£EPA
United States
Environmental Protection
Agency
Effluent Guidelines Division
and Permits Division
Washington DC 20460
August 1987
EPA 440/1-87/014
Guidance Manual
for Battery
Manufacturing
Pretreatment Standards
-------
GUIDANCE MANUAL
FOR
BATTERY MANUFACTURING
PRETREATMENT STANDARDS
Prepared by
the
Industrial Technology Division
Office of Water Regulations and Standards
and
Permits Division
Office of Water Enforcement and Permits
August 1987
Office of Water
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D-C- 20460
-------
ACKNOWLEDGEMENT
This document was prepared by Science Applications
International Corporation (SAIC) and Whitescarver Associates
under EPA Contract Nos. 68-01-6514, and 68-01-7043.
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TABLE OF CONTENTS
Page
1. INTRODUCTION 1-1
1.1 HISTORY OF THE BATTERY MANUFACTURING CATEGORY 1-2
2 . BATTERY MANUFACTURING CATEGORICAL STANDARDS 2-1
2 .1 AFFECTED INDUSTRY 2-1
2 . 2 PROCESS OPERATIONS 2-2
2 . 3 SUBCATEGORIZATION 2-3
2.3.1 Cadmium Subcategory 2-5
2.3.2 Calcium Subcategory 2-11
2.3.3 Lead Subcategory 2-14
2.3.4 Leclanche Subcategory 2-17
2.3.5 Lithium Subcategory 2-20
2.3.6 Magnesium Subcategory 2-23
2.3.7 Zinc Subcategory 2-26
2.4 OPERATIONS COVERED UNDER OTHER CATEGORIES 2-34
2.5 PRETREATMENT STANDARDS FOR THE BATTERY
MANUFACTURING CATEGORY 2-34
2.6 GUIDANCE FOR CONSIDERATION OF EMPLOYEE SHOWER
WASTEWATER AT LEAD SUBCATEGORY PLANTS 2-36
2.7 COMPLIANCE DATES 2-41
3 . TREATMENT TECHNOLOGIES 3-1
3 .1 END-OF-PIPE TREATMENT TECHNOLOGIES 3-2
3 . 2 IN-PROCESS CONTROL TECHNOLOGIES 3-4
4. REQUIREMENTS OF THE GENERAL PRETREATMENT REGULATIONS.... 4-1
4 .1 INTRODUCTION 4-1
4 . 2 CATEGORY DETERMINATION REQUESTS 4-2
4.3 MONITORING AND REPORTING REQUIREMENTS OF THE
GENERAL PRETREATMENT REGULATIONS 4-3
4.3.1 Baseline Monitoring Reports 4-3
4.3.2 Compliance Schedule Progress Report 4-6
4.3.3 Report on Compliance 4-6
4.3.4 Periodic Reports on Continued Compliance... 4-7
4.3.5 Notice of Slug Loading 4-7
4.3.6 Monitoring and Analysis to Demonstrate
Continued Compliance 4-8
4.3.7 Signatory Requirements for Industrial
User Reports 4-8
4.3.8 Recordkeeping Requirements 4-9
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4.4 APPLICATION OF THE COMBINED WASTESTREAM FORMULA... 4-9
4 . 5 REMOVAL CREDITS 4-12
4.6 FUNDAMENTALLY DIFFERENT FACTORS (FDF) VARIANCE 4-22
4.7 LOCAL LIMITS 4-23
5. APPLICATION OF BATTERY MANUFACTURING CATEGORICAL
PRETREATMENT STANDARDS 5-1
REFERENCES R-l
APPENDIX A GLOSSARY OF TERMS
APPENDIX B PSES AND PSNS FOR BATTERY MANUFACTURING
SUBCATEGORIES
Subpart A: Cadmium PSES B-l
Subpart C: Lead PSES B-2
Subpart D: Leclanche PSES B-3
Subpart F: Magnesium PSES B-3
Subpart G: Zinc PSES B-3
Subpart A: Cadmium PSNS B-6
Subpart B: Calcium PSNS B-7
Subpart C: Lead PSNS B-7
Subpart D: Leclanche PSNS B-8
Subpart E: Lithium PSNS B-8
Subpart F: Magnesium PSNS B-8
Subpart G: Zinc PSNS B-9
APPENDIX C
EPA AND STATE PRETREATMENT COORDINATORS
11
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LIST OF TABLES AND FIGURES
Table Page
2.1 BASIC DETERMINATIONS NEEDED TO APPLY BATTERY
MANUFACTURING REGULATION 2-6
2 . 2 CADMIUM SUBCATEGORY ANALYSIS 2-9
2 . 3 CALCIUM SUBCATEGORY ANALYSIS 2-13
2 . 4 LEAD SUBCATEGORY ANALYSIS.: 2-18
2 . 5 LECLANCHE SUBCATEGORY ANALYSIS 2-22
2 . 6 LITHIUM SUBCATEGORY ANALYSIS 2-25
2 . 7 MAGNESIUM SUBCAT1GORY ANALYSIS 2-28
2 . 8 ZINC SUBCATEGORY ANALYSIS 2-31
4 .1 COMBINED WASTESTREAM FORMULAS 4-13
4.2 COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS. 4-15
4. 3 FLOW-WEIGHTED AVERAGING (FWA) FORMULAS 4-20
5.1 ALLOWABLE MASS LOADINGS FROM PROCESS OPERATIONS
REGULATED BY BATTERY MANUFACTURING CATEGORICAL
PRETREATMENT STANDARDS 5-5
5.2 ALLOWABLE MASS LOADINGS FROM PROCESS OPERATIONS
REGULATED BY NONFERROUS METALS MANUFACTURING
CATEGORICAL PRETREATMENT STANDARDS - SECONDARY
LEAD SUBCATEGORY 5-7
5. 3 DERIVATION OF ALTERNATIVE LIMITS 5-9
5.4 BATTERY MANUFACTURING CALCULATION OF MASS
DISCHARGE LIMITS 5-12
5.5 NONFERROUS METALS MANUFACTURING CALCULATION OF
DISCHARGE LIMITS 5-14
5.6 SUMMARY OF TREATMENT EFFECTIVENESS
FOR THE NONFERROUS METALS MANUFACTURING
REGULATION 5-15
ill
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Figure
2.1 GENERALIZED CADMIUM SUBCATEGORY MANUFACTURING
PROCESS . 2-8
2.2 GENERALIZED CALCIUM SUBCATEGORY MANUFACTURING
PROCESS. . 2-12
2.3 LEAD SUBCATEGORY GENERALIZED MANUFACTURING PROCESS 2-16
2.4 GENERALIZED SCHEMATIC FOR LECLANCHE CELL
MANUFACTURE 2-21
2.5 GENERALIZED LITHIUM SUBCATEGORY MANUFACTURING
PROCESS 2-24
2.6 GENERALIZED MAGNESIUM SUBCATEGORY MANUFACTURING
PROCESS 2-27
2.7 GENERALIZED ZINC SUBCATEGORY MANUFACTURING
PROCESSES 2-30
5.1 EXAMPLE PLANT PRODUCTION AND FLOW DATA 5-4
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1. INTRODUCTION
The National Pretreatment Program establishes an overall
strategy for controlling the introduction of nondomestic wastes
to publicly owned treatment works (POTWs) in accordance with the
overall objectives of the Clean Water Act. Sections 307(b) and
(c) of the Act authorize the Environmental Protection Agency to
develop National Pretreatment Standards for new and existing
dischargers to POTWs. The Act makes these pretreatment standards
enforceable against dischargers to publicly owned treatment
works.
The General Pretreatment Regulations (40 CFR Part 403)
establish administrative mechanisms requiring nearly 1,500 POTWs
to develop local pretreatment programs to enforce the general
discharge prohibitions and specific categorical pretreatment
standards. These categorical pretreatment standards are designed
to prevent the discharge of pollutants which pass through, inter-
fere with, or are otherwise incompatible with the operation of
the POTW. The standards are technology-based for removal of
toxic pollutants and contain specific numerical limitations based
on an evaluation of specific treatment technologies for the
particular industrial categories. As a result of a settlement
agreement, EPA was required to develop categorical pretreatment
standards for 34 industrial categories with a primary emphasis on
65 classes of toxic pollutants.
1-1
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This manual provides guidance to POTWs on the application
and enforcement of the categorical pretreatment standards for the
battery manufacturing category. This document is based primarily
on two sources: Federal Register notices, which include the
official announcements of the categorical pretreatment standards,
and the final development document for battery manufacturing
which provides a summary of the technical support for the
regulations. Additional information on the regulations, the
manufacturing processes, and control technologies can be found in
these sources. A listing of all references used in the develop-
ment of this manual is provided at the end of this document. A
Glossary of Terms is provided in Appendix A of this document to
assist the reader in becoming familiar with the technical terms
used in this document.
1.1 HISTORY OF THE BATTERY MANUFACTURING CATEGORY
Battery manufacturing originated in 1786 with the invention
of the galvanic cell by Galvani. Electrochemical batteries and
cells using silver and zinc electrodes in salt water were
assembled as early as 1798 by Alessandro Volta as a result of
Galvani's work. In 1868, Leclanche developed the forerunner of
the modern dry cell in which he used an amalgamated zinc anode
and a carbon cathode surrounded by manganese dioxide immersed in
an ammonium chloride solution. Varying types of battery systems
have been introduced, many of which have been displaced by newer
and more advanced systems. In the last ten years lithium
batteries have been developed for many applications, including
heart pacemakers, and large programs have been funded for the
1-2
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development of electric powered automobiles and stand-by power
sources for utilities. Advancing technology of materials along
with new applications requirements will result in development of
newer systems and the redevelopment of some older systems.
It is estimated that there are 255 battery manufacturing
plants in the United States. A substantial majority of these are
located in California, Pennsylvania, North Carolina, and Texas.
Of the 255 identified battery manufacturing plants, 22 are direct
dischargers, 150 are indirect dischargers and 83 plants do not
discharge wastewater.
Categorical pretreatment standards for the battery
manufacturing category were promulgated on March 9, 1984 and
became effective on April 23, 1984. EPA had not previously
promulgated any pretreatment regulations for the battery
manufacturing category. In response to a settlement agreement,
(Battery Council International v. EPA, 4th Cir. No. 84-1507) an
amendment to the regulations was proposed on January 28, 1986 and
promulgated on August 28, 1986. The final compliance date for
the battery manufacturing categorical pretreatment standards was
March 9, 1987 for existing sources and upon commencement of
discharge for new sources.
1-3
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2. BATTERY MANUFACTURING CATEGORICAL PRETREATMENT STANDARDS
2.1 AFFECTED INDUSTRY
For the purpose of these categorical pretreatment standards,
battery means a modular electric power source where part or all
of the fuel is contained within the unit and electric power is
generated directly from a chemical reaction rather than
indirectly through a heat cycle engine. A unit or cell consists
of an anode, a cathode, and an electrolyte, plus mechanical and
conducting parts such as case, separator and contacts. Often
several units or cells are assembled into one device. For these
standards the term battery refers to a single cell or self-
contained assemblage of cells.
The battery manufacturing categorical standards establish
limitations and standards for those manufacturing plants at which
battery manufacturing operations occur. These operations include
all the specific processes used to produce a battery including
anode and cathode manufacturing processes and various ancillary
operations. Ancillary operations are primarily associated with
battery assembly and chemical production of anode or cathode
active materials. The categorical standards do not establish
discharge standards for the manufacturing operations associated
with the production of structural components such as cases,
separators, contacts, and other small parts manufactured in other
plants where other limitations and standards apply.
Battery manufacturing plants are included within Standard
Industrial Classification (SIC) Codes 3691, Storage Batteries and
3692, Primary Batteries, Dry and Wet. However, SIC codes cannot
2-1
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be used to make categorization determinations because the codes
are based on end use of the product and not the manufacturing
processes.
2.2 PROCESS OPERATIONS
Manufacturing operations vary widely, depending on the
particular battery application and the type of battery produced.
Battery manufacturing is typically comprised of production of
anodes, production of cathodes, and associated ancillary
operations necessary to produce a battery such as battery
assembly. These process operations are briefly discussed below:
Anodes - Anodes, in their final or fully charged form
in a battery are usually zerovalent metals. The active
mass for anodes is prepared by directly cutting and
drawing or stamping the pure metal or alloyed metal
sheet, by mixing metal powders with or without
electrolyte, by physically applying pastes of a
compound of the anode metal to the support structure,
or by precipitating a soluble salt of the metal onto a
carrier or support structure. The final step in anode
preparation for many types of batteries, especially
rechargeable ones, is formation or charging of the
active mass. Formation may be carried out on
individual electrodes or on pairs of electrodes (anode
and cathode) in a tank of suitable electrolyte. Most
often the electrodes for a battery are formed in pairs
and current is passed through the electrodes to charge
them. For some battery types, charge-discharge cycling
up to seven times is used for formation.
Cathode Manufacturing - Although usually designated by
metal type cathode active materials often consist of
oxidized metals, such as lead peroxide or nickel
hydroxide. Non-metals such as iodine (used in
lithium-iodine batteries) and meta-dinitrobenzene (used
in magnesium-ammonia reserve batteries) are other kinds
of cathode active materials. Cathode active materials
are weak electrical conductors and usually possess
little mechanical strength. Therefore, most cathodes
have a metallic current conduction support structure
and conducting material, often carbon or nickel, incor-
porated into the active mass. The active material may
be applied to the support as a paste, deposited in a
porous structure by precipitation from a solution,
2-2
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fixed to the support as a compacted pellet, or may be
dissolved in an electrolyte which has been immobilized
in a porous inert structure. Formation processes for
cathodes are similar to those used for anodes.
Ancillary Operations - Ancillary operations are those
operations unique to the battery manufacturing category
that are not specifically included under anode or
cathode fabrication. Ancillary operations are pri-
marily associated with cell and battery assembly and
chemical production of anode and cathode active
materials. Ancillary operations also include battery
washing (both intermediate and final product), and
washing of equipment, floors, and operating personnel
as well as some dry operations.
The reactive materials in most modern batteries include one
or more of the following toxic metals: cadmium, lead, mercury,
nickel, and zinc. These toxic metals are often found in
wastewater discharges and solid ^wastes from battery plants.
Water is used throughout the manufacturing process, specifically
in preparation of electrolytes and electrode active masses, in
deposition of active materials on electrode supporting
structures, in charging electrodes and removing impurities, and
in washing finished batteries, production equipment, and
manufacturing areas.
2.3 SUBCATEGORIZATION
The battery manufacturing category was subcategorized based
on anode material and electrolyte composition. The rationale for
this subcategorization is that many battery manufacturers produce
batteries with different anode-cathode pairs but with a common
anode material. The seven subcategories to which this regulation
applies are:
- Cadmium
- Calcium
- Lead
2-3
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- Leclanche (zinc anode with an acid electrolyte)
- Lithium
- Magnesium
- Zinc (with alkaline electrolyte)
These subcategories are represented by Subparts A-G of the
categorical standards.
These subcategories are further subdivided into
manufacturing process elements frequently referred to as
"building blocks" specific to basic manufacturing operations
within the subcategory. Promulgated standards are specific to
these elements. At the element level water use and pollutant
characteristics can be related to a specific measure of produc-
tion. This factor is referred to as a production normalizing
parameter (PNP). The PNP may be different in the different
subcategories or even different for each element. For example,
in the case of plants subject to the lead subcategory standards,
the PNP for all process elements for which discharge allowances
are provided (except for the truck wash process element) is the
total lead weight used (consumed) in the type of battery manufac-
tured. The PNP for truck wash is the weight of lead in batteries
(not total weight of batteries) moved in trucks. This does not
apply to truck washing at plants that have battery cracking or
secondary lead smelting which is covered under nonferrous metals
manufacturing.
The seven subcategories, their manufacturing operations and
resulting wastewater characteristics are described briefly in
this section. The application of the battery manufacturing cate-
gorical standards may be difficult for those unfamiliar with the
processes and terminology used. As a general guide, the Control
2-4
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Authority should ask the manufacturer the questions listed in
Table 2.1 to determine the applicable subcategories and stan-
dards. If further technical assistance is needed the Control
Authority is encouraged to contact the EPA Industrial Technology
Division project officer (Mary L. Belefski at (202) 382-7153).
2.3.1 Cadmium Subcategory
The Cadmium Subcategory encompasses the manufacture of all
batteries in which cadmium is the reactive anode material . Cad-
mium cells currently manufactured are based on nickel-cadmium,
silver-cadmium, and mercury-cadmium couples. Three general met-
hods for producing anodes are employed:
1) The manufacture of pasted and pressed powder anodes
physical application of the solids;
2) Electrodeposited anodes produced by means of
electrochemical precipitation of cadmium hydroxide
from a cadmium salt solution;
3) Impregnated anodes manufactured by impregnation of
cadmium solutions into porous structures and subse-
quent precipitation of cadmium hydroxide.
Five cathode manufacturing process elements are employed in
this Subcategory, three of which are specifically for production
of nickel cathodes and two are for production of silver and
mercury cathodes. They include:
(1) Nickel pressed powder cathodes
(2) Nickel electrodeposited cathodes
(3) Nickel impregnated cathodes
(4) Silver powder pressed cathodes
(5) Mercuric oxide powder pressed
2-5
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TABLE 2.1
BASIC DETERMINATIONS NEEDED TO APPLY
BATTERY MANUFACTURING REGULATION
I. DETERMINATION OF APPLICABLE SUBCATEGORY
A. What types of batteries do you manufacture?
B. What raw materials do you use for anode manufacture?
II. DETERMINATION OF APPLICABLE PROCESSES
A. How do you manufacture anodes?
B. How do you manufacture cathodes?
C. What ancillary operations do you perform?
III. DETERMINATION OF AN AVAILABLE PRODUCTION INFORMATION
A. Do you keep records on raw materials purchased?
B. Do you keep records on the weight of batteries produced
or number of batteries produced?
C. Over what period is this information available?
IV. DETERMINATION OF AN APPROPRIATE PRODUCTION RATE
A. Review guidance for determining a reasonable
representation for production as provided in the
Guidance Manual for the Use of Production-Based
Pretreatment Standards and the Combined Wastestream
Formula (September, 1985) and in 40 CFR Part 122.63
B. Determine a reasonable representation of the actual
production by reviewing the production data over a
period of three to five years and determining the high
months in each of these years. Divide the total
production in these high months by the total number of
production days in these high months to yield an
average daily production rate (regulatory day) which
is then used to determine the appropriate discharge
allowances. The data should be carefully examined for
consistency in production, and to insure that the
highest production months are not an anomaly.
2-6
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Assembly of all cells in this subcategory involves the
assembly of one or more anodes with cathodes and separators to
produce an active cell. One or more of these cells is then
inserted in a battery case, electrical connections are made, and
electrolyte is added, after which the case is covered and (if
appropriate) sealed.
Ancillary operations include washing assembled cells;
preparing electrolyte solutions; cleaning process areas and
equipment; employee washing to remove process chemicals; and the
production of active anode and cathode materials such as cadmium
powder, silver powder, nickel hydroxide and cadmium hydroxide.
Figure 2.1 is a schematic diagram of a generalized cadmium
subcategory manufacturing process.
Table 2.2 is a summary of the wastewater sources for the
cadmium subcategory. Process water use varies from plant to
plant depending upon the specific manufacturing operations
practiced. The most significant sources of process wastewater in
cadmium anode battery manufacture are in the deposition of elec-
trode active materials on supporting substrates and in subsequent
electrode formation (charging) prior to assembly into cells.
Additional points of process water use and discharge include wet
scrubbers for air pollution control, electrolyte preparation,
cell wash, floor wash, and employee showers and hand wash
intended to remove process chemicals.
The most significant pollutants are the toxic metals
cadmium, nickel, and silver. The waste streams are predominantly
alkaline and frequently contain high levels of suspended solids
including metal hydroxide precipitates.
