxygen.


16.2.2  Estimated Performance of BPT Systems

     Pollutants previously regulated  in this subcategory include
suspended solids, hexavalent chromium, total chromium, lead, and
zinc.  Where iron blues  are  manufactured, iron, total cyanide and
oxidizable cyanide are  regulated.  Raw waste priority  pollutants
found  in  significant   concentrations   during  screening  and
verification   sampling    were    presented   earlier.    Selected
pollutants which  may   require  regulation  in  addition  to those
listed above include antimony,  cadmium, copper and nickel.

     Waste water  treatment  at   chrome pigment  facilities ranges
from  simple  settling   and discharge  to  chemical  reduction,
precipitation and filtration.   One facility uses ion exchange for
treating wastes from a  single product.
                               403

-------
    At Plant  #894,  a   complex  facility also   producing   organic
pigments,   treatment   consists  of  equalization,   reduction  of
tiexavalent    chromium,   lime  addition  to
sedimentation,   biological  oxidation  and   filtration   prior
discharge.     Table    16-9  presents   effluent    monitoring
verification  sampling  results from this plant.
                                 precipitate  metals,
                                                   to
                                                  and
    At Plant   #002,   another   complex  facility,   waste   water
treatment   consists   of   reduction   of   hexavalent   chromium,
neutralization  with caustic, and filtration prior  to  discharge  to
a POTW.  During verification  sampling, the treatment  system was
not   operating    efficiently   so   analytical    results   were
inconclusive.

    BPT technology has been specified in  Section  8  as  reduction
of hexavalent   chromium,  hydroxide   precipitation  of metals,
clarification,   and  filtration  for  suspended  solids   removal.
Important  to   treatment  efficiency  is  sufficient  equalization
capacity to control waste variations and surges.
Base Level Performance Characteristics for BPT Pollutant  Removal

    Based on data presented in Table 16-9 and on  the   discussion
of  the  reduction of hexavalent chromium  with sulfur  dioxide  and
other  raetals with  hydroxide precipitation,  achievable   treated
effluent  quality  with  implementation  of   BPT   technology   is
presented in Table 16-10.
Base  Level
Removal
Performance Characteristics  for   Priority  Pollutant
    Additional priority   pollutant   metals   found   in   chrome
pigments  raw waste  were antimony,  cadmium,  copper   and  nickel.
Based on verification sampling results shown  in  Table  16-9 and  on
the   hydroxide   treatability    discussion    in    Section    8,
implementation  of  BPT  technology  will   achieve   the    treated
effluent quality presented in Table 16-10.


Pretreatment Applications

    Several chrome pigment plants discharge  waste  water  to POTWs
and removal  of incompatible heavy metal  pollutants is necessary.

    BPT technology  for pretreatment  of   chrome   pigments waste
waters is recommended.
                            404

-------
TABLE 16-9.    MONITORING AND VERIFICATION SAMPLING OF CHROME PIGMENTS FLAW
               #894
Verification Sampling:
Pollutant
Influent
3 mg/1
Avg Flow (m /kkg)
Total Suspended
Solids, TSS
Chromium, Cr
Chromium VI, Cr
Iron, Fe
Lead, Pb
Zinc, Zn
Cyanide, CN
Cyanide (Free) , CN
XT.
Antimony, Sb
Cadmium, Cd
Copper, Cu
Nickel, Ni
780

78
<0.01
49
15.2
4.2
5.1
<0.94
0.74
0.90
3.56
0.017

kg/kkg
78

7.8
<0.001
4.9
1.52
0.42
0.51
<0.094
0.074
0.090
0.36
0.0017
Effluent
mg/1
153
3.9

0.32
<0.03
0.30
0.11
0.058
<0.066
<0.011
0.30
0.0084
0.04
<0.024

kg/kkg
0.39

0.032
<0.003
0.03
0.011
0.0058
<0.0066
< 0.0011
0.030
0.00084
0.004
<0.0024
Monitoring Data - Treated Effluent
Total Suspended Solids, TSS
Chromium VI, Cr
Chromium, Cr
Copper, Cu
Lead, Pb
Zinc, Zn
Cyanide (Free) , CN
Cyanide (Total) , CN
Arsenic
Cadmium
Mercury




<



<
Avq
30 day Avq Waste Load (Avg)
Concentration mg/1
11.2 23.5
0.11 0.3
0.44
0.13
0.41
0.044
: 0.012
0.12
0.08
0.08
: 0.001
0.73
0.25
0.87
0.075
0.044
0.31
0.16
0.12
0.0017
kg/kkg
1.92
0.018
0.074
0.023
0.069
0.0072
0.0019
0.019
0.0125
0.013
0.00007
                                    405

-------
          TABLE  16-10   CONTROL PARAMETER  LIMITATIONS
                 SUBCATEGORY: Chrome Pigments
                     Level of Treatment:  1
                 Waste Water Flow:  100  m3/kkg
                                  Quality  Limit    Emission Limit
              Subcategory     (1)     (mg/1)           (kg/kkg)
Pollutant      Performance   VFR   	    	
                (mg/1)             30 day   24  hr    30  day  24 hr
                                   Aver     Max      Aver    Max
BPT Pollutants:

Total Suspended     22        2.0    15       30     1.5     3.0
Solids, TSS
Total Chromium,
Cr
Hexavalent
Chromium, Cr+6

Iron, Fe
Lead , Pb
Zinc, Zn
Cyanide, CN
Oxidizable
Cyanide, CN(A)
Proposed Priority
Pollutants
Copper, Cu

Nickel, Ni
0.73

0.30

(2)
0. 3
0.87
0.07
0. 31
0.04



0.25
(2)
0.05
3.

3.


2.
2.
2.
4.
4.



2.

2.
0

0


0
0
0
0
0



0

0
1.

0.


1.
0.
0.
0.
0.



0.

0.
0

2


0
8
4
5
05



3

1
3.0 0.
*
0.6 0.


2.0 0.
1.6 0.
0.8 0.
2.0 0.
0. 2 0.



0.6 0.

0. 2 0.
1

02


1
08
04
05
005



03

01
0.

0.


0.
0.
0.
0.
0.



0.

0.
3

06


2
16
08
2
02



06

02
  (1) - VFR:  ratio of the 24 hour variability  factor to the
            30  day variability factor.

  (2) - Verification Sampling
                               406

-------
Response to Remand  Issues

     Major remand issues   of  BPT limitations in this  subcategory
were the following:

     1.  The accuracy and  reliablity of the analytical method for
hexavalent chromium  in chrome   pigments  waste  waters  and  the
possible deletion   of  hexavalent  chromium  in  favor  of total
chromium as a control parameter.  Industry has shown that certain
waste   constituents  can   cause  a  reducing  environment which
interferes in the analysis of  hexavalent chromiun leading to low
results.   Industry  has   recommended an  alternative  analytical
technique which has yet to be accepted.  The questions  regarding
the present analytical method  need to be resolved.  However, the
high toxicity of hexavalent chromium  necessitates the regulation
and control of this pollutant.

     2.  The treatability   of particular pollutants found  in the
raw  waste loads,   including  the  achievable levels  with mixed
effluent  streams.   Industry  has  questioned  the  transfer  of
technology from  the  electroplating  industry.   The  achievable
effluent quality  presented above is based  on available  data on
the  treatability of  mixed  wastes  and  takes into account  the
variability of wastes encountered in this subcategory.


16.2.3  Estimated Performance of Advanced Level Systems


Advanced   Level  Performance  Estimates  for  BPT  and  Priority
Pollutant Removal

     Table 16-11  presents estimates  achievable effluent quality
through implementation of  this  advanced technology.


New Source Applications

     Following examination of  treatment technologies  applicable
to  new  chrome pigment facilities, it has been  determined  that
effluent quality achievable  through  the  implementation of  the
above advanced technology  is  appropriate for NSPS.


16.2.4 Cost Estimates
Discussion

     Cost estimates   for  models  having four different production
rates and two levels  of treatment  are presented in Tables 16-12,
16-13, 16-14,  and 16-15.  Annual treatment cost as a function of

                               407

-------
         TABLE  16-11   CONTROL PARAMETER LIMITATIONS
                SUBCATEGORY:  Chrome Pigments
                     Level  of  Treatment: 2
                Waste  Wa-ter  Flow: 100 m3/kkg
                                  Quality Limit   Emission  Limit
                               (1)     (mg/1)           (kg/kkg)
Pollutant      Treatability   VFR   	   	
                (mg/1)             30 day  24 hr   30 day  24 hr
                                   Aver    Max     Aver     Max
BPT Pollutants ;
Total Suspended
Solids, TSS
Total Chromium,
Cr
Hexavalent
Chromium, Cr+6
Iron, Fe
Lead, Pb
Zinc, Zn
Cyanide, CN
Oxidizable
Cyanide, CM (A)
Proposed Priority
Pollutants
Copper, Cu
Nickel, Ni
15

0.

0.

1.
0.
0.
0.
0.



0.
0.


05

2

0
1
2
5
05



05
1
2.

3.

3.

2.
2.
2.
4.
4.



2.
2.
0

0

0

0
0
0
0
0



0
0
15

1.

0.

1.
0.
0.
0.
0.



0.
0.


0

2

0
1
2
5
05



05
1
30 1.

3.0 0.

0.6 0.

2.6 0.
0. 2 0.
0.4 0.
2.0 0.
0.2 0.



0. 1 0.
0. 2 0.
5

1

02

1
01
02
05
005



005
01
3.

0.

0.

0.
0.
0.
0.
0.



0.
0.
0

3

06

2
02
04
2
02



01
02
  (1) - VFR:  ratio  of the 24 hour variability  factor  to  the
           30  day  variability factor.
                               408

-------
                    TABLE 16-12   MODEL PLANT TREATMENT COSTS

   Subcategory  CHROME PICMENTS                      Type of Regulation  BAT

   Production         1,500 metric tons per year (   1,653 tons per year)
                          4 metric tons per day  (       4 tons per day  )
   Waste water flow     454 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	               $36,800              $500
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               280,650             6,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	                65, 290             1,300
    Incidentals, overhead,
    fees, contingencies...                65,290             1,300
    Land	                 6,000

    TOTAL INVESTMENT COST               $463,030            $9,100

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.              $112,000           $14,000
    Energy	                 7,350               300
    Chemicals	                53,000             2,200
    Maintenance	                45,703               910
    Taxes and insurance...                13,890               273
    Residual waste
    disposal	                 5,000
    Monitoring, analysis
    and reporting	                15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $251,943           $25,183

C.  AMORTIZATION OF
    INVESTMENT COST                      $74,358            $1,480

    TOTAL ANNUAL COST                   $326,301           $26,663


    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.
                                     409

-------
                  TABLE 16-13   MODEL PLANT TREATMENT COSTS
  Subcategory  CHROME PIGMENTS

  Production
                                                  Type of Regulation  BAT
                  4,000 metric  tons per year (   4,410 tons per  year)
                     11 metric  tons per day  (      12 tons per  day )
Waste water flow    1219 cubic meters per day.
A.  INVESTMENT COST

   Construction  	
   Equipment in  place,
   including piping,
   fittings, electrical
   work and controls	
   Monitoring equipment
   in place	
   Engineering design
   and inspection	
   Incidentals,  overhead,
   fees, coatingencies...
   Land	

   TOTAL INVESTMENT COST

B.  OPERATION AND
   MAINTENANCE COST

   Labor and supervision.
   Energy	
   Chemicals	
   Maintenance	
   Taxes and  insurance...
   Residual veste
   disposal	
   Monitoring, analysis
   and reporting	
   TOTAL OPERATION AND
   MAINTENANCE COST

   WORTIZATION OF
   INVESTMENT COST

   TOTAL ANNUAL COST
                                            LEVEL OF TREATMENT*

                                          FIRST             SECOND
                                      $53,900



                                      510,000

                                        9,000

                                      114,580

                                      114,580
                                       12,000
                                     $814,060
                                     $112,000
                                       15,000
                                      141,300
                                       80,206
                                       24,421

                                       15,000

                                       15,000


                                     $402,927


                                     $130,495

                                     $533,422
 $1,000



 10,000



  2,200

  2,200


$15,400
$14,000
    300
  5,900
  1,540
    462
  7,500


$29,702


 $2,505

$32,207
   *First level represents the base cost of treatment system.
   Other levels represent the incremental cost above base cost.
                                     410

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                    TABLE 16-14   MODEL PLANT TREATMENT COSTS
   Subcategory  CHRCME PIGMENTS

   Production

   Waste water flow
                               Type of Regulation BAT
6,000 metric tons per year  (   6,615 tons per year)
   17 metric tons per day   (      18 tons per day )
 1820 cubic meters per day.
A.  INVESTMENT COST

    Construction 	
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	
    Monitoring equipment
    in place	
    Engineering design
    and inspection	
    Incidentals, overhead,
    fees, conting enc ies...
    Land	

    TOTAL INVESTMENT COST

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.
    Energy	
    Chemicals	
    Ma intenance	
    Taxes and insurance...
    Residual waste
    disposal	
    Monitoring, analysis
    and repo rting	
    TOTAL OPERATION AND
    MAINTENANCE COST

    AMORTIZATION OF
    INVESTMENT COST

    TOTAL ANNUAL COST
                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
                   $71,400



                   667,000

                     9,000

                   149,480

                   149,480
                    12,000
                $1,058,360
                  $112,000
                    20,200
                   211,500
                   104,636
                    31,750

                    20,000

                    15,000
                  $515,086
                  $170,242
                  $685,328
 $1,000



 14,000



  3,000

  3,000
$21,000
$14,000
    300
  8,800
  2,100
    630
  7,500


$33,330


 $3,416

$36,746
    *First level represents the base cost of treatment system.
    Other levels represent the incranental cost above base cost.
                                      411

-------
                  TABLE 16-15    MODEL PLANT TREATMENT COSTS
  Subcategory  CHROME PIGMENTS
               Type of Regulation  BAT
  Production        18,000 metric tons per year  (  19,845  tons per year)
                       51 metric tons per day   (       56  tons per day )
  Waste water flow     5460 cubic meters per day.


                                            LEVEL OF  TREATMENT*

                                          FIRST             SECOND
A.  INVESTMENT COST

   Construction	               $205,500             $2,000
   Equipment in  place,
   including piping,
   fittings, electrical
   work and controls	              1,495,500             30,000
   Monitoring equipment
   in place	                  9,000
   Engineering design
   and inspection	                342,000              6,400
   Incidentals,  overhead,
   fees,  contingencies...                342,000              6,400
   Land.,-	                  18,000

   TOTAL  INVESTMENT COST             $2,412,000            $44,800

B.  OPERATION AND
   MAINTENANCE COST

   Labor  and supervision.               $112,000            $14,000
   Energy	                  28,000                600
   Chemicals	                635,000             26,400
   Maintenance	                239,400              4,480
   Taxes  and  insurance...                  72,360              1,344
   Residual vaste
   disposal	                  60,000
   Monitoring,  analysis
   and reporting	                  15,000              7,500
   TOTAL OPERATION AND
   MAINTENANCE COST

C. MCRTIZATION OF
   INVESTMENT COST

   TOTAL ANNUAL COST
$1,161,760


  $389,503
$1,551,263
$54,324


 $7,288

$61,612
    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.
                                     412

-------
production  is shown graphically in Figure  16-12.  Treatment cost
per metric  ton of  product  is given in Figure 16-13.

     Table  16-16 shows   a  summary of the unit  cost  distribution
between  amortization   and   the  operation  and  maintenance cost
components  at various production rates and levels of treatment.
Summary

     Cost estimates   for
amortization, chemicals,
the total annual costs.
first level of  treatment  indicate that
and labor have a   significant impact on
     At the second  level  of  treatment,  additional labor and  and
monitoring costs have significant  impact on the annual costs.
                               4-13

-------

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               PRCDUCTICN, METRIC TCNSAEAR X 1000
Figure 16-12.  Annual treatment cost vs. production for the
              Chrome Pigments Subcategory
                    414

-------
240-
220 •
200,
180-
160 .
140
120
                       \
100
                                                                       LEVEL #2
 80
                                                                       EEVEL"
                          6          9           12

                    PKXXJCTLW,  METFilC TONS/YEAR X 1000
15
18
           Figure 16-13.  Annual unit treatment cost vs.  production for the
                             Chrome Pigments Subcategory
                                        415

-------
                TABLE 16-16   MODEL PLANT TREATMENT COSTS
Subcategory  CHROME PIGMENTS
                              Type of Regulation  BAT
                                          Annual  Treatment Costs  ($/kkg)
                                                 LEVEL OF  TREATMENT

                 PRODUCTION  FLOW       FIRST     SECOND   THIRD    FOURTH
                  (kkg/yr)  (m3/day)      $          $         $          $
Annual Operation
and Maintenance
Annual
Amortization
Total Cost
 1,500
 4,000
 6,000
18,000
 1,500
 4,000
 6,000
18,000

 1,500
 4,000
 6,000
18,000
  454
1,219
1,820
5,460
  454
1,219
1,820
5,460

  454
1,219
1,820
5,460
167.96
100.73
 85.85
 64.54
 49.57
 32.62
 28.37
 21.64

217.53
133.36
114.22
 86.18
16.79
 7.43
 5.56
 3.02
 0.99
 0.63
 0.57
 0.40

17.78
 8.05
 6.12
 3.42
Not Applicable
                               416

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                          SECTION 17
                   HYDROGEN CYANIDE INDUSTRY
17.1 ASSESSMENT  OF  THE WATER POLLUTION POTENTIAL  OF THE ANDRUSSOW
PROCESS
17.1.1 Industry Profile and Analytical Results

    Over 50   percent of  the  Hydrogen   Cyanide   manufactured is
produced by the Andrussow process,  while about   40   percent is a
by-product  from  acrylonitrile manufacture.  A   major portion of
the production is used  in the manufacture of methyl  methacrylate
for lucite, plexiglas molding and  extrusion powders, and surface
coating resins.  It  is also  used as a fumigant  for  orchards  and
tree crops.

    The industrial  data profile  for this industry   is given  in
Table 17-1,  while the  existing  regulations  are given in Table
17-2.

    Priority pollutants  found  at  significant   levels  in  raw
wastes  during sampling  at  Andrussow  Process   plants  were  as
follows:
               Maximum Concentrations
  Pollutant            Screening*
(ug/1)
   Verification
(2  Plants)
Cyanide
Tnallium
*Includes


other


cyanide
166
25
process wastes
186
No sample


taken

    The thallium detected is  believed  to   be  not related to the
HCN process,  but rather  to  metal cyanide  processes at the  same
plant.

    A summary of daily and  unit product raw waste loads for all
Plants sampled can be found in Table  17-3.    Individual plant raw
waste loads  per unit  product  found  in  sampling   can be found in
Table 17-4.

    Based on the total annual production of this subcategory and
the average  waste load generated per  unit   product, the estimated
total priority pollutant raw  waste loads generated each year for
    subcategory are as follows:
                              417

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TABLE  17-1
SUBCAIEGORir PROFILE DATA SUMMARY
SUBCATEGORY
HYDROGEN CYANIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this  subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           289,000 kkg/year
                           165,500 kkg/year
                                11
                                 3
                           218,000 kkg/year
                           136,000 kkg/year
                                75 percent
                                82 percent

                             8,500 kkg/year
                            64,600 kkg/year
                            57,800 kkg/year
                            57,800 kkg/year
                                65 percent

                                 3 years
                                 9 years

                             1,150 cubic meters/day
                             7,310 cubic meters/day

                                 6 cubic meters/kkg
                                50 cubic meters/kkg
Sources of data are Stanford Research Institute,  Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental  Analysis, Inc.;  Draft
Report, "Preliminary Economic Assessment of Effluent Limitations  in the
Inorganic Chemical Industry."
                                    418

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17-2 -
                EXISTING IMPUTATIONS  -  EFFLUENT LIMITATICN GUIDELINES

SUBCMTEGOKT Hydrogen Cyanide
SUBPAKT AP (40CFR 415.420, 5/22/75)
STANDARDS
Product Para-
Process meters
Andrussow ^s
Process
CN
CN(A)

BOD5

NH3 N
BPCTCA* BATEA NSPS
1 2
Max. Avg. Max. Avg. Max. Avg.
kg/kkg k/kkg k/kkg k/kkg k/kkg k/kkg
(mg/1) (mg/1) (mg/1) (mg/1) (mg/1) (mg/1)
2.4
(48.0)**
0.05
(1.0)
0.005
(0.1)
3.6
(72.0)
0.36
(7.2)
1.2
(24.0)
0.025
(0.5)
0.0025
(0.05)
1.8
(36.0)
0.18
(3.6)
 Sections 415.420, 415.421, and 415.422 were revoked by  the Agency
 |41 FR 10681, February 23, 1977) .
 wax. = Maximum of  any one day,
 Avg. = Average of  daily values for thirty consecutive days shall not exceed.
**
  flow basis  50,000  1/kkg.
                                    419

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            TAliL^E 17-3.    SUMMARY OF  RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING
to
o
"
SUBCATEGORY
Pollutant
Priority
Total
Cyanide, CNT
Free
Cyanide, CN
Conventional
TSS
NH3-N
BCDC
HYDROGEN CYANIDE
Loadings
kg/day
Minimum Average Maximum Minimum

173 205 237 0.81
106 113 120 0.49
152 383 614 1.02
3881 5793 7705 26.2
24.5 4323 8621 0.16

kg/kkg No. of Plants
Average Maximum Averaged

1.20 1.60 2
0.65 0.81 2
1.94 2.87
31.1 36.0
20.2 40.3

-------
SUBCATEGORY
     17-4.    PRIORITY POLLUTANT RAW WASTE LOADS Cin kg/kkg of Product)
      HYDROGEN CYANIDE
POLLUTANT
         PLANT
#765              # 782
                                                                #765
Total Cyanide, CNT

Free Cyanide, CNA

Thallium, Tl
  5.9

  NA

  0.0014
0.808

0.49
1.6

0.807
  NA = Not Available
                                    421

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          Pollutant
       Waste Load  (kg/year)
          Cyanide  (Total)
          Cyanide  (Free)
            200000
            110000
17.1.2 Process Waste Sources and  Waste  Water Treatment Data
General Process Description

     The hydrogen cyanide  subcategory  in this study is  confined
to  the Andrussow process,  in  which  air,  ammonia and methane  are
reacted to produce hydrogen  cyanide.

     The raw  materials  are  reacted  at  elevated  temperatures
(900-1000 Degrees C) over   a platinum catalyst.   The reaction is
given as:
     2CH4 + 2NH3 + 302 =  2HCN  +  6H20
                     (1)
     The source of  methane   is   natural gas containing 50  to 100
volume  percent methane.    In  addition to hydrogen  cyanide, the
reacted gases contain ammonia, nitrogen, carbon monoxide,   carbon
dioxide, hydrogen and small  amounts of oxygen, as well as   traces
of organic nitriles formed  from  nonmethane components of  natural
gas.  The reactor  gases  are cooled  and  then scrubbed in  one of
two processes which are used to  remove the unreacted ammonia.  In
one patented process the  gases are  scrubbed with phosphate  liquor
and  the  resulting  solution  is decomposed  and  the  phosphate
solution is recirculated.   The recovered  ammonia is recycled  to
the reactor.   In the  second  process  sulfuric acid  is  used to
absorb  ammonia  from  the   reactor  gases.   At  one  plant  the
resulting ammonium  sulfate   solution is used for the manufacture
of another product.
     The hydrogen
effluent gases  by
are  vented to the
hydrogen  cyanide,
produce HCN gas of
cyanide is  removed  from  the  ammonia   scrubber
absorbtion in cold water,  and  the  waste  gases
atmosphere.  The absorbed  solution containing
water, and other contaminants  is distilled  to
over 99 percent purity.
     The water produced  during  tiie  initial reaction (Equation 1)
of  the  formation  of   nydrogen  cyanide  is  purged  with  the
distillation bottom stream  and  is either recycled to the absorber
or  discharged  to  the   treatment  facility.   In  order  to  be
recycled,  the  absorber water  bottoms  have  to be  cooled  by
refrigeration prior to  reuse  in the HCN absorber  unit.  At plant
locations  where   cold   water   is  readily  available  in  large
quantity,  it  can  be   used   on  a  once-through  basis  with  a
                                422

-------
significant   savings  in  energy  costs.    Figure 17-1 presents a
general block diagram for the manufacture  of  hydrogen cyanide  by
the Andrussow process.
Water Use and  Waste Source Inventories

    Water usage - Water is  used   in noncontact   cooling  in the
absorber, pump seal quenches, flare  stack   flushes,   for washdown
and  cleanup of tank cars, and for  washing  equipment and cleaning
up leaks  and  spills.   Table 17-5  gives  the   detailed  water
consumption  at  one plant and also  the  total  consumption at  two
plants.   The  difference  in  water  usage at  these two plants  is
pronounced  due to  the use  of  refrigeration at   one plant, and
once-through cooling water at the other.

    Waste sources - The following  are the  sources of waste water
produced   from  the  manufacture   of  hydrogen  cyanide  by  the
Andrussow process.

    A.  Distillation bottoms:  The  waste water contains ammonia,
hydrogen cyanide and  small  amounts  of  organic   nitriles.  The
water  consists  of  the water  produced  by   the   reaction  plus
scrubber  water  used for the absorption  of  HCN.   The absorption
water  distillation bottoms  are  either  recycled to the ammonia
absorber or discharged to the treatment   facility.  Even  if  the
distillation bottom stream is recycled to the  absorber, a portion
of it is discharged to stop the build up  of impurities.

    B.  Scrubber streams:  If the  scrubber liquid is recycled,  a
portion of  it  has  to  be purged  to control  the  accumulation of
impurities.  The bleed  contains  the acid  used for  scrubbing and
minor amounts  of  organic  nitriles.  The  scrubber   solution can
also be used for the manufacture of  other  products  in whicn case
nothing is discharged from the scrubber  operation.

    C.  Other  waste  water:   This  includes leaks  and spills,
equipment  and  tank  car  washings,  noncontact   cooling   water
blowdown and rainfall runoff.  The  tank  cars  are  washed out  with
dilute acid or alkali  to remove any contaminants  present, which,
if allowed to remain in the tank car, can polymerize the hydrogen
cyanide  causing safety hazards due  to possible explosion  during
shipment.  The noncontact cooling water  may be contaminated  with
the product as a result of leaks.   The recirculated  cooling water
is monitored   for  cyanide and the  cooling   tower   blowdown  is
discharged  to  the waste water  treatment  facility.  During shut
down,  the  equipment  is  drained   to   avoid  freeze-up  and  the
resulting waste water is discharged  to the  treatment facility.
                              423

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                                            ACID
                                        COLD
                                       WATER
                                                                VINT
                                                                GASES
      METHANE
         AIR
      AMMONIA


	 £»
f
REACTOR



AMMONIA
ABSORBER


HCN ABSORPTION



DISTILLATION
1


                                                                                                I1CN PRODUCT
                                            T
                                       USED FOR THE
                                       MANUFACTURE OF
                                       OTHER PRODUCTS
                                       OR RECYCLED.
                                       WHEN RECYCLED,
                                       A BLEED IS SENT
                                       TO THE WASTE
                                       TREATMENT PLANT.
                                                     A PORTION OF THE
                                                     DISTILLATION BOTTOM
                                                     IS RECYCLED TO THE
                                                     ABSORBER. AFTER
                                                     COOLING THE REST IS SENT
                                                     TO THE TREATMENT
                                                     FACILITY.
Figure 17-1.
General process flow diagram for production of hydrogen cyanide  by
the Andrussow Process.

-------
     17-5.   WATER USAGE IN HYDROGEN CYANIDE  - ANDRUSSOW PROCESS
             SUBCATEGORY
plant                     Water Usage, m /kkg of  HCN
              Total Consumption              Non-contact Cooling
      '                29
 |782                   y>
 #765
                      58.3
 (1)                     3
   Detail water usage (m /kkg)  at Plant #782 is:

   Non-contact cooling                 =     18.9

   Direct process contact              =      7.45
   Indirect process contact            =      0.71
     (pumps, seals, leaks,
      spills, etc.)
   Maintenance, e.g. cleaning          =      0.313
     and work area washdown
   Non-contact ancillary uses          =      0.67
     (boilers, utilities, etc.)
   Exported steam                      =      1-44
                                    425

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Control and Treatment Practices

     Plant #765 was  visited  and   the waste water sampled  duriny
the screening phase of  the  program.   The combined  wastes consist
of distillation bottoms,  ammonia  recovery purge  liquor, tank  car
washings, leaks, spills and  equipment  clean out, purge from  the
noncontact  cooling  water   system and  stormwater  water runoff.
These  combined  wastes   are  commingled  with  the  other cyanide
production  waste  waters and sent to  the  alkaline chlorination
treatment facility.   This  consists  of a  trench, where the pH is
adjusted to  10 with  dilute   caustic,  followed  by  two  ponds.
Sodium hypochlorite is  added  at the pond inlets.  The effluents
from the ponds  are discharged to a   third  pond where sufficient
chlorine and caustic are  added  to   reach the required  effluent
quality;  namely, an  oxidizable  free cyanide residual of 0.1  ppm
and a  residual chlorine  of  about 15-20 ppm.  The  third pond is
operated on a  continuous flow mode and is  baffled  to  control
circulation.  Agitation   is  provided in the flow channel, and  the
outlet  is equipped with  a  control device  to stop the flow when
the effluent  cyanide   concentration exceeds  the  desired level.1
Figure 17-2 is a flow diagram of  the treatment process indicating
the sampling locations  used   during  the screening program.  Table
17-6 gives the flow and pollutant  data for  the sampled streams.
A comparison of the raw and   treated effluent  data  in the table
indicates  that  the  plant  achieves  a cyanide  reduction  of 99
pe rcent.

     Studies indicate that   the  presence  of  ammonia  tends  to
decrease the  effectiveness   of  cyanide destruction  by alkaline
chlorination  by competing  for the  chlorine.  Plants having good
ammonia  recovery  systems   are  able  to  mitigate  this type of
interference, and  improve   performance.   A major  concern with
alkaline   chlorination   of   hydrogen  cyanide   waste   is   the
possibility that chlorinated  organics might be produced.  At this
plant  extensive  sampling   and  analysis of the treated effluent
showed the  absence  of chlorinated  organics above the  detection
limit of 50 ppb.

     The second   hydrogen    cyanide   plant   sampled  in  the
verification phase was  Plant  #782.   The process waste water from
the hydrogen  cyanide plant   is  combined  with  other production
waste  waters and sent  to a  complex  biological treatment  system.
A  part of  the  commingled  waste water is  sent  to  an  ammonia
stripper from which the   aqueous  effluent  is mixed with the rest
of  the  waste water and  sent to  the  treatment  facility.  The
primary treatment facility  consists  of oil skimmers, grit removal
and pH adjustment.  The effluent  from the  primary treatment goes
through  an  API  separator   and  into  an  aerated  lagoon.   The
effluent  from the lagoon is  flocculated and sent to a clarifier.
The overflow from the clarifier is sent to a final settling basin
before discharge.  The  surface drainage from the hydrogen cyanide
and other process areas is  collected separately.  This is treated


                                426

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                                                                                     HYDROGEN CYMJIDE
                                                                                        WRSTE WATER
K)
                                                                                                            OTHER CYANIDE PRCtWCT
                                                                                                                      WATER
                                                                                                            DILUTE CAUSTIC
                                                   Waste streams  sampled
                                                                                      FINAL TREATED
                                                                                        EFFLUENT
                                                          Figure  17-2.   General waste water treatment process flow diagram at Plant £765
                                                                         showing the sampling points. (Hydrogen Cyanide Manufacture)

-------
TABLE 17-6.   FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
              STREAMS FOR PLANT #765 PRODUCING HYDROGEN CYANIDE
   Stream       Unit Flow         SS Load        NH3~N Load       CN Load
Description   m3/kkg of HCN    kg/kkg of HCN   kg/kkg of HCN   kg/kkg of HCN
Raw HCN waste
Influent to

57
57(1)

1.08
55.8(2)

27.2
11.07 (2'

0.82
0.388(2)

Treated
effluent from
the final pond
              57(2),(3)
1.9
                                       (2)
7.05
                     (2)
<0.000114
                      (2)
(1)
(2)
.(3)
The stream is a commingled waste water.  The flow given is the amount
contributed by the HCN process.

The pollutant load was calculated by apportioning the mass emitted between
the two waste streams on the basis of measured  flows.   This is clearly a
very approximate process and the results must be used with caution.

The addition or loss of water from rainfall,  addition of chemicals and
evaporation has not been estimated.
                                     428

-------
chemically  and   passed  through a  trickling  filter   from which  a
portion  of  the effluent is sent to   the  aerated  lagoon  and the
rest sent to  the clarifier influent.

    A general   flow  diagram  of the  treatment process including
the  streams  sampled is  shown in Figure  17-3.    Table 17-7 gives
the flow data and  concentrations of   the   important  pollutants.
Because  of the intermixing  of  the various product waste waters
unit pollution loads are uncertain and  are  not given.  The total
waste water generated  from HCN manufacture  and the amount  going
to the treatment facility was verified  during  the  plant visit and
was  confirmed  in the 308 Questionnaire response provided  by the
industry.  Based on  that flow and  the concentrations determined
by analysis,  the raw waste load is:


                 Flow      CN(T)            NH3-N,          TSS,
               m3/kkg   kg/kkg of HCN   kg/kkg  of HCN  kg/kkg of  HCN
Effluent from
Combined Plant   9-9            0.02           0.05         0.74
Waste Treatment
    The load values assigned to the HCN   process  were estimated
by proportioning the  total loads   in  relation  to the  respective
flow rates.   The result  is, therefore,   approximate and  must be
used with caution.  In calculating  the  pollutant  loads, the  loss
or gain of water to the treatment   system due  to  factors such  as
evaporation, loss  through filtered solids,  precipitation and the
water introduced by treatment chemicals,  has been neglected.

    The final  concentrations of   cyanide  and  ammonia  in   the
treated effluent  shown in Table 17-7  indicate  that the treatment
system is  efficient  in  the  removal  of  these pollutants  with
cyanide destruction exceeding 99 percent.

    The quantity of  waste water   produced  and  treated  at   two
plants producing  hydrogen cyanide  by  the  Andrussow process  is
given  in  Table 17-8.  The large variation  in  flow is due to the
fact that at Plant  #765  the water used   to absorb  the hydrogen
cyanide  from the reactor gases is  not recycled.   As  discussed
earlier,  that plant is  situated in a  location  where sufficient
cold  water is available for once-through use.    Since  the  cold
water  is readily available at  a low   cost, the   water  used for
absorption is discharged.  It is reported that   a  similar  plant
Practicing recycling, in the absence of available cold water, can
achieve a total waste effluent of 7.1  m3/kkg of HCN.
                               429

-------
DISTILLATION
BOTTCM TORGE
                                                 OTHER PRCOOCT
                                                  WRS1E WATER
                                                                               DRAIN
   e
                                                          L/1HKU PRODUCT
                                                           WASTE WATER
Sanpling points
                                       DISCHARGE
           Figure 17-3.   General  waste water treatment process flow diagram at Plant #782
                        showing the sairpling points.  (Hydrogen Cyanide Manufacture)
                                                     430

-------
   17-7.   FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
          STREAMS FOR PLANT#.782 PRODUCING HYDROGEN CYANIDE.
. 	
	 -
Stream
NO.
1

2

3

4

Waste
Stream
Description
Distillation
bottom purge
Artmonia stripper
influent
Ammonia stripper
effluent
Influent to

Flow
m /day
11.34

1143

1143

5564

CNT
rag/1
70

167

51.3

31

NH3-N
mg/1
887

410

41

1381

TSS
mg/1
24

76

162

110
     primary treatment
     facility

5    Final treated         NA             2.2           5.16        74.3
     effluent
= Not Available.
                                 431

-------
TABLE 17-8.    WASTE FLOW DATA FOR HCN PRODUCTION BY THE ANDRUSSOW
               PROCESS
Plant               Total waste going to the treatment facility  (m /kkg)

 #765                                    57
 #782                                     9-9*
  The breakdown and flow of the different waste streams comprising the total
  is given below:
             Source                       Unit Flow  m /kkg
  Recovery and purification                      6.3
  Pump seal quenches                             0.58
  Flare stack flushes                            0.09
  Sample hoods                                   0.02
  NH., stripper caustic                           0.24
  Steam condensate from NH  stripper             0.90
  Freeze protection                              0.06
  Washdowns and cleanup                          0.25
  Boiler blowdown and condensate                 1.48
                                    432

-------
Model Plant and BPT  Treatment System Specifications

    Production -  Eight  plants produce hydrogen   cyanide by  the
Andrussow  process  at a  total production rate  of  165,000    kkg/yr.
Production and waste water flow data are on  file  for  two  plants
which  produce a   total of 116,000  kkg/yr  or 70   percent  of the
total  United  States  production.   (This  is  approximately  80
percent of  the   United  States  production   by   the  Andrussow
process) .   For  waste   water  treatment  cost  estimates,   three
production levels   were selected for the model  plant.  These are
31,800, 50,900, and  63,600 kkg/yr.

    Waste water flow - Unit waste water flows for the two  plants
are 50 m3/kkg and  10 m3/kkg.  The difference  results  from the two
plants having different absorption water discharge practices (see
earlier discussion).    If  recycling  of  absorber   water  were
practiced  at the first  plant, the unit flow would   be  7  m3/kkg of
HCN.  For  model plants, treatment levels were based  on  this unit
flow rate   of  7 m3/kkg.   However, because  the conversion  to a
recycle system for this plant would be very energy  intensive, an
additional model may have  to  be developed for  treatment   costs
usiny the  larger flow rate.

    Pollutant loading   -  The three  major  pollutants   in  this
subcategory are   cyanide,   ammonia,  and  chlorine.    Screening
results  indicated a cyanide loading of 1.4  kg  per   kkg of  HCN.
This loading  is   in agreement with a previous document [Ref.   2]
and  is used for  the models.  Screening results also  indicated  an
ammonia loading  of 1.8  kg per kkg  of product following  ammonia
recovery.   Chlorine has been reported  at   levels  of   15 mg/1 and
higher    in   the   effluents   from   alkaline     chlorination.

    Treatment technology  - Alkaline  chlorination   was selected
and  used for   the  treatment of hydrogen cyanide  waste  water.  The
formation  of chlorinated organics by the usage of  this technology
has  not  been   confirmed.  Cyanide complexed by   metals  such as
copper, zinc and   cadmium would also be  effectively  destroyed by
alkaline chlorination.

    Chemicals used -  At  the  BPT level of  treatment,   alkaline
chlorination  requires 10 kg of chlorine and 10 kg  of  lime per kkg
of dCN.

    Solids Generated - Little, if any, solids  are  produced  in
the  HCN treatment  process.
                               433

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17.2 TECHNOLOGY BASED POLLUTION ABATEMENT
17.2.1 Advanced Level Treatment Applications
Control of Significant Observed  Priority Pollutants

     The only priority  pollutant  found  during field sampling was
cyanide,  both oxidizable and  in  the  form of metallic  complexes
such as ferro- and ferricynides.   Ammonia, which is present as  a
nonconventional pollutant, will  exert  a  demand for chlorine  used
to oxidize  cyanide.  This   pollutant   should be removed by steam
str ipping.


Removal Technologies Available

     Cyanide is  decomposed  readily   by  oxidation  at  high  pH
levels, forming  cyanate  as   an intermediate  product.   Further
decomposition  into carbon dioxide and  nitrogen is possible with
complete  oxidation.  Alkaline chlorination is widely used in the
electroplating industry to break down  metallic cyanide complexes.
Although other  oxidation agents  such as hydrogen peroxide might
be used,  their operating costs  are  generally not favorable.  If
ammonia is present,  it increases  the  cost  of chlorination since
it, too, reacts.  If ammonia is  not to be controlled,   ozonation
may prove to be a more cost  effective  oxidant.

