Revision 0-3/01/01
CFC
Concurrent
Technologies
Corporation
U.S. ENVIRONMENTAL PROTECTION AGENCY
ENVIRONMENTAL TECHNOLOGY VERIFICATION
PROGRAM
FOR METAL FINISHING POLLUTION PREVENTION
TECHNOLOGIES
VERIFICATION TEST PLAN
Evaluation of Davis Technologies International Corp. Industrial
Wastewater Treatment Plant for the Metal Finishing Industry
Concurrent Technologies Corporation is the Verification Partner for the EPA ETV Metal
Finishing Pollution Prevention Technologies Center under EPA Cooperative Agreement
For the
Revision 0
March 1, 2001
No. CR826492-01-0.
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etV
U.S. Environmental Protection Agency
Environmental Technology Verification Program
For Metal Finishing Pollution Prevention Technologies
Verification Test Plan
For the
Evaluation of Davis Technologies International Corp. Industrial
Wastewater Treatment Plant for the Metal Finishing Industry
Concurrent
CFC^ Technologies
Corporation
March 1, 2001
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TITLE: Evaluation of Davis Technologies International Corp. Industrial Wastewater
Treatment Plant for the Metal Finishing Industry
ISSUE DATE: March 1, 2001
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 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 Jim Totter and Valerie Whitman for their help in preparing this document.
Concurrent Technologies Corporation is the Verification Partner for the EPA ETV Metal
Finishing Pollution Prevention Technologies Center under EPA Cooperative Agreement No.
CR826492-01-0.
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Environmental Technology Verification Program for Metal Finishing Pollution Prevention
Technologies Verification Test Plan for the Evaluation of Davis Technologies International
Corp. Industrial Wastewater Treatment Plant for the Metal Finishing Industry
PREPARED BY:
Percy ffltzer
CTC Metal Finishing Engineer
George Cushnie
F.TV-MFProject Manager
Date
3-5 - CM
Date
APPROVED BY:
dm ton Twilley
CTC QA Manager
f
Donn Brown
CTC. F.TV-MF Program Manager
Alva Darnels
EPA E7V Center Manager
'James Davis
Davis Technologies International Corp.
*ii.obert Stone
Federal-Mogul
3.
/
' Date
Vy ° /
IJate
AtuchAjooi
Date
Date
3zlZrOL
Date
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.
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TABLE OF CONTENTS
Page
1.0 INTRODUCTION 1
2.0 TECHNOLOGY DESCRIPTION 2
2.1 Theory of Operation 2
2.2 Description of IWTP-MF System 2
2.3 Commercial Status 4
2.4 Environmental Significance 5
2.5 Local Installation 5
3.0 EXPERIMENTAL DESIGN 8
3.1 Test Goals and Objectives 8
3.2 Critical and Non-Critical Measurements 9
3.3 Test Matrix 10
3.4 Testing and Operating Procedures 11
3.4.1 Set-Up and System Initialization Procedures 11
3.4.2 System Operation 12
3.4.3 Sample Collection and Handling 13
3.4.4 Process Measurements and Information Collection 15
3.4.4.1 Wastewater Flow Rate and Volume Processed 15
3.4.4.2 Chemical Reagent Usage Data 15
3.4.4.3 Quantities of Recovered Oil and Sludge 16
3.4.4.4 Electricity Use Data 16
3.4.4.5 System Operation and Maintenance Labor Tasks 16
3.4.4.6 Historical Discharge Data 16
3.4.4.7 Cost Data 17
3.5 Analytical Procedures 17
3.5.1 Oil and Grease (O&G) 17
3.5.2 Solids 17
3.5.3 Total Organic Carbon (TOC) 18
3.5.4 Metals 19
3.5.5 Sulfide (as S) 19
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3.5.6 pH 19
3.5.7 Percent Water in Oil 19
3.5.8 Percent Solids in Sludge 20
4.0 QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS 20
4.1 Quality Assurance Objectives 20
4.2 Data Reduction, Validation, and Reporting 20
4.2.1 Internal Quality Control Checks 20
4.2.2 Calculation of Data Quality Indicators 21
4.2.2.1 Precision 21
4.2.2.2 Accuracy 22
4.2.2.3 Completeness 22
4.2.2.4 Comparability 23
4.2.2.5 Representativeness 25
4.2.2.6 Sensitivity 25
4.2.3 Other Calculations 26
4.2.3.1 Ability to Meet Metal Finishing and Proposed MP&M Limitations26
4.2.3.2 Mass Balance 27
4.2.3.3 Oil Recovery Efficiency 28
4.2.3.4 Pollutant Removal Efficiency 28
4.2.3.5 Energy Use 29
4.2.3.6 Cost Analysis 29
4.2.3.7 Sludge Generation Analysis 29
4.2.3.8 Environmental Benefit 30
4.3 Quality Audits 30
5.0 PROJECT MANAGEMENT 31
5.1 Organization/Personnel Responsibilities 31
5.2 Test Plan Modification 32
6.0 EQUIPMENT AND UTILITY REQUIREMENTS 32
7.0 HEALTH AND SAFETY PLAN 32
7.1 Hazard Communication 32
7.2 Emergency Response Plan 33
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7.3 Hazard Controls Including Personal Protective Equipment 33
7.4 Lockout/Tagout Program 33
7.5 Material Storage 33
7.6 Safe Handling Procedures 33
8.0 WASTE MANAGEMENT 34
9.0 TRAINING 34
10.0 REFERENCES 34
11.0 DISTRIBUTION 35
LIST OF FIGURES
Figure 1. Exterior of Mobile DTIC IWTP-MF System 3
Figure 2. Interior of DTIC IWTP-MF System 3
Figure 3. Diagram of DTIC IWTP-MF System 4
Figure 4. DTIC IWTP-MF in Use at an Industrial Site 4
Figure 5. Planned Location for IWTP-MF During Verification 11
LIST OF TABLES
Table 1. Summary of Current Limitations and Proposed Regulations Applicable to Federal-Mogul
and Recent Discharge Data 7
Table 2. Pretreatment Standards for Existing Sources for the MP&M Oily Wastes Subcategory
(40 CFR 438.65) 8
Table 3. Raw Wastewater Influent Data from Federal-Mogul 8
Table 4. Test Matrix 10
Table 5. Test Objectives and Related Test Measurements for Evaluation of the
IWTP-MF System 12
Table 6. Sampling Locations, Frequency and Parameters 14
Table 7. Sample Quantities from Each Wastestream by Parameter 15
Table 8. Summary of Analytical Tests and Requirements 18
Table 9. QA Objectives 24
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Table 10. Applicable Pretreatment Standards for Existing Sources for the
Metal Finishing Subcategory (40 CFR 433.15) 26
Table 11. Applicable Proposed Pretreatment Standards for Existing Sources for the MP&M Oily
Wastes Subcategory (40 CFR 438.65) and General Metals Subcategory
(40 CFR 438.15) 27
LIST OF APPENDICES
APPENDIX A: DTIC IWTP-MF Operating Procedures A-l
APPENDIX B: Data Collection Form for DTIC IWTP-MF System B-1
APPENDIX C: Test Plan Modification C-1
APPENDIX D: ETV-MF Operation Planning Checklist D-l
APPENDIX E: Job Training Analysis Form E-l
APPENDIX F: ETV-MF Project Training Attendance Form F-l
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ACRONYMS & ABBREVIATIONS
ASTM American Society for Testing and Materials
avg. Average
Ba Barium
BPT Best Practical Treatment
C Centigrade
CAS# Chemical Abstract Number
Cd Cadmium
CFR Code of Federal Regulations
Cr Chromium
CTC Concurrent Technologies Corporation
Cu Copper
DAF Dissolved Air Flotation
DOT Department of Transportation
DTIC Davis Technologies International Corp.
EPA US Environmental Protection Agency
ETV-MF Environmental Technology Verification for Metal Finishing
FPS Final Polishing System
ft2 Square feet
ft3 Cubic feet
g/L Gram(s) per liter
gpd Gallon(s) per day
gph Gallon(s) per hour
gpm Gallon(s) per minute
h Height
HCL Hydrochloric acid
HDPE High Density Polyethylene
HEM n-Hexane Extractable Materials
Hz Hertz
ICP - AES Inductively Coupled Plasma - Atomic Emission Spectroscopy
ID Identification
IDL Instrument Detection Limit
IWTP-MF Industrial Wastewater Treatment Plant for Metal Finishing
JTA Job Training Analysis
kWh Kilowatt hour
lb. Pound
L Liter
L/day Liter(s) per day
Lpm Liter(s) per minutes
Max. Maximum
MDL Method Detection Limit
mg/L Milligram(s) per liter
mg/kg Milligram(s) per kilogram
ml Milliliter
mm Millimeter
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ACRONYMS & ABBREVIATIONS (continued)
MP&M
Metal Products and Machinery
MRL
Method Reporting Limit
MS
Matrix spike
MSD
Matrix spike duplicate
MSDS
Material Safety Data Sheet
ND
No data
Ni
Nickel
NR
Not regulated
O&G
Oil and Grease
O&M
Operation and Maintenance
OSHA
Occupational Safety and Health Administration
PARCCS
Precision, accuracy, representativeness, comparability, completeness, and
sensitivity
Pb
Lead
pH
Value used to express acidity or alkalinity
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
PVC
Polyvinyl chloride
QA
Quality Assurance
QC
Quality Control
QMP
Quality Management Plan
R
Radius
Ref.
