NC0000175_Wasteload Allocation_19940103

NPDES DOCUMENT SCANNING. COVER SLEET
NC0000175
Unimin Quartz Operation
NPDES Permit:
Document Type:
Permit Issuance
... ............
Wasteload Allocation)
f
Authorization to Construct (AtC)
Permit Modification
Complete File - Historical
Engineering Alternatives (EAA)
Correspondence
Owner Name Change
Instream Assessment (67b)
Speculative Limits
Environmental Assessment (EA)
Document Date:
January 3, 1994
This documerit is prim -toed on rouse paper -ignore any
content on the resrerse side

J A N -
3-94 MON
16:Z2
P . 0
Minerals Research Laboratory
180 Coxe Avenue
Asheville, N. C. 28801 U.S.A.
704/251.81N
Fax 704/$51.6381
TO: r 11 Keou h
North Carolina State University
1
College of Engineering
FACSIMILE
_F_ater Oual i,_,_y Man . - ement
ifE 88A(iI8
FROM: James T. Tanner, Jr.
NCSU Minerals Resarch.. Laboratory ..._
MESSAGE:
North Toe River
a) low flow rate (7 day, 10
b) permissible maximum lbs. of fl
1. Unimin Corp.
2. K-T Feldspar
3. Feldspar Corp.
4. Uniznin at Harris N
Total
`� t'' n ••f f„.. . .
'JAN 3 1994
FAX NO: ( 919 ) _,_y 3 3 -9919
DATE SENT: 1/3/94
NO. OF PAGES: 1
FAX NO: ( 704 ) . _251-r63.81
PHONE: ( 704 ) 251-6155
year) = 45 ou.ft/sea. = 29.25 Mg/day
ides per day
/day
s/day
224' lbs/day
ining = ,249 lbs/day
707 lbs/day
C) Fluorides mg/lit = 207 X 454 03
29.25X 10 gal X 3785 lits/gal
= 2.9 mg/lit
d) Law says these cannot be more than 1.8 mg/lit at any one time
Question: How do you arrive at the 1.8 number?
North Carolina State University is a land.granl university and a cunstituaut institution u/ The University vi North Carolina.

Page 1
Note for Farrell Keough
From: Dianne Reid
Date: Dec, 17 1993 8:20 AM
Subject: RE: 1,2-Diphenylhydrazine
To: Farrell Keough
Noz'H 'Toy .�Ver4--
Haven't forgotten you. Just didn't get to it yesterday. I'll see what I can come up with. In
the meantime, I spoke with a Mr. Jim Tanner yesterday of NC State Mineral Research. He
had a question regarding how the fluoride permit limits for some Feldspar dischargers were
calculated - seems there are several in a stretch of (I didn't write down the river) - but the total
poundage allowed per day for all dischargers is 707 lbs/day. He calculated that the instream
standard would be 2.9 mg/1 instead of 1.8 mg/1 as in WQ standards and wants to know how
the permit limits were calculated. Who should he talk with? His number is 704-251-6155.
From: Farrell Keough on Thu, Dec 16, 1993 10:43 AM
Subject: 1,2-Diphenylhydrazine
To: Dianne Reid
7`!
119r �. 1,AlC. •-)
(S
I have info on hydrazines, but not on this particular one. What can you tell me?
A''*;- "A
f h A.. 1tc-,4 cY ���- -� c �� -� \ O C et3 .
) ,c• s --)(4
3(J M 7VEck de.GA rvgn►1