     Due to  excess chlorine-  usage, the discharge  from  cyanide
destruction is high in chlorine  and dechlorination will generally
be needed.  (In  contrast,   this is not  usually a problem in  the
electroplating  industry since there are longer retention periods
and  the  wastes   are  more   dilute.)    Dechlorination  can  be
accomplished by the use of an  aeration basin or  the addition  of
S02.    The   use   of  ozonation  would   negate  the  need  for
dechlorination.
Selection of Appropriate Technology
     BPT
ph
in
   adj ustment
   the industry.
(Level  1)  -  Two-stage alkaline chlorination followed  by
      was  chosen, in accordance with prevailing practice
     Level .2  -  Using  the  same  equipment as  in  Level 1,  excess
          is added to   insure  complete destruction of cyanide and
           chloramines.   The    second-stage  effluent   is then
chlorine
residual
dechlorinated.
                                434

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Floraras

   ei 1                      Figure 17-4

   el 2                      Figure 17-5

   pment Functions  -  In  Level  1,   the  raw waste  water  is
recin a holding   tank equipped  with an external  pump  and
rection system.   Caustic soda   and chlorine  are added  and
the contents  mixed  by  means   of  the  recirculation pump.
Fol this first  stage  alkaline  chlorination, the waste water
is r chlorinated  in a second tank  which  is  equipped with
aut pH control.   The   final  effluent is  neutralized to  pH
6-9e discharge.   In Level 2, using the same equipment as in
Lev the  chlorine   feed   to   the  second  stage  alkaline
chlion  system   is   increased.  To remove  excess  chlorine
befslease,  sulfur   dioxide   is  fed  by  a  modified   gas
chlor, with oxidation-reduction  potential control.  As  in
Levthe effluent   is  then  adjusted to  pH  6 to  9  before
dis.

   icals and  Handling -  Caustic  soda  solution,  chlorine,
sulaxide,* and sulfuric acid  are used in the waste treatment
pro Caustic  soda  and sulfuric acid  are common industrial
che  which   pose  no   special  hazards  when  handled  by
comal corrosion-resistant feeding equipment.  Chlorine and
suloxide are  received in one-ton  containers as compressed
gasand  are   fed  as  water  solutions  by vacuum-controlled
equ designed   for   the   specific  chemical.   No   unusual
chefeeding or handling  problems are  anticipated, provided
prens are taken  to  prevent gas leaks and  to  guard against
cor attack.

   ration and   Removal p_f  Solids -  Since  few  solids are
proin the treatment process, there is no significant sludge
disproblem.

   toring Requi rements  -  Internal  process  monitoring is
dorgely  with   automatic sensing  and control equipment for
re93 pH and chlorine/sulfur  dioxide residuals.  Field tests
foride  and/or   chlorine  in the  effluent  should  be made
reg by the operator,  and 24-hour composite effluent samples
sho collected and analyzed for cyanide as required in local
or permits.
17.stimated  Performance p_f BPT Systems

   najor  differences  in raw  waste  and  treated  effluent
quafound   at  plants  producing  tiydrogen  cyanide  by  the
And process  are  due  to the following:
                         435

-------
                             CAUSTIC SODA
             RAW
             WASTE WATER
U)
CTi
HOLDING AND 1ST
STAGE ALKALINE
  C HIX) RI NATION
                                                               -CHLORINE
                                                                   SECOND STAGE
                                                                ALKALINE CHLORINATIOH
                                                                                                            ADJUSTMENT
                                                                                                       % --- 1
                                                                                                           -L,
                                                                                                           H)
                                                                                                           T-
                                                                                                           L
                                                                                                                     EFFLUENT
                                  Includes flow monitoring,  pH monitoring and sampler.
                                 Figure 17-4.  Waste water treatment Level 1 for hydrogen cyanide subcategory.

-------
U)
                                           CHLORINE
                                CAUCTIC
                                 SODA
               RAW
              WASTE WA'TER
HOLDING AND 1ST STAGE
ALKALINE  CHLOR1NATION
                                                                         ADDITIONAL CHLORINE
                                                                                    SULFUR
t 1


DIOX
IDE f-
	 -n
'ORP
i
i
^r>ll A
"~1
If
                                                                                   ADJUSTMENT
   SECOND STAGE
ALKALINE CHLORINATION
                                                                                                                           AFFLUENT
                                  Includes flow monitoring,  pll monitoring and sampler.
                                  ORP  =  Oxidation Reduction Potential Control
                                   Figure 17-5.  Waste water treatment Level 2 for hydrogen cyanidQ subcategory.

-------
     Cooling water recycle  -   In   geographical locations where a
supply of cool water is available,  such  as at Plant #765, recycle
of the cyanide  recovery  absorption  waste water is not practical
because of  the intense energy   requirement for  refrigeration of
the stream prior to recycle.  This  once-through  contact water is
then treated and discharged.

     In locations  where a constant supply  of cool water  is not
available, as at Plant #782, absorption  water is refrigerated and
recycled.   Recycle  of this stream,  v/hich  is contaminated  from
contact with  hydrogen cyanide  and  ammonia, substantially reduces
the waste water volume requiring treatment.

     These two  different practices  in   handling  process waste
water account for the six-fold  variation in unit waste water flow
ooserved in this subcategory.

     Treatment Practices  - Alkaline   chlorination is  considered
the most effective  treatment   for  removal  of oxidizable or free
cyanide.  However, there  is concern   regarding the  formation of
chlorinated organic compounds when  organic material is  prevalent
in the raw waste water.

     At Plant #765, raw  wastes result  from the  manufacture  of
inorganic cyanide products.   Alkaline chlorination is  practiced
and  is effective in  removing  oxidizable cyanide, but is limited
to  some  extent  by  the  presence  of   ammonia.   Iron  cyanide
complexes, less toxic  than free  or  oxidizable cyanides, are not
reduced as effectively.

     At Plant  #782,   raw  wastes   include  wastes   from  the
manufacture of organic cyanide  products.   A biological treatment
system  is  in  place  to  reduce   organic  and  cyanide  wastes.
Although  effluent  pollutant concentrations are higher  at  this
plant, discharge  loads per  unit   of production are lower due to
the lower waste water flow.

     Table 17-9 and 17-10 present verification sampling data from
Plants #782 and #765.

     Pollutant Parameters  -    Analytical  procedures  for both
oxidizable  and  total  cyanide are   questionable  as  to their
accuracies  at  the  low  levels  of  concentration  necessary for
compliance  monitoring.  A new  method for analyzing oxidizable or
free  cyanide has  been recommended by  industry but has  not yet
been adopted.

     The use of BOD as a pollutant  parameter  has been questioned
at  plants  not  using  biological   treatment  because  the test
requires an acclimated ' seed culture   and  is highly sensitive to
cyanide and ammonia concentrations.
                                438

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    17.9.    VERIFICATION SAMPLING OF HYDROGEN CYANIDE PLANT #782
VERIFICATION:
Pollutant
Total Suspended
TSS
Cyanide (Total) ,
Cyanide (Free) ,
BOD
Ammonia, NH3
(Flow =6.25 m3/kkg)
Influent
mg/1 kg/kkg
Solids, no 2.87
CNT 31 0.808
CN 19.0 0.495
1549 40.34
1381 36.05

Effluent Quality
mg/1
74
2.2
1.73
376
5.04
Daily Monitoring Data - Treated Effluent
Parameter
Biochemical
Oxygen Demand,
BOD
Oxidizable
Cyanide CNft
Total Cyanide,
CN,
Armenia, NH-,
Total Suspended
Concentration (mg/1)
Min Avg Max
9.0 39.7 125
0.021 0.112 0.18
0.38 2.33 8.83
2.0 27.1 281
5.0 103 585
Waste Load (kg/kkg)
St.Dev. Min Avg Max
25.7 0.041 2.38 10.2
0.056 0.0014 0.0072 0.013
1.07 0.0025 0.14 1.0
27.4 0.023 1.7 24.1
84.1 0.0088 6.5 50.6
Solids, TSS
                                  439

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TABLE 17-10.   VERIFICATION SAMPLING OF  HYDROGEN CYANIDE PLANT #765
VERIFICATION

Pollutant
  (Flow = 57 mVkkg)

           Influent
         mg/1    kg/kkg
                 Effluent Quality
                       mg/1
Total Suspended Solids
TSS*
Cyanide (Total) , CN
Cyanide (Free) , CN
BOD
Ammonia, NH
71
28.4
6.81
6.3
194
6.52
2.61
0.626
0.580
17.8
19
<0.0026
<0.002
<33
124
  Average for 2 days only.


Monitoring Data - Treated Effluent

   Parameter
                1
  Concentration  (mg/1)
Min        Avg    Max
                           Waste Load (kg/kkg)
                St.Dev.    Min     Avg    Max
Total Cyanide,      0.78
0 . 01
           3.8    9.2
                2.56
0.039   0.192   0.46
Oxidizable
 Cyanide, CN
0.2    3.27      .319      0.0005  0.01   0.16
Ammonia Nitrogen,  3.86       72     204       46.2
 NH3-N

Chemical Oxygen    54.2       320     904      175.4
 Demand,COD

Total Organic      15.7       166     512      140
 Carbon, TOC

Total Suspended    5.0        35     267       55
 Solids,TSS
                                       0.193   3.63   10.2
                                       2.71   15.9    45.2
                                       0.78     8.3    25.6
                                       0.25    1.75   13.4
  Results of a 28-day comprehensive test.
                                     440

-------
    BPT technology   has  been specified as  alkaline chlorination
of hydrogen cyanide   waste waters.  Where biological treatment  is
applied to the  combined  process wastes, however, chlorination  is
not due to the possibility of chlorinated organics formation.


Base Level Performance  Characteristics for BPT Pollutant Removal

    Tiie treated     effluent   quality    achievable    through
implementation of  BPT  technology, presented  in  Tables 17-11 and
17-12,  is based primarily  on the quality  presently achieved   at
Plant #765 currently practicing this technology.  The  two  sets  of
limitations reflect  the  two  unit  flow rates that exist   in the
industry.

    Ammonia  limitations    are  based  on  a  presumed  influent
concentration of  40  mg/1 wich  can be achieved with  stripping.
Oxidizable cyanide limitations include a  variability  allowances
to account for the precision of the analytical methods as  well  as
plant variations.
Base Level
Removal
Performance  Characteristics   for   Priority  Pollutant
    No priority   pollutants, other than cyanide   attributable  to
hydrogen cyanide  production, were found to be of  significance.


Pretreatment  Applications

    BPT technology is applicable  for  pretreatment   of  hydrogen
cyanide wastes.   Plant #765 is presently discharging  to a POTW.

    Pollutants  such  as BOD,  TSS  and  pH are   compatible   with
municipal  treatment  systems,  and  cyanides  at  low levels are
easily biodegradable.    Many  states allow pretreatment to 2  mg/1
oxidizable cyanide and 10 mg/1 total cyanide.


Response to Remand Issues

    The following  major issues, comprising  industry's   comments
on   the  original  effluent   limitations,   were  reviewed   and
addressed :

    1.  The  accuracy  and  reliability of analytical  methods   for
measuring cyanide  from  hydrogen  cyanide  production.    At   the
present time,  a  more reliable  method for analysis recommended  by
industry is under  review.   The achievable discharge quality now
recommended as BPT reflects concentrations of cyanide that can be
reliably and  accurately analyzed.
                              441

-------
           TABLE 17-11  CONTROL PARAMETER  LIMITATIONS
                 SUBCATEGORY: Hydrogen  Cyanide
                      Level of Treatment:  1
                   Waste Water Flow:  50  m3/kkg
Subcategory
Pollutant Performance V
(2)
(mg/1)
Quality Limit
(1) (mg/1)
•T?D
30 day 24 hr
Av e r Max
Emission Limit
(kg/kkg)
30 day
Aver
24 hr
Max
BPT Pollutants:
Total Suspended 35
Solids, TSS
Ammonia, NH3 72
Biochemical Oxygen
Demand , BOD
Cyanide, CN 3.8
Oxidizable 0. 2
Cyanide, CN(A)
2.0

3.0

2.0
2.0
3.0

37.5

24

30
5.0
0.5

75

72

60
10
1.5

1.9

1.2

1.5
0.25
0.025

3.8

3.6

3.0
0.5
0.075

  (1) - VFR: ratio of the 24 hour variability  factor  to  the
            30 day variability factor.

  (2) - Average Values
                                442

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       TABLE  17-12   CONTROL PARAMETER LIMITATIONS
              SUBCATEGORY:  Hydrogen Cyanide
                   Level  of Treatment: 1
              Waste  Water  Flow: 8.9 m3/kkg


Pollutant



BPT Pollutants:
Total Suspended
Solids, TSS
Ammonia, NH3

Subcategory
Performance
(2)
(mg/1)


35

72
Quality Limit
(1) (mg/1)
VFR 	 _ _


30 day 24 hr
Av e r Ma x

2.0 37.5 75

3.0 24 72
Emission
Limit
(kg/kkg)



30 day
Aver

0.33 0

0. 21 0



24 hr
Max

.67

.43
Biochemical Oxygen
Demand , BOD
Cyanide, CN
Oxidizable
Cyanide, CN(A)
—
3.8

0.2
2.0 30 60
2.0 5.0 10

3.0 0.5 1.5
0.27 0
0.044 0

0.004 0
.54
.089

.009
(1) - VFR:  ratio of the 24 hour variability factor  to  the
         30  day variability factor.

(2) - Average Values
                             443

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     2.  Process  differences   in   the   production  of  hydrogen
cyanide, particularly the  different   processes used to  separate
ammonia  and   cyanide.   Although    the  two   major  production
facilities  use  different  processes  for  ammonia  and  cyanide
separation, raw waste loads of  ammonia  and cyanide resulting from
these processes do not differ significantly.

     3.  The  effect of geographic  location of  hydrogen  cyanide
plants as it relates to cooling  water practices.  The practice of
not recycling contact  absorption water  when  a  supply  of cool
water  is  available  has  been  discussed.   Recycling  at  such
locations  would  be   extremely energy  intensive.   Achievable
effluent quality  with BPT technology  has  been established with
consideration of the increased  volume of waste water when recycle
is not practical.

     4.  The  feasibility  and   cost-benefit   of  a  6  - 9  pH
requirement  for  plants  utilizing   alkaline  chlorination waste
treatment.    Costs   of   neutralization   following    alkaline
chlorination are included in the cost tables.

     5.  Contaminated   nonprocess  wastes  such   as  tank  car
washwater and maintenance  washdowns.   All wasta  water  sources
were  addressed  in  the discussion   of water use and waste water
sources.   These  sources  and   their flows  were  used  for  the
development of model plant unit  waste flows.

     6.  Deletion  from  this   subcategory  of  hydrogen  cyanide
produced as  a by-product of acrylonitrile production.  Only  the
Andrussow process for hydrogen  cyanide  production is addressed.


17.2.3  Estimated Performance erf Advanced Level Systems


Identification  of  Control and  Treatment Alternatives Applied to
the Model Plant

     Pollutants of major concern in this industry are cyanide and
ammonia.  The advanced  level   technology presented in  Section 7
allows  for  further  removal of ammonia  and  free  cyanide  by
break-point chlorination.  This  technology is not  applicable to
plants where the  potential  for the  formation  of  chlorinated
organics exists.
Advanced  Level  Performance    Estimates  for  BPT  and  Priority
Pollutant Removal
     ^      17-13 and  17-14  present  estimated achievable  effluent
quality through the  implementation  of this advanced technology-
                                444

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       TABLE  17-13   CONTROL PARAMETER LIMITATIONS
              SUBCATEGORY:  Hydrogen Cyanide
                   Level  of Treatment: 2
               Waste Water Flow:  50 m3/kkg
n/tllii-hant* TTfi^^^hll "i •h \7
rOl J. Uucin t. iLtrdL.ciiJj.j.iuy
(mg/l)
BPT Pollutants:
Total Suspended 25
Solids, TSS
Ammonia, NH3 5.0
Biochemical Oxygen
Demand, BOD 30
Cyanide, CN 5.0
Oxidizable
Cyanide, CN(A) 0.2
Total Residual
Chlorine, Cl 0.2
:======================================
Quality Limit Emission Limit
(1) (mg/l) (kg/kkg)
VFR —
30 day 24 hr 30 day 24 hr
Aver Max Aver Max

2.0 37.5 75 1.9 3.8

3.0 5.0 15 0.25 0.75

2.0 30 60 1.5 3.0
2.0 5.0 10 0.25 0.5

3.0 0.2 0.6 0.01 0. 03

2.0 0.2 0.4 0.01 0.02
(1) - VFR:  ratio  of the 24 hour variability factor to the
         30  day  variability factor.
                            445

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        TABLE  17-14   CONTROL PARAMETER LIMITATIONS
               SUBCATEGORY:  Hydrogen Cyanide
                    Level  of Treatment: 2
               Waste  Water  Flow:  8.9 m3/kkg
(1)
Pnllnt-^nt- Trp^h^hilit~v VF R
(mg/1)
BPT Pollutants:
Total Suspended 25 2.0
Solids, TSS
Ammonia, NH3 5.0 3.0
Biochemical Oxygen
Demand , BOD 30 2.0
Cyanide, CN 5.0 2.0
Oxidizable
Cyanide, CN (A) 0.2 3.0
Total Residual
Chlorine, C12 0.2 2.0
Quality Limit
(mg/1)
30 day 24 hr
Aver Max

37.5 75
5.0 15
30 60
5.0 10

0.2 0.6

0.2 0.4
Emission Limit
(kg/kkg)
30 day 24 hr
Aver Max

0.33 0.67
0.044 0.014
0.27 0.53
0.044 0.14

0.0018 0.005

0.0018 0.0036
(1)  -  VFR:  ratio  of the  24 hour variability factor to the
          30  day  variability factor.
                             446

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New
   Source  Performance Standards
    Examination  of  current control  and  treatment  practices  has
led to the  conclusion that NSPS for new hydrogen  cyanide  plants
should be equivalent to BPT treatment technology  with appropriate
recycle of  absorption water to minimize process waste volumes.
17.2.4 Cost  Estimates
Discussion

    The cost  estimates  for three models at  different production
and levels of  treatment are presented   in Tables  17-15,  17-16 and
17-17.  Annual  treatment costs as a   function  of  production  is
shown graphically in  Figure 17-6.  Treatment cost  per metric ton
of product is  shown in Figure 17-7.

    Table 17-18 gives  a summary of the unit  cost  distribution
between  amortization   and   operation  and    maintenance   cost
components at  various production and levels of  treatment.
Summary

    Cost estimates developed  for   the  first  level  of  treatment
indicate  that chemical cost has  the  most  significant impact on
the  total  annual  costs.   At the  second   level  of  treatment,
additional chemical cost is  the single  most important  factor in
the annual costs.
                               447

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                    TABLE 17-15. MODEL PLANT TREATMENT  COSTS

   Subcategory  HYDROGEN CYANIDE                     Type  of  Regulation  BAT

   Production        31,800 metric tons per year  (   35,059 tons per year)
                         90 metric tons per day   (      100 tons per day )
   Waste water flow     640 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	               $15,750            $5,100
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               150,700            41,500
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	                35,090              9,320
    Incidentals, overhead,
    fees, contingencies...                35,090              9,320
    Land	                 1,200

    TOTAL INVESTMENT COST               $246,830            $65,240

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $84,000
    Energy	                 2,750              1,900
    Chemicals	               199,000            116,000
    Maintenance	                24,563              6,524
    Taxes and insurance...                 7,404              1,957
    Residual waste
    d isposal	
    Monitoring, analysis
    and reporting	                15,000              7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $332,717           $133,881

C.  AMORTIZATION OF
    INVESTMENT COST                      $39,964            $10,614

    TOTAL ANNUAL COST                   $372,681           $144,495


    *First level represents the base cost of treatment  system.
    Other levels represent the  incremental cost above base cost.
                                      448

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               TABLE  17-16. MODEL PLANT TREATMENT COSTS
                                                 Type  of Regulation  BAT
  Subcategory  HYDROGEN CYANIDE

  Production        50,900  metric tons per year  (   56,117 tons per year)
                       145  metric tons per day  (      160 tons per day )
  Waste water flow    1020  cubic meters per day.


                                            LEVEL  OF TREATMENT*

                                          FIRST             SECOND
A.  INVESTMENT COST

   Construction	               $19,250             $5,500
   Equipment in  place,
   including piping,
   fittings, electrical
   work and controls	               224,750             46,500
   Monitoring equipment
   in place	                 9,000
   Engineering design
   and inspection	                 50,600             10,400
   Inc identals,  overhead,
   fees,  contingencies...                 50,600             10,400
   Land	                 1,200

   TOTAL INVESTMENT COST                $355,400            $72,800

B.  OPERATION AND
   MAINTENANCE COST

   Labor and supervision.               $84,000
   Energy	                 3,000              2,600
   Chemicals	               318,000            186,000
   Maintenance	                 35,420              7,280
   Taxes and  insurance...                 10,662              2,184
   Residual waste
   disposal	
   Monitoring, analysis
   and reporting	                 15,000              7,500

   TOTAL OPERATION AND
   MAINTENANCE COST                     $466,082           $205,564

C.  AMORTIZATION  OF
   INVESTMENT COST                      $57,628            $11,844
TOTAL ANNUAL COST
                                        $523,710
$217,408
*First  level  represents the base cost of  treatment system.
Other levels  represent the incremental  cost above base cost,
                                  449

-------
                    TABLE 17-17. MODEL PLANT TREATMENT COSTS

   Subcategory  HYDROGEN CYANIDE                     Type of Regulation  BAT

   Production        63,600 metric tons per year  (  70,119 tons par year)
                        181 metric tons per day   (     200 tons per day )
   Waste water flow    1280 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	               $24,250            $5,700
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               266,000            52,500
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	                59,850            11,640
    Incidentals, overhead,
    fees, contingencies...                59,850            11,640
    Land	                 1,200

    TOTAL INVESTMENT COST               $420,150           $81,480

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $84,000
    Energy	                 3,700             3,400
    Chemicals	               399,000           232,000
    Maintenance	                41,895             8,148
    Taxes and insurance...                12,604             2,444
    Residual waste
    disposal	
    Monitoring, analysis
    and reporting	                15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $556,199          $253,492

C.  AMORTIZATION OF
    INVESTMENT COST                      $68,163           $13,256

    TOTAL ANNUAL COST                   $624,362          $266,748


    *First level represents the base cost of treatment  system.
    Other levels represent the incremental cost above base cost.


                                     450

-------
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             30       40        50    ""    60       70       80


             HCN PRODUCTION,  METRIC TONS/YEAR X 1000



Figure 17-6.  Annual treatment cost as  a function of production for the

                     Hydrogen Cyanide Subcategory
                             451

-------
   16
   15
   14
   13
   12
   11
   10
•w-
§
                                              TT
         I  I  I
                i  i  Ki
                  i  i
                                                                I i
             30       40        50       60         70       80
                 HCN PRODUCTION,  METRIC TONS/YEAR X 1000

     Figure 17-7. Annual  unit treatment cost as a function of
        production for the Hydrogen Cyanide Subcategory
                              452

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                TABLE 17-18   MODEL PLANT TREATMENT COSTS
Subcategory  HYDROGEN CYANIDE
                              Type of  Regulation  BAT
                                           Annual Treatment Costs ($/kkg)
                                                 LEVEL OF TREATMENT

                 PRODUCTION   FLOW      FIRST     SECOND    THIRD    FOURTH
                  (kkg/yr)  (m3/day)      $         $         $         $
Annual Operation
and Maintenance
Annual
Amortization
Total Cost
31,800
50,900
63,600
  640
1,020
1,280
31,800
50,900
63,600
31,800
50,900
63,600
640
1,020
1,280
640
1,020
1,280
10.46
 9.16
 8.75
                    1.26
                    1.13
                    1.07

                   11.72
                   10.29
                    9.82
4.21
4.04
3.99
                     0.33
                     0.23
                     0.21

                     4.54
                     4.27
                     4.19
Not Applicable
                               453

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                          SECTION 18
                  SODIUM DICHROMATE  INDUSTRY
18.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL
18.1.1 Industry Profile a_nd Analytical  Results

    Most of  the  sodium  dichromate   produced   is   used   in the
chromic  acid and  pigment  industries.    It  is   used for  leather
tanning, and raetal treatment as well as a  corrosion  inhibitor.
    The industry profile data  for  this
Table 18-1, and  the summary of existing
Table 18-2.
              subcategory
              regulations
               is given
              is given
in
in
    Priority pollutants found  in significant
waste during sampling were as follows:
                     levels  in  the  raw
                Maximum Concentration
         Pollutant
Sc reening
Observed (ug/1)
       Verification
        (2 Plants)
Chromium
Nickel
Zinc
Copper
Silver
Selenium
252,
12,




070
500
544
35
<.05
<5
312,
1,
1,



000
260
230
240
228*
22*
          * Found at one plant only
         ** Non contact cooling water  at  one  plant  only

    A summary of daily and unit product   raw  waste  loads for all
plants sampled can  be found in Table 18-3.   Individual  plant raw
waste loads per unit product  found  in sampling  can be  found  in
Table 18-4.

    Based on the total annual production  of  this subcategory and
the average waste  load generated per unit product,  the  estimated
total pollutant  raw  waste  loads generated   each  year for this
subcategory are as follows:

                              454

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TABLE 18-1
SUBCAIEGORY PROFILE DATA SUMMARY
SUBGATEGORY
SODIUM DICHROMATE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           140,000 kkg/year
                           136,500 kkg/year
                                 5
                                 3

                           112,000 kkg/year

                                82 percent

                            20,700 kkg/year
                            66,800 kkg/year
                            37,300 kkg/year
                            24,800 kkg/year
                                77 percent

                                 7 years
                                28 years

                              455 cubic meters/day
                              720 cubic meters/day

                                 4 cubic meters/kkg
                                 8 cubic meters/kkg
Sources of data are Stanford Research Institute,  Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce,  Current Industrial
Reports, December 1977; Energy and Environmental  Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   455

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WmR 18-2 - EXISTING REGULATIONS - EFFLUENT LIMITATION GUIDELINES

SOBCMEGORY Sodium Dichromate
SUBPAKT Q (40CFR 415.170, 3/12/74)
	 	 STANDARDS
BPCTCA BATEA* NSPS
1 2
Max. Avg. Max. Avg. Max. Avg.
Product Para- kg/kkg k/kkg k/kkg k/kkg k/kkg k/kkg
Process meters (mg/1) (mg/1) (mg/1) (mg/1) (mg/1) (mg/1)
Na,Cr_0_ TSS 0.44 0.22 ^ J^fS?*96
221 or pwwp
Cr+6 0.009 0.0005 N° dischar9e
of pwwp
Cr(T) 0.0088 0.0044 N? dlschar9e
or pwwp
0.30 0.15
0.009 0.0005
0.0088 0.0044
* Section 415.173 was remanded and is presently reserved  (41 FR 51601,
 November 23, 1976) .

 "wax, = Maximum of any one day.
 Avg. = Average of daily values  for thirty consecutive days shall not exceed.

 pwwp = Process wastewater pollutants.
                                  456

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TABLE 18-3.
SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION SAMPLING

SUHCATEGOHY
1 vj| lutanl.
Priority
Chromium, Cr
Copper, Cu
Nickel, Ni
Silver, Ag
Zinc, Zn
Selenium, Se
Arsenic, As
Conventional
TSS
Hex. Chro-
SODIUM DICHROMATE
Loadings
kg/day
Minimum Average Maximum Minimum

82.1 132 181 0.95
0.0091 0.32 0.92 0.00005
0.27 4.26 8.98 0.006
0.058
0.067 0.22 3.91 0.0009
0.23
0.005
26603 131066 235646 140
27.5 1212 3105 0.466

kg/kkg
Average

1.17
0.0046
0.034
0.0009
0.002
0.003
0.00008
2068
15.7

No. of Plants
Maximum Averaged

1.39 2
0.013 3
0.049 3
1
0.003 3
1
1
3997
43.9
mium, Cr
        +6

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     18-4.    PRIORITY POLLUTANT RAW WASTE LOADS (in kg/kkg of Product)
            SODIUM DICHRCMATE
SUBCATEGORY
.	
POLLUTANT
Chromium, Cr
Copper, Cu
Lead, Pb
Nickel, Ni
Zinc, Zn
Silver, Ag
Selenium, Se
Arsenic, As
                     #493
0.95
0.00005


0.047
0.002
                 PLANT
                  #398
0.013
0.00014
0.049
0.0009


0.003
                     #376
1.39
0.0008
0.0002
0.006
0.003
0.00099

0.0008
                                     458

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          Pollutant
Waste Load  (kg/year)
          Chromium
          LMickel
          Zinc
          Copper
          TSS
          Cr + 6
     160000
       4600
        270
        630
280,000,000
  2,100,000
18.1.2 Process Waste Sources  and  Waste Wat, er Treatment Data
General Process Description

     The starting  materials
dichromate  are chromite ore,
above materials  are reacted,
reacted  with sulfuric  acid
reactions are given as:
    for  the   preparation  of  sodium
    limestone and  soda ash.   When the
    sodium chromate  is formed which  is
   to  produce  sodium dichromate.  The
4FeCr204
           8Na2C03
          702 =  8Na2Cr04
                  2Fe203
                                                      8C02
(i;
2>Ma2Cr04
H2S04 = Na2Cr207
         H20
                                          Na2S04
     Chromite ore  is  a  chromium   iron oxide  containing  ferrous
chromite  (FeCr204  or FeOCr203). Small amounts of aluminum,  silica
and magnesia are present.   For  the preparation of sodium chromate
and finally, sodium dichromate, high grade chromite ores are used
containing  approximately   50   percent  Cr203.   These  ores  are
imported  from South Africa.

     At the plant  site,  the  ore  is ground to a fine powder, mixed
with soda ash  and calcined   in   rotary  kilns at  1100  to  1150
degrees C.   The   reacted  product is  leached with hot water in a
leachate  tank.   The  thickener   underflow  is  filtered  and the
filtrate  recycled  to  the  leachate tank or thickener.  The  solid
filter cake  is dried   in  rotary  kilns.  The aluminum present  in
the  thickener  overflow  is  hydrolyzed  and  removed  from  the
chromate  solution as precipitated  aluminum  hydrate  in  slurry
form. The solution is centrifuged and the centrate is evaporated,
to  give  a concentrated  solution  of sodium chromate,  which is
reacted with sulfuric acid   to  give sodium dichromate and  sodium
sulfate.  Sodium sulfate crystallizes as anhydrous sodiun sulfate
from  the boiling  solution,   and  the crystals  are  removed  by
filtration.   The  filtrate  is  concentrated  in  multiple  effect
evaporators.  The  residual  sodium sulfates separate out as  solids
from each of the evaporators while the hot concentrated  solution
of sodium dichromate  from  the  last effect  of the evaporator  i3
                               459

-------
fed   to   a   water-cooled   crystal!izer.     Sodium   dichromate
crystallizes  out  and  is  centrifuged.   The   centrate, or  mother
liquor,  is   returned to the evaporator.    The  sodium  dichromate
crystals separated  in  the centrifuge  are  dried in a rotary  drum
dryer  and  then packaged  for sale or  stored  for use. Figure 18-1
presents a  generalized flow diagram  for  the   production of sodium
dichr ornate.
Water Use and  Waste Source Inventories

    Water Use  -  Water  is  used   for   noncontact  cooling,  in
leaching,  for  scrubbing  vent gases  and  for process  steam for
heating.   Water use information provided  in 308 Questionnaires is
given in  Table  18-5.    It is possible that the figures given  in
the 308 Questionnaires  may  be the  amount going  to  each  unit
operation  and  not  the  amount  added   as  makeup  water.   The
quantities  seem  unusually  high   for  an   industry   practicing
extensive recycling of water, as this one does.

    Waste Sources -

    A. Spent  ore:  Tiie unreacted ore is  removed from the process
as a sludge.   The  solids contain  chromium and other  impurities
originally present in the ore.  The  waste is  disposed as a solid
waste in  a  landfill or  is slurried  with  water  and sent to the
treatment facility.

    B.  Noncontact cooling water and cooling tower blowdown: The
noncontact  cooling  water is either used on a once-through basis
and  discharged or is recycled and  the blowdown discharged to the
treatment  facility-   In  addition  to   dissolved  sulfate   and
chloride, it may contain chromates.

    C.  Boiler  blowdown:   The  steam   used  for  heating  is
recovered  as  condensate, while the  boiler  blowdown is discharged
to the  treatment  facility.   It   may   become contaminated with
chromium  escaping from the process  area   and hence snould be sent
to the waste water treatment facility for treatment.

    The  majority   of  aqueous   streams   resulting  from  the
manufacture of sodium dichromate are  recycled.  Streams recycled
include compensates from product evaporation and  drying; product
recovery   filtrates;  air" pollution control  scrubber  effluents
from product drying, leaching  and   roasting  kilns;  filter wash
waters; and equipment  and process  area washdowns.  At two plants
the  v/aste  water, consisting  of   boiler  and noncontact cooling
tower, is used to slurry the spent  ore residue to the waste >vater
treatment facility. At  one plant,  the only waste water resulting
from process operations is the noncontact cooling water, which is
used on a once-through basis.

                             460

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                                                                                                                                                  TO SALES OR USE
                     SODA ASH
RECYCLE •
 WATER
 FROM
PROCESS
                                                                        COOLING TOWER AND —
                                                                                   BOILER
                                                                                 SLOWDOWN    TO WASTE
                                                                                                                           TO SALES
                                                                                                                                                       TO SALES
                                             Figure 18-1.  General process diagram for productions of sodium dichromate.

-------
18-5.
Source
              WATER USAGE IN SODIUM BICHROMATE SUBCATEGORY
                   Water usage  at plants   m /kkg of
Non-contact cooling

Direct process contact

Indirect process contact
(pumps, seals, leaks and
 spills)

Maintenance, e.g.
cleaning and work area
washdown

Air pollution control

Non-contact ancillary
uses
                   Plant #398

                       255

                         5.7

                         0.9



                         0.5



                         2.5

                         0.5
Plant #376

    11.39

      NA

      NA



      NA



      NA

      NA
Plant #493

     5.7

     2.85

     0.2



     0.2



     1.0

     3.12
NA = Not Available
                                   462

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Control and Treatment  Practices

     Three sodium dichrornate  plants  were visited  and  the waste
water streams sampled.    Plant  #493 was sampled in the  screening
phase and Plants  £376  and  #398 were sampled in the  verification
phase.

     At Plant  #493,   the   waste  water  going to  the  treatment
facility includes the   boiler and   cooling tower  blowdown  and a
small volume  of  effluent  from a  scrubber on a by-product sodium
sulfate  operation.    The   total  waste  includes the  spent ore
residue, wtiich is  also   sent  to  the treatment facility.   At the
treatment  facility, the  alkaline waste waters  are reacted with
imported acidic industrial  waste at an elevated temperature in  a
reactor.  The chromium  is precipitated during the reaction.  The
reacted waste is  sent  to clarifiers via  holding  tanks.   In the
clarifiers,  large quantities  of   water  are  used to  wash the
precipitated solids  in   a  counter-current  fashion.  The  final
clarifier  overflow, which  is  the treated effluent, is  filtered
and discharged and the  clarifier underflow is disposed  of  in  a
quarry.  Figure 18-2 is a block diagram of the treatment  process
and indicates which streams were  sampled.  Table 18-6  gives the
flow data and pollutant emissions  of the streams sampled.

     At Plant  #376,   sodium  sulfide  is used  for  simultaneous
chromate reduction  and precipitation.   The waste waters  at this
plant are  segregated  into  two  streams.  One stream  consists  of
the  cooling tower and  boiler  blowdown and is used for slurrying
the  spent  ore residue   to  the treatment facility.  The   second
waste stream consists  of  storrnwater runoff from  both the solids
disposal areas and the  production   areas.  The first waste  water
stream is mixed with sodium sulfide during transporation and sent
to  a diked containment   and  settling  pond  system.  The  sulfide
reduces the hexavalent  chromium to trivalent chromium, which  in
turn  is  precipitated  as  chromium  hydroxide.   The solids are
settled in the pond, and  the  overflow  from  the ponds  is  mixed
with the second waste  stream  and reacted with sufficient alkaline
sodium  sulfide to reduce   the  chromate and precipitate  chromium
hydroxide.  The reacted solution is sent to a settling pond where
the precipitated  and  other  suspended solids are settled  and the
overflow  discharged.   A  simplified  flow  diagram of  the waste
water  treatment process  is  given  in  Figure  18-3.  Table 18-7
gives the  flow  data   and  pollutant emissions  for  the  streams
sampled.

     At Plant #398, the only  effluent produced is  the noncontact
cooling water.  The noncontact  cooling  water  is used on  a once-
through basis and  is  discharged  without  treatment  through two
out-falls.  The solid  waste residuals  from the  leaching  process
are trucked to  a state-licensed  hazardous waste  landfill area.
The amount  of  solid  waste  residue disposed of is approximately
290  kg/kkg of product.   Table 18-8 gives the unit flow data and

                              463

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                                                                                     RAW WASTE WATER
                                                                                                              IMPORTED ACID
                                                                                                              INDUSTRIAL WASTE
CT>
                                                                   WATER
                                        e
Waste streams sampled.
                                                                                                                            TREATED EFFLUENT
                                                                                      SLUDGE TO
                                                                                    LAND DISPOSAL
                                           Figure 18-2.
            General  waste water treatment process flow diagram at Plant  1493 showing  the
                     sampling points.  (Sodium Dichromate Manufacture)

-------
TABLE 18-6.   FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
              STREAMS FOR PLANT #493 PRODUCING SODIUM DICHRCMATE
Stream No.  Waste Stream   Unit Flow     TSS Load
            Description                   kg/kkg
of Na2Cr207  of
                            Cr   Load    Chromium
                              kg/kkg
                                                                     road
                                                     of
                                                                  of
1


2
Raw  Waste
  Water
                 4.95
Treated Efflu-  28.91
  ent

Residue Slurry   2.13
                                         183


                                           0.013


                                         185
                             3.5


                             0.00004


                             0.0004
                                                                     1.25


                                                                     0.022


                                                                     3.93
                                   465

-------
                                             WkSTE
                                              MUD
                                             SLURRY
             e-
Ch
                                  e
                                                                         SODIUM SULFIDE
 SETTLING AND
  DEWATERIN3
IANDFILL AREAS
Waste streams sanpled.
                                                                                 TREATED EFFLUENT
                                               Figure  18-3.   General waste water treatment process flow diagram at Plant 1376
                                                      showing the sampling points. (Sodium Dichromate Manufacture)

-------
TABLE  18-7.   FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
              STREAMS FOR PLANT #376 PRODUCING SODIUM DICHRCMATE
Stream No.  Waste Stream   Unit Flow     TSS Load     Cr   Load   Chromium

                            m /kkg        kg/kkg        kg/kkg      Load
                          of Na2Cr207  of Na2Cr207    of Na2Cr207    kg/kkg
                                                                  of Na2Cr20?


    1       Mud Slurry       7.68       3988            0.407         1.041
              Waste

    2       Primary Pond     7.68           0.591         -           0.808
              Effluent

    3       Surface Runoff   4.16           0.621       0.057         0.55

    4       Effluent         4.16           7.942         -           0.77
                                   467

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     18-8.  FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLE WASTE
            STREAMS FOR PLANT #398 PRODUCING SODIUM DICHROMATE
Stream No.  Waste Stream   Unit Flow     TSS Lead      Cr   Load   Chromium
          Description     ^        kg/kkg        kg/kkg
                         0fNa2Cr207  of Na^O,   of Na^O,
    1     Non-contact        71           -             6.72       0.013
          cooling water

    2     Non-contact       206           -            14.28       0.018
          cooling water
                                  468

-------
pollutant emissions  for  the  process effluent.


