PHOSPHORIC ACID LISTING BACKGROUND

DOCUMENT FOR THE INORGANIC CHEMICAL

LISTING DETERMINATION

This Document Contains No Confidential Business Information

August, 2000

U.S. ENVIRONMENTAL PROTECTION AGENCY

ARIEL RIOS BUILDING
1200 PENNSYLVANIA AVENUE, N.W.
WASHINGTON, D.C. 20460
 TABLE OF CONTENTS

1. SECTOR OVERVIEW . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
1.1 SECTOR DEFINITION, FACILITY AND LOCATIONS . . . . . . . . . . . . . . . . . . . 1
1.2 PRODUCTS, PRODUCT USAGE AND MARKET . . . . . . . . . . . . . . . . . . . . . . . 3
1.3 PRODUCTION CAPACITY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
1.4 PRODUCTION, PRODUCT AND PROCESS TRENDS . . . . . . . . . . . . . . . . . . . 4

2. DESCRIPTION OF MANUFACTURING PROCESS . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

2.1 PRODUCTION PROCESS DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
2.2 PRODUCTION TRENDS, CHANGES AND IMPROVEMENTS . . . . . . . . . . . . 5
2.3 PROCESS FLOW DIAGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3. WASTE GENERATION AND MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3.1 WASTES OUTSIDE THE SCOPE OF THE CONSENT DECREE . . . . . . . . . . . . 7
3.2 SUMMARY OF WASTE GENERATION PROCESS . . . . . . . . . . . . . . . . . . . . . . 7
3.2.1 Arsenic Filter Cake . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11
3.2.2 Caustic Scrubber Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
3.2.3 Process Acid Leaks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
3.2.4 Phosphorous Acid Spills . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
3.2.5 Clean-up Washdown Water . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.2.6 Spent Mist Eliminator Packing (Filters) . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.2.7 Combustion Chamber Slag . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.2.8 Recycled Weak Phosphoric Acid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.2.9 Spent Filters (from purification) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18
3.2.10 Rubber Liners of Product Storage Tanks . . . . . . . . . . . . . . . . . . . . . . . . . . 19
3.2.11 Spent Filters for Product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.2.12 Off-Spec Phosphoric Acid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
3.2.13 Spent Activated Carbon . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
3.2.14 Spent Filters for Off-spec Product . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
3.2.15 Wastewater Treatment Sludge . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

Appendix A: Summary of Waste Generation and Management

Inorganic Listing Determination Phosphoric Acid

Listing Background Document i August, 2000
 LIST OF TABLES

Table 1.1 - Phosphoric Acid Producers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

Table 3.1 - Wastes Generated from the Production of Phosphoric Acid by the Dry Process . . . . . . . 9
Table 3.2 - Waste Management Summary for Arsenic Filter Cake . . . . . . . . . . . . . . . . . . . . . . . . . 11
Table 3.3 - Waste Management Summary for Caustic Scrubber Water . . . . . . . . . . . . . . . . . . . . . . 12
Table 3.4 - Waste Management Summary for Process Acid Leaks . . . . . . . . . . . . . . . . . . . . . . . . . 13
Table 3.5 - Waste Management Summary for Phosphorous Acid Spills . . . . . . . . . . . . . . . . . . . . . . 14
Table 3.6 - Waste Management Summary for Clean-up Washdown Water . . . . . . . . . . . . . . . . . . . 15
Table 3.7 - Waste Management Summary for Spent Mist Eliminator Packing (Filters) . . . . . . . . . . . 16
Table 3.8 - Waste Management Summary for Combustion Chamber Slag . . . . . . . . . . . . . . . . . . . . 17
Table 3.9 - Waste Management Summary for Recycled Weak Phosphoric Acid . . . . . . . . . . . . . . . 17
Table 3.10 - Waste Management Summary for Spent Filters (from purification) . . . . . . . . . . . . . . . . 18
Table 3.11 - Waste Management Summary for Rubber Liners of Product Storage Tanks . . . . . . . . 19
Table 3.12 - Waste Management Summary for Spent Filters for Product . . . . . . . . . . . . . . . . . . . . . 20
Table 3.13 - Waste Management Summary for Off-Spec Phosphoric Acid . . . . . . . . . . . . . . . . . . . 21
Table 3.14 - Waste Management Statistics for Spent Activated Carbon . . . . . . . . . . . . . . . . . . . . . 21
Table 3.15 - Waste Management Statistics for Spent Filters (for filtering off-spec product) . . . . . . . 22
Table 3.16 - Waste Management Statistics for Wastewater Treatment Sludge . . . . . . . . . . . . . . . . . 23

LIST OF FIGURES

Figure 1.1 - Geographical Distribution of Phosphoric Acid Producers . . . . . . . . . . . . . . . . . . . . . . . . 2

Figure 2.1 - Phosphoric Acid Process Flow Diagram . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Inorganic Listing Determination Phosphoric Acid

Listing Background Document ii August, 2000
1. SECTOR OVERVIEW

1.1 SECTOR DEFINITION, FACILITY AND LOCATIONS

In this study, EPA examined the wastes from the production of Phosphoric Acid by the dry process.1
Phosphoric Acid is produced in the United States by eight facilities utilizing this method. Table 1.1
presents the name and location of the manufacturers.2 Figure 1.1 shows the geographical locations of
the eight facilities presented in Table 1.1.General Listing Background Document For the Inorganic
Chemical Listing Determination, August 2000.

