SEPA
United States
Environmental Protection
Agency
Office of Research and
Development
Washington, DC 20460
EPA/540/2-91/014
July 1991
Superfund
Selection of Control
Technologies for
Remediation of Lead
Battery Recycling Sites
-------
EPA/540/2-91/014
July 1991
SELECTION OF CONTROL TECHNOLOGIES
FOR
REMEDIATION OF LEAD BATTERY RECYCLING SITES
by
Tapan K. Basu
Ari Selvakumar
Roger Gaire
Foster Wheeler Enviresponse, Inc.
Edison, New Jersey 08837
Contract No. 68-C9-0033
Project Officer
Michael D. Royer
Technical Support Branch
Super-fund Technology Demonstration Division
Edison, New Jersey 08837
U.S. Ehvlromaental .-.-otectitn Age
Ration 5, Library •' L-1S)
2bO S. Dearborn I'/; L, Koc,, IG/0
Chicago, IL 60604
RISK REDUCTION ENGINEERING LABORATORY
OFFICE OF RESEARCH AND DEVELOPMENT
U.S. ENVIRONMENTAL PROTECTION AGENCY
CINCINNATI, OHIO 45219
Printed on Recycled Paper
-------
NOTICE
This report has been reviewed in accordance with the U.S. Environmental Protection Agency's
peer and administrative review policies and approved for publication. Mention of trade names or
commercial products does not constitute endorsement or recommendation for use.
-------
FOREWORD
Today's rapidly developing and changing technologies and industrial products and practices
frequently carry with them the increased generation of materials that, if improperly dealt with, can
threaten both public health and the environment. The U.S. Environmental Protection Agency is charged
by Congress with protecting the Nation's land, air, and water resources. Under a mandate of national
environmental laws, the agency strives to formulate and implement actions leading to a compatible
balance between human activities and the ability of natural resources to support and nurture life. These
laws direct the EPA to perform research to define our environmental problems, measure the impacts,
and search for solutions.
The Risk Reduction Engineering Laboratory is responsible for planning, implementing, and
managing research, development, and demonstration programs to provide an authoritative, defensible
engineering basis in support of the policies, programs, and regulations of the EPA with respect to
drinking water, wastewater, pesticides, toxic substances, solid and hazardous wastes, and Superfund-
related activities. This publication is one of the products of that research and provides a vital communi-
cation link between the researcher and the user community.
This report will assist federal Remedial Project Managers in planning and managing the
technology selection aspects of Remedial Investigations and Feasibility Studies at sites contaminated
with the by-products of lead battery recycling operations. It consolidates useful information on lead
battery recycling sites, such as the following: identification and status of relevant National Priority List
sites; common waste types and matrices; applicable and relevant or appropriate requirements (ARARs);
clean-up target levels; key issues that affect technology selection; commonly selected treatment
technologies; treatability studies; and data needs for remedial investigations. The technology assess-
ment is done in terms of compliance with ARARs; short-term effectiveness; long-term effectiveness;
reduction of toxicity, mobility, and volume; implementability; and cost.
This report supplements the more general guidance provided in Guidance for Conducting
Remedial Investigations and Feasibility Studies Under CERCLA, Interim Final (USEPA, 1988c).
E. Timothy Oppelt, Director
Risk Reduction Engineering Laboratory
Hi
-------
ABSTRACT
The objective of this report is to provide federal remedial project managers (RPMs) and their
supporting contractors with information to facilitate the selection of treatment alternatives and cleanup
services at lead battery recycling sites. It tailors the Remedial Investigation/Feasibility Study (RI/FS)
process to lead battery recycling sites, evaluates currently used treatments, identifies remediation
alternatives, and forecasts the effectiveness of treatments. Eleven RI/FSs and fifteen Record of Decision
(ROD) documents for lead battery sites were the primary sources of information.
This report also addresses treatability studies at lead battery recycling sites. It presents relevant
examples drawn from results of such studies. Also, it describes the technologies commonly proposed in
RI/FSs and RODs. The technologies are evaluated against six of the nine EPA evaluation criteria
(compliance with ARARs; long-term effectiveness and permanence; reduction of toxicity, mobility, or
volume; short-term effectiveness; implementability; and cost). It compares the technologies to highlight
their salient advantages and disadvantages, and to emphasize those treatments most likely to be
successful in remediating lead battery recycling sites. Finally, it discusses innovative and emerging
technologies, which have the potential to treat lead contaminated wastes.
iv
-------
CONTENTS
Page
Notice ii
Foreword Hi
Abstract iv
Figures „ vii
Tables viii
Abbreviations and Symbols x
Acknowledgements xiii
1.0 Introduction 1
1.1 Purpose 1
1.2 Scope and Limitations 3
1.3 Approach 4
1.4 Report Organization 4
2.0 Scoping the RI/FS for Lead Battery Recycling Sites 5
2.1 Project Planning 5
2.2 Evaluation of Existing Data 7
2.2.1 Background Information on Lead-Acid Battery Construction, Chemistry,
and Recycling Procedures 7
2.2.2 Key Sources of Lead Battery Recycling Site-Related Information 7
2.2.3 Key Issues to Address During Scoping 9
2.3 Development of a Conceptual Site Model 13
2.4 Identification of Remedial Action Objectives 13
2.5 Identification of Potential Remedial Technologies 15
2.6 Identification of Applicable or Relevant and Appropriate Requirements (ARARs) 18
2.7 Identification of Data Needs 22
2.8 Data Quality Objectives 26
3.0 Site Characterization 31
3.1 Physical Characteristics 31
3.2 Source, Nature, and Extent of Contamination 32
3.3 Risk Assessment for Lead Battery Recycling Sites 32
3.3.1 Risk Assessment Guidance 33
3.3.2 Specific Risk Assessment Issues at Lead Battery Recycling Sites 34
3.3.2.1 Lead Issues for Lead Battery Recycling Sites 34
3.3.2.2 Exposure Pathways for Lead Battery Recycling Sites 35
3.3.2.3 Risk Assessment Data Needs 35
4.0 Lead Battery Recycling Treatability Studies 37
4.1 Site-Specific Lead Battery Recycling Treatability Studies 37
4.1.1 Solidification/Stabilization of Soil 37
4.1.2 Soil Washing/Acid Leaching 40
4.1.3 Recycling of Battery Casings 44
-------
CONTENTS (continued)
Page
5.0 Evaluating Remedial Alternatives 48
5.1 Remedial Action Objectives 48
5.2 Developing General Response Actions 48
5.3 Development and Screening of Technologies 48
5.3.1 No Action 51
5.3.2 Contaminated Medium: Soil 51
5.3.2.1 Solidification/Stabilization of Soil (S/S) 52
5.3.2.2 Soil Washing/Acid Leaching 57
5.3.2.3 Soil Excavation and Off-Site Disposal 60
5.3.2.4 Soil Capping 61
5.3.2.5 In Situ Vitrification 62
5.3.2.6 Other Innovative Processes 62
5.3.3 Contaminated Medium: Groundwater 64
5.3.3.1 Precipitation/Flocculation/Sedimentation 64
5.3.3.2 Ion Exchange 66
5.3.3.3 Other Innovative Processes 68
5.3.4 Contaminated Medium: Waste Piles 69
5.3.4.1 Waste Pile Removal and Off-Site Disposal 69
5.3.4.2 Recycling of Battery Casings 72
5.3.4.3 Other Innovative Processes 76
5.3.5 Contaminated Medium: Buildings, Structures, and Equipment 78
5.3.6 Contaminated Medium: Pits, Ponds, Lagoons, and Surface Water 78
References 80
Bibliography 85
Glossary 89
Appendices
A Background Information on Lead-Acid Batteries, Battery Breaking, and Secondary
Lead Smelting Operations, and Chemistry of Lead and Other Heavy Metals
at Lead Battery Recycling Sites 91
B Background Information on Superfund Lead Battery Recycling Sites 104
C Land Disposal Restrictions for Third Third Scheduled Wastes; Rule 123
D Cleanup Level for Lead in Groundwater 131
E Interim Guidance on Establishing Soil Lead Cleanup Levels at Superfund Sites 136
F U.S. Primary and Secondary Lead Smelters 140
vi
-------
FIGURES
Number
1
2
3
4
5
6
Appendix
Number
A-1
A-2
A-3
A-4
F-1
Example lead battery recycling site conceptual model
Decision tree showing when a waste is subject to land disposal restrictions
Bureau of Mines soil washing process for lead battery sites
Solubility of metal hydroxides and sulfides
Bureau of Mines battery casing washing process
Canonie Environmental's battery waste treatment process
Lead-acid battery construction
Generalized secondary lead refining process .
Flow diagram of lead-acid battery breaking ..
Equilibrium solubility of lead at 25°C and 1 atm
Location of primary and secondary smelters .
Page
14
21
59
67
73
75
92
96
97
102
142
vii
-------
TABLES
Number Paae
1 Summary of Materials at Lead Battery Sites 10
2 Lead Alloying, Refining, and Smelting Agents 11
3 Remedial Technologies Commonly Proposed for Lead Battery Recycling Sites .... 16
4 Remedial Actions at Lead Battery Recycling Sites and Action-Specific
ARAR Citations 19
5 Lead Battery Recycling Sites: Chemical-Specific ARARs for Lead and Criteria,
Advisories, and Guidance to be Considered 23
6 Summary of Soil Lead Action Levels for Lead Battery Sites Based on
RODs and/or Feasibility Studies 24
7 Input Parameters Needed for MINTEQA2 Metal Speciation Model 26
8 Typical Sampling Procedures at Lead Battery Recycling Sites 27
9 Data Requirements for Potentially Applicable Technologies 28
10 Target Analyte List (TAL) Metals 33
11 Solidification/Stabilization Treatability Study Results for Cement-Based Blends
Passing EP Toxicity Criterion for Lead at C&R Battery Site 39
12 TCLP Leach Test Results of Bench-Scale Study Conducted on Soil and Sediment
from the Gould Site 39
13 Summary of Canonie Test Results on the Recommended Binder Formulation
at Gould Site 40
14 Non-Lead Battery Solidification Case Studies (USEPA, 1989a) 41
15 Representative Results of the Bureau of Mines Treatability Tests on
Selected Samples of Battery Breaker Soil Wastes 45
16 Representative Results of the Bureau of Mines Treatability Tests on
Selected Chip Samples of Broken Battery Casing Wastes 46
17 Summary of General Response Actions and Associated Remedial
Technologies Commonly Proposed for Lead Battery Recycling Sites 49
18 Contractors/Vendors List 50
19 Summary of EPA Evaluation Criteria of Remedial Technologies for Soil 54
20 1990 Unit Costs Associated with Capping Disposal Sites 63
21 Summary of EPA Evaluation Criteria of Remedial Technologies for
Groundwater 65
22 Summary of EPA Evaluation Criteria of Remedial Technologies for
Waste Piles 70
23 Summary of Commercial Lead Battery Recycling Operations Offered
by Seven Companies 77
24 Summary of EPA Evaluation Criteria of Remedial Technologies for
Buildings, Structures, and Equipment 79
VIII
-------
TABLES (continued)
Appendix
Number
A-1 Elemental Additives to Anode in Lead-Acid Storage Battery
A-2 Typical Metals Concentrations in Lead-Acid Battery Acid
A-3 Some Physicochemical Properties of Selected Lead Compounds .
B-1 Summary of CERCLA Lead Battery Sites and Remedial Alternatives
Proposed (9/90)
F-1 List of U.S. Primary and Secondary Lead Smelters
ix
-------
ABBREVIATIONS AND SYMBOLS
AIC American Institute of Cancer
ANS American Nuclear Society
ARARs applicable or relevant and appropriate requirements
ASTM American Society for Testing and Materials
atm atmosphere
BOAT Best demonstrated available technology
BOM Bureau of Mines
CARTS Computer-Aided Response Technologies Selector
CERCLA Comprehensive Environmental Response, Compensation, and Liability Act
CERI Center for Environmental Research Information
CLP contract laboratory program
DLT dynamic leach test
DQO data quality objectives
ECAO Environmental Criteria and Assessment Office
EDTA ethylenediaminetetraacetic acid
EMR electromembrane reactor
EPA Environmental Protection Agency
EP Toxicity extraction procedure toxicity
FWEI Foster Wheeler Enviresponse, Inc.
GEB Guidance and Evaluation Branch
HEAST health effects assessment summary tables
-------
ABBREVIATIONS AND SYMBOLS (continued)
HPDE high density polyethylene
HSCD Hazardous Sites Control Division
IU/BK integrated uptake/biokinetic model
LDR land disposal restrictions
MCL maximum contaminant level
MEP multiple extraction procedure
MSW mobile soil washing
NMQ national ambient air quality
NCR National Contingency Plan
NIOSH National Institute for Occupational Safety and Health
NPDES National Pollution Discharge Elimination System
NPL National Priorities List
O&M operations and maintenance
OERR Office of Emergency and Remedial Response
ORD Office of Research and Development
OSC on-scene coordinator
OSHA Occupational Safety and Health Administration
OSW Office of Solid Waste
OSWER Office of Solid Waste and Emergency Response
OWPE Office of Waste Programs Enforcement
PAH polyaromatic hydrocarbon
xi
-------
ABBREVIATIONS AND SYMBOLS (continued)
PCB polychlorinated biphenyl
PCP pentachlorophenol
POTW publicly owned treatment works
RAGS risk assistance guidance for Superfund
RCRA Resource Conservation and Recovery Act
RfD reference dose
RI/FS remedial investigation/feasibility study
ROD Record of Decision
RPM remedial project manager
RREL Risk Reduction Engineering Laboratory
SITE Superfund Innovative Technology Evaluation (Program)
START Superfund Technical Assistance Response Team
TAL target analyte list
TCE trichloroethylene
TCLP Toxicity Characteristic Leaching Procedure
TIO Technology Innovation Office
USAGE United States Army Corps of Engineers
USEPA United States Environmental Protection Agency
USGS United States Geological Survey
XRF X-ray fluorescence
xii
-------
ACKNOWLEDGMENT
This report, Selection of Control Technologies for Remediation of Lead Battery Recycling Sites
was a cooperative effort between the EPA's Office of Emergency and Remedial Response (OERR) and
the Office of Research and Development (ORD). The document was prepared by Foster Wheeler
Enviresponse, Inc. (FWEI) under EPA Contract 68-C9-0033. The OERR Coordinator for the project was
Deborah McKie of the Hazardous Sites Control Division. The ORD coordinator for the project was Frank
J. Freestone, Chief of the Technical Assistance Section, Technical Support Branch, Superfund Technolo-
gy Demonstration Division, Risk Reduction Engineering Laboratory (RREL). The EPA Work Assignment
Manager was Michael D. Royer, also of the Technical Assistance Section. From FWEI, Tapan K. Basu
served as the Project Leader on this work assignment. Ari Selvakumar and Roger Gaire co-authored this
document.
The following FWEI personnel made constructive contributions to the preparation of this report:
Gerard Sudell, Gary Prager, and Ramjee Raghavan.
The authors express their appreciation to Marilyn Avery for editing, Thomas Douglas for
assistance in providing graphics, and to Michelle DeFort and Dorothy Taylor for word processing.
Development of this report involved the participation of the following reviewers, whose
comments contributed significantly to its quality:
Dr. Michael Amdurer
Ms. Robin Anderson
Mr. John Barich
Mr. Edwin F. Barth
Ms. Marlene Berg
Dr. John Brugger
Mr. David J. Bunte
Mr. Matt Charsky
Mr. Christopher J. Corbett
Mr. Michael Cox
Mr. Kenneth Dostal
Ms. Linda Fiedler
Mr. Mick Gilbert
Dr. Susan Griffin
Ms. Gail Hansen
Mr. Richard Koustas
Dr. S. Krishnamurthy
Mr. Paul Leonard
Mr. Michael Magyar
Ms. Donna M. McCartney
Ms. Andrea Mclaughlin
- EBASCO Services, Inc.
- EPA, OERR
- EPA Region X
- CERI, Cincinnati
- EPA, OERR
- EPA/RREL, Edison
- CH2M Hill
- GEB, OWPE
- EPA Region III
- EPA Headquarters
- RREL/ORD
- EPA, Technology Innovation Office
- EPA Region II
- EPA, Toxics Integration Branch
- EPA, OSW
- EPA/RREL, Edison
- EPA/RREL, Edison
- EPA Region III
- U.S. Bureau of Mines
- EPA Region III
- EPA, HSCD
xiii
-------
ACKNOWLEDGEMENT (continued)
Mr. Shahid Mahmud - EPA, HSCD
Mr. James Orban - EPA Region IV
Ms. Brigid OToole - RREL, Cincinnati
Mr. Timothy Prendiville - EPA Region V
Mr. William B. Schmidt - U.S. Bureau of Mines
Mr. R.L Stenburg - RREL, Cincinnati
Mr. Frank Tsang - EBASCO Services, Inc.
This report would not have been possible without the assistance of those who took the time and
effort to provide pertinent documents and information. Those who provided such information are too
numerous to name, but the following persons provided particular assistance:
Gordon Willey and Joseph Kruger, OERR; Eugene Dominach and Mick Gilbert, EPA Region II;
Fran Burns, EPA Region III; James Orban, Barbara Dick, Christi Goldman, Martha Berry, and
Anna Torgrimson, EPA Region IV; Anita Boseman, Brad Bradley, Steve Faryan, and Larry
Schmitt, EPA Region V; Monica Chapa, EPA Region VI; Richard Martyn, EPA Region IX; and,
Chip Humphrey, Jeff Webb, and Dave Einan, EPA Region X.
xiv
-------
SECTION 1
INTRODUCTION
1.1 PURPOSE
The objective of this report is to provide federal Remedial Project Managers (RPMs) and their
supporting contractors with information to facilitate the selection of treatment alternatives and cleanup
services at lead battery recycling sites. It tailors the Remedial Investigation/Feasibility Study (RI/FS)
process to lead battery recycling sites, evaluates currently used treatments, identifies remediation
alternatives, and forecasts the effectiveness of treatments.
Batteries account for more than 80% of the lead used in the United States, of which approxi-
mately 60% is reclaimed. In general, 50% of the national lead requirements are satisfied by recycled
products. During the information collection activities that support this report, 29 Superfund lead battery
recycling sites were identified. Twenty-two of these sites are on the National Priority List, indicating that
they have been or will be the subject of RIs and FSs. In addition, 18 lead battery sites are on the RCRA
Corrective Action list, with more in the process of being added. Also, as happened in the early 1980's,
adverse changes in lead production costs are likely to close some operating lead recycling facilities.
Some of these sites may require remediation.
This document principally assists the RPM by consolidating the following types of useful
information:
o Technologies selected via the RI/FS and removal process for other lead battery
recycling sites;
o Case studies of treatability studies on lead battery recycling site wastes;
o Profiles of potentially applicable innovative treatment technologies;
o Description of types of operations commonly conducted, and wastes generated at lead
battery recycling sites;
o Applicable and relevant or appropriate requirements (ARARs) identified in completed
RI/FSs;
o Key issues that commonly affect technology selection for lead battery recycling sites;
o Recommendations regarding technology considerations at various stages of the RI/FS
process;
-------
o A generalized assessment in terms of ARAR compliance; short-term effectiveness;
long-term effectiveness; reduction of toxicity, mobility, and volume; implementability;
and, costs of commonly selected technologies; and
o Lists of pertinent references and contacts.
This report is intended to be a useful technology-oriented reference, and not a detailed
instruction book on how to perform a RI/FS for a lead battery recycling site. It should be used in
conjunction with the more general guidance provided in Guidance for Conducting Remedial Investiga-
tions and Feasibility Studies under CERCLA, Interim Final (USEPA, 1988c) and other Office of Solid
Waste and Emergency Response (OSWER) guidance documents referenced at the end of this
document.
By consolidating the information, data, and references of the type described above, this
document assists the RPM to efficiently manage the remedy selection process in a manner that will
attain the program goals, management principles, and expectations set forth in the National Contingency
Plan (40CFR Sections 300.430(a)(1)(i-iii)). The ultimate goal of the remedy selection process is the
selection of remedies that are protective of human health and the environment. These remedies should
maintain protection over time and minimize untreated waste.
The program management principles include the following:
o Remediation of the site by operable units when early actions are necessary or appropri-
ate to achieve significant risk reduction quickly;
o Operable units should be remediated in a way that is consistent with the final remedy;
o The complexity of the site problems should be reflected in the data needs, the evalua-
tion of alternatives, and the documentation of the selected remedy.
The program expectations for selected remedies include:
o Treatment to address the principal threats at a site;
o Engineering controls, such as containment, for waste that poses a relatively low
long-term threat or for a situation where treatment is impractical;
o A site-specific combination of treatment and containment to achieve protection of human
health and the environment, as appropriate;
o Institutional controls to supplement engineering controls for long-term management and
to mitigate short-term impacts;
o Use of innovative technology when such technology offers potentially comparable or
superior treatment performance with fewer or lesser adverse impacts than other
available approaches (or when it lowers costs for similar levels of performance than
more demonstrated technologies);
o Beneficial return of useable groundwaters wherever practicable within a reasonable time
frame.
-------
This document also fulfills Objective 37B of the Superfund Management Review Implementation
Plan, which is to issue reports that identify specific technologies or combinations of technologies in
order to respond to generic site classes.
1.2 SCOPE AND LIMITATIONS
This report principally addresses Superfund sites where lead-acid battery recycling operations
were performed. Lead-acid battery recycling operations encompass battery breaking, component
separation, lead smelting, and lead refining. These operations, which are described in more detail in
subsequent sections, convert the lead in spent batteries into a marketable product. There are other
Superfund sites, with battery-related contamination, where lead recycling was not the predominant
operation, but these sites are not the focus of this report. Non-recycling lead battery sites, such as
battery acid disposal sites, battery disposal sites (where batteries are mixed with other non-battery
wastes), auto salvage operations, and battery manufacturing sites are included in the list of lead battery
sites in Appendix B.
The information-gathering effort for this project focused heavily on lead battery recycling sites in
the Superfund National Priority List. Project resources were insufficient to permit identification,
collection, and comparison of information and data from other lead-contaminated sites (e.g., lead mining
sites, ceramics manufacturing sites, or non-CERCLA lead sites) from which pertinent lessons might also
have been learned.
The report focuses on: (a) control technologies that have been selected (although in many cases
not yet applied) for remedial actions or removal actions at lead battery recycling sites, and (b) technolo-
gies in the EPA Office of Research and Development's Superfund Innovative Technology Evaluation
(SITE) Program that are innovative and potentially applicable to heavy metals.
No attempt has been made to identify and assess the applicability of all the remediation
technologies cited in Appendix D of the National Contingency Plan (40 CFR Part 300). For example,
containment technologies (e.g. grouting, slurry walls, etc.) are not addressed - except for capping,
addressed only briefly -- because they were not selected for remediating the lead battery recycling sites
that were identified in this project. Furthermore, the performance of containment systems for lead
battery recycling sites does not differ from other applications. Sufficient knowledge of this remedy exists
so that further coverage in this document was unnecessary.
This document addresses innovative treatment technologies only to a limited extent. The RPM
should recognize that the applicability of existing and future novel technologies to lead battery recycling
sites should be reassessed early in the RI/FS process. The SITE Program can provide the latest
information on many of them.
The reader is cautioned against a premature elimination of a technology based entirely on poor
performance reports in this or other documents. The reader should consider not just the technology's
failure, but also the reasons that are presented for it. Only if the same failure conditions are present, in
both the site scenarios and the historical information in this report, should one conclude that the
technology will not work. Even then, the possibilities of pre-treatment, technology modification, or
combined technologies should not be overlooked.
This document alerts the reader to regulatory and policy issues that have had or are expected to
have significant effects on selection of treatment technologies. However, a comprehensive analysis of
regulatory and policy issues was not within the scope of this document.
-------
1.3 APPROACH
The basic approach of this report is to (1) identify and classify Superfund lead battery recycling
sites, (2) obtain pertinent information (preferably from completed RI/FSs, and RODs), (3) review the
information for useful data, facts, trends, and lessons learned, and (4) summarize pertinent information in
a format that is convenient for the RPM.
This basic information collection was supplemented by the identification and limited information-
gathering on approximately 20 lead battery recycling sites where removal actions were planned, in
progress, or completed. It also accumulated material from discussions with RPMs; a review panel which
critiqued draft versions of the document; review of pertinent regulations (e.g., RCRA land disposal
restrictions), EPA guidance, research reports, and other information related to technology selection.
1.4 ORGANIZATION
This report is organized into five chapters: this introduction; three chapters that address
technology considerations during the RI/FS; and a separate chapter devoted to treatability studies,
which may be applicable to any stage of the RI/FS process. Appendices contain the following: a
descriptive list of Superfund lead battery sites; a discussion of lead battery structure and chemical
composition; the details of typical battery breaking and secondary lead smelting processes; the
chemistry of lead and other heavy metals found at lead battery recycling sites; selected lead-related
OSWER guidance; and a list of U.S. primary and secondary lead smelters.
-------
SECTION 2
SCOPING THE RI/FS FOR LEAD BATTERY RECYCLING SITES
Scoping is the initial planning phase of site remediation. It is enlarged and refined as new
information about the site becomes available. Scoping helps to focus activities and streamline the
RI/FS, thereby preventing needless expenditures of time and money for unnecessary sampling and
analyses. Scoping for a lead battery recycling site should encompass the following activities:
o Project planning*
o Evaluation of existing data*
o Conducting a site visit
o Development of a conceptual site model*
o Identification of remedial action objectives*
o Identification of potential remedial technologies*
o Collecting the data necessary for potential treatability studies
o Identification of potential applicable or relevant and appropriate requirements (ARARs)*
o Identification of data needs*
o Data quality objectives*
o Preparation of project plans
This section addresses only those items marked with an asterisk (*) because they provide
material supplemental to the contents of the general RI/FS guidance (USEPA, 1988c). The remaining
items are adequately addressed in the scoping section of the general RI/FS guidance.
2.1 PROJECT PLANNING
There are a number of individuals and organizations with considerable experience in selection of
control technologies for lead battery recycling sites. If it is necessary to augment regional experience
and capabilities, the RPM can contact the organizations listed below during the scoping phase. These
contacts may offer other valuable advice or support based on recent developments in their areas of
expertise.
-------
U.S. Bureau of Mines
CONTACT: Lead industry trends (mining, smelting, refining)
Michael Magyar Lead separation process development
FTS 634-1815 Acid-leaching treatability studies
Battery case and lead-contaminated soil characterization
EPA-BOM technical assistance Interagency Agreements
U.S. EPA Engineering and Treatment Technology Support Center
CONTACT: Superfund Technical Assistance Response Team (START)
Benjamin Blaney On-going, long-term, technical assistance at two lead battery
FTS 684-7406 recycling sites
FORUM Support
Lead battery recycling site treatability studies on solidification and soils
washing treatments
U.S. EPA Environmental Response Team
CONTACT: Rapid survey of lead contamination in soil via X-ray fluorescence;
George Prince past experience at several lead battery recycling sites
FTS 340-6740
CONTACT: Computer-Aided Response Technologies Selector (CARTS),
Robert Cibulskis now entering the prototype testing phase of development
FTS 340-6746
U.S. EPA Exposure and Ecorisk Assessment Technology Support Center
CONTACT: Metal Speciation Equilibrium Model for Surface and
Robert Ambrose Groundwater (MINTEQA2 and PRODEFA2), including past experience
FTS 250-3130 at several lead battery recycling sites
U.S. EPA Health Risk Technology Support Center
CONTACT: Development of Lead Biokinetic/Uptake Model
Pei-Fung Hurst
FTS 684-7300
U.S. EPA Monitoring and Site Characterization Technology Support Center
CONTACTS: X-ray fluorescence field survey methods, including work underway to
Kenneth W. Brown accelerate data mapping by coupling X-ray fluorescence detector to
FTS 545-2270 position indicating and data transmission technology.
William Engelmann
FTS 545-2664
-------
2.2 EVALUATION OF EXISTING DATA
A thorough search of existing data should prevent duplication of effort. The resulting remedial
investigation should be more focused and, therefore, more efficient in its expenditure of time and
resources.
2.2.1 Background Information on Lead-Acid Battery Construction. Chemistry, and Recycling
Procedures
If information on batteries, battery breaking, lead smelting, and the chemistry of pertinent heavy
metals has not been collected, the RPM should review the topics presented in Appendix A. These topics
can further an understanding of the site situation, which in turn would improve preliminary judgements
about the suitability of proposed treatments. In addition, the RPM must try to obtain detailed information
about the operational and disposal practices at the specific site.
Exchanging information with RPMs for similar lead battery recycling sites can help to identify
successful remedial approaches. A table in Appendix B describes the operations conducted at 44
CERCLA lead battery sites and their common sources of contamination.
2.2.2 Key Sources of Lead Battery Recycling Site-Related Information
In addition to the sources covered in the general RI/FS Guidance (USEPA, 1988c), there is a
substantial body of useful information available to the RPM. The key to Superfund information and
technical assistance sources is Technical Support Services for Superfund Site Remediation, 2nd Edition,
EPA/ 540/8-90/011, October 1990 - available at no cost from the Center for Environmental Research
Information at FTS-684-7562. It includes descriptions of technical support sources and brokers,
automated information systems, publications, and other sources of information.
If the USEPA-authored documents cited in the References and Bibliography are not already
accessible, the RPM can arrange to obtain them in a short time, at no cost from either the Superfund
Document Information Center at FTS-382-6940 or the Center for Environmental Research Information at
FTS-6847562. The EPA regional library can also loan hard copies or microfiche files.
This project has collected a considerable number of RI/FSs for lead battery recycling sites in
one location - the USEPA Technical Assistance Section, Technical Support Branch, Risk Reduction
Engineering Laboratory, Edison, NJ at (908) 321-6632. However, this file will not be updated; one must
check with the RPM (listed in Appendix B) to ensure the most up-to-date records.
To enhance their understanding of site operations, and increase the options for addressing
wastes at lead battery recycling sites, some RPMs have studied the lead and lead-acid battery industries.
Appendices A through F provide a substantial foundation for this education process. U.S. EPA reports
contain additional process and waste characterization information resulting from the study or regulation
of air, water, and solid waste pollution from lead mining, primary and secondary lead smelting, battery
manufacturing, and battery recycling. The best of these reports, identified during this project, are listed
below.
Inspection and Operating and Maintenance Guidelines for Secondary
Lead Smelter Air Pollution Control, EPA/600/2-84/026, January 1984.
NTIS # PB84149368. -- This document provides (pp. 3-22) a more
detailed description of secondary lead smelter processes and operations
that is found in Appendix A.
-------
Industrial Process Profiles for Environmental Use, Chapter 27, Primary
Lead Industry, EPA/600/2-80/168, July 1980. - This document contains
an overview and brief descriptions of 22 unit processes in the primary
lead industry (i.e., mining and subsequent processing of the lead ore).
Lead-Acid Battery Manufacture - Background Information for Proposed
Standards, EPA/450/3-79/028a, November 1979. -- This document
contains an overview of the lead-acid battery industry and process
description information (pp. 3-1 to 3-23).
Treatment Technology Background Document, EPA/530/SW-89/048A,
June 1989. NTIS # PB89-221410. -- This document describes 23 treat-
ment technologies. It was assembled in support of the Best Demon-
strated Available Technology (BOAT) selection for Third Third Wastes.
Among the technologies described are chemical precipitation, high
temperature metals recovery, ion exchange, stabilization, and fuel
substitution.
The National Institute for Occupational Safety and Health (NIOSH) has performed numerous
health hazard evaluations at lead battery facilities. These evaluations typically employ a site visit. They
produce a report that provides an overview of the processes performed at the site and a summary of the
health hazard evaluation. The numerous health hazard evaluation reports are listed (under Lead, by
company name) in the NIOSH Publications Catalog, available in EPA libraries. NIOSH has also
performed in-plant evaluations of control technologies for reducing worker exposures in the secondary
lead industry. The most valuable report is:
Demonstration of Control Technology for Secondary Lead Reprocess-
ing, 1984, Volume I, PB# 84-187-665; Volume II, PB# 84-187-673.
It describes 10 demonstrations of control technologies for reducing lead exposures in industrial lead
reprocessing operations. It details the affected processes and provides an overview of the lead industry
in the early 1980's. Participants included General Battery, Tonolli, East Penn, and Calwest Metals. If
printed NIOSH reports are not available in a particular EPA library, they should be available on
microfiche.
