1998 RCRA Section 3007 Survey of the Inorganic Chemicals Industry Instructions This RCRA Section 3007 questionnaire is being used to gather information about solid and hazardous waste management practices in the U.S. inorganic chemicals industry. The Environmental Protection Agency (EPA) requires this information to determine whether certain residual streams should be managed as hazardous under the Resource Conservation and Recovery Act (RCRA), 42 USC 6901 et seq., and should be listed as such in the Code of Federal Regulations. Under Section 3007 of RCRA, 42 USC 6927, you are required to provide us with this information. However, if you believe that some parts of the information supplied by you are commercially sensitive, you may claim protection for the data. Please note that this survey should be completed using available information or best engineering judgment and that you are not required to generate any new data. Responses may be typed or handwritten neatly. The signature/certification block should be completed by a senior official having authority over plant operations; it may not be completed by a consultant or any other third party. The questionnaire consists of 7 categories of questions: I. Corporate and Facility Information II. Process Information and Residual Identification III. Residual Generation and Management IV. Residual Characterization V. Management Units Characterization VI. General Facility Information VII. Certification Confidentiality: You may make a confidential business information (CBI) claim for each data element that is sensitive data. You may not withhold information from the Agency because you believe it is confidential. Information so designated will be disclosed by EPA only to the extent set forth in 40 CFR Part 2. If you fail to claim the information as confidential upon submission, it may be made available to the public without further notice to you. For each data point claimed to be CBI, complete the confidentiality claim in Appendix B. We must notify you if we intend to deny your claim, and you have the right to seek judicial review. Otherwise, we must protect the information from disclosure to anyone other than EPA and its authorized representatives, and we may not release it under the Freedom of Information Act. It may, however, be disclosed to Congress or the Comptroller General of the United States at their request, or be released by order of a Federal court. The complete regulations regarding confidential business information are given at 40 CFR Part 2 Subpart B. You may make a CBI claim with respect to all or any part of any information submitted in response to this request. Claims of confidentiality for information such as company name and address, site topography, and other information that is typically available through public sources are unlikely to be supportable. If a claim is made on such information, the Agency requires that you substantiate your claim; in that event, failure to substantiate your claim will result in a waiver of the claim. You are urged to review all potential confidentiality claims before presenting them to EPA and to make claims only on those portions of your response that you feel are business confidential. Return the completed survey within 60 days from date of receipt to: Anthony Carrell (5304W) Hazardous Waste Identification Division Office of Solid Waste, OSW (Note: Office of Solid Waste, OSW, was renamed Office of Resource Conservation and Recovery, ORCR, on January 18, 2009)U.S. Environmental Protection Agency 401 M St., S.W. Washington, D.C. 20460 Telephone: (703) 308-0458 For technical assistance, call (703) ???-????. If you wish to claim any portions of the survey as CBI, please send the completed survey to Regina Magbee (5304W) at the address above. I. Corporate and Facility Information The purpose of this question is to provide general information regarding the name, location, mailing address, and contacts for the facility. In addition, environmental permit numbers are requested to enable the Agency to obtain information otherwise submitted to EPA under different reporting requirements, rather than requiring the facility to report the same information twice. A. Parent Corporation B. Name of Company/Affiliate C. Other names by which the corporation may be known D. Address of Corporation Headquarters Street City State Zip E. Name of Facility F. Address of Facility Street City State Zip G. Mailing Address of Facility (if different from above) Street City State Zip H. Facility Location Latitude: deg min sec Longitude: deg min sec I. RCRA Hazardous Waste Generator ID Number: POTW/NPDES Permit Number: J. Name(s) of personnel to be contacted for additional information pertaining to this questionnaire Name Title Telephone II. Process Information and Residual Identification This question asks for more detailed information about the specific unit operations that are associated with the inorganic chemical processes. Characterization of these units will provide the Agency with basic information regarding the generation of residuals from the inorganic chemical processes. Please check off all of the pertinent boxes from the list of processes below. If your facility produces more than one product, the survey will have to be completed for each product and/or process. If your company does not produce any of these products, go to Section VIII and sign the certification. ___ sodium dichromate production ___ phosphoric acid production via the dry process ___ phosphorous trichloride production ___ phosphorous pentasulfide production ___ sodium chlorate production ___ antimony oxide production ___ cadmium pigment production ___ barium carbonate production ___ boric acid production ___ inorganic hydrogen cyanide production ___ titanium dioxide production (except for chloride process) ___ potassium dichromate production ___ phenyl mercuric acetate production ___ sodium phosphate production from wet process phosphoric acid Residuals generated from these units are referred to as the residuals of concern (RCs). Residuals may be solids, liquids, sludges, or confined gases. Residuals may be recycled within your process or reclaimed; such residuals must be identified regardless of their disposition. Also, residuals may be generated infrequently (e.g., only during unit turn-arounds). II.A. Process Descriptions and Flow Diagrams Provide a simplified process flow diagram (PFD) and a brief description for each of the checked processes above at your facility. It is not necessary to provide PFDs for your facility's other process units or for the facility's wastewater treatment facility. The process unit flow diagram should (1) illustrate the major process flows and (2) identify all residuals and their sources generated by the process. Some of the inorganic chemical processes require special information. These additional requirements are presented in the "Chemical-Specific Information" section below. For each process, use as much detail as is necessary to accomplish the applicable requirements. Appendix A provides example block flow diagrams, illustrating the types of information and level of detail that EPA is requiring. If your processes are similar to any of these examples, you have the option of editing the examples to reflect your operations rather than preparing new PFDs. The general information requirements of the PFDs are as follows. Provide a brief written description of the process including a discussion of major reaction and/or separation processes. The discussion should focus on the generation of the residuals, including residuals that may be subsequently recycled. All the residuals identified in the PFD should be mentioned in the process description. If applicable, describe any process used to collect/handle residual streams (e.g., off-gas scrubbers, filter press). Provide a block for each major unit operation in the production process (e.g., pre-treater, reactor, fractionator, crystallizer). Identify process inputs (i.e., feedstocks) by name and the process unit from which the input comes. With arrows, indicate the point at which each input is introduced into the process. Identify all products. For intermediate products, identify the typical downstream process units. Identify all residuals. Residuals may be solids, liquids, sludges, or confined gases. Residuals may be recycled within your process or reclaimed; such residuals must be identified regardless of their disposition. Also, residuals may be generated infrequently (e.g., only during unit turn-arounds). Some examples of residuals within the scope of this questionnaire are catalysts, waste liquor, leaching residual, still bottoms, scrubber wastewaters, and unsalable off-specification product generated during startup or unit upsets. Additionally, residuals can be generated during the treatment of other residuals (e.g., filter cake or ash from incineration). The following should NOT be identified as residual streams. Pump gland water Pipe rust and scale Boiler water lowdown Oily rags and gloves Sanitary wastes Sample bottles Storm water Pump casing sludge Cooling tower blowdown and sludge Assign each residual a unique Residual Identification Number (RIN). Use a line with an arrow to denote the point in the process from which the residual is generated, and identify the residual by its RIN. RINs should be unique. Sometimes two or more residual streams are combined prior to treatment or disposal. Each residual that is generated at a unique location should be assigned a unique RIN. For example, each wastewater stream should be assigned an individual RIN, even if the wastewater streams are combined for management. Process-Specific Information The following section describes the specific information requirements associated with each inorganic chemical process of concern. The purpose of this section is to focus your responses on the aspects of the processes that are of primary interest to the Agency. However, you should report all residuals generated from your process, as discussed above, even if they are not specifically addressed below. If residual