Reference
RPD
Relative Percent Difference
rpm
Revolutions per minute
S
Sulfur
SOP
Standard Operating Procedures
T
Total
TCLP
Toxicity Characteristic Leachate Procedure
TDS
Total dissolved solids
TOC
Total organic carbon/compound
TOP
Total organic parameter
TPH
Total petroleum hydrocarbons
TS
Total solids
TSS
Total suspended solids
U.S.
United States
VAC
Voltage alternating current
Micron
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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 Davis
Technologies International Corp. (DTIC) Industrial Wastewater Treatment Plant for the
Metal Finishing Industry (IWTP-MF). 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 Director.
The IWTP-MF system is designed to process wastewaters containing oils and/or dissolved
metals. The focus of testing will be to determine the quality of the effluent produced by the
IWTP-MF system at a pre-set flow rate, the quantity and characteristics of wastewater
sludge produced during treatment, the characteristics of recovered oil, and the approximate
cost of operation. In terms of effluent water quality, of particular interest is the ability of
the IWTP-MF to meet existing effluent standards for the Metal Finishing category [Ref. 1]
and proposed more stringent effluent standards for the Metal Products and Machinery
(MP&M) industrial point source category [Ref. 2], The Metal Finishing regulations were
promulgated in July 1983 and have served as the wastewater discharge limits for most
companies engaged in metal finishing operations since 1984. The proposed MP&M
limitations were published on January 3, 2001, and will be promulgated in final form in
December 2002. The MP&M limitations will replace the Metal Finishing limitations for
most metal finishing companies. Although the proposed MP&M limitations are subject to
change, the final limitations are expected to be similar.
Testing of the IWTP-MF system will be conducted at Federal-Mogul Corporation's facility
in Blacksburg, VA. Federal-Mogul is a major global manufacturer of original and
aftermarket automobile parts (www.federal-mogul.com); engine bearings are manufactured
at the Blacksburg facility. The industrial operations that generate wastewater at this location
include machining, metal forming, cutting, cleaning, electroplating, and conversion coating.
Testing will consist of three test runs, with a different raw wastestream processed during
each test run. The three wastestreams represent wastewaters from three common metal
finishing and/or MP&M manufacturing configurations:
1) Oily wastewater from metal machining/forming/cleaning.
2) Metal bearing wastewater from metal finishing.
3) A 10%/90% mixture of (1) and (2).
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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/quality control requirements of this task that will ensure the accuracy of
data, the use of proper data interpretation procedures, and an emphasis on worker health and
safety considerations.
2.0 TECHNOLOGY DESCRIPTION
2.1 Theory of Operation
The IWTP-MF system combines well known physical-chemical treatment processes (pH
adjustment, flocculation, and dissolved air flotation) that the manufacturer indicates have
been enhanced through design and engineering of the processing hardware and control
software and through use of a proprietary polymer that works over a wide range of
conditions. The treatment system is constructed of standard off-the-shelf components (PVC
Schedule 80 piping, pumps, sensors, etc.) and custom stainless steel dissolved air flotation
(DAF) tanks. It is also equipped with remote monitoring capability.
Effluent from the IWTP-MF system is reported to be very low in organics (i.e., oil), and
metals, and users may be able to directly reuse the treated effluent or recycle it after further
polishing (e.g., ion exchange or membrane technology).
According to the manufacturer, the IWTP-MF system is particularly applicable to
wastestreams containing both oils and dissolved metals, a situation common to metal
finishing and MP&M facilities. The IWTP-MF system can reportedly process wastewaters
containing oil in free, dissolved, dispersed, and emulsified forms. Most wastewater treatment
systems employed by metal finishing facilities are not specifically designed to process
wastewaters containing significant concentrations of oil, although oil is usually present in
these wastewaters as a result of metal cleaning operations, where cutting oils and coolants are
removed from the parts prior to metal finishing. Also, ancillary activities, such as machining,
are often present at these facilities and may contribute oily wastes. Significant
concentrations of oil can prevent complete and cost-effective treatment of the heavy metal
wastewater and can reduce the ultimate reusability of the wastewater.
2.2 Description of IWTP-MF System
The IWTP-MF system that will be tested is a mobile unit with a flow capacity of 75 to 115
liters/min (approximately 20 to 30 gallons per minute (gpm)). Photographs of the exterior
and interior of the mobile system are shown in Figures 1 and 2. A diagram showing the
layout of tanks is presented in Figure 3.
The IWTP-MF system consists of two separate processes, oil recovery and metals
precipitation, and each process consists of three stages. In the first stage of oil recovery, the
hydrocarbon (oil) is cracked via a pH adjustment with hydrochloric acid (HCL). The second
stage is flocculation, where a proprietary polymer is added that captures the hydrocarbons in
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a floe (small mass). In the third stage, dissolved air is injected into the wastewater, forcing
the flocculated material to the surface, where it is skimmed off and pumped to a collection
tank.
The metals treatment process is also conducted in three stages. In the first stage, the pH of
the wastewater is adjusted using sodium hydroxide. This causes metals to precipitate in a
hydroxide form. In the second stage, ferric chloride, acting as a coagulant and a proprietary
polymer are added, which causes precipitated metals to agglomerate in a dense floe. In the
third stage, dissolved air is injected into the wastewater, forcing the flocculated material to
the surface, where it is skimmed off and pumped to a collection tank.
Figure 1. Exterior of Mobile DTIC IWTP-MF System
Figure 2. Interior of DTIC IWTP-MF System
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Reagents Emulsion Breaking Solids Collection
Figure 3. Diagram of DTIC IWTP-MF System
2.3 Commercial Status
The DTIC IWTP-MF is a commercial product. A DTIC mobile unit can be leased and used
on a temporary basis, or a permanent system can be purchased and installed. The mobile
system has been used to treat wastewaters generated from metalworking, metal finishing,
machinery repair/cleaning, and textile processes. Figure 4 shows the IWTP-MF system
operating at an industrial site.
Figure 4. DTIC IWTP-MF in Use at an Industrial Site
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2.4 Environmental Significance
Wastewaters containing oil are often inadequately treated by conventional hydroxide
precipitation systems because oil can cause precipitated particles to remain suspended or
float in clariflers, resulting in carryover of solids to the discharge. As a result, both the oil
and grease (O&G) and metals concentrations of the effluent may exceed effluent limitations.
The DTIC IWTP-MF system is designed to process oily wastewater, metal-bearing
wastewater, or a combination of these two common Metal Finishing or MP&M industrial
point source category wastestreams. In each case, the effluent often is reported to be below
10 mg/L O&G and near detection limits for regulated metals. When processing oily
wastewater, the oil is recovered prior to metals treatment and can be used as a source of
energy. In addition to recovering a valuable resource, oil recovery improves subsequent
treatment operations (e.g., filtration) and reduces the quantity of sludge generated by the
metals precipitation process. Also, by producing an effluent that is very low in O&G
content, the effluent is more amenable to recycling. This is due to the fact that oil can blind
technologies such as ion exchange resins and membranes that are used for final polishing
prior to water reuse.
2.5 Local Installation
The DTIC IWTP-MF system will be installed at Federal-Mogul in Blacksburg, VA. This
facility manufactures engine bearings used in automobiles. The Federal-Mogul facility has
been in production since 1971. The present facility consists of 208,000 ft2 of manufacturing
and office space.
At Federal-Mogul, process wastewater is generated from various manufacturing operations.
These operations can be divided into two main types: (1) metal forming/machining/cleaning
and (2) metal finishing. Wastewaters from metal forming/machining/cleaning average
approximately 38,000 1/day (10,000 gpd), and they contain oil (free and emulsified), which is
a concern during treatment. The quantity of metal finishing wastewater averages
approximately 680,000 1/day (180,000 gpd). It contains certain regulated metals (chromium,
copper, lead, and zinc) and a low concentration of oil.
