Appendix — EI Du Pont De Nemours & Co. v. Train

Supreme Court brief1977

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¢. Supreme Court, U. &

2 FILED

r JUL 16 1976

iu the Supreme Court of the United States

October Term, 1976

No. 75-978

E. I. pu Pont pE Nemours AND CoMPANny, et al.,

Petitioners

Vv.

Russe. E. Train, as Administrator,

Environmental Protection Agency, et al.,

Respondents.

On Writ Of Certiorari To The United States

Court Of Appeals For The Fourth Circuit

Petition for Certiorari Filed January 12, 1976

Certiorari Granted April 19, 1976

- —>-

—_

in the Supreme Court of the United States

October Term, 1976

No. 75-978

E. I. pu Pont p—E Nemours anp CoMPAny, et al.,

Petitioners

Russexu E. Train, as Administrator,

Environmental Protection Agency, et al.,

Respondents.

On Writ Of Certiorari To The United States

Court Of Appeals For The Fourth Circuit

INDEX

Docket Entries and Chronological Listings

of Proceedings Below

In the United States District Court for the Western Dis-

trict of Virginia, Civ. A. No. 74-57

In the United States Court of Appeals for the Fourth Cir-

cuit, No. 74-2237 (Civil)

In the United States Court of Appeals for the Fourth Cir-

cuit, Nos. 74-1261, 74-1290, 74-1296-1304, 74-1357,

74-1406-07, 74-1588-90, 74-1670-1, 74-1741 ( Civil)

Administrative Proceedings in the

Environmental Protection Agency

Development Document for Effluent Limitations Guide-

lines and Standards of Performance: Inorganic Chemi-

cals, Alkali and Chlorine Industries ( Draft) [1-6]*

Effluent Limitation Guidance for the Refuse Act Permit

Program: Inorganic Chemicals Industry [2550-67]

Effluent Limitations Guidelines and Standards of Perform-

ance for New Sources: Advance Notice of Public Re-

view Procedures [4330-34

Economic Analysis of Proposed Effluent Guidelines (Draft)

[4335-40]

Development Document for Proposed Effluent Limitations

Guidelines and New Source Performance Standards

for the Major Inorganic Products [4455-58, 4473-78]

Effluent Limitations Guidelines and Standards of Perform-

ance and Pretreatment for Inorganic Chemicals

Manufacturing Point Source Category: Proposed

Rules {4861-4882}

Comments on Proposed Rules—N.L. Industries, Inc. [4918-

27]

151

*Bracketed page numbers refer to the Administrative Record as paginated

by EPA.

Comments on Proposed Rules—Olin Chemicals [5151-55]

Comments on Proposed Rules—E. 1. du Pont de Nemours

and Company [5156-64]

Comments on Proposed Rules—Manufacturing Chemists

Association [5264-66]

Effluent Standards and Water Quality Information Com-

mittee Evaluation of Current Methods for Establishing

Effluent Limitations for Industrial Point Source Cate-

gories [6472-80]

Letter from the Manufacturing Chemists Association to the

Environmental Protection Agency, November 12, 1973

(6495-99 ]

Letter from the Environmental Protection Agency to the

Manufacturing Cliemists Association, January 15, 1974

(6500-6504 }

Judicial Proceedings

Petition for Review—E. I. du Pont de Nemours and Com-

pany, et al., v. Russell E. Train, as Administrator, En-

vironmental Protection Agency (EPA), United States

Court of Appeals for the Fourth Circuit, No. 74-1261

Petition for Review—Dow Chemical Co.. et al.. v. Russell E.

Train, as Administrator, EPA, United States Court of

Appeals for the Fourth Circuit, No. 74-1301

Petition for Review—FMC Corporation v. Russell E. Train,

as Administrator, EPA, United States Court of Appeals

for the Fourth Circuit, No. 74-1296

Complaint—E. I. du Pont de Nemours and Company, et al.,

v. Russell E. Train, as Administrator, EPA, et al.,

United States District Court for the Western District

of Virginia, Civ. No, 74-57

Opinion and Order—E. I. du Pont de Nemours and Com-

pany, et al., v. Russell E. Train, as Administrator, EPA,

et al., United States District Court for the Western

District of Virginia, Civ. No. 74-37

162

168

178

181

188

192

199

200

202

204

219

Opinion and Order—E. I. du Pont de Nemours and Com-

pany, et al., v. Russell E. Train, as Administrator, EPA,

et al., United States Court of Appeals for the Fourth

Circuit, No. 74-2237 240

Opinion and Order—E. I. du Pont de Nemours and Com-

pany, et al., v. Russell E. Train, as Administrator, EPA,

United States Court of Appeals for the Fourth Circuit,

Nos. 74-1261, 74-1290, 74-1296-1304, 74-1357, 74-

1406-7, 74-1588-90, 74-1670-1, and 74-1741 253

Order Granting Certiorari—E. I. du Pont de Nemeurs and

Company, et al., v. Russell E. Train, Administrator,

EPA, et al., United States Supreme Court, No. 75-978 290

Order Granting Certiorari—E. I. du Pont de Nemours and

Co., et al., v. Russell E. Train, Administrator, EPA,

United States Supreme Court, No. 75-1473 291

Order Granting Certiorari—Russell E. Train, Administrator,

EPA, v. E. I. du Pont de Nemours and Company, et al.,

United States Supreme Court, No. 75-1705 292

Ps SE = ee - °

DOCKET ENTRIES AND CHRONOLOGICAL

LISTINGS OF PROCEEDINGS BELOW

IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF VIRGINIA

Civ. A. No. 74-57

4/1/74 Complaint filed.

5/13/74 Plaintiffs’ motion for separation of and expeditious

determination of basic issues of statutory con-

struction and for summary judgment, or, in the

alternative, declaratory judgment on such issues.

5/28/74 Defendants’ motion to dismiss, or, in the alternative,

to stay the proceedings.

9/27/74 Opinion and order.

10/8/74 Plaintiffs’ notice of appeal.

IN THE UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

No. 74-2237 (Civil)

11/8/74 Appeal docketed.

11/12/74 Joint stipulation and motion for consolidation with

Nos. 74-1261, etc.

11/19/74 Order consolidating this case with Nos. 74-1261,

etc.

12/10/74 Joint motion for consolidated oral argument in

No. 74-2237 and Nos. 74-1261, etc.

2/4/75 Joint motion for expedited oral argument.

4/22/75 Argument.

5/5/75 Motion of Appalachian Power Co., et al., to defer

decision on the merits.

5/20/75 Order denying motion.

6/11/7

6/17/75

12/30/75

Appellees’ motion to file supplemental memoran-

dum.

Motion granted.

Appellants’ motion to file appellants’ supplemental

brief in response to appellees’ supplemental

memorandum.

Opinion and order.

IN THE UNITED STATES COURT OF APPEALS

FOR THE FOURTH CIRCUIT

Nos. 74-1261, 74-1290, 74-1296-1304,

74-1357, 74-1406-07, 74-1588-90, 74-1670-1, 74-1741 ( Civil)

3/5/74

6/7/74

6/27/74

7/12/74

7/17/74

7/31/74

8/6/74

8/12/74

8/16/74

8/27/74

First petition for review.

Order establishing schedule for briefs.

Order consolidating cases into two groups, one per-

taining to efluent guidelines and one pertaining

to standards of performance for new sources.

Petitioner's motion for remand of effluent guidelines

for the hydrofluoric acid subcategory.

Petitioner's motion for remand of standards of per-

formance of new sources for the hydrofluoric acid

subcategory.

Stipulation by parties.

Order denying petitioner’s motion to remand ef-

fluent guidelines.

Order denying petitioner's motion to remand stand-

ards of performance.

Order withdrawing order denying remand.

Motion of National Resources Defense Council

(NRDC) to file a brief amicus curiae.

Motion granted.

9/9/74

9/13/74

9/30/74

10/7/74

10/29/74

11/15/74

12/19/74

1/29/7

2/4/75

3/28/75

4/4/75

4/10/75

4/11/75

4/14/75

vii

Motion of Chamber of Commerce of the United

States to file a brief amicus curiae.

Motion granted.

Motion of Allegheny Power System, Inc., to file a

brief amicus curiae.

Motion granted.

Motion of N. J. Zinc Co. to file a reply brief amicus

curiae.

Motion granted.

Motion of RMI Co. to file a brief amicus curiae and

to participate in oral argument.

Motion of RMI Co. granted as to brief amicus

curiae and denied as to participation in oral

argument.

Joint motion for consolidated oral argument.

Motion of American Petroleum Institute and Eleven

Member Companies to file a brief amicus curiae.

Motion of American Petroleum Institute, et al.,

granted.

Joint motion for expedited oral argument.

Motion of amicus curiae Allegheny Power Systems,

Inc., to file a supplemental brief.

Motion of Allegheny Power Systems, Inc., granted.

Motion of amicus curiae American Petroleum In-

stitute, et al., to file a supplemental memorandum.

Motion granted.

Respondent's motion to file supplemental memo-

randum.

Motion granted.

Motion of American Petroleum Institute, et all.

to participate in oral argument.

Viii l

4/22/75 Argument.

| iu the Supreme Court of the United States

5/5/75 — Motion of Appalachian Power Co., et al., to defer |

decision on the merits. | October Term, 1976

11/10/75 Motion of petitioner N. L. Industries, Inc., to stay

challenged effent guidelines pending decision.

No. 75-978

11/21/75 Motion by amicus curiae American Petroleum In-

stitute to file supplemental memorandum.

Oe te Nene oe eee ae aero +

12/22/75 Motion of American Petroleum Institute denied. E. I. pu Pont bE Nemours anv Company, et al., Petitioners,

3/10/76 Opinion and Order. v.

Russet E. Train, as Administrator,

Environmental Protection Agency, et al., Respondents.

in the

| Administrative Proceedings

}

Environmental Protection Agency

(1) DRAFT

EFFLUENT LIMITATIONS GUIDELINES

;

| DEVELOPMENT DOCUMENT FOR

AND STANDARDS OF PERFORMANCE

INORGANIC CHEMICALS, ALKALI AND

CHLORINE INDUSTRIES

Prepared by General Technologies Corporation

for United States

Environmental Protection Agency

: Under Contract Number 68-01-1513

JUNE 1973

[2] NOTICE

The attached document is a DRAFT CONTRACTOR'S

REPORT. It includes technical information and recommenda-

tions submitted by the Contractor to the United States Envi-

ronmental 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, including the recommendations, will be under-

going extensive review by EPA, Federal and State agencies,

public interest organizations and other interested groups and

persons during the coming weeks. The report and in particular

the contractor's recommended effluent limitations guidelines

and standards of performance is subject to change in any and

all respects.

The regulations to be published by EPA under Sections

304(b) and 306 of the Federal Water Pollution Control Act,

as amended, will be based to a large extent on the report and

the comments received on it. However, pursuant to Sections

304(b) and 306 of the Act, EPA will also consider additional

pertinent technical and economic information which is devel-

oped in the course of review of this report by the public and

within EPA. EPA is currently performing an economic impact

analysis regarding the subject industry, which will be taken

into account as part of the review of the report. Upon com-

pletion of the review process, and prior to final promulgation

of vegulations, an EPA report will be issued setting forth EPA’s

conclusions concerning the subject industry, effluent limita-

tions guidelines and standards of performance applicable to

such industry. Judgements necessary to promulgation of regu-

lations under Sections 304(b) and 306 of the Act, of course,

remain the responsibility of EPA. Subject to these limitations,

EPA is making this draft contractor's report available in order

to encourage the widest possible participation of interested

persons in the decision making process at the earliest possible

time.

The report shall have stauding 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 pre-

pared the information and recommendations. 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 Air and Water Programs

Effluent Guidelines Division |

Washington, D. C. 20460

[4] ABSTRACT

This document presents the findings of an eatensive study of

the inorganic chemicals, chlor-alkali industry by the General

Technologies Corporation for the Environmental Protection

Agency for the purpose of developing effluent limitations

guidelines, Federal standards of performance, and pretreat-

ment standards for the industry, to implement Sections 304,

306 and 307 of the “Act”.

Effluent limitations guidelines contained herein set forth the

degree of effluent reduction attainable through the application

of the best practicable control technology currently available

and the degree of effluent reduction attainable through the

application of the best available technology economically

achievable which must be achieved by existing point sources

by July 1, 1977 and July 1, 1983 respectively. The Standards

of Performance for new sources and pretreatment standards

contained herein set forth the degree of effluent reduction

which is achievable through the application of the best

available demonstrated control technology, processes, operai-

ing methods, or other alternatives.

Based on the use of Level I (BPCTCA) technology, the best

practicable currently available treatment, 14 of the 25 chemi-

cals under study can be manufactured with zero discharge of

process waste water. With the use of Level II (BACTEA)

technology, the best economically achievable, all of the 25

chemicals can be manufactured with zero discharge of proc-

ess waste water. Zero discharge of process waste water is also

achievable as a new source performance standard.

Supportive data and rationale for development of the pro-

posed effluent limitations guidelines and standards of per-

formance are contained in this report.

NOTICE: THESE ARE TENTATIVE RECOMMENDA-

TIONS BASED UPON INFORMATION IN THIS REPORT

AND ARE SUBJECT TO CHANGE BASED UPON COM-

MENTS RECEIVED AN DFURTHER INTERNAL REVIEW

BY EPA.

tk RRO eee ne i a a Re we ee wee et

Otten gr ne

ee he OIE Me oe

Ill

CONTENTS

Ree ie eT eRe

RECOMMENDATIONS _.__—_—stt—t—t—ssSCC

INTRODUCTION _..__—sts—CSsSsS—SSS

Purpose and Authority 00

Summary of Methods used for Develop-

ment of Effluent Limitation Guidelines

and Standards of Performance _.._____.

General Description of the Industry ___.

INDUSTRY CATEGORIZATION

Introduction ....___.______ andesiaiaan —

Categorization Criteria

Industry Categories __.. sciatica

Specific Industry Description by iii

WartTER UsE AND WASTE CHARACTERIZATION _.

Introduction

Specific Water Uses .

Process Waste Characterization .

Verification Sampling and Analytical

I ibstencisidbeiseltiticaiinlanii

SELECTION OF POLLUTION PARAMETERS ___.

Primary Waste Water Pollution

Parameters of Significance ._____

Secondary Waste Watcr Pollution

Parameters of Significance —_____ oe

IV-5

Section Page

Significance of Pollution Parameters... VI-2

Rationale for Selection of Pollution

NN 8 oe 088. eS Gee

VII ConrTrROL AND TREATMENT TECHNOLOGY....._—— VII -1

ETE OI SINNER Let MORO

General Methods for Control and

Treatment Practices Within the

Specific Control and Treatment Practices

[6]

VIII Cost, ENercy, AnD Non-WaATER QUALITY

ASPECTS - cuimetaaaean.

Cost and Reduction Benefits of Treatments

and Control Technology .....-__._... VIII-1

NN sc ictesscsescsssmsasbccaniasdieicihsinnthincsiindelisniican:. TE

Cost References and Rationales ___ —. -VITl-5

Definitions of Levels of Control and

ne eee

Cost of Control and Treatment Systems _.. VIII-6

Cost Effectiveness Information by

SEE sciccirsarsasinnmncincnenensinttenianiaisiied VIII-52

IX EFrrLveEnt REDUCTION ATTAINABLE THROUGH

THE APPLICATION OF THE BEsT PRACTICA-

BLé CONTROL TECHNOLOGY CURRENTLY

AVAILABLE, Levet I (BPCTCA) EFriv-

ENT GUIDELINES AND LIMITATIONS ee,

SEE CONGR eR,

Effluent Reduction Attainable Using Level

I (BPCTCA) Treatment Technology.._— IX-2

et a ee ek A

Section

X EFFivent Repucrion AVAILABLE THROUGH

XII

XIII

XIV

THE APPLICATION OF THE BEsT AVAILABLE

TECHNOLOGY ECONOMICALLY ACHIEVABLE,

Lever II (BACTEA) Errivent Gume-

LINES AND LIMITATIONS X-1

Introduction. X-1

Effluent Reduction Attainable Using Level

II (BACTEA) Treatment Technology. —_ X-2

New Source PERFORMANCE STANDARDS AND

PRETREATMENT STANDARDS, LEVEL III

(BADT) Gume.ines anp Lmaurations.._—_—“ X/I--1

ER TN SEAT eT XI-1

Effluent Reduction Attainable Using Level

III (BADT) Treatment Technology .. _ XI-2

Pretreatment Standards _.. = XI-3

ACKNOWLEDGMENTS ........ tt ti«XSTTZTI-

REFERENCES TT

SEARLS REA ane ae XIV-1

oe e ° o

[2550] October 30, 1972

EFFLUENT LIMITATION GUIDANCE

FOR

THE REFUSE ACT PERMIT PROGRAM

INORGANIC CHEMICALS INDUSTRY

Copied by MCA

[2551 | GENERAL

This guidance for the establishment of effluent limitations

for discharges in the Inorganic Chemicals Industry category

sets forth numerical limitations based on the application of

best practicable control technology currently available. Sched-

ule A values reflect the Agency's best technical judgment of

the effluent levels which can be achieved by the application

of the highest level of control technology which is now con-

sidered ‘practicable’ and ‘currently available’ for the industry.

