Revision 0 - 01/08/02
ElV
Concurrent
crc^ Technologies.
Corporation
U.S. Environmental Protection Agency
Environmental Technology Verification Program
For Metal Finishing Pollution Prevention Technologies
Verification Test Plan
for the
Evaluation of Lobo Liquids Rinse Water Recovery System
Revision 0
January 8, 2002
Concurrent Technologies Corporation is the Verification Partner for the EPA EW Metal
Finishing Pollution Prevention Technologies Center under EPA Cooperative Agreement No.
CR826492-01-0.
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etV
Concurrent
crcs Technologies
Corporation
U.S. Environmental Protection Agency
Environmental Technology Verification Program
For Metal Finishing Pollution Prevention Technologies
Verification Test Plan
for the
Evaluation of Lobo Liquids Rinse Water Recovery System
Revision 0
January 8, 2002
i
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TITLE: Environmental Technology Verification Program for Metal Finishing
Pollution Prevention Technologies Verification for the Evaluation of Lobo
Liquids Rinse Water Recovery System.
ISSUE DATE: January 8, 2002
DOCUMENT CONTROL
This document will be maintained by Concurrent Technologies Corporation in accordance with
the EPA Environmental Technology Verification Program Quality and Management Plan for the
Pilot Period 1995-2000 (EPA/600/R-98/064). Document control elements include unique issue
numbers, document identification, numbered pages, document distribution records, tracking of
revisions, a document MASTER filing and retrieval system, and a document archiving system.
ACKNOWLEDGMENT
This is to acknowledge Valerie Whitman for her help in preparing this document.
Concurrent Technologies Corporation is the Verification Partner for the EPA ETV Metal
Finishing Pollution Prevention Technologies Center under EPA Cooperative Agreement
No. CR826492-01-0.
11
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Environmental Technology Verification Program for Metal Finishing Pollution Prevention
Technologies Verification Test Plan for the Evaluation of the Lobo Liquids Rinse Water
Recovery System.
PREPARED BY:
James Toiler
€TC Project Manager
tA
G0orgt CiBtmig
HIV-Ml ProjectManager
| / O- O 1.
Dtur
APPROVED BY:
/? /?
Clinton Twitiey
CTCQA Manager
/// >'¦'
(5 ¦
Dvm Brown
€7C* ETV-MF Program Manager
Ckwrge MoSft (
pM3g>ltL.
LPA t-TY Ccnfi'r VtnMQer
fan Tunnichffe
Lobo Liquids LLC
0
Uk, u
fj Date
///Vo ^
J KcUvKfowry
Gull Industries
[ii j * h.
Jate
Signature denotes acceptance of this test plan as written regarding experimental design, quality assurance, test and
analysis methods, operational procedures, equipment configuration, project management and current system
operating effectiveness prior to testing.
ill
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
1.1 Background 1
1.2 Data Quality Obj ectives (DQO) 2
2.0 TECHNOLOGY DESCRIPTION 3
2.1 Theory of Operation 3
2.2 Description of the Lobo Liquids System 3
2.3 Description of Electrocoagulation System 5
2.4 Commercial Status 6
2.5 Environmental Significance 6
2.6 Local Installation 6
2.6.1 Electrocoagulation/Ion Exchange Polishing Mode 10
2.6.2 Ion Exchange Primary Treatment Mode 12
3.0 EXPERIMENTAL DESIGN 13
3.1 Test 1-Combined Electrocoagulation/Lobo Liquids System Test 13
3.1.1 Test Goals and Objectives 13
3.1.2 Critical and Non-Critical Measurements for Test 1 13
3.1.3 Test Matrix for Test 1 14
3.2 Test 2-Lobo Liquids System Used as Standalone Treatment System 16
3.2.1 Test Goals and Objectives 16
3.2.2 Critical and Non-Critical Measurements 17
3.2.3 Test Matrix for Test 2 17
3.3 Testing and Operating Procedures 18
3.3.1 Set-Up and System Initialization Procedures 19
3.3.1.1 Test 1 19
3.3.1.2 Test 2 19
3.3.2 System Operation 19
3.3.3 Sample Collection and Handling 21
3.3.3.1 Test 1 Sample Collection and Handling 21
3.3.3.2 Test 2 Sample Collection and Handling 22
3.3.3.3 Additional Information on Sample Collection and Handling .... 23
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3.3.4 Process Measurements and Information Collection 23
3.3.4.1 Duration of Treatment and Wastewater Volume Processed 23
3.3.4.2 Polymer Usage Data 24
3.3.4.3 Volume of Ion Exchange Regenerant 25
3.3.4.4 Ion Exchange System Regeneration Chemical Use 25
3.3.4.5 pH 26
3.3.4.6 Quantity of Sludge 28
3.3.4.7 Electricity Use Data 28
3.3.4.8 System Operation and Maintenance Data 29
3.3.4.9 Cost Data 29
3.3.4.10 Steel Plate Consumption 29
3.3.4.11 Ion Exchange System Operational Data 29
3.4 Analytical Procedures 29
QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS 30
4.1 Quality Assurance Objectives 30
4.2 Data Reduction, Validation, and Reporting 30
4.2.1 Internal Quality Control Checks 30
4.2.2 Calculation of Data Quality Indicators 32
4.2.2.1 Precision 32
4.2.2.2 Accuracy 32
4.2.2.3 Completeness 33
4.2.2.4 Comparability 35
4.2.2.5 Representativeness 35
4.2.2.6 Sensitivity 35
4.3 Additional Data Calculations 36
4.3.1 Ability to Meet Metal Finishing and Proposed MP&M Limitations 36
4.3.2 Mass Balance 37
4.3.3 Pollutant Removal Efficiency 38
4.3.4 Reusability of Treated Wastewater 39
4.3.5 Energy Use 39
4.3.6 Cost Analysis 39
4.3.7 Sludge Generation Analysis 40
4.3.8 Environmental B enefit 40
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4.4 Test Plan Modifications 40
4.5 Quality Audits 41
5.0 PROJECT MANAGEMENT 41
5.1 Organization/Personnel Responsibilities 41
6.0 EQUIPMENT AND UTILITY REQUIREMENTS 42
7.0 HEALTH AND SAFETY PLAN 42
7.1 Hazard Communication 42
7.2 Emergency Response Plan 43
7.3 Hazard Controls Including Personal Protective Equipment 43
7.4 Lockout/Tagout Program 43
7.5 Material Storage 43
7.6 Safe Handling Procedures 43
8.0 WASTE MANAGEMENT 43
9.0 TRAINING 44
10.0 REFERENCES 44
11.0 DISTRIBUTION 45
LIST OF FIGURES
Page
Figure 1. Diagram of Lobo Liquids System 4
Figure 2. Diagram of Electrocoagulation System 5
Figure 3. Photograph of Gull Industries' Decorative Chromium Plating Line 6
Figure 4. 20,000-Liter Equalization Tank 8
Figure 5. Diagram of the Combined Treatment System at Gull Industries 9
Figure 6. Photograph of the Ion Exchange Polishing System Installed at Gull Industries 11
Figure 7. Diagram of Lobo Liquids System Used as Primary Treatment System 12
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LIST OF TABLES
Table 1. Summary of Current and Proposed Regulations Applicable to Gull Industries 7
Table 2. Preliminary Analytical Results 12
Table 3. Test Matrix for Test 1: Combined Electrocoagulation System and Ion
Exchange Polishing System Test 15
Table 4. Test Objectives and Related Test Measurements for Test 1: Evaluation
of the Combined Electrocoagulation and Lobo Liquids Systems 16
Table 5. Test Matrix for Test 2: Standalone Lobo Liquids System 18
Table 6. Test Objectives and Related Test Measurements for Test 2: Standalone
Lobo Liquids System 18
Table 7. Sampling Sequence for Batch Treatment and Test Runs for Test 1 20
Table 8. Sampling Locations, Frequency and Parameters for Test 1 24
Table 9. Sampling Locations, Frequency and Parameters for Test 2 25
Table 10. Test 1 Sample Quantities from Each Sampling Point 27
Table 11. Test 2 Sample Quantities from Each Sampling Point 28
Table 12. Summary of Analytical Tests and Requirements 30
Table 13. QA Objectives 34
Table 14. Applicable Pretreatment Standards for Existing Sources for the Metal Finishing
Subcategory (40 CFR 433) 36
Table 15. Applicable Proposed Pretreatment Standards for Existing Sources for
the MP&M Job Shop Subcategory (66 FR 424) 37
LIST OF APPENDICES
APPENDIX A: Data Collection Forms for Electrocoagulation and Lobo Liquids
Systems A-l
APPENDIX B: Test Plan Modification Request B-l
APPENDIX C: ETV-MF Operation Planning Checklist C-l
APPENDIX D: Job Training Analysis Form D-l
APPENDIX E: ETV-MF Project Training Attendance Form E-l
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ACRONYMS & ABBREVIATIONS
|iS
Microsiemens
amp
Ampere
BPT
Best Practical Treatment
C
Celsius
cfm
Cubic Feet per Minute
coc
Chain of Custody
CTC
Concurrent Technologies Corporation
DAF
Dissolved Air Flotation
DC
Direct Current
DQO
Data Quality Objectives
EC
El ectrocoagul ati on
EHS
Extremely Hazardous Substances
EPA
U.S. Environmental Protection Agency
ETV-MF
Environmental Technology Verification - Metal Finishing
ft
Feet
g
Gram
gal
Gallon
gpd
Gallon per Day
gpm
Gallon per Minute
HEM
Hexane Extractable Material
hp
Horsepower
hr
Hour
ICP-AES
Inductively Coupled Plasma-Atomic Emission Spectroscop
ID
Identification
IDL
Instrument Detection Limit
JTA
Job Training Analysis
kg
Kilogram
kW
Kilowatt
kWh
Kilowatt Hour
L
Liter
L/min
Liter per Minute
LM
Laboratory Manager
Lobo Liquids
Lobo Liquids Rinse Water Recovery System
System
m3
Cubic Meters
MDL
Method Detection Limit
mg/L
Milligram/Liter
min
Minute
mL
Milliliter
MP&M
Metal Products & Machinery
MRL
Method Reporting Limit
MSDS
Material Safety Data Sheet(s)
NA
Not Applicable
ND
Not Detected
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ACRONYMS & ABBREVIATIONS (continued)
NR
Not Regulated
NRMRL
National Risk Management Research Laboratory
O&G
Oil and Grease
O&M
Operating & Maintenance
P
Percent Recovery
PARCCS
Precision, Accuracy, Representativeness, Comparability, Completeness and
Sensitivity
pH
Value used to express acidity or alkalinity
PLC
Programmable Logic Controller
POC
Point of Contact
POTW
Publicly Owned Treatment Works
PPE
Personal Protective Equipment
ppm
Parts per Million
PQL
Practical Quantification Limit
PSES
Pretreatment Standards for Existing Sources
psi
Pounds per Square Inch
QA/QC
Quality Assurance/Quality Control
QMP
Quality Management Plan
R
Raw Wastewater Samples
RPD
Relative Percent Difference
Rx
Reactor
SGP
Strategic Goals Program
SOP
Standard Operating Procedure
SR
Sample Result
SSR
Spiked Sample Result
STL
Severn Trent Laboratories
T
Treated Wastewater Samples
TDS
Total Dissolved Solids
TOC
Total Organic Carbon
TOP
Total Organic Parameter
TSA
Technical System Audit
TSS
Total Suspended Solids
U.S.
United States
IX
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1.0 INTRODUCTION
The purpose of this test plan is to document the objectives, procedures, equipment, and
other aspects of testing that will be utilized during verification testing of the Lobo
Liquids Rinse Water Recovery System (Lobo Liquids system). This test plan has been
prepared in conjunction with the U.S. Environmental Protection Agency's (EPA's)
Environmental Technology Verification Program for Metal Finishing Pollution
Prevention Technologies (ETV-MF). The objective of this program is to identify
promising and innovative pollution prevention technologies through EPA-supported
performance verifications. The results of the verification test will be documented in a
verification report that will provide objective performance data to metal finishers,
environmental permitting agencies, and industry consultants. A verification statement,
which is an executive summary of the verification report, will be prepared and signed by
the EPA National Risk Management Research Laboratory (NRMRL) Director and the
Concurrent Technologies Corporation ETV-MF Program Manager.
1.1 Background
The Lobo Liquids system is designed to process and recover for reuse wastewaters
generated by metal finishing processes. This wastewater usually contains dissolved
metals and other chemicals that are associated with the plating baths. At metal finishing
facilities, rinsing operations generate the majority of wastewater. A typical metal
finishing job shop discharges approximately 34,000 gallons per day (gpd) of wastewater,
which contains a residual concentration of pollutants after treatment. The average metal
finishing facility pays about $30,000/per year in water and sewer charges (based on
industry average of $3.50/1,000 gal) [Ref. 1], Recovering and reusing wastewater
reduces pollutant loadings on publicly owned treatment works (POTWs) or receiving
streams and reduces operating costs.