generation quantities are not reported in Section III for residuals (e.g., scrubber waters, process liquors) which result in process losses, report the make-up quantities or rate as part of the process descriptions. All Processes: Assign a RIN to each of the air pollution control streams, including particulate matter collected from ESP or wet gas scrubbers. Identify all vented gases by name and disposition location but do not assign a RIN. Assign a RIN to all wastewaters produced as a result of day-to-day operations. These RINs should include process wastewaters and scrubber solutions. Also assign a RIN to wastewaters produced as a result of scheduled maintenance or cleaning. Please show any specialized waste treatment facility or process used for waste remediation, such as filtration. Assign a RIN to any waste streams that are created as a result of scheduled maintenance or cleaning operations. These wastes do not need to appear on the PFD, but should be described elsewhere in the survey including Table III.1. Assign a RIN to each of the wastewater streams. These should include all wastes from scrubbing operations and subsequent waste treatment. The PFD should include any specialized waste treatment equipment and operations. Wastewater Treatment Operations EPA is requiring a limited amount of information for wastewaters generated from inorganic production processes and managed in a centralized wastewater treatment system (i.e., managed with wastewaters from other processes). Specifically: A PFD for the wastewater treatment system is not required. Specify if discharge is to a surface water or to a POTW. If wastewaters are generated, provide wastewater throughput (on an annual and daily basis) for the wastewater treatment plant in the process description. Describe any land based units (e.g. surface impoundments) in the wastewater treatment system. This includes settling ponds, biological treatment ponds, polishing ponds, etc. Sodium dichromate production Solid waste produced from ore residues, cleaning operations, or other routine operation, should also be assigned a RIN. The purpose of this study is not to make a hazardous waste determination on wastes that are exempt from hazardous waste regulation pursuant to 40 CFR 261.4(b)(7). With respect to sodium dichromate production, it is not necessary to assign a RIN to "treated residue from roasting/leaching of chrome ore". However, include these wastes in the PFD. Phosphoric acid production via the dry process Assign a RIN to each of the solid waste streams produced from production of phosphoric acid. This will include remediation and filtering wastes from arsenic sulfide removal as well as any calcium phosphate containing sludges from filtration of scrubber waste. This will also include any sludges or residuals produced as a result of phosphoric acid storage. Assign RINs to all other solid waste streams that are produced on a regular or scheduled basis related to the Dry Process phosphoric acid production. These will include: filter aids, filter cartridges, filter cloths, and solid wastes produced as a result of scheduled maintenance. Wastewaters produced as a result of arsenic filtration or other waste removal system should be assigned a RIN. Any specialized treatment facility should be included in the process unit flow diagram. This listing should not include small leak or spill wastes. Phosphorous pentasulfide production Assign a RIN to the wastewater streams including waste generated from the waterseal surrounding the vacuum still and wastewater from scrubbing operations. Please include any other waste streams that are generated during scheduled maintenance of the operations. Assign a RIN to each of the solid waste streams created during phosphorous pentasulfide production. These should include phosphorous mud residues created from clean out of the water seals as well as still pot residues that contain arsenic pentasulfide. Sodium chlorate production Assign a RIN to each of the liquid waste streams from the production of sodium chlorate. Include wastes from chromium removal process as well as scrubber waste waters. Please include any specialized process equipment in the PFD. Antimony oxide production Assign a RIN to each of the solid waste streams including reactor slags and scrubber lowdown sludge (from the direct method) or furnace slag (from the indirect method). Assign a RIN to each of the liquid waste streams including any liquid streams produced during production. Cadmium pigment production Assign a RIN to each of the solid wastes produced during pigment production. These will include filtration devices, filter solids, spent filter cartridges, filter aids, black ash filter media, and wastewater treatment sludges. Please show any specialized waste treatment facility or process used for waste remediation. Barium carbonate production Assign a RIN to each of the liquid waste streams produced from Barium Carbonate production. These should include all process waste waters. Assign a RIN to each of the solid waste streams including unused ore residues and process treatment sludges. Please include any specialized waste treatment systems and wastes on the PFD. Boric acid production Assign a RIN to each of the wastewaters, if any, created during the production of boric acid. These should include waste liquors centrifuges and dissolvers. Please show any special process equipment designed to treat waste liquors or other liquid waste streams. Assign a RIN to each of the solid waste streams, if any, created during boric acid production. These should include filtration wastes, if any, and arsenic sulfide wastes, if any. Inorganic hydrogen cyanide production Assign a RIN to all process wastewater and liquid waste streams. These should include ammonia-acid streams, if present, and all wastewater streams. Please show any specialized equipment used to handle or treat the ammonia-acid mixture, if present, or wastewater streams. Assign a RIN to any solid waste streams generated during production of hydrogen cyanide, if any. Titanium dioxide production Assign a RIN to each of the wastewaters produced during titanium dioxide production. These should include all wastewater streams regardless of origin. These wastewater streams shall include both strong and weak acid wastes as well as scrubber waters. Please show any specialized equipment used in the remediation of the waste streams in the PFD. Assign a RIN to each of the solid/sludge wastes generated in the titanium dioxide process. These should include metal/ore digestion sludges as well as any other sludge/solid waste streams. Please include any waste streams that are subsequently sold as by-product as part of the waste analysis. Potassium dichromate production Assign a RIN to all process wastewater and liquid waste streams. These should include mother liquors, if present, and all wastewater streams. Assign a RIN to any solid waste streams generated during production of potassium dichromate, if any. These should include solid filter aid waste and sodium chloride salts from mother liquors. Sodium phosphate production from wet process phosphoric acid Assign a RIN to each of the solid/sludge wastes generated in the production of sodium phosphate from wet process phosphoric acid. These should include filter cake wastes, arsenic sulfide as well as any other sludge/solid waste streams. Phenyl mercuric acetate production Assign a RIN to each of the solid/sludge wastes generated in the production of phenyl mercuric acetate. III. Residual Characterization The purpose of this question is to develop detailed information regarding the residuals identified in question II.A. This information will be central to the Agency's understanding of the characteristics of the RCs, the appropriate scope of the definitions of the RCs, hazard assessments, and, if necessary, land disposal restrictions (LDR) program analyses and regulatory impact analyses. Copy the blank Table III.1 and complete it for every residual identified in Question II.A. 1. Identify each residual using the Residual Identification Number (RIN) assigned in Section II.A. 2. Indicate the residuals common name within your facility. 3. Classify each residual using the codes presented below. 01 Solid catalyst 02 Liquid catalyst 03 Neutralization sludge 04 Process sludge 05 Spent filters or sorbents 06 Spent caustics, acids or treating solutions 07 Process wastewaters 08 Air pollution control scrubber solids 09 Other residuals, specify 4. If the residual has been identified as a hazardous waste in the facility's RCRA notification, indicate all applicable waste codes. If the residual is characteristically hazardous, please indicate the Dxxx code(s) that the waste exhibits. If the residual is not regulated as hazardous but is managed as hazardous in a hazardous waste management unit(s), please code as "AS". If using the "AS" code, indicate by footnote why this management practice is followed. 5. For each residual, provide the following typical physical characteristics (if applicable). Provide supporting documentation (e.g., lab results) if available. Otherwise these properties should be estimated. pH Reactive Cyanide and Sulfide Specific Gravity Vapor Pressure Viscosity Total Suspended Solids in WW Phase Distribution Particle Size Distribution Naturally Occurring Radioactive material (NORM) 6. List elements or compounds that are known by analysis to be present in the residual and specify the concentration of each using weight %, ppm, or mg/L. If you need more space for your response, please continue on a separate sheet of paper. Please submit any available analytical data characterizing the residuals; submit both leachate data (e.g., Toxicity Characteristic Leaching Procedure (TCLP), Synthetic Precipitation Leaching Procedure (SPLP)) and total compositional data where possible. Describe by footnote any difficulties encountered in obtaining these analytical data (e.g., difficulties encountered at the laboratory in analyzing for a particular constituent due to the waste matrix). Table III.1. Residual Characterization 1. RIN 2. Common Name CBI?