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ELECTROLYTE MAW
MATERIALS
\i
U 2
0 U
Si
i
ELECTROLYTE
PREPARATION
WASTEWATER
h
ANODE
PREPARATION
ANODE
ABCKMBLY
CATHODE
CATHODE
PREPARATION
WASTEWATER
CELL
WASH
I
WAITCWATER
PRODUCT
FLOOR
AND EQUIPMENT
WASH
WACTEWATER
EMPLOYEE
WASH
WASTEWATER
SPECIAL
CHEMICALS
AND
METALS
PRODUCTION
WACTCWATCR
FIGURE 2.1
GENERALIZED CADMIUM SUBCATEGORY MANUFACTURING PROCESS
2-8
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TABLE 2.2
CADMIUM SUBCATEGORY ANALYSIS
Grouping
Anode
Manufacture
Cathode
Manufacture
Element
Pasted and Pressed
Powder
Electrodeposited •
Impregnated
Silver Powder Pressed
Nickel Pressed Powder
Specific Wastewater Sources
(Subelement)
* Process Area Clean-up
Product Rinses
Spent Caustic
Scrubbers
Sintered Stock Preparation
Clean-up
Impregnated Rinses
.Spent Impregnation Caustic
Product Cleaning
Pre-formation Soak
Spent Formation Caustic
Post-formation Rinse
No Process Wastewater
Nickel Electrodeposited
Nickel Impregnated
Ancillary
Operations
Mercuric Oxide Powder
Pressed
Cell Wash
» No Process Wastewater
* Spent Caustic
* Post-formation Rinse
• Sintered Stock Preparation
Clean-up
* Impregnation Rinses
• Impregnation Scrubbers
• Product Cleaning
* Impregnated Plague Scrub
» Pre-formation Soak
• Spent Formation Caustic
* Post Formation Rinses
« Impregnation Equipment Wash
* Nickel Recovery Filter Wash
• Nickel Recovery Scrubber
• No Process Wastewater
• Cell Wash
2-9
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TABLE 2.2 (continued)
CADMIUM SUBCATEGORY ANALYSIS
Grouping
Ancillary
Operations
Element
Specific Wastewater Sources
(Subelements)
Electrolyte Preparation
Floor and Equipment
Wash
Employee Wash
Cadmium Powder
Production
Silver Powder
Production
Nickel Hydroxide
Production
Cadmium Hydroxide
Production
Equipment Wash
Floor and Equipment Wash
Employee Wash
Product Rinses
Scrubber
Product Rinses
Product Rinses
Seal Cooling Water
2-10
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2.3.2 Calcium Subcategory
The Calcium Subcategory includes batteries that use calcium
as the reactive anode material. Currently, only thermal
batteries for military applications are produced. These batteries
are designed for long-term inactive storage followed by rapid
activation and delivery of relatively high currents for short
periods of time. These characteristics are achieved by the use
of solid electrolytes (usually -a fused mixture of lithium
chloride-potassium chloride) which at the moment of use are
heated to above the melting point to activate the cell. This
heat is supplied by chemical reactants incorporated as a
pyrotechnic device in the cell. Cell anodes, depolarizers,
electrolytes, and cell activators (heating elements) are prepared
in the manufacture of calcium anode thermal batteries. Calcium
anode material is generally produced by vapor deposition of
calcium on a substrate of metal, such as nickel or iron, which
serves as a current collector and support for the calcium during
cell operation. Cathodic depolarizers include calcium chromate,
tungstic oxide, and potassium dichromate and are incorporated
into cells by impregnation of fibrous media, pelletization of
powders, and by glazing. The electrolyte usually consists of a
lithium chloride-potassium chloride mixture and is incorporated
into the cells in a similar manner as are the depolarizers.
Figure 2.2 shows a generalized diagram for calcium battery
manufacturing.
Table 2.3 shows a summary of the wastewater sources for each
process in the Subcategory. Since calcium, the cell anode
material, reacts vigorously with water, water use is avoided as
2-11
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• LEND DEPOLARIZER
AND ELECTROLYTE
HEATING
COMPONENT
PREPARATION
DEPOLARIZER
PREPARATION
WASTEWATER
ASSEMBLY
ANODE
MANUFACTURE
•HIP
CELL
TESTING
WASTtWATER
FIGURE 2.?
GENERALIZED CALCIUM SUBCATEGORY MANUFACTURING PROCESS
2-12
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Grouping
Anode
Manufacture
Cathode
Manufacture
Ancillary
TABLE 2.3
CALCIUM SUBCATEGORY ANALYSIS
Element
Vapor Deposited
Fabricated
Calcium Chrornate
Tungstic Oxide
Potassium Dichromate
Heating Component
Production:
Heat Paper
Heat Pellet
Cell Testing
Specific Wastewater Sources
(Subelements)
No Process Wastewater
No Process Wastewater
No Process Wastewater
No Process Wastewater
No Process Wastewater
Slurry Preparation
Filtrate Discharge
No Process Wastewater
Leak Testing
2-13
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much as possible. The most significant pollutants found in these
wastewaters are chromium (especially hexavalent chromium from
barium chromate) and asbestos. Both of these pollutants are
from raw materials used in the manufacture of heating components.
2.3.3 Lead Subcategory
The Lead Subcategory, which is the subcategory with the
largest number of plants and volume of production, includes
batteries which use lead anodes, lead peroxide cathodes, and acid
electrolytes. The subcategory includes lead acid reserve cells
and the more familiar lead acid storage batteries. Lead acid
batteries include cells with immobilized electrolytes for use in
portable devices; batteries used for automotive starting,
lighting, and ignition (SLI) applications; and a variety of
batteries designed for industrial applications. Lead reserve
batteries are similar to dehydrated plate lead batteries and are
produced from lead electroformed on steel which is immersed in an
acid electrolyte when placed in use.
SLI and industrial type batteries are manufactured and
shipped as "dry-charged" (shipped without acid electrolyte) and
"wet-charged" (shipped with acid electrolyte) units. Batteries
shipped without electrolyte include damp-charged batteries (damp
batteries) and dehydrated plate batteries (dehydrated batteries).
Damp batteries are usually manufactured by charging the elec-
trodes in the battery case after assembly (closed formation), and
emptying the electrolyte before final assembly and shipping.
Dehydrated batteries usually are manufactured by charging of the
electrodes in open tanks (open formation) followed by rinsing and
'2-14
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dehydration prior to assembly in the battery case. Wet-charged
batteries are usually manufactured by closed formation processes,
but can also be produced by open formation processes. Significant
differences in manufacturing processes and subsequent process
wastewater generation correspond to these product variations.
The manufacture of lead batteries includes the following
steps (see Figure 2.3):
1) Grid or plate support structure manufacture
2) Leady oxide production
3) Paste preparation and application to provide the
plate with a highly porous surface
4) Curing to ensure adequate paste strength and
adhesion to the plate
5) Assembly of plates into groups or elements
6) Electrolyte addition as appropriate
7) Formation or charging (including plate soaking)
which further binds the paste to the grid and
renders the plate electrochemically active
8) Final assembly
9) Testing and repair if needed
10) Washing
11) Final shipment
Process steps (1) through (7) are anode and cathode
operations while assembly, battery testing and repair, and batte-
ry washing are ancillary operations. Additional ancillary opera-
tions involved in the manufacture of lead batteries include floor
and truck washing, laboratory testing, and personal hygiene acti-
vities. Personal hygiene activities include mandatory employee
2-15
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~|
DRY BAG
HOUSE
1 i
REJECT* DUST
PLATES
RVJ
r
^
1 1
1 *
| WASTEWATER
LEAD DROSS*
PLUS REJECTS
TO TREATMENT
»
WET BATTERY LINE
ASSEMBLY
T
BURNPOS1
1 ACID FILL
BBER
SMALL PARTS
CASTING (FOR
ASSEMBLY)
FORM 1 i OP€«A
!3!^n.z_3
DUMP
ARV
TlO\S
WATER
^ PERSONAL
[ WASH
*
BOOST CHARGE
HYGIENE
' *
EWATER WASTEWATER
WASTEWAT!
TEST
•rtECYCLED TO SMELTER
PRODUCT
REJECTS'
FIGURE 2.3
LEAD SUBCATEGORY GENERALIZED MANUFACTURING PROCESS
2-16
-------
handwashing, respirator washing, and laundering of employee
work uniforms.
In general, process wastewater discharges result from the
preparation and application of electrode active materials (steps
1-6 above), formation and charging (step 7), washing finished
batteries (step 10 above), and from the various ancillary op-
erations (floor and truck washing, laboratory testing, and per-
sonal hygiene activities). Table 2.4 is a summary of wastewater
sources for each process in the lead subcategory. Wastewater
from the manufacture of lead batteries is acidic as a result of
contamination with sulfuric acid electrolyte and generally
contains dissolved lead and suspended particulates (including
lead solids).
2.3.4 Leclanche Subcategory
The Leclanche Subcategory includes the manufacture of
batteries that consist of a zinc anode, a carbon-manganese di-
oxide cathode, and an acid electrolyte (zinc chloride or zinc
chloride-ammonium chloride). Batteries in this subcategory con-
tain mercury which is used to amalgamate the zinc and reduce
internal corrosion. The mercury is generally added to the cell
electrolyte or separator. Types of batteries include the
familiar conventional carbon-zinc Leclanche cells or "dry cells"
(cylindrical, rectangular and flat), silver chloride-zinc cells
(less than 0.01 percent of total production in the subcategory),
carbon-zinc air cells, and foliar batteries. Carbon-zinc air
depolarized batteries which use alkaline electrolytes are
included in the Zinc Subcategory.
2-17
-------
TABLE 2.4
LEAD SUBCATEGORY ANALYSIS
Group ing/E1 ement
Anodes and Cathodes
Leady Oxide Production
Grid Manufacture
Grid Casting
Mold Release Formulation
Direct Chill Casting
Lead Rolling
Paste Preparation and Application
Curing
Closed Formation (In Case)
Single Fill
Double Fill
Fill and Dump
Open Formation (Out of Case)
Wet
Specific Wastewater Sources
(Subelements)
Ball Mill Shell Cooling
Scrubber*
Scrubber
Equipment Wash
Contact Cooling
Spent Emulsion Solution
Equipment and Floor Area
Cleanup
Scrubber*
Steam Curing
Humidity Curing
Contact Cooling
Formation Area Washdown
Scrubber*
Contact Cooling
Scrubber
Product Rinse
Formation Area Washdown
Contact Cooling
Scrubber*
Product Rinse
Formation Area Washdown
Plate Rinse
Spent Formation
Electrolyte
Formation Area Washdown
Scrubber*
2-18
-------
TABLE 2.4 (continued)
LEAD SUBCATEGORY ANALYSIS
Grouping/Element,
Dehydrated
Plate Soak
Ancillary Operations
Assembly - Small Parts Casting
Battery Wash
With Detergent
Water Only
Floor Wash
Wet Air Pollution Control
Battery Repair
Laboratory
Truck Wash
Personal Hygiene
Hand Wash
Respirator Wash
Laundry
Specific Wastewater Sources
(Subelements)
• Formation Area Washdown
• Plate Rinse
• Vacuum Pump Seals
• Scrubber*
* Soaking Acid
Scrubber*
Detergent Battery Wash
Water Only Battery Wash
Floor Wash
Power Floor Scrubbers
Slowdown From Scrubber
Processes *'d
Battery Repair Area Wash
Laboratory Sinks
Battery Electrolyte
Laboratory Wash
Scrubber Slowdown
Truck Wash
Hand Wash
Respirator wash and Rinse
Clothing Wash and Rinse
2-19
-------
The manufacture of batteries in this subcategory is com-
prised of the anode preparation, cathode preparation,the prepara-
tion or application of a separator, assembly of components into
cells and batteries, and ancillary operations performed in sup-
port of these basic manufacturing steps. Figure 2.4 is a
schematic diagram of a generalized Leclanche Subcategory
manufacturing process. Discharges from the manufacture of zinc
cans formed from zinc sheet are not regulated under the battery
manufacturing category. The flow allowance for all processes
except foliar miscellaneous equipment wash is 0.0 I/kg cells
produced.
Table 2.5 is a summary of the wastewater sources for this
subcategory, Wastewater discharges in this subcategory are
generally low and result only from separator production and from
cleanup of miscellaneous equipment. The most significant pollu-
tants in the wastestreams are mercury, zinc, ammonium chloride,
manganese dioxide and carbon. Starch and flour may also be
present from separator production. Recycle and reuse is
performed where possible in this subcategory to eliminate the
discharge of pollutants.
2.3.5 Lithium Subcategory
The Lithium Subcategory encompasses the manufacture of bat-
teries that use lithium as the reactive anode material. Included
are batteries for heart pacemakers, lanterns, watches, and
special military applications (such as thermal batteries). A
variety of cell cathode depolarizer materials are currently used
with lithium anodes including iodine, sulfur dioxide, thionyl
2-20
-------
ELECTROLYTE
RAW
MATERIALS
SEPARATOR
MAW
MATERIALS
i
ELECTROLYTE
FORMULATION,
SEPARATOR
PREPARATION
WASTEWATCR
ZINC
1
ANODE
METAL
FORMING
\
JANOOE
1
CATHODE RAW
MATERIALS
*
ASSEMBLY
CATHODE
PREPARATION
PRODUCT
MISCELLANEOUS TOOLS
AND EQUIPMENT PROM
ALL OPERATIONS
EQUIPMENT
AND AREA
CLEANUP
WASTEWATER
- OPERATION NOT REGULATED IN BATTERY
MANUFACTURING POINT SOURCE CATEGORY
FIGURE 2.4
GENERALIZED SCHEMATIC FOR LECLANCHE CELL MANUFACTURE
2-21
-------
TABLE 2.5
LECLANCHE SUBCATEGORY ANALYSIS
Grouping
Anode
Manufacture
Cathode
Ancillary
Operations
Element
Zinc Powder
Manganese Dioxide-Pressed o
- Electrolyte with Mercury
- Electrolyte without Mercury
- Gelled Electrolyte with Mercury
Specific Wastewater Sources
(Subelements)
No Process Wastewater
No Process Wastewater
Carbon (Porous)
Silver Chloride
Manganese
Dioxide-Pasted
Separators
Cooked Paste
Uncooked Paste
Pasted Paper with
Mercury
Equipment and Area
Cleanup
Foliar Battery
Miscellaneous Wash
No Process Wastewater
No Process Wastewater
No Process Wastewater
o Paste Setting
o Equipment Wash
o Equipment Wash
o Electrolyte Preparation
o Assembly Equipment Wash
o Employee Wash
o Electrode Preparation
Equipment Wash
o Miscellaneous Equipment
Wash
o Miscellaneous Equipment
and Area Wash
2-22
-------
chloride, and iron disulfide. Because lithium reacts vigorously
with water, electrolytes used in these batteries are generally
organic liquids, solids, or, in the case of thermal batteries,
solid inorganic salts which are fused during activation. The
manufacture of lithium anodes (Figure 2.5) generally involves
mechanical forming of metallic lithium to the desired configura-
tion. Cell cathode depolarizers are frequently blended with or
dissolved in the cell electrolyte. Thermal batteries manufac-
tured in this subcategory include a heating component (activator)
in addition to the anode, cathode depolarizer and electrolyte.
Due to lithium's high reactivity with water, anode proces-
sing and most cell assembly operations are performed without the
use of process water. Most assembly is accomplished in areas of
controlled low humidity. Process water is used in producing some
cell cathodes (specifically, lead iodide, iron disulfide, sulfur
dioxide, and thionyl chloride cathode production), either for
washing reactive materials or for air pollution control and area
cleanup.
The wastewaters from cathode operations, cell testing,
lithium scrap disposal, air scrubbers, and floor and equipment
wash contain metals and other pollutants. Pollutants found in
lithium subcategory wastewaters include asbestos, chromium, lead,
zinc, cobalt, iron, COD and TSS. Table 2.6 is a summary of the
wastewater sources for the Lithium Subcategory.
2.3.6 Magnesium Subcategory
The Magnesium Subcategory includes manufacturing operations
used to produce cells which pair magnesium anodes with various
2-23
-------
ANODC
MANUFACTURE
HEATING COMPONENT
PREPARATION
(THERMAL CELL.* ONLY)
DEPOLARIZER
PREPARATION
WASTEWATER
ASSEMBLY
r
CCLL TEST
WASTCWATEM
WASTEWATER
•LEND
OCPOLARIZEM
ELECTROLYTE
ELECTROLYTE
CELL
WASH
LITHIUM SCRAP
DISPOSAL
T
WASTEWATER
PRODUCT
WASTEWATER
FLOOR AND
EQUIPMENT
WASH
WASTEWATER
AIR SCRUBBERS
• WASTEWATER
FIGURE 2.5
GENERALIZED LITHIUM SUBCATEGOItY MANUFACTURING PROCESS
2-24
-------
TABLE 2.6
LITHIUM SUBCATEGORY ANALYSIS
Grouping
Element
Specific Wastewater Sources
(Subelements)
Anode
Manufacture
Cathode
Manufacture
Formed and Stamped
Iodine
Iron Bisulfide
Lead Iodide
Lithium Perchlorate
Sulfur Dioxide*
Thionyl Chloride*
Titanium Disulfide
No Process Wastewater
No Process Wastewater
Product Treatment
Equipment Wash
No Process Wastewater
Spills
Spills
No Process Wastewater
Ancillary
Operations
Heating Component Production:
Heat Paper
Heat Pellets
Lithium Scrap Disposal
Cell Testing
Floor and Equipment
Wash
Air Scrubbers
Cell Wash
Filtrate Discharge
Slurry Preparation
No Process Wastewater
Scrap Disposal
Leak Testing
Floor and Equipment Wash
Slowdown from various
production areas
Cell Wash
Wastewater discharged from air scrubbers for the manufacture
of these cathodes is included with ancillary operations.
2-25
-------
cathode materials such as manganese dioxide, barium chromate,
lithium chromate, magnesium hydroxide, and carbon. Carbon is
used in magnesium-carbon batteries which constitute 85% of total
subcategory production. Other cathode materials include: vanadium
pentoxide for thermal batteries; copper chloride, lead chloride,
silver, or silver chloride for magnesium reserve batteries; and
m-dinitrobenzene for ammonia activated cells. Electrolyte
materials consist of magnesium perchlorate, magnesium bromide,
lithium chloride, potassium chloride, and ammonia. Anode
manufacture generally requires mechanical forming and cutting of
magnesium metal, and cleaning and chromating to protect against
corrosion. Discharges from these mechanical and chromating opera-
tions are not regulated under the battery manufacturing
categorical standards. Cathodes are prepared by several
techniques including blending and pressing of powdered materials
and chemical treatment operations. Heating components
(activators) are manufactured for thermal batteries. Figure 2.6
is a schematic diagram of the magnesium battery manufacturing
process.
Pollutants resulting from magnesium anode battery manufac-
ture include asbestos, chromium (primarily hexavalent) from heat
paper production, silver, lead, nickel, iron, COD and TSS. Table
2.7 is a summary of the wastewater sources for the subcategory.
2.3.7 Zinc Subcategory
The Zinc Subcategory includes batteries that have an amalga-
mated zinc anode and an aqueous alkaline electrolyte (usually
potassium or sodium hydroxide). The zinc is amalgamated to
2-26
-------
WASTEWATER
to
I
to
-J
1 ANODE
| MCTAL
| FORMING
1
1
1
y
r
^ I CLEAN ft
1 CHROMA!
1
i
WASTE
FLOOR ft
EQUIPMENT
WASH
1
1
1
• n
i
re
_j
f
WAI
— •*
E
f
•ER
— V
LECTI
HEPAI
ANOI
C
1
IfASTE
»OLYTE
IATION
>t
:ELL
PEST
WATER
SEPARJI
PREPAY
1
'
ASSE
i
PRO)
T°" -^WASTEWATER »E«>I-*""Z="
(ATION -*-**STEWATER pREpAfl AT1ON
CATHODE
MBLY MANUFACTURE
HEATING
COMPONENT PREP. ^ WAS1
(THERMAL CELLS
ONLY)
9UCT
WASTEWATER
SUPPORT
WASTEWATER
•—— — OPERATIONS NOT REGULATED IN BATTERY
MANUFACTURING POINT SOURCE CATEGORY
FIGURE 2.6
GENERALIZED MAGNESIUM SUBCATEGORY MANUFACTURING PROCESS
-------
TABLE 2.7
MAGNESIUM SUBCATEGORY ANALYSIS
Grouping
Element
Specific Wastewater Source
(Subelements)
Anode
Manufacture
Cathode
Manufacture
Ancillary
Operations
Magnesium Powder
Carbon
Copper Chloride
Copper Iodide
Lead Chloride
M-Dinitrobenzene
Silver Chloride-
Chemically Reduced
Silver Chloride-
Electrolytic
Silver Chloride
Vanadium Pentoxide
Heating Component
Production:
Heat Paper
Heat Pellets
Cell Testing
Separator Processing
Floor and Equipment
Wash
Air Scrubbers
No Process Wasterwater
No Process Wastewater
No Process Wastewater
No Process Wastewater
No Process Wastewater
No Process Wastewater
Product Rinsing
Product Rinsing
No Process Wastewater
No Process Wastewater
Filtrate
Slurry Preparation
No Process Wastewater
Activation of Sea-Water
Reserve Batteries
Etching Solution
Product Rinsing
Floor and Equipment Wash
Slowdown from Various
Production Areas
2-28
-------
reduce anode corrosion and self-discharge of the cell. Batteries
manufactured differ considerably in physical configuration and in
production techniques depending upon the desired operational
characteristics of the cells. Six different cathode systems are
used to produce five types of batteries including alkaline
manganese batteries (manganese dioxide cathode system); carbon
zinc air batteries (porous carbon-atmospheric oxygen cathode
system); silver oxide zinc batteries (monovalent or divalent
silver oxide cathode system); mercury zinc batteries (mercuric
oxide and mercuric oxide with cadmium oxide cathode system); and
nickel zinc batteries (nickel hydroxide cathode system).