Model Plant and BPT  Treatment  System Specifications


Model plant specifications were selected  for the purpose of cost
estimation.   The  rationale  for  the  selection of model  plant
characteristics is as  follows:

     Production -    Five   industrial   plants   produce  sodium
dichromate at a  total production rate of  approximately  140,000
kkg/year.  Production  and waste water flow data, from which model
plant  characteristics  are  derived, are on file for three plants
which produce a total  of 112,000 kkg/year;  that is approximately
80  percent  of the  United  States production.   For  waste water
treatment cost estimates, three production levels were  selected.
These are 20,000 kkg/year, 50,000 kkg/year and 70,000 kky/year.
     Waste Water  Flow   -  Unit   waste flows  for the  two  plants
treating  their waste   waters are approximately 5 and 12ra3/kkg of
product.  For the model  plant,   7rn3/kkg  of sodium dichromate was
used as the waste water  flow.
     Pollutant Load ing   -  For  the model plant, it is assumed  that
the  spent  ore resTcTues are   slurried  and  transported  to   the
treatment facility,  since this  is the  prevalent practice at two
plants.   The spent  ore waste-generated residue at Plant 1969 is
290 kg/kkg of Na2Cr207.  The   hexavalent chromium loading  in the
waste water varies  from  0.5  to 14  kg/kkg of Na2Cr207.   Pollutant
loadings  used  for  the  model  plants are  suspended solids (spent
ore  residue) at 290  kg/kkg   Na2Cr207  produced, and  hexavalent
chromium at 5 kg/kkg.

     Chemicals required  -  To reduce  Cr+6  to  Cr + 3,   a  sodium
bisulfide dosage of  158  mg/1  is  needed, but to allow for reaction
with other metals,  a model dosage  of 200 mg/1 was used.  This is
equivalent to 1.4 kg/kkg of   product in  a unit flow of  7m3/kkg.
To raise the pH to  9.5,  100  mg/1 of lime is needed, equivalent to
0.7 kg/kkg  of product.  For  final neutralization, HCl  is used in
the amount of 10% of the lime  dosage.

     Solids generated -  Total  dry solids produced are 0.36 kg/kkg
of sodium dichromate.
                               469

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18.2 TECHNOLOGY BASED POLLUTION ABATEMENT


18.2.1 Advanced Level Treatment Applications


Control of Significant Observed Priority Pollutants

    Priority pollutants  found   in   significant amounts  are the
primary  pollutant,   hexavalent   chromium,  and   the common  heavy
metals often present as  impurities  in  the chromium ore,  notably
zinc and  nickel.    In controlling these metals  by the  processes
chosen  for the  treatment models,   incidental   removal  of  other
trace heavy metals will also be achieved.


Removal Technologies Available

    Alkaline precipitation  or   reaction   with    sulfide    will
separate nickel and  zinc from solution.  Hexavalent chromium must
be reduced to its  trivalent form  before it  can be precipitated by
alkaline substances.   Although   ion  exchange   or  xanthates can
remove metals from clarified solutions they are  inappropriate for
treating raw waste slurries from  this industry.


Technologies to be Applied at Each Level

    BPT (Level !_)_ - The system   utilizes  sodium  bisulfide added
to the raw wastes  to reduce hexavalent chromium   to its  trivalent
form and to  partially precipitate some of  the metals as metallic
sulfides, along with inert ore solids  in  a  first-stage  lagoon.
The lagoon effluent   is then subjected to  alkaline  precipitation
of trivalent  chromium,  followed   by  solids   separation  in  a
clarifier and by ph  adjustment of the overflow before discharge.
    Level 2_ - Dual-media filtration  is  added  to  achieve a higher
level of suspended solids removal,  including  metallic  hydroxides
and  sulfides which  may have passed  through  the   clarifier.   The
effluent is  adjusted  to a pH  range  of  6  to  9  as in Level 1.
These  technologies  are uniquely appropriate   for  wastes of the
sodium   dichromate   industry   because   the   sodim   bisulfide
?retreatment performs the dual function  of  converting  hexavalent
chromium to a  potentially  settleable   form,  as  well as reacting
with other heavy metals to form insoluble  metallic sulfides.
                             470

-------
Flow diagrams

     Level 1                 Figure 18-4

     Level 2                 Figure 18-5


     Equipment Functions  -  The raw waste flows into an equalizing
lagoon wheretFeinfluent flows are measured by a magnetic flow
meter  which  controls  application of  sodium bisulfide  solution
into the  influent  pipeline.   Hexavalent chromium is converted  to
the  less  toxic  trivalent  form and  together  with trace metal
sulfides and inert   solids   passes to the first-stage lagoon.   A
second application   of  sodium bisulfide  is made  in  the lagoon
outflow, and lime is  added  to precipitate  trivalent chromium and
residual  trace metals  prior  to clarification.   In Level  1 the
clarifier effluent  is adjusted to pi-1 6 to 9 and released.  In tiie
Level 2 system a dual   media  filter is added to remove additional
suspended material   from  the  overflow.  Clarifier  underflow and
filter backwash  are  returned to the equalizing  lagoon influent,
to be settled in the  la-goon.

     Chemicals and   Hand1ing   -   Sodium  bisulfide,  lime, and
hydrochloricacid are used  in the  treatment  process.  The first
application  of  sodium  bisulfide  is  made  into  the  influent
pipeline  in  proportion  to   flow,  minimizing  the  release   of
hydrogen sulfide at times when  the  influent pH may be low. The
second  application  of  sodium bisulfide is also  into a closed
pipeline  to  ensure  adequate  mixing  with the  settled  lagoon
effluent. Lime slurry is  fed  through conventional equipment ahead
of the clarifier.   Hydrochloric acid is used (instead of sulfuric
acid) to  minimize  the  formation  of gypsum  scale  which  could
result from  heavy  use  of lime followed by sulfuric acid.   There
do not appear to be unusual hazards involved  in the  handling  of
chemicals for the proposed  treatment.

     Sepa rat ion a_n_d_  Pi sposal  ojf  So 1 ids  -   As  a  basis  for
estimating   model"  pi a nt   c~ost~s,   influent  suspended  solids,
metallic hydroxide  and  sulfide precipitates, and filter  backwash
are returned  to or left  in  the influent  lagoons(s) .   As  each
lagoon becomes filled with  solids it is replaced by another, on a
ten-year cycle.  Liquid is  decanted from each  filled lagoon and
the solid material  needs  to be  disposed  of in either an on-site
or an off-site chemical landfill.

     Monito ring Requi rements  - Internal process monitoring should
include routine  testing  to maintain reducing conditions and a  pH
above 7 in the influent lagoons,  and simple field  determination
of  pH,  to  assure  that   the   optimum  level  is   reached  for
precipitation of  chromic   hydroxide.   Routine  testing  of  the
effluent  should  also  be  performed  at the  site to  show  that
hexavalent  chromium  is  being consistently reduced to   trivalent

                              471

-------
SODIUM SODIUM P|LIME
BISULFIDE BISULFIDE U
r-Ql
i :
i
RAW |
WASTE i
* r~]
/^v MPH ADJUSTMENT
. Q t---^) v


i


MAGNETIC 1
METER |
1
1
_^\ LAGOON /—*~\


•



\ /
1 — *\ LAGOON / — «J
1 ¥"""!
/*^v
! ! ©
U L T
^ i ! ^Q i

MIX
TANK k. y
N/CLARIFIER
1
| 1
L-_. ... 	 — trv« 	 1
Includes flow monitoring, pH monitoring and sampler.
  Figure  18~4.  Waste water treatment Level 1 for sodium dichronate  subcategory.

-------
                                                               BACKWASH
r
1 f=\ LIME
SODIUM . SODIUM n
BISULFI
r£l
I
1 j

RAW I
WASTE J.^
DEI BISULFIDE^y
1 p L— .@
f | ,_A LAGOON /_^ Y 1 !
1
^
»U |
MAGNET1C i
METER '
1
|
1
1






L..-A LAGOON / ^1
1
L 9 I
r ' u" q
JL i

MIX

TANK V )
*





A \^S^


pv pH ADJUSTMENT
F~ ~\
JL.
fpK)
vjy
^ ! . „ .
n 	 ntr^ "u " ••"
*
SUMP FILTER EFFLUENT


X/CLAIUFIER
1

U)
                                                                                      _1
                                      Includes flow monitoring, pH monitoring and sampler.
                                      Figure 18-5.  Waste water treatment Level 2 for sodium dicliromate sutcategory.

-------
chromium  and  that total chromium  in  the  final  effluent does  not
exceed the allowable limit.  Periodic   composite effluent samples
should be  analyzed for total chromium  by   the atomic absorption
method, for official reporting purposes.


18.2.2 Estimated Performance o_f BPT Systems

    Extensive recycle and reuse   of  process contact waste water
limit effluent  generation at  sodium   dichromate plants.  At two
facilities, cooling water  blowdown   streams are  used to slurry
spent ore  residues and the resultant waste  stream is treated for
the  removal of  chromium prior to discharge.    At the  remaining
plant, ore  residues  are removed  as  a  solid waste and  only once
through noncontact cooling water is discharged.

    Table 18-9  summarizes  effluent   control  and    treatment
technologies at each plant and indicates  the characteristics  of
the  resulting  effluents.  It can be noted  that  the cooling  water
at plant 1398  is  contaminated with chromium.   Low concentrations
and  high discharge volume account  for the  high   chromium effluent
loads.

    Raw waste  priority  pollutants  found   in   excess of  cutoff
limits at these three facilities were presented in  Section 6.  By
use  of the compressed scale method for  selecting pollutants which
might  require  regulation,  chromium,  nickel   and   zinc   were
identified.   Table  18-10  presents  priority pollutant  effluent
loads found during sampling at two of the  three facilities.

    BPT technology has been specified  as  reduction of hexavalent
chromium,  and  hydroxide precipitation of   chromium   with  final
settling to remove suspended solids.


Base Level Performance Characteristics  for BPT  Pollutant Removal

    Pollutant reductions achievable  by   application  of BPT  or
Level 1 technology are presented in Table  18-11.


Base  Level  Performance Characteristics   for Priority  Pollutant
Removal

    Table 18-11  also   presents  effluent  quality   achievable
through the application  of  BPT   or  Level 1 technology  for  the
reduction of priority pollutants.


Pretreatment Applications

    No sodium dichromate  plant presently discharges waste to   a

                             474

-------
 TABLE  18-9.     EFFLUENT CONTROL AND TREATMENT PRACTICES AND ACHIEVEMENTS
                 AT SODIUM DICHROMATE PLANTS *
Plant
#398
Control and
Treatment Practice
Once through
cooling water,
disposal of ore
residue as solid,
no treatment of
cooling water
discharge
Effluent Waste Load kg/kkg
CrT Cr+6 TSS
pH Avg. Max. Avg. Max. Avg. Max.
0.0079, 0.034
6.6
to
8.5
#493   Recirculate cooling     0.00038  0.0049           0.00018  0.1     0.3
       water, slurry ore
       residue, treat all  6'.3
       wastes with.pickle   to
       liquor, counter-    8.3
       current solids wash,
       clarify and filter
       effluent

#376   Recirculate cooling     0.00058  0.0017           0.00058   0.047  0.69
       water, slurry or
       residue, treat all
       wastewater with
       sodium sulfide,
       remove solids in
       settling ponds
 * See Reference 3.
                                   475

-------
     18-10.   VERIFICATION SAMPLING OF SODIUM DICHPOMATE PLANTS
Pollutant
 Plant #398
Treated Effluent
     kg/kkg
       Plant #493
Raw Waste     Treated Effluent
  kg/kkg     mg/1      kg/kkg
•total Suspended
Solids, TSS
Chromium VI, Cr
Chromium, Cr
Nickel, Ni
Zinc, Zn
Copper, Cu
Flow (m3/kkg)
2.05

43.9
**
0.049
0.0009
0.013
584
140

2.64
0.95
0.047
0.002
0.00005
3.8
2

0.004
2.5
0.090
0.110
0.016

0.0075

0.000016
0.0094
0.00034
0.00041
0.00006

  No treatment,  only cooling water outfalls,
 *
  Less than supply water of 0.495 mg/1.
                                  476

-------
           TABLE  18-11  CONTROL PARAMETER LIMITATIONS
                  SUBCATEGORY:  Sodium Bichromate
                       Level  of Treatment: 1
                   Waste  Water Flow: 7 m3/kkg
Pollutant
Subcategory
Per formance
  (mg/1)
      Quality  Limit
  (1)     (mg/1)
VFR   	
      30 day   24  hr
       Av e r     Max
                                                    Emission Limit
                                                        (kg/kkg)
                                                    30 day  24 hr
                                                     Aver    Max
BPT Pollutants:

Total Suspended      12
Solids, TSS
              2.0
        35
70    0.26    0.52
Total Chromium, Cr    0.05     2.0     0.5     1.0  0.0035  0.007
Hexavalent
Chromium, Cr+6

Proposed Priority
Pollutants
Nickel, Ni


Zinc, Zn
           (2)
      0.01    2.0
          (2)
      0.2     2.0

          (2)
      0.1     2.0
        0. 1
        0.5
 0.2  0.0008  0.0016
 1.0  0.0035.  0.007
        0.5      1.0   0.0035   0.007
   (1) - VFR: ratio  of  the  24  hour variability factor  to the
            30 day  variability factor.

   (2) - Verification  Sampling
                               477

-------
POTW.  Future discharges can readily  be  treated to BPT levels and
this standard should be adopted  for pre-treatment requirements.


18.2.3 Estimated Performance p_f  Advanced  Leve^l Systems


Advanced  Level  Performance  Estimates   for  BPT   and  Priority
Pollutant Removal

    Necessary to  the achievement of good  effluent quality after
precipitation  of  heavy metals,   is   the  control  of  suspended
solids. In the Sodium  Bichromate  Subcategory, it can  be assumed
that  chromium  is  a  significant constituent  in  the suspended
solids discharged. For  this reason,  only one  advanced treatment
alternative,   addition of  a filtration  unit  for solids control,
has been recomraended.

    Table 18-12  presents  the  estimated   achievable  effluent
quality through the implementation of this  advanced technology.


New Source Applications

    Examination of  current  control and  treatment practices in
this subcategory has led to  the conclusion that  NSPS for sodium
dichrornate  plants   should  represent   the  application  of  the
advanced recycle technology currently practiced at one facility.


Response to Remand Issues

    The zero discharge requirement originally promulgated as BAT
for sodium  dichromate production  was  remanded  on  the basis of
inadequate  technical  and   economic   justification   for   the
evaporative  technology  required  to  eliminate  discharge-    A
control  and  treatment alternative,   which  allows  waste  water
discharge,  has  been  identified  and   the  performance   levels
achievable have been demonstrated  at  one  facility.


18.2.4 Cost Estimates


Discussion

    The cost   estimates  of  three    aiodels  having  different
production  levels are  presented  in   Tables  18-13,  18-14,  and
18-15. Annual treatment  costs   as a  function  of  production are
shown graphically in Figure 18-6.   Treatment cost per metric ton
°f product is shown in Figure 18-7.


                             478

-------
           TABLE 18-12  CONTROL  PARAMETER LIMITATIONS
                 SUBCATEGORY:  Sodium Bichromate
                      Level  of Treatment: 2
                   Waste Water Flow: 7 m3/kkg
   lutant
    ility
(mg/1)
      Quality  Limit
  (1)     (mg/1)
VFR   	
      30 day   24 hr
       Aver    Max
                                                    Emission Limit
                                                       (kg/kkg)
                                                    30 day  24 hr
                                                     Aver    Max
BPT Pollutants;

Total Suspended
Solids, TSS
Hexavalent
Chromium, Cr+6

Proposed Priority
   15
Total Chromium, Cr   0.3
    0.1
2.0    15
            2.0
2. 0
        0. 2
0. 1
       30    0.10    0.21
        0.4  0.0014  0.0028
0.2  0.0008  0.0016
Pollutants
Nickel, Ni
Zinc , Zn

0.
0.

1
4

2.0 0.1
2.0 0.4

0.
0.

2
8

0.
0.

0007
003

0.0014
0.006
   (1) - VFR: ratio of  the  24  hour  variability factor to the
            30 day variability factor.
                               479

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                  TABLE 18-13. MODEL PLANT  TREATMENT COSTS

  Subcategory   SODILM BICHROMATE                     Type of Regulation   BAT

  Production         20,000 metric tons per year (   22,050 tons per year)
                        57 metric tons per day  (       63 tons per day  )
  Waste water flow      400 cubic meters per  day.


                                             LEVEL OF TREATMENT*

                                          FIRST            SECOND
A.  INVESTMENT  COST

   Construction	              $615,250            $4,700
   Equipment  in place,
   including  piping,
   fittings,  electrical
   work and controls	               168,500            33,200
   Monitoring  equipment
   in place	                 9,000
   Engineering design
   and inspection	               158,550             7,580
   Inc idental s, overhead,
   fees, contingencies...               158,550             7,580
   Land	               156,000

   TOTAL INVESTMENT COST              $1,265,850           $53,060

B.  OPERATION  AND
   MAINTENANCE COST

   Labor and  supervision.               $56,000           $14,000
   Energy	                 2,500               600
   Chemicals	                 17,000
   Maintenance	               110,985             5,306
   Taxes and  insurance...                 37,975             1,591
   Residual waste
   disposal	
   Monitoring, analysis
   and reporting	                 15,000             7,500

   TOTAL OPERATION AND
   MAINTENANCE COST                    $239,460           $28,997

C.  AMORTIZATION OF
   INVESTMENT COST                     $180,572            $8,632

   TOTAL ANNUAL COST                   $420,032           $37,629


   *First level represents the base  cost  of  treatment system.
   Other levels represent the  incremental cost above base cost.

                                   480

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TABLE 18-14. MOEEL PLANT TREATMENT COSTS
                                 Type of  Regulation  BAT
   Subcategory  SODIUM BICHROMATE

   Production        50,000 metric tons per year  (  55,125 tons par year)
                        142 metric tons per day   (     157 tons per day )
   Waste water .flow    1000 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	            $1,375,800            $8,600
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               302,500            80,500
    Monitoring equipment
    in place	                 7,000
    Engineering design
    and inspection	               337,060            17,820
    Incidentals, overhead,
    fees, contingencies...               337,060            17,820
    Land	               252,000

    TOTAL INVESTMENT COST             $2,611,420          $124,740

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $56,000           $14,000
    Energy	                 2,800             1,000
    Chemicals	                42,000
    Maintenance	               235,942            12,474
    Taxes and insurance...                78,342             3,742
    Residual waste
    disposal	
    Monitoring, analysis
    and reporting	                15,000             7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                    $430,084           $38,716

C.  AMORTIZATION OF
    INVESTMENT COST                     $383,877           $20,295

    TOTAL ANNUAL COST                   $813,961           $59,011


    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.
                481

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                  TABLE  18-15. MODEL PLANT TREATMENT COSTS

  Subcategory  SODIUM  BICHROMATE                     Type of Regulation  BAT

  Production        70,000 metric tons per year  (   77,175 tons per year)
                       200 metric tons per day  (      220 tons per day )
  Waste water flow    1400 cubic meters per day.


                                            LEVEL  OF TREATMENT*

                                          FIRST             SECOND
A.  INVESTMENT  COST

   Construction	            $1,742,950            $12,200
   Equipment  in  place,
   including  piping,
   fittings,  electrical
   work and controls	               390,500             91,500
   Monitoring  equipment
   in place	                 9,000
   Engineering design
   and inspection	               428,490             20,740
   Incidentals,  overhead,
   fees, contingencies...               428,490             20,740
   Land	               324,000

   TOTAL INVESTMENT COST             $3,323,430           $145,180

B.  OPERATION  AND
   MAINTENANCE COST

   Labor and  supervision.               $56,000            $14,000
   Energy	                 2,800              1,000
   Chemicals	                 58,000
   Maintenance	               299,943             14,518
   Taxes and  insurance...                 99,702              4,355
   Residual waste
   disposal	
   Monitoring, analysis
   and reporting	                 15,000              7,500

   TOTAL OPERATION AND
   MAINTENANCE COST                      $531,445            $41,373

C.  AMORTIZATION  OF
   INVESTMENT COST                      $488,007            $23,620

   TOTAL ANNUAL  COST                  $1,019,452            $64,993


   *First level  represents the base cost  of  treatment system.
   Other levels  represent the incremental cost above base cost.

                                  482

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   11
   10
                                     i   i
                                                          j®.
o
o
o

o
o
 X
 EH


 §
                     ll
                                           /   A
                                              A
w

                                   A \  i
                             I/
                            Z
                             a

                 /i / i
              4l£

              ZO        30      40       50        60        70

                    PRODUCTION, METRIC TONS/YEAR X 1000



Figure 18-6.  Relationship of annual treatment cost  to production

              for the Sodium Bichromate Subcategory
                              483

-------
    22
    21
    20
    19
    18
    17
    16
    15
    14
                    \
                         V
                                     \
                                             I  i
                                               J	I
                                               I  !
                                                    n
               20      30        40        50        60

                    PRODUCTION, METRIC TONS/YEAR X 1000
                                                            TO
Figure 18-7-   Relationship of annual unit treatment cost  to production
              for the Sodium Dichromate Subcategory
                             484

-------
     Table 18-16 gives a summary  of  the  unit  cost  distribution
between  amortization  and  the  operation  and  maintenance  cost
components at various production  and levels of treatment.
Summary

     At the first  level of  treatment,  investment costs  are high
because sludge  lagoons costs  are  provided  for a ten year period.
Therefore, amortization is the major   portion of the total  annual
costs.  In place of annual cost   for  the   residual waste  (sludge)
disposal,  a large  investment in  land  is  shown.  At the  second
level  of  treatment,  labor   and  amortization  have  significant
impact on the additional annual  costs.
                              485

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                TABLE  18-16   MODEL PLANT TREATMENT COSTS
Subcategory  SODIUM DICHROMATE
Type of Regulation  BAT
                                           Annual Treatment  Costs  ($/kkg)
                                                 LEVEL OF  TREATMENT

                  PRODUCTION  FLOW      FIRST     SECOND    THIRD    FOURTH
                  (kkg/yr)  (m3/day)      $         $         $          $
Annual  Operation
and Maintenance
Annual
Amortization
Total  Cost
20,000
50,000
70,000
400
1,000
1,400
11.97
8.60
7.59
1.45
0.77
0.59
20,000
50,000
70,000
20,000
50,000
70,000
400
1,000
1,400
400
1,000
1,400
9.03
7.68
6.97
21.00
16.28
14.56
0.43
0.41
0.34
1.88
1.18
0.93
          Not Applicable
                                 486

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                          SECTION 19
                    CARBON DIOXIDE  INDUSTRY
19.1 ASSESSMENT  OF  THE WATER POLLUTION POTENTIAL
19.1.1 Industry Profile and Analytical Results

    Carbon  dioxide is produced in gaseous,  liquid  or solid form.

    A major portion of the production   is  used  captively for the
production of urea   and for  the secondary   recovery  of oil  and
natural gas.   It   is also used  for  refrigeration,   in the  food
industry,  for the  carbonation of beverages,  in  fire  extinguishing
equipment, and oil  well stimulation.

    The industrial data profile for  this subcategory is given in
Table 19-1,   while  existing regulations  are   summarized in  Table
19-2.

    The only  priority  pollutant    found   at    a    significant
concentration in  the raw waste  during   screening  at  Plant #241
was:
         Pollutant
Concentration  (ug/1)

      910
    when  the  data   was  reviewed with   plant  personnel,   it  was
discovered that  the  high  zinc level  was   due  to  zinc corrosion
inhibitors  and  were  not  process  related.    Therefore,   this
subcategory has  been recommended as an exclusion candidate  under
Paragraph  8.
                             487

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TABLE  19-1.   -
SUBCATEGORY PROFILE DATA SUMMARY
SUECATEGORY
CARBON DIOXIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                        12,194,000 kkg/year
                         1,819,000 kkg/year
                               105
                                12
                           713,947 kkg/year
                           558,667 kkg/year
                                59 percent
                                31 percent

                             1,600 kkg/year
                           155,000 kkg/year
                                6 years
                               50 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  488

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     19-2  -     EXISTING REGULATIONS  -  EFFLUENT KCMTTATICN GUIDELINES
t^==. 	 : 	



SUBCATEGORY Carbon Dioxide
SUBPART
— -
Product
Process
AF (40CFR 415.320,

BPCTCA
Max.1 Avg.2
Para- kg/kkg k/kkg
meters (mg/1) (mg/1)
5/22/75)
STANDARDS
BATEA
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)


NSPS
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
CO        Reserved      Reserved         Reserved         Reserved
  £
 wax, = Maximum of any one day.

 Avg. = Average of daily values for thirty consecutive days shall not exceed.
                                  489

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                          SECTION 20
       CARBON  MONOXIDE AND BY-PRODUCT  HYDROGEN INDUSTRY
20.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL
20.1.1 Industry Profile and Analytical Results
    In the   production
carbon monoxide  is also
from several  gas sources
natural  gas,  coke oven
methane reformer gas.
of  hydrogen  by  refining   natural   gas,
produced.  Carbon monoxide  is  recovered
including partial combustion   of  oil or
gas, blast  furnace   gas, water  gas, and
    Carbon monoxide and  by-product hydrogen   form   the  building
blocks  for other chemicals such  as ammonia   and  methanol.    The
major use of carbon monoxide is for the  manufacture of methanol.
    It is  also used as a
special steels,  ' and nickel
the manufacture  of ammonia,
   gaseous  fuel  for   reducing  oxides for
   refining.   Carbon  monoxide  is used in
   acetic acid,  and  zinc  white pigments.
    The industrial profile data  for  this  subcategory is given in
Table 20-1,   while existing regulations  are  summarized  in  Table
20-2.
    Priority pollutants found at  significant
waste during  screening at Plant #981 were:
                       levels  in  the raw
         Pollutant
         Chromium
         Zinc
         Silver
         Mercury
 Concentration  (ug/1)
       2590
        820
          1.4
          1.2
    The only pollutants of significance  in  terms  of waste loads,
in the carbon monoxide subcategory are  chrome  and  zinc.   However,
this  is  the result of the  use additives   in cooling  water  to
inhibit corrosion,   and is not  process  related.   Therefore this
subcategory  has  been recommended   as  a   Paragraph  8  exclusion
candidate.
                             490

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TABLE  20-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
CARBON MONOXIDE AND BY-PRODUCT HYDROGEN
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           277,200 kkg/year
                                 5
                                 5

                           112,400 kkg/year

                                40 percent

                                47 kkg/year
                            63,000 kkg/year
                                8 years
                               19 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Coimerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  491

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     20-2 -     EXISTING REGULATIONS  -  EFFLUENT .LIMITATION GUIDELINES
                Carbon Monoxide and By-Product Hydrogen



SUBPAKT          AG   (40CFR  415.330,  5/22/75)





~                                      STANDARDS



                          BPCTCA             BATEA             NSPS

                         1         2
                     Max.      Avg.      Max.    Avg.       Max.     Avg.

Product     Para-     kg/kkg    k/kkg     k/kkg   k/kkg     k/kkg    k/kkg

Process     meters    (mg/1)      (mg/1)     (mg/D  (mg/1)     (mg/1)    (mg/1)




^                   0 5       0 25
and        rnn                 u.^o
2          LUU       (81.3)*   (40.7)



 2         TSS       °'12      °'06
           ibb       (19.5)     (9.8)
 "wax,  = Maximum of any one day.

 Avg.  = Average of daily values  for thirty consecutive days shall not exceed.





 *flow basis  6150 1/kkg.
                                  492

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                          SECTION 21
                    COPPER SULFATE INDUSTRY
21.1 ASSESSMENT OF THE WATER POLLUTION POTENTIAL


21.1.1 Industry Profile and Analytical Results

    Most of the copper  sulfate produced  is  sold  in  the  merchant
market, consequently captive use is very   small.    Copper sulfate
is used in  agriculture as an insecticide  and algicide, and  as an
addition   to   copper-deficient  soils.    It   is   also   used   in
electroplating  and in petroleum refining,  and  as a  preservative
for wood.

    The industrial profile data for this  subcategory is  given in
Table  21-1, while existing regulations  are  summarized in  Table
21-2.

    Priority pollutants  found at significant  concentrations in
the raw waste during screening at Plant #034  were  as  follows:

         Pollutant       Concentration (ug/1)
         Antimony              307
         Arsenic              3500
         Cadmium               870
         Copper          1,850,000
         Lead                   175
         Nickel             112000
         Zinc                 11000
         1,1,1-trichloroethane 244


    A large   portion of  the  raw  waste   water   at   this   plant
consists  of   ground  water  which  seeps   and  collects  in  the
basement,  along   with leaks and washdown water  from  the   process.
The  ground  water is contaminated from  the  surrounding  area which
is heavily industrialized. The trichloroethane  is  presumed   to be
external contamination.

    A summary of daily  and unit product raw waste  loads for the
Plant sampled" can  be found  in  Table  21-3.   No   verification

                             493

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TABLE  21-1
SUBCmEGORY PROFILE DATA SUMMARY
SUBCATEGORY
COPPER SULFATE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                            37,000 kkg/year
                                18
                                10
                            32,218 kkg/year
                            28,960 kkg/year

                                78 percent

                                45 kkg/year
                             9,100 kkg/year
                             2,020 kkg/year
                               510 kkg/year
                                50 percent

                                 3 years
                                52 years

                                 0 cubic meters/day
                                28 cubic meters/day

                               <0.1 cubic meter/kkg
                                2.1 cubic ireter/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Carroerce,  Current Industrial
Inorganic Chemical Industry."
                                  494

-------
21-2 -
                EXISTING REFLATIONS  -  EFFLUENT UMTTATICN GUIDELINES
SOBCMEGOKf

SUBPAKT
            Copper Sulfate

            AT  (40CFR  415.360, 5/22/75)
	 • STANDARDS
BPCTCA

Product
Process
Pure Raw
Materials
Process
Recovery
Process







Para-
meters

Cu




Cu

Ni

Se
Max.
kg/kkg
(mg/D

0.0006

0.069
(74.2)*
0.003
(3.2)
0.006
(6.5)
0.0015
(1.6)
Avg.
k/kkg
Cmg/1)

0.0002

0.023
(24.7)
0.001
(1.1)
0.002
(2.2)
0.0005
(0.5)
BATEA NSPS
Max. Avg. Max. Avg.
k/kkg k/kkg k/kkg k/kkg
(mg/1) (mg/1) (mg/1) (mg/1)











      = Maximum of any one day.
 *Avg. = Average of daily values for thirty consecutive days shall not exceed.
 *flow basis  930 1/kkg.
                                  495

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TABLE  21-3.   SUMMARY OF RAW WASTE LOADINGS FOUND AT   COPPER SULFATE PLANT
	 • 	 	 	
Pollutant
Priority
Antimony, Sb
Arsenic, As
Cadmium, Cd
Copper, Cu
Lead, Pb
Nickel, Ni
Zinc, Zn
Conventional
TSS
kg/day
Average

0.014
0.16
0.039
83.9
0.0079
5.08
0.50
1.78
Loadings
kg/kkg
Average

0.00069
0.0078
0.0019
4.11
0.00039
0.25
0.024
0.087
                                  496

-------
sampling was performed in this subcategory   because no additional
plants with single product waste streams  could be identified.

    Based on  the   total  annual    production  rate   of  this
subcategory  and  the  average  waste  load   generated  per  unit
product,  the estimated total pollutant raw  waste loads generated
each year for this subcategory are  as follows:


         Pollutant       Waste Load  (Kg/year)
Antimony
Arsenic
Cadmium
Copper
Lead
Nickel
Zinc
25.5
287
70
152,070
14.5
9,250
888
21.1.2 Process Waste Sources and Waste  Water Treatment Data
General Process Description

    Raw material  and_  process  -   Copper   sulfate is produced by
reacting  coppef~sho~t7~( blTster   copper)   with sulfuric acid, air,
and water.  The general reaction is:
    Cu + 1/2 02 + H2S04 =  CuS04  +   H20   (1)


    Some plants do  not start  with  copper metal but  use a waste
stream from copper  refineries  which consists  of copper, sulfuric
acid,  and a small  amount of nickel.   The  solution needs to  be
strengthened by the addition of more  copper but the same general
equation applies.

    The resulting copper  sulfate solution is either sold or fed
to crystallizers  producing  copper sulfate crystals.  These are
centrifuged, dried, screened, and  then packaged dry for sale.


Water Use and Waste Source Inventories

    Water uses -  Water  is used  in the   process  as  a reaction
component which becomes a part  of  the  dry oro.duct as its water of
crystallization.  Water is also used for  noncontact cooling, pump
seals, and washdowns. Table 21-4 gives a  summary  of  plant water
usages.


                             497

-------
TABLE 21-4         WATER USAGE IN COPPER SULFATE SUBGATEGORY
Plant
#284
#313
# 069
# 571
# 885
# 458
# 100
# 969
# 050
Process Contact
m Akg
1.210
24.76
4.35
0.150
2.11
3.59
1.28
1.28
1.28
Noncontact
Cooling
m /kkg
0
37.29
138.4
0
0
0
0
0
0
Pump, seals,
leaks, etc..
0.346
0.278
4.96
0.033
Nil
Nil
Nil
Nil
Nil
washdown
.m /kkg









                                 498

-------
    Waste_  Sources
    A.   Noncontact  cooling water is used in the crystallizers
    and  constitutes one of the main wastes.  This waste  is
    treated  before  final discharge.

    B.   Washdowns,  spills, and leaks are sources of contact
    waste  water,  but the flows are relatively small and
    intermittant, and do not represent a raajor waste source.

    C.   A  few plants use evaporators, and steam condensate
    is  an  additional noncontact waste formed in the process.

    D.   Solid waste is produced by some plants.  The
    copper metal  used in the process contains copper sulfides,
    which  are filtered out of the liquor and disposed of
    in  a landfill.
    Plants that produce  copper sulfate in the liquid  form have
no  contact waste streams from the process.   The  copper  metal,
acid, and water  are reacted  together to form the copper  sulfate
solution product with no generation of liquid wastes.
Control and Treatment Practices

    Treatment practices -  Plant #034  uses lime  neutralization
followed  by  filtration.  The filtrate  is discharged to a sewer
and the filter cake is hauled to a landfill.

    Plant #284 practices lime neutralization with  aeration  and
clarification.

    Plant #069 has  neutralization  and  equalization  treatment
before the waste is discharged to a sewer.

    Plant #313 uses lime  precipitation  at pH  10  followed   by
gravity separation and centrifugation to thicken the sludge.  The
waste is then  neutralized to pH  6.5-7.5 and  discharged. Plants
HOO, #969, #050,  #458, #885 and #571 have no treatment.


Description of Plants Visited and Sampled

    Plant #034 was the only plant visited and sampled. This  was
done during screening and no verification sampling was  conducted
for this subcategory.

    The waste from the plant drains into a sump from which  it  is
pumped  to two  neutralization tanks where  lime   is added.   The
waste is then  run through a filter press  and the filter residue
is  hauled to a  landfill disposal  site.  The filtrate   is mixed

                             499

-------
with  noncontact   cooling    water   and  steam  condensate  in  a
collection  tank.   The  wastes  are  then passed  through  a  cloth
filter  for  final polishing  and  discharged  to a sewer.  Figure
21-1 shows  the process  flow  and  sampling points for this plant.
Table  21-5  gives  the  waste   flows   and  classical  pollutant
emissions.
Evaluation of Production  and  Waste Water Flow Data

     Table 21-5  shows  that   the  treatment efficiency for  copper
removal  is above 99.5  percent  at Plant #034.   All other  copper
sulfate  plants treat their   wastes with  other process wastes or
they have no wastes.  This   plant was the only plant visited  for
those reasons.
Process Modifications  and  Technology Transfer Options

     Mechanical scrapers should  be installed on filters in plants
using impure raw materials.   This would eliminate  the  need  for
backwashing so  no waste   water  would be produced.  Solids wastes
would still have to  be disposed.   Installation of these  scrapers
would constitute a small capital  cost.
Best Management Practices

     The best  technology   available for  the treatment  of copper
sulfate waste, where  pure  copper is used  as the raw material, is
total recycle  of   process  waste.  This would require floor dikes,
plumbing and sumps, and mother  liquor recycle pumping and piping.

     The best  technology  for  waste treatment where copper sulfate
is prepared  from   copper  refinery by-product  is  collection  of
waste mother liquor and process spills, washdowns, etc., followed
by lime precipitation of   metal ions  with settling  of suspended
solids  and  filtration.    This would  require installing  dykes,
sewers, a  treatment   tank,  a  settling  tank,  filter presses, and
associated piping  and pumping (2).


Model Plant and BPT Level  Treatment System Specifications

     Production -   Copper   sulfate production  ranges  from 18900
kkg/yr to  189000 kkg/yr  in  plants for which 308  Questionnaires
were available. The   average  of the  ten plants is 73710  kkg/yr.
The operational mode  for   all these plants is assumed to be batch
and to run 250 days per year.

     Waste water flow - The waste water  flow used for  the model
plant was  0.9 m3/kkg of  copper sulfate.  Plant #748 has a  waste

                               500

-------
                     FBQM
              CU REFINERY
                                  WASH WATER
                                                   STEAM
                                                                   COOLING WATER
                                                EVAPORATOR
Ul
O
H
                 SETTLED FILTER^
                 CAKE
                            Sample points.
                                                                  CRYSTALLIZER
                                                               MOTHER
                                                               LIQUOR
                                                                  CENTRIFUGE
                                                         MOTHER LIQUOR
                                                       TO OTHER PROCESS
                                                                    DRiER
                                                                    CUSO.
                                                       STEAM CONDENSATE
NONCONTftCT
COOLING
WATER
                                                                                                             SPUXS, LEAKS,
                                                                                                           SEEPAGE, CLERNUP
                                                                                                                    111 LIME
                          NEUTRALIZER
                            TANKS
                             (2)
                              I
                                                                                                                FILTER
                                                                                                                 PRESS
                                                                                                             COLLECTION
                                                                                                                TANK
                                          COOLING
                                          WATER
                     Figure  21-1.   General  process  flow  diagram  at  Plant  #034  showing
                                        the  sampling  points.   Copper  Sulfate Manufacture

-------
TABLE 21-5.   FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
              STREAMS FOR PLANT #034 PRODUCING COPPER SULFATE
	 - 	 .
Waste Stream
Description
CuSO. waste*
Effluent from
Flow
m /kkg
2.23
2.23
TSS
kg/kkg
0.0862
0.0769
Phenol
kg/kkg
0.00004
0.000027
Cu
kg/kkg
4.11
0.0101
Ni
kg/kkg
0.248
_
lime treatment
Steam Condensate
0.371    0.00133
0.00167
 Infiltration of ground water  into the collection sump was  suspected at the
 time of  sampling.
                                  502

-------
flow  of
combine
CuS04 to
       0.52  m3/kkg  of   copper sulfate.  All  the other   plants
       their  wastes with  other  process  wastes or  purify  the
       reagent grade which produces more waste.
    Solid  wastes   - Copper sulfide  from   filtration is the only
solid waste that  requires disposal.  This  waste   must be disposed
of  in a chemical   landfill  since the  solids  may contain  other
contaminants or become oxidized  and commence  to  migrate into the
soil or ground water.

    Slimes from   the mother  liquor  and   copper  sulfate  solid
wastes are  all recycled  or sent to another facility for precious
metal recovery.
    Treatment  chemicals
precipitate metals  and  for
                             Caustic  soda    is    required   to
                           pH adjustment, usually  at pH to 9-10.
    For model   plants,  the assumed caustic  soda  dosage  was 0.33
Kg/kKg of copper sulfate,  calculated as  350  mg/1  in  a  unit waste
flow of .52 m3/kkg of product.