Note for Carla Sanderson / � 1 VUV) 13V
)51A-6()V () 4blf
Page 1
From: Greg Nizich
Date: Thu, Nov 18, 1993 2:00 PM .
Subject: French Broad River Basin
To: Carla Sanderson
I spoke with a guy in Denver today who was asking some questions about fluoride limits in
the North Toe River. He is concerned about how it would effect a permit for a new mining
facility. He said he had heard that the assimilative capacity for Fluoride in this river was 760
lbs/day and that it was already used up. He wanted to know if this was true, and if so did it
mean that an existing permit holder would have to voluntarily give up some of their allotment
in order for a new discharge of fluoride to be permitted. Could you give him a call or
forward it to the appropriate person? His name is Mark Semenoff (seriously, careful
pronunciation is the key), his # is 303-293-6512. thanks . Greg,
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Quartz Operation
P. O. Box 588
Bakersville Hwy.
Spruce Pine, NC 28777
[phone]
Fax: [phone]
i I? (... '777:-
rl
OCT . 29 1993 OCT 25 t993
41V. OF ENV1R0N"Enf CE 1. f : ' A.1. ;SALT,
DIRECTOFCS ) - FLC 7 p ?L Satire; E
October 22, 1993
Mr. Bruce Stricklind, Jr.
Chief, Commerce Finance Center
Department of Commerce
430 Salisbury Street
Raleigh, NC 27611
Re: Industrial Revenue Bond Application
of Feldspar Corp., Mitchell County
Dear Mr. Strickland:
NOV 4 1993
WATER QUALITY
SECTION
I am writing concerning the pending request by The Feldspar
Corporation, of Spruce Pine, NC, to issue $10,000,000 in Industrial
Revenue Bonds in Mitchell County. If the bonds are approved, the
ensuing plant expansion could affect adversely the UNIMIN
Corporation's existing operations downstream of The Feldspar
Corporation.
The Quartz and Feldspar production operations of UNIMIN
Corporation utilize the North Toe River as their makeup water
source, as well as the effluent discharge locations from mineral
processing. The main activities are governed by NPDES permit
Number NC0000175. Two feldspar producers (The Feldspar
Corporation and K. T. Feldspar Corporation) also discharge their
mineral processing plant effluent into the North Toe River. All
three mineral processors discharge effluent water containing
fluorides which are utilized in the separation and purification
of the mineral products.
The State of North Carolina Department of Environment, Health and__,
Natural Resources (NCDEHNR) has authorized the discharge of 574
pounds of dissolved fluoride ion (F-) as a daily average into the
North Toe River basin at Spruce Pine. This quantity has been
allocated in its entirety between the three mineral processing
plants.
Feldspar Corporation's plan to expand production would likely
create additional fluoride -bearing effluent from their facility
in the river basin. Barring a change in the allowable level by
NCDEHNR in the river, the other two producers would likely be
adversely impacted in terms of their fluoride discharging
authorization. UNIMIN Corporation is authorized 218 pounds F- as

Page 2
a daily average in the effluent. A review of recent NPDES Permit
monthly reports made by UNIMIN shows that the actual average poundage
discharged (195 pounds) is almost 90% of the 218 pound limit.
Therefore, there is little, if any, room for adjustment.
Since UNIMIN acquired these facilities starting in 1986,
there has been approximately $20 million of investment in plant
and facilities, a great deal of which has been devoted to
environmental compliance. These steps have enabled the water
treatment facilities at the plant to extract some 99% of the
total fluoride used. This has been achieved, despite UNIMIN
being located downstream of the other two facilities, and taking
in as feed water the fluoride contained in the effluent
discharged by the other two facilities. The fluoride already
contained in the intake water complicates UNIMIN's treatment
processes.
Further, UNIMIN has been recognized by the NCDEHNR as a proactive
company in environmental matters. UNIMIN has been so recognized
with reclamation awards, and praise from the department for
positive actions in water, sediment, and air quality areas.
The UNIMIN facility has the highest employment of the three
Spruce Pine mineral producers. The wages and benefits at UNIMIN
are equal.to or exceed those at the other producers. The UNIMIN
facility provides very high purity mineral products (quartz,
feldspar, and mica) for a number of demanding applications.
Among these are ultra high purity quartz products for lighting
and semi -conductor manufacturing applications. In these areas,
UNIMIN has a substantial national and international market,
supplying these products to virtually all of the major lighting
and semi -conductor glassware manufacturers world wide. In
support of this high purity and high tech operation, UNIMIN
boasts a substantial Quality Assurance and Research and
Development staff of 20 persons in addition to another 112
production and maintenance staff involved in mining and
mineral processing. The attached sheet shows employment and
fluoride poundage allocations for the three mineral producers.
Due to UNIMIN's extremely high quality products, plant updates
and active sales efforts worldwide, the facilities have operated
continuously at full employment, despite the poor economic
conditions the last few years both in the United States and the
industrialized countries worldwide.
UNIMIN's concern is the possibility of loss of fluoride effluent
poundage which might force greater employment losses at UNIMIN
than would be gained at The Feldspar Corporation. As can be seen
from the attached chart, UNIMIN has achieved a much higher
employment level per pound of discharge than the other producers.
Thus, if fluoride poundage levels and allocation become the