Manufacturing processes differ widely within the subcategory
resulting in differences in process water use and wastewater
discharge at each plant. There are seven distinct anode process
operations, ten distinct cathode process operations and eight
ancillary operations in various combinations at plants in the
subcategory. Ancillary processes are associated with cell
assembly, metal oxide production specific to battery
manufacturing, and general plant production activity from which
wastewater is generated and discharged. Figure 2.7 is a
schematic diagram of generalized zinc subcategory manufacturing
processes.
Table 2.8 is a summary of the wastewater sources for this
subcategory. Pollutants found in zinc subcategory wastewater
streams are primarily metals including zinc, mercury, silver and
nickel; oil and grease; and TSS.
2-29
-------
ANODCHAW
MATERIALS
CATHODE MAW
MATERIAL*
AMAL8AMATION
WASTEWATER
i
ELECTROLYTE
RAW MATERIALS
CHEMICAL
PREPARATION
or
DEPOLARIZER
WASTEWATER
ANODE
PREPARATION
I
WASTEWATER
ANODE
FORMATION
WASTEWATER
SPECIAL
CHEMICALS,
METALS
PRODUCTION
CATHODE
PREPARATION
WASTEWATER
ELECTROLYTE
PREPARATION
ANODE
WASTEWATER
CATHODE
FORMATION
ASSEMBLY
EMPLOYEE
WASH
WASTEWATER
CATHODE
WASTEWATER
CELL WASH
WASTEWATER
1
_t
REJECTS
REJECT CELL
HANDLING
WASTEWATER
PRODUCT
FLOOR AND
EQUIPMENT
WASH
WASTEWATER
SILVER
ITCH
WASTEWATER
FIGURE 2,7
GENERALIZED ZINC SUBCATEGORY MANUFACTURING PROCESSES
2-30
-------
TABLE 2.8
ZINC SUBCATEGORY ANALYSIS
Grouping
Anode
Manufacture
Cathode
Manufacture
Element
Cast or Fabricated
Zinc Powder-Wet Amal-
gamated
Zinc Powder-Gelled
Amalgam
Zinc Powder-Dry
Amalgamated
Zinc Oxide Powder-
Pasted or Pressed
Zinc Oxide Powder-
Pasted or Pressed,
Reduced
Zinc Electrodeposited
Porous Carbon
Manganese Dioxide-
Carbon
Mercuric Oxide (and
mercuric oxide -
manganese dioxide
carbon)
Mercuric Oxide-
Cadmium Oxide
Specific Wastewater Sources
(Subelement)
• No Process Wastewater
• Floor Area and Equipment
Cleanup
• Spent Aqueous Solution
• Amalgam Rinses
• Reprocess Amalgam Rinses
• Floor Area and Equipment
Cleanup
• No Process Wastewater
No Process Wastewater
• Post-formation Rinse
Post-electrodeposition
Rinses
Spent Amalgamation
Solution
Post-amalgamation Rinse
No Process Wastewater
No Process Wastewater
No Process Wastewater
• No Process Wastewater
2-31
-------
TABLE 2.8 (continued)
ZINC SUBCATEGORY ANALYSIS
Grouping
Cathode
Manufacture
(Cont'd.)
Element
Silver Powder Pressed
Silver Powder Pressed
and Electrolytically
Oxidized (Formed)
Specific Wastewater Sources
(Subelement)
* No Process Wastewater
• Post-formation Rinse
Ancillary
Operations
Silver Oxide
(Ag O) Powder
2
Silver Oxide
(Ag O) Powder-
2
Thermally Reduced or
Sintered, Electro-
lytically Formed
Silver Peroxide (AgO)
Powder
Nickel Impregnated
and Formed
Cell Wash
Electrolyte Pre-
paration
Silver Etch
Mandatory Employee
Wash
Reject Cell Handling
2-32
No Process Wastewater
Slurry Paste Preparation
Spent Caustic Formation
Post-formation Rinse
Utensil Wash
Spent Solution
Product Rinse
Product Soak
Refer to Cadmium Sub-
category Analysis
(Table 2.2)
Acetic Acid Cell Wash
Chromic Acid Containing
Cell Wash :
Methylene Chloride Celll
Wash
Freon Cell Wash
Non-chemical Cell Wash
Equipment Wash
Product Rinse
Employee Wash
Reject Cell Handling
-------
TABLE 2.8 (continued)
ZINC SUBCATEGORY ANALYSIS
Grouping Element. Specific Wastewater Sources
(Subelement)
Ancillary Floor Wash and Equip- * Floor and Equipment Wash
Operations ment Wash
(Cont'd.)
Silver Powder Pro- • Product Rinse
duction
Silver Peroxide • Product Rinses
Production • Spent Solution
2-33
-------
manufacturing categorical pretreatment standards. Grid casting,
continuous (direct chill) casting of lead, and melting furnaces
as applied to battery manufacturing are regulated here rather
than under the metal molding and casting category.
Additionally, lead rolling performed at lead battery plants
is addressed here rather than under the nonferrous metals forming
category. Wastewater generated by battery manufacturers1 lead
rolling operations currently are not discharged but rather are
hauled by licensed contractors. Although there are no
promulgated standards for this unit process, a discharge
allowance may be established on a case-by-case basis using
guidance contained in Volume II of the final development document
for battery manufacturing.
Production-based mass limitations only have been established
for battery manufacturing because flow reduction is a significant
part of the model technology for pretreatment. Categorical stan-
dards based on flow reduction cannot be meaningfully expressed on
a concentration basis. Site specific concentration standards
may, in some cases, be applied by the Control Authority in
accordance with EPA's Guidance Manual for the Use of Production-
Based Pretreatment Standards and the Combined Wastestream Formula.
The battery manufacturing standards include daily maximum
and maximum monthly average mass standards. The pretreatment
standards for existing sources (PSES) are presented in Table B-l
in Appendix B. The pretreatment standards for new sources (PSNS)
apply to battery manufacturing plants which began their operation
after November 10, 1982, the date of the proposed regulation.
2-35
-------
manufacturing categorical pretreatment standards. Grid casting,
continuous (direct chill) casting of lead, and melting furnaces
as applied to battery manufacturing are regulated here rather
than under the metal molding and casting category.
Additionally, lead rolling performed at lead battery plants
is addressed here rather than under the nonferrous metals forming
category. Wastewater generated by battery manufacturers1 lead
rolling operations currently are not discharged but rather are
hauled by licensed contractors. Although there are no
promulgated standards for this unit process, a discharge
allowance may be established on a case-by-case basis using
guidance contained in Volume II of the final development document
for battery manufacturing.
Production-based mass limitations only have been established
for battery manufacturing because flow reduction is a significant
part of the model technology for pretreatment. Categorical stan-
dards based on flow reduction cannot be meaningfully expressed on
a concentration basis. Site specific concentration standards
may, in some cases, be applied by the Control Authority in
accordance with EPA's Guidance Manual for the Use of Production-
Based Pretreatment Standards and the Combined Wastestream Formula.
The battery manufacturing standards include daily maximum
and maximum monthly average mass standards. The pretreatment
standards for existing sources (PSES) are presented in Table B-l
in Appendix B. The pretreatment standards for new sources (PSNS)
apply to battery manufacturing plants which began their operation
after November 10, 1982, the date of the proposed regulation.
2-35
-------
The PSNS are presented in Table B-2 in Appendix B. There are
no discharge allowances provided for process wastewater
pollutants from any battery manufacturing operation other than
those listed.
2.6 GUIDANCE FOR CONSIDERATION OF EMPLOYEE SHOWER WASTEWATER
AT LEAD SUBCATEGORY PLANTS
When EPA promulgated the battery manufacturing categorical
pretreatment standards on March 9, 1984, EPA determined that no
discharge allowance should be provided for employee showers at
lead subcategory plants. EPA reasoned that relatively few
employees in lead battery plants are exposed to high lead dust
levels and that adequate means are available for assuring that
substantially all lead is removed prior to showering. Therefore,
EPA concluded that there is no need for a plant to discharge
employee shower wastewater as regulated process wastewater (i.e.,
as water that has become contaminated with substantial amounts of
lead) and that employee shower wastewater can be discharged as
sanitary wastewater.
Following promulgation of the battery manufacturing
categorical standards, members of the lead battery manufacturing
industry argued that, in some cases, employee shower wastewater
may be significantly contaminated and require treatment. No data
were submitted to demonstrate the actual concentrations of lead
in shower wastewater and EPA continues to believe that shower
wastewater should not be classified as process wastewater. How-
ever, showers are required by the Occupational Safety and Health
Administration (OSHA) for battery plant employees working in
3
areas with lead exposure in excess of 50 mg/m (see 29 CFR
2-36
-------
Section 1910.1025). This indicates a potential for contamination
of some employee shower wastewater with some amount of lead.
Therefore, EPA believes that individual plants should have the
opportunity to demonstrate that their particular shower waste-
waters are significantly contaminated and should be accounted for
accordingly. As a result of a settlement agreement made between
EPA and the lead battery manufacturers, EPA addressed this con-
cern in an amendment promulgated on August 28, 1986 (see 51 FR
30814 to 30817).
The amendment modifies the way that contaminated shower
wastewaters are considered in the combined wastestream formula.
The combined wastestream formula (CWF), which is discussed in
more detail in Section 4.4 of this manual, provides a means for
determining final discharge limits for indirect industrial dis-
chargers that combine different wastestreams prior to treatment
and subsequently discharge the treated combined wastestream(s) to
a POTW. The formula treats certain types of wastestreams, in-
cluding sanitary wastestreams that are not regulated by a
categorical pretreatment standard, as "dilution" streams. Thus,
before the amendment battery shower wastewater was considered a
dilution stream. As now amended, the Control Authority is
authorized to exercise its discretion to classify shower waste-
water as an "unregulated" stream rather than a dilution stream
when the shower wastewater contains a significant amount of lead,
and the discharger combines the shower wastewater with process
wastestreams prior to treatment and discharge. Classification as
an unregulated rather than dilution stream would result in the
2-37
-------
consideration of shower wastewater as a contaminated stream that
may be combined with regulated wastestreams for purpose of waste-
water treatment. Unregulated wastestreams are afforded a pollu-
tant discharge allowance in the combined wastestream formula
while dilution streams are not.
EPA has selected 0.20 mg/1 as the concentration of lead that
represents a significant contamination of battery employee shower
wastewater. This is the lead concentration that was used by EPA
as a basis for establishing the monthly average lead mass limita-
tions in the regulation. EPA anticipates that a demonstration of
significant contamination would be based on sampling and analysis
data that show a lead concentration of 0.20 mg/1 or greater in
the shower wastewater. If the lead concentration in the waste-
stream is below 0.20 mg/1, the wastestream remains a dilution
stream.
The following discussion presents general information that
is useful for addressing shower wastewater issues that arise
during application and enforcement of the categorical pretreat-
ment standards for the lead subcategory of the battery
manufacturing category. When the Control Authority is requested
to consider the shower wastewater from a lead battery plant as an
unregulated wastestream, the Control Authority should:
• Request sampling and chemical analysis data to
support the classification of shower wastewater
as an unregulated wastestream.
• Determine an appropriate flow rate for the shower
wastewater.
• Confirm that the shower wastewater is discharged
to wastewater treatment prior to discharge to the
POTW. This is a very important point because the
amendment is only applicable to contaminated
2-38
-------
shower wastewater discharged to wastewater treat-
ment. Shower wastewater discharged directly to
the POTW is classified as a sanitary wastestream.
The lead sampling and analysis data provided for the shower
wastewater should be carefully reviewed by the Control Authority.
Sample collection methods should be examined to determine whether
the wastestream was sampled in a representative manner. EPA
recommends the use of grab composite or automatic composite
sampling techniques to determine the lead concentration in the
shower wastewater. The composite grab sample(s) should be
collected over the entire length of one or more shower periods.
The use of one-time grab samples is not recommended to determine
the lead concentration of this stream.
The justification for collection of composite samples rather
than one-time grab samples is as follows. It is reasonable to
assume that most of the lead on a battery employee will be washed
away during the early stages of a shower and the wastewater
generated from the final stages of the shower will probably
contain very little lead. Since employees usually do not shower
at exactly the same time during any given shower period the lead
concentration of shower wastewater will vary significantly and
irregularly over the course of the shower period. Therefore, a
sample of the shower > wastewater at one specific time (grab
sample) almost never results in a representative sample. The
determination of whether shower wastewater is "significantly
contaminated" is based on a representative average and not an
instantaneous high value, as might be obtained by a grab sample
at the beginning of a shower period.
2-39
-------
EPA also recommends that plant specific sampling data be
required for employee shower wastewater since lead concentrations
may vary from plant to plant. This recommendation is based on
the premise that employees who work in areas with higher lead
dust exposure levels carry more lead into the shower area than
employees who work in areas with lower exposure levels. Since no
two plants have exactly the same exposure levels for all
employees, the amount of lead introduced into shower wastewater
will vary from plant to plant. In addition, the OSHA standards
only require battery employees working in areas with exposure
3
levels in excess of 50 mg/m of air to shower. However, at some
battery plants, showers are also provided for employees exposed
3
to less than 50 mg/m . The shower wastewater at these plants
should contain lower lead concentrations than the wastewater from
plants where showers are only provided for employees exposed to
3
lead levels in excess of 50 mg/m . Therefore, plant specific
sampling data should be used to demonstrate the contamination of
shower wastewater.
The sample point location for the employee shower wastewater
should also be reviewed by the Control Authority. The most
desirable sample point location is the drain from the employee
shower area. The sample should be collected directly from the
drain pipe, if possible, or by partially blocking the drain to
allow for sampling of the wastewater accumulated around the drain
area.
The Control Authority must also determine an appropriate
flow range for the shower wastewater. A reasonable flow range is
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I/
25 to 30 gallons of wastewater for each employee that showers.
If a plant reports a flow greater than 25 to 30 gallons per
employee, water use practices for the shower area should be
carefully examined. One practice that leads to excessive water
use in the shower area is failure to turn off the flow of water
when employees are finished with their shower.
2.7 COMPLIANCE DATES
The compliance dates for new and existing facilities in the
battery manufacturing category are as follows:
Pretreatment Standards for March 9, 1987
Existing Sources (PSES)
Pretreatment Standards for Upon commencement
New Sources (PSNS) of discharge
(applies to any "new" plant
operating after
November 10, 1982)
i/
References listed on page Rl of this manual.
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3. TREATMENT TECHNOLOGIES
Wastewaters from battery manufacturing may be acid or alka-
line, may contain substantial levels of particulate and dissolved
metals, may contain small or trace amounts of toxic organics, and
are generally free from strong chelating agents. In general,
these pollutants are removed by chemical precipitation followed
by sedimentation or by sedimentation and filtration (lime and
settle, or lime, settle, and filter). The basis for the PSES
regulating the cadmium, lead, and zinc subcategories is the model
technology equivalent to BAT (best available technology) which
consists of flow reduction, oil skimming, and lime and settle.
The technology basis for PSES in the magnesium sub-category is
settle/recycle for heat paper production and lime and settle for
other wastewaters. The basis for PSES for the Leclanche
subcategory is lime, settle, and filter and water reuse where
possible. PSNS for all subcategories are based on the technology
equivalent to new source performance standards (NSPS) which
generally includes lime, settle, and filter. Treatment
techniques available to remove or recover wastewater pollutants
generated by battery manufacturing operations include individual
end-of-pipe and in-process technologies. While these are the
treatment technologies PSES and PSNS are based upon, individual
plants may use other technologies that achieve the standards at
their plants.
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3.1 END-OF-PIPE TREATMENT TECHNOLOGIES
The major end-of-pipe technologies for treating battery
manufacturing wastewaters are: oil skimming, chromium reduction,
chemical precipitation of dissolved metals, settling of suspended
solids, pressure filtration, and granular bed filtration. Al-
though not considered a major treatment technology for the
battery manufacturing category, membrane or polishing filtration
is often used following precipitation and sedimentation for more
consistent metals removal.
Skimming is used in battery manufacturing to remove free oil
used as a preservative or forming lubricant for various metal
battery parts and in lubricants used for drive mechanisms and
other machinery. Skimming removes pollutants with a specific
gravity less than water and is often found in conjunction with
air flotation or clarification to increase its effectiveness.
Common skimming mechanisms include the rotating drum type, a belt
type skimmer (which pulls a belt vertically through the water
thereby collecting oil), and API separators (which skim a
floating oil layer from the surface of the wastewater).
Chemical reduction of chromium is used in battery
manufacturing for treating chromium-bearing wastewater, primarily
from heat paper production in the calcium, lithium and magnesium
subcategories. The treatment of hexavalent chromium involves
reducing the hexavalent chromium to its trivalent form and
subsequent removal with a conventional precipitation-solids
removal system. Reduced chromium is removed from solution in
conjunction with other metallic salts by alkaline precipitation.
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In most cases, gaseous sulfur dioxide is used as the reducing
agent,
Chemical precipitation, followed by sedimentation,
filtration, or centrifugation, is used in battery manufacturing
for removal of dissolved metals. Chemical precipitation involves
adding a reagent to wastewater that will transform dissolved
metals to a non-dissolved state, permitting them to be removed by
settling, filtration or centrifugation. Reagents commonly used
are:
1) Alkaline compounds, such as lime or sodium hydroxide,
precipitate metals as hydroxides;
2) Soluble sulfides, such as hydrogen sulfide or sodium
sulfide, and insoluble sulfides such as ferrous sulfide,
precipitate metals as sulfides;
3) Ferrous sulfate or zinc sulfate precipitate
cyanide as a ferro or zinc ferricyanide complex;
4) Carbonates precipitate metals directly as carbonates,and
carbon dioxide converts hydroxides to carbonates.
The performance of chemical precipitation depends on the
following: maintenance of an appropriate pH (usually alkaline)
throughout the precipitation reaction and subsequent settling;
the addition of a sufficient excess of treatment ions to drive
the precipitation reaction to completion; the addition of an
adequate supply of sacrificial ions (such as aluminum or iron) to
ensure precipitation and removal of specific target ions; and
effective removal of the precipitated solids using appropriate
solids removal technologies.
Settling and clarification are used in battery manufacturing
to remove precipitated metals. Settling removes solid particles
from a liquid matrix by gravitational force. Settling is
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accomplished by reducing the velocity of the feed stream in a
large volume tank or lagoon so that gravitational settling can
occur." Settling is most often preceded by chemical precipitation
which converts dissolved pollutants to a solid form and by
coagulation of suspended precipitates into larger, faster
settling particles (using coagulants or polyelectrolytic floccu-
lants).
Pressure filtration is used in battery manufacturing for
sludge dewatering and for direct removal of precipitated and
other suspended solids from wastewater. Pressure filtration
works by pumping the water through a filter material which is
impenetrable to the solid phase thus separating the solids from
the water.
Granular bed filtration using filter media such as silica
sand, anthracite coal, and garnet supported by gravel are common-
ly used to remove suspended solids and colloidal particles.
Wastewater treatment plants often use granular bed filters for
polishing after clarification, sedimentation, or similar opera-
tions. The classic granular bed filter operates by gravity flow,
although pressure filters are also widely used.
