The nonfuel minerals industrv: regulatory impacts Enljironmental and healthlsafety regulations could affect costs, competitiveness, and viability. Here is an assessment with which The M I T R E Corp. assisted E P A a
-
Alex Hershaft Thr M I T R E Corporation Metrek Dirision McLran, Va. 22102 William Lacy L'S. Encironriiental Protection Agency Washington, D.C. 20460
Metal mining and processing represents an important pollution source of the nation's surface and ground waters. Attempts by the U.S. Environmental Protection Agency (EPA) to regulate these discharges have been stymied frequently by the technical difficulties and high costs associated with their control and treatment. These costs became a particularly contentious issue because of their potential impact on the viability of the U.S. metal industry, and its competitiveness in the world market. 404
Environmental Science & Technology
In December 1977, the administration requested EPA to assess the relationship of environmental quality, health, and safety regulations and the supply and price of metals and other nonfuel minerals. as part of a wideranging, high-level review of the national nonfuel minerals policy. The M I T R E Corporation was commissioned to assist in this assessment. The scope of the analysis was delineated in terms of the metals to be considered and the stages of processing. Among the 80 individual and group mineral commodities listed by the U S . Department of the Interior's Mineral Yearbook, well over one-half are metals and their compounds. The more important among these are aluminum, chromium. cobalt, copper, iron and steel, lead, magnesium, manganese, molybdenum, nickel, potassium, silver, sodium, tin, titantium, and zinc. Iron and steel, copper, and
lead were singled out to illustrate the case for the other metals. The typical metal life cycle encompasses extraction (mining of the ore). beneficiation (concentration) of the ore, smelting (reduction to metal), refining and alloying, shaping, finishing (mostly plating), fabrication of the end product, use, and disposal or recycling. Only the first four stages. accountable for most of the water pollutants, are covered here. Pollution problems Water pollutants are generated a t every step of metal mining and processing (Table I ) . Runoff from exposed ore bodies and overburden and tailing piles carries suspended solids, acid sulfates, heavy metals, and other dissolved salts. In the cases of lead and other deep mining operations, some of these pollutants find their way to groundwater. The slurry from the
0013-936X/80/0914-0404$01.00/0
@ 1980 American Chemical Society
beneficiation step, normally stored in tailing ponds, contains additional suspended solids, as well as chemicals used i n the ore concentration process. Smelting and refining effluents stem largely from the operation of wet scrubbers. They contain a large variety of heavy metals and other substances, occurring as impurities in the ore or added somewhere in processing. For ex a m p I e, e f fl u en t s from s tee I - making plants contain ammonia, cyanides, nitrates, oil and grease, and phenols introduced with the coke, as well as fluorides added as as a fluxing agent. Control technology Fortunately, most of these discharges can be controlled to a large degree. Runoff can be kept to a minimum and directed to tailing ponds or separate containment lagoons through suitable landscaping of the ground surface, including the use of dams and ditches. Percolation to the groundwater can be controlled by lining the bottom of the pond with clay, paving material, or an impermeable plastic or rubber membrane. I n lagoons or ponds, suspended solids settle out by gravity, and hydrocarbons undergo biodegradation. Acid sulfates are neutralized with lime and, as the pH is raised, heavy metals are precipitated as hydroxides or carbonates and may be recovered. They also can be precipitated as sulfides, which requires less time, but this technique is still being demonstrated on a commercial scale. Control and treatrnent techniques for smelting and refining operations differ for each specific unit operation. For example, the principal techniques employed by the iron and steel industry are listed in Table 2. Under the stimulation of EPA‘s regulatory, research, and development prpgrams, the metals industry has installed a number of successful systems for recycling its wastewater, reducing its discharges to the environment, and recovering valuable raw materials. Indeed, a recent survey of the iron and steel industry revealed extensive use of water recycling in most major processes. Other approaches to reduction of industrial discharges are reformulation of the product using a low- or nonpolluting material and equipment, or process modification.