* ______________________________ _______________ 3. Residual Code 4. RCRA Code: _____________________________ _______________ 4. Properties Particle Size Phase Distribution of Residual Distribution & Other Properties pH > 60 mm % Aqueous Liquid % Reactive CN ppm 1-60 mm % Organic Liquid % Reactive S ppm 100 m-1 mm % Solid % Vapor mm Hg 10 m-100 m % Other % Pressure (specify) Viscosity cP < 10 m % TSS in WW Specific Gravity NORM 5. Residual Characterization Element or Total TCLP Other Compounds Concentration Concentration Leaching (mg/kg) (mg/L) Procedure Concentration (mg/L), Specify *If CBI is claimed, complete Appendix B. IV. Residual Generation and Management The purpose of this question is to develop detailed information regarding the residuals identified in the previous question, particularly with respect to how these residuals are managed. This information will be central to the Agency's understanding of the industry wide residual management practices for the RCs, the appropriate scope of the definitions of the RCs, hazard assessments, land disposal restrictions (LDR) program analyses (if necessary), and regulatory impact analysis. Copy the blank Table IV.1, and complete it for every residual identified in Question II. The following numbered items describe the information requirements for the corresponding columns in Table IV.1. 1. Specify the Residual Identification Number (RIN). 2. Indicate the quantity (wet basis, as generated and prior to treatment, metric tons) of residual generated during the calendar year 1997. If a residual was managed by more than one method, complete Table III.I for this RIN to account for the total residual quantity to the different management methods. Each residual quantity should correspond to the management method (or sequence of management methods) listed in column 5. Indicate if the response to questions 2 or 3 are CBI. 3. Indicate frequency of residual generation using one of the following codes: A Continuous D Every 2 to 6 months B Every 1 to 7 days E Every 6 to 18 months (e.g., weekly) (e.g., annually) C Every 8 to 30 days F Other, specify (e.g., monthly) If the residual is generated less frequently than every 18 months, indicate in column 3 the typical number of years between residual generation events. 4. Indicate the management step. If a series of management steps are used, designate the first step by "1", the second step by "2," etc., and the final step by "F". Note that the last row should always be designated as "F." If only one management step is used, place an "F" in this column. 5. Specify the residual management method applied to the RIN using one of the codes provided below. Note that the management codes are broken into five categories: storage, treatment, recycle, transfer, and disposal. If a residual is subject to a sequence of methods (e.g., storage in a tank, onsite incineration), list the method codes on separate rows. If a residual is handled alternatively by more than one method, list each method or sequence of methods on a separate page. For parallel management methods, allocate the residual quantity reported in column 2 to the different management trains. Residual Storage Methods Storage includes any method used to temporarily hold the residual onsite prior to further management. 01-A Storage in a tank 01-B Storage in container (e.g., drum) 01-C Storage in pile with runon/runoff containment 01-D Storage in pile without runon/runoff containment 01-E Storage in surface impoundment 01-F Storage in roll-on/roll-off bin 01-G Other storage, specify Residual Treatment Methods For the purposes of this questionnaire, treatment includes any measure designed to change the character or composition of the residual to make it amenable to disposal or recovery or to reduce its toxicity, hazard, or volume. 02-A Onsite hazardous waste incineration 02-B Onsite non-hazardous waste incineration 02-C Onsite flare 02-D Onsite boiler 02-E Onsite industrial furnace 02-F Other onsite thermal treatment, specify 03-A Offsite hazardous waste incineration 03-B Offsite non-hazardous waste incineration 03-C Other offsite thermal treatment, specify 04-A Sludge thickening 04-B Sludge de-watering (centrifuge, filter press) 04-C Settling 04-D Filtration 04-E Emulsion break 04-F Thermal emulsion break 04-G Other phase separation, specify 04-H Evaporation 05-A Steam stripping 05-B Washing with solvent 05-C Washing with water 05-D Other cleaning/extraction, specify 06-A Onsite nonhazardous waste land treatment 06-B Offsite nonhazardous waste land treatment 06-C Onsite hazardous waste land treatment 06-D Offsite hazardous waste land treatment 07-A Onsite stabilization 07-B Offsite stabilization 08-A Neutralization 08-B Biotreatment 08-C Physical/Chemical treatment 09 Other treatment, specify Residual Recycle Methods Recycling/reclamation/reuse measures designed to recover useful constituents or energy, or to beneficially reuse the residual. 10-A Recovery as pH buffer at wastewater treatment plant 10-B Other recovery onsite, specify 10-C Other recycling/reclamation/reuse, specify type and onsite or offsite Residual Transfer Methods Residual transfer includes the transfer of residuals to offsite entities for recycling/reclamation/reuse. 11-A Transfer of acid or caustic for reclamation, regeneration or recovery 11-B Transfer for use as an ingredient in products that are placed on the land (e.g., fertilizer) 11-C Transfer to other offsite entity (specify type of recycling/reclamation/reuse) Residual Disposal Methods Disposal is the permanent disposition of the residual. 12-A Discharge to onsite wastewater treatment facility (with land based units) 12-B Discharge to onsite wastewater treatment facility (tank based system) 12-C Disposal offsite municipal Subtitle D landfill 12-D Disposal offsite industrial Subtitle D landfill 12-E Disposal offsite Subtitle C landfill 12-F Disposal offsite underground injection (specify class) 12-G Other discharge or disposal offsite, specify 13-A Disposal onsite Subtitle D landfill 13-B Disposal onsite Subtitle C landfill 13-C Disposal onsite underground injection (specify class) 13-D Disposal onsite hazardous waste surface impoundment 13-E Disposal onsite nonhazardous waste surface impoundment 13-F Other disposal onsite, specify 6. Assign a unique residual management unit number (RMUN) to each residual management unit involved in the residual management process described in column 5. Each management code in column 5 should have a corresponding RMUN in column 6. For example, if a residual is disposed of in an onsite, nonhazardous waste landfill (code 14-A in column 5), a unique RMUN should be assigned to the onsite landfill in column 6. This RMUN will be used to reference the onsite landfill throughout the rest of the questionnaire. If more than one residual is disposed of in this landfill, use the same RMUN for each residual. If another residual is disposed of in a different landfill, the different landfill should be assigned its own unique RMUN. 7. Indicate Yes/No and describe by footnote any planned changes in generation or management of this RIN. Table IV.1. Residual Generation Rate and Management 1. RIN _______ 2. Quantity Generated ____________ (MT) (CBI?) Year of Generation (if not 1997) _________ 3. Frequency of Generation ______________ 4. Management 5. Management 6. RMUN 7. Planned CBI?* Step Code Changes ------------------------------------------------------------ 1. RIN _______ 2. Quantity Generated ____________ (MT) (CBI?) Year of Generation (if not 1997) _________ 3. Frequency of Generation ______________ 4. Management 5. Management 6. RMUN 7. Planned CBI?* Step Code Changes ------------------------------------------------------------ 1. RIN _______ 2. Quantity Generated ____________ (MT) (CBI?) Year of Generation (if not 1997) _________ 3. Frequency of Generation ______________ 4. Management 5. Management 6. RMUN 7. Planned CBI?* Step Code Changes *If CBI is claimed, complete Appendix B. IV.B. Offsite Management Facilities Copy the blank Table IV.2 and complete it for all the offsite residual management facilities that manage residuals identified in Table IV.1. Table IV.2. Offsite Residual Management Facilities Residual Management Unit Number (RMUN): Name of Facility: Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): City/State/Zip Code: Distance from Facility: CBI? ------------------------------------------------------------ Residual Management Unit Number (RMUN): Name of Facility: Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): City/State/Zip Code: Distance from Facility: CBI? ------------------------------------------------------------ Residual Management Unit Number (RMUN): Name of Facility: Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): City/State/Zip Code: Distance from Facility: CBI? Residual Management Unit Number (RMUN): Name of Facility: Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): City/State/Zip Code: Distance from Facility: CBI? ------------------------------------------------------------ Residual Management Unit Number (RMUN): Name of Facility: Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): City/State/Zip Code: Distance from Facility: CBI? *If CBI is claimed, complete Appendix B. IV.C. Residual/Residual Management Unit Cross Reference Table This section is required for the storage, treatment, and disposal units identified in Table IV.1 (i.e., all RMUNs). Complete Table IV.3 for all active onsite and offsite residual management units. The following numbered items describe the information requirements for the corresponding columns in the table. Each residual management unit should have been assigned a UNIQUE number in Table IV.1. 1. Indicate the residual management unit number assigned in Table IV.1. 