    Solids generated  - Based  on sludge  production  of 5 Ibs/day
for 250 days/yr in the model plant, the annual   solids  production
is 340 kg, equivalent to unit  solids generation of  0.0046 kg/kkg
of product.
21.2 TECHNOLOGY BASED POLLUTION ABATEMENT
21.2.1 Advanced Level Treatment Applications
Priority Pollutants to be Controlled

    The priority  pollutants found  in  actual  plant  waste  waters
are closely related to the purity of  the  copper  and  acid  sources.
The heavy  metals,  cadmium, nickel   and  zinc,   which were  found
during  field sampling,  may  originate as   trace   impurities  in
copper scrap.   Arsenic was  found at  one   plant   in waste water
containing   floor  washings  and    infiltrated  groundwater.   A
possible source of arsenic, and other copper ore trace metals,  is
the use of sulfuric acid made from sulfur dioxide  produced in the
roasting  of copper sulfide  ore.  In  any  event  it appears that
copper, arsenic, cadmium,  nickel and zinc  are  typical pollutants
encountered in  copper  sulfate waste waters.   Assuming  that the
material sources  may  at some  time  include impure  acid,  copper
scrap and spent electrolyte solutions,  the  priority  pollutants to
be controlled are copper, zinc, nickel  cadmium  and arsenic.
                              503

-------
Removal Technologies Available
     Copper, nickel,
solution by alkaline
to 9.7  (cadmium).
used.  These metals
by ion exchange,  but
                      cadmium   and   zinc  can  be  separated  from
                     precipitation  at  pH values from 7.2 (copper)
                     Alternatively,  sulfide precipitation  can be
                     can also  be  removed from clarified solutions
                     the metal  ions  remain on the exchange  resins
or  in  the  regenerant  solutions  possibly  creating  additional
disposal problems.  Removal  of  trace metal concentrations by  the
xanthate process, although possible,  has  not  been widely used.
Some  reduction of  arsenic  concentrations at high  pH levels has
been reported, although the  removal  mechanism is not clear.  More
effective arsenic   removal   would  require the addition of  ferric
chloride during alkaline or  sulfide  precipitation of the process
wastes.
Technology to be Applied at  Each  Level

     BPT Model  (Level 1) - Alkaline  precipitation  using   caustic
soda  in  a  batch  process   was  chosen   as  the  most  effective
technology  for removal of heavy  metals   and  arsenic.    To suit a
40-hour, five-day production schedule  the wastes  are  received in
daily batches, and  are raised  to pH 10,  mixed,  and settled.   At
the end of the  work  week,   the  batch   is  filtered  and  the  pH
adjusted to between 6 and 9.
     Level _2  - Ferrous  sulfide  is
following alkaline  precipitation,
of trace metals.
                                    added  in  the  reaction vessel
                                     to  increase the precipitation
Flow Diagrams

     Level 1
                             Figure  21-2
     Level 2
                             Figure 21-3
     Equipment Functions  -  At  both levels the models are designed
for  batch  operation.Each   day's  wastes are  transferred  from
holding  sumps to  a  reaction vessel for storage.  At the end  of a
work week the BPT  treatment of  the accumulated waste consists of
adding caustic soda  to  pH 10,  mixing,   and applying  filter  aid
while filtering  in a  filter press.  After pH adjustment to the  6
to 9 range, the  filter  effluent is discharged. In  the  Level 2
model the equipment  remains the  same but precipitation is carried
out in two  steps.   Metallic   hydroxides are allowed to form  and
settle   in the   bottom  of  the   reaction  vessel.   Then ferrous
sulfide  is added to  the reactor  and mixed, to react with residual
metals.  Following  completion of  sulfide precipitation,  filter

                               504

-------
       CAUSTIC
         SODA
                  HOLDING
                    TANK
tn
O
Ul
RAW  WASTE WATER
                                                              FILTER AID-
                                                    REACTION
                                                       TANK
                                                                                                                 pH ADJUSTMENT
                                                                                           FILTER PRESS
                                                                                                                                              EFFLUENT
                     *
                      Includes flow monitoring, pH monitoring and sample
                                                                                     LANDFILL
                                                       Figure 21-2.   Waste water treatment Level 1 for copper sulfate  subcategory - batch process.

-------
                                       SODIUM
                                      BISULFIDE
                                               FILTER AID—|
                                            REACTION
                                                                                                   pH ADJUSTMENT
'includes flow monitoring, pH monitoring and sampler
                                                                            LANDFILL
                              Figure 21-3.   Waste water  treatment Level 2 for copper sulfate subctitegory - batch proces

-------
aid is added while  the mixture is being  filtered  through a filter
oress.  As   in   Level   1,   the  pH  is   adjusted   and the  filter
effluent is  discharged until the weekly  batch  is  exhausted.

    Chemicals  and   Handling  - Caustic   soda   solution  is  added
manually to  each batch until  the proper  pH  level  is reached.  In
Level  2,  batches   of  ferrous sulfide   are  prepared  by mixing
ferrous  sulfate and sodium  bisulfide  in a  well-ventilated  area.
Inert  filter  aid is applied  as  a   filter  precoat and is  added
continuously   during    the   filtering    process.   With   normal
precautions  there  are  no special chemical  handling problems  in
the treatment  of copper sulfate wastes.

    Separation and Removal o_f_ Solids -  All  solids  in both levels
are collected  as filter  cake in the  filter press, taken out  of
service   and    cleaned.   At  both   levels  the   dewatered   cake
containing   metallic  hydroxides, metallic   sulfides,  and  spent
filter aid  is  hauled to an off-site chemical landfill.

    Monitoring Regui rements  -  Alkaline precipitation  of  the
heavy  metals  is assured by bringing  the  reaction  vessel contents
to the proper  pH, as determined  by the   operator,  using field pH
equipment.   Periodic specific  analyses  of the final effluent for
priority pollutants for reporting purposes can be  made by  atomic
absorption methods  through a commercial  laboratory.


21.2.2 Estimated Performance o_f BPT Systems

    Copper  sulfate can  be manufactured  using pure copper as the
raw  material  or  an impure  copper   raw   material.   Waste  loads
emanating from  the  two sources  differ  greatly   in  that  total
recycle of   process wastes can be accomplished at  plants using  a
pure copper  source, while at plants using an impure raw material,
waste streams  need  to  be removed to some  extent to  avoid build-up
of contaminants in  the process.

    Based  on  the process technology  of  total   recycle  at plants
using a pure raw material, it has been  determined  that the degree
of waste control attainable is no discharge  of process wastes.

    BPT technology for copper sulfate  plants  utilizing an impure
raw  material   has   been  identified  as  hydroxide  treatment  to
precipitate  metals followed by settling  and filtration to remove
suspended  solids.   Table  21-6  presents raw wastes and treated
effluent  quality  results  from  sampling   of  Plant  ff034  where
treatment consists of lirne precipitation and  solids removal with
a filter press.
                             507

-------
TABLE  21-6.   VERIFICATION SAMPLING OF COPPER SULFATE PLANT #034
Pollutant
Flow =2.23 m /kkg
     Raw Waste
mg/1           kg/kkg
Treated Effluent
              kg/kkg
Total Suspended
Solids (TSS)
Copper, Cu
Nickel, Ni
Antimony, Sb
Arsenic, As
Cadmium, Cd
Chromium, Cr
Lead, Pb
Selenium, Se
Zinc , Zn
39.2
1850
112
0.33
3.50
0.870
0.142
0.180
< 0.011
11.1
0.087
4.1
0.248
0.0007
0.0078
0.0019
0.00038
0.00039
0.000024
0.025
35.0
4.65
0.240
0.036
< 0.020
0.001
0.005
0.005
0.100
0.016
0.078
0.010
0.0005
0.000079
0.000044
0.000002
0.00001
0.00001
0.00022
0.000035
 >\
 Before combining with non-contact cooling and steam condensate streams.
Monitoring Data - Treated Effluent
Total Suspended Solids, TSS

Copper, Cu

Nickel, Ni

Zinc, Zn

Arsenic, As

Selenium, Se
                              Flow = 3.7 m /kkg
                   Avg.


                   26

                    4.3

                    0.34

                    0.12

                    0.012

                    0.007
                                             mg/1
day Avg.

62.4
6.9
0.75
0.29
0.041
0.043
Avg.
kg/kkg
0.096
0.016
0.0013
0.00044
0.000044
0.00003
                                   508

-------
Base Level  Performance Characteristics  for  BPT  Pollutant Removal

    Based  on  effluent  quality   achieved   at    Plant   #034,
implementation of BPT  technology at copper   sulfate plants using
an  impure   raw  material   will  achieve   the   effluent  quality
presented in Table 21-7.

    Previous regulations included selenium  limitations, however,
selenium was not  found  to  be  a  significant pollutant  in raw
wastes at Plant #034.


Base  Level Performance  Characteristics  for Priority  Pollutant
Removal

    Raw waste priority pollutants  found  in significant amounts
during   sampling  of  Plant  #034   were   presented  above.   The
additional   pollutants   which  might   require    regulation  were
identified  as arsenic, cadmium and zinc.

    Table  21-7 also presents achievable  effluent quality through
implementation of BPT technology for these  pollutants.


Pretreatment Applications

    No copper  sulfate plant  presently  discharges  waste  to  a
POTW, however, Plant  #034 does plan to discharge to a  municipal
facility in  the future.   The toxicity of  copper is a concern as
it  can  have  a detrimental effect  on  POTW biota  and also   can
accumulate  in municipal sludges.  The volume of waste produced by
a copper sulfate plant is small enough  so  that  total copper loads
discharged  following  effective BPT treatment can  be accepted by
large  POTW's.   However,  for general  application,  pretreatment
will require careful waste water volume control.


21.2.3 Estimated Performance of Advanced  Level  Systems


Advanced  Level  Performance  Estimates   for  BPT  and  Priority
Pollutants  Removal

    Only one  advanced treatment alternative has been identified
for the Copper Sulfate  Subcategory.  Addition  of  sulfide before
filtration  for further removal  of copper  and other heavy  metals
is  proposed.

    Table  21-3 presents  estimates  achievable  effluent quality
through implementation of this advanced technology.
                              509

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    TABLE 21-7  CONTROL  PARAMETER LIMITATIONS
          SUBCATEGORY: Copper  Sulfate
              Level of Treatment: 3
          Waste Water Flow:  0.9  m3/kkg
D/-v Tin

BPT Eants
Totalande
Solid?
Coppe
Nicke
SelerSe
P r o per i o r
Pollu
Arsers
Cadmfl
Zinc ,
Subcategory
Do v f r\ irn 3 n ^ o
(mg/l)
m
d 62
6.9
0.7
0.04
ity

0.04
(2;
0.001
0.3
(1)
VFR


2.0
2.0
2.0
2.0


2.0
)
2.0
2.0
Quality Limit
(mg/l)
30 day 24 hr
Aver Max

15 30
2.5 5.0
0.5 1.0
0.1 0.2


0.1 0.2
0.05 0.1
0.4 0.8
Emission Limit
(kg/kkg)
30 day 24 hr
Aver Max

0.014 0.027
0.0022 0.0045
0.00045 0.0009
0.0001 0.0002


0.00009 0.00018
0.00004 0.00009
0.00036 0.00072
(1]R: ratio of the 24 hour  variability factor to the
    30 day variability  factor.

(2]rification Sampling
                      510

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        TABLE  21-8   CONTROL PARAMETER LIMITATIONS
               SUBCATEGORY: Copper Sulfate
                   Level of Treatment: 2
               Waste Water Flow: 0.9 m3/kkg
DA! 1 ni'ant1 Trp;

BPT Pollutants:
Total Suspended
Solids, TSS
Copper, Cu,
Nickel, Ni
Selenium, Se
Proposed Priority
Pollutants
Arsenic, As
Cadmium, Cd
Zinc, Zn
^ 1* ah i 1 i h v
(mg/1)

15
0.5
0.2
0. 1


0.05
0.01
0. 2
(1)
VFR


2.0
2.0
2.0
2.0


2.0
2.0
2.0
Quality Limit
(mg/1)
30 day 24 hr
Aver Max

15 30
1.0 2.0
0.2 0.4
0.1 0.2


0.05 0.1
0.01 0.02
0.2 0.4
Emission Limit
(kg/kkg)
30 day 24 hr
Av e r Max

0.014 0.027
0.0009 0.0018
0.0002 0.0004
0.0001 0.0002


0.00004 0.00009
0.00001 0.00002
0.0002 0.0004
(1) - VFR:  ratio of the 24 hour variability  factor  to  the
         30 day variability factor.
                            511

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Pretreatrnent Applications

     Only one copper sulfate plant  is  planning  to discharge  waste
to  a POTW following pretreatment.   Should  further metals  removal
be  required  due  to the sensitivity  of  a   particular  POTW, the
application   of  this  advanced    technology   would   then   be
appropr iate.


New Source Application

     After examination of the  effectiveness  of the two  treatment
technologies  applicable  to   copper  sulfate wastes, it has been
determined  that BPT technology  in  conjunction  with careful waste
water volume control in the design  and  operation of a new  copper
sulfate facility should achieve  effluent  quality  equivalent to
that quality estimated for the advanced  technology.
21.2.4 Cost Estimates
Discussion

     The cost estimate of  one model   plant  having   two  levels of
treatment  and the same level of  production  at  both the  levels is
presented in Table 21-9.  Table 21-10  gives  a  summary of the unit
cost  distribution  between  amortization    and   operation   and
maintenance cost components at two  levels  of treatment.


Summary

     Cost estimates developed  for  the first level   of  treatment
indicate that amortization and labor constitute a  major  portion
of the annual costs.  At the second  level of  treatment  there  is
insignificant change  in the annual  costs.
                               512

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                  TABLE  21-9.  MODEL PLANT TREATMENT COSTS
  Subcategory  COPPER  SULFATE

  Production         2,045 metric tons per year  (
                         5 metric tons per day  (
  Waste water flow       8 cubic meters per day.
             Type of Regulation   BAT

             2,254 tons per  year)
                 6 tons per  day  )
A.  INVESTMENT COST

   Construction  	
   Equipment in  place,
   including piping,
   fittings, electrical
   work and controls	
   Monitoring equipment
   in place	
   Engineering design
   and inspection	
   Incidentals,  overhead,
   fees, contingencies.,.
   Land	

   TOTAL INVESTMENT COST

B.  OPERATION AND
   MAINTENANCE COST

   Labor and  supervision.
   Energy	
   Chemicals	
   Ma intenance	
   Taxes and  insurance...
   Residual waste
   disposal	
   Monitoring, analysis
   and reporting	

   TOTAL OPERATION AND
   MAINTENANCE COST

C.  AMORTIZATION  OF
   INVESTMENT COST

   TOTAL ANNUAL  COST
                                            LEVEL OF TREATMENT*

                                          FIRST            SECOND
  $9,200



  53,000

   9,000

  14,240

  14,240
   1,200

$100,880
  $8,000
      15
   1,000
   9,968
   3,026

     100

   2,500


 $24,609


 $16,217

 $40,826
  $200



 1,000



   240

   240


$1,680
    30
   168
    50
 1,250


$1,498


  $273

$1,771
   *First level  represents the base cost  of treatment system.
   Other  levels  represent the incremental cost above base cost.
                                   513

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                 TABLE  21-10    MODEL PLANT TREATMENT COSTS
Subcategory  COPPER SULFATE                        Type of Regulation  BAT
                                            Annual Treatment Costs ($/kkg)
                                                  LEVEL OF TREATMENT

                  PRODUCTION  FLOW      FIRST     SECOND    THIRD    FOURTH
                   (kkg/yr)  (m3/day)      $         $         $         $
Annual Operation
and Maintenance       2,045       8     12.03      0.73     Not Applicable

Annual
Amortization          2,045       8      7.93      0.13

Total Cost            2,045       8     19.96      0.87
                                  514

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                          SECTION  22
                    NICKEL SULFATE  INDUSTRY
22.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL
22.1.1 Industry Profile and Analytical  Dat a

    Most of the nickel sulfate  produced  is  sold   in the merchant
market.  The major use of nickel  sulfate  is  in  the metal  plating
industry. It  is also used in dyeing  and  printing  fabrics and for
producing a patina on zinc and brass.

    The industry  profile data   summary  is   given in Table 22-1,
while existing regulations are summarized in Table 22-2.

    Priority pollutants  found  at  significant  concentrations  in
the raw waste during sampling at  Plant  #369  were  as follows:

                 Maximum Concentration Observed
    Pollutant                (ug/1)
                    Screening      Verification (2 Plants)
Nickel
Copper
Chromium
Thallium
Lead
Mercury
Cadmium
Selenium
175,500
73,300
1,300
21
55
4
9
<235
1,115,000
355
110
<3
120
10
160
141
    A summary of daily and unit  product  raw waste loads for  all
plants sampled can be found in Table  22-3.   Individual plant  raw
waste loads per unit product  found   in   sampling   can be found in
Table 22-4.
    The total annual  production   rate  for
unavailable   at   this  time.   Therefore,
pollutant  waste  loads  generated   by   this
calculated and presented.
this subcategory  is
the  total  priority
 industry  cannot be
                              515

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TABLE  Z2-1
SUBCATEGORy .PROFILE DATA .SUMMARY
SUECATEGORY
NICKEL SULFATE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this  subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                                12
                                 6
                            24,770 kkg/year
                            17,670 kkg/year
                                62 kkg/year
                             8,250 kkg/year
                             2,100 kkg/year
                             1,600 kkg/year
                                 3
                                48

                               < 1 cubic maters/day
                               200 cubic meters/day

                               < 1 cubic meters/kkg
                                20 cubic meters/kkg
Sources of data are Stanford Research Institute,  Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental  Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  516

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TABLE  22-2 -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES
SUBCATEGORY Nickel Sulfate
SUBPAKT
AU (40CFR 415.470,
5/22/75)

STANDARDS
Product
Process
Pure
Raw
Materials

Impure
Raw
Materials


BPCTCA
Max. Avg,
Para- kg/kkg k/kkg
meters (mg/1) (mg/1)
„. No discharge
of pwwp 3
TSS No discharge
of pwwp
N. 0.006 0.002
(5.1)* (1.7)
0.096 0.032
(82.1) (27.4)
BATEA
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp
No discharge
of pwwp



NSPS
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp
No discharge
of pwwp



  wax, = Maximum of any one day.
 2
  Avg. = Average of daily values for thirty consecutive days shall not exceed.

  pwwp = Process wastewater pollutants,

 * flow basis  170 1/kkg.
                                   517

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     TABLE  22-3.    SUMMARY OF RAW WASTE LOADINGS FOUND IN SCREENING AND VERIFICATION  SAMPLING
CO

SUBCATEGORY NICKEL SULFATE
Pollutant
Minimum
Priority
Cadmium, Cd 0.000014
Chromium, Cr 0.00023
Copper, Cu O'.OOll
Lead, Pb 0.000082
Mercury, Hg
Nickel, Ni 0.27
Selenium, Se 0.00027
Thallium, Tl
Conventional
TSS 0.34
Loadings
kg/day
Average Maximum Minimum

0.0015 0.0045 0.000002
0.00091 0.0018 0.00001
0.039 0.11 0.0001
0.0014 0.0028 0.00002
0.000027
10.8 31.5 0.035
0.00059 0.00091 0.00003
0.000032
31.2 92.5 0.031
kg/kkg
Average Maximum

0.00017 0.0005
0.00025 0.0005
0.01 0.03
0.0001 0.0003
0.00003'
1.20 3.45
0.000035 0.00004
0.000009
10.1
No. of Plants
Averaged

3
2
3
3
1
3
2
1


-------
22-4.    PRIORITY POLLUTANT RAW WASTE LOADS  (in kg/kkg of Product)
SUBCATB30RY
POLLUTANT

Nickel, Ni
Copper,. Cu
Chronium, Cr
Lead, Pb
Zinc, Zn
Mercury, Hg
Cadmium, Cd
Selenium, Se
Thallium, Tl
NICKEL
SULFATE

PLANT
#369
0.073
0.030
0.0005
0.00002
0.00011

0.000004

0.000009
#572
3.45
0.0001

0.0003
0.0012
0.0003
0.0005
0.00003

#120
0.035
0.0002
0.00001
0.00006
0.00004

0.000002
0.00004

                             519

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22.1.2 Process Waste Sources  and  Waste Water Treatment Data
General Process Description

     Raw materials and  process  -  Two different
used  to producenickel  sulfate.    Pure nickel
powder  is  used  or    spent   nickel  catalysts,
solutions or residues.  The general  reaction is:
                   raw materials are
                   or  nickel  oxide
                    nickel  plating
     NiO + H2S04  =
NiS04
H20
(1)
     The nickel sulfate produced  when pure raw materials  are used
is filtered and sold or processed further using a crystallizer to
produce a solid nickel sulfate  product.   This must be classified,
dried, and screened before  it  is  ready for sale.

     The use of impure  raw  materials produces  a  nickel sulfate
solution which must be  treated  in sequence with oxidizers,  lime
and sulfides  to precipitate impurities  which are then removed by
filtration.   Tiie nickel  sulfate solution  can  be  sold or  the
product may be crystallized, classified,   dried,  and screened  to
produce solid nickel sulfate for  sale.
Water Use and Waste Source  Inventories
     Water uses -  Noncontact  cooling  water  is  used for   nickel
sulfate production in  the  reactor  and  in crystallizers.  Water is
used for direct process  contact  in the reactor.  Small amounts of
water are used for maintenance purposes, washdowns,  cleanup, etc.
Table 22-5 gives a summary of  water  usage.

     Waste Sources

     Noncontact cooling  water  is the main  source of waste  water,
but it is not usually  treated  before discharge.

     Direct process contact water constitutes the  major  portion
of  treated  waste.    The  waste   comes  from   the  preliminary
preparation  of spent  plating  solutions  used  in  the process.
Plants which use impure  nickel   raw materials generate a   filter
backwash waste stream  with high impurity  levels.   This   stream
must be sent through the treatment system.
     Washdowns, spills,  pump leaks,  and maintenance
for the remaining  wastes produced  by nickel sulfate
                       uses  account
                       plants.
                               520

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    22-5.   WATER USAGE IN THE NICKEL SULFATE SUBCATEGORY
 |120
*
 Includes uses for other processes.
plant         Non-contact cooling    Direct Process contact    Micellaneous
                    m3/kkg                  m3/kkg          (^'_ J
                                                                   m /kkg

 #313 *             37.29                  24.76                  0.278
 #069                 1.67                   0.0098                0.0196
 #572 *               4.98                   0.349                 0.896
                      0.417                  0.783                 0.094
                    13.64                   4.013                  Nil
      *
 #603             2035                   814                      Nil
                                   521

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Control and Treatment Practices

     Treatment practices  at   Plants #313,   #069,  #572,  #369 and
#120  all  employ caustic  precipitation  of  metal-bearing  waste
waters followed  by filtration.   The solid wastes are disposed of
or  used as  landfill at  Plant  #120, while the liquid wastes are
recycled to the process.

     Plant #369  was  visited   in  the  screening  phase  of the
program.  Treatment at  this  plant consists of adjusting the  ptl to
between 9  and 10 for the  precipitation of metal hydroxides  which
are removed  by  settling  prior  to  final  discharge.  Figure 22-1
shows the treatment system and  sampling points.  Table 22-6  gives
flows and pollutant emissions  for the streams sampled.

     Plants #572 and  #120 were   visited  and sampled during the
verification  phase of  the program.   At Plant #572,  the wastes,
washdowns,  leaks, and  air   scrubber  water are put  through  an
equalization tank and then discharged to  the municipal treatment
system.  In  the equalization  tank, alkaline wastes from  another
process are mixed in and  the  pH is  raised to  10.  Treatment of
process wastes  at  Plant  #120   consists   of  pH  adjustment  to
precipitate  nickel  and   other  trace  metals  followed  by  sand
filtration.   The wastes   are  mixed with  other plant wastes and
discharged through  a single  outfall.   Figures 22-2, 22-3,  and
22-4 show the general flow sheets and waste  streams sampled for
#572 and #120  respectively.   Table 22-6  shows the waste streams
and loadings for both plants.
Evaluation of Production  and  Waste Flow Data

     The flow for  nickel   sulfate wastes ranged from 0.417  m3/kkg
to  0.722 m3/kkg.  This   gives   an average  of  0.570  u3/kkg  of
product.  This data  is based   on  the only  two  plants where the
NiS04  waste streams  were separated from other wastes.  All the
plants visited produced solid wastes  as sludges but no flow data
was available.
     Table
visited.
22-6 summarizes the waste flow  data   for  all  plants
Process Modifications  and  Technology Transfer Options

     Mechanical  scrapers  should be installed on filters at plants
which  use   impure   raw   materials.    This  would  eliminate   the
backwash  and  reduce   the   amount of waste water produced. Solids
would need   to be disposed.   Installation  of the scrapers would
amount to a  very small capital  cost.
                               522

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                                                                                 PROCESS
                                                                                  WASTES
                                                                                                                 NaOH
                                                                                  i
i
WASTE WATER
COLLECTION
SUMP
1^1
4^11
TREATMENT
TANK
to
•€^#3 ^
                                                                                                                                           SLUDGE TO LANDFILL
                                                                                                                        DECANT
                                                                            BATCH OPERATION
01
K>
U)
                                                                                 Sampling points.
                                                                                                               TREATED EFFLUENT
                                                                                                                   TO SEWER
                                                                            Figure 22-1.  General waste water treatment process flow diagram showing
                                                                                      the sampling points.  (Nickel Sulfate Manufacture)

-------
TABLE 22-6.   FLOW AMD POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
              STREAMS FOR PLANTS PRODUCING NICKEL SULFATE
    Stream
 Flow
m /kkg
 TSS        Ni        Cu        Pb

kg/kkg    kg/kkg    kg/kkg    kg/kkg
Untreated waste       0.417

Treated waste         0.417
             Plant #369

                      0.073     0.031     0.0005

                      0.00058   0.0075    0.0002
Scrubber waste
 3.15
 Plant #572

10.15     3.45
0.00013   0.0003
NiSO. waste           0.722

All Nickel wastes     7.54

Treated effluent      7.54
             Plant #120

             0.031    0.0355

            0.521     0.094

            0.032     0.0015
                    0.00015   0.00004
                    0.0002
                                   524

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Ul
K>
Ln
LEAKS, SPILLS, ETC., FROM
       OTHER PROCESSES
                                                                                                                                                         NiSO.
                                                                                                                                  SOLID WASTE
                                                                                                                                  TO DISPOSAL
                                                                                                           ALKALINE WASTES
                                                             Figure 22-2.   General process flow diagram at plant #572 shewing the sampling points.

                                                                                                  Nickel Sulfate Manufacture

-------
NICKEL

OXIDE
	 P»
DIGESTOR
i A «-»-.ir-ir-m

                                                  t
           PLATING

      • SODA ASH
                                                             EFFLUENT
                                                   CALCITE
                                                   -H
                                                    COOLINO
                                                    WATER
                                                          HOLDING TANK
                                 DRYER
                                             DUSTS
                                  I
                              COOL, SCREEN,
                                PACKAGE
                                   f
SCRUBBER
                                             DUSTS
                                                                          QC LAB
1IC ACID
ER
•£
SE
3OE
kM

JEVAPORAT10N TANK ^
                  STEAM
                   WATER
                              SOLID  PRODUCT
Figure  22-3.   -General process flow diagram of Plant  #120.

                         Nickel Sulfate Manufacture
                                       526

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                                           OTHER NICKEL WASTES
NiSO. PROCESS
     VfflSTE
                                                                                       SOLIDS TO NiSO.
                                                                                           PROCESS
                 Sampling points
                                                                         DISCHAHGE
                                                              #3
               Figure.22-4.   General waste water treatment process flow diagram at Plant £120
                                      showing the sanpling points.
                                     (Nickel Sulfate Manufacture)
                                                 527

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Best Management: Practices

     The best  technology   for   the   treatment  of  wastes  when
starting with  pure   raw materials   is  to  recycle  all  process
waters.   To implement  this   treatment proper recycle piping  and
pumping would be needed.

     The best  technology   available  where  nickel  sulfate  is
manufactured from  impure plating  solution is caustic addition  to
precipitate  nickel   followed   by   sand  filtration   to  remove
suspended   solids.   This    would   require   installing  caustic
treatment tanks, filters, pH  control equipment, and the necessary
piping and pumping.


Model Plant and BPT Treatment System Specifications

     Best Practical   Technology  for  plants using pure nickel as a
raw  material  is  total  recycle of  all process water.  A plant
using impure raw materials  requires  caustic neutralization of  the
waste followed by  sand  filtration.

     Waste system  water flow  - The   flow used for the model plant
is 0.64 m3/kkg of  nickel sulfate. This  is based  on the largest
producer in the industry.   Plant #369 showed  a waste  flow  of
0.416 m3/kkg  and  #120  showed 0.722 m3/kkg.   Other  plants have
combined  waste  waters  and  their   flows  are  not  known with
accuracy.

     Production -  Nickel sulfate  production ranges from 96 kkg/yr
to 5,910kkg/yr in the plants   for  which 308 Questionnaires were
available.  The average production  for these six plants was 2,120
kkg/yr.   The  production   levels  selected  for  the model plant
ranged from 900 kkg/yr  to 7,000  kkg/yr.  The mode of operation at
all nickel sulfate plants is  the  batch process and, for the model
plant, is assumed  to  operate  for  250 days/year.
     Sol id waste generation  -  Solid wastes are generated from  the
filtration  "and  settling  of   metals  from  the  nickel  sulfate
solution.  The  solids   can  be recycled to the  process for reuse
when pure raw material  is  used.   If the solids cannot be recycled
they  must  be  disposed of   in a chemical  landfill  because  the
solids may contain   contaminants  that  can pollute  the soil   or
ground water. The quantity generated is assumed to be 0.39 kg/kkg
of nickel sulfate.

     Treatment chemicals - Caustic is required for neutralization
to precipitate the  metals  as their hydroxides. Acid is needed  for
pH adjustment before final discharge. For the  model plant, these
practices were  assumed   to   use 0.0016 kg/kkg  and 0.0001 kg/kkg

                                528

-------
respectively.


22.2 TECHNOLOGY BASED POLLUTION  ABATEMENT


22.2.1 Advanced Treatment Applications


Priority Pollutants to be Controlled

    The priority  pollutants   present  in  a  specific  process
operation  depends  upon  the   sources  and  nature  of  the  raw
materials being used,  which   presumably  could vary from time to
time.  If impure  raw materials  include spent plating  solutions,
most of the heavy metals  (except nickel)   will  be rejected  from
the  process  as  sludges   from  the purification of  the  plating
solutions prior to  nickel  sulfate  production.  If  these sludges
are  handled as  solids,  they  can  be  segregated  for  further
reclamation or  for  safe   disposal  at  a chemical landfill.  If
sludges from the process are discharged as slurries to  the waste
treatment facilities they   will  be  settled or filtered during the
treatment proposed for  the model systems.  The only  significant
priority pollutant found  in the  sampling program was nickel.


Removal Technologies Available

    Alkaline precipitation will  remove  nickel  and most  other
heavy  metals from solution,   allowing  them  to  be  settled and
filtered  in  successive  steps.   Nickel  and  the  common heavy
raetals, except chromium  can also  be  precipitated  as  metallic
sulfides, for later separation by settling and filtration.


Technology to be Used at Each  Level

    BPT - Because it is widely   used in  the industry,  alkaline
precipitation with  caustic soda is  chosen as the BPT  (Level  1)
model. With dual media  filtration  it  is  operated  as  a  batch
process to suit the production schedule.

    Level 2 -  Alkaline  precipitation  is supplemented  by  the
addition of~ferrous sulfide, to  precipitate dissolved nickel more
effectively before the filtration step shov/n  in Level 1.
                              529

-------
Flow Diagrams


      Level 1                      Figure 22-5

      Level 2                      Figure 22-6


     Equipment Functions   -   Wastes  are  received  in a  one-day
holding tank or waste water  collection sump which is drained  each
day to a reaction vessel.  At the end  of a normal work week, the
contents of the  reaction  vessel   are raised to about  pH 10  with
caustic soda,  thoroughly  mixed,  and allowed  to  settle.   The
separated liquids and serni-solids are then filtered and the  final
effluent  is  adjusted  to  a   pH  from 6 to 9 before discharge.  In
the  small and  medium  models it  is assumed that both the liquid
and the semi-solids   in the  reaction tank are filtered through  a
high-pressure filter  press,  and   discharged after pH adjustment.
In the highest production  model,  which produces 13 m3 per day  of
wastes, seni-solids   are filtered through  a  filter press  and a
separate dual media filter is provided for filtering the decanted
liquid. In Level 2 the  metallic  hydroxide sludge is drawn off to
a  sludge  holding  tank   and the  clarified  supernatant in  the
reaction  tank  is 'treated  with  ferrous  sulfide,  precipitating
metallic sulfides.    The batch is then filtered  through a filter
press  (for small or medium plants)  or through a filter press  (for
semi-solids) and a dual- media  filter  (for supernatant) in  the
larger operations.

     Chemicals and Handling  -  Caustic soda  in solution form  is
used for alkaline precipitation at both levels  to form insoluble
metallic  hydroxides  without  precipitating  calcium sulfate, as
would  occur  with  lime   application.  Caustic  soda solution is
handled  in conventional equipment, or is  drawn  in batches  from
shipping containers when small  volumes are needed.  In  Level 2,
ferrous  sulfide  is  prepared from  ferrous  sulfate  and sodium
bisulfide. When these materials are mixed in  a  well  ventilated
space  and applied to  the  alkaline  supernatant  in  the reaction
tank there are no special  problems.

     Separation and   Removal  o_f Solids - In the  small and medium
production  models, at   both levels,  essentially all solids are
collected in a filter press,  which is periodically  cleaned.  The
dewatered sludge is   hauled  to a  chemical landfill. In the larger
model  plant,  backwash from  cleaning  the  dual  medium filter
returns  to the influent holding   tank, from which the  suspended
solids pass  via the  reaction tank and from  there to  the sludge
filter press.

     Monitoring Requi rements -  Satisfactory separation of  heavy
metals  can  be assured by maintaining  the  proper  reaction pH,
which  can be  determined manually  on each  batch,  using  simple

                                530

-------
                                                                BACKWASH
     CAUSTIC
      3ODA
Ln
00
     RAW WASTE WATER f
                                                                                                                       pH ADJUSTMENT
                        Includes flow monitoring, pH monitoring and sampler
                                                                                                           FILTER PRESS
                                                                                                            LAND? ILL
                                                                                                                                       •O-
EFFLUENT
                                     Figure 22-5.  Waste water treatment level 1 for nickel aulfate subcatejory - batch process.

-------
("FERROUS          SODIUM
                                                                     BA.CKWASH
M
CAUSTIC COD \ ' •-
j
I

1
t
HOLDING
TANK
	 »• 1
RAW WASTE 1 	 1 	 ' 1
WATER f L
I


3

^ OT^ A
J^ T

                             L-
                                                         POLYMER
                                                        TANK
                                                                                                                      pH ADJUSTMENT



ER








DUAL
MEDIA
FILTER

M
!____ g, 	

0^



FILTER AID
1
1
1
1
1
I


~XT
3><->->
SLUDGE
HOLDING TAKK

"j FILTER PRESS
Lr~ ~|
1
J

                                                                                                             LANDFILL
                                                                                                                                                          EFFLUENT
                                 Includes flow monitoring, pH monitoring and sampler
                                            Figure  22-6.  waste water treatment Level 2 for nickel sulfate subcategory - batch process.

-------
field equipment.   Occasional monitoring of  nickel  in  the  effluent
for reporting   purposes  should  be  done   by   atomic  absorption
methods  on   a   sample  of the  liquid  discharge.  Monitoring for
dissolved sulfide  should not be  necessary,   because   unreacted
ferrous  sulfide  will oxidize  to ferric  sulfide  and settle with
the other metallic sulfides.


22.2.2 Estimated  Performance of BPT Systems

    BPT technology has been specified as hydroxide precipitation
of  metals,  followed  by  filtration to remove   suspended solids.
Plant #120 is currently practicing this  technology.    Table 22-7
presents effluent quality achieved  at  this  facility  as well as
results from the  verification sampling program.


Base Level Performance Characteristics for  BPT  Pollutant  Removal

    Effluent quality  achievable  through  implementation  of BPT
technology is  presented  in Table  22-8  and  is based  on quality
achieved at  Plant #120.
Base  Level  Performance  Characteristics   for  Priority Pollutant
Removal

    None of the  additional priority  pollutants   identified were
found at levels that would require  treatment.


Pretreatment Applications

    Two nickel sulfate  plants are  known  to  presently  discharge
to POTWs.  Pretreatment at one plant  is  simple   settling while at
the other, it is hydroxide precipitation followed  by settling.

    Considering the  small waste water   flows  generated  in the
manufacture of nickel  sulfate, the  application of BPT technology
is appropriate for pretreatment.


22.2.3 Estimated Performance o:f Advanced Level  Systems


Advanced  Level  Performance  Estimates   for    BPT  and  Priority
Pollutant Removal

    Only one advanced treatment alternative  has   been  developed
for the nickel sulfate  subcategory.   Addition  of  sulfide  before
filtration for further removal of nickel is proposed.


                              533

-------
TABLE 22-1.    WASTE CHARACTERISTICS OF NICKEL  SULFATE PLANT #120


Verification Sampling:       Flow = 0.72 m /kkg
                        Raw Waste           Treated Effluent Quality*
Pollutant           mg/1         kg/kkg             mg/1
                Avg.   Max.    Avg.   Max.      Avg.    Max.


Total Suspen-  43     64      0.842   1.25      4.33    8
  ded Solids

Nickel, Ni     49.15  75.80   0.962   1.48      0.2    0.34


Effluent Monitoring: Daily Data

Pollutant             Concentration  (rag/1)                    Waste Load (kg/kkg
	Min	Avg.	Max	St.Dev.    Min	Avq    ^

Nickel, Ni         0.08       1.83      8.33       2.22      0.043     0.35   l.i-
                                   534

-------
          TABLE  22-8   CONTROL PARAMETER  LIMITATIONS
                 SUBCATEGORY: Nickel  Sulfate
                     Level of Treatment:  1
                 Waste Water Flow:  0.64 m3/kkg

rOl 1 UT.au U
Subcategory
(mg/1)
(1)
VFR

Quality Limit
(mg/1)
30 day 24 hr
Av e r Max
Emission Limit
(kg/kkg)
30 day 24 hr
Av e r Max
BPT Pollutants :

Total Suspended     4.0(2)    2.0     15
Solids, TSS
Nickel, Ni
2.7
3.0
       30    0.0096   0.019


2.0    6.0   0.0013   0.0038
  (1) - VFR:  ratio of the 24 hour  variability factor to the
           30 day variability  factor.

