Revision 0-6/15/01
                                                Concttrteni
                                                Technologies
              U.S. Environmental Protection Agency
         Environmental Technology Verification Program
      For Metal Finishing Pollution Prevention Technologies
                      Verification Test Plan

                              for the

Evaluation of Hydrometrics, Inc. High Efficiency Reverse Osmosis
       (HERO™) Industrial Wastewater Treatment System

                            Revision 0
                           June 15, 2001
   Concurrent Technologies Corporation is the Verification Partner for the EPA ETV Metal
   Finishing Pollution Prevention Technologies Center under EPA Cooperative Agreement
                           No. CR826492-01-0.

-------
                                                    Revision 0-6/15/01
                                                   Technvfogies
             U.S. Environmental Protection Agency
        Environmental Technology Verification Program
     For Metal Finishing Pollution Prevention Technologies
                    Verification Test Plan

                           for the

Evaluation of Hydrometrics, Inc. High Efficiency Reverse Osmosis
      (HERO™) Industrial Wastewater Treatment System
                         June 15, 2001

-------
                                                                     Revision 0-6/15/01
TITLE:            Evaluation of Hydrometrics, Inc. High Efficiency Reverse Osmosis
                   (HERO™) Industrial Wastewater Treatment System

ISSUE DATE:      June 15, 2001
                              DOCUMENT CONTROL

This document will be maintained by Concurrent Technologies Corporation in accordance with
the EPA Environmental Technology Verification Program Metal Finishing Technologies Quality
Management  Plan. Document  control elements include unique issue numbers, document
identification, numbered pages, document distribution records, tracking of revisions, a document
MASTER filing and retrieval system, and a document archiving system.
                               ACKNOWLEDGMENT
This is to acknowledge Valerie Whitman and Marvin South  (CTC), Mike Stites (Honeywell
FM&T), and Mark Reinsel, Ph.D., P.E. (Hydrometrics, Inc.) for their help in preparing this
document.
     Concurrent Technologies Corporation is the Verification Partner for the EPA ETV Metal
     Finishing Pollution Prevention Technologies Center under EPA Cooperative Agreement
                                  No. CR826492-01-0.
                                         11

-------
                                                                                   Revision 0-6/15/01
                 Environmental Technology Verification for Metal Finishing Technologies Program
             (ETV-MF) Verification Test Plan for the Evaluation of Hydrometrics, Inc. High Efficiency
                       Reverse Osmosis (HERO™) Industrial Wastewater Treatment System.
             PREPARED BY:
a

              C.hns
              RTV-MF Project Manager
                f'* Project
             APPROVED BY:

              Clittfon E.
              CTTQAManecr

              Dunn W. Rr(m--n
              CTC ETV-Mf Program
             AWQ£.
             EPA ETV Center
                           Inc.

                                                                              7/S/o i

                                                                               Date
                                                                         	^r%  r^

             Signature denotes acceptance of this test plan as written regarding experimental design, quality assurance, test and
             analysis methods,  operational procedures, equipment configuration, project management and current HERO™
             system operating effectiveness prior to testing.
                                                       in

-------
                                                                     Revision 0-6/15/01


                              TABLE OF CONTENTS
                                                                              Page

1.0 INTRODUCTION	1
       1.1    Background	2
       1.2    Data Quality Objectives (DQO)	3
2.0 TECHNOLOGY DESCRIPTION	3
       2.1    Theory of Operation	3
       2.2    Commercial Status	5
       2.3    Pollution Prevention Classification	5
       2.4    Environmental Significance	6
3.0 PROCESS DESCRIPTION	8
       3.1    Equipment and Flow Diagram	8
       3.2    Test Site	9
       3.3    KCP Conventional Wastewater Treatment System	10
             3.3.1   Copper Recovery & Cyanide Oxidation	10
             3.3.2   Chromium Reduction	11
             3.3.3   Lime Precipitation & Clarification	11
       3.4    Hydrometrics Mobile HERO™ Unit Installation at KCP	12
             3.4.1   Pretreatment	12
                    3.4.1.1 Prefiltration & SAC Ion Exchange Treatment	12
             3.4.2   HERO™ System	12
                    3.4.2.1 WAC Ion Exchange Treatment	12
                    3.4.2.2 Membrane Degasification	12
                    3.4.2.3 pH Adjustment and Reverse Osmosis (RO)	12
4.0 EXPERIMENTAL DESIGN	13
       4.1    Test Goals and Objectives	13
       4.2    Critical and Non-Critical Measurements	14
       4.3    Test Matrix	15
             4.3.1   HERO™ System Wastewater Recovery-Test #1	15
             4.3.2   WAC Ion Exchange Unit Copper Recovery - Test #2	15
       4.4    Operating Procedures	18
                                         IV

-------
                                                                        Revision 0-6/15/01

       4.5     Sampling, Process Measurements, and Analytical Methods	18
              4.5.1  Sampling Responsibilities & Procedures	18
              4.5.2  Process Measurements	22
              4.5.3  Testing Parameters	25
                    4.5.3.1 Flow Rate	25
                    4.5.3.2 Temperature	25
                    4.5.3.3 pH	25
                    4.5.3.4 Specific Conductivity	25
                    4.5.3.5 Total Suspended Solids (TSS)	26
                    4.5.3.6 Total Dissolved Solids (TDS)	26
                    4.5.3.7 Oil & Grease (O&G)	26
                    4.5.3.8 Metals	26
                    4.5.3.9 Additional Proposed MP&M Limits	27
                    4.5.3.10  Additional KCP Recycled Water Quality Standards	27
              4.5.4  Calibration Procedures and Frequency	28
              4.5.5  Mass Balance	28
              4.5.6  Energy Use	30
              4.5.7  Cost Analysis	30
              4.5.8  Waste Generation Analysis	31
5.0 QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS	31
       5.1     Quality Assurance Objectives	31
       5.2     Data Reduction, Validation, and Reporting	31
              5.2.1  Internal Quality Control Checks	31
              5.2.2  QA/QC Requirements	32
                    5.2.2.1 Duplicates	32
                    5.2.2.2 Matrix Spikes	33
                    5.2.2.3 Field Blanks	33
              5.2.3  Calculation of Laboratory Data Quality Indicators	33
                    5.2.3.1 Precision	34
                    5.2.3.2 Accuracy	34
                    5.2.3.3 Comparability	35
                    5.2.3.4 Completeness	35
                    5.2.3.5 Representativeness	35

-------
                                                                    Revision 0-6/15/01

                   5.2.3.6 Sensitivity	35
      5.3    Quality Audits	36
6.0  PROJECT MANAGEMENT	37
      6.1    Organization/Personnel Responsibilities	37
      6.2    Test Plan Modifications	38
      6.3    Schedule/Milestones	38
      6.4    Documentation/Records	38
7.0  EQUIPMENT	38
      7.1    Equipment List and Utility Requirements	38
      7.2    Monitoring/Sampling Equipment	39
8.0  HEALTH AND SAFETY PLAN	40
      8.1    Hazard Communication	40
      8.2    Emergency Response Plan	40
      8.3    Hazard Controls Including Personal Protective Equipment	40
      8.4    Lockout/Tagout Program	41
      8.5    Material Storage	41
      8.6    Safe Handling Procedures	41
9.0  WASTE MANAGEMENT	41
10.0  TRAINING	41
11.0  REFERENCES	42
12.0  DISTRIBUTION	42

                                LIST OF FIGURES
Figure 1: HERO™ Wastewater Treatment Diagram - Simplified	4
Figure 2: HERO™ System Chemical Reactions	7
FigureS: HERO™ Wastewater Treatment System	9
Figure 4: HERO™ Wastewater Treatment System Diagram -Detailed	11
Figure 5: KCP's Mobile HERO™ System 	13
Figure 6: Test Data Collection Form 	23
Figure 7: Fundamental Material Balance Equation 	29
Figure 8: Material Balance Equation for KCP HERO™ System 	29
                                        VI

-------
                                                                   Revision 0-6/15/01

                                LIST OF TABLES

Table 1: Objectives and Related Test Measurements for Evaluation of the HERO™ System.... 17
Table 2: Sample Quantities	19
Table 3: Test Matrix	20
Table 4: Aqueous Samples	21
Table 5: QA Objectives for Precision, Accuracy, and Detection Limits	24
Table 6: Equipment List and Utility Requirements	39
Table 7: Monitoring/Sampling Equipment	40

                              LIST OF APPENDICES

APPENDIX A:       ETV-MF Operation Planning Checklist	  A-l
APPENDIX B:       Job Training Analysis Form	  B-l
APPENDIX C:       ETV-MF Project Training Attendance Form	  C-1
APPENDIX D:       Test Plan Modification	  D-l
                                       vn

-------
                                                                    Revision 0-6/15/01
amp
ATC
C
°C
cm
coc
CSR
CTC
CWA
DOE
DQO
EPA
ETV-MF
FM&T
ft2
ft3
gal
gfd
gpd
gpm
HOPE
HEM
HERO™
hp
hr)
Hz
1C
ICP-AES
ID
IDL
KCP
kWh
JTA
L
LM
MBS
MDL
mg
mg/L
mL
MMTC
MP&M
MRL
MS
         ACRONYMS & ABBREVIATIONS

Ampere(s)
Automated Temperature Compensated
Specific Conductivity
Degrees Celsius
Centimeter
Chain of Custody
Code of State Regulations
Concurrent Technologies Corporation
Clean Water Act
U.S. Department of Energy
Data Quality Objectives
U.S. Environmental Protection Agency
Environmental Technology Verification for Metal Finishing
Federal Manufacturing & Technology
Square Feet
Cubic Feet
Gallon
Gallons of Permeate Produced per Square Foot of Membrane per Day
Gallons per Day
Gallons per Minute
High Density Polyethylene
Hexane Extractable Material
High Efficiency Reverse Osmosis System
Horsepower
Hour
hertz
Ion Chromatography
Inductively Coupled Plasma - Atomic Emission Spectroscopy
Identification
Instrument Detection Limit
Kansas City Plant
Kilowatt-Hour
Job Training Analysis
Liter
Laboratory Manager
Metabisulfite
Method Detection Limit
Milligram
Milligrams per Liter
Milliliter
Michigan Manufacturing Technology Center
Metal Products & Machinery
Method Reporting Limit
Matrix Spike
                                        Vlll

-------
                                                                    Revision 0-6/15/01
MSD
MSDS
Hg
us
NA
O&G
O&M
OOP
P
PARCCS

PM
POC
POTW
PPE
ppm
psi
PVD
QA/QC
QMP
R&D
RO
RPD
SAC
SP-
SR
SSR
IDS
TEFC
TOC
ISA
TSS
U.S.
VOC
WAC
   ACRONYMS & ABBREVIATIONS (continued)

Matrix Spike Duplicate
Material Safety Data Sheet
Microgram
Micro-Siemens
Not Applicable
Oils and Grease
Operating & Maintenance
Open Drip-Proof
Percent Recovery
Precision, Accuracy, Representability, Comparability, Completeness and
Sensitivity
Program Manager
Point of Contact
Publicly Owned Treatment Works
Personal Protective Equipment
Parts per Million
Pounds per Square Inch
Physical Vapor Deposition
Quality Assurance/Quality Control
Quarterly Management Plan
Research & Development
Reverse Osmosis
Relative Percent Difference
Strong Acid Cation
Sampling Point
Sample Result
Spiked Sample Result
Total Dissolved Solids
Totally Enclosed Fan-Cooled
Total Organic Carbon
Technical System Audit
Total Suspended Solids
United States
Volatile Organic Carbon
Weak Acid Cation
                                         IX

-------
                                                                       Revision 0-6/15/01
1.0     INTRODUCTION

       The purpose of this test plan is to document the objectives, procedures, equipment, and
       other aspects of testing  that will be utilized  at Honeywell Federal Manufacturing &
       Technology's (FM&T's) Kansas City Plant (KCP), in Kansas City,  Missouri, during
       verification  testing  of a three-stage  reverse  osmosis wastewater treatment  system
       manufactured by Hydrometrics, Inc.  (Hydrometrics).  Hydrometrics' High Efficiency
       Reverse Osmosis (HERO™)  wastewater treatment system is a pollution  prevention
       technology  applicable to metal  finishing operations  that generate wastewater  from
       chemical rinses and spent baths, as well as collected storm water and spill residues.  This
       test plan has been prepared to evaluate the performance of the technology in conjunction
       with the U.S. Environmental Protection Agency's (EPA's) Environmental  Technology
       Verification  for Metal Finishing  (ETV-MF) Program.   The objective of the ETV-MF
       Program  is  to  identify  promising  and  innovative  pollution prevention  treatment
       technologies through EPA-supported performance verifications and to provide objective
       performance data to providers, purchasers, and permitters of environmental technologies.

       Hydrometrics, founded in 1979 and located in Helena, Montana, distributes the HERO™
       industrial wastewater  treatment  system,  which uses a  three-stage  reverse  osmosis
       treatment process to remove and concentrate metals for recovery while producing a high
       quality  product water for recycle and reuse.  The  three steps involved in the HERO™
       process are ion-exchange, membrane degasification, and reverse osmosis.   The system
       reportedly recovers nearly  100 percent of valuable metals, which  may be suitable for
       direct recycle back to the process as a liquid or recovered as scrap metal using traditional
       electro winning technologies.  Treated water produced  in the process  is reported to be
       high quality and may be suitable for direct recycle as process water make-up,  cooling
       water make-up, boiler feed water, or direct discharge.  The HERO™ technology was
       developed by  Deb Mukhopadhyay in  1996  to provide  ultra-pure  water  to  the
       microelectronics industry. Since that time,  the now-patented technology has been tested
       on several  industrial wastewater applications in industries where large quantities of
       wastewater are typically generated.

