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14. He indicated that the cadmium and chromium limits might be lower because <br /> of Superfund, and this is shown in the table too. <br /> Regarding the question of whether the CRF can meet these metal limits-1 have <br /> attached a graph and table from an EPA publication (Lancy, R.E. and Rice, R.L., <br /> Waste Treatment Upgrading Metal-Finishing Facilities to Reduce Pollution, <br /> Environmental Protection Agency • Technology Transfer, July 1973, revised <br /> January 1974, EPA 625/3-13-002), but originally published in Germany. The graph <br /> seems to represent the EPA's official position and has been reproduced in many <br /> publications. It shows the lowest solubilities that can be achieved for segre- <br /> gated cadmium, chromium, copper, nickel, and zinc salts in distilled water con- <br /> taining a. strong base. The table shows the effect of hard water. Note that <br /> even in hard water it is possible to meet the MWCC limits for segregated metal <br /> streams. The solutions -from the regenerated canisters are segregated and these <br /> represent about sixty percent of the flow. Most of the batch dumps also repre- <br /> sent segregated metal solutions although somewhat contaminated. There are, <br /> however, rinses and some batch dumps such as those from zinc chromating which <br /> may present a problem because they contain two or more metals and the the opti- <br /> mum pH for precipitation differs markedly for the different metals. In these <br /> cases two hydroxide precipitation steps or polishing with sulfide or ion <br /> exchange canisters will be used to meet the limits. There may also be dif- <br /> ficulties with certain streams containing chelating agents, such as electroless <br /> copper and electroless nickel . The chelating agents will be removed using acti- <br /> vated carbon if this is necessary to meet the limits. Lead has not been men- <br /> tioned here as the CRF may be handling lead only as already precipitated sludges <br /> containing copper, lead, and tin. <br /> Regarding the cyanide limit, it has been our intention to oxidize cyanide with <br /> chlorine, chlorine dioxide, or sodium hypochlorite. One should be able to <br /> assure complete destruction of cyanide by using a long enough detention time in <br /> the reactor and using a dose high enough to assure a small chlorine residual . <br /> The exact conditions required, however, will not be known until tests are done <br /> early in the design process. In various documents EPA seems confident that the <br /> limits can be met. <br /> It has been our intention to neutralize each batch of CRF wastewater to pH 7 <br /> before discharge. This will certainly meet the MWCC limits of pH between 5.0 <br /> and 10.0 at discharge. <br /> Neutralization of CRF wastewater will raise its dissolved solids content because <br /> the reaction product of sulfuric acid and caustic is sodium sulfate. I have <br /> already estimated the sodium sulfate discharge in my 1983 February 10 memorandum <br /> to Dan Shuster, which is attached. At 0.25 percent sodium sulfate the Central <br /> Facility's 75,000 gallons per day would contain about 1,560 pounds per day of <br />