The wastewater treatment system in use at Federal-Mogul was installed in 1982, and some
changes and additions have been made since then. The present system consists of
pretreatment (destruction of cyanide, chromium reduction, ultrafiltration for oil removal),
hydroxide precipitation of metals, clarification, and sand filtration. Wastewaters containing
high concentrations of lead are segregated from other streams and are separately processed
using an evaporator system. However, lead also is present in the wastestreams processed
though the wastewater treatment system. Sludge generated by the main treatment system is
dewatered on a filter press. Treated effluent is discharged to the city sewer system.
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The current discharge limits for Federal-Mogul and recent analyses of discharges are shown
in Table 1. Also shown in Table 1 are the proposed pretreatment limits for existing sources
for the MP&M General Metals subcategory.
The proposed MP&M limitations for the General Metals subcategory are based on:
In-process flow control and pollution prevention
Segregation of wastewater streams
Preliminary treatment steps as necessary (including oils removal using oil-water
separation by chemical emulsion breaking)
Chemical precipitation using lime or sodium hydroxide
Sedimentation using a clarifier
The pretreatment standards for existing sources for the MP&M Oily Waste subcategory are
presented in Table 2. The proposed MP&M limitations for the Oily Waste subcategory are
based on:
In-process flow control
Pollution prevention
Oil-water separation by ultrafiltration
The proposed MP&M General Metals subcategory (40 CFR 438.15) limitations are
significantly lower than the existing limitations. These new standards will be published in
final form in December 2002, and companies will need to comply with the limitations
starting in December 2005. It is apparent that the existing Federal-Mogul wastewater
treatment system is consistently meeting current limitations, but not meeting all of the
proposed MP&M limitations. With respect to the proposed MP&M limits, the parameters of
greatest concern are chromium, copper, lead, and zinc. Recent analyses of Federal-Mogul
raw wastewater (i.e., before treatment) for these four parameters are summarized in Table 3.
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Table 1. Summary of Current Limitations and Proposed Regulations Applicable to Federal-
Mogul and Recent Discharge Data
Current Federal-
Federal-Mogul
Proposed MP&M
Mogul Limitations
Historical Effluent
Pretreatment Standards for
IWTP Permit
Data
Existing Sources (PSES)
General Metals
Parameter
Subcategory
Daily
Max.,
mg/L
Monthly
Avg.,
mg/L
Daily
Max.,
mg/L
Monthly
Avg., mg/L
Daily
Max.,
mg/L
Monthly
Avg., mg/L
Cyanide T
0.5
NR
0.018
0.01
0.21
0.13
Cyanide A
NR
NR
ND
ND
0.14
0.07
Cadmium
0.02
NR
0.004
<0.004
0.14
0.09
Chromium T
1.0
NR
NR
NR
NR
NR
Copper
1.0
NR
0.699
0.643
0.55
0.28
Lead
0.5
NR
0.466
0.169
0.04
0.03
Mercury
0.005
NR
0.0002
<0.0002
NR
NR
Manganese
NR
NR
ND
ND
0.13
0.09
Molybdenum
NR
NR
ND
ND
0.79
0.49
Nickel
1.0
NR
0.07
0.02
0.50
0.31
Silver
NR
NR
0
0
0.22
0.09
Tin
NR
NR
ND
ND
1.4
0.67
Zinc
2.61
1.48
1.05
0.584
0.38
0.22
Selenium
0.02
NR
0
0
NR
NR
Total
0
NR
0
0
NR
NR
Residual CI
O&G (local
100
NR
57
82.14
NR
NR
limit)
O&G (as
NR
NR
ND
ND
15
12
HEM)
TSS
NR
NR
18.5
13.9
NR
NR
TOC
NR
NR
ND
ND
87
50
TOP
NR
NR
ND
ND
9.0
4.3
Sulfide (as S)
NR
NR
ND
ND
31
13
Notes:
NR = not regulated.
ND = no data.
Federal-Mogul discharge data are from seven recent months.
Current Federal-Mogul limitations are based on a combination of local standards and Federal standards (40
CFR 433). The values shown are the most stringent limitations.
O&G (as hexane extractable material (HEM)) is not regulated under pretreatment standards for the General
Metals subcategory. However, it is regulated under the Best Practical Treatment (BPT) limitations for
direct dischargers in the General Metals subcategory (40 CFR 438.12). The values shown are the BPT
proposed limitations.
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Table 2. Pretreatment Standards for Existing Sources for the MP&M Oily Wastes
Subcategory (40 CFR 438.65)
Parameter
Maximum Daily, mg/L
Maximum Monthly mg/L
TOC (as indicator)
633
378
TOP
9.0
4.3
Sulfide (as S)
31
13
O&G (as HEM)
27
20
Notes:
Upon agreement with the permitting authority, facilities must choose to monitor for total organic parameters (TOP)
or total organic carbon (TOC), or implement a management plan for organic chemicals as specified in 40
CFR 438.4(a).
O&G (as HEM) is not regulated under pretreatment standards for the Oily Wastes subcategory. However, it is
regulated under the best practical treatment (BPT) limitations for direct dischargers in the Oily Wastes
subcategory (40 CFR 438.62). The values shown are the BPT proposed limitations.
Table 3. Raw Wastewater Influent Data from Federal-Mogul
Parameter
Average Concentration, mg/L
Maximum Concentration, mg/L
Chromium
0.5
13.8
Copper
23.3
60.2
Lead
7.3
36.6
Zinc
5.2
6.5
Notes:
Based on analyses of 90 samples collected between 5/24/00 and 11/16/00.
3.0 EXPERIMENTAL DESIGN
3.1 Test Goals and Objectives
The overall goals of this ETV-MF project are to (1) evaluate the ability of the DTIC IWTP-
MF system to remove pollutants from metal finishing and MP&M point source category
wastewaters, with the metal finishing and proposed MP&M effluent guidelines used as target
effluent concentrations, and (2) to evaluate the operating characteristics of the system with
respect to approximate operating costs, effluent characteristics, oil recovery, and sludge
characteristics.
The following is a summary of primary project objectives. For the installation at Federal-
Mogul:
Conduct verification testing in order to:
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1) Determine the ability of the IWTP-MF system to remove specific pollutants from
wastestreams and meet the applicable metal finishing and proposed MP&M daily
maximum limitations.
2) Determine the ability of the IWTP-MF system to recover oil from wastewater.
3) Determine the quantity and chemical characteristics of the sludge generated by the
treatment process.
Determine the cost of operating the IWTP-MF system for the specific conditions
encountered during testing.
1) Identify operating and maintenance (O&M) tasks.1
2) Determine the quantity and cost of chemical reagents used.
3) Determine the quantity and cost of energy consumed by operating the system.
4) Determine the cost of sludge disposal.
5) Determine the cost savings associated with the recovered oil.
Quantify the environmental benefit by determining the reduction in metals discharged to
the Blacksburg Publicly Owned Treatment Works (POTW) and the percentage of oil
recovered.
3.2 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:
source and input volumes of raw wastewater (liters/test run)
input quantity of chemical treatment reagents (kg/test run) and other materials used in
treatment and costs ($/test run)
output volume of recovered oil (liters/test run)
output volume of sludge (liters/test run)
chemical characteristics of raw wastewater [mg/L of TSS, O&G, O&G (as HEM)2, TOC,
cadmium, chromium, copper, lead, manganese, molybdenum, nickel, tin, sulfide (as S),
zinc, and TDS]*
chemical characteristics of treated effluent [mg/L of TSS, O&G, O&G (as HEM), TOC,
cadmium, chromium, copper, lead, manganese, molybdenum, nickel, tin, sulfide (as S),
zinc, and TDS]*
chemical characteristics of recovered oil (% water)
chemical characteristics of sludge (% solids, mg/L of cadmium, chromium, copper, lead,
1 O&M tasks will be observed and documented; however, the associated costs will not be verified during this project
since operation of the mobile IWTP-MF system by DTIC staff will not be representative of a permanently installed
system operated by plant personnel.
2 O&G refers to oil and grease as measured by EPA Method 413.1 (freon extraction). O&G (as HEM) refers to oil and
grease as measured by EPA Method 1664 (hexane extraction).
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manganese, molybdenum, nickel, tin, and zinc)
O&M labor tasks
energy use for IWTP-MF (e.g., pumps) (kWh/test run) and costs ($/test run)
*Parameters vary by test run as described in section 3.4.3.
Non-Critical Measurements:
pH
instantaneous flow rate of input wastewater
3.3 Test Matrix
The verification test will be performed in three distinct test periods or "runs." The raw
wastestream will be varied for each test run. Test run 1 will have a duration of one day, and
test runs 2 and 3 will each have a duration of 4 days. During each 24-hour period, a separate
set of influent and effluent samples will be collected and analyzed. Therefore, one paired set
of influent and effluent data points will be generated during run 1 and four sets of paired data
points will be generated each for test runs 2 and 3. Sampling of the oil and sludge will be
limited to once per test run. The varied operating conditions for the three test runs are shown
in Table 4.