much of the monitoring and enforcement activity to the states. The years 1969-72 witnessed the enactment of the Yational Environmental Policy Act ( N E P A ) and the Federal Water Pollution Control Act amendments ( F W P C A ) , as well as the creation of the Council on Environmental Quality and the U S . Environmental Protection Agency (EPA). N E P A requires all federal agencies undertaking a major action significantly affecting the quality of the human environment to prepare an environmental impact statement (EIS) for public review and comment. Federal regulation of water pollution can be traced back to the Refuse Act of 1899, which prohibited dumping of debris that would pose a hazard to navigation. This was followed by a
series of Rivers and Harbors Acts, again dealing directly with navigational problems. However, a more comprehensive attempt to protect the nation’s water quality did not surface until the Water Pollution Control Act of 1948, which formally assigned responsibility for pollution control to state and local governments. That act was amended a number of times, progressively strengthening the federal role and placing increasing emphasis on control of toxic and hazardous substances. Eventually, enactment of the Clean Water Act of 1977 superseded all the earlier water pollution legislation, and it now governs most of EPA’s current regulator) activity in this area. The principal goal of the Clean Water Act is “to restore and maintain
Law and institutions In the wake of heightened public concern, the federal government assumed overall management of the nation’s environmental quality in the late 1960s and early 1970s, but delegated Volume 14, Number 4, April 1980
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the chemical, physical, and biological integrity of the nation's water." Secondary goals and policies include elimination of discharge of pollutants into navigable waters by 1985; achievement of a water quality that provides for the protection and propagation of fish. shellfish, and wildlife and for recreation in and on the water by July 1983; prohibition of the discharge of toxic pollutants i n toxic amounts: and establishment of a major R & D effort leading to elimination of pollutant discharges into surface waters. The principal regulatory provisions affecting metal mining and processing are delineated in Table 3. Voreover. Section I O 7 authorizes EPA, i n cooperation with the Appalachian Regional Commission and other federal agenc i es, to demon st r a t e coni p r e h e n s i ve approaches to the control of \cater pollution from active or abandoned mining operations. Section 304, nhich provides for water quality standards and effluent limitation guidelines, also calls upon EPA to issue guidelines for identifying and evaluating the nature and extent of nonpoint pollution sources, and to publish procedures for their control. Other federal laws that may be applicable to water pollution associated with metal mining and processing include the Safe Drinking Water Act of 1974 ( S D W A ) and the Resource Conservation and Recovery Act of I976 ( R C R A ) . Regulations under the S D W A would specify maximum permissible levels of various substances in drinking water associated with metal mining and processing. These regulations would seek to prevent contamination of groundwater supplies by percolation and by underground injection of harmful substances. R C R A prohibits open dumping and regulates the treatment, storage, transportation, and disposal of hazardous wastes to prevent contamination of surface and groundwaters. The act also requires EPA, in consultation with the Secretary of the Interior, to conduct a detailed study of the adverse environmental effects of solid waste from active and abandoned mines. A t present, regulations of mining waste await the resolution of several questions, such as which mining wastes qualify under the act as solid waste or hazardous waste, and whether overburden and tailing piles qualify as open dumps. State laws regulating water pollution by metal mining and processing have been largely superseded by the federal Clean Water Act. T h e principal responsibilities of the states, under 406
Environmental Science & Technology
the act, are to establish water quality standards, and to implement the federal effluent limitations guidelines. The standards are intended to reflect the highest anticipated use for the given water body, in accordance with the federal water quality criteria established for that use. Effluent guidelines Effluent limitation guidelines specify the degree of effluent reduction attainable through the application of the best practicable control technology (BPT), the best available technology econoniically achievable (BAT), and the best conventional pollutant control technology (BCT). The performance and pretreatment standards for new sources establish similar limitations for industrial sources that discharge into navigable waters which were constructed after promulgation of the standards and for publicly owned treatment works ( P O T W ) , respectively. Distinct sets of guidelines and standards have been issued for 42 industrial categories, including four metal industries, and for a number of operations under each category (Table 4). Implementation of the guidelines and standards is driven by a complex set of deadlines geared to the type of industrial category and specific pollutants, required level of control technology. age of the source, and the point of discharge (waterway or sewer). I t is achieved through the hational Pollutant Discharge Elimination System ( Y P D E S ) , which is administered by 32 state agencies and by EPA regional offices in the remaining 18 states. The K P D E S requires a permit for each point source discharging into navigable waters. A state may impose effluent limitations that are more stringent than the federal guidelines if this is required to meet the water quality standards for a partacular Lvater area. States may also implement their own standards of performance for new sources, with the approval of EPA. Cnder provisions of the court settlement in the case of the Natural Resources Defense Council c. Train, effluent guidelines and standards are now being expanded to encompass limitations of 65 families of toxic substances. I n the nonferrous metals manufacturing category, 5 8 subcategories are under consideration. In the ore mining and dressing category, there is a question of defining requirements for zero discharge of certai n pollutants. Ambient water quality criteria for the 65 families of pollutants are being established under the same court settlement. Other regulatory initiatives
provisions being planned include development of effluent guidelines for BCT and revision, clarification, and updating of current N P D E S regulations. Benefits of regulation Benefits of controlling water pollution associated with metal mining and processing arise from the reduction of damages caused by water pollution and from increased opportunities open to the user by improved water quality. Damages may take several forms: direct losses to health, crops, ecosysiems, materials, aesthetic amenities and other resources, which