The U.S. Bureau of Mines is another valuable source of background information, such as the
following two informative reports:
The Impact of Existing and Proposed Regulations Upon the Domestic
Lead Industry, August 1988, Open File Report 55-88.
Domestic Secondary Lead Industry: Production and Regulatory Com-
pliance Costs, 1987, Information Circular 9156.
As these titles suggest, the documents assess the economic effects of compliance on the
secondary lead industry. They present process descriptions and detailed production cost estimates.
-------
2.2.3 Key Issues to Address During Scoping
Chapter 2 of the USEPA RI/FS Guidance (1988c) addresses the topic of scoping the RI/FS. For
lead battery recycling sites, additional issues should be investigated during scoping:
The Presence of Young Children or Pregnant Women on or Near the Site-
This indicates a need for prompt action, as unborn and young children are particularly
susceptible to the adverse effects of lead poisoning.
Non-Process Sources of Lead-
The natural background lead in soil, leaded gasoline exhaust, spilled leaded gasoline, municipal
incinerators, and plumbing systems can complicate setting cleanup levels. They can also raise problems
in allocation of cleanup responsibility and costs, thus affecting selection and implementation of control
technologies. Hence, such hidden sources of lead must be carefully considered when determining
extent of lead contamination.
A Thorough Understanding of Site History-
Knowledge of shipping and receiving information, materials handling and storage practices,
process descriptions, and waste disposal practices is critical to assessing the site contamination. It is
necessary to determine whether the operation was strictly a battery breaking operation, a combination of
battery breaking and other metal salvage operations, or a combined battery breaking and smelting
operation.
Battery breaking operations - Although these operations may be limited to physical breaking
and separation processes, thermal processes were used in some instances to either melt the scrap lead
or separate it from plastic. Reducing its volume improved handling prior to off-site shipment. Either
case would require investigation of air emissions and residuals.
Salvage operations -- For other than battery breaking, the investigation must extend to other
liquids and metals.
Smelting and refining sites - Here the RPM must consider numerous additional sources and
types of contamination (e.g., air emissions, smelting and refining agents, and process by-products).
Table 1 summarizes the types of materials found at such sites; Table 2 summarizes alloying, smelting
and refining agents.
Spent battery acid (sulfuric acid)-
Acid contamination should be thoroughly investigated for several important reasons.
o Bulk sulfuric acid in tanks, lagoons, etc. poses a potential worker health and safety
threat.
o Sulfuric acid may promote the mobility of lead and other metals by lowering pH, thereby
increasing their solubility.
-------
TABLE 1. SUMMARY OF MATERIALS AT LEAD BATTERY RECYCLING SITES
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
Whole batteries
Polypropylene battery scrap, mixed/
unmixed/buried
Hard rubber battery scrap, mixed/
unmixed/buried
Metallic lead scrap, mixed/unmixed/
buried, powder/chips/chunks
Unmixed battery mud (lead sulfate and
lead oxides)
Alloying agents *
Refining agents *
Smelting agents *
Slag/matte
Flue dust
Dross
Lead oxides
Sulfuric acid
Lead-contaminated soil
Air pollution control sludges
Water pollution control sludges
Wastewater
Debris
Battery breaking site
X
X
X
X
X
X
X
X
X
X
Integrated
smelter/refiner site
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
* See Table 2 for listing.
10
-------
TABLE 2. LEAD ALLOYING, REFINING, AND SMELTING AGENTS
Alloying Agents
(Watts, 1984)
Refining Agents
(USBOM Circular 9156)
Smelting Agents
Antimony
Arsenic
Cadmium
Calcium
Copper
Nickel
Selenium
Tin
Air
Aluminum
Ammonium Nitrate
Calcium
Magnesium
Natural Gas
Pitch
Potassium Carbonate
Red Lead (Pb304)
Sawdust
Sodium Hydroxide
Sodium Nitrate
Steam
Sulfur
Zinc
Coke
Limestone
Scrap Iron
Silica
Slag
o Sulfuric acid may decompose soil minerals, causing elevated levels of metals in surface
or groundwater.
o Soils where sulfuric acid has been dumped are likely to be high in sulfates, which may
adversely affect solidification/stabilization.
o Depressed pH caused by sulfuric acid can render surface and ground water unpotable
and can adversely affect biota.
The list of likely areas for acid contamination includes the following:
o Battery storage areas (before and after breaking), where acid could leach through soil
underneath the piles
o Soil beneath or surrounding battery breaking equipment
o Acid collection sumps, ponds, or lagoons
o Acid discharge areas
Although lead is generally relatively immobile in soil, the combination of enhanced solubility by
sulfuric acid, porous soil, and/or geology; a high water table; and close proximity to wells or sensitive
environmental areas can result in elevated mobility (and risk).
Asbestos insulation on furnaces and other process equipment and piping-
Asbestos removal can significantly alter cleanup plans.
11
-------
Physical Integrity-
Particularty with older facilities, the RPM must assess the integrity of secondary smelter
structures to ensure the safety of on-site personnel.
The Volume of Material Requiring Cleanup—
This should receive careful consideration. The factors listed below have had a dramatic effect
on volume at lead battery recycling sites:
Burial or incorporation of lead-contaminated wastes into various on-site structures (e.g.,
berms, road surfaces, etc.--a rather common practice at lead battery recycling sites)--A current survey
compared to a pre-operations topographic map can provide useful clues as to where excavations may
have occurred.
Off-site contamination-lf not addressed early in the project, these factors can radically change
the volume to be addressed by the RI/FS:
o Contaminated waste material, sold or given away, could potentially require retrieval and
cleanup.
o Stack emissions may have extended contaminated areas off-site.
o Wind-carried dust from on-site waste piles or other surfaces may have polluted off-site
areas.
o Nearby residences may have received elevated internal lead concentrations.
o Runoff and flooding may have carried contamination off-site.
o Off-site battery breaker facilities may have fed the defunct smelter. Even though
operations may have ceased, these sites may be considered part of the cleanup.
Filtered or unfiltered samples-This choice may affect the amount of lead measured in ground-
water.
The cleanup level selected-This choice depends upon the risk assessment approach and
results. If possible, the specific approach to establishing the cleanup level should be determined early in
the process. Changes in cleanup levels can radically affect the technical and economic feasibility of
remedial options, and hence, the validity of the Feasibility Study.
Storage practices-Storage of raw materials and process by-products require particular
attention. Unlined and/or uncovered areas are sources of contaminated runoff, leachate, and dust.
Recycling of on-site materials-Reuse of these materials may be possible. The RPM should
first explore the possibility of transferring unused raw materials or materials that are commonly recycled
within an operating smelter. For example, some smelters may discard slag with recoverable lead
content, but the cost of off-site transportation to applicable smelters may have made recovery economi-
cally infeasible.
12
-------
The RPM should arrange inspection of on-site materials by primary and secondary lead smelters
and refiners, battery case manufacturers, and boilers and industrial furnace operators that burn
hazardous wastes as fuel supplements. Among the two predominant types of automotive battery
casings, modern polypropylene battery casings are routinely recycled. The older hard rubber cases are
not recycled. However, there appears to be some potential for using hard rubber as a fuel supplement.
Solid waste products from the furnaces may be acceptable for recycling if the metal content is
high enough and objectionable materials are not present, (i.e., slag for lead recovery and matte for iron
recovery).
Disposal locations-Slag and other debris disposal locations may adversely affect feasibility of
in situ solidification.
2.3 DEVELOPMENT OF A CONCEPTUAL SITE MODEL
Development of a conceptual site model accomplishes two goals: (1) it garners a general
understanding of the site to aid in evaluating potential risks to human health and the environment, and
(2) it assists in setting priorities for the activities conducted at the site.
The conceptual site model is a graphic representation of site dynamics. The site model
identifies the following:
o Potential sources of contamination (waste piles, pits, ponds, and lagoons).
o Types of contaminants and affected media (soil, groundwater, surface water, buildings,
structures, and equipment).
o Release mechanisms and exposure pathways of potential contamination.
o Actual and potential human and environmental receptors.
Figure 1 shows an example of a lead battery recycling site conceptual model. After evaluating
the existing data and completing the site visit, the RPM should determine the contaminant release and
transport mechanisms associated with his/her site.
2.4 IDENTIFICATION OF REMEDIAL ACTION OBJECTIVES
Preliminary remedial action objectives are developed during scoping to identify preliminary
remedial action alternatives and Rl data requirements. The objectives are based on the existing data for
the site and the site conceptual model. The preliminary objectives and goals should be developed in
conjunction with the preliminary ARARs and exposure assessment for the site.
Site-specific remedial action objectives for lead battery recycling sites should relate to specific
sources, contaminants, exposure pathways, and receptors. The following remedial action objectives are
typical of lead battery recycling sites and should be considered for the site of interest:
o Protect human and environmental receptors against present or future, direct and dermal
contact with contaminated soil or ingestion of it.
o Minimize damage to the saturated zone and provide adequate protection of it from
migrating (leaching) soil contaminants.
13
-------
s-
t
»
•
»
In
il
1
U
r
|
•
•
•
s
«/»
ra
*
£
1
ex.
•
•
IS
is
oo
•
•
•
•
S
1
1
•3
r1!
Ill
gSo
gs§
I
Source: Modified from USEPA, 1988c.
Figure 1. Example lead battery conceptual site model.
li
14
-------
o Protect human and environmental receptors against present or future dermal adsorption
and ingestion of contaminated groundwater.
o Protect human and environmental receptors against present or future dermal contact
with contaminated structures, buildings, and equipment; also protect them from direct
contact and ingestion of contaminated waste piles.
o Protect human receptors from present or future inhalation of contaminated dust.
o Protect human and environmental receptors against present or future, direct and dermal
contact with and ingestion of contaminated sediments/sludges in pits, ponds, lagoons,
and surface water.
2.5 IDENTIFICATION OF POTENTIAL REMEDIAL TECHNOLOGIES
Preliminary identification of remedial action alternatives should begin after the identification of
preliminary remedial action objectives. The remedial action alternatives developed at this time will help
focus the scope of the Rl activities. They will delineate the degree of data collection for soils, groundwa-
ter, and other media as well as identifying the action-specific ARARs that may influence the scope of the
Rl. The alternatives developed at this time will be refined during the RI/FS process and may change
over time as more information becomes available from the Rl activities.
The remedial technologies commonly proposed in ROOs for lead battery recycling sites are
shown in Table 3. The RPM should investigate the application of other innovative technologies to
remediation of heavy metals. For example, the Superfund Innovative Technology Evaluation (SITE)
Program supports testing of innovative and emerging technologies, reports on their progress, and
documents results. Some innovative technologies specific to heavy metals are discussed in Section 5:
in situ solidification/stabilization, biological sorption of metals, in situ vitrification, flame reactor process,
cyclone furnace, and debris washing system.
As of September 1990, 14 lead battery sites have received Records of Decision (ROD), but none
have implemented treatment remedies. Four RODs have selected No Action remedies (Voortman Farm,
PA; Reeser's Landfill, PA; Union Scrap Iron and Metal, MN; and NL/Taracorp/Golden Auto Parts, MM).
Four other sites (Brown's Battery Breaking, PA; C&R Battery, VA; Hebelka Auto Salvage, PA; and Kas-
souf-Kimerling, FL) have recently received RODs. It appears that an acid-leaching process for cleaning
lead-contaminated soil and battery casings, developed by the U.S. Bureau of Mines (BOM), will be used
on the pilot-scale to treat contaminated soils from the United Scrap Lead and Arcanum sites in Ohio
(possibly in FY91). Other sites are moving towards implementation, after FY91, of other treatment
remedies cited in RODs (e.g., solidification, battery casing washing, and off-site recycling). Also, as
described in Section 4, a number of treatability studies have been conducted with varying degrees of
success regarding (a) solidification/stabilization of soils, (b) washing of soils, (c) acid leaching of soils,
(d) acid leaching of battery cases, (e) segregation and cleaning of battery case scrap, and (f) battery
case recycling.
A number of treatment technologies have been implemented as part of removal actions by the
end of 1990.
Soil-
Solidification of lead-contaminated soil has been completed at the Norco Battery Site,
Norco, CA.
15
-------
TABLE 3. REMEDIAL TECHNOLOGIES COMMONLY PROPOSED FOR LEAD
BATTERY RECYCLING SITES
Contaminated
medium
Technology
Description
Soil
Groundwater
Waste Piles
No action
Solidification/stabilization
Soil washing
Acid leaching
Excavation and off-site
disposal
Capping
No action
Precipitation/flocculation/
sedimentation
Ion exchange
Washing
Removal and off-site disposal
Separation and recycling
Provides a baseline against which other
alternatives can be compared. Includes
groundwater monitoring and land use
restrictions.
Mixes the waste with pozzolanic mate-
rial to produce a strong, monolithic
block.
Uses particle size separation and an
aqueous medium to extract contami-
nants from the soil.
Uses an acid to extract contaminants
from the soil.
Excavates and transports material for
disposal in a RCRA facility.
Installs impermeable barrier/s over the
contaminated soil.
Includes groundwater monitoring and
land use restrictions.
Removes metals as hydroxides, car-
bonates, or sulfides.
Exchanges toxic ions with relatively
harmless ions held by the ion ex-
change material.
Uses a liquid medium to extract
contaminants from battery casings.
Excavates and transports material for
disposal in a RCRA facility.
Separates waste piles based on differ-
ences in size, shape, and density into
components of metallic lead, plastic,
ebonite, and lead oxide. Recyclable
materials are sold.
16
-------
TABLE 3. (continued)
Contaminated
medium
Technology
Description
Buildings, structures,
and equipment
Pits, ponds, lagoons,
and surface water
No action
Demolition
Decontamination
Drainage control measures
Pump and treat water
Dredge sediments mechani-
cally and treat together with
contaminated soil
Includes boarding-up and land use
restrictions.
Includes complete or partial destruction
of structures and disposal of debris.
Washes contaminated structures/
equipment with organic solvent or
detergent.
Includes grading of the site, revegeta-
tion, and addition of storm sewers or
drainage ditches.
Same as groundwater above.
Same as soil above.
o Solidification of lead-contaminated soil should have commenced by the end of 1990 at
the Cedartown Battery Site, Cedartown, GA and at the Lee's Farm Site, Woodville, Wl.
o Liming of soil was used to elevate pH at the C&R Battery Site, Richmond, VA.
o Liming of soil was also used to elevate pH at Murrieta School Site, Murrieta, CA. After
liming, the surface was covered with a 4-inch aggregate base and a 3-inch asphalt
cover.
o Contaminated soil was stabilized with "shotcrete" at the Standard Steel & Metals Salvage
Yard Site, Anchorage, AK.
o Stabilization of contaminated soils, followed by asphalt capping, was completed in June
1988 under a consent order at the NL/Taracorp/Golden Auto Parts Site, St. Louis Park,
MN.
Water-
Lead-contaminated surface water was treated to a discharge level of 25 ppb during
removal actions at the Tonolli Site in Nesquehoning, PA. The treatment system em-
ployed several holding ponds, a rectangular clarifier, a fine paniculate filtering system,
two cation exchange cells, one anion exchange cell, and an activated alumina cell.
17
-------
Pits, Ponds, and Lagoons-
o Sludge in the bottom of the lagoon was removed, dewatered using a filter press, and
disposed on-site at the Tonolli Site, Nesquehoning, PA.
Piles-
o Off-site recycling of lead oxide was chosen by the owner of the Gulf Battery Exchange,
Ocean Springs, MS.
o Off-site recycling of rubber battery chips from Union Scrap Iron and Metals Site,
Minneapolis, MN was accomplished by sending the material to Delatte Metals, Inc., LA.
o Off-site recycling of batteries was part of removal actions at Standard Steel & Metals
Salvage Yard, Anchorage, AK.
Buildings, Structures, and Equipment-
o Concrete floors were scraped of soil and washed with high pressure hoses as part of
removal action at United Scrap Iron & Metal, Minneapolis, MN.
o Floors and walls were decontaminated by sweeping, vacuuming and steam cleaning at
Michael Battery Company Site, Bettendorf, IA.
o Process equipment was decontaminated/demolished under a consent decree at the
NL/Taracorp/Golden Auto Parts Site, St. Louis Park, MN.
Because potential remedies are the core of the RI/FS, Section 5 evaluates them in detail. The
RPM will find Section 5 valuable in planning treatability studies during the scoping phase.
2.6 IDENTIFICATION OF APPLICABLE OR RELEVANT AND APPROPRIATE REQUIREMENTS
(ARARs)
Identifying ARARs assists the RPM in (1) establishing cleanup criteria for remedial alternatives;
(2) planning field activities; and (3) implementing remedial action. ARARs for lead battery recycling sites
have been identified by existing RI/FSs and RODs. The CERCLA Compliance with Other Laws Manual
(USEPA, 1988d) will assist the RPM if it is necessary to identify other site-specific ARARs. ARARs that
apply to lead-battery sites are divided into three categories:
o Action-Specific ARARs (performance design standards, LDRs, etc.).
o Chemical-Specific ARARs (MCLs, MCLGs, etc.).
o Location-Specific ARARs (floodplains, wetlands, etc.).
Action-Specific ARARs
Table 4 lists potential action-specific ARARs which the RPM should consider during the remedy
selection process for lead battery recycling sites. Action-specific ARARs are usually technology- or
18
-------
TABLE 4. REMEDIAL ACTIONS AT LEAD BATTERY RECYCLING SITES
AND ACTION-SPECIFIC ARAR CITATIONS
Remedial action
Potential action-specific
ARAR citation
Land disposal restrictions
Placement of waste in land disposal unit
Slurry wall
Placement of liquid waste in landfill
Surface water control
Disposal or decontamination of equipment, structures, and
soils
Treatment unit
Waste pile
Capping
Construction of surface impoundment
Closure with waste in place
Discharge of treatment system effluent
OSHA regulation
40CFR
40CFR
40CFR
40CFR
40CFR
40CFR
40CFR
40CFR
268 Subtitle C
268 Subpart D
268 Subpart D
264.314
264.251
264.273
264.301
264.221
40 CFR 264.114
40 CFR 264.190-264.192
40 CFR 254.221
40 CFR 264.251
40 CFR 264.343
40 CFR 264.601
40 CFR 264.251
40 CFR 264.228
40 CFR 264.310
40 CFR 264.117
40 CFR 264.258
40 CFR 264.220
40 CFR 264.228
40 CFR 264.310
40 CFR 122.44
40 CFR 125.104
40 CFR 122.41
29 CFR Parts 1904, 1910, and 1926
Source: USEPA, 1988d.
activity-based requirements or limitations. These requirements are triggered by the selection of a par-
ticular remedial activity. Since the RPM usually considers multiple alternative actions, very different
requirements can come into play. Action-specific requirements do not determine the selection of
remedial alternatives; rather, they indicate how the choice must be made.
19
-------
If lead-contaminated wastes (i.e., soils and fragments of battery cases) fail the Toxicity
Characteristic Leaching Procedure (TCLP) test with lead levels equal to or greater than 5.0 mg/L, they
are a RCRA hazardous waste (D008). Lead wastes that produce leachate levels less than 5.0 mg/L are
not considered RCRA hazardous wastes (unless they are hazardous for some other reason).
RCRA hazardous wastes from pits, ponds, lagoons, groundwater, waste piles, soils, structures,
or equipment must meet RCRA Subtitle C treatment, storage, and disposal requirements. RCRA Subtitle
C regulations include the Land Disposal Restrictions (LDRs) in 40 CFR Part 268. The LDRs prohibit the
land disposal of certain RCRA hazardous wastes unless they meet specified treatment standards.
These treatment standards are based on the performance of a Best Demonstrated Available Technology
(BOAT) identified for each RCRA waste code. Treatment standards may be expressed as concentrations
in the TCLP extract or as total waste concentrations.
The LDR program is a "phased-in" program; each waste code has a specific effective date. The
effective date for D008 characteristic lead wastes was August 8, 1990. Much of the contaminated
material at lead battery recycling sites exhibits the TCLP characteristic for lead. Therefore, the LDRs are
applicable to remedial actions involving placement of such hazardous wastes from lead battery recycling
sites. The RPM must research the individual effective date for each Extraction Procedure Toxicity (EP
Toxicity) metal identified at a site.
The treatment standard for lead wastewaters and nonwastewaters is 5.0 mg/L. Wastes treated to
this level have complied with the LDR requirements. By definition, such wastes are no longer RCRA
hazardous wastes. They may, therefore, be sent for disposal in a Subtitle D facility. Lead acid batteries
have a separate treatment standard for thermal recovery of lead in secondary lead smelters. Therefore,
LDR compliance requires that this treatment technology must be used for such wastes.
It should be noted that the storage of lead batteries with the outside shell intact is not consid-
ered land disposal because the battery shell is considered a container (See 40 CFR 264.314(d)(3)).
However, battery storage is subject to the Subpart J storage standards (relating to secure storage,
secondary containment in some instances, and other requirements). (See Appendix C.) Storage of
other D008 lead materials prior to smelting is considered land disposal. Because large amounts of such
materials remain at smelting facilities, EPA has granted a two-year national capacity variance until May 8,
1992 -- allowing such storage prior to smelting (Federal Register, June 1, 1990).
Because TCLP has replaced the EP Toxicity method, a waste may exhibit the TCLP toxicity
characteristic, but not exhibit the EP Toxicity characteristic. In such a case, the waste is considered a
"newly identified" characteristic waste; it is not subject to the LDRs. Therefore, if a waste exhibits the
TCLP toxicity characteristic, the waste should also be analyzed using the EP toxicity method to
determine whether it is subject to the LDRs. Figure 2 outlines this process in a decision tree.
It is important to note that such "newly identified" wastes, while not subject to the LDRs, are still
RCRA hazardous wastes. They can only be sent for off-site disposal in an approved Subtitle C facility. If
the waste is to be landfilled on-site, then the remedial alternative must meet the requirements of 40 CFR
264 regarding capping, closure, and groundwater monitoring.
On-site treatment, such as soil washing of lead-contaminated soil, produces wastewater that can
generally be discharged to groundwater, nearby surface water, or a surface drainage area after
treatment. These discharge methods must meet the applicable state and National Pollution Discharge
Elimination System (NPDES) effluent requirements (whichever is more stringent). The wastewater
treatment residues (sludges) may be hazardous and would require further treatment if they are found to
be characteristic wastes, prior to disposal.
20
-------
Is lead contaminated
waste a hazardous waste?
Conduct TCLP test
NO
YES
Characteristic hazardous waste
Is waste subject to LDRs?
Conduct EP Toxicity test
Non-hazardous waste
Not subject to. LDRs
because waste is newly
, identified
characteristic waste
Figure 2. Decision tree showing when a waste is subject
to land disposal restrictions.
21
-------
Occupational Safety and Health Act (OSHA) Regulations (29 CFR Parts 1904, 1910, and 1926)
apply to all work performed during implementation of a remedial action.
Chemical-Specific ARARs
Lead is the primary contaminant at lead battery recycling sites. Other metals such as antimony,
arsenic, cadmium, chromium, copper, and nickel may be present in trace amounts. The RPM should be
aware that these heavy metals are toxic and, therefore, their concentrations should be checked against
ARARs for these metals. Table 5 lists chemical-specific ARARs for lead.
The Office of Emergency and Remedial Response (OERR) has recommended an interim cleanup
level of 15 ppb for lead in potable groundwater, based on childhood health risks. The EPA has identified
10 jig/dL of lead as a blood level of concern in young children. Lead levels above 10 ng/dL are
associated with increased risk of adverse effects on neurological development and diverse physiological
functions. Lead levels in drinking water of 15 ppb and below should correlate with blood levels of lead
below the concern level of 10 ng/dL (USEPA, 1990b) (Appendix D).
Health-based lead cleanup goals for soil must be developed on a site-by-site basis, since
specific ARARs do not exist at this time. The development of a health-based level is important in deter-
mining acceptable levels of residual contamination in soil. The Center for Disease Control (1985) has
reported that concentrations of lead greater than 500 to 1,000 mg/kg in soil could lead to elevated lead
levels in children who inhale or swallow contaminated dirt. This concentration range has been adopted
by EPA (1989c) as the guidance level for childhood lead exposure at residential sites (Appendix E).
OSWER is currently revising this guidance. The updated guidance, which is scheduled for publication
within the next several months, will offer an alternate approach. It will use a biokinetic/uptake model for
determining site-specific, health-based soil lead standards. Use of the model may result in cleanup
levels outside the 500-1,000 ppm range. In addition, EPA has recently issued RODs for a number of
lead battery site cleanups. Different lead action levels were implemented at specific sites under varying
site conditions (Table 6). These lead action levels are examples of previously selected cleanup levels;
they do not constitute guidance. A baseline risk assessment must be done at each site to establish
cleanup goals.
Location-Specific ARARs
Location-specific ARARs are restrictions placed on the concentration of hazardous substances
or on activities solely because they are done in specific locations. Typically, these locations include
floodplains, wetlands, historic sites, and sensitive ecosystems or habitats.
The RPM should be aware that the local and state regulations may apply more stringent
standards than those identified above. Since ARARs are subject to modification at any time, the RPM
must keep abreast of regulatory changes. The RPM should also communicate with all appropriate state
personnel (i.e., project managers, ARAR coordinators, and toxicologists) regarding changes in state and
local ARARs.
2.7 IDENTIFICATION OF DATA NEEDS
Existing information will typically be insufficient to adequately define the site, plan for potential
treatability studies, and evaluate remedial technologies. For a lead battery recycling site, specific needs
for additional data should be included in the RI/FS Work Plan.
22
-------
TABLE 5. LEAD BATTERY RECYCLING
AND CRITERIA, ADVISORIES,
SITES: CHEMICAL-SPECIFIC ARARs FOR LEAD
AND GUIDANCE TO BE CONSIDERED
Authority/Requirement/Citation
Office of Emergency and Remedial
Response and the Office of Waste
Programs Enforcement
Resource Conservation and Recov-
ery Act
Office of Emergency and Remedial
Response and the Office of Waste
Programs Enforcement
Clean Water Act
Federal Ambient Water Quality Crite-
ria for Protection of Human Health
Clean Water Act
Federal Ambient Water Quality Crite-
ria for Protection of Human Health
Clean Air Act
National Ambient Air Quality Stan-
dards (NAAQS)
Contaminant
Lead
Lead
Lead
Lead
Lead
Lead
Media
Soil
Wastewater and non-
wastewater
Groundwater/
drinking water
Surface water
Surface water
Air
Criteria'
500-1, 000 ppm in soil
(under EPA consider-
ation)
5.0 mg/L level
15 /ig/L
50 *ig/L in water
3.2 ^g/Lb
5.6 ^g/L
1 .5 /*g/m3 in air
Factors
Interim guidance (Ap-
pendix E)
TCLP Toxicity
Recommended by
OERR (Appendix D)
Water & fish ingestion
For freshwater
For marine
CO
a Criteria are subject to periodic review and modification.
b Hardness dependent. This criterion value was calculated using a hardness value of 100 mg/L as CaCO3.
-------
TABLE 6. SUMMARY OF SOIL LEAD ACTION LEVELS FOR LEAD BATTERY SITES
BASED ON RODS AND/OR FEASIBILITY STUDIES*
Source
Preventing lead poisoning in young children by
Centers for Disease Control, 1985
EPA OSWER Directive #9355.4-02
EPA Region HI, ROD, Brown's Battery Breaking
Site, PA
EPA Region III, ROD, C&R Battery Company,
Inc. Site, VA
EPA Region III, ROD, Hebelka Auto Salvage
Yard, PA
EPA Region V, ROD, United Scrap Lead, OH
EPA Region V, ROD, Arcanum Iron and Metal
Site. OH
EPA Region IV, Feasibility Study, Bypass 601
Groundwater Contamination Site, NC
EPA Region IV, Feasibility Study, Sapp Battery
Salvage Site, FL
EPA Region X. ROD, Gould Site, OR
EPA Region X, ROD, Western Processing, WA
Routes
of exposure
Childhood lead
poisoning
Direct contact
Ingestion and
inhalation
Ingestion
Ingestion
Ingestion
Direct contact
Ingestion
Direct contact
Ingestion
Ingestion
Soil lead level
for the protection
of human health
500 to 1,000 mg/kg
500 to 1,000 mg/kg
NA
100 mg/kg
560 mg/kg
500 mg/kg
500 mg/kg
500 mg/kg
79 mg/kg
1,150 mg/kg
1,000 mg/kg
NA
Risk range**
NA
NA
NA
9x10'7-1.6x10'5
for arsenic
NA
NA
NA
NA
NA
NA
4X10"8 - 9.X10"6
for PCB
Basis of decision
Recommended action level for resi-
dential areas.
Recommended action level for resi-
dential areas.
Action level for residential environ-
ment.
Action level for non-residential envi-
ronment.
Based on safe soil ingestion sce-
nario.
Action level for residential environ-
ment.
Action level for residential environ-
ment.
Action level for residential environ-
ment.
Action level for residential environ-
ment.
Action level for work place use.
Action level for residential environ-
ment.
Based on worker scenario.
* There are no date for any other sites.
** Carcinogenic potency factor has not been established for lead so a cancer risk calculation is impossible to perform at this time.
NA Not available.
-------
Sampling and Toxic'rtv Characteristic Leaching Procedure (TCLP) Testing
This test will determine whether lead-contaminated soils or sludges are RCRA hazardous wastes.
The Migration of Lead. Other Metals, and Arsenic
A number of soil and water properties affect migration. Models have been developed to assess
chemical equilibrium for these complex interactions. Table 7 lists the types of input required for metals
speciation models (Hill et al, 1989). Metals speciation models have been used at several lead battery
recycling sites (eg., C&R Battery, VA; ILCO, AL; and Kassouf-Kimerling Battery, FL). As noted in Section
2.1, it is recommended that early coordination be arranged with the EPA Exposure and Ecorisk
Assessment Technology Support Center to ensure the adequate collection of data for speciation models.
If undisturbed, lead tends to accumulate in the soil surface, usually in the top few centimeters.
Concentrations decrease with depth (Adiano, 1986). Insoluble lead sulfide is typically immobile in the
soil profile (Butler, 1954).
Depending on the chemical constituents in a system, pH can have an important impact on the
solubility and, therefore mobility, of metal contaminants. Generally, metals solubility increases with
decreasing pH; arsenic mobility increases with increasing pH. These trends depend on the nature of the
anions and cations in the system, and the presence of chelating agents. Also, the stability of molecular
and ionic species of lead are influenced by pH (Gambrell et al, 1980). The intensity of fixation of lead by
soils is also influenced by pH (Misra and Pandley, 1976; Farrah and Pickering, 1977).
The Cation Exchange Capacity of Soils
This capacity affects the quantity of metal cations that can be tied up by a given amount of soil
and the mobility of the metals. Therefore, the cation exchange capacity of the soils on-site should be
measured.
The Organic Matter Content of a Soil
This content can affect metal mobility in two ways: by affecting oxidation reduction potentials,
and by providing a source of chelating agents, which can increase metal mobility.
More Accurate Delineation of Contaminated Areas
The area and depth of soil and other media contaminated with lead are required to calculate the
feed quantities to be processed. Table 8 lists some sampling techniques for various media, including
portable X-ray fluorescence (XRF) detectors for measuring lead concentrations in soil.
Field-portable XRF units are being used to make in situ measurements of contaminated soil areas
at lead battery recycling sites. XRF can quickly determine the presence of a target metal (Roy F.
Weston, Inc., 1990). This increases the sample population and data averaging that can be used in
mapping, contouring, and other interpretive methods. In situ measurements with the XRF system allow
technicians to immediately locate and quantify surface lead concentrations. The instrument can also be
used for collected samples from subsurface locations. The instrument detection limit for lead is 70 ppm
(USEPA, 1988b). The overall advantages of XRF include 1) minimal sample preparation time, 2) rapid
turnaround analysis time, 3) multi-element analytical capacity, and 4) non-destructive analysis. Its only
disadvantage is the requirement for validation of the method and its applicability must be validated at
each site.
25
-------
TABLE 7. INPUT PARAMETERS NEEDED FOR MINTEQA2 METAL SPECIATION MODEL
Conductivity
PH
Temperature
Total dissolved solids
Hardness
Density
Dissolved oxygen (DO)
Alkalinity
Sulfate
Sulfides [and hydrogen sulfide or methane]*
Chloride
Bromide
Nitrate
Nitrite
Ammonia
Ortho phosphate
Heavy metals
Iron
Manganese
Sodium
Potassium
Calcium
Magnesium
Aluminum
Bicarbonate
Carbonate
Silica
Dissolved organic
carbon**
The following additional redox species, where the
measurement for the total shows the metal to be
present:
Fe+z
Mn+z
Cr+8
Cr+3
* Only to be analyzed for samples with zero DO and an H2S odor; however, the sample collector In
the field should make a note about the presence or absence of a sulfide odor.