Page 3
controlling factors, there is a threat that the Industrial
Revenue Bond funded expansion of Feldspar Corp. could result in a
Net Loss of jobs in Mitchell County.
We would appreciate your careful review of this information, and
consider it while acting on The Feldspar Corporation plant expansion
Industrial Revenue Bonds issue.
In addition, we would request that a copy of the application for
these Bonds be sent to our attorney, Albert L. Sneed, Jr., Post Office
Box 7376, Asheville, North Carolina 28802. If there are charges for
copying, please send us a bill.
' cerely,
C. F. Stover
Regional General Manager
cc: Mr. Jonathan B. Howes, Secretary
NC Department of Environment
Health and Natural Resources
512 No. Salisbury Street
Raleigh, NC 27611

FLUORIDE ALLOCATIONS FOR
FELDSPAR PRODUCERS
Daily Employees
Approx. Prod'n Fluoride Pounds Per Pound
Company Employees Allocation Fluoride
Feldspar Corp. 66 224 .29
K-T Feldspar 29 132 .22
UNIMIN Corp. 132 218 .69
TOTALS 245 574 .43

PROCEDURE FOR DEVELOPMENT OF NPDES PERMIT LIMITS
FOR THE FELDSPAR CORPORATION, INDUSMIN, INC.,
INTERNATIONAL MINERALS AND CHEMICAL CORPORATION
AND UNIMIN, INC.
Discussion
As a result of the reduction of total 'available fluoride (F1)
allocation wasteload to the river, the addition of another.Fl user,
and changes in production figures since allocations•were made previ-
ously, the Ashevi.;.le Regional Office developed a questionnaire on
process activiti;ek to be completed by each company discharging F1 to
the North Toe River to assist in a new allocation effort 'The
results of that.., . uestionnaire will be used to develop . individual
allocations of fluoride for each facility. Confidentiality of the
ore.production;was requested by each company. This information is on
file in the Cerit ral Office. .
The obj ectri.ve . of this process is simple, but the,meOhanics are
difficult. The:. E �vironmental Management Commission hasa policy of
providing equivalent allocations to each discharge offgoting the same
water quality 1; pited stream segment. For a more clear :y define„ �..
equivalent allocation example, let us look at BOD . tf.3_; .;rL
charges to the same segment are water y si gm quality limited-: �;�o�e� r�s�rie- w4
tive than minimum treatment requirements (i.e. secondary
domestic -type wastes and Environmental Protection Agent (' A) . 16 1993
guideline requirements for industrial process wastes} .hen
allocations ar0 set by equivalent reductions in minimum treatmen iL F��.�S
requirements. ::For illustration, say one is domestic -and the Qh�
discharge is cpmpr.sed of process industrial wastewater then the BOD
in the domestic is reduced equivalently from secondary,,levels and the
process reduced the same percentage from'the applicable EPA guideline
allowance until dissolved oxygen standards are complied with.
Equivalent allocations is a concept related.to.riparian rights.
Typically, riparian issues revolve around water use1..however, in
developing wastel.oad allocations to a common receiving;:stream,
assimilative.capacity is the resource available. Each.allocation
roust allow that qualified user a rightful share of -the resource.
Since the resource is fixed in size, then the agency esponsible for
allocation must find some way to distribute the capacity in a manner
that equivalntiy maintains each user's right. A qualified user in
this respe^t.is the riparian property owner with legal access to the
resource. It is important to recognize that assimilative capacity as
a riparian.e;ommodity is not necessarily related to water use from the
stream where, a user needs to discharge waste. In fact, because of
the nature of assimilative capacity, its allocation cannot be based
upon the quantity of water used. It would be extremely unfair and
not reflective of relative treatment burden to give•a smaller alloca-
tion to a user that for example recycles wastewaterin the production
process. The amount of final product produced would-be a much better
indicator. This same reasoning must apply when consi;�.^ring that a

