W-P2MF-01-02
                             September 2001
  Environmental Technology
      Verification Report

      Evaluation of USFilter
          Corporation's
RETEC® Model SCP-6 Separated
   Cell Purification System for
   Chromic Acid Anodize Bath
            Solution
              Prepared by

         Concurrent Technologies Corporation


        Under a Cooperative Agreement with


        U.S. Environmental Protection Agency

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                                        NOTICE

This publication was developed under Cooperative  Agreement No.  CR826492-01-0 awarded by
the U.S.  Environmental Protection Agency.  The Agency  reviewed  this  document.   The Agency
made comments and suggestions on the document intended to improve the scientific analysis and
technical  accuracy  of  the  statements  contained in  the  document.   Concurrent  Technologies
Corporation  (CTC)  accommodated  EPA's comments  and suggestions.   However,  the  views
expressed in this document are those  of Concurrent Technologies Corporation and EPA does not
endorse any  products or commercial  services mentioned in this publication.   The document will
be  maintained by  Concurrent  Technologies Corporation in accordance with the 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.

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                                W-P2MF-01-02
                                September 2001
  Environmental Technology
       Verification Report

      Evaluation of USFilter
           Corporation's
RETEC® Model SCP-6 Separated
   Cell Purification System for
   Chromic Acid Anodize Bath
              Solution
                Prepared by
               Project Manager
                Chris Start
        Michigan Manufacturing Technology Center
              Plymouth, Ml 48170
              Program Manager
               Donn Brown
         Concurrent Technologies Corporation
               Largo, FL 33773
             EPA Center Manager
               Alva Daniels
       National Risk Management Research Laboratory
             Cincinnati, Ohio 45628

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                                      FOREWORD

The  Environmental  Technology  Verification (ETV) Program has been established  by the U.S.
Environmental  Protection  Agency  (EPA)  to   evaluate  the  performance  characteristics  of
innovative environmental  technologies  for any  media and  to  report  this objective information to
the states, local  governments, buyers,  and users  of environmental technology.   EPA's Office of
Research  and  Development  (ORD)  has  established  a  five-year  pilot  program  to  evaluate
alternative  operating  parameters  and  to   determine  the  overall  feasibility  of  a  technology
verification program.  ETV began  in October  1995 and was  evaluated through September 2000.
EPA  is  preparing  a  report  to  Congress  containing  results  of  the  pilot program  and
recommendations for its future operation.

EPA's ETV  Program, through  the National Risk Management Research  Laboratory  (NRMRL),
has partnered with CTC under the Environmental Technology Verification Program P2 Metal
Finishing Technologies Center (ETV-MF).   The  ETV-MF Center, in  association with the EPA's
Metal Finishing Strategic Goals  Program,   was   initiated  to identify   promising and innovative
metal   finishing   pollution   prevention   technologies   through  EPA-supported   performance
verifications.  The following report describes the  verification  of the performance of the USFilter
Corporation's  RETEC®  Model SCP-6  Separated Cell  Purification  System  for  chromic acid
anodize bath solution in the metal finishing industry.
                                            111

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                        ACRONYM and ABBREVIATION LIST
°C
ACGffl
Ah
CARB
CTC
DVI
dynes/cm
EFF
EPA
ETV
ETV-MF

gal
gpm
g/L
HDPE
HP
hrs/wk
ICP-AES
IDL
IN
kWh
lb.(s)
LCS
L
MDL
min
mL
mm
MMTC
MSDS
NIOSH
NRMRL
O&M
ORD
OSHA
P2
PEL
QA
QA/QC
QMP
RPD
SCP
SP
Degrees Celsius
American Conference of Government Industrial Hygienists
Amp-hours
California Air Resources Board
Concurrent Technologies Corporation
DV Industries, Inc.
Dynes per Centimeter
Effluent
U.S. Environmental Protection Agency
Environmental Technology Verification
Environmental Technology Verification Program P2 Metal
Finishing Technologies
Gallon
Gallon per Minute
Gram per Liter
High Density Polyethylene
Horsepower
Hours per Week
Inductively Coupled Plasma - Atomic Emission Spectrometry
Instrument Detection Limit
Influent
Kilowatt-hour
Pound(s)
Laboratory Control Sample
Liters
Method Detection Limit
Minute
Milliliteits)
Millimeters
Michigan Manufacturing Technology Center
Material Safety Data  Sheet
National Institute of Occupational Safety and Health
National Risk Management Research Laboratory
Operating and Maintenance
Office of Research and Development
Occupational Safety and Health Administration
Pollution Prevention
Permissible Exposure  Limit
Quality Assurance
Quality Assurance/Quality Control
Quality Management  Plan
Relative Percent Difference
Separated Cell Purification
Sample Point
                                           IV

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              ACRONYM and ABBREVIATION LIST (continued)
SR                Sample Result
S SR              Spiked Sample Result
TLV              Threshold Limit Value
TSA              Technical Systems Audit
VDC              Voltage (DC)

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                              ACKNOWLEDGEMENTS

This is  to  acknowledge Jim Totter and Valerie  Whitman of CTC for their help in preparing this
document.   CTC also acknowledges the support of all those who helped plan and implement the
verification  activities  and prepare  this report.   In particular, a special  thanks  to  Alva Daniels,
EPA  ETV  Center  Manager, and  Lauren Drees,  EPA Quality  Assurance  Manager.  CTC also
expresses   sincere  gratitude  to USFilter,  the  manufacturer of  the RETEC® Model   SCP-6
Separated  Cell  Purification  System,  for  their participation in and  support  of this  program, and
their  ongoing  commitment to  improve  metal  finishing  operations.    In  particular,  CTC  thanks
Mike Chan, Vice President of USFilter.   CTC  also thanks DV Industries, Inc.  of Lynwood,
California,  for the use  of their facilities and materials,  and the extensive  contributions of Tom
Davis and Scott Smith for the performance of this verification test.
                                             VI

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              THE ENVIRONMENTAL TECHNOLOGY VERIFICATION PROGRAM
        U.S. Environmental Protection Agency
                                                                           Concurrent Technologies Corporation
                       ETV VERIFICATION STATEMENT
TECHNOLOGY TYPE:
APPLICATION:
TECHNOLOGY NAME:

COMPANY:
POC:

ADDRESS:

E-MAIL:
                             ELECTRODIALYSIS
                             CHROMIC ACID ANODIZE BATH MAINTENANCE

                             RETEC® Model SCP-6 Separated Cell Purification System

                             USFilter Corporation
David Hill

28 Cook Street
Billerica, MA 01821
hilld(ausfilter.com
                                                      PHONE:    (978)262-2313
                                                       FAX:       (978) 667-1731
The  United States  Environmental  Protection  Agency  (EPA)  has  created  the  Environmental  Technology
Verification (ETV) Program to facilitate the deployment of innovative or improved environmental technologies
through performance verification and dissemination of information.  The goal of the ETV Program is to further
environmental  protection by  substantially  accelerating the acceptance and use of improved, cost-effective
technologies.   ETV  seeks to achieve this  goal by  providing high-quality,  peer-reviewed  data on technology
performance to  those  involved in the  design,  distribution,  financing,  permitting,  purchase,  and  use  of
environmental technologies.

ETV works in  partnership with recognized standards and testing organizations, stakeholder groups  consisting of
buyers, vendor organizations, and states, with the full participation of individual technology developers.  The
program evaluates the performance of innovative technologies by developing test plans that are responsive to the
needs of stakeholders, conducting field or  laboratory tests (as appropriate),  collecting and  analyzing data, and
preparing peer-reviewed reports.  All evaluations are conducted in accordance with rigorous quality assurance
protocols to ensure that data of known and adequate quality are generated and that the results are defensible.

The ETV P2 Metal Finishing Technologies (ETV-MF) Program, one of 12 technology focus areas under the ETV
Program, is operated  by Concurrent  Technologies Corporation, in  cooperation  with EPA's National Risk
Management Research Laboratory.  The ETV-MF Program has evaluated the performance  of an electrodialysis
technology  for  the purification of chromic  acid anodize bath solution.  This verification statement provides a
summary of the test results for the USFilter RETEC® Model SCP-6 Separated  Cell Purification System.
VS-P2MF-01-02

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VERIFICATION TEST DESCRIPTION

The USFilter RETEC® Model SCP-6 (RETEC® unit) was tested, under actual production conditions, on a chromic
acid  anodize bath solution, at DV  Industries,  Inc. (DVI) in Lynwood, California.  Chromic acid anodizing is
performed on various aluminum parts in one of two independent parts processing tanks: a 27-foot or a 62-foot
tank.  The verification test evaluated the ability  of the RETEC® unit to purify the chromic acid anodize bath
solution of process contaminants in the 27-foot chromic anodizing tank.

Testing was conducted during two distinct 5-week test periods (Baseline and Operational Modes):
•  During the first test period (Baseline Mode), the RETEC® unit was turned off, and the chromic acid anodizing
   bath was monitored to determine the buildup rate of process contaminants. Aluminum parts were anodized at
   typical processing rates for DVI.
•  During the second test period (Operational Mode), the  RETEC® unit was turned on, and the chromic acid
   anodizing bath was monitored to determine the rate of process contaminant removal.  Again, aluminum parts
   were anodized at typical processing rates for DVI.

Historical operating and maintenance  labor requirements,  chemical  usage,  and waste generation data were
collected to perform the cost analysis.

TECHNOLOGY DESCRIPTION

The  RETEC®  Model SCP-6 Separated Cell Purification  System purifies and reconditions spent chromic acid
anodizing solution by circulating it through a specialized electrochemical cell.  Anodizing solution is recirculated
between  the anolyte section of the  RETEC® cell  and  the anodizing process tank.  During this process, trivalent
chromium in the anodizing solution  is oxidized to hexavalent chromium, and  metal cations are transported to the
catholyte solution through a porous, polymeric  membrane separating the anolyte and catholyte compartments of
the cell.  The treated process solution is then returned  to the anodizing bath.  The metal  contaminants removed
from the  process solution are kept in solution in the catholyte side of the cell until the solution becomes saturated
with contaminants.  At DVI, the RETEC® saturated catholyte waste (100 gallons) is disposed of about four times
a year.

VERIFICATION OF PERFORMANCE

In the Baseline Mode, six  weekly grab samples were collected over a five-week period from the anodizing tank
and analyzed to determine the buildup rate of process contaminants. In addition, weekly grab samples from the
rinse  tanks upstream and  downstream  of the  anodizing tank were collected and analyzed for mass balance
purposes  related to the anodizing tank.  Rinse tank analyses showed dragout to be insignificant.

In the Operational Mode, five weekly grab samples were collected over a six-week period from the anolyte and
catholyte sections of the RETEC® unit.  All samples were analyzed for process contaminants in order to perform a
mass balance and determine the removal efficiencies of  process contaminants from the anodized bath solution.

Eleven weeks after the RETEC® unit was turned on (16 weeks after test  started), samples were again collected
from  the RETEC® unit.   These samples  are designated  as  "1Q" in  Table  J  and represent the chemical
characteristics of the anolyte and catholyte at the end of the first quarter of the catholyte operating cycle, 11 weeks
after the RETEC® system was turned on.