Schedule A values are based on experience with the technology,

including demonstration projects, pilot plants, and actual use,

which demonstrates that it is reliably achievable.

In every case of (i) new plants installing pollution abate-

ment equipment and (ii) existing plants now beginning a’)ate-

ment programs, you should apply Schedule A values. In some

cases, economic and social factors may affect the practicability

of applying control techniques to achieve these values, and may

require some modification of Schedule A values as to particular

plants. These instances should be kept to an absolute minimum.

Guidance on the economic and social factors which may require

that you consider such modifications, as well as more detailed

explanation of the engineering assumptions underlying the

Schedule A values, will be provided at technical seminars to

be conducted concerning each industrial category.

[2552] Schedule B values represent the most lenient accept-

able effluent levels. No plant should achieve less pollution

reduction than Schedule B values. Schedule B values may be

applied where a discharge has, at the tiie the permit is issued,

commenced and made substantial progress on an abatement

program that will be completed within 24 months or less from

the time the discharge permit is issued. If the plant also has

extensive ongoing pollution abatement programs in other areas

such as air pollution the Regional Administrator may modify

this 24-month period.

If effluent limits based on ‘best practicable control tech-

nology’ fail to meet water quality standards, then such limits

will be upgraded to comply with water quality standards and

EPA policy.

INDUSTRIAL CATEGORY DESCRIPTION

Inorganic Chemicals, Alkalies and Chlorine are covered in

the Standard Industrial Classification (SIC) 2812, 2816, and

2819. Inorganic compounds such as anhydrous ammonia, su-

perphosphates and urea are not covered in this category since

they are included in the Fertilizers Industry category. The

following products were selected for Guidelines based on in-

formation and data available.

Aluminum Chloride

Aluminum Sulfate

Chlorine-Sodium Hydroxide

Hydrochloric Acid

[2553]

Hydrofluoric Acid

Hydrogen Peroxide

Lime

Nitric Acid

Elemental Phosphorus

Sulfuric Acid

RATIONALE

General

The effluent guidelines for the inorganic chemical industry

were developed from information in the Industrial Waste Study

of Inorganic Chemicals, Alkalics and Chlorine by General

Technologies Corporation; from information resulting from a

survey of 76 inorganic chemicals plants by the Manufacturing

Chemists Association (MCA); from Corps of Engineers permit

data and from use of engineering judgment.

The industries in these categories manufacture products

from raw materials that are inorganic in nature, thereby result-

ing in wastewater containing a low biochemical oxygen de-

mand, inert solids, large amounts of dissolved solids, and

effluents with a wide range of pH values. The major pollutant

common to nearly all of the industry is inorganic suspended

solids, a parameter that can be controlled with sedimentation

basins designed for minimal short circuiting and sufficient

detention time.

[2554] Total dissolved solids, chiefly chlorides and sulfates,

constitute the second major class of pollutants for the inor-

ganic industry. However, it should be noted that guidelines

are not presently placed on dissolved solids, chlorides, and

sulfates. When the discharge of any of these parameters may

be in violation of Federal or State or local water quality stand-

ards, limits will be established. When such is the case a

substantial amount of dissolved solids reduction can be effected

through in-plant controls some of which are:

(1) Chlorine-caustic

(a) non-contact vapor condensers.

(b) use of indirect chlorine coolers in the chlorine

compression process

(d) recycling of sodium chloride from the evapora-

tors concentrating caustic soda

(e) use of indirect vapor condensers in the brine

dechlorination process

(f) recycle of brine filter backwashwater

(g) collection and reuse of effluent from waste

chlorine gas disposal system

(h) maximum removal of brine solution from slur-

ries resulting in precipitation of impurities from

raw brine solutions

[2555] (i) containment and recycling of spills and leaks

back to the process.

(2) Nitric Acid

(a) replacement of barometric quench condensers

with non-contact condensers

(b) the use of single and double mechanical pump

seals

(3) Hydrochloric Acid

(a) curbing and floor sumps to collect and recycle

strong acid spills and leaks

(b) maximize the efficiency of the cooler and ab-

sorber to minimize the chloride wasteload from

the scrubber.

(4) Hydrogen Peroxide (organic method )—separation of

organic solvents from the aqueous media with de-

canters or API separators for recycle or recovery.

(5) Hydrofluoric Acid—maximize for efficiency of the

acid absorbers to minimize the fluoride wasteload

from ejector scrubber systems.

(6) Sulfuric Acid—curbing and floor sumps to collect and

recycle spills ard leaks.

TREATMENT MODELS

Treatment models representing “Best Practicable Treatment”

are described for each of the product industries. They are not

intended to specify procedures [2556] or processes, but to il-

lustrate and demonstrate the means by which “A” levels may —

be achieved. Alternative abatement techniques which will

achieve the same end are encouraged.

Aluminum Chloride— sedimentation and coagulation.

Aluminum Sulfate— sedimentation and recycling of clari-

fied effluent.

Chlorine-caustic— sedimentation, chemical precipita-

tion—coagulation—sedimentation, fil-

tration, carbon adsorption, neutrali-

zation, water recycling, and water

conservation practices.

Hydrochloric Acid— segregation of cooling water, col-

lection of spills and leaks for recycle

or land disposal.

Hydrofluoric Acid— lime precipitation, coagulation floc-

culation, sedimentation and neutrali-

zation.

Hydrogen peroxide (organic method )—Biological oxida-

tion of organic solvents, sedimenta-

tion.

Lime— dry collection of dust.

Nitric Acid— segregation of cooling water, collec-

tion of spills and leaks for recycle or

land disposal.

Phosphorus— sedimentation and recycle.

Sulfuric Acid— segregation of cooling water, collec-

tion of spills and leaks for recycle or

land disposal.

[2557] SPECIFIC FOR PRODUCT

Aluminum Chloride—Level B is based upon reducing sus-

pended solids in the scrubber wastewaters which do not use

alkaline solutions to a level of 25 mg/I. Level A is based upon

reducing suspended solids levels in alkaline scrubber solutions

to 15 mg/I since this type of wastewater would produce an

aluminum hydroxide precipitate that will readily flocculate and

settle to produce a clarified effluent. Those concentrations are

used to calculate the achievable wasteload from water usage

and production data in the General Technologies Report.

Aluminum Sulfate—Level B is based on lime neutralization

followed by sedimentation and recycle of a portion of the

effluent. Level A is based on total recycle from the treatment

pond which is practiced in 10 of 12 plants in the MCA waste-

water survey data. Plants producing iron-free Aluminum Sul-

fate may require special consideration.

Chlorine-Caustic—Effuent levels for suspended solids are

based on 25 mg/1 from settling ponds for the B level and

15 mg/I! for the A level. Waste loads for suspended solids

limits in pounds per ton of chlorine production are based on

flow data from the General Technologies Report, the MCA

survey and data supplied by the Chlorine Institute. Flow basis

numbers are for process water only. Much of the data available

includes cooling water or is from plants where cooling water

and process water are not separated. To meet both A & B

levels, it is expected that process water and cooling water

separation and water recvcle will be required.

[2558] The mercury effluent limitation of 0.1 pounds per day

for the entire chlor-alkali . . . is to be measured at the outlet

from the mercury treatment unit. Should there be another

process at the location that has an effluent containing mercury,

that stream must be treated in the mercury treatment unit and

thus be included in the 0.1 pound per day limitation. Mercury

residuals (i.e., mercury picked up between the treatment unit

outlet and the discharge to the stream) are frequently a

problem. Where residuals are a demonstratable problem, iden-

tify the quantity of mercury involved and develop a program

with schedules for correction.

Lead generally separates out in settling ponds but may re-

quire soda ash or caustic treatment. Projects, for installation

of metal anodes provide benefits that will pay for the installa-

tion and climinate lead in the effiuent. Estimates of their pres-

ent use indicate that one third of the plants use metal anodes

now and an additional third have them under active con-

sideration.

Hydrochloric Acid (chlorine burning process )—Level B is

based on caustic neutralization of acid leaks and wastewater

from the scrubber. Hydrochloric acid processes are quite

commonly located at the same site as caustic chlorine plants

and as such, the acid wastewaters can be used to neutralize

alkaline wastewaters. Level A is achieved by returning leaks

to the process or by neutralization and land disposal.

[2559] Hydrofluoric Acid—Level B can be achieved by treat-

ing effluents with lime to a pH of 10-11. This neutralizes the

sulfuric acid, reduces the fluoride content to 5 ppm and

suspended solids to 25 ppm. Acidification of the effluent reduces

pH to 9 or less. Level A is based on a large reduction of process

water flow achieved by recycle and 15 ppm suspended solids.

This is documented by data from one plant.

Hydrogen Peroxide (organic process)—The B level is based

on the disposal of the biodegradable solvent waste, either by

discharge to a municipal biological treatment system or a

solvent collection and recycling system. The A level is based

on achieving 15 ppm suspended solids removal in the final

effluent by coagulation.

Lime—Level B is based upon the discharge of wet scrubber

waste to a settling pond with effluent containing 20 ppm sus-

pended solids. Level A has no waterborne discharge since wet

scrubber waste can be eliminated using dry collection methods.

Nitric Acid—Effluent from the process is due to leaks. Level B

is based on neutralization of leakage with caustic. Level A is

based on return of the leakage to the process or by land disposal

of leaks.

Phosphorus—B levels are achieved by phosphorous burial,

lime and settling pond treatment for solvable phosphates and

fluorides and dry collection of solid phosphates. A small part

of the flow to the settling [2560] pond is discharged. The

remainder is recycled. Recycle of water from the settling ponds

provides the basis for Level A.

Sulfuric Acid—Wastes from this process are leaks. Level B is

achieved by lime and settling pond treatment of the leaks to

25 ppm suspended solids. Level A is achieved by returning the

leakage to the process. It may be necessary to give special con-

sideration to operations producing high quality product.

GENERAL CONSIDERATIONS

The pH level of any discharge stream from any process in

these industries must be within a range of 6.0 to 9.0. The

adjustment of pH presents no difficulty in the treatment of

waste. Total neutralization may be undesirable in some cases

due to TDS loads or natural buffering capacities.

Concentration limits for heavy metals will be established by

the Regional Administrator. A guidance document on this

subject is being prepared. Limits are needed on each metal

present but the limit will vary depending on what other metals

are present that cause a synergistic effect. Heavy metals in-

clude, but are not limited to, copper, zinc, cadmium, tin,

selenium, nickel, lead, and chromium.

All solid waste materials generated within the industrial

complex or collected from the waste treatment facilities, includ-

ing such items as [2561] chemical sludges and filter cakes are

to be disposed of in a well managed and well designed chemical

land fill to prevent leachades and overflows from entering

navigable waters or their tributaries.

Heat is a potential pollution problem in the inorganic chemi-

cal industry. Where settling basins and precipitation processes

are used in the treatment of waste, there should be sufficient

retention time to cool the stream down to acceptable tempera-

ture levels. However, some of the processes may not include

this type of treatment. Calculation methods to determine

thermal loadings are presently being derived by Office of

Enforcement and General Counsel to assist EPA Regional per-

sonnel in processing permit applications. However, thermal

discharges must be in compliance with all applicable water

quality standards (Federal and/or State).

The process wastewater from a particular plant should be

limited on total pounds of a particular pollutant per day. The

total pounds per day is the product of the pounds per unit of

production multiplied by the production capacity.

In applving these limitations the source of water used in the

plant must be taken into consideration. Where the source is

the same as the receiving water the limitations applied are “net

increases. Where the source is municipal, private water supply,

well water, or water from another drainage basin, the limita-

tions applied are “gross” load.

[2562] The effluent guidelines are based on process waste-

water, i.e., that coming in contact with process materials. This

does not include noncontact cooling water, cooling tower blow-

down or boiler blowdown.

VIOLATIONS

The effluent limitations shown in Attachments A and B are

average values. It shall be considered a violation of the waste

discharge permit if the average values based on daily 24-hour

composite samples over any 20 consecutive working days

exceeds the limitations placed on any parameter in Attach-

ment A or B.

tt shall be considered a violation of the waste discharge

permit if any single composite sample exceeds the limitations

shown in Attachments A or B more than 50 percent.

Four violations in any one single year will require an action

memorandum from the Regional Administrator containing rec-

ommendations on what action is to be taken.

Any single violation of the permit may be considered grounds

for revocation.

SAMPLING AND MONITORING

Sampling and monitoring is to be required to adequately

characterize the effluent quality. Generally, only those parame-

ters present in significant [2563] quantity need to be monitored.

A review of data after an initial plan has been in effect

for 6 months is in order to make adjustments as needed. Where

there is potential for discharge of hazardous materials, spot

checks will be needed at suitable intervals. Flow measurements

may be other than continuous if continuous measurement is

impractical and if the proposed alternate adequately charac-

terizes the flow. Samples should be taken just prior to the dis-

charge to the stream (except mercury—described elsewhere ).

Analytical methods will be by Standard Methods, 13th

edition, 1971. However, alternate methods may be approved

upon submission of acceptable information and justification.

[2564] Suggested Sampling and Analyses

Requirements

Parameter Sample Type Frequenci

Flow Continuous Continuous

Temperature Continuous Continuous

pi Continuous Continuous

Chemical Oxygen

Demand 24-hr Composite — Twice Weekly

Suspended Solids 24-hr Composite — Three Times Weekly

Alkalinity Grab Twice Weekly

Total Dissolved Solids 24-hr Composite — Three Times Weekly

Grease and Oil Grab Once Weekly

Chlorides 2A-hr Composite — Three Times Weekly

Sulfates 24-hr Composite — Three Times Weekly

Monitor for the following parameters if present:

Chlorinated Hydrocarbons BOD

Phenol

Sampling and Analyses for Specific Industries

Industry Parameter

Chloro-Alkali;

Hyg Cell Mercury 24-hr Composite Daily

Chloro-Alkali;

Diaphragm Cell — Lead

24-hr Composite Twice Weekly

Hydrofluoric Acid Fluorides 24-hr Composite Twice Weekly

Silicates 24-hr Composite Twice Weekly

Aluminum Chloride Aluminum 24-hr Composite Twice Weekly

Phosphorus-

Electrolytic Phosphate 24-hr Composite Twice Weekly

Aluminum —24-hr Composite Once Weekly

Fluoride 24-hr Composite Twice Weekly

[2565 ] X. REFERENCES

1. Industrial Waste Study of Inorganic Chemicals, Alkalies

and Chlorine, U.S. Environmental Protection Agency draft

report by General Technologies Corporation, 1821 Michael

Faraday Drive, Reston, Virginia 22070, (July 23, 1971)

[2566] ATTACHMENT A

Inorganic Chemicals, Alkali and Chlorine Industry

Effluent Guidelines

Lb per Ton of Product

Total Other

Flow Basis® Suspended by

Product Gal/Ton Solids Note

ALUMINUM CHLORIDE 120 0.015

ALUMINUM SULFATE No waterborne process effluent

131 pages.

Manufacturing Chemists Association Wastewater Survey of

the Inorganic Chemicals Industry, (June 1972).

Inorganic Chemicals Industry Profile (updated) by Data-

graphics by Cyrus William Rice & Company, July 1971.

Industrial Waste Study—Mercury—Using Industries by

Litton Systems, Inc., July 1971.

Caustic CHLORINE: °*

Diaphragm Cell 8,000 1.0 1

Mercury Cell 5,000 0.6 2

Downs Cell 7,300 0.9 _

HypROCHLORIC AcID No waterborne process effluent

(Chlorine burning ) )

Hypror.uoric Acip 4,672 0.6 3

HypDROGEN PEROXIDE

( Organic process ) 8,600 1.1 4

Lime/CALCINATION No waterborne process effluent

Nitric Acip No waterborne process effluent

PHOSPHORUS No waterborne process effluent

Sutruric Acip No waterborne process effluent

(Sulfur burning

contact plants )

pH range is 6-9 for all products

NOTES: 1. 0.04 #/ton lead

2. 0.1 #/day mercury for the entire operation without regard to

capacity***

3. 0.2 #/ton fluorides

4. 0.06 #/ton TOC

*The flow basis numbers are to show how numbers were derived and are not

intended as flow limitations.

**Units are per ton of chlorine production.

*°*The EPA goal of no mercury discharge may reduce this number as it

becomes practical.