Table 1.1 - Phosphoric Acid Producers

Facility Name Facility Location

1. Albright & Wilson Company (Albright & Wilson) 2151 King Street
Charleston, SC 29405

2. FMC Corp. (FMC, NJ) 500 Roosevelt Avenue

Carteret, NJ 07008

3. FMC Corp. (FMC, KS) 440 North 9th Street

Lawrence, KS 66044

4. Rhodia Inc. (Rhodia, PA) 2300 South Pennsylvania Avenue

Morrisville, PA 19067

5. Rhodia Inc. (Rhodia, TN) 4600 Centennial Boulevard

Nashville, TN 37209

6. Solutia Inc.* (Solutia, GA) 1610 Marvin Griffin Road

PO Box 1473
Augusta, GA 30903

7. Solutia Inc. (Solutia, MI) 5045 West Jefferson Avenue

Trenton, MI 48183

8. Solutia Inc. Carondelet Plant (Solutia, IL) 500 Monsanto Avenue

East St. Louis, MO 62206

* The Solutia, GA facility stopped producing phosphoric acid in March, 1998.

1
This was required by the consent decree as described in General Listing Background
Document For the Inorganic Chemical Listing Determination, August 2000.
2
EPA, RCRA §3007, Survey of Inorganic Chemicals Industry

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 1 August, 2000
 Figure 1.1 - Geographical Distribution of Phosphoric Acid Producers 1

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1
See Table 1.1 for facility name and location.

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 2 August, 2000
1.2 PRODUCTS, PRODUCT USAGE AND MARKET

The chemical formula for phosphoric acid is H3PO4. As a product, phosphoric acid is produced as a
concentrated liquid acid as opposed to crystalline form. Phosphoric acid has a molecular weight of
98.0 grams (g)/mol, and exists in a solid, unstable form that melts at 42.3 degrees Celsius ( C). It
readily solublizes in water to form an acidic solution.

Phosphoric acid is used in fertilizers, soaps and detergents, inorganic phosphates, pickling and
rust-proofing of metals, in pharmaceuticals, sugar refining, gelatin manufacturing, water treatment,
animal feeds, electropolishing, conversion coatings for metals, dental cements, acid catalysts, in foods
and carbonated beverages, and as a laboratory reagent. It is also used in direct acid treatment of metal
surfaces, manufacture of fire control agents, antifreeze, catalysts, drilling muds, phosphors, refractories,
and dyeing textiles. Phosphoric acid is also registered as a bactericide and disinfectant. It is used to
disinfect dairy farm milk handling facilities, equipment and dairy animals, and food processing water
systems. It is also used to disinfect food processing/handling areas, kitchens, and bathrooms. It may
also be used in eating establishments for sterilizing equipment and utensils. Agriculturally, phosphoric
acid is registered as an adjuvant.3

The historical market for phosphoric acid has shown a negative growth of approximately minus 1.2
percent per year in the period spanning the years 1989-1998 thus accounting for the production
reduction and consolidation moves made by several manufacturers of this product. Future growth of
the market from the present time until the year 2003 is expected to reverse this decline at the rate of
anywhere from 0 to 1 percent per year. Market demand for this product was approximately 350,000
tons in 1998. 4

Published statistics for the production of phosphoric acid are lumped together with the production of
elemental phosphorous. The reason for joining these statistics is that most of the elemental phosphorous
that is mined is converted into phosphoric acid. The current breakdown of phosphorous usage (these
figures include demand for elemental phosphorus and purified wet acid on a phosphorus-equivalent
basis, as well as average annual exports of about 20,000 tons) is as follows: Phosphoric Acid, 65
percent (sodium phosphates, 55 percent; direct phosphoric acid sales, 25 percent; calcium, ammonium
and potassium phosphates, 20 percent); direct reaction chemical production, including phosphorus
trichloride, pentasulfide and pentoxide, 35 percent. 5

1.3 PRODUCTION CAPACITY

3
Environmental Defense Fund Scorecard Home Page, www.scorecard.org/chemical-
profiles/html/phosphoric_acid.html
4
See www.chemexpo.com/news/newsframe.cfm?framebody=/news/profile.cfm.
5
Id.

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 3 August, 2000
According to ChemExpo,6 domestic capacity for elemental phosphorus or purified wet-process
phosphoric acid (PWA) was 355,625 short tons in 1999. Commercial production of elemental
phosphorus is from prepared phosphate rock, which is reacted with coke and silica in an electric
furnace. Most of the phosphorus produced is converted to furnace phosphoric acid through reaction
with air and water in burning towers.

1.4 PRODUCTION, PRODUCT AND PROCESS TRENDS

The shutdown of high-cost capacity during the past few years and a consolidation in the phosphorus
and phosphates business are expected to firm up industrial phosphates and other segments of the
market that have suffered long periods of losses. Phosphorus chemicals are growing at a modest pace,
and phosphorus trichloride, a herbicide precursor, is increasing at a rate well above the overall trend
line.

Traditional furnace-derived phosphoric acid is likely to continue to lose ground to cost-effective purified
wet process acid, although at a lesser rate. Well over half of elemental phosphorus remains dependent
on dry process phosphoric acid, a market that is projected to increase only slightly if at all.