Average  analytical results for key parameters are shown in Table i. Hexavalent chromium is the primary active
ion in the chromic anodizing process.   Trivalent chromium is the natural  occurring reduced state of hexavalent
chromium.  The reduction from hexavalent chromium to trivalent chromium occurs  in the anodizing bath over a
period of time, and can be accelerated by temperature  and  pH changes,  and chemical and electrochemical
reactions.   Aluminum  and magnesium are the primary anodizing bath contaminants.   A small amount of
aluminum (0.39 g/L) is required  for the aluminum anodizing process to occur.  After six  weeks of RETEC®

VS-P2MF-01-02                                        viii

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operation, the purified chromic acid anodized  solution maintained a relatively steady chemical and contaminant
composition similar to the  anodizing solution  at the time  of RETEC® start-up.   The buildup of process
contaminants  in  the  anodizing solution  was slowed, while the contaminant level in the catholyte increased
dramatically, showing a contamination transfer across the polymeric membrane.
Sampling Week
0 - Baseline
1 - Baseline
2 - Baseline
3 - Baseline
4 - Baseline
5 - Baseline
6 - Operational
7 - Operational
8 - Operational
9 - Operational
10- Operational
11- Operational
16- 1Q
Hexavalent
Chromium
(by titration)
g/L
Anolyte /
Catholyte
48.0/NA
48.0/NA
48.1/NA
47.5/NA
50.5/NA
51.5/20.6
52.6/21.3
52.9/22.5
53.5/36.1
53.8/41.5
Trivalent
Chromium
(by titration)
g/L
Anolyte /
Catholyte
<1.1/NA
<1.1/NA
<1.1/NA
<1.1/NA
<1.1/NA
<1. 1/<1.1
<1. 1/<1.1
<1. 1/<1.1
<1. 1/<1.1
<1.1/1.7
Total
Chromium
(by ICP-AES)
g/L
Anolyte /
Catholyte
49.0/NA
46.0/NA
42.0/NA
43.0/NA
50.0/NA
46.0/18.0
44.0/20.0
44.0/21.0
48.0/34.0
46.0/42.0
Total
Aluminum
(by ICP-AES)
g/L
Anolyte /
Catholyte
3.6/NA
3.7/NA
3.8/NA
4.0/NA
4.5/NA
4.5/0.1
4.1/2.0
4.1/3.2
4.6/3.8
4.4/5.4
Total
Magnesium
(by ICP-AES)
g/L
Anolyte /
Catholyte
0.27/NA
0.31/NA
0.25/NA
0.26/NA
0.32/NA
0.32/0.09
0.29/0.12
0.22/0.15
0.24/0.20
0.21/0.25
Thanksgiving holiday - no samples collected this week
52.7/51.6
NA
<1. 1/<1.1
NA
50.0/48.0
52.5/50.5
4.9/6.4
5.4/7.5
0.24/0.28
0.26/0.31
Titration =  Standard  sodium thiosulfate  titration, 1999  Metal  Finishing Guidebook, Vol.  97,  No. 1,  Control,
    Analysis, and Testing Section - Chemical Analysis of Plating Solutions,  Charles Rosenstein and Stanley
    Hirsch, Table VIII - Test Methods for Electroplating Solutions, page 538.
ICP-AES = Inductively Coupled Plasma-Atomic Emission Spectrometry (EPA SW-846 Method 601 OB)
NA = Not Applicable

                                 Table i. Summary of Key Analytical Data

Oxidation  of Trivalent Chromium to Hexavalent Chromium.  The oxidation of trivalent chromium to
hexavalent  chromium in the anolyte and the transfer of hexavalent chromium  across the polymeric membrane
from the catholyte to the anolyte by the RETEC® unit is marketed as one of the beneficial conversions performed
by the electrochemical process. However, as can be seen in Table  i, trivalent chromium levels were never above
background levels in the anolyte; therefore, there was no quantifiable oxidation to hexavalent chromium.  A slight
increase in hexavalent chromium levels in the anolyte was observed, but  since DVI adds  chromic acid to the
anodizing bath on a regular basis,  this increase  in hexavalent chromium concentration  can not be definitively
attributed to the RETEC® electrolytic reaction. Hexavalent chromium levels measured by titration that are higher
than total chromium levels measured by ICP-AES are due to uncertainties inherent in the precision of these two
different analytical methods.

Contaminant Removal.  Removal of the  primary  contaminants  of the  chromic  acid  anodize  bath  solution,
aluminum and magnesium, are shown in Table ii. For the Baseline Mode,  the average aluminum increase in the
anolyte  was 0.180 g/L per week.   The average magnesium increase in the anolyte was 0.010 g/L per week.
During the  Operational Mode, aluminum and magnesium levels  in  the anolyte remained relatively  stable, while
the catholyte showed an overall increase  of 6.32  g/1 of aluminum.  The total volume of catholyte solution at the
end of the  verification test was 392 gallons (150 gallons in the  clarifier + 30  gallons in the RETEC® cell and
piping +  212  total gallons  of  catholyte overflow collected  during  the test).   Multiplying  the  aluminum
contamination increase in the catholyte by the total catholyte volume gives an overall removal of 9,378 grams of
aluminum from the  anolyte solution over the six week test period (6.32 g/1 x 392 gallons x 3.7854 liters/gallon =
VS-P2MF-01-02
                                                    IX

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9,378 grams).  The  increase in magnesium contamination of the catholyte was less pronounced, showing an
overall increase of 0.19 g/1.  Multiplying the magnesium contamination increase in the catholyte by the total
catholyte volume gives an overall removal of 282 grams  of magnesium from the anolyte solution over the six
week test period (0.19 g/1 x 392 gallons x 3.7854 liters/gallon = 282 grams). The RETEC® unit proved to be an
adequate technology for  removing  aluminum contamination from the chromic  acid anodize solution at DVI;
however, the unit was not able to completely arrest the contamination rise in the anodizing bath.  Since the six-
cell model installed at DVI is the smallest RETEC® unit  made by USFilter, it is possible that a larger unit  may
solve this problem. However, since the RETEC® unit was turned on when the anodizing bath was within 1.6 g/L
of its upper limit for aluminum, the purification system was unable to prevent the anodizing  bath from reaching
the upper contamination limit triggering disposal of the anodizing bath.   It can be concluded that the RETEC®
system extended the anodizing bath life by slowing the contamination build-up rate, but due to the relatively short
verification test period, the length of this extension could not be determined.
Anolyte
Aluminum
Magnesium
Baseline Mode
Operational Mode
Baseline Mode
Operational Mode
Catholyte
Aluminum
Magnesium
Operational Mode
Operational Mode
Start
(g/L)
3.6
4.5
0.27
0.32
End
(g/L)
4.5
4.9
0.32
0.24
Change
(g/L)
+0.9
+0.4
+0.05
-0.08
Average Weekly Increase
(g/L)
+0.180
+0.067
+0.010
-0.0133

0.085
0.087
6.40
0.28
+6.32
+0.19
+1.053
+0.0317
                                      Table ii.  Contaminant Removal

Energy Use. Energy requirements for operating the RETEC® unit at DVI include electricity for the anolyte and
catholyte pumps  and the system rectifier.   Electricity use was determined to be 6,366 kWh/day, based on
continuous operation of the system.

Waste Generation.  A waste generation analysis was performed using operational data collected during the
verification test period, and historical records from DVI.  Waste generation data normalized  to the amount of
work processed over the verification test period showed an anodizing bath waste generation reduction of about 54
percent when the RETEC® system was in use.  Implementation of the RETEC® Model SCP-6 extended the life of
the anodizing bath, thus generating less chromic acid waste.  However, some of this waste reduction is offset by
chromic acid waste generated by the RETEC® system.  The net reduction of concentrated waste generated from
the chromic acid anodizing process when the purification system was in use is thus reduced to 46 percent.

Hexavalent Chromium Air  Emissions.  Air emissions from the DVI anodizing bath/RETEC unit were tested for
hexavalent chromium.  The aim of this testing was  to check  to  see if the RETEC  unit contributed  to the
concentration of airborne hexavalent  chromium in the  DVI facility.  Air  monitoring was conducted in both the
Baseline and Operational phases of the verification test. The  RETEC system exhibited a slight increase in the
overall hexavalent chromium air emissions to the DVI facility.  Air monitoring  results indicated an average
process hexavalent chromium emission increase of 0.124 |jg/m3.  Personal monitoring during the verification test
was performed; however, the samples became contaminated with hexavalent chromium from routine paint filter
change-out maintenance  operations,  so the results had to be  discarded.   Process  emission readings during the
operational phase of the RETEC®  verification test were well  within all  applicable regulatory  and suggested
exposure limits.

Operating and Maintenance Labor. Operating  and  maintenance  (O&M) labor requirements for the RETEC®
Model SCP-6 were monitored during testing. The O&M labor requirements for the equipment were observed to
be 2.8 hrs/wk.  Accounting for savings in reduced labor associated  with  anodizing bath chemical additions, the
RETEC® system O&M  labor  averages  about 135 labor hours per year.  O&M tasks performed  during the
                                                     x
VS-P2MF-01-02

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verification test included daily inspections of the unit, recording of system parameters, and additions of chromic
acid flakes to the clarifier to maintain the catholyte pH below 2.

Cost Analysis. A cost analysis of the RETEC® Model SCP-6 was performed using current operating costs and
historical records from DVI.  The installed capital cost (1993) of the unit was $35,230 (includes $33,630 for the
system  and  $1,600 for installation costs).   The annual cost savings associated with the unit is $8,288.    The
projected payback period is 4.2 years.

SUMMARY

The test results show that the RETEC® Model SCP-6 does provide an environmental benefit by extending the bath
life of the chromic acid anodize solution, thereby reducing the amount of liquid wastes produced by the anodizing
operation  without removing the required anodizing  constituents of the  bath.   The economic benefit associated
with this  technology is  primarily  in  reduced waste disposal  costs associated with the  life extension of the
anodizing bath. Process emission increases of hexavalent chromium during the operation of the RETEC® unit are
negligible. As with any technology selection, the end user must select appropriate bath maintenance  equipment
and chemistry for a process that can meet their associated environmental restrictions, productivity, and  anodizing
requirements.
   Original signed by:
   E. Timothy Oppelt
Original  signed by:
Donn Brown
E. Timothy Oppelt
Director
National Risk Management Research Laboratory
Office of Research and Development
U.S. Environmental Protection Agency
Donn W. Brown
Manager
P2 Metal Finishing Technologies Program
Concurrent Technologies Corporation
    NOTICE:  EPA verifications  are  based  on  evaluations  of  technology performance under  specific,
    predetermined criteria and appropriate quality assurance procedures.  EPA and CTC make no expressed or
    implied warranties as to the performance of the technology and do not certify that a technology will always
    operate as verified.  The end user is solely responsible for complying with any and all applicable federal,
    state, and local requirements. Mention of commercial product names does not imply endorsement.
VS-P2MF-01-02
                                                     XI

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                               TABLE OF CONTENTS
1.0   INTRODUCTION	1
2.0   DESCRIPTION OF CHROMIC ACID ANODIZE BATH SOLUTION
      PURIFICATION SYSTEM	1
      2.1    Anodize Bath Purification Equipment	1
      2.2    Test Site Installation	3
      2.3    Operating Flow	4
3.0   METHODS AND PROCEDURES	6
      3.1    Test Objectives	6
      3.2    Test Procedure	8
             3.2.1  System Set-Up	8
             3.2.2  Testing	8
      3.3    Quality Assurance/Quality Control	8
             3.3.1  Data Entry	8
             3.3.2  Sample Collection and Handling	9
             3.3.3  Calculation of Data Quality Indicators	9
                   3.3.3.1   Precision	9
                   3.3.3.2   Accuracy	10
                   3.3.3.3   Completeness	10
                   3.3.3.4   Comparability	10
                   3.3.3.5   Representativeness	11
                   3.3.3.6   Sensitivity	11
4.0   VERIFICATION DATA	12
      4.1    Analytical Results	12
      4.2    Process Measurements	13
      4.3    Production Data	15
      4.4    Other Data	16
      4.5    Hexavalent Chromium Air Monitoring	16
5.0   EVALUATION OF RESULTS	16
      5.1    Oxidation of Trivalent Chromium to Hexavalent Chromium	16
                                         xu

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      5.2    Contaminant Removal	17
      5.3    Mass Balance	18
      5.4    Hexavalent Chromium Air Monitoring Results	19
      5.5    Energy Use	20
      5.6    Operating and Maintenance Labor Analysis	21
      5.7    Chemical Use Analysis	22
      5.8    Waste Generation Analysis	23
      5.9    Cost Analysis	24
      5.10   Project Responsibilities/Audits	25
6.0   REFERENCES	26
                                 LIST OF FIGURES
Figure 1. RETEC® Chromic Acid Anodize Bath Solution Purification at DVI, Inc ..................... 2
Figure 2. RETEC® SCP- 6 System [[[ 3
Figure 3. RETEC Chromium Purification Cell Reactions [[[ 5
                                 LIST OF TABLES

Table 1.  Test Objectives and Related Test Measurements Conducted During the	7
         Verification of the USFilter RETEC® Model SCP-6	7
Table 2.  Laboratory Methodology Information	12
Table 3.  Summary of Analytical Results (RETEC® & Bath)	13
Table 4.  Summary of Process Measurements	14
Table 5.  DVI Production (Ah required for anodizing)	15
Table 6.  Other Data Collected During Verification	16
Table 7.  Contaminant Removal	17
Table 8.  Summary of Analytical Results (Rinse & Flake)	19
Table 9.  Air Monitoring Results - Baseline Phase	20

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Table 12. Results of Waste Generation Analysis	23
Table 13. Annual Costs/Savings	25
                              LIST OF APPENDICES

APPENDIX A:      Precision Calculations	A-l
APPENDIX B:      Accuracy Calculations	B-l
APPENDIX C:      Representativeness Calculations	C-1
                                        xiv

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1.0    INTRODUCTION

       The RETEC® Model SCP-6 (RETEC® unit) is an electrochemical  purification  system for
       recycling  spent  chromic  acid  anodized   bath  solution.     Chromic  acid  anodizing  is
       performed on various aluminum parts in one of two independent parts processing lines:  a
       27-foot or a 62-foot tank.  The verification test evaluated the ability  of the RETEC  unit
       to purify  the chromic acid  anodize  bath  solution  of process contaminants in the 27 foot
       chromic anodizing tank.   It was tested by CTC under the  U.S.  Environmental Protection
       Agency (EPA) Environmental  Technology Verification Program  for  P2  Metal Finishing
       Technologies (ETV-MF).   The purpose  of this report  is  to  present the results  of the
       verification test.

