Process and sites diagram - US Environmental Protection Agency

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yp . • Faiaral Rag^star / Vd. 55. No. 15 / Ttmdav. Isnuary 23, 1990 / Rules and ReeuUtkKis 233- procesa wastewatK and remams a Bevill waste. b. Volume. TVfo ceasasenters urged EPA to reconsider its proposed determteatioa tbat prscess wastewater from coal gasification faila the high volume criterion. Tbey contended that the data cited by EPA te the September 25,1989 Federal Register were not accurate. Both commenten stated that process wastewatera are actually generated at a rate that far exceeds cme million metric tons per year. One commenter daimed that rather than being generated at a rate of 5984)30 metric tons per year, this waste is produced at a rate of approximately S.OOaoOO metric tons per year. Tbe commenter believed that this error was based on the A^^ncy's misunderstaner and projected dmnigh tbe end of the year. EPA bas carefully reviewed tbe comments and survey infonnatioa and agrees that (1) Tbe fodlity mischaraterised die pomt of generation when it initially completed tbe 19n National Sta-vey. wbicb EPA used te developing tbe propoaafc and (2) procaas wastewater froin OMI gasiflcatioa meets the high vobimc aritetion bacaaaa it ia clearly genantad hi i|aasitltlis abeve tba applicable critatiosi vabie of \XHUm mt/yr snma^ par fadUty actabliabsd by the Septsrabar 1 final rak. c. Hasard. A i iiiiimasHiB aupportad EPA's pnqmsMl detenniaattosi tbat OMI gasifieatiaa psucaaa nastessMtai meets the low hazard cht 3. Furnace Off-GeaSaBds From Elemental PhospMwaProdartina Onei dedason toi solids bom ( prodtKtioD fivB tfaa BeviU i a. Processing Criterion/Waste Definition. One rnasmaaler raiaed several iaaaea aboet tbe defiaffioa (rf this waste stream. Tbe onmmwtar supported EPA's propassd determination diat faraaca off-gaa soUda an "solids." even tei^ ana facility generates tba tvaate te tba form of a slurry. Tba commanter matkm tbet fumaoe off-gas solids from elmnental pbospborooB production ate generated eitiier as a solid waste stream or as a slurry and contends tbat tbe term "elemental phosphorus off-gas solids" was specifically defteed to indude, amoiig other things, "predpitator slurry." EPA's assertion that die commenter aggregated off-gas solids with scrubber blowdown is, tbe commenter claimed incorrect The commenter also daimed that further examteation shows that tbe material stream is more property dassified as "phossy water" and that one result of reclassification is that 1.5 million tons of furnace off-gas sohds should be reclassified as "phossy water." The commenter matetained that the regulatory status of "phossy water" for the September 1.1989 Fteal Rule was based upon data that understated the generation rate of this process stream by approximately one-halt Tbe commenter further mamtateed tbat all furnace offgas aolida waste streams need to be sinnlarly dassified to prevent this rulemaking from having mequitabie competitive effects between companies. EPA agreea that the waste stream te questioa sboold be defined uniformly acrosa all fadUties tbat generate it Becanae tbe waste stream is generated (and menaged) as a solid at the raaiority of facilities where it is generated EPA.'» position ia tbat the waste of teterest is a solid As a result at tbe two facilities at whicb the off-gas solids are collected te a bqaid tbe h^ volume and low hazard criteria have been applied to the sobds entrained witbte these liquid wastes, as detenained try the settled solids reported by the facilities in their reaponsaa to the National Sarvey. Tba liquid portions of tba wastes, as generated dearly fail die appUcabie high voiame criterion (average anniiai generatkm rate of more tban on* odllioa metric tone per year). It. Vahime. A comaamter stated that the waata stream encompassing fomaca off-gas sohds from elemental phosphorous production is generated as a liquid at one facility. The commenter concurred that the stream does not meet the high votooe criterion. Another caaaaaentar argued tbet because of tbe relattvety low volume of the furnace oflgas solids (4.686 mt/yr), the treatment of thaaa sobds as hazardoos waatea ts reasoaaUe SBKI practicable. Hoarwar. one commenter argued tbet the wdansa detarmination must ba made using data from all fadlitiea tbat generate fumaca off-gas soUda. ERA'S proposed datambiatian tbat tbe average rate of generation per facility ia 4.685 metric tons par year was. tbey rontendad Imaed on incomplete information bccaase data from facilities that sabmitted data as Confidential Bosteesa Information were not tecluded The commenter furdier contended that when all five facilities' furaace off-gas solids material streams are considered, the per plant facility average