       FM&T  is evaluating a 15 gallon per minute (gpm) pilot scale HERO™ system at the
       KCP, and upon successful completion of the evaluation, they have the option to install a
       full-scale 100-200 gpm unit, which will treat all KCP wastewater. The 15 gpm HERO™
       system  is commercially available from Hydrometrics, Inc.  KCP is owned by the U.S.
       Department of Energy (DOE), and is operated by Honeywell FM&T. KCP manufactures
       a wide  variety of products for national defense  systems.  More than 95 percent of the
       work done at the KCP is for the  DOE.  For over 50 years, the KCP has manufactured
       some of the DOE's most intricate and technically demanding products.  They produce
       over 40 different lines of products ranging from semiconductors to semi-trailers, which
       include  electronic,  mechanical,  engineered   material,  and  plastics  manufacturing
       technologies. The large size and wide array of operations associated with the KCP make
       it an ideal site for demonstrating the diversity of the HERO™ system for metal finishing
       industries in general.

-------
                                                                  Revision 0-6/15/01
This project will evaluate the ability of the Hydrometrics HERO™ system to treat and
recycle the KCP's combined wastewater for reuse in the plant.  A separate Hydrometrics
copper recovery unit will also be evaluated in its ability to recover copper from a cyanide
waste stream.   Metal recovery is normally done within the HERO™ system, but due to
precipitation and removal of the copper during a pretreatment step, the installation of a
second ion exchange unit is required.  This ion exchange unit uses identical resin to the
integral HERO™ system ion exchange unit, but on a smaller scale, and must be installed
before the  KCP's conventional cyanide destruction pretreatment  step.  Evaluating and
verifying the performance of the Hydrometrics system will be accomplished by collecting
operational data and in-process samples for analysis.  The resultant test data will be used
to prepare a material balance and determine the  efficiency of water treatment/reuse and
metals recovery for  a given set of operating conditions.

The  test plan  described  in this document has been structured  to  allow the above
objectives to be met using sound scientific principles. This document explains testing
plans with respect  to areas such as test methodology,  procedures, parameters, and
instrumentation.  Section  5.0 describes Quality Assurance/Quality Control (QA/QC)
requirements of this task that will ensure the accuracy of data.  Also presented within this
document are data interpretation procedures and hypothesized results. Worker health and
safety considerations are covered in section 8.0.

This test plan will be available at the test site, and verification testing will be conducted
in accordance with the test plan requirements.

1.1    Background

There  are  more  than  15,000  companies  in  the  U.S.  that  perform  metal finishing
operations.  These  companies  discharge  their process wastewaters either  directly  to
waterways  or indirectly  to Publicly Owned Treatment Works (POTWs). Metal finishing
generates more individual wastewater discharges than any other industrial category [Ref.
1]. Many pollutants contained in metal finishing process waters are toxic,  so to comply
with Clean Water Act (CWA)  requirements, the wastewaters are treated  before being
discharged. Regulations, in general, require reduction of hexavalent chromium, oxidation
of cyanides, removal of heavy metals, and pH control.

The KCP has several plating, coating, and other metal processing operations that generate
wastewaters that are combined with other non-process industrial wastewaters and treated
in a conventional on-site wastewater treatment system, and then discharged to a POTW.
The HERO™ system will be installed before or after the conventional system to process
the wastewater so it can be reused at KCP. Copper from the cyanide process rinse water
will be concentrated in a separately installed recovery unit, and calculated using a copper
mass balance on the influent and the effluent to this unit.  The recycle of metal finishing
wastewaters is of great importance, not only from a financial standpoint, but a regulatory
standpoint as well.  Many of the heavy metals found in metal finishing wastewaters are
considered toxic by EPA.  Heavy metals such as copper and chromium have also been
identified as high priorities for reduction/elimination and off-site recovery from plating

-------
                                                                       Revision 0-6/15/01
       operations by the National Metal Finishing Research & Development (R&D) Plan, and
       are addressed in the Strategic Goals Program regarding toxic metals reduction/utilization.

       Typical reverse osmosis (RO) wastewater treatment systems can be costly and difficult to
       operate.  Membranes may foul easily and require replacement, organics in the wastewater
       are  only  moderately  rejected,  and costly  anti-sealant additions and activated carbon
       pretreatment are often required.  Conventional RO  systems typically exhibit  a low
       operating flux and a  product  water recovery  of  only 75 percent.  Due to the high
       operating pH of the reverse osmosis step, Hydrometrics' HERO™ system is essentially
       immune to fouling, thus extending the membrane life and increasing the operating flux by
       up to two times that of conventional RO. The HERO™ system exhibits a higher rejection
       of organics, requires no anti-sealant additions, and has a product water recovery of up to
       95 percent.  This results in the potential for low-cost, zero-liquid discharge operations, or
       wastewater that meets most existing discharge permits.  Recycling wastewater on-site and
       metals off-site reduces water consumption and discharge levels,  resulting in lower water
       and waste disposal costs.  The HERO™ system reportedly  solves the problems normally
       associated with  standard RO systems, and does so with reduced installation investment
       and operating costs.

       1.2    Data Quality Objectives (DQO)

       The systematic  planning  elements of the data quality objectives process identified in
       "Guidance for the Data Quality Objectives Process" (EPA  QA/G-4, August 2000), were
       specifically utilized during preparation of this verification test plan.  The project team,
       composed of representatives from CTC, the testing organization, the technology vendor,
       the host site, and the US EPA, who assisted in preparing this test plan, jointly developed:
       the  test objectives, critical  and non-critical  measurements, the test matrix,  sample
       quantity,  type, and frequency,  analytical methods, and quality  assurance objectives to
       arrive at an optimized test designed to verify the performance of the technology.

2.0    TECHNOLOGY DESCRIPTION

       2.1    Theory of Operation

       The patented HERO™ process for which Hydrometrics is licensed combines "off-the-
       shelf technologies  to convert wastewater into reusable  water.   Figure  1 shows a
       simplified diagram of the HERO™ process for wastewater purification.

       In the first step of the HERO™ process, ion exchange removes  ions that  form scale.
       Removing the hardness from the  wastewater  results  in a waste being  generated as a
       concentrated brine solution.  The second step is membrane degasification, which removes
       the buffering effect from carbon dioxide to lower caustic demands in the final step of the
       process.  Carbon dioxide is the only byproduct of the second step, where the wastewater
       alkalinity is removed.   The final step in the HERO™ process is reverse osmosis.  The
       high pH of the wastewater entering this stage eliminates fouling of the RO membrane. A
       concentrated brine solution waste is generated from this step as well.

-------
                                                                Revision 0-6/15/01
According  to Hydrometrics, the  combined, concentrated brine solutions  from the
HERO™ process represent a single waste stream, generally less than five percent of the
feed stream and usually suitable for direct discharge to a POTW.  Alternatively, the waste
stream could be evaporated to dry  solids, since the volume of water is greatly reduced
compared to waste streams generated in a traditional RO  system. Evaporation of the
waste stream may help in becoming a zero-liquid discharging facility.

Hydrometrics claims the HERO™ system can handle more total  suspended solids (TSS),
oil  &  grease  (O&G),  residual  chlorine, and biological  activity than  traditional RO
systems.   They have installed units  capable of treating a broad range of wastewater
streams with total dissolved solids (IDS) ranging up to 30,000 mg/L.

                                      Waste
                                      Water
                                                  Step #1
                                                  Ion
                                                  Exchange
                                       ^^      Step #2
                             co      R"nRl      Membrane
                                                  Degasification
                                                  Step #3
                                     C             Reverse

                                                  Osmosis
                                     Purified
                                      Water

      Figure 1: HERO™ Wastewater Treatment Diagram - Simplified

The diagram in Figure 2 illustrates the reactions that typically take place within each step
of the HERO™  process.  Hydrometrics has designed permanently installed HERO™
systems in a wide range of wastewater flow.  For the verification testing, KCP will have a
mobile, 15 gpm unit installed following their conventional wastewater treatment system.
The  15 gpm unit will only  be  treating a portion of the KCP wastewater effluent for
demonstration  purposes.

-------
                                                                 Revision 0-6/15/01
2.2    Commercial Status

The HERO™ system was introduced to the market in 1996 by Deb Mukhopadhyay.  The
target market was providing ultra-pure water to the microelectronics industry.  Several
units in this application have been operating at electronics manufacturing facilities such
as Intel and Micron.

In 1998, Hydrometrics licensed the process and began  providing  the technology for
industrial  wastewater  applications.   The  HERO™  process  was  patented  in  1999.
Approximately ten wastewater applications have been tested using the HERO™ process.
Wastewaters tested came from the following industries: mining and smelting, petroleum
refining, water produced from oil and gas drilling, natural gas power generation, and
metal finishing. Within the metal finishing industry, a range of potential applications are
possible for addressing plating baths, etching baths, or rinse waters from metal finishing
operations, circuit board manufacturing, and related processes. The HERO™ system  is
reportedly especially suited for  applications where large quantities of fresh water are
required, fresh water is in short supply, or environmental requirements are stringent.  The
HERO™ system  is also reportedly  beneficial  for applications  where traditional RO
systems have  failed or are too  costly to operate.  There  are approximately  a  dozen
HERO™ systems of various flow capacities in operation in the U.S., Asia, Europe, and
South America.

2.3    Pollution Prevention Classification

Hydrometrics' HERO™ system is a wastewater treatment technology that falls under the
water use reduction/recycle focus area.  Tested industrial wastewaters have exhibited
efficient separation of individual  metals for recovery and recycle (near 100 percent), and
very high  product  water recovery (up  to  95 percent,  compared  to  75  percent for
traditional RO).  This results in minimized fresh water consumption  and the elimination
or reduction of wastewater discharge.  The unit also  minimizes energy consumption  in
relation to traditional RO systems.  The HERO™ system waste stream is five times more
concentrated than  traditional RO waste,  reducing  the  required  evaporation  time
associated with mechanical dryers, and thereby reducing  energy  consumption for zero-
liquid discharge applications status.

Due to the rising costs of chemicals, energy, and treatment/disposal fees, and increasingly
more  stringent environmental  requirements, wastewater reduction/reuse has become a
greater priority to metal  finishing companies, and the methods  and technologies they
employ  have increased in sophistication.  Today, firms are willing to expend significant
amounts of capital and operating funds for equipment and methods that primarily reduce
the disposal frequency and amount of their process wastewaters.  By recovering water
and valuable metals for  reuse/resale, the HERO™ process makes  large steps toward
achieving these goals.

-------
                                                                  Revision 0-6/15/01
2.4    Environmental Significance

Wastewaters containing up to 30,000 parts per million (ppm) TDS and heavy metals have
been treated by the HERO™ process to meet drinking water standards. Purified water
from the HERO™  system is normally suitable for reuse or direct discharge, meeting
existing wastewater discharge compliance limits.   With reuse,  facilities can  make
significant  strides  toward  zero-liquid  discharge,  water  conservation,  and reduced
environmental liability.

The high recovery,  concentration,  and possible reuse/recycle of heavy metals from the
HERO™ process results  in a reduction of metals emissions to the environment,  a high
priority in the Metal Finishing Industry's Strategic Goals Program regarding toxic metals
reduction/utilization, and is consistent with the recommendations of the National Metal
Finishing R&D Plan.

-------
                                                                  Revision 0-6/15/01
Wastewater from Pretreatment
1
HP1 h,
(Regenerating Solution)
Air ^


STEP #1: WEAK ACIE
EXCHANGE (HAR1
Ca "1 f(HC03)2 Ca
Mg ^ SO4 + H2Z = M|
Na2J [d2 Na
Cal
During Regeneration: Mg >Z
Na2J
Her) ^
i
> CATION (WAC) ION
MESS REMOVAL)
"1 f"2CO2
5 \- Z + 2H2O + ^ H2SO4
2J [_2HC1
pH « 4.5
r
STEP #2: MEMBRANE DEGASIFICATION
(ALKALINITY REMOVAL)
H2C03 *
MiOTT ^
]
Hr> i
pH « 4.5
r
STEP #3: HIGH PH REVERSE OSMOSIS
(CONTAMINANT REMOVAL)
pH « 10.0
H20
Cal
Na2J 1
To Pretreatment
Clarifier 	 ^-ToPOT^
(if available)
OR
^ CO-
1
Atmosphere
y
O&G, SS, Metals, Biologicals & Other
Organics
	 ^ (Waste Brine Solution)
1
To POTW
+
Recycled Water (RO Permeate)
To Process or POTW
Figure 2: HERO™ System Chemical Reactions

-------
                                                                       Revision 0-6/15/01
3.0    PROCESS DESCRIPTION

       3.1    Equipment and Flow Diagram

       The technology utilizes proven and available "off-the-shelf equipment components.  The
       equipment is compact (about 8' x 20' depending on flow and application), skid mounted,
       and modular for simple expansion. Electrical service of 480 volt, 50 amp, 3-phase, 60 Hz
       is required. Operations are automated and simple, reportedly resulting in low operation
       and maintenance costs.  The unit usually operates in a continuous mode, although it also
       has  the  capability  to operate in a batch mode.   Existing RO systems can be easily
       retrofitted to operate in the HERO™ configuration.