       The  RETEC®  unit  was  tested  to  evaluate  and  characterize  the  operation  of the
       electrochemical  purification  system through measurement of various process parameters.
       Testing was conducted  at  DV Industries, Inc.  (DVI)  in Lynwood,  California.   DVT
       anodizes  a  wide  range of  aluminum  parts for the aerospace,  military,  and commercial
       industries.

2.0    DESCRIPTION OF CHROMIC  ACID ANODIZE BATH SOLUTION
       PURIFICATION SYSTEM

       2.1    Anodize Bath Purification Equipment

       A diagram  of the RETEC® unit  is shown in  Figure 1.   The  RETEC® Model  SCP-6
       consists of  a rectifier,  a clarifier to  remove  metal  hydroxides  that  are  formed  in the
       catholyte  as  acids are purified and recovered, and an electrolytic  cell.  The electrolyzer
       box  is fabricated  of  polyvinyl chloride  and  is  supplied  with inlet,  outlet,   and drain
       connections  and valves.   The cell  consists  of a  series  of anodes  and  cathodes.   The
       individual  lead anodes  are contained  within separate anode chambers.  The front and back
       sides   of  the  anode chambers have  diaphragms of  Elramix™,  a porous,   polymeric
       membrane, separating the anolyte  and catholyte compartments.   Elramix™, manufactured
       by ELTECH International  Corporation, was selected as  the separator of choice after an
       extended evaluation  of a wide  variety  of commercial materials having  properties required
       for use as cell separators.   Titanium mesh cathodes,  which are  easily  removed from the
       cell, are placed between each anode chamber.   The anodes and cathodes are  connected to
       copper bus bars  located on opposite sides of the cell box.  The electrolyzer can operate
       with a full complement of anode  chambers or  any fewer numbers  depending on capacity
       requirements.  The  cell is equipped with an  air  sparging  system  to prevent  metals and
       metal   hydroxides  formed  in the catholyte from  settling  in the  cell.  However,  it was
       determined by DVT  that the formation of solids could be  controlled by maintaining the
       pH of the catholyte <2 with  additions of chromic acid, and  therefore, the air sparging
       system was not used at DVT.

       A thermo-sensor  is included   with  the   electrolyzer  to  shut  off  the  rectifier  if the
       temperature  of the  liquid  being treated  exceeds  the  pre-set limit.  A thermo-controller
       resets  the system.   The RETEC®  electrolyzer  is  also supplied  with a manifold located

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beneath the  electrolyzer box that hydraulically connects each anode  compartment to the
anolyte  reservoir.  The anolyte  feed  manifold  is  located beneath the cathode bus bar.
Solution from the  anodizing tank is pumped into  the  anode  frames  through  the anolyte
feed manifold.  The  anodizing solution is returned  by gravity  to  the  anodizing tank  from
the anolyte reservoir.
    RETEC® SEPARATED CELL PURIFICATION (SCP) SYSTEM
          Chromic Acid Anodize Bath Solution Purification at DVI, Inc.
             Clarifier Overflow
D = Anolyte  D = Catholyte   D = Waste Products
                                                  = Pump   XI = Valve
     Figure 1. RETEC® Chromic Acid Anodize Bath Solution Purification
                                at DVI, Inc.

The RETEC®  electrolyzer sits on a steel chassis, which mounts onto a stand to  provide
the proper  height when installed  at the anodizing  line.   The stand contains  shelves for
mounting the liquid feed  pumps.   Figure 2  shows a picture of a six-compartment acid
purification  cell (RETEC®  SCP-6), clarifier and rectifier  similar  to  the  one verified at
DVI.

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                      Figure 2. RETEC® SCP-6 System

Utility requirements for the RETEC® Model SCP-6 at DVI include:

•   Electricity - Rectifier: 460 VAC, 60 Hz, three-phase SCR
•   Electricity - Anolyte Pump: 115 VAC, 50/60 Hz, 1/25 HP, 5 gpm
•   Electricity - Catholyte Pump:  115 VAC, 50/60 Hz, 1/16 HP, 10 gpm

2.2    Test Site Installation

The metal finisher selected for  testing  is  DVI in  Lynwood,  California.  Established  in
1957,  the  135,000   square  foot  facility  has  one of  the   nation's  largest  anodizing
departments.   They  serve a variety  of customers, with a  large  majority of  the  work
dedicated to the aerospace, military,  and commercial industries.

The Lynwood  plant  utilizes   a  USFilter  RETEC®  Model   SCP-6  Separated   Cell
Purification  System installed on  the  27-foot, 10,000 gallon  chromic acid anodizing  (type
I)  line.   The Model  SCP-6  has  been  operating  successfully  in  purification  mode  since
1995.  Anodizing  bath solution  is purified  of  tramp metals  and trivalent  chromium, and
the catholyte,  which is also anodizing bath  solution, is circulated through the  RETEC®
system, resulting in the recovery of hexavalent  chromium  for reuse in  the  anodizing bath.
DVI has  not  experienced any degradation  in plating quality since the installation of the
RETEC®  unit.   The  DVT anodizing line  uses a manually operated rack  system.  Materials
anodized  on the line consist of various grades of aluminum, primarily  7075, 2024, 2219,
6061,  and  7050.    Parts  first  go through  an alkaline  clean,  a  caustic etch,  then a
deoxidizing  tank.  Subsequently, they go to  the anodizing step,  and finally the parts are
sealed.   Each  process  step is  followed  by  a  single-stage  flowing  rinse.    Since  the
anodizing  bath operates  at an elevated temperature, there is  some  evaporation from the

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tank.  On occasion, DVI will add water and/or chromic acid flakes to the bath to maintain
the proper anodizing bath chemical parameters.

The  solution from the  anodizing bath  was re-circulated through the  anolyte compartment
of the cell at a rate of about 1.5 gpm.  The cell applies approximately 200A @ 3 VDC for
the electrolytic  reaction  to take  place.   Trivalent chrome  is  oxidized to  hexavalent
chrome, and at the same  time, tramp metals  are rejected through the Elramix™ separator
into  the  catholyte compartment.    Anodizing  solution also acts as  the  catholyte and  is
pumped  continuously  through the  catholyte  compartment at  a  rate  of  about 4  gpm.
Hexavalent  chrome  in  the  catholyte   passes  through  the  Elramix™   into the  anolyte
compartment - this gives  a substantial recovery of the hex chrome from the catholyte at
the same time.

The  chromic acid used at this facility  is created by mixing tap water with chromic acid-
flake, which is sold by Van Waters & Rogers, Inc., a company located in Los Angeles,
California.   The Material  Safety  Data Sheet (MSDS) for this product can be found  in the
test plan [Ref. 2]. The concentration of chromic acid is controlled  based on free and total
chrome  concentration, which is determined twice  a week by a  sodium thiosulfate titration
method  performed by the DVT  process chemists.   When  measurements indicate that the
chromium   concentration   is  approaching  the   lower  recommended   operating   level,
additional chromic acid flakes are added to the anodizing bath.

Fumetrol 140 Mist Suppressant is also added to the bath  to act as a wetting agent to lower
the surface tension of the  bath.   Keeping  the  surface tension of the anodizing bath in the
prescribed operating  limits  keeps the hexavalent chromium air  emissions to  a minimum.
The Fumetrol 140 Mist Suppressant is also sold to DVT by Van  Waters & Rogers, Inc., of
Los Angeles, California.  The MSDS for this  product  can  be  found in the  test  plan [Ref.
2].   The concentration  of Fumetrol  140 Mist Suppressant is controlled  based on surface
tension,  which  is determined twice  a week by  stalagmometer  measurements performed by
the DVI  process chemists.  When measurements indicate  that  the surface  tension  is
approaching  the  upper  recommended operating   limit,  additional  Fumetrol  140  Mist
Suppressant is added to the anodizing bath.

When  the  catholyte  reaches the  aluminum  saturation  limit  (approximately every  three
months),  two-thirds  (100  gallons)   of the  clarifier is  drained  off and sent  for waste
disposal.  The catholyte is then recharged with a fresh mixture of chromic acid.

2.3    Operating Flow

Anodizing  solution  is recirculated between the anolyte section  of  the RETEC®  cell and
the anodizing tank.   During this  process, trivalent  chromium in the solution is oxidized to
hexavalent  chromium,  and  metal   cations  in  solution  are transported   through  the cell
separator to  the  catholyte  section of the cell.  The rate of trivalent  chromium oxidation
and  the  transfer rate  of metal   cations are  related to the  operating  conditions.    The
oxidation  rate of trivalent chromium will vary with cell  current,  and will be  greater  at
high current  and  high trivalent chromium concentration.  The  anolyte to catholyte transfer

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rate  of metal  cations will depend on the species of  cation present in  solution,  cation
concentration, and  the pH of the catholyte.  Process operating conditions will  vary and
will depend upon the type and degree of contamination of the anodizing bath.

Catholyte solution is circulated between the catholyte section  of the RETEC® cell and the
clarifier.   The  catholyte pH is controlled by the  addition of anodizing solution or straight
chromic  acid  to  the clarifier.    Hexavalent  chromium in  the   catholyte is transferred
through the cell separator  to the anolyte side  of the cell and then to the anodizing tank.
Metal  impurities in the  chemicals added to the clarifier tank for pH  control,  and  those
impurities  that  are  transferred  from  the  anolyte  through  the   cell  separator  into the
calholyte, all accumulate in the catholyte solution.

Disposal  of the   catholyte saturated  with tramp metal  impurities is  required   when
adjusting the catholyte operating conditions by  pH addition  is no longer possible.   The
tramp  metal  cations precipitate  out  as  their  respective  hydroxides,  which  are  then
separated  from  solution in the clarifier.   This  catholyte saturation timeframe  varies based
on  process chemistry,  RETEC®  operating parameters,  contamination build-up  rate, and
workload, but historically occurs about once every three months.

The  diagram in Figure 3 illustrates the reactions that typically take place in the  RETEC®
cell.    While this  simplified diagram  shows only one anode  chamber,  the Model SCP-6
used at DVI contains six anode chambers.
                 RETEC CHROME PURIFICATION (CP) SYSTEM
                          Chromium Purification Cell Reactions
                                                  ELRAMIX™ Cell Separator
               <+)     Anode




*s
^
^
Cr+3 	 ^ CrO4-2
1 — |



*
M+n 	 ^ M(OH)n

Cr+3 	 ^ Cr(OH)3
X*



                                                                     Cathode
                     Anolyte
                     Chamber
Catholyte
Chamber
           Figure 3. RETEC® Chromium Purification Cell Reactions

At DVI, the RETEC®  cell is cleaned on a quarterly basis.  This time  period was selected
out of  convenience and  does not  necessarily  reflect  the required  frequency of  cleaning.

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       The  RETECR  unit operating manual  suggests that users  monitor  the  physical condition
       and contamination  buildup on the cathodes to determine when the unit requires cleaning.
       When a high level  of contamination buildup on the cathodes is evident, the unit requires
       cleaning.   The  contamination rate varies  from site to site,  depending on factors such as
       process  load and   contaminant  characteristics.    The  cleaning  schedule  is  determined
       through  operating  experience.   The  unit was  not  cleaned during the  six weeks of
       RETEC®operation.    Cleaning the RETEC®  cell  produces  about  30 gallons of chromic
       acid waste.

3.0    METHODS AND PROCEDURES

       3.1    Test Objectives

       The  following  is  a summary  of project  objectives.    Under  normal system operating
       conditions for the installation at DVI:

       •  Prepare a material balance for certain anodizing bath constituents and  contaminants in
          order to:
          1)   Evaluate  the ability of the RETEC® unit to oxidize trivalent chromium formed
               in the bath during the anodizing process.
          2)   Evaluate  the ability of the RETEC® unit to  remove aluminum and other tramp
               metals from the process bath that build up during the anodizing process.
          3)   Evaluate  the  ability of the RETEC® unit  to recover chromic acid from the
               catholyte  solution.

       •  Determine  the  cost  of operating the chromic  acid anodize bath solution  purification
          system for the specific conditions encountered during testing by:
          1)   Determining labor requirements needed to operate  and  maintain  the RETEC®
               unit.
          2)   Determining the quantity  of energy  consumed  by the  RETEC® unit during
               operation.
          3)   Determining other costs associated with operation of the RETEC® unit.