[2567 ] ATTACHMENT B

Inorganic Chemicals, Alkali and Chlorine Industry

Effluent Guidelines

Lb per Ton of Product

Total Other

Flow Basis® Suspended _ by

Product Gal/Ton Solids Note

ALUMINUM CHLORIDE 120 0.025 _

ALUMINUM SULFATE 400 0.08 _

Caustic CHLorine® ®

Diaphragm Cell 30,000 6.3 l

Mercury Cell 20,000 4.3 2

Downs Cell 7,300 15 _

Hyprocuworic Acip

(Chlorine burning ) 1,000 — =

Hypror.uoric Acip 36,000 7.5 3

HypROGEN PEROXIDE

( Organic process ) 8,600 1.8 -

Lime/CALCINATION 200 0.03 4

Nitric Acip 86 0.01 —

PHOSPHORUS 8,000 1.7 5

SuLFuRIC ACID

(Sulfur burning

contact process ) 1,200 0.25 _

pH range is 6-9 for all products

NOTES: 1. 0.2 #/ton, lead

2. 0.1 #/day of mercury for the entire operation without regard to

capacity

3. 1.5 #/ton, fluorides

4. 0.03 #/ton, COD

5. 0.2 #/ton, phosphates; 0.2 # /ton, fluorides;

0.001 #/ton, elemental phosphorus

*The flow basis numbers are to show how numbers were derived and are not

intended as flow limitations.

**Units are per ton of chlorine production.

(38 Fed. Reg. 21202 ( August 6, 1973) ]

[4330] NOTICES

ENVIRONMENTAL PROTECTION AGENCY

EFFLUENT LIMITATIONS GUIDELINES AND STAND-

ARDS OF PERFORMANCE FOR NEW SOURCES

Advance Notice of Public Review Procedures

Advance notice is hereby given concerning notices of pro-

posed rule making to be published by the Environmental Pro-

tection Agency (“EPA”) with respect to effluent limitations

guidelines, standards of performance, and pretreatment stand-

ards for new sources pursuant to sections 304(b) 306 and

307(c) of the Federal Water Pollution Control Act, as amended

(33 U.S.C. 1251, 1314, 1316 and 1317(c); 86 Stat. 816 et seq.;

Pub. L. 92-500) (“the Act”). The purpose of this notice is to

facilitate public comment upon the regulations to be promul-

gated under sections 304(b), 306 and 307(c), both before and

after the publication of the notices of proposed rule making.

In addition, this notice will explain EPA’s overall plans for

development of effluent limitations guidelines anc standards of

performance for new sources and the approach which is being

taken by the Agency in discharging the duties placed upon

the Administrator under sections 304(b), 306 and 307(c) of

the Act.

EPA believes that the exposure of the technical basis and

reasoning underlying regulations to be established pursuant to

sections 304(b), 306 and 307(c) is essential to the promulga-

tion of sound effluent limitations guidelines and standards of

performance for new sources. At the same time, because of the

deadlines for action imposed upon the Administrator under the

Act, both EPA and the public will be pressed to analyze and

resolve highly complex and important issues in a relatively

short time. In order both to develop sound regulations and

meet the time schedules set by the Act, EPA intends to identify

as many issues and elicit points of criticism at the earliest

possible time. To resolve such issues often will require further

staff work and management decision-making within EPA and

may necessitate substantial redrafting of regulations and sup-

port documents. Therefore, extensive external review cannot

be postponed until internal EPA review of initial reeommenda-

tions for effluent limitations guidelines and standards of per-

formance has been completed, but must proceed concurrently

with EPA’s own internal review and decision-making if the

Act’s deadlines are to be met.

EPA has already begun this process by seeking comments

upon draft technical reports from persons and organizations

known to be interested in particular source categories. These

reports (which are discussed further below) contain tentative

recommended effluent limitations guidelines and standards of

performance. This notice seeks to supplement this already

initiated external review and facilitate further review and

public comment in late August and early September, when

notices of proposed rule making will be published in the

Feperat Recister. The notice is divided into three parts. First,

the basic legal authority for regulations concerning effluent lim-

itations guidelines and standards of performance for new

sources will be set forth. Second, EPA’s general methodology

will be described. Third, the means by which EPA has to date,

and will in the future, seek the widest possible public scrutiny

of the technical and legal basis for the regulations to be estab-

lished will be explained.

1. Legal authorities—(a) Existing point sources. Sec-

tion 301(b) of the Act requires the achievement by not later

than July 1, 1977, of effluent limitations for point sources, other

than publicly owned treatment works, which require the appli-

cation of the best practicable control technology currently

available as defined by the Administrator pursuant to sec-

tion 304(b) of the Act. Section 301(b) also requires the

achievement by not later than July 1, 1983, of effluent limita-

tions for point sources, other than publicly owned treatment

works, which require the application of the best available

technology economically achievable which will result in reason-

able further progress toward the national goal of eliminating

the discharge of all pollutants, as determined in accordance

with regulations issued by the Administrator pursuant to sec-

tion 304(b) of the Act.

Section 304(b) of the Act requires the Administrator to pub-

lish regulations providing guidelines for effluent limitations

setting forth the degree of effluent reduction attainable through

the application of the best practicable control technology cur-

rently available (the 1977 requirement) and the degree of

effluent reduction attainable through the application of the best

control measures and practices achievable including treatment

techniques, process and procedure innovations, operating

methods and other alternatives (the 1963 requirements).

(b) New sources. Section 306 of the Act requires the

achievement by new sources of a Federal standard of per-

formance providing for the control of the discharge of pol-

lutants which reflects the greatest degree of effluent reduction

which the Administrator determines to be achievable through

application of the best available demonstrated control tech-

nology, processes, operating methods, or other alternatives,

including, where practicable, a standard permitting no dis-

charge of pollutants.

Section 306(b)(1)(B) of the Act requires the Administrator

to propese regulations establishing Federal standards of per-

formance for categories of new sources included in a list

published pursuant to section 306(b)(1)(A) of the Act. The

Administrator published in the Feperat Recister of Janu-

ary 16, 1973, (38 FR 1624) a list of source categories for which

standards of performance for new sources will initially be

established. Section 306(a)(2) defines “new source” as “any

source, the construction of which is commenced after the pub-

lication of proposed regulations prescribing a stand- [4331] ard

of performance under this section which will be applicable to

such source * * °.”

Section 307(c) of the Act requires the Administrator to

promulgate pretreatment standards for a category of new

sources at the same time that standards of performance for that

category are promulgated pursuant to section 306. EPA pres-

ently plans to include in proposed and promulgated reguiations

establishing standards of performance for new sources, provi-

sions which will require application of pretreatment standards

which are consistent with EPA’s proposed pretreatment stand-

ards for existing sources. The basis for the latter standards is

set forth in the Feperat Recister of July 19, 1973 (38 FR

19236) under 40 CFR Part 128. The provisions and rationale

of Part 128 are equally applicable to sources which would

constitute “new sources”, under section 306 if they were to

discharge pollutants directly to navigable waters, except for

§ 128.133. That section provides a pretreatment standard for

“incompatible pollutants” which requires application of the

“best practicable control technology currently available,” sub-

ject to an adjustment for amounts of pollutants removed by the

publicly owned treatment works. Since the pretreatment

standards to be promulgated under section 307(c) apply to

new sources, the regulations establishing standards of per-

formance for new sources will amend § 128.133 to require

application of the standard of performance for new sources

rather than the “best practicable” standard applicable to exist-

ing sources under sections 301 and 304(b) of the Act.

2. EPA’s methodology—(a) Overall approach. The tech-

nical studies discussed below and the development of regula-

tions for effluent limitations guidelines and standards of

performance are undertaken in the following manner. The

point source category is first studied for the purpose of deter-

mining whether separate limitations and standards are appro-

priate for different segments within the category. This analysis

includes a determination of whether differences in raw material

used, product produced, manufacturing process employed, age

and size of plants, waste water constituents and other factors

require development of separate limitations and standards for

different segments of the point source category. The raw waste

characteristics for each such segment are then identified. This

includes an analysis of (1) the source, flow and volume of

water used in the process employed and the sources of waste

and waste waters in the plant; and (2) the constituents of

waste waters. The constituents of the waste waters which

should be subject to effluent limitations guidelines and stand-

ards of performance are then identified.

Next, the contro] and treatment technologies existing within

each segment are identified. This includes an identification of

each distinct control and treatment technology, including both

in-plant and end-of-process technologies, which exists or is

capable of being designed for each segment. It also includes an

identification of the effluent level resulting from the application

of each of the treatment and control technologies, in terms of

the amount of constituents and the chemical, physical, and

biological characteristics of pollutants. The problems, limita-

tions and reliability of each treatment and control technology

are also identified. In addition, any non-water quality environ-

mental impact, such as the effects of the application of such

technologies upon other pollution problems, including air, solid

waste, noise and radiation is examined. Finally, the energy

requirements of each control and treatment technology are

determined, as well as the cost of the application of such

technologies.

This information is then evaluated in order to determine

what levels of technology constitute the “best practicable con-

trol technology currently available”, “best available technology

economically achievable” and the “best available demonstrated

control technology, processes, operating methods, or other

alternatives.” In identifying such technologies, various factors

are considered including the total cost of the application of

technology in relation to the effluent reduction benefits to be

achieved from such application, the age of equipment and

facilities involved, the process employed, the engineering as-

pects of the application of various types of control techniques,

process changes and non-water quality environmental impact

(including energy requirements).

The data on which the above analysis was performed in-

cluded EPA permit applications, EPA sampling and inspections,

industry submissions and consultant reports, including the

reports discussed below.

(b) Technical studies. Studies of some thirty point source

categories for which regulations will initially be promulgated

were instituted by EPA as soon as possible after passage of

the Federal Water Pollution Control Act Amendments of 1972

(October 18, 1972). These studies constitute in-depth analyses .

of the technological feasibility and economic costs of reducing

or eliminating discharges of pollutants. The studies, along

with other information obtained by EPA in the course of

internal and external review of the resulting reports or other-

wise available to EPA, will serve as a foundation for the regu-

lations to be issued under section 304(b) and 306 of the Act.

To have attempted to amass within the Agency in a very

short period of time the large number of technical personnel

with experience in the many diverse point source categories to

be covered would have been impractical. Therefore, the

overall data base and initial analysis has been obtained through

contracts with qualified technical consultants. These con-

sultants were instructed to perform in-depth studies of each

point source category, under the supervision and with the

assistance of EPA, in accordance with the methodology de-

scribed above. The resulting draft reports include initial tenta-

tive recommendations with respect to the effluent limitations

guidelines and standards of performance for the particular

point source category concerned. The draft reports and rec-

ommendations are then subjected to extensive internal and

external review. The contractors are assisting in the initial

collection and collation of the data base. The responsibility for

establishing effluent limitations guidelines and standards of

performance for new sources, of course, remains with EPA.

For each of the point source categories covered by the tech-

nical studies, EPA is also conducting supplementary studies of

the economic impact which could result from application of

alternative control and treatment technologies. These studies

add to the economic analyses already undertaken as part of

the technical studies, which center upon the investment and

operating costs associated with various alternative control and

treatment technologies, by estimating the broader economic

effects which might result from the required application of

various technologies. The economic impact studies will investi-

gate effects of alternative approaches in terms of product price

increases, effects upon employment and the continued viability

of affected plants, effects upon foreign trade and other com-

petitive effects. These reports may be obtained in the same

manner as the EPA draft reports, as discussed in section 3(c)

below.

Contractors’ technical studies of the following point source

categories have been completed:

1. Pulp, Paper and Paperboard Mills

2. Builders Paper and Board Mills

3. Meat Product and Rendering Processing

4. Dairy Product Processing

5. Grain Mills

6. Canned and Preserved Fruits and Vegetables Process-

ing

7. Canned and Preserved Seafood Processing

8. Beet Sugar Processing

9. Cane Sugar Processing

10. Textile Mills

11. Cement Manufacturing

12. Feedlots

13. Electroplating

14. Organic Chemicals Manufacturing

15. Inorganic Cheinicals Manufacturing

16. Plastics and Synthetic Materials Manufacturing

17. Soap and Detergent Manufacturing

18. Fertilizer Manufacturing

Petroleum Refining

Iron and Steel Manufacturing

Nonferrous Metals Manufacturing

Phosphate Manufacturing

Steam Electric Powerplants

Ferroalloy Manufacturing

Leather Tanning and Finishing

Glass Manufacturing

Insulation Fiberglass Manufactviing

Timber Products Processing

Beet Sugar Processing Industry

Insulation Fiberglass Industry

3. Public participation in the development of regulations—

(a) Review of the draft contractors’ reports. The completed

contractors’ reports are presently undergoing intensive analysis

within [4332] EPA and are also receiving extensive external

review and comment. This process of internal and external

review is being carried on simultaneously in order to make the

most of the time available under the Act. Once the contrac-

tors’ draft reports are received by EPA, they are immediately

distributed to a list of external reviewers for critical analysis.

The persons or institutions listed below have been sent the

draft reports. They have been asked to comment within 30

days so there will be time for their comments to be taken into

account by EPA when preparing proposed rule making

documents.

States

Alabama Water Improvement Commission

State Office Building

Montgomery, Alabama 36104

State of Alaska

Department of Environmental Conservation

Pouch O

Juneau, Alaska 99801

Commission of Arizona State Department of Health

4019 N. 33rd Avenue

Phoenix, Arizona 95017

Department of Pollution Control and Ecology

1100 Harrington Avenue

Little Rock, Arkansas 72202

California State Water Resources Control Board

Sacramento, California 95814

Water Pollution Control Division

Colorado Department of Health

4210 E 11th Avenue

Denver, Colorado 80220

Division of Water Compliance and Hazardous Substances

Department of Environmental Protection

State Office Building

Hartford, Connecticut 06115

Department of Natural Resources and Environmental

Control

Capitol Complex

Tatnall Building

Dover, Delaware 19901

Department of Pollution Control

2562 Executive Center Circle East

Tallahassee, Florida 32301

Environmental Protection Divisiou

Department of Natural Resources

47 Trinity Avenue, S.W.

Atlanta, Georgia 30334

Assistant Director for Environmental Health

Hawaii State Department of Health

P.O. Box 3378

Honolulu, Hawaii 96801

Indiana Stream Pollution Control Board

1330 West Michigan Street

Indianapolis, Indiana 46206

State of Idaho

Department of Environmental and Community Services

State House

Boise, Idaho 83720

Water Quality Management Division

Department of Environmental Quality

Lucos State Office Building

Des Moines, Iowa 50319

Division of Environmental Health

Kansas State Department of Health

535 Kansas Avenue

Topeka, Kansas 66603

Kentucky Water Pollution Control Commission

275 East Main Street

Frankfort, Kentucky 40601

Louisiana Stream Control Commission

P.O. Drawer FC

University Station

Baton Rouge, Louisiana 70803

Environmental Health Division

Louisiana State Board of Health

New Orleans, Louisiana

Department of Environmental Protection

State House

Augusta, Maine 04430

Water Resources Administration

Tower State Office Building

D2 Water Resources

Annapolis, Maryland 21401

Division of Water Pollution Control

State Office Building

100 Cambridge Street

Boston, Massachusetts 02202

Michigan Water Resources Commission

Steven T. Mason Building

Lansing, Michigan 45916

Minnesota Pollution Control Agenc

State Board of Health Building

717 Delaware Street, SE

Minneapolis, Minnesota 55440

Mississippi Air and Water Pollution Control Commission

P.O. Box 827

Jackson, Mississippi 39205

Missouri Clean Water Commission

P.O. Box 154

Jefferson City, Missouri 65101

Division of Environmental Sanitation

State Department of Health

Cogswell Building

Helena, Montana 59601

Department of Environmental Control

1420 P Street

Lincoln, Nebraska 60509

Nevada Commission of Environmental Protection

201 South Fall Street

Carson City, Nevada 89701

New Hampshire Water Supply and Pollution Control

Commission

Prescott Park

105 Loudon Road

Concord, New Hampshire 03301

rtment of Environmental Protection

P.O. Box 1390

Trenton, New Jersey 08625

New Mexico Environment Improvement Agency

P.O. Box 2348

Santa Fe, New Mexico 87501

Industrial Waste Bureau

New York State Department of Environmental

Conservation

50 Wolf Road

Albany, New York 12201

Office of Air and Water Resources

Department of Natural and Economic Resources

P.O. Box 27687

Raleigh, North Carolina 27611

Environmental Health and Engineering Services

Department of Health

State Capitol

Bismarck, North Dakota 58501

Ohio Environmental Protection Agency

Columbus, Ohio 43216

ent of Pollution Control

2241 N.W. 40th Street

Oklahoma City, Oklahoma 73112

Oregon Department of Environmental Quality

1234 S.W. Morrison

Portland, Oregon 97205

Bureau of Sanitary Engineering

ent of Environmental Resources

P.O. Box 2351

Harrisburg, Pennsylvania 17120

Division of Water Pollution Control

Rhode Island Department of Health

State Office Building

Providence, Rhode Island 02903

South Carolina Pollution Control Authority

P.O. Box 11628

Columbia, South Carolina 29311

Division of Sanitary Engineers and Environmental

Protection

State Department of Health

State Capitol

Pierre, South Dakota 57501

Division of Water Quality Control

Department of Public Health

621 Cordell Hull Building

Nashville, Tennessee 37219

Texas Water Control Board

P.O. Box 13246

Capitol Station

Austin, Texas 78711

Bureau of Environmental Health

Division of Health

44 Medical Drive

Salt Lake City, Utah 84113

Vermont Agency of Environmental Conservation

Montpelier, Vermont 05602

Virginia State Water Control Board

1010 State Office Building

Richmond, Virginia 23219

Washington Department of Ecology

P.O. Box 829

Olympia, Washington 98504

West Virginia Division of Water Resources

Department of Natural Resources

1201 Greenbriar Street

Charleston, West Virginia 25311

Division of Environmental Protection

Wisconsin Department of Natural Resources

P.O. Box 450

Madison, Wisconsin 53701

Sanitary Engineering Services

Division of Health and Medical Services

rtment of Health and Social Services

State Office Building

Cheyenne, Wyoming 82001

Territories

Environmental Quality Commission

Government of Samoa

Pago-Pago, Tutuila

American Samoa 96920

Water Pollution Control Program

Government of Guam

P.O. Box 2816

Agana, Guam 96910

Environmental Quality Board

P.O. Box 11785

San Juan, Puerto Rico 00910

Office of High Commission

Division of Environmental Health

Trust Territory of the Pacific Islands

Saijsan Mariana Island 92950

River Basin Commissions

Delaware River Basin Commission

25 State Police Drive

West Trenton, New Jersey 08628

New England Interstate Water Pollution Control

Commission

[4333] 607 Boylston Street

Boston, Massachusetts 02116

Ohio River Vailey Sanitation Commission

414 Walnut Street

Cincinnati, Ohio 45202

34 35

The reports have also been transmitted to the following American Iron and Steel Institute