       In the HERO™ process, weak acid cation (WAC) ion exchange is used to remove sodium
       and hardness  associated with  alkalinity.  Other cations (such as  copper, barium, iron,
       manganese and zinc) are also removed.  Treated water is  slightly acidic.  The bicarbonate
       alkalinity in the water is converted to carbon dioxide.  Additional  acid may be added to
       convert the remaining alkalinity to carbon dioxide. After degasification in the next step,
       the  TDS  is reduced according to Hydrometrics.  The WAC is regenerated periodically
       using sulfuric or hydrochloric acid.  The concentrated waste brine solution is mixed with
       the  RO reject stream for disposal.  Alternatively, Hydrometrics says the brine solution
       could be recirculated to a clarifier, if one is used as pretreatment to the HERO™ system
       for further precipitation of any remaining contaminants.

       After WAC ion exchange treatment,  the water is passed through a counter-current air
       stripper (membrane degasifier) to remove  the carbon dioxide created in the WAC  ion
       exchange process.   This step removes the buffering capacity of the  water, thereby
       minimizing caustic addition in the next step. In the high pH RO step, a small amount of
       caustic is used to increase the pH prior to treatment.  Operating at high pH has several
       important advantages:

       •  Fats and oils are emulsified. These materials are kept in solution and rejected rather
          than plating out on the membrane surface.

       •   Silt fouling is eliminated.   Membranes used in normal  RO systems become  fouled
          with silt, biological growth and organic matter.  When this occurs, the membranes are
          cleaned with  softened water at pH 10.  HERO™ systems operate continuously with
          softened feed water at pH 10.  Silt and organic matter are continuously  cleaned from
          the membrane surface and biological growth is eliminated.

       •   Silica solubility is increased.  Increased silica solubility at high pH prevents silica
          scaling  on the  membrane.  Silica  can often  be  a  limiting factor  controlling  the
          recovery limit of an RO system.

       •  Weak  organic  acids  are  ionized.  Low  concentrations of these acids can  foul
          membranes unless they are ionized.  Once ionized at high pH,  the membranes reject
          these acids.

-------
                                                                 Revision 0-6/15/01
Industrial  wastewater  quality is inherently  site-specific.   Accordingly, wastewater
treatment systems are generally designed for specific applications.  For example,  feed
water with elevated hardness, total hardness in excess of total alkalinity, high TSS,  or
high oil and grease may require additional pretreatment prior to the HERO™ system.
This pretreatment  may include  filters, strong  acid cation  (SAC) ion  exchange,  or
clarifiers.  For reasons like this,  HERO™  systems are designed to address the specific
wastewater quality characteristics of the host facility.

Figure 3 shows a photograph of a full-scale, 90 gpm,  permanently installed HERO™
system.
             Figure 3: HERO™ Wastewater Treatment System

3.2    Test Site

The host site  selected for testing is Honeywell FM&T's KCP in Kansas City, Missouri.
Honeywell FM&T,  a  prime  contractor  for  the  DOE,  manages  and  operates  the
approximately one  million  square  foot  KCP.   Honeywell FM&T  is  a division  of
Honeywell, headquartered in Morristown, New  Jersey.   Honeywell  and its divisions
produce many high-tech  products for consumer and government use. Virtually every
form of air transportation depends on at least one of Honeywell's systems, including
every manned space flight since the beginning of the U.S. space program.

The KCP is  a  state-of-the-art facility that manufactures  a wide array of mechanical,
electrical, and engineered material components for the DOE.  The KCP was established
in 1949.

-------
                                                                 Revision 0-6/15/01
The KCP manufactures electronic, mechanical, and engineered material components for
national defense systems.  Within the engineered material components operations they
have capabilities for applying and evaluating low and zero volatile organic carbon (VOC)
paints, dry film lubricants, and powder coatings.  Plasma, electrophoresis, and chemical
surface pretreatments are also available.  Electroplated coating applications include
copper, tin, tin-lead,  zinc,  cadmium,  nickel, electroless  nickel, hard and soft gold,
rhodium, and black and brown oxides. They  electroform copper, nickel, and gold.  On
difficult-to-plate substrates,  a combination of vacuum  deposition and electroplating  is
used to achieve adherent coatings.

The microelectronics manufacturing division of the facility consists of 19,000 square feet
(ft2)  of clean-rooms,  1,800  ft2 of laser  rooms,  and 26,000 ft2  of  manufacturing  and
support area.

Capabilities include Thin Film Networks, Thick Film Networks,  and Low Temperature
Co-fired  Ceramic  Networks.    Several  film materials including titanium, palladium,
palladium-gold,  platinum-gold, gold,  silver,  copper, and  chromium are  applied to a
variety of  substrate  materials using processes such as electroplating, sputtering  and
physical vapor deposition (PVD).

Figure 4 shows a detailed  schematic of the HERO™ industrial wastewater treatment
application complete with sampling points.

3.3    KCP Conventional Wastewater Treatment System

       3.3.1   Copper Recovery &  Cyanide Oxidation

       Copper will be recovered from the plating shop cyanide rinse water waste stream
       by employing a separate WAC ion exchange unit supplied by Hydrometrics,  Inc.
       Copper/cyanide bearing rinse waters are formed when drag-out or drippage from
       cyanide plating baths  contaminate rinse baths during normal copper  plating
       operations.  This separate unit will remove copper that is complexed with cyanide.
       Normally, metals recovery with the HERO™ process is achieved in the WAC ion
       exchange unit that is  integral to the three-step treatment process.  However, since
       cyanide oxidation results in copper precipitation, copper removal is more efficient
       prior to the cyanide oxidation process. A full-scale separate WAC ion exchange
       unit would  be regenerated with sulfuric acid; however, no regeneration will be
       necessary during the  verification test.  The quantity of recovered copper will be
       calculated by doing a mass balance for copper on the influent and effluent of the
       WAC unit.  The treated water will then go through the normal cyanide oxidation
       process.  This is necessary to prevent health and safety issues associated with the
       release of cyanide gas later in the treatment system.
                                    10

-------
                                                                    Revision 0-6/15/01
                                       SP-A = HERO™ Influent
                                       SP-B = HERO™ Effluent
                                       SP-C = WAC Waste Solution
SP-D = RO Waste Solution
SP-E = Metals Recovery Influent
SP-F = Metals Recovery Effluent
         = Plating Process Wash Waters
Q = Existing KCP Water Treatment System
| = HERO™ Pretreatment Steps For KCP Water
fj = Standard HERO™ Wastewater Treatment System
(R) = Regeneration Solution
   Figure 4: HERO™ Wastewater Treatment System Diagram - Detailed

       3.3.2   Chromium Reduction

       A conventional step of the KCP wastewater treatment process is the reduction of
       chromium in the chromium plating rinse waters.   The  chromium plating rinse
       waters are treated with metabisulfite (MBS) in order to reduce chromium in the
       hexavalent state to the more stable and less toxic trivalent chromium state.  The
       effluent from this step moves directly to the next step, precipitation/clarification.

       3.3.3   Lime Precipitation & Clarification

       Spent rinse water from the cyanide  oxidation, chromium reduction,  acid and
       caustic rinse water, and other finishing rinse water (aqueous degreasing, cleaning
       and rinsing) are then commingled in  3,750 gal flash mix  tanks, where they are
       treated with a sodium  hydroxide/lime slurry and mechanically mixed.  They are
       pumped at a rate of approximately 170 gpm into the conventional wastewater
       treatment system. Up to 80,000 gal of combined wastewater per day are treated in
       this conventional lime  precipitation/clarification unit during the single 10-hour
       operating shift. This system removes metals and O&G, and provides a consistent
       water quality feed to the remainder of the treatment system.
                                     11

-------
                                                                Revision 0-6/15/01


       The concentrated reject from the clarifier will continue to be pressed,  dried, and
       sent for disposal as an F006 waste.

3.4    Hydrometrics Mobile HERO™ Unit Installation at KCP

       3.4.1  Pretreatment

             3.4.1.1   Prefiltration & SAC Ion Exchange Treatment

             The HERO™ system will be  installed online and operated continuously.
             Wastewater from the prefilter  is pumped through the HERO™ system at a
             flow rate of about 15 gpm.  In addition to the normal three-step HERO™
             process, prefiltration of the post-clarified feed water to remove residual
             suspended solids  and  a SAC ion exchange  process  will be used  for
             verification testing due to the  high hardness-to-alkalinity ratio.  (SAC ion
             exchange treatment will not be required for full-scale treatment  if pre-
             softened water is used.   A standard water softener would be used to treat
             all make-up water and eliminate hardness from the process water circuit.)
             SAC  ion  exchange treated water  is then sent to  the first step  in  the
             standard HERO™ process, the WAC ion exchange unit.

       3.4.2  HERO™ System

             3.4.2.1  WAC Ion Exchange Treatment

             Wastewater  from  the  SAC  ion  exchange  flows into  the  WAC  ion
             exchange step of the HERO™ process to remove  all remaining hardness.
             Because the WAC resin is in acid form, this step also lowers the pH of the
             water to 4.5,  and  converts carbonate and bicarbonate to carbon dioxide.
             This unit is regenerated using a dilute solution of hydrochloric acid.

             3.4.2.2   Membrane Degasification

             From  the WAC  ion  exchange  outlet,  the wastewater  goes through
             degasification to remove carbon dioxide.  This inexpensive step removes
             the buffering capacity of the water, minimizing pH adjustment costs. Acid
             addition prior to the degasifiers may be necessary to lower the pH to 4.5
             for complete carbon dioxide conversion.

             3.4.2.3   pH Adjustment and Reverse Osmosis (RO)

             The final step in  the HERO™ system is adjustment to pH 10 and RO
             treatment.  Operating the RO at high pH avoids bio-fouling  and silica
             scaling, and enhances silt rejection. Treated wastewater is  returned to the
             rinse water make-up  system at a flow of about 15 gpm.  Dissolved solids
             are discharged to the sewer.
                                    12

-------
                                                                       Revision 0-6/15/01
                    The  15 gpm unit installed at the KCP for verification will process about
                    7,200 gallons per day (gpd) (based on 8 hrs/day operation).  If selected for
                    permanent  installation,  a  100-200  gpm  HERO™ system  would  be
                    scheduled to be installed in late 2001/early  2002 and will treat all of the
                    KCP process wastewater, with a capacity of 48,000-96,000 gpd (based on
                    8 hrs/day operation).  The concentrated brine solution  that is  generated
                    during the ion exchange step will be recirculated back to the conventional
                    wastewater treatment system where any remaining metal cations will settle
                    out in the clarifier.  The waste brine solution from the reverse osmosis step
                    of the HERO™  process will be directly discharged to the sewer in  the
                    permanent installation configuration.  Zero  liquid discharge is  not being
                    pursued at the Honeywell facility.  With the 15 gpm unit, Hydrometrics
                    estimates that about 5 percent or 360 gpd of waste brine solution will be
                    generated by the HERO™ process (also based on 8 hrs/day operation). If
                    selected  for permanent installation at the KCP,  the  full-scale,  100-200
                    gpm HERO™ system waste brine generation will increase to about 4,000
                    gpd (based on 5  percent of 80,000  gpd - KCP's current treatment flow).
                    This wastewater  discharge volume sounds like a large quantity, but would
                    be a 95  percent  reduction in wastewater discharges to the POTW from
                    their current 80,000 gpd.

                    Pictures  of a  15  gpm, mobile HERO™ system like  the one that will be
                    installed  at the KCP for the verification test are provided for reference in
                    Figure 5
                        Figure 5: KCP's Mobile HERO™ System

4.0    EXPERIMENTAL DESIGN

       4.1    Test Goals and Objectives

       The overall goal of this project is to establish the technical and economic performance
       parameters that will enable a potential user to determine if the Hydrometrics HERO™
       wastewater treatment system is appropriate and feasible under their specific operating
       conditions.  The objective of testing is to generate the analytical data and performance
       observations required in supporting these technology verification efforts.
                                           13

-------
                                                                 Revision 0-6/15/01
The following are statements of specific project objectives:

•  Evaluate, document, and verify the performance of the separate HERO™ wastewater
   WAC ion exchange treatment technology for the recovery of copper that builds up in
   the  process  rinse  water  during   the  cyanide-containing finishing  operations.
   Characterize the recovered copper for salability options.

•  Evaluate, document,  and verify the HERO™ wastewater treatment technology's
   removal efficiency for IDS, O&G (as HEM), Ag, Al, As, Ba, Ca, Cd, Cl, CN, Cr, Cu,
   Fe, Hg,  Mg, Mn, Mo, Na, Ni,  Pb,  Sn, Zn, total residual  chlorine, sulfate, nitrate,
   sulfides, chloride, fluoride, dissolved silica, total  alkalinity, TOC, and  TSS that
   accumulate in process rinse waters during finishing operations.

•  Quantify the energy required to operate the system. Primary energy users include the
   electrical service to the automated system, instrument readouts, and the liquid feed
   pumps. This information  will  be used to estimate operating costs for the HERO™
   wastewater treatment system.

•  Quantify environmental benefit by determining the reduction in wastewater disposal
   quantities versus HERO™ waste sludge quantities/characteristics.

4.2    Critical and Non-Critical Measurements

Measurements that will be taken during testing are classified below as either critical or
non-critical.   Critical measurements are those that  are  necessary to achieve project
objectives.   Non-critical  measurements  are those related to process  control  or general
background readings.