       •  Quantify the environmental  benefit by performing an  analysis of waste  generation,
          which  compares  the quantity  of waste generated  before  and  after the  installation of
          the RETEC® unit. Data collected to satisfy the test objectives are shown in Table 1.

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Test Mode
Baseline:
(RETEC®
Off)
Operational:
(RETEC®
On)
Test Objectives
Determine the build-up rate of contamination in the
chromic acid anodize bath solution.
Monitor and record anodizing process operational
parameters.
Evaluate the ability of the RETEC " unit to oxidize trivalent
chromium formed in the bath during the anodizing process.
Evaluate the ability of the RETEC " unit to remove
aluminum and other tramp metals from the process bath
that build up during the anodizing process.
Evaluate the ability of the RETEC " unit to recover chromic
acid from the catholy te solution.
Monitor and record anodizing process and RETEC " system
operational parameters.
Determine labor requirements needed to operate and
maintain the RETEC® unit.
Determine the quantity of energy consumed by the
RETEC® unit during operation.
Determine the cost of operating the chromic acid anodize
bath purification system for the conditions encountered
during testing
Quantify /identify the environmental benefit.
Test Measurements
Chemical characteristics of chromic acid anodize bath solution.
Chemical characteristics of upstream and downstream rinse tank water.
Volume and physical characteristics of chromic acid anodize bath solution.
Volume and physical characteristics of anodizing process rinse tank water.
Quantity and price of chemical/water additions to the anodizing bath.
Production throughput for anodizing bath.
Worker exposure to hazardous air emissions.
Volume of anodizing solution and flow rate through RETEC " unit.
Chemical characteristics of chromic acid anodize bath solution (anolyte).
Volume of anodizing solution and flow rate through RETEC " unit.
Chemical characteristics of chromic acid anodize bath solution (anolyte).
Volume, flowrate and chemical characteristics of catholyte solution.
Volume and chemical characteristics of the waste products.
Volume of anodizing solution and flow rate through RETEC " unit.
Chemical characteristics of chromic acid anodize bath solution (anolyte).
Volume, flow rate and chemical characteristics of catholyte solution.
Volume and chemical characteristics of the waste products.
Volume and physical characteristics of anodizing solution (anolyte).
Volume and physical characteristics of chromic acid catholyte solution.
Volume and physical characteristics of anodizing process rinse tank water.
Quantity and price of chemical/water additions to the anodizing bath.
Quantity and price of chemical/water additions to the RETEC® system.
Production throughput for anodizing bath.
Worker exposure to hazardous air emissions.
O&M labor required during test period.
Quantity of energy used by liquid transfer pumps (anolyte and catholyte).
Quantity of energy used by RETEC® electrochemical cell (rectifier).
Costs of O&M labor, materials, and energy required during test period.
Quantity and price of make-up and process control chemicals/water added during
testing.
Review historical waste disposal records and compare to current practices.
Table 1. Test Objectives and Related Test Measurements Conducted During the
             Verification of the USFilter RETEC® Model SCP-6

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3.2    Test Procedure

       3.2.1  System Set-Up

       Prior to testing,  the  RETEC® cell  was turned off, drained and cleaned, and the
       clarifier was  emptied according to the manufacturer's instructions [Ref.  1].  Five
       weeks  of  anodizing  and  sampling were completed with the RETEC® unit turned
       off.  At the end  of the five-week "Baseline" period, the RETEC® cell and clarifier
       were filled with  freshly mixed chromic acid  solution to act as the  catholyte, and
       the RETEC®  unit was started.  Weekly  sampling continued, once the unit was
       operating,  for another six weeks with an anolyte flow rate of about 2.0 gpm.  This
       flow rate is in the middle of the target operating range used by DVT.

       3.2.2  Testing

       The  RETEC®  unit was tested in  accordance with the verification test plan [Ref  2.
       Testing was conducted during two distinct test periods:

       During the first  test  period  (Baseline  Mode),  the unit was  turned off and weekly
       sampling  occurred under normal production  conditions at DVI.    Contamination
       build-up data and process operating  measurements  were  gathered during this five-
       week period.

       During the second test period (Operational Mode), the  RETEC® unit was turned
       on and operated  under  normal production conditions.  Weekly samples were taken
       to determine  contaminant removal rate from the anodizing  bath  and the recovery
       rate of hexavalent chromium from the process.

       As  indicated  in  section 2.2, when the catholyte reaches the aluminum saturation
       limit (approximately  every  90 days),  two-thirds (100  gallons) of the  clarifier  is
       drained off and  sent for waste  disposal.   The catholyte is  then  recharged with  a
       fresh mixture of chromic acid.   The  Operational Mode commenced with a fresh
       mixture of chromic  acid catholyte.    Therefore,  during  this  project, Operational
       Mode  testing was conducted during the  1st  quarter of the semi-annual operating
       cycle.  Clarifier  samples are scheduled to be  collected in the  final  quarter of the
       operating  cycle  as well, and  an revision  of the  Verification Report  stating the
       volume and composition of this RETEC  waste  stream  will be  issued when this
       catholyte lifespan data is obtained.

3.3    Quality Assurance/Quality Control

       3.3.1  Data Entry

       Sampling  events, process measurements, and  all  other data were recorded by the
       ETV-MF  Project Manager  or his  representative on pre-designed forms provided
       in the verification test plan [Ref 2].

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3.3.2  Sample Collection and Handling

Prior to  the verification  test,  sampling  ports  were installed on  the anolyte  and
catholyte lines of the RETEC®  unit.   Polyethylene tubes were connected to these
two  sampling ports and  directed into  500-ml High Density Polyethylene (HDPE)
aqueous  sample containers.   500 ml  grab samples were taken with  a 1000  ml
polypropylene sampling  beaker from  the  anodizing  bath,  rinse tanks  and waste
drums.   During  sampling, the sample  collection  containers were  kept cool  by
placing them in a cooler containing ice.

All aqueous samples were collected  in  the  HDPE  containers at  weekly intervals
over  an  eleven-week  period.   At the end  of each weekly sampling  event, the
HDPE containers  were  labeled and  stored  in a cooler containing ice, awaiting
shipment to the analytical laboratories.

A sample of the chromic  acid-flake (MSDS # OZ4824) supplied by Van Waters
& Rogers,  Inc.  of  Los  Angeles, California,  was  collected  from  its  original
shipping  container.   These samples were labeled and stored prior to shipment h a
cooler containing ice.

Samples  shipped to the  analytical  laboratories were packed in coolers containing
"blue ice."  A laboratory  courier  picked up and delivered  the samples within  six
hours of sampling.   All shipments were  secured with  strapping tape and security
seals and accompanied by chain of custody forms.

3.3.3  Calculation of Data Quality Indicators

Data  reduction,  validation,   and  reporting were  conducted  according   to  the
verification test plan [Ref 2] and the ETV-MF  Quality Management Plan (QMP)
[Ref 3].  Calculations of data quality indicators are discussed in this section.

       3.3.3.1   Precision

       Precision  is  a measure  of the agreement  or  repeatability of a  set  of
       replicate  results obtained from  duplicate  analyses  made  in the laboratory
       under  identical  conditions.    To   satisfy  the  precision  objectives,  the
       replicate  analyses  must  agree within  defined percent  deviation   limits,
       expressed as a percentage, Relative  Percent Difference (RPD), calculated
       as follows:
       RPD = {(|Xi - X2|)/(Xi + X2)/2} x 100% =
                                                  |X,-X2|
                                                     2
                                          _+X2)

where,
         Xi = larger of the two observed values
         X? = smaller of the two observed values
                                                     xlOO%

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The  analytical  laboratories  performed a  total of 75  precision  evaluations
on aqueous samples.   All  of the results were  within  the  precision limits
identified in the verification test plan [Ref 2].  The results of the  precision
calculations are summarized in Appendix A

3.3.3.2   Accuracy

Accuracy   is  a  measure  of the  agreement   between  an  experimental
determination  and  the  true value  of  the parameter being  measured.
Analyses  with  spiked  samples  were   performed  to  determine  percent
recoveries  as  a means  of checking  method  accuracy.    The  percent
recovery, expressed as a percentage, is calculated as follows:

      (SSR-SR)"
      V        ' xlOO%
          SA
where:
         SSR = spiked sample result
          SR = sample result (native)
          SA = the concentration added to the spiked sample

Quality  Assurance  (QA)  objectives  are  satisfied  for  accuracy  if  the
average  recovery  is  within  selected  goals.    The  analytical  laboratories
performed 75 accuracy evaluations on aqueous samples.   All results were
within the limits  identified  in  the  verification  test plan  [Ref  2].   The
results of the accuracy calculations are summarized in Appendix R

3.3.3.3  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, expressed as a percentage,  is
calculated using the following formula:

Completeness =      Valid Measurements x 100%
                     Total Measurements

QA objectives  are satisfied  if the percent completeness  is 90 percent  or
greater.    All  measurements  made  during  this  verification project were
determined to be valid and completeness  was 100  percent.  Therefore the
completeness objective was satisfied.

3.3.3.4  Comparability

Comparability is a 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 was  achieved  during this  verification
                        10

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test by the use  of consistent  methods  during sampling  and  analysis and
traceability of standards to a reliable source.

3.3.3.5  Representativeness

Representativeness refers to the  degree to which the data accurately and
precisely represent the conditions or characteristics of the parameter being
tested.   For  this verification  project,  one  field duplicate   sample  was
collected from  each sample location and sent to the laboratory for analysis.
Representativeness was calculated  as an  RPD  of these field  duplicates.
The results of these calculations are shown in Appendix C.

3.3.3.6  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 were used for this project.

Instrument Detection Limit (DDL)  is the minimum  concentration that can
be differentiated  from  instrument background  noise; that  is, the  minimum
concentration detectable by the measuring instrument.

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
sample matrix.    In other words, this  is the lowest concentration that can be
reported with  confidence.   It may be determined  by an DDL.   The MDLs
for this verification project are shown in Table 2.

Method Reporting Limit  (MRL)  is the concentration of the  target analyte
that   the  laboratory   had  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   without
qualifications by the laboratory].
                         11

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Critical
Measurements
Hexavalent
Chrome
Trivalent
Chrome
Hexavalent
Chrome
Trivalent
Chrome
Selected Metals
(Cr, Al & Mg)
Selected Metals
(Cr, Al & Mg)
Matrix
Aqueous
(Bath/
RETEC®)
Aqueous
(Bath/
RETEC®)
Aqueous
(Rinsewater)
Aqueous
(Rinsewater)
Aqueous
Solid
(Cr Flake)
Method
See Note 1
See Note 1
SM 3500 Cr D
SM 3500 Cr D
SW-846
3010A/6010B
SW-846
3050B/ 6010B
Reporting
Units
g/L
g/L
ug/L
ug/L
ug/L
mg/Kg
Method of
Determination
Titration
Titration
Colorimetric
Colorimetric
ICP-AES
ICP-AES
MDL
UOg/L
l.lOg/L
10 Hg/L
5 Hg/L
2 -100 ng/L
2 -20 mg/Kg
MRL
2.00 g/L
2.00 g/L
100 ng/L
100 ng/L
10 -100 Hg/L
2 -20 mg/Kg
    Note  1:  Standard  sodium thiosulfate  titration  was used to  determine  the hexavalent and trivalent  chromium
       concentration.   These procedure  were  taken directly from the  1999 Metal  Finishing Guidebook,  Vol. 97,
       No. 1,  Control, Analysis, and Testing  Section - Chemical Analysis of Plating Solutions, Charles Rosenstein
       and Stanley Hirsch, Table VIII - Test Methods for Electroplating Solutions, page 538.
    SM = Standard Methods for the Examination of Water and Wastewater, 20th Edition, January 15,1999.
    ICP-AES = Inductively Coupled Plasma-Atomic Emission Spectrometry (EPA SW-846 Method 601 OB)

                        Table 2. Laboratory Methodology Information

4.0    VERIFICATION DATA

       4.1     Analytical Results

       A complete summary of  analytical  data for the anolyte  and  catholyte is presented in
       Table  3.    Samples  were  collected  over an eleven-week  period  and  analyzed  for
       hexavalent and  trivalent  chromium,  total chromium,  aluminum  and  magnesium.   During
       the five-week Baseline Mode, samples were collected from the chromic  acid anodize bath
       solution as grab  samples directly from the anodizing bath.  During the  Operational Mode,
       samples were  taken  from  the  sampling ports  installed  on the  RETEC® anolyte  and
       catholyte liquid transfer  lines.   The  "1Q"  samples are post-verification test  samples from
       the anolyte  and catholyte lines of the RETEC®  unit,  collected at  the end of the 1st quarter
       of the catholyte operating cycle,  11  weeks  after the RETEC® unit was  turned on,  and just
       prior to disposal  of the  anodizing bath.  Anodizing bath disposal was required  because
       aluminum contamination reached the bath's upper limit.