for the "furnace off-gas solids" is 44.012 metric tons per year, and that this average is well withm any statistical margin for error and thus, furnace off-gas solids should be deemed a "high volume" waste. As stated above, "furnace off-gaa solids" generated at two facilities that reported using wet collection systems . are defined as the solids removed from the scrabber waten. Ftmiace off-gas solids generated by three other facilities are te fact solids as generated. Revised (and final) waste generation deterannations have been prepared on this basis and are presented in Section m. below. These data show that fnrnau off-gas sobds is not a high volume waste. c. Hazard. Two conunenten addressed the hazard level of furnace off-gas solids from elemental phosphorus fnoduction. Onacommente! statMl tbat the aaalyticai intemation it provided te tbe 1989 National Ssrvey demonstrated tbat the wastaatream is not a hazardoos waste under the RCRA charaderistic of corrosivity. The other commenter contended thst samples of the slurry of furnace off-gas solids were found to contate cadmium te concentratioDS as great as 249 percent c the regulatory level of 100 times the MCL. Review of EPA's samphng data indicated tbat this waste passes the )ov^ hazard triterian. as discussed m Section mbebw. 4. Process Wastewater From Hydroflaaric Add Productioa a. Processing Criterion/Waste Defmitien. Two cvBuaentera described the byikofluoiic add prodection process. Tbe faydrofluoric add productioa prooaas extracts mteerel values by reaction ef mineral rock with sulfuric add creates a caldum sulfate co-product Saorogypsum. which is slnrrted to dispoaaL and circulates process waste«»atar through a pond system prior to reeae in tbe processing facility. One uoimuenter noted diat addttional procaaa wsatewater is generated by daaaing die hydroflooric acid gaa. One conenanter argued tfiat EPA's determiaatiaa to bat separately fluorogypaeto aad process wastewater fixim hydnAeortc acid production is impmiticaL The similarities tietween
2332 Federal Regiater / VoL 55, No. 15 / Tueaday. January 23, 1990 / Rules and Regulationa the two waste streams are such that at the Calvert City. Kentucky hydrofluoric add plant the two are oMningled at the potet of generation. The commenter claimed that the proposed regulation would impose different regulatory requirements on two similar wastes (because fluorogypsum would remate excluded but process wastewater would not), which from a practical perspective, is unreasonable stece the requirements applicable to one will affect the management of the other. EPA should allow process wastewater from hydrofluoric add production to rotate its status under the Bevill exdusion. and should not evaluate fluorogypsum and process wastewater separately, because the two streams are essentially identicaL EPA disagrees. The two waste streams are identifiably distted (one is a solid and the other a liqtud) and are generated by different parts of the production process. The fad tbat they are currenUy co-managed does not imply that they should or must be comanaged b. Volimie. Two commenten disagreed vn\h EPA's proposed determination that process wastewater from hydrofluoric add production failed to meet tbe high voliune criterion. One commenter questioned the basis for EPA's dedsioa given the lack of data. The commenter argued that tbe waste was not induded te the 1989 National Survey of Solid Wastes from Mteeral Processing Facilities. Therefore, te tbe September 25,1989 NPRM. tbe average rate of generation of process wastewater from hydrofluoric add was listed as "n/a". Yet EPA determined tbat this liquid wasta stieam was not generated te quantities over 1,000,000 metric tons per year through calculations or teterpretations of survey results, which were not provided te tbe background dociunents. The second commenter argued that EPA may have overiooked or misundentood tba Sarvey data, te fact they stated ptocase wastewater from bydrofhatlo add prtMluction is generated at tm avaraga rale per facility far te mtatm al 1 mUllon metric tons per year. The^pauuantar resubmitted its Survey, nftkb indudaa a process flow diagram ot tfaa Iwdrofluoric add process. Infonnatioa is auo provided on the volume of process* wastewster generated and managed te sections 5 and 6 of the Survey. One commenter supported EPA's application of tbe higb voiuma critarian to tbe reported process wastawatar inflows to surface unpotrndoMata. Tba commenter mamiamed that tba flow rate to surface ia.