Consolidation has long been expected in the U.S. market for phosphorus and derivatives, but the
changes announced in May 1998 amount to a major shift in the industry. The new 50-50 company
formed by FMC and Monsanto/Solutia includes the companies' phosphorus chemical operations in
North America and Brazil. It will initially have 12 manufacturing sites and more than $600 million in
sales. The takeover of Albright & Wilson by Rhodia makes the French company the global leader in
phosphates and gives it a leading position in the European market for sodium tripolyphosphate. 7

2. DESCRIPTION OF MANUFACTURING PROCESS

2.1 PRODUCTION PROCESS DESCRIPTION

This section provides the general process flow and typically generated residuals for dry process
phosphoric acid production. Liquid phosphorous and pure oxygen are fed to a combustion furnace
where the phosphorous and oxygen react to form phosphorous pentoxide. The high temperature in the
combustion furnace causes slow erosion of the refractory brick which must be removed and replaced
periodically. The phosphorous pentoxide vapor 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, which is weak phosphoric acid, is returned to the condenser
to recover a strong phosphoric acid. The excess scrubber air is vented and releases an airborne waste
stream to the atmosphere, which contains trace phosphoric acid. The scrubber system contains filters,

6
Id.
7
Id.

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 4 August, 2000
which are changed periodically. 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 (H2S), and the remaining waste is a filter cake sludge typically
sent to an off-site Subtitle C landfill. The spent filters from purification are changed periodically and are
also sent to an off-site Subtitle C landfill. Any spills or leaks from phosphoric acid storage tanks are
collected in contained areas and pumped to the on-site wastewater treatment system.

2.2 PRODUCTION TRENDS, CHANGES AND IMPROVEMENTS

There is no indication of upcoming production changes from current practices.

2.3 PROCESS FLOW DIAGRAM

The following process flow diagram (Figure 2.1) is general and may not account for specific process
variations used by listed manufacturers of phosphoric acid. This flow diagram illustrates the major
process steps described above and identifies wastestreams at their point of generation in the process.

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 5 August, 2000
 Figure 2.1 - Phosphoric Acid Process Flow Diagram

Water

Vent to
Caustic
Atmosphere
Vent to Scrubber
Atmosphere Water

Spent Mist
Eliminator Scrubber Sodium Scrubber
Packing Hydrosulfide
Filter Rubber Liners
(Filters)
Aid of Product
Recycled Weak Recycled Weak
Phosphoric Acid Phosphoric Acid

Oxygen
P 2O 5 Product
Combustion
Condenser Purification Filtration Storage Product
Liquid Furnace
Tanks
Phosphorous

Refractory Combustion Arsenic Spent Off-spec

Spent Product
Brick Chamber Filter Filters Phosphoric
Filters
Slag Cake Acid
Filtration Process Acid Leaks
Recycled Acid
Phosphoric Acid Spills
(Off-spec)
Clean-up and Washdown Water

Spent Spent
Filters Activated
Carbon

6
3. WASTE GENERATION AND MANAGEMENT

Appendix A presents a complete summary of the wastestreams generated at each of the facilities in the
phosphoric acid sector, the volume of the wastestreams generated in MT/yr, and the associated final
management step. Section 3.1 discusses wastes reported by the facilities, in the RCRA §3007
questionnaire, that are outside the scope of the consent decree. Section 3.2 presents a discussion of
each wastestream and identifies where in the process the waste is generated, the subsequent
management steps employed at each facility, a characterization of the wastestream, the generated
volume, and the result of initial risk screening analysis.

3.1 WASTES OUTSIDE THE SCOPE OF THE CONSENT DECREE

EPA does not consider some kinds of debris and plant component materials to fall within the scope of
the consent decree, including refractory brick. This material is considered to be a structural component
of the plant rather than a waste from the process production.

3.1.1 Refractory Brick

The refractory brick is generated infrequently (6-18 months) when a rebuild or repair of the combustion
furnace is required. Only two facilities reported generating refractory brick in 1998. However, other
facilities have generated this waste in the past. Rhodia, PA generated 180 MT in 1997 and Solutia,
GA generated 90 MT in 1995. Some facilities are switching to steel towers and will cease generating
this waste.

3.2 SUMMARY OF WASTE GENERATION PROCESS

Eight facilities manufacturing this chemical in 1998 generated approximately 850 MT of waste.
According to the RCRA §3007 questionnaire the facilities that produced phosphoric acid via the dry
process in 1998 reported generating varying numbers of wastestreams. Even through their processes
are basically the same there are variations in the number of wastestreams at each facility. For example,
Rhodia, PA reported generating two wastestreams and Solutia, MI reported generating ten
wastestreams.

Together, the different manufacturing process units produced sixteen different wastestreams. The units
and wastestreams are as follows:

Combustion Furnace:

• Refractory Brick
• Combustion Chamber Slag

Scrubber:

• Spent Mist Eliminator Packing (Filters)

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 7 August, 2000
• Recycled Weak Phosphoric Acid
• Caustic Scrubber Water

Purification and Filtration:

• Arsenic Filter Cake

• Spent Filters (from purification)
• Spent Filters for Off-spec Product
• Spent Activated Carbon for Off-spec Product

Product Storage and Maintenance:

• Rubber Liners of Product Storage Tanks

• Off-Spec Phosphoric Acid
• Process Acid Leaks
• Phosphoric Acid Spills
• Clean-up Washdown Water
• Spent Filters for Product
• Wastewater Treatment Sludge

Table 3.1 provides a summary of the identified wastestreams generated by facilities.