agencies or organizations: American Livestock Feeders Association

American Meat Institute

Agencies and Offices of/or Related to the American Mining Congress

Federal Government American National Cattleman’s Association

Department of Agriculture American Paper Institute

Atomic Energy Commission American Petroleum Institute

Department of Commerce American P lywood Association

Department of Defense American Public Power Association

Federal Power Commission American Shrimp Canners Association

Department of Health, Education, and Welfare American Wood Preservers Association

Department of Housing and Urban Development American Wood Preservers Institute

Department of the Interior American Textile Manufacturers Institute

Office of the Energy Advisor A.S.G. Industries, Inc.

Department of the Treasury Atomic Industrial Forum, Inc.

National Industrial Pollution Control Council Beet Sugar Development Foundation

U.S. Department of Commerce Carpet and Rug Institute

Water Resources Council Catfish Farmers of America

Tennessee Valley Authority Chesapeake Bay Seafood Industries Association, Inc.

Chlorine Institute

Public Interest Groups Copper and Brass Fabricators Council

The American Society of Civil Engineers Corn Refiners Association, Inc.

The American Society of Mechanical Engineers Dairy Industry Committee

Businessmen for the Public Interest Dimmitt Agricultural Industry

Conservation Division Edison Electric Institute

National Wildlife Federation Environmental Pollution Control Program

The Conservation Foundation Glass Container, Inc. ;

Environmental Defense Fund, Inc. The Ferroalloy Association

Hudson River The Fertilizer Institute

Sloop Restoration, Inc. Ford Motor Company

Natural Resources Defense Council Glass Division

Water Pollution Control Federation Glass Containers Manufacturers Institute

Hawaiian Sugar Planters Association

Hardwood Plywood Manufacturing Association

Industry Trade Associati i

ndustry Trade Associations or Companies Institute of American Poultry Industries

The Aluminum Association International Institute of Synthetic Rubber Producers

Aluminum Smelting and Recycling Institute Libbey-Owens-Ford Co.

American Corn Millers Federation Manufacturing Chemists Association

American Electroplaters’ Society Metal Finishers Suppliers Association

American-Florida Sugar Cane League Miller’s National Federation

American Frozen Food Institute National Association of Electric Companies

American Hardboard Association National Association of Metal Finishers

National Broiler Council

National Canners Association

National Council of the Paper Industry for Air and Stream

Improvement, Inc.

National Independent Meat Packers Association

National Fisheries Association

National Forest Products Association

National Milk Producers Federation

National Pork Producers Association

National Renders Association, Inc.

National Rural Electric Cooperative Association

Northern Textile Association

National Soft Wheat Millers Association

Portland Cement Association

P.P.G. Industries, Inc.

Protein Cereal Products Institute

Puerto Rico Land Administration

Rice Millers Association

Rubber Manufacturing Association

Technical Association of the Pulp and Paper Industry

Soap and Detergent Association

Synthetic Organic Chemical Manufacturers Association

Tanner’s Council of America, Inc.

Tennessee Valley Public Power Association

Tuna Research Foundation, Inc.

Technical Association of the Pulp and Paper Industry

United States Beet Sugar Association

United States Cane Sugar Refiner’s Association

Western States Meat Packers Association

Western Wood Preserver Association

(b) Public availability of draft technical reports. The draft

repo ts are voluminous and rapid reproduction in large quanti-

ties is difficult to accomplish. In order to maximize the

usefulness of early external review of the reports, the reports

must be transmitted to interested persons immediately upon

receipt by EPA. Printing of substantial quantities of the reports

would consume two to three weeks and, under applicable

federal regulations, no more than approximately 160 copies of

the reports may be provided through outside printing contracts.

The 160 copies of the report supplied by the contractors have

already been largely exhausted in transmissions to the organiza-

tions listed above, and for internal review purposes within EPA.

However, a copy of every report is available in each of EPA’s

regional offices, which are listed in the Appendix to this notice,

and a complete set of the reports is also available in EPA’s

Washington offices (Office of Public Affairs, Environmental

Protection Agency, Room W-227, Waterside Mall, Washington,

D.C. 20460). The Washington Office will also maintain a

complete set of comments received from the public upon draft

reports and upon the notices of proposed rule making which

will subsequently be published. The draft reports, revised EPA

reports which are described below, and all public comments,

will be available for inspection and copying during regular

business hours. Under EPA’s information regulations (40 CFR,

Part 2), a fee may be required for making copies.

In addition to review of the EPA Copies of the reports,

interested persons may in many instances obtain a copy of a

draft report by contacting an organization listed above with

which they have an affiliation or by seeking to review a copy

in the possession of the appropriate State agency.

sion of internal and external review of the initial draft reports

and their tentative recommendations, an EPA draft —

be prepared in support of proposed regulations to be issued in

che Pumunaa Rasta. The EPA draft report will be published

simultaneously with the notice of proposed rule making. The

EPA draft report may be different from the contractors’ reports,

particularly as to the assessment of practicability or availability

of technology, and the conclusions reached with respect to

effuent limitations guidelines and standards of performance

for new sources.

However, EPA does not anticipate that the EPA report will

be markedly different in terms of the fundamental data base for

the regulations. In most cases, major issues or objections to the

approach taken or the conclusicns reached in the EPA draft

report will have already been raised by the contractors’ draft

report. Criticisms of the adequacy of the data base and the

analytical methods employed should therefore be i

now rather than after the notice of proposed rule making.

Nevertheless, EPA does not regard the contractors’ draft

report as an official EPA document and additional comments

will, of course, be solicited once the EPA draft report and the

associated proposed regulations are published (A final EPA

report will also be prepared and published in support of the

final regulations promulgated under sections 301, 304(b), 306

and 307(c).) The EPA draft report will be sent to the list of

reviewers set forth earlier in this notice. In addition, EPA is

establishing a mailing list of other persons wishing to obtain a

copy of the EPA draft report. Any person wishing to be included

on the list should so request as soon as possible, but no later

than August 20, 1973. The request should be addressed to the

“EPA Information Center, Attention: Mr. Philip B. Wisman,

Environmental Protection Agency, Room W-327, Waterside

Mall, Washington, D.C. 20460”, and should indicate which

specific reports the person or organization is interested in

receiving. EPA will transmit a copy of the EPA draft report to

those on the mailing list, as soon as the report is available.

Copies of the EPA draft reports will otherwise be transmitted,

upon request to EPA, at the address just quoted, as soon as

possible. The economic studies referred to in section 2(b)

above will be made available upon request in the same manner

as the EPA draft reports.

EPA desires to make copies of all reports available to inter-

ested parties wishing to comment as soon as possible. EPA

therefore requests the cooperation of the [4334] public who

are interested in, but not directly affected by, the proposed

regulations in awaiting the final EPA report to be published

after the final regulation is printed in the Feperat RecisTERr,

rather than requesting copies of the EPA draft reports.

(d) Solicitation of public comments. By seeking comments

upon the initial draft reports which have already been pre-

pared, and the initial recommended guidelines and standards

which those reports contain, much of the analysis and comment

which would ordinarily occur after notices of proposed rule

making are published is taking place now. In this way the

resolution of many issues can be accomplished even befe: .

notices of proposed rule making are published. These issues

will be identified and their resolution explained in the notices

of proposed rule making. Issues which remain unresolved will

he highlighted in the notices. In addition, EPA hopes to enable

all interested parties to be sufficiently familiar with the complex

technical details underlying the proposed effluent limitations

and standards so that they can respond to notices of proposed

rule making in a relatively short time. In order to meet the

deadlines imposed by the Act, the present plan is that the

notices of proposed rule making will request formal, public

comments within 21 days of publication of the notices in the

Feperat Recister. Those persons who have indicated their

desire to be included on the mailing list described above will

receive copies of EPA’s draft report supporting the proposed

regulations in the Feperat Recisrer. As noted, these reports

will reflect EPA’s judgment as to the proper regulations; how-

ever, they will be based in large part upon the initial draft

reports (which will have been available in most cases since

early July 1973) and any comments received thereon.

EPA will consider all comments received up to the time

indicated in the notices of proposed rule making. In addition,

to the extent time allows, early comments upon the initial draft

reports will be considered when developing proposed rule

making regulations.

(e) Conclusion. In summary, EPA is, by this notice, seeking

to encourage as wide ranging and thorough public review prior

to proposal and promulgation of effluent limitations guidelines

and standards of performance as is possible within the time

allowed. The following specific steps may be taken by inter-

ested persons:

1. Submit comments upon initial draft reports and economic

studies. To facilitate rapid transmission of comments to the

persons concerned within EPA, and also have a copy which is

immediately available for public review, EPA requests that

comments be submitted in triplicate. All comments received

before or after publication of the notice of proposed rule

making, as well as all technical and economic reports, will be —

available for inspection and copying at the Office of Public

40 4l

Affairs, Room 227, West Tower, Waterside Mall, neg regular this fits with the detailed requirements of sections 304(b), 306

business hours (8:00 a.m.—4:30 p.m.). and 307(c) of the Act.

: July 31, 1973.

2. Request inclusion on a mailing list for the EPA draft ae Rosert L. SANSOM,

reports and economic studies which will be published about the | Assistant Administrator jor

same time as notices of proposed rule making in the FepeRAL J Air and Water Programs.

RecisTer. Requests to be included on the mailing list should

be received by August 20, 1973 and should indicate which

specific reports are requested.

5. Comment upon the notices of proposed rule making and

the associated draft EPA technical and economic reports. All

comments received within 21 days after publication of the

notices in the Feperat RecisTer will be considered.

4. All public comments, requests to be included on the mail-

ing list for reports and other requests for reports may be

addressed to “EPA Information Center, Attention; Mr. Philip

B. Wisman, Environmental Protection Agency, Room W-327,

Waterside Mall, Washington, D.C. 20460.”

In conclusion, it should be emphasized that EPA seeks com-

ments upon its overall approach and legal interpretation of its

responsibilities under sections 304(b), 306 and 307(c) of the

Act, as well as upon the technical aspects of the initial draft

reports, and the EPA reports to be issued. However, it should

be also emphasized that the early expressiun of comments is

essential if EPA is to be able to make whatever adjustments and

responses which may be necessary in time to satisfy its respon-

sibilities under the Act. In the event comments are in the

nature of criticisms as to the adequacy of data which is avail-

able or which may be relied upon by the Agency, comments

should identify any additional data which may be available

and should indicate how such data is pertinent to the develop-

ment of regulations under sections 301, 304(b), 306 and 307(c)

of the Act. In the event comments address the approach taken

to establishing an effluent limitation guideline or standard of

performance, EPA solicits suggestions as to what alternative

approach should be taken, or result reached, and why and how

Appendix

Director, Office of Public Affairs

Environmental Protection Agency

401 M Street, S.W.

Washington, D.C. 20460

Director of Public Affairs

Region I

Environmental Protection Agency

Room 2303

John F. —— Federal Building

Boston, Massachusetts 02203

Director of Public Affairs

Region II

Environmental Protection Agency

Room 847

26 Federal Plaza

New York, New York 10007

Director of Public Affairs

Region III

Environmental Protection Agency

Curtis Bldg., 6th and Walnut Streets

Philadelphia, Pennsylvania 19106

Director of Public Affairs

Region IV

Environmental Protection Agency

Suite 300

1421 Peachtree Street, N.E.

Atlanta, Georgia 30309

Director of Public Affairs

Region V

Environmental Protection Agency

1 N. Wacker Drive

Chicago, Illinois 60606

Director of Public Affairs

Region VI

Environmental Protection Agency

1600 Patterson Street

Dallas, Texas 75201

Director of Public Affairs

Region VII

Environmental Protection Agency

1735 Baltimore Street

Kansas City, Missouri 64108

Director of Public Affairs

Region VIII

Environmental Protection Agency

Lincoln Tower, Room 916

1860 Lincoln Street

Denver, Colorado 80203

Director of Public Affairs

Region IX

Environmental Protection Agency

100 California Street

San Francisco, California 94102

Director of Public Affairs

Region X

Environmental Protection Agency

1200 6th Avenue

Seattle, Washington 98101

[FR Doc.73-16133 Filed 8-3-73; 8:45 am]

[4335] This document is available in limited quantities

through the U.S. Environmental Protection Agency, Informa-

tion Center, Room W-327 Waterside Mall, Washington, D.C.

20460.

The document will subsequently be available through the

National Technical Information Service, Springfield, Virginia

22151.

[4436] EPA-230/1-73-015

AUGUST 1973

Economic Analyses

Proposed Effluent Guidelines

INORGANIC CHEMICALS, ALKALI AND

CHLORINE INDUSTRIES (Major Products)

U.S. ENVIRONMENTAL PROTECTION AGENCY

Office of Planning and Evaluation

Washington, D.C. 20460

[4337] This report has been reviewed by the Office of Plan-

ning and Evaluation, EPA, and approved for publication.

Approval does not signify that the contents necessarily reflect

the views and policies of the Environmental Protection Agency,

nor does mention of trade names or commercial products con-

stitute endorsement or recommendation for use.

[4338] PREFACE

The attached document is a contractors’ study prepared for

the Office of Planning and Evaluation of the Environmental

Protection Agency (“EPA”). The purpose of the study is to

analyze the economic impact which could result from the appli-

cation of alternative effluent limitation guidelines and standards

of performance to be established under sections 304(b) and

306 of the Federal Water Pollution Control Act, as amended.

The study supplements the technical study (“EPA Develop-

ment Document”) supporting the issuance of proposed regu-

lations under sections 304(b) and 306. The Development

Document surveys existing and potential waste treatment

control methods and technology within particular industrial

source categories and supports promulgation of certain effluent

limitation guidelines and standards of performance based upon

an analysis of the feasibility of these guidelines and standards

in accordance with the requirements of sections 304(b) and

306 of the Act. Presented in the Development Document are

the investment and operating costs associated with various

alternative control and treatment technologies. The attached

document supplements this analysis by estimating the broader

economic effects which might result from the required applica-

tion of various control methods and technologies. This study

investigates the effect of alternative approaches in terms of

produce price increases, effects pon employment and the

continued viability of affected plants, effects upon foreign trade

and other competitive effects.

The study has been prepared with the supervision and review

of the Office of Planning and Evalua ‘on of EPA. This report

was submitted in fulfillment of Task Order NO. 8, Contract

68-01-1541 by Arthur D. Little, Inc. Work was completed as of

August 1973.

This report is being | ‘eased and circulated at approximately

the same time as publica.ion in the Federal Register of a notice

of proposed rule making under sections 304(b) and 306 of the

Act for the subject point source category. The study has not

been reviewed by EPA and is not an official EPA publication.