Operational data will be  collected on the  HERO™ wastewater  treatment system
performance during the treatment of process wastewater. The following operational data
will be collected:

Critical Measurements

•  Concentrations of TDS, O&G (as hexane extractable material (HEM)), Ag, Al, As,
   Ba, Ca,  Cd, CN, Cr, Cu, Fe,  Hg, Mg, Mn, Mo,  Na, Ni, Pb, Sn, Zn, total residual
   chlorine, sulfate, nitrate,  sulfides,  chloride,  fluoride,  dissolved  silica,  TOC, total
   alkalinity, and TSS in the HERO™ system influent and effluent
•  Specific conductivity and total alkalinity of rinse water influent/effluent
•  Rinse water processing rate and total volume
•  Waste volumes, characteristics (TDS, O&G (as HEM),  Ag, Al, As, Ba, Ca, Cd, CN,
   Cr, Cu,  Fe, Hg, Mg, Mn, Mo, Na,  Ni, Pb, Sn, Zn, total  residual chlorine, sulfate,
   nitrate,  sulfides, chloride,  fluoride, dissolved silica, total alkalinity, TOC, and TSS),
   and disposal costs
•  Concentrations and volumes of copper in cyanide  rinse water, WAC process influent
   and effluent
                                    14

-------
                                                                 Revision 0-6/15/01
Non-Critical Measurements

•  Membrane flux/fouling
•  Membrane vessel pressure
•  pH of rinse water influent/effluent and waste products
•  Temperature of rinse water influent/effluent and waste products
•  Operating and Maintenance (O&M) labor requirements
•  Reagent (lime, sulfuric acid and caustic) use rates

This data will  be used to determine the system material balance, wastewater purification
rate, O&M requirements,  and  the  cost-effectiveness for  a  given set of  operating
conditions.

Historical Data

Historical data on the KCP's wastewater disposal quantities prior to installation of the
HERO™ wastewater treatment system will be collected and provided in the verification
report to determine the environmental benefit.

The  KCP's records  regarding plating rinse water quality  measurements will also be
reviewed and  summarized in the verification report in order to alleviate plating quality
concerns regarding the implementation of the HERO™ wastewater treatment system.

4.3    Test Matrix

The unit will be evaluated on its ability to efficiently treat and recover metal finishing
process wastewater. The specific tests planned are described in Table 1.  In order to gain
the valuable  system performance  information desired for the  ETV-MF  Program,
sampling, testing, and documentation will take place over a four-day period.

       4.3.1   HERO™ System Wastewater Recovery - Test #1

       A large portion  (46  percent) of  the combined KCP wastewater is dilute, non-
       production wastewater. This non-production wastewater consists of non-contact
       cooling water, boiler blow-down water, laboratory sink water, etc.  The remaining
       54 percent of the KCP's spent process water  consist of non-metal-finishing
       industrial process wastewaters,  and rinse waters  from metal finishing.   The
       HERO™ system will  be evaluated on its ability to separate chemical contaminants
       from the wastewater and recycle the water back to the  metal finishing process
       rinse tanks.

       4.3.2   WAC Ion Exchange Unit Copper Recovery - Test #2

       A very small amount or  KCP's  wastewater, about 330 gpd, is cyanide-bearing
       rinse water  from the KCP  metal finishing  shop's  copper plating operations.
       Copper is a  potential recyclable/salable metal,  and this  verification test will
                                    15

-------
                                                          Revision 0-6/15/01
include a separate WAC ion exchange unit installed between the cyanide rinse
water storage tank and the first step of the cyanide oxidation process.  This WAC
unit  uses resin identical to the WAC unit within  the HERO™  system where
metals recovery would normally take place, but on a smaller scale.  Due to KCP's
conventional wastewater treatment system, a separate WAC unit must be installed
upstream of that system in order to recover the copper.   Because of the  small
amount of cyanide-bearing rinse water generated at KCP, copper recovery will
not be economically feasible at KCP. The verification on this WAC  unit will
demonstrate the HERO™ system's ability to remove  valuable metals for recovery,
recycle and/or sale.

4.3.3 HERO Effluent Water Recycling

The  rinse water used in KCP metal finishing operations is standard Kansas City
tap water.  Recycled water from the HERO™  system must meet the minimum
quality standards equal to this tap water.   A sample of KCP's tap water was
analyzed before the verification test for TDS, O&G (as HEM),  Ag, Al, As, Ba,
Ca, Cd, Cl, CN, Cr, Cu, Fe, Hg, Mg, Mn, Mo, Na, Ni, Pb, Sn, Zn, total residual
chlorine,  sulfate,  nitrate,  chloride,  sulfides,  fluoride, dissolved  silica,  total
alkalinity,  TOC, and  TSS and will  be  compared  to recycled  water from the
HERO™ treatment system in the verification report.

4.3.4 RO Waste Solution

According to Hydrometrics, the single waste stream produced in  the process is
generally less than  10 percent of the feed stream.  This concentrated waste brine
solution is  generated from the ion exchange and reverse osmosis steps of the
HERO™ treatment system, and Hydrometrics claims it is  generally suitable for
direct discharge to a POTW.  This waste consists primarily  of sodium sulfate, but
may  also contain heavy metals, suspended solids, O&G, biological materials, and
other organic materials that have been removed from the wastewater. The KCP's
waste brine solution has been tested in a bench-top  test, and it meets all current
KCP wastewater  discharge  limits.   The  KCP must sample  and  test  their
wastewater every six months, according to their sewer discharge permit; however,
they  typically sample and test every other month.  The RO waste solution will be
evaluated to ensure it meets KCP's discharge limits.
                             16

-------
                                                                                    Revision 0-6/15/01
Test
1. HERO™ System
Wastewater
Recovery
2. WACIon
Exchange Unit
Copper Recovery
Test Objectives
Prepare a material balance for wastewater constituents.
Evaluate the ability of the HERO™ system to process
wastewater and separate chemical contaminants from water.
Determine the wastewater recovery rate of the system,
normalized based on production throughput of wastewater.
Determine the labor requirements needed to operate and
maintain the HERO™ system.
Determine the quantity of energy consumed by the
HERO™ system during operation.
Determine the cost of operating the wastewater recycle
system for the specific conditions encountered during the
testing.
Quantify /identify the environmental benefit.
Prepare a material balance for copper recovered from the
cyanide-bearing rinse waster.
Evaluate the ability of the WAC ion exchange unit to
process wastewater and separate copper contaminants from
water.
Determine the copper recovery rate of the system,
normalized based on production throughput of wastewater.
Determine the labor requirements needed to operate and
maintain the WAC ion exchange unit.
Determine the cost of operating the WAC ion exchange unit
for the specific conditions encountered during the testing.
Quantify /identify the environmental benefit.
Test Measurement
• Chemical characteristics of influent.
• Chemical characteristics of effluent.
• Volume and chemical characteristics of the RO waste solution.
• Quantity of treatment chemicals used during testing.
• Chemical characteristics of influent.
• Chemical characteristics of effluent.
• Volume of water recovered.
• Production throughput of wastewater.
• O&M labor requirements during test period.
• Quantity of energy used by pumps and motors.
• Costs of O&M labor, materials, and energy required during test period.
• Quantity and price of treatment chemicals used during testing.
• Review of historical waste disposal records and compare to verification
test practices.
• Chemical characteristics (Cu) of influent.
• Chemical characteristics (Cu) of effluent.
• Volume and chemical characteristics of copper removed from
wastewater.
• Quantity of treatment chemicals used to recover the copper.
the
• Chemical characteristics (Cu) of influent.
• Chemical characteristics (Cu) of effluent.
• Volume of copper recovered.
• Production throughput of wastewater.
• O&M labor requirements during test period.
• Costs of O&M labor and materials required during the test period.
• Quantity and price of chemicals used during copper recovery.
• Review of historical waste disposal records and comparison
verification test practices.
to
Table 1: Objectives and Related Test Measurements for Evaluation of the HERO™ System
                                        17

-------
                                                                       Revision 0-6/15/01
4.4    Operating Procedures

The 15 gpm, trailer-mounted HERO™ system will be parked on a concrete pad adjacent to the
building housing the existing lime precipitation clarifier wastewater treatment system.  A blind
sump  surrounds the concrete pad, as this  is a designated chemical loading/unloading area,
complete with secondary containment. The  separate copper recovery ion exchange unit will be
installed within the KCP wastewater treatment plant, inside the secondary containment wall, next
to the cyanide rinse water holding tank.  Treated  water from KCP's conventional wastewater
treatment plant will be piped to the  HERO™ system.  The HERO™ system will polish pre-
treated water from  an estimated  80,000 gpd  combined flow of non-production wastewater, non-
metal finishing process wastewater, acid/caustic rinse water, and metal finishing rinse waters.

Hydrometrics  and  KCP personnel will perform normal operation  and  maintenance activities
during testing. These activities will be observed and noted by the ETV-MF Project Manager.

The HERO™ system will be operated six to  eight hrs/day.  The exact number of operating hours
will depend on the KCP work-load schedule. The verification test period will be four workdays.

4.5    Sampling, Process Measurements, and Analytical Methods

       4.5.1   Sampling Responsibilities & Procedures

       By using a dual wastewater holding tank  system at the facility, it is anticipated that
       contaminant concentration should remain relatively stable over each  day of testing. The
       incoming wastewater is stored in large holding tanks where  it is isolated at the start of
       each day from incoming wastewater, and agitated with mixing pumps. The stream is then
       fed  into the traditional wastewater  treatment plant and on into the HERO unit at a
       uniform rate.

       Grab samples will be taken from the sampling ports associated with the corresponding
       sampling points specified in Figure  4.  Sampling  will occur in  the quantities listed in
       Table 2, and the frequency listed in Table 3 for each parameter.  The KCP waste
       treatment operators will use their dual-waste holding tank system to  isolate, collect, mix
       and provide consistent wastewater flows for the duration of the four day verification test.

       The appropriate sampling container  will be used as outlined in Table 4 for each test
       parameter.  Each sample bottle will be labeled with the date, time, sample identification
       (ID)  number, and test parameters required.  Sampling will take place at least one hour
       after any  system  shut-down/start-up  operations.    Sample  preparation methods are
       described in each individual analytical method.
                                       18

-------
                                           Revision 0-6/15/01

TSS
TDS
TOC
O&G
(as HEM)
Metals
Sulfide
Total Cyanide
Chloride
Sulfate
Nitrate, as N
Fluoride
Total
Alkalinity
Dissolved Silica
SP-A
HERO™ Unit
5axlL
5axlL
10cx500mL
12exlL
5axlL
5ax500mL
5ax500mL
5axlL
5axlL
5axlL
5axlL
5axlL
5ax500mL
SP-B
HERO™ Unit
5axlL
5axlL
10cx500mL
12exlL
5axlL
5ax500mL
5ax500mL
5axlL
5axlL
5axlL
5axlL
5axlL
5ax500mL
SP-C
HERO™ Unit
5axlL
5axlL
10cx500mL
12exlL
5axlL
5ax500mL
5ax500mL
5axlL
5axlL
5axlL
5axlL
5axlL
5ax500mL
SP-D
HERO™ Unit
5axlL
5axlL
10cx500mL
12exlL
5axlL
5ax500mL
5ax500mL
5axlL
5axlL
5axlL
5axlL
5axlL
5ax500mL
SP-E
2nd WAC Unit
-
-
-
-
5axlL
(Cu only)
-
-
-
-
-
-
-
-
SP-F
2nd WAC Unit
-
-
-
-
5axlL
(Cu only)
-
-
-
-
-
-
-
-
Field Blank -
Lab DI Water
lbxlL
lbx!L
2d x 500 mL
2dxlL
lbxlL
lbx500mL
lbx500mL
lbxlL
lbxlL
lbxlL
lbxlL
lbxlL
lbx500mL
Notes:
a Sample quantities of 5 include 1 grab sample on 4 successive days, and 1 duplicate.
b Sample quantities of 1 include 1 grab sample (laboratory DI water).
0 Sample quantities of 10 include 1 grab and 1 archive sample on 4 successive days, 1 duplicate and 1 duplicate archive.
d Sample quantities of 2 include 1 sample and 1 archive (laboratory DI water).
e Sample quantities of 12 include 1 grab and 1 archive sample on 4 successive days, 1 duplicate, 1 duplicate archive, 1 MS
and 1 MSD.
One duplicate sample will be collected from each sample location during the verification test period.
Matrix spike (MS) and matrix spike duplicate (MSD) analysis will be performed on each duplicate sample for all applicable
parameters.
The duplicate, MS and MSD samples must be collected on the same day at approximately the same time.
The archive samples will not be analyzed unless necessary; they will be identified as "Archive" and transported in a shipping
container separate from the other samples.
Table 2: Sample Quantities
            19

-------
                                            Revision 0-6/15/01
SAMPLE
LOCATION
SP-A
HERO™ Influent















SP-B
HERO™ Effluent
SP-C
WAC Waste
Solution
SP-D
RO Waste Solution
SP-E
Metals Recovery
Influent
SP-F
Metals Recovery
Effluent
# OF SAMPLES
5
(4 + one duplicate)















5
(4 + one duplicate)
5
(4 + one duplicate)

5
(4 + one duplicate)
5
(4 + one duplicate)

5
(4 + one duplicate)

FIELD
BLANK
1























1





FREQUENCY
1 grab
sample/day















1 grab
sample/day
1 grab
sample/day

1 grab
sample/day
1 grab
sample/day

1 grab
sample/day

TEST
DURATION
4 days
















4 days

4 days


4 days

4 days


4 days


PARAMETERS
TSS, IDS, TOC,
O&G (as HEM),
Specific
Conductivity,
Total Alkalinity,
Ag, Al, As, Ba,
Ca, Cd, Cl, Cr,
Cu, Fe, Hg, Mg,
Mn, Mo, Na, Ni,
Pb, Sn, Zn, Total
Residual
Chlorine, Sulfate,
Sulfide, Nitrate,
Fluoride, CN,
Dissolved Silica,
Temp., pH, Flow
Rate
Same as SP-A