3.2 IN-PROCESS CONTROL TECHNOLOGIES
In-process control technologies are intended to reduce or
eliminate the amount of pollutants or the volume of wastewater
requiring end-of-pipe treatment thereby improving the quality of
the effluent discharge. The in-process technologies which are
applicable to most battery manufacturing subcategories discussed
here are waste segregation, water recycle and reuse, water use
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reduction, process modification, and plant maintenance and good
housekeeping. Specific application of these techniques varies
among the battery manufacturing subcategories and some apply only
to specific processing steps. Additional details are in Section
VII of the final technical development documents for battery
manufacturing.
Waste segregation of multiple process wastewater streams
having significantly different chemical characteristics may lead
to reductions in treatment costs and pollutant discharges. Bat-
tery manufacturing commonly produces waste streams with high
concentrations of toxic metals, containing primarily suspended
solids, and others that are quite dilute. Separation of these
individual process wastestreams may improve the quality of the
effluent discharge since treatment of more concentrated waste-
streams is usually more efficient than treatment of dilute
streams. Similarly, separation of noncontact cooling water from
process wastewater prevents dilution of the process wastes and
maintains the purity of the noncontact stream for subsequent
reuse or discharge.
Wastewater recycle and reuse are frequently possible without
treatment or with minimum treatment of the wastewater, and there-
fore are effective in reducing pollutant discharges and overall
treatment costs. Recycle applies to the return of process waste-
water usually after treatment to the process or processes from
which it originated, and reuse applies to the use of wastewater
from one process into another process. The most frequently
recycled wastestreams include air pollution control scrubber
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discharges, and wastewater from equipment and area cleaning. In
addition, wastewater from some product rinsing operations and
contact cooling waters are available for recycle or reuse.
Water use reduction includes reducing the volume of waste-
water discharge by simply eliminating excess flow and unnecessary
water use. Often this can be accomplished by employing automatic
shutoff valves or manual controls to turn off water flows when
production units are inactive and by implementation of more
effective water use in some process operations, particularly in
rinsing operations and in equipment and area cleanup. Rinsing
efficiency can be increased by the use of multi-stage and
countercurrent cascade rinsing. Additional reduction in process
wastewater discharge may also be achieved by the substitution of
dry air pollution control devices such as baghouses for wet
scrubbers where the emissions requiring control are amenable to
these techniques.
Process modifications deal with process alternatives which
significantly affect the quantity and quality of wastewater
produced. In general, changes in electrolyte addition techniques
and changes in electrode formation processes are process changes
found most frequently in the battery manufacturing category. In
addition, changes in amalgamation procedures and improvements in
process control to reduce rework requirements are viable
techniques to reduce wastewater discharges. Most process modifi-
cations to reduce pollutant discharges are specific to individual
subcategories; however, one process modification applicable to
several subcategories is the substitution of alternative formula-
tions for cell wash materials containing chromate and cyanide.
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This substitution reduces or eliminates these pollutants from the
process wastewater.
Plant maintenance and good housekeeping practices can signi-
ficantly reduce pollutant loadings at battery manufacturing
plants due to the large quantities of toxic materials used as
active materials in battery electrodes. These materials are
handled at battery manufacturing plants and may be spilled in
production areas. The water used in the cleaning of spills may
contribute significantly to wastewater discharges. Good house-
keeping includes floor maintenance and treatment, preventing
leaks and spills, and cleaning up leaks and spills which cannot
be avoided as soon as possible.
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4. REQUIREMENTS OF THE GENERAL PRETREATMENT REGULATIONS
4.1 INTRODUCTION
This section provides a brief overview of the General Pre-
treatment Regulations for Existing and New Sources (40 CFR Part
403) and identifies those provisions of the regulations which
have a direct bearing on the application and enforcement of
categorical pretreatment standards for the battery manufacturing
category.
The General Pretreatment Regulations (40 CFR 403) establish
the framework and responsibilities for implementation of the
•S
National Pretreatment Program. The effect of these regulations
is essentially three-fold. First, they establish general and
specific discharge prohibitions as required by sections 307(b)
and (c) of the Clean Water Act. The general and specific
prohibitions are described in 40 CFR Section 403.5 of the General
i
Pretreatment Regulations and apply to all nondomestic sources
introducing pollutants into a POTW whether or not the source is
subject to categorical pretreatment standards.
Second, these regulations establish an administrative
mechanism to ensure that National Pretreatment Standards
(prohibited discharge standards and categorical pretreatment
standards) are applied and enforced upon industrial users.
Approximately 1,500 POTWs are required to develop locally
administered pretreatment programs to ensure that nondomestic
users comply with applicable pretreatment standards and require-
ments .
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Third, and most importantly for the purposes of this
guidance manual, the General Pretreatment Regulations contain
provisions relating directly to the implementation and enforce-
ment of the categorical pretreatment standards. Provisions
governing basic reporting requirements, local limits, compliance
monitoring activities, and the procedures associated with
categorical determinations are set out in the regulations. POTW
representatives are referred to 40 CFR Part 403 for specific
language and requirements.
EPA is considering making a number of changes to the General
Pretreatment Regulations. These changes will affect some of the
provisions of the pretreatment regulation discussed in this sec-
tion including the following:
• Baseline monitoring reports
• Report on compliance
• Periodic reports on continued compliance
The anticipated changes could alter the guidance in this
section. Therefore, the reader is advised to keep abreast of
changes to the General Pretreatment Regulations.
4.2 CATEGORY DETERMINATION REQUEST
An existing industrial user (IU) or its POTW may request
written certification from EPA or the delegated State specifying
whether or not the industrial user falls within a particular
industry subcategory and is therefore subject to a particular
categorical pretreatment standard. Although the deadline for
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submitting a categorical determination request by existing
industrial users subject to the battery manufacturing categorical
pretreatment standards has passed, a new industrial user may
request this certification for a category determination anytime
prior to commencing its discharge. Similarly, a POTW may request
the certification on behalf of the IU. Requests should be
directed to the EPA Regional Water Management Division Director
or the State Director as appropriate using the procedures set out
in 40 CFR 403.6(a). Additional assistance in determining the
proper category for wastewaters from such operations may be
obtained by contacting the Industrial Technology Division at U.S.
EPA Headquarters.
4.3 MONITORING AND REPORTING REQUIREMENTS OF THE GENERAL
PRETREATMENT REGULATIONS
In addition to the requirements contained in the battery
manufacturing categorical pretreatment standards, battery manu-
facturers discharging to POTWs must fulfill the reporting
requirements contained in 40 CFR Section 403.12 of the General
Pretreatment Regulations. These requirements include the submis-
sion of a baseline monitoring report, compliance schedule prog-
ress reports (when necessary), periodic compliance reports and
notices of slug loading, as well as a 3 year record-keeping
requirement. Each of these reporting requirements is briefly
summarized below.
4.3.1 Baseline Monitoring Reports
All industrial users subject to categorical pretreatment
standards must submit a baseline monitoring report (BMR) to the
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Control Authority. The purpose of the BMR is to provide
information to the Control Authority to document the industrial
user's current compliance status with a categorical pretreatment
standard. The Control Authority is defined as the POTW if it has
an approved pretreatment program, the state if the state has an
approved state pretreatment program or the EPA regional office if
neither the POTW or state have approved pretreatment programs.
Additional guidance on BMR reporting is available from the state
or EPA regional pretreatment coordinator (see the list of
guidance manuals in the References section of this document). A
complete listing of current EPA and state pretreatment
coordinators is provided in Appendix C.
BMR Due Dates
Section 403.12(b) requires that BMRs be submitted to the
Control Authority within 180 days after the effective date of a
newly promulgated categorical pretreatment standard or 180 days
after the final administrative decision made upon a categorical
determination request (see section 4.2 above), whichever is
later. The BMR due date for existing facilities in the battery
manufacturing category was October 20, 1984.
BMR Content
A BMR must contain the following information as required by
403.12(b).
1. Name and address of the facility, including names of
operator(s) and owner(s).
2. List of all environmental control permits held by or
for the facility.
3. Brief description of the nature, average production
rate and SIC code for each of the operation(s)
conducted, including a schematic process diagram
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which indicates points of discharge from the regulated
processes to the POTW.
4. Average daily and maximum daily flow data (in gallons
per day) for regulated process streams discharged to
the municipal system. Flow measurements of other
wastestreams will be necessary if application of the
combined wastestream formula is anticipated (see
section 4.4 below).
5. Identification of the applicable pretreatment standards
for each regulated process wastestream and the results
of measurements of flow rates and pollutant
concentrations (or mass where required by the standard
or the Control Authority). The mass of pollutants in
the wastestreams must be expressed in terms of daily
average and daily maximum values. Analytical methods
used must be in accordance with the procedures con-
tained in 40 CFR Part 136, or as otherwise directed and
approved by EPA. Sampling is to be undertaken using a
flow proportional composite method whenever possible.
Otherwise, where composite sampling is not feasible,
grab samples are appropriate. Samples must be
representative of daily operations. Where the flow of
the regulated stream being sampled is less than or
equal to 250,000 gallons per day, the industrial user
must take three samples within a two week period.
Where the flow of the stream is greater than 250,000
gallons per day, the industrial user must take six
samples within a two week period. If other wastewaters
are mixed with wastewater from the regulated process,
the industrial user should measure flows and
concentrations of the appropriate wastestreams to allow
use of the combined wastestream formula (see section
4.4 below). Proposed revisions to 40 CFR Part 403 may
alter the number of samples required to be submitted in
a BMR.
6. The BMR must include the dates, times and sampling
locations and the analytical methods used to derive the
testing results.
7. Finally, an authorized representative of the IU (see 40
CFR Section 403.12 (k) ) must certify as to whether
the facility is currently meeting the categorical pre-
treatment standards. In the event the standards are
not being achieved, the certification must contain a
compliance schedule which identifies the additional
operation and maintenance measures and/or abatement
technology necessary to bring the IU into compliance
and the timetable for completing these actions. The
final date for completing these actions and achieving
compliance must not exceed the compliance deadline
established by the standard. lUs are referred to 40
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CFR Section 403.12(b)(7) and (c) for more specific
instructions on preparing this compliance schedule.
4.3.2. Compliance Schedule Progress Report
In the event the IU certifies that it is not meeting the
categorical standard on a consistent basis a compliance schedule
must be submitted with the BMR that describes the actions the IU
will take and a timetable for completing those actions to achieve
compliance with the standard. The completion date in the
schedule must not be later than the compliance date established
for the particular categorical standard. The compliance
schedule must contain increments of progress and dates for
completion of each increment. Further, no increment shall exceed
nine months.
Within 14 days of each date in the compliance schedule, the
user must submit a progress report to the Control Authority. The
compliance schedule progress report must indicate whether or not
it complied with the increment of progress intended to be met.
If the target date was not met, the report must indicate a
revised date on which it expects to comply, the reasons for the
delay and the steps to be taken to return to the schedule
established in the BMR.
4.3.3 Report On Compliance
Within 90 days of the final compliance date for the battery
manufacturing pretreatment standards, or in the case of a new
source, following commencement of the introduction of wastewater
into the POTW, any industrial user subject to these standards
must submit to the Control Authority a compliance report that
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indicates whether or not applicable pretreatment standards are
being met on a consistent basis. The report must indicate the
nature and concentration of all regulated pollutants in the
facility's regulated process wastestreams; the average and maxi-
mum daily flows of the regulated streams; and contain a statement
as to whether compliance is consistently being achieved, and if
not, what additional operation and maintenance or pretreatment is
necessary to achieve compliance (see 40 CFR Section 403.12(d)).
4.3.4 Periodic Reports On Continued Compliance
All industrial users subject to the battery manufacturing
pretreatment standards must submit a biannual "periodic
compliance report" during the months of June and December unless
required more frequently by the Control Authority. The Control
Authority may change the months during which the reports must be
submitted. The report shall indicate the precise nature and mass
(and concentration if required by the Control Authority) of the
regulated pollutants in its discharge to the POTW during the
reporting period and the average and maximum daily flow rates.
The methods used to sample and analyze the data, and a certi-
fication that the methods conformed to those methods outlined in
the regulations should be included in the report. (see 40 CFR
Section 403.12(e)).
4.3.5 Notice Of Slug Loading
Section 403.12(f) requires industrial users to notify the
POTW immediately of any slug loading (i.e. discharge of any
pollutant, including oxygen demanding pollutants, to the POTW
system at a flow rate or pollutant concentration which might
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cause interference with the POTW.)
4.3.6 Monitoring And Analysis To Demonstrate
Continued Compliance
Section 403.12(g) states that industrial user reports aust
contain the results of sampling and analysis of the user's
discharge, but does not prescribe any particular frequency of
monitoring. The battery manufacturing pretreatment standards
also do not establish monitoring frequency. Therefore, the
appropriate Control Authority must establish the monitoring fre-
quency to adequately demonstrate that indirect dischargers sub-
ject to these pretreatment standards are in compliance with the
applicable standards. EPA has issued guidance on suggested moni-
toring frequencies for the first year until sufficient baseline
data are collected (see Pretreatment Compliance Monitoring and
Enforcement Guidance, July 1986).
Sampling and analysis shall be in accordance with the
procedures established in 40 CPR Part 136. When Part 136 techni-
ques are not available or are inappropriate for any pollutant,
sampling and analysis shall be conducted in accordance with
procedures established by the Control Authority or using any
validated procedure. However, all procedures for sampling and
analysis not included in Part 136 must be approved in advance by
EPA.
4.3.7 Signatory Requirements For Industrial User Reports
All reports submitted by industrial users (BMR, Initial
Report on Compliance, and Periodic Reports, etc.) must be signed
by an authorized representative in accordance with 40 CFR Section
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403.12(k). Note that false statements or misrepresentations in
the aforementioned reports are punishable by a fine of not more
than $10,000 or by imprisonment for up to 2 years, or by both
under Section 309(c)(4) of the CWA.
4.3.8 Recordkeeping Requirements
Records of all sampling activities required under the
regulations above must include dates, exact place(s), methods and
times as well as identifying the person(s) taking the sample. In
addition, testing records must indicate the dates and person(s)
performing the analysis as well as the analytical techniques used
and the results thereof. These records shall be maintained for a
minimum of three years (see 40 CFR Section 403.12(n)(2) and shall
be available for inspection and copying by the Control Authority.
4.4 APPLICATION OF THE COMBINED WASTESTREAM FORMULA
The Combined Wastestream Formula (CWF) (40 CFR Section
403.6(e)) is a mechanism for calculating appropriate discharge
limitations for combined wastestreams. The CWF was developed to
account for the dilutional effect of mixing one regulated
wastestream with other regulated, unregulated, or dilution
streams prior to treatment. The following definitions and condi-
tions are important to the proper use of the CWF.
Definitions
• Regulated Process Wastestream - an industrial process
wastestream regulated by national categorical pretreat-
ment standards.
• Unregulated Process Wastestream - an industrial process
wastestream that is not regulated by a categorical
pretreatment standard and is not a dilute wastestream
(see below).
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• Dilute Wastestream - Boiler blowdown, noncontact
cooling water, and sanitary wastewater (unless
regulated by the categorical pretreatment standard).
The Control Authority has discretion to classify boiler
blowdown and noncontact cooling water as unregulated
wastestreams when these streams contain a significant
amount of a regulated pollutant, and combining them
with regulated process wastewaters will result in a
substantial reduction of that pollutant (see 12 ERG
1833 and 40 CFR Part 403).
Note; These definitions apply to individual pollutants.
Therefore a wastestream from a process may be
regulated for one pollutant and unregulated for another.
* Mass-based Production Related Standard - a standard
setting forth the quantity (mass) of a pollutant
allowed to be discharged per each defined unit of
production. Usually for battery manufacturing expressed
in rag/kilogram of metal used or applied (Ib/million
pounds of metal used or applied).
* Mass-based Limit - a limit setting forth the quantity
(mass) of a particular pollutant which may be discharg-
ed in a specific wastestream. This is derived from
the mass-based production related standard and is
usually expressed in mg/day (Ib/day).
* Concentration-based Limit - a limit based on the
relative strength of a pollutant in a wastestream,
usually expressed in mg/1 (Ib/gal).
CWF Conditions
The regulations specify that the following conditions must
be met by a municipality and its industries when applying the
CWF:
* Alternative discharge limits calculated in place of a
categorical pretreatment standard must be enforced as
categorical pretreatment standards themselves.
• Calculation of alternative limits must be performed by
the Control Authority (generally the POTW) or by the
industrial user with written permission from the Con-
trol Authority.
* Alternative limits must be established for all
regulated pollutants in each of the regulated
processes.
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* The Control Authority should use mass limits, but may
use equivalent concentration limits when only
production based mass standards are provided by the
applicable categorical pretreatment standard.
* Both daily maximum and long-term average (usually
monthly) average alternative limits must be calculated
for each regulated pollutant.
• An industrial user operating under an alternative limit
derived from the CWF must immediately report any signi-
ficant or material changes in the regulated, unregu-
lated or dilution wastestreams or production rates to
the Control Authority.
• If a facility institutes process changes or production
rates change and these changes warrant, the Control
Authority may recalculate the alternative limits at its
discretion or at the request of the industrial user.
The new alternative limits will be calculated within 30
days of receiving notice of the change(s).
* The Control Authority may impose stricter alternative
limits, but may not impose alternative limits that are
less stringent than the calculated alternative limits.
• A calculated alternative limit cannot be used if it
results in a discharge limit below the analytical
detection level for that pollutant. If a calculated
limit is below the detection limit, the IU must either:
1) not combine the dilute streams before they reach the
combined treatment facility, or 2) segregate all waste-
streams entirely.
• The categorical pretreatment standards for the
regulated wastestreams which are applied to the CWF
must be consistent in terms of the number of samples on
which the standard is based.
Monitoring Requirements for IndustrialUsersUsing the CWF
Self-monitoring requirements by an industrial user are
necessary to ensure compliance with the alternative discharge li-
mit. Because battery manufacturing pretreatment standards do not
include self-monitoring requirements, the Control Authority will
establish minimum self-monitoring requirements.
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Application of the CWF
The actual combined wastestream formulas used with the
categorical pretreatment standards are presented in Table 4.1. It
is important to remember that when two or more regulated waste-
streams from different regulated categories are mixed prior to
treatment, it is necessary to determine which pretreatment
regulation applies to each separate regulated wastestream. All
dilution and unregulated wastestreams need to be identified.
Table 4.2 presents an example of how the CWF is used to
calculate alternative limits for specific battery manufacturing
operations. The example applies to an integrated facility that
has operations regulated by the battery manufacturing categorical
pretreatment standards, as well as the metal finishing
categorical pretreatment standards.
Flow Weighted Averaging
The CWF is applicable to situations where wastewater streams
are combined prior to treatment. However, for facilities that
combine regulated process wastewaters with waters that are not
regulated after treatment but prior to monitoring by the Control
Authority (usually at the discharge point to the sanitary sewer),
a flow weighted average or more stringent approach must be used
to adjust categorical pretreatment standards. The flow weighted
averaging formula for use in these circumstances is set out in
Table 4.3.
4.5 REMOVAL CREDITS
A removal credit allows a POTW to provide its industrial
users with a credit (in the form of adjusted categorical pre-
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TABLE 4.1
COMBINED WASTESTREAM FORMULAS
Alternative Mass Limit Formula
M = / „ Ml x
cwf
M - alternative mass limit for the pollutant
cwf
M - Categorical Pretreatment Standard mass limit for
i the pollutant in regulated stream i
F - average daily flow (at least 30 day average) of regulated
i stream i
F - average daily flow (at least 30 day average) of dilute
D wastestream(s)
F - average daily flow (at least 30 day average) through the
T combined treatment facility (including regulated,
unregulated and dilute wastestreams)
N - total number of regulated streams
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TABLE 4.1
COMBINED WASTESTREAM FORMULAS (Continued)
Alternative Concentration Limit Formula:
C =
cwf
C F
i i
T
D
T
C - alternative concentration limit for the pollutant
cwf
C - Categorical Pretreatment Standard concentration limit for
i the pollutant in regulated stream i
F - average daily flow (at least 30 day average) of regulated
i stream i
F - average daily flow (at least 30 day average) of dilute
D wastestream(s)
F - average daily flow (at least 30 day average) through the
T combined treatment facility (including regulated,
unregulated and dilute wastesteams)
N - total number of regulated streams
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TABLE 4-2
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
The following example provides calculations for determining
alternate discharge limits for nickel using the combined
wastestream formula. The following calculations assume combina-
tions of various regulated and dilute wastestreams with the
following characteristics. All wastestreams are combined prior
to treatment.