** Perhaps dissolved concentrations of specific organic complexes if important for a specific metal.
Source: Hill et al, 1989.
In situ XRF analysis was used exclusively at Brown's battery breaking site during the Phase II
activities (Roy F. Weston, 1990). A portable XRF system was used at the C&R Battery site to screen the
surface soil, subsurface soil, and sediment samples collected during the field investigation. This
minimized the number of samples sent to the Contract Laboratory Program (CLP) laboratories for
analysis. XRF was also used to measure lead concentrations in soil and sediment. The data correlated
closely with the CLP results (NUS, 1990).
Data Sufficient for a Preliminary Assessment
The data must support a preliminary assessment of the suitability of potential remedial alterna-
tives. Table 9 lists typical data required to evaluate each type of treatment. Section 5 presents a further
discussion of remedial technologies.
2.8 DATA QUALITY OBJECTIVES
Data quality objectives (DQOs) for lead battery recycling sites are formulated to ensure that data
of appropriate quality and correct quantity are obtained during remedial response activities. To confirm
that the data are adequate, a clear understanding of the objectives and the decision-making method
must be achieved early in the project planning process. This is accomplished by the development of
DQOs.
26
-------
TABLE 8. TYPICAL SAMPLING PROCEDURES AT LEAD BATTERY RECYCLING SITES
Media
Sampling technique
Remarks
Soils
Waste piles
Pits, ponds, lagoons,
and surface water
Groundwater
Buildings, structures,
and equipment
Grain sampler (thief)
Sampling trier
Trowel (scoop)
Veihmeyer sampler
X-ray fluorescence
Split spoon sampler
Shelby tube sampler
Waste pile sampler
Thief
Auger
Coliwasa
Dipper (pond sampler)
Weighted bottle
Tap
Bailer (monitoring wells)
Surface-wipe sampling
Particularly applicable for sampling powdered or granular lead wastes such as PbO-containing soils.
For surface soils only.
Primarily for core sampling near surface. Not recommended for granular materials.
Generally applicable for soil samples less than 3 inches in depth.
Recommended for sampling at depths 10-15 feet. Difficult to use on stony, rocky, or very wet soil.
XRF has been used successfully to detect lead in soil in concentrations as low as 70 ppm in soil. This
is an in situ analysis technique. Further details can be found in Project Report EPA/600/4-87/021.
Mostly commonly used soil sampling device. Determines the stratification, identification, consistency,
and density of the soils present at a site.
Used to obtain undisturbed samples.
Reid-fabricated PVC pipe approximately 5 ft long and 1.25 inches in diameter, cut lengthwise, and
bored into the pile by hand (basically a large sampling trier).
Available at laboratory supply stores.
Primarily used to sample hard or packed solid wastes or soil.
Permits the sampling of both free-flowing liquids and slurries. Primary limitation: the sample depth
cannot exceed 1.5M.
Not available commercially, usually fabricated for particular application.
Bottles must be fabricated in accordance with ASTM D-270 and ASTM
E-300.
A 2-liter (minimum) sample must be collected for a minimum of 5 minutes.
Excellent means for collecting samples from monitoring wells. They are relatively inexpensive.
Buildings should undergo preliminary sampling for hazardous or toxic vapors and participates.
Source: USEPA, 1984, USEPA, 1980, and USEPA, 1985a.
-------
TABLE 9. DATA REQUIREMENTS FOR POTENTIALLY
APPLICABLE TECHNOLOGIES
Technology
Data requirement
Soil
Solidification/stabilization
(USEPA, 1986a and Arniella et al., 1990)
Soil washing/acid leaching
(USEPA, 1989d and USEPA, 1990c)
Capping
(USEPA, 1987c)
Off-site land disposal
(USEPA, 1987e)
Ground water
Precipitation/flocculation/sedimentation
(USEPA, 1989b)
o Metal concentrations
o Moisture content
o Bulk density
o Grain-size distribution
o Waste volume
o Sulfate content
o Organic content
o Debris size and type
o TCLP
o Soil type and uniformity
o Moisture content
o Bulk density
o Grain-size distribution
o Clay content
o Metal concentrations/species
o pH
o Cation exchange capacity
o Organic matter content
o Waste volume
o Mineralogical characteristics
o Debris size and type
o TCLP
o Extent of contamination
o Depth to groundwater table
o Climate
o Waste volume
o Soil characterization as dictated by the
landfill operator and the governing
regulatory agency
o Waste volume
o TCLP
o Total suspended solids
o pH
o Metal concentrations
o Oil and grease
o Specific gravity of suspended solids
28
-------
TABLE 9. (continued)
Technology
Data requirement
Ion exchange
(USEPA, 1989b)
Pumping via wells
Waste Piles
Off-site landfill
(USEPA, 1987e)
Washing of battery casings
Recycling of battery casings
o Total suspended solids
o Total dissolved solids
o Inorganic cations and anions
o Oil and grease
o pH
o Depth to water table
o Groundwater gradients
o Hydraulic conductivity
o Specific yield estimate
o Porosity
o Thickness of aquifers
o Storativity
o Waste pile characterization as dictated
by land disposal restrictions
o Waste volume
o TCLP
o Casing type
o Bulk density
o Grain-size distribution
o Metal concentrations
o TCLP
o Composition of battery casings
o Metal concentrations
o Waste volume
o Other information required by recipient
o TCLP
29
-------
For a lead battery recycling site, DQOs should focus on site media: groundwater, soil, waste
piles, pits, ponds, lagoons, contaminated buildings, structures, and equipment. For more in-depth
information on DQOs the reader should consult Data Quality Objectives for Remedial Response Actions
(USEPA, 1987b), the second volume of which details the development of DQOs for a site containing,
TCE, lead, chromium, and arsenic.
30
-------
SECTION 3
SITE CHARACTERIZATION
Site characterization encompasses the Rl efforts to define the nature and extent of contamina-
tion at a lead battery recycling site and to collect information needed to conduct the risk assessments
and to select the appropriate remedial alternative for the site. Thus it facilitates the selection of remedial
action alternatives. The following site characterization activities comprise a standard Rl:
o Establish the physical characteristics of the site,
o Define the source, nature, and extent of the contamination, and
o Prepare a baseline risk assessment.
3.1 PHYSICAL CHARACTERISTICS
Data on the physical characteristics of the site and its surrounding areas are collected 1) to
identify potential exposure transport pathways and receptor populations, and 2) to provide sufficient
engineering data to develop and evaluate remedial action alternatives. The following information is used
to define a site's physical characteristics:
o A summary of previous physical data accumulated about the site.
o Site surface features (e.g., battery breakage areas, disposal areas, pits, ponds, lagoons,
buildings, and structures).
o Site geology (depth of aquifer, type of bedrock, etc.).
o Soil and vadose zone characteristics (permeability, moisture content, cation exchange
capacity, pH, etc.).
o Site hydrogeology (depth to water table, hydraulic conductivity, porosity, groundwater
flow direction, etc.).
o Surface water hydrology (drainage patterns, flow in surface water bodies, etc.).
o Meteorological data (precipitation, temperature, etc.).
o Information on demographics, land use, and water use (current/future population,
location of drinking water intake, recreational areas, etc.).
o Ecological information (wetlands, floodplains, parks, etc.).
31
-------
These data may be obtained from a variety of federal, state, and local sources including aerial
photographs, historical photographs, topographic surveys, site operation records, sampling/monitoring
results, demographics, United States Geological Survey (USGS), zoning maps, previous investigations,
and interviews with present/past site owners and employees.
3.2 SOURCE, NATURE, AND EXTENT OF CONTAMINATION
Typical sources of contamination at lead battery recycling sites are heavily contaminated soils;
waste piles; groundwater; pits, ponds, and lagoons; surface water; and buildings, structures, and
equipment. Geophysical surveys can be used to determine the vertical and lateral variations in both
subsurface stratigraphy and subsurface metal contamination. A variety of survey techniques (e.g.,
ground penetrating radar, electrical resistivity, electromagnetic induction, magnetometry, and seismic
profiling) can effectively detect the locations and extent of buried waste deposits. Borehole geophysics
can be conducted at selected well locations in order to better characterize subsurface stratigraphy.
Field screening techniques such as XRF can be used to pinpoint sampling locations at areas of greatest
contamination ("hot spots"). Soil and waste samples are typically analyzed in the laboratory for the
USEPA Target Analyte List (TAL) metals, TCLP toxicity, total cyanide, total organic carbon, pH,
acidity/alkalinity, and cation exchange capacity. Table 10 contains a complete list of TAL metals.
Monitoring wells are installed and sampled upgradient and downgradient from a lead battery
recycling site. Groundwater monitoring wells are allowed to equilibrate before water level measurement
or groundwater sampling. A slug or pump test can also be performed to evaluate aquifer characteristics.
Samples from the wells are analyzed for TAL metals, total cyanide, total organic carbon, total suspended
solids, total dissolved solids, pH, alkalinity/acidity, hardness, sulfate, chloride, specific conductance,
temperature, and dissolved oxygen. Remedial actions in some geographic regions may be based on
unfiltered groundwater samples, while in others filtered or both filtered and unfiltered samples are used.
Filtered sample analyses are used for concentrations of dissolved and colloidal groundwater con-
stituents. Unfiltered sample analyses are appropriate for total metals concentrations, including metals
contained in suspended sediments.
Water and sediment samples are collected from pits, ponds, lagoons, and surface water; the
samples are analyzed for the chemical parameters mentioned above.
Sampling methods for tests that determine the nature and extent of contamination on building,
structure, and equipment surfaces have not yet been standardized. Surface-wipe sampling is generally
used. In surface-wipe sampling (wet or dry), a surface is wiped with a cotton swab or filter paper.
These media may or may not be wetted with solvent. When needed, small sections of contaminated
structure materials (e.g., corings) can determine the depth of contaminant penetration into porous
materials such as wood or concrete. More information on this subject can be obtained from Guide for
Decontaminating Buildings, Structures, and Equipment at Superfund Sites (USEPA, 1985a).
More details on sampling and analysis can be obtained from Data Quality Objectives for
Remedial Response Actions (USEPA, 1987b), Compendium of Superfund Field Operations Methods
(USEPA, 1987a), and Tesf Methods for Evaluating Solid Waste - Physical/Chemical Methods (USEPA,
1980).
3.3 RISK ASSESSMENT FOR LEAD BATTERY RECYCLING SITES
Risk assessments evaluate the likelihood and potential magnitude of human or environmental
exposure to hazardous substances. Risk assessments can help determine what cleanup levels and
remedies are needed. Risk assessments are multidisciplinary. They may involve expertise in numerous
32
-------
TABLE 10. TARGET ANALYTE LIST (TAL) METALS
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Calcium
Chromium
Cobalt
Copper
Iron
Lead
Magnesium
Manganese
Mercury
Nickel
Potassium
Selenium
Silver
Sodium
Thallium
Vanadium
Zinc
areas, such as chemistry, toxicology, hydrogeology, soil science, environmental modeling, and statistics.
Because risk assessment is an integral part of decision-making at all stages of the RI/FS process, the
project team should employ risk assessors and toxicologists early in the process.
Risk assessments at lead battery recycling sites do not differ in approach from those at other
types of CERCLA sites, but there are a few unique features that are helpful to consider in planning a
RI/FS.
3.3.1 Risk Assessment Guidance
The Superfund Program recommends the use of five EPA publications in assessing risk at sites.
o Risk Assessment Guidance for Superfund (RAGS) - Volume I, Human Health Evaluation
Manual (USEPA, 1989e),
o Risk Assessment Guidance for Superfund (RAGS) - Volume II, Environmental Evaluation
Manual (USEPA, 1989f).
o Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions
(USEPA, 1990f).
o Guidance for Conducting Remedial Investigations and Feasibility Studies Under
CERCLA. Interim Final (USEPA, 1988c).
o The Risk Assessment Guidelines of 1986 (USEPA, 1987d).
Superfund has established a technical support center at the Environmental Criteria and
Assessment Office (ECAO) in Cincinnati, Ohio (FTS-684-7300). EPA publishes quarterly Health Effects
Assessment Summary Tables (HEAST). A general overview of toxicity information on the three most
prevalent contaminants at lead battery recycling sites -- lead, antimony, and arsenic - is provided below.
Lead-
Acute inorganic lead intoxication in humans is characterized by brain disease, abdominal pain,
destruction of red blood cells, liver damage, kidney disease, seizures, coma, and respiratory arrest.
Chronic, low levels of lead exposure can affect the hematopoietic system, the nervous system,
and the cardiovascular system. Lead inhibits several key enzymes involved in heme biosynthesis. One
characteristic effect of chronic lead intoxication is anemia, due to reduced hemoglobin production and
shortened erythrocyte survival. In humans, lead exposure has caused nervous system injury, reducing
33
-------
hand-eye coordination, reaction time, visual motor performance, and nerve conduction velocity. The
developing child seems especially sensitive to lead-induced nervous system injury.
Lead can also affect the immune system and produce gingival lead lines. Epidemiological
studies have indicated that chronic lead exposures may be associated with increased blood pressure.
Exposure to lead has been associated with sterility, abortion, and infant mortality. Organolead
compounds are neurotoxic.
EPA has classified lead as a Group B2 carcinogen based on renal tumors in experimental
animals (Federal Register, August 18, 1988).
Antimony-
Antimony exposure can irritate the gastrointestinal tract. Acute toxic effects include severe
vomiting and diarrhea. With occupational exposures, rhinitis and acute pulmonary edema may occur.
Inhalation of some antimony compounds can inflame the nasal lining, the throat, the trachea,
and the bronchi. It can cause both chronic obstructive lung disease and emphysema. Transient spots
on the skin have been reported in workers.
Arsenic--
Acute oral exposure to arsenic can cause muscle cramps, facial swelling, cardiovascular
reactions, severe gastrointestinal damage, and vascular collapse leading to death. Inhalation exposures
can cause severe irritation of the nasal lining, larynx, and bronchi.
Chronic oral or inhalation exposure can produce changes in skin, including hyperpigmentation
and hyperkeratosis; peripheral neuropathy; liver injury; and cardiovascular disorders. Oral exposures
may be associated with peripheral vascular disease.
Arsenic is a known human carcinogen. Oral exposures are associated with skin cancer;
inhalation exposures can cause lung cancer.
3.3.2 Specific Risk Assessment Issues at Lead Battery Recycling Sites
3.3.2.1 Lead Issues for Lead Battery Recycling Sites-
Before collecting environmental data at the site, the RPM should consult with the Regional
Toxicologist to assess the state of risk assessments for lead-contaminated sites. Currently, EPA has no
established reference dose (RfD) or slope factor to estimate the numerical noncarcinogenic and carcino-
genic health impacts resulting from lead exposures. Previous toxicity values for lead, most notably
those published by the American Institute of Cancer (AIC) in the Superfund Public Health Evaluation
Manual, have been withdrawn and their use prohibited. Risk assessments performed before 1989 may
use the AIC; however, current risk assessment guidance disqualifies its use. Furthermore, development
of an RfD to evaluate the quantitative, noncancer effects of lead has been prevented by a lack of hard
data on the effects in infants and young children. The multiple media providing exposure to lead also
makes it difficult to gather statistics for threshold. Therefore, EPA may elect to use other risk models in
evaluating the potential risks associated with lead exposure.
Because health effects may be correlated with it, the level of lead in blood is a more appropriate
benchmark for health effects than an estimated intake level. The Integrated Uptake/Biokinetic (IU/BK)
34
-------
model, currently being developed by the EPA and New York University as a software package, may
provide a means of predicting lead levels in blood -- based on total lead uptake from inhalation, and
ingestion of soil, dust, paint, food, and drinking water. The current IU/BK model estimates lead uptake
and blood levels in children up to 6 years old. This model is designed to accept input of site-specific
variables. If these variables are not available, the model defaults to pre-programmed values. This model
is still under development; in the future, it may provide a new approach to determining lead exposure.
The EPA Regional Toxicologist should be consulted before employing any lead exposure model.
An OSWER directive (Appendix E) suggests soil cleanup levels between 500 and 1,000 ppm for
lead-contaminated soils In residential or potential residential areas ~ taking site conditions into
consideration (USEPA, 1989C). However, this directive is not sensitive to the multi-media nature of lead
exposure and to the variable contribution to total lead uptake of these media at varying sites. Therefore,
OERR is proposing the use of the IU/BK model, which will tailor soil cleanup levels to the site, and the
RPM should check the status of the modified guidance.
3.3.2.2 Exposure Pathways for Lead Battery Recycling Sites-
Exposure assessment encompasses three objectives: to identify actual or potential exposure
pathways, to characterize the potentially exposed populations, and to determine the extent of the
exposure. Lead contamination at battery recycling sites may occur through one or more of the following
mechanisms:
o Ingestion of contaminated media, such as groundwater and soil;
o Inhalation of contaminated media through exposure to entrained dust, including
ingestion of particulates that have been expelled from the lungs; and
o Dermal exposure to contaminated media.
The potential risk from each of these exposure pathways must be evaluated in the context of the
site. In all cases, exposure potential, based on current and future site activities, should be evaluated for
both residential and occupational exposures. If site-specific intake values are not available, the EPA-
published intake values for ingestion and inhalation (USEPA, 1988e and USEPA, 1988f) should be used.
These default values should provide estimates of potential exposure to site contaminants.
Children are especially sensitive to low-level effects of lead contamination. Other receptors
should not be excluded, but exposure of children is of paramount importance in the assessment. The
risk to children is greater, not only because of lead toxicity, but also because of childhood activity
patterns. They tend to play outdoors where there is increased potential for exposure to lead in soil. Soil
ingestion rates are higher for children than for other groups.
Site access is often restricted; therefore on-site exposures to contaminated media may be
limited. However, should someone gain access to the site, they may experience additional exposure to
contaminated soils and other particulates. Ingestion exposure is intensified by hand-to-mouth activity.
In addition, contaminants may be transported home, with subsequent exposure to other family members.
3.3.2.3 Risk Assessment Data Needs-
Although the data needs for risk assessment at lead battery recycling sites are generally similar
to those at other sites, some unique features should be considered: the physical nature of the waste,
the use of background data, and the association of lead with other metals. If the biokinetic model is to
35
-------
be used, input needs should be assessed before data are collected. Since the uptake biokinetic model
is under development and therefore subject to revision, it is recommended that ECAO (FTS-684-7300) be
contacted to ascertain its status and required input values.
The physical characteristics of wastes at lead battery recycling sites differ from those at many
other types of sites. Large pieces of metallic lead and contaminated battery casings are unique to these
sites. The consideration of these physical characteristics is important in planning the Rl. Because it is
unlikely that these large pieces of contaminated material will follow the same migration pathways as fine-
grained material, it is necessary to assess both particle size and contaminant concentrations. For
example, incidental ingestion of contaminated material may be due to various hand-to-mouth activities
(such as smoking and eating). However, this mechanism would apply only to the fine-grained material;
large pieces of casings or slag would not be ingested. Particle size will also determine whether
contaminated material can become air-entrained.
To obtain Rl data for the risk assessment, likely exposure scenarios should be developed. If the
exposure routes depend on particle size, it may be necessary to conduct size separation on key
soil/material samples and to analyze fine and coarse fractions separately for metal concentrations.
Adequate characterization of background lead concentrations may also be necessary -
especially for sites having high natural background concentrations or sites affected by mining activities.
Plans for collecting background samples should be verified statistically to ensure that the correct
numbers and sample locations are targeted.
Other metals may be associated with lead battery recycling sites. Analyses should not exclude
other toxic metals. The site history should be critically evaluated to determine if other activities there
may have caused other types of contamination.
36
-------
SECTION 4
LEAD BATTERY RECYCLING TREATABILITY STUDIES
Treatability studies are tests designed to provide critical data needed for the evaluation and,
ultimate implementation of one or more treatment technologies at a specific site. They can be run in the
laboratory or the field. These studies generally aid the characterization of the untreated waste and
analysis of technology performance under different operating conditions. The results may be qualitative
or quantitative, depending on the level of the test. Three types of factors dictate the level of test needed;
phase-related (e.g., RI/FS or RD/RA), technology-specific, and site-specific factors. More information on
treatability studies can be obtained from Guide for Conducting Treatability Studies Under CERCLA
(USEPA, 1989b) and on treatability study vendors, from Inventory of Treatability Study Vendors - Volume
I (USEPA, 1990b).
4.1 EXAMPLES OF SITE-SPECIFIC LEAD BATTERY RECYCLING TREATABILITY STUDIES
Treatability studies on the technologies listed below and described in Section 5 have been
documented in RI/FS documents for lead battery recycling sites:
o Solidification/stabilization (cement-based) - very effective on lead-contaminated soils.
o Soil washing -- promising in the laboratory, but unsuccessful at two sites because of
material handling problems.
o Acid-leaching (Bureau of Mines process) ~ promising, but still in bench-scale develop-
ment.
o Recycling of battery casings -- (Canonie Environmental Services Corp. process) claimed
to produce approximately 75 percent recyclable materials at Gould Site in Oregon.
4.1.1 Solidification/Stabilization of Soil
Norco Site--
Only one full-scale, on-site treatment has been completed to date at a Superfund lead battery
recycling site (Norco Battery Site in California). The Norco Site had approximately 8,000 tons of soil
contaminated with lead sulfate (levels up to 80,000 mg/kg). Raw untreated soils had an EP Toxicity
value for lead exceeding 400 mg/L Contaminated soils were screened to 1-1/2 in., pretreated with a
40% calcium hydroxide slurry, and set aside for 3 days before treatment by fixation. This soil was then
mixed, in a mobile plant, with portland cement, fly ash, and water at a rate of 300 tons per day. Results
achieved were as follows:
o EP Toxicity and TCLP results for lead after 28 days: < 5 mg/L;
37
-------
o American Nuclear Society (ANS) 16.1: greater than leach index of 12; and
o Unconfined compressive strength: >500 psi (Martyn, EPA Region 10, personal commu-
nication, 1990).
C&R Battery Site-
HAZCON, Inc. conducted a bench-scale treatability study at the C&R Battery Site in Virginia to
determine the solidification reagents and ratios most suitable to lead-contaminated soil. The concentra-
tion of lead in the EP Toxicity extract (untreated soil) was 119 mg/L. This treatability study evaluated the
effectiveness of mixing various ratios of pozzolanic materials with soil, including Type I and Type II
Portland cement, fly ash, lime, sodium silicate, and sodium phosphate. Only the cement-based (i.e.,
cement or cement with additives) blends exhibited increases in resistance to leaching of lead. The
treatability results also indicated that the addition of lime and sodium silicate to the cement/soil mixture
significantly decreased the teachability of the solidified material. (See Table 11.) The stabilization
mixture with the smallest percent volume increase that met the EP Toxicity criterion consists of a
1:0.6:0.03 soil/cement/sodium silicate ratio (by weight). Unconfined compressive strength test results
indicated 28-day compressive strengths greater than 1,400 psi for the solidified materials (NUS, 1990).
Gould Site-
A bench-scale study -- conducted by Weston Services, Inc. on soil and sediment from the Gould
Site in Oregon -- suggested that Portland cement, cement kiln dust, and lime kiln dust, mixed with the
soil and sediment at specific increments, improved the consistency, structural stability, and non-
leachability of the contaminated materials. Table 12 summarizes the TCLP laboratory test data for the
various admixtures (Dames and Moore, 1988).
A pilot-scale treatability test was conducted at the Gould site by Canonie Environmental to
collect the information needed to select a formulation for stabilization of waste materials left on the site
following remediation. The program demonstrated that a mix of approximately 14 percent Portland
cement Type l-ll, 25 percent cement kiln dust, and 35 percent water successfully stabilized soils and
waste products crushed to 1/8-in. size. As shown in Table 13, this formulation met all the physical
strength and long-term stability requirements for on-site disposal (Canonie Environmental, undated).
Sapp Battery Site-
A treatability study was conducted at the Sapp Battery Site in Florida to evaluate cementation
technologies for leachate minimization potential. The chemical fixation results indicate that the cement
mixture was much more effective in binding lead than the cement, fly ash, and lime mixture. The
Portland cement mixture exhibited excellent binding capacity in all samples tested. The fixed sample
levels were at or near the lead detection limit of 0.06 mg/L (USEPA, 1989d), far below the maximum
allowable concentration of 5 mg/L (EP Toxicity).
38
-------
TABLE 11. SOLIDIFICATION/STABILIZATION TREATABILITY STUDY RESULTS
FOR CEMENT-BASED BLENDS THAT PASSED EP TOXICITY
CRITERION FOR LEAD AT THE C&R BATTERY SITE
Soil
1.0
1.0
1.0
1.0
1.0
1.0
Type II
Portland
cement
0.6
0.6
0.6
1.0
1.0
1.0
Lime
0.067
0.7
0.0
0.0
0.055
0.0
Sodium
silicate
0.0
0.03
0.08
0.0
0.0
0.0
Sodium
phosphate
0.0
0.0
0.0
0.0
0.0
0.067
Lead
concentration
in extract*
(mg/l)
4.2
3.2
1.5
2.4
0.8
2.2
*Concentration in EP Toxicity extract.
EP Toxicity criterion for lead is 5 mg/L
EP Toxicity value for untreated soil was 119 mg/L.
TABLE 12. TCLP LEACH TEST RESULTS OF BENCH-SCALE STUDY
CONDUCTED ON SOIL AND SEDIMENT FROM THE GOULD SITE
Soil
matrix
Soil
Sediment
Soil
Soil
Soil
Soil
Soil
Sediment
Sediment
Soil
Soil
Soil
Soil
Reagent
description
N/A
N/A
20% Portland cement
20% Cement kiln dust (CKD)
20% Fly ash
20% Lime kiln dust
20% CKD, 0.22% sodium carbonate
50% Cement kiln dust
50% Lime kiln dust
10% CKD, 1.4% sodium carbonate
10% Cement kiln dust
30% Cement kiln dust
10% CKD, 3.7% sodium carbonate
Lead leachate
level mg/L
710.0
24.0
NDa
3.5
503.0
1.0
36.6
ND
1.0
503.0
336.0
1.4
69.4
*ND - Sample was analyzed, but not detected.
Source: Dames and Moore, 1988
39
-------
TABLE 13. SUMMARY OF CANONIE TEST RESULTS ON THE RECOMMENDED
BINDER FORMULATION AT GOULD SITE
Test
Criteria
Results
Pass/fail
Unconfined Compressive
Strength (ASTM C39)
Extraction Toxicity Procedure
(EPA Method 1310)
Permeability (USAGE
EM-110-2-1906)
Long-Term Leaching
(ANSI/ANS 16.1)
Wet/Dry Test (ASTM 4843)
Potential Reactivity of
Aggregates (ASTM C289)
50 Ibs/in2 gauge (psig)
5 ppm
10"4 cm/sec (less than
surrounding soil)
No specific criteria
Less than 30% wt. loss
Classified as innocuous
255 psig to 1,432 psig
0.8 ppm to 1.7 ppm
Up to 3x10"6 cm/sec
Less than 4 ppm dis-
solved lead (declining
concentration with time)
Less than 0.06% wt. loss
Classified as innocuous
Pass
Pass
Pass
Pass
Pass
Pass
Source: Canonie Environmental, undated.
Lee's Farm-
The proprietary MAECTITE™ Process, developed by Maecorp, Inc. has been proposed as a
treatment at the Lee's Farm in Wisconsin. It will stabilize contaminated waste by converting the lead into
a chemical complex which is resistant to leaching. Full-scale operations are scheduled to begin in late
1990 (Maecorp, Inc., personal communication, 1990).
Cedartown Battery-
At Cedartown Battery in Georgia, a contract has been awarded for solidification of approximately
22,000 cu yd lead-contaminated soil to the following specifications (after curing 28-days): EP Toxicity <_
50 ppb; TCLP <. 50 ppb, MEP <_ 5 ppm; permeability >. 1x10"" cm/s; unconfined compressive strength
>. 50 psi; and volumetric increase <. 50%.
Non-Lead Battery Sites-
Table 14 lists non-battery sites where stabilization/solidification has been used, is in use, or is
proposed for use in remediating hazardous wastes containing lead (USEPA, I989a). For additional
information on solidification/stabilization, see Section 5.
4.1.2 Soil Washing/Acid Leaching
Soil washing is primarily a physical process whereby the contaminants which are physically and
chemically adhered to the smaller soil particles (i.e., clay, silt, and humus) are separated from the larger
particles. In contrast to soil washing, acid leaching dissolves contaminants by lowering the pH of the
system. Soil washing and acid leaching have been tested on the laboratory- and bench-scale with
promising results.
40
-------
TABLE 14. NON-LEAD BATTERY SOLIDIFICATION CASE STUDIES (USEPA, 1989a)
Site/
contractor
Unnamed,
ENRECO
Marathon Steel,
Phoenix, AZ
Silicate technology
N.E. Refineiy
ENRECO
Amoco Wood
River
Chemfix
Pepper Steel A
Alloy
Miami, FL
VFL Technology
Corporation
Chem Refinery, TX
HAZCON
Chicago Waste
Hauling, American
Colloid
John's Sludge Fit,
KS/Terracon Con-
sultants, Inc.
Saco Tannery
Waste Pits, ME,
VFL Technology
Corporation
DouglassviUe, PA
HAZCON
Contaminant
(concentration)
Pb/Md 2-100 ppm
Pb, Cd
Oil sludges, Pb, Cr,
As
Oil/so lids
Cd, Cr, Pb
Oil sat. soil
Pb - 1,000 ppm
PCBs - 200 ppm
As - 1-200 ppm
Combined metals
sulfur, oil, sludges.
etc.
Metals: Cr, Pb, Ba,
Hg,Ag
Pb, Cr, acid
Cr(> 50,000 ppm)
Pb (> 1,000 ppm)
Zn - 30-50 ppb
Pb - 24,000 ppm
PCBs - 50-80 ppm
Phenol - 100 pg/L
Oil and grease
Treatment
volume
7,000 yd-*
150,000yd5
100,000yd3
90.000,000 gal
62,000yd3
(plus 5,000
tons of sur-
face debns)
90.000 gal
(445 y20%
(volume >30-
35%)
NA
> Vaned,
-20% average
Average 15%
-1%
> Estimated
10%
> Variable
> Variable
>15%
NA
Scale of
operation
Full
Full
Full
Full (sue
delutedin
1985)
Full
Full
Bench
Bench
Pilot
Pilot
-------
TABLE 14. (continued)
Site/
contractor
Portable Equip-
ment, Claduunas,
OR, CHEMFDC
Contaminant
(concentration)
Pb, Cu, PCB»
Treatment
volume
40^
Physical
form
Sou
Chemical
pretreatment
Y/N
N
Binder
Cement, ciucate
Percentage
binder(s)
added
NA
Treatment
(batch/
continuous
in situ)
Batch
Disposal
(on-site/
off-site)
NA
Volume,
increase
%
NA
Scale of
operation
Pilot
"Total volume on-cite.
NA - Not available.
-------
Lee's Farm/ILCO Sites--
Two sites have unsuccessfully attempted soil washing of lead-contaminated soil. Lee's Farm in
Woodville, Wisconsin attempted soil washing with EDTA after brief laboratory-and bench-scale testing.
However, this attempt was discontinued when material handling problems became excessive (USEPA,
1988a). The EPA Mobile Soils Washing System (MSW) was used at the ILCO Site in Leeds, Alabama.
The MSW reduced the level of lead in the ILCO soil from 47,000 to 1,300 ppm. However, severe
materials handling problems - such as fine particles clogging the filter, excessive suspended solids
loading to the EDTA/lead recovery system - prevented the MSW from cleaning up the entire site
(USEPA, 1988a).
Arcanum/Lee's Farm Sites-
Researchers have investigated the process characteristics, design, and economics of a soil-
washing process that employs an electromembrane reactor (EMR) to treat contaminated soils and to
recover heavy metals such as lead (USEPA, 1988a). The electrowinning process uses EDTA as the
chelating agent and recovers lead by electrodeposition. Treatability studies were performed on lead-
contaminated soils from two Superfund sites (Arcanum near Troy, Ohio and Lee's Farm in Woodville,
Wisconsin). The optimum EDTA/lead molar ratio appears to be 1.5 to 2.0 for both soils tested (USEPA,
1988a). EDTA was not effective in chelating metallic lead in the soils obtained from the Arcanum or
Lee's Farm sites.