2. For offsite units, state "OFF." For onsite units, state "ON." 3. Indicate the unit type using the following codes to describe each unit: Land-Based Residual Management Unit Codes: L-1 Land treatment L-2 Surface impoundment L-3 Landfill L-4 Deep well injection L-5 Pile L-6 Other (specify) Other Residual Management Unit Codes: 1 Tank (including concrete-lined basins) 2 Container 3 Boiler 4 Incineration 5 Other (specify) 4. Indicate the common name used by your facility for this unit. 5. Indicate the RINs of all the primary and secondary residuals managed at each unit during 1997. Table IV.3. Onsite and Offsite Residual Management Unit Identification 1.RMUN 2.Location 3.Unit 4.Unit Common 5.RINs CBI?* Type Name Managed in Unit ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. IV.D. Chemical Production and Residual Management Costs Please provide product yields for 1997 by completing Table IV.4 below. Complete Table IV.4 for each of the chemicals of concern and the amount generated in 1997. 1. Indicate the types of products generated. 2. Indicate the total production for each residual for 1997 (MT/yr). Table IV.4. Total Production 1. Product 2. 1997 Total Production (MT/yr) CBI?* ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ This section asks for the total annual management costs for each residual generated, any transportation costs, and payment received. 1. Give the Residual Identification Number (RIN) for each residual generated. 2. Provide the transportation cost (if any) to offsite storage facilities. ($/MT) 3. Provide the total management cost. ($/MT) 4. Indicate whether payment was received. ($/MT) Table IV.5. Residual Management Cost Table 1.RIN 2.Transportation 3.Management 4.Payment CBI?* Cost ($/MT) Cost ($/MT) Received ($/MT) ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. V. Residual Management Unit Characterization The purpose of this question is to collect more detailed information characterizing the residual management units identified in Question IV. This question should not be completed for offsite facilities that are not owned wholly or in part by either the facility or its parent company (i.e., facilities that are not captive offsite facilities). V.A. General Information 1. Specify the residual management unit number noted in column 1 of Table IV.3. 2. Specify the month and year that the unit was opened. 3. Specify the month and year that the unit is expected to be closed. 4. Estimate the lifetime of the unit (active life). 5. Indicate the RCRA permit status of the unit using one of the following codes. N None IS Interim status (40 CFR Part 265) B Part B (40 CFR Part 264) S Solid Waste Management Unit (SWMU) (as defined by 40 CFR Part 264.90) Table V.1. Residual Management Unit Characterization 1.Residual 2.Date 3.Expected 4.Active 5.RCRA CBI?* Management Opened Closure Date life Permit Unit Number (month/ (month/year) (years) Status year) (N, IS, B, S) ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. V.B. Land-Based Units (other than land treatment): Unit Size and Covers Complete Tables V.2 for all onsite and captive offsite land-based management units (except land treatment units) listed in Table IV.3. The following numbered items describe the information requirements for the corresponding columns in the table. 1. Indicate the residual management unit number (as noted in Table IV.3, column 1). 2. Indicate the surface area of the unit (acres). 3. Indicate the average height of the unit above grade (ft) and the average depth of the unit below grade (ft). For example, if your landfill's finished elevation (excluding final cover) is 5 feet above grade and it extends 10 feet below grade, report "5/10" in this column. 4. Indicate the total capacity of the unit (cubic yards). 5. Indicate the remaining capacity of the unit as of January 1997 (cubic yards). 6. Indicate the percent of the remaining capacity that was used in 1997. 7. Specify the frequency in which a cover is applied (daily, weekly, biweekly, monthly, other). 8. Are there dust suppression methods in place? If yes, specify the type in a footnote. Table V.2. Land-based Units (other than land treatment): Unit Size 1.RMUN 2.Surface 3.Height (ft) 4.Total 5.Remaining Area above below Design capacity as (Acres) grade grade Capacity of 1/97 (cu. (cu. yd.) yd.) 6. % Remaining 7.Frequency 8. Dust CBI?* capacity used in Which Suppression? in 1997 Cover is Applied *If CBI is claimed, complete Appendix B. V.C. Land-based Units: Landfills Complete Tables V.3 for all onsite and captive offsite landfill units listed in Table IV.3. The following numbered items describe the information requirements for the corresponding columns in the table. 1. Specify the residual management unit number noted in Col. 1 of Table IV.3. 2. Specify the total area of the landfill (acres). 3. Specify the number of cells the landfill is divided into. 4. Specify the average area of the landfill active at any time (acres). 5. Specify the thickness of the waste distributed over the cell (ft.). 6. Specify the percentage of the area of the total landfill that contains the waste. Table V.3. Land-based Units: Landfills 1.RMUN 2.Total 3.# of 4.Active 5.Thickness 6.% of CBI?* Area Cells Area of Waste Total (acres) (acres) Distributed Landfill Over Cell that (ft.) Contains the Waste ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. V.D. Land-Based Units: Design and Construction 1. Indicate the residual management unit number (as noted in Table IV.3, column 1). 2. Using the codes below, characterize each layer of the unit's liner in sequence from the uppermost layer to the bottom of the unit. Use a separate line for each layer. 1 Re-compacted clay liner 2 Synthetic liner 3 Natural clay liner 4 Leachate collection layer 5 No liner 6 Other liners (specify) 3. Indicate the thickness of the layer. 4. Indicate the units (inches or millimeters) associated with the thickness measurement in column 3. Table V.4. Land-based Units: Liner Construction 1.RMUN 2.Liner Construc- 3.Layer 4.Thickness CBI?* tion Code Thickness Units (inches or mm) ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. V.E. Land Treatment Units 1. Indicate the residual management unit number (as noted in Table IV.3, column 1). 2. Indicate the surface area of the unit (acres). 3. Indicate the typical surface area in which a residual is applied (acres). 4. If the residual is incorporated into the soil, indicate the method used. If the residual is not incorporated into the soil, indicate code 5 in the table. 1 Disking 2 Other surface application (specify type) 3 Subsurface injection 4 Other (specify) 5 Residual NOT incorporated 5. Indicate the depth of incorporation (inches). 6. Specify the frequency of application (daily, weekly, biweekly, monthly, other). 7. Indicate the total annual residual application for 1997 (MT). Table V.6. Land Treatment Units 1.RMUN 2.Surface 3.Surface 4.Method 5.Depth of Area area residual of Soil Incorporation (acres) is applied Incorpor- (inches) (acres) ation 6.Frequency of 7. 1997 Total CBI?* Application Residual Applied (MT) *If CBI is claimed, complete Appendix B. Table V.5. Land-based Units: Leachate and Run-on/Run-off Control 1. RMUN 2. Annual Leachate 3. Contact with 4. Runoff Volume (MT) Storm Water Under Possible? Storm Water (Yes/No) Permit? (Yes/No) 5. Flood 6.Distance 7.Run-on/Run-off 8.Run-on/Run-off Plain Type to Nearest Storm Severity Control System Downgradient Type Water Body (ft) 9. Run-off 10. Description CBI?* Destination Attached Code (Yes/No) *If CBI is claimed, complete Appendix B.V.F. Leachate and Run-on/Run-off Control for all Land-Based Units 1. Indicate the residual management unit number (as noted in Table IV.3, column 1). 2. If known, specify the annual leachate volume (MT). 3. Is there potential for storm water contact with this unit(s), its contents, or spillages and leaks associated with it? (Yes/No) 4. Will stormwater runoff from the residual management unit(s) in column 1 be managed under a storm water permit? (Yes/No) 5. Indicate the severity of the storm event that the unit's run-on/runoff control system is designed to protect against. 10 year 50 year 500 year 25 year 100 year 6. Indicate if the unit(s) is located in a flood plain. (Yes/No) If yes, indicate the type of flood plain (e.g., 25, 50, 100 year). 7. Indicate the distance from this unit(s) to the nearest downgradient water body (feet). 8. Indicate the type of the run-on/runoff control system in place (indicate all that apply). 1 Berms to prevent water running onto the unit 2 Berms to prevent water running off the unit 3 Berms to prevent flood water from reaching the unit 4 Dikes to prevent water from running onto the unit 5 Dikes to prevent water from running off the unit 6 Dikes to prevent flood water from reaching the unit 7 Diversion ditches to prevent water running onto the unit 8 Diversion ditches to prevent water running off the unit 9 Diversion ditches to prevent flood water from reaching the unit 10 Other (specify) 9. Indicate where the runoff is sent. 1 Onsite wastewater treatment 2 Offsite wastewater treatment 3 Discharged without treatment 4 Other (specify) 10. Provide a brief description of the run-on/runoff control system, including dimensions of barriers (e.g., height, top width, bottom width, run/rise) and materials of construction. Indicate in column 4 whether you have provided this information. (Y/N) V.G. Tanks Complete Table V.7 for all onsite and captive offsite permanent tanks noted in Table IV.3. This section is not required for mobile tanks, such as those brought onsite by contractors providing turnaround services. The following numbered items describe the information requirements for the corresponding columns in the table. 1. Indicate the residual management unit number (as noted in Table IV.3, column 1). 2. Indicate the tank volume (gallons). 3. Indicate the tank area (ft2). 4. Is secondary containment provided? (Yes/No) 5. Does the tank have a roof? (Yes/No) Table V.7. Tank Information 1. RMUN 2. Tank 3. Tank 4. Secondary 5. Covered? CBI?* Volume Area Containment? (Yes/No) (gal) (ft2) (Yes/No) ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. V.H. Surface Impoundments Complete Table V.8. for all onsite and captive offsite units listed in Table IV.C, section 3, that are surface impoundments. The following numbered items correspond to the columns in Table V.8. 1. Indicate the residual management unit number. 