       The  primary contaminants of the chromic acid  anodizing bath solution  are  aluminum and
       magnesium.    The values  for  these  parameters during the  Baseline Mode  represent
       contaminant  build-up  during  normal  production conditions.    During the  Operational
       Mode,  the  RETEC  unit was placed in operation to purify the chromic acid anodize bath
       solution.    The  normal  production  conditions   observed in  the  Baseline Mode  were
       maintained in the Operational Mode.
                                               12

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Sampling Week
0- Baseline
1- Baseline
2- Baseline
3- Baseline
4- Baseline
5- Baseline
6- Operational
7- Operational
8- Operational
9- Operational
10- Operational
11- Operational
16- 1Q
Hexavalent
Chromium
(by titration)
g/L
Anolyte /
Catholyte
48.0/NA
48.0/NA
48.1/NA
47.5/NA
50.5 /NA
51.5/20.6
52.6/21.3
52.9/22.5
53.5/36.1
53.8/41.5
Trivalent
Chromium
(by titration)
g/L
Anolyte /
Catholyte
< 1.1 /NA
< 1.1 /NA
< 1.1 /NA
< 1.1 /NA
< 1.1 /NA

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Test Mode/
Sample Date
Anodizing
Bath
Volume,
gallons
Anodizing
Bath
Surface
Tension
dynes/cm
Anodizing
Bath
(Anolyte)
Temp.
°C
Anodizing
Bath
PH
Anolyte
Flow
Rate
gpm
RETEC®
Amp-
hours Ah
Catholyte
Temp.
°C
Catholyte
PH
Catholyte
Flow
Rate
gpm
Baseline Mode
09-14-00
09-21-00
09-28-00
10-05-00
10-12-00
10-19-00
Average
9,240
9,320
9,320
9,400
9,400
9,320
9,333
24.6
20.7
19.6
24.8
24.7
24.7
23.2
38.5
36.2
35.9
34.1
34.0
35.3
35.7
0.70
0.55
0.75
1.04
0.69
0.73
0.74
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Operational Mode
10-26-00
11-02-00
11-09-00
11-16-00
11-23-00
11-30-00
Average
9,320
9,240
9,240
9,160
*
9,240
9,240
26.3
26.6
27.3
28.1
*
27.1
27.1
33.3
33.4
34.0
33.3
*
33.2
33.4
0.81
0.81
1.11
0.86
*
0.95
0.91
1.51
1.44
1.69
1.64
*
2.94
1.84
27,594
31,285
34,264
38,744
41,372
43,598
36,143
31.5
31.4
30.7
30.7
*
31.4
31.1
1.08
2.89
1.19
2.52
*
1.12
1.76
4.49
3.78
4.44
2.98
*
4.26
3.99
* Thanksgiving holiday - no monitoring done this week.
 NA = Not Applicable

                        Table 4. Summary of Process Measurements

       Anodizing bath  volume is maintained by  the periodic addition of water to the anodizing
       tank by  the  DVT  maintenance personnel.   There  was  only one  water addition to the
       anodizing bath during  the  eleven-week verification test period.  160  gallons of water was
       added to the anodizing tank during the Baseline Mode on 10-5-00.

       Anodizing  bath  surface   tension  is  required  to  be maintained  below  40  dynes/cm.
       Maintaining the  surface tension of the chromic acid  anodizing bath below this level  limits
       hexavalent chromium  air  emissions.   In  order to maintain the surface tension  below the
       required  limit, DVI maintenance personnel added a total of 17 gallons of Fumetrol  140
       Mist Suppressant (MSDS# P14857VS) which is supplied by Van Waters & Rogers, Inc.
       of Los Angeles, California.   Six gallons were  added to  the  anodizing  tank during the
       Baseline Mode, and 11 gallons were added during the Operational Mode.

       The target anolyte flow rate range specified by USFilter for DVTs RETEC  system  is 1-3
       gpm.   The  target flow rate for the catholyte is 4  gpm.  During operation  of the unit,
       operators  adjust the  flow  rate  of  the  anolyte   and   catholyte   solutions  within  the
       recommended operating limits.   If the anolyte flow is too high, there is an increase in the
       bleed-through of  anolyte  from the  anolyte side  of the  system to  the  catholyte  side,
       causing the  clarifier to  overflow.   Clarifier  overflow  is  normally  piped  back  to the
       anodizing tank for reintroduction to  the  anolyte loop, but was disconnected and piped to
       temporary storage  drums  for the duration  of the  verification test  in order  to track its
                                             14

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volume.   Clarifier  overflow averaged about  35  gallons  per week with a  total  of 212
gallons during the six weeks of RETEC  operation.
                               ®
Total  amp-hours for the RETEC  unit is a function of the electricity required to complete
the electrochemical reaction  in  the  cell.   The  amount  of electricity  introduced  to  the
process is controlled by  adjusting the voltage cf the RETEC® cell.  The amount of voltage
required is dependent on several factors, including  the chemical composition and physical
characteristics  of the catholyte.    To maintain  the catholyte in the proper pH  for  the
reaction to  occur,  an average  of 17 pounds of  chromic  acid  flake was added  to  the
clarifier each week of the test (total 102 pounds) over the 6 weeks of RETEC® operation.

4.3    Production Data

The RETEC  system  is connected  to  the 27-foot chromic acid  anodizing tank at DVI.
The anodizing bath can accept parts up to 26'xlO'x5';  however, due to the large  quantity
of uniquely  sized parts, it was not feasible to measure production volume by  square feet
anodized.  At DVI,  production volume  is  measured in overall amp-hours for the 27-foot
line.    The  amp -hours  required  to anodize  parts  in the 27- foot line  during  verification
testing are summarized in Table 5.
Test Mode/
Sample Date
Anodizing Bath
Amp-hours
Baseline
09-14-00
09-21-00
09-28-00
10-05-00
10-12-00
10-19-00
Total Baseline
0
52,834
48,618
41,720
40,863
43,068
227,103
Operational
10-26-00
11-02-00
11-09-00
11-16-00
11-23-00
11-30-00
Total Operational
Total
38,344
38,585
32,371
44,338
39,505
26,936
220,079
447,182
Anodizing Bath Process Load







"\
"N-^^ /\
\
^


123456789 10 11
Sampling Week

              Table 5. DVI Production (Ah required for anodizing)
                                      15

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       4.4    Other Data

       Other data collected during the course of the verification test are summarized in Table 6.
Description
Cost of chromic acid flake
Chromic acid used 3/20/99-1/3/00 - RETEC® off*
Chromic acid used 1/3/00-9/6/00 - RETEC® on*
Chromic acid additions during Baseline Mode
Chromic acid additions during Operational Mode
Cost of Fumetrol 140 Mist Suppressant
Fumetrol 140 used 3/20/99-1/3/00 - RETEC® off*
Fumetrol 140 used 1/3/00-9/6/00 - RETEC® on*
Fumetrol 140 additions during Baseline Mode
Fumetrol 140 additions during Operational Mode
Electricity by cost
Labor cost (loaded rate)
Initial cost RETEC® unit*
Installation cost RETEC® unit*
Value
$1.31perlb
9,010 Ib
8,890 Ib
990 Ibs
760 Ibs
$515/gal
32 gal
31 gal
14 gal
17 gal
$0.09/kWh
$10.00/hr
$33,630 (1993)
$1,600 (1993)
       *Data from D VI historical records

                     Table 6. Other Data Collected During Verification

       4.5    Hexavalent Chromium Air Monitoring

       Air emissions from the  DVI anodizing bath/RETEC  unit were  tested  for  hexavalent
       chromium.    The  objective  of this testing was to  check to  see  if the RETEC  unit
       contributed to the  concentration  of airborne  hexavalent chromium  in the DVT  facility.
       Air monitoring  was  conducted  in  both the  Baseline  and Operational  phases  of the
       verification test.   During  each  phase, multiple two-hour samples  were  collected  from a
       stationary  process emissions monitor as well as a worker  breathing  zone air monitor for
       personal  exposure.   Personal  exposure and process emissions  samples were collected in
       accordance  with  appropriate  National  Institute  of  Occupational   Safety  and  Health
       (NIOSH), and  California Air  Resources Board (CARB)  methods,  respectively.    Both
       types of samples were analyzed according to EPA method 306 for hexavalent chromium.

5.0    EVALUATION OF RESULTS

       5.1    Oxidation of Trivalent Chromium to Hexavalent Chromium

       The  oxidation of trivalent  chromium  to hexavalent  chromium in  the  anolyte  and the
       transfer  of hexavalent  chromium  across the  polymeric  membrane from the catholyte to
       the anolyte  by  the RETEC   unit is  marketed  as one  of  the beneficial  conversions
       performed by the electrodialysis process.  However, as  can be seen in Table  3, trivalent
       chromium levels  were never above background levels  in  the  anolyte, so there was no
       quantifiable  oxidation  to  hexavalent   chromium.     A  slight  increase  in   hexavalent
       chromium levels  in  the anolyte  was observed, but since DVT  adds chromic acid to the
       anodizing  bath on a regular basis, this increase in  hexavalent chromium concentration can

                                             16

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not be definitively attributed to the RETEC®  electrolytic reaction.  Increases in catholyte
hexavalent  chromium may be attributed to the fact that DVI adds chromic acid flake  to
the catholyte to control catholyte pH.  Hexavalent chromium levels measured by  titration
that are higher than  total  chromium levels measured by ICP-AES are due to uncertainties
inherent in the precision of these two analytical methods.

5.2    Contaminant Removal

Reduction of the rate of increase of the primary contaminants of the chromic acid anodize
bath solution, aluminum and magnesium, are shown in Table 7.  For the Baseline Mode,
the average weekly aluminum increase in the anolyte was 0.180 g/L.   The average weekly
magnesium  increase in  the  anolyte  was  0.010  g/L.   During  the  Operational Mode,
aluminum and magnesium  levels in  the  anolyte  remained  relatively   stable,  while the
catholyte  showed  an overall increase  of  6.32 g/1  of aluminum.    The total volume  of
catholyte  solution at the  end of the  verification test was 392 gallons (150 gallons in the
clarifier +  30 gallons  in  the RETEC® cell and piping  + 212 total gallons of catholyte
overflow  collected during  the  test).  Multiplying the  aluminum contamination increase  in
the catholyte by  the total  catholyte volume gives an overall  removal of 9,378 grams  of
aluminum from the anolyte solution over the six week test period  (6.32 g/1 x 392  gallons
x  3.7854 liters/gallon = 9,378 grams).   The  increase in magnesium contamination  in the
catholyte was less pronounced,  showing an overall increase of 0.19 g/1.  Multiplying the
magnesium contamination  increase in the catholyte by the total catholyte volume gives  an
overall removal of 282 grams of magnesium from the anolyte  solution over the  six week
test period (0.19  g/1  x 392 gallons x 3.7854 liters/gallon = 282 grams).  The RETEC® unit
proved to  be an adequate technology  for  removing  aluminum   contamination  from the
chromic acid anodize solution at DVI; however, the unit was not able to completely arrest
the contamination rise in the anodizing bath.   Since the  six-cell model installed at DVI  is
the smallest RETEC®  unit made by USFilter,  it is possible  that a larger unit  may  solve
this problem.  However,  since  the RETEC®  unit was turned  on  when  the anodizing bath
was within 1.6 g/L of its upper limit for aluminum, the purification system was unable to
prevent the  anodizing  bath  from  reaching  the  upper contamination limit,  triggering
disposal of the anodizing  bath.   It can be concluded that the RETEC® system extended
the anodizing  bath  life   by  slowing the  contamination build-up rate,  but due  to the
relatively  short  verification  test  period,  the  length  of  this  extension  could not  be
determined.
Anolyte
Aluminum
Magnesium
Baseline Mode
Operational Mode
Baseline Mode
Operational Mode
Catholyte
Aluminum
Magnesium
Operational Mode
Operational Mode
Start
(g/L)
3.6
4.5
0.27
0.32
End
(g/L)
4.5
4.9
0.32
0.24
Change
(g/L)
+0.9
+0.4
+0.05
-0.08
Average Weekly
Increase (g/L)
+0.180
+0.067
+0.010
-0.0133

0.085
0.087
6.40
0.28
+6.32
+0.19
+1.053
+0.0317
                       Table 7. Contaminant Removal
                                      17

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5.3    Mass Balance

Mass balance calculations  are  designed  to  be an  accounting of the weights  of materials
entering  and  leaving  a processing unit.    They  help to  evaluate how effectively  the
sampling and analytical procedures account for certain key parameters.