The focus of testing will be to determine the quality of the effluent produced by the Lobo
Liquids system at a pre-set flow rate and the quantity and characteristics of by-products
produced during processing. In terms of effluent water quality, of particular interest is
the ability of the treatment system to meet existing effluent standards for the Metal
Finishing point source category [Ref. 2] and proposed effluent standards for the Metal
Products and Machinery (MP&M) point source category [Ref. 3], The metal finishing
regulations were promulgated in July 1983, and for most metal finishing companies are
the applicable current standards. The proposed MP&M limitations were published on
January 3, 2001. EPA must take final action on the proposed rule by December 2002.
This final action does not have to be new limits, but can be a decision by the Agency not
to impose any additional regulations on the metal finishing industry. If new limits are
imposed, the MP&M limitations will replace the metal finishing limitations for most
metal finishing companies.
Testing of the Lobo Liquids system will be conducted at Gull Industries, located in
Houston, Texas. Gull Industries is a metal finishing job shop that performs decorative
chromium electroplating (consists of cleaning and nickel and chromium electroplating),
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electroless nickel plating, and passivation of stainless steel. A Lobo Liquids system has
been installed at Gull Industries since January 2001. That system has a design flow rate
of 83 liters/minute (L/min) (22 gallons per minute (gpm)) and it can be operated in a
batch or continuous mode. Also, it can be operated as a standalone treatment system or
as a polishing technology. At Gull Industries, an electrocoagulation system is also
installed, which is a 38-L/min commercial unit with two electrocoagulation reactors
(Rxs) connected in series.
The verification test will evaluate the Lobo Liquids system in two modes:
• Ion exchange polishing system following an electrocoagulation process
• Ion exchange standalone treatment system
During the first test, wastewater from the Gull Industries electroplating line will be
processed through the electrocoagulation system and subsequently processed through the
Lobo Liquids system. Testing will consist of three runs, with each run treating
approximately 3,400 L of wastewater. During testing, samples of raw and treated
wastewater and sludge, and ion exchange regenerate, will be collected and analyzed.
During the second test, the Lobo Liquids system will treat the raw wastewater as a
standalone technology. Prior to this test, the Lobo Liquids system will be regenerated. It
will then be put into service and will process wastewater until regeneration is required.
During testing, samples of raw and treated wastewater, and ion exchange regenerate, will
be collected and analyzed.
This test plan has been structured based on a format developed for ETV-MF projects.
This document describes the intended approach and explains testing plans with respect to
areas such as test methodology, procedures, parameters, and instrumentation. Also
included are quality assurance (QA)/quality control (QC) requirements of this task that
will ensure the accuracy of data, data interpretation procedures, and worker health and
safety considerations.
1.2 Data Quality Objectives (DQO)
The systematic planning elements of the data quality objectives process identified in
"Guidance for the Data Quality Objectives Process" (EPA QA/G-4, August 2000) [Ref.
4] were specifically utilized during preparation of this verification test plan. A project
team composed of representatives from CTC, the testing organization, the technology
vendor, the host site, the analytical laboratory, and EPA assisted in preparing this test
plan. The team jointly developed the test objectives; critical and non-critical
measurements; test matrix; sample quantity, type, and frequency; analytical methods; and
QA objectives to arrive at an optimized test designed to verify the performance of the
technology.
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2.0 TECHNOLOGY DESCRIPTION
2.1 Theory of Operation
The Lobo Liquids system consists of three skid-mounted, ion exchange pressure vessels,
with interconnecting piping and control valves. It is also equipped with a personal
computer based control system running under Windows.
Ion exchange is a chemical reaction wherein an ion from solution is exchanged for a
similarly charged ion attached to an immobile solid particle (i.e., ion exchange resin).
Ion exchange reactions are stoichiometric (i.e., predictable based on chemical
relationships) and reversible. The strategy employed in using this technology is to
exchange somewhat harmless ions (e.g., hydrogen and hydroxyl ions), located on the
resin, for ions of interest in the solution (e.g., regulated metals). In the most basic sense,
ion exchange materials are classified as either cationic or anionic. Cation resins
exchange hydrogen ions for positively charged ions such as nickel, copper and sodium.
Anion resins exchange hydroxyl ions for negatively charged ions such as chromates,
sulfates and cyanide [Ref. 5],
Ion exchange resins are usually contained in vessels referred to as columns. The basic
column consists of a resin bed, which is retained, in the column with inlet and outlet
screens, and service and regeneration flow distributors. Piping and valves are required to
direct flow, and instrumentation is required to monitor water quality and control
regeneration timing. The systems are operated in cycles consisting of the following four
steps:
1) Service (exhaustion) - Water solution containing ions is passed through the ion
exchange column or bed until the exchange sites are exhausted.
2) Backwash - The bed is washed (generally with water) in the reverse direction of the
service cycle in order to expand and resettle the resin bed.
3) Regeneration - The exchanger is regenerated by passing a concentrated solution of
the ion originally associated with it (usually a strong mineral acid or base) through
the resin bed.
4) Rinse - Excess regenerant is removed from the exchanger, usually by passing water
through it.
2.2 Description of the Lobo Liquids System
The Lobo Liquids system consists of skid-mounted pressure vessels, with interconnecting
piping and control valves. The process parameters and equipment status are constantly
monitored and fed back to the control system and can be viewed on a display located in
the control panel, which is also mounted on the skid.
A schematic diagram of the Lobo Liquids system is shown in Figure 1. The system
operates by receiving influent from a tank, via a three-way valve and the suction side of a
pump. The water is then discharged from the pump under pressure, and is monitored for
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pH, specific conductance, pressure, and flow. The resultant analogue signals are sent to
the control system for subsequent processing and display. Each of the analogue signals
has two high-level and two low-level alarms. The alarms cause the valve systems to
either open or close, which cause a change of direction or stopping of flow. The water is
allowed to enter the top of the first vessel containing a cation resin to remove the initial
shock loading of heavy metals, whereupon it exits at the bottom of that vessel.
Figure 1. Diagram of Lobo Liquids System
The partially de-ionized water then enters the second and third vessels (anion columns) in
the same manner as the first vessel, and there the remaining ionic loading is removed.
The resultant discharge from the third vessel is again monitored for specific conductance
and can then be reused in the metal finishing process.
The contaminants from the influent (i.e., metal cations) and anions (hexavalent chromium
and nonmetals) will remain in each of the three vessels bonded to each of the special
purpose resins. The water is allowed to flow continuously through the system until such
time that the resin is exhausted (i.e., its ability to remove cations and anions from the
water is ended). This is determined by the specific conductance of the water exiting the
system at the third vessel. At this point the system will go off line (usually outside
production hours) and regenerate itself in situ.
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The regeneration process (the process of removing cations and anions from the resin,
which were captured during normal operation) is carried out automatically. Each vessel
will regenerate itself in turn starting with the first vessel. Passing acids and/or bases over
the resins, which will remove the captured cations and anions, carries out regeneration of
the resin. City water is used as a rinse following regeneration. This regenerant will exit
each of the vessels and be captured in the regenerant storage for subsequent processing
and disposal. At this point the unit will then be ready to go back on line for the
processing of influent.
2.3 Description of Electrocoagulation System
Various configurations of the electrocoagulation system are in use. A diagram of a
typical system is shown in Figure 2. Wastewater initially flows into the
electrocoagulation Rx. Systems can be configured with one or more Rxs in series. In the
electrocoagulation Rx, a direct current (DC) (100 to 120 amperes (amp), 25 to 40 volts
DC) is applied using an associated rectifier and sacrificial anode plates. The typical
residence time in the reactor is 14 seconds. Reactions occur in the Rx, including the
reduction of Cr+6 to Cr+3 and the generation of insoluble oxides and hydroxides. The
wastewater flows from the Rx to a de-foam tank, which has a residence time of 30 min.
Electrolysis gases are separated from the wastewater in the de-foam tank, which is
agitated by a mechanical mixer. A polymer is sometimes added to improve floe
formation as the wastewater exits the de-foam tank. The wastewater is then transferred
through a sludge thickener to a conventional clarifier where solids separation takes place.
The overflow from the clarifier is discharged to the intermediate storage tank. The
underflow from the clarifier goes to a thickener. Thickened sludge is dewatered on a
filter press and sent off-site for recovery or disposal.
Solids
Wastewater
Treated Wastewater
is Discharged
Filtrate
~Returned to
Treatment
Process
Solids
Figure 2. Diagram of Electrocoagulation System
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2.4 Commercial Status
The Lobo Liquids system is a commercial product. The electrocoagulation system is a
separate commercial product.
2.5 Environmental Significance
The Lobo Liquids system reportedly removes toxic metals to near or below detection
limits and effectively deionizes wastewater. Resultant discharges of the wastewater
contain little or no measurable concentrations of toxic metals. Also, the processed water
may be sufficiently purified for reuse in the electroplating process, which may entirely
eliminate the discharge of liquid to the sewer or receiving streams.
2.6 Local Installation
The Lobo Liquids and electrocoagulation systems will be tested at Gull Industries,
located in Houston, Texas. Gull Industries is a metal finishing job shop that performs
nickel and chromium electroplating, electroless nickel-plating, and passivation using
nitric acid. The current discharge limits for Gull Industries are shown in Table 1.
A photograph of the decorative chromium plating line is shown in Figure 3.
Figure 3. Photograph of Gull Industries' Decorative Chromium Plating Line
Gull Industries has established water-recycling specifications that must be met in order to
reuse treated wastewater. These specifications are:
• Total Dissolved Solids (TDS) of 250 mg/L
• Specific conductance: maximum of 500 microsiemens (|lS)
• pH: within the range of 5.0 to 9.0 standard units
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The electrocoagulation system installed at Gull Industries is rated at 38 L/min and has
dual electrocoagulation Rxs, piped in series. The Lobo Liquids system installed at Gull
Industries is rated at 83 L/min. It has one cation column (1.02 cubic meters (m3) of resin)
and two anion columns (total of 1.13 m3 of resin).
Parameter
Current Gull Industries
Limitations
MP&M Pretreatment Standards
for Existing Sources (PSES)
Job Shop Subcategory
Daily Max.,
mg/L
4-Day Avg.,
mg/L
Daily Max.,
mg/L
Monthly Avg.,
mg/L
Cyanide T
NR
NR
0.21
0.13
Cyanide A
5.0
2.7
0.14
0.07
Cadmium
1.2
0.7
0.21
0.09
Chromium*
3.0
1.0
1.3
0.55
Copper*
3.0
2.0
1.3
0.57
Lead
0.6
0.4
0.12
0.09
Mercury*
0.02
0.01
NR
NR
Manganese
NR
NR
0.25
0.10
Molybdenum
NR
NR
0.79
0.49
Nickel*
3.0
2.0
1.5
0.64
Silver*
2.0
1.0
0.15
0.06
Tin
NR
NR
1.8
1.4
Zinc
2.61
1.48
0.35
0.17
O&G (local
limit)
100
NR
NR
NR
O&G (as
HEM)
NR
NR
52
26
TSS
NR
NR
NR
NR
TOC
NR
NR
78
59
TOP
NR
NR
9.0
4.3
Sulfide (as S)
NR
NR
31
13
NR = Not Regulated
*Local standard only (grab/composite instead of daily max./4-day average).
Current Gull Industries limitations are based on a combination of local and Federal standards (40 CFR 413
and 40 CFR 433).
O&G (as HEM) are not regulated under pretreatment standards for the Job Shop subcategory. However, it is
regulated under the Best Practical Treatment (BPT) limitations for direct dischargers in the Job Shop
subcategory (66 FR 423). The values shown are the BPT proposed limitations.
Table 1. Summary of Current and Proposed Regulations Applicable to Gull Industries
The majority of wastewater generated at Gull Industries is rinsewater and to a lesser
extent spent cleaning baths. Approximately 7,500 L of wastewater is generated on a
daily basis at Gull Industries. The concentration of regulated metals in the wastewater is
typically above 300 mg/L (mostly nickel and chromium). Raw wastewater is stored in a
20,000-L equalization tank (Figure 4) prior to treatment.
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Figure 4. 20,000-Liter Equalization Tank
A diagram of the combined electrocoagulation/ion exchange system installed at Gull
Industries is shown in Figure 5. It consists of electrocoagulation (two Rxs in series), de-
foam tank, flow-through sludge thickener, clarifier, filter press, ion exchange system,
storage tanks, and associated pumps, piping and controls. The treatment tanks (de-foam
tank, flow-through sludge thickener, clarifier) have a total liquid capacity of
approximately 3,400 L (900 gal).
