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K "i <br /> Serving the World S Telephone <br /> Environmental Needs (415)933-222500 ^ <br /> 355 Lennon Lane SS✓✓ <br /> Walnut Creek, �YoCalifornia 94598 <br /> JMA James M. Montgomery h1O1 tis 199� gC� <br /> _. Consulting Engineers, Inc. 5 <br /> cv <br /> 0000 November 9, 199Q9 ),W <br /> City of Manteca <br /> 1001 West Center Street <br /> Manteca, CA 95336 <br /> Attention: Mr. James Podesta File: 912.0390/6.3.11 <br /> Deputy Director of Public Works <br /> Subject: Indy Electronics - Industrial Waste Discharge Permit Review <br /> James M. Montgomery Consulting Engineers (JMM) has reviewed Indy Electronics' request for an <br /> amendment to their Industrial Waste Discharge Permit, Permit No. 88-1. Indy is planning to <br /> install an anodization line to their manufacturing operation, which will introduce additional <br /> chemicals to their existing discharge. Estimates of the operating and discharge concentrations of <br /> each anodizing chemical were provided in the permit application. <br /> ANODIZING CHEMICALS <br /> The following chemicals will be used in the anodization line: sulfosalicylic acid, sulfuric acid, <br /> sodium nitrite, phosphoric acid, ethylene glycol n-butyl ether, ferric sulfate, and sodium <br /> bifluoride. Of these chemicals, only the ethylene glycol n-butyl ether is prohibited by City <br /> Ordinances 644 and 770A, although it is not a priority pollutant. The ordinances prohibit the <br /> discharge of all ethers to the sewer system in any amount, because the presence of ethers in the <br /> sewer promotes the possibility of hazardous fire, explosion, or toxic fume conditions. If ethers <br /> should reach the treatment plant these same hazardous conditions could exist, in addition to <br /> possible toxicity to biological treatment organisms, treatment process inhibition, or pass-through. <br /> The potential impacts of discharging ethylene glycol n-butyl ether and the other anodizing <br /> chemicals listed above to the sewer and treatment plant are discussed below. <br /> Ethylene Glycol n-Butyl Ether (C6H14O2). The preferred name for ethylene glycol n- <br /> butyl ether is 2-butoxyethanol, although fifteen other names also are in use for this compound <br /> (EPA 560fMS-84-001a). 2-Butoxyethanol is a long-chain organic with a relatively low Henry's <br /> Law constant of 2.08E-07 atm-m3/mole (8.51E-03 mg/m3/mg/L), indicating a very low potential <br /> for volatilization to the sewer atmosphere. Research by Bridie (1979), Price (1974), and Yasuda <br /> (1978) indicates that 2-butoxyethanol is readily degraded by typical sewage organisms. Therefore, <br /> discharging this compound to the Manteca sewer system in the quantities and concentrations <br /> requested by Indy is not expected to have any negative impacts. <br /> Sulfur Compoun.ls. Under their existing permit Indy is already discharging sulfuric acid <br /> (H2SO4), sulfates, and sulfides to the sewer system, all of which can corrode iron, steel, concrete, <br /> asbestos-cement, and cement mortar. Additionally, the release of dissolved hydrogen sulfide can <br /> lead to severe odor problems. However conditions within the sewer that lead to corrosion and <br /> odor release are dependent on pH, dissolved oxygen, temperature, and sewer flow. Indy's <br /> existing permit requires a discharge pH within the range of 6 to 10 pH units and a maximum <br />