£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

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             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

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                         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.
                               2-7

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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

-------
• 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

-------
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

-------
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

-------
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

-------


LEADY 1
ir.n , OXIDE I
PRODUCTION |i,

SULFURIC ACID «— ^»| M'XER ^_^
\
1
PASTE
PbO-Pb
RECYCLED
TO MIXER
-SEPARATORS — *•
OPEN FUHMATlGhl
DEHYDRATED LINE
\


f
"2SU4 naAiw 1

H,. n i
*n !,.,.,„ , y, 	 ;.' F-
DRY |

CASE — «J ASSEMBLY I

• URN POST 1
' T
COVER -»] SEAL | 	
1
WASTEWATER WATER — *•
SCRUBBER
mmmj
WA
W«
PASTING
MACH
WITH t
INE


STORAGE
OR CURE
OF PLATES
»
[ STACKER
T
WELD
ASSEI
ELEMI
REJ
PLA'
MBLED
•NTS
BATTE
CASE
COVEF
:CT-
FES
1 FRESH ACID

\ \
H2 *
PIG LEAD OR
SHEET LEAD
J
STE
TER
GRID
MANUFACTURE


PbO CLEAN-UP
~|
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

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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

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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

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 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

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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

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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

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               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

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     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
                               2-40

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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.

                               2-41

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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.
                               3-1

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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.
                               3-2

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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
                               3-3

-------
 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



                               3-4

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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





                               3-5

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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.
                               3-6

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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.
                               3-7

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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 .




                               4-1

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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





                               4-2

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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


                               4-3

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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

                               4-4

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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

                          4-5

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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

                               4-6

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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



                               4-7

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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
                               4-8

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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).

                               4-9

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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.


                               4-10

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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.
                               4-11

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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-





                               4-12

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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
                                4-13

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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
                                4-14

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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.
                                4-15

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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

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                            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 ,

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                               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

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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

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 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

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-------
  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

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                     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

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                     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

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                     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

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                       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

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                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
                                      C-7

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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
                                      C-8

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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
                                      C-9

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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


                                      C-10

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