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Sampling
Point 1
Influent (Raw
Wastewater from
Equalization tank)
Storage
Tanks
1 or 2
Sampling
Point 2
+P asses
1 and 2
Caustic
Final
Storage
~ »
Anion
Column
Sampling^/
Point 6 .1.
Conductivity
measurement
Rectifier
ir ir
Rx
Caustic
T T
Anion
Column
Overflow to
Intermediate
Storage Tank
Sampling
Point 5
Acid
T ~
Overflow from
Clarifier
-Filter
Press Filtrate
Solids
Cation
Column
ter-
Inter-
mediate
Storage
Tank
Sludge
Hopper
pH, conductivity,
Sampling
flow, and pressure p0jut 3
measurements
Regen-^:
erant
Storage
Filtrate
"To Intemiediate
Storage Tank
Sampling
Point 4
Sampling
Point 7
Regeneration Flow
Figure 5. Diagram of the Combined Treatment System at Gull Industries
The following indicates the size and utility requirements of the Lobo Liquids system
installed at Gull Industries:
• Flow Rate: 83 L/min (22 gpm)
• Electrical: 2.2 Kilowatts (kW)
• Air: 1 cubic foot per minute (cfm) @ 80 pounds per square inch (psi) intermittently
• City Water: Max flow 13.6 L/min (3.6 gpm), for regeneration only
• Dimensions: Length 15 feet (ft)
Width 8 ft
Height 10 ft
The Lobo Liquids system has the following parameters monitored and continuously
logged to disk:
• Inlet specific conductance (|iS)
• pH
• Pump discharge pressure (psi)
• Flow (gpm)
• Outlet specific conductance (|iS)
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All parameters are logged by software for subsequent analysis and archived for viewing
at a later date. All events are date and time stamped. As part of the after sales back up,
the system is connected to a modem, so that if a problem should arise the manufacturer is
able to remotely interrogate the system for troubleshooting purposes. It also allows
downloading of software updates.
The Gull Industries treatment system can be operated in two different modes, as
described below.
2.6.1 Electrocoagulation/Ion Exchange Polishing Mode
In this mode, wastewater treatment is performed on a batch basis. Each batch
consists of approximately 3,400 L (900 gal) and the processing rate is 38 L/min.
Approximately one to two batches are processed each day. During treatment,
wastewater is pumped from the 20,000-L equalization tank through the Rx.
Wastewater exiting the Rx is diverted to one of two storage tanks (Tanks 1 and 2).
Once the entire batch has been processed, the wastewater in that storage tank is
tested using bench-top methods1. If the wastewater is insufficiently treated, it is
reprocessed through the electrocoagulation system and diverted to the other
storage tank, and retested using the bench-top methods. If the wastewater is
determined to be sufficiently treated, i.e. the metals concentrations are below
discharge limits as listed in Table 1, the wastewater is reprocessed through the
electrocoagulation unit and the discharge is diverted to the de-foam tank. The
wastewater then flows through the sludge thickener and the clarifier and is
collected in the intermediate storage tank. From this point, the wastewater is
processed through the Lobo Liquids system.
As discussed above, the electrocoagulation process is repeated as necessary until
the bench-top methods indicate that the concentration of regulated parameters is
sufficiently low. Typically, each 3,400 to 3,800-L batch at Gull Industries is
processed through the Rx two times. During the first pass, most of the hexavalent
chromium is reduced to trivalent chromium, and a portion of the dissolved metals
is precipitated. During the second pass, the majority of the dissolved metals are
precipitated. Analytical results of samples collected during a preliminary test of
the technology reflect these expected results (see Table 2).
A photograph of the Lobo Liquids system is shown in Figure 6. The system
operates by pumping wastewater (effluent from electrocoagulation system) from
the intermediate storage tank to the ion exchange system. The wastewater passes
continuously through one cation and two anion columns. The ion exchange
polishing system removes any residual dissolved metals near or below detection
levels and substantially lowers the TDS of the water. Analytical results of
1 A sample of the wastewater from the storage tank in use is subjected to a simulated treatment process, performed
in a beaker. A small amount of polymer is added to the beaker, which causes precipitated solids in the wastewater
to form a dense floe and settle to the bottom of the beaker. The clarified wastewater or "supernatant" is then
sampled and tested for nickel and chromium using bench-top analytical procedures.
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samples collected during a preliminary test are shown in Table 2. The effluent of
the ion exchange system is sufficiently purified that it is used as rinse water on the
Gull Industries metal finishing line. The wastewater may also be discharged to
the city sewer system. The pH and specific conductance of the wastewater are
monitored at various points in the process. The system is capable of treating up to
approximately 45,000 to 90,000 L of wastewater before the resin is exhausted
(i.e., its ability to remove cations and anions from the wastewater is ended). This
is determined by the specific conductance of the water exiting the system at the
third vessel. Once the resin is exhausted, the system will go off line (usually
outside production hours), and regenerate itself in situ.
Figure 6. Photograph of the Ion Exchange Polishing System Installed at Gull Industries
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Raw
(mg/L)
Pass 1
(mg/L)
Pass 2
(mg/L)
IX
TDS
1320
876
655
127
Chromium (Hexavalent)
70.5
<0.015
<0.015
<0.015
Cadmium
0.008
ND
ND
ND
Chromium (T)
89.5
ND
0.287
ND
Copper
1.31
ND
0.011
ND
Iron
6.65
11.1
8.80
ND
Lead
0.252
0.013
ND
ND
Manganese
0.171
2.96
1.71
ND
Molybdenum
ND
ND
ND
ND
Nickel
202
45.6
1.29
1.98
Tin
0.057
ND
ND
ND
Zinc
3.09
0.734
ND
ND
ND = Not Detected
Table 2. Preliminary Analytical Results
2.6.2 Ion Exchange Primary Treatment Mode
A diagram of the Lobo Liquids system at Gull Industries operating as a
standalone treatment system is shown in Figure 7. During operation, the raw
wastewater is pumped from the equalization tank to the Lobo Liquids system, and
the effluent is discharged to the final storage tank, from where it is available for
reuse on the metal finishing line. In this mode, the Lobo Liquids system is
operated continuously during production hours and is idled during non-production
hours. The system is operated in this manner until the resin columns require
regeneration, which occurs approximately every 10 to 20 business days.
Regenerant is collected in the regenerant storage tank.
Effluent
Recycled to Metal
Finishing Rinse Tanks
" 'iT
Caustic
Anion
Column
Caustic
Anion
Column
Acid
Cation
Column
Sampling
Point 5
pH, Conductivity,
Flow, and Pressure
Measurements
Sampling
Point 6
Conductivity
Measurement
Regeneration Flow
Influent (Raw
Wastewater from
Metal Finishing Rinse
Tanks Via Equalization Tank)
Sampling
Point 7
Figure 7. Diagram of Lobo Liquids System Used as Primary Treatment System
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EXPERIMENTAL DESIGN
3.1 Test 1 - Combined Electrocoagulation/Lobo Liquids System Test
3.1.1 Test Goals and Objectives
The overall goals of Test 1 are: (1) evaluate the ability of the combined
electrocoagulation system and Lobo Liquids ion exchange polishing system to
remove pollutants from metal finishing job shop wastewaters with the metal
finishing effluent guidelines used as target effluent concentrations, (2) determine
the ability of the systems to recover water for reuse in the electroplating process,
(3) evaluate the operating characteristics of the systems with respect to sludge and
regenerant generation and operating costs, and (4) evaluate the environmental
benefit by determining the reduction in metals discharged to the city sewer
system.
The following is a summary of primary project objectives. For the installation at
Gull Industries, verification testing is being conducted in order to:
• Determine the ability of the electrocoagulation and ion exchange polishing
systems to remove specific contaminants from wastestreams and meet Gull
Industries' target criteria for water reuse.
• Determine the quantity and chemical characteristics of the sludge generated
by the electrocoagulation treatment process and the cost of sludge disposal.
• Determine the cost of operating the electrocoagulation and ion exchange
polishing systems for the specific conditions encountered during testing:
- Determine the amount and cost of operating and maintenance (O&M)
labor.
- Determine the quantity and cost of chemical reagents used and other
materials (e.g., filters), including ion exchange regeneration.
- Determine the quantity and cost of steel plates (anodes) consumed.
- Determine the quantity and cost of energy consumed by operating the
systems.
• Quantify the environmental benefit by determining the reduction in metals
discharged to the sewer system beyond that required by the metal finishing
standards.
3.1.2 Critical and Non-Critical Measurements for Test 1
Measurements that will be taken during testing are classified below as either
critical or non-critical. Critical measurements are those that are necessary to
achieve the primary project objectives. Non-critical measurements are those
related to process control or general background readings.
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Critical Measurements:
• volume of wastewater treated (L/run)
• quantity (kilogram (kg)/run) and costs ($/run) of chemical treatment reagents
and other materials used in treatment
• mass of steel plates consumed (kg)/volume processed
• volume of filter press sludge generated (L/test)
• chemical characteristics of raw wastewater (specific conductance (|iS)2, mg/L
of total suspended solids (TSS), O&G (as HEM), total organic carbon (TOC),
cadmium, hexavalent chromium, chromium (T), copper, iron, lead,
manganese, molybdenum, nickel, tin, sulfide (as S), zinc, and TDS)
• chemical characteristics of treated effluent from the electrocoagulation system
(specific conductance (|iS), mg/L of TSS, O&G (as HEM), TOC, cadmium,
hexavalent chromium, chromium (T), copper, iron, lead, manganese,
molybdenum, nickel, tin, sulfide (as S), zinc, and TDS)
• chemical characteristics of treated effluent from the Lobo Liquids system
(specific conductance (|iS), pH, mg/L of TSS, O&G (as HEM), TOC,
cadmium, chromium (+6) chromium (T), copper, iron, lead, manganese,
molybdenum, nickel, tin, sulfide (as S), zinc, and TDS)
• chemical characteristics of filter press sludge from the electrocoagulation
system (density, mg/L of solids, cadmium, chromium (T), copper, lead,
manganese, molybdenum, nickel, tin, and zinc)
• O&M labor requirements (hours/run) and costs ($/run)
• energy use for components of the electrocoagulation and ion exchange
polishing systems (e.g., rectifier, pumps) (kWh/run) and costs ($/run)
• Chemical use during ion exchange regeneration
Non-Critical Measurements:
• electrocoagulation rectifier DC output (amp-hours)
• pH of raw wastewater
• pH of treated wastewater following treatment by the electrocoagulation
system
• flow, pH, and specific conductance of wastewater at various internal points
within the Lobo Liquids system
3.1.3 Test Matrix for Test 1
The verification test will be conducted by processing batches (3,400-L each) of
raw wastewater through the electrocoagulation system and subsequently through
the Lobo Liquids system (each completely treated batch is referred to as a "run").
Each batch will be processed through the electrocoagulation reactors a minimum
2 Specific conductance is a measure of the ability of a water solution to conduct an electrical current. It is
commonly expressed in microsiemens. Specific conductance is related to the type and concentration of ions in
solution and can be used for approximating the dissolved-solids content of the water.
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of three times3 (3 "passes") prior to clarification. Following clarification, the
wastewater will be stored in an intermediate storage tank. It will then be
processed through the Lobo Liquids system and collected in a final storage tank.
For each run, samples will be collected of the initial raw wastewater, the
discharge after each pass through the two electrochemical reactors, the treated
wastewater following clarification, the influent to the Lobo Liquids system, and
the effluent from the Lobo Liquids system. A single sludge sample will be
collected after all the batches of wastewater are treated, and a single sample of the
ion exchange regenerant will be collected after the Lobo Liquids system is
regenerated. The operating conditions for the three runs are shown in Table 3.
Run
Wastewater
Processed
Electrocoagulation
System Conditions
Lobo Liquids System
Conditions
1
3,400 L of raw
wastewater
• 38 L/min
• 3 EC cycles
• 100 to 120 amps
• 25 to 40 volts DC
• Variable pH
• 10-20 mg/L polymer
addition
• 80 L/min
• Variable pH
2
3,400 L of raw
wastewater
• 38 L/min
• 3 EC cycles
• 100 to 120 amps
• 25 to 40 volts DC
• Variable pH
• 10-20 mg/L polymer
addition
• 80 L/min
• Variable pH
3
3,400 L of raw
wastewater
• 38 L/min
• 3 EC cycles
• 100 to 120 amps
• 25 to 40 volts DC
• Variable pH
• 10-20 mg/L polymer
addition
• 80 L/min
• Variable pH
Table 3. Test Matrix for Test 1: Combined Electrocoagulation System and Ion Exchange
Polishing System Test
Test objectives and measurements are summarized in Table 4. The analytical test
parameters selected for this verification test are the parameters found in the Metal
Finishing and proposed MP&M regulations, plus iron, which is contributed to the
wastewater during the electrocoagulation process.