Table 4. Test Matrix
Test Run
Duration
Conditions
Test Run 1
One -24 hr Test
-75 liters/min (20 gpm) flow
-100% oily wastewater
Test Run 2
Four -24 hr Tests
-75 liters/min (20 gpm) flow
-100% metal-bearing wastewater
Test Run 3
Four -24 hr Tests
-75 liters/min (20 gpm) flow
-10% oily/90% metal-bearing
wastewater
Raw wastewater (prior to treatment by ultrafiltration) generated by the Federal-Mogul metal
forming/machining/cleaning operations will be used as the source of oily wastewater.
Wastewater from metal finishing operations will be the source of metal-bearing wastewater.
This wastewater will be pretreated for cyanide destruction and chromium reduction, prior to
treatment in the IWTP-MF system.3
Test objectives and measurements are summarized in Table 5.
The analytical test parameters selected for this verification test are the parameters found in
the metal finishing and proposed MP&M regulations for the applicable subcategories.
3 The system that will be tested at Federal-Mogul is not designed for cyanide oxidation or chromium reduction.
Therefore, the metal-bearing wastewater will be processed through these two pretreatment steps using the existing
Federal-Mogul system. The pretreated metal-bearing wastewater will then serve as the influent for the IWTP-MF
system.
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Testing and Operating Procedures
3.4.1 Set-Up and System Initialization Procedures
DTIC will be responsible for transporting the IWTP-MF to the test site, connecting
the system to the Federal-Mogul wastewater sumps, initializing the system, and
operating the system during testing. They will also be responsible for reporting to the
ETV-MF Project Manager all operational and maintenance activities performed
during the verification test. The system will be set up and operated for a time period
of at least 24 hours prior to start of the first test run. The first test run will begin once
DTIC indicates that the system is operational and stable. Following each test run and
prior to the start of subsequent test runs, the wastewater feed will be changed
according to the test matrix described in section 3.3, and the system will be run for a
minimum time period of 4 hours before initiating the next test run. This time period
will allow the system to stabilize under the new feed characteristics.
A photograph of the area where the IWTP-MF system will be located during testing is
shown in Figure 5. The DTIC trailer will be parked in a fenced area, between the
cooling tower shown on the right and the building shown on the left (see Figure 5).
This building houses the existing Federal-Mogul treatment system. The existing raw
and treated wastewater sumps (in ground) are located directly next to the building.
This location will provide easy access to the source of raw wastewater and the
receiving tank for the treated effluent.
11/17/2000
DTIC trailer will
be located here
In-ground sumps
Figure 5. Planned Location for IWTP-MF During Verification
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Table 5. Test Objectives and Related Test Measurements for Evaluation
of the IWTP-MF System
Test
Test Objective
Test Measurement
Runs 1,
2 and 3
Determine the ability of the IWTP-MF system to
remove specific pollutants from wastestreams
and meet the applicable metal finishing and
proposed MP&M limitations.
-Source and input volumes of raw wastewater.
-Chemical characteristics of the influent and
effluent.
Runs 1,
2 and 3
Determine the ability of the IWTP-MF system to
recover oil from wastewater.
-Source and input volumes of raw wastewater.
-O&G content of the influent and effluent.
-Quantity of recovered oil.
-Chemical characteristics of recovered oil.
Runs 1,
2 and 3
Determine the quantity and chemical
characteristics of the sludge generated by the
treatment process.
-Source and input volumes of raw wastewater.
-Quantity and chemical characteristics of the
sludge.
Runs 1,
2 and 3
Determine the cost of operating the IWTP-MF
system for the specific conditions encountered
during testing.
-Source and input volumes of raw wastewater.
-O&M labor tasks performed.
-Energy use for IWTP-MF.
-Input quantity and costs of chemical treatment
reagents (pounds/test run) and other materials
used in treatment.
-Cost of sludge disposal.
-Cost savings associated with the recovered oil.
Run 3
Quantify the environmental benefit by
determining the reduction in metals discharged
to the Blacksburg POTW.
-Source and input volumes of raw wastewater.
-Chemical characteristics of the effluent.
-Historical effluent data.
3.4.2 System Operation
DTIC will be responsible for operating the IWTP-MF system according to the
procedures found in Appendix A. As discussed in section 3.4.1, the first test run will
begin once DTIC indicates that the system is operational and stable. Following each
test run, and prior to the start of subsequent test runs, the wastewater feed will be
changed according to the test matrix described in section 3.3, and the system will be
run for a minimum time period of 4 hours before initiating the next test run. This
time period will allow the system to stabilize under the new feed characteristics. The
unit will be operated for one day during test run 1 and four days each during each test
runs 2 and 3.
The source of raw wastewater is an equalization sump that is part of the Federal-
Mogul wastewater treatment system. Federal-Mogul will be responsible for diverting
the correct wastestream (i.e., untreated oily, metal-bearing, or mixture) to the
equalization sump. The effluent from the IWTP-MF system will be pumped to
Federal-Mogul's mixing tank located at the head of their treatment system. Oil
recovered by the IWTP-MF system and sludge generated by the system will be
collected in separate drums that will be located next to the DTIC trailer. These
products will be disposed through means used by the Federal-Mogul operation.
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3.4.3 Sample Collection and Handling
Automatic composite samplers (ISCO 6700 Series or equivalent) will be used to
collect the influent and effluent samples. These samples will be collected in glass
containers. The composite samples will be collected on a time-proportioned basis.
The automatic samplers will be set to collect 80 ml + 10 ml every 15 minutes. Grab
samples of the influent and effluent will be collected for O&G, O&G (as HEM), pH,
and sulfide (as S) analyses. These grab samples will be collected 4 ±_2 hours after the
start of the sampling and 4 + 2 hours before the end of the 24-hour test period. The
automatic sampler will be used to accomplish the collection of grab samples. It will
be used between sampling events to avoid interfering with the collection of the
composite samples. The composite sample collection container will be set aside. The
automatic sampler will be set on "manual pump" and the grab sample bottles will be
filled. When grab sampling is completed, the composite sample collection container
will be placed back into the automatic sampler and composite sampling resumed.
Because there is the potential for oil to adhere to the inside of the sampler tubing and
sample collection container, the sampler tubing and collection container will be
observed for adherence of oil and documented in the field notebook. An abbreviated
sampling run using the automated sampler and fresh water will be performed to
ensure the sampler is programmed to collect the correct amount of sample prior to the
first test run. An equipment blank sample will be collected prior to the each test run.
Deionized water will be pumped through the automated sampler and tubing to clean
the tubing and pump. After the pump and tubing has been cleaned deionized water
will be pumped through the sampler and the deionized water will be analyzed for
O&G, O&G (as HEM), TOC, metals, and sulfide (as S).
Grab samples of the recovered oil will be collected using a clean ladle, after first
completely mixing the material. Grab samples of the sludge will be collected using a
clean spatula, after first completely mixing the material. Oil and sludge samples will
be placed into 1-liter, wide mouth glass jars. Samples will be collected according to
the schedule presented in Table 6. The analytical parameters for each sample are
also presented in Table 6. Sampling events will be recorded on the form shown in
Appendix B.
At the time of sampling, each sample container will be labeled with the date, time,
and sample II) number. Samples to be analyzed at an off-site laboratory will be
accompanied by a chain of custody form; the ETV-MF Project Manager will generate
the chain of custody form. The chain of custody 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 chain of
custody signatures. All samples will be transported in appropriate sample transport
containers (e.g., coolers with packing and blue ice) directly to the lab or by common
carrier using two-day express service. The transport containers will be secured with
tape to ensure sample integrity during the delivery process to the analytical
laboratory. The ETV-MF Project Manager or designee will perform sampling, and
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Table 6. Sampling Locations, Frequency and Parameters
Test Run
Sample
Sample Location
Frequency/Type
Parameters
Run 1
Raw
wastewater
Automatic composite
sampler will draw
sample from the Federal-
Mogul equalization
sump.
Daily 24-hour composite
samples collected during
each test run.
TSS, TOC, cadmium,
chromium, copper, lead,
manganese, molybdenum,
nickel, tin, zinc, TDS
Run 1
Raw
wastewater
Sample from the
Federal-Mogul
equalization sump.
2 per 24 hours.
Grab samples.
O&G, O&G (as HEM), sulfide
(as S), pH
Run 1
Treated effluent
Automatic composite
sampler will draw
sample from treated
effluent return line.
Daily 24-hour composite
samples collected during
each test run.
TSS, TOC, cadmium,
chromium, copper, lead,
manganese, molybdenum,
nickel, tin, zinc, TDS
Run 1
Treated effluent
Sample from treated
effluent return line.
2 per 24 hours.
Grab samples.
O&G, O&G (as HEM), sulfide
(as S), pH
Run 1
Recovered oil
Recovered oil drum
1/test run. Representative
grab sample collected after
completion of test run.