- 2 -
JUL 16 1993
user's water supply may be relatively independent of the surG`r 0— FILES
waters where treated wastewater would be discharged (i.e. well, lake
on a tributary, public water system). Riparian rights are also
considered to be available to all qualified users (those with legal
access). As a result, property owners that have not in the past
exercised their right to a particular aspect of riparian resources
such as fluoride assimilative capacity cannot be refused that right
just because they chose not to use it in the past. However, "new
source" discharges have, within the EPA guideline process, been
treated somewhat differently because of treatment technology avail-
ability and the opportunity with new construction to incorporate
current environmental control systems. This provides some basis for
adjusting the allocation for new users but not for denying one. With
the respect to the issue of riparian rights, the allocation process
presented here will consider a user's right to the resource under
review, that being assimilative capacity.
In the situation under review on the North Toe River, there are
no approved EPA guidelines; therefore, the beginning basis must be
developed. With the objective of a fair and equitable reallocation
for each user, the factors used to set the allocations must be stable
and consistent. The factors must not reward poor operation or
inefficient production but, must reflect the burden of removal
accurately. With these criteria it is possible to eliminate several
factors provided in the questionnaires. First, total raw ore feed
tonnage on site is an inappropriate factor to use. Total feed
tonnage does not necessarily reflect a representative comparison of
how much fluoride wastewater will be produced. In addition and
similar in some respects, the feed tonnage to operations using
fluorides is not an appropriate factor because it may improperly give
differing Fl allocations when comparing several operations just due
to process control activities within feldspar or guartz production.
Specifically, if one company can render higher feldspar per ton of
feed to the process, using feed tonnage would therefore cause that
plant to receive a relatively lower allocation of F1 even through
actual finished product could be equal to or greater than the other
plant.
Without question, the factor most appropriate for projecting
fluoride allocations is finished feldspar and quartz products.
Finished product figures are far and away the favored factor in EPA's
guidelines. The basic concept of using production is attractive in
itself. Across a particular manufacturing category there is typic-
ally variation in production techniques, waste treatment technology,
management, market, and many other factors. The company that can
apply the most effective use of raw materials, develop or locate in
good market situations, and effectively comply with federal and local
laws is going to prosper. By using finished product figures as the
basis for wastewater controls, regulatory agencies are allowing the
other market factors to function freely. It is not the responsi-

-3-
bility of environmental agencies to develop controls which adjust
market factors.
The previous discussion clearly illustrates why exact quantities
of chemicals used in a process should not be. an allocation factor,
but it is important to briefly review the use of hydrof loric (HF)
acid in feldspar and high purity quartz production. The use of this
chemical is a critical factor in determining a relative weighting
factor for feldspar verses quartz production.
There is considerable variability in the amount of HF each
company uses or projects it will use to process quartz. This is a
reflection of two basic factors: 1) variations of process feeds and
2) a lack of actual operating knowledge about the process. The
second factor is certainly an important issue in developing a F1
wasteload credit for quartz production. Only IMC is today producing
high purity quartz. Both Feldspar and Unimin have fairly solid plans
underway to install quartz production. Evenconsidering variability
in production, it is certain that the reliability of the data pro-
vided from a firm already producing a product is higher than that of
a company not producing the same product. In this same respect, the
confidence placed in projections from a company on the verge of
adding the process will be higher than that placed in figures from a
company in the initial stages of developing a quartz production
program. This might be better illustrated by looking at the quartz
data in the following table:
Quartz Production Information
Final Pro- Gals.
Quartz Feed HF Solution duction-- HF/tons
Tonnage Used % Actual HF Quartz Quartz
Facility tons/mo. gal/mo. In Solution tons/mo. Produced
Feldspar 1910. 24000 70 1150 20.8
Indusmin 6424 327000 70 4800 68.1
IMC 3319 30135 70 2766 10.9
Unimin 1955 47500 70 1750 27.1
Clearly, both the level of quartz output and the HF needed as.
provided byIndusmin is out of
proportion to the other f ackltes�•:4 tis;,
Therefore, those figures should not be used in making a. weighting i
•factor for quartz production. z :'.,; "
Sok-

-4-
In producing a final allocation factor, it is necessary to
weight quartz production higher than feldspar production. Even
though HF is used in the quartz process to "polish" or increase
quartz purity, HF used per ton of product is much higher for quartz
production than for feldspar production. Thus, fluoride waste from
the quartz operation will contain higher quantities of F1, and
therefore, represent a greater treatment burden. To develop the
weighting factor, the feldspar data must be examined:
Facility
Feldspar
Indusmin
IMC
Unimin
Feldspar Production Information
Feldspar Feed
Tonnage HF Used
tons/mo. gal/mo.
34233
24372
22003
8833
2252
2070
3190
1585
Feldspar
Finished
tons/mo.
21181
17043
10710
5300
Gal HF (70%) Feed Tonnage
Per Ton to Feldspar
Feldspar Produced
Produced- S
0 .i3O It'
19ti2.1
0.30 �� 1.7
Currently, only Unimin is not producing feldspar. However,
because HF used and the feed tonnage to production tonnage ratio is
close to those shown for the other three companies, the UNIMIN
information will be considered in developing a weighting factor. HF
used per ton produced for feldspar averages 0.23 gal/ton (0.11 to
0.30 range). For quartz production this same factor averages 19.6
gal/ton (range 10.9 to 27.1, excluding the Indusmin information). On
the basis of this comparison and without respect to water use,
significantly more fluoride waste is created for every ton of high
purity quartz produced than is produced for every ton of finished
feldspar. Thus, when dividing the available fluoride wasteload, al
greater amount of fluoride (mass) should be allowed per ton of high
purity quartz than per ton of finished feldspar.
To decide upon a weighting factor for quartz production, it will
be necessary to examine several issues. Simply applying the HF use
ratios would result in what may be an excessive weighting factor--
19.6 divided by 0.23 equals 85.2 using the range of HF to quartz
produced ratios, 10.9 to 27.1, and the HF to feldspar produced
ratios, 0.11 to 0.30, a "calculated" weighting factor ranges from 246
to 36. This shows a variation of almost 7 to 1. It is also clear
that some of the waste handling technologies available for dealing
with fluoride wastewater apply to both the feldspar and quartz waste
streams. Recycle of fluoride contaminated water is an option that is
relatively independent to fluoride concentrations, provided that
wastewater containing fluoride is reused only in conjunction with