3 As discussed in section 2.6.1, Gull Industries repeats the electrocoagulation process until the wastewater is
sufficiently treated to meet local standards. Typically, the wastewater is processed for two times through the Rx;
however, a greater number of cycles are possible to attain complete treatment.
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Test
Test Objective
Test Measurement
Runs 1 to 3
Determine the ability of the
electrocoagulation system to remove
specific pollutants from wastestreams and
meet the applicable Metal Finishing and
proposed MP&M limitations and water
recycling specifications of Gull industries.
- Volumes of raw wastewater processed.
- Chemical characteristics of the influent
and effluent.
Runs 1 to 3
(combined)
Determine the quantity and chemical
characteristics of the sludge and regenerant
generated by the treatment processes.
- Volumes of raw wastewater treated.
- Quantity, density and chemical
characteristics of the sludge.
- Quantity and chemical characteristics of
the regenerant.
Runs 1 to 3
Determine the cost of operating the
treatment systems for the specific
conditions encountered during testing.
- Volume of raw wastewater processed.
- O&M labor requirements.
- Energy use.
- Input quantity and costs of chemical
treatment reagents (pounds/test run) and
other materials used in treatment.
- Cost of sludge disposal.
- Cost of steel plates consumed.
Runs 1 to 3
(combined)
Quantify the environmental benefit by
determining the reduction in metals
discharged to the Houston POTW beyond
that required by the Metal Finishing
regulations.
- Volume of raw wastewater processed.
- Chemical characteristics of the effluent.
Table 4. Test Objectives and Related Test Measurements for Test 1: Combined
Electrocoagulation and Lobo Liquids Systems
3.2 Test 2 - Lobo Liquids System Used as Standalone Treatment System
3.2.1 Test Goals and Objectives
The overall goals of Test 2 are: (1) evaluate the ability of the Lobo Liquids ion
exchange system to remove pollutants from metal finishing job shop wastewaters
with the metal finishing effluent guidelines used as target effluent concentrations,
(2) determine the ability of the Lobo Liquids system to recover water for reuse in
the electroplating process, (3) evaluate the operating characteristics of the ion
exchange system with respect to regeneration and operating costs, and (4)
evaluate the environmental benefit by determining the reduction in metals
discharged to the city sewer system.
The following is a summary of primary project objectives. For the installation at
Gull Industries, verification testing is being conducted in order to:
• Determine the ability of the Lobo Liquids system to remove specific
contaminants from wastestreams and meet Gull Industries' target criteria for
water reuse.
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• Determine the cost of operating the Lobo Liquids system for the specific
conditions encountered during testing:
• Determine the amount and cost of O&M labor.
• Determine the quantity and cost of chemical reagents used and other materials
(e.g., filters), including ion exchange regeneration.
• Determine the quantity and cost of energy consumed by operating the system.
• Quantify the environmental benefit by determining the reduction in metals
discharged to the sewer system beyond that required by the metal finishing
standards.
3.2.2 Critical and Non-Critical Measurements
Measurements that will be taken during testing are classified below as either
critical or non-critical. Critical measurements are those that are necessary to
achieve the primary project objectives. Non-critical measurements are those
related to process control or general background readings.
Critical Measurements:
• volume of wastewater treated (L/run)
• quantity (kg/run) and costs ($/run) of chemical treatment reagents and other
materials used in treatment
• chemical characteristics of raw wastewater (specific conductance (|iS), mg/L
of TSS, O&G (as HEM), TOC, cadmium, hexavalent chromium, chromium
(T), copper, lead, manganese, molybdenum, nickel, tin, sulfide (as S), zinc,
and TDS)
• chemical characteristics of treated effluent from the Lobo Liquids system
(specific conductance (|iS), pH, mg/L of TSS, O&G (as HEM), TOC,
cadmium, hexavalent chromium, chromium (T), copper, lead, manganese,
molybdenum, nickel, tin, sulfide (as S), zinc, and TDS)
• chemical characteristics of the Lobo Liquids system regenerant (mg/L of
solids, cadmium, chromium (T), copper, lead, manganese, molybdenum,
nickel, tin, zinc)
• O&M labor requirements (hours/run) and costs ($/run)
• energy use for components of the Lobo Liquids system (e.g., pumps)
(kWh/run) and costs ($/run)
Non-Critical Measurements:
• pH and specific conductance of wastewater at various internal points within
the Lobo Liquids system
3.2.3 Test Matrix for Test 2
A single run will be performed during Test 2. The run will be conducted by
processing 80 L/min of raw wastewater through the ion exchange system until the
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system requires regeneration. The Lobo Liquids system will be regenerated prior
to the run and will be operated continuously during production hours at Gull
Industries (approximately 8 hr/day) and idled during non-production hours. The
treated wastewater will be reused on the Gull Industries metal finishing line.
Samples will be collected of the initial raw wastewater and the effluent from the
ion exchange system. A single sample of the ion exchange regenerant will be
collected after the Lobo Liquids system is regenerated. The operating conditions
for the run are shown in Table 5.
Wastewater Processed
Test Conditions
Raw wastewater generated
from rinsing operations at
Gull Industries.
• Regeneration prior to run
• Operate system during production hours
• 80 L/min flow rate
• Stop run when system requires regeneration.
Table 5. Test Matrix for Test 2: Standalone Lobo Liquids System
Test objectives and measurements are summarized in Table 6. The analytical test
parameters selected for this verification test are the parameters found in the Metal
Finishing and proposed MP&M regulations, plus iron, which is present in the Gull
Industries wastewater.
Test
Test Objective
Test Measurement
Run 1
Determine the ability of the
Lobo Liquids system to remove
specific pollutants from
wastestreams and meet the water
recycling criteria of Gull
industries.
- Volumes of raw wastewater processed.
- Chemical characteristics of the influent and
effluent.
Run 1
Determine the quantity and
chemical characteristics of the
regenerant generated by the
treatment processes.
- Volumes of raw wastewater treated.
- Quantity and chemical characteristics of the
regenerant.
Run 1
Determine the cost of operating
the treatment system for the
specific conditions encountered
during testing.
- Volume of raw wastewater processed.
- O&M labor requirements.
- Energy use.
- Input quantity and costs of chemical
treatment reagents (pounds/run) and other
materials used in treatment.
Run 1
Quantify the environmental
benefit by determining the
reduction in metals discharged to
the Houston POTW beyond that
required by the local regulations.
- Volume of raw wastewater processed.
- Chemical characteristics of the effluent.
Table 6. Test Objectives and Related Test Measurements for Test 2: Standalone Lobo
Liquids System
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Testing and Operating Procedures
3.3.1 Set-Up and System Initialization Procedures
3.3.1.1 Test 1
The electrocoagulation and ion exchange systems are currently installed at
Gull Industries, and no additional equipment set-up is required. The
electrocoagulation system will be drained and cleaned and the ion
exchange system will be regenerated prior to testing. The quantity of
chemicals used for regeneration and the total volume of regenerant
collected will be measured and recorded in accordance with procedures
outlined in sections 3.3.4.3 and 3.3.4.4. A diagram of the system
configuration for Test 1 is shown in Figure 5.
Prior to initiating each run, the entry of wastewater into the 20,000-L
equalization tank (raw wastewater storage) will be stopped until the
pumping of the raw wastewater through the electrocoagulation reactor is
complete (approximately 90 min). This procedure will eliminate
variability of raw wastewater characteristics during each batch and allow
for grab sampling of the raw wastewater.
3.3.1.2 Test 2
The ion exchange system will be regenerated prior to testing, and the
regenerant storage tank will be subsequently drained. A diagram of the
system configuration for Test 2 is shown in Figure 7.
3.3.2 System Operation
During Tests 1 and 2, the systems will be operated by Gull Industries according to
the standard procedures found on file at Gull Industries. These are the
procedures used on a daily basis at Gull Industries for conducting wastewater
treatment. Representatives of the electrocoagulation and the ion exchange system
manufacturers will assist with operation of the systems. During Test 1, the source
of raw wastewater during testing is the equalization tank that is part of the
existing Gull Industries wastewater treatment system. The effluent from the Lobo
Liquids system will be collected into the final storage tank and tested by Gull
Industries and reused on their metal finishing lines or discharged to the city sewer
system in accordance with their present discharge permit. During Test 2, the raw
wastewater will be pumped from the equalization tank to the ion exchange
system, and the effluent will discharge to a storage tank (to be installed), from
where it will be pumped for reuse on the metal finishing line.
During Test 1, both the electrocoagulation system and the ion exchange system
will be operated in batch modes, and only one system will be operated at a time.
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Initially the electrocoagulation system will process a batch of raw wastewater, and
the treated water will be collected in the intermediate storage tank. The
electrocoagulation system will then be idled. The ion exchange system will then
be initiated; it will process the batch of wastewater in the intermediate storage
tank and discharge it to the final storage tank. This cycle will be repeated for
each run.
As discussed in section 2.6, the treatment tanks installed at Gull Industries have a
liquid capacity of approximately 3,400L. Prior to the start of the first run, the
tanks will be drained and cleaned. The system will then process one batch (3,400
L) of wastewater using three passes through the Rx units before diverting the
wastewater to the de-foam tank, thickener, and clarifier. Processing the first batch
of wastewater through the electrocoagulation system will fill the treatment tanks
(de-foam, thickener, and clarifier) with wastewater, but little or no discharge of
treated wastewater to the intermediate storage tank will occur. When the second
batch of wastewater is treated and passes through these tanks, this will cause an
overflow of approximately 3,400L of wastewater from the clarifier to the
intermediate storage tank. In effect, the raw wastewater volume from one batch
treatment is discharged to the intermediate storage tank during the treatment of
the subsequent batch. Some commingling of wastewater batches will occur, but
this is not expected to have an effect on the results. Due to the "plug-flow" design
of the system, samples of the raw wastewater from one run can be accurately
paired with intermediate and final discharge samples of the subsequent run to
determine the approximate pollutant removal efficiency of the systems. For
example, when the Run 2 influent is being processed, samples from the
intermediate storage tank, ion exchange influent, and final treated wastewater will
be collected and the results paired with the Run 1 influent results.
During Test 2, the Lobo Liquids system will be set to automatically stop the
service cycle and initiate the regeneration cycle when the specific conductance of
the effluent is above 500 |iS. This event is expected to occur approximately 10 to
20 operating days after initiation of Test 2.
The collection of samples from each batch treatment event during Test 1 and its
relation to the runs is described in Table 7.
Run
Raw
EC
Intermediate
Sludge
rx
Final
Regeneran
Wastewater
Reactor
Treated
Sample
Inf.
Treated
t
Batch
Sample
Discharge
Wastewater
Point 4
Sample
Wastewater
Sample
Point 1
Sample
Sample
Point 5
Sample
Point 7
Point 2
Point 3
Point 6
1
Run 1
Ri
ECi
-
-
-
-
-
2
Run 1/2
r2
ec2
Ii
-
IXi
Fi
-
3
Run 2/3
r3
ec3
I2
-
IX2
f2
-
4
Run 3
r4
-
I3
Si-3
1X3
f3
REG
Table 7. Sampling Sequence for Batch Treatment and Runs for Test 1
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During Test 2, the ion exchange system will be operated continuously during
production hours at Gull Industries, and the system will be idled during non-
production hours. The ion exchange system will be operated in this manner until
the system requires regeneration. The length of Test 2 is expected to be four to
five business days.
3.3.3 Sample Collection and Handling
3.3.3.1 Test 1 Sample Collection and Handling
During Test 1, samples will be collected from the sampling points shown
in Figure 5.
• Raw wastewater (sample point 1). A sampling port has been
installed from which the raw wastewater samples will be collected.
Grab samples of the raw wastewater will be collected 30 min (+/- 10
min) after initiation of each run (four) and placed into the appropriate
sample containers. In order to generate a treated wastewater sample
for the final run, it will be necessary to process a fourth batch of raw
wastewater. A grab sample from this batch will also be collected,
since some commingling of batches will occur. Although this sample
will not be paired with a treated wastewater sample, the analytical
results of this sample may be useful during an evaluation of data. The
sampling sequence is described in Table 7.