Wastestream Flow
Wastestream Type (gpd)
Battery Manufacturing
(Cadmium Subcategory)
Electrodeposited regulated 2,000
Anodes
Nickel regulated 13,000
Impregnated
Cathodes
Metal Finishing regulated 15,000
(Nickel Plating)
Sanitary dilute 50,000
The alternative discharge limit for nickel (daily maximum)
at a cadmium battery manufacturing plant that also performs
nickel plating and discharges sanitary wastewater is calculated
as follows.
SOLUTION
Step l: Determine the applicable nickel daily maximum limit for
each wastestream.
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TABLE 4-2
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS (continued)
BATTERY MANUFACTURING
Cadmium Electrodeposited Anodes
Average Daily Production
Maximum Daily Limit for Nickel
Average Daily Water Use
Allowable Nickel Mass =260 (67.49)
Nickel Impregnated Cathodes
Average Daily Production
Daily Maximum Limit for Nickel
= 260 kg/day of cadmium
applied
= 67.49 mg/kg of cadmium
applied
= 2,000 gpd
= 17,547 mg/day
= 230 kg/day of nickel
applied
= 384 mg/kg of nickel
applied
Average Daily Water Use
Allowable Nickel Mass = 230 (384)
Total Battery Manufacturing
Total Allowable Nickel Mass for Battery Mfg.
Average Daily Water Use for Battery Mfg.
Equivalent Concentration for Battery Mfg.
METAL FINISHING
Average Daily Production
Daily Maximum Limit for Nickel
Average Daily Water Use
= 13,000 gpd
= 88,320 mg/day
= 105,867 mg/day
= 15,000 gpd
= 1.86 mg/1
for Nickel
= not required
=3.98 mg/1
= 15,000 gpd
Allowable Nickel Limit =3.98 (15,000 x 3.785) = 225,965 mg/day
4-16
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TABLE 4-2. COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS
(Continued)
Step 2: Draw a schematic showing processes, flows
and applicable limits.
Battery Manufacturing
Cadmium Subcategory
(Nickel Inpregnated
Cathodes)
13,000 gpd
Ni = 88,320 mg/day
Battery Manufacturing
Cadmium Subcategory
(Cadmium Electro-
deposited Anodes)
Metal Finishing
(Nickel Plating)
Sanitary
Wastes
2,000 gpd
Ni = 17,547 mg/day
Ni
I
I-1
15,000 gpd
Ni = 105,867 mg/day
(1.8 6 mg/1)
15,000 gpd
225,989 mg/day
(3.98 mg/1)
50,000 gpd
Ni = N/A
i
Pretreatment
T
POTW
Adjusted Categorical
-Pretreatment Standards
Apply Here
-------
TABLE 4-2
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS (continued)
Step 3: Using the combined wastestream formula (mass or
concentration limit formula), substitute the
appropriate values and calculate the adjusted limit.
a) Mass Limit Formula
/ F - F
N
M = Z Mi x
cwf i=l
15,000 + 15,000 + 50,000 - 50,000 gpd
Ni = 105,867 + 225,965 X
cwf mg/day mg/day
15,000 + 15,000 gpd
Ni = 331,832 mg/day
cwf
Ni = 0.332 kg/day
cwf
b) Concentration Limit Formula
/
/N
/ z
c =
cwf
Ci Fi
N
i=l
Fi
x
F - F
T D
/I.86 mg/1 x 15,000 gpd + 3.98 mg/1 x 15,000 gpd
Ni = I x
cwf \
15,000 gpd + 15,000 gpd
15,000 + 15,000 + 50,000 - 50,000 gpd
15,000 + 15,000 + 50,000 gpd
4-18
-------
TABLE 4-2
COMBINED WASTESTREAM FORMULA EXAMPLE CALCULATIONS (continued)
Ni = 2.925 X 0.375
cwf
Ni = 1.097 mg/1
cwf
Step 4: Observe significant figures
Ni = 332,000 rag/day or 1.10 mg/1
cwf
Step 5: Calculate the adjusted long term average (maximum
monthly average) for nickel.
Step 6: Calculate adjusted limits for other regulated
pollutants.
4-19 ,
-------
TABLE 4.3
FLOW-WEIGHTED AVERAGING (FWA) FORMULAS
FWA FORMULA WITH ALGEBRAIC TERMS
N
(C F ) + ( E C F )
cwf t i=i nri nri
(1) C =
fwa
F1
t
(2) M M + M
fwa cwf nr
EQUATION JL
C - alternative pollutant concentration limit in combined
fwa wastestreams after treatment derived using FWA
C - alternative pollutant concentration limit in treatment
cwf unit effluent, derived using the CWF
F - average daily flow (at least 30 day average) through the
t combined treatment facility
C - concentration of nonregulated waste stream i
nri
F - average daily flow (at least 30 day average) of non-
nri regulated wastestream i
F1 - average daily flow (at least 30 day average) into
t regulated monitoring point (generally point of
discharge to sanitary sewer)
EQUATION £
M - alternative pollutant limit in combined wastestreams
fwa after treatment derived using FWA
M - alternative pollutant mass limit in treatment unit
cwf effluent, derived using the CWF
M - mass of the pollutant in nonregulated wastestreams
nr
4-20
-------
treatment standards) for consistent removal of pollutants by the
POTW. Industrial users receiving such a credit are allowed to
discharge to the POTW greater quantities of regulated pollutants
than otherwise permitted by applicable categorical pretreatment
standards. Section 403.7 of the General Pretreatraent Regulations
establishes the conditions under which a POTW can obtain
authorization to grant removal credits. Removal credits are
pollutant specific (i.e., may only be granted on a pollutant by
pollutant basis).
In order to qualify for removal credit authority a POTW must
satisfy the conditions set out in the regulations including a
demonstration of the POTW's ability to "remove" the pollutant in
question on a long tern? or consistent basis, that is, the removal
is not subject to significant seasonal variations. Removal
credits can only be granted for pollutants regulated by a
categorical pretreatment standard.
Approval for removal credits may not be granted if it will
cause the POTW to violate its NPDES permit. Other criteria
including compliance with water quality criteria and standards
and sludge disposal regulations must be satisfied as well. Even
though the POTW may be located in an NPDES State which has an
approved state pretreatment program, final approval of the POTW's
request rests with EPA, unless EPA has granted or delegated final
approval authority to the state through a State/EPA Memorandum
of Agreement (MOA).
Note; The removal credits regulation promulgated on August 3,
1984 (49 FR 31212) was challenged as too lenient by an
4-21
-------
environmental group, the Natural Resources Defense Council
(NRDC). The United States Court of Appeals for the Third Circuit
ruled in favor of NRDC, concluding that EPA's 1984 removal credit
rule fails to meet the requirements mandated by Section 307 of
the Clean Water Act (NRDC v. EPA, 790 F.2 d 289 (3rd Cir 1986).
Although several parties petitioned the Supreme Court to review
the Third Circuit ruling, the Court denied the requests. Thus,
the Third Circuit decision became final.
In addition to the litigation described above, the
amendments to the Clean Water Act contain a provision which would
vacate one element of the Third Circuit's decision - the sludge
question - as it effects POTWs currently authorized to grant
removal credits (as of the date of enactment.) However, this
congressional reprieve would lapse on August 31, 1987, the date
the Agency is required to have final regulations addressing toxic
pollutants in municipal sludge. As a result of these complica-
tions, no regulatory basis currently exists for the granting of
removal credits.
4.6 FUNDAMENTALLY DIFFERENT FACTORS (PDF) VARIANCE
A request for a fundamentally different factors variance is
a mechanism by which a categorical pretreatment standard may be
adjusted, making it more or less stringent, on a case-by-case
basis. If an industrial user, a POTW, or any interested person
believes that the factors relating to a specific industrial user
are fundamentally different from those factors considered during
development of the relevant categorical pretreatment standard and
that the existence of those factors justifies a different
4-22
-------
discharge limit from that specified in the categorical
pretreatment standard, then they may submit a request to EPA for
such a variance within 180 days after the effective date of the
standard (see 40 CFR Section 403.13).
Although EPA has no statutory basis for granting adjustments
to categorical pretreatment standards because a source is
"fundamentally different", the U.S. Supreme Court has previously
recognized the FDF variance's legitimacy as an administrative
tool to address concerns with both direct and indirect
dischargers. In fact, in CMA v. NRDC, 53 LW 4193 (No. 83-1013,
2-27-85), the Court upheld EPA in a challenge to the Agency's
determination that under the appropriate circumstances FDF
variances could be granted for toxic pollutants, otherwise
regulated by categorical pretreatment standards. For other court
decisions on FDF variances the reader is referred to E.I.
duPont de Nemours v. Train, 430 U.S. 112 (1977) and
EPA v. National Crushed Stone Assoc. 449 U.S. 64 (1980).
4.7 LOCAL LIMITS
Local limits are numerical pollutant concentration or mass-
based values that are developed by a POTW for controlling the
discharge of conventional, non-conventional or toxic pollutants
into its sewer systems. They differ from National Categorical
Pretreatment Standards in that categorical pretreatment standards
are developed by EPA and are based upon the demonstrated perfor-
mance of available pollutant control technologies (for specific
categorical industries). These national technology-based catego-
rical standards do not consider local environmental criteria or
4-23
-------
conditions, and are only developed to assure that each point
source within a specified category meets a minimum discharge
standard which is consistent across the United States for all
POTWs.
Local limits, on the other hand, are developed to address
specific localized impacts and factors that are unique to the
POTW. Local limitations must be designed to protect the POTW
from:
* Introduction of pollutants into the POTW which could
interfere with its operation, including contamination
of a POTWs sludge which would limit sludge uses or
disposal practices.
* Pass-through of inadequately treated pollutants which
could violate a POTWs NPDES permit or applicable water
quality standards I/
Local limits are required under 40 CFR Section 403.5 and must
be developed when it is determined that categorical pretreatment
standards are not sufficient to enable the POTW to prevent
interference and pass-through. For more information on the
minimum local limit requirements for POTWs with approved
pretreatment programs and the relationship between local limits
and categorical pretreatment standards, refer to the memorandum
signed by Rebecca Hanmer on August 5, 1985 entitled
Local Limit Requirements for POTW Pretreatment Programs. Copies
of this memorandum can be obtained from the 1PA regional
pretreatment coordinators listed in Appendix C.
I/ The terms "pass through" and "interference" are defined more
precisely in 40 CFR Section 403.3.
4-24
-------
In addition to protecting against interference and pass-
through, local limits must be developed to protect the POTW from
discharges that may result in:
* Fire or explosion
* Corrosion
* Obstruction of flow in sewers
* Excessive discharge of conventional pollutants
• Heat that may cause interference
EPA encourages local limits for volatile toxic substances to
protect worker health and safety as well.
To assist municipalities in developing defensible and
technically sound numerical effluent limitations, EPA has pre-
pared some general guidelines on limit development in its
document Guidance Manual for POTW Pretreatment Program Develop-
ment dated October 1983. Appendix L of this document lists the
general methodology, required formulas and typical environmental
criteria used to develop local limits. This manual is available
from EPA regional offices and NPDES states and should be careful-
ly followed when developing local limits. Although a detailed
discussion of local limits development is beyond the scope of
this document, the general methodology includes the following
five steps:
Step 1 - Survey conditions of collection system and monitor
sewer atmosphere to determine whether limits are
necessary to prevent collection system hazards.
Step 2 - Determine the maximum raw waste loading to the
headworks of the treatment plant (for each
specific pollutant) that will assure that the POTW
does not experience interference or pass-through
4-25
-------
Step 3 - Calculate the allowable loading to the POTW by
subtracting the uncontrollable portion of
pollutant discharge to the POTW (from domestic and
infiltration/inflow sources) from the total raw
waste loading value.
Step 4 - Distribute the controllable loading to industrial
users through an allocation process.
Step 5 - Derive specific local limits from the allocation
results and from the survey of the collection
system.
The above five-step process must be performed for each
pollutant which the POTW determines may need a specific local
limitation. As a general rule, the limit setting analysis should
be performed for all pollutants which are discharged to the POTW
in significant quantities. The POTW should identify pollutants
of concern through an evaluation of the POTW's industrial waste
survey. A procedure for evaluating industrial waste survey re-
sults is also included in the EPA guidance manual mentioned
earlier.
In addition, EPA has developed a computer software program
that incorporates the general methodology required to develop
local limits and alleviates a substantial amount of the tedious
calculations required to develop these limits. This computer
program has the following capabilities to aid the POTW in limit
development;
• Performs the four-step limit setting analysis on a
microcomputer
• Supplements POTW data with "built-in" files containing
data on industrial/municipal wastewater characteris-
tics, POTW removal rates, and biological process
inhibition data
• Allocates controllable pollutant loads using several
different methodologies
4-26
-------
POTWs may obtain information on this computer program by
contacting any of the ten EPA regional offices. Instructions
will be provided on how to use the computer program as well as
how to access a computer system which supports it.
4-27
-------
-------
5. APPLICATION OF BATTERY MANUFACTURING CATEGORICAL
PRETREATMENT STANDARDS
This section provides guidance to Control Authorities on how
to apply production-based standards. Production-based standards
are expressed in terms of allowable pollutant mass discharge per
unit of production (mg/kg). Direct application of this standard
would require the Control Authority to make direct measurements
of the flow of the regulated wastestreams and the corresponding
current production rate. Rather than measure the production rate
each time compliance monitoring is performed, the Control
Authority may use equivalent mass or equivalent concentration
limits. A reasonable representation of the industrial facility's
actual production and actual flows are used to derive these
limits that are essentially equivalent to the production-based
standards. EPA recommends that long-term average production and
flow rates be determined based on the examination of several
years (such as 5 years) of data. In some cases production may
have specific seasonal fluctuations. The Control Authority may
choose to issue a tiered permit (more than one standard based on
different production levels) if significant change in the long-
term average production is expected during the term of the
permit. Further guidance can be found in EPA's Guidance Manual
for the Use of Production Based Pretreatment Standards and the
Combined Wastestream Formula.
An example of how to develop mass equivalent limits and use
the combined wastestream formula (CWF) was presented in Section
4.4. Another example is provided to demonstrate the application
5-1
-------
of production based standards to a lead subcategory battery
plant, which many Control Authorities may encounter. Concepts
used in this example can be applied to the other battery subcate-
gories. If difficulties are encountered, the Control Authority
is encouraged to contact the EPA Industrial Technology Division
Project Officer for technical clarifications or the Permits Divi-
sion for pretreatment or permit clarifications. The example
demonstrates the development of equivalent concentration based
limits and the use of the combined wastestream formula (CWF) to
derive the alternative, discharge standard for the total plant.
The plant used in this example is a lead battery
manufacturing plant, producing automotive batteries, and a
secondary lead smelter. The regulated wastestreams from battery
manufacturing and smelting are combined with noncontact cooling
water and sanitary wastes prior to treatment. The plant also
discharges employee shower wastewater to treatment and plant
management contends that the employee shower wastewater is
contaminated with lead. They have requested that the Control
Authority classify the stream as an unregulated wastestream
instead of a dilution stream, and have provided sampling and
analysis data. Documentation for the shower wastewater is:
• The sample collected was multiple grabs composited over
the entire length of one shower period
• Twenty-five employees showered during the sample
collection period
• The total volume of water used during the sample
collection period was 625 gallons (25 gallons/employee)I/
_!/ Note: The usual volume of water per person per shower is
25-30 gallons. (See References on R-l).
5-2
-------
* Analytical data showed a 0.25 mg/1 lead concentration in
the wastewater sample collected
• An average of 50 employees shower each day (50
employees/day).
Based on this information, the Control Authority classifies
the employee shower wastewater as an unregulated stream with a
1,250 gpd flow (25 gallons/employee x 50 employees/day).
The alternative concentration limit for the total plant is
developed through the following successive steps.
Step 1 - Draw a simple process flow diagram showing all regulated
category (or subcategory) process wastestreams and other
wastestreams that are combined prior to treatment (see
Figure 5.1) Determine appropriate production rates and
discharge flows for each regulated category.
Step 2 - Determine the mass limit for each regulated category
that is combined for treatment using the following
formula:
Mass limit = production-based standard (mg/kg)
x regulatory production rate (average or
other reasonable estimate) (kg/day).
For example, the maximum one day standard for lead for
open formation is 0.71 mg/kg of lead used and the
actual amount of lead used is 5000 kg/day. The mass
limit for the example plant is 3550 mg/day (0.71 mg/kg
x 5000 kg/day). Table 5^1 displays these calculations
in a tabular format. Mass limits for the regulated
battery plant wastestreams were calculated using the
pretreatment standards shown in Appendix B of this
5-3
-------
U1
1
L _
r
^
—————— I
Paste Preparation |
and Application
20,000 kg/day 1
., , 1
0.0001 MGD 1
1
I
1
Closed Formation
Single Fill
15,000 kg/day
________ — 1 open I
1 De^
Non-Contact
Cooling &
Sanitary
Water
0.
fc I
* 1
1 5,00(
Employee
J
1
nswrn 0.00125
°5MGD j MGD
1
1
1
Batter
1
NONFERROUS METALS MFC - 30.000
. SECONDARY LEAD SUBCATEGORY lead
1
1
L
prou
FIGURE 5.1
EXAMPLE PLANT PRODUCTION AND FLOW DATA
BATTERY MANUFACTURING - LEAD SUBCATEGORY
(Production unit used is kg/day of lead used)
'ormation Battery Wash
fdrated (Detergent)
) kg/day 20,000 kg/day
0.002 MGD
\
t
^^
0.005 MGD
V Cracking Facility
0.004 MGD
Miscellaneous
(Hand Wash &
Floor Wash)
20,000 kg/day
1
1
1
1
1
I .
1
1
1
0.0002 MGD
t
i
^^
0.0001 MGD
Washdown
kg/day of 30,000 kg/day of
scrap lead produced
uced from smelting
0.002 MGD
Employee Washdown
30,000 kg/day of
lead produced
from smelting
!
1
1
I
1
1
1
t
1
J
T
R
E
A
T
- M
E
N
T
TO
POTW
-------
TABLE 5-1
ALLOWABLE MASS LOADINGS FROM PROCESS OPERATIONS REGULATED BY
BATTERY MANUFACTURING CATEGORICAL PRETREATMENT STANDARDS
Pb Limit 2/
Daily Max.
and
Production
Regulated I/
Wastestream (kg/day)
Paste Preparation 20,000
& Application
Closed Formation 15,000
Single Fill
Open Formation 5,000
Dehydrated
Battery Wash 20,000
(Detergent)
Miscellaneous 20,000
Total
Monthly Discharge
Average Allowance 3_/
Daily Monthly
(mg/kg) Max. Avg.
(ing/day) (ing/day)
0.0 4/ 0
0.0
: 0.0 4/ 0
0.0
0.71 3550
0.34
0.38 7600
0.18
0.13 2600
0.06
13750
0
0
1700
3600
1200
6500
NOTES:
I/ See Figure 5-1 for specific production parameter. The
production number for lead used was estimated for the
example plant based on the fact that the plant produces
1364 batteries per day. If the amount of lead used is
difficult to obtain from a plant manufacturing standard
automotive batteries, 22 pounds of lead per battery can
be used for an estimate. This number was based on
information supplied by battery manufacturers when the
regulation was being developed. However, the actual
amount used might currently be less because manu-
facturers have developed methods for producing lighter
batteries using less lead. The production number used
should be verified with the plant personnel.
2/ PSES from 40 CFR 461. See Appendix A in this manual.
3/ Limit multiplied by average daily production rate (e.g.,
(0.71 mg/kg) x (5,000 kg/day) = 3550 mg/day
4/ Paste preparation and application and closed formation-
single fill have no discharge allowances.
5-5
-------
manual for the lead subcategory (page B-2 and B-3)
multiplied by the plant's regulatory production rate
(average or other reasonable estimate). Note from Figure
5-1 that the paste preparation and application and closed
formation - single fill operations should not receive a
discharge allowance. Even if wastewaters from these
operations were being discharged, the battery
manufacturing pretreatment standard states "no discharge
allowance for process wastewater pollutants" for these
operations. This means that no discharge allowance for
pollutants is allowed although a flow discharge may be
allowed. The facility's smelter operations are regulated
by the nonferrous metals manufacturing categorical
pretreatment standards secondary lead subcategory. Three
of the facility's process operations, battery cracking,
facility washdown, and employee washdown, are regulated
by the nonferrous standards.