EPA Test Program-
EPA recently completed a series of laboratory tests on soil and casing samples from metal
recycling sites. These tests were intended to determine, among other findings, the feasibility of using
soil washing to reduce lead contamination. The soii samples from these sites were subjected to bench-
scale washing cycles using water, EDTA, or a surfactant (Tide detergent), respectively. The results did
not augur success for battery breaker applications. Soil washing did not remove significant amounts of
lead from any of the soil fractions. The lead was not concentrated in any particular soil fraction but
rather was distributed among all the fractions. A comparison of lead concentrations in the wash waters
indicated that the EDTA wash performed better than the surfactant and water washes (PEI Associates,
Inc., 1989). While EDTA was reasonably effective in removing lead, Bureau of Mines researchers
observed that its effectiveness seemed to vary with the species of lead present (Schmidt, 1989). The
Bureau also felt that there are a number of problems associated with EDTA's field application, such as
the following:
o Cost of the reagent.
o Extreme difficulties in filtering sands and silts.
o Complexity of recycling EDTA.
o Variety of EDTA forms required (depending on the prevalence of various lead species).
Barth et al of EPA conducted a bench-scale study on contaminated soils from several battery
cracking sites across the United States. In this study, soil washing was used as a pretreatment before
solidification/stabilization (S/S). This treatment train approach is feasible because lead is more easily
separated from coarse size particles. S/S is then applied to the smaller volume of fine size particles.
Different washes of tap water (pH = 7), anionic surfactant (0.5%), and Na
-------
that the chelating wash solution removed more lead from the raw soil than the water or surfactant
washes. However, the amount removed was insignificant compared to the total lead content. The
authors concluded that weathering time impacts the efficiency of separating contaminants from a soil.
S/S was effective in reducing the mobility of lead from the washed fines (Barth et al, 1990).
BOM Acid Leaching -
The Bureau of Mines (BOM) conducted bench-scale studies to evaluate the performance of acid
leaching solutions on lead in contaminated soil at battery recycling sites. They first subjected soil to an
ammoniacal leach containing ammonium carbonate and ammonium bisulfite. This converted the lead
species to lead carbonate, which would then be leached with fluosilicic acid and the lead electrowon
from solution. While electrowinning the lead was feasible, its plant required a significant capital outlay.
Since the quantities of contaminated materials to be treated at a single site were relatively small,
BOM decided to investigate the production of lead sulfate sludge instead of lead metal. In this case, the
soil would be subjected to carbonation followed by nitric acid leaching. This would be followed in turn
by the addition of sulfuric acid to precipitate the lead from the solution as lead sulfate.
Table 15 shows some representative results from the Bureau of Mines test. The results indicated
that nitric acid solutions can achieve very high removal efficiencies for soil (greater than 99%) and an EP
Toxicity level less than 1 mg/L (Schmidt, 1989). For additional discussion on soil washing, see
Section 5.
4.1.3 Recycling of Battery Casings
There has been no actual field experience to date in the recycling of battery casings at lead
battery recycling sites. BOM-conducted, bench-scale treatability studies showed good removal
efficiencies (Table 16). The residual battery casing materials have an EP Toxicity lead concentration less
than 5 mg/L (Schmidt, 1989).
Three battery casing separation tests were performed on Gould Site materials. One test
employed equipment manufactured by MA Industries, Inc. and the other two equipment manufactured by
Poly-Cycle Industries, Inc. The two companies manufactured similar equipment. However, MA Indus-
tries markets equipment for battery breaking operations, while Poly-Cycle primarily deals only with the
already separated battery components. Each process is designed for spent batteries, not battery
components mixed with dirt and mud. The treatability results were as follows:
o Separated plastic components failed the TCLP lead test. Ebonite failed badly, even after
washing with hydrochloric acid and deionized water.
o A hydrochloric acid wash removed only a minor fraction of the lead contamination from
the plastic.
o A deionized water wash had little or no effect on the lead content.
These results indicate that lead is interstitial or bound into the solid plastic or ebonite matrix,
rather than surficial (Dames and Moore, 1988).
A number of commercial vendors were contacted about recycling the Gould, Inc. battery casings
(Tetta, 1989). Several of their facilities feed the ebonite casing component directly to a smelting furnace
as a source of fuel and carbon. Most of the companies expressed reluctance because the amount of
44
-------
TABLE 15. REPRESENTATIVE RESULTS OF THE BUREAU OF MINES TREATABILITY TESTS
ON SELECTED SAMPLES OF BATTERY BREAKER SOIL WASTES
Site/waste
United Scrap Lead soil
United Scrap Lead soil
Arcanum soil
Arcanum soil
C&R Battery Soil Sample B
Common
lead
species
Pb, PbSO4, PbOx
Pb, PbS04> PbOx
Pb (6.6%), PbSO4
Pb (6.6%), PbSO4
Pb, PbSO4, PbCO3,
PbO2
Average"
lead
total
(ppm)
8,000-18,000
8,000-18,000
71,000
71,000
71,000
Leaching
method
15% HNO3, 2-hr wash
and 1% HNO3, 24-hr
soak
80 g/L F*, 4-hr & 20
g/L F*, 4-hr, 2-stage
wash, 1%HNO3> 24-hr
soak
80 g/L F*. 4-hr, 50 'C
& 20 g/L F*, 4-hr,
50 "C, 2-stage leach
and 1% HNO3, 24-hr
wash
15% HNO3, 2-hr, 50'C
leach and 1% HNO3,
50 -C, 24-hr wash
15%HNO3, 2-hr and
2% HNO3, 24-hr wash
and 1 -hr water rinse
Total
lead
(ppm)
200
203
334
<250
29
EP
Toxicity
(mg/L)
<1.0
<1.0
0.26
<0.1
<0.1
"No initial EP Toxicity data available.
F* Fluosilicic acid
Source: Schmidt, 1989
-------
TABLE 16. REPRESENTATIVE RESULTS OF THE BUREAU OF MINES TREATMENT TESTS ON
SELECTED CHIP SAMPLES OF BROKEN BATTERY CASING WASTES
Site/waste
United Scrap lead
granulated chips
Arcanum broken chips
C&R Battery casing
chips
Gould buried casing
chips
(broken)
Rhone-Poulenc casing
chips (broken)
Common
lead
species
PbSO4, Pb
PbSO4, Pb
PbSO4, Pb
PbCO3, PbS04
PbCO3
Average*
lead
total
(ppm)
3,000
3,000
175,000
65,000
Leaching
method
0.5%HNO3, 1-hr,
20 -C wash
1% HNO3, tap wa-
ter, 50 -C, 24-hr,
agitated
1% HNO34-hr,
wash and water
rinse
Ammonium carbon-
ate carbonation,
1% HNO3, 20 -C, 4-
hr wash
Calcium carbonate
carbonation, 0.5%
HNO3, 20 -C, 1-hr
wash
Total
lead
(ppm)
86
210
277
145
516
EP
Toxicity
(mg/L)
<0.2
<3.5
0.15
0.52
3.68
"No initial EP Toxicity data available.
Source: Schmidt, 1989
-------
recoverable lead in the Gould ebonite would be low and its recovery would lower their production
capacity (Tetta, 1989). Several developing processes should become capable of processing waste
battery piles and recovering valuable materials. The success of a particular process will depend, in part,
on how strongly the lead adheres to the ebonite.
Canonie Environmental Services Corp. under contract to NL Industries, Inc. has developed a
proprietary process. They claim this process is capable of recycling 75 percent of the materials at the
Gould site waste.
47
-------
SECTION 5
EVALUATING REMEDIAL ALTERNATIVES
5.1 REMEDIAL ACTION OBJECTIVES
At lead battery recycling sites, the general remedial action objective is to provide adequate
protection for the public and the environment against ingestion, direct contact, or inhalation through the
following:
o Contact with contaminated soil, sludge, sediment, waste piles, buildings, structures,
and/or equipment;
o Contaminated runoff from the site;
o Potential use of contaminated groundwater;
o Contaminated airborne paniculate emissions.
Site-specific remedial action objectives should refer to specific sources, contaminants, pathways,
and receptors.
5.2 DEVELOPING GENERAL RESPONSE ACTIONS
General response actions for lead battery recycling sites that potentially meet the remedial
action objectives have been identified. These actions are media-specific. They include no action, treat-
ment, containment, removal, or any combination of these. Table 17 lists the general response actions
and associated remedial technologies proposed in presently available RI/FS studies and RODs
according to each contaminated medium found at lead battery recycling sites. A list of contrac-
tors/vendors for several specific technologies is given in Table 18.
5.3 DEVELOPMENT AND SCREENING OF TECHNOLOGIES
Feasible remedial alternatives for CERCLA lead battery recycling sites for each medium of
concern will now be discussed in detail. (Appendix B [Table B-1] lists these alternatives.) Each
technology will also be evaluated for six of the nine evaluation criteria developed by EPA: compliance
with ARARs; long-term effectiveness and permanence; reduction of toxicity, mobility, or volume; short-
term effectiveness; implementability; and cost. They are not, however, evaluated against overall
protection of human health and the environment, state acceptance, and community acceptance (the
other three EPA criteria).
Innovative technologies are "those technologies where limited available data on the performance
and/or cost inhibit their use for many Superfund types of applications (USEPA, 1991)." Currently, all
48
-------
TABLE 17. SUMMARY OF GENERAL RESPONSE ACTIONS AND ASSOCIATED REMEDIAL TECHNOLOGIES
COMMONLY PROPOSED FOR LEAD BATTERY RECYCLING SITES
Medium
Soil
Groundwater
Waste piles
Building, structures, and
equipment
Pits, ponds, lagoons,
surface water
General response action
No action
Treatment
Soil removal
Containment
No action
Treatment
Treatment
Removal
Resource recovery
No action
Demolition and disposal
Decontamination
Drainage control
Sediment treatment
Sediment removal
Remedial technology
Environmental monitoring
Solidification/stabilization
Soil washing
Excavation and off-site disposal in a RCRA landfill
Capping
Groundwater monitoring
Pumping with precipitation/flocculation/sedimentation treatment
Ion medium filtration
On-site washing with lead recovery
RCRA landfill
Recycling
Boarding up structures
Off-site RCRA landfill
Solvent or detergent washing
Drainage control measures
Solidification /stabilization
Mechanical dredging and off-site disposal in a RCRA landfill
Known lead
battery sites
including the
technology
4
9
2
2
3
4
3
1
1
2
3
All sites
3
2
All sites
3
1
-------
TABLE 18. CONTRACTOR/VENDOR LIST
Process
Company name, location
Solidification/stabilization
Soil washing
Acid leaching
Precipitation/flocculation/
sedimentation
Recycling
o Pretreatment
o General
o Lead
o Plastic
o Ebonite
ATW/Caldweld, Sante Fe Springs, CA
Bethlehem Steel, Bethlehem, PA
Chemfix Technologies, Inc., Metairie, LA
Chemical Waste Management, Riverdale, IL
Ensite, Inc., Tucker, GA
Ensotech, Inc., North Hollywood, CA
Envirite Reid Services, Plymouth Meeting, PA
Geo-Con, Inc., Pittsburgh, PA
IM-Tech, Oakwood, TX
International Waste Technologies, Wichita, KS
Lopat Enterprises, Wanamassa, NJ
Maecorp, Inc., Chicago, IL
Resource Recovery of America, Inc., Lakeland, FL
Separation and Recovery Systems, Inc., Irvine, CA
Silicate Technology Corp., Scottsdale, KZ.
Soliditech, Inc., Houston, TX
Solidtek Systems, Inc., Morrow, GA
ToxCo, Division of Thorne Environmental, Inc., Anaheim, CA
Wastech, Inc., Oak Ridge, TN
Westinghouse Hittman Nuclear, Inc., Columbia, MD
Biotrol, Inc., Chaska, MN
Chapman, Inc., Atlantic Highlands, NJ
Ecova Corporation, Redmond, WA
Harmon Environmental Services, Inc., Auburn, AL
Ozonics Recycling Corporation, Key Biscayne, FL
Waste-Tech Services, Inc., Golden, CO
Westinghouse Electric Corporation, Pittsburgh, PA
Bureau of Mines, Washington, DC
ANDCO Environmental Process, Amherst, NY
Carbon Air Services, Hopkins, MN
Chemical Waste Management, Riverdale, IL
Detox, Inc., Dayton, OH
Ensotech, Inc., North Hollywood, CA
Envirochem Waste Mgmt. Serv., Gary, NC
Rexnord Industries, Milwaukee, Wl
Tetra Recovery System, Pittsburgh, PA
Canonie Environmental Services Corp.
Waste exchanges (PIES Bulletin Board)
Smelters (Appendix F)
Battery case manufacturers
Cement kilns & power plants
Sources: USEPA, 1986b; USEPA, 1986c; USEPA, 1987c; and USEPA, 1990h
50
-------
source control technologies -- with the exception of immobilization of most inorganics and incineration of
most organics - are innovative. With regard to groundwater remediation, all in situ technologies for
remediating groundwater and source material are currently considered innovative. This section will
discuss potentially applicable innovative technologies that are either in or selected for the SITE
demonstration program. The technologies will be discussed by medium (i.e., for soil: Biotrol, Inc. Soil
Washing, Geo Safe In Situ Vilification, in situ solidification/stabilization, Retech, Inc. Plasma Reactor, and
Babcock and Wilcox Co. Cyclone Furnace; for groundwater: Bio-Recovery Systems, Inc. Biological
Sorption and Colorado School of Mines' Wetlands-Based Treatment; and for waste piles: Horsehead
Resource Development Co., Inc. Flame Reactor and Risk Reduction Engineering Laboratory Debris
Washing System).
5.3.1 No Action
The no action alternative provides a baseline against which other alternatives can be compared.
This alternative contains no remedial action yet it does involve environmental monitoring and institutional
restrictions such as site fencing, deed restrictions, restrictions on groundwater usage, warning against
excavation, and public awareness programs.
Periodic groundwater monitoring is conducted throughout the area of potential contamination
using on-site/off-site monitoring wells and, possibly, nearby residential wells. It evaluates the migration
of contaminants and the potential for contamination of nearby residential wells. In addition, sampling of
surface water and soil/sediment are conducted to monitor off-site transport of contaminants via surface
water runoff, erosion, and fugitive dust.
Advantages:
o None. However periodic monitoring of groundwater provides a warning mechanism
against future contaminant concentrations and possible migration from the site.
Disadvantages:
o No treatment or engineering control is exercised. Therefore risks due to direct contact,
ingestion and inhalation remain.
o Neither toxicity, mobility, nor volume of contaminants is reduced.
o There may be a time lag between contaminant migration and detection.
5.3.2 Contaminated Medium: Soil
Overview-
o The RPM should be aware that no full-scale, innovative technologies have yet been
applied at lead battery recycling sites. However, prior to completion of this report, novel
(non-cement based) solidification operations to achieve very low allowable leachate
levels were planned for sites at Lee's Farm, Wisconsin and Cedartown Battery, Georgia.
o Cement-based solidification has been most widely used/tested S/S technology.
o Soil washing/acid leaching - in particular the BOM process - shows promise. Howev-
er, it still remains to be proven in a pilot-scale unit. Its planned implementation at the
USL and Arcanum sites in Ohio should provide valuable information on the process.
51
-------
o Excavation and off-site disposal has been practiced in the past. However, it will not
continue (due to Land Disposal Restrictions), unless the contaminated materials are
treated prior to disposal.
o Capping has been proposed for some sites with low contamination levels.
Lead is the primary contaminant found in soil at lead battery recycling sites. Other heavy metals
such as antimony, cadmium, copper, arsenic, and selenium are sometimes present, but normally only in
trace concentrations. Lead-contaminated soils are a RCRA characteristic waste if the TCLP lead level is
greater than 5.0 mg/L. To ensure protection of personnel and the community, a health-based action
level must be developed at lead battery recycling sites.
In accordance with OSWER Directive #9355.4-02, ARARs are not available for lead in soil, and
therefore, a soil cleanup range of 500 to 1,000 mg/kg established by the Center for Disease Control
(1985) - based on childhood lead poisoning - has been adopted as a technical directive (USEPA,
1989c). This OSWER directive is currently undergoing review and may be revised. Different action
levels have been implemented at specific sites under varying site conditions. (See Table 6.)
Sediments and sludges from pits, ponds, lagoons, and surface water are generally treated with
contaminated soils at lead battery recycling sites.
5.3.2.1 Solidification/Stabilization of Soil (S/S)-
Solidification processes produce monolithic blocks of waste with high structural integrity. The
contaminants do not necessarily interact chemically with the solidification reagents (typically ce-
ment/lime) but are mechanically locked within the solidified matrix. Stabilization methods usually involve
the addition of materials such as fly ash or blast furnace slag which limit the solubility or mobility of
waste constituents -- even though the physical handling characteristics of the waste may not be changed
or improved (USEPA, 1982). Methods involving S/S techniques are often proposed in RODs and RI/FSs
for lead battery recycling sites. Solidification/stabilization of contaminated soil can be conducted either
in situ or ex situ. In situ S/S techniques are now considered innovative and are discussed later in this
section.
Usually S/S encompasses excavating the surface and subsurface soils contaminated with lead
and treating them with a pozzolanic stabilization process. If the treated soil no longer displays the TCLP
toxicity characteristic for lead, it can be deposited off-site in a local industrial or sanitary landfill or in an
on-site landfill. If the treated soil complies with RCRA land disposal restrictions [40 CFR 268], it can be
deposited in a RCRA landfill.
The most common processes used at lead battery recycling sites employ portland cement or
lime pozzolans. S/S involves mixing the contaminated soil with portland cement and/or lime along with
other binders such as fly ash or silicate reagents to produce a strong, monolithic mass. Cement is
generally suitable for immobilizing metals (such as lead, antimony, cadmium, and nickel) which are
found at lead battery recycling sites. Because the pH of the cement mixture is high (approximately 12),
most multivalent cations are converted into insoluble hydroxides or carbonates. They are then resistant
to leaching. Arsenic does not form insoluble hydroxides or carbonates. Some metals like lead, nickel,
etc. have increased solubility at the very high pHs that occur in the cement hydration reaction. For
example, during the S/S processing of lead with cement, the lead is most likely converted into its least
soluble form, namely lead hydroxide (Pb(OH)2). On the other hand, when a weak acid-slurry salt such
as sodium silicate (Na2Si03) is added, the salt undergoes hydrolysis and increases the OH" concentra-
tion drastically. This results in the formation of PbO22" which can leach out easily. Therefore, pH is the
52
-------
key process variable to control (Barth et al, 1990). This effect is important when highly alkaline binders
are used. However, metal hydroxides and carbonates are insoluble only over a narrow pH range; they
are subject to leaching and solubilization in the presence of even mildly acidic leaching solutions, such
as rain (USEPA, 1985c). Therefore, the solidified waste must be capped or deposited in a landfill. S/S
increases the weight and volume of the original material from 10 to 100%, thereby increasing transporta-
tion and disposal costs. The actual increase in volume should be verified during treatability studies.
Critical parameters in stabilization treatment include the selection of stabilizing agents and other
additives, the waste-to-additive ratio, and the mixing and curing conditions. All these parameters depend
on the chemical and physical characteristics of the waste. Bench-scale treatability tests are required to
select the proper additives ratios and curing times. Leaching and compressive strength tests determine
the integrity of the end product. Numerous leaching tests have been developed to test solid wastes,
including the American Nuclear Society leach tests (ANS 16.1), and the Dynamic Leach Test (DLT)
developed especially for hazardous wastes. More detail can be obtained from Stabilization/Solidification
of CERCLA and RCRA Wastes: Physical Tests, Chemical Testing Procedures, Technology Screening,
and Field Activities (USEPA, 1989a).
Advantages:
o It reduces the migration of lead.
o Treatment is relatively inexpensive.
o Solid product can be prepared by careful selection of material.
o Mixing equipment is readily available.
o Technology is suitable for immobilizing heavy metals, such as lead at lead battery
recycling sites.
o Additives are readily available.
Disadvantages:
o It increases volume of treated material.
Problems and Concerns:
o Secondary containment may be needed because lead, still present, may migrate with
time. No long-term data is available at this time.
o Undesirable chemical reactions can occur. Material compatibility must be investigated.
o Large amounts of dissolved sulfate salts or metallic anions in wastes (e.g., arsenates and
borates) hamper solidification and concrete stability.
o Organic matter, lignite, silt, or clay in wastes increases setting time and can lead to
materials handling and mixing complications.
o Oil and grease interfere with bonding by coating the waste particles.
53
-------
TABLE 19. SUMMARY OF EPA EVALUATION CRITERIA OF REMEDIAL TECHNOLOGIES FOR SOIL
Remedial
technology
No action
Solidification/
stabilization
Compliance
with
ARARs
Doe* not comply with RCRA
clean closure or landfill clo-
sure requirements [40 CFR
Part 264, Subpart GJ.
Must comply with NAAQ Stan-
dards for lead and paniculate
matter.
Worker protection dunng on-
slte activities must comply
with OSHA health and safety
requirements.
Must comply with RCRA clo-
sure requirements under 40
CFR Part 264, Subpart G.
Off-site or on-srie disposal
must comply with RCRA land
disposal restrictions [40 CFR
Pan 268].
Off-site transportation must
comply with
o RCRA hazardous waste
generator and trans-
portation regulations.
o Federal and stale DOT
transportation
regulations.
Long-term
effectiveness
and
permanence
Contaminants would contin-
ue to migrate off-site and
downward through subsur-
face soil.
Groundwater monitoring
would determine degree of
contaminant leaching and
provide a warning mecha-
nism.
No long-term human health
or environmental risks would
be anticipated with site (data
on long-term effectiveness
of solidification is limited).
Reduction of
toxfctty, mobility,
or volume
Does not reduce toxtcity, mo-
bility, or volume of contami-
nation In the soil.
Increases volume of contami-
nated soil (approximately 10-
10O%).
Reduces the mobility of lead
In the soil.
Short-term
effectiveness
Remedial action not In-
volved. Protection of work-
ers, community, and environ-
ment during remediation
activities Is not a consider-
atlon.
Minimal protection of public
health from exposure to on-
site surface soils.
Oust may be generated dur-
ing excavation and handling
activities.
Respiratory protection, fugi-
tive dust control procedures.
and air monitoring may be
required to protect workers
and community.
Imptomentablllty
No Imptomentablllty consid-
erations.
Would not Interfere with future
Widely Implemented and reli-
able.
Large staging area required.
Many vendors, mobile sys-
tems available for processing
excavated soH.
Would not Interfere with future
remedial actions at site.
Presence of Interfering com-
pounds may inhibit solidifica-
tion process.
Cost
No caprtai costs.
There will be
costs associated
with samplinQ
and analysis.
$27-$164/cuyd°
(USEPA. 1S86a).
-------
TABLE 19. (continued)
Remedial
technology
Solidification/
•tabulation
(continued)
Sofl washing/
acid teaching
Excavation and off-site
disposal
Compliance
wtth
ARARs
On-sN* treatment must com-
ply with RCRA and state oper-
ating regulations.
If treated soil it shipped to a
sanitary/industrial waste land-
fill, the facility must comply
with RCRA and state regula-
tions.
Must comply with NAAQ stan-
dards for lead and partlculate
matter.
Worker protection during on-
site activities must comply
with OSHA health and safety
requirements.
Must comply with RCRA clo-
sure requirements under 40
CFR Part 264. Subpart G.
On-site treatment must com-
ply with RCRA and state oper-
ations regulations.
On-site or off-site disposal
must comply with RCRA land
disposal restrictions (40 CFR
Part 268).
Must comply with NAAQ stan-
dards for lead and paniculate
matter.
Worker protection during on-
slte activities must comply
with OSHA health and safety
requirements.
Off-site transportation must
comply with
Long-term
effectiveness
and
permanence
No long-term human health
or environmental risks would
be associated wtth site.
Groundwater monitoring not
required.
No long-term human health
or environmental risks would
be associated with site.
Groundwater monitoring not
required.
Reduction of
toxlctty, mobility,
or volume
Permanently reduces toxlctty
of soil by removing lead.
Concentrates contaminants
into much smaller volume.
In order to reduce volume.
process must provide a satis-
factory method for treating
washing fluids.
Does not reduce toxicity or
volume of contaminants in
the soil. Mobility Is reduced
by placing them in a RCRA-
landfill.
Short-term
effectiveness
Dust may be generated dur-
ing excavation and handling
activities.
Respiratory protection, fugi-
tive dust control procedures,
and air monitoring may be
required to protect workers
and community.
Dust may be generated dur-
ing excavation and handling
activities. Respiratory protec-
tion, fugitive dust control
procedures, and air monitor-
Ing may be required to pro-
tect workers and community.
Implementablltty
Bench- and pilot-scale testing
required to assess all
Implementablllty
considerations.
No mobile systems available;
treatment plant must be con-
structed on-*tte.
Large staging area required.
Technologies are demonstrat-
ed and commercially avail-
able.
Land disposal restrictions
apply.
Would not Interfere wtth future
remediation actions at site.
Cost
$208/cu yd"
(Schmidt, 1989).
Value of recov-
ered metal can
partially offset
treatment costs.
$287-488 cu yd"
(1982) (Environ-
mental Law Insti-
tute, 1984).
Ol
Ul
-------
TABLE 19. (continued)
Remedial
technology
Excavation and off-site
disposal (continued]
Capping
Compliance
with
ARARs
o RCRA hazardous waste
generator and trans-
portation regulations,
o Federal and Stale DOT
transportation regula-
tions
The disposal facilities must
comply with RCRA and state
regulations for disposal.
Must comply with NAAQ stan-
dards for lead and particulate
matter.
Worker protection during on-
site activities must comply
with OSHA health and safety
requirements.
Must comply with RCRA clo-
sure requirements under 40
CFR Part 264, Subpart G.
Long-term
effectiveness
and
permanence
Capping provides protection
of public hearth from expo-
sure to on-srie soil contami-
nation and controls off-site
migrations of contaminants.
Groundwater monitoring
required to verify that no
leaching of contaminants
occurs at downgradient
locations.
Reduction of
toxicfty, mobility,
or volume
Does not reduce toxicity or
volume of contamination at
the Kite.
Reduces downward mobility
of contaminants and reduces
off-site migration of contami-
nants due to wind erosion
and surface water run-off.
Short-term
effectiveness
Dust may be generated dur-
ing excavation and handling
activities. Respiratory protec-
tion, fugitive dust control
procedures, and air monitor-
ing may be required to pro-
tect workers and community.
ImplementabllKy
Readily Implemented.
Technologies are reliable and
commercially available.
Future remedial actions re-
quired removal of cap and
disposal of cap materials If
caps Is not reinstalled.
Cost
$6.06/sq ft" for a
multi-layered cap
(USER A, 1885b).
Cost varies with
the type of cap.
"Updated to 1990 using cost indexes in Engineerings News Record.
-------
Successful S/S of soil would achieve a remedial action objective by protecting the public health
from ingestion and inhalation of contaminated soil, and by inhibiting the migration of lead and other
contaminants to groundwater and off-site. This technology is a RCRA Land Disposal Restriction Best
Demonstrated Available Technology (BOAT) to treat lead-contaminated wastes (D008 wastes). Table 19
summarizes the EPA evaluation criteria for technologies that remediate soil used at sites with completed
RI/FS or RODs.
Two specific in situ S/S techniques, studied under the SITE Program, hold promise for lead
battery recycling sites.
International Waste Technologies/Geo-Con, Inc. In Situ Solidification/Stabilization
Process-This in situ solidification/stabilization technology immobilizes organic and inorganic com-
pounds in wet or dry soils, using additives to produce a cement-like mass. The basic components of
this technology are: Geo-Con's deep soil mixing system (DSM) which delivers and mixes the chemicals
with the soil in situ; and a batch mixing plant to supply the International Waste Technologies (IWT)
proprietary treatment chemicals.
The IWT technology can be applied to soils, sediments, and sludges contaminated with organic
compounds and metals. The technology has been laboratory-tested on soils containing pentachlorophe-
nol (PCP), polychlorinated biphenyls (PCBs), refinery wastes, and chlorinated or nitrated hydrocarbons.
The DSM system can be used in almost any soil type. However, mixing time increases in
proportion with fines. It can be used below the water table and in soft rock formations. Large
obstructions must be avoided. The SITE Demonstration of this technology occurred in April, 1988.
S.M.W. Seiko, Inc. In Situ Solidification/Stabilization-The Soil-Cement Mixing Wall (S.M.W.)
technology developed by Seiko, Inc. involves the in situ stabilization and solidification of contaminated
soils. Multi-axis, overlapping, hollow-stem augers are used to inject solidification/stabilization agents
and blend them with contaminated soils in situ. The product is a monolithic block down to the treatment
depth. This technology applies to soils contaminated with metals and semi-volatile organic compounds.
This project was accepted into the SITE Demonstration Program in June 1989. Site selection is
currently underway.
5.3.2.2 Soil Washing/Acid Leaching-
Soil washing is a water-based process for mechanically scrubbing soils ex situ to remove
undesirable contaminants. The process removes contaminants from soils in one of two ways: by
dissolving or suspending them in the wash solution or by concentrating them into a smaller volume of
soil through simple particle size separation techniques. Acid leaching dissolves contaminants by
lowering the pH of the system.
This technology excavates the lead-contaminated soil, washing the lead on-site with a solution
(such as nitric acid or EDTA), and returning the treated soil to the site for disposal in the excavation
area. There is limited field experience with the washing of excavated soil at lead battery recycling sites.
(See Section 4.1.2.) EDTA was used as part of an EPA emergency response at Lee's farm in Wisconsin
with less than satisfactory results due to materials handling and other process-related problems, such as
wastewater treatment, filtering of the sand and silts, incompatibility of processing equipment with EDTA
(Weston-Sper, 1988). Bench-scale treatability studies performed at three lead battery recycling sites
(C&R Battery, VA; and United Scrap Lead and Arcanum, OH) by the U.S. Bureau of Mines showed high
removal efficiencies for lead using nitric acid. One of the limitations of soil washing as a viable
alternative concerns the physical nature of the soil. Soils which are high in clay, silt, or fines have
57
-------
proven difficult to treat. Bench-and pilot-scale testing must be performed prior to implementation. This
technology requires significant development. It is classified as emerging or innovative in the United
States. Nevertheless, it is used extensively in Europe. More details on non-U.S. processes can be
obtained from Treatment Technology Bulletin: Soil Washing (USEPA, 1990c). This document is
currently in draft form, with final edition expected in 1991.
Figure 3 describes the U.S. Bureau of Mines Acid Leaching Process. Fine soil is subjected to a
carbonation step, using ammonium carbonate solution. Ammonium bisulfite (NH4HS03) is also added to
convert PbO2 in the soil to PbSO4; the PbS04 is, in turn, converted to PbCO3 by the ammonium car-
bonate ((NH4)2CO3). The mix is heated and agitated to precipitate the lead as acid-soluble lead car-
bonate. The carbonated soil is washed in a nitric acid solution to solubilize the lead carbonate. The mix
is filtered, rinsed, and conveyed to acid soak tanks where lead sulfate is precipitated by sulfuric acid
(Schmidt, 1989). There is a market for lead sulfate. The clean soil is stored or returned to the site.
Waste streams from the washing system require further treatment before final discharge. Some active
lead battery recycling sites have on-site industrial wastewater treatment systems that may be able to
receive these waste streams.
Bench- and laboratory-scale treatability tests, as discussed in Section 4, would determine the
type of washing solution, optimum concentration, optimum reaction time, potential methods of
regeneration, and other wastewater treatment requirements. Soil washing produces large amounts of
contaminated water requiring treatment.
Advantages:
o Volume of the contaminant mass is reduced.
o Recyclable lead product from acid leaching can partially offset the cost of treatment.
Disadvantages:
o Soil washing and acid leaching are still in the bench-scale development stage.
o Soils which are high in clay, silt, and/or humic material have proven difficult to treat.
o Workers must be trained to handle acids for the acid leaching process.
o Specialized acid-resistant equipment must be used for the acid leaching process.
Problems and Concerns:
o Mineralogical characteristics of soil and previous soil treatment (e.g., neutralization) can
have detrimental effects on process reactions and usage of reagents.
o Laboratory and pilot testing are necessary to determine feasibility.
o Effluent from soil washing systems require further treatment before final discharge. If
reagents are expensive and are not recyclable, they will increase treatment costs.
o Lead sulfate sludge may require further treatment before sale.