-5-
fluoride processes (fluoride interference with other ore processing
activities). Therefore, while the waste handling demands for pure
quartz are higher than for feldspar, that demand is likely to be
lower than indicated by HF use information. Another factor available
that points to this conclusion is that IMC which has the only operat-
ing high purity quartz system, also has the lowest mass discharge of
three facilities. It is true, however, that IMC's wastewater control
system represents what the Regional Office considers the standard for
the industry. What these points show is that there are technologies
which can, when applied with a strong management commitment, effec-
tively reduce the quantity of fluoride released to the receiving
waters.
The final issue that must be discussed in recommending a weight-
ing factor, is certainly equal to those just noted: i.e.,the real
world impact of the facilities receiving the allocations. In this
matter we are dealing, with four separate industrial corporations
involved (or soon to be involved) as competitors in the same busi-
ness, all located in the same general area, and all sharing a common
riparian resource. Real and perceived conflicts make negotiating
very difficult. Add to this a common view from all the companies
that the fluoride standard is too restrictive and the recent emer-
gence of the fourth competitor and you have a sensitive environment
in which existing allocations must be reduced. The only way to
examine this aspect of the allocation process is to calculate fluo-
ride distributions for a variety of weighting factors. In doing so
it will be necessary to provide the distributions over the entire
range of near term configurations:
Configuration I - Unimin Corporation not producing feldspar or
Configuration II
Configuration III
Configuration IV
quartz. The Feldspar Corporation operating
without the planned high purity quartz
facility, Indusmin at current feldspar
production, and IMC producing feldspar and high
purity quartz at current levels.
-'Unimin Corporation not producing feldspar or
quartz, The Feldspar Corporation operating with
the high purity quartz facility and Indusmin,
Inc. and IMC as described in I.
- Unimin Corporation producing feldspar and quartz,
and other three companies as described in I.
Unimin Corporation as in III, The Feldspar �
Corporation producing high purity quarti:� %�'
other two companies as described irI:.- ''"`�
i j .; r
c.E 1995
�;RAL Ft��s
CF �

Configuration V - Unimin Corporation as in III, The Feldspar
Corporation and Indusmin, Inc. producing high
purity quartz and IMC as described in I.
Configuration VI - The Feldspar Corporation, IMC, Indusmin, Inc.
and Unimin Corporation as described in V and
Indusmin, Inc. with a 50% expansion of the
feldspar plant.
The process in developing a specific allocation can be described
as follows:
A. Calculate an allocation factor (Af) for each facility
within a specific configuration:
Af =F+Wf x Q
where:
Af = Allocation factor,
F = Finished feldspar in tons per month (information
supplied by the company),
Wf = Weighting factor for quartz production,
Q = Finished high purity quartz, tons/mo.
B. Project a percentage share (PS) of available fluoride for
each facility under each configuration.
PS = Af x 100
SUM Af
where:
SUM Af = sum of all four Af ' s for a particular
configuration.
C. Calculate the specific fluoride allocation (A-lbs/day
each company.
A = PS x AW
where:
-7775°
s; s
100 ' `:;,b. j6 1"
V
•
AW = Available wasteload to North Toe River = 574
lbs/day.

-7-
For comparison purposes the following information is provided:
Facility Fluoride Information
Facility
Unimin
Feldspar
Indusmin
IMC
F1 Dis-
charged
Maximum
Fl Current % Of Monthly % Of Most Current % Of
Permit Limits Total 1985-86 Total F1 Allocation Total
All Figures
lbs/day
*
279.1 38 256 38 218 38
220.3 30 261 39 172 30
235.0 32 160 23 184 32
Monthly Average
*Unimin projects 125#/day.