• Electrocoagulation reactor discharge (sample point 2). A sampling
port has been installed on the electrocoagulation reactor unit from
which discharge samples will be collected. Grab samples of the
discharge for hexavalent chromium and other metals analyses will be
collected 30 min (+/- 10 min) after the first and second passes are
initiated and placed into the appropriate sample containers. The
electrocoagulation discharge contains both water and precipitated
solids. These samples will be filtered at the analytical laboratory prior
to analyses.
• Intermediate treated wastewater (sample point 3). Treated
wastewater is discharged from the clarifier and filter press (separate
pipes) to the intermediate storage tank. This tank cannot be fully
drained due to its design. Therefore, to collect a representative
sample, it is necessary to intercept the incoming flow before it
commingles with the water in the intermediate storage tank. To
accomplish this, a five-gal container will be hung inside the storage
tank, above the water level, to intercept the two discharges. The
discharges will enter the container and overflow into the intermediate
storage tank. Grab samples for hexavalent chromium, other metals,
pH, TDS, specific conductance, O&G, and sulfide will be collected 30
min (+/- 10 min) following initiation of the third pass. Samples will
be collected using a glass ladle to draw treated wastewater from the
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five-gal container and pour it into the appropriate sample bottles.
• Wastewater treatment sludge (sample point 4). After completion of
the three runs, the filter press will be discharged to the sludge hopper.
Grab samples of the sludge will be collected from the sludge hopper at
five separate points using a clean spatula, after first completely mixing
the material. The sludge sample will be placed into 1-L, wide mouth
glass jars and mixed again.
• Ion exchange system influent (sample point 5). Grab samples of
influent to the Lobo Liquids system will be collected from a sampling
port for hexavalent chromium, other metals, pH, TDS, and specific
conductance analyses. The samples will be collected 10 min (+/- 5
min) after initiation of the ion exchange treatment cycle.
• Final treated wastewater (sample point 6). Grab samples of treated
wastewater from the Lobo Liquids system will be collected from a
sampling port. Grab samples will be collected 20 min (+/- 5 min) after
initiation of the ion exchange treatment process for hexavalent
chromium, other metals, pH, TDS, specific conductance, O&G, and
sulfide analyses.
• Ion exchange system regenerant (sample point 7). The Lobo
Liquids system is regenerated approximately every 20 days when it is
used in combination with the electrocoagulation system. The
regenerant is collected in the regenerate storage tank. A Gull
Industries employee, who will be trained by the ETV-MF Project
Manager, will take grab samples of the regenerate from the regenerate
storage tank for metals analyses.
3.3.3.2 Test 2 Sample Collection and Handling
During Test 2, samples will be collected from the sampling points shown
in Figure 7. Samples will be collected from sample points 5 and 6 during
the first three days of verification testing. Sampling will not be conducted
during days 4 through 7 of verification. Sampling will resume on day 8 of
testing and continue until the resin columns are exhausted. After day 4,
only the samples collected on the day prior to regeneration after day 8 will
be analyzed. Sampling procedures are described below.
• Ion Exchange System Influent (sample point 5). Grab samples of
influent to the Lobo Liquids system will be collected from a sampling
port for hexavalent chromium, other metals, pH, TDS, specific
conductance analyses. Grab samples will be collected each day four
hours (+/- one-hour) after daily start-up of the ion exchange treatment
process.
• Final treated wastewater (sample point 6). Grab samples of treated
wastewater will be collected on a daily basis from a sampling port.
Grab samples will be collected each day four hours (+/- one-hour)
after daily start-up of the ion exchange treatment process. The
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samples will be analyzed for hexavalent chromium, other metals, pH,
TDS, specific conductance, O&G, and sulfide.
• Ion exchange system regenerant (sample point 7). The Lobo
Liquids system is regenerated approximately every 10 to 20 days when
it is used as the primary treatment system. The regenerant is collected
in the regenerate storage tank. A grab sample of the regenerate from
the regenerate storage tank will be collected for metals analyses.
3.3.3.3 Additional Information on Sample Collection and Handling
Samples will be collected according to the schedule presented in Tables 8
and 9. All sampling events will be recorded on the forms shown in
Appendix A.
At the time of sampling, each sample container will be labeled with the
date, time, and sample identification (ID) number. Samples to be analyzed
at an off-site laboratory will be accompanied by a chain of custody (COC)
form. The COC form will provide the following information: project
name, project address, sampler's name, sample numbers, date/time
samples were collected, matrix, required analyses, and appropriate COC
signatures. All samples will be transported in appropriate sample
transport containers (e.g., coolers with packing and blue ice) directly to the
lab. The transport containers will be secured with COC tape to ensure
sample integrity during the delivery process to the analytical laboratory.
The Project Manager (or trained designee) will perform sampling, and
labeling, and ensure that samples are properly secured and shipped to the
laboratory for analysis.
3.3.4 Process Measurements and Information Collection
Process measurements and information collection will be conduced to provide the
following data: duration of treatment, volume of wastewater processed, reagent
usage, steel plate (anode) consumption, sludge quantity, electricity use, and O&M
activities. The methods that will be used for process measurements and
information collection are discussed in this section.
3.3.4.1 Duration of Treatment and Wastewater Volume Processed
During both tests, the duration of each treatment cycle will be measured
by recording the start and stop times for both the electrocoagulation and/or
ion exchange polishing systems onto the data collection form found in
Appendix A. During Test 1, the volume of wastewater processed during
each batch will be measured after the first pass using the graduated scale
found on storage tanks 1 and 2. During Test 2, the volume of water
processed each day will be determined from the flow data recorded by the
Lobo Liquids system. Prior to testing, the flow accuracy of the flow meter
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will be measured, and final flow measurements will be corrected if
necessary.
Sample
Sample Location
Frequency/Type
Parameters
Raw wastewater
Sample point 1
(sample port)
One/run, plus a sample from
the fourth batch. Grab
sample collected after 30 min
(+/-10 min) of initiation of
run.
TSS, TOC, cadmium, hex
chromium, chromium (T),
copper, iron, lead, manganese,
molybdenum, nickel, tin, zinc,
TDS, O&G, sulfide, pH
Electrocoagulation
reactor discharge
Sample point 2
(sample port)
One/run. Grab sample
collected after 30 min (+/-10
min) of initiation of run.
cadmium, hex chromium,
chromium (T), copper, iron, lead,
manganese, molybdenum, nickel,
tin, zinc, pH
Intermediate treated
wastewater
Sample point 3
(container located in
mouth of
intermediate storage
tank)
One/run. Grab sample
collected after 30 min (+/-10
min) of initiation of run.
TSS, TOC, cadmium, hex
chromium, chromium (T),
copper, iron, lead, manganese,
molybdenum, nickel, tin, zinc,
TDS, O&G, sulfide, pH, specific
conductance
Sludge
Sample point 4
(sludge hopper)
One/verification test.
Representative grab sample
collected after completion of
the runs.
% solids, density, cadmium,
chromium, copper, iron, lead,
manganese, molybdenum, nickel,
tin, zinc
Ion exchange
system influent
Sample point 5
(sample port)
One/run. Grab sample
collected after 15 min (+/- 5
min) of initiation of run.
TSS, TDS, TOC, cadmium, hex
chromium, chromium (T),
copper, iron, lead, manganese,
molybdenum, nickel, tin, zinc,
TDS, O&G, sulfide, pH, specific
conductance
Final treated
wastewater
Sample point 6
(sample port)
One/run. Grab sample
collected after 20 min (+/- 5
min) of initiation of run.
TSS, TDS, TOC, cadmium, hex
chromium, chromium (T),
copper, iron, lead, manganese,
molybdenum, nickel, tin, zinc,
TDS, O&G, sulfide, pH, specific
conductance
Ion exchange
system regenerant
Sample point 7
(regenerant storage
tank)
One/verification test.
Representative grab sample
collected after completion of
the ion exchange system
regeneration.
cadmium, hex chromium,
chromium (T), copper, iron, lead,
manganese, molybdenum, nickel,
tin, zinc
Table 8. Sampling Locations, Frequency and Parameters for Test 1
3.3.4.2 Polymer Usage Data
During Test 1, the quantity of polymer used by the electrocoagulation
system will be measured and recorded after completion of the verification
test. This will be accomplished by subtracting the quantity of polymer in
the feed tank at the start and completion of the verification tests (four
batches). Measuring the height of the polymer in the cylindrical feed tank
and calculating the volume using the formula for a right circular cylinder
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will determine the quantity of polymer. The depth of polymer at the start
and completion of the verification test will be entered into the forms in
Appendix A.
Sample
Sample Location
Frequency/Type
Parameters
Ion exchange
system influent
Sample point 5 (sample
port)
One per day for the first three
days plus one on the last day
of test.
TSS, TDS, TOC, cadmium, hex
chromium, chromium (T),
copper, lead, manganese, iron,
molybdenum, nickel, tin, zinc,
TDS, O&G, sulfide, pH, specific
conductance
Final treated
wastewater
Sample point 6 (sample
port)
One per day for the first three
days plus one on the last day
of test.
TSS, TDS, TOC, cadmium, hex
chromium, chromium (T),
copper, lead, manganese, iron,
molybdenum, nickel, tin, zinc,
TDS, O&G, sulfide, pH, specific
conductance
Ion exchange
system
regenerant
Sample point 7
(regenerant storage tank)
Representative grab sample
collected after completion of
the ion exchange system
regeneration.
One/verification test.
cadmium, chromium (+6),
chromium (T), copper, iron, lead,
manganese, molybdenum, nickel,
tin, zinc
Table 9. Sampling Locations, Frequency and Parameters for Test 2
3.3.4.3 Volume of Ion Exchange Regenerant
The Lobo Liquids system will be regenerated prior to and following both
verification tests. Volume measurement data from the regeneration
process prior to Test 1 and following Test 2 will be used in order to
determine the volume of regenerant. During regeneration, the columns are
flushed with hydrochloric acid (cation column), sodium hydroxide (anion
columns), and water. These solutions are combined into the regenerant
storage tank. The storage tank will be emptied prior to regeneration. The
depth of regenerant at the completion of the ion exchange cycle will be
entered into the forms in Appendix C.
3.3.4.4 Ion Exchange System Regeneration Chemical Use
During Tests 1 and 2 the quantity of hydrochloric acid and sodium
hydroxide used by the Lobo Liquids system for regeneration will be
determined after completion of the system regeneration described in
section 3.3.4.3. This will be accomplished by subtracting the quantities of
hydrochloric acid and sodium hydroxide in their respective feed tanks at
the start and completion of the ion exchange cycle. Measuring the height
of the hydrochloric acid and sodium hydroxide in the cylindrical feed
tanks and the circumferences of the tanks and calculating the volume
using the formula for a right circular cylinder will determine the quantity
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of hydrochloric acid and sodium hydroxide. The depths of hydrochloric
acid and sodium hydroxide at the start and completion of the ion exchange
cycle will be entered into the forms in Appendix A.
3.3.4.5 pH
The pH provides a general indication of the acidity or alkalinity of a
wastewater. It is also a regulated parameter for most dischargers. The pH
of the influent and effluent samples will be determined by using a digital
meter (electrometric). The digital meter will be calibrated using two
buffers that bracket the expected measurement range. The calibration will
be verified by measuring the pH of a buffer solution with a pH near the
center of the calibration range. The ETV-MF Project Manager will record
the manufacturer, lot number, and the expiration date of the buffer in the
field notebook.