The study will be considered along with the information con-

tained in the development document and any comments re-

ceived by EPA on either document before or during p

rule making proceedings necessary to establish final regulations.

Prior to final promulgation of regulations, the accompanying

study 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. It cannot be

cited, referenced, or represented in any respect in any such

proceeding as a statement of EPA’s views regarding the subject

industry.

[4339] TABLE OF CONTENTS

Page

List oF TABLES. we .cnnaciliidisinaiamemnsinnbiniaaticameniins * a

List or FicurEs. ____. sanpslieeaeeantiananecatipecsanatetiimnenaete., ae

I, SUMMARY .. nocmencenanignenienttniminnsticiigeiineasen nietaniiiiniial 1

A. Introduction — 1

B. Conclusions 7

II. INpustry CHARACTERIZATION—ADDITIONAL Propucts.. 23

A. Calcium Carbide 23

B. Sodium Sulfate 36

C. Titanium Dioxide ~ 4

D. Sodium Bichromate _ 76

E. Potassium Richromate _ 90

III. Intpact ANAysits—Inrr1aL Stupy Propucts 93

A. Aluminum Chioride Lk.

B. Aluminum Sulfate — _ 94

C. Chlorine and Caustic Soda — — 95

D. Hydrochloric Acid - a

E. Hydrofluoric Acid ao-~iemniniblintnilinisiiinnindiiaia ae

F. Hydrogen Peroxide 99

G. Lime _ . 100

H. Nitric Acid ‘icccudiatdadhinshienad tiie

Sulfuric Acid -

TABLE OF CONTENTS (Continued)

[4340] Page

. Impact ANALYsIS—ADDITIONAL PRODUCTS

i I ce ticatilancirtsicntintiratqnen:-<enntgn 105

SS _, eee

EET RIE AE _ 107

D. Sodium Chromate and Bichromate —..________ 112

[4455] EPA 440/1-73/007

Development Documeni for

Proposed Effluent Limitations Guidelines

and New Source Performance Standards

for the

MAJOR INORGANIC PRODUCTS

Segment of the

Inorganic Chemicals Manufacturing

Point Source Category

UNITED STATES ENVIRONMENTAL PROTECTION

AGENCY

AUGUST 1973

[4456] DEVELOPMENT DOCUMENT

for

PROPOSED EFFLUENT LIMITATIONS GUIDELINES

and

NEW SOURCE PERFORMANCE STANDARDS

for the

MAJOR INORGANIC PRODUCTS SEGMENT OF THE

INORGANIC CHEMICALS MANUFACTURING

POINT SOURCE CATEGORY

RussELL TRAIN

Administrator

Rosert L. SANSOM

Assistant Administrator for Air & Water Programs

ALLEN CyrwINn

Director, Effluent Guidelines Division

E.woop E. MartTIN

Project Officer

September, 1973

Effluent Guidelines Division

Office of Air and Water Programs

U.S. ENVIRONMENTAL PROTECTION AGENCY.

Washington, D.C. 20460

[4457] ABSTRACT

This document presents the findings of an extensive study of

selected major inorganic chemicals for the purpose of develop-

ing effluent limitation guidelines for existing point sources and

standards of performance and pretreatment standards for new

sources, to implement Sections 304, 306 and 307 of the Federal

Water Pollution Control Act, as amended (33 U.S.C. 1551,

1314, and 1316, 86 Stat. 816 et seq.) (the “Act”).

Effluent limitations guidelines contained herein set forth the

degree of effluent reduction attainable through the application

of the best practicable controt technology currently available

(BPCTCA) and the degree of effluent reduction attainable

through the application of the best available technology eco-

nomically achievable (BATEA) which must be achieved by

existing point sources by July 1, 1977 and July 1, 1983 respec-

tively. The standards of performance and pretreatment stand-

ards for new sources contained herein set forth the degree of

effluent reduction which is achievable through the application

of the best available demonstrated control technology,

processes, operating methods, or other alternatives.

Based on the application of best practicable technology cur-

rently available 14 of the 25 chemicals under study can be

manufactured with no discharge of process waste water pol-

lutants to navigable waters. With the best available technology

economically achievable 23 of the 25 chemicals can be manu-

factured with no discharge of process waste water pollutants

to navigable waters. No discharge of process waste water pol-

lutants to navigable waters is achievable as a new source

perfor: xance standard for all chemicals except titanium dioxide.

Supporting data and rationale for development of the pro-

posed effluent limitations guidelines and standards of per-

formance are contained in this report.

[4458] CONTENTS

Section Page

I. CONCLUSIONS AE PR Ne! «ae i ak a. 1

II. RECOMMENDATIONS .. 3

III. INTRODUCTION _ a 7

IV. Inpustry CATEGORIZATION... tC

V. Water Use anp WasTE CHARACTERIZATION..._———C«éST7'S

VI. SELECTION OF POLLUTION PARAMETERS ...—_—_—so€2N5

VII. ConTROL AND TREATMENT TECHNOLOGY ss sé«é2

VIII. Cost, ENercy, anD Non-WaTER QUALITY

ASPECTS eaten

IX. EFF.Lvent REDUCTION ATTAINABLE THROUGH

THE APPLICATION OF THE BEST PRACTICABLE

ConTroL TECHNOLOGY CURRENTLY AVAILABLE,

EFFLUENT GUIDELINES AND LIMITATIONS 353

X. EFFLvENt REDUCTION ATTAINABLE THROUGH

THE APPLICATION OF THE BEsT AVAILABLE

TECHNOLOGY ECONOMICALLY ACHIEVABLE

EFFLUENT GUIDELINES AND LIMITATIONS. 369

XI. New Source PERFORMANCE STANDARDS AND

PRETREATMENT RECOMMENDATIONS... 377

XII. ACKNOWLEDGEMENTS... 381

UR REET ELS ASS Oe TTC Oa 385

XIV. G.Lossary ’ . 391

[4473] SECTION Ill

INTRODUCTION

Purpose and Authority

The United States Environmental Protection Agency (EPA)

is charged under the Federal Water Pollution Control Act

Amendments of 1972 with establishing effluent limitations

which must be achieved by point sources of discharge into the

navigable water of the United States.

Section 301(b) of the Act requires the achievement by not

later than July 1, 1977, of effluent limitations for point sources,

other than publicly owned treatment works, which are based

on the application of the best practicable control technology

currently available as defined by the Administrator pursuant to

Section 304(b) of the Act. Section 301(b) also requires the

achievement by not later than July 1, 1983, of effluent limita-

tions for point sources, other than publicly owned treatment

works, which are based on the application of the best available

technology economically achievable which will result in rea-

sonable further progress toward the national goal of elim-

inating the discharge of all pollutants, as determined in

accordance with regulations issued by the Administrator pur-

suant to Section 304(b) to the Act. Section 306 of the Act

requires the achievement by new sources of a Federal standard

of performance providing for the control of the discharge of

pollutants which reflects the greatest degree of effluent reduc-

tion which the Administrator determines to be achievable

through the application of the best available demonstrated

control technology, processes, operating methods, or other

alternatives, including, where practicable, a standard permit-

ting no discharge of pollutants. Section 304(b) of the Act re-

quires the Administrator to publish within one year of enact-

ment of the Act, regulations providing guidelines for effluent

limitations setting forth the degree of effluent reduction attain-

able through the application of the best practicable control

technology currently available and the degree of effluent

reduction attainable through the application of the best control

measures and practices achievable including treatment tech-

niques, process and procedure innovations, operation methods

and other alternatives. The regulations proposed herein set

forth effluent limitations guidelines pursuant to Section 304(b)

of the Act for the inorganic chemicals manufacturing point

source category,

Section 306 of the Act requires the Administrator, within one

year after a category of sources is included in a list published

pursuant to Section 306(b) (1) (A) of the Act, to propose

regulations establishing Federal standards of performances for

new sources within such categories. The Administrator pub-

lished in the Federal Register of January 16, 1973 (38 F.R.

1624), a list of 27 source categories. Publication of the list

constituted announcement of the Administrator's intention of

establishing, under Section 306, standards of performance

[4474] applicable to new sources within the inorganic chemical

manufacturing point source category, which was included

within the list published January 16, 1973.

SUMMARY OF METHODS USED FOR DEVELOPMENT

OF EFFLUENT LIMITATION GUIDELINES AND

STANDARDS OF PERFORMANCE

The Environmental Protection Agency has determined that

a rigorous approach including plant surveying and verification

testing is necessary for the promulgation of effluent standards

from industrial sources. A systematic approach to the achieve-

ment of the required guidelines and standards includes the

following:

(a) Categorization of the industry and determination of

those industrial —— for which separate effluent

limitations and standards need to be set;

(b) Characterization of the waste loads gon from

discharges within industrial categories and sub-

categories;

technology within each industrial category and sub-

category;

(d) Identification of those plants having the best practical

technology currently available (exemplary plants);

and

(e) Generation of supporting verification data for the best

practical technology including actual sampling of

plant effluents by field teams.

The culmination of these activities is the development of the

guidelines and standards based on the best practicable current

technology.

This report describes the results obtained from application

of the above approach to the inorganic chemicals industry.

Thus, the survey and testing covered a wide range of processes,

products, and types of wastes. Studies of a total of twenty-five

chemicals, listed in terms of products below, are summarized

in this report. A separate report covering the phosphorus

based segment of the phosphorus chemicals industry was also

generated under the same contract.

Selected Inorganic Chemicals

Aluminum Chloride Potassium Metal

Aluminum Sulfate Potassium Sulfate

Calcium Carbide Sodium Bicarbonate

Calcium Chloride Sodium Carbonate

Chlorine (Soda Ash )

Hydrochloric Acid Sodium Chloride

Hydrogen Peroxide Sodium Dichromate

[4475] Hydrofluoric Acid Sodium Hydroxide

Calcium Oxide and Sodium Metal

Calcium Hydroxide Sodium Silicate

(Lime) Sodium Sulfate

Nitric Acid Sodium Sulfite

Potassium Chromates Sulfuric Acid

Potassium Hydroxide Titanium Dioxide

Categorization and Waste Load Characterization

The effluent limitation guidelines and standards of perform-

ance proposed herein were developed in the following manner.

The point source category was first categorized for the purpose

of determining whether separate limitations and standards are

appropriate for different segments within a point source cate-

gory. Such subcategorization was based upon raw material

used, product produced, manufacturing process employed, and

other factors. The raw waste characteristics for each sub-

category were then identified. This included an analysis of

(1) the source and volume of water used in the process em-

ployed and the sources of waste and waste waters in the plant;

and (2) the constituents of all waste waters including harmful

constituents and other constituents which result in degradation

of the receiving water. The constituents of waste waters which

should be subject to effluent limitations guidelines and stand-

ards of performance were identified.

The full range of control and treatment technologies existing

within each subcategory was identified. This included an

identification of each control and treatment technology, includ-

ing both inplant and end-of-process technologies, which are

existent or capable of being designed for each subcategory. It

also included an identification of the amount of constituents

(including thermal) and the characteristics of pollutants

resulting from the application of each of the treatment and

control technologies. The problems, limitations and reliability

of each treatment and control technology were also identified.

In addition, the non-water quality environmental impact, such

as the effects of the application of such technologies upon other

pollution problems, including air, solid waste, noise and radia-

tion were also identified. The energy requirements of each of

the control and treatment technologies were identified as well

as the cost of the application of such technologies.

Cost information contained in this report was obtained

drectly from industry during exemplary plant visits, from engi-

neering firms and equipment suppliers, and from the literature.

The information obtained from the latter three sources has been

used to develop general capital, operating and overall costs

for each treatment and control method. Costs have been put

on a consistent industrial calculation basis of ten year straight

line depreciation plus allowance for interest at six [4476] per-

cent per year (pollution abatement tax free money) and

inclusion of allowance for insurance and taxes for an overall

fixed cost amortization of fifteen percent per year. This gen-

eralized cost data plus the specific information obtained from

plant visits was then used for cost effectiveness estimates in

Section VIII and wherever else costs are mentioned in this

report.

The data for identification and analyses were derived from

a number of sources. These sources included EPA research

information, published literature, qualified technical consulta-

tion, on-site visits and interviews at numerous inorganic chem-

ical plants throughout the U.S., interviews and meetings with

various trade associations, and interviews and meetings with

various regional offices of the EPA. All references used in

developing the guidelines for effluent limitations and standards

of performance for new sources reported herein are included

in Section XIII of this report.

Exemplary plant selection

The following exemplary plant selection criteria were devel-

oped and used for the selection of exemplary plants.

(a) Discharge effluent quantities

Plants with low effluent quantities or the ultimate of no

pollutants discharge were preferred. This minimal discharge

may be due to reuse of water, raw material recovery and re-

cycling, or to use of evaporation. The significant parameter

was minimal waste added to effluent streams per weight of

product manufactured. The amount of wastes considered here

were those added to waters taken into the plant and then

discharged.

(b) Effluent contaminant level

Preferred plants were those with lowest effluent contaminant

concentrations and lowest total quantity of waste discharge

per unit of product.

Use of good management practices such as water re-use,

planning and inplant water segregation, and the proximity of

cooling towers to operating units where airborne contamination

of water can occur were considered.

(d) Land utilization

The efficiency of land use was considered.

(e) Air pollution and solid waste control

xemplary plants must possess overall effective air

eh clit onal pollution control where relevant in addition to

water pollution control technology. Care was taken to insure

that all plants chosen have minimal discharges into the environ-

ment and that exemplary sites are not those which are exchang-

ing one form of pollution for another of the same or greater

magnitude.

(f) Effluent treatment methods and their effectiveness

Plants selected shall have in use the best currently available

treatment methods, operating controls, and operational relia-

bility. Treatment methods considered included basic process

modifications which significantly reduce effluent loads as well

as conventional treatment methods.

(g) Plant facilities

All plants chosen as exemplary had all the facilities normally

associated with the production of the specific chemical (s ) in

question. Typical facilities generally were plants which have

all their normal process steps carried out on-site.

Plant management philosophy

Plants were preferred whose management insists upon effec-

tive equipment maintenance and good housekeeping practices.

These qualities are best identified by a high operational factor

and plant cleanliness.

(h) Geographic location

Factors which were considered are plants operating in close

proximity to sensitive vegetation or in densely populated areas.

Other factors such as land availability and differences in state

and local standards were also considered.

(i) Raw materials

Differences in raw material purities were given strong con-

sideration in cases (e.g., TiO) where the amounts of wastes

are strongly influenced by the purity of raw materials used.

Several plants using different grades of raw materials were

considered for those chemicals for which raw material purity

is a determining factor in waste control. Chemicals where this

was found to be of importance are titanium dioxide, aluminum

sulfate, the dichromates, and to a lesser extent chlorine and

sodium chloride.

(j) Diversity of processes

On the basis that all of the above criteria are met, considera-

tion was given to installations having a multiplicity of manu-

facturing processes. [4478] However, for sampling purposes,

the complex facilities chosen were those for which the wastes

could be clearly traced through the various treatment steps.

(k) Production

On the basis that other criteria are equal, consideration was

given to the degree of production rate scheduled on water pol-

lution sensitive equipment.

(1) Product purity

For cases in which purity requirements play a major role in

determining the amounts of wastes to be treated and the degree

of water recycling possible, different product grades were con-

sidered for subcategorization.

Sampling of Exemplary Plants

The details of how the exemplary plants were sampled and

the analytical techniques employed are fully discussed in Sec-

tion V, of this report.

GENERAL DESCRIPTION OF THE INDUSTRY

Brief descriptions of each of the twenty-five chemical indus-

tries are presented in subsequent subsections. Process flow

sheets for the industries may be found in Sections IV and V.

Production tonnages reported for 1971 were taken from Current

Industrial Reports, Inorganic Chemicals, U.S. Bureau of

Census, Series M28A(71)-14.(1) These values are summarized

in Table I, at the end of this section. Also included are pro-

duction tonnages for years prior and subsequent to 1971, where

available, and the number of plants producing each chemical.

[4861]

THURSDAY, OCTOBER 11, 1973

WASHINGTON, D.C.