% water
Run 1
Sludge
Sludge drum
1/test run. Representative
grab sample collected after
completion of test run.
% solids, cadmium,
chromium, copper, lead,
manganese, molybdenum,
nickel, tin, zinc
Runs 2 and
3
Raw
wastewater
Automatic composite
sampler will draw
sample from the Federal-
Mogul equalization
sump.
Daily 24-hour composite
samples collected during
each test run.
TSS, TOC, cadmium,
chromium, copper, lead,
manganese, molybdenum,
nickel, tin, zinc, TDS
Runs 2 and
3
Raw
wastewater
Sample from the
Federal-Mogul
equalization sump.
2 per 24 hours.
Grab samples.
O&G, O&G (as HEM), sulfide
(as S), pH
Runs 2 and
3
Treated effluent
Automatic composite
sampler will draw
sample from treated
effluent return line.
Daily 24-hour composite
samples collected during
each test run.
TSS, TOC, cadmium,
chromium, copper, lead,
manganese, molybdenum,
nickel, tin, zinc, TDS
Runs 2 and
3
Treated effluent
Sample from treated
effluent return line.
2 per 24 hours.
Grab samples.
O&G, O&G (as HEM), sulfide
(as S), pH
Runs 2 and
3
Recovered oil
Recovered oil drum
1/test run. Representative
grab sample collected after
completion of test run.
% water
Runs 2 and
3
Sludge
Sludge drum
1/test run. Representative
grab sample collected after
completion of test run.
% solids, cadmium,
chromium, copper, lead,
manganese, molybdenum,
nickel, tin, zinc
labeling, and ensure that samples are properly secured and shipped per regulations
under Department of Transportation (DOT) and OSHA to the laboratory for analysis.
The sample quantities required for analysis of samples, field duplicates, matrix spike
and matrix spike duplicates are identified in Table 7. Sample container volumes are
identified in Table 8.
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Table 7. Sample Quantities from Each Wastestream by Parameter
Sample
Parameter
Equipment
Run 1
Run 2
Run 2
Run 2
Run 2
Run 3
Run 3
Run 3
Run 3
Location
Blank
Day 1
Day 1
Day 2
Day 3
Day 4
Day 1
Day 2
Day 3
Day 4
Influent
TOC
4
4
4
4
4
4
8
4
4
TSS/TDS
1
1
1
1
1
1
2
1
1
Metals
1
1
1
1
1
1
2
1
1
O&G
4
4
4
4
4
4
7
4
2
O&G (as HEM)
4
4
4
4
4
4
7
4
2
Sulfide
2
2
2
2
2
2
5
2
1
Effluent
TOC
3
8
4
8
4
4
4
8
4
4
TSS/TDS
2
1
2
1
1
1
2
1
1
Metals
3
2
1
2
1
1
1
2
1
1
O&G
3
7
4
7
4
4
4
7
4
4
O&G (as HEM)
3
7
4
7
4
4
4
7
4
4
Sulfide
3
5
2
5
2
2
2
5
2
2
Recovered
2
3
2
oil
Sludge
1
2
1
3.4.4 Process Measurements and Information Collection
Process measurements and information collection will be conducted to provide the
following data: flow, reagent usage, recovered oil quantity, sludge quantity,
electricity use, operation and maintenance activities, and historical discharge data.
The methods that will be used for process measurements and information collection
are discussed in this section.
3.4.4.1 Wastewater Flow Rate and Volume Processed
The volume of wastewater processed during each test run will be measured
using a GFI 5500 series flow meter/totalizer. This instrument is presently
installed in the IWTP-MF system. The flow meter will be calibrated prior to
testing using a "stopwatch and bucket" method. The flow totalizer will be
read at the start and end of each test run and three times per day during each
test run. The instantaneous flow rate will be read three times per day during
each test run. The flow meter readings and the times those readings are taken
will be recorded on the data collection form in Appendix B.
3.4.4.2 Chemical Reagent Usage Data
The quantities of treatment reagents (hydrochloric acid, ferric chloride,
polymer and sodium hydroxide) used will be measured and recorded on a
daily basis. This will be accomplished by filling the feed tanks at the
beginning of each day to a preset point, and measuring the volume needed to
refill the feed tanks at the end of each 24-hour period. The volume of reagent
used will be entered on the form in Appendix B.
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3.4.4.3 Quantities of Recovered Oil and Sludge
Empty drums will be used at the start of each test run for collection of
recovered oil and sludge. The quantities of recovered oil and sludge
generated will be measured at the end of each 24-hour sampling period in
terms of both volume and weight. This will be accomplished by measuring
the volume in the drums at the end of the 24-hour period. The two
volume/weight measurements will be recorded on the form in Appendix B.
The volume of the contents of the drums will be calculated by subtracting the
initial volume from the final volume. Volume will be determined by
measuring the depth of the material in the drum and the diameter of the drum
and using the standard formula for calculating the volume of a cylinder (3.141
x r2h). These measurements will be made using a meter stick with increments
of 0.001 m. The weight of the recovered oil and sludge will be determine by
weighing a container and than weighing it with a liter of contents. The weight
of the recovered oil and sludge is weight (final weight minus the weight of the
container) of one liter volume time the number of liters. A scale (0 to 100 kg)
will be used for weighing the container. The scale will be calibrated with
mass weights prior to the verification test; the calibration will be recorded in
the field notebook.
3.4.4.4 Electricity Use Data
Electricity use will be calculated by determining the power requirements and
cycle times of pumps and other powered devices associated with the IWTP-
MF.
3.4.4.5 System Operation and Maintenance Labor Tasks
The ETV-MF Project Manager will observe operation of the IWTP-MF
system during the verification test. DTIC operating personnel will report any
IWTP-MF system changes or maintenance activities to the ETV-MF Project
Manager. This includes changes to the flow rate or chemical feed rate, filter
replacement, and similar activities. The ETV-MF Project Manager will record
notes pertaining to these activities on the form in Appendix B.
3.4.4.6 Historical Discharge Data
Historical discharge data covering the previous 12 months will be provided by
Federal-Mogul. These data will be used to establish the performance of the
existing treatment system. This performance will be used in the analysis of
environmental benefits.
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3.4.4.7 Cost Data
DTIC will provide unit cost data for the chemical reagents. Federal-Mogul
will provide the cost data for electricity, labor, sludge disposal, and the value
of recovered oil.
3.5 Analytical Procedures
Chemical analyses of the samples will be conducted to evaluate the effectiveness of the
DTIC IWTP-MF and the characteristics of residuals. The selected analytical parameters are
primarily chemical parameters that are regulated under 40 CFR 433 or proposed under 40
CFR 438. All analytical procedures that will be used during this verification test are EPA
methods. A summary of analytical tests is presented in Table 8, and the discussion of these
parameters follows.
3.5.1 Oil and Grease (O&G)
Oil is contributed to the cleaner bath when parts are processed. The oil is a
combination of machining and cutting oils and coolants that are used in
metalworking. Oil loading and the efficiency of oil separation will be measured by
performing oil measurements on both the influent and effluent streams of the DTIC
IWTP-MF.
Two analytical methods for measuring oil and grease will be used, EPA Method
413.1 and EPA Method 1664. It is necessary to use both methods in order to
determine if the DTIC IWTP-MF can meet applicable regulations and to compare
with historical records. The selected samples will be acidified with hydrochloric acid
to lower the pH to less than 2. Method 413.1 uses Fluorocarbon 113 as the extraction
solvent, and Method 1664 uses n-hexane as the extraction solvent. The EPA Method
1664 is a liquid/liquid extraction, gravimetric procedure for the determination of the
extractable materials. EPA Method 413.1 is liquid/liquid extraction gravimetric
procedure for the determination of oil and grease.
3.5.2 Solids
Solid material is present in the wastewater in both dissolved and suspended forms.
Removal of solids is often an objective of treatment even though solids themselves
are not always regulated. This is due to the fact that the solids present in wastewater
are often composed of regulated material such as metals. A high suspended solids
concentration in a treated effluent is often a sign of a poorly operated treatment
system. High dissolved solids may limit the reusability of the water for rinsing or
other purposes.
To determine the effectiveness of the DTIC IWTP-MF unit with regard to removal of
particulates, tests for non-filterable residue (EPA Method 160.2) will be performed.
The referenced method produces values commonly referred to as total suspended
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solids (TSS). The EPA Method 160.1, filterable residue, will be used to determine
total dissolved solids (TDS).