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 8 August, 2000
 Table 3.1 - Wastes Generated from the Production of Phosphoric Acid by the Dry Process
Facility Arsenic Caustic Process Phosphoric Clean-up Spent Mist Combustion Recycled
Filter Scrubber Acid Acid Spills and Eliminator Chamber Weak
Cake Water Leaks Washdown Packing Slag Phosphoric
Water (Filters) Acid

Albright & Wilson x x x

FMC, NJ x x x x

FMC, KS x x x x x

Rhodia, PA x

Rhodia, TN x x x

Solutia, GA x x x x

Solutia, MI x x x x

Solutia, MO x x x x x

Inorganic Listing Determination Phosphoric Acid

Background Listing Document, Draft 9 August, 2000
 Table 3.1 - Wastes Generated from the Production of Phosphoric Acid by the Dry Process (continued)

Facility Spent Rubber Spent Filters Off-spec Spent Spent Wastewater Refractory
Filters Liners of for Product Phosphoric Activated Filters Treatment Brick
(for Sludge
(from Product Acid Carbon
filtering
purification Storage off-spec
) Tanks product)

Albright & x
Wilson

FMC, NJ

FMC, KS

Rhodia, PA x

Rhodia, TN x x x

Solutia, GA x x x x

Solutia, MI x x x x x x

Solutia, MO x x x

Inorganic Listing Determination Phosphoric Acid

Listing Background Document 10 August, 2000
3.2.1 Arsenic Filter Cake

Waste Generation

The phosphoric acid from the condenser goes to a purification process, where filter aid and sodium
sulfide solution or hydrogen sulfide gas are added to remove arsenic impurities that are present in the
elemental phosphorous. The most significant solid waste generated weekly from the purification
process of phosphoric acid is arsenic filter cake. All eight facilities reported generating filter cake. In
1998, seven facilities reported generating 613.94 MT of arsenic filter cake.

The arsenic filter cake is generated at various rates from 6.10 MT/yr to 248.0 MT/yr.

Waste Management

All facilities managed this waste the same way. The filter cake is stored in containers, sent off-site for
stabilization and then sent to an off-site Subtitle C landfill as a hazardous waste. Table 3.2 presents the
generated volume and the final management step used by the facilities for this wastestream.

Table 3.2 - Waste Management Summary for Arsenic Filter Cake

Final Management # of Wastestreams # of Wastestreams Total Volume

with Reported with (MT/yr)
Volumes Unreported Volumes

Disposal off-site Subtitle 7 1* 613.94

C landfill
* Solutia, GA reported generating 88.6 MT in 1997.

Waste Characterization

As part of the analytical phase of the listing determination, the Agency collected “familiarization”
samples of arsenic filter cake from two facilities - Albright & Wilson and FMC, NJ. The following are
results from this sampling and from data reported by the facilities in the RCRA §3007 Questionnaire.

This waste carries hazardous waste codes D002 (corrosive) and D004 (arsenic). One facility reported
this wastestream to be a characteristic waste carrying hazardous waste code D007 (chromium). The
chemical constituents that were detected include arsenic, barium, lead, zinc, chromium, nickel and
phosphorous.

Results of Initial Risk Screening Analysis

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 11 August, 2000
This waste was not sampled and did not warrant a risk assessment for the following reasons:

1. The waste exhibits one or more hazardous waste characteristic.

2. The waste is characteristically hazardous waste that is managed as hazardous from the point of
generation through disposal including meeting applicable land disposal restriction (LDR)
standards.

3.2.2 Caustic Scrubber Water

Waste Generation

The filtered acid is free of arsenic but still contains a trace level of H2S which needs to be removed by
sparging air through the acid. The vent from the purification process is scrubbed in the hydrogen sulfide
scrubber generating caustic scrubber water. Three facilities reported generating caustic scrubber
wastewater.

The caustic scrubber water is generated at various rates from 36.0 MT/yr to 1,080 MT/yr.

Waste Management

The wastestream was listed by Albright & Wilson plant as non-hazardous waste and was discharged
together with all the other facility wastewater to the facility’s centralized tank-based wastewater
pretreatment system before being discharged to a publically owned treatment works (POTW). Two
facilities reported that it was returned as makeup solution to the purification process. Table 3.3
presents the generated volume and the final management step used by the facilities for this wastestream.

Table 3.3 - Waste Management Summary for Caustic Scrubber Water

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

POTW Discharge 1 0 36.0

Recycled back to process 2 0 1350.0

Waste Characterization

Facilities did not characterize this wastestream.

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 12 August, 2000
Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment for the following reasons:

1. The wastewater is managed in enclosed systems and, therefore, no exposure pathway exists.
2. Discharge to a POTW is exempt from RCRA regulations and regulated extensively under the
Clean Water Act.
3. The recycled wastewater has no potential for release to the environment.

3.2.3 Process Acid Leaks

Waste Generation

This wastestream is generated at storage area as spills or leaks from storage tanks. Two facilities
reported generating this wastestream.