the user is unable or unwilling to avoid 0 avoidance losses incurred in seeking to prevent, mitigate. or repair the above losses nonuser losses suffered by people who have no plans to use the affected waters, but are deeply concerned 2.bout their restoration and preservation. It may be noted that this last component has been an important factor in the enactment of pollution control legislation. Pollution may adversely affect eight types of water uses: municipal supply, industrial supply, agricultural supply, commercial fishing. wildlife preser-
Volume 14, Number 4 , April 1980
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vation, recreation, navigation, and aesthetic enjoyment. In the first three instances, the loss may be classified almost entirely as avoidance of damage, incurred in the process of treating polluted water supplies to the required level of quality. The remaining uses are subject to direct losses in terms of fish landings, wildlife population diversity, recreational person-days and tourist trade, increased replacement and maintenance, and reduced property values, respectively. Nonuser values are reflected principally in the uses affecting society as a whole, that is, wildlife preservation, recreation, nav408
Environmental Science & Technology
igation, and aesthetic enjoyment. The accuracy of benefit estimates associated with implementation of a given regulation has suffered frequently from lack of adequate information on the relationships between implementation of a regulation, reduction in ambient pollutant levels, and decrease in damages. Only an upper limit on the potential benefits may be estimated reliably, in terms of total damages associated with metal mining and processing. Another important handicap in assessing the benefits of current water pollution control regulations i\ the very
recent date of their promulgation. and hence, the virtual lack of a historical record. For example, the effluent standards for the mining and processing of iron and steel, copper, and lead wcre published only in July 1978. Effects of earlier regulations have been blurred frequently by inadequate or shifting water quality sampling, analysis, and reporting procedures. Kevertheless, there is impressive cvidence of water quality improvement attributable to pollution control regulations. An analysis of pollution by 47 steel mills performed by the Council on Econoniic Priorities revealed a sub-
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stantial reduction in the discharges of suspended solids, oil and grease, ammonia, cyanides, and phenols, following enactment of the tough Federal Water Pollution Control Act amendments of 1972. A related analysis of phenol levels in the Ohio River and its tributaries, by the Council on Environmental Quality, found that the rate of violations of drinking water standards dropped by 50% between 1968, when the pollution control effort began, and 1976. Estimates of capital and operating costs of control equipment reported in the literature vary widely and give rise 410
Environmental Science 8 Technology
to acrimony between EPA and the regulated industry. These variations can be attributed to differing computation procedures and assumptions about the applicability, extent, and timing of control requirements; design of the control system: availability and effectiveness of control equipment; capital and operating costs of the various components; start-up datc and period of amortization; discount rate and base year; value of any recovered resources; and other pertinent variables. In each case, the assumptions typically serve the special interests of the computation.
EPA recently completed a survey of control costs in the major metal industries. Preliminary results are presented in Tables 5 and 6 for several subcategories of iron and steel, and the copper manufacturing industries. Capital investment includes the costs of research and development, engineering design, land and equipment, construction and installation, and start-up. Annual costs cover operation and maintenance, expendable resources, and insurance and taxes, but not repayment of principal and interest. The costs were computed for hypothetical facilities representative of the location, size, and age of the actual facilities. All figures are reported in July 1978 dollars. The estimated capital and annual costs of achieving BPT and BAT in the iron and steel industry are reported in Table 5. The table covers all significant subcategories of the mining and processing phase, but not the fabrication and finishing phase. T h e three alternatives in the BAT portion of Table 5 refer to different treatment methods and degrees of water reuse. The costs of achieving three levels of pollutant reduction in the effluents from primary copper smelting and refining operations are presented in Table 6. T h e upper part refers to treatment of contact cooling water in a n 1 1 000-gpd plant, whereas the lower part reports on the treatment of effluents from contact cooling, acid plant, slag, and electrolyte in a 2.24million-gpd plant. The three alternative levels of treatment all involve recycling contact cooling water, and combined treatment of 5% blowdown with the other waste streams before recycling. The first alternative only provides for lime precipitation, the second adds filtration, and the third includes treatment by activated carbon, as well. T h e impacts of these costs can be assessed in terms of supply and price of the metal products, foreign trade, employment, and inflation. The supply and price impacts are based on the projected incremental cost of controls, the demand and supply forecasts, the elasticity of supply and price, the utilization of the industry’s productive capacity, and the U S . share of the market. T h e impact on foreign trade may be assessed by allowing imports to replace the loss in U.S. production in the face of constant demand. T h e impact on employment then could be determined by converting the loss of production into equivalent jobs on the basis of availability and productivity of the labor force. Finally, the impact on inflation may be analyzed by ex-
PEAT: Industrial Chemistry and Technology By CHARLES H FUCHSMAN CHAPTER HEADINGS l i t r o d u c t i c n Chemical Cbaracterization of P e a k Solvent Extraction of Peat Bitumens ProdJction of Peat Waxes R e s i i Component of Peat Bitumens Peat Carbohydrates Ccmposi* o n and Hydrolysis Acid Hydrolysis of Unfractionated Peat C o m p o s t i o i of Pea: Hydrolysates I n t e i d e d for Yeast Pro duction Humic Acics and Lignins Peat Prolysis and Coke Pro duction Distillates anc Gases from Peat Pyrolysis Activated Carb o r from Peat Chemica Methods of Peat Analysis Sca'e of Peat Chemical O p e r a t i o i s Techno'ogical Perspectives for Peat Chemi cals Ecological and Other Ervironmental Factors Affecting the Chemical Technology of Peat References Subject Index 7980 288 pp S28 00 ISBN 0-72264650-9
Now Complete in Three Volumes. . .