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Sample
Location/Parameters
Bottle Type
Batch
1
Batch
2
Batch
3
Batch
4
Total
Sample
Raw Wastewater (Sample point 1)
TOC
1000 mL plastic bottle
1
1
1
1
4
Cr+6, TSS, TDS, pH,
specific conductance
500 mL plastic bottle
1
1
1
1
4
Metals*
500 mL plastic bottle
1
1
1
1
4
O&G (HEM)
1,000 mL wide mouth glass jar (2 each)
1
1
1
1
4
Sulfide
250 mL plastic bottle
1
1
1
1
4
EC Reactor Discharge (Sample point 2)
Cr+6, pH
500 mL plastic bottle
3
3
-
12
Metals*
500 mL plastic bottle
3
3
-
12
Intermediate Treated Wastewater (Sample point 3)
TOC
1000 mL plastic bottle
-
3**
1
1
5
Cr+6, TSS, TDS, pH,
specific conductance
500 mL plastic bottle
-
3**
1
1
3
Metals*
500 mL plastic bottle
-
3**
1
1
5
O&G (HEM)
1,000 mL wide mouth glass jar (2 each)
-
3**
1
1
5
Sulfide
250 mL plastic bottle
-
3**
1
1
5
Sludge (Sample point 4)
Metals*, % solids,
density
1,000 mL wide mouth glass jar
3**
3
Ion exchange Influent (Sample point 5)
TOC
125 mL amber glass bottle (4 each)
-
i
1
1
4
Cr+6, TSS, TDS, pH,
specific conductance
500 mL plastic bottle
-
i
1
1
4
Metals*
500 mL plastic bottle
-
i
1
1
4
O&G (HEM)
1,000 mL wide mouth glass jar (2 each)
-
i
1
1
4
Sulfide
250 mL plastic bottle
-
i
1
1
4
Final Treated Wastewater (Sample point 6)
TOC
1000 mL plastic bottle (4 each)
-
i
1
3**
5
Cr+6, TSS, TDS, pH,
specific conductance
500 mL plastic bottle
-
i
1
3**
5
Metals*
500 mL plastic bottle
-
i
1
3**
5
O&G (HEM)
1,000 mL wide mouth glass jar (2 each)
-
i
1
3**
5
Sulfide
250 mL plastic bottle
-
i
1
3**
5
Regenerant (Sample point 7)
Cr+6
500 mL plastic bottle
-
-
-
1
1
Metals*
500 mL plastic bottle
-
-
-
1
1
* Cadmium, chromium (T), copper, iron, lead, manganese, molybdenum, nickel, tin, and zinc
**Includes duplicate and matrix spike
Table 10. Test 1 Sample Quantities from Each Sampling Point
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Sample
Location/Parameters
Bottle Type
Day 1
Day 2
Day 3
Last
Day
Total
Sample
Ion Exchange Influent
(Sample point 5)
TOC
1000 mL plastic bottle (4 each)
1
1
1
1
4
Cr+6, TSS, TDS, pH,
specific conductance
500 mL plastic bottle
1
1
1
1
4
Metals*
500 mL plastic bottle
1
1
1
1
4
O&G (HEM)
1,000 mL wide mouth glass jar (2
each)
1
1
1
1
4
Sulfide
250 mL plastic bottle
1
1
1
1
4
Final Treated
Wastewater (Sample
point 6)
TOC
1000 mL plastic bottle (4 each)
1
1
3**
1
6
Cr+6, TSS, TDS, pH,
specific conductance
500 mL plastic bottle
1
1
3**
1
6
Metals*
500 mL plastic bottle
1
1
3**
1
6
O&G (HEM)
1,000 mL wide mouth glass jar (2
each)
1
1
3**
1
6
Sulfide
250 mL plastic bottle
1
1
3**
1
6
Regenerant (Sample
point 7)
Cr+6
500 mL plastic bottle
-
-
-
1
1
Metals*
500 mL plastic bottle
-
-
-
1
1
* Cadmium, chromium (T), copper, iron, lead, manganese, molybdenum, nickel, tin, and zinc
**Includes duplicate and matrix spike
Table 11. Test 2 Sample Quantities from Each Sampling Point
3.3.4.6 Quantity of Sludge Generated
The quantity of sludge generated will be measured at the end of the first
verification test. This will be accomplished by transferring the sludge that
is discharged from the filter press into an empty drum, measuring the
height of the sludge and the circumference of the drum, and calculating
the sludge volume using the formula for a right circular cylinder. The
height of sludge in the drum will be recorded on the forms found in
Appendix A. The analytical laboratory will determine the density of the
sludge, and the mass of sludge will be calculated by multiplying the
sludge volume by its density.
3.3.4.7 Electricity Usage Data
Electricity usage will be calculated by determining the input power
requirements of pumps, the rectifier, and other powdered devices
associated with the electrocoagulation system and Lobo Liquids system.
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3.3.4.8 System Operation and Maintenance Data
System operation and maintenance activities will be observed during each
run. Any non-routine operational or maintenance procedures performed
will be documented. This includes changes to the flow rate or chemical
feed rate, filter replacement, and similar activities. Labor requirements
(hrs.) will also be recorded. The team leader will record notes pertaining
to these activities on the data forms in Appendix A.
3.3.4.9 Cost Data
Gull Industries will provide the cost data for steel plates, electricity, labor,
chemical reagents, and sludge disposal. Gull Industries will also provide
one month of historical data for chemical reagent use and volumes of
wastewater treated.
3.3.4.10 Steel Plate Consumption
Steel plate consumption is relatively slow and cannot be accurately
measured during the short duration of the verification test. Therefore, six
months of historical data will be collected from Gull Industries regarding
steel plate consumption.
3.3.4.11 Ion Exchange System Operational Data
Data from the internal logging system of the ion exchange unit will be
used to provide operational data (non-critical). The system has the
following parameters monitored and continuously logged to disk:
• Inlet specific conductance (|iS)
• pH
• Pump discharge pressure (psi)
• Flow (gpm)
• Outlet specific conductance (|iS)
Prior to testing, the measurement devices will be calibrated according to
each manufacturer's procedures. All events are date and time stamped.
Gull Industries will provide these data to the ETV Project Manager at the
completion of the test in a spreadsheet format.
3.4 Analytical Procedures
All analytical procedures that will be used during this verification test are EPA methods
or other recognized methods. A summary of analytical tests is presented in Table 12.
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Parameter
Test Method
Preservation/Handling
Hold Time
Metals
(dissolved)
EPA 200.7
Cool storage
(<4°C)
pH <2 \\ /HN03
6 months
Metals
(sludge)
SW-846
3 05 0B/6010B
cool storage (<4°C)
6 months
Chromium
(hexavalent)
SW-846
7196A
cool storage (<4°C)
24 hrs
O&G (as HEM)
EPA Method 1664
cool storage (<4°C)
pH<2 \\ /HN03
28 days
pH
digital meter
NA
analyze
immediately
sulfide (S)
EPA Method 376.2
cool storage (<4°C)
zinc acetate + NaOH to
pH >12
7 days
TDS
EPA Method 160.1
cool storage (<4°C)
7 days
TOC
EPA Method 415.1
cool storage (<4°C)
acidify to pH <2 w/HN03
28 days
TSS
EPA Method 160.2
cool storage (<4°C)
7 days
specific
conductance
EPA Method 120.1
cool storage (<4°C)
28 days
sludge % water
SW-846 Draft
Update IVA 9000
cool storage (<4°C)
28 days
sludge specific
gravity
SM2710F
cool storage (<4°C)
28 days
Table 12. Summary of Analytical Tests and Requirements
QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS
Quality Assurance/Quality Control (QA/QC) activities will be performed according to the
applicable section of the Environmental Technology Verification Program Metal
Finishing Technologies Quality Management Plan (ETV-MF QMP) [Ref. 6],
4.1 Quality Assurance Objectives
The first QA objective is to ensure that the process operating conditions and test methods
are maintained and documented throughout each test and laboratory analysis of samples.
The second QA objective is to use standard test methods (where possible) for laboratory
analyses. The test methods to be used are listed in Table 12.
4.2 Data Reduction, Validation, and Reporting
4.2.1 Internal Quality Control Checks
Raw Data Handling. Raw data are generated and collected by laboratory analysts
at the bench and/or sampling site. These include original observations, printouts,
and readouts from equipment for sample, standard, and reference QC analyses.
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Data are collected both manually and electronically. At a minimum, the date,
time, sample ID, raw signal or processed signal, and/or qualitative observations
will be recorded. Comments to document unusual or non-standard observations
also will be included on the forms, as necessary. The forms presented in
Appendix A will be used for recording data on-site.
The on-site Project Team member will generate COC forms, and these forms will
accompany samples when they are shipped off-site.
Raw data will be processed manually by the analyst, automatically by an
electronic program, or electronically after being entered into a computer. The
analyst will be responsible for scrutinizing the data according to laboratory
precision, accuracy, and completeness policies. Raw data bench sheets and
calculation or data summary sheets will be kept together for each sample batch.
From the standard operating procedure and the raw data bench files, the steps
leading to a final result may be traced. The ETV-MF Project Manager will
maintain process-operating data for use in verification report preparation.
Data Package Validation. The generating analyst will assemble a preliminary
data package, which shall be initialed and dated. This package shall contain all
QC and raw data results, calculations, electronic printouts, conclusions, and
laboratory sample tracking information.
A second analyst will review the entire package and check sample and storage
logs, standard logs, calibration logs, and other files, as necessary, to ensure that all
tracking, sample treatments, and calculations are correct. After the package is
reviewed in this manner, a preliminary data report will be prepared, initialed, and
dated. The entire package and final report will be submitted to the Laboratory
Manager (LM).
The LM shall be ultimately responsible for all final data released from the
laboratory. The LM or designee will review the final results for adequacy to task
QA objectives. If the LM or designee suspects an anomaly or non-concurrence
with expected or historical performance values, or with task objectives for test
specimen performance, the raw data will be reviewed, and the generating and
reviewing analysts queried. If suspicion about data validity still exists after
internal review of laboratory records, the LM will authorize a re-test. If sufficient
sample is not available for re-testing, a re-sampling shall occur. If the sampling
window has passed, or re-sampling is not possible, the LM will flag the data as
suspect. The LM signs and dates the final data package.
Data Reporting. A report signed and dated by the LM will be submitted to the
ETV-MF Project Manager. The ETV-MF Project Manager will decide the
appropriateness of the data for the particular application. The final report
contains the laboratory sample ID, date reported, date analyzed, the analyst, the
standard operating procedure (SOP) used for each parameter, the process or
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sampling point identification, the final result, units, and all QC data generated.
The ETV-MF Project Manager shall retain the data packages as required by the
ETV-MF QMP [Ref. 6],
4.2.2 Calculation of Data Quality Indicators
Analytical performance requirements are expressed in terms of precision,
accuracy, representativeness, comparability, completeness, and sensitivity
(PARCCS). Summarized below are definitions and QA objectives for each
PARCCS parameter.
One influent sample from each run shall be submitted with a field duplicate. All
analytes from this sample will have matrix spike and matrix spike duplicate
analyses performed.
4.2.2.1 Precision
Precision is a measure of the agreement or repeatability of a set of
replicate results obtained from duplicate analyses made under identical
conditions. Precision is estimated from analytical data and cannot be
measured directly. The precision of a duplicate determination can be
expressed as the relative percent difference (RPD), and calculated as:
RPD =
X.-X,
(X,+X,J
xl00%
where:
Xi = larger of the two observed values
X2 = smaller of the two observed values
Multiple determinations will be performed for each test on the same test
specimen. The replicate analyses must agree within the relative percent
deviation limits provided in Table 13.
4.2.2.2 Accuracy
Accuracy is a measure of the agreement between an experimental
determination and the true value of the parameter being measured.
Accuracy is estimated through the use of known reference materials or
matrix spikes. It is calculated from analytical data and is not measured
directly. Spiking of reference materials into a sample matrix is the
preferred technique because it provides a measure of the matrix effects on
analytical accuracy. Accuracy, defined as percent recovery (P), is
calculated as:
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P =
(SSR-SR)
SA
x 100%
where:
SSR = spiked sample result
SR = Sample result (native)
SA = the concentration added to the spiked sample
Analyses will be performed with periodic calibration checks with
traceable standards to verify instrumental accuracy. These checks will be
performed according to established procedures in the contracted
laboratory(s) that have been acquired for this verification test. Analysis
with spiked samples will be performed to determine percent recoveries as
a means of checking method accuracy. QA objectives will be satisfied if
the average recovery is within the goals described in Table 13.
4.2.2.3 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 is calculated using the
following formula:
Completeness = Valid Measurements x 100%
Total Measurements
Experience on similar projects has shown that laboratories typically
achieve about 90 percent completeness. QA objectives will be satisfied if
the percent completeness is 90 percent or greater as specified in Table 13.
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4.2.2.4 Comparability
Comparability is another qualitative measure designed to express the
confidence with which one data set may be compared to another. Sample
collection and handling techniques, sample matrix type, and analytical
method all affect comparability. Comparability is limited by the other
PARCCS parameters because data sets can be compared with confidence
only when precision and accuracy are known. Comparability will be
achieved in this technology verification by the use of consistent methods
during sampling and analysis and by traceability of standards to a reliable
source.
4.2.2.5 Representativeness
Representativeness refers to the degree to which the sample represents the
properties of the particular wastestream being sampled. For the purposes
of this demonstration, representativeness will be determined by submitting
identical samples (field duplicates) to the laboratory for analysis. The
samples will be representative if the relative percent difference between
the sample and the field duplicate is similar to or less than the precision
(laboratory duplicates) calculation of the sample. Three identical samples
(one each of influent, effluent, and sludge) will be collected during the
course of the verification test. Representativeness will be satisfied if the
analytical results for each parameter are within 25 percent of the results
for the associated duplicate sample.
4.2.2.6 Sensitivity
Sensitivity is the measure of the concentration at which an analytical
method can positively identify and report analytical results. The
sensitivity of a given method is commonly referred to as the detection
limit. Although there is no single definition of this term, the following
terms and definitions of detection will be used for this program.