  (2) - Verification sampling
                              535

-------
  e  22-9  presents  estimated  achievable  effluent quality
thmplernentation of this advanced  technology.
Nee  Applications

  r  examination of the effectiveness  of  the  two  treatment
teies  applicable  to nickel  salfate  wastes,   it has  been
ded  that BPT technology in conjunction  with  careful waste
waume  control in the design  and  operation of a new nickel
sifacility  should achieve effluent   quality  equivalent to
    y estimated for the advanced  technology.
2< amortization  and   operation    and   maintenance  cost
ccs at various production and levels  of treatment.
 :  estimates developed for the   first   level  of   treatment
i  that  at a  low  production   level   labor   cost  has  a
smt  impact   on  the  total   annual    costs.   At  medium
pm level, amortization,  operation  and maintenance  costs
a  important factors in  the  annual   costs.    At a  high
p>n level, amortization  cost is a   significant  factor  in
til costs.  At the second level   of  treatment,  there is no
smt change in the annual cost,  with  production.
                        536

-------
           TABLE  22-9  CONTROL PARAMETER LIMITATIONS
                 SUBCATEGORY: Nickel  Sulfate
                     Level of Treatment: 2
                 Waste Water Flow:  0.64  m3/kkg
Pollutant
Treatability
  (mg/1)
  (1)
 VFR
                                   Quality Limit
                                      (mg/1)
                                     Emission  Limit
                                         (kg/kkg)
                                   30  day  24 hr   30 day   24 hr
                                    Aver    Max     Aver    Max
BPT Pollutants:

Total Suspended     15
Solids, TSS
Nickel, Ni
    0.5
               2.0    15
3.0
       30     0.0096  0.019


0.5     1.5  0.00032  0.00096
  (1) - VFR:  ratio of the  24  hour  variability factor  to  the
           30 day variability  factor.
                              537

-------
                    TABLE 22-10. MODEL PLANT TREATMENT COSTS

   Subcategory  NICKEL SULFATE                       Type of Regulation  BAT

   Production           900 metric tons per year  (     992 tons per year)
                          2 metric tons per day   (       2 tons per day )
   Waste water flow       3 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	                $6,000              $100
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	                29,500               900
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	                 8,900               200
    Incidentals, overhead,
    fees, contingencies...                 8,900               200
    Land	                 1,800

    TOTAL INVESTMENT COST                $64,100            $1,400

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.                $8,000
    Energy	                    30
    Chemicals	                   200                30
    Maintenance	                 6,230               140
    Taxes and insurance...                 1,923                42
    Residual waste
    disposal	                   100
    Monitoring, analysis
    and reporting	                 2,500             1,250

    TOTAL OPERATION AND
    MAINTENANCE COST                     $18,983            $1,462

C.  AMORTIZATION OF
    INVESTMENT COST                      $10,136              $227

    TOTAL ANNUAL COST                    $29,119            $1,689


    *First level represents the base cost of treatment system.
    Other levels represent the  incremental cost above base cost.
                                     538

-------
                   TABLE 22-11.MODEL PLANT TREATMENT COSTS
  Subcategory  NICKEL SULFATE

  Production
                                                   Type of Regulation  BAT
                   4,000 metric  tons  per  year (    4,410 tons per year)
                      11 metric  tons  per  day  (       12 tons per day )
Waste water flow       11 cubic meters per day.
A.  INVESTMENT COST

   Construction 	
   Equipment in place,
   including piping,
   fittings, electrical
   work and controls	
   Monitoring equipment
   in place	
   Engineering design
   and inspection	
   Incidentals, overhead,
   fees, contingenc ies...
   Land	

   TOTAL INVESTMENT COST

B.  OPERATION AND
   MAINTENANCE COST
                                            LEVEL OF TREATMENT*

                                           FIRST            SECOND
                                        $8,350



                                        51,000

                                         9,000

                                        13,670

                                        13,670
                                         1,800

                                       $97,490
  $100



   900



   200

   200
$1,400
Labor and supervision.

Chemicals 	

Taxes and insurance...
Residual waste
disposal 	
Monitoring, analysis
and reporting 	

TOTAL OPERATION AND
MAINTENANCE COST
C. AMORTIZATION OF
INVESTMENT COST
TOTAL ANNUAL COST
$8 , 000
40
900
9,569
2,924

100

2,500


$24,033

$15,568
$39,601


75
140
42



1,250


$1,507

$227
$1,734
   *First level represents the base  cost of treatment system.
   Other levels represent the  incremental cost above base cost,
                                    539

-------
                    TABLE 22-12. MODEL PLANT TREATMENT COSTS

   Subcategory  NICKEL SULFATE                       Type of Regulation  BAT

   Production         7,000 metric tons per year  (   7,717 tons per year)
                         20 metric tons per day   (      22 tons per day )
   Waste water flow      18 cubic meters per day.


                                             LEVEL OF TREATMENT*

                                           FIRST            SECOND
A.  INVESTMENT COST

    Construction 	               $12,000              $200
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	                94,500             1,000
    Monitoring equipment
    in place	                 9,000
    Engineering design
    and inspection	                23,100               240
    Incidentals, overhead,
    fees, contingencies...                23,100               240
    Land	                 3,000

    TOTAL INVESTMENT COST               $164,700            $1,680

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.                $8,000
    Energy	                    50
    Chemicals	                 1,600               135
    Maintenance	                16,170               168
    Taxes and insurance...                 4,941                50
    Residual waste
    disposal	                   200
    Monitoring, analysis
    and reporting	                 2,500             1,250

    TOTAL OPERATION AND
    MAINTENANCE COST                     $33,461            $1,603

C.  AMORTIZATION OF
    INVESTMENT COST                      $26,308              $273

    TOTAL ANNUAL COST                    $59,769            $1,876


    *First level represents the base cost of treatment system.
    Other levels represent the incremental cost above base cost.
                                     540

-------
 80 h
§60[-
o







                                                     | LEVEL #1
         IEVEL
#2!
 30
            ICH
 20
        I  i
        I  I
 10
                                                                                   I  i
                                     I
                           2345

                            PRODUCTION,  METRIC TONS/YEAR X 1000
           Figure 22-7.   Relationship of annual treatment cost to production for

                         the Nickel Sulfate Subcategory
                                            541

-------
  40
  30
to-


EH
 I 20
      T~tT
                \T
                 w
K
 \\i
                       \\
        w
         IV
             JS
                                           ^x
                                JLBVEL J2
  10
                                       LCVSIj #1
               12345

                          PRODUCTION, METRIC TONS/YEAR X 1000
            Figure 22-8.  Relationship of annual unit treatment cost to production

                          for the Nickel Sulfate Subcategory
                                     542

-------
                TABLE  22-13   MODEL PLANT TREATMENT COSTS
Subcategory  NICKEL SULFATE
                             Type of  Regulation  BAT
                                           Annual Treatment Costs ($/kkg)
                                                 LEVEL OF TREATMENT

                 PRODUCTION  FLOW      FIRST     SECOND    THIRD    FOURTH
                  (kkg/yr)  (m3/day)      $         $         $         $
Annual Operation
and Maintenance
Annual
Amortization
Total Cost
  900
4,000
7,000
  900
4,000
7,000

  900
4,000
7,000
 3
11
18
 3
11
18

 3
11
18
21.09
 6.01
 4.78
11.26
 3.
 3.
                                          89
                                          76
32.35
 9.90
 8.54
1.62
0.38
0.23
0.25
0.06
0.04

1.88
0.43
0.27
Not Applicable
                                 543

-------
                          SECTION  23


                    SILVER NITRATE  INDUSTRY



23.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL


23.1.1 Industry Profile and Analytical  Results

    Most of the silver nitrate  produced  is  for   captive use  in
the photographic industry-  It  is also  used  in  the manufacture of
silver salts, mirrors, for silver plating,  coloring porcelain and
as a chemical reagent.

    The industry profile data  is   given   in  Table  23-1,   while
existing regulations are summarized  in  Table  23-2.

    Priority pollutants  found  at   significant   levels  during
sampling ab Plant #609 were:


                    Concentration  (ug/1)
    Pollutant      Screening   Verification
    Silver            164                65
    Cyanide           580               470
    Silver was not  found  at a  significant  concentration during
verification sampling of the same  plant.    However,  a significant
level of cyanide was found again.  The  source  of  cyanide was found
to be  from a soaking solution  which   is  used   to remove  silver
nitrate stains from  workers'  clothes.  This solution is sent to
the  silver  recovery  treatment  system.    When   plant  personnel
discontinued  this   practice   cyanides    disappeared  from  the
effluent.

    Action on this subcategory   has   been deferred  in accordance
with Paragraph 8 of the Settlement Agreement.   A new subcategory
including all silver compounds v/illbe  reviewed  under Phase II BAT
review.
                              544

-------
TABLE  23-1
SUBCATEGORY iPRQFZLE .DATA .SUMMARY
SUBCATEGORY
SILVER NITRATE
Total  subcategory capacity rate
Total  subcategory production rate
Number of plants in this  subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Miniirtum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                            35,000 kkg/year
                                 7
                                 2
                             6,507 kkg/year
                             3,256 kkg/year

                                 9 percent

                                50 kkg/year.
                             3,206 kkg/year
                                20 years
                                64 years

                                <1 cubic meters/day
                                38 cubic meters/day

                                 1 cubic meter/kkg
                                 4 cubic meters/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  545

-------
23-2 -
SDBCATEGOKf

SUBPAKT
                EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES
            Silver Nitrate

            BA  (40CFR  415.530, 5/22/75)
                                       STANDARDS
Product
Process
      Para-
      meters
     BPCTCA
Max.1
kg/kkg
 (mg/1)
              BATEA             NSPS
    2
Avg.      Max.    Avg.      Max.     Avg.
k/kkg     k/kkg  k/kkg     k/kkg    k/kkg
 (mg/1)     (mg/1)  (mg/1)     (mg/1)   (mg/1)
AgNCL
      Ag


      TSS
0.009
(6.0)*

0.069
(46.0)
0.003
(2.0)

0.023
(15.3)
 wax,  = Maximum of any one day.
 o
 Avg.  = Average of daily values for thirty consecutive days shall not exceed.
 *flow basis  1500 1/kkg.
                                   546

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                          SECTION 24


                   SODIUM BISULFITE INDUSTRY



24.1 ASSESSMENT  OF THE WATER POLLUTION  POTENTIAL


24.1.1 Industry Profile and Analytical Results

    Sodium Bisulfite is manufactured both  in liquid  and  powdered
form.  Captive use. is very small.  Sodium bisulfite   is   used   in
the manufacture  of  photographic chemicals,  organic  chemicals,
textile and in food processing.  It  is   also  used  in the tanning
industry  and in the sulfite process for the manufacture  of paper
products..

    The industry profile data are   given   in   Table   24-1, while
existing regulations are summarized  in Table 24-2.

    Priority pollutants found  at significant  levels in  the  raw
waste during sampling at Sodium Bisulfite Plants  were as  follows:
                             Maximum
    Pollutant       Concentration  Observed  (ug/1)
                  Screening        Verification (2  Plants)
Copper
Zinc
Cadmium
Chromium
Antimony
Lead
Mercury
Nickel
Silver
375
2,430
6
17
30
8
3
250
2
926
3,600
41
3,360
650
1,050
16.
455
<30






7


    A summary of daily and unit  product  raw waste  loads for all
plants  sampled  can be  found   in   Table 24-3.   Individual plant
raw waste loads per unit product  found   in sampling can be  found
in Table 24-4.

    The total  annual  production   rate  for this  subcategory is

                              547

-------
TABLE  24-1
SUBCATEGOEY PROFILE DATA SUMMARY
SUBCATEGOKY
                      SODIUM BISULFITE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum.
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                                 9
                                 2
                            46,000 kkg/year
                            28,300 kkg/year
                             4,700 kkg/year
                            23,600 kkg/year
                            17,800 kkg/year
                            16,900 kkg/year
                               62 percent

                                4 years
                               19 years

                                3 cubic meters/day
                              100 cubic meters/day

                              <<1 cubic meter/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce,  Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   548

-------
TBBLE 24-2 -     EXISTING REGULATIONS  -  EFFLUENT L3METATICN GUIDELINES
                 Sodium Bisulfite

SUBPAKT           BB (40CFR  415.540, 5/22/75)
                                       STANDARDS
                          BPCTCA            BAIEA             NSPS
                     Max.      Avg.       Max.    Avg.      Max.     Avg.
 Product     Para-     kg/kkg    k/kkg     k/kkg  k/kkg     k/kkg    k/kkg
 Process     meters     (mg/1)     (nig/1)     (mg/D  (mg/D     (mg/1)   (mg/1)


           Reserved      Reserved         Reserved         Reserved
 Max, = Maximum of any one day.
 Avg. = Average of daily values for thirty consecutive days  shall  not exceed.
                                   549

-------
TABLE 24-3.
SUMMARY OF RAW WASTE LOADINGS FOUND  IN SCREENING AND VERIFICATION SAMPLING

SUBCATEGORY
Pollutant
Priority
Antimony, Sb
Cadmium, Cd
<-n Chromium, Cr
01
0
Copper, Cu
Lead, Pb
Mercury, Hg
Nickel, Ni
Zinc, Zn
Conventional -
TSS
COD
SODIUM BISULFITE
Minimum

0.00045
0.00023
0.018
0.005
0.000091
0.000091
0.0032
0.016
3.20
54.4
kg/day
Average

0.0018
0.0003
0.54
0.011
0.0045
0.00021
0.0068
0.18
12.9
117
Maximum

0.0041
0.00041
1.05
0.015
0.0095
0.00045
0.0091
0.42
25.4
234
Loadings
Minimum

0.000007
0.000004
OT0003
0.00007
0.000007
0.000001
0.00005
0.0002
0.21
1.33
kg/kkg
Average

0.000052
0.00001
0.011
0.00046
0.000092
0.000006
0.00031
0.0053
0.27
2.94
Maximum

0.00008
0.000017
0.022
0.001
0.0002
0.00001
0.0007
0.0088
0.38
4.04
No. of Plants
Averaged

2
3
2
2
3
2
3
3



-------
     24-4.-    PRIORITY POLLOTANT  RAW V&STE LOADS  (in kg/kkg of Product)
      SODIUM BISULFITE
SUBCATEGORY
POLLUTANT
         PLANT
                          #282
               # 987
                  #586
Copper, Cu



Zinc, Zn



Cadmium, Cd



Chromium, Cr



Lead, Pb



Mercury, Hg



Nickel, Ni



Antimony, Sb
0.001




0.007




0.000017








0.000007



0.000007




0.0007




0.00007
0.00007




0.0002




0.000004




0.0003



0.00007




0.000001



0.00005



0.000007
0.0002




0.0088




0.00001




0.022




0.0002




0.00001




0.00017




0100008
                                    551

-------
unavailable  at  this  time.     Therefore,
pollutant  waste loads  generated   by  this
calculated and presented.
                                        the  total
                                         industry
  priority
cannot  be
24.1.2 Process Waste Sources  a_nd  Waste Water Treatment Dajta


General Process Description

     Raw material and process  -   Sodium bisulfite  is produced by
reacting sodium  carbonate   (soda  ash)   with  sulfur dioxide and
water.  The reaction is:
Na2C03
              2S02 + H20  =  2NaHS03  +C02  (1)
     This reaction produces  a  slurry of sodium bisulfite crystals
which can  be  sold,  but  which   is  usually  processed  to form
anhydrous   sodium  metabisulfite.     This  requires  thickening,
centrifuging, drying, and  packaging  operations.


Water Use and Waste Source Inventories

     Water uses -  Direct  process  contact water is used to slurry
the  sodium carbonate for  the  reaction.  Noncontact cooling water
is another water  use at one plant.    Water is also used for pump
seals,  maintenance and washdowns.   Table 24-5 gives a summary of
water  usage at  the  plants for   which 308  Questionnaires  were
avaliable.

     Waste Sources - Noncontact cooling water from the centrifuge
is  a  source  of waste  at  one plant.  However,  direct  process
contact water is  the  main  source  of waste water which  must be
treated,  together  with   miscellaneous wastes such as water used
for maintenance purposes,  washdowns, and spill cleanup.


Control and Treatment Practices

     The Best Practicable  Control  Technology has been identified
as  neutralization with  caustic   soda  followed by  aeration and
filtration. Aeration removes  the  reduced sulfur compounds which
contribute to a high COD in  the raw  waste.
     Plant
blows  air
d ischarged
      #987 adds 50 percent  caustic  to  the oxidation tank and
       through  while mechanically  agitating.    The waste is
      to a river following  the  17-hour retention period.
     Plant #282   uses   caustic   soda or  sodium carbonate  for pH
control  followed  by   sodium  hypochlorite  addition  to  oxidize
                               552

-------
       WATER USAGE IN THE SODIUM BISULFITE SUBCATEGORY
       Direct Contact Process  Noncontact Cooling    Maintenance

                3 ,.,                 3 ,              WasMowns, etc.
               m /kkg              m /kkg               J
   	m /kkg	



#Z              0.872                3.85               0.843



#5               NA                 NA                NA



#9              1.15                 0                 0.397
NA Bailable
                             553

-------
sulfite and  other reduced   sulfur   species.   The waste  is then
neutralized and discharged  to  a  County sewer.

     Plant #586  mixes   the bisulfite  waste  with waste from an
amine plant, and  ZriS04  production  wastes,  and truck wash  waste.
Lime  is added to the wastes  which are  then passed  through an
aeration  tank  with  eight-hour's  retention time.   The  treated
waste goes through  primary and secondary   settling before final
di scharge.

     Plant #282  was  visited   in  the  screening  phase  of the
program. The  bisulfite   waste  is  treated  on a batch basis every
two or three days.   Sodium hypochlorite is added to the waste to
oxidize the sulfite.  The   oxidized  sulfite waste  is mixed with
wastes  from  an  organic   chemical  plant   and neutralized. The
combined wastes are then discharged to a sewer.  Table 24-6 shows
the  flow data and pollutant  emissions,  while Figure 24-1 gives
the process flow diagram and  shows  the sampling points  used in
screening .

     In verification,  two  plants were  visited,  namely #586 and
#987. At Plant #586 the  sodium bisulfite wastes are combined with
many  other  process wastes and  they are treated together.  Figure
24-2 shows the  flowsheet and  the  points  sampled.   Table  24-7
gives  the  pollutant  emissions and  flow  data  for  the waste
streams.  The  filter wash   is the   main  process waste  at Plant
#987.  This waste is neutralized with caustic  soda to pH  9 - 10
to convert  the bisulfite waste  to  sulfite.  The sulfite  is then
oxidized  with  air to   sulfate.   The treated  waste,  including
solids, is discharged to a  river.  Table 24-8 shows the pollutant
emissions  and  flow data   for the  waste streams sampled.  Figure
24-3 shows the process flow diagram and sampling points at   Plant
#987.
Evaluation of Production  and  Waste Flow Data

     Screening and   verification  sampling  showed   significant
levels  of  zinc   in  the  waste streams.   Plants  #987 and #586
effectively treated  the wastes  to remove the zinc.   Plant  #282
did not remove the  zinc   from  the waste stream.   This plant was
the smallest producer  of  sodium bisulfite of the  plants sampled.
The waste flows   varied from  0.102 m3/kkg for'#987 to 9.68 m3/kkg
at #586.
Model Plant Selection

     Waste water   flow  -   The  sources of waste water include wet
air  scrubbers,   Eilter  backwash,  floor  washings,  leaks,  and
spills. The unit  flow  rates ranged from O.lm3/kkg to 0.3ra3/kkg of
product at  the three   plants for  which 308  Questionnaires were

                               554

-------
   24-6.   FLOW AND POLLIJTANT CONCENTRATION DATA OF THE SAMPLED WASTE
           STREAMS FOR PLANT #282 PRODUCING SODIUM BISULFITE
Waste Stream
Untreated waste
Treated waste
TABLE 24-7. FLOW
Flow TSS COD Zn Cu
m3/kkg kg/kkg kg/kkg kg/kkg kg/kkg
2.67
2.67
AND POLLUTANT
STREAMS FOR PLANT
0.237 4.04 0.0067 0.001
0.424 2.61 0.0068 0.00085
CONCENTRATION DATA OF THE SAMPLED WASTE
#586 PRODUCING SODIUM BISULFITE

Waste Stream
MBS Sump #1
MBS Sump #2
Mine Oxidation
Pond
Flow
m3/kkg
9.68
9.68
2.77

ZnS04 Pond Effluent 78.54
Lime Treatment
Influent
Truck Washdown
S02 Wastes
Final Treated
TSS COD Zn Cu
kg/kkg kg/kkg kg/kkg kg/kkg
0.191 1.12 0.0067 0.011
0.051 0.455 0.0025 0.00031
2.43 2.33 0.0031 0.00028

11.85 0.759 1.38 0.0022
109.7 10.76 28.55 - 0.0040

0.134
85.86
188.3

0.0117 0.0975 0.00517 2.69xlO~6
1.97 52.5
4.27 21.70
Effluent
                                555

-------
                                                                                                              MR
         SUBLIMED
          SULFUR
Ul
Ln
CTi
             Waste streams sampled.
                                                                                                                                     TO SEHER
                                               COOLING
                                                WASTE
                                                            MISCELLANEOUS    SODIUM
                                                                WASTE        I1YKC1ILORITE
 OflGANIC
CHEMICAL
 WASTES
                                               Figure 24-1.   General process flow diagram at Plant #282showing the sampling points.
                                                                                   Sodium Bisulfite Manufacture

-------
                                                            AND »2
LTI
LH
                                             Waste streams sampled.
                                                                                         AMINE PLANT
                                                                                      OXIDATION TANK
                                                                                                  S3
                                                                                       LIME TREATMENT
                                                                             AIR
                                                                                         AERATION TANK
                                                                                      PRIMARY SETTLING
                                                                                                                  14
                                                                                                                               SO2 AREA DRAINS
                                                                                                                               TRUCK  WASHDOWN
ZnS04 PLANT
                                                                                                                                        WASTE
                                                                                                                                Zn SETTLING POND
  POLISHING
SETTU1NG TANK
                                                                                                                                                              OLTIFALL
                                                          Figure 24-Z.   General fj.ow diagram at  Plant K586 showing the sanpling points.
                                                                                      Sodium Bisulfite Manufacture

-------
TABLE 24-8.   FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WAS1E
              STREAMS FOR PLANT #987  PRODUCING SODIUM BISULFITE
Waste Stream Flow
m.3/kkg
No. 1 filter
Floor wash,
etc.
No. 2 Filter
Wash
spills,

Wash
Treatment Influent
(1+2+3)

54 Hour Aeration
Treated Effluent
0
0

0
0

0
0
.051
.0123

.0386
.102

.133
.133
TSS
kg/kkg
0
0

0
0

0
0
.113
.0457

.0052
.315

.375
.0031
COD
kg/kkg
1.
0.

0.
3.

1.
1.
42
299

908
46

19
02
Zn
kg/kkg
7
4

3
2

2
7
.lxlO~5
.4xlO~5

.9xlO~5
.4xlO~4

,4xlO~4
.99xlO~7
Cu
kg/kkg

1.8xlO~5
1.11x10

3.57x10
-5

-5
7.5xlO~5

7.5xlO~
3.6x10"

5
5
                                   558

-------
                                       TO ATMOSPHERE
U1
cn
                                                                                                                                   FILTER WASH
               AJKALINE SLURRY
ANHYDROUS SODIUM
    BISULFI1E
                                                                                                                                               II  AND 13
                                            DRAINS, DRIPS,
                                          SPILLS, WASHDOWNS
                  OUTFALL TO RIVER
                                                                                                  NaOH     AIR
                                                         Figure 24-3.   General process flow diagram ah Plant J987  showing the sanpling points.

                                                                                             Sodium Bisulfite Manufacture

-------
available.  The average was
used for tne model plant.
                  approximately 0.2m3/kkg and this
                                                   was
     Production - Sodium   bisulfite  production  ranges  from 4770
kkg/yr to31,800 kkg/yr at   the  three plants for which data was
available.    The  average   production  is  17,800  kkg/yr.   The
production rates at the three plants were used as the model  plant
production rates.  The  operational  mode  is  continuous  and  is
assumed to run 350 days per  year.

     Sol id wastes -   In  the  production of sodium bisulfite and
process waslfe(Treatment there is  little solid waste  generation,
although precipitation  of   zinc   hydroxide may  result in  small
quantities of filter  cake   requiring disposal.  The model plants
assumed no significant solid waste production.
     T
pH to  9-5.
waste.  For
to be 0.195
	 chemicals -  Caustic   soda is needed to adjust  the
 The only other   requirement  is air to  oxidize  the
the  model plant,  the caustic soda dosage was assumed
kg//kkg.
24.2 TECHNOLOGY BASED  POLLUTION  ABATEMENT
24.2.1 Advanced Level  Treatment  Applications
Priority Pollutants to  be  Controlled

     Priority pollutants should  not normally be present in wastes
originating solely from the  manufacture of sodium bisulfite  from
sodium  carbonate and sulfur dioxide.   However,  it  is  reported
that some  sources  of  sodium  carbonate  contain  zinc and other
trace metals in measurable amounts. Therefore,  a treatment system
to control zinc is proposed. If   no  zinc is  found at a specific
plant,  Levels  2 and   3   of  the treatment models  would not be
necessary.

     Dissolved zinc  was found in  some  sodium  bisulfite  waste
waters during  the  sampling  program.   Since no  use of zinc was
found in the  process,  it  might be assumed that  zinc enters the
waste stream  by  corrosion   of  galvanized  metals, by  coproduct
operations  or  from  nonprocess  zinc   compounds   used  by the
industry.
Removal Technologies  Available
     Zinc  is
10.0 or when
can also be
 readily
   reacted
 adsorbed
precipitated at  pH values  between 8.4_and
 with sulfides in various  forms.  Zinc ions
from  clarified solutions  by   ion  exchange
                               560

-------
resins and precipitated by starch  xanthates.


Selection of Appropriate Technology

    In addition  to  controlling   zinc,   the  treatment  process
selected must control the COD  associated  with bisulfites.

    BPT  (Level lj_ - Batch aeration  at  pH  9.5 was chosen as  the
most cost-effective method of   lowering the  COD associated  with
the primary pollutant, sodium  bisulfite.   Solution  of  C02  from
the air during aeration reduces the  ph  below 9 before discnarge.

    Level 2_  -  Aerated  effluent  from   the  BPT   system   is
chlorinated to  complete  COD  removal,  and  is  then  filtered to
remove  finely  divided  suspended  matter  carried  through   or
produced  in the BPT  system,  particularly if zinc is present  in
the incoming wastes.

    Level 3_ - Ferrous sulfide is  applied  ahead of  the Level  2
dual media filter,  to precipitate any  residual zinc by the  more
effective sulfide process.


Flow Diagrams

    Level 1                     Figure  24-4

    Level 2                     Figure  24-5

    Level 3                     Figure  24-6

    Wastes are  treated  in   daily   batches,  followed  by  con-
tinuous   cumulative  aeration   and  weekly   filtration  of  five
accumulated  daily   batches,    to  suit   a   five-day,  40-hour
production schedule.

    Equipment Functions^  -   In  Level   1,  the  raw  wastes  are
received  in  a one~day holding  tank,  adjusted  to pH  9.5  with
caustic soda and jet aerated  by recirculation of the daily batch.
At the end of each  day the  batch is transferred  to  a reaction
tank  sized for one week's  flow, which  is continuously aerated by
recirculation  tiirough air  aspirators.  On  the  sixth  day  the
aerated weekly batch is discharged  directly (Level 1) or tiirough
a dual   media filter   (Levels 2 and 3).    At Level  2 continuous
aeration  is terminated  early  on  the sixth day and  the weekly
batch   is recirculated  through  the hydraulic eductor  of a  gas
chlorinator  to oxidize any residual  COD.   At Level  3, ferrous
sulfide is added  before  filtering,  to  precipitate any residual
zinc,   if  COD  limits can  be  consistently met  by  long-period
aeration,  and  if  zinc  is  not  found in  the  raw  wastes, the
advanced  levels of treatment  would serve  no purpose.

                              561

-------
en
to
                CAUSTIC SODA
                   RAW
              WASTE WATER
                                              AIR
HOLDING

 TANK
                                                                                                     * EFFLUENT
                                                   REACTION TANK
                              Includes flow monitoring, pH monitoring, and sampler.
        Figure 24-4.  Waste water treatment Level 1 for sodium bisulfite  subcategory - batch
                                                                      process

-------
Ul
Ch
U)
                    CAUSTIC SODA
                                   r~
                                                            BACKWASH
               RAW
                WASTE WATER
                                                 44-
                                                                      CHLORINATION
                                                      -AIR
HOLDING
  TANK
                                                                           	-Qi-
                                                      •N-
                                                             REACTION TANK
                       *  Includes flow monitoring, pH  monitoring,  and sampler.
                                                                                FILTER
                                                                                                                           EFFLUENT
                                     Figure 24-5.   Waste water treatment Level 2  for sodium bisulfite subcategory - batch process.

-------
en
                                                                      FERROUS
                                                                      SULFATE
  SODIUM
BISULFIDE
                         CAUSTIC SODA
                                                    BACKWASH
                                                                   CHLORINATION  ,
         f*"           Jj_
                    -«*

RAW
'1
1
1
t
— . — «- — — ^ N^.


•Q^
X


•*— AIR

-------
    Chemicals a_nd_ Hailing - Caustic  soda  solution, chlorine and
ferroHs suit ide~ are usecT  in the  treatment processes. Caustic soda
and chlorine, are  common  industrial  chemicals which  are fed by
conventional equipment  designed   to   minimize leaks, spills, and
hazards  to  personnel.   Ferrous  sulfide  is  prepared  by mixing
ferrous  sulfate  with  sodium   bisulfide  under  well-ventilated
conditions.  When the  usual precautions  are taken in the proper
handling of  corrosive  and  toxic  chemicals,  there should be no
special problems in applying the  proposed technologies.

    Separation a_nd_ Removal gjf Sol ids   - No solids are formed  in
the proposed  treatment,  with the   possible  exception of  small
amounts  of  zinc  hydroxide  and  zinc  sulfide  in  the  filter
backwash,  if  zinc should be present  in the raw  wastes.  In that
event,  the  precipitated solids   returned   to the  holding  tank
during  backwashing will  settle   in   the  hopper  bottom  of the
reaction   tank.  As necessary, these  solids can be drawn off to a
small earthen drying bed,  where  liquids will drain into the soil
and the insoluble zinc compounds  will  remain at the site.

    Monitoring Requi rements  -   Internal process monitoring will
be done   with standard field  equipment measuring  pH, dissolved
oxygen and chlorine.   If  zinc  is present in the raw materials, a
periodic laboratory analysis for  zinc  should be made on the final
effluent.   Monitoring    for  dissolved  sulfide  should  not  be
necessary, since  excess  sulfide  will react with iron from  the
ferrous sulfate applied in Level  3,  oxidizing to insoluble ferric
sulfide.


24.2.2 Estimated Performance of  BPT Systems

    Waste waters  from the production  of  sodium  bisulfite  are
characterized by high  concentrations  of COD and small flow rates.
The  COD load  results from the  presence  of product  material in
filter  wash   waters  and  general    maintenance  arid   cleanout
operations.

    Raw waste  loads  found  in  screening  and  verification were
presented  above.  The  only priority pollutant which might require
regulation is zinc.  Although zinc   was found in all three of the
plants sampled, its source has not  been determined.

    BPT technology  has  been specified  as extended aeration to
oxidize  COD.  This  technology  should achieve 95 percent removal
of COD. Treated effluent  quality and  treatment practices at three
plants are presented in Table 24-9.
                              565

-------
 TABLE 24-9.    TREATMENT PRACTICES AND VERIFICATION SAMPLING AT SODIUM
                BISULFITE PLANTS
 Plant  Treatment
              Treated Effluent
    TSS              COD               zn
rag/1   kg/kkg    rag/1    kg/kkg    mg/1    kg/kkg
#282    Caustic neutral-
        ization sodium
        hypochlorite
        oxidation
    ^
#586    Lime pH adjust-
        ment aeration,
        and settling
159    0.424     979     2.61      2.54    0.0068  2.
 22.7  —
115.3
0.059  —
   Combined treatment with other process wastes.
                                    566

-------
Base Level  Performance Characteristics  for  Conventional Pollutant
Removal

    Based  on   a  95  percent  COD removal  efficiency by  extended
aeration,   implementation  of  3PT   technology  will  achieve the
effluent quality  presented in Table  24-10.


Base Level  Performance for Priority  Pollutant Removal

    Table  24-10   also  presents   effluent  quality  achievable
through  implementation of BPT for zinc.


Pretreatment  Applications

    One plant   manufacturing   sodium    bisulfite   presently
discharges   to  a  POTW.   Since the  major  pollutants  in  this
subcategory,      TSS and  COD, are   compatible with  conventional
sewage treatment, BPT  technoloy is  applicable  for pretreatment.
Also,  since   waste   water   flow  volumes   are  small  in   this
subcategoy, limitations for suspended solids can be increased for
pretreatment.


24.2.3 Estimated  Performance  of Advanced  Level Systems


Advanced  Level  Performance  Estimates   for  BPT   and  Priority
Pollutant Removal

    Table  24-11  and 24-12 presents  estimated achievable effluent
quality through implementation of these  technologies.
Pretreatment Applications

    As discussed  earlier,   BPT   technoloy  is  recommended
pretreatment of sodium bisulfite  wastes.
                                                           :o r
New
Source  Applications
    Examination of  the  alternative   treatment   technologies
proposed  for  this subcategory   has led to  the conclusion  that
Level  2  technology  is  applicable  to  new  sodium   bisulfite
facilities.
                              567

-------
           TABLE 24-10  CONTROL PARAMETER LIMITATIONS
                 SUBCATEGORY:  Sodium Bisulfite
                      Level  of Treatment: 1
                  Waste Water  Flow: 0.2 m3/kkg
Pollutant
Subcategory
Per formance
  (mg/1)
      Quality  Limit
  (1)     (mg/1)
VFR   	
      30 day   24 hr
       Aver    Max
                                                    Emission Limit
                                                        (kg/kkg)
                                                    30 day  24 hr
                                                     Aver    Max
BPT Pollutants:

Total Suspended    23(2)
Solids, TSS

Chemical Oxygen    980(2)

Demand, COD

Proposed Priority
Pollutants

Zinc, Zn         0.2(2)
              2.0     37.5     75    0.0075  0.015
              2.0    500     1000    0.10    0.20
              2.0
        0. 5
1.0  0.0001  0.0002
   (1) - VFR: ratio of  the  24  hour variability factor to the
            30 day variability factor.

   (2) - Verification sampling
                               568

-------
          TABLE 24-11  CONTROL  PARAMETER LIMITATIONS
                SUBCATEGORY:  Sodium Bisulfite
                     Level  of Treatment: 2
                 Waste Water  Flow: 0.2 m3/kkg
Pollutant
Treatability
   (mg/1)
     Quality  Limit
 (1)     (mg/1)
VFR   	
     30  day   24  hr
      Av e r     Max
                                                    Emission Limit
                                                       (kg/kkg)
                                                    30  day  24 hr
                                                     Av e r    Max
BPT Pollutants :

Total Suspended      15
Solids, TSS

Chemical Oxygen     100
Demand, COD

Proposed Priority
Pollutants

Zinc, Zn             0.4
               2.0    15
               2.0   100
               30     0.003   0.006
              200    0.02    0.04
               2.0
        0.4
0.8  0.00008 0.00016
  (1) - VFR: ratio of  the  24 hour variability  factor to the
           30 day variability factor.
                               569

-------
           TABLE 24-12  CONTROL  PARAMETER LIMITATIONS
                 SUBCATEGORY:  Sodium Bisulfite
                      Level  of Treatment: 3
                  Waste Water  Flow:  0.2 m3/kkg
Pollutant
Treatability
  (mg/1)
      Quality Limit
  (1)     (mg/1)
 VFR   	
      30 day  24 hr
       Av e r    Ma x
                                                    Emission Limit
                                                        (kg/kkg)
                                                    30 day  24 hr
                                                     Aver    Max
BPT Pollutants;

Total Suspended    15
Solids, TSS

Chemical Oxygen    100
Demand, COD

Proposed Priority
Pollutants
Zinc, Zn
     0.2
              2.0     15
              2.0    100
2.0
0. 2
               30    0.003   0.006
              200    0.02    0.04
0.4  0.00004 0.00008
  (1) - VFR: ratio of  the  24  hour  variability factor to the
            30 day variability factor.
                               570

-------
24.2.4 Cost Estimates
Discussion

    The cost  estimates   of   three   models  having   different
production levels are presented  in  Tables 24-13,  24-14 and 24-15.
Annual  costs  for  three  treatment   levels  as   a  function  of
production are shown graphically  in  Figure 24-7.   Treatment cost
oer metric ton of product  is shown  in Figure 24-3.
    Table 24-16 gives a su^iiaary   of  the  unit cost  distribution
between afaortization operation  and maintenance.   Cost components
at various production and  levels  of treatment are also shown.
Summary

    Cost estimates  developed  for  the  first level  of treatment
indicate  that  labor and   amortization  cost  has  a significant
impact on the total annual   costs.   At the second and third level
of treatment,  for low production,   operation and maintenance has
a significant  impact on   the  additional annual costs.  At medium
and high production, amortization  and  operation and maintenance
costs constitute the major  portion  of the additional costs.
                              571

-------
                    TABLE 24-13. MODEL  PLANT TREATMENT COSTS

   Subcategory  SODIUM BISULFITE                      Type of Regulation  BAT

   Production         4,770 metric  tons per  year (    5,258 tons per year)
                         13 metric  tons per  day  (       15 tons per day )
   Waste water flow     2.8 cubic meters per day.


                                                  LEVEL OF TREATMENT*

                                          FIRST          SECOND          THIRD
A.  INVESTMENT COST

    Construction 	               $5,550          $1,650         $1,750
    Equipment in place,
    including piping,
    fittings, electrical
    work and controls	               47,800          20,500         16,200
    Monitoring equipment
    in place	                9,000
    Engineering design
    and inspection	               12,470           4,430          3,590
    Incidentals, overhead,
    fees, contingencies...               12,470           4,430          3,590
    Land	                1,800

    TOTAL INVESTMENT COST               $89,090         $31,010        $25,130

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.              $15,000          $1,000         $2,000
    Energy	                1,600              60             75
    Chemicals	                  400           1,200          1,210
    Maintenance	                8,729           3,101          2,513
    Taxes and insurance...                2,672             930            753
    Residual waste
    disposal	
    Monitoring, analysis
    and reporting	                2,500           1,250          1,250

    TOTAL OPERATION AND
    MAINTENANCE COST                    $30,901          $7,541         $7,801

C.  AMORTIZATION OF
    INVESTMENT COST                     $14,202          $5,045         $4,088

    TOTAL ANNUAL COST                   $45,103         $12,586        $11,889


    *First level represents the  base  cost of treatment system.
    Other levels represent the  incremental cost above base cost.
                                     572

-------
                TABLE  24- 14. MODEL PLANT TREATMENT COSTS
Subcategory  SODIUM  BISULFITE
Production
                                                  Type of  Regulation  BAT
                  16,900  metric tons per year  (  18,632 tons  per  year)
                      48  metric tons per day   (      53 tons  per  day )
Waste water flow      10  cubic meters per day.
                                               LEVEL OF  TREATMENT*

                                      FIRST          SECOND           THIRD
A.  INVESTMENT COST

   Construction 	
   Equipment in place,
   including piping,
   fittings, electrical
   work and controls	
   Monitoring equipment
   in place	
   Engineering design
   and inspection	
   Inc identals, overhead,
   fees, conting enc ies...
   Land	

   TOTAL INVESTMENT COST

B.  OPERATION AND
   MAINTENANCE COST

   Labor and supervision.
   Energy	
   Chemicals	
   Maintenance	
   Taxes and insurance...
   Residual waste
   disposal	
   Monitoring, analysis
   and reporting	

   TOTAL OPERATION AND
   MAINTENANCE COST

C.  AMORTIZATION OF
   INVESTMENT COST

   TOTAL ANNUAL COST
                                     $8,500



                                     82,400

                                      9,000

                                     19,980

                                     19,980
                                      1,800
                                   $141,660
                                     $15,000
                                       3,100
                                       1,340
                                      13,986
                                       4,249
                                       2,500


                                     $40,175


                                     $22,755

                                     $62,930
                                                      $4,100



                                                      37,150



                                                       8,250

                                                       8,250
                                                     $57,750
                                                      $1,000
                                                          90
                                                       2,560
                                                       5,775
                                                       1,732
                                                       1,250
                                                     $12,407


                                                      $9,395

                                                     $21,802
 $4,200



 28,150



  6,470

  6,470
$45,290
 $2,000
    110
  2,600
  4,529
  1,358
  1,250


$11,847


 $7,368

$19,215
 *First level represents the base cost  of  treatment system.
 Other levels represent the incremental cost  above base cost.
                                 573

-------
                    TABLE  24-15.MODEL PLANT TREATMENT COSTS

   Subcategory  SODIUM BISULFITE                      Type of Regulation  BAT

   Production        31,800 metric  tons per year (   35,059 tons per year)
                         90 metric  tons per day  (      100 tons per day )
   Waste water flow     19 cubic meters per day.