Initially,  this verification test included  a  planned  mass balance exercise to be  contained in
the verification  report; however,  due to  specific  process design  at DVT  and  technical
constraints,  it was  determined  that a mass balance exercise would not be feasible.  Mass
balance calculations typically measure  the inputs  to a process and compare them with  the
outputs to confirm that the totality of all output constituents are equal or close  to the input
constituents.   This comparison is  highly  effective  in  determining  the  process efficiency
and sampling/analytical  accuracy for a single pass processing  system such as a filter, or a
multi-pass processing unit such  as a membrane with an influent that is stable or exhibits a
known flux in constituents.

At DVI,  it is impossible to detect a contaminant differential in the influent and effluent of
the RETEC® system.   The unit removes a minute amount of tramp metals and oxidizes an
even  smaller  amount  of trivalent chromium to  hexavalent  chromium  on each pass,  but
analytical methods  and  their  inherent limitations  on  accuracy, precision and resolution
prohibit  the  measurement  of  these  changes  during a single  pass through  the system.
When measured over  an extended period  of weeks, a change trend was observed, but a
mass   balance  calculation  still  remains  impossible   since  an  unknown,   continuously
changing amount of tramp metals are introduced into  the equation on an irregular basis
during normal processing.

The  closest  resemblance to a mass  balance  exercise one  can conduct is an estimated
aluminum mass  balance.   The increase  in  aluminum contamination in the anodizing bath
during the Baseline Mode was  0.9 g/L.  Normalized to the Ah of work completed during
that period,  there  was  a 3.96  x  10~3 g/L rise in aluminum contamination for  every  1,000
Ah.   If that contamination rate is extended  into  the Operational Mode for the amount of
work  done  during  that  period,  there  should  have   been  an  aluminum  contamination
increase  of another 0.87 g/L in the anodizing bath.  The bath, at 34,973 L the last day of
the test, should have generated an additional 30,480 grams of aluminum contamination.

If the actual analytical results  for aluminum  in the anodizing  bath  are  totaled,  the
RETEC   system catholyte and the  clarifier  overflow,  23,431 grams of aluminum can be
accounted for (77  percent).    (NOTE:  aluminum  and  magnesium in the  upstream  and
downstream rinse tanks, as well  as  the  raw chromic acid flakes was negligible,  less than
0.85% of the  aluminum generated during the test - see Table 8.)  The missing 23 percent
of aluminum (7,049 grams, or  0.201 g/L in  the anodizing  bath) could be  attributed to  the
inherent  limitation  in  precision  of the  analytical method, which was as  high  as 4 percent
for the  DVI  verification test.    A variation  of 4 percent translates  to final  aluminum
contamination  reading of the anodizing bath of  + 0.196 g/L (4.9  x .04), very  close to  the
missing 0.201 g/L.  Metals solids  can also  precipitate  out of solution  from the catholyte.
A small  amount of this  granular  solid,  not accounted for  in  the  analytical  results, was
observed building up  and settling to the bottom  of the RETEC® reaction cell.  Still more
is assumed to be  at  the  bottom  of the clarifier,  but quantities  were  not   ascertainable

                                       18

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       during the test period.   Another  explanation for the  missing aluminum is the possible
       formation  of aluminum  complexes in the anodizing bath, which the aluminum analytical
       method does not measure.  In the Electroplating Engineering  Handbook by Lawrence J.
       Durney [Ref  4],  it  is  stated  that  dissolved  aluminum  can  react with  trivalent  and
       hexavalent  chromium  to form  aluminum dichromate.    This  aluminum complex is not
       detected by the aluminum  analytical method  used to measure the aluminum in the  bath,
       and could therefore account for the missing aluminum.
Sampling Week
0- Baseline
1- Baseline
2- Baseline
3- Baseline
4- Baseline
5- Baseline
6- Operational
7- Operational
8- Operational
9- Operational
10- Operational
11- Operational
Chromic Flake
Hexavalent
Chromium
(Colorimetric)
g/L
Upstream Rinse
/ Down Rinse
.043 / .0043
.0347. 0028
.0397. 0019
.0417. 0056
.053 / .0063
.0717. 0058
.048 / .0036
.0347. 0016
.0347. 0017
.083 7 .0046
Trivalent
Chromium
(Colorimetric)
g/L
Upstream Rinse
/ Down Rinse
< .00001 / .00052
< .00001 / .00056
< .00001 / .00035
< .00001 / .00069
<. 00001 /. 0004
< .00001 / .00099
<. 00001 /. 0005
< .00001 / .00046
<. 00001 /. 0007
< .00001 / .00042
Total
Chromium
(ICP-AES)
g/L
Upstream Rinse
/ Down Rinse
.041 7 .0049
.0317.0034
.0367.0021
.0387.0064
.047 7 .0071
.064 7 .0066
.0447.0041
.0317.002
.029 7 .0025
.0787.0055
Total
Aluminum
(ICP-AES)
g/L
Upstream Rinse
/ Down Rinse
.0033 /<. 0002
.0026 7 .0003
.0033 7 .0004
.00377.001
.0044 7 .0007
.00667.0014
.0045 7 .0007
.003 7 .0003
.0029 7 .0006
.0079 7 .0007
Total
Magnesium
(ICP-AES)
g/L
Upstream Rinse /
Down Rinse
.0157.016
.0157.015
.0157.015
.0157.015
.0157.015
.0157.015
.0147.015
.0157.015
.0157.015
.0167.016
Thanksgiving holiday - no samples collected this week.
.0517.0031
NA
< .00001 / .00029
NA
.0467.0036
480.0 (g/Kg)
.0049 7 .0005
0.15 (g/Kg)
.0157.016
1.2 (g/Kg)
NA = Not applicable
                  Table 8. Summary of Analytical Results (Rinse & Flake)

       5.4    Hexavalent Chromium Air Monitoring Results

       Baseline  air  monitoring  results  indicated   an   average  process  hexavalent  chromium
       emission of  0.1112  |J,g/m3.   Personal exposure  monitoring  resulted in an  average of
       0.5199  ng/m3.   Both readings are  well  within the Occupational  Safety and Health
       Administration  (OSHA)  Permissible  Exposure  Limit  (PEL)  of  100  |J,g/m3  and  the
       American  Conference  of Government  Industrial  Hygienists  (ACGIH)  Threshold  Limit
       Value(TLV)of50ng/m3.
                                             19

-------
Operational  air  monitoring  results  showed  an  average process  hexavalent  chromium
emission of  1.3495 ng/m3.   These readings are twelve times higher than the Baseline
results,  however, they are still  well below the OSHA  and ACGIH  limits.   A  certain
increase  in  process emissions  was expected due  to the  aeration of the open-topped
RETEC clarifier that took place  during the operational phase of the  verification test.  The
stationary  air monitoring equipment  collected  samples from  an  elevated platform adjacent
to the RETEC clarifier.

Personal  monitoring during the  operational phase  was  performed,  however, the  worker
being monitored also  performed  maintenance on paint booth filters which contained dried
chromium containing  paint flakes  and dust.   This  activity  contaminated the samples,  so
the results were discarded.
Sample Location
RETEC Clarifier
Run No.
Run#l
Run #2
Run #3
Volume of Air
Sampled (m3)
1.89
1.96
1.96
Hexavalent Chromium
ug/sample
0.198
0.099
0.349
ug/m3
0.105
0.051
0.178
               Table 9. Air Monitoring Results - Baseline Phase
Sample Location
RETEC Clarifier
Run No.
Run#l
Run #2
Run #3
Volume of Air
Sampled (m3)
1.88
1.88
2.05
Hexavalent Chromium
ug/sample
1.20
1.56
5.29
ug/m3
0.638
0.830
2.581
            Table 10. Air Monitoring Results - Operational Phase

Operational  air monitoring abnormalities withheld,  the  RETEC system  exhibited  a slight
increase in the overall hexavalent air  emissions to the DVT facility.  It is  imperative to
realize that this increase  only raised the DVI ambient  air quality from  0.2% to 2.7% of
the ACGIH TLV.  The results of the air monitoring are shown in Tables 9 and 10.

5.5    Energy Use

The  primary  energy  requirements for operating  the RETEC® system  at  DVI  include
electricity  for  the system  rectifier  and  liquid transfer pumps.   Electricity is  also used for
instrumentation and intermittent compressed  air used for  agitation; however,  the  energy
requirements for these are less significant and were not evaluated during this project.

RETEC®  system  rectifier electrical  requirements  (volts,   amps  and  amp  hours) were
recorded from gauges on the RETEC® system rectifier instrument panel each week.  The
results are summarized in Table 11.
                                      20

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Rectifier electricity use was calculated by multiplying  total  amp-hours by average system
voltage and dividing by  1,000 (3.11  x216,857/l,000) to get 675.9 kWh for the six week
Operational Mode of the verification  test.  This reduces to  an average  of 16.1  kWh/day.
Since the rectifier is left  on at all times, the total annual consumption operating 365  days
per year is 5,876.5 kWh/yr.

Liquid transfer pump electricity use  was calculated by multiplying the horsepower  (HP)
of each system pump (1/25 and 1/16 HP) by .746  kW/HP-hr by the number of hours of
use.   The result is 191.0 kWh/yr and 298.4 kWh/yr respectively, based on continuous use
(6,400 hrs/yr) of the pumps.  Therefore the  combined  energy consumption for  the liquid
transfer pumps  is  489.4 kWh/yr,  making the  total  electricity demands  for  the  entire
RETEC® system 6,366 kWh/yr.
Test Mode/
Sample Date
Amperage
(amps)
Voltage
(VDC)
Amp-hours
(Ah)
Operational
10-19-00
10-26-00
11-02-00
11-09-00
11-16-00
11-23-00
11-30-00
Total
312
148
140
230
165
*
350

3.0
3.6
3.4
3.1
2.7
*
2.9

0
27,594
31,285
34,264
38,744
41,372
43,598
216,857
*No sampling taken during Thanksgiving; however, recording devices continued to measure and read data
                          -i®
         Table 11. RETEC  System Rectifier Electrical Requirements

5.6    Operating and Maintenance Labor Analysis

Operations and maintenance  (O&M) labor  requirements for the purification  system  were
observed  during  testing.   Quarterly,  the  RETEC®  cell  is drained and cleaned.   This
process  was  not  observed  during  the  verification  test;   however,  interviews  with
maintenance personnel  and supervisors determined that it takes  about 4 labor hours to
complete the cleaning and start-up procedure (16 hr/yr).

On a daily basis,  operators periodically checked and  recorded the anolyte and catholyte
flow  rates,  rectifier voltage/amperage  and catholyte  pH  and made  adjustments,  when
necessary.  At 5 minutes per shift, three shifts per day, five days per week (plus one shift
on  Saturday),  these daily  tasks take  approximately one hour and twenty  minutes  each
week to perform.  On a 50-week/yr basis, operating checks take approximately 67 hrs/yr.

RETEC®  system chemical  additions are another maintenance labor requirement.  Periodic
additions of chromic  acid  to the clarifier are necessary to keep the pH of the catholyte
under a pH of 2.  Keeping the catholyte pH at this level prevents the precipitation of the
tramp  metals and  other contaminants  as their respective hydroxides.   Observation of the
maintenance personnel  showed  an  average of  40 minutes per  week dedicated to the
                                      21

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       preparation and addition of chromic acid to the catholyte.  On a 50-wk/yr basis, chemical
       additions take approximately 33 hrs/yr.

       Typical  equipment  maintenance  and  parts  replacement  average  about  two  hours  per
                                                                                   ®
       month  (24  hrs/yr).  In summary, total O&M labor requirements for the  RETEC   system
       average about 140 hrs/yr.

       Other O&M labor associated with the chromic acid anodizing process, which is  affected
       by the operation  of the purification  unit,  is the disposal  and make-up of anodizing bath
       chemistries.  This process  involves draining a  pre-identified  amount of  the chromic acid
       anodizing  solution, and  refilling the  tank with  fresh water  and chemicals.   Sometimes
       DVI does a full bath  dump (approximately 8,600 gallons), and  sometimes they only do  a
       half bath dump (approximately 4,500 gallons).   The amount of bath dumped is a  decision
       made by DVI management at the time of disposal.  In either instance, the process takes
       about five labor hours to complete.  DVI performed two bath dumps in 1999, and two in
       2000.  Since  the  number  of bath  dumps was the  same for  each year, there were no
       increases/decreases in O&M labor requirements based on bath dumps  when RETEC  is
       turned on versus when it is turned off.