Waste Management

Prior to discharge, both facilities collected this waste in tanks and neutralized it. After that, the Rhodia,
TN plant discharged the waste under NPDES permit and FMC, KS facility recycled this wastestream
in an acid furnace. Table 3.4 presents the generated volume and the final management step used by
the two facilities for this wastestream.

Table 3.4 - Waste Management Summary for Process Acid Leaks

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

NPDES discharge 1 0 25.0*

Recycled 1 0 2.0

* Approximately 25.0 MT from all processes at Rhodia, TN. The waste volume from just the
phosphoric acid process was not available.

Waste Characterization

The FMC, KS facility reported it as non hazardous waste.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment for the following reasons:

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 13 August, 2000
1. When recycled, no exposure pathway of concern exists.
2. Discharges to surface water under an NPDES permit are exempt from RCRA regulations and
regulated extensively under the Clean Water Act.

3.2.4 Phosphorous Acid Spills

Waste Generation

This wastestream is generated occasionally in phosphoric acid production area during unloading
process. Three facilities reported generating this wastewater.

Waste Management

Two facilities reported that prior to NPDES discharge, the waste is collected in tanks or roll-on/off
bins, and neutralized in on-site wastewater treatment plants (WWTP). No phosphoric acid is
discharged from the WWTP. At one facility (Solutia, MO) the spills of phosphoric acid to the ground
are neutralized and sent off-site for disposal at a Subtitle D landfill. Table 3.5 presents the generated
volume and the final management step used by the facilities for this wastestream.

Table 3.5 - Waste Management Summary for Phosphorous Acid Spills

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

NPDES discharge 2 0 6.25*

Disposal off-site Subtitle 1 0 0.5

D landfill
* Includes 4.5 MT of waste generated by Solutia, GA which stopped producing phosphoric acid in
March, 1998.

Waste Characterization

All three facilities reported this wastestream to be a characteristic waste carrying hazardous waste code
D002 (corrosivity). Solutia, MI reported arsenic, barium, zinc, copper, lead, and mercury.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment for the following reasons:

1. Discharges to surface water under an NPDES permit are exempt from RCRA regulations and
regulated extensively under the Clean Water Act.
2. The characteristically hazardous waste (D002) is managed as hazardous from the point of

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 14 August, 2000
 generation through disposal including meeting applicable LDR standards.
3. Very small volumes are generated.

3.2.5 Clean-up Washdown Water

Waste Generation

This wastestream is generated at various points in the phosphoric acid generation process at one
facility. This wastewater includes clean-up water and any spilled or leaked phosphoric acid from
storage tanks.

Waste Management

Clean-up and washdown water from across the unit is collected in a sump and discharged to the
wastewater treatment system (tanks) for neutralization before being discharged to POTW. Table 3.6
presents the final management step used by the facility for this wastestream.

Table 3.6 - Waste Management Summary for Clean-up Washdown Water

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

POTW 0 1 Not Reported

Waste Characterization

The facility did not characterize this wastestream.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment because discharges to POTW are
exempt from RCRA regulations and regulated extensively under the Clean Water Act.

3.2.6 Spent Mist Eliminator Packing (Filters)

Waste Generation

The scrubber system contains filters, which when spent make up this wastestream. Six facilities
reported generating this waste. Five facilities generated this wastestream in 1998 and Solutia, GA
generated 15 MT in 1995.

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 15 August, 2000
Waste Management

The packing material from the mist eliminator is changed periodically every 6-18 months. Four facilities
stored this waste in containers, neutralized it and sent it off-site to a Subtitle D landfill with liner and
leachate collection. After rinsing, the spent filters are disposed by FMC, NJ as non-hazardous waste in
a Subtitle C landfill and FMC, KS sent the filters off-site for metal recovery. Table 3.7 presents the
generated volume and the final management step used by the five facilities for this wastestream.

Table 3.7 - Waste Management Summary for Spent Mist Eliminator Packing (Filters)

Final Management # of Wastestreams # of Wastestreams Total Volume

with Reported with (MT/yr)
Volumes Unreported Volumes

Disposal off-site Subtitle 3 1* 24.4

D landfill

Disposal off-site Subtitle 1 0 2.0

C landfill

Off-site Metal Recovery 1 0 2.0

* Solutia, GA reported generating 15.0 MT in 1995.

Waste Characterization

Facilities did not characterize this wastestream.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment for the following reasons:

1. The filters are not expected to accumulate chemicals at concentration level of concern because
they are for condensation, they are not designed to absorb constituents.
2. One facility manages the filters at a Subtitle C landfill.
3. One facility sends them for metal recovery, no exposure pathway exists.
4. The waste is treated to remove or immobilize any low levels of phosphoric acid or arsenic that
may be presented in the wastes.

3.2.7 Combustion Chamber Slag

Waste Generation

The chamber slag is generated infrequently (6-18 months) when a rebuild or repair of the combustion
furnace is required. Only Solutia, MO, reported generating a small amount of this solid waste.

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 16 August, 2000
Waste Management

This waste is placed in containers and sent off-site to a Subtitle C incineration facility. Table 3.8
presents the generated volume and the final management step used by the facility for this wastestream.

Table 3.8 - Waste Management Summary for Combustion Chamber Slag

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

Off-site Hazardous Waste 1 0 0.1

Incineration

Waste Characterization

The facility reported this wastestream to be a characteristic waste carrying hazardous waste code D002
(corrosivity). The waste contains arsenic, barium, lead, nickel, chromium, zinc and traces of cadmium
and silver.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment because the waste is
characteristically hazardous waste that is managed as hazardous from the point of generation through
disposal including meeting applicable LDR standards.