ANALYTICAL METHODS FOR COAL AND COAL PRODUCTS
ainining the effect of changes in metal prices on the wholesale price of manufactured goods. Sensitibity to costs In recent years, EPA has grown inc rea si n g 1y sen sit i v e to the pot e n t i a 1 adverse impacts of the incremental costs of pollution control regulations. Some 40 measurcs are being considered or iniplcmentcd to reduce the burden on industry, .i+ithout incurring ;I significant loss in cnvironinental quality. These may be classified a s : i n t e r a ge n cy coo r d i n ii t i o n regulatorq revic\r improved communication with industry provision for plant-wide standards provision for industry initiatives. Coordination of related regulations among such agencies as EPA, the Occupational Safet!. and Health Administration, the Food and Drug Adm in i s t ra t ion, and the Consumer Product Safety Commission is intended to mininiize t.he occurrence of regulatory gaps, overlaps. and jurisdictional conflicts. Review of current and a n t i c i pat ed e nv i ro n in en t a I reg u lations, both within and outside of EPA. is designed to eliminate those that are no longer needed, to streamline those that are inordinately bur-
Ed ted b j CLARENCE KARR JR FROM REVIEWS OF PREVIOUS VOLUMES [Volumes 1 a r d 21 constitute a reference set requires for all involbed In coal research particularly those interested in developing a background i i coal chemistry Advances in chemical techniques I recent years are presentec in a useful way the second vo urne provides a necessary addition to the descr ption of t e c h i i q u e s currently in use by ccal scientists -AMERICAN SCiENTiST Volume Ill A s a c o T o r e h e i s i v e reference that w I 1 f i ' l the need f o r an aJthOrilative s ngle soLrce on the methods of analysis a r d cqaracterizat o n cf coal and its rlunerous products t'lis publication is cut stardiig Cor+riSutions a r e n a d e by researchers w th high expertise in t+eir d scip i r e s T + e tbeor, and p w t i c a l labo ra'ory details of the var O L S anal): ca netclcas are mcst tbor OJghIy covered a i d there is a most pleasing cross-referencing -A I Stairer ir E N E R G Y W O R L D CONTENTS ANALYSIS OF BASES D P M a q k a Coke Oven Gas Ana ysis M C Yar, n- ng et a C?aracterizaticrl of Recoverec! Vc ati e s F'CT A High M e t h a r e Coal and tbe Sign 'icarlce of These F ndings N E Vanderborg? a n d R L H a n s o q Character zation of Coa s U s i i g Laser Pyrol,sis-Gas Chro-natcgraphb S B K i r g a n c R A Magee ProdJc' Stream A i a l b s i s from aq U r d e r ground Coal Gas ficat o r Test WASTE PRODUCT STREAMS AND ENVIRONMENTAL PROBLEMS S J R i s s e l l a r c S M R Stepusin Analys s o' M neral Mat'er in Coal Coal Gasification Ash and Coal Liqbefact on ResldLes b / S c a n n i i g Electron M crosccpy and X Ray Diffrac'ion S F Tucker Analyses c f Ccke Oden EfflJents for Polynuclear Aromatic Co-npcunds R G Ltiihy a?d R W W a i t e r s The ProdJCt c i Managemerlt and Chem stry of Coa G a s f i c a t i o r Wastewaters J S Frclci-ler a n d M R Pe ersen Charac'erizaticn of ProdJcts By prodLC's a i d Effluents from Coal C c i v e r s i o n P?ocesses for Env ronmertal PLrposes SPECIAL I N STRUNENTAL TECHNIQUES FOR ANALYSES OF COAL AND ITS es lrls'rurnertal Activatior Analysis of Coa anc Coal Ast- LY th T i - e r r a and E p i t i e r m a NeLtrons A Vc bor+il Fast-NeJtron Acti/atior A r a ysis tor O x v g e r T i t r o g e i anc Si i c o r i i Coal Coal A s p and Related ProdLcts R Raymond Jr ard 9 Goo e, E ect'cr P 3be M i c r o i r a l b z e r n Coal Research J W P ather e' a X ?av F Jc'escence A n a l l s i s of Trace Elements in Coal and Soivert Refined Cca E Y b g g i i s ana G P H v f / r r a n MossDsuer A n a i j s i s of l r o i B e a r i i g Pqases n Coal Coke and A s k B C Gets'e F