Instrument Detection Limit (IDL) is the minimum concentration that can
be measured from instrument background noise.
Method Detection Limit (MDL) is a statistically determined
concentration. It is the minimum concentration of an analyte that can be
measured and reported with 99 percent confidence that the analyte
concentration is greater than zero as determined in the same or a similar
matrix. (Because of the lack of information on analytical precision at this
level, sample results greater than the MDL but less than the practical
quantification limit (PQL) will be laboratory qualified as "estimated.")
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MDL is defined as follows for all measurements:
MDL t(n-i;i-a = O.99) XS
where: MDL = method detection limit
t(n-i,i-a = 0.99) = students t-value for a one-sided 99 percent
confidence level and a standard deviation
estimate with n-1 degrees of freedom
s = standard deviation of the replicate analyses
Method Reporting Limit (MRL) is the concentration of the target analyte
that the laboratory has demonstrated the ability to measure within
specified limits of precision and accuracy during routine laboratory
operating conditions. (This value is variable and highly matrix dependent.
It is the minimum concentration that will be reported without
qualifications by the laboratory.)
4.3 Additional Data Calculations
4.3.1 Ability to Meet Metal Finishing and Proposed MP&M Limitations
The results of each test cycle will be compared to the applicable metal finishing
limitations (Table 14) and Proposed MP&M limitations (Table 15). To meet a
metal finishing or MP&M limit, the analytical result must be equal to or below
the corresponding daily maximum limit.4 The comparison will be made on a
parameter-by-parameter basis for each cycle. The applicable limitations are the
pretreatment standards for existing sources for the metal finishing category (40
CFR 433.15) and proposed pretreatment standards for existing sources for the
MP&M Job Shop subcategory (66 FR 424).
Parameter
Metal Finishing Category (40 CFR 433.15)
Daily Max., mg/L
Monthly Avg., mg/L
Cadmium
0.69
0.26
Chromium
2.77
1.71
Copper
3.38
2.07
Lead
0.69
0.43
Nickel
3.98
2.36
Zinc
2.61
1.48
Table 14. Applicable Pretreatment Standards for Existing Sources for the
Metal Finishing Category (40 CFR 433.15)
4 It is anticipated that for certain parameters the influent concentration will be below the discharge limit. These
instances will be identified during data reduction and reported as such in the verification report.
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Parameter
MP&M Job Sho
p Subcategory (66 FR 424)
Daily Max., mg/L
Monthly Avg., mg/L
Cadmium
0.21
0.09
Chromium
1.3
0.55
Copper
1.3
0.57
Lead
0.12
0.09
Manganese
0.25
0.10
Molybdenum
0.79
0.49
Nickel
1.5
0.64
Tin
1.8
1.4
Zinc
0.35
0.17
O&G (as HEM)
52
26
TOC
78
59
Sulfide (as S)
31
13
O&G (as HEM) are not regulated under pretreatment standards for the Job Shop subcategory. However, it
is regulated under the BPT limitations for direct dischargers in the Job Shop subcategory (66 FR 424).
The values shown are the BPT proposed limitations.
Table 15. Applicable Proposed Pretreatment Standards for Existing Sources for the
MP&M Job Shop Subcategory (66 FR 424)
4.3.2 Mass Balance
Mass balance calculations will be performed for chromium (T) and nickel, which
are the two metal parameters of greatest significance at Gull Industries. During
Test 1, the mass balance will be performed for the electrocoagulation system only
since the ion exchange system will not be tested over a full cycle. The mass
balance results will be used as an indicator of the accuracy of the verification test.
The mass balance criterion will be satisfied when the mass balance is within the
range of 75 percent to 125 percent.
The equation for the chromium mass balance for Test 1 is shown below,
nickel mass balance equation will be similar.
mass bal. (%) = [((Ce x Ve) + (Cs x Vs)) / (Ci x Vi)] x 100%
The
where:
Ce = intermediate treated wastewater chromium
concentration (mg/L)
Ve = intermediate treated wastewater volume processed
during the test period (L)
Cs = filter press sludge chromium concentration (mg/L)
Vs = filter press sludge volume generated during the test
period (L)
Ci = raw wastewater chromium concentration (mg/L)
Vi = raw wastewater volume processed during the test
period (L)
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The equation for the chromium mass balance for Test 2 is shown below,
nickel mass balance equation will be similar.
The
mass bal. (%) = [((CF x VF) + (CR x VR)) / (Ci x Vi)] x 100%
where: CF = final treated wastewater chromium concentration
(mg/L)
VF = final treated wastewater volume processed during
the test period (L)
CR = regenerant chromium concentration (mg/L)
Vr = regenerant volume generated at end of the Test 2
(L)
Ci = raw wastewater chromium concentration (mg/L)
Vi = raw wastewater volume processed during the test
period (L)
4.3.3 Pollutant Removal Efficiency
The pollutant removal efficiency is calculated based on a comparison of raw
wastewater and treated wastewater concentrations for each pollutant parameter
and each run. The equation for zinc removal is shown below. The removal
efficiency rate for each pollutant parameter will be separately calculated. These
include: O&G (as HEM), TOC, cadmium, hexavalent chromium, chromium (T),
copper, lead, manganese, molybdenum, nickel, sulfide (as S), tin, and zinc.
where:
Zi
Vi
ZE
VE
[((Zi x Vi) - (ZE x VE)) / (Zi x Vi)] x 100%
zinc recovery efficiency
raw wastewater zinc concentration (mg/L)
raw wastewater volume processed during the test cycle
(L)
treated wastewater zinc concentration (mg/L)
treated wastewater volume processed during the test
cycle (L)
As a result of its design, the electrocoagulation system retains a volume of
wastewater in the treatment system tanks approximately equal to the volume of
one batch. The tanks operate as a plug flow reactor; as a batch of wastewater is
processed through the tanks, the existing wastewater in the tanks is pushed
through the system and is discharged to the final storage tank. To account for this
design, during Test 1, the treated wastewater samples (E) will be paired with the
raw wastewater samples (R) from the previous batch as shown in Table 7.
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4.3.4 Reusability of Treated Wastewater
The reusability of the treated wastewater as process water will be determined by
comparing the results of the pH and specific conductance analytical tests of the
final treated water to standards used by Gull Industries for water reuse. Treated
water meeting both of these standards will be deemed reusable. The Gull
Industries standards are:
• Specific conductance: maximum of 500 |iS
• pH: within the range of 5.0 to 9.0 standard units
4.3.5 Energy Usage
Separate energy usage analyses will be performed for Tests 1 and 2. Energy
requirements for the electrocoagulation and Lobo Liquids systems will be
calculated by summing the total quantity of horsepower (hp) hours for each
system and dividing by 1.341 hp-hr/kWh to arrive at electricity needs. The
energy requirements will be calculated separately for each system.
4.3.6 Cost Analysis
Separate cost analyses will be performed for Tests 1 and 2. These analyses will
determine the operating costs of the electrocoagulation and Lobo Liquids systems
considering the following cost parameters: chemical reagents, steel plates, other
materials (e.g., filters), electricity, labor, and sludge management. Costs will be
calculated and expressed in dollars per thousand liters processed ($/1000 L) by
dividing the cost by the total volume of wastewater processed during the
verification test. Total costs will be calculated separately for each system by
summing the individual cost elements. The calculation of treatment cost is shown
below.
Ctreat cost ~ (R+A + M + E + L+S)/V
where: .Ctreatcost = cost of treatment ($/1000 L)
R = cost of chemical reagents used ($)
A = cost of steel plates consumed ($)*
M = cost of materials used ($)
E = cost of electricity used ($)
L = cost of labor ($)
S = cost of sludge management ($)*
V = volume of wastewater processed during the
verification test (1000 L)
*Test 1 only
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4.3.7 Sludge Generation Analysis
During Test 1, the quantity of sludge generated will be measured at the end of the
verification test as described in section 3.3.3.1. The quantity will be expressed as
volume of sludge generated (wet basis) and weight of sludge generated (wet and
dry basis). The weight of the sludge on a dry-weight basis will be calculated as
follows:
Sdly = (Swet x % solids) /100%
where: Sdry = dry weight of sludge
Swet = wet weight of sludge as measured during
verification test
% solids = percent solids from lab analysis of sludge
4.3.8 Environmental Benefit
Separate environmental benefit analyses will be performed for Tests 1 and 2.
This analysis will quantify the environmental benefit of the electrocoagulation/ion
exchange polishing technologies installed at Gull Industries by determining the
quantity of regulated pollutants removed beyond the level required by the metal
finishing regulations (40 CFR 433).
Pb = Pv-Ph
where: Pb = quantity of regulated pollutants removed beyond the
level required (gram (g)/1000 L)
Pv = sum of allowable pollutant discharged (g/1000 L)
(calculated by multiplying the daily maximum limit
times the volume of wastewater processed and
summing over all regulated parameters)
Ph = sum of actual pollutant mass discharged during
verification test (g/1000 L) (calculated by multiplying
the average final concentration for the three runs times
the volume of wastewater processed and summing over
all regulated parameters)
4.4 Test Plan Modifications
In the course of verification testing, it may become necessary to modify the test plan due
to unforeseen events. These modifications will be documented using a Test Plan
Modification Request (Appendix B), which must be submitted to the CTC Project
Manager for approval. Upon approval, the modification request will be assigned a
number, logged, and transmitted to the requestor for implementation.
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4.5 Quality Audits
Technical System Audits. An audit will not be performed during verification testing by
the CTC QA Manager. The EPA QA Manager may also conduct an audit to assess the
quality of the verification test.
Internal Audits. In addition to the internal laboratory QC checks, internal quality audits
will be conducted to ensure compliance with written procedures and standard protocols.
Corrective Action. Corrective action for any deviations to established QA and QC
procedures during verification testing will be performed according to section 2.10 Quality
Improvement of the ETV-MF QMP [Ref. 6],
Laboratory Corrective Action. Examples of non-conformances include invalid
calibration data, inadvertent failure to perform method-specific QA, process control data
outside specified control limits, failed precision and/or accuracy indicators, etc. Such
non-conformances will be documented on a standard laboratory form. Corrective action
will involve taking all necessary steps to restore a measuring system to proper working
order and summarizing the corrective action and results of subsequent system
verifications on a standard laboratory form. Some non-conformances are detected while
analysis or sample processing is in progress and can be rectified in real time at the bench
level. Others may be detected only after a processing trial and/or sample analyses are
completed. Typically, the LM detects these types of non-conformances. In all cases of
non-conformance, the LM will consider sample re-analysis as one source of corrective
action. If insufficient sample is available or the holding time has been exceeded,
complete re-processing may be ordered to generate new samples if a determination is
made by the ETV-MF Project Manager that the non-conformance jeopardizes the
integrity of the conclusions to be drawn from the data. In all cases, a non-conformance
will be rectified before sample processing and analysis continues.
5.0 PROJECT MANAGEMENT
5.1 Organization/Personnel Responsibilities
The ETV-MF Project Team that is headed by CTC will conduct the evaluation of the
electrocoagulation and ion exchange polishing systems. The CTC ETV-MF Program
Manager, Donn Brown, will have ultimate responsibility for all aspects of the technology
evaluation. The ETV-MF Project Manager assigned to this evaluation is George
Cushnie. Mr. Cushnie and/or his staff member will be on-site throughout the series of
treatment runs and will conduct or supervise all sampling and related measurements, with
one exception.5 During Tests 1 and 2, the operating cycle of the Lobo Liquids system
will extend beyond the time period the ETV-MF team will be on-site. During Test 1, at
the end of the operating cycle, a Gull Industries employee will collect a sample of the ion
exchange regenerate from the regenerant storage tank (sample point 7) and ship the
5 The CTC ETV-MF Program Manager, Donn Brown, will make a determination as to the qualifications of any staff
member assigned to the project. This will occur prior to testing.
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sample to the laboratory. During Test 2, a Gull Industries employee will collect influent,
effluent, and regenerant samples from the ion exchange system. The ETV-MF Project
Manager will train the Gull Industries employee with regard to sampling protocol, sample
preservation, and COC.
Ian Tunnicliffe will head the ion exchange staff. He will be on call throughout the entire
test period to answer questions concerning operation of the system.
Gull Industries personnel will be responsible for operating the electrocoagulation and ion
exchange polishing systems and providing historical wastewater volume and cost
information. Gull Industries will also be responsible for the disposal of all residuals
generated during the verification test.
Severn Trent Laboratories (STL) in Houston, Texas, is responsible for analyzing
verification test samples. The LM, Jodi Romine, will be point of contact (POC). STL is
approved by the State of Texas for the analyses identified in this test plan.