Same as SP-A


Same as SP-A

Copper, Temp.,
pH, Flow rate

Same as SP-E


Table 3: Test Matrix
         20

-------
                                                                                 Revision 0-6/15/01
ANALYTE
TSS
IDS
TOC
O&G (as HEM)
Metals
(except Hg)
Hg
Sulfide
Total Cyanide
Chloride
Sulfate
Nitrate, as N
Fluoride
Total Alkalinity
Dissolved Silica l
METHOD
EPA 160.2
EPA 160.1
SW-846
9060
EPA 1664
EPA 200.7
EPA 245.1
EPA 376.1
EPA 335.3
EPA 300.0
EPA 300.0
EPA 300.0
EPA 300.0
EPA 3 10.1
EPA 370.1
SAMPLE BOTTLE
1 L (HOPE)
1L HOPE
500 mL amber glass
1 L amber glass
1LHDPE
1LHDPE
500 mL HOPE
500 mL HOPE
1 L HOPE
1 L HOPE
1 L HOPE
1 L HOPE
1 L HOPE
500 mL HOPE
PRESERVATION
Cool to 4°C
Cool to 4°C
H2SO4 to pH < 2
& cool to 4°C
H2SO4 to pH < 2
& cool to 4°C
HNOa to pH < 2
& cool to 4°C
HNOa to pH < 2
& cool to 4°C
NaOH to pH>9/Zn
Ac, & cool to 4°C
NaOHtopH> 12
& cool to 4°C
None
Cool to 4°C
Cool to 4°C
None
Cool to 4°C
Cool to 4°C
HOLD TIME
7 days
7 days
28 days
28 days
6 months
28 days
7 days
14 days
28 days
28 days
48 hours
28 days
14 days
28 days
                                    Table 4: Aqueous Samples

              Samples to be analyzed at the off-site laboratory will be  accompanied by a chain-of-
              custody (COC) form.  The samples will be stored and transported in appropriate sample
              transport containers  (e.g., coolers with packing and blue ice) by common carrier.  The
              transport containers will be secured with tape seals to ensure sample integrity during the
              delivery process to  the analytical laboratories.   The ETV-MF Project  Manager will
              perform sampling and labeling, and ensure that samples are properly stored and secured
              for transport to the analytical laboratory.  Pace Analytical Services  Inc. will perform all
              aqueous analytical transportation and the testing of all samples.
1 Digestion is not required, due to lack of molybdate unreactive silica.  Filtration shall be prepared by the laboratory
 immediately upon receipt
                                                21

-------
                                                                 Revision 0-6/15/01
4.5.2   Process Measurements

Monitoring during the verification test period will be accomplished by  recording key
operating data.  Monitoring instrumentation will be calibrated and used by the ETV-MF
Project Manager according to manufacturer recommendations.   See section 4.5.4  for
specific calibration procedures.  Process measurements will be recorded on the test data
collection form (Figure 6) at the same time that aqueous sampling occurs, that is to say,
once a day, in accordance with Table 3. On-site measurements will be performed three
times for each sampling activity in order to  determine compliance with the QA objectives
stated in Table 5.

Wastewater  flow  rates for this verification  test will  be  measured by  an  Omega
Engineering,  Inc.,  Model FD-7000   multi-liquid  ultrasonic  flowmeter  with  non-
penetrating transducers. Wastewater pH and temperature will be measured on-site with a
Davis  Instruments  Model  #9214 microprocessor controlled,  automatic temperature
compensated  pH meter with built-in temperature  sensor.   See Table 5  for equipment
performance details.  Wastewater specific conductivity will be measured with an Oakton
Acorn® Series CON 5 microprocessor controlled, automatic temperature compensated
conductivity  meter with built-in temperature  sensor.   See  Table 5 for  equipment
performance details.  Total residual chlorine will be measured on-site immediately after
sampling with a Hach® Pocket Colorimeter™ filter photometer with total chlorine reagent
set. See Table 5 for equipment performance details.

Membrane flux is the decrease in permeate flow rate due to membrane performance
deterioration, caused by the membrane becoming fouled with contaminants. Flux will be
calculated as the gallons of permeate product per square foot of membrane per day (gfd).
Increasing the  flux  results  in  lower  capital  costs and better effluent quality.    In
conventional  RO  systems, membranes foul with scale (divalent metal precipitates),
organics (oil and hydrocarbons), and microbial growth.  The HERO™ process reportedly
eliminates this by removing the  divalent metal ions and then operating the RO at a high
pH where organics are emulsified and biological growth does  not occur.  Hydrometrics
claims the HERO™ system achieves an operating flux that is up to two times that of
traditional RO.  RO  reject  flowrate  will  be  collected,  then membrane flux  will be
calculated upon completion of the verification test.
                                22

-------
                                            Test Data Collection Form
DATE:
                                                                                                   Revision 0-6/15/01
OPERATION: HERO™ Wastewater Treatment System
SAMPLE DATA
Date



















Time



















Sample
Location



















Initials



















INFLUENT (FEED) WATER
PARAMETERS
Temp.
(°C)



















pH



















Flow
Rate
(gpm)



















SC
(US)



















Total
C12
(mg/L)



















RO REJECT / WAC WASTE
PARAMETERS
Temp.
(°O



















pH



















Flow
Rate
(gpm)



















Total
Volume
(gal)



















EFFLUENT (PERMEATE) WATER
PARAMETERS
Temp
(°O



















pH



















Flow
Rate
(gpm)



















SC
(US)



















Total
C12
(mg/L)



















                                            Figure 6: Test Data Collection Form



                                                          23

-------
                                                                                                                    Revision 0-6/15/01
Measurement
TOC
O&G (as HEM)
Metals (- Hg)
Hg
Sulfide
Total Cyanide
Chloride
Sulfate
Nitrate
Fluoride
Total Alkalinity
Dissolved Silica
TSS
TDS
Total Residual C12
Flow Rate
Temperature
pH
Specific Cond.
Membrane Flux
Matrix
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Aqueous
Method
EPA 9060
EPA 1664
EPA 200.7
EPA 245.1
EPA 376.1
EPA 335.3
EPA 300.0
EPA 300.0
EPA 300.0
EPA 300.0
EPA 3 10.1
EPA 370.1
EPA 160.2
EPA 160.1
EPA 330.5
EPA 3. 1.9
EPA 170.1
EPA 150.1
EPA 9050A
-
Units
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
mg/L
L/hr
°C
pH
M-S/cm
gfd
Method of
Determination
Combustion / Oxidation
Gravimetric
ICP-AES
Manual Cold Vapor
Titrimetric, Iodine
Colorimetric, Automated UV
Ion Chromatography
Ion Chromatography
Ion Chromatography
Ion Chromatography
Colorimetric (Methyl Orange)
Colorimetric
Gravimetric
Gravimetric
DPD-Colorimetric
Ultrasonic Flowmeter
Thermometric
Electrometric
Wheatstone Bridge-Type
Calculated
MRL
10.0
5.68
0.004-1.0
0.0002
0.5
0.005
1.0
1.0
1.0
0.2
1.0
1.0
5.0
5.0
0.01
0.3-3.6
0.1
0.01
1.0
N/A
Precision
(RPD)
<30
<30
<30
<30
<30
<30
<30
<30
<30
<30
<30
<30
<30
<30
<2
<1
< 1
<0.2
<2
N/A
Accuracy
(% Recovery)
70-130
70-130
70-130
70-130
70-130
70-130
70-130
70-130
70-130
70-130
70-130
70-130
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Completeness
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
90
N/A
EPA/821/C-99/004:
EPA SW-846:
N/A - Not applicable
EPA Methods and Guidance for Analysis of Water
EPA Test Methods for Evaluating Solid Waste
                                 Table 5: QA Objectives for Precision, Accuracy, and Detection Limits
                                                                    24

-------
                                                          Revision 0-6/15/01
4.5.3   Testing Parameters

       4.5.3.1  Flow Rate

       Liquid transfer pumps deliver  process  water to various parts  of the
       HERO™ system during the purification process.  The rate at which these
       liquids are  transferred is of major importance in the  HERO™ system.
       Liquid flow rates will be determined at all liquid sampling points (SP-A
       through SP-F) with an Omega Engineering, Inc., Model FD-7000 multi-
       liquid  ultrasonic  flowmeter  with non-penetrating  transducers.  (EPA
       Method 3.1.9 and equipment manufacturer's instructions)

       4.5.3.2  Temperature

       While temperature  is not a critical parameter in the HERO™ process, it
       will be monitored at all liquid sampling points  (SP-A through SP-F) in
       order to determine the temperature range  of the wastewaters being treated
       as they enter  and exit the HERO™ process during  the verification test
       (EPA   Method   170.1   and  equipment manufacturer's  instructions).
       Temperature will be measured with a Davis  Instruments Model #9214
       microprocessor controlled, automatic temperature compensated pH meter
       with built-in  temperature sensor.   Wastewater entering the  HERO™
       system is not temperature controlled, and is typically ambient temperature.

       4.5.3.3  pH

       pH of the wastewater is a critical parameter in the HERO™ process. The
       wastewater  is  acidified  before the degasification step,  and the pH is
       increased before the reverse osmosis step. The pH of the wastewater will
       be monitored at all liquid sampling points (SP-A through SP-F) in order to
       determine the  pH range of the wastewaters being treated as they  enter and
       exit the HERO™ process during the verification  test (EPA Method 150.1
       and equipment manufacturer's instructions).  pH will be measured with a
       Davis Instruments  Model #9214  microprocessor controlled,  automatic
       temperature compensated pH meter with built-in temperature sensor.

       4.5.3.4  Specific Conductivity

       Conductivity is the  measurement of a material's ability to conduct electric
       current.  The ability to  transmit  an electrical  current depends  on the
       concentration  of charged or ionic species in the  material.  Hence, the
       measure of the conductance is used to approximate the total concentration
       of  ionic species  present.  This measurement is an estimator  of water
       contamination.  Specific  conductivity will be measured at the  HERO™
       system influent and effluent (SP-A & SP-B), and waste  products (SP-C &
       SP-D). (EPA Method 9050A and equipment manufacturer's instructions).
                             25

-------
                                                   Revision 0-6/15/01
Specific conductivity will be measured with an Oakton Acorn® Series
CON 5 microprocessor controlled, automatic temperature compensated
conductivity meter with built-in temperature sensor.

4.5.3.5  Total Suspended Solids (TSS)

TSS are non-filterable particles of solids dispersed but undissolved in the
wastewater, which cloud the water's appearance and impair the efficiency
of the rinse waters.  It is important to remove these contaminants in order
to meet regulatory requirements and give the recovered wastewater  a clean
and clear appearance.   Samples will be collected at the HERO™  system
influent, effluent, and waste  streams (SP-A through SP-D) and analyzed
for TSS according to EPA Method 160.2.

4.5.3.6  Total Dissolved Solids (TDS)

TDS  are  the  total of disintegrated  organic  and inorganic  materials
contained in the wastewater.  TDS also impair the efficiency of the rinse
waters; therefore, it is critical to remove TDS in order to make the water
fit for recycling  back to the industrial  processes.   Samples will be
collected at the HERO™ system influent, effluent, and waste streams (SP-
A through SP-D) and analyzed for TDS according to EPA Method 160.1.

4.5.3.7  Oil & Grease (O&G)

Oil  and grease are contributed to the wastewater as oily parts are  rinsed.
The O&G is a combination of machining and cutting oils and coolants that
are used in metalworking.  These fluids may contain mineral oils,  natural
oils, fats and derivatives, or synthetic lubricants.  O&G in the wastewater
must be removed before the water can be recycled to the process rinse
baths.  Samples for total recoverable O&G (as HEM) will be collected at
the HERO™ system influent, effluent, and waste streams (SP-A through
SP-D), and analyzed for O&G (as HEM) by EPA Method 1664.

4.5.3.8  Metals

Certain contaminant metals will  accumulate in the process rinse  waters
based on the type of substrate being finished and the finishing processes.
Most of these metals will come from  drag-out or drippage into the rinse
waters. These metals need to be removed before the water can be recycled
to the  process rinse baths.  Samples will be collected at the  HERO™
system influent, effluent, and waste streams (SP-A through SP-D) and will
be analyzed according to  EPA Method  200.7  for  all  metals  except
mercury, which will be analyzed by EPA Method 245.1.
                      26

-------
                                                   Revision 0-6/15/01
For the 2nd WAC unit installed on the KCP CN wastewater stream, only
copper will be sampled and analyzed in the influent and effluent of this
unit (SP-E and SP-F).

4.5.3.9 Additional Proposed MP&M Limits

The proposed Metal Products & Machinery (MP&M) rule discharge limits
will have a major impact on the metal finishing industry. Fortunately for
the KCP, they are already monitoring their wastewater effluent for most of
the proposed MP&M contaminants. Installing the HERO™ system should
enable the KCP to recycle  approximately  95 percent of their current
wastewater for  reuse.   The  remaining five  percent  consist of the
regeneration waste  from the  ion exchange step and  the  waste brine
solution from  the reverse osmosis step.  These waste streams will be
commingled and tested for the standard contaminants  that the KCP is
required to monitor for discharge to  the  sanitary sewer.  In addition to
these standard contaminants, the waste stream will be tested for additional
contaminant parameters, which will  require monitoring under the new
proposed MP&M limits for metal finishers. These new parameters for the
KCP are: manganese, molybdenum, tin, sulfide, total  cyanide, TSS, and
total organic carbon (TOC).  Samples will be taken at the HERO™ system
influent,  effluent, and waste  streams (SP-A  through SP-D)   (MP&M
metals: EPA Method 200.7; total cyanide: EPA Method 335.3; TSS: EPA
Method 160.2; TOC: SW-846 Method 9060; sulfide: EPA Method 376.1).