Volume 38 @ Number 196

PART II

ENVIRONMENTAL

PROTECTION

AGENCY

Effluent Limitations

Guidelines and Standards

of Performance and

Pretreatment

Proposed Rules

[4862] ENVIRONMENTAL PROTECTION

AGENCY

[40 CFR Part 415]

EFFLUENT LIMITATIONS GUIDELINES AND STAND-

ARDS OF PERFORMANCE AND PRETREATMENT

FOR INORGANIC CHEMICALS MANUFACTURING

POINT SOURCE CATEGORY

Notice of Proposed Rulemaking

Notice is hereby given that effluent limitations guidelines

for existing sources and standards of performance and pre-

treatment standards for new sources set forth in tentative form

below are proposed by the Environmental Protection Agency

(EPA) for the aluminum chloride production subcategory

(Subpart A), the aluminum sulfate production subcategory

(Subpart B), the calcium carbide production subcategory

(Subpart C), the calcium chloride production subcategory

(Subpart D), the calcium oxide and hydroxide production sub-

category (Subpart E), the chlorine and sodium or potassium

hydroxide production subcategory (Subpart F), the hydro-

chloric acid production subcategory (Subpart G), the hydro-

fluoric acid production subcategory (Subpart H), the hydrogen

peroxide production subcategory (Subpart I), the nitric acid

production subcategory (Subpart J), the potassium metal pro-

duction subcategory (Subpart K), the potassium dichromate

production subcategory (Subpart I), the potassium sulfate

production subcategory (Subpart M), the sodium bicarbonate

production subcategory (Subpart N), the sodium carbonate

production subcategory (Subpart O), the sodium chloride

production subcategory (Subpart P), the sodium dichromate

and sodium sulfate production subcategory (Subpart Q), the

sodium metal production subcategory (Subpart R), the sodium

silicate production subcategory (Subpart S), the sodium sulfite

production subcategory (Subpart T), the sulfuric acid produc-

tion subcategory (subpart U ), and titanium dioxide production

subcategory (Subpart V), of the inorganic chemicals manu-

facturing category of point sources pursuant to sections 301,

304(b) and (c), 306(b) and 307(c) of the Federal Water

Pollution Coniroi Act, as amended (33 U.S.C. 1251, 1311,

1314 (b) and (c), 1316(b) and 1317(c); 86 Stat. 816 et seq.;

Pub. L. 92-500) (the “Act”).

(a) Legal authority. (1) Existing point sources. Section

301(b) of the Act requires the achievement by not later than

July 1, 1977, of effluent limitations for point sources, other than

publicly owned treatment works, which require the application

of the best practicable control technology currently available

as defined by the Administrator pursuant to Section 304(b)

of the Act. Section 301(b) also requires the achievement by

not later than July 1, 1983, of effluent limitations for point

sources, other than publicly owned treatment works, which

require the application of best available technology economi-

cally achievable which will result in reasonable further prog-

ress toward the national goal of eliminating the discharge of

all pollutants, as determined in accordance with regulations

issued by the Administrator pursuant to section 304(b) of

the Act.

Section 304(b) of the Act requires the Administrator to

publish regulations providing guidelines for effluent limita-

tions setting forth the degree of effluent reduction attainable

through the application of the best practicable control tech-

nology currently available and the degree of effluent reduc-

tion attainable through the application of the best control

measures and practices achievable including treatment tech-

niques, process and procedure innovations, operating methods,

and other alternatives. The regulations proposed herein set

forth effluent limitations guidelines, pursuant to section 304(b)

of the Act, for the aluminum chloride production subcategory

(Subpart A), the aluminum suliate production subcategory

(Subpart B), the calcium carbide production subcategory

(Subpart C), the calcium chloride production subcategory

(Subpart D), the calcium oxide and hydroxide production sub-

category (Subpart E), the chlorine and sodium or potassium

hydroxide production subcategory (Subpart F), the hydro-

chloric acid production subcategory (Subpart G), the hydro-

fluoric acid production subcategory (Subpart H), the hydrogen

peroxide production subcategory (Subpart I), the nitric

acid production subcategory (subpart J), the potassium metal

production subcategory (Subpart K ), the potassium dichromate

production subcategory (Subpart L), the potassium sulfate

production subcategory (Subpart M), the sodium bicarbonate

production subcategory (Subpart N), the sodium carbonate

production subcategory (Subpart O), the sodium chloride

production subcategory (Subpart P), the sodium dichromate

and sodium sulfate production subcategory (Subpart Q), the

sodium metal production subcategory (Subpart R), the sodium

silicate production subcategory (Subpart S), the sodium

sulfite production subcategory (Subpart T), the sulfuric acid

production subcategory (Subpart U), and titanium dioxide

production subcategory (Subpart V), of the inorganic chemi-

cals manufacturing category.

(2) New sources. Section 306 of the Act requires the

achievement by new sources of a Federal standard of perform-

ance providing for the control of the discharge of pollutants

which reflects the greatest degree of effluent reduction which

the Administrator determines to be achievable through applica-

tion of the best available demonstrated control technology,

processes, operating methods, or other alternatives, including,

where practicable, a standard permitting no discharge of pol-

lutants.

Section 306(b)(1)(B) of the Act requires the Administrator

to propose regulations establishing Federal standards of per-

formance for categories of new sources included in a list

published pursuant to section 306(b)(1)(A) of the Act. The

Administrator published in the FeperaL RecisTer of January

16, 1973, (38 FR 1624) a list of 27 source categories, includ-

ing the inorganic chemicals manufacturing category. The regu-

lations proposed herein set forth the standards of performance

applicable to new sources for the alumnium chloride production

subcategory (Subpart A), the aluminum sulfate production sub-

category (Subpart B), the calcium carbide production subcate-

gory (Subpart C), the calcium chloride production subcategory

(Subpart D), the calcium oxide and hydroxide production sub-

category (Subpart E), the chlorine and sodium or potassium

hydroxide production subcategory (Subpart F), the hydro-

chloric acid production subcategory (Subpart G), the hy-

drofluoric acid production subcategory (Subpart H), the

hydrogen peroxide production subcategory (Subpart I), the

nitric acid production subcategory (Subpart J), the potassium

metal production subcategory (Subpart K), the potassium

dichromate production subcategory (Subpart L), the potassium

sulfate production subcategory (Subpart M), the sodium bi-

carbonate production subcategory (Subpart N), the sodium

carbonate production subcategory (Subpart O), the sodium

chloride production subcategory (Subpart P), the sodium di-

chromate and sodium sulfate production subcategory (Sub-

part Q), the sodium metal production subcategory (Subpart R),

the sodium silicate production subcategory (Subpart S), the

sodium sulfite production subcategory (Subpart T), the sul-

furic acid production subcategory (Subpart U), and titanium

dioxide production subcategory (Subpart V), of the inorganic

chemicals manufacturing category.

Section 307(c) of the Act requires the Administrator to

promulgate pretreatment standards for new sources at the

same time that standards of performance for new sources are

promulgated pursuant to section 306. Sections 415.15, 415.25,

and 415.35, 415.45, 415.55, 415.65, 415.75, 415.85, 415.95,

415.105, 415.115, 415.125, 415.135, 415.145, 415.155, 415.165,

415.175, 415.185, 415.195, 415.205, 415.215, 415.225, proposed

below provide pretreatment standards for new sources within

the aluminum chloride production subcategory (Subpart A),

the aluminum sulfate production subcategory (Subpart B), the

calcium carbide production subcategory (Subpart C), the

calcium chloride production subcategory (Subpart D), the cal-

cium oxide and hydroxide production subcategory (Subpart E),

the chlorine and sodium or potassiura hydroxide production

subcategory (Subpart F’), the hydrochloric acid production sub-

category (Subpart G), the hydrofluoric acid production subcat-

egory (Subpart H), the hydrogen peroxide production sub-

category (Subpart I), the nitric acid production subcategory

(Subpart J ), the potassium metal production subcategory (Sub-

part K), the potassium dichromate production subcategory

(Subpart L), the potassium sulfate production subcategory

(Subpart M), the sodium bicarbonate production subcate-

gory (Subpart N), the sodium carbonate production sub-

category (Subpart O), the sodium chloride production subcate-

gory (Subpart P), the sodium dichromate and so- [4863] dium

sulfate production subcategory (Subpart Q), the sodium metal

production subcategory (Subpart R), the sodium silicate pro-

duction subcategory (Subpart S), the sodium sulfite produc-

tion subcategory (Subpart T), the sulfuric acid production

subcategory (Subpart U), and titanium dioxide production

subcategory (Subpart V), of the inorganic chemicals manufac-

turing category.

Section 304(c) of the Act requires the Administrator to issue

to the States and appropriate water pollution cor*»ol agencies

information on the processes, procedures or operating methods

which result in the elimination or reduction of the discharge

of pollutants to implement standards of performance under

Section 306 of the Act. The Development Document referred

to below provides pursuant to Section 304(c) of the Act, in-

formation on such processes, procedures of operating methods.

(b) Summary and basis of proposed effluent limitations

guidelines for existing sources and standards of performance

and pretreatment standards for new sources. (1) General

methodology. The effluent limitations guidelir~s and standards

of performance proposed herein were developed in the follow-

ing manner. The point source category was first studied for

the purpose of determining whether separate limitations and

standards are appropriate for different segments within the

category. This analysis included a determination of whether

differences in raw material used, product produced, manufac-

turing process employed, age, size, waste water constituents

and other factors require development of separate limitations

and standards for different segments of the point source cate-

gory. The raw waste characteristics for each such segment

were then identified. This included an analysis of (1) the

source, flow and volume of water used in the process employed

and the sources of wasie and waste waters in the operation

and (2) the constituents of al] waste water. The constituents

of the waste waters which should be subject to effluent limita-

tions guidelines and standards of performance were identified.

The control and treatment technologies existing within each

segment were identified. This included an identification of

each distinct control and treatment technology, including both

in-plant and end-of-process technologies, which are existent or

capable of being designed for each segment. It also included

an identification of, in terms of the amount of constituents and

the chemical, physical, and biological characteristics of pol-

lutants, the effluent level resulting from the application of

each of the technologies. The problems, limitations and relia-

bility of each treatment and control technology were also

identified. In addition, the non-water quality environmental

impact, such as the effects of the application of such technol-

ogies upon other pollution problems, including air, solid waste,

noise and radiation, were identified. The energy requirements

of each control and treatment technology were determined as

well as the cost of the application of such technologies.

The information, as outlined above, was then evaluated

in order to determine what levels of technology constitute the

“best practicable control technology currently available,” “the

best available technology economically achievable” and the

“best available demonstrated control technology, processes,

operating methods, or other alternatives.” In identifying such

technologies, various factors were considered. These included

the total cost of application of technology in relation to the

effluent reduction benefits to be achieved from such applica-

tion, the age of equipment and facilities involved, the process

employed, the engineering aspects of the application of various

types of control techniques, process changes, non-water quality

environmental impact (including energy requirements) and

other factors.

The data upon which the above analysis was performed in-

cluded EPA permit applications, EPA sampling and inspec-

tions, consultant reports, and industry submissions.

The pretreatment standards proposed herein are intended

to be complementary to the pretreatment standards proposed

for existing sources under Part 128 of 40 CFR. The basis for

such standards are set forth in the Feperat Recister of July 19,

1973, 38 FR 19236. The provisions of Part 128 are equally

applicable to sources which would constitute “new sources,”

under section 306 if they were to discharge pollutants directly

to navigable waters, except for § 128.133. That section provides

a pretreatment standard for “incompatible pollutants” which

requires application of the “best practicable control technology

currently available,” subject to an adjustment for amounts of

pollutants removed by the publicly owned treatment works.

Since the pretreatment standards proposed herein apply to new

sources, §§ 415.15, 415.25, 415.35, 415.45, 415.55, 415.65, 415.75,

415.85, 415.95, 415.105, 415.115, 415.125, 415.135, 415.145,

415.155, 415.165, 415.175, 415.185, 415.195, 415.205, 415.215,

and 415.225 below amend § 128.133 to require application of

the standard of performance for new sources rather than the

“best practicable” standard applicable to existing sources

under sections 301 and 304(b) of the Act.

(2) Summary of conclusions with respect to the inorganic

chemicals manufacturing category of point sources.

(i) Categorization. For the purpose of establishing effluent

limitations guidelines and standards, the inorganic chemicals

manufacturing category was divided into twenty-two discrete

subcategories consistent with the specific chemicals produced.

Various other means to group the twenty-two chemicals into

subcategories were investigated. Factors such as raw waste

loads, water requirements, and manufacturing processes do not

establish a sound basis for subcategorization because the -aw

materials used and production processes employed are specific

for each chemical. Although certain waste water constituents

inay be reduced to similar concentrations for selected chemical

groupings, the quantities of pollutants discharged based on

production volume are different for each chemical because of

specific water requirements.

Thus, for the purpose of these regulations, a subcategory was

established for each chemical product. This subcategorization

scheme simplifies the application of effluent limitations guide-

lines because inorganic chemical plants vary significantly in

terms of product mix. This scheme also reflects differences in

the treatability of waste streams due to the manufacturing

process variables unique to each chemical.

(ii) Process descriptions, water use and waste water charac-

terization for each chemical subcategory

(1) Aluminum chloride. Anhydrous aluminum chloride is

manufactured by the reaction of gaseous chlorine with molten

aluminum metal. Chlorine is introduced below the surface of

the molten aluminum. The aluminum chloride sublimes and

is collected by condensation.

No water is used in the process except in cases where a wet

scrubber is used to eliminate the discharge of unreacted chlo-

rine gas to the atmosphere. The wet scrubbing solution may

be sold as a byproduct or recycled after the precipitation of

aluminum salts.

(2) Aluminum sulfate. Aluminum sulfate is produced by

the reaction of bauxite ore with concentrated sulfuric acid.

Ground ore and acid are reacted in a digester, yielding alumi-

num sulfate in solution plus muds and insoluble waste mate-

rials. These waste products are removed during sedimentation

and filtration. The filtered product liquor 1s either shipped as

liquid aluminum sulfate or evaporated to recover a solid prod-

uct. Waste muds may be ponded to settle the solids and the

clear water may be recycled.

(3) Calcium carbide. Calcium carbide is prepared by the

reaction of calcium oxide with carbon in a high temperature

furnace. The product is then cooled, crushed, screened, pack-

aged, and shipped. The only wastes from this process are air-

borne dusts from the furnace coke dryer, from screening and

from the packing station. All collected dusts may be returned

to the furnace.

(4) Calcium chloride. The limitations presented herein

apply only to the brine extraction process of manufacturing

calcium chloride. Salt is solution-mined and the resulting

brines concentrated to rernove sodium chloride by precipitation

and then purified by the addition of other materials to precipi-

tate sodium, potassium, and magnesium ions. The process

wastes are weak brine solutions from the blowdown of the

various brine purification steps.

(5) Calcium oxide and hydroxide. Calcium oxide and hy-

droxide are produced by calcining various types of limestone

in continuous vertical or rotating kilns. This is a dry process,

and the only waterborne wastes result from wet scrubbing of

the gaseous kiln effluent to remove particulates.

[4864] After calcination, the calcium oxide and hydroxide

are cooled and packaged as a lump product or crushed and

screened to yield a pulverized product.

(6) Chlorine and sodium or potassium hydroxide. The

major chlorine production results from the electrolysis of

sodium or potassium brines. Sodium hydroxide or potassium

hydroxide are produced as byproducts. Two types of elec-

trolysis cells may be used.

In the mercury cell process, the raw material is dissolved

and purified by addition of barium carbonate, soda ash, and

lime to remove magnesium, calcium, and sulfate ion prior to

electrolysis. The insolubles formed are filtered from the brine,

which is fed into a mercury cell, where chlorine is liberated

at one electrode and a sodium-mercury amalgam is formed at

the other.

The chlorine formed is cooled, dried in a sulfuric acid stream,

purified to remove chlorinated organics, compressed and sold.

The mercury-sodium amalgam formed is treated with water to

decompose the amalgam. Sodium hydroxide and hydrogen

are formed in the reaction. The mercury liberated is returned

to the electrolysis cells. The hydrogen is cooled, scrubbed to

remove traces of mercury, compressed and sold.

The sodium hydroxide formed during the decomposition of

the amalgam is filtered, concentrated, and sold. Waste brines

emerging from the electrolysis cells are concentrated and

recycled.

In the diaphragm cell process, chloride brines are first puri-

fied and then electrolyzed in a diaphragm cell. Chlorine,

formed at one electrode, is collected, cooled, dried with

sulfuric acid, purified, compressed, and liquefied. At the

other electrode, sodium hydroxide is formed and hydrogen is

liberated. The hydrogen is cooled, purified, and compressed.

The sodium hydroxide formed, along with unreacted brine, is

evaporated to 50 percent concentration. During the partial

evaporation, most of the unreacted sodium chloride precipitates

and is removed by filtration for recycle to the process. The

sodium hydroxide solutions are further evaporated to yield solid

products.

(7) Hydrochloric acid. Hydrochloric acid may be manu-

factured by two major processes. The process considered

herein is direct reaction of chlorine with hydrogen. The other

major source of production is as a byproduct of organic chlori-

nation reactions.

In production by direct reaction, hydrogen and chlorine gas

are reacted in a vertical burner. The product, hydrogen chlo-

ride, is cooled and then absorbed in water. No waterborne

wastes are generated during normal operation. The start-up

wastes may be treated and reused.