160.1 = Filterable Residue (TDS)
160.2 = Non-filterable Residue (TSS)
Table 8. Summary of Analytical Tests and Requirements
Parameter
Test Method
Sample
Sample
Preservation/
Hold
Bottle
Container
Handling
4°C
Time
O&G
EPA Method
413.1
Glass jar
1000 ml
4°C
Acidify to pH
<2 w/HCL
28 days
O&G
EPA Method
1664
Glass jar
1000 ml
4°C
Acidify to pH
<2 w/HCL
28 days
TSS
EPA Method
160.2
Polyethylene
500 ml
4°C
7 days
TOC
EPA Method
415.1
Glass
40 ml vials
x 4
4°C
Acidify to pH
<2 w/H2S04
28 days
TDS
EPA Method
160.1
Polyethylene
250 ml
4°C
7 days
pH
Digital meter
Polyethylene
100 ml
N/A
Analyze
immediately
Metals
SW-846
Polyethylene
500 ml
4°C
6 months
Wastewater
3005A/6010B
Acidify to pH
<2 w/HN03
Metals
SW-846
Polyethylene
500 g
4°C
6 months
Sludge
3050B/6010B
Sulfide (as S)
EPA Method
Polyethylene
1000 ml
4°C Zinc
7 days
Wastewater
376.1
Acetate +
NaOH to pH
> 12
% water
Karl-Fisher
Glass
250 ml
4°C
28 days
Note: A separate portion of the sludge sample will be dried at 100°C to constant weight to
determine percent moisture. The moisture results will be used to correct sample
concentrations to a dry weight basis.
3.5.3 Total Organic Carbon (TOC)
Total organic carbon is a direct measure of the organic content of water. It can be
used to monitor processes for the treatment or removal of organic contaminants
without undue dependence on the oxidation states, and can do so at low
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concentrations. Organic brighteners, cleaning compounds, oil and similar materials
contribute to the organic content of metal finishing wastewaters. To determine the
effectiveness of the DTIC IWTP-MF unit with regard to removal of organics, a TOC
test (EPA 415.1) will be performed. The selected samples will be preserved with
sulfuric acid to lower the pH to less than 2. The samples should be collected so they
contain as little air as possible (zero headspace). The analysis method is a
combustion-infrared method.
3.5.4 Metals
Various metals are regulated under 40 CFR 433 and 40 CFR 438. The regulated
metal parameters include cadmium, chromium, copper, lead, manganese,
molybdenum, nickel, tin, and zinc. These metals are contributed to MP&M
wastewaters from electroplating and similar processes. To determine the
effectiveness of the DTIC IWTP-MF system with regard to removal of metals from
the wastewater, the selected test will determine the concentration of cadmium,
chromium, copper, lead, manganese, molybdenum, nickel, tin, and zinc. The selected
aqueous samples will be acidified with nitric acid to lower the pH to less than 2. For
the aqueous influent and effluent samples, the sample is digested using SW-846
Method 3005A and analyzed using SW-846 Method 6010B. This method is
Inductively Coupled Plasma - Atomic Emission Spectroscopy (ICP-AES). For the
analysis of the solid waste samples, the solid waste will be digested using SW-846
Method 3050B and will be analyzed using SW-846 Method 6010B.
3.5.5 Sulfide (as S)
Through development of the MP&M regulations, EPA has determined that sulfide is
present in MP&M facility wastewaters. Very little data exist for this parameter for
MP&M wastewaters and related treatment systems. To determine the effectiveness of
the DTIC IWTP-MF unit with regard to removal of sulfide, tests for sulfide (as S)
(EPA Method 376.1) will be performed on wastewater. The sample will be preserved
with zinc acetate and pH adjustment using sodium hydroxide to a pH greater than 12.
3.5.6 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 pH 7 and 10 buffers. The ETV-MF Program Manager will
record the manufacturer, lot number and the expiration date of the buffer in the field
notebook.
3.5.7 Percent Water in Oil
Percent water provides an indication concentration of the oil collected and the
analytical procedures determine the concentration is a Karl-Fisher method.
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3.5.8 Percent Solids in Sludge
Percent moisture in the sludge will be determined for part of the sludge sample. It
will be dried to constant weight at 100°C. The weight lost is the amount of moisture
that it contained. By subtracting the amount of moisture from the total weight, the
percent solids can be obtained.
QUALITY ASSURANCE/QUALITY CONTROL REQUIREMENTS
Quality Assurance/Quality Control 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. 3].
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 8.
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 sampling site. These include original observations, printouts, and readouts from
equipment for sample, standard, and reference QC analyses. 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 in the data
package submitted by the laboratory to CTC.
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 Program 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
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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.
The Laboratory Manager shall be ultimately responsible for all final data released
from the laboratory. The Laboratory Manager or designee will review the final
results for adequacy to task QA objectives. If the manager 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 manager will authorize a re-test. If
sufficient sample is not available for re-testing, a re-sampling shall occur. If the
sampling window has passed, or re-sampling is not possible, the manager will flag the
data as suspect. The Laboratory Manager signs and dates the final data package.
Data Reporting. A report signed and dated by the STL Project Manager 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 SOP
used for each parameter, the process or sampling point identification, the final result,
and the results of all QA/QC analyses (field duplicates, matrix spike, and matrix spike
duplicates). The ETV-MF Program Manager shall retain the data packages as
required by the ETV-MF QMP [Ref. 3].
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.
The oily wastewater, metal-bearing wastewater and oily/metal-bearing wastewater
mixture are different matrices. Therefore, a field duplicate, matrix spike and matrix
spike duplicate from the effluent of all three waste streams will be analyzed. A field
duplicate, matrix spike, and matrix spike duplicate from the influent of the oily/metal-
bearing wastewater mixture will also be analyzed. In addition, a field duplicate on a
sludge sample and on a recovered oil sample will be analyzed.
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:
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RPD = {(|Xi -X2|)/(Xi +X2)/2} x 100% = J lXl 1 x 100%
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 be equal to or less the relative percent
deviation limits provided in Table 9.
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:
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 9.
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
P
SSR ~ SR x 100%
SA
where:
SSR
SR
SA
spiked sample result
sample result (native)
the concentration added to the spiked sample
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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 9.
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.
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Table 9. QA Objectives
Critical
Measurements
Matrix
Method
Reporting
Units
Method of
Determination
MRL
mg/L or
mg/kg
Precision
(RPD)
Accuracy
(%
Recovery)
Completeness
O&G
Water
EPA 413.1
mg/L
gravimetric
1.0
<14
77 - 129
90
O&G (HEM)
Water
EPA 1664
mg/L
gravimetric
2.85
<30
70-130
90
TSS
Water
EPA 160.2
mg/L
gravimetric
4.0
<15
N/A
90
TDS
Water
EPA 160.1
mg/L
gravimetric
10
<10
N/A
90
TOC
Water
EPA 415.1
mg/L
combustion or
oxidation
1.0
<10
85-111
90
Metal
Water
SW-846 3005A
6010B
mg/L
ICP-AES
.003-0.1*
<10-12*
85-111
90
Solid
SW-846 3050B
6010B
mg/kg
ICP-AES
0.25-5.0*
<10-36*
85-111
90
Sulfide (as S)
Water
EPA 376.1
mg/L
titration
1.0
<10
90-110
90
pH
Water
Digital Meter
pH units
electrometric
. 1 pH unit
<2 pH unit
N/A
90
% Water
Recovered
oil
Karl-Fisher
%
titration
N/A
N/A
N/A
90
Flow rates:
Wastewater Feed
(Influent)
Wastewater
Product (Effluent)
Water
Water
Flow Totalizer
Flow Totalizer
Liters/min
Liters/min
Stop watch &
bucket
Stop watch &
bucket
10 %
10 %
<10
<10
N/A
N/A
90
90
EPA: EPA Methods and Guidance for Analysis of Water
SW-846: EPA Test Methods for Evaluating Solid Waste
* Depending on analyte
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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.
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
definition 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.")
MDL is defined as follows for all measurements:
MDL = t(n_i;i_oc = 0.99) xs
where: MDL = method detection limit
t(n-i,i-a = 0.99) = students t-value for a one-sided 99%
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.)
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4.2.3 Other Calculations
4.2.3.1 Ability to Meet Metal Finishing and Proposed MP&M
Limitations
The results from each daily set of analytical data will be compared to the
applicable Metal Finishing (Table 10) and Proposed MP&M limitations
(Table 11). To meet a Metal Finishing or MP&M daily maximum 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 daily analysis of the effluent. The applicable
limitations for test run 1 are the proposed pretreatment standards for
existing sources for the MP&M Oily Wastes subcategory (40 CFR
438.65). The applicable limitations for test runs 2 and 3 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 General Metals subcategory (40 CFR
438.15).