2. What is the total wastewater flow through the surface impoundment? 3. What is the residual wastewater flow? 4. What is the total surface impoundment area? 5. Is the surface impoundment aerated? 6. Specify the type of liner (e.g., clay, synthetic). 7. Does liner have leak detection system? (Yes/No) 8. Are there plans to close, retrofit, or switch to tanks? (Y/N) If yes, provide detail in footnote and estimate the quantity of material that would be removed. Table V.8. Surface Impoundments 1.RMUN 2. Total 3. Residual 4. Total 5. Aerated? WW Flow WW Flow S.I. through Area S.I. (m2) 6.Liner 7. Leak 8. Closure CBI?* Type Detection plans? System (Y/N) *If CBI is claimed, complete Appendix B. V.I. Deep Well Injection Complete Table V.9. for all onsite and captive offsite deep well injection residual management units previously identified in Table IV.C, section 3. 1. Indicate the residual management unit number. 2. Indicate the injection rate (gal/yr) for the residual and total rate for the well. 3. Indicate the distance from grade to the top of the injection zone (ft). 4. Indicate the regulatory status of the well using the following codes: 1 Class I nonhazardous waste 2 Class I hazardous waste 3 Class I hazardous waste with approved "no migration" petition 4 Other (specify) 5. Attach a construction design of the well showing the date of completion and information on the hydrogeological characteristics of each formation penetrated by the well (e.g., hydraulic conductivity, effective porosity, thickness, fluid elevation, aquifers and pressure). Indicate in column 5 whether you have provided this information (Y/N). Table V.9. Injection Well Characteristics 1. RMUN 2. Injection 3. Depth from 4. Regulatory Rate (gal/yr) grade to top status code of injection zone (ft) 5. Additional CBI?* information attached? (Yes/No) *If CBI is claimed, complete Appendix B. V.J. Containers Containers are any enclosed storage device that is not a tank (see 40 CFR 260.10), landfill, or surface impoundment. Have identified residuals been stored or treated onsite in containers at any time since January 1, 1997? Yes/No (Circle one). If yes, complete Table V.10 for each RIN stored or treated in containers. If the facility has several onsite and captive offsite container storage areas, provide information only on the primary container storage area for each RIN. The following numbered items describe the information requirements for the corresponding columns in the table. 1. Residual Management Unit Number (RMUN). 2. Indicate the type of container (e.g., 55-gal. drum, 30 cu.yd. roll-off bin) and size. 3. Is the container closed (Yes/No)? Table V.10. Containers 1. RMUN 2. Container type and size 3. Closed? CBI?* (Yes/No) ------------------------------------------------------------ ------------------------------------------------------------ ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. V.K. Piles Have identified residuals been stored or treated in onsite or captive offsite piles at any time since January 1, 1997? Yes/No (Circle one) If yes, complete Table V.11. for each pile noted in Table IV.1 1. What is the Residual Management Unit Number? 2. Are there dust suppression methods in place (Yes/No)? If yes, specify the type in a footnote. 3. Specify if the pile has: 01 concrete pad 02 runoff containment 03 synthetic liners 4. Are the runon/runoff controls in tact (Yes/No)? 5. Specify the average volume in the pile. Table V.11. Piles 1.RMUN 2.Dust 3.Concrete 4.Runon/ 5.Average CBI?* Suppression Pad/Runoff runoff Volume (Yes/ No)? Containment/ controls in Pile Synthetic (Yes/No)? (cu. yd) Liners? *If CBI is claimed, complete Appendix B. VI. General Facility (Both onsite and facility-owned offsite) This section asks for general information on your facility and land use inside and outside the facility. This information will be used in the fate and transport part of EPA's analysis. Please provide a detailed map of the facility and surrounding area. This map may be a photocopy of one previously sent to a state or federal agency. The map should include items 1 though 4 listed below within 1 mile of the facility boundary, if available. 1. Facility property boundary 2. Location of all residual management units 3. Ground water gradient and direction 4. Prevailing wind direction VII. Certification I certify under penalty of law that I have personally examined and am familiar with the information contained herein and, that based on my inquiry of those responsible for obtaining the information, I believe the above to be true and complete, and I am aware that there are substantial penalties for submitting false information. Signature _________________________________________________ Date ________________ Telephone __________________________ Name (print) _______________________________________________ Title ______________________________________________________ Authority for the collection of the above information is contained in the Resource Conservation and Recovery Act, 42 USC 6901 et seq. APPENDIX A Examples Example PFD for Sodium Dichromate Manufacture Chromite ore is fed to a drier and grinder to size the chromite ore. The drier is vented and the exiting air contains fine particulate matter vented to atmosphere. The chromite ore is then fed to an alkaline roaster where limestone and soda ash are introduced to increase roasting rate. The kiln is vented and the stream is rich with carbon dioxide. After roasting, the mix is leached and filtered allowing the chromium to remain in solution. The filtered residuals are sent to a residual drier and then recycled to the kiln. The residue drier also has a vent that releases small amounts of soda ash and limestone particulates. The chromium solution that remains after leaching is then sent to a precipitation vessel where sulfuric acid and soda ash are added to reduce the pH to 5 to precipitate the remaining ore residues and activate the hexavalent form of chromium. The ore residuals are then sent to treatment and settling which will be described later. The precipitation stage also produces a carbon dioxide rich stream which is vented to atmosphere. The chromium solution filtrate is split to produce two grades of product. Twenty percent of the chromium stream leaving the precipitation step is immediately evaporated and crystallized to produce technical grade Sodium Chromate (Na2CrO4). The evaporator used to dry the product produces a gaseous waste stream that contains mostly water vapor and small amounts of particulate product. The remaining 80% of the chromium precipitate stream is diverted to become Sodium dichromate. This solution is further acidified with sulfuric acid to a pH of 4.0 to produce the dichromate form of chromate. This solution is partially evaporated and centrifuged to separate Sodium Sulfate from the dichromate solution. The sodium sulfate is dried and sold as a by-product. After the removal of the sodium sulfate the dichromate solution is centrifuged and crystallized. Any liquid residuals are recycled to the evaporator and sodium sulfate removal stage. The crystallized sodium chromate is then sent to a final drying step and then packaged as product. The waste treatment and settling unit receives waste from the ore residue precipitant stage and also handles wastes generated from scheduled clean-outs. The waste treatment unit uses flocculating agents to help precipitate the ore residues. This unit also generates two wastes: a solid waste and a liquid waste (RIN 1 and 2). RIN 1 is sent to an off-site industrial Subtitle D landfill. RIN 2 waste is drummed and sent to an off-site publicly owned treatment works (POTW). These wastes are treatment residues from the roasting and leaching of chrome ore and are exempt from hazardous waste regulation by the Bevill exemptions. Example PFD for Dry Process Phosphoric Acid Manufacture Liquid Phosphorous and pure oxygen are fed to a combustion furnace where the phosphorous and oxygen react to form phosphorous pentoxide. This gas is then fed into a condenser where water is sprayed over the gas to create phosphoric acid. Escaping gas is collected in a scrubber with fresh water being the collection agent. The scrubber water, now phosphoric acid, is returned to the condenser. The scrubber is vented and releases an airborne waste stream to the atmosphere which contains trace phosphoric acid. The phosphoric acid from the condenser is sent to purification where sodium hydrosulfide is added to precipitate arsenic sulfide and calcium sulfide. The precipitates are then filtered with the help of a filter aid and the product is packaged. Escaping gas from filter waste solids are scrubbed to remove hydrogen sulfide, and the remaining sludge waste is then sent to an offsite Subtitle C landfill (RIN 1). A solid waste stream is also generated from product storage (RIN 2 not shown on PFD). This waste is mostly inert material which is collected in sludge form and also sent to the offsite Subtitle C landfill. Example PFD for Phosphorous Trichloride Manufacture The production begins as phosphorous liquid is sprayed into a reactor simultaneously fed with chlorine gas. The ensuing chemical reaction produces phosphorous trichloride and is controlled and slowed by recycling phosphorous trichloride. The reacted phosphorous trichloride is then sent to be purified by distillation. Residual gases are scrubbed with water to produce hydrochloric acid and phosphorous acid. These waters (also along with some arsenic trichloride) are sent to waste water treatment (RIN 1). The waste treatment plant uses lime to neutralize the acids and this liquid is sent to a surface impoundment, Subtitle D. Total wastewater flow through the WWTP is 15 million MT/yr. Another residual is produced during regular plant turnaround. Reactor cleaning produces an arsenic bearing sludge (RIN 2 not shown in PFD). Reactor cleaning also uses many solvents which result in arsenic bearing waste streams (RIN 3 not shown in PFD). RIN 2 is drummed and shipped to Subtitle C landfill; RIN 3 is drummed and shipped to offsite solvent recovery. Example PFD for Phosphorous Pentasulfide