58
-------
C7I
CO
[ ACID WASH 1^
SOIL
RINSE
EVAPO
WION
FEED
CASINGS
SCR
EJN>
I CARBONATION
OVERSIZE
( +4 INCH )
T
J '
SOIL
RINSE »j_FIL
1 Ann
J Hl
H,SO, »f PRECIP
,
RINSF
ICUADO
TT-I •> FILTRATE -
RINSE
i/APlj
VVMwl 1
ER 1
TATION |
rn 1 ta» ^llinfiF
lATinu 1
Figure 3. Bureau of Mines Soil Washing Process
LIME
•f PRECIP
TATION
GYPSUM
REGENERATION -h NH3
S02
CO,
-------
Biotrol, Inc. Soil Washing--The Biotrol Soil Washing System is a water-based, volume-reduction
process for treating excavated soil. The objective of this process is to concentrate the contaminants in a
smaller volume of material separate from a washed soil product. The efficiency of soil washing can be
improved using surfactants, detergents, chelating agents, pH adjustment, or heat. This technology is
applicable to soils contaminated with polyaromatic hydrocarbons (PAHs), PCP, pesticides, PCBs, various
industrial chemicals, and metals. This process was demonstrated under the SITE program in 1989 for
soil contaminated with PCP and PAHs from the MacGillis & Gibbs Superfund Site in New Brighton,
Minnesota.
5.3.2.3 Soil Excavation and Off-Site Disposal
Excavation and removal of contaminated soil to a RCRA landfill, have been performed exten-
sively at lead battery recycling sites. Off-site disposal must be done in a RCRA landfill. Landfilling of
hazardous materials is becoming increasingly difficult and expensive due to growing regulatory control.
Excavation and removal are applicable to almost all site conditions, although they may be cost-
prohibitive for sites with large volumes, greater depths or complex hydrogeologic environments.
Determining the feasibility of off-site disposal requires knowledge of land disposal restrictions (See
Section 2.4) and other regulations developed by state governments. Excavation can be accomplished
by a wide variety of conventional equipment such as backhoes, cranes, draglines, clamshells, dozers,
and loaders. The hauling equipment includes scrapers, haulers, dredges, dozers, and loaders. Fugitive
dusts from excavation are commonly controlled by chemical dust suppressants, wind screens, water
spraying, and other dust control measures (e.g., maintaining a favorable slope).
Advantages:
o Engineering control is achieved.
o Contamination is eliminated at the site.
o There is no need for long-term monitoring.
o It is capable of combination with almost any other remedial
technology.
Disadvantages:
o Costs associated with off-site disposal are high.
o Short-term impacts such as fugitive dust emissions are a major
concern.
o Contamination is transferred to another location.
Problems and Concerns:
o The location of the RCRA-compliant landfill, to which the excavated soil would be
transported, has a substantial impact on cost.
o Without treatment, this technology may not meet RCRA land disposal restrictions.
60
-------
5.3.2.4 Soil Capping-
Capping involves the installation of an impermeable barrier over the contaminated soil to restrict
access and reduce infiltration of water into the soil. A variety of cap designs and materials are available.
Most designs are multi-layered to conform with the performance standards in 40 CFR 264.310 which
addresses RCRA landfill closure requirements. However, single-layered designs are used for special
purposes at lead battery recycling sites, for example, when treated soil is backfilled into an excavated
area. Low permeability clays and synthetic membranes are commonly used. They can be covered with
top soil and vegetated to protect them from weathering and erosion. Soil materials are readily available,
and synthetic materials are widely manufactured and distributed.
The selection of capping materials and a cap design are influenced by specific factors such as
local availability and cost of cover materials, functions of these materials, the nature of the waste being
covered, local climate, site hydrogeology, and the projected future use of the site.
There are two basic capping designs: multi-layered and single-layered. The RCRA land disposal
regulations of 40 CFR, Subparts K through N require multi-layered caps. The statute describes the
proper design: a three-layered system consisting of 1) a low permeability layer, 2) a drainage layer, and
3) an upper vegetative layer (USEPA, I985b).
For the first 20 years of service, a properly installed cap generally performs well. However, it
should be inspected on a regular basis for signs of erosion, settlement, or subsidence - and restored as
necessary. In addition, associated groundwater monitoring wells must be maintained and sampled
periodically.
Advantages:
o Engineering control (containment) is achieved.
o It presents a more economical alternative than excavation and removal of wastes.
o The technology reliably seals off contamination.
o Soil materials are readily available.
o Synthetic materials are widely manufactured and distributed.
Disadvantages:
o It does not remove contamination.
o It establishes need for long-term maintenance.
o Design life is uncertain.
o Long-term monitoring is required.
Problems and Concerns:
o Periodic inspection and maintenance (i.e., mowing, reseeding, resealing) are needed to
assure a cap's long-term integrity.
61
-------
The cost of a cap depends on the type and amount of materials selected, the thickness of each
layer, and the region. Table 20 presents the general material and installation costs for caps larger than
10 acres. In a recent RCRA Part B permit application for a 4-acre hazardous waste landfill, the installed
cost of a multi-layered cap was estimated at $5A5/tf. The design for this cap included 3 ft of top soil,
overlying a 1 -ft sand layer, overlying 1 ft of compacted clay, overlying a 30-mil High Density Polyethylene
(HOPE) liner, overlying 2 ft of compacted clay (USEPA, 19855).
5.3.2.5 In Situ Vitrification-
Contaminated soils are converted into chemically inert, stable glass and crystalline materials by
a thermal treatment process. Large electrodes are inserted into soil containing significant levels of
silicates. Because soil typically has low conductivity, flaked graphite and glass frit are placed on the soil
surface between the electrodes to provide a starter path for electric current. A high current passes
through the electrodes and graphite. The heat melts contaminants, gradually working downward
through the soil. Volatile compounds are collected at the surface for treatment. After the process ends
and the soil has cooled, the waste material remains fused in a chemically inert and crystalline form that
has very low teachability rates. This process can be used to remove organics and/or immobilize
inorganics in contaminated soils or sludges. It has not yet been applied at a Superfund site. However,
it has been field demonstrated on radioactive wastes at the DOE's Hanford Nuclear Reservation by the
Geosafe Corporation.
Advantages:
o Technology is suitable for immobilizing heavy metals.
o Resulting vitrified mass is effectively inert and impermeable.
Disadvantages:
o The process is energy intensive and often requires temperatures up to 2500°F for fusion
and melting of the waste matrix.
o Special equipment and trained personnel are required.
o The technology has not been demonstrated for heavy metals yet.
Problems and Concerns:
o Water in the soil affects operational time and increases the total costs of the process.
o The technology has the potential to cause some contaminants to volatilize and migrate
to the outside boundaries of the treatment area.
5.3.2.6 Other Innovative Processes-
Retech, Inc. Plasma Reactor-This thermal treatment technology uses heat from a plasma torch
to create a molten bath that detoxifies contaminants in soil. Organic contaminants vaporize and react at
very high temperatures to form innocuous products. Solids melt into the molten bath. Metals remain in
this phase, which -- when cooled - forms a non-leachable matrix.
62
-------
TABLE 20. 1990 UNIT COSTS ASSOCIATED WITH CAPPING DISPOSAL SITES
Element
Cost*
Clearing and grubbing
Excavation
Earthfill
Berms and levees
Soil liners
Backfill
Soil import
Drainage sand
Drainage rock (rounded)
Soil placement
Vegetation, mulch, and hydroseed
Geotextile fabrics
Bentonite admix (2-9 Ibs/yd3)b
Membrane liners
Nonreinforced
30 mil PVC
30 mil CPE
30 mil Butyl/EPDM
30 mil Neoprene
100 mil HOPE
Reinforced
36 mil Hypalon (CSPER)
60 mil Hypalon (CSPER)
36 mil Hypalon
Installation, excluding earthwork
$l,227.00/acre
$1.78/yd3
$2.34/yd3
$3.46/yd3
$3.46/yd3
$11.71/yd3
$11.71/yd3
$1.12/yd3
$1.227.00/acre
$1.12-$3.46/yd2
$0.22-$1.23/ft=
$0.28 - $0.39^
$0.39 - ^.SO/ft2
$0.50-$0.61/ft2
$0.78 - $0.89^
$1.23-$1.78/ft2
$0.56 - $0.67/ft2
$0.89-$1.12/ft2
$0.56 - $0.67^
$0.67-$1.34/ft2
"Based on costs for a 400,000 ft2 area (USEPA, 1985b) as updated by construction, labor, and material
cost Indices in Engineering News Record 1985 and 1990.
"Includes mixing and placing.
PVC - polyvinyl chloride
CPE - chlorinated polyethylene
EPDM - ethylene-propylene-diene-monomer
CSPER - chlorosulfonated polyethylyene (reinforced)
63
-------
This technology can treat both liquid and solid organic compounds. It is most appropriate for
soils and sludges contaminated with metals and hard-to-destroy organic compounds. A demonstration
is planned in late 1990 at a Department of Energy research facility in Butte, Montana.
Babcock and Wilcox Co. Cyclone Furnace Process--This cyclone furnace technology is
designed to decontaminate wastes containing both organic and metal contaminants. The cyclone
furnace retains heavy metals in a non-leachable slag and vaporizes organic materials prior to incinerating
them.
The treated soils resemble natural obsidian (volcanic glass), similar to the final product of
vitrification.
This technology is applicable to solids and soil contaminated with organic compounds and
metals. Babcock and Wilcox are developing this process under the SITE Emerging Technologies
Program.
5.3.3 Contaminated Medium: Groundwater-
Treatments using precipitation/flocculation/sedimentation and ion exchange are often consid-
ered for remediation of lead battery recycling sites.
Groundwater contamination at lead battery recycling sites is primarily caused by lead and other
heavy metals such as cadmium, chromium, arsenic, and antimony. Very often the levels of these
contaminants are below detection limits. Lead contamination above 15 /Kj/L in groundwater is
considered a health threat. Groundwater treatments such as precipitation/flocculation/sedimentation,
ion exchange, and ion medium filtration have been recommended in RODs and RI/FSs. Ion medium
filtration, referred to as the "metal grabber" process, is based on passing metal-contaminated water
through a medium that selectively binds cations. Unlike an ion exchange bed, the unit is a disposable
canister containing a granular solid medium instead of a regenerate resin. Ion medium filtration is still
in pilot-scale development (Woodward-Clyde Consultants, 1988); therefore, it will not be further
discussed as an available remedy.
Contaminated water from pits, ponds, and lagoons is typically pumped and treated together with
groundwater.
Contaminated groundwater can be treated on-site and then discharged either to a publicly
owned treatment works (POTW), to a surface water body, or into the ground. Some active lead battery
recycling sites may have on-site industrial wastewater treatment systems that can receive groundwater.
A NPDES permit would be required for surface water discharge. Table 21 summarizes EPA evaluation
criteria of remedial alternatives for groundwater.
5.3.3.1 Precipitation/Flocculation/Sedimentation-
The combination of precipitation/flocculation/sedimentation is a well-established technology with
specific operating parameters for metals removal from groundwater. This technology pumps ground-
water through extraction wells and then treats it to precipitate lead and other heavy metals. Typical
removal of metals employs precipitation with hydroxides, carbonates, or sulfides. Hydroxide precipita-
tion with lime is the most common choice. Generally lime, soda ash, or sodium sulfide is added to
water in a rapid-mixing tank along with flocculating agents such as alum, lime, and various iron salts.
This mixture then flows to a flocculation chamber that agglomerates particles, which are then separated
from the liquid phase in a sedimentation chamber. Other physical processes, such as filtration, may
64
-------
TABLE 21. SUMMARY OF EPA EVALUATION CRITERIA OF REMEDIAL
TECHNOLOGIES FOR GROUNDWATER
Remedial
technology
No action
Treatment using
precipitation/
flocculation/
sedimentation
Treatment using ion
exchange
Compliance
with
ARARs
Does not comply with HCRA
clean closure or landfill closure
requirements [40 CFR Part 264,
Subpart G].
Complies with chemical-specif-
ic and action-specific ARARs
On-site surface water discharge
must comply with the NPDES
regulations.
Remjection of treated water
Into the ground must comply
with Federal MCL or applicable
state laws.
Complies with chemical-specrf-
Ic and action-specific ARARs
On-site surface water discharge
must comply with the NPDES
regulations.
Reinfection of treated water
into the ground must comply
with Federal MCL or applicable
state laws.
Long-term
effectiveness
and
permanence
Contaminants would continue
to migrate off-site and down-
ward through subsurface soil.
Groundwater monitoring
would determine degree of
contaminant leaching and
provide a warning mechanism.
No long-term human health or
environmental risks would be
associated with the site.
No long-term human health or
environmental risks would be
associated with the site.
Reduction of
toxictty, mobility,
or volume
Does not reduce toxlclty,
mobility, or volume of
contamination in the
groundwater.
Permanently reduces
toxiclty and volume of
contaminants.
Permanently reduces
toxicity and volume of
contaminants.
Short-term
effectiveness
No remedial action in-
volved, so protection of
workers, community, and
environment during
remediation activities Is
not a consideration.
Minimal protection of pub-
lic health from exposure to
on-srte groundwater.
Dust may be generated
during excavation and
handling activities.
Respiratory protection,
fugitive dust control pro-
cedures, and air monitor-
ing may be required to
protect workers and com-
munity
Dust may be generated
during site activities. Re-
spiratory protection, fugi-
tive dust control proce-
dures, and air monitoring
may be required to protect
workers and community.
Implementablltty
No implementaWlity con-
siderations.
Would not Interfere with
future remedial actions.
Technologies are well
demonstrated and com-
mercially available.
Would not Interfere with
future remedial actions at
•He.
Technologies are well
demonstrated and com-
mercially available.
Would not Interfere with
future remedial actions at
site.
Cost
No capital costs.
There will be costs
associated with
sampling and
analysis.
Equipment rental
ranges from
$5,492 to
$27,462/month"
depending on the
flow rate.
(USEPA, 1986b)
Ion exchange sys-
tem servicing a
flow of 50 gpm
required an Initial
capital Investment
of $81 ,650" and
an annual opera-
tion and mainte-
nance cost of
115,850° (USEPA,
1986b).
"Updated to 1990 using cost indexes in Engineering News Record.
-------
follow. Metal sulfides exhibit significantly lower solubility than their hydroxide counterparts, achieve more
complete precipitation, and provide stability over a broad pH range (Figure 4). At a pH of 4.5, sulfide
precipitation can achieve the EPA-recommended standard for potable water (i.e., 15 Mg/L). Sulfide
precipitation -- often effective - can be considerably more expensive than hydroxide precipitation, due to
higher chemical costs and increased process complexity. The precipitated solids would then be handled
in a manner similar to contaminated soils. The supernatant would be discharged to a nearby stream or
to a POTW.
Selection of the most suitable precipitate or flocculant, optimum pH, rapid mix requirements, and
most efficient dosages is determined through laboratory jar test studies.
Groundwater pumping and treatment would require a longer time span - depending on the
surface area of the contaminated aquifer, its porosity, and its hydraulic conductivity. Models can
estimate the time required to restore the water in a contaminated aquifer to a desired cleanup level for a
given chemical (USEPA, 1990g). At Western Processing in Kent, Washington, a feasibility study
concluded that the pumping and treating process would take up to 120 years (CH2M Hill, 1985); at the
Sapp Battery Site, Florida, it would take only 7 years (Ecology and Environment, 1987).
Advantages:
o Treatment of contaminated groundwater is achieved.
o Technologies are well established.
o Operating parameters have been defined.
o Equipment is readily available and easy to operate.
o This process can be easily integrated into more complex treatment systems.
Disadvantages:
o Sludge must be sent for proper disposal.
o This technology requires a relatively longer time period.
Problems and Concerns:
o Sludge residues may be hazardous; they may require further treatment before disposal.
5.3.3.2 Ion Exchange-
Ion exchange is a process whereby the toxic ions are removed from the aqueous phase in an
exchange with relatively harmless ions held by the ion exchange material. Modern ion exchange resins
consist of synthetic organic materials containing ionic functional groups to which exchangeable ions are
attached. These synthetic resins are structurally stable and exhibit a high exchange capacity. They can
be tailored to show selectivity towards specific ions. The exchange reaction is reversible and concentra-
tion-dependent; the exchange resins are regenerable for reuse. All metallic elements - when present as
soluble species, either anionic or cationic ~ can be removed by ion exchange.
A practical upper concentration limit for ion exchange is about 2,500 to 4,000 mg/L A higher
66
-------
Concentration of Dissolved Metal (mg/l)
p
ro
o
o
o
d>
o
i.
o>
CO
o
I
CD
CO
i
S co
JB_ O.
-i IT
§ =
j?
I
S
a
a>
(O
(D
CO
-------
concentration results in rapid exhaustibn of the resin and inordinately high regeneration costs.
Suspended solids in the feed stream should contain less than 50 mg/L to prevent plugging the resins.
Specific ion exchange systems must be designed on a case-by-case basis (USEPA, I986b).
Advantages:
o Technologies are well established.
o Ion exchange systems are commercially available.
o Units are relatively compact and not energy intensive.
Disadvantages:
o Technology requires a skilled operator.
Problems and Concerns:
o Solution used to regenerate contaminated exchange resins must be sent for proper
disposal via posttreatment.
o Regenerating chemical must be compatible with the waste being
treated.
o Resins must be regenerated.
o Spent resin containing contaminant (e.g., lead) requires RCRA
disposal.
5.3.3.3 Other Innovative Processes-
The Bio-Recovery Systems, Inc. Biological Sorption Process--Bio-Recovery Systems, Inc. in
Las Cruces, New Mexico is testing AlgaSORBR, a new technology for the removal and recovery of heavy
metal ions from groundwater. This biological sorption process is based on the affinity of algae cell walls
for heavy metal ions. This technology is being tested for the removal of metal ions that are "hard" or
contain high levels of dissolved solids from groundwater or surface leachates. This process can remove
heavy metals including lead. This process is being developed under the SITE Emerging Technologies
Program.
Colorado School of Mines' Wetlands-Based Treatment-This wetlands-based treatment uses
natural biological and geochemical processes inherent in man-made wetlands to accumulate and
remove metals from contaminated water. The treatment system incorporates principal ecosystem
components from wetlands, such as organic soils, microbial fauna, algae, and vascular plants.
Waters contaminated with high metal concentrations and have a low pH flow through the
aerobic and anaerobic zones of the wetland ecosystem. The metals can be removed by filtration, ion
exchange, adsorption, absorption, and precipitation through geochemical and microbial oxidation and
reduction.
68
-------
The Colorado School of Mines has entered this process in the SITE Emerging Technologies
Program.
5.3.4 Contaminated Medium: Waste Piles
Waste pile removal and off-site disposal have been practiced in the past but probably will not
continue due to Land Disposal Restrictions (LDRs), unless the materials are treated prior to disposal.
Recycling of waste piles, in particular the process developed by Canonie Environmental and
sponsored by NL Industries for the Gould Site shows promise. However, it still remains to be proven in
a field-scale unit.
Waste piles at lead battery recycling sites are usually by-products from recycling operations.
These waste piles can be broken down into several components: battery casings (made of hard rubber,
ebonite, or polypropylene), battery internal components, matte (a metallic sulfide waste containing iron
and lead), slag, and contaminated debris (see Appendix B). They are contaminated with lead and other
heavy metals such as cadmium, chromium, antimony, and arsenic.
Four alternatives are considered as treatments in presently available RODs and RI/FSs: no
action, washing, recycling, and removal for off-site disposal. Recycling separates the primary source
materials into lead fines, plastics, ebonite, and sludge. Lead fines are potentially marketable. Plastic can
be recycled; battery case manufacturers already use this product. Although ebonite has no current
market, it has been previously used in other applications such as in fence posts, oil-drilling liquids,
asphalt aggregate, and lead smelter fuel. The possibility of using ebonite from the Gould Site as fuel for
cement kilns or coal-burning power plants is currently being assessed. A lead smelter can be used to
recover lead from sludge. Smelter feed requires lead content of at least 27%. Appendix F lists the
primary and secondary lead smelters in the U.S. Table 22 summarizes EPA evaluation criteria of
remedial technologies for waste piles.
5.3.4.1 Waste Pile Removal and Off-Site Disposal-
The combination of waste pile removal and off-site disposal encompasses excavation, removal,
transportation, and disposal off-site -- in a RCRA-compliant landfill. The RCRA-compliant landfill must
meet all regulatory requirements for isolation of contaminated materials from the environment through
the use of impervious liners, clays, and other RCRA design features. Landfilling of hazardous materials
is becoming increasingly difficult and expensive due to growing regulatory control. LDRs now require
treatment of waste to reduce lead in TCLP leachate below 5 mg/L (or to the level prescribed in a
treatability variance) prior to disposal. The technologies proposed for excavation and off-site disposal
have been demonstrated; they are commercially available. Excavation and removal can totally eliminate
both contamination at a site and the need for long-term monitoring.
Advantages:
o This remedy eliminates the contamination at the site.
o There is no need for long-term monitoring.
o Treatment can be used in combination with other remedial
technologies.
69
-------
TABLE 22. SUMMARY OF EPA EVALUATION CRITERIA OF REMEDIAL TECHNOLOGIES FOR WASTE PILES
Remedial
technology
Removal and off-site
disposal
Recycling
Compliance
with
ARARs
Must comply with NAAQ stan-
dards for lead and paniculate
matter.
Worker protection during on-site
activities must comply with
.OSHA health and safety require-
ments.
Must comply with RCRA closure
requirements under 40 CFR Part
264, Subpart G.
Off-site disposal must comply
with LDRs (40 CFR Part 268).
Off-site transportation must
comply with the following:
o RCRA hazardous waste
generator and trans-
portation regulations.
o Federal and stale DOT
transportation regula-
tions
The disposal facilities must
comply with RCRA and state
regulations for disposal.
Must comply with NAAQ stan-
dards for lead and paniculate
matter.
Worker protection during on-site
activities must comply with
OSHA health and safety require-
ments.
On-site treatment must comply
with RCRA and state operating
regulations.
Off-site disposal must comply
with LDRs (40 CFR Part 268).
Long-term
effectiveness
and
permanence
No long-term human
health or environmental
risk would be associated
with the site.
No long-term human or
environmental risks would
be associated with site If
successful.
Reduction of
toxicKy, mobility,
or volume
Does not reduce toxicrty or
volume of contamination in
the waste piles.
The contaminant that Is recov-
ered becomes a product. The
reduction of toxicrty, mobility,
and volume of remaining
waste may or may not be
significant depending on the
extent of the recycling opera-
tions.
Short-term
effectiveness
Dust may be generated
during excavation and
handling activities. Re-
spiratory protection, fugi-
tive dust control proce-
dures, and air monitoring
may be required to protect
workers and community.
Dust may be generated
during removal and han-
dling activities. Respira-
tory protection, fugitive
dust control procedures,
and air monitoring may be
required to protect workers
and community.
Implementabiltty
Technologies are demon-
strated and commercially
available.
Land disposal restrictions
apply.
Would not Interfere with
future remedial actions at
site.
Processes available for
battery casing fragments
have not been shown
practicable for ebonite
casings.
Cost
$287-488 cu yd0
(1982) (Environmen-
tal Law Institute,
1S84).
No Information avail-
able.
-------
TABLE 22. (continued)
Compliance
,. Jaja
Wlul
ARAR*
Off-site transportation must
comply wHh tho following:
o RCRA hazardous waste
generator and trans-
portation regulations.
o Federal and stale DOT
transportation regula-
tions.
The disposal facilities must
comply with RCRA and state
regulations for disposal.
Long-term
effectiveness
and
permanence
Reduction of
toxtetty, mobilty,
orvohme
Short-term
offocynoneii
ImpkHnentabillty
Cost
"Updated to 1990 using cost indexes In Engineering News Record.
-------
Disadvantages:
o Costs associated with RCRA off-site disposal are high.
o Fugitive dust control may be expensive.
Problems and Concerns:
o The location of the RCRA-compliant landfill, to which the contents of waste piles would
be transported, has a substantial impact on cost.
o LDRs may affect the implementability.
5.3.4.2 Recycling of Battery Casings-
This alternative comprises excavation of the waste piles, followed by on-site separation of battery
casing fragments. Separation is followed by recycling (possibly off-site) of those components that can
be recycled, RCRA off-site disposal of hazardous non-recyclable components, and on-site disposal of
nonhazardous components. During recycling the mixed primary source materials are separated into
components of lead fines, plastic, and ebonite.
Waste Pile Washing via BOM Process-This technology, developed by the Bureau of Mines, is
similar to acid leaching of soil but somewhat less complicated. However, it is unproven and requires
testing to determine its feasibility. In this process, battery casings are washed with a leaching agent
such as nitric acid to remove lead. Bench-scale treatability studies shown in Table 16, performed on
battery casings at the C&R Lead Battery Site, showed good removal efficiencies. Samples of residual
battery casing materials, after leaching, had an EP Toxicity lead concentration of less than 5 mg/L
(Schmidt, 1989 and NUS, 1990).
Figure 5 shows the U.S. Bureau of Mines process. The waste pile is first screened and washed.
The sludge washed from the plastic/ebonite casings is recovered as a by-product. The casings are then
subjected to a carbonation step, followed by granulation, and recovery of the metallic lead particles.
The casings are then subjected to a nitric acid leach, followed by the addition of sulfuric acid to
precipitate the lead in solution as lead sulfate, which is sold as a by-product. The cleaned plastic casing
chips can be sold to a plastic manufacturer for recycling.
Bench- and pilot-scale treatability studies must be conducted to determine the feasibility of this
technology.
Advantages:
o Usable by-products (lead and plastic) may be recovered.
Disadvantages:
o Pilot- and full-scale treatment is unproven.
Problems and Concerns:
o Laboratory and pilot-scale testing are necessary to determine technical/economic
feasibility.
72
-------
FEED
SLUDGE
MAKEUP UNO,
-•f ACID
WASH
RINSE
RINSE
WASTE
PREC1PTATION
RINSE
SLUDGE
Source: Schmidt, 1989
Figure 5. Bureau of Mines battery casing washing process.
»- GYPSUM
73
-------
o Effluents from washing systems require post-treatment and/or RCRA disposal.
Canonie Recycling Process-Canonic Environmental Services Corp. under contract to NL
Industries, Inc. has developed a proprietary process for remediating lead battery and smelting wastes at
the Gould Site in Portland, Oregon (Canonie Environmental, undated). The process uses a liberation
and separation approach to separate the waste materials into recyclable and nonrecyclable products.
The process operates principally with water; it does not import toxic chemicals to the site. The
recyclable products consist of:
o Materials with a lead content sufficiently high for recycling, and
o Cleaned materials such as plastic and ebonite that will pass the EP Toxicity test for lead.
o The materials that cannot be cleaned to pass the EP Toxicity test for lead and do not
contain sufficient lead for recycling are considered "nonrecyclable".
The process is shown schematically in Figure 6. The battery casing is crushed and washed in
the first stage. The fines are screened from the washed material, the solids are separated from the water
in a settling tank, and the settled pulp is filtered from the solution. These materials are the filter cake
that will typically contain more than 40% lead and less than 30% moisture.
Following the first wash, the screen oversize is fed to a gravity separation device. This system
separates the plastic and ebonite in the waste from furnace products, rocks, and trash excavated with
the waste. The trash products are collected and stabilized for on-site disposal or off-site disposal in a
Class I landfill.
The ebonite and plastic material passes to the second wash stage where the residual amounts
of lead contamination are removed. The second wash is specifically designed to clean these materials
so that they will pass the EP Toxicity test for lead. The cleaned material will typically contain between
100 and 500 ppm total lead.
Performance at the Gould Site-The Gould site contains approximately 117,500 tons of waste.
Canonie claims that its process there could produce approximately 80,500 tons of recyclable materials
and 37,000 tons of material for stabilization and subsequent on-site disposal. At other sites, the amount
of recyclable material may vary according to site history and use (Canonie Environmental, undated).
Advantages:
o Process operates principally with water; it does not bring toxic chemicals on-site.
o It reduces the quantity of material of hazardous waste that must be sent for disposal.
o It can obtain from the waste a product with a higher economic value than the waste.
Disadvantages:
o Wastes must be properly disposed.
o Effluent from washing systems requires further treatment before discharge.
74
-------
BATTERY CASINGS
1— •
' WASH STATION
NO. 1
UQUID/SOLID
SEPARATOR
WATER TO
RECYCLE OR
DISCHARGE
FILTER
LEAD FINES
TO RECYCLE
WATER TO
RECYCLE OR
DISCHARGE
CLEAN PLASTIC
TO RECYCLE
CLEAN HARD
RUBBER TO
RECYCLE
Source: Canonie Environmental
Figure 6. Battery waste treatment process.
-------
Problems and Concerns:
o The technology is still developmental.
o The market for clean ebonite should be confirmed.
Commercial Recycling Operations--PEI conducted a study for USEPA to evaluate commercial
recycling as a remedial alternative for battery casing contamination at the Gould site in Portland,
Oregon. It identified seven companies with recycling capabilities (Area Engineering, DeLatte Metals,
Engitec Impianti, Galena Industries, Interstate Lead Co., M.A. Industries, and Poly-Cycle Industries).
Table 23 lists the companies and summarizes pertinent data about their six processes, such as the wash
solutions and the final lead content of the recycled ebonite. Area Engineering and Galena Industries use
the Cal West equipment. None of the seven companies, with the possible exception of those using the
Cal West equipment, were reported to have successfully separated a waste battery pile and produced an
ebonite product that meets the EP Toxicity standard for lead. Cleaning battery wastes from a Superfund
site is difficult for the following reasons:
o The presence of rock and slag that must be removed to avoid damaging the process
equipment.
o The presence of soil, which presents two problems: foaming, and degradation of the
lead oxide product. The soil usually remains with similarly-sized lead oxide particles.
Foaming can be prevented by adding appropriate chemicals.
o Lead oxide may be more firmly embedded in the ebonite by lengthy storage in the
ground, making these two components very difficult to separate.
More information can be obtained from Survey of Commercial Battery Recyclers, A Draft Report
(PEI Associates, Inc., 1988).
5.3.4.3 Other Innovative Processes-
The Horsehead Resource Development Co., Inc. Flame Reactor Process-The Horsehead
flame reactor process is a patented, hydrocarbon-fueled, flash smelting system that treats residues and
wastes containing metals. The reactor processes wastes with a very hot reducing gas >2000°C
produced from the combustion of solid or gaseous hydrocarbon fuels in oxygen-enriched air. In a
compact, low cost reactor, the feed materials react rapidly, allowing a high waste throughput. The end
products are a non-leachable slag (glass-like when cooled) and a recyclable heavy metal-enriched oxide,
which may be marketable. The volume reduction achieved by the process depends on the chemical
and physical properties of the waste.
Electric arc furnace dust, lead blast furnace slag, iron residues, zinc plant leach residues,
purification residues, brass mill dusts, and brass mill fumes have been successfully tested. Metal-bearing
wastes have also been treated; zinc (up to 40% removal), lead (up to 10%), cadmium (up to 3%),
chromium (up to 3%). Other waste feeds contained copper, cobalt, nickel, and arsenic. A SITE
demonstration has been scheduled at the Monaca facility in Pennsylvania. It has not been widely tested
for use at Superfund site cleanups.
The Risk Reduction Engineering Laboratory (RREL) Debris Washing System-Developed by
RREL staff and IT Environmental Programs, Inc. (formerly PEI Associates, Inc.), this technology will
decontaminate debris found at Superfund sites throughout the country. The debris washing system has
76
-------
TABLE 23. SUMMARY OF COMMERCIAL LEAD BATTERY RECYCLING OPERATIONS OFFERED BY SEVEN COMPANIES
Process
conditions
Screening for rodts
Wash solutions used
Separation process
Final ebonite particle size
Final lead concentration in
ebonite
Final EP Toxicity of ebonite
Process modification
Installations
Area
Engineering
Manual
Detergents, proprietary ingredients,
kad-loc
Cal West separator (heavy media)
i/2- to r
100 ppm
Sppm
None
Socorro, NM
Hermosa Beach, CA
Delatte
Metals
Manual
Water
Wet classification
Unknown
Unknown
Unknown"
Unknown
Pontachatoula,
LA
Milan, Italy
Engitec
Impianti
None
Water
Hydrodynamic sepa-
rator
Unknown
Unknown
Unknown6
Add hydrodynamic
separator
Toronto, Canada
Granite City, IL
Galena
Industries
Manual
Detergent, propri-
etary ingredients,
lead-loc
Cal West separator
(heavy media)
Detergent, propri-
etary ingredients,
lead-loc
1/2- to 1-
50 ppm
Unknown*
None
Socorro, NM
Interstate
Lead Co.