                                                   LEVEL OF TREATMENT*

                                          FIRST          SECOND           THIRD
A.  INVESTMENT COST

    Construction  	              $12,400          $6,250          $6,450
    Equipment in  place,
    including piping,
    fittings, electrical
    work and controls	              123,900          63,700          64,400
    Monitoring equipment
    in place	                9,000
    Engineering design
    and inspection	               29,060          13,990          14,170
    Incidentals,  overhead,
    fees, contingencies...               29,060          13,990          14,170
    Land	                3,000

    TOTAL INVESTMENT COST              $206,420         $97,930         $99,190

B.  OPERATION AND
    MAINTENANCE COST

    Labor and supervision.              $15,000          $1,000          $2,000
    Energy	                6,200              90            132
    Chemicals	                2,700           4,840           4,910
    Maintenance	               20,342           9,793           9,919
    Taxes and insurance...                6,192           2,937           2,975
    Residual waste
    disposal	
    Monitoring, analysis
    and reporting	                2,500           1,250           1,250

    TOTAL OPERATION AND
    MAINTENANCE COST                    $52,934         $19,910         $21,186

C.  AMORTIZATION  OF
    INVESTMENT COST                     $33,095         $15,933         $16,138

    TOTAL ANNUAL  COST                   $86,030         $35,843         $37,324


    *First level  represents the  base cost of treatment system.
    Other levels  represent the  incremental cost above base cost.


                                     574

-------
 120
 no
 100
  90
                                                                 LEVELS ±2
11.
o
§80
                                                                      HEVEI
                                                                            #1
  60
                     \
  50
           !   !cr
  40
       !    i
  30
                             0       "'15          20         25
                            PRODUCTION, METRIC TCNS/YEAR x 1000
                                                                           M
                                                                                       35
            Figure 24-7. Variation of annual treatment cost with production for the
                          Sodium Bisulfite Subcategory
                               575

-------
12
11
10
•to-

EH
      I  !
      i  r
                    I  !
                              \
                           \!   IV  •
                             \!\
                               \T\
                                 XT'
                                       X
                                                   \L 1EVEILS
        I  I   I
                     I  I   !
                             i   i  !
                          10          15          20          25
                           PRODUCTION, METRIC TONS/YEAR X 1000
           Figure 24-8.  Variation of annual unit treatment cost with production
                         (Sodium Bisulfite Manufacture)
                                 576

-------
                 TABLE 24-16   MODEL PLANT TREATMENT COSTS
Subcategory  SODIUM BISULFITE
                              Type  of Regulation  BAT
                                           Annual Treatment  Costs  ($/kkg)
                  PRODUCTION  FLOW
                  (kkg/yr)  (m3/day)
Annual  Operation
and Maintenance
Annual
Anortization
Total  Cost
 4,770
16,900
31,800
 4,770
16,900
31,800

 4,770
16,900
31,800
 3
10
19
 3
10
19

 3
10
19

FIRST
$
6.48
2.38
1.66
2.98
1.35
1.04
9.46
3.72
2.71
LEVEL OF
SECOND
$
1.58
0.73
0.63
1.06
0.56
0.50
2.64
1.29
1.13
TREATMENT
THIRD
$
1.83
0.81
0.67
1.11
0.57
0.51
2.94
1.38
1.18
FOURTH
$
Not
Applicable


                                577

-------
                          SECTION  25


                      SODIUM HYDROSULFITE



25.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL


25.1.1 Industry Profile and Analytical  Results

    Most of the sodium hydrosulfite produced  in the U.S. is sold
in  the merchant  market.  Sodium  hydrosulfite  is extensively used
in  dyeing  (cotton)   and in  the  printing   industry.   It  is  a
powerful reducing agent  and  is   used   in   wood  pulp bleaching,
reducing, and stripping operations  in  the  food,  vegetable oil and
soap industries.

    The industry profile data  are  presented in  Table 25-1,  while
existing regulations are summarized  in  Table 25-2.

    Priority pollutants  found   at significant  concentrations in
the raw  waste  during screening  at Sodium  Hydrosulfite - Formate
Process Plant #672 were as follows:
                     Maximum  Concentration Observed
         Pollutant                ug/1
         Cadmium                      43
         Chromium                   9300
         Copper                     1450
         Lead                       1294
         Nickel                     1665
         Silver                      128
         Zinc                      27412
         Pentachlorophenol           373
         Phenol                      160
         Cyanide                     101
         Mercury                      28
         Selenium                     34
    The plant  was  sampled  using   verification  procedures.  No
Plants were visited during  the verification phase of the study.
                             578

-------
TABLE 25-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
SODIUM HYDROSULFITE (FORMATE PROCESS)
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                            40,340 kkg/year
                            39,940 kkg/year
                                 2
                                 1
                            20,450 kkg/year
                            20,450 kkg/year
                                50 percent
                                51 percent
                               100 percent
                               273 cubic meters/day
                              4.68  cubic meters/kkg
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   579

-------
TABLE 25-2  -     EXISTING REGULATIONS  -  EFFLUENT KCMTTATICN GUIDELINES

SUBCftlEGORY        Sodium Hydrosulf ite

SUBPART            BE  (40CFR  415.570, 5/22/75)


	STANDARDS

                            BPCTCA            BATEA             NSPS
                          1          2
                      Max.      Avg.       Max.    Avg.       Max.     Avg.
 Product     Para-     kg/kkg    k/kkg     k/kkg  k/kkg     k/kkg    k/kkg
 Process     meters    (mg/1)     (mg/1)     (mg/1)  (mg/1)     Cmg/1)    Cmg/1)

 Sodium
 Hydro-      Reserved       Reserved        Reserved         Reserved
 Sulfite
      = Maximum of  any one day.
  Avg. = Average of  daily values for thirty consecutive days shall not exceed.
                                    580

-------
     A summary of daily  and  unit product raw waste
plant sampled can be  found  in Table 25-3.
                                            loads for  the
     Based on  the  toal  annual   production of sodium hydrosulfite
by  the formate process  and  the  average waste load  generated per
unit product, the   estimated  total  priority pollutant waste loads
generated each  year  for this particular process  subcategory are
as follows:
          Pollutant
                 Waste  Load  (kg/year)
          Cadmium                  2.8
          Chromium             5,590
          Copper                  76
          Lead                    28
          Nickel                 108
          Silver                   3.2
          Zinc                   440
          Pentachlorophenol        28
          Phenol                  12
          Cyanide                  2.8
          Mercury                  0. 26
          Selenium                 2.4
25.1.2 Process Waste  Sources and Waste Water Treatment Data
General Process  Description
     Raw
hyd rosulfite  Ts
sodium  hydroxide
presence
reaction  is
materials_ and  process  -  In  the  formate  process,  sodium
        produced  By  reacting   sodium formate solution,
          solution  and   liquid   sulfur dioxide  in   the
of a recycled stream  of  methanol  solvent.    The  general
2HC02Na + 3NaOH  +  3S02   = Na2S204 + NaHCOS  + Na2S03  + CO + 2H20 (1)
     The operation  occurs in several steps:

1.  An aqueous  solution  of sodium formate is prepared and introduced
    into the  reactor.

2.  The recycled  stream  of methanol containing sulfur dioxide is
    introduced  into the  reactor.

3.  The sodium  hydroxide and sodium formate solutions, liquid sulfur
    dioxide,  and  recycled methanol are then contacted under pressure
                               581

-------
25-3.    SUMMARY OF RAW. V3ASTE LOADINGS FOUND AT A SODIUM HYDROSULFITE
        PLANT  (FORMATE PROCESS)
- — — -~ ~~~
pollutant
Priority
Cadmium, Cd
Chromium, Cr
Copper, Cu
Lead, Pb
Nickel, Ni
Silver, Ag
Zinc, Zn
Pentachlorophenol
Phenol
Conventional
TSS
COD
Loadings
kg/day
Average

0.0041
0.81
0.11
0.041
0.16
0.0045
0.63
0.04
0.017
91.6
1687
kg/kkg
Average

0.00007
0.14
0.0019
0.0007
0.0027
0.00008
0.011
0.0007
0.0003
1.57
28.9
                              582

-------
    at slightly elevated  temperatures.

     Sodium hydrosulfite  then  precipitates and forms a slurry  in
the   reactor.   The   coproduct,   sodium  sulfite,   and  sodium
bicarbonate and carbon monoxide  gas are formed.

     There is a small amount   of  methyl formate produced in  the
reactor  as  a  side  reaction  between  the sodium  formate  and
methanol:
HC02Na + CH30H = HC02CH3  + NaOH               (2)
     This side reaction  product  remains in the recycling methanol
during the  entire   process.   As a  result,  some of the  methanol
must be periodically purged   from the  recycle  system  to  avoid
excessive buildup of this  impurity.

     The resulting  slurry  of   sodium hydrosulfite in the solution
of  methanol,  methyl   formate  and    coproducts  is  sent  to  a
pressurized  filter  operation  which  recovers  the crystals  of
sodium  hydrosulfite.  The  crystals   are  dried in a  steam heated
rotary drier, recovered  and packaged.  The filtrate  and backwash
liquors  from  the   filter operation  are  sent  to  the  solvent
recovery  system  as  is the  vaporized  methanol from  the drying
operation.   The drying  of the   sodium hydrosulfite  filter cake
must be  done very  carefully  as  it  is heat sensitive and tends to
decompose to sulfite.

     A general process   flow  diagram for Plant #672  can be found
in Figure 25-1.
Water Use and Waste  Source  Inventories

     Water use - Water  is  used  in the process  as make up for  the
reaction solutions and  for  steam generation in the rotary dryers.
Water is also used for  noncontact cooling in the reactor gas vent
scrubbers and dryers, as well  as pump seals and washdowns.

     Sources of waste water

     A.  The strongest  process  waste is the aqueous residue from
the distillation column bottoms  (solvent recovery system). This
waste  contains concentrated  reaction coproducts  and  is  purged
from the  system at  a rate  of  approximately 14,000 GPD.  At plant
#672 this waste is sent to  a  coproduct pond where it is held  and
either sold  to  the  pulp   and  paper  industry or  bled  into  the
treatment system.
                               583

-------
                                                            GASEOUS
                                                          CCHPRDDUCTS
                                                                                   VINT GRS
                                                                                   SCRUBBER
                                                                               LIQUID SULFUR DIOXIDE
                       SODIUM FOFMATE SOLUTION
                       SODIUM HYDROXIDE SOLUTION
                                                                               . RECYCLED HETHANOL, SO., AND
                                                               REflCTOR
                                                                                            METHYL FORMATE
Ul
00
                                                                                  FILTER
                                                                                            . FILTRATE
                                                                                         ./ AND
                                                                                             BACKWASH
                                                                                             LIQUOR
                                                                                 SODIUM HYDRDSULFITE
                                                                                        CRYSTALS
DISTILLER
 COLUMN
(SOLVENT
RECOVERY)
                                                                                                                           DISTILLER COLUMN BOTTOMS
                                                                                                                          iCO-PRODUCT WASTES TO POND)
                                                                                                           VAPORIZED
                                                                                                            MBTHANOL
                                                                                                              DRYER
                                                                                                                            DRIED PRODUCT
                                                   Figure 25-1.   General process flow diagram at Plant J672
                                                                      Sodium Hydrosulfite Manufacture

-------
     B.  The  dilute   wastes from  process are  contributed  fron
leaks, spills, washdowns,  and  tank car washing.  At  Plant #672,
this is  collected   in a   sump and then  sent   to the  biological'
treatment system.

     C.  Cooling    tower   and  boiler  blowdown  constitutes  a
noncontaminated  waste water source.  This  is sent to the final
compartment  of  the  chlorine contact  tank, without treatment for'
discharge with the  combined  effluent of the treatment plant.

     D.  The vent gas  scrubbers create a waste  water source which
is sent  to the  methanol   recovery distillers   for recycle.  This
waste eventually goes  to  the  coproduct pond  with the distilling
column bottoms.

     A general flow diagram   of Plant #672 showing process  waste
sources and sampling  points  is shown in Figure  25-2.  The sources
of waste water for  each sampling point are as follows:
 1.  Coproduct pond.
 2.  Dilute waste  from sodium hydrosulfite process area
     at sumps.
 3.  Combined  influent to  treatment.  This point collects
     waste  from  points 1  and 2, plus the sodium bisulfite
     waste  stream.
 4.  Treated effluent  at  the outfall.

     A tabulation of  raw  waste flows, concentrations and loadings
for  the two waste  steams  to treatment at Plant #672 can be found
in Table 25-4.
Control and Treatment  Practices

     The  Best  Practical  Technology for sodium  hydrosulfite waste
treatment   is   equalization,   aeration   (biological   oxidation)
clarification   and   final   settling  and  equalization  prior  to
d ischarge.

     Treatment practices  -  The only  plant  visited during  the
screening   program   was   Plant   #672.    Verification   sampling
procedures  were  used.  Because of  the nature  of  the two  waste
streams,  each   one  is   handled differently.  The dilute  waste is
first sent  to a   holding   pond where the flow equalized and  the
waste   mechanically   aerated.    This   pond   also    contains
approximately  1500   gallons  per  day  of  waste   from  a  sodium
bisulfite   process.    The   pond  effluent  is  pH  adjusted  with
sulfuric    acid    and    sent    to   an   aeration   basin.    A
nitrogen-phosphate   fertilizer  and  urea  are  added  here   for
nutrients.  Approximately 3500 gallons  per day of  sanitary  waste
and  up  to 25,900  gallons per day of clean dilution water are also
added   to the  aeration  basin.  This basin formerly had mechanical
aerators,   but   now   has   air  diffusers  which  allow  better


                               585

-------
Ln
oo
CTi
                                              SODIUM HYDROXIDE
                                           SODIUM
                                           BISUIFITE
                                           WASTE
                                                                  '13
LINE
                                ' TO CONCENTRATOR
                                                                                                                   COOLING TOWER
                                                                                                                AND BOILER SLOWDOWN
                                 SANITARY WASTE
                              WASTE SIUDGE
                                                                                                                                                                     DISCHARGE
                                              I-  _  _  _  _L
                                                                                                                                   Waste streams sampled
                                                  Figure 25-2.   General process flow diagram at. Plant. 1771 showing the sampling points.
                                                                                      Sodiun Hydrosulfite Manufacture

-------
TABLE 25-4.  FLOW AND POLLUTANT CONCENTRATION DATA OF THE SAMPLED WASTE
             STREAMS FOR PLANT #672' PRODUCING SODIUM HYDROSULFITE
Parameter
  Stream #1  (Coproduct)    Stream #2 (Dilute Waste)
Flow m /kkg

Pollutant

Chemical Oxygen
 Demand, COD

Total Suspended
 Solids, TSS

Zinc, Zn
           0.91                       1.87

  mg/1           kg/kkg      mg/1            kg/kkc

77,922            70.9     14,628             27.4
    61
    24
0.056
0.022
263
  0.77
0.49
0.0014
All values are averages of three days of sampling.
                                    587

-------
temperature  control for biological  oxidation.    The effluent from
aeration goes  to a clarifier.  Approximately  14,000 gallons per
day of the   settled sludge is   returned  to  the aeration basin and
2400 gallons  per  day  is sent to   drying   piles on site.   More
dilution  water  is added  to   the   clarifier  when needed for TDS
control.  The  overflow  from  the clarifier  goes to  a  chlorine
contact tank because of  the   sanitary waste.   The blowdown water
from the cooling  tower and boilers is added to the final chamber
of  the chlorine contact tank.    The  effluent from this  unit is
sent to  a final  polishing  pond for   settling and  equalization
before discharge.

    The coproduct waste  from  the  distilling  column  bottoms  is
sent to  a lined  coproduct pond  at a rate of 14,000 gallons per
day and held  for  one of  two  possible  disposal methods.  When
there is a market for  the  coproducts, the   waste is concentrated
and sold to  the  pulp  and paper industry.   At  times when  this is
not  possible, and the pond reaches  near   capacity, the waste is
bled into the treatment system  described above through the dilute
waste holding pond.

    A general flow diagram of  the  biological  treatment system is
also included in Figure 25-2.

    Table 25-5  shows the total  combined  input to the  treatment
system,  the  treated  effluent  quality  and  efficiency  of  the
system.
Evaluation of Production  and  Waste  Flow Data

    Only two  plants   utilize   the   formate  process  in  this
subcategory. Data  from the one   plant sampled can be  considered
representative of this  process   for both plants.  The other plant
in  this  subcategory has  an  identical, though  slightly  smaller,
production  process.  However,   the  waste  treatment  system  is
different,  and on  a   larger scale,  due to the large loadings of
waste from several  other  products.  Because of the large product
mix, representative treatment data   for sodium hydrosulfite waste
water  only cannot  be  analyzed   for  this plant.   Plant £672 was
visted for this reason.

    Table 25-5 shows that the  treatment  efficiency for chemical
oxygen demand removal is  95.2 percent and total suspendend solids
removal  is 97 percent.   Zinc is shown  here, having  the highest
concentration of several  metals  found at significant levels, with
a removal of  almost 98 percent.  The higher effluent flow is due
to  the  addition of  the  sanitary  waste, dilution  water,  and
cooling tower and boiler  blowdown to  the treatment system.  These
sources  should  have little   or no effect on  the  analyzed  and
calculated values for treatment  plant efficiencies.  At the  time
screening sampling  was   conducted  at  Plant  #672,  none  of the


                              588

-------
TABLE 25-5.   INFLUENT AND EFFLUENT QUALITY AND EFFICIENCY FOR PLANT #672
              WASTE WATER TREATMENT SYSTEM FOUND DURING SCREENING SAMPLING
Parameter
     Stream #3
   (Raw Influent)
             Stream #4        % Removal
         (.Treated Effluent)
Flow  m /kkg

Pollutant

Chemical Oxygen
 Demand, COD

Total Suspended
 Solids, TSS

Zinc, Zn
        1.87

  mg/1       kg/kkg

15,487
   843
     5.85
29.0
 1.58
 0.011
      4.68

mg/1        kg/kkg

740          3.46     95.2%


 25          0.12     97.0%


  0.122      0.00057  97.91
  Higher flow due to the addition of Sanitary Waste and Dilution Water to the
  aeration basin plus cooling tower and boiler blowdown to the chlorine
  contact tank.

All values are an average of three days of sampling.
                                    589

-------
coproduct waste water  was  being  sent to the biological treatment
system.  As a result, the sodium  hydrosulfite process waste being
treated was from the dilute  waste area only.


Model Plant and BPT Treatment  System Specifications

    The specifications  of   the   waste  input  parameters and  the
design of the model plant BPT  level  treatment system are based on
the  foregoing information presented  on Plant #672.

    In this  subcategory,  commercial  fertilizer  and  urea   are
added to stimulate  growth  of  the biomass employed in  biological
treatment, and not for direct  reaction with a residual pollutant.

    Therefore, the  chemicals   used  to  not  bear   a   fixed
relationship  to   the   plant  production  in   units  of  sodium
hydrosulfite.

    Organic solids  generated in the model  treatment system  are
assumed to be disposed of on land at the site, without a separate
cost for sludge disposal.


25.2 TECHNOLOGY BASED POLLUTION ABATEMENT


25.2.1 Advanced Level Treatment Appl ications


Priority Pollutants to be Controlled

    Although sodium  hydrosulfite is  being manufactured by both
the  zinc process and the  formate  process, the trend is away  from
the  zinc  process  for   environmental  reasons.   This discussion
concerns only the formate   process,   using a sodium formate  feed
stock from a source  which   appears   to contain significant heavy
metal impurities, (chromium, zinc,  nickel,  lead and  copper) as
well as  trace amounts of   cyanide.   A predominant characteristic
of sodium hydrosulfite waste is their high chemical oxygen demand
resulting from various   forms  of  sulfite, from methyl formate  and
from residual  methanol  after  a   solvent recovery  process.   Low
levels of phenolic compounds are  also found in the raw wastes.

    In this subcategory  an   exception  is  made to  the  assumed
exclusion of sanitary  sewage  from the waste stream.  To  utilize
the  nutrients  and bacteria  present  in sewage  as  support for   a
biological oxidation  system  to   control  organics and COD,   the
Plant sanitary wastes are included in the biological treatment.

    The significant heavy   metals appear  largely in a coproduct
waste stream which  is often sold for  use in  the pulp and paper
                              590

-------
industry. When no market exists,  these  wastes are  bled  into  the
product  wastes.  To  provide   the   capability for  treating   the
co-product wastes, the model plant  design flow and pollutant load
are based on continuous treatment of combined wastes.

     Two levels of  treatment  are proposed,  in order to deal with
the  priority pollutants  which   were found  in the wastes  of  one
plant sampled during the verification phase.


Removal Technologies Available

     Practical technologies  for controlling   COD include  various
forms of mechanical and biological  oxidation.  For the relatively
simple chemical oxidation of sulfite to sulfate, intimate contact
with  atmospheric  oxygen    is effective,   using  submerged   air
diffusers, induced air  in   a  circulating   system  or mechanical
surface  aeration.   For   biochemical   oxidation   of  resistant
organics such as formates, phenols,  chlorinated hydrocarbons,  and
methanol,  trickling  filtration,  rotating   biological discs  or
variations of the activated  sludge  process  can provide  intimate
contact  between  organic  pollutants  and   the   microbiological
organisms which use them as  food.

     Technologies for  controlling   heavy metals include alkaline
precipitation, which is  effective  for   the  common  heavy metals,
and  sulfide  treatment,  which   precipitates  nickel,  zinc   and
copper, but does  not  control chromium without a subsequent pH
increase.  Other  less appropriate  metal removal techniques have
been discussed under other subcategories.


Selection of Appropriate Technology

     BPT  (Level JJ_  -  In  the treatment system  pH  adjustment,
biological  oxidation,  settling  and  chlorination  are  used to
reduce  COD and coliform  organisms   in the   combined wastes,  in
accordance with existing plant practice.

     Level 2_ - The coproduct   wastes are separately subjected  to
alkaline precipitation,  to  remove   the toxic  heavy metals   and
reduce arsenic, and then are combined with  the product wastes  for
biological oxidation treatment and  chlorination, as in Level 1.

     If an actual formate process plant employs metal-free sodium
formate  in its process there is no  reason to  expect heavy  metals
in  the  process  wastes  and   Level 2   treatment should  not  be
necessary.
                               591

-------
Flow Diagrams

    BPT (Level 1)           Figure  25-3

    Level  2                 Figure  25-4

    Equipment Functions - Combined  product  and coproduct wastes
are received in a mixed and  aerated  equalizing basin, adjusted  to
a neutral pH and aerated in  a  4  day  aerated lagoon, including   50
percent  return  of  underflow to   the  influent.  Plant  sewage,
nutrients and diluting water are  added to the lagoon to  promote
biological   oxidation  of COD  and  organics.   Lagoon effluent   is
clarified,   chlorinated and  sent   to  a  polishing  pond  before
discharge through effluent   monitoring facilities. Cooling  tower
and  boiler blowdown wastes  enter  the  system after chlor ination,
since  they require no  treatment   except settling  of  scale and
inert debris in the polishing   pond.   Floating aerators are  used
in the  equalization basin and compressed  air is diffused in the
aerated lagoon, for  mixing  and introduction of dissolved oxygen
into the mixed liquor.

    In the  Level  2  treatment  model ,  coproduct  wastes  are
received  in a separate 18-hour   aerated and recirculated holding
tank,  which  is  pumped  at  average  daily  flow  to  a gravity
clarifier,  adding  sufficient  lime   to reach  a  pH of 10.5.  The
clarifier  overflow   joins  the  product  waste  stream  in  the
equalization basin of the BPT  system.   All features  of  the BPT
system remain the  same, since it  was  originally sized to handle
the combined wastes.

    Chemicals and handling  -  Sulfuric acid, lime, filter aid and
chlorine  are  chemicals commonly   used in waste treatment.  When
handled  in corrosion resistant  equipment designed for their use,
no unusual hazards are expected.   Raw sewage and 10-10-10 liquid
fertilizer  introduced  into  the aerated lagoon become thoroughly
mixed  and  are eventually  consumed   in the  biological oxidation
process,   constituting   no  threat   to   operating  personnel.
Chlorine,  used for control  of coliform bacteria,  is received  in
ton containers  and  applied  as a   chlorine water solution using
standard solution  feed  chlorination equipment.   There  are   no
unusual  chemical  handling  problems in  treating  these wastes,
provided the waste streams are kept  at a neutral or alkaline pH.

    Separation and disposal of:  solids - In the BPT system, waste
activated sludge~io~l ids are  assumed  to be dried in sludge beds  at
the  site,  to  be  used  as  fertilizer  for  plant  landscaping.
Clarifier  underflow  from   alkaline precipitation  of  coproduct
waste  in Level 2 is assumed to  be   sent to a sludge holding tank
and dewatered at  suitable intervals  in a filter press, followed
by hauling   of  solids  to   a   chemical  landfill.   Filter press
filtrate is returned to the  holding  tank for retreatment.


                              592

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                                  a
                                                                                                                                                      COOLING TOWER AND
                                                                                                                                                      BOILER SLOWDOWN
U1
U3
                      A
PRODUCT AND

CO-PRODUCT       \_
WASTE WATER
                            EQUALIZATION
                                                                                                                                *—WASTE SLUDGE
                                                                     RECIKCULATION
          Includes flow monitoring,  pH nonitoring and sampler.
                                                               Figvire 25-3.     Waste water treatment level 1 for sodiim hydrosulfite.

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PRODUCT
WASTE
WATOR
                            e
                                                                            SLUDGE
                                                                           HOLDING
                                         ACID
                                              SEWAGE
                                                                                                          LANDFILL
EQUALIZATION
'4
i
NUTRIENT DILUTION WATER
e
1 * r

\ / *ff
AERATED LAGOON
J
\
                                                                                                                                 CHLORD1ATION
                                                                                                     CLARIFIER
                                                                                                                                   O-A
                                                                                                                           COOLING
                                                                                                                           TOWER
                                                                                                                           AND
                                                                                                                           BOILER
                                                                                                                           BTjOWDOWN
                                                                                                                                                POLISHING POND
                                                                                                                            -6»- WASTE SLUDGE
                                                                                                                                                                   EFFLUENT
                                                                    RBCIRCUIATION
           Includes flow monitoring, pll monitoring and saiipler.
                                                           Figure  25-4.    Waste water treatment Level 2  for sodium hydrosulfite.

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     Monitoring requirements - Internal monitoring  should  include
simple  field  tests  for  pH,  chlorine   residual  and  settleable
solids. Maintenance of the co-product  stream  clarifier  at  a  pH of
10.5 is expected to  provide control of heavy metals  without need
for  routine  metal analyses,  but  effluent   samples  should  be
analyzed for  chromium, zinc,  copper, nickel and  lead   by atomic
absorption  for  offical   reporting   purposes,   in  addition  to
periodic COD tests for general evaluation  of  the  treatment.
25.2.2 Estimated Performance of BPT  Systems
     Raw waste loads  found at Plant
The   organic   priority  pollutants
                         #672  were presented above.
                          found  were   phenol   and
pentachlorophenol.   Priority  pollutants   which   might    require
regulation are chromium and zinc. Waste  water  treatment   at Plant
#672 consists of equalization, aeration  in  a biological  oxidation
pond,   clarification,  chlorination   and   settling    prior  to
discharge.  Table 25-6 presents the results of sampling  treatment
influent and effluent.  At the time of sampling,  coproduct  waste
was not being treated.

     BPT technology   has  been  specified  as the    technology
presently  in  use at Plant #672.  Design and  cost estimates  are
based on inclusion of coproduct wastes.
Base Level Performance Characteristics  for  BPT  Pollutant  Removal

     Table 25-7 presents  effluent  quality  achievable  through the
implementation of BPT technology.
Base  Level
Removal
Performance  Characteristics  for Priority Pollutant
     Priority pollutants,  both  metals  and   organics,  are  being
reduced  to  acceptable  levels  with  the   present   BPT  system.
Reduction of metals is assumed to be coincidental; the  metals are
perhaps  precipitating as carbonates.  No estimate can  be made of
the  achievable effluent quality  for metals,  when   an  additional
load  of  metal-bearing  waste  water  is  discharged    from  the
coproduct pond.
Pretreatment Applications

     No formate  process   sodium   hydrosulfite   plant
discharges  to  a  POTW.   BPT  technology  would  be
however, should such a discharge  occur  in  the  future.
                                           presently
                                           applicable
                               595

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      25-6.   SCREENING RESULTS FROM SODIUM HYDRDSULFITE PLANT #672
Pollutant

Flow  (m /kkg)
Chemical Oxygen
Demand, COD

Total Suspended
Solids, TSS

Zinc, Zn

Chromium, Cr

Copper, Cu

Lead, Pb

Nickel, Ni

Cadmium, Cd

Phenol

Pentachlorophenol
   Raw Waste  Influent
   ing/1           kg/kkg
         1.87
15,500
   840
29.0
 1.58
                Treated Effluent
                mg/1      ^  kg/kkg
                      4.68
740
 25
3.46
0.12
5.8
7.4
1.0
0.83
1.4
0.037
0.15
0.37
0.011
0.014
0.0019
0.0015
0.0027
0.000069
0.0003
0.0007
0.12
<0.043
0.028
0.07
0.16
0.029
<0.01
<0.01
0.00057
<0.0002
0.00013
0.00013
0.00075
0.00014
<0. 00005
<0. 00005
  Higher flow due  to the addition of sanitary wastes and dilution water to
  the aeration basin,  plus cooling tower and boiler blowdown to the chlorine
  contact tank.
                                     596

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            TABLE 25-7  CONTROL  PARAMETER LIMITATIONS
                SUBCATEGORY:  Sodium  Hydrosulfite
                      Level  of Treatment: 1
                  Waste Water Flow:  4.7 m3/kkg
                                    Quality Limit   Emission Limit
               Subcategory      (1)     (mg/1)           (kg/kkg)
Pollutant      Performance    VFR    	   	
                  (mg/1)             30  day  24 hr   30 day  24  hr
                                     Aver     Max     Aver    Max


BPT Pollutants;

Total Suspended     25(2)     2.0     37.5     75     0.18   0.36
Solids, TSS

Chemical Oxygen    740(2)     2.0   1000   2000      4.7    9.4
Demand, COD



   (1) - VFR: ratio of  the  24  hour  variability factor to the
            30 day variability  factor.

   (2) - Verification sampling
                               597

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25.2.3 Estimated Performance g_f  Advanced Level Systems


Advanced  Level  Performance   Estimates  for  BPT   and  Priority
Pollutant Removal

    No improvement   in    effluent   quality  with   regard   to
conventional   pollutants    is   expected  with   this   advanced
technology.   But  effluent  quality in terms of  priority  metals
will be controlled to  the  levels indicated in Table 25-8.
New  Source Applications

    The advanced control  and  treatment technology is recommended
for  new formate process  sodium   hydrosulfite facilities as NSPS.
However,  BPT technology  would   be  applicable  when a market  is
available for the coproduct  stream.


25.2.4 Cost Estimates
Discussion

    The cost estimate   of  one  model   plant having  two levels of
treatment and the same  level  of production at both the levels  is
presented in Table  25-9.  Table 25-10 gives a summary of the unit
cost distribution between amortization operation  and maintenance
cost components at  two  levels of treatment.


Summary

    Cost estimates developed for the first and the second levels
of treatment indicate that  labor and  supervision costs constitute
a major  portion  of the annual cost.  This reflects the manpower
requirements  for operating  the treatment  systems on  a 24-hour
basis.
                              598

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            TABLE 25-8  CONTROL  PARAMETER  LIMITATIONS
                SUBCATEGORY: Sodium  Hydrosulfite
                      Level of Treatment:  2
                  Waste Water Flow:  4.7  m3/kkg
Pollutant
Performance
  (mg/1)
      Quality Limit
  (1)    (mg/1)
VFR   	
      30 day  24 hr
       Av e r    Max
                                                    Emission Limit
                                                       (kg/kkg)
                                                    30 day  24 hr
                                                     Aver    Max
BPT Pollutants;

Total Suspended    25
Solids, TSS

Chemical Oxygen  1000
Demand , COD

Proposed Priority
              3.0
       37.5
              2.0  1000
112   0.18    0.53
              2000   4.7     9.4
Pollutants
Zinc, Zn
Chromium, Cr

0.5
0.1

2.0
2.0

0.5
0. 1

1.0 0.0024 0.0047
0.2 0.0005 0.0009
  (1) - VFR: ratio of the  24 hour  variability factor  to  the
            30 day variability  factor.
                               599

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                   TABLE  25-9. MODEL  PLANT  TREATMENT COSTS
  Subcategory  SODIUM HYDROSULFITE  Fonnate  Process Type of Regulation  BAT

  Production        20,450 metric tons  per year  (   22,546 tons per year)
                        58 metric tons  per day  (       64 tons per day )
  Waste water flow     273 cubic meters per  day.


                                             LEVEL  OF TREATMENT*

                                          FIRST             SECOND
A.   INVESTMENT COST

    Construction  	                $51,000            $11,500
    Equipment in  place,
    including piping,
    fittings, electrical
    work and controls	                113,000            110,200
    Monitoring equipment
    in  place	                 9,000
    Engineering design
    and inspection	                 34,600             24,340
    Incidentals,  overhead,
    fees, contingencies...                 34,600             24,340
    Land	                 12,000              2,400

    TOTAL INVESTMENT COST                $254,200           $172,780

B.   OPERATION AND
    MAINTENANCE COST

    Labor and supervision.               $168,000            $84,000
    Energy	                 12,000              1,200
    Chemicals	                  3,500             18,500
    Maintenance	                 24,220             17,038
    Taxes and  insurance...                 7,626              5,183
    Residual waste
    disposal	                                    2,500
    Monitoring, analysis
    and reporting	                 15,000              7,500

    TOTAL OPERATION AND
    MAINTENANCE COST                     $230,346           $135,921

C.   AMORTIZATION  OF
    INVESTMENT COST                       $39,405            $27,720

    TOTAL ANNUAL  COST                    $269,751           $163,641


    *First level  represents the  base cost of  treatment system.
    Other levels  represent the  incremental cost above base cost.
                                    600

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                 TABLE  25-10   MODEL PLANT TREATMENT COSTS
Subcategory  SODIUM HYDROSULFITE   Formate Process Type of Regulation  BAT
                  PRODUCTION   FLOW
                   (kkg/yr)  (m3/day)
                                            Annual Treatment Costs ($/kkg)
                    FIRST
                    $
                                                  LEVEL OF TREATMENT
SECOND
$
THIRD
$
FOURTH
 $
Annual Operation
and Maintenance

Annual
/Amortization

Total Cost
20,450     273     11.26       6.65      Not Applicable


20,450     273      1.93       1.36

20,450     273     13.19       8.00
                                  601

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                          SECTION  26


                  HYDROCHLORIC  ACID INDUSTRY


26.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL


26.1.1 Industry Profile and Analytical Results

    Most of the hydrochloric  acid  is produced as a by-product in
the manufacture of chlorinated  organic compounds.   It is used in
oil  well  activation,  pickling of  steel,  metal  cleaning,  in
monosodium  glutamate  manufacture  and starch  hydrolysis.  It is
also used as an  acid  reagent   in several  chemical manufacturing
processes.

    The industry profile data  for  this  subcategory are given in
Table 26-1, while  existing   regulations  are summarized in Table
26-2.

    Priority pollutants found  in the raw waste during  screening
at Hydrochloric Acid Plant #014  were as follows:


                        Maximum Concentration Observed
         Pollutant                  ug/1

         Lead                        3.5
         Mercury                     2
         Nickel                      5.5
    On the basis  of  these  findings,  this subcategory has  been
recommended as an exclusion candidate  under Paragraph 8.
                              602

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TABLE 26-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
HYDROCHLORIC ACID
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                         2,270,000 kkg/year
                                83
                                20
                           755,000 kkg/year
                           567,000 kkg/year

                                25 percent
                                4 years
                               49 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  603

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     26-2 -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES
                 Hydrochloric Acid


SUBPAKT           G   (40CFR  415.70, 5/22/75)
                                       STANDARDS
                           BPCTCA*            BATEA*            NSPS*
                         1         2
                     Max.      Avg.       Max.   Avg.      Max.     Avg.
Product     Para-     kg/kkg   k/kkg     k/kkg  k/kkg     k/kkg    k/kkg
Process     meters     (mg/1)     (mg/1)     (mg/1) (mg/D    (mg/1)   (mg/1)


Hydrochloric          No discharge         No discharge     No discharge
Acid                 of pwwp 3             of pwwp          of pwwp
 *
 Sections 415.72,  415.73,  and 415.75 were remanded and are presently
 reserved (41 FR 51601,  November 23, 1976) .

 raax,  = Maximum of any one day.
 2
 Avg.  = Average of daily values for thirty consecutive days  shall not exceed.

 pwwp = Process wastewater pollutants.
                                   604

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                           SECTION 27


                      NITRIC ACID INDUSTRY
27.1 ASSESSMENT  OF  THE  WATER POLLUTION POTENTIAL


27.1.1 Industry  Profile and Analytical Results

    Most of the  nitric acid produced is  used in the manufacture
of ammonium  nitrate   and other  nitrogen  fertilizers.   On  site
captive  use is  extensively practiced.  It  is also  used   in   the
manufacture of   explosives, plastics and other organic  products.
Other uses are as an  acidic and pickling agent.

    The industry profile data for this subcategory  are given  in
Table  27-1, while   existing regulations are summarized in  Table
27-2.

    Priority pollutants found in raw wastes during  sampling  were
as follows:
                      Maximum Concentration Observed
                                   ug/1
     Pollutant        Screening            Verification
                     (2  Plants)              (1 Plant)
Chromium
Zinc
Lead
Mercury
Silver
2-4 Dinitrophenol
Nickel
Cyanide
110
120
29
.47
.5
215
170
<.04
100
791
<10
4.5
<15
Not analysed
85
<.02
    The 2-4 Dinitrophenol   is presumed to be from  comtamination
by the  organic   products  manufactured at  the  plant,   and   not
process related. The  chromium and zinc are due  to  cooling  water
conditioners present  in  the blowdown which is  mixed  with process
streams.

    It has been recommended that this subcategory be  included in
the fertilizer  industry  guidelines.
                              605

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TABLE 27-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
NITRIC ACID
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total "capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                         9,177,000 kkg/year
                         7,171,000 kkg/year
                               87
                               11
                         1,106,000 kkg/year
                           774,400 kkg/year
                               12 percent
                               11 percent
                                 4 years
                                83 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   606

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TABLE 27-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES


SUBCAIEGORY       Nitric Acid

SUBPART           J   (40CFR  415.100,  3/12/74)


'                                        STANDARDS

                           BPCTCA*           BATEA*            NSPS*
                          1         2
                      Max.      Avg.      Max.   Avg.      Max.      Avg.
Product     Para-     kg/kkg    k/kkg     k/kkg  k/kkg    k/kkg    k/kkg
Process     meters    (mg/1)     (rng/1)     (mg/1)  (mg/1)     (mg/D    (mg/1)

Nitric                No discharge        No discharge    No discharge
Acid                  of pwwp 3            of pwwp          of pwwp
  Sections 415.102, 415.103, and 415.105 were remanded and are presently
 -.reserved (41 FR 51601, November 23, 1976) .
  wax, = Maximum of any one day.
 2
  Avg. = Average of daily values for thirty consecutive days shall not exceed.

  pwwp = Process wastewater pollutants.
                                   607

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                          SECTION  28
                   SODIUM CARBONATE  INDUSTRY
                        (SOLVAY  PROCESS)
28.1 ASSESSMENT OF THE WATER  POLLUTION  POTENTIAL
28.1.1 Industry Profile and Analytical  Results

    On-site captive production  of  sodium  carbonate (soda ash)  is
a dominant practice.  Sodium  carbonate  is  used in the  manufacture
of sodium bicarbonate, ammonium  chloride  and  calcium chloride.

    The industry  profile data  are   given in Table  28-1,   while
existing regulations are summarized  in  Table  28-2.