Manufacture The production of phosphorous pentasulfide begins by feeding liquid phosphorous and liquid sulfur into a cast iron reactor. The reactor temperature starts at 200ø Celsius and quickly rises due to the exothermic reaction taking place. The reactor is continually filled with nitrogen gas to prevent oxidation of sulfur. The reactor batches are forced by nitrogen gas into an electrically heated vacuum still where the liquid product is cleaned leaving a residue in the still consisting of glassy phosphates, carbon and iron sulfur compounds (RIN 1). The residue is sent to an on-site Subtitle D landfill. The purified product is cast into cones and then crushed and packaged. The liquid product ignites when it contacts air and emits phosphorous pentasulfide and sulfur dioxide. These contaminants are scrubbed and the waste waster from the scrubber is sent to a neutralization tank prior to discharge (RIN 2). The neutralized wastewater is sent to WWTP which realizes a total flow of 25 million MT/yr. The scrubber vent is nearly clean and is vented to atmosphere. Example PFD for Sodium Chlorate Manufacture Sodium chlorate is manufactured by first preparing a brine mixture from rock salt. This salt is treated by addition of sodium hydroxide and sodium carbonate to reduce the calcium and magnesium levels. The brine is then fed to an electrolysis unit where sodium chloride oxidizes with three water molecules to produce the product along with hydrogen gas. The hydrogen gas is very pure and sent to flare. The sodium chlorate solution is then sent to a chromium removal stage where with the addition of sodium thiosulfate the chromium will precipitate out in the form of chromium (III) oxide. This precipitant is filtered and returned to the brine preparation tank. The filter solids generated from filtration (RIN 1) are shipped to an offsite Subtitle C landfill. The final product is a chromate/chloride mixture. Example PFD for Antimony Oxide by the Direct Method The production begins by feeding antimony sulfide ore into a furnace to be burned in air. The resulting reaction creates antimony oxide and sulfur dioxide. The ore creates a slag that must be removed periodically (RIN 1) and contains antimony, arsenic, and some lead. This slag is shipped to an offsite secure Subtitle C landfill. The sulfur dioxide and other gasses produced are sent to a wet scrubber where hydrated lime is added to remove most of the sulfur dioxide. Escaping gases are vented to atmosphere with low levels of sulfur dioxide and particulates. The resulting liquid waste stream is sent to a settling tank, allowing the water to be recycled to the scrubber, while the sludge (RIN 2) generated is put in drums and shipped off-site and disposed of in a Subtitle C landfill. After the product antimony oxide is collected in baghouse after roasting, it is packaged as a technical grade product. Periodically a portion of the scrubber water must be purged. About 5000 MT of scrubber water (RIN 3) is removed each year and sent to WWTP. The total wastewater flow through the WWTP is approximately 20 million MT per year. Example PFD for Antimony Oxide by the Indirect Method Antimony Oxide is manufactured by first feeding a combination of coke, antimony oxide ore, iron oxide, and silica to a blast furnace. These constituents react to release elemental antimony in liquid form. Blast furnace off-gasses, mostly carbon dioxide, are vented into a baghouse where ore particulates are recovered and off-gases are vented to the atmosphere (RIN 1) . The off-gas particulates are recycled to the blast furnace. The extracted liquid antimony is then refined before oxidation. After being refined the liquid antimony is volatilized and then sent to the oxidation process where air is forced through liquid antimony. The oxidized product is then allowed to cool and condense in the dry storage facility before being drummed for shipping. The wastes produced in this process are a slag which contains arsenic, lead, and antimony from both the refining process as well as the blast furnace and off-gas from product collection. The slag (RIN 2) is sold to an offsite lead recovery operation. Example PFD for Cadmium Pigments Manufacture This facility produces one cadmium pigment, cadmium red. Production of Cadmium Red begins by reacting cadmium metal with sulfuric acid. The off-gasses, which contain hydrogen, water vapor, cadmium sulfide, and some sulfuric acid, are water scrubbed. Off gas vapors is vented to the atmosphere, while the liquid (RIN 1)is sent to waste treatment. The reaction products are sent to filtration, where unreacted cadmium is separated and returned to the reaction vessel. The cadmium sulfide is then sent to a second reactor where selenium is added to provide the red coloration and sodium sulfide is added to precipitate out sodium sulfate. The reaction products are once again filtered; filter sludges (RIN 2) are washed then sent to waste treatment (discussed below) while the liquid product is sent to be dried. The drying and calcination kiln has a vent that leads to a dry collection store. The store collects particulate product (RIN 3) and returns it to the kiln; off-gasses from the store are vented to the atmosphere. After the product is dried, it is ground to the proper size and washed with water. The wash waters (RIN 4) are sent to waste treatment (RIN 4) while the product is again dried and then packaged. The drier vent is sent to a baghouse; particulates (RIN 5) are collected and sent to the kiln, while off-gas is vented to atmosphere. The waste treatment facility described above accepts wastes RIN 2 and RIN 4. These wastes are acidic, and as such, are treated with lime to adjust the pH to precipitate cadmium and zinc salts. The water (RIN 5) is then filtered and sent to the WWTP. Total wastewater flow of the WWTP is 25 million MT/yr. The treatment solids are sold to an off-site firm to recover the cadmium metal (RIN 6) . Example PFD for Barium Carbonate Manufacture The first step of barium carbonate manufacture is the crushing and milling of barite ore to 100 mesh in preparation of further processing. This ore is fed to a baking kiln along with coke in a ratio of 5:4. This mixture is baked at high temperature for about ten minutes where the reactions release sulfur dioxide, carbon monoxide, carbon dioxide, as well as other prolific constituents. The airborne wastes are scrubbed with calcium carbonate and sodium carbonate to precipitate calcium sulfate and sodium sulfate (RIN 1). The calcium/sodium sulfate residue is collected and sent to a Subtitle D landfill. The remaining airborne wastes are vented to the atmosphere. The solid remaining in the kiln is ground leached with hot water. The barium sulfide solution is then decanted and clarified using three serial clarifiers. The ore residue is removed during the decantation process, dried, and then sent to an onsite Subtitle D landfill (RIN 2). The clarified barium sulfide is then sent to a precipitation tank where soda ash is added to produce barium carbonate. As a byproduct of this reaction sodium sulfide and sodium hydrogen sulfide are produced. These byproducts are sent to an evaporation tank where the solids are collected and sent to an offsite Subtitle C landfill (RIN 3). Water from the evaporator is recycled to the leaching process. The barium carbonate precipitate is then washed and filtered in preparation for drying. The filter water is recycled to the leaching process, while the barium carbonate solid is sent to drying. The drier is vented and allows small amounts of product particulates to escape. The dry product is then sized and packaged. Example PFD for Boric Acid Manufacture Orthoboric acid production begins by reacting sodium borate pentahydrate with sulfuric acid. The resulting reaction creates orthoboric acid in solution with sodium sulfate and water. The boric acid, which is a solid after reaction, is then filtered. The filter cake, which is primarily boric acid is cleaned and crystallized. Excess liquor is cleaned from the acid by means of recycled wash water from a later cleaning step. The liquor water (RIN 1) is sent to be stabilized and sent to an offsite Subtitle C landfill. The boric acid then is crystallized and centrifuged to remove the final traces of mother liquor from the product (RIN 2). This waste liquor is transferred to an on-site WWTP with an on-site surface impoundment. The total flow in the surface impoundment is 1 million MT/yr. The spent mother liquor is recycled to the redissolver step. The final product is then dried and packaged. The filtrate from the reactor is sent to be cooled to remove the byproduct of sodium sulfate. The sodium sulfate drops out of solution upon cooling and is sent to the next stage, while the remaining liquor is recycled to the filter. The sodium sulfate is then returned to a slurry via waterwash and is evaproated before being sent to centrifuge for drying and separtaion. The liquid that is produced from the centrifuge is drummed (RIN 3) and sent off site for incineration. The sodium sulfate crystals are then dried further and packaged. Example PFD for Hydrogen Cyanide Manufacture Andrussow Process with ammonia recycle Ammonia, natural gas, and air are fed into the primary reactor and heated over platinum and rhodium catalyst to 1100ø Celsius. The products are moved through the reactor and quenched immediately to 350ø Celsius via a waste heat boiler. The products and unreacted reactants then move to an ammonia absorber where a monoammonium phosphate solution is added. This converts the ammonia to diammonium phosphate and the liquid is removed and taken to the ammonia recovery system which will be described later. The product off-gas is sent from the ammonia absorber to the hydrogen cyanide absorber where cold water is added to entrain the hydrogen cyanide. The excess unreacted gasses are sent to flare. The hydrogen cyanide-water mixture is then sent to a cyanide stripper where excess water is removed from the liquid. Wastewater is partially recycled to the cyanide absorber and part is sent to waste water treatment (RIN 1). After being stripped to near purity, the hydrogen cyanide- water mixture has sulfur dioxide added in a fractionator to act as an inhibitor. This mixture is the final product. The ammonia recovery system accepts diammonium phosphate from the ammonia absorber. The system consists of a steam stripper and a fractionator. From the stripper, the overhead containing water and ammonia is condensed and sent to a fractionator where the water is removed and sent to wastewater treatment (RIN 2). The stripper bottoms are recycled to the ammonia absorber. The ammonia gas is then mixed with fresh ammonia for recycle into the primary reactor. Spent Pt/Rd catalyst (RIN 4) is removed every 2 years and sent offsite for metals reclamation. The wastewater treatment facility accepts wastewaters RIN 1 and RIN 2 from the process. The total wastewater flow for the WWTP is 20 million MT/yr. The wastewater is fed into a retention pond where the pH is adjusted to 10. Next, sodium hypochlorite is added to chlorinate the waste for cyanide destruction. After settling for 9 hours the liquid is discharged to an offsite POTW (RIN 3). Example PFD for Titanium Dioxide Manufacture The sulfate process begins by feeding dried ilmenite ore into a batch reaction still with concentrated sulfuric acid. The acid digests the ore over the period of an hour resulting in a green, thick, titanyl sulfate sludge. The reactor is then flooded with warm water and steam creating a slurry of titanyl sulfate which is pumped into settling tanks. Scrap iron is then added to the mixture to reduce the ferric ions in the slurry to the ferrous state. Sodium hydrosulfide is then added to precipitate all of the heavy metal sulfides, flocculating agents are added to precipitate all of the suspended solids, and Antimony Oxide is added to control the quality of the final product. The solution is then filtered to remove the precipitants and vacuum crystallized to cool the purified liquid. The titanium liquor is then hydrolyzed to titanium dioxide hydrate by boiling and seeding with the hydrate product. The hydrate then precipitates from the acid solution and the pulp is removed via a rotary filter. The solid product is then leached to remove the final traces of the acid solution and then sent to be calcinated. Calcination takes place in a rotary kiln at 850ø Celsius to dehydrate the titanium dioxide. The final product is then sent to treatment, where surface treatments are added to improve dispersability. The product is again dried, then sized and packaged. This process creates a number of residuals. Ore digestion creates two RCs: vented gases and a digestion ore sludge. The vented gases are released to the atmosphere. Digestion sludge is removed after flocculation and primary filtration of the titanyl sulfate (RIN 1). This digestion sludge is rich in heavy metals, chromium, and alumina, and is drummed and sent to an offsite Subtitle C landfill. The centrifugation of the titanyl sulfate solution also produces an acidic waste (RIN 2), which is commercially sold as copperas. The filtering of the titanium dioxide hydrate solution produces a large quantity of strongly acid waste (RIN 3). This waste is sent to a neutralization tank along with the weak acid produced from the cleaning of the hydrate (RIN 4). Waste water from the neutralization tank is released upon neutralization to the WWTP, while the solids (RIN 7) are filtered and sent to an offsite Subtitle D landfill. Scrubber water is also produced which contains particulate product from the calcinator (RIN 6) which is sent to an onsite WWTP. The final treatment step in the titanium dioxide process produces a small amount of wastewater containing product and some additives (RIN 5). This waste is sent to an onsite Subtitle D surface impoundment for storage and then to WWT. Total wastewater flow for the facility is approximately 20 million MT/yr. Example PFD for Potassium Dichromate Potassium dichromate is made by the reaction of potassium chloride and sodium dichromate liquor in solution. The solution is then pH adjusted, saturated and filtered. Filtering produces solid filter aid waste (RIN 1) which is drummed and shipped to a Subtitle C landfill. The material is then vacuum cooled to precipitate crystalline potassium dichromate which is recovered by centrifuging. The mother liquor from the product centrifuge is then concentrated to precipitate sodium chloride which is removed as a solid waste (RIN 2) from a salt concentrator and centrifuge. The waste solid sodium chloride is contaminated with chromate salts and is considered hazardous and is subsequently transported to an offsite Subtitle C landfill. The resulting potassium dichromate solution is then evaporated to recover the product. Next, the material is dried, sized and packaged. The dust produced during the drying and packaging is sent to a dust collection area where it is settled and returned to the reaction tank via conveyor. Example PFD for Wastes from the Production of Sodium Phosphate from Wet Process Phosphoric Acid Sodium phosphate from the wet feedstock method is produced by a series of precipitation reactions followed by a final neutralization step to release the product. Wet phosphoric acid is fed into the system with sodium carbonate until a pH of approximately 2.0 is reached. This step precipitates sodium fluorisilicate. Primary filtration results in a filter cake (RIN 1) which is shipped to a Subtitle C landfill. The precipitant is removed by centrifugation and the remaining solution is sent to a secondary precipitation train to remove iron and aluminum phosphates and arsenic salts by neutralization to a pH of approximately 5.0 and treatment with sodium sulfide (arsenic precipitant). The arsenic sulfide (RIN 2) is containered and shipped to a Subtitle C landfill. This step removes any remaining fluorides that escaped the previous precipitation step. These are then sent to the secondary crystallizer, then filtered to remove the precipitants (RIN 3). The precipitants are then managed in an on-site Subtitle D landfill. The remaining acid is then sent to final neutralization with sodium carbonate. The pH is neutralized to approximately 8.5 if the desired product is trisodium phosphate. The final neutralization also produces some monosodium dihydrogen phosphate and some monosodium monohydrogen phosphate. Example Response to Question III.A Residual Characterization 1. RIN 2. Common Name CBI?* ________1_____________________ ______04_________ 3. Residual Code 4. RCRA Code: ____digestion sludge__________ ___D007____________ 4. Properties Particle Size Phase Distribution of Residual Distribution & Other Properties pH 3.5 > 60 mm 10% Aqueous Liquid 65% Reactive CN ppm 1-60 mm 65% Organic Liquid % Reactive S ppm 100 m-1 mm 0.1 Solid 40% Vapor mm Hg 10 m-100 m 5% Other % Pressure (specify) Viscosity cP < 10 m % TSS in WW Specific Gravity NORM 5. Residual Characterization Element or Total TCLP Other Compounds Concentration Concentration Leaching (mg/kg) (mg/L) Procedure Concentration (mg/L), Specify ------------------------------------------------------------ Arsenic 250 ------------------------------------------------------------ Barium 200 ------------------------------------------------------------ Cadmium ND ------------------------------------------------------------ Chromium 5 ------------------------------------------------------------ Lead 10 ------------------------------------------------------------ Iron 32000 ------------------------------------------------------------ Magnesium 640 ------------------------------------------------------------ Silver ND ------------------------------------------------------------ Titanium 24000 ------------------------------------------------------------ Zinc 1300 ------------------------------------------------------------ Sodium 250000 ------------------------------------------------------------ *If CBI is claimed, complete Appendix B. Example Response to Question IV.A Residual Generation Rate and Management 1. RIN __1_____ 2. Quantity Generated ___5000______ (MT) (CBI?) Year of Generation (if not 1997) _________ 3. Frequency of Generation _____B_________ 4. Management 5. Management 6. RMUN 7. Planned CBI?* Step Code Changes ------------------------------------------------------------ 1 01-B 10 N ------------------------------------------------------------ F 13-B 20 N ============================================================ 1. RIN __2_____ 2. Quantity Generated ___5000______ (MT) (CBI?) Year of Generation (if not 1997) _________ 3. Frequency of Generation _____B_________ 4. Management 5. Management 6. RMUN 7. Planned CBI?* Step Code Changes ------------------------------------------------------------ F 10-C 30 (offsite N reclamation ============================================================ 1. RIN __3_____ 2. Quantity Generated ___53,000______ (MT) (CBI?) Year of Generation (if not 1997) _________ 3. Frequency of Generation _____A_________ 4. Management 5. Management 6. RMUN 7. Planned CBI?* Step Code Changes ------------------------------------------------------------ 1 08-A 40 N ------------------------------------------------------------ F 12-A 50 ============================================================ Example Response to Question IV.B. Offsite Management Facilities Residual Management Unit Number (RMUN): 30 Name of Facility: Thoroughburn, Inc. Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): Route 6 City/State/Zip Code: Warm Springs, Nevada 08012 Distance from Facility: 150 miles CBI? ------------------------------------------------------------ Residual Management Unit Number (RMUN): Name of Facility: Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): City/State/Zip Code: Distance from Facility: CBI? ------------------------------------------------------------ Residual Management Unit Number (RMUN): Name of Facility: Hazardous Waste Facility ID Number (if any): Facility Location (Street, Route Number, or Other Specific Identifier): City/State/Zip Code: Distance from Facility: CBI? ------------------------------------------------------------ Example Response to Question IV.C. Onsite and Offsite Residual Management Unit Identification 1.RMUN 2.Location 3.Unit 4.Unit Common 5.RINs CBI?