-8-
Fluoride and Quartz Production Summary
Facility
Unimin
Feldspar
Indusmin
IMC
*50% expansion at Indusmin.
Facility
Wf = 1
Unimin
Feldspar
Indusmin
IMC
Wf = 85
Unimin
Feldspar
Indusmin
IMC
Wf = 6
Unimin
Feldspar
Indusmin
IMC
Finished Feldspar
tons/mo.
•
5300
21181
17043 (25443*)
10710
Finished Quartz
tons/mo.
Comparison Wasteloads Under Configuration I
AF
0
21181
17043
13476
51700
0
21181
17043
245820
284044
0
21181
17043
27306
65530
PS (%)
0
41
33
26
100
0
7
6
87
100
0
32
26
42
100
1750
1150
500
2766
A (#/day)
0
235
189
150
574
0
40
34
500
574
0
183
149
242
7 4-

-9_
Comparison Wasteload Under Configuration IV
Wf = 1
Unimin 7050 -12 69
Feldspar 22331 37 212
Indusmin 17043 28 161
IMC 13476 23 132
59900 100 574
Wf = 6
Unimin 15800 18 103
Feldspar 28081 32 183
Indusmin 17043 19 109
IMC 27306 31 179
88230 100 574
These five comparison allocation distributions are presented as
illustration of the effects of different weighting factors (Wf) . In
reviewing this issue, the Division of Environmental Management staff
examined distributions over all four configurations with Wf's of 1,
2, 3, 6, 10, and 85. In comparing all these figures with the
Facility Fluoride Information table and considering all the issues
disct.ssed in this report, it was concluded that a Wf of six (6)
represented a reasonable weighting of quartz production fluoride
waste burden and produces a fair fluoride allocation distribution
that is achievable with existing technologies. It is clear from the
comparisons presented that the range of possible weighting factors
represents, at the low end, an unfair situation to quartz producers
and a.t the high end an unrealistic disruption in the previous alloca-
tion pattern. A value of six for Wf is something of a middle ground
position, providing each user a piece of the allocation pie large
enough to permit compliance.
In applying this approach there are some issues which must be
addressed. Permits should not be based on projected production
activities, but revisions to the distribution of F1 allowable should
be adjusted when the new process is added (i.e. configuration
shifts). Initially, no high purity quartz production at Feldspar,
Unimin or Indusmin will exist, and the allocation -would not change
until these processes came on line. Because Unimin does no=-,,
produce feldspar, lds ar no allocation for `' ` �r`' - P r F1 would apply until s} ���i�od���
tion exists. The following is a table showing allocationitthT4 r_
do

Allocations Proposed
Facility AF PS (%) A (#/day)
Configuration I
Unimin 0 0 0
Feldspar 21181 32 183
Indusmin 17043 26 149
IMC 27306 42 242
65530 100 574
Configuration II
Unimin 0 0 0
Feldspar 28082 39 224
Indusmin 17043 23 132
IMC 27306 38 218
72431 100 574
Configuration III
Unimin 15800 19 109
Feldspar 21181 26 149
Indusmin 17043 21 121
IMC 27306 34 195
81330 100 574
Configuration IV
Unimin 15800 18 103
Feldspar 28081 32 183
Indusmin 17043 19 109
IMC 27306 31 179
88230 100 574
Configuration V
Unimin 15800 17 98
Feldspar 28081 • 31 178
Indusmin 20043 22 126
IMC 27306 30 172
91230 100 574
Configuration VI
Unimin 15800 16
Feldspar 28081 28
Indusmin 28443 29
IMC 27306 27
99630 100

-11-
Unimin Corporation's TSS effluent limitations will remain 20
mg/1 daily average, 30 mg/1 daily maximum until the Company starts to
produce feldspar. The limits will then change to 707 lbs/day and
1414 lbs/day daily average and daily maximum. These limits were
developed using the EPA draft development document - Mineral Mining
and Processing Industry.
589 tons x 0.6 lb x 2000 lbs = 707 lbs
day of raw ore 1000 lbs. product ton day of TSS
Effluent limitations for TSS, pH and turbidity and flow for The
Feldspar Corporation, Indusmin, Inc. and IMC are the same as those
limits proposed in the last wasteload allocation dated May 5, 1986.
A copy of the proposed effluent limits for Configurations I - VI
for each company is attached.