ûundmants can be used to estimate process wastewater flow rates. According to the commenter, data available through plant NPDES records, the conunenter daimed tedicate that the flow rate does exceed the 1.000.000 metiric tens per year Bevill criterion. Specifically, the most recent water balance, submitted as part of the NPDES renewal application, tedicated that the inflow to surface impoundments from the hydrofluoric add production process was 2,079,400 gaUons per day, which is equivalent to 2.900.000 metric tons per year, according to the commenter. The Agency has carefully reviewed these comments and the revised survey submitted by the commenter and agrees that process wastewater from hydrofluoric add production satisfies the higb volume criteriort as discussed below te section IIL c. Hazard. Two commenten addressed the hazard level of process wastewater from hydrofluoric add production. One commenter agreed with EPA's proposed determteation that tbe waste is low hazard Another commenter daimed however, that EPA's samphng data demonstrated that process wastewater bota hydrofluoriv. add pnxluction exhibits the hazardous waste charaderistic of corrosivity (pH values of 1.4 and 1.86), and questioned EPA's hilure to remove the waste from tba Bevill exdusion. The commenter also urged EPA to consider this data te preparing its Report to Congress. Ine Agency generally agrees %vith the commenter that all relevant hazard data should be considered te the study of the waste stream when preparing the Report to Congress. However. EPA finalized the low haiard criterion te the September 1, 1989 rule smd ia not currentiy entertaining commentii on it The Agency's rationale for tbe low hazard aitarion ia outlteed te 54 FR 36592. EPA's sampling data tedicate tbat this waste does not exhibit a pH of less than 1. and tberefcae, complies with the low hazard criterion. S. Process Wastewater From Primary Lead Processing a. PrtxaeMing Criterion/Waste Definitioa. One commenter daimed that EPA must study all process wastewaten from primary lead production, contandiag tbat onca EPA completes its stiidy. it will realize tbat these are not wastaa, because process wastewaten from primary lead production are reused witbte tbe primary lead production circuit RCRA hazardous waste requiramants, tberefore. are not approprtate. In response to this comment EPA notes that tba extant to wbicb this waste stream is managed through "dosed loop" recycling, and hence, is'not subject to RCRA requirements, would be addressed te the Report to Congress, if this material were foimd to meet the Bevill special waste criteria. The waste does not meet these criteria, however, and thus will not be teduded te the Report to Congress. Nevertheless, if die waste is managed te such a way that it does not meet the definition of a solid waste, then RCRA hazardous waste requirements would not apply. One commenter urged EPA to clarify its defiiution of process wastewater from primary lead production so that all waten that are collected from processing operations are specifically teduded te teat definition. The commenter states that the only reason for EPA's tedudlng contad cooling water te the definition of process wastewater and not tedudlng acid plant blowdown Is tee arbitrary elimteation of one relatively large volume process water stream from the volume amount te addition, defining this waste as "waten that are uniquely assodated wite processing operations that haws accumulated contamteants to the p^tet that they must be removed bom the mteeral production system" is confusing. Do the waten need to be removed from tee system, or do tee contaminants need to be removed from tee waten? EPA responds teat tee reasons for distinguishing between different aqueous waste streams generated m tee mteeral processing tedustry have been discussed at lengte te previous rulemaking notices (54 FR 15316, April 17,1989; and 54 FR 36592, September 1, 1989.) Briefly. EPA believes tee disttections it bas made are appropriate based on tea available infonnation concerning tee waste cbaraderistics and potets of generation te the process. As explateed te the preamble to tee September 1.1988 final rule, EPA has considered add plant blowdown and oteer wastewaten from primary lead processing to be two distted wastes because these wastes have substantially different characteristics. EPA believes teat tee definition of wastewater dearly tedicates tbat it is tee wastewater teat needs to be removed from tee system because it is tbe wastewater and not tee contaminants to wbicb the definition refen. b. Volume. One commenter stated teat tee volume EPA osad aa a basis for proposing to eliminate process wastowatar bom prtaiary lead productioa was UHM tban tee acteal amount generatad at tts plants. Tbe commenter argued tbat this tecorred determination was a result of artificial
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Process and sites diagram - US Environmental Protection Agency

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