* Type Name Managed in Unit ------------------------------------------------------------ 10 On 2 Container (Drum) 1 ------------------------------------------------------------ 20 On L-3 Subtitle C Landfill 1 ------------------------------------------------------------ 30 Off 5 Thoroughburn 2 (HTMR) Metal reclamation ------------------------------------------------------------ 40 On 1 Neutralization 3 tank ------------------------------------------------------------ 50 On L-6 WWTP 3 ============================================================ Exhibit IV.4. Example Response to Question IV.D. Total Production 1. Product 2. 1997 Total Production (MT/yr) CBI? ------------------------------------------------------------ Titanium dioxide 54,000 ------------------------------------------------------------ Copperas 53,000 ============================================================ Example Response to Question IV. Residual Management Cost Table 1.RIN 2.Transportation 3.Management 4.Payment CBI?* Cost ($/MT) Cost ($/MT) Received ($/MT) ------------------------------------------------------------ 1 50 50 ------------------------------------------------------------ 2 45 ------------------------------------------------------------ 3 100 75 ------------------------------------------------------------ Example Response to Question V.A. Residual Management Unit Characterization 1.Residual 2.Date 3.Expected 4.Active 5.RCRA CBI?* Management Opened Closure Date life Permit Unit Number (month/ (month/year) (years) Status year) (N, IS, B, S) ------------------------------------------------------------ 10 N ------------------------------------------------------------ 20 6/85 6/10 25 S ------------------------------------------------------------ 30 N ------------------------------------------------------------ 40 N ------------------------------------------------------------ 50 N ------------------------------------------------------------ 60 N ------------------------------------------------------------ 70 4/79 4/99 28 S ------------------------------------------------------------ 80 1/82 1/07 30 S ============================================================ Example Response to Question V.2. Land-Based Units (other than land treatment): Unit Size and Covers 1.RMUN 2.Surface 3.Height (ft) 4.Total 5.Remaining Area above below Design capacity as (Acres) grade grade Capacity of 1/97 (cu. (cu. yd.) yd.) ------------------------------------------------------------ 20 12 10 15 250,000 100,000 ------------------------------------------------------------ 70 6 3 32 225,000 50,000 ------------------------------------------------------------ 80 24 10 15 500,000 250,000 ------------------------------------------------------------ 6. % Remaining 7.Frequency 8. Dust CBI?* capacity used in Which Suppression? in 1997 Cover is Applied ------------------------------------------------------------ 10 Daily ------------------------------------------------------------ 15 ------------------------------------------------------------ 1 Daily ------------------------------------------------------------ Example Response to Question V.C. Land-based Units: Landfills 1.RMUN 2.Total 3.# of 4.Active 5.Thickness 6.% of CBI?* Area Cells Area of Waste Total (acres) (acres) Distributed Landfill Over Cell that (ft.) Contains the Waste ------------------------------------------------------------ 20 40 4 12 4 45 ------------------------------------------------------------ 80 65 6 10 8 20 ============================================================ Exhibit V.4. Example Response to Question V.4. Land-Based Units: Design and Construction 1.RMUN 2.Liner Construc- 3.Layer 4.Thickness CBI?* tion Code Thickness Units (inches or mm) ------------------------------------------------------------ 20 2 10 mm ---------------------------------------------------- 3 250 mm ---------------------------------------------------- 4 ============================================================ 70 5 500 mm ---------------------------------------------------- ---------------------------------------------------- ---------------------------------------------------- ============================================================ 80 3 400 mm ---------------------------------------------------- ---------------------------------------------------- ---------------------------------------------------- ============================================================ Example Response to Question V.E. Leachate and Run-on/Run-off Control 1. RMUN 2. Annual Leachate 3. Contact with 4. Runoff Volume (MT) Storm Water Under Possible? Storm Water (Yes/No) Permit? (Yes/No) ------------------------------------------------------------ 20 10 Yes Yes ------------------------------------------------------------ 70 5000 Yes Yes ------------------------------------------------------------ 80 25 Yes Yes ------------------------------------------------------------ 5. Flood 6.Distance 7.Run-on/Run-off 8.Run-on/Run-off Plain Type to Nearest Storm Severity Control System Downgradient Type Water Body (ft) ------------------------------------------------------------ 50 5200 50 1 ------------------------------------------------------------ N 3000 10 3 ------------------------------------------------------------ N 3000 25 1 ------------------------------------------------------------ 9. Run-off 10. Description CBI?* Destination Attached Code (Yes/No) ------------------------------------------------------------ 1 No ------------------------------------------------------------ 1 Yes ------------------------------------------------------------ 3 Yes ------------------------------------------------------------ Example Response to Question V.E. Land Treatment Units 1.RMUN 2.Surface 3.Surface 4.Method 5.Depth of Area area residual of Soil Incorporation (acres) is applied Incorpor- (inches) (acres) ation ------------------------------------------------------------ 140 80 10 1 12 ------------------------------------------------------------ 6.Frequency of 7. 1997 Total CBI?* Application Residual Applied (MT) ------------------------------------------------------------ Monthly 2100 ------------------------------------------------------------ Exhibit V.7. Example Response to Question V.F. Tanks 1. RMUN 2. Tank 3. Tank 4. Secondary 5. Covered? CBI?* Volume Area Containment? (Yes/No) (gal) (ft2) (Yes/No) ------------------------------------------------------------ 40 5000 40 No Yes ------------------------------------------------------------ Example Response to Question V.H. Surface Impoundments 1.RMUN 2. Total 3. Residual 4. Total 5. Aerated? WW Flow WW Flow S.I. through Area S.I. (m2) ------------------------------------------------------------ 70 20 35,000 97,000 Yes ------------------------------------------------------------ 6.Liner 7. Leak 8. Closure CBI?* Type Detection plans? System (Y/N) ------------------------------------------------------------ None No No ------------------------------------------------------------ Example Response to Question V.I. Deep Injection Well 1. RMUN 2. Injection 3. Depth from 4. Regulatory Rate (gal/yr) grade to top status code of injection zone (ft) ------------------------------------------------------------ 110 75 million 100 1 ------------------------------------------------------------ 5. Additional CBI?* information attached? (Yes/No) ------------------------------------------------------------ Yes ------------------------------------------------------------ Exhibit V.10. Example Response to Question V.J. Containers 1. RMUN 2. Container type and size 3. Closed? CBI?* (Yes/No) ------------------------------------------------------------ 10 Drum, 500 cu. yd Yes ------------------------------------------------------------ Example Response to Question V.K. Piles 1.RMUN 2.Dust 3.Concrete 4.Runon/ 5.Average CBI?* Suppression Pad/Runoff runoff Volume (Yes/ No)? Containment/ controls in Pile Synthetic (Yes/No)? (cu. yd) Liners? ------------------------------------------------------------ 150 No Pad w/synthetic Yes 10,000 liner ------------------------------------------------------------ APPENDIX B Claim of Confidentiality Substantiating the Claim of Confidentiality You may make a confidential business information (CBI) claim for each data element that is sensitive data. The series of questions needs to be filled out for each data point that is claimed to be CBI. Attach additional pages as needed. 1. For what period of time do you request that the information be maintained as confidential? If the occurrence of a specific event will eliminate the need for confidentiality, please specify that event. 2. Information submitted to EPA becomes stale over time. Why should the information you claim as confidential be protected for the period of time specified in your answer to question #1? 3. What measures have you taken to protect the information claims as confidential? Have you disclosed the information to anyone other than a governmental body or someone who is bound by an agreement not to disclose the information further? If so, why should the information still be considered confidential? 4. Has any governmental body made a determination as to the confidentiality of the information? If so, please attach a copy of the determination. 5. Is the information contained in any publicly available material such as promotional publications, annual reports, articles, permits, etc.? Is there any means by which a member of the public could obtain access to the information? 6. For each section of information claimed as confidential, discuss with specificity why release of the information is likely to cause substantial harm to your competitive position. Explain the nature of these harmful effects, why they should be viewed as substantial, and the causal relationship between disclosure and such harmful effects. How could your competitors make use of this information to your detriment? 7. Please discuss any other information you deem relevant.