3.2.8 Recycled Weak Phosphoric Acid

Waste Generation

All eight facilities reported recycling weak phosphoric acid produced in the scrubber as a necessary
part of production process in their process description submitted with their RCRA §3007
questionnaire. However, only five also reported it as a wastestream. FMC, NJ generated a similar
wastestream after washing spent scrubber filters (8 MT/yr) and recycles this waste together with the
scrubber water.

The recycled weak phosphoric acid is generated at various rates from 9,000 MT/yr to 5,374,202
MT/yr.

Waste Management

The scrubber water, which is weak phosphoric acid is continuously returned for recovery to the acid
generation process. Table 3.9 presents the generated volume and the final management step used by

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 17 August, 2000
the facilities for this wastestream.

Table 3.9 - Waste Management Summary for Recycled Weak Phosphoric Acid

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

Recycled back to process 5* 1 5,467,843

* includes FMC, NJ spent filter wash water (8.0 MT).

Waste Characterization

Facilities did not characterize this wastestream.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment because there is no significant
potential for release to the environment.

3.2.9 Spent Filters (from purification)

Waste Generation

The purification filters are designed to remove arsenic from phosphoric acid. The facilities changed
them periodically (6-18 months) and it becomes a hazardous waste. Two facilities reported generating
this waste in 1998 and Solutia, GA reported generating 7.15 MT in 1994.

Waste Management

Solutia, MI and Solutia, GA reported that spent filters are stored in containers, sent off-site for
stabilization and then sent off-site to an Subtitle C landfill as hazardous waste. Solutia, MO incinerated
this waste at a Subtitle C facility. Table 3.10 presents the generated volume and the final management
step used by the facilities for this wastestream.

Table 3.10 - Waste Management Summary for Spent Filters (from purification)

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

Disposal off-site Subtitle 1 1* 1.63

C landfill

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 18 August, 2000
 Off-site Hazardous Waste 1 0 3.0
Incineration
*Solutia, MO generated 7.15 MT in 1994

Waste Characterization

Two facilities reported this wastestream to be a characteristic waste carrying a hazardous waste code
D004 (arsenic).

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment because the waste is
characteristically hazardous waste that is managed as hazardous from the point of generation through
disposal including meeting applicable LDR standards.

3.2.10 Rubber Liners of Product Storage Tanks

Waste Generation

The rubber liners in the phosphoric acid storage tanks are changed periodically (6-18 months). Three
facilities reported generating this wastestream.

Waste Management

The rubber liners was stored in containers, neutralized with soda ash and then sent to an off-site Subtitle
D landfill with liner and leachate collection. At Solutia, MO this waste was incinerated at a Subtitle C
facility. Table 3.11 presents the generated volume and the final management step used by the facilities
for this wastestream.

Table 3.11 - Waste Management Summary for Rubber Liners of Product Storage Tanks

Final Management # of Wastestreams # of Wastestreams Total Volume

with Reported with (MT/yr)
Volumes Unreported Volumes

Disposal off-site Subtitle 2 0 36.14*

D landfill

Off-site Hazardous Waste 1 0 1.75

Incineration
* Includes 18.0 MT of waste generated by Solutia, GA which stopped producing phosphoric acid in
March, 1998.

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 19 August, 2000
Waste Characterization

Facilities did not characterize this wastestream.

This waste was not sampled and did not warrant a risk assessment for the following reasons:

1. The wastestream is treated to remove or immobilize any low levels of phosphoric acid that may
present in the waste.
2. The wastestream is generated in relatively small volumes.
3. Solutia, GA facility stopped generating this waste.
4. Solutia, MO manages this wastestream as hazardous from the point of generation through
disposal.

3.2.11 Spent Filters for Product

Waste Generation

Solutia, MI and Solutia, GA filter the phosphoric acid product prior to loading tank cars and trucks to
remove settled solids generating this wastestream.

Waste Management

The filters are changed periodically (6-18 months) and rinsed with water prior to being stored in
containers. After that they are stabilized or neutralized they are disposed off-site in a Subtitle D landfill
with liner and leachate collection. Table 3.12 presents the generated volume and the final management
step used by the facilities for this wastestream.

Table 3.12 - Waste Management Summary for Spent Filters for Product

Final Management # of Wastestreams # of Wastestreams Total Volume

with Reported with (MT/yr)
Volumes Unreported Volumes

Disposal off-site Subtitle 2 0 1.04*

D landfill
* Includes 0.5 MT of waste generated by Solutia, GA which stopped producing phosphoric acid in
March, 1998.

Waste Characterization

The facilities did not characterize this wastestream.

This waste was not sampled and did not warrant a risk assessment for the following reasons:

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 20 August, 2000
1. The wastestream is treated to remove or immobilize any low levels of phosphoric acid that may
present in the waste.
2. The wastestream is generated in relatively small volumes.
3. The filters are used late in the process where contaminants are expected to be low due to the
required purity of the food-grade product.

3.2.12 Off-Spec Phosphoric Acid

Waste Generation

Off-spec phosphoric acid, a periodically generated waste was reported by Solutia, MI.