Mass limits for the secondary lead smelter wastestreams
were determined by using the standards provided in 40 CFR
421 for the secondary lead subcategory of the nonferrous
metals manufacturing category (See 49 FR 8740 March 8,
1984) multiplied by the plant's regulatory production rate
(Figure 5-1). Note that the facility washdown
wastestream receives zero discharge allowance (the
production-based standard is depicted as 0.000 mg/kg of
lead produced from smelting). These equivalent
mass limits are shown in Table 5-2. Once the
allowable mass loadings, as derived in Tables 5-1 and
5-6
-------
TABLE 5-2
ALLOWABLE MASS LOADINGS FROM PROCESS OPERATIONS REGULATED
BY NONFERROUS METALS MANUFACTURING CATEGORICAL PRETREATMENT
STANDARDS - SECONDARY LEAD SUBCATEGORY
Regulated
Wastestream
Battery Cracking
Facility Washdown
Employee Handwash
Production
(kg/day)
30,000
30,000
30,000
Totals
Pb Limit
Daily Max.
and
Monthly
Avg.
(mg/kg)
0.189
0.087
0.0
0.0
0.008
0.004
Discharge Allow.
Daily Monthly
Max. Avg.
(mg/day) (mg/day)
5670
0
240
5910
2610
0
120
2730
5-7
-------
5-2, have been calculated, the combined wastestream
formula can be applied. Since both the battery and
nonferrous metals categorical pretreatment standards
are mass limitations, the appropriate form of the com-
bined wastestream formula is the alternative mass limit
formula, previously presented in Table 4-1 of this
manual (see CWF Conditions in the discussion of the
CWF, Section 4.4).
Step 3 - Determine which wastestreams are regulated, unregulated
or dilution wastestreams. This classification along
with their respective flows is shown in Table 5-3.
Step 4 - Calculate a mass limit for the total plant using the
alternative mass limit formula in Table 4.1. The ap-
plication of the alternative mass limit formula to the
example plant for the pollutant lead is presented
in Table 5-3. The mass limit as derived in Table 5-3
applies to the combined industrial plant discharge to
the POTW after wastewater treatment.
Step 5 - Calculate an equivalent concentration limit by dividing
the alternative mass limit by the average total plant
flow. (This step is shown in Table 5-3)
Step 6 - Follow the same procedure for calculating the monthly
average limit for lead as well as the daily maximum and
monthly average limits for all other regulated
pollutants.
In some cases, the POTW may wish to regulate other
pollutants not regulated by the battery manufacturing categorical
5-8
-------
TABLE 5-3
DERIVATION OF ALTERNATIVE LIMITS
Regulated Wastestreams:
Battery Manufacturing
1. Open Formation
2. Battery Wash
(Detergent)
3. Miscellaneous
Total
Flow
MGD (I/day)
0.002 (7570)
0.004 (15140)
0.0002 (757)
0.0062 (23467)
Mass Based Limit
One Day Max for
Lead (mg/day) I/
3550
7600
2600
13750
Nonferrous Metals Manufacturing
1. Battery Cracking
2. Employee Handwash
3. Facility Washdown
Total
0.0050 (18925) 5670
0.0020 (7570) 240
0.0001 (379) 0
0.0071 (26874) 5910
Notes:
See Figure 5-1 for specific production parameter. The
production number for lead used was estimated for the
example plant based on the fact that the plant produces
1364 batteries per day. If the amount of lead used is
difficult to obtain from a plant manufacturing standard
automotive batteries, 22 pounds of lead per battery can
be used for a estimate. This number was based on
information supplied by battery manufacturers when the
regulation was being developed. However, the actual
amount used might currently be less because manufactur-
ers have developed methods for producing lighter
batteries using less lead. The production number used
should be verified with the plant personnel.
5-9
-------
TABLE 5-3
DERIVATION OF ALTERNATIVE LIMITS (continued)
Unregulated Wastestreams;
1. Employee shower 0.00125 MGD = 4731 I/day
Dilution Wastestreams;
1. Noncontact Cooling
and Sanitary 0.0500 MGD = 189,250 I/day
Using Table 4.1, Alternative Mass Limit Combined Wastestream
Formula Calculate Alternative Mass Limit:
M
Lead = (13750 + 5910) X (23467+26874+4731+189250-189250)
(23467 + 26874)
M
Lead = 19660 X 55072
50341
M
Lead = 19660 X 1.094
M
Lead = 21508 mg
Convert Alternative Mass Limit to the Equivalent
Concentration Limit:
Equivalent concentration limit = 21508 mg/day
244322 I/day
= 0.088 mg/1
5-10
-------
pretreatment standards. For example, in the lead subcategory,
there were initially 12 toxic pollutant parameters considered for
regulation. These pollutants were found in the lead subcategory
raw wastestreams in significant concentrations. However, only
copper and lead were selected for regulation. The other pol-
lutants, not specifically regulated, would also be controlled by
the removal of the selected regulated pollutants and the overall
costs for monitoring and analysis would be reduced.
Should the POTW desire to regulate other pollutants found in
a lead battery manufacturing plant's discharge, the POTW could
apply local limits based on EPA's maximum allowable headworks
loading methodology. The POTW could also calculate a local limit
for the plant using EPA's technology - based methodology. The
Development Document for Effluent Limitations Guidelines and
Standards for Battery Manufacturing provides mass limits for the
12 toxic pollutant parameters based on the application of
treatment and control options presented for Best Available
Technology (BAT) and New Source Performance Standards (NSPS) for
direct dischargers. The example in Table 5-4 illustrates how to
calculate the mass discharge limits for lead, copper, and zinc
for lead battery manufacturing at the plant previously described.
Should the POTW desire to regulate other pollutants found in
the secondary lead smelter wastewater discharges (nonferrous
metals manufacturing - secondary lead subcategory), the POTW
could apply local limits or calculate a technology-based
pretreatment standard. The Development Document , for Effluent
Limitations Guidelines and Standards for Nonferrous Metals
Manufacturing - Phase I provides production normalized flows for
5-11
-------
TABLE 5-4. BATTERY MANUFACTURING CALCULATION OP MASS DISCHARGE LIMITS
WASTEWATER
STREAM
Paate Preparation
b Application
Cloaad Formation
Single Fill
Open Formation
Dehydrated
Battery Wash
(Detergent)
Miscellaneous
PRODUCTION I/
(KG/DAY)
20,000
15,000
5,000
20,000
20,000
Employee
Showers
Total
NOTES:
4,731 L/day
POLLUTANT
Pb
CU
Zn
Pb
CU
Zn
Pb
CU
Zn
Pb
Cu
Zn
Pb
Cu
Zn
Pb
Cu
Zn
LIMIT 2_/
DAILY MAX
MONTHLY AVG
(MG/KG)
DISCHARGE ALLOWANCE 3_/
Pb Cu
MAX AVG MAX AVG
(MG/DA'i)
Zn jl/
MAX AVG
0.0 0
0.0 0
0.0 0
0.0 0
0.0 0
0.0
0.0 0
0.0 0
0.0 0
0.0 0
0.0 0
0.0
0.71 3,550
0.34 1,700
3.19 15,950
1.68 8,400
2.45 12,250
1.02
0.38 7,600
0.18 3,600
1.71 34,200
0.90 18,000
1.32 26,400
0.54
0.13 2,600
0.06 1,200
0.58 11,600
0.31 6,200
0.45 9,000
0.19
0.42 mg/1 1,987
0.20 946
1.90 8,989
1.00 4,731
1.46 6,907
0.61
0
0
5,100
10,800
3,800
2,886
15,737 7,446 70,739 37,331 54,557 22,586
I/ See Figure 5-1'for specific production parameter. The production number for lead used was estimated for the
example plant based on the fact that the plant produces 1,364 batteries per day. If the amount of lead used
is difficult to obtain from a plant manufacturing standard automotive batteries, 22 pounds of lead per
battery can be used for an estimate. This number was based on information supplied by battery manufacturers
when the regulation was being developed. However, the actual amount used might currently be less because
manufacturers have developed methods for producing lighter batteries using less lead. The production number
used should be verified with the plant personnel.
2/ PSES from 40 CFR 461. See Appendix B in this manual.
3/ Multiply production times daily maximum and monthly average limit.
•)/ Zinc is not a regulated pollutant parameter for the lead subcategory of battery manufacturing and would be
~ considered an unregulated pollutant in the CWF, however the calculations are shown if the POTW wants to
apply technology—based standards for this pollutant. Zinc was detected and considered for regulation in
lead battery manufacturing and although not regulated, mass limits are provided as guidance in the battery
technical development document (Volume II, pages 642-649).
5/ Mass discharge limits calculated by multiplying flow (rather than production) times the treatment effec-
~ tivonoss concentrations '(mg/1) for lime and settle technology in Table 5-6. These concentrations rather
than daily maximum and monthly average limits are shown in the table. For example, lead one day max is 4731
I/day X 0.42 mg/1 = 1987 mg/day.
5-12
-------
each process operation and a treatment effectiveness concen-
tration table for all pollutants of concern based on treatment
systems used for BAT and NSPS for direct dischargers. The
example in Table 5-5 illustrates how to calculate the mass dis-
charge limits for lead, copper and zinc for the secondary lead
smelter operations at the example plant. Table 5-5 also presents
the production normalized flows needed to calculate mass limits
for the secondary lead smelter operations, and Table 5-6 presents
the treatment effectiveness concentrations used for the nonfer-
rous metals manufacturing regulation.
5-13
-------
TABLE 5-5. NONFERROUS METALS MANUFACTURING CALCULATION OF DISCHARGE LIMITS
WASTEWATER
STREAM
Batt«ry
Cracking
Facility
Washdown
Employee
Handwash
Total
PRODUCTION I/
(KG/DAY)
30,000
(0.673 I/kg)
30,000
30,000
(0.027 I/kg)
POLLUTANT
Pb
Cu
Zn
Pb
Cu
Zn
Pb
Cu
Zn
LIMIT 2/ DISCHARGE ALLOWANCE 3_/
DAILY MAX Pb CuV Zn
MONTHLY AVG MAX AVG MAX AVG MAX AVG
(HG/KG) (HG/DAY)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
.189
.087
.861
.410
.687
.283
.0
.0
.0
.0
.0
.0
.008
.004
.035
.016
.028
.011
5,670
2,610
25,830
12,300
20,610
8 ,490
0
0
0
0
0
0
240
120
1,050
480
840
330
5,910 2,730 26,880 12,780 21,450
8,820
21,647 10,176 97,619 50,111 76,007 31,406
Plant Total
(Tables 5-4 and 5-5)
NOTES:
I/ Seo Figure 5—1 for specific production parameter.
2/ PSES from 40 CFR 421.
3/ Multiply production times daily maximum and monthly average limit.
4/ Copper is not a regulated pollutant parameter for the secondary lead subcategory and would be considered an
unregulated pollutant in the CWF, however the calculations are shown if the POTW wants to apply technology-
based standards for this pollutant. Copper, although not specifically considered for regulation, was
quantifiable in wastestreams from nonferrous metals manufacturing. The additional calculation includes
using the production normalized flow (PNF) for the particular process (I/kg of production) from the
technical development document and multiplying this number by the treatment effectiveness concentration
(mg/1) for the pollutant parameter and the treatment technology. (See Table 5-6; lime, settle and filter
for nonferrous metals.)
For example:
Battery Cracking:
PNF is 0.673 I/kg of lead scrap produced (from nonferrous metals manufacturing technical development
document).
Treatment effectiveness concentrations for copper are:
1.28 mg/1 for the one day maximum and 0.61 mg/1 for the monthly average.
One day maximum mass limit for copper is:
(0.673 I/kg X 1.28 mg/1) x 30,000 kg/day
0.861 mg/kg X 30,000 kg/day = 25,830 mg/day
5-14
-------
TABLE 5-6.
SUMMARY OF TREATMENT EFFECTIVENESS (ng/1)
FOR THE NONFERROUS METALS MANUFACTURING REGULATION
ollutant
arameter
14 Sb
15 As
17 Be
18 Cd
19 Cr
20 Cu
21 Cn
22 Pb
23 Hg
24 Ni
25 Se
26 Ag
27 Tl
28 Zn
Al
Co
F
Fe
Mn
P
O&G
TSS
.mmonia
arium
oron
esium
a Ilium
ermanium
old
afnium
ridium
iolybdenum
alladium
latinum
.adium***
.henium
.ubidium
'antalum
'in
'Itanium
'ungsten
'ranium
'anadium
.irconium
L &
S Technology System
One-Day
Mean
2
14
4
12
32
7
1
6
1
1
4
.70
.51
.30
.08
.08
.58
.07
.12
.06
.74
.30
.10
.50
.33
.24
.05
.50
.41
.16
.08
.00
.20
.42
.36
.12
.08
.08
* *
.28
.08
.83
* *
* *
.17
.83
.12
* *
.14
.19
.29
.00
* *
Max
2
2
1
1
1
1
2
1
6
35
1
16
20
41
133
5
1
*
28
6
*
*
30
6
*
6
6
*
.87
.09
.23
.34
.44
.90
.29
.42
.25
.92
.23
.41
.05
.46
.43
.21
.00
.20 .
.68
.70
.00
.00
.30
.55
.84
.51
.44
.44
.10
.80
.44
.61
.10
.10
.00
.61
.51
.45
.38
.94
.96
.50
.10
10-Day
Avg
1.28
.93
.55
.15
.18
1.00
.12
.20
.10
1.27
.55
.17
.91
.61
3.20
.09
19.90
.61
.29
6.83
12.00
19.50
58.60
2.54
.84
.23
.18
.18
* *
13.90
.18
3.42
* *
* *
11.23
3.42
.23
* *
.22
.41
2.78
4 .73
* *
30-Day
Avg
1.14
.83
.49
.13
.12
.73
.11
.16
.10
1.00
.49
.16
.81
.45
2.52
.08
.50
.21
6.60
10.00
15.50
52.10
NC
NC
NC
.12
.12
* *
NC
.12
NC
* *
* *
10.00
NC
NC
A *
* *
NC
NC
NC
* *
L S
& F Technology System
One-Day
Mean
.47
.34
.20
.05
.07
.39
.05
.08
.04
.22
.20
.07
.34
.23
1.49
.03
14.50
.28
.14
2.72
2.60
32.20
.28
.36
.12
.07
.07
* *
4.81
.07
1.23
* *
* *
4.13
1.23
.12
* *
.14
.13
.85
2.67
* *
Max
1
1
1
1
1
6
35
1
11
10
15
133
1
1
*
19
5
*
*
20
5
*
3
4
*
.93
.39
.82
.20
.37
.28
.20
.28
.15
.55
.82
.29
.40
.02
.11
.14
.00
.20
.30
.20
.00
.00
.30
.15
.84
.51
.37
.37
.10
.70
.37
.03
.10
.10
.00
.03
.51
.45
.38
.53
.48
.29
.10
10-Day
Avg
.86
.62
.37
.08
.15
.61
.08
.13
.06
.37
.37
.12
.61
.42
2.71
.07
19.90
.61
.23
4.60
10.00
12.00
58 .60
.51
.84
.23
.15
.15
* *
9 .01
.15
2.23
* *
* *
7.25
2.23
.23
* *
.22
.23
1.55
3.12
* *
30-Day
Avg
.76
.55
.32
.08
.10
.49
.08
.11
.06
.29
.33
.10
.55
.31
2.41
.06
.50
.19
4.40
10.00
10.00
52.10
NC
NC
NC
.10
.10
* *
NC
.10
NC
* *
* *
6.67
NC
NC
* *
* *
NC
NC
NC
* *
Sulfide & Filter
Technology System
Mean
One-Day
Max
.01
.08
.05
.01
.03
.05
.05
.01
.04
.21
.21
.04
.13
.21
.21
.04
10-Day
Avc
.02
.09
.09
.02
.06
.09
.09
.02
.02
.08
.08
.02
.05
.08
.08
.02
07/03/86
7.28
28.80
13.90
NC
4.81
19.70
9.01
NC
NC Not Calculated
•Limits of Detection
"None Established
***Isotope 226, Values in
picocuries per liter
5-15
-------
-------
REFERENCES
BatteryManufacturing
Final Rule Promulgated
Correction Notice
Correction Notice
Proposed Amendment
Final Amendments Promulgated
Development Document for
Effluent Limitations Guidelines
and Standards for Battery Manu-
facturing Volume I and Volume II
Federal Register Notice
And Documents
3/9/84 49 FR 9108
4/9/84 49 FR 13879
7/9/84 49 FR 27946
1/28/86 51 FR 3477
8/28/86 51 FR 30814
9/84 EPA 440/1-84/067
Vol I NTIS #PB 85121507
Vol II NTIS #PB 85121515
Nonferrous Metals Manufacturing
Final Rule (Phase I) Promulgated 03/08/84
Final Rule Correction 07/24/84
Final Rule Correction 07/28/85
Final Rule (Phase II) Promulgated 09/20/85
49 FR 8742
49 FR 29792
50 FR 12252
50 FR 38276
Metal Finishing
Final Rule Promulgated
General Pretreatment Regulations
40 CFR
40 CFR
40 CFR
40 CFR
40 CFR
40 CFR
40 CFR
40 CFR
40 CFR
Part
Part
Part
Part
Part
Part
Part
Part
Part
403
403
403
403
403
403
403
403
403
07/15/83
01/28/81
05/17/84
07/10/84
08/03/84
09/25/85
06/04/86
07/01/86
10/09/86
01/14/87
48 FR 32485
46 FR
49 FR
49 FR
49 FR
50 FR
51 FR
51 FR
51 FR
52 FR
9404
21037
28058
31212
38809
20426
23759
36368
1586
REFERENCE FOR SHOWER FLOW, SECTION 2.6
Metcalf and Eddy, Inc., "Wastewater Engineering: Treatment,
Disposal, Reuse." McGraw-Hill, Inc., N.Y., Page 17 (1979).
U.S. EPA, "Design Manual-Onsite Wastewater Treatment and Disposal
Systems." EPA 625/1-80-012, Pages 54, 80 (October 1980).
R-l
-------
REFERENCES (continued)
GUIDANCE MANUALS
Guidance Manual for POTW October 1983
Pretreatment Program Development
Procedures Manual for Reviewing a October 1983
POTW Pretreatment Pretreatraent Program
Guidance Manual for the Use of September 1985
Production-Based Pretreatment
Standards and the Combined
Wastestream Formula
Pretreatment Implementation Review January 1985
Task Force (PIRT) Final Report
Guidance Manual for Implementing Total September 1985
Toxic Organics (TTO) Pretreatment
Standards
RCRA Information on Hazardous Wastes for September 1985
Publicly Owned Treatment Works
Guidance Manual Preparing and Reviewing September 1985
Removal Credits Applications
Compliance Monitoring and Enforcement July 1986
Guidance
PRELIM 3.0: EPA Computer Model for September 1986
Development of Local Limits (user
manual and computer disk for use
on an IBM compatible microcomputer)
Guidance Manual for Electroplating and February 1984
Metal Finishing Pretreatment Standards
Copies of the technical and economic documents may be obtained
from the USEPA, Industrial Technology Division (WH-552),
Washington, DC, (202) 382-7126, or from the National Technical
Information Services (NTIS), Springfield, VA 22161, (703) 487-
4650. Pretreatment Program Manuals may be obtained from USEPA,
Permits Division (EN-336), Washington, D.C. 20460, 202-475-9526.
R-2
-------
APPENDIX A
GLOSSARY OF TERMS
-------
-------
GLOSSARY OF TERMS
Active Material - Electrode material that reacts chemically to
produce electrical energy when a cell discharges. Also, such
material in its original composition, as applied to make an
electrode.
Amalgamation - (1) Alloying a zinc anode with mercury to prevent
internal corrosion and resultant gassing in a cell. (2)
Treatment of wastewater by passing it through a bed of metal
particles to alloy and thereby remove mercury from the water.
Anode - The electrode by which electrons leave a cell. The
negative electrode in a cell during discharge.
Battery - A device that transforms chemical energy into
electrical energy. This term usually applies to two or more
cells connected in series, parallel or a combination of both.
Common usage has blurred the distinction between the terms "cell"
and "battery" and frequently the term battery is applied to any
finished entity sold as a single unit, whether it contains one
cell, as do most flashlight batteries, or several cells, as do
automotive batteries.