Table 10. Applicable Pretreatment Standards for Existing Sources for the
Metal Finishing Subcategory (40 CFR 433.15)
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
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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Table 11. Applicable Proposed Pre treatment Standards for Existing Sources for the
MP&M Oily Wastes Subcategory (40 CFR 438.65) and
General Metals Subcategory (40 CFR 438.15)
MP&M Oily Wastes
MP&M General Metals
Subcategory (40 CFR 438.65)
Subcategory (40 CFR 438.65)
Parameter
Daily Max.,
mg/L
Monthly Avg.,
mg/L
Daily Max.,
mg/L
Monthly Avg.,
mg/L
Cadmium
NR
NR
0.14
0.09
Chromium
NR
NR
0.25
0.14
Copper
NR
NR
0.55
0.28
Lead
NR
NR
0.04
0.03
Manganese
NR
NR
0.13
0.09
Molybdenum
NR
NR
0.79
0.49
Nickel
NR
NR
0.50
0.31
Tin
NR
NR
1.4
0.67
Zinc
NR
NR
0.38
0.22
O&G (as
27
20
15
12
HEM)
TOC
633
378
87
50
TOP
9.0
4.3
9.0
4.3
Sulfide (as S)
31
13
31
13
Notes:
NR = not regulated.
O&G (as HEM) is not regulated under pretreatment standards for the Oily Wastes or General Metals
subcategory. However, it is regulated under the BPT limitations for direct dischargers in the Oily
Wastes subcategory (40 CFR 438.62) and General Metals subcategory (40 CFR 438.12). The values
shown are the BPT proposed limitations.
4.2.3.2 Mass Balance
Mass balance calculations are performed for the metals parameters for test
runs 2 and 3. These 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% to 125%. The equation for the
zinc mass balance is shown below. Other mass balance equations will be
similar.
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Mass Balance (%) = [((ZE x VE) + (Zs x Vs))/(Zi x Vi)] x 100%
where: ZE = avg. effluent zinc concentration for test run
(mg/L)
VE = effluent volume processed during the test run
(liters)
Zs = sludge zinc concentration (mg/kg)
Vs = sludge quantity processed during the test run
(kg)
Zi = avg. influent zinc concentration for test run
(mg/L)
Vi = influent volume processed during the test run
(liters)
4.2.3.3 Oil Recovery Efficiency
The oil recovery efficiency is determined by comparing the quantity of oil
recovered to the quantity of oil in the influent. These calculations are
performed for each daily set of analytical results. The equation for oil
recovery calculation is shown below.
Oeff (%) = [(Oor x VOR)/(Oi x Vi)] x 100%
where: Oeff = oil recovery efficiency
Oor = concentration of oil in the oil recovery tank
(mg/L)
Vor = volume collected in the oil recovery tank
during the test run (liters)
Oi = avg. concentration of oil in the influent for test
run (mg/L)
Vi = influent volume processed during the test run
(liters)
4.2.3.4 Pollutant Removal Efficiency
The pollutant removal efficiency is calculated based on a comparison of
influent and effluent concentrations for each pollutant parameter.5 These
calculations are performed for each daily set of analytical results. The
equation for zinc removal is shown below. The removal efficiency rate
for each pollutant parameter will be separately calculated. These include:
O&G, O&G (as HEM), TOC, cadmium, chromium, copper, lead,
manganese, molybdenum, nickel, sulfide (as S), tin, and zinc.
5 Pollutant removal efficiency will only be calculated for parameters that are found at concentrations above detection
limits in the influent.
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Zremove (%)
[((Zi x Vi) - (ZE x Ve))/(Zi x Vi)] x 100%
where:
move = zinc removal efficiency
Zi = influent zinc concentration (mg/L)
Vi = influent volume processed during the test
period (liters)
ZE = effluent zinc concentration (mg/L)
Ve = effluent volume processed during the test
period (liters)
4.2.3.5 Energy Use
Energy requirements for the IWTP-MF system will be calculated by
summing the total quantity of horsepower hours and dividing by 1.341
HP-hr/kWh to arrive at electricity needs.
4.2.3.6 Cost Analysis
This analysis will determine the operating cost of the IWTP-MF system
considering the following cost parameters: chemical reagents, other
materials (e.g., filters), electricity, sludge management, and oil recovery.
Costs will be calculated separately for each cost parameter for each test
run and expressed in dollars per thousand liters processed (S/1000 1) by
dividing the cost by the total volume of wastewater processed for a given
test run. Total costs for each test run will be calculated by summing the
individual cost elements. The calculation of treatment cost for test run 1 is
shown below. Cost equations for other test runs will be similar.
C
where: C
-treat cost 1
= (Ri + Ml + El + Si + Oi)
¦treat cost 1 =
= total cost of treatment for test run 1 (S/10001)
Ri =
= cost of chemical reagents for test run 1
(S/1000 1)
Mi =
= cost of materials for test run 1 (S/1000 1)
Ei =
= cost of electricity for test run 1 (S/1000 1)
Si =
= cost of sludge management for test run 1
(S/1000 1)
Oi =
= cost (or savings) of oil recovery for test run 1
(S/1000 1)
4.2.3.7 Sludge Generation Analysis
The quantities of recovered oil and sludge and will be measured each day.
This will be accomplished by measuring the volume and weight of the
collection drums prior to the start of a 24-hour sampling period and at the
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end of the collection period. The volume/weight of the contents of the
drums will be calculated by subtracting the initial volume/weight from the
final volume/weight.
4.2.3.8 Environmental Benefit
This analysis will quantify the environmental benefit of the technology for
test run 3.6 Using historical data provided by Federal-Mogul, the
concentration of pollutants in the effluent from the existing Federal-Mogul
treatment system will be calculated (average of 12 months of data). These
values will be converted to grams per year discharged for each pollutant
parameter using historical flow rate data. These values will be compared
to the projected performance of the IWTP-MF system by using the
analytical results of verification testing7 and the same historical flow rate
data.
Pb = Ph - Pv
where: Pb = projected reduction of pollutant mass
discharged during 12 month historical period
Ph = sum of actual pollutant mass discharged during
12 month historical period
Pv = calculated sum of pollutant mass discharged
during 12 month historical period using
verification test results
Another aspect of the environmental benefit determination will be the
percentage of oil recovered during test run 3. The calculation presented in
4.2.3.3 will be used for this purpose.
4.3 Quality Audits
Technical System Audits. CTC will not perform a technical systems audit on this
verification test. The EPA Quality Assurance Manager may conduct an audit to assess
the quality of the verification test.
Internal Audits. In addition to the internal laboratory quality control checks, internal
quality audits will be conducted to ensure compliance with written procedures and
standard protocols.
6 The influent wastewater during test run 3 closely resembles the actual treatment system influent at Federal-Mogul.
Test runs 1 and 2 are not representative of the influent at Federal-Mogul and therefore will not be evaluated under
this particular analysis.
7 Historical effluent data are only available for certain parameters. Therefore, this environmental benefit analysis
will be limited to a comparison of those parameters only.
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Corrective Action. Corrective action for any deviations to established quality assurance
and quality control procedures during verification testing will be performed according to
section 2.10, Quality Improvement, of the ETV-MF QMP [Ref. 3].
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 and provided along
with the results to the CTC ETV-MF Program Manager. 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 Laboratory Manager detects these types of non-conformances. In all cases of non-
conformance, the Laboratory Manager will consider sample re-analysis or instrument
calibration verification as sources of corrective action. If insufficient sample is available
or the holding time has been exceeded, the Laboratory Manager will contact the CTC
ETV-MF Program Manager to discuss generating new samples, if possible, if a
determination is made 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
DTIC IWTP-MF system. The 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 test period and will conduct or oversee all
sampling and related measurements.8
James Davis will head the DTIC staff. DTIC will be responsible for transportation, set-
up, shutdown, and operation of the IWTP-MF system. They will be on-site or on-call
throughout the entire test period.
Federal-Mogul personnel will assist as needed by providing historical data and
identifying wastestreams. Federal-Mogul will be responsible for the disposal of all
residuals generated during the verification test.
The ETV-MF Project Manager or staff member will collect samples and record data from
process measurements.
8 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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Severn Trent Laboratories of Tampa, FL, is responsible for analyzing verification test
samples. The Project Manager, Michele Lersch, will be the point of contact (813-621-
0784). Severn Trent Laboratories is approved by the State of Florida for the analyses
identified in this test plan.
The ETV-MF Project Manager and Federal-Mogul (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 Center Manager.
5.2 Test Plan Modification
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 C), which is submitted to the CTC ETV-MF Program
Manager for approval. Upon approval, the modification request will be assigned a
number, logged, and transmitted to the requestor for implementation.
6.0 EQUIPMENT AND UTILITY REQUIREMENTS
The DTIC IWTP-MF system is a self-contained mobile system that is owned by DTIC. Pumps
and hosing that will be used to transfer the wastewater are also owned by DTIC. Influent
wastewater will be pumped from a storage tank, processed by the IWTP-MF system and returned
to a different storage tank. The storage tanks are part of the existing Federal-Mogul wastewater
treatment system. The only utility requirement for operating the IWTP-MF system is electricity,
and the requirement is 480 VAC/60Hz/three-phase/100 amperes. The IWTP-MF system has a
quick-connect for electricity. An appropriate electrical supply will be provided by Federal-
Mogul. The electrical supply connection will be performed by Federal-Mogul.