(8) Hydrofluoric acid. Hydrofluoric acid is manufactured by

reacting the mineral fluorspar (CaF.) with concentrated sul-

furic acid in a furnace. The hydrofluoric acid leaves the

furnace as a gas, is cooled and absorbed in water prior to

purification. In the purification system, the crude acid is

redistilled and either absorbed in water or compressed for sale

as anhydrous hydrofluoric acid.

(9) Hydrogen peroxide. Hydrogen peroxide is manufactured

by three different processes; (1) an electrolytic process;

(2) oxidation of alkyl! hydroanthraquinones; and (3) as a by-

product in the manufacture of acetone from isopropyl alcohol.

The limitations presented herein apply only to the first two

processes.

In the electrolytic process, a solution of ammonium (or

other) bisulfate is electrolvzed, yielding ammonium persulfate

at the anode and hydrogen gas at the cathode. The persulfate

is then reacted with water to vield hydrogen peroxide and

the original bisulfate. In the oxidation process, alkylanthra-

quinone is reduced by hydrogen over a supported metal catalyst

(typically palladium on alumina), yielding the corresponding

alkylhydroanthraquinone. This, in turn, is oxidized by oxygen

in a forced gas stream to produce the original alkylanthra-

quinone plus hydrogen peroxide. The hydrogen peroxide

is extracted with water and the alkylanthraquinone is recycled.

(10) Nitric acid. Nitric acid is produced by catalytic oxida-

tion of ammonia to nitrogen dioxide which is reacted with

water vapor under pressure to obtain the acid. In the process,

compressed, purified, and preheated air and anhydrous am-

monia are mixed and passed over a platinum-rhodium wire

gauge catalyst. The resultant mixture of nitric oxide and

excess air is introduced into a stainless steel absorption tower

where the nitric oxide is oxidized. The resulting nitrogen

dioxide is then reacted with water. The only process wastes

from a well-designed plant are weak nitric acid solutions

which may be recycled.

(11) Potassium metal. Potassium is produced by the reaction

of potassium chloride with sodium vapors. No water is used

in this manufacturing process. The potassium chloride is

melted in a gas-fired melt pot and is fed to an exchange column.

The molten potassium chloride is contacted by ascending

sodium vapors, yielding sodium chloride and elemental potas-

sium. The sodium chloride is normally recovered and sold.

(12) Potassium dichromate. Most potassium dichromate

manufactured in the U.S. is made by reacting a sodium dicro-

mate dihydrate solution with potassium chloride. The potas-

sium dichromate is crystallized from solution resulting in a

relative pure product which requires only removal of water

prior to sizing and packaging. The process water may be

recycled back to the initial reaction tank.

(13) Potassium sulfate. Potassium sulfate is prepared by

treating dissolved langbenite ore (K:SO,e2MgSO,), a natu-

rally occurring potassium magnesium sulfate mineral, with

potassium chloride. The ore is crushed and dissolved in water

to which potassium chloride is added. Partial evaporation of

the solution results in selective precipitation of potassium sul-

fate. This is recovered by centrifugation or filtration, dried

and sold. The resulting brine liquor may be held in evaporation

ponds, reused as process water, or evaporated to dryness to

recover magnesium chloride.

(14) Sodium bicarbonate. Sodium bicarbonate is made by

reacting sodium carbonate with water and carbon dioxide

under pressure. The bicarbonate precipitates from solution

and is centrifuged or filtered, washed, dried, and packaged.

Treated process waste water may be recycled after concentra-

tion with respect to sodium carbonate.

(15) Sodium carbonate. Sodium carbonate (soda ash) is

produced by the Solvay process or by the mining of trona

(sodium sesquicarbonate ) in California and Wyoming.

The Solvay process involves a reaction of ammonia and

carbon dioxide in a brine solution to yield sodium bicarbonate.

This is converted to the carbonate by heating. Ammonia may

be recovered by adding slaked lime to the used liquor. Large

quantities of dissolved and suspended solids are generated by

this process. A typical effluent after sedimentation and neu-

tralization contains over 100,000 mg/! of dissolved materials

(mainly NaCl and CaCl).

The mining of trona currently accounts for approximately

forty percent of sodium carbonate production.

(16) Sodium chloride. Sodium chloride may be produced

by solution brine mining, by solar evaporation of sea water, or

by conventional mining of rock salt. The regulations presented

herein apply to the first two processes. Solar evaporation to

produce sodium chloride consists of holding sea water in large

ponds where the water is allowed to evaporate. After saturation

is reached, the brine is fed to a crystallizer where sodium

chloride is precipitated. The brine solution may be further

treated to recover potassium and magnesium salts. Solution-

mining of brines involves pumping water into an underground

salt deposit and recovering the brine solution for treatment.

The specific treatment is variable depending on the nature

of the impurities present. Typically, the brine may be first

aerated to remove hydrogen sulfide and, in many cases, small

amounts of chlorine are added to complete sulfide removal and

oxidize all iron salts present to the ferric state. The brine is

then pumped to settling tanks where it is treated with calcium

carbonate and sodium hydroxide to remove most of the calcium,

magnesium and iron present as insoluble salts. After clarifica-

tion to remove these insolubles, the brine is then sent to mul-

tiple effect evaporators. As water is removed, salt crystals form

and are removec as a slurry. After screening to remove lumps,

the slurry is then washed with fresh brine. The washed slurry

is filtered, the mother liquor is returned to the evaporators

and the salt crystals from the filter are dried, screened, and

packaged.

Waste water results from the multiple evaporators and

dryers and from the brine purification processes.

(17) Sodium dichromate and sodium sulfate. Sodium di-

chromate and sodium sulfate are prepared by calcining a

mix- [4865] ture of chrome ore, sodium carbonate, and lime,

followed by leaching the soluble chromates with water. Cal-

cium salts are precipitated by pH adjustment and then removed

along with iron oxide. The leachate containing the soluble

chromate is then acidified with sulfuric acid, forming sodium

dichromate and sodium sulfate. The dichromate solution is

partially evaporated and fed to a crystallizer where sodium

dichromate crystals are formed. The crystals are centrifuged

to remove excess water, then dried and packaged.

The sulfate is precipitated following the partial evaporation

process. The leachate is filtered and dried. The insoluble

residue remaining from the leaching operation may be re-

cycled to leach out additionai material.

(18) Sodium metal. The process used to manufacture

sodium metal, commonly called the Downs cell process, con-

sists of the electrolysis of fused sodium chloride at about 600° C.

The salt is mixed with alkali fluorides and calcium chloride

to sufficiently lower the melting point, and the charge is then

fused in a Downs cell. Molten sodium formed at the cathode

is transported to a collection vessel, from which the metal is

withdrawn from the bottom, filtered, and packaged in the

form of bricks of various sizes.

It is essentially a dry process. However, water-borne wastes

are generated during cleancst and washdown of cells when

the electrolyte is replenished, from scrubbing chlorine tail

gases and also from drying the chlorine with sulfuric acid.

(19) Sodium silicate. The production of sodium silicate

generally involves reacting soda ash or anhydrous sodium

hydroxide with silica. The product is then dissolved in water

under pressure to prepare sodium silicate solutions. The water-

borne wastes include unreacted silica, sodium hydroxide and

sodium silicate. The pollutants are the result of tank wash-

downs, product shock cooling with water and wet scrubbers.

These wastes may be ponded to settle the solids and the clear

liquid may be partially recycled and partially pond evaporated.

The waste solution may be further reacted with sodium hy-

droxide to manufacture metasilicates which may be isolated

by evaporation and sold.

(20) Sodium sulfite. Sodium sulfite is manufactured by

reacting sulfur dioxide with soda ash. The sulfur dioxide gas

is fed into a solution of sodium carbonate until the product is

acidic. The solute consists mainly of sodium bisulfate which

is converted into sodium sulfite by the further addition of

soda ash. The solution is boiled to evolve carbon dioxide.

The crude sulfite is filtered to remove insolubles, crystallized

and dried.

The wastes consist of sulfides from the purification steps,

and sulfites and sulfates which result from periodic wash-

downs. The sulfite may be oxidized to sulfate by aer*tion and

suspended solids removed by filtration.

(21) Sulfuric acid. Sulfuric acid is manufactured primarily

by the contact process which involves the burning of sulfur to

sulfur dioxide. The sulfur dioxide is catalytically oxidized to

sulfur trioxide which is reacted with water to yield sulfuric

acid. Within the contact process there are three basic types

of plants: (i) Double absorption plants use paired sulfur

trioxide absorption towers and catalyst beds in series to maxi-

mize conversion of sulfur dioxide so that tail gas scrubbers are

not required; (ii) single absorption plants use single towers

and catalyst beds and tail gases frequently have to be scrubbed

to remove sulfur oxides; and (iii) spent acid plants use spent

sulfuric acid in place of, or in addition to, sulfur as a raw

material.

The regulations presented herein apply only to the first two

plant types. In the double absorption contact process, sulfur

is burned to yield sulfur dioxide which is then passed through

a catalytic converter with air to produce sulfur trioxide. The

sulfur trioxide is then absorbed in 95-97 percent sulfuric acid.

The gases emerging from the absorber are then fed to a second

converter to oxidize the remaining sulfur dioxide to sulfur

trioxide, which is then absorbed in a second absorption tower.

The tail gases are vented to the atmosphere. They are suf-

ficiently depleted of sulfur oxides so that gas scrubbers are not

required. Prevention of leaks and spills can eliminate the

discharge of process waste water pollutants.

The single absorptien process differs from that previously

described only in the arrangement of the converters and ab-

sorbers. The rest of the process is the same. For the single

absorption process, the sulfur dioxide is passed through one

or more converters and then into one or more absorbers prior

to venting to the atmosphere. These tail gases usually need

to be scrubbed and the waste water treated.

(22) Titanium dioxide. Titanium dioxide may be manufac-

tured using either the chloride or sulfate process. In the sulfate

process, ground ilmenite ore (FeO TiO.) is digested with

concentrated sulfuric acid at high temperatures. The acid

used is normally about 150 percent of the weight of the ore.

In some cases, small amounts of antimony trioxide are also

added. The resulting sulfates of titanium and iron are then

leached from the reaction mass with water and any ferric salts

present are reduced to ferrous salts by treatment with iron

scrap to prevent coloration of the titanium dioxide.

After these operations, the solutions are clarified, cooled and

sent to a vacuum crystallizer. There, ferrous sulfate crystallizes

out and is separated from the mother liquor by centrifugation.

This material is either sold or disposed of as a waste.

The mother liquor is clarified by filtration after addition of

filter aids and further concentrated by vacuum evaporation.

Seed crystals or other nucleating agents are added and then

concentrated liquor is treated with steam to hydrolyze the

titanium sulfate present. This precipitates as acidic hydrated

titanium. The precipitate is collected by filtration, washed

several times and calcined at 900-950°C to yield titanium

dioxide. This calcined product is ground, and further processed

to yield a purer product.

In the manufacture of titanium dioxide by the chloride

process, ores containing titanium dioxide, iron, aluminum,

vanadium, plus other minor trace impurities, are dried to re-

move moisture, then fed up to a high temperature fluidized bed

chlorinator. Coke needed to promote chlorination is also dried

and fed to the reactor.

The gaseous reaction products contain titanium tetrachloride,

ferrous and ferric chlorides, carbon monoxide and dioxide,

hydrogen chloride (from the hydrogen in the coke and ore,

etc. ), entrained coke and ore, plus all other chlorinated impuri-

ties in the ore. These pass to a long cooling train which cools

the product stream so that all of the iron chlorides and most

of the remaining metal chlorides condense. Solids are separated

from the gaseous titanium tetrachlorides by centrifugation or

other mechanical means and slurred in water for discharge from

the process as raw waste.

The remaining gaseous titanium tetrachloride is then con-

densed. Noncondensable reaction gases, containing small

amounts of titanium tetrachloride, silicon tetrachloride and hy-

drogen chloride are water scrubbed, then vented.

Crude titanium tetrachloride is purified to remove traces of

silicon, vanadium, iron, magnesium, manganese, aluminum,

chromium, etc., by various techniques including distillation,

absorption, ion exchange, and chemical precipitation with

hydrogen sulfide, inorganic salts, or organic compounds. All

methods yield a pure titanium tetrachloride fraction, and a

contaminant sludge which is slurred in water and discharged

with the cooling tower waste.

The pure titanium tetrachloride is vaporized, superheated,

and added to the oxidation reactor with hot air or oxygen to

form a pure, finely divided, pigmentary titanium dioxide.

The oxidation reactor product stream, consisting primarily

of chlorine, nitrogen, and suspended titanium dioxide is cooled

and the titanium dioxide separated mechanically by means of

cyclones, bag filters, or precipitators for further processing.

Chlorine and nitrogen from the oxidation product stream are

fed to the chlorinator with makeup chlorine to produce more

titanium tetrachloride. The recovered pigment is calcined and

surface treated to impact desirable optical or physical proper-

ties. The titanium dioxide is ground to submicron sized par-

cles, and packed as finished product.

(iii) Control and treatment technology for the inorganic

chemicals manufacturing category.

Although waste effluents from inorganic chemical plants

widely differ in both chemical nature and raw waste loadings,

many pollution control techniques and treatment processes are

common throughout the industry. Good control and contain-

ment practices may significantly reduce the quantity of water

[4866] requiring treatment. These practices include monitoring

techniques, safety practices, in-process abatement measures,

spill and leak prevention, containment provisions, and segrega-

tion practices.

The purity of the raw materials used in many manufacturing

processes significantly influences the waste load. Economics

and availability, however, necessitate use of impure ores and

technical grade reactants. These impurities may he controlled

by washing, purifying, separating or beneficiating the raw ma-

terials prior to use in the manufacturing process. Treatment of

ores may be done at the mining site where beneficiating waste

may be controlled and handled with minimal pollutant effects.

Segregation of waste streams is an important waste control

technique. Large uncontaminated water streams should be

sepa’ ..ed from the process waste water to minimize the quan-

tity of water requiring treatment.

Spills and leaks can be minimized by employing good house-

keeping practices. Provisions for containment and isolation of

occasional leaks and spills may be implemented.

Many waterborne wastes result from product losses in

bottling, packing, or shipping areas. Good engineering and

housekeeping may be used to reduce losses to a minimum.

In many manufacturing processes wet scrubbers are used to

control air pollution. The scrubbing solution may generally be

treated and reused or sold. In some cases, conversion to a dry

abatement system is justified because of product recovery.

Unit operations and processes to treat process waste water

streams in the inorganic chemicals manufacturing category

include sedimentation, filtration, clarification, chemical treat-

ments, centrifugation, ion exchange, carbon adsorption, and

evaporation. The specific treatment technique and resulting

effluent quality depend on the waste load generated by each

manufacturing process.

Fourteen chemical manufacturing processes, including the

production of aluminum chloride, aluminum sulfate, calcium

carbide, hydrochloric acid, calcium oxide, potassium, potassium

sulphate, sodium bicarbouate, sodium chloride (by the solar

evaporation process), sodium silicate, and sulfuric acid, gen-

erate relatively small quantities of waste water. The process

waste streams generally may be treated and recycled, reused,

evaporated for product recovery, or sold.

The following chemical processes generate waste streams

which require treatment to reduce quantities of suspended

solids. They include calcium chloride production by solution

brine-mining, hydrogen peroxide production by the organic

process, sodium production, sodium chloride production by

solution-mining and sodium carbonate production by the Solvay

process. Treatment generally consists of various liquid-solid

separation operations including sedimentation and filtrations to

reduce effluent concentrations of suspended solids to 25 mg/I.

Neutralization of acidic or alkaline streams is required.

Recycle and reuse of various waste streams are possible. Addi-

tional treatment and in-process changes (replacement of haro-

metric condensers with noncontact heat exchangers, for exam-

ple) make chemical production feasible with no discharge of

process waste water pollutants for al! processes except soda ash

production. Additional treatment of soda ash waste will reduce

the suspended solids concentration to 15 mg/l.

The remaining manufacturing processes, hydrogen peroxide

production by the electrolytic process, sodium dichromate and

sodium sulfate production, chlor-alkali facilities using either the

diaphragm or mercury cell process and titanium dioxide pro-

duction by the chloride or sulfate process, require treatment

to reduce suspended solids concentrations. In addition, the

effluent contains dissolved metals which are present in poten-

tially harmful quantities. The presence of these pollutants, in-

cluding mercury, lead, chromium and other metals, necessitates

additional treatment specific for the potentially harmful pol-

lutant present. Cyanide solutions from the electrolytic process

to manufacture hydrogen peroxide may be passed through an

ion exchange system and oxidized to a cyanate solution.