4.5.3.10 Additional KCP Recycled Water Quality Standards

KCP has stated that the recycled water  from the HERO™ system should
be of a water quality that meets or exceeds the Kansas City tap water that
KCP currently used for rinse bath make-up, non-contact cooling water,
boiler water,  etc.   The  Missouri Code of  State Regulations (CSR),
Department  of Natural Resources,  Public  Drinking  Water Program,
Contaminant Levels and Monitoring Regulations (10 CSR Division 60 -
Chapter 4) sets forth the maximum allowable  contaminant  levels for
drinking water. It is to these standards that KCP would like to polish their
wastewater.  Fortunately for the KCP, they are already monitoring their
wastewater effluent for most of the contaminants.  The  recycled water will
be tested for the following additional contaminant parameters that require
monitoring under the drinking water program:  chloride, total  residual
chlorine, sulfate, nitrate as N, fluoride, total alkalinity and dissolved silica.
Samples will be taken at the HERO™ system influent,  effluent, and waste
streams (SP-A through SP-D)  (chloride, fluoride, nitrate as N and sulfate:
EPA Method  300.0; total residual chlorine: EPA  Method 330.5; total
alkalinity: EPA Method 310.1; dissolved silica: EPA Method 370.1).
                      27

-------
                                                          Revision 0-6/15/01
4.5.4   Calibration Procedures and Frequency

The following procedures will be used to calibrate the instruments/equipment that
will be used to collect critical measurements:

2)   Instruments used to perform aqueous analytical methods will be calibrated
     according to the laboratory  quality assurance plan by Pace Analytical
     Services.

3)   The ultrasonic liquid flowmeter, used to measure the flow rate of liquids
     within the HERO™ system,  is on an annual calibration  schedule.   The
     flowmeter  is calibrated by the equipment manufacturer.  The ETV-MF
     Project Manager will verify the flowmeter has been calibrated prior to use.
     An operational  check will be conducted at the start of each sampling day,
     and in accordance with the equipment manufacturer's instructions by the
     ETV-MF Project Manager.

4)   Wastewater temperature  is not a  controlled parameter; however, pH is
     controlled  throughout  the  conventional  wastewater  treatment  system.
     Temperature  and pH measurements will be taken each time a sample is
     drawn from its respective sampling port. The digital pH reader/temperature
     probe will be calibrated at the start of each sampling day by the ETV-MF
     Project Manager.  The following calibration information will be collected
     and recorded in the field notebook: buffer supplier, lot number, expiration
     date, and date of usage.

5)   Specific conductivity measurements will be taken each time a sample is
     drawn from its respective sampling  port.  The digital conductivity meter will
     be  calibrated at the start of  each  sampling day by the ETV-MF Project
     Manager.   The  following  calibration  information will  be collected and
     recorded in the field notebook: standard  solution  supplier,  lot number,
     expiration date, and date of usage.

6)   Total residual chlorine measurements will be taken each time a sample is
     drawn from its respective sampling port.  The digital filter photometer has
     been calibrated  by the  equipment manufacturer and  is on an annual
     recalibration  schedule.   The ETV-MF Project Manager  will verify the
     photometer meter has been calibrated prior to use.

4.5.5   Mass Balance

The conservation of mass/energy  in any isolated system is one  of the most
fundamental laws in science and engineering.  The mass/energy balance is a tool
that was developed  to  account  for the  inputs, outputs,  consumption,  and
accumulation in  a system.    To  determine  system efficiency, measuring  or
quantifying all of the elements for a mass balance in an industrial setting is very
                             28

-------
                                                          Revision 0-6/15/01
difficult. The greatest challenge is generally defining the system boundaries and
what  degree  of accuracy  is required.  Sampling,  measurement, and analytical
errors preclude  absolute precision; however, the mass/energy balance provides us
with  a  fundamental tool  for  evaluating  the performance  of environmental
technologies where we are generally evaluating some form of efficiency.

Figure 7 illustrates the most fundamental form of the material balance equation.
Batch systems  and continuous systems can both be modeled using this general
form.

Mass
Accumulation
Within the
System


Equals


Mass Input
Through
System
Boundaries


Less


Mass Output
Through System
Boundaries



Plus


Mass
Generated
Within the
System


Less


Mass
Consumed
Within the
System

      Figure 7: Fundamental Material Balance Equation

Figure 8 illustrates the material flow into and out of the KCP HERO™ system.
   Wastewater
    Influent
       HERO™
       System
                                                 Wastewater Effluent
                           Waste Brine Solution
                                               Recovered Metals Solution
Figure 8: Material Balance Equation for KCP HERO™ System

The goal of the Hydrometrics HERO™ system verification project is to determine
performance, and this  can generally be measured in  terms  of efficiency.  For
water recovery technologies, percent contaminant removal  and percent water
recovery are measures of system efficiency.

To  determine efficiency,  the  fundamental  material  balance  equation  can be
simplified as:
where:
            X,
            Xw
            Xe
                               X; — Xw + Xe
Mass in influent
Mass in waste
Mass in effluent
                             29

-------
                                                          Revision 0-6/15/01
Sampling will occur in the quantities  listed in Table 2, at the frequency and
duration  specified in Table 3. Historical operating records at the KCP indicate
that there is an average of 78 ppm of copper in the untreated cyanide-bearing rinse
water.  At the current KCP flow rate,  this equates to a potential 50 pounds of
copper recovered per year. Conventionally treated KCP wastewater meets current
sewer disposal limits, but is not recyclable due to elevated levels of sodium,
chloride, nitrates, sulfates, and zinc.  The HERO™ system is designed to reduce
these contamination levels so that the treated water can be recycled.  Four days of
sampling was  selected in order to show the treatment of a significant volume of
wastewater at a steady contaminant-loading rate.

To determine the contaminant removal efficiency for any parameter, the material
balance equation for the KCP HERO™ system is expressed as:
where:
           Ceff    =   Target contaminant removal efficiency
             C;    =   Influent target contaminant concentration (mg/L)
            IVoi    =   Influent volume processed during the test (L)
             Ce    =   Effluent target contaminant concentration (mg/L)
           Eyoi    =   Effluent volume processed during test (L)

The removal efficiency will be calculated on a daily basis.

4.5.6   Energy Use

Energy requirements for the HERO™ unit will be calculated by determining the
power requirements and cycle times  of pumps and other powered devices.  For
motors and pumps, summing the total quantity of horsepower hours and dividing
by 1.341 HP-hr/kWh will determine electrical consumption.

4.5.7   Cost Analysis

This analysis will quantify the accumulative cost benefit of the technology.  The
cost  of operating the mobile HERO™ unit at the KCP will be calculated for
comparison to operating costs for a  time period prior to utilization of the unit.
Operating costs will then be extrapolated, using normalized data,  for a full scale
HERO™ unit for treating all of the KCP's wastewater. Operating costs may be
offset by recovered metals, recycled water, and less waste requiring disposal. For
the baseline conditions, the most recent applicable data available, collected by the
KCP, will be used.  The cost analysis will compare operating costs, including:
chemical costs and savings, waste treatment/disposal costs and savings, and costs
for labor, utilities, maintenance and other materials.
                             30

-------
                                                                       Revision 0-6/15/01
             4.5.8  Waste Generation Analysis

             This analysis  will quantify the environmental benefit of the technology.  The
             waste generation rates for operating the mobile HERO™ unit at the KCP will be
             calculated and compared to waste  generation rates for a time period prior to
             utilization of the  unit.  Waste generation rates will then be extrapolated, using
             normalized  data,  for a full  scale HERO™  unit for treating all of the KCP's
             wastewater.    For the baseline conditions,  the  most  recent  applicable data
             available, collected by the KCP, will be used.  The waste generation analysis will
             consider type/characteristics, volume, and frequency of waste generated.

5.0    QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS

       QA/QC  activities  will  be  performed  according  to the  applicable sections  of the
       Environmental Technology Verification Program Metal Finishing Technologies Quality
       Management Plan (ETV-MF QMP) [Ref. 3].

       5.1    Quality Assurance Objectives

       One QA objective is to ensure that the process operating conditions  and test methods are
       maintained  and documented throughout each test  and laboratory analysis of samples.
       Another QA objective is to use standard test methods for laboratory analyses.  The test
       methods to be used are shown in Tables 3 & 4.  The analytical methods that will be used
       for analyzing the samples are standard EPA  methods.

       5.2    Data Reduction, Validation, and Reporting

             5.2.1  Internal Quality Control Checks

             Raw Data Handling.  Raw data is generated and collected by laboratory analysts
             at the bench and/or sampling site. These include original observations, printouts,
             and  readouts from equipment for sample, standard,  and reference QC analyses.
             Data is collected both manually and  electronically.  At a minimum, the date, time,
             sample ID,  instrument ID, analyst  ID,  raw signal  or processed signal, and/or
             qualitative  observations will be recorded.   Comments to document unusual or
             non-standard observations also will be included on the forms, as necessary.  Data
             collected on-site will be recorded onto the form presented in Figure 6.  The ETV-
             MF  Project Manager will complete COC forms  that will  accompany samples
             during shipment to the respective labs. Raw data will be processed manually by
             the analyst,  automatically by an electronic program, or electronically after being
             entered into a computer.  The analyst will be responsible  for scrutinizing the data
             according to laboratory precision, accuracy, and completeness policies.  Raw data
             bench  sheets and calculation or data  summary sheets will be kept together for
             each sample batch.  From the  standard operating procedure and the raw data
             bench  files,  the steps leading to a final result can be traced.   The CTC ETV-MF
                                          31

-------
                                                           Revision 0-6/15/01


Program Manager (PM)  will maintain process-operating data for use in report
preparation.

Data Package Validation.  The generating analyst will assemble a preliminary
data package, which shall be initialed and dated.  This package shall contain all
QC and raw  data  results, calculations,  electronic  printouts,  conclusions, and
laboratory sample tracking information.  A second analyst will review the entire
package and check  sample and storage logs, standard logs, calibration logs, and
other  files, as  necessary, to ensure that all tracking,  sample treatments, and
calculations are correct.  After  the package  is reviewed in this  manner,  a
preliminary data report will be prepared, initialed, and dated. The entire package
and final report will be submitted to the Laboratory Manager (LM). The LM shall
be ultimately responsible for all final data released from the laboratory.  The LM
or designee will review the final results for adequacy to the QA objectives.  If the
manager or designee suspects an  anomaly or non-concurrence with expected or
historical performance values, the raw data will be reviewed, and the generating
and reviewing analysts queried. If suspicion about data validity still exists after
internal review of laboratory records, the manager will  authorize a re-test.  If
sufficient sample is not available for re-testing, a re-sampling  shall occur. If the
sampling window has passed, or re-sampling is not possible, the manager will flag
the data as suspect.  The LM signs and dates the final data package.

Data Reporting.  A report signed and dated by the LM will be submitted in
duplicate to the ETV-MF Project Manager and CTC Project Manager. The ETV-
MF Project Manager will decide the appropriateness of the data for the particular
application.   The final report contains the laboratory sample  ID,  date reported,
date analyzed, the analyst, the method used for each parameter, the process or
sampling point identification, the final result, the units, and the quality control
sample results.  The CTC QA Manager shall review the data packages as required
by the ETV-MF QMP [Ref 3]. The CTC ETV-MF Program Manager shall retain
the data packages as required by the ETV-MF QMP.

5.2.2   QA/QC Requirements

For those  measurements where  duplicates,  spikes,  and spike duplicates  are
inappropriate (e.g., flow rate, pH, temperature, specific conductivity, total residual
chlorine and membrane  flux) additional  measurements  will take  place.   A
minimum of three repetitions will be conducted for each measurement for each
sampling day  in order to ensure  compliance with the QA objectives stated in
Table  5.  The instrument  will be recalibrated if the objectives  for  these
measurements are not met.

       5.2.2.1  Duplicates

       Duplicate samples collected  in the field will be used to quantify sample
       representativeness  associated  with the  entire  sampling  and  analysis
                             32

-------
                                                           Revision 0-6/15/01
       system.  Duplicate samples (submitted as two aliquots) will be submitted
       at least once during the test period. Duplicate samples will be collected
       from both the influent and effluent of the HERO™  system  during the
       treatment of the combined wastewater and cyanide-bearing wastewater.
       The duplicate samples will be analyzed for all analytical parameters listed
       in Table 3.

       5.2.2.2  Matrix Spikes

       Matrix spike/spike duplicates will be performed at least once during the
       test period for each applicable parameter.  For example,  several different
       process streams will be sampled as shown in Table 3 (SP-A through SP-
       F).   Test parameters  that can undergo matrix  spike/spike duplicate
       procedures  are:  TOC, O&G  (as  HEM), metals, and  sulfide,  sulfate,
       fluoride, nitrate,  chloride,  dissolved silica and total cyanide (TSS, TDS,
       and  total  alkalinity   cannot  undergo  matrix  spike/spike  duplicate
       procedures).    A matrix  spike/spike  duplicate for each of  these test
       parameters will be performed on the duplicate sample for each sampling
       point during the four-day sampling period. Sample splitting will occur at
       the  analytical laboratory  with the  exception of O&G (as HEM), which
       requires additional bottles to be collected  at the time of sampling in order
       to  provide  enough  sample  to perform matrix  spike/spike duplicate
       procedures.