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 the
training, materials, and equipment necessary for assigned personnel 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 hazardous substance. The Federal-Mogul (host facility)
Hazard Communication Program will be reviewed during training prior to the start of any
work and will be reinforced throughout the test period. All appropriate Material Data
Safety Sheet (MSDS) forms will be available for chemical solutions used during testing.
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7.2 Emergency Response Plan
Federal-Mogul (host facility) has a contingency plan (Consolidated Emergency Response
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 the initial training, and
the plan will be accessible to them for the duration of the project
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 Federal-
Mogul (host facility) manufacturing facility: approved safety glasses with side
splashguards, ear plugs, and safety shoes.
The IWTP-MF system is essentially a closed process and fully contained within the
trailer. The system will be located in a secure area during verification testing (see Figure
5). There are no apparent hazards to the surrounding community due to operation or
testing of the system.
7.4 Lockout/Tagout Program
The Federal-Mogul (host facility) Lockout/Tagout Program will be reviewed prior to
testing, and relevant lockout/tagout provisions of the program will be implemented.
7.5 Material Storage
In accordance with the Federal-Mogul Hazard Communication Program, any materials
used during the project will be kept in proper containers and labeled according to local,
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 Federal-Mogul
Consolidated Emergency Response Plan.
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8.0 WASTE MANAGEMENT
The IWTP-MF system will process wastewater generated by manufacturing operations at
Federal-Mogul. After processing, the effluent from the IWTP-MF system will be
transferred to the existing Federal-Mogul treatment system and processed through the
existing system before being discharged to the Blacksburg POTW. Any residuals
generated by the IWTP-MF system will be managed by Federal-Mogul in accordance
with local, state, and Federal laws.
Prior to testing, local and state authorities will be notified of the verification test by
Federal-Mogul.
9.0 TRAINING
Environmental, health and safety training will be coordinated with Federal-Mogul staff.
All ETV-MF personnel will undergo environmental, health and safety training provided
by Federal-Mogul prior to initiating the verification test.
Also, the ETV-MF Job Training Analysis (JTA) Plan [Ref. 5] will be utilized to identify
additional training requirements relating to quality control, worker safety and health, and
environmental issues. The purpose of this JTA Plan is to outline the overall procedures
for identifying the hazards and quality issues and training needs. This JTA Plan
establishes guidelines for creating a work atmosphere that meets the quality,
environmental, and safety objectives of the ETV-MF Pilot. The JTA Plan describes the
method for studying ETV-MF project activity and identifying training needs. The ETV-
MF Operation Planning Checklist (Appendix D) will be used as a guideline for
identifying potential hazards, and the Job Training Analysis Form (Appendix E) 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 F).
10.0 REFERENCES
1) EPA. Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards for the Metal Finishing Point Source Category.
2) EPA. Effluent Limitations Guidelines, Pretreatment Standards, and New Source
Performance Standards for the Metal Products and Machinery Point Source
Category; Proposed Rule.
3) Concurrent Technologies Corporation. "Environmental Technology Verification
Program Metal Finishing Technologies (ETV-MF) Quality Management Plan."
December 9, 1998.
4) 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.
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5) Concurrent Technologies Corporation. "Environmental Technology Verification
Program Metal Finishing Technologies (ETV-MF) Pollution Prevention
Technologies Pilot Job Training Analysis Plan." May 10, 1999.
11.0 DISTRIBUTION
Alva Daniels, EPA (3)
James and Geri Davis, DTIC
Bob Stone, Federal-Mogul
George Cushnie, CAI Resources, Inc.
Donn Brown, CTC (3)
Clinton Twilley, CTC
Michele Lersch, Severn Trent Laboratories
35
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APPENDIX A
DTIC IWTP-MF Operating Procedures
-------
DTIC IWTP-MF Operating Procedures
The IWTP-MF operates in a semiautomatic process. The following provides an overview of the
daily startup and shutdown procedure. The plant is self-regulating during normal operating
conditions. However, there are four (4) steps where the operator is required to be involved.
Step #1
Prior to daily starting of the plant, the operator is required to perform an inspection of the plant's
physical condition to ensure all equipment appears to be normal and ready for operation. This
will be done in accordance with a checklist provided in the Operator's Guide.
Step #2
Daily initialization is a two-step process, checking certain items in accordance with the
Operator's Guide in preparation to power up the system.
First Part: Power Circuit
Initialize the master power circuit, 480 VAC
1. Power up the 120 VAC power circuit
1. Power on the interior lights
2. Power on the 120 VAC pump circuit
3. Power on the sensor control circuit and check the following:
(1) water level controls
(2) pH monitoring circuit
(3) flow meter
(4) interior lighting
2. Power up the 480 VAC motor control circuit
1. Check all variable speed motor controller displays
2. Power on the skimmer and inspect for proper operation
3. Momentarily start sludge discharge pumps
Second Part: Chemical Circuit
Check each chemical pump for proper operation
3. Manually start each pump and check for proper operation
4. Check and fill, as necessary, all chemical feed tanks
5. Observe the pH control circuit is operating properly for the adjustment of the
acid and alkaline levels
A-l
-------
Step #3
Start the system in accordance with the Operator's Guide. Observe that all mixer motors and
pumps are operating properly. Observe that the dissolved air flotation (DAF) pumps have come
up to proper operating levels of dissolved air in the treatment water. This indicates that the
treatment process is ready to go online. Then start the feed and discharge pumps and open the
discharge and feed valves. The system is now online and operating under internal control. The
operator should continue to observe the operation of the plant for the next 30 minutes to ensure
proper and stable operation.
Step #4
Shut down
The following two-step procedure must be followed in order to shut down the plant.
First part
1. Close the feed pump value and the discharge valve
2. Shut off power to the feed pump and mixer motors in accordance with the
Operator's Guide and checklist for overnight or weekend shutdown; follow the
Operator's Guide for extended or transport shutdown procedures.
Second part
3. Follow the Operator's Guide and secure the DAF pumps
4. Secure the secondary 480 VAC power
5. Secure the 120 VAC sensor power circuit
6. Inspect the system for any leaks and abnormal conditions
7. Secure the lighting power circuit
8. Secure the secondary 120 VAC circuit
9. Secure the main 480 VAC power circuit
A-2
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APPENDIX B
Data Collection Form for DTIC IWTP-MF System
-------
Data Collection Form for DTIC IWTP-MF System
Test Run/Day: _
ETV-MF Project Manager:
DTIC Operator: _
Parameter/Date/T ime
Reading/Sample #
Observations/Comments
Flow Totalizer
Start (1):
Reading (1):
Reading (1):
Reading (1):
Stop (1):
Flow Instantaneous
Start (1/min):
Reading (1/min):
Reading (1/min):
Reading (1/min):
Stop (1/min):
Wt. of Sludge
Start (kg):
Stop (kg):
Depth of Sludge Drum Contents
Start (m):
Stop (m):
Wt. of Oil
Start (kg):
Stop (kg):
Depth of Oil Drum Contents
Start (m):
Stop (m):
Reagent Usage
Acid (1):
Caustic (1):
Polymer (1):
Ferric chloride (1)
Samples Collected
Influent:
Effluent:
Sludge drum:
Oil drum:
Additional Notes:
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APPENDIX C
Test Plan Modification
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Test Plan Modification
In the course of verification testing, it may become necessary to modify the test plan due to
unforeseen events. The purpose of this procedure is to provide a vehicle whereby the necessary
modifications are documented and approved.
The Test Plan Modification Request form is the document to be used for recording these
changes. The following paragraphs provide guidance for filling out the form to ensure a
complete record of the changes made to the original test plan. The form appears on the next
page.
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 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:
Requestor:
Project Manager:_
Program Manager:
C-2
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APPENDIX D
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 checked for 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 shutdown must be documented in Test Plan.
Equipment requiring special fire prevention precautions (e.g., Class D fire
extinguishers)?
Modifications to or impairment of building fire alarms, smoke detectors,
sprinklers or other fire protection or suppression systems?
Equipment lockout/tagout or potential for dangerous energy release?
Lockout/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 checked for 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 "Iinitials & Date Completed" column above.
ETV-MF Project Manager;
(Name) (Signature) (Date)
D-2
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APPENDIX E
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 F
ETV-MF Project Training Attendance Form
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ETV-MF Project Training Attendance Form
ETV-MF Project:
Date
Training
Completed
Employee Name
Last First
Training Topic
Test
Score
(If applic.)
ETV-MF Project Manager:
Name Signature
Date
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