Chloralkali plants using the mercury cell process may treat

mercury-containing streams with sodium sulfide. Lead dis-

charges from the diaphragm cell process may be eliminated by

use of stable metal anodes. Hexavalent chromium resulting

from the production of sodium dichromate may be reduced to

trivalent chromate and precipitated with lime or caustic.

Additional treatment based on available technologies and

various in-process modifications make it possible to produce the

above named chemicals, except titanium dioxide, with no

process waste water discharge. Although acid recovery and

reuse is being investigated in the titanium dioxide production

process, it has not been demonstrated in large scale operation.

Additional treatment will reduce the effluent suspended solids

concentration to 15 mg/I.

(iv) Cost estimates and economic impact for control of

waste water pollutants in the inorganic chemicals manufac-

turing category.

Treatment costs to achieve the effluent reductions attainable

by the application of the best practicable technology currently

available and by application of the best available technology

economically achievable are specific for each chemical manu-

facturing process. The annual cost to achieve the best prac-

ticable technology is less than $1/ton of product for fifteen

major chemical manufacturing processes. The costs are less

than $2/ton of product for five chemicals. Annual treatment

costs are $14 and $12/ton of product for hydrofluoric acid and

sodium dichromate. Because of the relatively high list price

for these chemicals, the treatment costs represent only 2.5 and

3.3 percent of the current list price.

The manufacture of titanium dioxide generates waste water

characterized by high pollutant concentrations. Currently only

minor treatment is being practiced. The implementation of

best practicable technology currently available results in an

annual cost of $82/ton of product for the sulfate process and

$37/ton of product for the chloride process. These figures are

14 and 6.4 percent of the current list price. Because substitute

products may be used only on a limited basis and demand cur-

rently exceeds the supply, these costs may be passed on as

price increases with minor economic impact.

The incremental annual costs to achieve the degree of reduc-

tion attainable by the application of best available technology

economically achievable average less than two percent of the

current list price for all products from these chemical manu-

facturing processes. On this basis, it is concluded that these

guidelines and standards will have no major economic impact

and that the guidelines and standards set forth in this regulation

are economically achievable.

(v) Nonwater quality aspects of pollution control in the

inorganic chemicals manufacturing category.

The large volumes of sludge generated by some treatment

processes create a substantial solid waste problem. Landfill

and lagoon sites of adequate size and good design are essential

for treatment processes. Best practicable control technology

and best available control technology as they are known today,

require disposal of the pollutants removed from waste waters

in this industry in the form of solid wastes and liquid concen-

trates. In most cases these are non-hazardous substances requir-

ing only minimal custodial care. However, some constituents

may be hazardous and may require special consideration. In

order to ensure long term protection of the environment from

these hazardous or harmful constituents, special consideration

of disposal sites must be made. All landfill sites where such

hazardous wastes are disposed should be selected so as to pre-

vent horizontal and vertical migration of these contaminants to

ground or surface waters. In cases where geologic conditions

may not reasonably ensure this, adequate legal and mechanical

precautions (e.g., impervious liners) should be taken to ensure

long term protection to the environment from hazardous mate-

rials. Where appropriate the location of solid hazardous ma-

terials disposal sites should be permanently recorded in the

appropriate office of legal jurisdiction. Ocean disposal and

deep-well injection may be practiced only under strictly regu-

lated conditions, consistent with the requirements of Federal

and State laws.

The inorganic chemicals manufacturing category has large

energy requirements for furnaces, kilns, calciners, distillations

columns, evaporators, and other common equipment. In con-

trast, application of the suggested treatment practices con-

sumes less than one percent of this amount.

No significant noise or air pollution problems are expected to

resu't because [4867] of the application of water pollution

control equipment.

The report entitled “Development Document for Proposed

Effluent Limitations Guidelines and News Source Performance

Standards for the major inorganic products Segment of the

Inorganic Chemicals Manufacturing Point Source Category”

details the analysis undertaken in support of the regulations

being proposed herein and is available for inspection in the

EPA Information Center, Room 227, West Tower, Waterside

Mall, Washington, D.C., at all EPA regional offices, and at State

water pollution control offices. A supplementary analysis pre-

pared for EPA of the possible economic effects of the proposed

regulations is also available for inspection at these locations.

Copies of both of these documents are being sent to persons or

institutions affected by the proposed regulations, or who have

placed themselves on a mailing list for this purpose (see EPA’s

Advance Notice of Public Review Procedures, 38 FR 21202,

August 6, 1973). An additional limited number of copies of

both reports are available. Persons wishing to obtain a copy

may write the EPA Information Center, Environmental Protec-

tion Agency, Washington, D.C. 20460, Attention: Mr. Philip B.

Wisman.

tion, the agencies and groups listed below were consulted and

given an opportunity to participate in the development of

effluent limitations guidelines and standards proposed for the

phosphate manufacturing category. All participating agencies

have been informed of project developments. An initial draft

of the Development Document were sent to all participants and

comments were solicited on that report. The following are the

principal agencies and groups consulted: (1) Effluent Stand-

ards and Water Quality Information Advisory Committee

(established under section 515 of the Act); (2) all State and

U.S. Territory Pollution Control Agencies; (3) the Manufac-

turing Chemists’ Association; (4) the Chlorine Institute; Puerto

Rico Land Administration; (5) American Society of Mechani-

cal Engineers; (6) American Society of Civil Engineers; (7)

Hudson River Sloop Restoration, Inc.; (8) National Resource

Defense Council; (9) Water Pollution Control Federation;

(10) the National Wildlife Federation; and (11) Michigan

Students Environmental Foundation.

The following organizations responded with comments:

Department of Defense; Department of Commerce; Common-

wealth of Kentucky; Department for Natural Resources and

Environmental Protection; Texas Water Quality Board; De-

partment of Natural Resources; State of Michigan Water

Resources Commission; Michigan Student Environmental Con-

federation, Inc.; Allied Chemical Corporation; the Chlorine

Institute, Inc.; American Cyanamid Company; E. I. duPont

De Nemours & Company; FMC Corporation; Manufacturing

Chemists’ Associations; and Monsanto Industrial Chemicals

Company.

The primary issues raised in the development of these pro-

posed effluent limitations guidelines and standards of per-

formance and the treatment of these issues herein are as

follows:

(1) The inorganic chemicals manufacturing category is very

large and diverse. In establishing effluent guidelines it was

necessary to consider numerous factors which may predicate

varying the guidelines to accommodate differences in plant size,

age, geographical location, manufacturing processes employed

and product mix. Comments from various industrial concerns

indicate that they feel these variables justify further segmenta-

tion of the industry. The key issue is the degree to which the

inorganic chemicals manufacturing category should be seg-

mented for the purpose of establishing effluent guidelines and

standards of performance. One extreme is to establish one

limitation for the entire industry. Examination of the dis-

similarities in manufacturing processes and wasteloads gener-

ated for each chemical reveal that this approach is technically

unsound. On the other extreme, each chemical plant is unique

and presents specific treatment problems. If the regulations

presented herein are to reflect every variation, it is necessary to

have separate guidelines for each plant. This approach does

not reflect the intent of the Act and is unworkable.

The approach selected was to examine all variables and

segment the industry into workable subcategories consistent

with these variations. Twenty-two subcategories have been

established based on the chemical product manufactured. In

cases where two dissimilar processes are used to manufacture

the same product, separate limitations have been established

within the subcategory.

While it is recognized that differences in plant age and size

will affect the treatment costs to a certain degree, the limita-

tions presented herein may be practicably achieved industry-

wide.

Some plants use dry air pollution abatement systems whereas

others employ wet scrubbers. Again, it is recognized that it is

more difficult for plants using wet scrubbers to achieve the

effluent limitations. However, this scrubbing solution may be

treated and subsequently recycled or sold. In some cases,

product recovery justifies conversion to a dry system.

Other variations, including quality of raw materials, product

mix, and geographical locations, are addressed in the Develop-

ment Document where alternative treatment schemes are pre-

sented to demonstrate industry-wide applicability.

(2) Some commentors criticized the methodology used in

preparing the effluent limitations and standards of performance.

The concept of basing standards on the exemplary plants was

questioned. This approach was detailed in the legislative his-

tory of the Act and serves as a logical basis for developing

guidelines based on best practicable technology currently avail-

able. In many cases in the inorganic chemical industry, only

one or two plants were considered exemplary based on waste

water treatment of effluents generated by the production of a

given chemical. Industry representatives interpret “average of

the best” to require the compilation of data from a wider seg-

ment of the industry. In many cases, however, only one or two

plants were demonstrating exemplary treatment practices.

Where this treatment was considered economically practicable

and applicable industry-wide, it was selected as the basis for

guidelines.

(3) Industry representatives and various government agen-

cies questioned the appropriateness of establishing a 1977

standard for fourteen chemicals requiring a zero discharge of

process waste water pollutants to navigable waters, when the

Act lists this as a national goal to be achieved by 1983.

Technology based standards as detailed in Section 301,

304(b) and 306 require the maximum pollutant reductions

prior to 1983 consistent with the economic and technological

factors considered under Sections 304(b) and 306. This does

not preclude the promulgation of a zero discharge standard for

1977.

All fourteen chemicals are currently being produced in ex-

emplary plants with a zero discharge of process waste water

pollutants. Zero discharge may be achieved for ten of the

fourteen chemicals at an annual incremental cost of less than

one percent of the list price. Three other chemicals may be

manufactured with a zero discharge by spending less than four

percent of the current list price. Sodium chloride production

by brine-mining requires an expenditure of eleven percent of

the list price. Because of the relatively low price, however,

this results in a price increase of only 0.1 cents/Ib of product

which will not significanily impact the economy.

(4) Commentors expressed concern about an initial proposal

to eliminate the discharge of process waste water pollutants

from the Solvay process used to manufacture soda ash. This

process generates extremely large quantities of pollutants, most

of which are currently discharged with little treatment. An

alternate process, mining trona, exists for producing soda ash.

This mining operation is relatively clean and produces soda

ash at an equitable price. (Shipping costs are offset by large

operating costs for the Solvay process plants.) Currently forty

percent of the soda ash manufactured in the United States

results from mining trona, and production figures indicate that

this percentage will continue to increase. There appears to be

an ample supply of this ore, sufficient to accommodate the soda

ash market for years to come.

It was concluded that no technology is available and eco-

nomically achievable for the elimination of discharges from

Solvay plants. Although the mining option exists, it was felt

that Congress did not intend to eliminate large scale operations.

The 1983, standard proposed herein requires implementation

of the best available treatment technology which is econom-

ically achievable for Sol- [4868] vay plants. New source Solvay

plants are required to achieve zero discharge of process waste

water pollutants, but this will have no impact on existing facili-

ties. It is recognized that this standard may well constitute a

prohibition of construction of new Solvay process plants unless

some radical new technology is developed. However, ample

supplies of soda ash may be obtained by mining trona. More-

over the newest Solvay process plant was constructed in 1933

and there are no known plans to build any new Solvay plants.

(5) Industry felt that the cost data for pollution control

equipment given in Section VIII of the Report is underesti-

mated.

The cost information was obtained directly from industry

during exemplary plant visits, from engineering firms and

equipment suppliers, and from literature. The information

obtained from the latter three sources was used to develop

general capital, operating and overall costs of each treatment

and control method. This data plus the specific information

verified by plant visits was used to generate the cost effective-

ness curves in Section VIII of the Development Document and

wherever else costs are mentioned.

(6) Dissolved solids are presented in significant quantities

in the effluent resulting from the manufacture of most inorganic

chemicals. Initially, guidelines were proposed limiting the

quantities of dissolved solids. Many comments detailed objec-

tions to limiting total dissolved solids. In any cases, dis-

charged sulfates and chlorides caused no deieterious effects in

receiving waters. The disposal methods for concentrated dis-

solved solids have large energy requirements. Considering the

non-water quality impact and cost-benefit relationship, it was

concluded that only harmful dissolved materials (mercury,

lead, etc.) could be practicably limited by technology based

standards.

(7) Various agencies expressed concern about the ultimate

disposal methods for harmful solid materials including mercury,

chromium, etc. As detailed in the Development Document,

care must be taken to prevent future dissolution of these mate-

rials and subsequent pollution of navigable waters by run-off

or ground water infiltration. These metals remain soluble and

may be carried into ground water un!ess extraordinary meas-

ures are taken to prevent leaching. Ocean dumping and deep-

well disposal are allowed only under strictly regulated condi-

tions in accordance with the requirements of applicable Federal

and State laws.

(8) Several comments question the economic feasibility of

achieving the proposed limitations for chlor-alkali plants. In-

dustry felt that a zero discharge of process waste water pol-

lutants is impossible to achieve, and that further segmentation

of the chlor-alkali industry based on size and product mix in

individual plants is required.

The effluent limitations based on best practicable technology

currently available are being achieved in three exemplary

plants. Treatment for both the mercury cell and diaphragm

cell chlor-alkali plant effluents consists of incinerating or land-

filling chlorinated organic wastes, filtering and settling cell

rebuilding wastes, ponding or returning brine purification muds

to the brine cavity and partial recycle of the weak brine solu-

tions. In the mercury cell process, curbing and collection of

leaks and spills, followed by treatment with sodium sulfide, are

required to reduce effluent mercury concentrations.

Although no plants are currently achieving no discharge of

process waste water pollutants, the required technology is avail-

able and demonstrated. Annual incremental costs to achieve

this level are less than one percent of the current list price.

Available technology which will effect a zero discharge of

pollutants consists of using the spent sulfuric acid solution for

neutralization of other plant waste streams, sale as weak acid,

sale to an acid regeneration plant for reprocessing or recycling

after concentration. The hypochlorite waste from the tail gas

scrubber may be treated and subsequently recycled, sold, or

used to manufacture HCl. All weak brine sviutions may be

recycled to the process after extraction elimination of impuri-

ties. In the diaphragm cell process, the use of dimensionally

stable anodes will eliminate the lead discharge.

(9) Many comments referred to cooling water, boiler blow-

down waste water problems, and water supply waste water

problems. These are to be dealt with later as a separate cate-

gory. Any cooling water that picks up process related pol-

lutants from leaks becomes process waste water. It is the

responsibility of the plant to monitor cooling water streams for

leaks, and to treat contaminated cooling water to the standards

established for process waste water discharges.

(10) It has been pointed out by commenters that the eco-

nomic impact analysis considered fully only 16 of the chemical

commodities subject to this regulation. Because the remaining

chemicals are largely interdependent with chemicals considered

fully in the analyses or because the projected cost increase was

a small percentage of the selling price, these chemicals did not

appear to require a rigorous economic impact analysis. How-

ever, because of this comment, EPA is undertaking a further

analysis of the economic impact of these regulations on the

production of calcium chloride, sodium bicarbonate, sodium

carbonate, sodium chloride, sodium metal, sodium silicate,

sodium sulfite, and potassium sulfate. EPA requests comments

and specific data on the possible economic impact of this pro-

posed regulation on these chemicals.

Interested persons may participate in this rulemaking by

submitting written comments in triplicate to the EPA Informa-

tion Center, Environmental Protection Agency, Washington,

D.C. 20460, Attention: Mr. Philip B. Wisman. Comments on all

aspects of the proposed regulations are solicited. In the event

comments are in the nature of criticisms as to the adequacy of

data which is available, or which may be relied upon by the

Agency, comments should identify and, if possible, provide

anv additional data which may be available and should indicate

why such data is essential to the development of the regula-

tions. In the event comments address the approach taken by

the agency in establishing an effluent limitation guideline or

standard of performance, EPA solicits suggestions as to what

alternative approach should be taken and why and how this

alternative better satisfies the detailed requirements of sec-

tions 301, 304(b), 306 and 307 of the Act.

A copy of all public comments will be available for inspection

and copving at the EPA Information Center, Room 227, West

Tower, Waterside Mall, 401 M Street, SW., Washington, D.C.

A copy of preliminary draft contractor reports, the Develop-

ment Document and economic study referred to above, and

certain supplementary materials supporting the study of the

industry concerned will also be maintained at this location for

public review and copying. The EPA information regulation,

40 CFR Part 2, provides that a reasonable fee may be charged

for copying.

All comments received within thirty days of publication of

this notice in the Fepenar. Recisten will be considered. Steps

previously taken by the Environmental Protection Agency to

facilitate public response within this time period are outlined

in the advance notice concerning public review procedures

published on August 6, 1973 (38 FR 21202).

Dated October 1, 1973.

Russevy E. Train,

Administrator.

PART 415—EFFLUENT LIMITATIONS GUIDELINES

FOR EXISTING SOURCES AND STANDARDS OF

PERFORMANCE AND PRETREATMENT STAND.-

ARDS FOR NEW SOURCES FOR THE INORGANIC

CHEMICALS MANUFACTURING POINT SOURCE