rae'prin' ns So id Coals Using P J I s ~a r d Nu tiple PL se Nuclear Masnet c Pescnance S S' J Warne Differertial Tierma1 A n a l j s i s of Coal Minerals BY-PRODUCT UTILIZATION AND MISCELLANEOUS PROBLEVS K S Vorres P r e d i c t i o i 01 Ash M e t i n g Behavior From Coal Ash Composition G L Flsiier a n d D F S N a ' J s c h S z e - D e p e i d e n c e of the Physical ana CClem cal Properties of Coal Fly Ash A Voibor!h Problems o' Oxygen Stoichiometry in Analyses of Coal anc Rela'ed Materia s A A t t a r Sulfu. Groups n Coal and Their D e ' e m i a t l o n s 7979 655 op S55 00 I S B N 0 72 399903 0 Volume I 7978 592 p~ S49 50 ISBN 0 72 399907-4 Volume I I '978 688 DD S55 GC i S 5 N 0 72 399902 4 Se! p r i c e for VolLrres / / i ~3 / / / 5'72750 ($15950 i f p b r c h a s e d s e o a r a ' e y ) Set prices are r o t valid in ALstral a or New Zealand Valid o i l v o n cJrchase of all volJ-nes Send pa)r?ent w tb order a i d save postage and i a n d l i n g c i a r g e Pr ces are sbbieci io c h a r g e w ihout notice
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‘Baker I nstra-Analyzed’
Maximum Limits of Impurities Total Organic Carbon(1) Total Trihalomethanes (2)
ppb max 0 1 ppb rnax
100
( 1)
Method UltraVlolet promoted Chemlcal oxidation conversion to methane. flame ionization detection
( 2)
Method Purge and trap TTHM E c h l o r o f o r m bromoform * chlorodlbromomethane bromodichlorornethane
densome, and to simplify application and reporting procedures. This effort is coordinated at the cabinet level by the President’s Regulatory Council, chaired by EPA Administrator Douglas Costle. Improved communication between EPA and a regulated industry should provide more adequate lead times to introduce the required control devices and techniques and to promote a more reliable assessment of the technical feasibility and cost of a given control requirement. Provision for plant-wide effluent limitations would allow industry to allocate its control resources in a more cost-effective manner. Industry, too, can help with the regulatory process. Indeed, joint R & D efforts between industry and EPA have produced important reductions in process effluents and improvements in control technology. Sharing of process and control information can assist the EPA regulatory staff in developing more cost-effective regulations. Development and implementation of uniform cost estimating guidelines should improve industry’s credibility in this area and assist EPA’s economic staff in the performance of more accurate cost-benefit analyses.
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Environmental Science & Technology
Alex Hershaft ( I ) is a senior staff member in the Encironmental Engineering Department o f t h e M I T R E Corporation. .Ve directed M I T R E ’ S aSsessment o f the inzpact of encironmental regulations of the nonfuel minerals industry. Preciously, he serced as director of encironmental studies f o r seceral other consulting f i r m s in the Washington area. Hershaft holds a Ph.D. .in chemistrj.from Iowa State Unicersity and an A . B . f r o m the Unicersity o f Connecticut. William J . Lacy ( r ) is the director of the Water and Hazardous Materials Monitoring Research Dicision. and the f o r m e r principal engineering science adcisor, E P A Office of R A D . H e procides top-lecel technical liaison with relecant gocernmental, pricate, professional, and international organizations and serced as the E P A project officer on the M I T R E study. Lacy is a graduate o f the Unicersity o f Connecticut. H e has completed the course requirementsfor his Ph.D. and has undertaken postgraduate studies at a number o f other institutions. H e is a registered professional engineer (chemical) and a diplomat of the American Academy o f Encironmental Engineers.
