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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 625/3-73-002), 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 som- 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 20.0 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 owmorandum <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 />