Manual
Acid, detergent
Specific- gravity
separator
3/8" to 1/2"
Unknown
<1 ppm
Add extra convey-
or and hopper
Leeds, AL
M.A.
Industries
Manual
Water, detergent
Rising current
separator, flota-
tion
Unknown
5,000 ppm
Unknown"
Add anti-foaming
chemicals
Unknown
Poly-Cycle
Industries
Manual
Water
Flotation air sepa-
rators
r
296.8 ppm
Unknown*
Modify wash sys-
tems
Jacksonville, IX
^Company claims ebonite fails EP Toxicity for lead.
Company claims ebonite passes EP Toxicity for lead.
Source: PEI Associates, Inc, 1988
-------
been demonstrated and will be commercially developed by IT Environmental Programs, Inc. The DWS
can clean various types of debris (e.g., metallic, masonry, or other solids) that are contaminated with
hazardous chemicals such as pesticides, PCBs, lead, and other metals. This process is being evaluated
by EPA in the SITE Program. Bench-scale studies conducted on six pieces of debris including plastic
spiked with DDT, lindane, PCB and lead sulfate, then washed using surfactant achieved an overall
percentage reduction of lead greater than 98%. This technology has potential application to battery
casings and other metallic and masonary debris found at lead battery recycling sites.
5.3.5 Contaminated Medium: Buildings. Structures, and Equipment
Contamination of buildings, structures, and equipment Is caused primarily by spillage, storage of
the hazardous materials in and around lead battery recycling facilities, and fugitive dust. The common
remediation technologies are demolition and decontamination. Twenty-one decontamination methodolo-
gies, Including both traditional and developing techniques, are described In Guide for Decontaminating
Buildings, Structures, and Equipment at Superfund Sites (USEPA, 1985a). This reference provides the
guidance for site cleanup personnel in decontaminating buildings, structures, and equipment. Demoli-
tion and detergent or solvent washing have been proposed in RI/FSs and RODs for lead battery
recycling sites. None have yet recommended detergent or solvent washing. More often, buildings are
demolished and the rubble is sent off-site to landfills. Table 24 summarizes the EPA evaluation criteria of
treatment technologies for buildings, structures, and equipment.
5.3.6 Contaminated Medium: Pits. Ponds. Laooons. and Surface Water
Pits, ponds, lagoons, and surface water typically contain sulfurlc acid,lead, and other metals.
Contaminated water may be pumped into the system, neutralized with caustic soda or lime, and treated
together with groundwater. However, it may be advantageous to treat them separately -- depending on
their composition. Contaminated sediments would be dredged mechanically, dewatered, and treated
together with contaminated soil.
In order to minimize surface water and run-off from the site as pathways of contaminant
migration, drainage control measures have been recommended in RI/FSs and RODs for lead battery
recycling sites. Such measures include grading, revegetation, the construction of storm sewers, and the
addition of drainage ditches.
78
-------
TABLE 24. SUMMARY OF EPA EVALUATION CRITERIA OF REMEDIAL TECHNOLOGIES
FOR BUILDINGS, STRUCTURES, AND EQUIPMENT
Remedial
technology
Demolition
Decontamination
Compliance
...ill,
Wllfl
ARARs
Mint comply with NAAQ stan-
dards lor toad and paniculate
matter.
Worker protection during on-site
activities must comply with OSHA
health and safety requirements.
Off -site transportation must com-
ply with the following:
o RCRA hazardous waste
generator and trans-
portation regulations.
o Federal and state DOT
transportation regula-
tions.
The disposal facilities must com-
ply with RCRA and state regula-
tions for disposal.
Must comply with NAAQ stan-
dards for lead and particulate
matter.
Workers protection during on-site
activities must comply with OSHA
health and safety requirements.
Long-term
effectiveness
and
permanence
No long-term human health
or environmental risks
would be associated with
the site.
No long-term human health
or environmental risks
would be associated If all
the contaminants are
removed.
Reduction of
toxtetty, mobility,
or volume
Does not reduce toxfcHy or
volume of contamination.
Mobility b reduced by dispos-
al In a RCRA landfill.
Reduces the overall volume of
the contaminated buildings.
Reduces the toxlcity of the
buildings by removing the
contaminants.
Short-term
effectiveness
Dust may be generated dur-
ing excavation and handling
activities. Respiratory protec-
tion, fugitive dust control
procedures, and air monitor-
Ing may be required to pro-
tect workers and community.
Dust may be generated dur-
ing decontamination activi-
ties.
Respiratory protection may
be required to protect work-
ers.
Imptomentabiltty
Technologies are demon-
strated and commercially
available.
LORs apply.
Action would interfere with
future remedial actions at
site.
Relatively simple to Imple-
ment However. It Is site-
•p0CfnC.
Collection, treatment, and
disposal of decontamina-
tion fluids are the most
difficult concerns of this
tocnnoiOQy.
Cost
S8.96/sq ft" or
(242/cuyd. (USEPA,
1985a).
No information avail-
able.
"Updated to 1990 using cost Indexes in Engineering News Record.
-------
REFERENCES
Arniella, E. F. and L J. Blythe. 1990. Solidifying Traps. Chemical Engineering, pp. 92-102.
Adiano, D. C. 1986. Trace Elements in the Terrestrial Environment. Springer-Verlag, New York.
Barth, E. F. and R. P. Traver. 1990. Treatment of Lead Battery Contaminated Soil Utilizing Soil Washing
and Solidification/Stabilization Technology. Proceedings of the 1990 EPA/A&WMA International
Symposium, Hazardous Waste Treatment: Treatment of Contaminated Soils, Cincinnati, Ohio.
Barth, E. F., and R. Soundararajan. 1990. Solidification/Stabilization Treatment of Lead Battery Site
Soils. Superfund '90 - Proceedings of the 11th Annual National Conference, The Hazardous
Materials Control Research Institute, Washington, DC. pp. 665-667.
Black and Vetch. Undated. Draft. Remedial Investigation Report for Brown's Battery Breaking Site,
Shoemakersville, Pennsylvania.
Butler, J. R. 1954. Journal of Soil Science. 5:156-166.
COM Federal Programs Corporation. Undated. Draft Annotated Technical Reference for Hazardous
Waste Sites Prepared for Environmental Protection Agency, OWPE Compliance Branch.
Canonie Environmental. Undated. Report on Stabilization Design Study for Gould Site in
Portland, Oregon.
Canonie Environmental. Undated. Information Sheet on Process for Remediating Lead Battery Sites.
COM Federal Programs Corporation. 1988. Remedial Investigation/Feasibility Study Report for United
Scrap Lead Site, Troy, Ohio.
Center for Disease Control. 1985. Preventing Lead Poisoning in Young Children. U.S. Department of
Health and Human Services, Cincinnati, Ohio.
CH2M Hill and Ecology and Environment, Inc. 1985. Feasibility Study Report for Western Processing,
Kent, Washington.
CH2M Hill. 1986. Remedial Investigation/Feasibility Study Report for Arcanum Iron and Metal Site,
Arcanum, Ohio.
Dames and Moore. 1988. Remedial Investigation/Feasibility Study Report for Gould Battery, Inc. Site,
Portland, Oregon.
EBASCO Services, Inc. 1990. Remedial Investigation/Feasibility Study Report for Bypass 601
Groundwater Contamination Site - Martin Scrap Recycling Facility, Concord, North Carolina.
Ecology and Environment, Inc. 1989. Remedial Investigation/Feasibility Study Report for Sapp Battery
Site, Jackson County, Florida.
80
-------
Ecology and Environment, Inc. 1989. Final On-Scene Coordinator's Report for Alaska Battery
Enterprises, Fairbanks, Alaska.
Environmental Law Institute. 1984. Compendium of Cost of Remedial Technologies at Hazardous Waste
Sites. Draft Report Prepared to the United States Environmental Protection Agency Office of
Emergency and Remedial Response, Washington, DC.
ERM-South, Inc. 1987. Remedial Investigation/Feasibility Study Report for 58th Street Landfill Site,
Tampa, Florida.
Farrah, H. and W. F. Pickering. 1977. Australian Journal of Chemistry. 30:1417-1422.
Federal Register. 1988. 40 CFR Parts 141 and 142. Drinking Water Regulations, Maximum Contaminant
Level Goals and National Primary Drinking Water Regulations for Lead and Copper; Proposed Rule.
United States Environmental Protection Agency, Washington, DC. pp. 31516-31578.
Federal Register. 1990. 40 CFR Part 148 et al. Land Disposal Restrictions for Third Third Scheduled
Wastes; Rule. United States Environmental Protection Agency, Washington, DC. pp. 22567-22660.
Gambrell, R. P, R. A. Khalid, and W. H. Patrick, Jr. 1980. Environmental Science and Technology.
4:431-436.
Ghassemi, M., K. Yu., and S. Quinlivan. 1981. Feasibility of Commercialized Water Treatment
Techniques for Concentrated Water Spills. Prepared for U.S. Environmental Protection Agency,
Municipal Research Laboratory, Cincinnati, Ohio.
Hill, D. W., and J. D. Allison. 1989. Application of Metals Speciation Modeling to Superfund Sites in EPA
Region IV. Presented at the Workshop on Metal Speciation and Transport in Groundwaters, Jekyll
Island, Georgia.
Isherwood, R. J., et al. 1988. U.S. Bureau of Mines. Open File. Report No. 55-88.
Misra, S. G., and G. Pandley. 1976. Plant Soil. 45:693-696.
National Institute for Occupational Safety and Health (NIOSH). 1982. Demonstration of Control
Technology for Secondary Lead Reprocessing. Volume 1.
NUS Corporation. 1988. Remedial Investigation/Feasibility Study Report for Hebelka Auto Salvage
Yard, Lehigh County, Pennsylvania.
NUS Corporation. 1990. Remedial Investigation/Feasibility Study for C&R Battery Site, Chesterfield
County, Virginia.
PEI Associates, Inc. Undated. Lead Battery Site Treatability Studies. Contract No.68-03-3413.
Submitted to Risk Reduction Engineering Laboratory, Edison, New Jersey.
PEI Associates, Inc. 1988. Technical Assistance to USEPA Region 10 for the Gould Superfund Site,
Portland, Oregon - Survey of Commercial Battery Recyclers. Draft Report. Contract No. 86-03-3419.
Work Assignment #19. Submitted to Hazardous Waste Engineering Research Laboratory,
Cincinnati, Ohio.
81
-------
Roy F. Weston, Inc. 1990. Soil Sampling at Brown's Battery Breaking Site, Tilden Township,
Pennsylvania.
Schmidt, B. William. 1989. Assessment of Treatment Techniques at Superfund Battery Sites.
International Symposium on Hazardous Waste Treatment: Treatment of Contaminated Soils,
Cincinnati, Ohio.
Smith, R. Craig and Daley R. Michael. 1987. Domestic Secondary Lead Industrial Production and
Regulatory Compliance Costs. 1C 9156. United States Department of the Interior, Washington, DC.
Tetta, A. David. 1989. Recycling of Battery Casings at a Superfund Site. Superfund '89 - Proceedings
of the 10th National Conference, The Hazardous Materials Control Research Institute, Washington,
DC. pp. 301-305.
U.S. Bureau of Mines Treatability Study. 1989. Treatment of Lead Battery Sites. RMIS No. 731. April
Summary Report.
USEPA. 1980. Test Methods for Evaluating Solid Waste - Physical/Chemical Methods SW-846.
U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, Washington,
DC.
USEPA. 1982. Guide to Disposal of Chemically Stabilized and Solidified Waste. SW-872.
U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, Washington,
DC.
USEPA. 1984. Sampling and Analysis Methods for Hazardous Waste Combustion. EPA/600/8-84/002.
U.S. Environmental Protection Agency Office of Research and Development, Washington, DC.
USEPA. 1985a. Guide for Decontaminating Buildings, Structures, and Equipment at Superfund Sites.
EPA/600/2-85/028. Hazardous Waste Engineering Research Laboratory, Cincinnati, Ohio.
USEPA. 1985b. Handbook, Remedial Action at Waste Disposal Sites (Revised). EPA/625/6-85/006.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
USEPA. 1986a. Handbook for Stabilization/Solidification of Hazardous Wastes. EPA/540/2-86/001.
Hazardous Waste Engineering Research Laboratory, Cincinnati, Ohio.
USEPA. 1986b. Mobile Treatment Technologies for Superfund Wastes. EPA/540/2-86/003(f).
U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, Washington,
DC.
USEPA. 1986c. Superfund Treatment Technologies: A Vendor Inventory. EPA/540/2-86/004(f).
U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, Washington,
DC.
USEPA. 1987a. A Compendium of Superfund Field Operations Methods. EPA/540/P-87/001.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
82
-------
USEPA. 1987b. Data Quality Objectives for Remedial Response Activities. EPA/540/G-87/004.
U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, Washington,
DC.
USEPA. 1987c. A Compendium of Technologies Used in the Treatment of Hazardous Wastes.
EPA/625/8-87/014. Center for Environmental Research Information, Office of Research and
Development, Cincinnati, Ohio.
USEPA. 1987d. The Risk Assessment Guidelines of 1986. EPA/600/8-87/045. U.S. Environmental
Protection Agency Office of Health and Environmental Assessment, Washington, DC.
USEPA. 1987e. Technology Briefs: Data Requirements for Selecting Remedial Action Technology.
EPA/600/2-87/001. Hazardous Waste Engineering Research Laboratory, Cincinnati, Ohio.
USEPA. 1988a. Engineering Treatment Forum Technical Assistance Report: Lead Battery Reclamation
Sites. EPA/600/X-88/242. Hazardous Waste Engineering Research Laboratory, Cincinnati, Ohio.
USEPA. 1988b. Project Report: Evaluation of a Prototype Field-Portable X-ray Fluorescence System for
Hazardous Waste Screening. EPA/600/4-87/021. Environmental Monitoring System Laboratory,
Las Vegas, Nevada.
USEPA. 1988c. Guidance for Conducting Remedial Investigations and Feasibility Studies under
CERCLA. EPA/540/G-89/004. U.S. Environmental Protection Agency Office of Emergency and
Remedial Response, Washington, DC.
USEPA. 1988d. CERCLA Compliance with Other Laws Manual. Draft. OSWER Directive 9234.1-01.
U.S. Environmental Protection Agency, Washington, DC.
USEPA. 1988e. Superfund Exposure Assessment Manual. EPA/540/1-88/001. OSWER Directive
9285.5-1. U.S. Environmental Protection Agency Office of Emergency and Remedial Response,
Washington, DC.
USEPA. 1988f. Exposure Factors Handbook. EPA/600/8-89/043. U.S. Environmental Protection
Agency Office of Health and Environmental Assessment, Washington, DC.
USEPA. 1989a. Stabilization/Solidification of CERCLA and RCRA Wastes: Physical Tests, Chemical
Testing Procedures, Technology Screening, and Field Activities. EPA/625/6-89/022. Center for
Environmental Research Information, Cincinnati, Ohio.
USEPA. 1989b. Guide for Conducting Treatability Studies under CERCLA. Interim Final.
EPA/540/2-89/058. U.S. EPA Office of Solid Waste and Emergency Response, Washington, DC.
USEPA. 1989c. Memorandum from Henry L Longest II, Director, Office of Emergency and Remedial
Response to Regional directors, Draft Interim Guidance on Establishing Soil Lead Cleanup Levels at
Superfund Sites. OSWER Directive 9355.4-02. U.S. Environmental Protection Agency Office of
Emergency and Remedial Response, Washington, DC.
USEPA. 1989d. Superfund Treatability Clearinghouse Abstracts. EPA/540/2-89/001.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
83
-------
USEPA. 1989e. Risk Assessment Guidance for Superfund Volume I. Human Health Evaluation Manual
(Part A). Interim Final. EPA/540/1-89/002. U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response, Washington, DC.
USEPA. 1989f. Risk Assessment Guidance for Superfund Volume II. Environmental Evaluation Manual.
Interim Final. EPA/540/1-89/001. U.S. Environmental Protection Agency Office of Solid Waste and
Emergency Response, Washington, DC.
USEPA. 1990a. Memorandum from Henry L Longest, Director, Office of Emergency and Remedial
Response to Patrick M. Tobin, Director, Waste Management Division, Region IV, Cleanup Level for
Lead in Groundwater. U.S. Environmental Protection Agency Office of Emergency and Remedial
Response, Washington, DC.
USEPA. 1990b. Inventory of Treatability Study Vendors. Volume I. EPA/540/2-90/003a.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
USEPA. 1990c. Treatment Technology Bulletin: Soil Washing. Draft. Risk Reduction Engineering
Laboratory, Edison, New Jersey.
USEPA. 1990d. The Superfund Innovative Technology Evaluation Program: Progress and
Accomplishments Fiscal Year 1989. EPA/540/5-90/001. U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response, Washington, DC.
USEPA. 1990e. Handbook on In-Situ Treatment of Hazardous Waste-Contaminated Soil.
EPA/540/2-90/002. Risk Reduction Engineering Laboratory, Cincinnati, Ohio.
USEPA. 1990f. Role of the Baseline Risk Assessment in Superfund Remedy Selection Decisions. Draft.
OSWER Directive 9355.0-30. U.S. Environmental Protection Agency Office of Solid Waste and
Emergency Response, Washington, DC.
USEPA. 1990g. Basics of Pump-and-Treat Groundwater Remediation Technology. EPA/600/8-90/003.
Robert S. Kerr Environmental Research Laboratory, Ada, Oklahoma.
USEPA. 1990h. The Superfund Innovative Technology Evaluation Program: Technology Profiles.
U.S. Environmental Protection Agency Office of Research and Development, Cincinnati, Ohio.
USEPA. 1991. Innovative Treatment Technologies. Quick Reference Fact Sheet. Draft. OSWER
Directive 9380.3-05FS. U.S. Environmental Protection Agency Office of Solid Waste and Emergency
Response, Washington, DC.
U.S. Geological Survey. 1976. Lead in the Environment. Professional Paper No. 957.
Watts, G. B. 1984. The Sapp Battery Site, Jackson County, Florida. Remedial Investigation. Florida
Department of Environmental Regulation, Florida.
Weston-Sper, Technical Assistance Team, Region V. 1988. Engineering Evaluation/Cost Analysis for
Lee Farm Site, Woodville, Wisconsin.
Woodward-Clyde Consultants. 1988. Remedial Investigation/Feasibility Study Report for Schuylkill Metal
Facility, Plant City, Florida.
84
-------
BIBLIOGRAPHY
Basu, T. K., C. Gutterman, and R. Raghavan of Foster Wheeler Enviresponse, Inc. 1989. Draft:
Laboratory Feasibility Study for the Removal of Lead and Other Heavy Metals from Soils, Sludges,
and Sediments at Superfund Sites. Submitted to USEPA. Contract No. 68-03-3255.
Engineering Science. 1989. Work Plan to Conduct Remedial Investigation and Feasibility Study at the
Tonolli Corporation site, Nesquehoning, Pennsylvania.
Freeman, H.M. 1989. Standard Handbook of Hazardous Waste Treatment and Disposal. McGraw-Hill,
New York, NY.
Gutterman, C. and R. Raghavan of Foster Wheeler Envireponse, Inc. 1989. Selective Treatment of Lead
and Other Heavy Metals in Soils, Sludge, and Sediments at Superfund Sites. Submitted to USEPA.
Contract No. 68-03-3255.
Powers, P. W. 1976. How to Dispose of Toxic Substances and Industrial Wastes. Noyes Data, Park
Ridge, New Jersey.
PRC Environmental Management, Inc. 1989. Draft Data Transmittal Memorandum for Phase I Remedial
Investigation at H. Brown Superfund Site, Walker, Michigan.
Record of Decision for Western Processing Company, Inc., King County, Washington. August 1984.
Record of Decision for Western Processing Company, Inc., King County, Washington. September 1985.
Record of Decision for Sapp Battery Site, Jackson County, Florida. September 1986.
Record of Decision for Gould, Inc., Portland, Oregon. March 1988.
Record of Decision for Voortman Farm Site, Lehigh County Pennsylvania. June 1988.
Record of Decision for NL/Taracorp/Golden Auto Park Site, St. Louis, Minnesota. September 1988.
Record of Decision for United Scrap Lead, Troy, Ohio. September 1988.
Record of Decision for Hebelka Auto Salvage Yard, Lehigh County, Pennsylvania. March 1989.
Record of Decision for Reeser's Landfill, Lehigh County, Pennsylvania. March 1989.
Record of Decision for Kassouf-Kimerling Battery Disposal, Hillsborough County, Florida. March 1989.
Record of Decision for Floowood Site, Rankin County, Mississippi. September 1988.
Record of Decision for Union Scrap, Hennepin County, Minnesota. March 1990.
Record of Decision for Arcanum Iron and Metal Site, Drake County, Ohio. Undated and unsigned.
Record of Decision for Kassouf-Kimerling Battery Site, Hillsborough County, Florida. March 1990.
85
-------
Record of Decision for Brown's Battery Breaking Site, Tilden Township. Pennsylvania. September 1990.
Ruggaber, G. J., J. D. Allison, and T. L Allison. 1990. Use of MINTEQA2 and MULTIMED Models to
Evaluate Soil Cleanup Levels at a Lead Battery Superfund Site.
Banning, D. E. 1984. In Situ Treatment. Project A. USEPA, Cincinnati, Ohio.
USEPA. 1979. Characterization of Priority Pollutants from a Secondary Lead and Battery Manufacturing
Facility. EPA/600/2-79/039. U.S. Environmental Protection Agency Industrial Environmental
Research Laboratory, Cincinnati, Ohio.
USEPA. 1979. Lead-Acid Battery Manufacture-Background Information for Proposed Standards.
EPA/450/3-79/028a. Office of Air Quality Planning and Standards, Research Triangle Park, North
Carolina.
USEPA. 1979. Status Assessment of Toxic Chemicals. EPA/600/2-79/21 Oh. U.S. Environmental
Protection Agency Industrial Environmental Research Laboratory, Cincinnati, Ohio.
USEPA. 1980. Interim Guidelines and Specifications for Preparing Quality Assurance Project Plans.
QAMS-005/08.
USEPA. 1980. Industrial Process Profiles for Environmental Use - Chapter 27 - Primary Lead Industry.
EPA/600/2-80/168. U.S. Environmental Protection Agency Industrial Environmental Research
Laboratory, Cincinnati, Ohio.
USEPA. 1980. Overview of Foreign Nonferrous Smelter Technology. EPA/600/2-80/159.
U.S. Environmental Protection Agency Industrial Environmental Research Laboratory, Cincinnati,
Ohio.
USEPA. 1985. Remedial Action Costing Procedures Manual. EPA/540/2-85/503. U.S. Environmental
Protection Agency Hazardous Waste Engineering Research Laboratory, Cincinnati, Ohio.
USEPA. 1985. Modeling Remedial Actions at Uncontrolled Hazardous Waste Sites EPA/540/2-85/001.
U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response, Washington,
DC.
USEPA. 1985. Covers for Uncontrolled Hazardous Waste Sites. EPA/540/2-85/002.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
USEPA. 1985. Handbook: Dust Control at Hazardous Waste Sites. EPA/540/2-88/003.
U.S. Environmental Protection Agency Hazardous Waste Engineering Laboratory, Cincinnati, Ohio.
USEPA. 1986. Superfund Federal Lead Remedial Project Management Handbook. EPA/540/G-87/001.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
USEPA. 1986. Superfund State Lead Remedial Project Management Handbook. EPA/540/G-87/002.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
86
-------
USEPA. 1988. Technology Screening Guide for Treatment of CERCLA Soils and Sludges.
EPA/540/2-88/004. U.S. Environmental Protection Agency Office of Solid Waste and Emergency
Response, Washington, DC.
USEPA. 1988. Superfund Procedures. OSWER Directive 9360.0-03B. U.S. Environmental Protection
Agency Office of Emergency and Remedial Response, Washington, DC.
USEPA. 1988. Superfund Remedial Design and Remedial Action Guidance. OSWER Directive
9355.0-4A. U.S. Environmental Protection Agency Office of Emergency and Remedial Response,
Washington, DC.
USEPA. 1988. Community Relations in Superfund: A Handbook. Interim Version. EPA/540/G-88/002.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
USEPA. 1989. Overview: Soil Washing Technologies for Remediation. Compiled by Francine Everson
and Richard P. Traver.
USEPA. 1989. Superfund LDR Guide #1: Overview of RCRA Land Disposal Restrictions (LDRs).
9347.3-01 FS. U.S. Environmental Protection Agency Office of Solid Waste and Emergency
Response, Washington, DC.
USEPA. 1989. Superfund LDR Guide #2: Complying with the California List Restrictions Under Land
Disposal Restrictions (LDRs). 9347.3-02FS. U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response, Washington, DC.
USEPA. 1989. Superfund LDR Guide #3: Treatment Standards for Minimum Technology Requirements
Under Land Disposal Restrictions (LDRs). 9347.3-03FS. U.S. Environmental Protection Agency
Office of Solid Waste and Emergency Response, Washington, DC.
USEPA. 1989. Superfund LDR Guide #4: Complying with the Hammer Restrictions Under Land
Disposal Restrictions (LDRs). 9347.3-04FS. U.S. Environmental Protection Agency Office of Solid
Waste and Emergency Response, Washington, DC.
USEPA. 1989. Superfund LDR Guide #5: Determining When Land Disposal Restrictions (LDRs) are
Applicable to CERCLA Response Actions. 9347.3-05S. U.S. Environmental Protection Agency Office
of Solid. Waste and Emergency Response, Washington, DC.
USEPA. 1989. Superfund LDR Guide #6A: Obtaining a Soil and Debris Treatability Variance for
Remedial Actions. 9347.3-06FS. U.S. Environmental Protection Agency Office of Solid Waste and
Emergency Response, Washington, DC.
USEPA. 1989. Superfund LDR Guide #7: Determining When Land Disposal Restrictions (LDRs) are
Relevant and Appropriate to CERCLA Response Actions. 9347.3-07S. U.S. Environmental Protection
Agency Office of Solid Waste and Emergency Response, Washington, DC.
USEPA. 1989. Evaluation of Groundwater Extraction Remedies: Volume 1 Summary Report.
EPA/540/2-89/054. U.S. Environmental Protection Agency Office of Emergency and Remedial
Response, Washington, DC.
87
-------
USEPA. 1989. Evaluation of Groundwater Extraction Remedies: Volume 2 Case Studies 1-19. Interim
Final. EPA/540/2-89/054b. U.S. Environmental Protection Agency Office of Emergency and
Remedial Response, Washington, DC.
USEPA. 1989. Evaluation of Groundwater Extraction Remedies: Volume 3 General Site Data -
Database Reports. Interim Final. EPA/540/2-89/054b. U.S. Environmental Protection Agency
Office of Emergency and Remedial Response, Washington, DC.
USEPA. 1989. The Superfund Innovative Technology Evaluation Program: Technology Profiles.
EPA/540/5-89/013. U.S. Environmental Protection Agency Office of Solid Waste and Emergency
Response, Washington, DC.
USEPA. 1990. Physical/Chemical Treatment of Hazardous Wastes: Speaker Slide Copies and
Supporting Information. CERI-90-16. Center for Environmental Research Information, Cincinnati,
Ohio.
USEPA. 1990. Guidance of Expediting Remedial Design and Remedial Action. EPA/540/G-90/006.
U.S. Environmental Protection Agency Office of Emergency and Remedial Response, Washington,
DC.
USEPA. 1990. Emerging Technologies: Bio-Recovery Systems Removal and Recovery of Metal Ions
from Groundwater. EPA/540/5-90.005a. U.S. Environmental Protection Agency Office of Research
and Development, Washington, DC.
88
-------
GLOSSARY
Alloy:
Blast furnace:
Bullion:
Casting:
Charging:
Dross:
Ebonite:
Grid:
Hammer mills:
Lead-acid
battery:
Matte:
Plate:
Polypropylene:
Primary lead
smelter:
Refining:
Reverberatory
furnace:
Rotary furnace:
A substance that is a mixture of two or more metals, or of a metal and
motal
a non-
metal.
A tower-like furnace for separating metal in which a blast of air is forced into the
furnace from below, producing the intense heat needed.
Ingots of metal.
The process of forming (molten metal) into a particular shape by pouring it into
a mold.
The process of loading materials in furnaces for heating or melting.
Metal oxides in or on molten metal.
A hard rubber made by treating crude rubber with a large amount of sulfur and
subjecting it to intense heat.
Metallic plate in a battery storage cell that conducts the electric current and
supports the active material (e.g., lead and lead dioxide).
Pivoted hammers mounted on a horizontal shaft, used for shredding, component
separation, and washing.
A storage device for electrical current that consists of plates (lead dioxide and
lead on metallic lead grids) that are immersed in a sulfuric acid solution within
individual cells, and enclosed in an acid-proof case.
An impure mixture of sulfides that is produced in smelting.
A smooth, flat, relatively thin piece of metal or other materials.
A very light, highly resistant, thermoplastic resin used in packaging.
A system which separates and refines lead from ore using high-temperature
furnace/s.
Reducing material to a pure state, free from impurities, drosses, etc.
A furnace where metal is heated by a flame deflected downward from the roof.
A furnace which gives heat to the crown and maintains heat under the molten
metal so that the metal is heated from below as well as above.
89
-------
Saw-type
breaker:
Secondary lead
smelter:
Slag:
Smelting:
Speiss:
A machine which cuts the top off batteries, thus allowing the acid to drain and
permitting removal of the enclosed lead plates.
A system which recycles new and old scrap using high temperature furnaces.
The fused refuse separated from a metal in the process of smelting.
Melting metallic material to separate impurities from pure metal.
A mixture of metallic arsenides produced during the smelting process.
90
-------
APPENDIX A
BACKGROUND INFORMATION ON LEAD-ACID BATTERIES,
BATTERY BREAKING, SECONDARY LEAD SMELTING OPERATIONS,
AND CHEMISTRY OF LEAD AND OTHER HEAVY METALS AT LEAD BATTERY RECYCLING SITES
A.1 LEAD-ACID STORAGE BATTERY DESCRIPTION
Most people are familiar with the outward appearance of automotive batteries. However, the
RPM for a lead battery recycling site will probably observe various internal and external battery
fragments on site. The RPM will review site operating processes and environmental data that require an
understanding of battery's physical and chemical composition. Thus, the following descriptive
information, drawn predominantly from the Sapp Battery Site Remedial Investigation Report, should be
useful to the RPM.
A lead acid storage battery, the essential construction of which is shown in Figure A-1, consists
of two electrodes dipped into partly diluted sulfuric acid. The positive electrode (cathode) consists of
pure lead dioxide and the negative electrode (anode) is a grid of metallic lead containing various
elemental additives including antimony, arsenic, cadmium, copper, and tin.
The following reactions take place on discharge between the two electrodes dipped into the acid
electrolyte:
Cathode
Pb02(s) + 4H+(aq) + 2e -> Pb2+(aq) + 2H20W
Pb2
(aq)
PbS0
4(s)
Pb02(s) + 4H+(aq)
S042-(aq) + 2e" -> PbS04(s) + 2H20H
91
-------
TERMMAL
POSTS
VENT PLUGS
CONTAINER
COVER
THROUGH THE
PARTrTON
CONNECTORS
POsrrivE
PLATE
(CATHODE)
ENVELOPE
SEPARATORS
NEGATIVE PLATE
(ANODE)
SEDWENT SPACE
Figure A-1. Lead-acid battery construction.
Source: Watts, 1984
92
-------
Anode
Pbw -> Pb2+(aq, + 2e-
Pb2+(aq, + S042M -> PbS04(s)
Pb(s) + S042M -> PbS04(s) + 2e
Overall Reaction
Pbw + Pb02(s) + 4H+(aq) + 2S042-(aq) -> 2PbS04(s) + 2H20W
Electrical energy is generated during the reactions above. To recharge the battery, electric
energy is applied and the reactions are reversed.
The electrodes are isolated by PVC envelope separators (in the case of maintenance-free
batteries) and a fibrous, paper material (in conventional batteries). A standard automotive battery
contains 13 or 15 plates per cell, with six cells in series, each delivering 2 volts.
The primary function of the various elemental additives in the lead anode is to increase anode
hardness. Table A-1 summarizes these additives and their concentrations.