Waste Management

This waste was placed in drums, sent off-site for stabilization and sent off-site to a Subtitle C landfill.
Table 3.13 presents the generated volume and the final management step used by the facility for this
wastestream.

Table 3.13 - Waste Management Summary for Off-Spec Phosphoric Acid

Final Management # of Wastestreams # of Wastestreams Total Volume

with Reported with (MT/yr)
Volumes Unreported Volumes

Disposal off-site Subtitle 1 0 0.71

C landfill

Waste Characterization

The facility reported this wastestream to be a characteristic waste carrying hazardous waste code D002
(corrosivity). The chemical constituents that were reported include arsenic, barium, cadmium,
chromium, copper, lead and zinc.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment because the waste is
characteristically hazardous waste that is managed as hazardous from the point of generation through
disposal including meeting applicable LDR standards.

3.2.13 Spent Activated Carbon

Waste Generation

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 21 August, 2000
The carbon is used by Rhodia, TN to filter off-spec phosphoric acid. They reported generating spent
activated carbon in 1996, as a non-hazardous waste.

Waste Management

The waste is stored in containers, sent off-site for stabilization and disposed off-site in a Subtitle D
landfill with liner and leachate collection. Table 3.14 presents the generated volume and the final
management step used by the facility for this wastestream.

Table 3.14 - Waste Management Statistics for Spent Activated Carbon

Final Management # of Wastestreams # of Wastestreams Total Volume

with Reported with (MT in 1996)
Volumes Unreported Volumes

Disposal off-site Subtitle 1 0 3.0

D landfill

Waste Characterization

The facility reported this waste as non-hazardous.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment for the following reasons:

1. The waste is infrequently generated (last generated in 1996) and in relatively small volumes. If
annualized over three years, would amount to 1.0 MT per year.
2. Contaminants are expected to be low due to the required purity of the food-grade product.

3.2.14 Spent Filters for Off-spec Product

Waste Generation

This residual is generated when filtering off-spec product. Only Rhodia, TN reported recycling off-
spec product. Before the off-spec product is returned back to the process it is filtered generating this
wastestream.

Waste Management

These filters are changed periodically (6-18 months) stored in roll-on/off bin and disposed in an off-site
Subtitle D landfill with liner and leachate collection. Table 3.15 presents the generated volume and the
final management step used by the facility for this wastestream.

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 22 August, 2000
 Table 3.15 - Waste Management Statistics for Spent Filters (for filtering off-spec product)

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

Disposal off-site Subtitle 1 0 0.5

D landfill

Waste Characterization

The facility did not characterize this wastestream.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment for the following reasons:

1. The waste is generated in relatively small volumes.

2. Contaminants are expected to be low due to the required purity of the food-grade product.

3.2.15 Wastewater Treatment Sludge

Waste Generation

Sediment gradually accumulates in the wastewater treatment system. Periodically the sediment is
removed from the wastewater system generating this waste. Three facilities reported generating this
wastestream.

Waste Management

The facilities stored this waste in containers and then sent it off-site for disposal at a Subtitle D landfill.
Table 3.16 presents the generated volume and the final management step used by the facilities for this
wastestream.

Table 3.16 - Waste Management Statistics for Wastewater Treatment Sludge

Final Management # of Wastestreams # of Wastestreams with Total Volume

with Reported Unreported Volumes (MT/yr)
Volumes

Disposal off-site Subtitle 0 3*

D landfill
* All three facilities reported that wastes from phosphoric acid production are a very minor contributor

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 23 August, 2000
to the particulate matter which accumulates in these systems. Two facilities did not report volumes due
to very small input of phosphoric acid production wastes to the WWT system; one facility estimated
that 0.0001% of 4,640 MT sludge generated (or 0.005 MT) was from phosphoric acid production.

Waste Characterization

The facilities reported this waste as nonhazardous.

Results of Initial Risk Screening Analysis

This waste was not sampled and did not warrant a risk assessment because the waste is generated in
relatively small volumes.

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 24 August, 2000
 APPENDIX A

Summary of Waste Generation and Management

 Wastestream Facility Volume Hazardous Final
(MT/yr) Waste # Managemen
t

Arsenic Filter Cake Solutia Inc. 56.84 D002, D004 Disposal off-
5045 West Jefferson Avenue D007 site Subtitle C
Trenton, MI 48183 landfill

Solutia Inc. 88.6 (1997) D002, D004

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

Albright & Wilson Company 6.1 D002, D004

2151 King Street
Charleston, SC 29405

FMC Corp. 62.0 D004

500 Roosevelt Avenue
Carteret, NJ 07008

FMC Corp. 248.0 D004

440 North 9th Street
Lawrence, KS 66044

Rhodia Inc. 130.0 D004

4600 Centennial Boulevard
Nashville, TN 37209

Solutia Inc. Carondelet Plant 93.0 D002,D004

500 Monsanto Avenue
East St. Louis, MO 62206

Rhodia Inc. 18.0 D002, D004

2300 South Pennsylvania
Avenue
Morrisville, PA 19067

Caustic Scrubber Albright & Wilson Company 36.0 None Discharged to

Discharge 2151 King Street POTW
Charleston, SC 29405

FMC Corp. 270 None Recycled

500 Roosevelt Avenue
Carteret, NJ 07008

FMC Corp. 1,080 None

440 North 9th Street
Lawrence, KS 66044

Spent Activated Rhodia Inc. 3.0 (1996) none Disposal off-

Carbon (for filtering off- 4600 Centennial Boulevard site Subtitle D
spec product) Nashville, TN 37209 landfill