       The  number of make-up  chromic acid additions when the RETEC®  system  was off  in
       1999 was 49,  and when it was on in 2000, there were 46 additions,  a decrease  of  6
       percent.  In regards to Fumetrol 140 Mist Suppressant make-up additions, in 1999 there
       were 31, and in 2000 there were 22, a decrease of 29 percent.  At thirty minutes for  a
       chromic acid addition, and  twenty minutes for  a mist suppressant addition, this translates
       to an annual savings  of about 5 hours of  O&M labor  requirements.    Net  O&M labor
       requirements related to the operation of the RETEC® system are 140 - 5 = 135 hrs/yr.  No
       additional O&M tasks were performed during the test period.

       5.7    Chemical Use Analysis

       From 3/20/99  to  1/3/00 (9.5 months), when the chromic acid  anodizing purification unit
       was off-line, DVI used the following chemicals:

       •  Anodizing tank new bath creation chromic acid flake: 3,300 Ibs.
       •  Anodizing tank new bath creation Fumetrol 140 Mist Suppressant: 16 gallons
       •  Anodizing tank make-up chromic acid flake: 5,710 Ibs.
       •  Anodizing tank make-up Fumetrol 140 Mist Suppressant:  16 gallons

       This period saw 1,346,149  Ah of anodizing being completed.  This normalizes an  average
       chemical  consumption  of 6.69  Ibs.  of chromic  acid  flake  and  .0234  gallons  of mist
       suppressant per 1,000 Ah.

       In 2000,  from 1/3/00  to 9/6/00 (8 months),  when the purification unit was on-line1,  DVI
       used the following chemicals:

       •  Anodizing tank new bath creation chromic acid flake: 3,300 Ibs.
       •  Anodizing tank new bath creation Fumetrol 140 Mist Suppressant: 18 gallons
1 The RETEC® system was off-line for a one month period (4/26/00 to 5/31/00) for an equipment design retrofit.

                                            22

-------
•   Anodizing tank make-up chromic acid flake: 5,370 Ibs.
•   Anodizing tank make-up Fumetrol 140 Mist Suppressant: 13 gallons
•   RETEC® system catholyte creation chromic acid flake: 85 Ibs.
•   RETEC® system catholyte make-up chromic acid flake: 127 pounds

This period saw 1,360,124 Ah of anodizing being completed.    This  normalizes to  an
average chemical consumption  of 6.53  Ibs.  of chromic acid flake and .0228 gallons  of
mist suppressant per 1,000 Ah.

A comparison in chemical  consumption  results in a small  decrease in chromic acid (0.16
Ibs. per 1,000 Ah) and mist suppressant (0.0006 gallons per 1,000 Ah) when the RETEC®
system is  in operation.  This translates to average  annual  chemical savings of 323 Ibs.  of
chromic acid flake and 1.2 gallons of Fumetrol 140 Mist Suppressant.

5.8    Waste Generation Analysis

When  the anodizing bath reaches its upper  limit for aluminum contamination, it must  be
disposed of, and a fresh  anodizing bath  must formulated.  Sometimes DVI does a full
bath dump (approximately 8,600 gallons),  and sometimes they  only do a half bath dump
(approximately 4,500 gallons).   The amount of bath dumped is a decision made by DVT
management at the time of disposal.

The purpose of  the RETEC®  system is to extend the  anodizing bath life by  removing the
tramp  metal   contaminants  from  the  anodizing  bath  and  concentrating  them  in  the
catholyte,  thus  reducing the  tramp  metal  contamination  in  the  anodizing  bath  and
extending  its  life.   When the  catholyte  reaches its upper limit for metals contamination,
and is  no  longer able to maintain the metals in solution, it must be sent for  disposal (180
gallons) as well.

During the Baseline Mode,  the  RETEC® unit was turned off.  The anodizing bath saw an
overall increase of 0.9 g/L of aluminum over this period.  Normalized  to the amount  of
work measured in Ah during the Baseline  Mode, this results  in an average  of 3.66 gallons
of chromic acid waste accumulation per 1,000 Ah.

In the  Operational Mode, the  RETEC® unit was on.   The anodizing bath saw an overall
increase of 0.4 g/L of aluminum.  Normalized to the  amount of work measured in amp-
hours  (Ah)  for  the Operational  Mode,  this  results  in  an average of  1.68 gallons  of
chromic acid waste accumulation per 1,000 Ah. The results are summarized in Table 12.
Date
09/14/00
10/19/00
10/19/00
11/30/00
Aluminum
Contamination
(g/L)
3.6
4.5
4.5
4.9
Anodizing
Completed
(Ah)
227,103
220,079
Total
Aluminum
Increase (g/L)
0.9
0.4
Waste
Generation
(gal/1,000 Ah)
3.66
1.68
               Table 12. Results of Waste Generation Analysis
                                     23

-------
The  difference in aluminum  accumulation  between  the  two  periods,  1.98  gallons  per
1,000 Ah,  is  the apparent contamination  reduction  as  a direct result of the  RETEC®
system.   At the total Ah of work performed during the  Operational Mode, this  translates
to 220 k Ah x 1.68  = 370 gallons of chromic acid waste.  However, we have to account
for the added  waste  stream of the catholyte when the RETEC® system is in operation.  In
2000, DVI had to dispose of the catholyte  and clean  the RETEC® unit four times, or once
per quarter.  The Operational Mode of the  verification test was just under  1.5 months, so
one-half (65 gallons) of a catholyte  disposal/system cleaning will be accounted  for h our
waste generation  calculations.    Therefore  the  RETEC® system generated  65 gallons  of
additional chromic acid waste.  Subtracting this from the waste  disposal reduction  of 370
gallons  results in net savings  of  305  gallons  of chromic   acid  for  the  1.5   month
Operational Mode of the verification test, or about 2,440 gallons of chromic acid  waste
per year.

5.9    Cost Analysis

The  capital  cost  of  the  RETEC® system was $35,230  (1993;  includes $25,630  for  the
electrolytic cell,  pumps,  stand  and clarifier,  $8,000 for the  rectifier,  and  $1,600  for
installation costs).

Annual  costs  and savings associated with  the  chromic acid anodize solution purification
operation  are  shown in  Table  13.   The  operating costs of  the  RETEC  system  are
$53,676.  The operating  costs of the  anodizing bath prior to installation of the RETEC®
system were $61,964, resulting  in  net  annual  savings  of $8,288.   The  simple payback
period is 4.2 years (capital cost/net annual savings).

Since some  cost items are normalized to the workload as measured in amp-hours (Ah) for
each year, and the workload varies from year to year, the following table is  based  on a
fictitious 2,000,000 Ah year.   (According  to  DVI operation logs,  Tank  #9, where  the
RETEC® system is installed, saw 2,018,859 Ah in the year 2000).
                                      24

-------
Item
Purification unit
O&M labor (see
section 5.5)
Chromic acid
anodizing tank
maintenance
O&M labor (see
section 5.5)
Chromic acid per
1,000 Ah (see
section 5.7)
Fumetrol 140 mist
suppressant per
1,000 Ah (see
section 5.7)
Electricity for
purification unit
(see section 5.4)
Waste disposal
fees per 1,000 Ah
(see section 5.8)
Total Costs
Prior to Installation of RETEC®
System
Units
0
35hrs
6.69 Ibs.
0.0234 gal.
0
3.66 gal.

Unit
Cost
$/unit
N/A
10.00
1.31
515

2.73

Costs/yr
(2M
Ahr/yr)
$
0
350
17,528
24,102
0
19,984
61,964
After Installation of RETEC®
System
Units
140 hrs.
30 hrs.
6.53 Ibs.
0.0228 gal.
6,366 kWh
1.98 gal.

Unit
Cost
$/unit
10.00
10.00
1.31
515
0.09
2.73

Costs/yr
(2M
Ahr/yr)
$
1,400
300
17,109
23,484
573
10,810
53,676
                       Table 13. Annual Costs/Savings

5.10   Project Responsibilities/Audits

Verification  testing  activities  and sample  analysis  were performed according to section
6.0 of the Verification Test Plan [Ref. 2].

There were  two verification test audits  conducted  during the verification period  for this
technology.   The  first  audit  was  an  external  EPA  Technical  Systems Audit  (TSA)
conducted by  subcontractor,  John  H.  Nicklas of Science  Applications  International
Corporation  on September 28, 2000.   There were no Findings, two Observations and two
Additional Technical Comments.   All  corrective  actions were completed as instructed  in
the audit report issued by Mr. Nicklas.

The second  audit conducted on this verification test was an internal CTC TSA conducted
by  Mr.  Clinton Twilley,  CTC  QA Manager,  on  November  9,  2000.   Mr.  Twilley
identified no Findings, three  Observations and five  Additional Technical  Comments.  All
corrective actions were complete as of the end of the verification test.
                                     25

-------
6.0    REFERENCES

       1.    ELTECH International Corporation,  "RETEC® CP Model 6 Chrome Purification
            System Users Manual - Version 1.1. " March 1994.

       2.    Concurrent  Technologies  Corporation,   "Environmental Technology  Verification
            Program for Metal Finishing Pollution Prevention Technologies Verification Test
            Plan,  Evaluation of USFilter RETEC® Separated Cell Purification of Chromic
            Acid Anodize Bath Solution" September 13, 2000.

       3.    Concurrent  Technologies  Corporation,   "Environmental Technology  Verification
            Program Metal Finishing Technologies Quality Management Plan" December 9,
            1998.

       4.    Durney, Lawrence  J.  (ed).  Electroplating  Engineering Handbook, 4th  Edition,
            Chapman & Hall, London,  UK, 1996.

       5.    Lenore  S.  Clesceri,  Andrew  D. Eaton, Arnold E.  Greenberg (editors) Standard
            Methods for the Examination  of Water and  Wastewater, 20th Edition, American
            Public Health Association, and the Water Environment Federation, 1998.

       6.    Michael Murphy (ed).  Metal Finishing 67th Guidebook and Directory Issue, Metal
            Finishing Magazine, Volume 97, Number 1, January 1999.
                                           26

-------
      APPENDIX A
PRECISION CALCULATIONS

-------
PRECISION CALCULATIONS
Laboratory ID
L2002928-001
L2002928-001
L2002 928-001
L2002923-003
L2002923-005
N/A
N/A
N/A
N/A
L2003022-006
L2003022-006
L2003022-006
L2003022-005
N/A
N/A
L2003070-001
L2003070-001
L2003070-001
L2003089-005
N/A
N/A
L2003 163-005
L2003 163-005
L2003 163-005
L2003 163-005
N/A
N/A
L2003247-006
L2003247-006
L2003247-006
L2003247-005
N/A
N/A
L2003308-007
L2003308-007
L2003308-007
L2003308-007
N/A
N/A
N/A
N/A
N/A
N/A
L2003388-008
L2003388-008
L2003388-008
L2003388-001
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
L200348 1-008
L200348 1-008
CTCTD
Batch Sample
Batch Sample
Batch Sample
0914G-CC
0914H-CC
0914F-CT
0914F-CT
0914F-CTD
0914F-CT
0921H-M
0921H-M
0921H-M
0921H-CC
0921F-CT
0921F-CT
Batch Sample
Batch Sample
Batch Sample
0928H-CC
0928F-CT
0928F-CT
1005H-CC
1005H-CC
1005H-CC
1005H-CC
1005F-CT
1005F-CT
1012H-M
1012H-M
1012H-M
1012H-CC
1012F-CT
1012F-CT
1019H-CC
1019H-CC
1019H-CC
1019H-CC
1019A-CT
1019A-CT
1019A-CTD
1019A-CTD
1019B-CT
1019B-CT
1026H-M
1026H-M
1026H-M
1026H-CC
1026A-CT
1026A-CT
1026B-CT
1026B-CT
1026B-CTD
1026B-CTD
1026C-CT
1026C-CT
1102H-M
1102H-M
Parameter
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Units
mg/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
Sample
Value
4.52
0.479
20.4
88.9
9.03
46.57
46.57
47.43
46.57
5.32
3.76
19.9
7.75
49.15
48.29
4.98
0.480
14.8
6.89
48.14
49.02
6.03
6.82
20.6
15.6
47.52
47.52
5.83
7.60
20.4
16.2
50.52
50.52
6.37
7.15
20.2
15.6
51.48
51.48
51.48
51.48
20.59
19.73
5.67
4.61
19.7
8.35
52.93
52.50
21.34
21.34
21.34
22.20
17.07
17.07
5.52
2.45
Duplicate
Value
4.46
0.475
20.3
89.6
9.10
50.02
46.57
49.15
46.57
5.26
3.75
19.8
7.70
47.43
47.43
4.95
0.480
14.8
7.00
48.14
49.02
5.96
6.75
20.5
15.8
47.52
47.52
5.85
7.57
20.4
16.3
50.52
50.52
6.37
7.30
20.6
15.6
51.48
51.48
51.05
51.48
20.59
19.73
5.67
4.62
19.8
8.34
52.07
52.07
21.34
21.34
21.34
21.34
17.07
17.07
5.42
2.50
RPD%
1
<1
<1
<1
<1
7
0
4
0
1
<1
<1
<1
4
2
<1
0
0
2
0
0
1
1
<1
1
0
0
<1
<1
0
<1
0
0
0
2
2
0
0
0
<1
0
0
0
0
<1
<1
<1
2
<1
0
0
0
4
0
0
2
2
RPD%
Limits
<30
<30
<30
<30
<30
<10
<10
<10
<10
<30
<30
<30
<30
<10
<10
<30
<30
<30
<30
<10
<10
<30
<30
<30
<30
<10
<10
<30
<30
<30
<30
<10
<10
<30
<30
<30
<30
<10
<10
<10
<10
<10
<10
<30
<30
<30
<30
<10
<10
<10
<10
<10
<10
<10
<10
<30
<30
RPDMet
Y/N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
        A-l