The ETV-MF Project Manager and Gull Industries (host facility) have the authority to
stop work when unsafe or unacceptable quality conditions arise. The CTC ETV-MF
Program Manager will provide periodic assessments of verification testing to the EPA
ETV Program Manager.
6.0 EQUIPMENT AND UTILITY REQUIREMENTS
The electrocoagulation system and Lobo Liquids system are permanently installed at Gull
Industries. The only utility requirements for operating the systems are electricity,
compressed air, and city water.
7.0 HEALTH AND SAFETY PLAN
This Health and Safety Plan provides guidelines for recognizing, evaluating, and
controlling health and physical hazards throughout the workplace. More specifically, the
Plan specifies for assigned personnel the training, materials, and equipment necessary to
protect themselves from hazards created by acids and any waste generated by the process.
7.1 Hazard Communication
All personnel assigned to the project will be provided with the potential hazards, signs
and symptoms of exposure, methods or materials to prevent exposures, and procedures to
follow if there is contact with a particular substance. The Gull Industries (host facility)
Hazard Communication Program will be reviewed during training and will be reinforced
throughout the test period. All appropriate Material Safety Data Sheet(s) (MSDS) forms
will be available for chemical solutions used during testing.
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7.2 Emergency Response Plan
Gull Industries has a contingency plan to protect employees, assigned project personnel,
and visitors in the event of an emergency at the facility. This plan will be used
throughout the project. All assigned personnel will be provided with information about
the plan during training.
7.3 Hazard Controls Including Personal Protective Equipment
All assigned project personnel will be provided with appropriate personal protective
equipment (PPE) and any training needed for its proper use, considering their assigned
tasks. The use of PPE will be covered during training as indicated in section 9.0.
The following PPE will be required and must be worn at all times while in the Gull
Industries facility: eyeglasses with side splashguards.
7.4 Lockout/Tagout Program
The electrocoagulation and Lobo Liquids systems are fully installed. There is no need
for implementation of a lockout/tagout program.
7.5 Material Storage
Any materials used during the project will be kept in proper containers and labeled
according to state and Federal laws. Proper storage of the materials will be maintained
based on associated hazards. Spill trays or similar devices will be used as needed to
prevent material loss to the surrounding area.
7.6 Safe Handling Procedures
All chemicals and wastes or samples will be transported on-site in non-breakable
containers used to prevent spills. Spill kits will be strategically located in the project
area. These kits contain various sizes and types of sorbents for emergency spill clean up.
Emergency spill clean up will be performed according to the Emergency Response Plan.
WASTE MANAGEMENT
The electrocoagulation and Lobo Liquids systems will process wastewater generated by
manufacturing operations at Gull Industries. After processing, the effluent from
treatment will be transferred to the existing Gull Industries storage tanks and
subsequently reused as process water and/or discharged to the Houston POTW. Any
residuals generated by the electrocoagulation or Lobo Liquids systems will be managed
by Gull Industries in accordance with Gull Industries requirements.
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9.0 TRAINING
It is important that the verification activities performed by the ETV-MF Program be
conducted with high quality and with regard to the health and safety of the workers and
the environment. By identifying the quality requirements, worker safety and health, and
environmental issues associated with each verification test, the qualifications or training
required for personnel involved can be identified. Training requirements will be
identified using the Job Training Analysis (JTA) Plan [Ref. 8],
The purpose of this JTA Plan is to outline the overall procedures for identifying the
hazards and quality issues and training needs for each verification test project. This JTA
Plan establishes guidelines for creating a work atmosphere that meets the quality,
environmental, and safety objectives of the ETV-MF Center. The JTA Plan describes the
method for studying ETV-MF project activity and identifying training needs. The ETV-
MF Operation Planning Checklist (Appendix C) will be used as a guideline for
identifying potential hazards, and the JTA Form (Appendix D) will be used to identify
training requirements. After completion of the form, applicable training will be
performed. Training will be documented on the ETV-MF Project Training Attendance
Form (Appendix E). Health and safety training will be coordinated with Gull Industries
personnel.
10.0 REFERENCES
1) Data collected by the Metal Finishing Strategic Goals Program (SGP) (see
www. strategi cgoal s. org).
2) EPA, Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards for the Metal Finishing Point Source Category (40 CFR
433).
3) EPA, Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards for the Metal Products and Machinery Point Source
Category; Proposed Rule (66 FR 424, January 3, 2001).
4) U.S. EPA Office of Environmental Information, "Guidance for the Data Quality
Objectives Process, EPA QA/G-4, " EPA/600/R-96/055, August 2000.
5) Cushnie, George C., Pollution Prevention and Control for Plating Operations,
National Center for Manufacturing Sciences, Ann Arbor, MI, 1994.
6) Concurrent Technologies Corporation, "Environmental Technology Verification
Program Metal Finishing Technologies (ETV-MF) Quality Management Plan,
Revision 7," March 26, 2001.
7) U.S. EPA Office of Research and Development, "Preparation Aids for the
Development of Category IV Quality Assurance Project Plans" EPA/600/8-91/006,
February 1991.
8) Concurrent Technologies Corporation, "Environmental Technology Verification
Program Metal Finishing Technologies (ETV-MF) Pollution Prevention
Technologies Pilot Job Training Analysis Plan" May 10, 1999.
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11.0 DISTRIBUTION
George Moore, EPA (3)
J. Kelly Mowry, Gull Industries
Jerry Givens, Gull Industries
Ian Tunnicliffe, Lobo Liquids
George Cushnie, CAI Resources, Inc.
Donn Brown, CTC (3)
Jodi Romine, Severn Trent
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APPENDIX A
Data Collection Forms for Electrocoagulation and
Lobo Liquids Systems
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Data Collection Form for Electrocoagulation and Lobo Liquids Systems
General Test Data
Date:
ETV-MF Project Manager:
Gull Industries Operator:
Parameter
Reading
Observations/Comments
Polymer Tank Dimensions
IX Acid Tank Dimensions
IX Caustic Tank Dimensions
Sludge Generation Volume:
Electricity Cost:
Labor Cost:
Acid Cost:
Caustic Cost:
Steel Plate Cost:
Steel Plate Usage:
Notes:
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Data Collection Form for Electrocoagulation System
Cycle-Specific Data
Date:
ETV-MF Project Manager:
Gull Industries Operator:
Parameter/Time
Reading or Sample #
Observations/Comments
Batch /Pass
Electrocoagulation Start Time:
Amp-hour reading A at start:
Amp-hour reading B at start:
Electrocoagulation Stop Time:
Amp-hour reading A at stop:
Amp-hour reading B at stop:
Volume Treated (L):
Polymer Height:
Sample Point 1
Sample Point 2
Sample Point 3
Sample Point 4
Batch /Pass
Electrocoagulation Start Time:
Amp-hour reading A at start:
Amp-hour reading B at start:
Electrocoagulation Stop Time:
Amp-hour reading A at stop:
Amp-hour reading B at stop:
Volume Treated (L):
Polymer Height:
Sample Point 1
Sample Point 2
Sample Point 3
Sample Point 4
Notes:
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Data Collection Form for Lobo Liquids System
Cycle-Specific Data
Date:
ETV-MF Project Manager:
Gull Industries Operator:
Regeneration
Parameter/Time
Reading or Sample #
Observations/Comments
Acid Tank Height at Start:
Caustic Tank Height at Start:
Ion Exchange Regen. Start Time:
Ion Exchange Regen. Stop Time:
Acid Tank Height at Completion:
Caustic Tank Height at Completion:
Sample Point 7:
Volume of Regenerant:
System Operation
Parameter/Time
Reading or Sample #
Observations/Comments
Batch
Ion Exchange Start Time:
Ion Exchange Stop Time:
Sample Point 5:
Sample Point 6:
Notes:
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APPENDIX B
Test Plan Modification Request
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TEST PLAN MODIFICATION REQUEST
In the course of verification testing, it may become necessary to modify the test plan due to
unforeseen events. The purpose of this procedure is to provide a vehicle whereby the necessary
modifications are documented and approved.
The Test Plan Modification Request form is the document to be used for recording these
changes. The following paragraphs provide guidance for filling out the form to ensure a
complete record of the changes made to the original test plan.
The person requesting the change should record the date and project name in the form's heading.
Program management will provide the request number.
Under Original Test Plan Requirement, reference the appropriate sections of the original test
plan, and insert the proposed modifications in the section titled Proposed Modification. In the
Reason section, document why the modification is necessary; this is where the change is
justified. Under Impact, give the impact of not making the change, as well as the consequences
of making the proposed modification. Among other things, the impact should address any
changes to cost estimates and project schedules.
The requestor should then sign the form and obtain the signature of the project manager. The
form should then be transmitted to the CTC ETV-MF Program Manager, who will either approve
the modification or request clarification. Upon approval, the modification request will be
assigned a number, logged, and transmitted to the requestor for implementation.
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TEST PLAN MODIFICATION REQUEST
Date: Number: Project:
Original Test Plan Requirement:
Proposed Modification:
Reason:
Impact:
Approvals:
Reque stor:
Project Manager:_
Program Manager:
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APPENDIX C
ETV-MF Operation Planning Checklist
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ETV-MF Operation Planning Checklist
The ETV-MF Project Manager prior to initiation of verification testing must complete this form.
If a "yes " is checkedfor any items below, an action must be specified to resolve the concern on
the Job Training Analysis Form.
Project Name: Expected Start Date:
ETV-MF Project Manager:
Will the operation or activity involve the following: Yes No Initials & Date
Completed
Equipment requiring specific, multiple steps for controlled shutdown?
(e.g. in case of emergency, does equipment require more than simply
pressing a "Stop" button to shut off power?) Special Procedures for
emergency shut-down must be documented in Test Plan.
Equipment requiring special fire prevention precautions? (e.g. Class D
fire extinguishers)
Modifications to or impairment of building fire alarms, smoke
detectors, sprinklers or other fire protection or suppression systems?
Equipment lockout/tagout or potential for dangerous energy release?
Tockout/tagout requirements must be documented in Test Plan.
Working in or near confined spaces (e.g., tanks, floor pits) or in
cramped quarters?
Personal protection from heat, cold, chemical splashes, abrasions, etc.?
Use Personal Protective Equipment Program specified in Test Plan.
Airborne dusts, mists, vapors and/or fumes? Air monitoring,
respiratory protection, and /or medical surveillance may be needed.
Noise levels greater than 80 decibels? Noise surveys are required.
Hearing protection and associated medical surveillance may be
necessary.
X-rays or radiation sources? Notification to the state and exposure
monitoring may be necessary.
Welding, arc/torch cutting, or other operations that generate flames
and/or sparks outside of designated weld areas? Follow Hot Work
Permit Procedures identified in Test Plan.
The use of hazardous chemicals? Follow Hazard Communication
Program, MSDS Review for Products Containing Hazardous
Chemicals. Special training on handling hazardous chemicals and
spill clean-up may be needed. Spill containment or local ventilation
may be necessary.
Working at a height of six feet or greater?
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ETV-MF OPERATION PLANNING CHECKLIST
The ETV-MF Project Manager prior to initiation of verification testing must complete this form.
If a "yes " is checkedfor any items below, an action must be specified to resolve the concern on
the Job Training Analysis Form.
Project Name:
ETV-MF Project Manager:
Will the operation or activity involve the following: Yes No Initials & Date
Completed
Processing or recycling of hazardous wastes? Special permitting may
be required.
Generation or handling of waste?
Work to be conducted before 7:00 a.m., after 6:00 p.m. and/or on
weekends? Two people must always be in the work area together.
Contractors working in CTC facilities? Follow Hazard Communication
Program.
Potential discharge of wastewater pollutants?
EHS aspects/impacts and legal and other requirements identified?
Contaminants exhausted either to the environment or into buildings?
Special permitting or air pollution control devices may be necessary.
Any other hazards not identified above? (e.g. lasers, robots, syringes)
Please indicate with an attached list.
The undersigned responsible party certifies that all applicable concerns have been indicated in
the "yes" column, necessary procedures will be developed, and applicable personnel will receive
required training. As each concern is addressed, the ETV-MF Project Manager will initial and
date the "initials & date completed" column above.
ETV-MF Project Manager
(Name) (Signature) (Date)
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APPENDIX D
Job Training Analysis Form
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Job Training Analysis Form
ETV-MF Project Name:
Basic Job Step
Potential EHS Issues
Potential Quality
Issues
Training
ETV-MF Project Manager:
Name Signature
Date
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APPENDIX E
ETV-MF Project Training Attendance Form
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ETV-MF Project Training Attendance Form
ETV-MF Center Project:
Date
Training
Completed
Employee Name
Last First
Training Topic
Test
Score
(If applic.)
ETV-MF Project Manager:
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