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 1 August, 2000
 Wastestream Facility Volume Hazardous Final
(MT/yr) Waste # Managemen
t

Spent Filters (for Rhodia Inc. 0.5 None Disposal off-

filtering off-spec 4600 Centennial Boulevard site Subtitle D
product) Nashville, TN 37209 landfill

Refractory Brick Solutia Inc. Carondelet Plant 0.2 None Off-site

500 Monsanto Avenue Hazardous
East St. Louis, MO 62206 Waste
Incineration

Rhodia Inc. 180 (1997) None Disposal off-

2300 South Pennsylvania site Subtitle D
Avenue. Morrisville, PA 19067 landfill

Solutia Inc. 90.72 None

5045 West Jefferson Avenue
Trenton, MI 48183

Solutia Inc. 90 (1995) None

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

Clean-up and Albright & Wilson Company Not Reported None Discharge to
Washdown Water 2151 King Street POTW
Charleston, SC 29405

Process Acid Leaks FMC Corp. 2.0 Non Recycled

440 North 9th Street Hazardous
Lawrence, KS 66044

Rhodia Inc. 25.0 None NPDES permit

4600 Centennial Boulevard discharge
Nashville, TN 37209

Phosphoric Acid Spills Solutia Inc. Carondelet Plant 0.5 D002 Disposal off-
500 Monsanto Avenue site Subtitle D
East St. Louis, MO 62206 landfill

Solutia Inc. 1.72 D002 NPDES permit

5045 West Jefferson Avenue discharge
Trenton, MI 48183

Solutia Inc. 4.53 D002

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 2 August, 2000
 Wastestream Facility Volume Hazardous Final
(MT/yr) Waste # Managemen
t

Waste Water Rhodia Inc. NR none Disposal off-

Treatment Sludge 4600 Centennial Boulevard site Subtitle D
Nashville, TN 37209 landfill

Solutia Inc. NR none

5045 West Jefferson Avenue
Trenton, MI 48183

Albright & Wilson Company NR none

2151 King Street
Charleston, SC 29405

Spent Mist Eliminator FMC Corp. 2.0 None Disposal off-

Packing (Filters) 500 Roosevelt Avenue site Subtitle C
Carteret, NJ 07008 landfill

FMC Corp. 2.0 None Off-site Metal

440 North 9th Street Recovery
Lawrence, KS 66044

Rhodia Inc. 10.9 None Disposal off-

4600 Centennial Boulevard site Subtitle D
Nashville, TN 37209 landfill

Solutia Inc. Carondelet Plant 0.5 None

500 Monsanto Avenue
East St. Louis, MO 62206

Solutia Inc. 13 None

5045 West Jefferson Avenue
Trenton, MI 48183

Solutia Inc. 15 (1995) None

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

Combustion Chamber Solutia Inc. Carondelet Plant 0.1 D002 Off-site

Slag 500 Monsanto Avenue Hazardous
East St. Louis, MO 62206 Waste
Incineration

Weak Phosphoric Acid Solutia Inc. Carondelet Plant 47,283 None Recycling
(Vent scrubber water) 500 Monsanto Avenue
East St. Louis, MO 62206

Solutia Inc. 5,374,202 None

5045 West Jefferson Avenue
Trenton, MI 48183

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 3 August, 2000
 Wastestream Facility Volume Hazardous Final
(MT/yr) Waste # Managemen
t

Solutia Inc. Not Reported None

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

FMC Corp. 9,000 None

500 Roosevelt Avenue
Carteret, NJ 07008 8.00

FMC Corp. 36,000 None

440 North 9th Street
Lawrence, KS 66044

Spent Filters (from Solutia Inc. Carondelet Plant 3.0 D004 Off-site
purification) 500 Monsanto Avenue Hazardous
East St. Louis, MO 62206 Waste
Incineration

Solutia Inc. 1.63 D004 Disposal off-

5045 West Jefferson Avenue site Subtitle C
Trenton, MI 48183 landfill

Solutia Inc. 7.15 (1994) None

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

Rubber Liners of Solutia Inc. Carondelet Plant 1.75 None Off-site

Product Storage Tanks 500 Monsanto Avenue Hazardous
East St. Louis, MO 62206 Waste
Incineration

Solutia Inc. 18.14 None Disposal off-

5045 West Jefferson Avenue site Subtitle D
Trenton, MI 48183 landfill

Solutia Inc. 18.0 None

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

Spent Filters for Solutia Inc. 0.54 None Disposal off-

Product 5045 West Jefferson Avenue site Subtitle D
Trenton, MI 48183 landfill

Solutia Inc. 0.5 None

1610 Marvin Griffin Road
PO Box 1473
Augusta, GA 30903

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 4 August, 2000
 Wastestream Facility Volume Hazardous Final
(MT/yr) Waste # Managemen
t

Off-spec Phosphoric Solutia Inc. 0.71 D002 Disposal off-

Acid 5045 West Jefferson Avenue site Subtitle C
Trenton, MI 48183 landfill

Inorganic Listing Determination Phosphoric Acid

Background Listing Document 5 August, 2000