-------
Laboratory ID
L200348 1-008
L200348 1-007
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
L2003566-008
L2003566-008
L2003566-008
L2003566-007
N/A
N/A
N/A
N/A
N/A
N/A
L2003639-008
L2003639-008
L2003639-008
L2003639-007
N/A
N/A
N/A
N/A
N/A
N/A
L2003756-008
L2003756-008
L2003756-008
L2003756-007
N/A
N/A
N/A
N/A
N/A
N/A
crcro
1102H-M
1102H-CC
1102A-CT
1102A-CT
1102B-CT
1102B-CT
1102C-CT
1102C-CT
1102C-CTD
1102C-CTD
1102D-CT
1102D-CT
1109H-M
1109H-M
1109H-M
1109H-CC
1109A-CT
1109A-CT
1109B-CT
1109B-CT
1109C-CT
1109C-CT
1116H-M
1116H-M
1116H-M
1116H-CC
1116A-CT
1116A-CT
1116B-CT
1116B-CT
1116C-CT
1116C-CT
1130H-M
1130H-M
1130H-M
1130H-CC
1130A-CT
1130A-CT
1130B-CT
1130B-CT
1130C-CT
1130C-CT
Parameter
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Units
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
Sample
Value
19.3
6.68
52.93
52.93
23.05
23.05
23.05
22.20
22.20
22.20
16.22
16.22
5.25
2.81
19.6
4.18
53.78
53.78
36.71
36.71
25.61
25.61
5.69
5.96
21.2
9.41
53.78
54.83
41.83
43.54
25.61
26.46
5.32
4.03
20.6
7.68
53.29
53.29
51.60
51.60
45.68
46.52
Duplicate
Value
19.6
6.70
52.93
52.07
22.20
23.05
22.20
21.34
21.34
21.34
15.37
15.37
5.10
2.76
19.2
4.09
52.93
53.78
35.85
36.71
24.76
25.61
5.66
5.85
20.8
9.22
53.78
53.78
40.98
42.68
25.61
26.46
5.12
3.84
19.8
7.66
52.44
52.44
51.60
51.60
45.68
45.66
RPD%
2
<1
0
2
4
0
4
4
4
4
5
5
3
2
2
2
2
0
2
0
3
0
<1
2
2
2
0
2
2
2
0
0
4
4
4
<1
2
2
0
0
0
2
RPD%
Limits
<30
<30
<10
<10
<10
<10
<10
<10
<10
<10
<10
<10
<30
<30
<30
<30
<10
<10
<10
<10
<10
<10
<30
<30
<30
<30
<10
<10
<10
<10
<10
<10
<30
<30
<30
<30
<10
<10
<10
<10
<10
<10
RPDMet
Y/N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
A-2

-------
      APPENDIX B
ACCURACY CALCULATIONS

-------
ACCURACY CALCULATIONS
CTC
SAMPLED)
Batch Sample
Batch Sample
Batch Sample
0914G-CC
0914H-CC
0914F-CT
0914F-CT
0914F-CTD
0914F-CTD
0921H-M
0921H-M
0921H-M
0921H-CC
0921F-CT
0921F-CT
Batch Sample
Batch Sample
Batch Sample
0928H-CC
0928F-CT
0928F-CT
1005H-CC
1005H-CC
1005H-CC
1005H-CC
1005F-CT
1005F-CT
1012H-M
1012H-M
1012H-M
1012H-CC
1012F-CT
1012F-CT
1019H-CC
1019H-CC
1019H-CC
1019H-CC
1019A-CT
1019A-CT
1019A-CTD
1019A-CTD
1019B-CT
1019B-CT
1026H-M
1026H-M
1026H-M
1026H-CC
1026A-CT
1026A-CT
1026B-CT
1026B-CT
1026B-CTD
1026B-CTD
1026C-CT
1026C-CT
1102H-M
1102H-M
Parameter
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Units
mg/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g4
g/L
g/L
g/L
mg/L
mg/L
Sample
Value
<0.2
<0.01
15.6
43.3
4.31
48.1
46.7
48.6
46.7
0.32
3.36
15.4
2.83
48.1
48.1
0.2
0.01
9.87
1.86
48.1
49.02
1.07
6.29
15.5
5.59
47.5
47.52
0.73
7.07
15.3
6.26
50.5
50.5
1.41
6.76
15.5
5.77
51.5
51.48
51.5
51.48
20.6
19.73
0.71
4.14
14.9
3.57
52.7
52.21
21.3
21.34
21.3
22.3
17.1
17.07
0.31
2.04
Sample
+Spike Value
4.52
0.479
20.4
88.9
9.03
93.1
74.16
93.9
73.30
5.32
3.76
19.9
7.75
91.4
71.37
4.98
0.48
14.8
6.89
91.9
72.65
6.03
6.82
20.6
15.6
90.7
71.72
5.83
7.60
20.4
16.2
94.0
74.0
6.37
7.15
20.2
15.6
94.3
75.30
94.3
74.65
63.4
43.70
5.67
4.61
19.7
8.35
93.9
75.12
64.0
45.24
64.0
45.24
59.7
40.98
5.52
2.45
Spike
Value
5.00
0.500
5.00
50.0
5.00
43.0
24.0
43.0
24.0
5.00
0.500
5.0
5.0
43.0
24.0
5.00
0.500
5.0
5.0
43.0
24.0
5.00
0.500
5.0
10.0
43.0
24.0
5.00
0.500
5.0
10.0
43.0
24.0
5.00
0.500
5.0
10.0
43.0
24.0
43.0
24.0
43.0
24.0
5.00
0.500
5.0
5.0
43.0
24.0
43.0
24.0
43.0
24.0
43.0
24.0
5.00
0.500
Recovery %
90
96
96
91
94
104
114
105
110
100
80
90
98
100
97
100
96
99
101
101
98
99
106
102
100
100
100
102
106
102
99
101
97
99
78
94
98
99
99
99
96
99
99
99
94
96
96
95
95
99
99
99
95
99
99
104
82
Target %
Recovery
75-125
75-125
75-125
75-125
75-125
80-120
80-120
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
80-120
80-120
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
80-120
80-120
80-120
80-120
80-120
80-120
75-125
75-125
Accuracy
Met? Y/N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
       B-l

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CTCTD
1102H-M
1102H-CC
1102A-CT
1102A-CT
1102B-CT
1102B-CT
1102C-CT
1102C-CT
1102C-CTD
1102C-CTD
1102D-CT
1102D-CT
1109H-M
1109H-M
1109H-M
1109H-CC
1109A-CT
1109A-CT
1109B-CT
1109B-CT
1109C-CT
1109C-CT
1116H-M
1116H-M
1116H-M
1116H-CC
1116A-CT
1116A-CT
1116B-CT
1116B-CT
1116C-CT
1116C-CT
1130H-M
1130H-M
1130H-M
1130H-CC
1130A-CT
1130A-CT
1130B-CT
1130B-CT
1130C-CT
1130C-CT
Parameter
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Aluminum
Chromium
Magnesium
Hex chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Hex chrome
Total chrome
Units
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
mg/L
mg/L
mg/L
mg/L
g/L
g/L
g/L
g/L
g/L
g/L
Sample
Value
15.0
1.57
52.9
52.84
22.5
23.08
22.5
21.91
21.9
21.62
15.9
15.65
0.55
2.46
15.5
1.66
53.5
53.78
36.1
36.71
25.3
25.61
0.72
5.53
16.4
4.61
53.8
54.06
41.5
43.25
25.6
26.46
0.46
3.60
16.1
3.06
52.7
52.72
51.6
51.60
45.7
46.52
Sample
+Spike Value
19.3
6.68
96.0
75.98
64.8
46.10
64.0
44.39
64.0
44.39
58.8
38.42
5.25
2.81
19.6
4.18
96.4
77.66
78.5
60.61
68.2
48.6
5.69
5.96
21.2
9.41
95.5
76.83
83.6
67.44
66.5
50.37
5.32
4.03
20.6
7.68
94.7
75.2
93.8
75.28
87.9
69.36
Spike
Value
5.00
5.0
43.0
24.0
43.0
24.0
43.0
24.0
43.0
24.0
43.0
24.0
5.00
0.500
5.00
2.50
43.0
24.0
43.0
24.0
43.0
24.0
5.00
0.500
5.00
5.0
43.0
24.0
43.0
24.0
43.0
24.0
5.00
0.500
5.00
5.0
43.0
24.0
43.0
24.0
43.0
24.0
Recovery %
86
102
100
96
98
95
96
93
97
94
99
94
94
701
82
101
99
99
98
99
99
95
99
86
96
96
97
94
97
100
95
99
97
86
90
92
97
93
98
98
98
95
Target %
Recovery
75-125
75-125
80-120
80-120
80-120
80-120
80-120
80-120
80-120
80-120
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
80-120
80-120
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
80-120
80-120
80-120
80-120
75-125
75-125
75-125
75-125
80-120
80-120
80-120
80-120
80-120
80-120
RPDMet
Y/N
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
Y
1 Accuracy results for this sample may be skewed due to relatively high concentration of sample analyte compared to the spike
concentration.  The Laboratory Control Sample (LCS) was acceptable (91 percent), therefore, the data was approved.  All
remaining accuracy checks for metals were within the goal of 75-125 percent.
                                                      B-2

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          APPENDIX C
REPRESENTATIVENESS CALCULATIONS

-------
REPRESENTATIVENESS CALCULATIONS
CTCW
SAMPLE
0914F-M
0914F-MD
% Difference
0914F-CT
0914F-CTD
% Difference
0921 G-M
0921 G-MD
% Difference
0921 G-CC
0921G-CCD
% Difference
0928H-M
0928H-MD
% Difference
0928H-CC
0928H-CCD
% Difference
1019A-M
1019A-MD
% Difference
1019A-CT
1019A-CTD
% Difference
1026B-M
1026B-MD
% Difference
1026B-CT
1026B-CTD
% Difference
1102C-M
1102C-MD
% Difference
1102C-CT
1102C-CTD
% Difference
Aluminum
(EPA6010B)
3.6
4.2
-14.3
-
-
-
0.0026
0.0027
-3.7
-
-
-
0.0004
0.0004
0.0
-
-
-
4.5
4.3
4.8
-
-
-
2.0
2.0
0.0
-
-
-
2.6
2.3
11.5
-
-
-
Chromium
(EPA6010B)
49.0
53.0
-7.5
-
-
-
0.031
0.032
-3.1
-
-
-
0.0021
0.0021
0.0
-
-
-
46.0
45.0
2.2
-
-
-
20.0
19.0
5.0
-
-
-
20.0
18.0
10.0
-
-
-
Magnesium
(EPA6010B)
0.27
0.26
3.7
-
-
-
0.015
0.016
-6.2
-
-
-
0.015
0.015
0.0
-
-
-
0.32
0.27
16.0
-
-
-
0.12
0.12
0.0
-
-
-
0.13
0.12
7.7
-
-
-
Hex Chrome
(Titration)
-
-
-
48.0
48.6
-1.2
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
51.5
51.3
0.4
-
-
-
21.3
21.3
0.0
-
-
-
22.5
21.9
2.7
Tri
Chrome
(Titration)
-
-
-
<1.1
<1.1
0.0
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
<1.1
<1.1
0.0
-
-
-
<1.1
<1.1
0.0
-
-
-
<1.1
<1.1
0.0
Hex
Chrome
(SM-3500
CrD)
-
-
-
-
-
-
-
-
-
0.034
0.035
-2.9
-
-
-
0.0019
0.0018
5.3
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
Tri Chrome
(SM-3500
CrD)
-
-
-
-
-
-
-
-
-
ND
ND
0.0
-
-
-
0.00035
0.00036
-7.9
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
-
            C-l

-------