    Priority pollutants  found   in  significant concentrations  in
the  raw  waste during screening  of   Sodium Carbonate  Plant  #261
were:
         Pollutant       Concentration  ug/1
         Antimony                430
         Beryllium               220
         Lead                   2700
         Thallium                200
         Zinc                    750
         Silver                  <57
    Plant #261 is the only  plant  that   is operating  using  this
process. It does  not appear  likely that more plants of this type
will be constructed since  there  is a lower cost,  cleaner  process
available.   The  sources  of priority pollutants,  particularly
lead,  is  under  investigation.    Because of the nature  of this
industry,  it has  been  recommended  that  this   subcategory  be
further studied under Phase  II.
                              603

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TART.71  28-1    	SUBCATEGORy PROFILE DATA SUMMAEY	

SUBCAIEGORY          SODIUM CARBONATE

Total subcategory capacity rate               8,650,000  kkg/year
Total subcategory production rate
Number of plants in this subcategory                 10
308 Data on file for                                  8
    With total capacity of                    3,629,000  kkg/year
    With total production of                  2,828,000  kkg/year
    Representing capacity                            42  percent
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum                                  10  years
            Maximum                                  95  years
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   609

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TABLE 28-2  -     EXISTING REGULATIONS  .-  EFFLQEtSTT LIMITATION GUIDELINES


SUBCAiEGORY        Sodium Carbonate

SUBPAKT            0  (40CFR  415.150, 3/12/74)
STANDARDS
Product
Process
Sodium
Carbonate
Para-
meters
TSS
BPCTCA*
1 2
Max. Avg.
kg/kkg k/kkg
(mg/1) (mg/1)
0.20
(222.2)**
0.10
(111.1)
BATEA*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
0.34 0.17
NSPS*
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp 3
 *
  Sections 415.152, 415.153, and 415.155 were remanded and are presently
 , reserved (41 FR 51601, November 23, 1976).
  wax, = Maximum of any one day.
 2
  Avg. = Average of daily values for thirty consecutive days shall not exceed.

  pwwp = Process wastewater pollutants,
**flow basis   900  1/kkg.
                                    610

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                           SECTION  29


                     SODIUM  METAL  INDUSTRY



29.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL


29.1.1 Industry Profile  and Analytical Results

    Sodium metal  is  manufactured with chlorine by electrolysis
of  fused salt.  It is used   in  the  production of tetraethyl  lead
gasoline additives,  sodium  cyanide, sodium peroxide, and titanium
and  zirconium metals.  In   liquid   form, it  is used as a nuclear
reactor coolant; it  is also used  as a light, thermally conductive
solid  in various applications.

    The industry profile  for this   subcategory is given in Table
29-1, while existing  regulations  are summarized in Table 29-2.

    No priority   pollutants  were   found   at   significant
concentrations during  screening   of Sodium Metal Plant #339.  On
the  basis  of   these   findings,    this  subcategory   has  been
recommended as an exclusion candidate under Paragraph 8.
                               611

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      29-1           SUBCATEQOEY .PROFILE DATA SUMMARY
SUBCATEGORY          SODIUM METAL

Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory                 5
308 Data on file for                                 2
    With total capacity of                       332,000 kkg/year
    With total production of                     300,000 kkg/year
    Representing capacity                           88  percent
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   612

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TABLE 29-2 -      EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES


SUBCATEGORY        Sodium Metal


SUBPART            R   (40CFR  415.180, 3/12/74)



                                        STANDARDS


                            BPCTCA *          BATEA*            NSPS*
                          1          2
                      Max.      Avg.       Max.    Avg.      Max.     Avg.
 Product     Para-    kg/kkg    k/kkg      k/kkg  k/kkg     k/kkg    k/kkg
 Process     meters     (mg/1)     (mg/1)     (n*g/D  (mg/1)    (rag/1)
 Sodium      „,„,;       n ..,      n --,       No discharge     No discharge
 Metal                                      of pwwpj         of pwwp
  Sections 415.182, 415.183, and 415.185 were remanded and are presently
  reserved (41 FR 51601, November 23, 1976).

  wax, = Maximum of any one day.
 2
  Avg. = Average of daily values  for thirty consecutive days shall not exceed.

  pwwp = Process wastewater pollutants.'
                                   613

-------
                          SECTION  30


                   SODIUM SILICATE  INDUSTRY



30.1 ASSESSMENT OF THE WATER POLLUTION  POTENTIAL


30.1.1 Industry Profile and Analytical  Results

    Sodium silicate is manufactured  both  in liquid and anhydrous
powdered form.  It has many industrial  uses, such as additives in
adhesives,  flocculants, and cleaning  agents.   It is also used in
the production of soap and household  detergents.

    The industry profile for  this  subcategory is given  in Table
30-1, while existing regulations  are  summarized in Table 30-2.

    Priority pollutants  of significance   found  in the effluent
during screening at Sodium Silicate  Plant  #807 were as follows:


         Pollutant       Concentration (ug/1)
         Nickel                 121
         Silver                   1.3
         Mercury                  1.3


    Due to the low waste loads   generated  by this industry, this
subcategory has been recommended  as  an  exclusion candidate  under
Paragraph 8.
                              614

-------
TABLE 30-1
SUBCATEQORY PROFILE DATA SUMMARY
SUBCATEGORY
SODIUM SILICATE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           814,000 kkg/year
                           679,000 kkg/year
                                30
                                 7
                           300,700 kkg/year
                           254,900 kkg/year
                                37 percent
                                37 percent

                            12,400 kkg/year
                            57,300 kkg/year
                                   7 years
                                  43 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  615

-------
     30- Z -     EXISTING REGULATICMS  -  EFFLUENT LIMITATION GUIDELINES

SUBCATEGORY        Sodium Silicate

SUBPAKT            S  (40CFR  415.190, 3/12/74)


                                        STANDARDS

                            BPCTCA*            BAIEA *            NSPS *
                          1          2
                      Max.      Avg.       Max.    Avg.      Max.     Avg.
 Product     Para-     kg/kkg    k/kkg      k/kkg  k/kkg     k/kkg    k/kkg
 Process     meters     (mg/1)     (mg/1)     (mg/1)  (mg/1)    (mg/1)   (mg/1)

 Sodium      „,,,.,       n n,      n nnc      No discharge     No discharge
                      U • U-L      U • UUD             "
 _ t T .  .      XOO       U • U-L      U • UUD       ,-     "5          j~
 Silicate                                   of pwwp3         of pwwp
 *
  Sections 415.192, 415.193, and  415.195 were remanded and are presently
 .reserved (41 FR 51601, November 23,  1976).
  wax, = Maximum of any one day.
 2
  Avg. = Average of daily values  for thirty consecutive days  shall not exceed.
  pwwp = Process wastewater pollutants,
                                   616

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                          SECTION  31


                    SULFURIC  ACID  INDUSTRY



31.1 ASSESSMENT OF THE WATER POLLUTION POTENTIAL


31.1.1 Industry Profile and  Analytical  Results

    Sulfuric acid  is one  of the  most   extensively  used  of all
manufactured chemicals.    The   major industrial  use  is  in  the
fertilizer industry, with  on-site captive use of the product as a
dominant practice.   It   is  also  used   in  the  manufacturing  of
plastics, explosives, detergents, hydrofluoric acid, nuclear fuel
and  several other organic  and  inorganic  products.

    The industry profile  data for  this  subcategory are given  in
Table 31-1, while   existing  regulations  are  summarized in  Table
31-2.

    No priority    pollutants    were   found   at   significant
concentrations in the raw  waste during  screening of Sulfuric Acid
Plant #363.  On the basis  of these  findings, this subcategory has
been recommended as an exclusion  candidate under Paragraph 8.
                              617

-------
TABLE 31-1    -      SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEQORY
                     SULFURIC ACID
Total subcategory capacity rate              42,144,000 kkg/year
Total subcategory production rate            30,464,000 kkg/year
Number of plants in this subcategory                151
308 Data on file for                                 47
    With total capacity of                    8,800,000 kkg/year
    With total production of                  6,300,000 kkg/year
    Representing capacity                            21 percent
    Representing production                          21 percent
    Plant production range:
            Minimum                               5,300 kkg/year
            Maximum                              47,700 kkg/year
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum                                   3 years
            Maximum                                  78 years
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   618

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TABLE 31-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITATICN GUIDELINES


SUBCATEGORY        Sulfuric Acid

SUBPART            U  (40CFR  415.210, 3/12/74)


'                                       STANDARDS

                            BPCTCA*           BMEA*            NSPS*
                          1          2
                      Max.      Avg.      Max.   Avg.       Max.      Avg.
 Product     Para-     kg/kkg    k/kkg     k/kkg k/kkg     k/kkg    k/kkg
 Process     meters     (mg/1)     (mg/1)     (mg/1)  (mg/1)     (mg/1)    (mg/1)

 Sulfuric              No discharge         No discharge     No discharge
 Acid                  of pwwpr             of pwwp          of pwwp
  Sections 415.210, 415.212, 415.213, and  415.215 were remanded are are
 ^presently reserved  (41 FR 51601, Novennber  23,  1976) .
 Max, = Maximum of any one day.
 2
 Avg. = Average of daily  values  for thirty consecutive days shall not exceed.

 pwwp = Process wastewater pollutants,
                                   619

-------
                           SECTION 32
                  AMMONIUM CHLORIDE INDUSTRY
32.1 ASSESSMENT OF  THE  WATER POLLUTION POTENTIAL


32.1.1 Industry Profile and  Analytical Results

    Most ammonium  chloride   is produced  as a  by-product  in  the
manufacturing  of   sodium   carbonate (soda  ash)  by  the   Solvay
process. It is used  in   the  manufacture  of dry  cell  batteries,
explosives, dyes, used  as  a  washing powder, as a soldering   flux,
as a  chemical reagent,  and as a medicinal additive to livestock
feed. It is also used  in  pharmaceutical preparations and  freezing
mixtures.

    The industry profile   for this subcategory is given  in  Table
32-1, while existing  regulations are summarized in Table  32-2.

    No priority    pollutants   were   found   at   significant
concentrations in the  waste  during screening of Ammonium  Chloride
Plant  #736.   Ammonium  was found to  be  the only pollutant  of
significance.   Since   ammonia is not a priority pollutant,  this
subcategory has been  recommended as an exclusion candidate   under
Paragraph 8.
                               620

-------
TABLE 32-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
AMMONIUM CHLORIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                                 6
                                 3
                            52,400 kkg/year
                            29,800 kkg/year
                             4,600 kkg/year
                            13,400 kkg/year
                                17 years
                                43 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                    621

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TABLE 32-2  -     EXISTING REGULATIONS  .-  EFFLUENT .LIMITATION GUIDELINES
SIH^TEGORY Ammonium Chloride
SUBPAKT X (40CFR 415.240, 5/22/75)
STANDARDS
Product Para-
Process meters
Mronium
Chloride NH3~N
(Anhydrous)
S01^ NH.-N
By-Product ^3
BPCTCA
Max. Avg.
kg/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp3
8.8 4.4
BATEA
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp
NSPS
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
No discharge
of pwwp
      = Maximum of any one day.
 "i

 Avg. = Average of daily values for thirty consecutive days shall not exceed.


 pwwp = Process wastewater pollutants.
                                    622

-------
                          SECTION  33


                  AMMONIUM  HYDROXIDE  INDUSTRY


33.1 ASSESSMENT OF THE WATER POLLUTION POTENTIAL


33.1.1 Industry Profile  and  Analytical Results

    Ammonium hydroxide   is   predominately  used  as  a  chemical
intermediary  and  reagent.    It   is also used in  the dyeing and
bleaching  of  fabrics,   the  production  of  ammonium salts  and
aniline dyes, and the extraction  of alkaloids from plants.

    The industry profile for this   subcategory is given in Table
33-1, while existing  regulations  are summarized in Table 33-2.

    No plants  in   this  subcategory  were  found  that  had  a
discharge.   Therefore,   this industry has been recommended as  a
Paragraph 8 exclusion candidate.
                               623

-------
TABLE  33-1
SIJECATEGORY PROFILE DATA .SUMMARY
SUBCAIEGORY
AMMONIUM HYDROXIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                            41,800 kkg/year
                            17,000 kkg/year
                              206 kkg/year
                            9,500 kkg/year
                               10 years
                               26 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   624

-------
TABLE  33-2 -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES
SUBCATEGOKY

SUBPART
      Ammonium Hydroxide

      Y   (40CFR  415.250, 5/22/75)
                                        STANDARDS
 Product
 Process
Para-
meters
      BPCTCA
    1         2
Max.      Avg.
kg/kkg    k/kkg
 (mg/1)     (mg/1)
   BATEA
Max.   Avg.
k/kkg  k/kkg
 (mg/1)  (mg/1)
    NSPS
Max.     Avg.
k/kkg    k/kkg
(mg/1)    (mg/1)
 Amonium
 Hydroxide
Reserved
    Reserved
 Reserved
                                                Reserved
 "Max, = Maximum of any one day.
  Avg. = Average of daily values  for thirty consecutive days shall not exceed.
                                    625

-------
                           SECTION 34


                   BARIUM  CARBONATE INDUSTRY



34.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL


34.1.1 Industry Profile  and Analytical Results

    Barium carbonate   is  used  in glass manufacturing, as a  flux
in  ceramics and enamelling, as  an intermediate  in the production
of  barium oxide  and  hydroxide  and  as a coating for photographic
paper.   It  is also  used   in the synthetic dyestuff industry and
for the removal of soluble  sulfate in brick manufacturing.

    The industry profile  for  this subcategory is given  in Table
34-1, while existing  regulations are summarized in Table  34-2.

    No priority pollutants were found  at  significant levels  in
the waste  during screening of   Barium Carbonate Plant  #360.   On
the  basis   of   these  findings,  this  subcategory  has  been
recommended as an exclusion candidate under Paragraph 8.
                               626

-------
TABLE  34-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
BARIUM CARBONATE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                                7
                                5
                            57,000 kkg/year
                            48,745 kkg/year
                              158 kkg/year
                           26,190 kkg/year
                                9 years
                               24 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   627

-------
TABLE 34-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITfiTICN GUIDELINES
SUBCATEGORY


SUBPART
Barium Carbonate


Z  (40CFR  415.260, 5/22/75)
STANDARDS
Product
Process
Barium
Carbonate
Para-
meters
Reserved
BPCICA
1 2
Max. Avg.
kg/kkg k/kkg
(mg/1) (mg/D
Reserved
BA1EA
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
Reserved
NSPS
Max.
k/kkg
(mg/D
Reserved
Avg.
k/kkg
(mg/1)

      = Maximum of any one day,
 2
 Avg. = Average of daily values for thirty consecutive days  shall not exceed.
                                    628

-------
                          SECTION  35
                      BORIC ACID  INDUSTRY
35.1 ASSESSMENT OF THE WATER  POLLUTION  POTENTIAL
35.1.1 Industry Profile  and  Analytical  Results

    Boric acid   is   used   in  the  manufacture  of  chromic oxide,
glazes, enamels,  textile   fiberglass,  and  heat resistant glass.
It  is also  used  medicinally as  a   mild  antiseptic and in atomic
power plants as a nuclear  moderator.

    The industry profile  for  this subcategory  is given in Table
35-1 and the existing  regulations  are summarized in Table 35-2.
    Priority pollutants
during- screening of  Boric
 found  at
Acid Plant
 significant
#778 were:
concentrations
         Pollutant
Concentration (ug/1)
         Copper                340
         Thallium              140
         Zinc       A         1190
         Bis(2-ethy]^exyl)
           phthalate'          530
         Mercury                 1.6
    This subcategory   has  only three plants, and
water discharge   is  not  high.    Because of  the
industry,  it  has  been   recommended  that  this
further studied  under  Phase  II.
                        the  total waste
                        nature  of  this
                         subcategory  be
                               629

-------
TABLE 35-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
BORIC ACID
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           122,600 kkg/year
                                 3
                                 2
                            97,500 kkg/year
                            93,850 kkg/year

                                77 percent

                            30,156 kkg/year
                            63,694 kkg/year
                               30 years
                               83 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  630

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TABLE 35-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES
SUBCMEGORY
SUBPAKT
Boric Acid
AB (40CFR
415.280, 5/22/75)

STANDARDS
Product
Process
BPCTCA BATEA
Max. Avg. Max. Avg.
Para- kg/kkg k/kkg k/kkg k/kkg
rosters (mg/1) (mg/1) (mg/1) (mg/1)
NSPS
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
 Boric
 Acid        AS
 (Ore-mined)
 (TRONA)
   TSS
   AS
   TSS
0.0028    0.0014
0.14      0.07
No discharge
of pwwp 3
No discharge
of pwwp
No discharge
of pwwp
  Max, =
Maximum of any one day.
 T
  Avg. = Average of daily values for thirty consecutive days shall not exceed.
  pwwp = Process wastewater pollutants.
                                    631

-------
                          SECTION  36


                  CALCIUM CARBONATE  INDUSTRY



36.1 ASSESSMENT OF THE WATER  POLLUTION  POTENTIAL


36.1.1 Industry Profile and Analytical  Results

    Calcium carbonate  is manufactured  both in pure and  impure
form and it is extensively used  in  many  industries.  In the pure
form,  it  is  used  in  the   rubber,  paint,   cement,  paper  and
pharmaceutical industries.

    The industry profile for   this subcategory is given in Table
36-1, while existing  regulations are  summarized in Table 36-2.

    No priority  pollutants  were found at significant levels  in
the  raw waste  during screening of Calcium Carbonate Plant #883.
On  the  basis  of   these findings,  this  subcategory  has  been
recommended as an exclusion candidate  under Paragraph 8.
                               632

-------
TABLE 36-1
SUBCATEGORY PROFILE DATA .SUMMARY
SUBCATEGORY
CALCIUM CAPBONATE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           129,600 kkg/year
                            81,300 kkg/year
                            72,400 kkg/year

                               56 percent

                              555 kkg/year
                            49,800 kkg/year
                               25 years
                               50 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                    633

-------
TABLE  36-Z -      EXISTING REGULATIONS  -  EFFHJENT LIMITATION GUIDELINES
SUBCATEGOKY

SUBPART
      Calcium Carbonate

      AD   (40CFR  415.310, 5/22/75)
                                         STANDARDS
 Product
 Process
Para-
meters
     BPCTCA
    1          2
Max.      Avg.
kg/kkg    k/kkg
 (mg/1)     (mg/1)
              BATEA
          Max.    Avg.
          k/kkg  k/kkg
           Cmg/1)  (mg/1)
    NSPS
Max.     Avg.
k/kkg    k/kkg
 (mg/1)    (mg/1)
 Calcium
 Carbonate
 (Milk of
 Lime)

 Solvay
 Recovery
TSS
TSS
0.56
(50.0)*


1.16
(49.6)
0.28
(25.0)


0.58
(24.8)
  Max, = Maximum of any one day,
 2
  Avg. = Average of daily values for thirty consecutive days shall not exceed.
 *flow basis  11,200 1/kkg.
                                    634

-------
                           SECTION 37
                    CUPROUS  OXIDE INDUSTRY
37.1 ASSESSMENT OF  THE  WATER POLLUTION POTENTIAL
37.1.1 Industry  Profile  and  Analytical Results

    Copper oxide  is  used  in the manufacture of glass,  ceramics,
marine  paints   and   photoelectric cells.   It  is  also   used  in
agriculture as   a   seed   fungicide,  and   as an  antiseptic  and
catalyst.

    The  industry  profile  for this subcategory is given in  Table
37-1, while existing  regulations are summarized in Table 37-2.

    Only one  plant  was  found to be producing this product  at the
time of screening.   Because  this is now a single plant  industry,
this   subcategory  has   been  recommended  for  exclusion  under
Paragraph  8.
                               635

-------
TABLE 37-1     	SUBCATEGORY PROFILE DATA SUMMARY

SUBCATEGORY         CUPROUS OXIDE

Total subcategory capacity rate               Unknown
Total subcategory production rate             Unknown
Number of plants in this subcategory          NO plants
308 Data on file for                          Unknown
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   636

-------
TABLE 37-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES




SOBCATEGORY        Cuprous Oxide



SUBPART            AK  (40CFR  415.370, 5/22/75)





                                        STANDARDS



                           PBCTCA            BATEA            NSPS

                          1         2
                      Max.       Avg.      Max.   Avg.      Max.     Avg.

 Product     Para-     kg/kkg    k/kkg     k/kkg  k/kkg     k/kkg    k/kkg

 Process     meters    (mg/1)     (ng/1)     (mg/1)  (rog/D     (mg/1)    (mg/D



            Reserved      Reserved        Reserved        Reserved
  wax, = Maximum of  any one day.

  Avg. = Average of  daily values for thirty consecutive days shall not exceed.
                                    637

-------
                          SECTION  38


                  MANGANESE  SULFATE INDUSTRY



38.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL


38.1.1 Industry Profile  and Analytical Results

    Manganese sulfate  is  normally  sold as a mixture of tetra and
penta  hydrates.  It   is used in  oils  for  the  manufacture  of
varnishes, in dyeing  and in the  manufacture of porcelain.  It  is
also used in the fertilizer industry.

    The industry profile  for this  subcategory is  given in Table
38-1, while existing  regulations are summarized in Table 38-2.

    Only one  plant   in  this subcategory  was  found  to  be i-n
production-  at  the time of screening.  Out  of the  eight plants
contacted,  four  no   longer   produced  it,  two  were fertilizer
manufacturers  and  one   manufactured  reagent   grade  manganese
sulfate.  Because this   is now a  single  plant  industry,  this
subcategory has been  recommended for exclusion under Paragraph 8.
                               638

-------
TABT.K38-1     	SUBCaTEGQRY PROFILE DATA .SUMMARY

SUBCATEGORY          MANGANESE SULFATE

Total subcategory capacity rate               Unknown
Total subcategory production rate             Unknown
Number of plants in this subcategory          No Plants
308 Data on file for                          Unknown
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  639

-------
TABLE 38-2  -     EXISTING REGULATIONS  -  EFFLUENT LZMTTATICM


SUBCMEGORY       Manganese Sulfate

SUBPART           AT  (40CFR  415.460, 5/22/75)


^~                                       STANDARDS

                           P3CTCA             BATEA             NSPS
                           1          2
                      Max.      Avg.       Max.   Avg.       Max.     Avg.
 Product     Para-     kg/kkg    k/kkg     k/kkg  k/kkg     k/kkg    k/kkg
 Process     meters     (mg/1)     (mg/1)     (mg/D  (mg/1)     (mg/1)    (mg/1)

 Manganese   Reserve^      Reserved         Reserved         Reserved
 Sulrate
 "wax, = Maximum of any one day.
 2
  Avg. = Average of daily values for thirty consecutive days shall not exceed.
                                     640

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                           SECTION  39


                  STRONG  NITRIC  ACID INDUSTRY



39.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL


39.1.1 Industry Profile  and Analytical Results

    Strong or   concentrated    nitric  acid  is  used   in  the
manufacture of organic compounds  where nitric acid is required to
act as an  oxidizing   agent rather   than as  an acid.  It is also
used in the manufacture  of dye  intermediates, and explosives.

    The industry profile  for  this  subcategory is given in  Table
39-1, while existing  regulations  are summarized in Table 39-2.

    Priority pollutants  found   in  the  waste  streams  during
sampling of Strong Nitric  Acid  Plants were:


                             Maximum
    Pollutant        Concentration  Observed  (ug/1)
                     Screening      Verification
                     (2  Plants)       (1 Plant)
Chromium
Zinc
Lead
Mercury
Silver
Nickel
Cadmium
Cyanide
40,000
900
70
8.
•
<5
<2
•



6
69


02
<50
115
<10
1.
<15
<50
<2
<.



2


02
    In a  followup,  it  was   found that the chromium and zinc are
used  as corrosion  inhibitors in  the  cooling water, and are not
process related.    The other  values are below significant levels.

    Verification sampling  at Plant #623 confirmed this.

    On the basis   of these  findings, this subcategory has  been
recommended for  exclusion under Paragraph 8.
                               641

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TABLE  39-1
SUECATEGORY PROFILE DATA SUMMARY
SUBCATEQORY
STRONG NITRIC ACID
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           155,200 kkg/year
                           121,000 kkg/year
                            5,300 kkg/year
                           60,200 kkg/year
                               11 years
                               49 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                    642

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     39-2  -     EXISTING REGULATIONS  -  EFFLUENT .LIMITATION GUIDELINES


SUBC&TEGORY       Strong Nitric Acid

SUBPAKT           AV   (40CFR  415.480, 5/22/75)


                                        STANDARDS

                           BPCICA            BATEA             NSPS
                          1          2
                      Max.      Avg.      Max.   Avg.       Max.      Avg.
Product     Para-     kg/kkg    k/kkg     k/kkg k/kkg     k/kkg    k/kkg
Process     meters    (mg/1)     (mg/1)     (mg/1)  (mg/1)     (mg/1)    (mg/1)

Strong
Nitric      Reserved       Reserved       Reserved         Reserved
Acid
 wax. = Maximum of any one day.
 2
 Avg. = Average of daily values  for thirty consecutive days shall not exceed.
                                     643

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                           SECTION 40


                 OXYGEN AND  NITROGEN INDUSTRY



40.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL


40.1.1 Industry Profile and Analytical Results

    Oxygen, along  with   nitrogen,   is  produced  from  air  by
distillation of liquefied  air.   Oxygen  is used in the production
of steel,  gas  welding,   medicine,  jet fuel, sewage  treatment
plants  and  in  the  manufacture of ethylene  and  acetylene. In
rocket  propullsion,  liquid  oxygen  is often used  as a  crygenic
liquid  oxidizer  in  the   main  stage  boosters  used  for space
exploration.

    The largest use  of nitrogen is  in the manufacture of ammonia
by the  Haber process.    It   is also used in cryosurgery.  As an
inert gas,  it is used to  prevent oxidation by air.  In the liquid
form, it is used for  low  temperature refrigeration.

    The industry profile   for  this  subcategory is given in Table
40-1, while existing  regulations are summarized in Table 40-2.

    Only one priority pollutant was found at a significant level
in the  raw waste  during   screening of Oxyen and  Nitrogen Plant
#993.


         Pollutant        Concentration (ug/1)

         Copper                  590


    Due to the small  quantity of  waste water discharged by the
industry  and  the  resulting  low  waste  load  generated,  this
subcategory has  been recommended as an exclusion candidate under
Paragraph 8.
                               644

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TABLE 40-1
SUBCATEGORY PROFILE DATA .SUMMARY
SUBCATEGORY
OXYGEN AND NITROGEN
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                        31,174,000 kkg/year

                           171
                             9
                         1,588,000 kkg/year
                         1,473,000 kkg/year
                                 5 percent
                             2,400 kkg/year
                           378,000 kkg/year
                                4 years
                               36 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                    645

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TABLE 40-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES




SOBCATEGOKY       Oxygen and Nitrogen



SUBPAKT           AW  (40CFR  415.490, 5/22/75)
STANDARDS
Product
Process
BPCTCA
1 2
Max. Avg.
Para- kg/kkg k/kkg
meters (mg/1) (mg/1)
BATEA
Max. Avg.
k/kkg k/kkg
(mg/1) (mg/1)
NSPS
Max . Avg .
k/kkg k/kkg
(mg/1) (mg/1)
            Oil and   0.002     0.001


                      (51'3)*   (25'6)
 "Max, = Maximum of any one day.
 2
 Avg. = Average of daily values  for thirty consecutive days shall not exceed.





 *flow basis  39 1/kkg.
                                    646

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                           SECTION 41


                   POTASSIUM IODIDE INDUSTRY



41.1 ASSESSMENT OF  THE  WATER POLLUTION POTENTIAL


41.1.1 Industry Profile and Analytical Results

    Potassium iodide   is   used   in  photographic  emulsions,  in
animal  and poultry feeds,  table salts  and analytical chemistry.
It  also has a number of medical  uses.

    The  industry profile   for this subcategory is given in Table
41-1, while existing regulations are summarized in Table 41-2.

    Priority pollutants  found   during  screening  of  Potassium
Iodide Plant #118 were:

         Pollutant       Concentration (ug/1)
         Copper                 1900
         Thallium                 28
         Zinc                    930*
         Silver                   35

*The water  supply was  found  to have 900 ug/1 zinc and is presumed
to  be  the source.

    Due to  the  small  quantity  of waste water  discharged by the
industry,   and   resulting    low  waste  loads   generated,  this
subcategory has  been  recommended as an exclusion  candidate under
Paragraph 8.
                                647

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TABLE 41-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
POTASSIUM IODIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                           122,560 kkg/year
                                 9
                                 4
                             1,985 kkg/year
                             1,300 kkg/year

                               10 percent

                               79 kkg/year
                              634 kkg/year
                               27 years
                               42 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                    648

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TABLE 41-2  -
EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES
SUBCATEGORY



SUBPART
Potassium Iodide


AY   (40CFR  415.510, 5/22/75)
STANDARDS
Product Para-
Process meters
Potassium Tgs
Iodide
Sulfide
Iron
Barium
BPCTCA BATEA NSPS
1 2
Max. Avg. Max. Avg. Max. Avg.
kg/kkg k/kkg k/kkg k/kkg k/kkg k/kkg
(mg/1) (mg/1) (mg/1) (mg/1) (mg/1) (mg/1)
0.09
(75.0)*
0.015
(12.5)
0.015
(12.5)
0.009
(7.5)
0.03
(25.0)
0.005
(4.2)
0.005
(4.2)
0.003
(2.5)
  Max, = Maximum of  any one day.
 2
  Avg. = Average of  daily values  for thirty consecutive days shall not exceed.
 *flow basis  1200 1/kkg.
                                     649

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                          SECTION  42


                 SODIUM  HYDROSULFIDE  INDUSTRY



42.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL


42.1.1 Industry Profile and Analytical Results

    Sodium hydrosulfide  is   used   in   the manufacture of  sodium
sulfide and other chemicals and  paper   (Kraft) .   It is also  used
in dehairing of hides and industrial  waste water treatment.

    The industry profile for this  subcategory is given in  Table
42-1, while existing  regulations are  summarized  in Table 42-2.

    Priority pollutants  found in  the  waste  during  screening of
Sodium Hydrosulfide Plant £144 were:


         Pollutant        Concentration (ug/1)
         Phenol                    76
         Napthalene                90


    Due to the  very  small  flows and waste  loads  generated  by
this  industry,  this   subcategroy  has  been  recommended  as  a
Paragraph 8 exclusion  candidate.
                               650

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TABLE  42-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
SODIUM HYDROSULFIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                               12
                                3
                           56,900 kkg/year
                           44,700 kkg/year
                            3,800 kkg/year
                           36,500 kkg/year
                                5 years
                               14 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                   651

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TABLE  42-2 -      EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES


SUBCAIEGORY        Sodium Hydrosulf ide

SUBPART            BD  (40CFR  415.560, 5/22/75)


                                        STANDARDS

                           BBCTCA             BATEA             NSPS
                          1          2
                      Max.      Avg.      Max.   Avg.       Max.      Avg.
 Product     Para-     kg/kkg    k/kkg    k/kkg  k/kkg     k/kkg    k/kkg
 Process     meters    (mg/1)     (mg/1)     (mg/1)  (mg/1)     (mg/1)    (mg/1)

 Sodium
 Hydro-      Reserved       Reserved        Reserved         Reserved
 Sulfide
 Max, = Maximum of any one day.
 2
 Avg. = Average of daily values  for thirty consecutive days shall not exceed.
                                   652

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                          SECTION 43
                SODIUM  SILICOFLUORIDE INDUSTRY
43.1 ASSESSMENT OF THE WATER  POLLUTION POTENTIAL
43.1.1 Industrial Profile  and  Analytical Results

    Sodium Silicofluoride is  used  in the  manufacture of sodium
fluoride and  in   the   light  metal industry as a protective agent.
It  is also  used  as an insecticide,  as  a  fluxing  and  opaquing
agent for ceramics and in  detergent  products.

    The industry profile  for  this subcategory is given in  Table
43-1, while existing  regulations are summarization in Table 43-2.

    This subcategory  was not  included  in  the  present study.
Screening has been recommended under Phase II.
                               653

-------
      43-1           SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY          SODIUM SILICOFLUORIDE

Total subcategory capacity rate
Total subcategory production rate                51,800 kkg/year
Number of plants in this subcategory                 6
308 Data on file for                                 1
    With total capacity of                        7,460 kkg/year
    With total production of                      3,970 kkg/year
    Representing capacity
    Representing production                        7.5 percent
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                  654

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TABLE 43-2  ~     EXISTING REGULATIONS  ~  EFFLUENT LIMITATION GUIDELINES

SUBCATEGORY        Sodium Silicofluoride

SUBPART            BF  (40CFR  415.580, 5/22/75)


""                                       STANDARDS

                           BPCTCA*            BATEA*            NSPS*
                      Max.      Avg,      Max.   Avg.      Max.      Avg.
 Product     Para-     kg/kkg    k/kkg    k/kkg k/kkg    k/kkg    k/kkg
 Process     meters    (mg/1)     (mg/1)     (mg/1)  (mg/1)     (mg/1)    (mg/1)

 Sodium                0 -       0 25

 &    Fluorlae  <«•<»*•  «»•«
            mcc       0-6       0.3
                      (48.0)    (24.0)
 Sections 415.580,  415.581,  and 415.582 were  revoked by the Agency and are
 presently reserved (41 FR 51601, November 23,  1976) .
 "wax, = Maximum of any one day,
 o
 Avg. = Average of daily values for thirty consecutive days shall not exceed.



**flow basis  12,500 1/kkg.
                                     655

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                           SECTION 44


                  SODIUM  THIOSULFATE INDUSTRY



44.1 ASSESSMENT OF THE WATER POLLUTION POTENTIAL


44.1.1 Industry Profile  and Analytical Results

    Sodium thiosulfate  is extensively used in the development of
negatives and  prints  in   the  photographic industry.  It is also
used in  medicine, in  the paper and dyeing  industries  and as a
bleaching agent for  natural products.

    The industry  profile data are  given  in Table 44-1,  while
existing regulations are summarized in Table 44-2.

    No priority  pollutants were found  at significant levels in
the  raw waste during  screening of Sodium Thiosulfate Plant #987.

    On the  basis of  these findings, this subcategory has  been
recommended as an exclusion candidate under Paragraph 8.
                              656

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TABLE 44-.1
SUBCATEGORY PROFILE DATA .SUMMARY
SUBGATEGORY
SODIUM THIOSULFATE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum.
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                                6
                                5
                            88,000 kkg/year
                            70,300  kkg/year
                            4,400 kkg/year
                           27,000 kkg/year
                               3 years
                              51 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chenical Industry."
                                   657

-------
TABLE  44-Z -      EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES
SUBCATEGORY

SUBPART
      Sodium Thiosulfate

      BG  (40CFR  415.590, 5/22/75)
                                        STANDARDS
 Product
 Process
Para-
meters
      BPCTCA
Max.      Avg.
kg/kkg    k/kkg
 (mg/1)     (mg/1)
   BATEA
Max.   Avg.
k/kkg  k/kkg
 (mg/1)  (mg/1)
    NSPS
Max.     Avg.
k/kkg    k/kkg
 (mg/1)    (mg/1)
 Sodium
 Thio-
 sulfate
Reserved
     Reserved
Reserved
Reserved
 "Max, = Maximum of any one day.
 2
  Avg. = Average of daily values for thirty consecutive days shall not exceed.
                                     658

-------
                           SECTION 45


                     SULFUR DIOXIDE INDUSTRY



45.1 ASSESSMENT OF  THE  WATER POLLUTION POTENTIAL


45.1.1 Industry Profile and Analytical Results

    Most sulfur  dioxide  is  produced  in  the  gaseous   form,
although  a small percentage is also produced in liquid  form.   In
the  gaseous   form,    it  is  predominantely  used   in  on-site
manufacture of sulfuric acid.  It  is also  used in the  paper  and
petroleum industries, as  well as for fermentation control  in  the
wine industry, for   bleaching in the textile and food   industries
and  in the production of other chemicals.

    The industry profile data in this subcategory  are  given   in
Table 45-1, while existing  regulations are  summarized  in   Table
45-2.

    No priority pollutants  were found at significant   levels  in
the  waste during screening of Sulfur Dioxide  Plant #363.   On  the
basis of these findings, this subcategory has been recommended  as
an exclusion  candidate  under Paragraph 8.
                               659

-------
TABLE  45-1
SUBCATEGORY PROFILE DATA SUMMARY
SUBCATEGORY
                     SULFUR DIOXIDE
Total subcategory capacity rate
Total subcategory production rate
Number of plants in this subcategory
308 Data on file for
    With total capacity of
    With total production of
    Representing capacity
    Representing production
    Plant production range:
            Minimum
            Maximum
    Average production
    Median production
    Average capacity utilization
    Plant age range:
            Minimum
            Maximum
    Wastewater flow range:
            Minimum
            Maximum
    Volume per unit product:
            Minimum
            Maximum
                               15
                                5
                          453,000 kkg/year
                          364,000 kkg/year
                           27,800 kkg/year
                          170,000 kkg/year
                                3 years
                               51 years
Sources of data are Stanford Research Institute, Directory of Chemical
Producers, U.S.A., 1977, U.S. Department of Commerce, Current Industrial
Reports, December 1977; Energy and Environmental Analysis, Inc.; Draft
Report, "Preliminary Economic Assessment of Effluent Limitations in the
Inorganic Chemical Industry."
                                    660

-------
     45-2  -     EXISTING REGULATIONS  -  EFFLUENT LIMITATION GUIDELINES

SUBCATEGORY        Sulfur Dioxide

SUBPART            BI   (40CFR  415.610,  5/22/75)


^                                       STANDARDS

                           BPCTCA            BAIEA            NSPS
                          1         2
                      Max.       Avg.      Max.   Avg.      Max.     Avg.
Product     Para-     kg/kkg    k/kkg     k/kkg  k/kkg     k/kkg    k/kkg
Process     meters    (mg/1)     (mg/1)     (mg/1)  (mg/D     (mg/D    (mg/D


D'oxide     Reserved        Reserved        Reserved        Reserved
 Max, = Maximum of any one day.
 2
 Avg. = Average of daily values  for thirty consecutive days shall not exceed.
                                    661

-------
                          REFERENCES

1.   U.S. Environmental Protection Agency.  Major Inorganic
    Products, Development Document.  EPA-44Q/l-74-007a, 1974.

2.   U.S. Environmental Protection Agency.  Development Document
    for Interim Final Effluent Limitations Guidelines and
    Proposed New Source Performance Standards for the Signifi-
    cant Inorganic Products.  EPA-440/1-75-037, 1975.  358 pp.

3.   Calspan Corp.  Addendum to Development Document for Effluent
    Limitations Guidelines and New-Source Performance Standards.
    Major Inorganic Products Segment of Inorganic Chemicals
    Manufacturing Point Source Category.  Contract No.
    68-01-3281, 1978.

4.   Sampling Screening Procedure for the Measurement of Priority
    Pollutants.  U.S. Environmental Protection Agency, 1976.
    6 pp.

5.   Coleman, R. T., J. D. Colley, R. F. Klausmeiser, D. A.
    Malish, N. P. Meserole, W. C. Micheletti, and K.
    Schwitzgebel.  Treatment Methods for Acidic Wastewater
    Containing Portntially Toxic Metal Compounds.
    EPA Contract No. 68-02-2608, U.S. Environmental Protection
    Agency, 1978.  220 pp-

6.   Kraus, K. A., and H. 0. Phillips.  Processes for Removal
    and/or Separation of Metals from Solutions.  U.S. Patent
    3,317,312, U.S. Patent Office, May 2, 1967.  9 pp.

7.   Scott, M. C.  Heavy Metals Removal at Phillips Plating.
    WWEMA Industrial Pollution Conference, St. Louis, Missouri,
    1978.  16 pp.
                        TM
8.   Scott, M. C.  Sulfex   - A New Process Technology for
    Removal of Heavy Metals from Waste Streams.  The 32nd
    Annual Purdue Industrial Waste Conference, Lafayette,
    Indiana, 1977.  17 pp.

9.   Patterson, J. W., and R. A. Minear.  Wastewater Treatment
    Technology.  Illinois Institute of Technology, 1973.

10.  Patterson, J. W.  Wastewater Treatment Technology.  Ann
    Arbor Science Publishers, Inc.  Ann Arbor, Michigan, 1975.


                            662

-------
                      REFERENCES (continued!