       5.2.2.3  Field Blanks

       Field blanks of laboratory-supplied deionized water will be prepared on-
       site and submitted to the  analytical laboratory during the verification test
       period. The  analysis of  these  samples  for  the  normal test  parameters
       (TOC, TSS,  TDS,  O&G (as HEM), metals, and sulfide,  sulfate, fluoride,
       nitrate, chloride, dissolved  silica, total cyanide and total alkalinity) will
       ensure that (1) analytical equipment-cleaning protocols  adequately remove
       residual contamination from previous use,  (2)  sampling  and sample-
       processing procedures do not result in contamination,  and (3) equipment
       handling  and transport between periods of sample  collection  do not
       introduce contamination.

5.2.3   Calculation  of Laboratory Data Quality Indicators

Analytical  performance  requirements  are expressed in terms of  precision,
accuracy,   representability,  comparability,   completeness,   and   sensitivity
(PARCCS).  Summarized below  are  definitions and QA objectives for  each
PARCCS parameter.
                             33

-------
                                                    Revision 0-6/15/01
5.2.3.1   Precision

Precision is a  measure of the  agreement or repeatability  of a set of
replicate results obtained  from duplicate analyses made under identical
conditions.  Precision is  estimated from analytical data and  cannot be
measured directly.  The precision of a duplicate determination  can be
expressed as the relative percent difference (RPD), and calculated as:
where:
                     RPD =
        Xi = sample result
        X2 = duplicate result
                              X,-X,
                             (X.+XJ
  x 100%
Multiple determinations will be performed for each test on the same test
specimen.  The replicate analyses must agree within the relative percent
deviation limits provided in Table 5.

5.2.3.2   Accuracy

Accuracy is a  measure  of the agreement between  an experimental
determination  and  the  true  value  of  the  parameter being measured.
Accuracy is estimated through the use  of known reference materials or
matrix spikes.  It is calculated from  analytical data and is not measured
directly.   Spiking  of reference materials into a  sample matrix is the
preferred technique because it provides a measure of the matrix effects on
analytical accuracy.   Accuracy, defined as  percent recovery (P), is
calculated as:
                    P =
                         (SSR-SR)
                             SA
xlOO%
where:
          SSR   =   spiked sample result
           SR   =   sample result
           SA   =   the concentration added to the spiked sample

Analyses  will  be  performed  with periodic  calibration  checks  with
traceable standards to verify instrumental accuracy.  These checks will be
performed according to established procedures in the contracted laboratory
that  have been  acquired  for the HERO™ system verification testing.
Analysis with spiked samples  will be  performed to determine percent
recoveries as a means of checking method accuracy.  QA objectives are
satisfied if the average recovery is within the goals described in Table 5.
                       34

-------
                                                    Revision 0-6/15/01
5.2.3.3   Comparability

Comparability is another qualitative measure designed to express the
confidence with which one data set may be compared to another. Sample
collection and handling techniques,  sample matrix type, and analytical
method all affect comparability.  Comparability is limited by the other
PARCCS parameters because data sets can be compared with confidence
only when precision  and accuracy are known.  Comparability will be
achieved in the HERO™ technology verification by the use of consistent
methods during sampling and analysis and by traceability of standards to a
reliable source.

5.2.3.4   Completeness

Completeness is defined as the percentage of measurements judged to be
valid, compared to the total number of measurements made for a specific
sample  matrix and analysis.   Completeness is  calculated  using the
following formula:
           _    ,          Valid Measurements   .,„„„.
           Completeness =	x 100%
                           Total Measurements
Experience  on similar projects  has  shown that laboratories typically
achieve about 90 percent completeness.  QA objectives will be satisfied if
the percent completeness is greater than the value specified in Table 5.

5.2.3.5   Representativeness

Representativeness refers to the degree to which the data accurately and
precisely represents  the conditions or  characteristics of the parameter
represented  by  the  data.    For the purposes  of  this  demonstration,
representativeness will be achieved by presenting identical samples (field
duplicates)  to  the  specified lab(s)  and  executing  consistent  sample
collection and mixing procedures. Three identical samples (one each of
influent, effluent, and sludge) will be collected  during the course of the
verification  test.  Representativeness will be satisfied  if the analytical
results for each parameter is less than 30 percent of the results  for the
associated duplicate sample.

5.2.3.6   Sensitivity

Sensitivity  is the measure of the concentration at which an analytical
method  can positively  identify and  report analytical  results.   The
sensitivity of a given method is commonly referred to as the detection
limit.  Although there  is no single definition of this term, the following
terms and definitions of detection will be used for this program.
                       35

-------
                                                                  Revision 0-6/15/01


              Instrument Detection Limit (IDL) is the minimum concentration that can
              be measured from instrument background noise.

              Method  Detection   Limit   (MDL)  is  a   statistically  determined
              concentration.  It is the minimum concentration of an analyte that can be
              measured and reported with  99  percent  confidence  that the analyte
              concentration is greater than zero as determined in the  same or  a similar
              matrix. (Because of the lack of information on analytical precision at this
              level,  sample results greater than  the MDL but less  than the method
              reporting limit (MRL) will be flagged).

              MDL is defined as follows for all measurements:

                         MDL=t(n.u.a = 0.9
              where:
                         MDL   =   method detection limit
                    t(n-i,i-a = o.99)   =   students t-value for a one-sided 99 percent
                                     confidence level and a standard deviation
                                     estimate with n-1 degrees of freedom
                              s   =   standard deviation of the replicate analyses

              Method Reporting Limit (MRL) is the concentration of the target analyte
              that the  laboratory has  demonstrated  the ability to  measure  within
              specified limits  of precision  and accuracy during routine laboratory
              operating conditions.  (This value is variable and highly matrix-dependent.
              It is the minimum concentration that will be reported as "unqualified" by
              the laboratory).

5.3    Quality Audits

Technical System Audits.  An audit will be performed during verification testing by the
CTC QA Manager according to section 2.9.3 Technical Assessments  of the ETV-MF
QMP [Ref. 3] to ensure testing and data collection  are performed  according to the test
plan requirements. In addition to the CTC Technical System Audit (TSA), the EPA QA
Manager will also conduct an audit to assess the quality of the verification test.

Internal Audits. In addition to the internal laboratory quality  control checks,  internal
quality  audits will be conducted to  ensure  compliance with  written procedures and
standard protocols.

Data Quality  Assessments.   The  CTC QA  Manager will also perform data quality
(statistical) assessments on data collected during the analysis of one metal and one anion.

Corrective Action. Corrective Action  for any  deviations to established quality assurance
and quality control procedures during verification testing will be performed according to
section 2.10 Quality Improvement of the ETV-MF QMP [Ref. 3].
                                    36

-------
                                                                       Revision 0-6/15/01
       Laboratory  Corrective Action.    Examples  of  non-conformances  include  invalid
       calibration data, inadvertent failure to perform method-specific QA, process control data
       outside specified control limits, failed  precision and/or accuracy indicators, etc.  Such
       non-conformances will be documented  on a standard laboratory form. Corrective action
       will involve taking all necessary steps  to restore a measuring system to proper working
       order  and  summarizing  the  corrective  action and  results  of subsequent  system
       verifications on a standard laboratory form. Some non-conformances are detected while
       analysis or sample processing is in progress and can be rectified in real time at the bench
       level.   Others may be detected only after a processing trial and/or sample analysis is
       completed.  Typically, the LM  detects these types of non-conformances.  In all cases of
       non-conformance, the LM will consider sample  re-analysis as one source of corrective
       action.  The LM will contact the ETV-MF Project Manager if reanalysis does not correct
       the non-conformance.  If insufficient sample is available or the holding time has been
       exceeded,  complete re-processing  may be ordered  to generate new samples  if  a
       determination is  made by  the  ETV-MF  Project Manager that the non-conformance
       jeopardizes the integrity of the conclusions to be drawn from the data. In all cases, a non-
       conformance will be rectified before sample processing and analysis continues.

6.0    PROJECT MANAGEMENT

       6.1     Organization/Personnel Responsibilities

       The ETV-MF  Project Team that is headed by CTC  will conduct the evaluation of
       Hydrometrics'  HERO™ system. The CTC ETV-MF Program Manager, Donn Brown,
       will have responsibility  for  all  aspects  of the technology  verification,   including
       appointment  of  a  Project Manager, making  ETV-MF  Project Team  personnel
       assignments, and coordination  of technology testing.   The ETV-MF  Project Manager
       assigned to the HERO™ verification  is Chris  Start  of the  Michigan Manufacturing
       Technology Center (MMTC). MMTC is one of four partner organizations under contract
       to CTC for the  ETV-MF Program.  Mr. Start and/or his staff/subcontractors will conduct
       or oversee all sampling and related measurements, and ensure that required laboratory
       QC analyses (spikes/duplicates) are performed.

       Hydrometrics will arrange transport  of the  mobile  HERO™  unit  to the  test  site.
       Hydrometrics will perform start-up.   Once the system  is performing per the  design
       objectives, verification testing will commence.  Hydrometrics personnel will continue to
       operate the system.   A Hydrometrics  representative (Steve Ackerlund) will assist in
       verification testing of the HERO™ system and will be on-call during the test period for
       response in the event of equipment problems.

       Pace Analytical Services is responsible for performing aqueous chemical analysis of all
       samples taken  during the verification  test.  Pace Analytical Services is accredited by
       NELAC for the analyses identified in this Test Plan.  Jim Dowse is the Pace Analytical
       Services point of contact (POC).
                                          37

-------
                                                                       Revision 0-6/15/01


       The ETV-MF Project Manager and the KCP have the authority to stop work when unsafe
       or unacceptable quality conditions arise.  The CTC ETV-MF PM will provide periodic
       assessments of verification testing to the EPA ETV Center Manager.

       6.2    Test Plan Modifications

       In the course of verification testing, it may become necessary to modify the test plan due
       to unforeseen  events.   These  modifications will  be documented using a  Test  Plan
       Modification Request form (Appendix D),  which must be submitted to the CTC ETV-
       MF  Program Manager for approval.  Upon arrival, the modification request will be
       assigned a number, logged, and transmitted to the requestor for implementation.

       6.3    Schedule/Milestones

       The schedule/milestones will be determined mutually by CTC, Hydrometrics, and KCP.

       6.4    Documentation/Records

       Original documentation generated during verification testing (COC forms, data collection
       forms, analytical results, etc.) will be maintained at the CTC office in Largo, Florida.

7.0    EQUIPMENT

       7.1    Equipment List and Utility Requirements

       The FtERO™ 15 gpm unit consists of the following equipment:

       Prefiltration  System:  20-micron bag filter (with  in-line spare)  followed  by a 36"
       diameter by 84"  tall multi-media depth filter.  These filters are fed  by a 5-hp totally
       enclosed fan-cooled (TEFC) pump that produces approximately 20 gpm at 50 pounds per
       square inch (psi) during normal operation,  and 100 gpm at 45 psi when cleaning the
       multi-media filter.  Filtered solids are periodically back-washed  to the clarifier, where
       they are removed.

       SAC System: 36" diameter by  84" tall pressure vessel containing 20  cubic feet (ft3) of
       SAC resin (with in-line spare).  This vessel is regenerated using a  salt brine while the in-
       line spare is in operation.

       WAC System (x2): The HERO™ unit contains a pressure tank containing 10 ft3 of WAC
       resin and can be piped for either up-flow or down-flow operation. The copper recovery
       WAC ion exchange unit will be installed at KCP adjacent to the  cyanide rinse water
       holding tank.

       Degasification System: This portion of the FtERO™ unit consists of two 4" by 28"
       Celgard Liqui-Cel Membrane Contractors,  which can be  operated either in  series or
                                          38

-------
                                                                Revision 0-6/15/01
parallel. Air for these strippers is provided by a 1-1/2 hp compressor and exits through a
stack above the roof of the mobile HERO™ trailer.