The electrolyte used in a battery is 15-20% sulfuric acid, which has a specific gravity of 1.250, a
pH of 0.8 S.U. and a specific conductivity of > 100,000 jjmhos/cm. Sulfate concentrations range from
130,000 mg/l to 170,000 mg/l. As might be expected, when the sulfuric acid electrolyte is in contact
with the electrodes, a certain amount of dissolution takes place. Table A-2 gives the metals concentra-
tions typically found in battery acid.
An average automotive battery weighs 17.2 kg (38 Ib), and contains 8.6-9.1 kg (19-20 Ib) of lead
(equally divided between anode and cathode), 1.4 kg (3 Ib) of polypropylene plastic, and approximately
2 liters of sulfuric acid. Although most battery cases are now constructed of polypropylene, they were
previously composed primarily of hard rubber material (e.g., ebonite) - styrene-butadiene cross-linked
with sulfur (1%-3%), carbon black or powdered anthracite (30%-50%), and zinc oxide (2%-4%). The
ebonite cases were rigid and brittle, with a nominal 1/4-in thickness (Black and Veatch, undated).
93
-------
TABLE A-1. ELEMENTAL ADDITIVES IN ANODE GRID OF LEAD-ACID STORAGE BATTERY
Element
Concentration range (%)
Purpose
Cadmium
Antimony
Arsenic
Tin
Copper
Calcium/lead alloy
Selenium/lead alloy
0.1 -0.14
21/2-7 1/2
0.15
0.10-0.5
0.05
Grid-hardening agent - no longer used as
an additive.
Grid-hardening agent - high concentra-
tions of antimony tend to poison the
electrolytic process.
Grid-hardening agent - used as substitute
for antimony.
Grid-hardening agent.
Smelting impurity which aids in electrolyt-
ic conductivity.
Prevents hydrogen degassing in mainte-
nance-free batteries.
Prevents hydrogen degassing in mainte-
nance-free batteries.
Source: Watts, 1984
A.2 BATTERY BREAKING AND SECONDARY LEAD SMELTING DESCRIPTION
The lead recovery aspects of lead-acid battery recycling operations consist of battery breaking,
followed by lead smelting and refining, as shown in Figure A-2 (modified from figure in Smith, et al,
1987).
A.2.1 Battery Breaking
Battery breaking is the first step in the lead recycling process. The flow diagram in Figure A-3
depicts the lead-acid battery breaking process. Most breakers are either hammer mills or saw-type
breakers. NIOSH divides battery breaking operations into 7 categories (NIOSH, 1982):
94
-------
TABLE A-2. TYPICAL METALS CONCENTRATIONS IN LEAD-ACID BATTERY ACID
Metal Concentration (mg/l)
Paniculate lead (as lead sulfate >0.45 v. size) 60 - 240
Lead (dissolved) 1 - 6
Arsenic 1 - 6
Antimony 20-175
Zinc 1 -13.5
Tin 1-6
Cadmium 5 - 20
Calcium 20-150
Iron 112
Selenium Analysis not available
Note: With the exception of lead, all analyses are for total metals.
Source: Watts, 1984
(a) Whole battery charging. This technique, developed by the Bergsoe smelter in
Denmark, purposely emphasizes as little battery breaking as possible (only
about 20% of the battery mass need to be broken). The acid is drained from
the battery before charging. "Whole" batteries are mixed with other charge
materials on concrete beds using a rubber-tired front-end loader. After the
charge is prepared, it is loaded into the furnace by front-end loader. Although it
may seem to be a low-level emitting process, emissions and exposures are still
a significant problem. Few smelters in the USA use this approach because of
the large furnace size required and the resultant poor economics.
(b) Battery breaking by shear or saw. Many smelters dismantle batteries in a hand
operation in which employees (1) separate plastic and rubber batteries, (2) cut
the top of the battery off, (3) empty the content of the battery onto a pile.
Typically, front-end loaders then move the battery parts to storage and disposal.
This operation is labor intensive, creates significant emissions during cutting and
handling, and has traditionally been a physically tiring, irritating (acid mist), and
high lead exposure job.
(c) Hammer-mill battery-breaking. In order to speed up the process, remove
employee from exposure, and utilize plastic battery cases for fuel or resale,
many plants use hammer mills to break batteries. Unfortunately, this approach
continues to require hand separation of plastic and rubber cased batteries and
manual handling of rubber-cased batteries. Furthermore, the hammer mill is a
high-energy machine which creates high levels of lead and acid mist emissions.
(d) Rotation-type separators. A number of flotation-type battery-breakers are
currently employed in today's (1982) smelters. The technique uses shears,
95
-------
Excess slag
Rubber/ebonite
Plastic
Excess dross
Market Market
Market
Market
Figure A-2. Generalized secondary lead refining process.
Source: Modified from Smith, et al., 1987
-------
CD
•vj
Batteries
Direct discharge
to environment
Battery breaking
(primarily hammer mill
or saw-type breaker)
Ackj
Collection facility
Plastic, rubber/ebonite
Lead plate,
posts, sludge
Spillage
Rubber/ebonite
Plastic
Disposal
Reuse
-Fuel
- Fill and paving material
• Oil drilling mud
-Other
•*- Disposal
Recycling
- Battery cases
-Other
Secondary lead smelters
Discharge
Acid recycle
Figure A-3. Flow diagram of lead-acid battery breaking.
-------
saws, and/or hammer mills to reduce battery scrap to small pieces. The separator
produces output streams of hard lead (grids and posts), oxide and sulfate sludge,
plastic, and rubber. The advantage of this system are (1) positive control of furnace
feed enables use of more sophisticated furnaces, e.g., rotary, and (2) separate recycling
of plastic case material which, as of December 1981, was selling for 15-17 cents per
pound. Unfortunately, as with other approaches, emissions are significant and expo-
sures are high.
(e) Low-energy shredders. At least five secondary smelters have (or, have had) low
energy shredders installed for breaking batteries. This system uses a low rpm,
low energy shredding device to slowly shred batteries into chargeable or
separable pieces.
(f) Manual battery breaking. At least one battery breaking operation involved the
use of axes to hack the battery casings apart in order to allow acid to drain and
permit access to the lead.
(g) Cracking by dropping. In some operations the batteries are dropped on a hard
surface to crack the case and allow the battery acid to drain.
A.2.3 Secondary Lead Smelting (Smith et al. 1987)
The smelting process separates the metal from impurities in either blast, reverberatory,
or rotary furnaces. It consists of three basic operations:
o Initial burnout, which incinerates combustibles.
o Sweating, which releases lead metal at its low melting point.
o Slagging, which forms a molten lead layer and a layer of oxidized impurities.
When a charge is heated in a furnace, the pure metal portion melts first, leaving the flux
and metallic oxides for conversion to slag.
The blast furnace is used for whole battery scrap. The blast furnace can simultaneously
burn out and sweat the charge, thereby conserving fuel and time. However, it is useful
only for large operations with a high volume of scraps, and it is incapable of producing
lead alloys of different antimony content from the same feed.
A reverberatory furnace can process a finer particle feed, control the antimony content,
and carry out batch operations when the supply of scrap material is limited. The
furnace produces antimony-rich slag (5 to 9%) and low-antimony lead (less than 1%).
98
-------
The rotary furnace has the flexibility to produce a single metal product, like the blast
furnace. Like the reverberatory furnace, it allows the refiner the option of producing low-
antimony lead for further refinement as well as a high- or low-antimonial alloy. However,
rotary furnaces tend to produce more exhaust gas and fumes and require more skillful
operation than the other two furnaces. They are also more labor intensive.
Refining is the final step in chemically purifying recycled lead. It takes place in oven-
topped containers called refining kettles that are constructed of cast iron or steel. The
refining process transforms lead bullion to soft pure lead or alloys. After refining and
alloying, the metal is pumped into casting machines and water-cooled.
A.3 CHEMISTRY OF LEAD AND OTHER HEAVY METALS AT LEAD BATTERY RECYCLING SITES
Overview
The chemistry of elemental lead and lead compounds is very complex. Lead's complexity is
exhibited by the capacity of soils (and associated groundwater) to vary adsorption as a function of pH,
cation exchange capacity, organic carbon content, lead speciation, soil/water redox potential, phos-
phate/carbonate levels, and clay content.
Lead (Pbl
Lead is generally the most widespread and concentrated contaminant present at a lead battery
recycling site (i.e., battery breaker or secondary lead smelter). It generally poses the greatest environ-
mental and human health risk.
Lead occurs naturally in crustal material. It is a constituent of more than 200 minerals - most of
them, very rare. The average abundance of lead in the earth's crust is approximately 15 ppm. Lead is
commonly associated with ores of copper, zinc, silver, arsenic, and antimony in deposits formed by the
replacement of limestone or dolomite. In addition, lead may occur in a variety of igneous, metamorphic,
and sedimentary rocks (USGS, 1976).
Weathering of lead-bearing rocks is a very slow process. Analysis of nearly 1,000 soil samples
collected from across the U.S. found that the relative abundance of lead in soil ranges from less than 10
99
-------
ppm to 700 ppm with a mean concentration of 16 ppm. Only 6% of these samples contained greater
than 30 ppm of lead (USGS, 1976).
Lead is a heavy metal that exists in three oxidation states: 0, +2(ll), and +4(IV). Lead (Pb),
lead sulfate (PbS04), lead oxide (PbO), and lead dioxide (PbO2) are the predominant lead species found
at a lead battery site. However, the lead species at sites with carbonate soils are generally carbona-
ceous forms, such as lead carbonate (PbCO3), hydrocerussite (Pb3(CO3)2(OH)2), or lead hillite (Pb4SO4
(C03)2(OH)2). For example, the predominant lead species at the C&R Battery site in Virginia was
hydrocerussite.
The metallic lead and lead dioxide electrodes in batteries - and other lead minerals or salts --
have relatively higher densities than water. Some of the compounds are slightly soluble while others are
insoluble in water (Table A-3). Throughout most of the natural environment, the divalent form, Pb+2, is
the most stable ionized form.
Lead compounds can also be adsorbed onto hydrous oxides of iron and manganese and be
immobilized in double and triple salts. Soils strongly retain lead in their upper few centimeters; they are
the major sinks for pollutant lead. Lead can also be biomethylated, forming tetramethyl and tetraethyl
lead. These compounds may enter the atmosphere by volatilization.
The capacity of soil to adsorb lead increases with pH, cation exchange capacity, organic carbon
content, soil/water Eh (redox potential), and phosphate levels. Lead exhibits a high degree of adsorp-
tion on clay-rich soil. Only a small percent of the total lead in soil is leachable; the major portion is
usually solid or adsorbed onto soil particles. However, as lead is removed from solution, desorption of
lead may occur -- maintaining an elevated lead concentration in solution. Surface runoff, which can
transport soil particles containing adsorbed lead, facilitates migration and subsequent desorption from
contaminated soils. On the other hand, groundwater (typically low in suspended solids and leachable
lead salts) does not normally create a major pathway for lead migration. Lead compounds are soluble
only at low pHs. For example, at a pH of 8 or less, the value of dissolved lead could be above the
proposed drinking water standard of 15 ng/L (Figure A-4). If battery breaking activities have occurred
on-site, and the battery acid was disposed on-site, elevated concentrations of lead and other metals may
have migrated to groundwater.
100
-------
TABLE A-3. SOME PHYSICOCHEMICAL PROPERTIES OF SELECTED LEAD COMPOUNDS
Compound
Lead
Lead dioxide
Lead carbonate
Lead hydro-
cerrusite
Lead hydroxide
Lead sulfide
Lead oxide
Lead sulfate
Tetramethyl lead
Tetraethyl lead
Formula
Pb
Pb02
PbC03
Pb3(C03)2(OH)2
Pb(OH)2
PbS
PbO
PbS04
-------
CO
o
f)
0)
-------
Cadmium (Cdl
Cadmium was used in the past as a grid hardening agent in lead batteries. Its concentration
ranges between 5-20 mg/L In aqueous solutions, cadmium exists only in the +2 state. Cadmium is
adsorbed by soils and sediments containing aluminum, iron, and manganese oxides. Cadmium mobility
in aquatic systems will be controlled by sediment movement. In subsurface soil and groundwater,
cadmium will be relatively immobile.
103
-------
APPENDIX B
BACKGROUND INFORMATION ON
SUPERFUND LEAD BATTERY RECYCLING SITES
B.1 IDENTIFICATION AND CLASSIFICATION OF LEAD BATTERY SITES
During the course of this project, 44 CERCLA lead battery Superfund sites were identified. Table
B-1 provides a brief summary of the sites, including a contact point, where available. These lead battery
sites consisted of two main groups: lead battery recycling sites and non-recycling sites.
1. Lead battery recycling sites -- Twenty-nine (29) lead battery recycling sites were iden-
tified. A lead battery recycling site is defined in this report as a location where battery
breaking, secondary lead smelting, or lead refining operations have been conducted.
The lead battery recycling sites can be further classified into two sub-groups:
(a) Battery breaker sites (20 identified), where operations consisted principally of
battery breaking, with the recovered lead being taken off-site for further process-
ing; and,
(b) Integrated battery breaking/smelting/refining sites (9 identified).
Of these 29 lead battery recycling sites, 22 are on the Eighth Update to the National
Priority List (NPL) and have been or will be subjected to the Remedial Investigation/
Feasibility Study process. Some of these 22 sites on the NPL have also been the
subject of removal actions. The other 7 lead battery recycling sites are those where
only removal actions are underway or completed.
Of the 22 lead battery recycling sites on the NPL, 10 have completed RODs; 8 of those
RODs were reviewed in preparation of this report. Remedial Investigation and Feasibility
Study reports were obtained for 8 of these sites. Additional documents on several of
104
-------
TABLE B-1. SUMMARY OF CERCLA LEAD BATTERY SITES AND REMEDIAL ALTERNATIVES PROPOSED (9/90)
Site name/location/state/
NPL ID*/EPA ID*/point of
contact (POC)
Region Site description
Threat/problem
Selected remedy,* present north
capital and O&H costs,
ROD date
O
U1
New London Sub Marine Base,
New London, CT
NPL ID*: 01CT021
EPA ID*:
Paul Marchessault FTS-883-1793
2. NL Industries,
Pedricktown, NJ
NPL ID*: 02NJ060
EPA ID*: NJD061843249
Mick Gilbert FTS-264-6418
Eugene Dominach FTS-340-6666
3. Brown's Battery Breaking Site,
Shoemakersvilie, PA
NPL ID*: 03PA060
EPA ID*: PAD980831812
Chris Corbett FTS-597-6906
4. C&R Battery Co., Inc.,
Chesterfield County, VA
NPL ID*: 03VA017
EPA ID*: VAD049957913
Paul Leonard FTS-597-1286
5. Dorney Road Landfill,
Hertztown, PA
NPL ID*:
EPA ID*: PAD980508832
POC: Not determined
Submarine battery servicing
facility. Volatile organic
compounds pesticides, PCBs,
and spent battery acids buried
below the water table in Area
A landfill.
Integrated battery breaking/
lead smelting/refining
facility/on-site landfill
(11 acres).
Ill Battery breaking facility
(14 acres).
Ill Battery breaking facility
(11 acres).
Ill Landfill with some lead
battery waste.
Sediment and surface
water contaminated with
metals and pesticides.
Soil, groundwater,
surface water
contaminated with
heavy metals.
Soil, groundwater, and
sediments contaminated
with metals including
lead.
Soil contaminated with
inorganics including
lead, antimony, and
arsenic.
Soil and surface water
contaminated with VOCs,
organics, and inorganics.
Remedy not selected. Remedial investigation in
progress. Monitoring wells installed, sampling to
begin 11/90.
RI/FS in progress. Landfill capped, teachate
collection and treatment underway.
Permanent relocation of all on-site
residences and the on-site business.
S342.900 (present worth). ROD for other operable
units pending. 9/28/90.
Stabilization of contaminated soil and
sediment; off-site disposal of the
stabilized material in a sanitary/
industrial waste landfill; residual contaminated
soil covered with a soil cap.
$15,572,000 (present worth). 3/30/90.
Off-site disposal of ponded water;
regrading and installation of multi-
layer cap; runon/runoff controls; runoff
and groundwater monitoring; access and deed
restrictions. $14,000,000 (present worth)
$42,000 (annual O&M). 9/29/88.
Remediation selected in RODs have not been implemented (9/90).
(continued)
-------
TABLE B-1. (continued)
Site name/location/state/
NPL ID#/EPA ID#/point of
contact (POC)
Region Site description
Threat/problem
Selected remedy,* present worth
capital and O&M costs,
ROD date
6. Hebelka Auto Salvage Yard,
Weisenburg Township, PA
NPL ID*:
EPA ID#: PAD980829329
Fran Burns FTS-597-4750
Jacks Creek/Sitkin Smelting
and Refining, Haiti and, PA
NPL ID*: 03PA125
EPA ID#: PAD980829493
Garth Conner FTS-597-0439
III Automobile junk yard with
intermittent periods of
activity involving salvage
operations (20 acres).
Ill Smelting/refining facility
and mining operation.
Soil and debris
(battery casings)
contaminated with
metals including lead.
Soil contaminated with
PCBs, surface water
contaminated with lead
and PCBs.
Excavation and on-site fixation of
soil followed by off-site disposal;
excavation and recycling of battery
casings; soil backfilling and
vegetation. 16,073,436-6,884,652
(present worth), $0 (OSM). 3/31/89.
Pre-RI activities in progress.
O
O>
8. Lancaster Battery, III
Lancaster, PA
NPL lOt:
EPA ID*: PAD003004496
POC: Not determined
9. Reeser's Landfill, PA III
NPL ID*:
EPA ID#: PAD980829261
Vic Janosik FTS-597-8996
10. Tonolli Corp., Nesquehoning, PA III
NPL ID#: 03PA123
EPA ID#: PAD073613663
Donna McCartney FTS-597-1101
Former recycler of lead
batteries from automobiles
and trucks.
Unlined municipal dump that
contained some battery cases.
Integrated battery breaker/
smelter/refiner (30 acres).
Soil, groundwater, and
surface water contaminated
with metals including lead,
arsenic, cadmium, and
copper.
None.
Soil and waste piles
contaminated with
metals including lead,
arsenic, cadmium, and
copper.
Removal action -- about 1,400 tons of lead-
contaminated soil excavated and disposed at
off-site disposal facilities.
No action. Groundwater review due
within five years. 3/30/89.
RI/FS in progress. Removal actions included
draining and treating contaminated lagoon water.
Remediation selected in RODs have not been implemented (9/90).
(continued)
-------
TABLE 8-1. (continued)
Site name/location/state/
NPL ID*/EPA ID*/point of
contact (POO
Region Site description
Threat/problem
Selected remedy,* present worth
capital and O&M costs,
ROD date
11. Voortman Farm, Upper Saucon
Township, PA
NPL ID*: 03PA123
EPA ID*: PAD980692719
Nick Dinardo FTS-597-3541
12. Bypass 601 Groundwater
Contamination, Concord, NC
NPL ID*:
EPA ID*:
AI Cherry FTS-257-7791
13. Cedartoun Battery, Inc.
Cedar-town, GA
NPL ID*:
EPA ID*: GAD984273821
Larry Brannen FTS-257-3931
14. Cedartoun Industries, Inc.,
Cedartoun, GA
NPL ID*: 04GA017
EPA ID*: GAD095840674
Randy Dominy FTS-257-2643
15. Gulf Battery Exchange,
Ocean Springs, MS
NPL ID*:
EPA ID*: MSD06462619S
POC: Not determined
16. Interstate Lead Co., (ILCO)
Leeds, AL
NPL ID*: 04AL014
EPA ID*: ALD041906173
Anna Torgrimson FTS-257-2643
III Batteries dumped in sinkhole,
not a battery recycler (43
acres).
IV Abandoned battery salvage and
recycling facility (13 acres).
IV Battery breaking facility.
IV Battery breaking and
secondary lead smelting
facility (7 acres).
IV Battery crushing facility.
IV Battery breaking/secondary
lead smelting facility.
On-site and off-site disposal
of lead-bearing wastes.
Grounduater monitored for
contaminated from metals
including lead and
cadmium.
Soil contaminated uith
lead, chromium, nickel,
and sulfate.
Not determined.
Soil and sediments
contaminated with
lead.
Soil, surface water,
and grounduater
contaminated with lead.
Groundwater and sediments
contaminated with lead.
No action. Continued grounduater
monitoring. $26,010 (present worth)
S6.860 (annual O&M). 6/30/88.
RI/FS in progress. Alternatives under
consideration: no action, capping, in-situ
solidification on-site treatment and
disposal, off-site treatment and disposal.
Removal action -- contract for solidifi-
cation of 22,000 y3 of lead-contaminated
soil awarded, implementation planned for
late 1990 and early 1991.
Not determined.
Removal action (1983-84) - off-site disposal
of contaminated soils and acid. On-site con-
solidation and capping of soils.
Installation of clay cap over some areas
completed under partial consent decree.
Feasibility study yet to be completed.
Remediation selected in RODs have not been implemented (9/90).
(continued)
-------
TABLE B-1. Ccontinued)
Site name/location/state/
NPL ID*/EPA ID*/point of
contact (POC)
Region Site description
Threat/problem
Selected remedy,* present worth
capital and OiM costs,
ROD date
8
17. Kassouf-Kimerling Battery,
Tampa, FL
NPL ID*:
EPA ID*:
Dave Abbott FTS-257-2643
18. Palmetto Recycling, Inc.
Columbia, SC
NPL ID*: (KSC023
EPA ID*-. SC0003562217
Al Cherry FTS-257-7791
19. Sapp Battery Salvage,
Cottondale, FL
NPL ID*: 04FL018
EPA ID*: FLD980602882
Martha Berry FTS-257-2643
20. Schuylkill Metals Corp.,
Plant City, FL
NPL ID*: 04FL019
EPA ID*: FLD062794003
Barbara Dick FTS-257-2643
IV
IV
IV
IV
Landfill where empty lead-acid
battery casings were deposited
(1 acre).
Battery breaking facility
(2 acres).
Battery breaking facility.
Extensive environmental
damage to cypress swamp
(45 acres).
Battery breaking facility.
Harsh contaminated due to
operations.
(17 acres).
Soil, debris, and ground-
water contaminated with
metals including
arsenic, cadmium, and
lead.
Soil and sediments
contaminated with metals
including lead, cadmium,
and chromium.
Groundwater, surface
water, and sediments
contaminated with metals.
Soil and sediment con-
taminated with lead,
groundwater, and surface
water contaminated with
lead, chromium, and
nickel.
ROD 1, Landfill, 3/31/89 -- Excavation of landfill
wastes and underlying soil following by solidifi-
cation/chemical fixation and disposal in on-site
landfill. $2,500,000-3,500,000. 3/30/90.
ROD 2, Marsh, 3/30/90 - Excavation and treatment by
solidification of contaminated marsh sediments;
sediment beyond 20 ft from landfill and 150 ft in
drainage canal to be left in place.
Pre-RI.
Excavation, solidification/fixation, and
on-site disposal of solidified soil and
sediments; grounduater pump and treatment;
surface water treatment end discharge; and
assessment of potential institutional controls.
$14,318,544 (capital), $25,631 (annual OiM)
9/26/86.
Excavation of process area soil; separation
of soil end debris by screening; treatment
of the soils by chemical fixation; crushing
and washing of debris for recycling; treat-
ment of surface water and groundwater by ion medium
filtration. Harsh remediation will involve mechani-
cal controls, i.e., fencing and monitoring for west
marsh and flood control gates to provide continued
surface water inundation resulting in anaerobic
sediments and monitoring for the east marsh.
* Remediation selected in ROOs have not been implemented (9/90).
(continued)
-------
TABLE B-1. (continued)
Site name/location/state/
NPL 1D#/EPA IWpoint of
contact (PCXT)
Region
Site description
Threat/problem
Selected remedy,* present worth
capital and O&M costs,
ROD date
21. Scott's Creek, Neu Bern, NC
NPL ID*:
EPA ID*: NCD9B0848840
POC: Not determined
22. Arcanum Iron and Metal Site,
Darke County, OH
NPL ID*: OSOH003
EPA ID*: OHD017506171
Anita Boseman FTS-886-6941
23. H. Broun Co., Inc.
Grand Rapids, HI
NPL ID*: OSMI108
EPA ID*: MID017075136
Timothy Prendiville FTS-886-5152
24. NL Industries/Taracorp Lead
Smelter, Granite City, IL
NPL ID*: 05IL035
EPA ID*: ILD09673H68
Brad Bradley FTS-886-4742
25. NL Industries/Taracorp/Golden Auto
Parts, St. Louis Park, MN
NPL ID*:
EPA ID*:
POC: Not determined
IV Old batteries located on-site.
Battery breaking facility
(4.5 acres).
Battery breaking facility,
portions of facility also
used as a dump (4 acres).
Integrated battery breaking
and secondary lead smelting
facility (25 acres).
Integrated battery breaking
and secondary lead smelting
facility.
Soil, groundwater, and
surface water contaminated
with lead.
Removal action - about 490 y3 of lead-contaminated
fill and battery casings excavated and deposited
off-site.
Groundwater, surface water. Excavation and off-site disposal of soil
soil, and sediments with >500 mg/kg lead; excavation and on-
contaminated with inorganics, site disposal of soil with lead between
background and 500 mg/kg; removal of
battery casings; conduct treatability studies and
on-site landfill ing; and deed restrictions on land
and aquifer usage. $9,929,000 (capital), $37,000
(annual O&M). 9/26/86.
including lead, antimony,
and arsenic.
Lead contamination in
air, surface water,
sediments, and
groundwater.
Soil contaminated with lead.
None.
RI in progress.
Excavation of soils from residential and
commercial areas, consolidation in on-site
pile, followed by multi-media capping. 9/86.
No action.
9/29/88.
Continued groundwater monitoring.
(continued)
Remediation selected in RODs have not been implemented (9/90).
-------
TABLE B-1. (continued)
Site name/location/state/
NPL ID*/EPA ID#/point of
contact (POO
Region
Site description
Threat/problem
Selected remedy,* present worth
capital and O&H costs,
ROD date
26. Prestolite Battery Division,
Vincimes, IN
NPL ID*:
EPA ID*:
Bob Lance FTS-886-4745
27. Rosen Metals/Ken Lee Prop.,
Woodville, UI (also known as
Lee's Farm)
NPL ID*:
EPA ID*: WID980615553
Steven Faryan FTS-353-9351
28. Rosen Metals/Phoenix Metals,
Baldwin, UI
NPL ID*:
EPA ID*: HID023K5592
Steven Faryan FTS-353-9351
29. Scrap Processing Co., Inc.,
Medford, UI
NPL ID*: 05UI034
EPA ID*: UID046536785
Bill Messenger FTS-353-1057
30. Union Scrap Iron and Metal
Co., Minneapolis. MN
NPL ID*: 05MN020
EPA ID*: MND022949192
Jim Vanderkloot FTS-353-9309
Former battery manufacturing Soil contaminated with lead. Not determined.
site (3.6 acres).
Abandoned stone quarry used to Soils and sediments
dispose of battery casings contaminated with lead.
(1.5 acres).
Burned battery tops to recover Soil contaminated with
lead. lead.
Auto salvage operation that
included battery breaking
facility (2 acres).
Automobile battery breaking
operations (1 acre).
Acidic, lead-bearing soil
in pond, potential threat
to groundwater.
None.
Chemical fixation of the lead-contaminated
waste using the Regional ERCS contractor's
proprietary treatment process, and capping
treated material on-site. Removal action in
progress. 11/90.
Not determined.
Not determined.
No action. 3/30/90.
* Remediation selected in RODs have not been implemented (9/90).
(continued)
-------
TABLE B-1. (continued)
Site name/location/state/
NPL ID*/EPA ID*/point of
contact (POO
Region Site description
Threat/proble
Selected remedy,* present worth
capital and OM costs,
ROD date
31. United Scrap Lead Co., Inc.
Troy, OH
NPL ID*: 050H044
EPA ID*: OH0018J92928
Anita Boseman FTS-886-6941
Battery breaking facility
(25 acres).
32. Cal West Metals, Lemitar, NM
NPL ID*: 06NM0111
EPA ID*: NM0097960272
Monica Chapa 2U-655-6730
Carlos Sanchaz FTS-255-6710
33. Michael Co., (Bettendorf)
Bettendorf, IA
NPL ID*:
EPA ID*: IAD021693338
William Burm FTS-276-7792
Roy Cross Iand FTS-757-3881
34. Murrieta Christian School,
Murrieta, CA
NPL ID*:
EPA ID*: CAD982405409
Brad Shipley FTS-484-1026
VI
VII
IX
Soil and sediments
contaminated with
arsenic and lead.
Processed automobile batteries
to recover lead.
Former battery manufacturing
and recycling facility. There
are three other similar sites
contaminated by the same
company (each <1 acre).
Defunct battery manufacturing
site on which a small private
school was built.
Soil, groundwater, surface
water, and sediments
contaminated with lead.
Soil and SU contami-
nated with lead.
Soil, surface water,
groundwater contaminate!
with lead.
Excavation and treatment of battery casings
and contaminated soil by washing, with lead
recovery and off-site disposal or recycling
of casings, and replacement of residual soils
on-site; excavation and dewatering of sediments
on-site and disposal with soil; construction of
a soil cover, and revegetation; decontamination
of contaminated buildings and debris with off-
site disposal; installation of a new residential
well; deed restrictions; drainage control; and
Groundwater and surface water monitoring.
S26.924.000 (present worth), $55,375 (annual O&M).
9/30/88.
RI in progress.
Removal action -- excavation of soil >1,000 ppm
and off-site disposal. Building interiors decon-
taminated via sweeping/vacuuning/steam-cleaning.
Removal action -- consolidate contaminated soils,
add quick line, apply a graded, 4-inch aggregate
base covered by a 3-inch asphalt cap.
Remediation selected in RODs have not been implemented (9/90).
(continued)
-------
TABLE B-1. (continued)
Site name/location/state/
MPL ID*/EPA I0#/point of
contact (POO
Region Site description
Threat/problem
Selected remedy,* present worth
capital and O&M costs,
ROD date
ro
35. Norco Site, Norco, CA
NPL ID#:
EPA ID*: CAD982040057
Richard Martyn FTS-744-19K
36. Alaska Battery Enterprises,
Fairbanks, AK
NPL ID*: 10AK002
EPA ID#: AKD004904215
Jeff Webb FTS-399-6707
37. Alaska Husky Battery, Inc.,
Anchorage, AK
NPL ID*:
EPA ID*: AKD009246497
POC: Not determined
38. Arctic Surplus, Fairbanks, AK
NPL ID#: 10AK008
EPA ID*:
POC: Not determined
IX A former battery breaking
facility (16 acres).
Battery sales, recycling and
battery parts casting opera-
tions were conducted on-site
(<1 acre).
Battery breaking facility.
Salvage operations including
battery breaking (22 acres).
Not determined.
Soil and groundwater
contaminated with lead.
Groundwater contaminated
with lead and PCBs.
Soil and groundwater
contaminated with lead,
zinc, PCBs, chlordane,
phenanthrene, and
pyrene.
Removal action -- cement-based solidification used
to treat approximately 8,000 tons of soil.
TCLP after 28 days <1 mg/L; ANS 16.1 greater
than leach index of 12; unconfined compressive
strength >500 psi.
Removal action -- excavation of lead-contaminated
soil above 1,000 mg/kg and disposal in a RCRA-
landfill. Site listed on NPL.
Removal action -- approximately 1,580 y3 of PCB
and lead-contaminated soil were excavated and
sent for disposal off-site.
EPA-initiated removal action in Sept. 1989:
fencing the site, removing 22,000 Ibs of
asbestos, stabilizing approximately 75 gal
of chlordane, collecting grounduater samples,
and better defining waste streams on-site.
Site listed on NPL.
Remediation selected in RODs have not been implemented (9/90).
(continued)
-------
TABLE B-1. (continued)
Site name/location/state/
NPL 1D*/EPA I Did/point of
contact (POC)
Region Site description
Threat/problem
Selected remedy,* present worth
capital and O&M costs,
ROD date
CO
39. Gould, Inc., Portland, OR
NPL ID*: 100R002
EPA ID*: ORD095003687
Chip Humphrey FTS-423-2678
40. Hanford 1100-Area, Benton
County, WA
NPL ID*: 10WA054
EPA ID*: WA4890090075
Dave Einan FTS-444-3883
41. Harbor Island/RSR Battery Site,
Seattle, WA
NPL ID*: 10WA008
EPA ID*: UAD980722839
Keith Rose FTS-399-7721
42. Spokane Junk Yard, Spokane, WA
NPL ID*:
EPA ID*: WAD981767296
POC: Not determined
43. Standard Steel Metal Salvage Yard,
Anchorage, AK
NPL ID*:
EPA ID*: AKD980978787
Johnson/Longston
Battery breaking and lead
smelting facility (60 acres).