11.   Schlauch, R. M., and A. C. Epstein.  Treatment of Metal
      Finishing Wastes by Sulfide Precipitation.
      EPA-600/2-75-049, U.S. Environmental Protection Agency,
      1977.  89 pp.

12.   Campbell, H. J., Jr., N. C. Scrivner, K. Batzar, and
      R. F. White.  Evaluation of Chromium Removal from a Highly
      Variable Wastewater Stream.  The 32nd Annual Purdue
      Industrial Waste Conference,  Lafayette, Indiana, 1977.
      38 pp.

13.   Wing, R. E., C. L. Swanson, W. M. Doane, and C. R. Russell.
      Heavy Metal Removal with Starch Xanthate-Cationic Polymer
      Complex.  J. Water Pollution Control Federation, 46(8):
      2043-2047, 1974.

14.   Wing, R. E.  Heavy Metal Removal from Wastewater with Starch
      Xanthate.  In: Proceedings of the 29th Annual Purdue
      Industrial Waste Conference,  Lafayette, Indiana, 1974.
      pp. 348-356.

15.   Wing. R. E.  Removal of Heavy Metals from Wastewater with
      a Starch Xanthate-Cationic Polymer Complex.  The 46th
      Annual Conference of the Water Pollution Control Federation,
      Cleveland, Ohio, 1973.  38 pp.

16.   Wing, R. E. Removal of Heavy Metals from Wastewater with
      Starch Xanthate.  Presented at the Traces of Heavy Metals
      in Water: Removal and Monitoring Conference, Princeton,
      New Jersey, 1973.  pp. 258-273.

17.   Swanson, C. L., R. E. Wing, W- M. Doane, and C. R. Russell.
      Mercury Removal from Waste Water with Starch Xanthate-
      Cationic Polymer Complex.  Environmental Science & Tech-
      nology 7(7):614-619, 1973.

18.   Hanway, J. E., Jr., R. G. Mumford, and D. G. Barth.  A
      Promising New Process for Removing Heavy Metals from
      Wastewater.  Civial Engineering-ASCE 47(10) : 78-79, 1976.

19.   Hanway, J. E., Jr., R. G. Mumford, and P. N. Mishra.
      Treatment of Industrial Effluents for Heavy Metals Removal
      Using the Cellulose Xanthate Process.  The 71st Annual
      Meeting of the American Institute of Chemical Engineers,
      Miami, Florida, 1978.  21 pp.

20.   Wing, R. E., L. L. Navickis,  B. K. Jasberg, and W. E.
      Rayford.  Removal of Heavy Metals from Industrial Waste-
      waters Using Insoluble Starch Xanthate.  EPA-600/2-78-085,
      U.S. Environmental Protection Agency, 1978.  116 pp.


                               663

-------
                   REFERENCES  (.continued)

21.   de  Jong,  G.  J.,  and  Ir. C.  J.  N.  Rekers.   The  Akzo  Process
     for the Removal  of Mercury  from Waste Water.   Journal  of
     Chromatography 102:  443-451, 1974.

22.   van der Heem,  P.  The  Removal  of  Traces  of Heavy  Metals
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23.   Chemical  Marketing Recorder, July 24,  1978.

24.   Slen, T.  T., M.  Chem,  and J. Lauber.   Incineration  of  Toxic
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25.   TRW Systems  Group.   Recommended Methods  of Reduction,
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26.   Ellerbusch,  F.,  and  H. S. Skrovronek.  Oxidative  Treatment
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27.   Knopp, P. V.,  and T. L. Randall.  Detoxification  of Specific
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28.   Arthur D. Little, Inc.  Treatment Technology Handbook.

29.   Schell, W. J.  Membrane Ultrafiltration  for Water Treatment.
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30.   Vanderborght,  B.  M., and R. E. Van  Grieken.  Enrichment
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31.   Cheremisinoff, P. N.,  and F. Ellerbusch.   Carbon  Adsorption
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32.   Jacobs Engineering Group, Inc. Study of the Application of
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                             664

-------
                     REFERENCES (.continued}

35.  Rubel, F., Jr., and R. D- Woosley.  Removal of Excess
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36.  Wu, Y. C.  Activated Alumina Removes Fluoride Ions From
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37.  Maier, F. J.  Partial Defluoridation of Water.  Public
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38.  Maier, F. J.  New Fluoride Removal Method Cuts Costs.
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43.  Gupta, S., and K. Y. Chen.  Arsenic Removal by Adsorption.
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44.  Larsen, H. P., J. K. Shou, and L. W. Ross.  Chemical  Treat-
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45.  Nilsson, R.  Removal of Metals by Chemical Treatment of
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46.  Sorg, T. J., 0. T. Love, and G.  S. Logsdon.  Manual of
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     Environmental Protection Agency, 1977.  73 pp.
                               665

-------
                    REFERENCES  (.continued)

47.  Colley,  J. D.,  C. A. Muela,  M.  L.  Owen,  N.  P. Meserole,
    J. B.  Riggs,  and J. C.  Terry.   Assessment of  Technology
    for Control of  Toxic Effluents  from the  Electric  Utility
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    Agency,  1978.

48.  Smithson,  G.  R., Jr.   An Investigation of Techniques  for
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49.  Patterson, J. W., H. E. Allen,  and J. J.  Scala.   Carbonate
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50.  Sabadell,  J.  E. Traces of  Heavy Metals  in Water  Removal
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51.  U.S.  Environmental  Protection Agency.  Environmental
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    Chemicals. EPA Contract No. 68-03-2403,  1977.
                                666

-------
                         BIBLIOGRAPHY

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  Heavy Metal  Sulfides.  U.S.  Patent 3,740,331.   U.S.  Patents
  Office.  June 19, 1973.

Birkett, J. D.  Electrodialysis - An Overview.   Industrial
  Water Engineering 14(5):6-9,  1977.

Bowen, L. B., J. H. Mallinson,  and J. H. Cosgrove.   Waste
  Recovery: Zinc Recovery from Rayon Plant Sludge.  Chemical
  Engineering  Progress 73(5):50-54, 1977.

Case, 0. P.  Metallic Recovery  from Waste Waters  Utilizing
  Cementation.  EPA 670/2-74-008.  U.S. Environmental
  Protection Agency, 1974.   36 pp.

Cheng M. H., J. W. Patterson, and R. A. Minear.   Heavy  Metals
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  Federation 47 (2) :362-376,  1975.

Cheremisinoff,  P. N., and Y.  H.  Habib.  Cadmium,  Chromium,  Lead,
  Mercury: A Plenary Account for Water Pollution.   Part 2  -
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  1972.

Cohen, J. M.  Trace Metal Removal by Wastewater Treatment.
  EPA Technology Transfer, 1977.

Current Industrial Reports Inorganic Chemicals.   U.S.  Department
  of Commerce  Bureau of the  Census, 1977.

Davis, H. J., F. S. Model, and  J. R. Leal.   PBI Reverse Osmosis
  Membrane for Chromium Plating Rinse Water.   EPA-600/2-78-040.
  U.S. Environmental Protection Agency, 1978.   35 pp.
                               667

-------
                    BIBLIOGRAPHY - continued

Dean, J. G., F. L. Bosqui, and K. H. Lanouette.  Removing Heavy
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Dow Chemical Company.  Selecting Ion Exchange Resins for Water
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Energy and Environmental Analysis, Inc.  Draft Preliminary
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FMC Corp.  Industrial Wastewater Treatment.  A guidebook to
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   Pennsylvania.

FMC Corp.  Hydrogen Peroxide.  Chemical and Technical Data.
   Philadelphia,  Pennsylvania.

Ford, D. L.  Putting Activated Carbon in Perspective to 1983
   Guidelines.  Industrial Water Engineering 14(3):20-27,  1977.

General Technology Corporation.  Draft Contractor Document for
   Major Inorganic Chemicals.  1973.

General Technology Corporation.  Final Contractor Document for
   Major Inorganic Chemicals.  1975.

Greek, B. F., and W. F. Fallwell.  Chlorine,  Major Alkalies.Still
   in Doldrums.  Chemical and Engineering News 56(6):8-ll, 1978.

Grover, P.  A Waste Stream Management System.  Chemical
   Engineering Progress 73 (12) :71-73, 1977.

Haggenmacher, J.  H.   Chromate Removal Decreases Slowdown to
   Below 0.05 ppm Hexavalent Chrome.  Chemical Processing, 1977.

Hoyle, D. L. Designing for pH Control.  Chemical Engineering
   83 (24) :121-126, 1976.

Jacobs Engineering Group, Inc.  Estimating Standards

Jenkins, S. H., D. G. Keight, and R. E. Humphreys.  The Solu-
   bility of Heavy Metal Hydroxides in Water, Sewage and Sewage
   Sludge - I The Solubility of Some Metal Hydroxides.   Int.
   J. Air Wat. Poll. 8:537-556, 1964.

Jenkins, S. H., D. G. Keight, and A. Ewins.  The Solubility of
   Heavy Metal Hydroxides in Water, Sewage, and Dewage Sludge -
   II The Precipitation of Metals by Sewage.   Int. J. Air Wat.
   Poll. 8:679-693,  1964.

                               668

-------
                   .BIBLIOGRAPHY - continued

Keating, E. J., R. A.  Brown,  and E. S.  Greenberg.   Phenolic
   Problems Solved with  Hydrogen Peroxide Oxidation.   The
   33rd Annual Industrial  Waste Conference,  West Lafayette,
   Indiana, 1978.  20  pp.

Kibble, W. H.  Hydrogen  Peroxide Helps  Solve Industrial Waste-
   water Problems.   Industrial  Wastes 26-29, 1978.

Knocke, W. R., T. Clevenger,  M.  M. Ghosh, and J. T.  Novak,
   Recovery of Metals  from Electroplating Wastes.   The 33rd
   Annual Industrial Waste Conference,  west  Lafayette, Indiana,
   1978.  37  pp.

Lanouette, K. H.  Heavy  Metals  Removal.  Chemical  Engineering
   Deskbook Issue 84(22):73-80,  1977.

Linstedt, K.  D., C.  P. Houck, and J.  T. O'Connor.   Trace
   Element Removals  in Advnaced Wastewater Treatment  Processes.
   Journal Water Pollution Control Federation 43 (7) :1507-1513,
   1971.

Mir,  L., W. Eykamp,  and  R. L. Goldsmith.  Current  and Developing
   Applications for  Ultrafiltration.   Industrial Water
   Engineering 14(3):14-19, 1977.

Morton, S. D., and E.  W. Sawyer.  Clay  Minerals Remove Organics,
   Viruses and Heavy Metals from Water.  Water and Sewage Works
   123(Reference No. 1976):R-117-R120,  1976.

Porter, J. W., Brothers, G. W.,  and W.  B. Whitton.   Cost
   Estimating Guidelines for  Wastewater Treatment  Systems.
   EPA 17090  DRU.  U.S.  Environmental Protection Agency, 1970.
   96 pp.

Resources Conservation Co. The RCC Brine Concentrator.  Renton,
   Washington.

Richardsons Estimating Standards.  Means Cost Data.   1978.

Rizzo, J. L., and A. R.  Shepherd.  Treating  Industrial Waste-
   water with Activated  Carbon.   Chemical Engineering 84(1):
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Rosenzweig, M. D.  Mercury Cleanup Routes -  I Chemical
   Engineering 82(2):60-61, 1975.

Sabadell, J.  E., ed.   Traces  of Heavy Metals in Water Removal
   Processes  and Monitoring.  EPA-902/9-74-001.  U.S. Environ-
   mental Protection Agency,  1973.  342 pp.
                                669

-------
                     BIBLIOGRAPHY - continued

Shen, Y.S.  Study of Arsenic Removal from Drinking Water.  Water
    Journal American Water Works Association 65 (8):543-548, 1973.

Sigworth, E. A., and S. B. Smith.  Adsorption of Inorganic
    Compounds by Activated Carbon.  Journal American Water Works
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    a Metal Finishing Job Shop.  EPA-670/2-74-042.  U.S. Environ-
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    From Waste Water.  Chemical Engineering Progress 73(5):60-64,
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                                 670

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                        ACKNOWLEDGEMENTS
     The  staff   of  Jacobs   Environmental  Division  of  Jacobs
Engineering   Group  Inc.   is gratefully  acknowledged  for  their
assistance   in   field  investigations,  sample analysis, technical
engineering,  and preparation  of the report.  Mr. Henry Cruse was
Program Director at Jacobs,  the  Project Manager was Mr.  Michael
Warner,   and  the Jacobs personnel who  provided  major  technical
input to  this project  were:
     Bonnie  J.  Parrott
     Mazhar  Mohiuddin
     Mahendra  L.  Shah
     Carl  B. Johnston
     Dr.  Kar Y.  Yu
     W.  Dennis  Merklin
     Mark  K. Jackson
John H. Taylor, Jr.
  (Laboratory Director)
Dr. Nelson F. Phelan
  (Senior Analytical Chemist)
Dale R. Rushneck
  (Mass Spectroscopist)
     Acknowledgement and  appreciation  are also extended to  Dr.
Martin   D.   Schwartz  and  Dr.  Ben  C.  Edmondson  of Technology
Associates   of Southern California,  Inc.  for  their  invaluable
contributions  to  the project.

     The assistance of the EPA project officers and  staff of the
Effluent Guidelines  Division   is  also   greatly  appreciated,
including the  guidance  given by Mr. Walter J. Hunt who  was  the
Inorganic Chemicals Branch Chief through January, 1979.
                                671

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                         APPENDIX A
               ANALYSIS OF  LONG TERM  EFFLUENT
                       MONITORING DATA
                             FOR
              THE INORGANIC CHEMICALS  INDUSTRY
INTRODUCTION
     This appendix  contains   tabulated    summaries   of   the
statisical parameters derived  from  the analysis  of long   term
effluent monitoring data colleced by  industry  and  reported  to
the EPA or state regulatory agencies  during  the last two   or
three  years.   The  particular   sets of  data  selected   for
analysis are  taken from  plants  which  apply  a  well defined
treatment  technology to  process   waste waters  from single
product or product group manufacturing operations  associated
with a specific  subcategory.  Data have   been excluded which
represent waste waters diluted with   noncontact  cooling water
or  commingled with waste  sources  from unrelated   products.
Each table in the appendix  indicates the   actual   number  of
observations on which  the  calculated statistical parameters
are based.  The derivation of  the parameters was discussed  in
Section 9 of the draft report.

     The statistical  performance information  presented   here
was used  to  develop the  control  parameter limitations   for
each subcategory  considered   in  detail in  the  main  report.
These were expressed as the achievable Quality Limits  (mg/1)
and Emission  Limits (kg/kkg)  for each pollutant assuming  the
model  plant  flow  conditions  and   applying  the   specified
pollutant removal technologies  at  each  level of  treatment.
The  tables on the  following  pages   summarize the   available
historical  effluent   monitoring   results    and  give    the
individual plant performance characteristics in  concentration
and  loading units for both daily and monthly  measurements.
Three  sets of  variability  factors  are shown on  each table
however,  only  the  middle value (Variability  Factor II)  is
used to calculate the plant "Performance Standards"  shown   in
the  right  hand  column  of   each  table.   Similarly,    the
Variability   Factor  Ratio  (VFR)  used   to  calculate   the
subcategory   "Control   Parameter    Limitations"    is    the
Variability  Factor  II  for   daily  measurements  divided  by
Variability Factor II for 30-day  average data.

     In general,  the  monitoring time period  for  most firms
doing so  for NPDES permits was from  January  1, 1975 through
June 30,  1976.   Firms  who   monitored  over this  time period
provided up to 18  months of 30   day  average data  and as  many

                           A-l

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as 547 measurements of daily or  24  hour  data.   In  cases  where
monitoring  was  done  less  frequently   than   daily,  perhaps
omitted on weekends,  or only weekly  measurements,  the actual
number of  observations  used in  the calculation  is  recorded
for each parameter.

     Included  in   this   Appendix   are  statistical   measures
appropriate to the  analysis of  long  term monitoring data  and
the  historical  performance of  inorganic  chemical pollutant
discharge levels.  The   statistics  presented  include measures
of amount or level of pollutant  discharge,  such as   long term
average, minimum level,  and maximum level for  both  daily,  or
24 hour measurements, as well as  30 day  average measurements.

     Also given  in   the  table   is   the  co-efficient    of
variation, CV, which relfects the   dispersion  of measurements
above and below the long term average level.   Other  measures
of variability  that  may be of   interest,   such as range  or
standard deviation are also calculated for  any parameter from
any  information given herein.   In  addition to statistics  of
pollutant  level   and  variation   of  pollutant  level,  three
variability  factors  are  printed  in  each   parameter.    A
variability factor is the ratio  of  an upper percentile of  the
distribution   of   pollutant  measurements  to   the   long term
average pollutant  level.  The basis   of the  particular  upper
percentile  chosen for Variability  Factors  I,  II,  and  III  is
explained as a footnote  to the table.

     The historical   performance   of   each    firm,  using
Variability Factor II,   is given   for each   parameter  and  is
expressed in the same units as the  long  term  average.

     For reference, the  tables in  this Appendix are organized
by  inorganic  chemical  subcategory   and  the  manufacturing
process in that subcategory.  For  each plant,  as many as four
tables  are included.    These tables  appear in  the following
order :
      1.   Daily measurements  of  pollutant concentrations  in  the
      effluent stream  given  in  parts  per  million (ppm).

      2.   Daily measurements  of  total effluent discharge  load
      measured in  kilograms  per  day.

      3.   30 Day averages  of  pollutant concentration (ppm).

      4.   30 Day averages  of  total  effluent pollutant load
      (kg/day) .
                           A-2

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                           Table A-la

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #747
 Parameter

   (ppn)
         Historical Summary
             Statistics
Variability   Performance
  Factors      Standards
        No  Min Aver  Max  CV
     II  III    (V.F. II)
Mercury,Hg   530 .006 .014 .021 .286 1.54 1.88 2.15

TSS          530  1.00 7.4  62. .581 2.09 3.04 3.87

Chlorine,C12 428 0.08 .638 1.50 .463 1.75 2.28 2.71

 (Total Residual)
                                                 .026

                                                 22.5

                                                 1.46
  I -
 II -
III -
95% of the daily maximum measurements expected to be less
than the performance standard, P.
(Z = 1.64)

99% of the daily maximum measurements expected to be less
than the performance standard, P.
(Z = 2.33)

All but one daily maximum measurement per year expected
to be less than the performance standard, P.
(Z = 2.78)
                              A-3

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                           Table A-lb

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #747
 Parameter

  (kg/day)
 Historical Summary
     Statistics
Variability   Performance
  Factors      Standards
No  Min Aver  Max  CV
     II  III   (V.F. II)
Mercury,Hg   530 .015 .031 .047 .129 1.24 1.66 1.84    .051

Chlorine,C12 420 .156 1.44 3.40 .463 1.87 2.54 3.09    3.65
(Available)
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-4

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                           Table A-lc

           Historical Effluent Monitoring Data Summary
       with Variability factors and Performance Standards
                         30 "Day Averages
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #747
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppn)       No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg    18 .008 .014 .020 .293 1.40 1.47 1.67    0.21

TSS           18  5.1  7.4 12.9 .355 1.49 1.58 1.83    11.7

Chlorine,C12  18 .380 .638 .847 .194 1.27 1.38 1.45    0.88
 (Available)
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-5

-------
                           Table A-ld

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #747
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg    18 .020 .031 .037 .197 1.28 1.33 1.47    .041

Chlorine,C12  18  .91 1.44 2.23      1.35 1.50 1.59    2.16
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                               A-C

-------
                           Table A-2a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #317
               Historical Summary
                   Statistics
Parameter

  (ppb)       No  Min Aver  Max  CV    I
Variability   Performance
  Factors      Standards
                                            II  III   (V.F. II)
Mercury,Hg   516 .041 .634 2.87 .910 2.62 4.52 6.40    2.87
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-7

-------
                           Table A-2b

           Historical Effluent Monitoring Eata Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #317
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III   (V.F. II)
Mercury,Hg  516 .0005 .011 .088 .818 2.58 4.35 6.10    .046
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-8

-------
                           Table A-2c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Chlorine Subcategory
                      Mercury Cell Process
                           Plant #317
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppb)      No  Min Aver  Max  CV    I    II  III   (V.F. II)
Mercury,Hg    17 .325 .634 1.15 .293  1.42 1.45 1.68    0.919
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-9

-------
                           Table A-2d

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #317
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
    (kg/day)      No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg       17 .005 .011 .019 .273 1.38 1.45 1.64    .015
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-10

-------
                           Table A-3a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #195
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppm)       No  Min Aver  Max  CV    I    II  III   (V.F. II)
Mercury,Hg  349 .0005 .014 .136 2.29 3.69 9.45 17.49   0.132
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-ll

-------
                           Table A-3b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #195
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg  349 .0001 .003 .088 2.33 3.77 10.22 19.60   .028
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-12

-------
                           Table A-3c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #195
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppn)
No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg   17 .0009 .014 .062 1.21 2.67 2.99 3.82    .042
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-13

-------
                           Table A-3d

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #195
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg   17 .0002 .003 .014 1.33 2.88 3.22 4.15   .0088
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-14

-------
                           Table A-4a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #324
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppn)      No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg    82.002  .004 .011 .500 1.73 2.24 2.66   0.009

Chlorine,C12  49 2.0  19.1   62 1.01 2.78 4.96 7.23    94.7
(Total Residual)
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-15

-------
                           Table A-4b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #324
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg    82 .021 .047 .118 .383 1.71 2.20 2.66    .104

Chlorine,C12  49 20.5  203  663 1.03 2.81 5.04 7.39    1026
 (Residual)
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-16

-------
                           Table A-4c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #324
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppm)      No  Min Aver  Max  CV    I    II  III    (V.F. II)
Mercury,Hg    22 .003 .004 .008 .250 1.42 1.60 1.71   0.006

Chlorine,C12  14  4.0 19.1 57.8 .969 2.34 2.91 3.25    55.6
(Total Residual)
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-17

-------
                           Table A-4d

           Historical Effluent Monitoring Eata Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Subcategory Chlorine
                      Mercury Cell Process
                           Plant #324
 Parameter

   (kg/day)
 Historical Summary
     Statistics
Variability   Performance
  Factors      Standards
No  Min Aver  Max  CV
     II  III    (V.F. II)
Mercury,Hg    22 .032 .047 .098 .340 1.47 1.66 1.78    .079

Chlorine,C12  14 39.1  203  616 .945 2.33 2.89 3.22     588
(Residual)
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-18

-------
                           Table A-5a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                      Subcategory Chlorine
                      Diaphram Cell Process
                           Plant #967
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (kg/day)       No  Min Aver  Max  CV    I    II  III   (V.F. II)
Lead,Pb         153 .045 1.42 5.40 .824 2.51 4.12 5.69    5.85
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-19

-------
                           Table A-5b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                      Subcategory Chlorine
                      Diaphram Cell Process
                           Plant #967
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (kg/day)       No  Min Aver  Max  CV    I    II  III    (V.F. II)
Lead,Fb          12 .460 1.42 5.40 .824 1.50 1.58 1.83    2.25
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-20

-------
                           Table A-6a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                        Daily Measurments
                  Subcategory Hydrofluoric Acid
                           Plant #722
 Parameter

   (ppn)
 Historical Summary
     Statistics
Variability   Performance
  Factors      Standards
No  Min Aver  Max  CV
     II  III   (V.F. II)
Arsenic,As    50 .020 .035 .100 .314 1.56 1.92 2.20   0.067

Fluoride,F   129  .25 1.39 4.00 .589 2.11 3.08 3.94    4.28

Ammonia,NH3   50  .01 .104  .40 .865 2.58 4.32 6.05   0.449

Lead,Pb       49  .10 .142 1.20 1.58 3.35 7.26 12.02   1.03

Zinc.Zn       51  .04 .140  .47 .807 2.49 4.06 5.59   0.569

TSS           41    1 21.1  144 1.13 2.93 5.48 8.23     116
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-21

-------
                           Table A-6b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Hydrofluoric Acid
                           Plant #722
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Arsenic,As    50 .052 .383 .598 .345 2.01 2.84 3.57    1.09

Fluoride,F   129 3.98 16.4 65.4 .701 2.31 3.57 4.75    58.6

Ammonia,NH3   50 .114 1.13 4.77 .982 2.75 4.85 7.02    5.48

Lead,Pb       49 .261 1.68 15.0 1.51 3.30 6.98 11.39   11.8

Zinc,Zn       51 .125 1.63 4.64 .920 2.66 4.58 6.52    7.46

TSS           41 14.2  263 1962 1.21 3.02 5.79 8.86    1525
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-22

-------
                           Table A-6c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Hydrofluoric Acid
                           Plant #722
               Historical Summary      Variability   Performance
 Parameter         Statistics           • Factors      Standards
   (ppm)      No  Min Aver  Max  CV    I    II  III    (V.F. II)
Arsenic,As     5 .020 .035 .058 .371 1.51 1.73 1.86   0.061

Fluoride,F    5 .769 1.39 2.24 .371 1.52 1.74 1.87    2.42

Ammonia,NH3    6 .028 .104 .170 .548 1.76 2.08 2.27   0.216

Lead,Pb        6 .100 .142 .322 .577 1.80 2.15 2.35   0.305

Zinc,Zn        6 .076 .140 .225 .429 1.59 1.84 1.99   0.258

TSS            5 8.83 21.1 32.4 .483 1.67 1.95 2.12    41.2
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-23

-------
                           Table A-6d

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Hydrofluoric Acid
                           Plant #722
 Parameter
Historical Summary
    Statistics
Variabilty    Performance
  Factors      Standards
(kg/day)
Arsenic, As
Fluor ide,Fl
Ammonia ,NH3
Lead,Pb
Zinc,Zn
TSS
No
5
5
6
6
6
5
Min
.215
8.09
.279
.990
.715
106
Aver
.383
16.4
1.13
1.68
1.63
263
Max
.598
28.5
2.15
3.86
2.94
433
CV
.345
.438
.639
.596
.531
.487

1
1
1
1
1
1
I
.48
.61
.89
.83
.74
.67
II
1.68
1.87
2.27
2.18
2.05
1.96
III
1.
2.
2.
2.
2.
2.
80
02
49
39
24
13
(V.F. II)
.644
30.6
2.56
3.67
3.34
516
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 U - 95% of the  monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the  monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-24

-------
                           Table A-7a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                 Subcategory Hydrofluoric Acid/
                           Plant #705
 Parameter

   (kg/day)
               Historical Summary
                   Statistics
Variability   Performance
  Factors      Standards
                 No  Min Aver  Max  CV
        II  III   (V.F. II)
Fluoride      15 4.54 16.7 27.2 .449 1.62 1.74 2.05    29.0

TSS              16 7.26 28.6 52.2 .441 1.61 1.72 2.02    49.2
  I -
 II -
III -
      All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

      95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

      99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-25

-------
                           Table A-8b

           Historical Efficient Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Titanium Dioxide
                        Chloride Process
                           Plant #172
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Man Aver  Max  CV    I    II  III    (V.F. II)


Chromium,Cr  394 .000 .013 .210 1.69 3.45 7.78 13.2    .097

Copper,Cu    394 .000 .027 .190 1.04 2.85 5.20 7.70    .139

Zinc,Zn      394 .000 .028 .108 .679 2.25 3.42 4.50    .097

TSS          394 0.40 8.34 176. 1.92 3.54 8.35 14.6    69.7
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-26

-------
                           Table A-8c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Titanium Dioxide
                        Chloride Process
                           Plant #172
Parameter
(ppn)
Chromium, Cr
Copper ,Cu
Zinc,Zn
TSS
Historical Summary
Statistics
No
13
13
13
13
Min
.000
.000
.001
1.20
Aver
.004
.010
.012
3.14
Max
.013
.030
.026
8.60
CV
.750
.700
.500
.599
Variability
Factors
I
2.03
2.01
1.66
1.83
II
2.46
2.43
1.93
1.98
III
2.72
2.69
2.10
2.39
Performance
Standards
(V.F. II)
0.010
0.024
0.023
6.22
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-27

-------
                           Table A-8d

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Titanium Dioxide
                        Chloride Process
                           Plant #172
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Chromium,Cr   13 .002 .013 .043 .769 2.14 2.62 2.91    .033

Copper,Cu     13 .000 .027 .100 .852 2.22 2.74 3.04    .073

Zinc,Zn       13 .004 .028 .051 4.29 1.56 1.80 1.94    .051

TSS           13 2.60 8.34 24.0 .695 1.96 2.14 2.62    17.9
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-28

-------
                           Table A-9a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Titanium Dioxide
                         Sulfate Process
                           Plant #559
 Parameter

   (ppn)
  Historical Summary
      Statistics
                                       Variability   Performance
                                         Factors      Standards
 No  Min Aver  Max  CV
                                            II  III    (V.F. II)
Cadmium,Cd

Chromium,Cr

Iron,Fe
(total)

Iron,Fe
(diss)

Lead, Pb

Nickel,Ni

Zinc,Zn

TSS
              26 .001 .009 .020 .444 1.77 2.03 2.35   0.018

              26 .010 .021 .070 .857 2.54 4.23 5.87   0.088

              30  .40 3.25 19.1 1.42 3.24 6.74 10.9    21.9


             153 .080 .279 4.98 2.01 3.59 8.64 15.32   2.41
 26 .002 .017 .050 .765 2.35 3.67 4.91

 26 .010 .029 .080 .690 2.29 3.52 4.66

 26 .010 .027 .300 2.11 3.63 9.93 18.8

183      35.8      1.71 3.44 7.70 13.0
                                                      0.062

                                                      0.102

                                                      0.268

                                                       276.
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-29

-------
                           Table A-9b
           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Titanium Dioxide
                         Sulfate Process
                           Plant #559
               Historical Summary
 Parameter         Statistics

  (kg/day)    No  Min Aver  Max  CV
                          Variability   Performance
                            Factors      Standards
                               II  III   (V.F. II)
Cadmium,Cd

Iron,Fe
(Total)

Iron,Fe
(Diss)

Lead, Pb

Nickel,Ni

Zinc,Zn

TSS
 26 .004 .062 .119 .435 1.83 2.44 2.95    .151

 30   29 214. 1299 1.44 3.24 6.74 10.9    1444


153  4.0 19.4 400. 2.37 3.70 9.56 17.74   186.


 26 .008 .115 .297 .652 2.23 3.36 4.40    .385

 26 .057 .191 .463 .675 2.26 3.45 4.55    .658

 26 .049 .190 2.24 2.24 3.67 9.24 16.9    1.75

183  57. 2390      1.76 3.46 7.86 13.4   18784
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-30

-------
                           Table A-9c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Titanium Dioxide
                         Sulfate Process
                           Plant #559
Parameter
(PPtn)
Cadmium, Cd
Chromium, Cr
Iron,Fe
(Total)
Iron,Fe
(Dissolves)
Lead , Pb
Nickel ,Ni
Zinc,Zn
TSS
Historical Summary Variability
Statistics Factors
No
6
6
1

5
6
6
6
6
Win Aver Max
.003 .009 .013
.010 .021 .035
3.25

.150 .279 .400
.003 .017 .028
.012 .029 .042
.010 .027 .068
1.57 35.8 74.8
CV I II III
.333 1.46 1.55 1.78
.429 1.59 1.70 2.00
.259 1.36 1.42 1.60

.330 1.46 1.54 1.77
.529 1.68 1.80 2.14
.346 1.49 1.57 1.82
.741 2.05 2.23 2.75
.866 2.20 2.42 3.01
Performance
Standards
(V.F. II)
0.014
0.036
4.62

.430
0.031
0.045
0.060
86.6
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-31

-------
                           Table A-9d

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Titanium Dioxide
                         Sulfate Process
                           Plant #559
Parameter
(kg/day)
Cadmium, Cd
Chromium, Cr
Iron,Fe
(diss)
Lead,Pb
Nickel ,Ni
Zinc,Zn
TSS
Historical Summary
Statistics
No Min
6 .016
6 .070
5 10.0
6 .021
6 .080
6 .074
6 116.
Aver
.062
.136
19.4
.115
.191
.190
2390
Max
.085
.202
27.0
.160
.258
.498
4797
CV
.355
.338
.291
.417
.330
.774
.857
Variability
Factors
I
1.49
1.47
1.40
1.59
1.46
2.08
2.19

1.
1.
1.
1.
1.
2.
2.
II
58
56
46
69
54
27
41
III
1.83
1.79
1.68
1.98
1.77
2.81
3.00
Performance
Standards
(V.F. II)
.098
.212
28.4
.194
.294
..431
5759
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the  monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the  monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-32

-------
                           Table A-lOa

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Aluminum Fluoride
                           Plant #251
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppm)       No  Man Aver  Max  CV    I    II  III   (V.F. II)
Lead,Pb      152 0.11 2.28 12.8 .601 2.13 3.12 4.01    7.11
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                               A-33

-------
                           Table A-lOb

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Aluminum Fluoride
                           Plant #251
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)     No  Min Aver  Max  CV    I    II  III   (V.F. II)
Lead,Pb
152 0.09 2.15 15.3 .753 2.40 3.82 5.17    8.20
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-34

-------
                           Table A-lOc

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Aluminum Floride
                           Plant 1251
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppn)       No  Min Aver  Max  CV    I    II  III    (V.F. II)
Lead,Pb       10 1.51 2.28 3.90 .601 1.47 1.55 1.78    3.54
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-35

-------
                           Table A-lOd

           Historical Effluent Monitoring Eata Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Aluminum FLoride
                           Plant #251
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)     No  Min Aver  Max  CV    I    II  III    (V.F. II)
Lead,Pb       10 1.51 2.15 3.70 .326 1.45 1.54 1.76    3.30
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-36

-------
                           Table A-lla

           Historical  Effluent Monitoring  Data  Summary
      with Variability Factors and Performance Standards
                         30 Day Averages
                   Chrome Pigments Subcategory
                           Plant #894
Parameter
(Ppn)
Arsenic ,As
Cadmium, Gd
Chromium, Cr
(hexavalent)
Chromium,Cr
Copper ,Cu
Lead,Pb
Mercury,Hg
Zinc,Zn
Cyanide, CN
(A)
Cyanide, CN
(total)
Historical Summary
Statistics
No
23
23
23
23
23
23
23
23
23
23
Variability
Factors
Min Aver Max CV I
.0096
.050
.028
.197
.038
.217
.0004
.012
.0003
.025
.079
.079
.112
.442
.134
.412
.001
.04
.019
.118
.235
.164
.592
.799
.296
1.635
.0018
.087
.076
.316
.622
.339
1.04
.404
.529
.681
.401
.437
1.57
.995
II
2.
1.
2.
1.
1.
2.
1.
1.
3.
2.
Ill
02
56
70
66
87
12
66
72
58
63
Performance
Standards
(V.F. II)
.156
.123
.302
.733
.250
.873
.0016
.074
.068
.310
SS            23 0.27   11.2 33.3  .662      2.01         22.5
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-37

-------
                           Table A-12a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Hydrogen Cyanide
                        Andrussow Process
                           Plant #782
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
    (ppm)      No  Min Aver  Max  CV    I    II  III    (V.F. II)
Ammonia,NH3   35  14. 113. 188. .335 1.62 2.02 2.34    229
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
      expected to be within the performance standard, P.
      (Z = 1.39)
                              A-38

-------
                           Table A-12b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Hydrogen Cyanide
                        Andrussow Process
                           Plant #782
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Ammonia,NH3   35  112 1533 2419 .365 1.68 2.14 2.51    3283
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
      expected to be within the performance standard, P.
      (Z = 1.39)
                               A-39

-------
                           Table A-12c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Hydrogen Cyanide
                        Andrussow Process
                           Plant #782
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppm)      No  Min Aver  Max  CV    I    II  III    (V.F. II)
Ammonia,NH3    8  80. 113. 134. .335 1.23 1.32 1.38    150
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-40

-------
                           Table A-12d

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Hydrogen Cyanide
                       Andrussow Process
                           Plant #782
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Ammonia,NH3    8  908 1533 1941 .212 1.29 1.42 1.49    2177
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-41

-------
                           Table A-13a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                           Subcategory
                        Andrussow Process
                           Plant #765
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppm)      No  Min Aver  Max  CV    I    II  III    (V.F. II)
Cyanide,CN   534  .01 .202 3.27 1.58 3.35 7.26 12.01   1.46
(Available)

Cyanide,CN    25 .039 .192 .460 .667 2.25 3.42 4.50    .065
(Total)

Ammonia,NH3   26 .193 3.63 10.2 .636 2.29 3.51 4.64    12.7

COD           25 2.71 15.9 45.2 .552 2.04 2.90 3.66    46.1

TOC           26 .783 8.30 25.6 .845 2.55 4.22 5.88    35.0

SS            22    5   35  267 1.57 3.34 8.16 11.9     286
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-42

-------
                           Table A-13b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Subcategory Hydrogen Cyanide
                        Andrussow Process
                           Plant #765
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppm)      No  Win Aver  Max  CV    I    II  III    (V.F. II)
Cyanide,CN    19 .082 .202 .351 .391 1.54 1.78 1.91   0.359
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-43

-------
                           Table A-13c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                  Hydrogen Cyanide Subcategory
                        Andrussow Process
                           Plant #765
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)     No  Min Aver  Max  CV    I    II  III    (V.F. II)
Cyanide,CN    19 .082 .202 .351 .391 1.54 1.78 1.91    .358
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-44

-------
                           Table A-14a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Sodium Dichromate
                           Plant #493
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppn)       No  Min Aver  Max  CV    I    II  III   (V.F. II)
Chromiun,Cr  29    11   25   51 .314 1.58 1.95 2.24    48.7
 (Total)
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-45

-------
                           Table A-14b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                  Subcategory Sodium Dichromate
                           Plant #493
 Parameter
Historical Summary
    Statistics
Variability   Performance
  Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Chromium,Cr   20 .005 .046 .342 1.80 3.47 7.92 13.56   .368
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-46

-------
                           Table A-15a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                   Subcategory Nickel Sulfate
                           Plant #120
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppn)
No  Min Aver  Max  CV    I    II  III    (V.F. II)
NickelfNi     88 .080 1.83 8.33 1.21 3.03 5.84 8.96    10.7
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-47

-------
                           Table A-15b

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                       Daily Measurements
                   Subcategory Nickel Sulfate
                           Plant #120
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)     No  Min Aver  Max  CV    I    II  III    (V.F. II)
Nickel,Ni     88 1.02 8.32 44.6  1.31 3.13 6.24 9.80    51.9
  I - 95% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 1.64)

 II - 99% of the daily maximum measurements expected to be less
      than the performance standard, P.
      (Z = 2.33)

III - All but one daily maximum measurement per year expected
      to be less than the performance standard, P.
      (Z = 2.78)
                              A-48

-------
                           Table A-15c

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                   Subcategory Nickel Sulfate
                           Plant #120
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (ppn)
No  Min Aver  Max  CV    I    II  III    (V.F. II)
Nickel,Ni
 3 1.29 1.83 2.48 1.21 1.38 1.54 1.63    2.82
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-49

-------
                           Table A-15d

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                   Subcategory Nickel Sulfate
                           Plant #120
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
  (kg/day)    No  Min Aver  Max  CV    I    II  III    (V.F. II)
Nickel,Ni      3 5.04 8.32 11.1 .302 1.42 1.49 1.70    12.4
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-50

-------
                           Table A-16a

           Historical Effluent Monitoring Data Summary
       with Variability Factors and Performance Standards
                         30 Day Averages
                 Subcategory Sodium Hydrosulfite
                           Plant #672
               Historical Summary      Variability   Performance
 Parameter         Statistics            Factors      Standards
   (kg/day)
No  Min Aver  Max  CV
II  III   (V.F. II)
TSS
36  .91 3.78 41.1 1.69 3.35 3.77 4.94    14.2
  I - All but one of the 12 monthly averages in one year are
      expected to be within the performance standard, P.
      (Z = 1.39)

 II - 95% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 1.64)

III - 99% of the monthly averages are expected to be within the
      performance standard, P.
      (Z = 2.33)
                              A-51

-------