RO  System:  The HERO™ unit RO system consists of five stages of 120" pressure
vessels, each  containing three  or four membranes.  The first stage consists of two 4"
vessels rated for 600 psi and is fed by a 10-hp open drip-proof (ODP) pump.  The reject
from the first stage is fed to the second stage (a single 4" vessel rated for 600 psi). The
third stage consists of a single 4" pressure vessel rated for 1000 psi and is fed via another
10-hp ODP booster pump.   The fourth and fifth stages each consist of a single 2.5"
pressure vessel rated for 1000 psi.  The permeate from each pass is combined in a single
stream with  a flow  of approximately 15  gpm.   The reject  from the fifth pass is
approximately 1 gpm.  Equipment and utility requirements are identified in Table 6.
EQUIPMENT
Number Req'd

1
1
1

1

2

2
1

3
2
1
2
Type of Equipment
Prefilter System
20-micron bag filter
Multi-media depth filter
Pump - 5 hp TEFC
SAC System
Pressure vessel w/ 20 ft3 of SAC resin
WAC System(s)
Pressure vessels w/ 15 ft3 of WAC resin
Degasification System
Celgard Liqui-Cel Membrane Contractors
Air compressor
RO System
4 Pressure vessels w/ 4 membranes
Pumps- 10 hp ODP
4 Pressure vessel w/ 4 membranes
2.5 Pressure vessels w/ 3 membranes
Comments

Contains in-line spare
36 diameter by 84 tall
Normal=20 gpm @ 50 psi; Cleaning=100
gpm @ 45 psi

36 diameter by 84 tall; contains in-line
spare

Can be piped for either up-flow or down-flow operation

4 x 28 each; can be operated either in series or parallel
1-1/2 hp

Rated for 600 psi

Rated for 1,000 psi
Rated for 1,000 psi
SPARE PARTS
12
4
6
4
2
10
4 Brackish water RO membranes
4 Seawater RO membranes
2.5 Seawater RO membranes
5 -micron cartridge filters (set + spare)
1 -micron cartridge filters
20-micron bag filters






Required Utilities
Utilities to include: Electrical • Automated control panel: 50 amp, 480 volt, 3-phase, 60 Hz Air

• Liquid transfer pumps: 110 VAC Water
• None
• None
             Table 6: Equipment List and Utility Requirements

7.2    Monitoring/Sampling Equipment

All monitoring/sampling equipment to be used during testing is identified in Table 7.
                                    39

-------
                                                                        Revision 0-6/15/01
Equipment
Omega Engineering, Inc. Model FD-7000 Multi-Liquid
Ultrasonic Flowmeter
Davis Instruments Model #9214 ATC pH Meter with
Integral Temperature Sensor
Oakton Acorn® Series CON 5 Conductivity Meter with
Integral Temperature Sensor
Hach® Pocket Colorimeter™ Filter Photometer with Total
Chlorine Reagent Set
Purpose
Flow of System Liquids
Process pH and Temperature
Process Specific Conductivity
Process Total Residual Chlorine
                        Table 7: Monitoring/Sampling Equipment

8.0    HEALTH AND SAFETY PLAN

       This Health  and Safety Plan  provides guidelines  for  recognizing, evaluating,  and
       controlling health and physical hazards that could occur during verification testing. More
       specifically,  the Plan  specifies  for  assigned  personnel;  the  training,  materials,  and
       equipment necessary to protect them from hazards; and any waste generated. The KCP
       Hazcom/Personal  Protective Equipment (PPE) Plan/Program will be used throughout the
       HERO™ verification testing  for any activities  related  to  the conventional wastewater
       treatment system that operates at the KCP. For activities involving the HERO™ system,
       Hydrometrics will provide operating procedures  and all  associated  health and  safety
       plans/procedures.

       8.1    Hazard Communication

       All  personnel assigned to the project will be provided with the potential hazards, signs
       and symptoms of exposure, methods or materials to prevent exposures, and procedures to
       follow if there is contact with a particular substance during verification testing. Hazard
       communication will take place during training and will be reinforced throughout the test
       period.  All appropriate Material Safety Data Sheets (MSDSs) will be available for the
       chemical solutions used during the testing.

       8.2    Emergency Response Plan

       The KCP has a contingency plan to protect employees, assigned  project personnel,  and
       visitors in the event of an emergency at the facility. This plan will  be used throughout the
       project.  All assigned personnel will be provided with information about the plan during
       training.

       8.3    Hazard Controls Including Personal Protective Equipment

       All  assigned project personnel and visitors will be provided with appropriate PPE  and
       any training needed for its proper use, considering their assigned tasks.  The use  of PPE
       will be covered during training.
                                           40

-------
                                                                        Revision 0-6/15/01
       8.4    Lockout/Tagout Program

       The KCP's lockout/tagout procedure will be implemented when necessary and will be
       explained to anyone required to perform such duties.  Equipment installation performed
       by Hydrometrics and the KCP is not included within the scope of this test plan.  No
       lockout/tagout activities are anticipated during the verification test.

       8.5    Material Storage

       Any  materials used during the project will  be kept  in proper containers and labeled
       according to Federal and  state  law.  Proper storage of the materials will be maintained
       based on associated hazards.  Secondary containment, spill trays, or similar devices will
       be used as needed to prevent material loss to the surrounding area.

       8.6    Safe Handling Procedures

       All  chemicals and  wastes or  samples  will be transported on-site in non-breakable
       containers used to prevent spills.  Emergency spill clean-up will be performed according
       to the KCP procedures.

9.0    WASTE MANAGEMENT

       The HERO™ system will process wastewater generated by  manufacturing  operations at
       the KCP. Prior to processing by the HERO™ system, the wastewater will  be treated by
       the  conventional wastewater treatment  system at the KCP.   After treatment by the
       HERO™ system, the wastewater will  be returned  to the conventional wastewater
       treatment system.   The existing wastewater treatment system is  fully permitted, and
       achieves compliance with discharge requirements  in  accordance with  local, state, and
       Federal laws. Hydrometrics says the reagents to be added to the HERO™ process during
       verification  test will  increase  the  TDS,  but they  will  not  upset  existing  clarifier
       operations.  Hydrometrics will retain any unused acid or caustic.

10.0   TRAINING

       It is important that the verification activities performed by the  ETV-MF Center be
       conducted with high quality and with regard to the health and safety of the workers and
       the environment. By identifying the quality requirements, worker safety and health, and
       environmental issues associated with each verification test, the qualifications or training
       required for  personnel involved  can be  identified.   Training requirements will be
       identified using the Job Training Analysis (JTA) Plan [Ref. 4].

       The purpose  of the JTA Plan  is to outline the overall procedures for identifying the
       hazards, quality issues, and training needs for  each verification test project.  The  JTA
       Plan establishes guidelines for creating a work  atmosphere  that meets  the  quality,
       environmental, and safety objectives of the ETV-MF Center.  The JTA Plan describes the
       method for  studying ETV-MF project activity and identifying training needs. The ETV-
                                          41

-------
                                                                     Revision 0-6/15/01
      MF  Operation  Planning  Checklist (Appendix A)  will be  used as a guideline  for
      identifying potential hazards, and the JTA Form (Appendix B) will be used to identify
      training requirements.   After  completion of the form, applicable training will  be
      performed. Training will be documented on the ETV-MF Project Training Attendance
      Form (Appendix C).

11.0   REFERENCES

      1)   Thomas J. Weber, Wastewater Management  Inc., "Wastewater Treatment" Metal
           Finishing Guidebook and Directory Issue, 1999, pg. 801.

      2)   U.S. EPA Office of Environmental Information, "Guidance for the Data Quality
           Objectives Process EPA QA/G-4", EPA/600/R-96/055, August 2000.

      3)   Concurrent  Technologies  Corporation  (CTC),    "Environmental  Technology
           Verification  Program  Metal  Finishing   Technologies   (ETV-MF)  Quality
           Management Plan" Revision 1, March 26, 2001.

      4)   Concurrent  Technologies  Corporation  (CTC),   "Environmental   Technology
           Verification  Program  Metal  Finishing  Technologies   (ETV-MF)  Pollution
           Prevention Technologies Pilot Job Training Analysis Plan" May 10, 1999.

      5)   US EPA Office  of  Research and Development, "Waste Reduction  in the Metal
           Fabricated Products Industry" EPA/600/SR-93/144, September 1993.

      6)   George  C.  Cushnie  Jr.,  CAI  Engineering,  "Pollution Prevention  and Control
           Technology for Plating Operations" NCMS/NAMF, 1994.

12.0   DISTRIBUTION

      Alva E. Daniels, EPA (3)
      W. Steve Ackerlund, Hydrometrics, Inc.
      Don J. Fitzpatrick, Honeywell FM&T - KCP
      Chris L. Start, MMTC (2)
      Donn W. Brown, CTC (2)
      Clinton E. Twilley, CTC
      Scott W. Maurer, CTC
      Jim Dowse, Pace Analytical Services, Inc.
                                         42

-------
                                    Revision 0-6/15/01
           APPENDIX A
ETV-MF Operation Planning Checklist

-------
                                                                  Revision 0-6/15/01
          ETV-MF OPERATION PLANNING CHECKLIST

The ETV-MF Project Manager prior to initiation of verification testing must complete this form.
If a "yes " is checked for any items below, an action must be specified to resolve the concern on
the Job Training Analysis Form.
 Proj ect Name:	
ETV-MF Project Manager:
     Expected Start Date:
Will the operation or activity involve the following:
Yes   No
Initials & Date
Completed
Equipment requiring specific, multiple steps for controlled shutdown?
(e.g., in case of emergency, does equipment require more than simply
pressing a "Stop" button to shut off power?) Special Procedures for
emergency shut-down must be documented in Test Plan.
Equipment requiring special fire prevention precautions? (e.g., Class D fire
extinguishers)
Modifications to or impairment of building fire alarms, smoke detectors,
sprinklers, or other fire protection or suppression systems?
Equipment lockout/tagout or potential for dangerous energy release?
Lockout/layout requirements must be documented In Test Plan.
Working in or near confined spaces (e.g., tanks, floor pits) or in cramped
quarters?
Personal protection from heat, cold, chemical splashes, abrasions, etc.? Use
Personal Protective Equipment Program specified in Test Plan.
Airborne dusts, mists, vapors and/or fumes? Air monitoring, respiratory
protection, and /or medical surveillance may be needed.
Noise levels greater than 80 decibels? Noise surveys are required.
Hearing protection and associated medical surveillance may be necessary.
X-rays or radiation sources? Notification to the state and exposure
monitoring may be necessary.
Welding, arc/torch cutting, or other operations that generate flames and/or
sparks outside of designated weld areas? Follow Hot Work Permit
Procedures identified in Test Plan.
The use of hazardous chemicals? Follow Hazard Communication
Program, MSDS Review for Products Containing Hazardous Chemicals.
Special training on handling hazardous chemicals and spill clean-up may
be needed. Spill containment or local ventilation may be necessary.
Working at a height of six feet or greater?




































                                     A-l

-------
                                                                      Revision 0-6/15/01
            ETV-MF OPERATION PLANNING CHECKLIST

  The ETV-MF Project Manager prior to initiation of verification testing must complete this form.
  If a "yes " is checked for any items below, an action must be specified to resolve the concern on
  the Job Training Analysis Form.

   Proj ect Name:	
  ETV-MF Project Manager:  	
  Will the operation or activity involve the following:
       Yes   No
Initials & Date
Completed
Processing or recycling of hazardous wastes? Special permitting may be
required.
Generation or handling of waste?
Work to be conducted before 7:00 a.m., after 6:00 p.m., and/or on
weekends? Two people must always be in the work area together.
Contractors working in CTC facilities? Follow Hazard Communication
Program.
Potential discharge of wastewater pollutants?
EHS aspects/impacts and legal and other requirements identified?
Contaminants exhausted either to the environment or into buildings?
Special permitting or air pollution control devices may be necessary.
Any other hazards not identified above? (e.g., lasers, robots, syringes)
Please indicate with an attached list.
























  The undersigned responsible party certifies that all applicable concerns have been indicated in
  the "yes" column, necessary procedures will be developed, and applicable personnel will receive
  required training. As each concern is addressed, the ETV-MF Project Manager will initial and
  date the "initials & date completed" column above.
ETV-MF Project Manager:
                              (Name)
(Signature)
     (Date)
                                           A-2

-------
                                Revision 0-6/15/01
      APPENDIX B
Job Training Analysis Form

-------
                                                      Revision 0-6/15/01
               JOB TRAINING ANALYSIS FORM
ETV-MF Project Name:

Basic Job Step













Potential EHS Issues













Potential Quality
Issues













Training













ETV-MF Project Manager:

Name

                            Signature
                             Date
                             B-l

-------
                                      Revision 0-6/15/01
             APPENDIX C
ETV-MF Project Training Attendance Form

-------
                                                         Revision 0-6/15/01
             ETV-MF Project Training Attendance Form
ETV-MF Pilot Project:

Date
Training
Completed





















Employee Name
Last First





















Training Topic





















ETV-MF Project Manager:
                                 C-l

-------
                               Revision 0-6/15/01
    APPENDIX D
Test Plan Modification

-------
                                                                       Revision 0-6/15/01
                               Test Plan Modification

In the course of verification testing, it  may become necessary to modify the test plan due to
unforeseen events. The purpose of this procedure is to provide a vehicle whereby the necessary
modifications are documented and approved.

The Test Plan  Modification  Request form is the  document  to be used for recording these
changes.  The  following paragraphs provide guidance for filling out the form to  ensure  a
complete record of the changes made to the original test plan.

The person requesting the change should record the date and project name in the form's heading.
The CTC ETV-MF PM will provide the request number.

Under "Original Test Plan Requirement," reference the appropriate sections of the original test
plan, and insert the proposed modifications in the section titled "Proposed Modification." In the
"Reason" section, document why the  modification is necessary; this is where the change is
justified.   Under "Impact,"  give  the  impact of  not  making the  change,  as well  as the
consequences of making the proposed modification.  Among  other things, the  impact should
address any changes to cost estimates and project schedules.

The requestor  should then sign the form and obtain the  signature of the ETV-MF Project
Manager (Partner).  The ETV-MF Project Manager (Partner) should sign both lines if he is the
requestor. The  form should then be transmitted to the  CTC ETV-MF PM, who will either
approve the modification or request clarification.  Upon approval, the modification request will
be assigned a number, logged, and transmitted to the requestor for implementation.
                                     D-l

-------
                                                         Revision 0-6/15/01
              TEST PLAN MODIFICATION REQUEST







Date:	     Number:	    Project:	






Original Test Plan Requirement:	
Proposed Modification:
Reason:
Impact:
Approvals:






Requestor:
ETV-MF Project Manager:
CTC ETV-MF Program Manager:
                                  D-2

-------