Cathode - The electrode by which electrons enter a cell. The
positive electrode in a cell during discharge.
Cell - The basic building block of a battery. It is an
electrochemical device consisting of an anode and a cathode in a
common electrolyte kept apart with a separator. This assembly
may be used in its own container as a single cell battery or be
combined and interconnected with other cells in a container to
form a multicelled battery.
Charge - The conversion of electrical energy into chemical energy
within a cell-battery. This restoration of active electronic
materials is done by forcing a current through the cell-battery
in the opposite direction to that during discharge. See
"Formation."
Chemical Precipitation - The use of an alkaline chemical to
remove dissolved metals from wastewater.
Closed Formation - Formation of lead battery plates done with the
plates already in the battery case.
Countercurrent Cascade Rinsing - A method of rinsing or washing
using a segmented tank system in which water flows from one tank
segment to the next counter to the direction of movement of the
material being washed.
A-l
-------
Current Collector - The grid portion of the electrode which
conducts the current to the terminal.
Depolarizer - A term often used to denote the cathode active
material.
Dry Charge Process - A process for the manufacture of lead acid
storage batteries in which the plates are charged by electrolysis
in sulfuric acid, rinsed, and drained or dried prior to shipment
of the battery. Charging of the plates usually occurs in
separate containers before assembly of the battery but may be
accomplished in the battery case. Batteries produced by the dry-
charge process are shipped without acid electrolyte. Also
referred to as dehydrated plate or dehydrated batteries.
Electrode - The positive (cathode) or negative (anode) element
in a cell or battery, that enables it to provide electric power.
Electrodeposition - Electrochemical deposition of an active
material from solution onto an electrode grid or plaque.
Electroforming - See (1) Electrodeposition, and (2) Formation.
Electrolyte - The liquid or material that permits conduction of
ions between cell electrodes.
Electrolytic Precipitation - Generally refers to making powdered
active material by electrodeposition and physical removal; e.g.,
silver powder from silver bars.
Electroplating - (1) Electrodeposition of a metal or alloy from a
suitable electrolyte solution; the article to be plated is
connected as the cathode in the electrolyte solution; direct
current is introducted though the anode which consists of the
metal to be deposited. (2) The Electroplating Point Source
Category.
Element - A combination of negative and positive plates and
separators to make a cell in a lead-acid storage battery.
End-of-Pipe Treatment - The reduction or removal of pollutants by
treatment just prior to actual discharge to a point outside an
industrial plant.
Filtration - Removal of solid particles from liquid or particles
from air or gas stream through a permeable membrane or deep bed.
The filter types include: gravity, pressure, microstraining,
ultrafiltation, reverse osmosis (hyperfiltration).
A-2
-------
Formation - An electrochemical process which converts the battery
electrode material into the desired chemical condition. For
example, in a silver-zinc battery the silver applied to the
cathode is converted to silver oxide and the zinc oxide applied
to the anode is converted to elemental zinc. "Formation" is
generally used interchangeable with "charging", although it may
involve a repeated charge-discharge cycle.
Grid - The support for the active materials and a means to
conduct current from the active materials to the cell terminals;
usually a metal screen, expanded metal mesh, or a perforated
metal plate.
Impregnation - Method of making an electrode by precipitating
active material on a sintered nickel plaque.
In-Process Control Technology - The regulation and conservation
of chemicals and rinse water throughout the operations as opposed
to end-of-pipe treatment.
Open Formation - Formation of lead battery plates done with the
plates in open tanks of sulfuric acid. Following formation
plates are placed in the battery cases.
Paste - Powdered active material mixed with a liquid to form a
paste to facilitate application to a grid to make an electrode.
Plaque - A porous body of sintered metal on a metal grid used as
a current collector and holder of electrode active materials,
especially for nickels-cadmium batteries.
Plate - A positive or negative electrode used in a bettery,
generally consisting of active material deposited on or in a
current-collecting support.
Pressure Filtration - The process of solid-liquid phase
separation effected by forcing the more permeable liquid phase
through a mesh which is impenetrable to the solid phase.
Recycled Water - Process wastewater or treatment facility
effluent which is recirculated to the same process.
Reserve Cell - A class of cells which are designated as
"reserve", because they are supplied to the user in a non-
activated state. Typical of this class of cell is the carbon-
zinc air reserve cell, which is produced with all the components
in a dry or non-activated state, and is activated with water
when it is ready to be used.
A-3
-------
Reused Water - Process wastewater or treatment facility effluent
which is further used in a different manufacturing process. For
example, the reuse of process wash water as noncontact cooling
water.
Sedimentation - The gravity induced deposition of suspended
matter carried by water, wastewater, or other liquids, by
gravity. It is usually accomplished by reducing the velocity of
the suspended material. Also called settling.
Separator - A porous material, in a battery system, used to keep
plates of opposite polarity separated, yet allowing conduction of
ions through the electrolyte.
Sinter - Heating a metal powder such as nickel to an elevated
temperature below its melting point which causes it to
agglomerate and adhere to the supporting grid.
Sintered-plate Electrode - The electrode formed by sintering
metallic powders to form a porous structure, which serves as a
current collector, and on which the active electrode material is
deposited.
Storage Battery - A battery that can store chemical energy with
the potential to change to electricity. This conversion of
chemical energy to electricity can be reversed thus allowing the
battery to be recharged.
Wet Charge Process - A process for the manufacture of lead acid
storage batteries in which the plates are formed by electrolysis
in sulfuric acid. The plate forming process is usually done with
the plates inside the assembled battery case but may be done with
the plates in open tanks. In the case of large industrial wet
lead acid batteries, problems in formation associated with
inhomogeneities in the large plates are alleviated by open tank
formation. Wet charge process batteries are shipped with acid
electrolyte inside the battery casing.
Wet Scrubber - A unit in which dust and fumes are removed from an
air or gas stream to a liquid. Gas-liquid contact is promoted by
jets, sprays, bubble chambers, etc.
A-4
-------
APPENDIX B
PSES AND PSNS FOR BATTERY MANUFACTURING SUBCATEGORIES
-------
-------
TABLE B.I
PRETREATMENT STANDARDS FOR EXISTING
SOURCES FOR THE BATTERY
MANUFACTURING CATEGORY (40 CFR 461)
Subpart A; Cadmium
1) Electrodeposited
Anodes
(mg/kg or lb/1,000,000
Ib of cadmium)
2) Impregnated
Anodes
(mg/kg or lb/1,000,000
Ib of cadmium)
3) Nickel Electro-
deposited Cathodes
(mg/kg or lb/1,000,000
Ib of nickel applied)
4) Nickel Impregnated
Cathodes
(mg/kg or lb/1,000,000
Ib of nickel applied)
5) Miscellaneous
Wastewater Streams (1)
(mg/kg or lb/1,000,000
Ib of cells produced)
6) Cadmium Powder
Production
(mg/kg or lb/1,000,000
Ib of cadmium powder
produced)
7) Silver Powder
Production
(mg/kg or lb/1,000,000
Ib of silver powder
produced)
8) Cadmium Hydroxide
Production
(mg/kg or lb/1,000,000
Ib of cadmium used)
Pollutant
Cadmium
Nickel
Zinc
Cobalt
Cadmium
Nickel
Zinc
Cobalt
Cadmium
Nickel
Zinc
Cobalt
Cadmium
Nickel
Zinc
Cobalt
Cadmium
Nickel
Zinc
Cobalt
Cadmium
Nickel
Zinc
Cobalt
Cadmium
Nickel
Silver
Zinc
Cobalt
Cadmium
Nickel
Zinc
Cobalt
Daily
Maximum
11.95
67.49
51.32
7.38
68.0
384.0
292.0
42.0
11.22
63.36
48.18
6.93
68.0
384.0
292.0
42.0
0.79
4.47
3.40
0.49
2.23
12.61
9.59
1.38
1.09
6.16
1.32
4.69
0.67
0.05
0.27
0.20
0.03
Maximum
Monthly Avg.
5.27
44.64
21.44
3.16
30.0
254.0
122.0
18.0
4.95
41.91
20.13
2.97
30.0
254.0
122.0
18.0
0.35
2.96
1.42
0.21
0.99
8.34
4.01
0.59
0.48
4.08
0.55
1.96
0.29
0.02
0.18
0.09
0.012
B-l
-------
TABLE B.I
PRETREATMINT STANDARDS FOR EXISTING
SOURCES FOR THE BATTERY
MANUFACTURING CATEGORY (40 CFR 461) (continued)
Subpart A:= Cadmium (cont'd) Pollutant
9) Nickel Hydroxide Cadmium
Production Nickel
(mg/kg or lb/1,000,000 Zinc
Ib of nickel used) Cobalt
Daily
Maximum
5.61
31.68
24.09
3.47
Maximum
Monthly Avg
2.48
20.96
10.07
1.49
Subpart C; Lead
1) Open Formation- Copper
Dehydrated Lead
(mg/kg or lb/1,000,000
Ib of lead used)
2) Open Formation-Wet Copper
(mg/kg or lb/1,000,000 Lead
Ib of lead used)
3) Plate Soak Copper
(mg/kg or lb/1,000,000 Lead
Ib of lead used)
4) Battery Wash-Detergent (2) Copper
(mg/kg or lb/1,000,000 Lead
Ib of lead used)
5) Direct Chill Lead Casting Copper
(mg/kg or lb/1,000,000 Lead
Ib of lead used)
6) Mold Release Formulation Copper
(mg/kg or lb/1,000,000 Lead
Ib of lead used)
7) Truck Wash Copper
(mg/kg or lb/1,000,000 Lead
Ib of lead in trucked
batteries)
8) Laundry Copper
(mg/kg or lb/1,000,000 Lead
Ib of lead used)
3.19
0.71
0.100
0.022
0.039
0.008
1.71
0.38
0.0004
0.00008
0.011
0.002
0.026
0.005
0.21
0.05
1.68
0.34
0.053
0.010
0.021
0.004
0.90
0.18
0.0002
0.00004
0.006
0.001
0.014
0.002
0.11
0.02
B-2
-------
TABLE B.I
PRETR1ATMENT STANDARDS FOR EXISTING
SOURCES FOR THE BATTERY
MANUFACTURING CATEGORY (40 CFR 461) (continued)
Subpart C; Lead (cont'd)
Pollutant
Daily
Maximum
Maximum
Monthly Avg
9) Miscellaneous
Wastewater Streams (3)
(mg/kg or lb/1,000,000
Ib of lead used)
Subpart D:__ Leclanche
1) Foliar Battery
Misc. Wash
(mg/kg or lb/1,000,000
Ib of cells produced)
Copper
Lead
Mercury
Zinc
Manganese
0.58
0.13
0.010
0.067
0.019
0.31
0.06
0.004
0.030
0.015
Subpart F;_ Magnesium
1) Silver Chloride Cathodes- Lead 1,032.36
Chemically Reduced Silver 1,007.78
(mg/kg or lb/l,ooo,000
Ib of silver processed)
2) Silver Chloride Cathodes- Lead 60.9
Electrolytic Silver 59.5
(mg/kg or lb/1,000,000
Ib of silver processed)
3) Cell Testing Lead 22.1
(mg/kg or lb/1,000,000 Silver 21.6
Ib of cells produced)
4) Floor and Equipment Wash Lead 0.039
(mg/kg or lb/1,000,000 Silver 0.038
Ib of cells produced)
491.60
417,86
29.0
24.7
10.5
8.9
0.018
0.015
Subpart G_; Zinc
1) Wet Amalgamated
Powder Anode
(mg/kg or lb/1,000,000
Ib of zinc)
Chromium
Mercury
Silver
Zinc
Manganese
0.24
0.14
0.23
0.80
0.37
0.099
0.055
0.093
0.34
0.16
B-3
-------
TABLE B.I
PRETREATMENT STANDARDS FOR EXISTING
SOURCES FOR THE BATTERY
MANUFACTURING CATEGORY (40 CFR 461) (continued)
Subpart G; Zinc (cont'd)
2) Gelled Amalgam
Anodes
(mg/kg or lb/1,000,000
Ib of zinc)
3) Zinc Oxide Formed Anodes
(mg/kg or lb/1,000,000
Ib of zinc)
4) Electrodeposited Anodes
(mg/kg or lb/1,000,000
Ib of zinc deposited)
5) Silver Powder Formed
Cathodes
(mg/kg or lb/1,000,000
Ib of silver applied)
6) Silver Oxide Powder
Formed Cathodes
(mg/kg or lb/1,000,000
Ib of silver applied)
7) Silver Peroxide
Cathodes
(mg/kg or lb/1,000,000
Ib of silver applied)
8) Nickel Impregnated
Cathodes
(mg/kg or lb/1,000,000
Ib of nickel applied)
Pollutant
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Nickel
Silver
Zinc
Manganese
Daily
Maximum
0.030
0.017
0.028
0.099
0.046
9.53
5.42
8.89
31.64
14.74
94.47
53.68
86.03
313.46
146.00
13.07
7.43
12.18
43.36
20.20
8.73
4.96
8.14
28.98
13.50
2.09
1.19
1.95
6.95
3.24
88.0
50.0
384.0
82.0
292.0
136.0
Maximum
MonthlyAvg
0.012
0.006
0.012
0.042
0.020
3.90
2.17
3.68
13.22
6.28
38.65
21.47
36.50
130.97
62.26
5.35
2.97
5.05
18.12
8.61
3.57
1.99
3.37
12.11
5.76
0.87
0.48
0.81
2.90
1.38
36.0
20.0
254.0
34.0
122.0
58.0
B-4
-------
TABLE B.I
PRETREATMENT STANDARDS FOR EXISTING
SOURCES FOR THE BATTERY
MANUFACTURING CATEGORY (40 CFR 461) (continued)
Subpart G; Zinc (cont'd)
9) Miscellaneous
Wastewater Streams (4)
(mg/kg or lb/1,000,000
Ib of cells produced)
10) Silver Etch
(mg/kg or lb/1,000,000
Ib of silver processed)
11) Silver Peroxide
Production
(mg/kg or lb/1,000,000
Ib of silver in silver
peroxide produced)
12) Silver Powder
Production
(mg/kg or lb/1,000,000
Ib of silver powder
produced)
Pollutant
Chromium
Cyanide
Mercury
Nickel
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Daily
Maximum
0.57
0.38
0.32
2.48
0.53
1.88
0.88
3.27
1.86
3.05
10.86
5.06
3.48
1.96
3.24
11.55
5.38
1.41
0.80
1.32
4.69
2.18
Maximum
Monthly Avg
0.23
0.16
0.13
1.64
0.22
0.79
0.37
1.34
0.74
1.26
4.54
2.16
1.42
0.79
1.34
4.83
2.29
0.58
0.32
0.55
1.96
0.93
(1) Includes discharges from cell wash, electrolyte preparation,
floor and equipment wash, artd employee wash.
(2) Numbers reflect amendment as a result of a settlement agree-
ment between EPA and lead battery manufacturers.
(3) Includes discharges from floor wash, wet air pollution con-
trol, battery repair, laboratory, hand wash, and respirator
wash.
(4) Includes discharges from cell wash, electrolyte preparation,
employee wash, reject cell handling, and floor and equipment
wash.
B-5
-------
TABLE B.2
PRETREATMENT STANDARDS FOR NEW SOURCES
FOR THE BATTERY MANUFACTURING
CATEGORY (40 CFR 461)
Daily
Subpart, A; Cadmium Pollutant Maximum
1) Electrodeposited Cadmium 7.03
Anodes Nickel 19.33
(mg/kg or lb/1,000,000 Zinc 35.85
Ib of cadmium) Cobalt 4.92
2) Impregnated Cadmium 40.0
Anodes Nickel 110.0
(mg/kg or lb/1,000,000 Zinc 204.0
Ib of cadmium) Cobalt 28.0
3) Nickel Electro- Cadmium 6.60
deposited Cathodes Nickel 18.15
(mg/kg or lb/1,000,000 Zinc 33.66
Ib of nickel applied) Cobalt 4.62
4) Nickel Impregnated Cadmium 40.0
Cathodes Nickel 110.0
(mg/kg or lb/1,000,000 Zinc 204.0
Ib of nickel applied) Cobalt 28.0
5) Miscellaneous Cadmium 0.47
Wastewater Streams (1) Nickel 1.28
(mg/kg or lb/1,000,000 Zinc 2.38
Ib of cells produced) Cobalt 0.33
6) Cadmium Powder Cadmium 1.31
Production Nickel 3.61
(mg/kg or lb/1,000,000 Zinc 6.70
Ib of cadmium powder Cobalt 0.92
produced)
7) Silver Powder Cadmium 0.64
Production Nickel 1.77
(mg/kg or lb/1,000,000 Silver 0.93
Ib of silver powder Zinc 3.27
produced) Cobalt 0.45
8) Cadmium Hydroxide Cadmium 0.028
Production Nickel 0.077
(mg/kg or lb/1,000,000 Zinc 0.142
Ib of cadmium used) Cobalt 0.019
Maximum
Monthly Avg
2.81
13.01
14.76
2.46
16.0
74.0
84.0
14.0
2.64
12.21
13.86
2.31
16.0
74.0
84.0
14.0
0.19
0.86
0.98
0.16
0.53
2.43
2.76
0.46
0.26
1.19
0.39
1.35
0.22
0.011
0.051
0.058
0.009
B-6
-------
TABLE B.2
PRETREATMENT STANDARDS FOR NEW SOURCES
FOR THE BATTERY MANUFACTURING
CATEGORY (40 CFR 461) (continued)
Subpart A; Cadmium (cont'd)
9) Nickel Hydroxide
Production
(mg/kg or lb/1,000,000
Ib of nickel used)
Subpart B: Calcium
Pollutant
Cadmium
Nickel
Zinc
Cobalt
Daily
Maximum
3.30
9.08
16.83
2.31
Maximum
Monthly Avg
1.32
6.11
6.93
1.16
There shall be no discharge for process wastewater pollutants from any
battery manufacturing operations in the calcium subcategory.
Subpart C;
l)
Lead
Open Formation-
Dehydrated
(mg/kg or lb/1,000,000
Ib of lead used)
2) Open Formation-Wet
(mg/kg or lb/1,000,000
Ib of lead used)
3) Plate Soak
(mg/kg or lb/1,000,000
Ib of lead used)
4) Battery Wash-Detergent (2)
(mg/kg or lb/1,000,000
Ib of lead used)
5) Direct Chill Lead Casting
(mg/kg or lb/1,000,000
Ib of lead used)
6) Mold Release Formulation
(mg/kg or lb/1,000,000
Ib of lead used)
7) Truck Wash
(mg/kg or lb/1,000,000
Ib of lead in trucked
batteries)
8 ) Laundry
(mg/kg or lb/1,000,000
Ib of lead used)
Copper
Lead
Copper
Lead
Copper
Lead
Copper
Lead
Copper
Lead
Copper
Lead
Copper
Lead
Copper
Lead
2.15
0.47
0.067
0.014
0.026
0.005
0.576
0.126
0.000256
0.000056
0.007
0.0017
0.006
0.001
0.14
0.03
1.02
0.21
0.032
0.006
0.012
0.002
0.274
0.058
0.00012
0.00002
0.0037
0.0008
0.003
0.0007
0.07
0.01
B-7
-------
TABLE B.2
PRETREATMENT STANDARDS FOR NEW SOURCES
FOR THE BATTERY MANUFACTURING
CATEGORY (40 CFR 461) (continued)
Daily Maximum
Subpart C; Lead (cont'd) Pollutant Maximum Monthly Avg
9) Miscellaneous Copper 0.39 0.19
Wastewater Streams (3) Lead 0.085 0.039
(rag/kg or lb/1,000,000
Ib of lead used)
Subpart D; Leclanche
1) Foliar Battery Mercury 0.010 0.004
Misc. Wash. Zinc 0.067 0.030
(rag/kg or lb/1,000,000 Manganese 0.019 0.015
Ib of cells produced)
Subpart Et Lithium
1) Lead Iodide Cathodes Chromium 23.34 9.46
(mg/kg or lb/1,000,000 Lead 17.66 8.20
Ib of lead)
,2) Iron Disulfide Cathodes Chromium 2,79 1.13
(mg/kg or lb/1,000,000 Lead 2.11 0.98
Ib of iron disulfide)
3) Miscellaneous chromium 0.039 0.016
Wastewater Streams (4) Lead 0.030 0.014
(mg/kg or lb/1,000,000
Ib of cells produced)
Subpart F; Magnesium
1) Silver Chloride Cathodes- Lead 22.93 10.65
Chemically Reduced Silver 23.75 9.83
(mg/kg or lb/1,000,000
Ib of silver processed)
B-8
-------
TABLE B.2
PRETREATMENT STANDARDS FOR NEW SOURCES
FOR THE BATTERY MANUFACTURING
CATEGORY (40 CFR 461) (continued)
Subpart F: Magnesium (cont*d) Pollutant
Daily
Maximum
Maximum
Monthly Avg
2) Silver Chloride Cathodes- Lead
Electrolytic Silver
(rag/kg or lb/1,000,000
Ib of silver processed)
3) Cell Testing Lead
(mg/kg or lb/1,000,000 Silver
Ib of cells produced)
4) Floor and Eguipment Wash Lead
(mg/kg or lb/1,000,000 Silver
Ib of cells produced)
40.6
42.1
19.5
15.3
0.026
0.027
18.9
17.4
7.89
6.31
0.012
0.011
Subpart G; Zinc
1) Zinc Oxide Formed
Anodes
(mg/kg or lb/1,000,000
Ib of zinc)
2) Electrodeposited
Anodes
(mg/kg or lb/1,000,000
Ib of zinc deposited)
3) Silver Powder Formed
Cathodes
(mg/kg or lb/1,000,000
Ib of silver applied)
4) Silver Oxide Powder
Formed Cathodes
(mg/kg or lb/1,000,000
Ib silver applied)
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
4.55
2.82
4.55
0.87
6.50
45.09
27.91
45.09
8.59
64.41
6.24
3.86
6.24
1.19
8.91
4.17
2.58
4.17
0.79
5.96
1.97
1.19
1.97
0.39
4.98
19.54
11.81
19.54
3.86
49.38
2.70
1.63
2.70
0.53
6.83
1.81
1.09
1.81
0.36
4.57
B-9
-------
TABLE B.2
PRETREATMENT STANDARDS FOR NEW SOURCES
FOR THE BATTERY MANUFACTURING
CATEGORY (40 CFR 461) (continued)
Subpart G: Zinc (cont'd)
Pollutant
Daily
Maximum
Maximum
Monthly Avg
5) Silver Peroxide
Cathodes
(mg/kg or lb/l,000,000
Ib of silver applied)
6) Nickel Impregnated
Cathodes
(mg/kg or lb/l,000,000
Ib of nickel applied)
7) Miscellaneous
Wastewater Streams (5)
(mg/kg or lb/1,000,000
Ib of cells produced)
8) Silver Etch
(mg/kg or lb/l,000,000
Ib of silver processed)
9) Silver Peroxide
Production
(mg/kg or lb/1,000,000
Ib of silver in silver
peroxide produced)
10) Silver Powder
Production
(mg/kg or lb/l,000,000
Ib of silver powder
produced)
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Nickel
Silver
Zinc
Manganese
Chromium
Cyanide
Mercury
Nickel
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
Chromium
Mercury
Silver
Zinc
Manganese
1.00
0.62
1.00
0.19
1.43
42.0
26.0
42.0
42.0
8.0
60.0
0.27
0.039
0.17
0.27
0.27
0.05
0.39
1.56
0.97
1.56
0.30
2.23
1.66
1.03
1.66
0.32
2.37
0.67
0.42
0.67
0.13
0.96
0.43
0.26
0.43
0.09
1.09
18.2
11.0
18.2
18.2
3.6
46.0
0.12
0.016
0.07
0.12
0.12
0.02
0.30
0.68
0.41
0.68
0.13
1.71
0.72
0.44
0.72
0.14
1.82
0.29
0.18
0.29
0.06
0.74
B-10
-------
TABLE B.2
PRETRIATMENT STANDARDS FOR NEW SOURCES
FOR THE BATTERY MANUFACTURING
CATEGORY (40 CFR 461) (continued)
(l) Includes discharges from cell wash, electrolyte
preparations, floor and equipment wash, and employee wash.
(2) Numbers reflect amendment as a result of a settlement agree-
ment between EPA and lead battery manufacturers.
(3) Includes discharges from floor wash, wet air pollution con-
trol, battery repair, laboratory, hand wash, and respirator
wash.
(4) Includes discharges from floor and equipment wash, cell
testing and lithium scrap disposal.
(5) Includes discharges from cell wash, electrolyte preparation,
employee wash, reject cell handling, and floor and equipment
wash.
B-ll
-------
-------
APPENDIX C
EPA AND STAT1 PRETREATMENT COORDINATORS
-------
-------
APPENDIX C
PRETREATMENT COORDINATORS
U.S. EPA Headquarters and Regional Contacts - 1987
Region Contact Phone Numbers
1 Mr. Gerald Potamis (Permits, Room 2203) (617) 565-3519
Mr. Dan Murray (Permits Compliance,
U.S. EPA Room 2103) (617) 565-3500
Region 1
Water Division
John F. Kennedy Federal Building
Room 2203 or 2103
Boston, MA 02203
2 Mr. George Meyer (212) 264-2676
Mr. Pat Durak (212) 264-9878
U.S. EPA
Region 2
26 Federal Plaza
Room 845A
New York, NY 10278
3 Ms. Charlene Harrison (Permits)(3UM-51) (215) 597-9406
Mr. John Lovell (Enforcement)(3WM-52) (215) 597-6279
U.S. EPA
Region 3
841 Chestnut Building
Philadelphia, PA 19107
4 Mr. Albert Herndon (404) 347-2211
Water Management Division
Facilities Performance Branch
U.S. EPA
Region 4
345 Courtland Street, N.E.
Atlanta, GA 30365
5 Mr. Dave Rankin (Permits)(WQP-TUB-8) (312) 886-6111
Mr. Gary Amendola (WQC-TUB-8) (312) 353-2105
U.S. EPA (Enforcement)
Region 5
230 S. Dearborn Street
Chicago, IL 60604
ALL FEDERAL EXPRESS
111 W. Jackson St.
8th Floor
Chicago, IL 60604
C-l
-------
PRETREATMENT COORDINATORS (Continued)
Region Contact Phone Numbers
6 Mr. Lee Bohme (Permits)(6W-PM) (214) 655-7175
Ms. Wren Stenger (Enforcement) (214) 655-6470
U.S. EPA
Region 6
Allied Bank Tower at Fountain Place
1445 Ross Avenue
Dallas, TX 75270
7 Mr. Lee Duvall (WACM) (913) 236-2817
U.S. EPA
Region 7
726 Minnesota Avenue
Kansas City, KS 66101
8 Mr. Marshall Fischer (8WM-C) (303) 293-1592
Ms. Dana Allen (303) 293-1593
U.S. EPA
Region 8
1 Denver Place
999 18th St., Suite 500
Denver, CO 80202-2405
9 Mr. Keith Silva (Permits)(W-5-l) (415) 974-8298
Ms. Christine Wright-Shacklett (415) 974-8311
U.S. EPA (Enforcement)(W-5)
Region 9
215 Fremont Street
San Francisco, CA 94105
10 Mr. Robert Robichaud (M/S 521)(Permits) (206) 442-1448
Mr. Bill Chamberlin (Enforcement)
U.S. EPA
Region 10
Permits Branch
1200 Sixth Avenue
Seattle, WA 98101
Headquarters - Permits Division
Permits U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Mr. William Diamond (EN-336) (202) 475-9537
Chief, Program Implementation Branch
Room 214, N.E. Mall
Mr. Tim Dvyer (EN-336) (202) 475-9526
Environmental Engineer
Technical Support Branch
Room 208, N.E. Mall
C-2
-------
PRETREATMENT COORDINATORS (Continued)
Headquarters -
Permits
(Continued)
Contact
Mr. Robert Eagen (EN-336)
Environmental Engineer
or
¥ork Assignment Manager
Program Implementation Branch
Room 208, N.E. Mall
Dr. James D. Gallup (EN-336)
Chief, Technical Support Branch
Room 208, N.E. Mall
Mr, Geoff Grubbs (EN-336)
Chief, Program Development Branch
Room 211, N.E. Mall
Ms. LeAnne E. Hammer (EN-336)
Environmental Engineer
Program Development Branch
Room 2702, N.E. Mall
Mr. Craig Jakubowics (EN-336)
Program Implementation Branch
Room 208, N.E. Mall
Mr. Tom Laverty (EN-336)
Section Chief,
Program Implementation Branch
Room 2702, N.E. Mall
Mr. Ed Ovsenik (EN-336)
Program Implementation Branch
Room 214, N.E. Mall
Ms. Martha Prothro (EN-336)
Director, Permits Division
Room 214, N.E. Mall
Mr. Chuck Prorok (EN-336)
Environmental Protection Specialist
Program Implementation Branch
Room 2702, N.E. Mall
Mr. Jim Taft (EN-336)
Program Development Branch
Room 2702, N.E. Mall
Phone Numbers
(202) 475-9529
(202) 475-9541
(202) 475-9539
(202) 475-7050
(202) 475-9533
(202) 475-7054
(202) 475-9516
(202) 475-9545
(202) 475-7053
(202) 475-7051
C-3
-------
PRETREATMENT COORDINATORS (Continued)
Headquarters
Permits
(Continued)
Headquarters
Enforcement
Contact
Mr. Hap Thron
Section Chief
Technical Support Branch
Room 214, N.E. Mall
Enforcement Division
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Mr. Salahdin Abdul-Haqq (EN-338)
Environmental Engineer
Room 216, N.E. Mall
Mr. Edward Bender, Ph.D. (EN-338)
Biologist
Room 216-F, N.E. Mall
Mr. Andy Hudock (EN-338)
Environmental Engineer
Room 216, N.E. Mall
Mr. William Jordan (EN-338)
Director, Enforcement Division
Room 216, N.E. Mall
Mr. Richard Kinch (EN-338)
Environmental Engineer
Room 216-E, N.E. Mall
Ms. Anne Lassiter (EN-338)
Chief, Enforcement Division
Room 216, N.E. Mall
Ms. Virginia Lathrop (EN-338)
Environmental Scientist
Room 216, N.E. Mall
Mr. Gary Polvi (EN-338)
Supervisor, Environmental Engineering
Room 216, N.E. Mall
Phone Numbers
(202) 475-9537
(202) 382-4373
(202) 475-8331
(202) 382-7745
(202) 475-8304
(202) 475-8319
(202) 475-8307
(202) 475-8299
(202) 475-8316
C-4
-------
PRETREATMENT COORDINATORS (Continued)
Headquarters - Contact Phone Numbers
ITD
Industrial Technology Division
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
Devereaux Barnes (¥H-552) (202) 382-7120
Acting Director, ITD
Room E911C
Mary L, Belefski (WH-552) (202) 382-7153
Project Officer, Battery Manufacturing
Room E905B
Ernst P. Hall (WH-552) (202) 382-7126
Chief, Metals Industry Branch
Room E905C
C-5
-------
NPDES STATE PRETREATMENT CONTACTS
REGION 1
CT Mr. Mike Harder
Assistant Director
Permits and Enforcement
Department of Environmental
Protection
State Office Building
165 Capitol Avenue
Hartford, CT 06115
(203) 566-3245
RI Ms. Christine Volkay-Hilditch
Sanitary Engineer
Rhode Island Department of
Environmental Management
Water Resources Division
Permits and Planning Section
83 Park Street
Providence, RI 02903
(401) 277-3961
VT Mr. Gary Shokes
Environmental Engineer
¥ater Resources Department
Agency for Environmental
Conservation
State Office Building
Montpelier, VT 05602
(802) 828-3341
REGION 2
NJ Mr. Kenneth Goldstein
Environmental Engineer
Division of Water Resources
Office of Sludge Management and
Industrial Pretreatment
P.O. Box 2809
Trenton, NJ 08625
(609) 292-0407
NY Mr. Joseph F. Kelleher, P.E.
Chief, Technical Transfer
Mr, Stuart E. Smith, P.E.
Senior Sanitary Engineer
Bureau of Municipal Project
Management
N.Y. State Department of
Environmental Conservation
50 tfolf Road, Room 306
Albany, N¥ 12233-0001
(518) 457-6716/457-5968
REGION 3
DC Mr. Jean Levesque
Administrator
Water Resources Management Admin.
5010 Overlook Avenue, S.W.
Washington, DC 20032
(202) 767-7651
DE Mr. Paul Jones '
Environmental Engineer
Water Resources Section
Division of Environmental Control
Dept. of Natural Resources and
Environmental Control
Edward Tatnell Building
. 89 Kings Highway
P.O. Box 1401
Dover, DE 19901
(302) 736-5733
MD Ms. Merrylin Zaw-Mon
Chief, Pretreatment Section
Maryland Office of Environmental
Protection
State of Maryland
201 W. Preston Street
Baltimore, MD 21203
(301) 225-6461
PA Mr. Tim Carpenter
Chief, Operation Section
Division of Sewerage and Grants
Bureau of Water Quality
Management
Pennsylvania Department of
Environmental Resources
P.O. Box 2063
Harrisburg, PA 17120
(717) 787-3481
VA Ms. LaVern Corkran
Pretreatment Program Director
State Water Control Board
Office of Engineering Application
P.O. Box 11143
2111 N. Hamilton Street
Richmond, VA 23230
(804) 257-6313
C-6
-------
NPDES STATE PRETREATMENT CONTACTS (Continued)
REGION 3
(Continued)
W Mr. Pravin Sangani
Mr. Dave Montali
West Virginia Dept. of Natural
Resources
1201 Greenbrier Street
Charleston, UV 25311
(304) 345-8855/348-4086
REGION 4
AL Mr. Curt Johnson
Environmental Engineer II
Alabama Department of Environmental
Management
Water Division
State Office Building
1751 Federal Drive
Montgomery, AL 36130
(205) 271-7700
GA Mr. John Beall
Water Quality Control
Environmental Protection Division
Georgia Department of Natural
! Resources
205 Butler Street E. Tower
Atlanta, GA 30334
(404) 656-7400
KY Mr. Michael Welch
Permit Review Branch
Division of Water
Natural Resources and Environmental
Protection Cabinet
18 Reilly Road
Frankfort, KY 40601
(502) 564-3410
MS Mr. Jerry Cain
Chief, Industrial Wastewater
Mississippi Department of Natural
Resources
Bureau of Pollution Control
P.O. Box 10385
Jackson, MS 39209
(601) 961-5171
NC Mr. Doug Finan
Supervisor
Pretreatment Unit
North Carolina Dept. of Natural
Resources & Community Develop.
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC 27611-7687
(919) 733-5083
SC Mr. Alton Boozer
Domestic Wastewater Division
South Carolina Department of
Health and Environmental Control
2600 Ball Street
Columbia, SC 29201
(803) 734-5300
TN Mr. Jim Cornwell
Division of Water Pollution
Control
Tennessee Dept. of Health and
Environment
150 9th Avenue North
Terra Building, 2nd Floor
Nashville, TN 27219-5405
(615) 741-0633
REGION 5
IL Ms. Angela Tin
Pretreatment Coordinator
Permits Section
Division of Water Pollution
Control
Illinois EPA
2200 Churchhill Road
Springfield, IL 62706 .
(217) 782-0610
IN Mr. Lonnie Brumfield
Indiana Pretreatment Coordinator
Indiana Dept. of Environmental
Management
Office of Water Management
105 South Meridian
Indianapolis, IN 46225
(317) 232-8710
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NPDES STATE PRETREATMENT CONTACTS (Continued)
REGION 5
(Continued)
MI Mr. Frank Baldwin or
Mr. Bruce C. Moore
Industrial Pretreatment Program
Dept. of Natural Resources
P.O. Box 30028
Lansing, MI 48909
(517) 373-4624
(517) 373-4625
MN Mr. Randy Dunnette
Minnesota Pollution Control
Agency
1935 West County Road B-2
Roseville, MN 55113
(612) 296-7756
OH Mr. Mehmet Tin or Ms. Heidi Sorin
Special Project Coordinator
Ohio Environmental Protection
Agency
P.O. Box 1049
Columbus, OH 43216-1049
(614) 466-3791
ALL FEDERAL EXPRESS
361 East Broad St.
Columbus, OH 43215
WI Mr. Stan Kleinert
Environmental Specialist
Wisconsin Dept. of Natural
Resources
P.O. Box 7921
Madison, ¥1 53707
(608) 267-7635
REGION 6
AR Mr. Dick Quinn
Ms. Donna Parks
Pretreatment Coordinator
Enforcement Division
Arkansas Department of Pollution
Control and Ecology
8001 National Drive
Little Rock, AR 72009
(501) 562-7444
REGION 7
IA Mr. Steve Williams
Environmental Specialist
Wastevater Permits Branch
lova Department of Natural
Resources
Henry A, Wallace Building
900 East Grand
Des Moines, IA 50319
(515) 281-8884
KS Mr. Don Carlson/Steve Casper
Chief, Industrial Unit
Water Pollution Control Section
Kansas Department of Health &
Environment
Building 740 - Forbes Field
Topeka, KS 66620
(913) 862-9360
MO Mr. Richard Kuntz
Environmental Engineer
Missouri Dept. of Natural
Resources
Division of Environmental Quality
P.O. Box 176
Jefferson City, MO 65102
(314) 751-6996
NE Mr. Jay Ringenberg
Environmental Specialist
Water Pollution Control Division
Nebraska Dept. of Environmental
Control
Box 94877, Statehouse Station
301 Centennial Mall, South
Lincoln, NE 68509
(402) 471-2186
REGION 8
CO Ms. Pat Nelson
Water Quality Control Division
Colorado Dept. of Health
4210 E. llth Avenue
Denver, CO 80220
(303) 331-4755
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NPDES STATE PRETREATMENT CONTACTS (Continued)
REGION 8
(Continued)
MT Mr. Fred Shewman
Sanitary Engineer
Water Quality Bureau
Montana Department of Health
Capitol Station
Helena, MT 59601
(701) 224-2375
ND Ms. Sheila Kuhn - Permits
North Dakota State Department of
Health
1200 Missouri Avenue
Bismarck, ND 58505
(701) 224-4578
UT Mr. Donald Hilden
Environmental Health Specialist
Utah Department of Health
Division of Environmental Health
Bureau of Water Pollution Control
P.O. Box 16690
Salt Lake City, UT 84116-0690
(801) 533-6146
WY Mr. John Wagner
Technical Supervisor
Water Quality Division
Wyoming Dept. of Environmental
Quality
Hathaway Office Building
Cheyenne, WY 82002
(307) 777-7781
REGION 9
AZ Mr. Jim Mestin
Mr. Steve Devereaux
Mr. Andrew Rendes - Southern Reg.
Arizona Dept. of Health Services
Office of Water and Wastewater
Quality Control
4040 E. 29th St.
Tucson, AZ 85711
(602) 628-5321
AZ Mr. Gordon Fox
Pretreatment Coordinator -
Northern Region
Arizona Dept. of Health Services
Office of Water and Wastewater
Quality Control
2501 N. 4th St., Suite 14
Flagstaff, AZ 86001
(602) 779-0313
AZ Mr. Paul Steadman
Section Manager
Operations and Compliance Section
. Bureau of Water Quality Control
Arizona Dept. of Health Services
2005 N. Central Ave., Rm. 302
Phoenix, AZ 85004
, (602) 257-2242
CA Mr. Ron Duff
Chief, Pretreatment Unit
Division of Water Quality
CA State Water Resource Control
Board
901 P Street
P.O. Box 100
Sacramento, CA 95801
(916) 324-1260
HI Mr. Shinji Soneda
Chief of Environmental Protection
and Health Services
Hawaii State Department of Health
P.O. Box 3378
Honolulu, HI 96801
Attn: Dennis Lau
(808) 548-6410
NV Mr. Joe Livak
Pretreatment Coordinator
Department of Environmental
Protection
201 S. Fall Street
Capitol Complex
Carson City, NV 89710
(702) 885-4670
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NPDES STATE PRETREATMENT CONTACTS (Continued)
REGION 10
OR Mr. John Harrison
Supervisor, Source Control
Oregon Department of
Environmental Quality
Executive Building
811 Southwest 6th Avenue
Portland, OR 97204
(503) 229-5325
WA Mr. Stan Springer
Pretreatment Coordinator
Washington Department of Ecology
Mail St. PV-11
Olympia, UA 98504
(206) 459-6043
it U.S. GOVERNMENT PRINTING OFFICE: 1887— 716-002/ 60728
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