Waste battery acid disposal
area (<1 acre).
A 350-acre industrial area
in Seattle, WA.
Metal salvage and scrapping
company that dealt with
batteries and transformers.
Metal salvage yard.
Soil and sediments
contaminated with
metals including lead.
None.
Air contaminated
with lead.
Soil, surface water, and
groundwater contaminated
with lead, cadmium, and
PCBs.
Soil and surface water
contaminated with lead,
PCBs, furans, cyanides,
and asbestos.
Excavation and separation of battery casing
fragments and matte; recycling of components
that can be recycled; off-site RCRA landfill
disposal for nonrecyclable components; on-site
disposal of nonhazardous, nonrecyclable components;
excavation, fixation/stabilization on-site
disposal of contaminated soil, sediments, and
matte; followed by soil capping, revegetation,
and grading; and groundwater, surface water,
and air monitoring.
$3,491,603 (capital), $17,073,581 (present
worth O&M). 3/31/88.
Pre-RI in progress. ROD due in 1993.
RI in progress. ROD due in 1992.
Removal action partially complete. Excavated
lead hot spots and capping of remaining lead-
contaminated soils planned.
Removal action -- off-site disposal or recycling
of contaminated soils stabilized with shotcrete.
Remediation selected in RODs have not been implemented (9/90).
(continued)
-------
TABLE B-1. (continued)
Site name/location/state/
NPL IDtf/EPA ID#/point of
contact (POC)
Region Site description
Threat/problem
Selected remedy,* present worth
capital and O&M costs,
ROD date
44. Western Processing, Kent, UA
NPL ID*:
EPA ID*:
John Barich FTS-399-8562
Recycling site. Battery
case chips and battery acid
were included in wastes
on-site.
Groundwater, surface water,
soil, and creek sediments
contaminated with VOCs,
organics, including PCBs
and PAHs, and metals.
Soil sampling and analysis of on-site and
off-site areas; excavation and off-site
disposal of selected soils and non-soil
materials; excavation or cleaning and plugging
all utility and process lines in Area I; Grounwater
extraction and treatment; stormwater control;
excavation and on-site disposal of selected soils;
excavation of utility lines; cleaning utility man-
holes and vaults; capping; performing bench-scale
testing of soil solidification technique; excavation
of Mill Creek sediments; and performing supplemental
remedial planning studies if groundwater contamina-
tion migrates.
$5,000,000 (capital). 8/5/84 and 9/25/85.
Remediation selected in RODs have not been implemented (9/90).
-------
these sites (e.g., On-Scene Coordinator Reports, RI/FS Work Plans, and technical
papers) were also studied.
2. Lead battery, non-recycling sites - Fifteen of the 44 lead battery Superfund sites had
substantial battery-related contamination. At these sites, non-recycling operations
included battery acid disposal; auto salvage operations where batteries accumulated;
battery disposal (in many cases mixed with other non-battery wastes); and battery
manufacturing. Information on these sites was considered valuable for this report if (a)
portions of the contamination at the site were distinctly battery-related (that is, not mixed
together with a lot of non-battery wastes), and (b) a treatment was underway or
completed on the battery- related wastes.
B.2 SUMMARY DESCRIPTION OF CERCLA LEAD BATTERY RECYCLING SITES
1. Physical Description - As can be seen in Appendix A from the descriptions of the
battery breaking, smelting, and refining processes, numerous types of operations can
occur at these sites. Similar operations may be executed with a range of procedures.
Nonetheless, some useful generalizations about these sites are possible.
Battery breaking operations - These enterprises are often small businesses with limited
environmental control programs. Battery breaking operations may have been conducted
at various places on the site. Disposal of the residuals from the battery breaking
operations tends to be haphazard. For instance, spent battery acid may or may not
have been treated prior to discharge to a swamp, ditch, pit, or lagoon. Battery casing
fragments, battery sludge, and metallic lead chips (separate or mixed) may be placed in
piles, buried, mixed with asphalt for use on site roads, or sent off-site for re-use. In a
few cases, battery tops were burned in order to remove the casing material and permit
recovery of the metallic lead. Battery breaking operations are not necessarily small;
50,000 batteries per week were reportedly processed at one site (Sapp Battery). Also,
materials other than batteries were processed at some of these sites, adding non-
battery-related contamination.
Organized, integrated, industrial operations - These operations involved processes not
only for battery breaking and component segregation, but also for acid handling and
115
-------
treatment, smelting, refining, air and water pollution control, and in some instances,
battery case recycling and battery manufacturing. These facilities are generally owned
by large companies with several plants. These companies may have considerable
experience with remedial investigations and feasibility studies concerning lead battery
sites, either as an owner or PRP. The contamination at these integrated facilities is
present in spent acid, metallic lead, lead compounds, and lead-contaminated battery
casings. Acid treatment, mechanized battery breaking, component segregation, sizing,
and washing are more common at these sites than at battery breaker sites. The inte-
grated battery breaking/smelting/refining sites also generated lead smelting and refining
wastes (e.g., lead slag, dross, matte, speiss, dusts, stack emissions, wastewater, and
residuals from air and water pollution control). The smelters typically use a landfill or
slag pile close to the operation. Wastes from some smelters have been sent off-site (for
such uses as alley surfacing, fill material, recycling) or for disposal. Also, some of the
reagents (e.g., arsenic, cadmium, and antimony) used in the smelting, refining, and
alloying processes -- although used in much small quantities than lead -- are hazardous.
They require attention regarding worker safety, site characterization, and if necessary,
remedial action. The number and type of buildings, structures, and equipment that
require investigation, demolition, or disposal at an integrated battery breaker/smelter/
refiner operation is typically greater than for a simple battery breaker site. Plastics
reprocessing and battery manufacturing residuals may also be present at integrated
battery breaker/smelting/refining sites. There are only a few former plastics reproces-
sing and battery manufacturing sites that are currently on the NPL. These sites have not
had RIs or FSs completed to date, so plastics recycling and battery manufacturing
operations are not addressed in this document.
2. Types of Contamination at Defunct Lead Battery Recycling Sites -- The information
obtained on lead battery recycling sites shows that RPMs are typically confronted with
metallic lead and lead compounds as the principal contaminants of concern. The
metallic lead occurs in a variety of alloys and physical forms, (e.g., plates, chips,
powders, dusts, bound to battery casing scraps, or incorporated in slag). The lead
compounds from scrap batteries include lead sulfate and lead oxides. Other lead
compounds (e.g., PbCO3, Pb(OH)2) may be formed in treatment processes that neutral-
ize battery acid. Still other lead compounds may be formed via reactions with the soil.
116
-------
Other metals (e.g., cadmium, copper, arsenic, antimony, and selenium) are often present
at lead battery recycling sites, but usually in much lower concentrations than lead ~
often below hazardous concentrations. Also, sulfuric acid from batteries may remain in
liquid form in pits, ponds, lagoons, storage tanks, or treatment vessels. The acid may
also have contaminated the soil, elevated sulfate levels, and depressed pH. Of course,
non-battery recycling operations at these sites, have introduced other contaminants.
Asbestos insulation may also be present on piping and equipment at smelting and
refining sites.
3. Contamination Sources at Defunct Lead Battery Recycling Sites -There are five sources
of environmental and health risks from defunct lead battery recycling sites:
o Soil -- Lead-contaminant concentrations are common to lead battery recycling
sites. TCLP values exceeding 5 mg/L are typically found in soil samples from
these sites, indicating that the soil is a RCRA hazardous waste. Lead in soil is
rather immobile. At several sites the lead contamination in the soil does not
exceed a depth of a few centimeters. There are, however, exceptions to lead's
limited mobility in soil. These exceptions appear to be caused by: (1) excava-
tion and burial of lead-contaminated wastes (e.g., scrap battery parts), or (2) a
combination of very permeable soil, geological conditions coupled with the
solubilizing effects of low pH (caused by the presence of large amounts of bat-
tery acid), and/or a high water table. Acid rain could also depress pH, but was
not cited as a major contributor to increased lead mobility in soil at the NPL
sites investigated.
Soil can be contaminated by a variety of direct and indirect processes during
battery breaking operations. Initially battery breaking was conducted in such a
manner that the battery acid, the soluble lead in the acid, the lead sulfate
sludge, metallic lead (chips, plates, dust), spongy lead, and lead dioxide were
intentionally or inadvertently placed on the surface of the soil. Leaching and
runoff from surface contamination and waste piles expanded the volume of the
117
-------
contaminated soil. Burial of battery recycling wastes depressed the pH, thereby
increasing the solubility of lead in soil water. The presence of untreated battery
acid and of acid rain are potential accelerators of the mobility of lead in soil.
During secondary lead smelter operations, stack emissions and lead dusts have
spread soil contamination. At some active lead smelters, dust sweepings have
such high lead content (NIOSH, 1982) that they are fed back into the smelting
furnaces for lead recovery.
Soils are commonly a source of health and environmental concern at lead
battery recycling sites due to the many pathways of contamination: leaching
from the soil into wells on or close to the site, runoff that traverses surface soil
and subsequently contaminates surface water and sediments, and airborne dust
that may be ingested or inhaled.
Groundwater - The inorganic lead compounds associated with lead battery
recycling have low aqueous solubility. However, the Maximum Contaminant
Level for total lead in drinking water is currently 15 ppb - only a small amount
of lead can make the groundwater unacceptable as a drinking water source.
Furthermore, reducing the pH will substantially increase the aqueous solubility of
lead. One source (Watts, 1984) indicates that the solubility of lead at a pH of 4
could increase to 10,000 ppm. Therefore, if the sulfuric acid in the recycled
batteries was not collected or neutralized, its discharge could elevate levels of
soluble lead in the groundwater.
Piles -- The piles found at a site may be broken into four general types:
(1) Battery casing scrap piles - These piles consist of battery casing
fragments (hard rubber, ebonite, or polypropylene) with lead sulfate
imbedded in cracked casing material; internal battery components (e.g.,
polyvinyl chloride, paper); residual lead sulfate sludge; lead dioxide;
sulfuric acid; metallic lead particles; and scrap. Additional processing
(cleaning, sizing, separation) may have processed the material further
for on-site or off-site use for plastic recycling or fuel. Lead content of
118
-------
battery scrap piles ranges from 1% to 30% total lead. Lead in TCLP
leachate frequently exceeds 5 mg/L Battery casing piles can be
hazardous by virtue of their lead and lead compounds contents:
leaching into and through the soil to groundwater or surface
water (and subsequently to drinking water);
moving to receptors via surface runoff, then to surface waters or
sediments, thereby affecting drinking water or ambient water
quality, and also contaminating sediments;
migrating from the site as airborne dust; or
directly contacting humans or animals in the food chain.
Although it has not been raised as a concern in the RI/FS, a pile of
battery chips could burn, emitting lead and other contaminants to the
air.
(2) Smelter/refiner waste piles - Although a fair amount of recycling of
process by-products occurs in smelting and refining operations, various
non-recyclable wastes are generated. These wastes are considered
non- recyclable for technical, environmental, health, or economic rea-
sons. They may include slag (principally silicates produced during the
smelting process), matte (a metallic sulfide containing iron and lead
produced during the smelting process), speiss (a mixture of metallic
arsenides produced during the smelting process), dross (the scum that
forms on the surface of molten metals because of oxidation or the rising
impurities to the surface), air and water pollution control sludges, other
residuals, and miscellaneous debris. Some of these materials may have
been recycled during operations at one site, but not at another. Waste
piles may also include battery debris, if some or all of the casings have
not been recycled. In addition, other operations conducted at the site
or landfill could have received wastes from other sites or non-battery
lead scrap. These wastes are possible sources of non-battery contami-
nants.
119
-------
Lead content in waste piles can be substantial. For example, lead
content in samples from one pile ranged from 1 % to 28%. Contamina-
tion emanating from these smelter/refiner waste piles has been man-
aged with a range of care and success at various sites.
Smelter/refiner waste piles are hazardous because lead, lead com-
pounds and other contaminants could be transported to receptors via
leaching to groundwater, runoff, airborne dust, and direct contact.
(3) Commonly re-used smelter/refiner by-product piles - Depending upon
the operation at a particular site, piles of slag, dross, speiss, matte, and
pollution control sludges may have been set aside for recycling back
into these or other processes. The materials may have potential value
to another smelter/refiner.
These by-product piles pose the same types of health and environmen-
tal threats as for the smelter/refiner waste piles described in (2). De-
pending on the site, some routes of migration may have been blocked,
for example by a concrete pad covering, or runoff channelling to an
on-site treatment facility. Also, these piles would typically be smaller
than the waste piles.
(4) Raw materials - There may be whole spent batteries, scrap lead, coke,
scrap iron, and other smelting and refining agents present on-site.
Hazardous constituents from the raw materials could potentially be
transported to receptors via leaching, surface runoff, airborne dust, and
direct contact.
Structures, buildings, and equipment -- A variety of contaminated structures,
buildings, and equipment, which may be encountered at lead battery recycling
sites, will require characterization. Once surface contaminant types and levels
are identified, a determination must be made: whether no action, decontamina-
tion, re-use, or demolition/disposal is/are necessary, feasible, and appropriate.
120
-------
Residences on and near several sites have required characterization of con-
taminant levels.
The following types of structures and equipment have existed near process
buildings:
shipping and receiving areas; battery breakers; acid collection sumps;
battery component segregation, sizing, and cleaning machinery (e.g.,
conveyors, screens, cyclone separators, flotation separators, washing
apparatus, and associated piping, tanks, etc.);
kiln feedstock preparation areas; kilns (blast, reverberatory, or rotary);
sweater furnaces; agglomeration furnaces; refining kettles; and associat-
ed exhaust stacks and piping, some of which may be asbestos- coated;
air and water pollution control equipment and associated piping, tanks
(perhaps containing corrosive and toxic wastewater), and mixers;
storage bins (covered and uncovered, with and without floors) for
batteries, battery scrap, slag, dross, and other process raw materials,
by-products or waste;
plastics washing and recycling equipment;
above or below ground fuel tanks;
sewer and wastewater lines
Process structures, buildings, and equipment have been considered hazardous
because lead, lead compounds, refining agent dusts (e.g. arsenic, a carcino-
gen), and other contaminants could be transported to receptors via contaminat-
ed surface runoff, airborne dust, and direct contact. Recognition, evaluation,
and control of risks posed by airborne dust and direct contact are particularly
relevant for the protection of workers involved in site investigations, sampling,
decontamination, or demolition operations.
Pits, ponds, lagoons, and surface water -- These locations may contain corro-
sive and otherwise contaminated waters and sludges. If unlined or poorly lined,
they can act as a source of contamination to underlying soil and groundwater.
121
-------
If precipitation exceeds evaporation, water contaminated by corrosive, soluble,
and suspended solids may overflow boundaries and migrate. A similar situation
could occur if an impoundment wall fails.
122
-------
APPENDIX C
LAND DISPOSAL RESTRICTIONS FOR THIRD THIRD
SCHEDULE WASTES; RULE
123
-------
Friday
June 1. 1990
Part II
Environmental
Protection Agency
40 CFR Part 148 et al.
Land Disposal Restrictions for Third
Third Scheduled Wastes; Rule
124
-------
Federal Register / Vol. 55, No. 106 / Friday, June 1, 1990 / Rules and Regulations 22565
BOAT TREATMENT STANDARDS FOR D007
[Nonwastewaters]
Regulated constituent
Chromium (Total)..
Maximum
lor any
single grab
sample,
TCLP (mg/l)
50
BOAT TREATMENT STANDARDS FOR D007
[Wastewaters]
Regulated constituent
Chromium (Total)
Maximum
lor any
single grab
sample,
total
composition
(mg/i)
50
BOAT TREATMENT STANDARDS FOR U032
[Nonwastewaters]
Regulated constituent
Chromium (Total) . ...
Maximum
tor any
single grab
sample.
TCLP (rng/l)
0094
BOAT TREATMENT STANDARDS FOR U032
[Wastewaters]
Regulated constituent
Chromium (Total)
Maximum
tor any
single grab
sample,
loial
composition
(nuj/l)
032
f. Lead
D008—EP toxic for lead.
P110—Tetraelhyl lead.
U144—Lead acetate.
U145—Lead phosphate
U140—Lead subacetate.
K039—Emission control dust/sludge from
secondary lead smelting.
K100—Waste leaclung solution from acid
leaching of emission control dust/sludge
from secondary lead smelting.
(1) D008 Wastes. The Agency, as one
alternative, proposed treatment
standards below the characteristic
levels for nonwaslewaters and
wustewaters as 0.51 mg/l TCLP and O.O'l
mg/l, respectively. The Agency also
proposed an option of capping the
treatment standards for D008 at the
characteristic level. Additional data and
comments were received that indicated
that the proposed levels of 0.51 mg/l
TCLP and 0.04 mg/l were unachievable
for many D008 wastes on a routine
basis. After detailed analysis of the
available data, EPA concludes that
trealment to 5.0 mg/l EP best represents
the achievable treatment standard for
the entire spectrum of D008
nonwaslewaters. In addition, EPA is
establishing the treatment standard for
Wastewaters at the characterislc level
for the reasons stated in section III.D of
the pieamble.
(a) Nonwastewaters. The Agency
proposed a cut-off concentration of 2.5%
total lead as a means of distinguishing
between those essentially inorganic
nonwastewaters containing recyclable
levels of lead and those which can be
effectively stabilised. Consequently, the
Agency proposed two treatabihty
groups for lead based on the 2.5% cutoff
as the Low and High Lead Subcategory.
The Agency solicited comments on the
use of the cutoff level and whether the
2.5% total lead gives an accurate
description of lead that can be recycled
from D008 nonwustewaters. Many
comrnenters requested that the Agency
not promulgate the cutoff level. In fact,
many comrnenters suggested that it is
not economically feasible to recycle
lead from wastes with less than 25%
lead. Many comrnenters (inlcuding those
from secondary lead industry itself] also
stated that lead concentrations are not
the sole measure of recyclabihty. The
commenters presented data that
indicates that DOG8 nonwastewaters
wilh greater than 2.5% total lead can
often be stabilized. Therefore, the
Agency hua decided not to promulgate
the cutoff levels and has decided not to
adopt proposed high and low lead
treatabihty groups for D008
nonwastewaters and instead to
promulgate gcnerically applicable
treatment standards.
In addition, the Agency proposed and
solicited comments on three options for
the development of treatment standards
for D008 nonwastewaters. The first
option was to develop a numerical
treatment standard for those DOOB
nonwastewaters that can be stabilized.
Consequently, the Agency proposed a
numerical treatment standard of 0.51
mg/l for teachable lead based on a
transfer of the performance of
stabilization for F006 wastes. The
second option was to specify Thermal
Recovery as a method of treatment as
the treatment standard for D008
nonwastewaters where the lead could
be recovered. The third option was to
limit the treatment standard for DOOO
nonwastewaters to the characteristic
level.
During the comment period, the
Agency received D008 nonwuatewatcr
data from various sources. Most of the
data came from stabilizing specific DOOtt
nonwastewaters. Some of the data were
from the foundry industry, secondary
lead smelters, the glass industry, and
commercial treaters of D008
nonwastewaters. The majority of the
data received by the Agency did not
have the proper QA/QC, corresponding
influent and effluent data, and design
and operating parameters, so the
Agency is hesitant to use the data in
developing treatment standards. The
Agency, nevertheless, evaluated all of
the data to assess the range of waste
variability and what standard could
typically be achieved.
Stabilization data was submitted by
the foundry industries by Wheland
Foundry and the American Foundrymen.
The untreated lead concentration ranged
up to 88 mg/l leachable using the EP
toxicity test. An analysis of the data
indicates that the performance of the
treatment system could achieve
leachable levels of lead lower than the
characteristic level. In fact, the highest
leachable concentration of lead is 1.4
mg/l. Although these data showed that
the leachable concentration of lead was
below the characteristic level, the
leachable level for cadmium was higher
than the characteristic level. These data
clearly show that the other metals in the
wastes could affect the performance of
stabilization for this waste. Put another
way, this means (assuming proper
treatment performance) that the
performance of the trealment system
could achieve concentration levels
below the characteristic level for lead
but levels higher than the characteristic
level for cadmium.
Data was submitted by two glass
manufactures, Vision East! and Ciby-
Gcigy Corporation. Vision Ease
submitted treatment data for
stabilization of ground glass particles,
wastewater treatment sludges, and
polishing and grinding dust. The type of
binder used was hydrated lime and
sodium monophosphate. The comnienter
indicated that thieve untreated wastes
contained total lead concentrations
greater than 2.5% and leached higher
than the characteristic level; however,
no actual influent concentrations were
submitted. The commenter also did not
submit QA/QC data. If the Agency
calculated a treatment standard using
the stabilized data, the standard would
be the characteristic level of 5.0 mg/l
measured by the EP test.
Ciby-Gcigy submitted treatment data
for waste produced in the manufacture
of glass enamels. These wastes were
produced from equipment and container
washing duiing the manufacturing
125
-------
22566
Federal Register / Vol. 55, No. 106 / Friday, June 1, 1990 / Rules and Regulations
process. These washing were treated by
a wastewater treatment system that
generated a sludge that exhibited the
characteristic of toxicity for lead. The
commenter submitted two sets of data.
The first set of data was treatment of a
25.fi% lead oxide sludge by stabilizing
with clays, flints, and calcium chloride
and then heating the waste to a
maximum temperature of 1850 degrees
Fahrenheit to produce a ceramic
material. This ceramic material leached
lead concentration ranging from 0.2 to
0.4 ppm as measured by the F.P test. If
the Agency calculated a treatment
standard for this waste, the treatment
standard would be 0.89 mg/1 measured
by the EP test. For this data set, there
was no untreated leachable
concentrations of lead, therefore the
Apcncy cannot determine whether the
waste was hnznrdous before treatment.
The second data set contained lead
oxide concentration ranging from 13% to
7S"1. The waste was mixed with borax
and then heated to a maximum
temperature of 1950 degrees Fahrenheit.
This ceramic material leached lead at
levels ranging from 0.2-40 ppm measued
by the EP test. Of the 11 data points that
were collected by the commenter, 4 of
the 11 would fail the EP test. The
Agency did not use these data to
calculate a treatment standard,
however, because each used different
binder ratios. These two data sets from
glass manufacturers clearly show the
diversity of tlie waste and a difference
in treatable levels. In some cases
stabilization can reduce teachability of
lead at, or somewhat below, the
characteristic level.
The Agency received data from the
Secondary I-rad Smelters Association
(Sl.SA) on the treatment of slag by
stabilization. The wastes contained total
concentrations of up to 10 percent lead.
The types of binders that were used
were portland cement, polymers, and
silicates. The commentcr submitted
approximately 110 data points from two
different plants. The binder to waste
ratios ranged from 1 to 2, to 1 to 15. In
the data submission, there was no QA/
QC data and no corresponding influent
leachable lend concentration. One data
set was based on use of portland cement
as a stabilizing agent with a binder to
waste ratio ranging from 1 to 5, to 1 to
10. The Agency calculated a treatment
standard of 2.47 mg/1 was measured by
the TCLP from these data. The other
data set was based on the use of
polymers and silicates as stabilizing
agents with binder to waste ratio
ranging from 1 to 5, to 4 to 10. There
were approximately 94 data points, and
of these data points, one was above the
characteristic level for lead. The Agency
used these data to calculate a treatment
standard of 4.82 mg/1 as measured by
the TCLP.
The Hazardous Waste Treatment
Council (HWTC) submitted eight data
sets for the treatment of D008
nonwastewaters. There was no QA/QC
and influent leachable concentration of
lead. The data set with the highest
concentration of total lead was a zinc
ammonium chloride solid from the
manufacture of containers. This waste
had a total lead concentration of 49,000
ppm This waste was stabilized to a
leachable level of lead ranging from 6.47
to 8.7 ppm as measured by the TCLP.
This stabilized waste represented a
volume increase ratio ranging from 1.8 to
2.5.
The data set with the next highest
total lead concentration was generated
from an incinerator fly ash from the
aerospace industry that contained 810
ppm of total lead. Based on the data
provided in the comments, this waste
would not be considered
characteristically hazardous due to the
fact that the untreated leachable level
for lead is 0.0749 ppm. This waste was
treated by stabilizing with a binder to
waste ratio ranging from 0.89 to 2.0. The
treated leachable level.1) ranged from 0.1
to .27 ppm as measured by the TCLP.
The third highest data set represented
data from three soils contaminated with
lead and petroleum, with concentrations
ranging from 29 to 561 ppm total lead.
This waste contained total lead
concentration of 29 ppm, and had a
corresponding untreated leachable level
of 6 01 ppm as measured by the TCLP,
which is above the characteristic level.
These soils resulted in the best
treatment, with levels ranging from .000
to 0.257 ppm as measured by the TCLP.
This represented a volume increase
ranging from 1.6 to 3.4.
The HWTC provided three other data
sets representing waste generated as
writer filtrate and sludge from the
manufacture of conduit, as ammonium
hydroxide sludge from electroplating,
and as sump sludge from the
reconditioning of metal drums. These
wastes had total lead concentrations
ranging from 234 to 400 ppm. There was
no untreated TCLP data corresponding
to the total lead levels. The stabilized
wastes ranged in concentration from .06
to .10 ppm as measured by the TCLP.
The binder to waste ratio ranged from
1.6 to 3.5.
Of these data, the waste with the
highest total lead concentration shows
treatment levels barely above the
characteristic level of 5 ppm. These data
show that a high concentration of lead
(approximately 5%) could barely be
stabilized to the characteristic level
(although the data are so sparse that no
hard conclusions are possible). These
data also show that most of the
untreated wastes discussed in the
HWTC comments did not exhibit a
characteristic before stabilization. Also,
these data highlight the diversity of DOOO
nonwastewaters that can be treated.
The HWTC commented on data
submitted to EPA from the Secondary
Lead Smelters Association (SLSA). The
HWTC concluded that the treatment
data support concentrations of lead
below the characteristic level. The
HWTC also stated that these data
support the proposed BOAT treatment
standard of 0.51 mg/1, or at least
achieving levels below the characteristic
level. The HWTC points out that agents
such as fly ash, lime, and sulfide would
provide for a higher degree of
stabilization than just adding portland
cement.
The Agency does not agree with the
HWTC that these data support
treatment levels significantly below the
characteristic level. The data provided
by SLSA clearly show that two treated
data points of 07 were above the
characteristic level. The Agency used
the data to calculate a treatment
standard of 4.82 mg/1, very close to the
5.0 mg/1 characteristic level. In addition,
the Agency does not agree with HWTC
that other stabilizing agents may
provide a higher degree of stabilization.
At the least, the proposition is not self-
evident. The data provided by SLSA
show treatment by three types of
binders and a significant range of binder
to waste ratios. Using the highest binder
to waste ratio for these wastes, the
treated level is higher than the
characteristic level. (In addition, there
are issues of whether stabilization of
slag is appropriate treatment. See
discussion of inorganic debris in
preamble section III.A.l.a.(2).)
The Agency does not believe that the
data it received in response to the
proposed rule represent the entire
spectrum of characteristic lead
nonwastewaters. Also, these data do not
support the assumption that
characteristic lead nonwastewaters can
typically be treated to levels
significantly less than the EP
characteristic level. The limited amount
of data does not reflect the full measure
of waste variability inherent in a
characteristic waste, particularly
variability of matrices and lead
concentrations. In addition, the
commenters do not address how
treatability of other metals could be
affected by optimized lead treatment,
126
-------
Federal Register / Vol. 55. No. 100 / Friday, June 1, 1990 / Rules and Regulations 22567
nor has EPA had the time to address this
issue. With the treatment of the Vision
Ease waste to 5.0 mg/1 as measured by
the EP and the SLSA data demonstrating
treatment to 4.B2 mg/1 as measured by
the TCLP, and data points above the
characteristic level submitted by the
waste treatment industry, the Agency is
adopting for nonwastewater forms of
D008 wastes, the treatment standard
equal to 5.0 mg/1 as measured by the EP
procedure. The Agency is adopting this
approach to address the range of
variability Inherent in the D008 wastes.
Decause a facility may generate a
waste containing lead and other metals,
the TCLP (which is required for most
other metals) may be used to measure
compliance with this standard. EPA is
not basing the standard for D006 on the
TCLP, however, because that protocol is
more aggressive for lead than the EP.
The Agency is not sure that levels of 5.0
mg/1 as measured by the TCLP are
typically achievable. The TCLP can be
used to demonstrate compliance.
However, if the analysis shows that the
waste leaches below 5.0 mg/1 for lead as
measured by the TCLP, then the facility
has complied with the standard. If the
waste leaches above 5.0 mg/1 for lead,
then the facility may analyze the sample
using the El1 procedure. (It should be
noted, however, that if a waste exhibits
the amended toxicity characteristic, it
must still be managed in a Subtitle C
facility even if it is not prohibited from
land disposal).
(1)) Wastewaters. In the November 22,
19(39, proposed rule, the Agency
proposed a treatment standard for D008
wastewaters of 0.04 mg/1 based on a
transfer of the performance of
precipitation with lime and sulfide,
filtration, and settling for K062
wastewaters. In addition, the Agency
solicited comments on the approach of
specifying a precipitant as a method of
treatment for D008 wastewaters.
Comments were solicited on whether
the Agency should develop treatment
standards based on data provided from
the primary and secondary lead
smelters industries as part of the
Agency's effluent limitation guidelines
program.
Many commenters questioned the
Agency's technical capabilities of the
transfer of the performance of the
treatment system for KOG2 wastes as
compared to DOOQ wastewaters. In
particular, the commenters pointed out
that the untreated K062 wastewaters
had low concentration of lead compared
to the D008 wastes as actually
generated. However, Commenters
submitted additional data indicating
that although the 0.04 mg/1 for load was
unachievable, precipitation and
filtration treatment could achieve
concentrations of lead in the effluent
lower than the characteristic level.
In particular, the Agency received
treatment data for D008 wastewaters
from three sources. One set of data
submitted to the Agency was from the
Battery Council, Inc (BCI). These data
represented a small portion of the data
that was collected in the effluent
limitations guidelines program for the
battery and nonferrous metals point
source category. BCI's contention was
that if the Agency decides to develop
treatment standards lower than the
characteristic level for D008
wastewuters, then the Agency should
base the levels on the effluent guidelines
for the battery and nonfenous metals
categories. The Battery Council
submitted treatment data using the
following treatment technologies: lime
settling, lime settling and filtration, and
carbonate precipitation, settling, and
filtration. This data showed influent
concentration levels ranging up to 300
ppm. The data showed a substantial
reduction of lead and other metals from
the treatment system. BCI submitted
corresponding quality assurance/quality
control (QA/QC) information for the
data. If the Agency uses the data from
the treatment system, the calculated
treatment standard would be roughly 0.6
mg/1, an order of magnitude lower than
the characteristic level.
in addition, the Agency received D008
wastewuter data from Tricil
Environmental Services, a treater of
D008 and other characteristically
hazardous wastewaters. However, this
waste was commingled with other waste
before treatment, thereby blending
down such that the concentration of
lead would be lower than what was
actually reported. Data was submitted
on the treatment of lead by precipitation
with phosphate, followed by settling,
and filtration. The concentration of lead
in the influent before blending down
ranged up to 50,000 ppm. If the Agency
used all of the treatment data in order to
calculate a treatment standard, the
performance of the treatment system
indicates that a calculated treatment
standard is 0.2 mg/1, which is more than
an order of magnitude lower than the
characteristic level. The Agency would
hesitate to use the data in developing
treatment standards for D008
wastewuters due to the lack of QA/QC
data and corresponding influent and
effluent data. Because of the initial
concentration of lead and
concentrations of other dissolved metal,
the Agency believes that these wastes
represent the variability associated with
the characteristic wastes.
Also, the Agency received treatment
data from a foundry facility treating
D008 wastewater. This data represents
treated wastewaters by precipitation
with high magnesium lime and nitration.
The lead concentration in the untreated
wastewater ranged up to 276 mg/1. If the
Agency used all of the treatment data,
the calculated treatment standard is 0.4
mg/1, which is an order of magnitude
lower than the characteristic level. For
this data, the Agency evaluated the QA/
QC data, the design and operating
parameters, and corresponding influent
concentrations.
Bused on the evaluation of all of the
wastewaters data received from
comments, as well as the various Clean
Water Act, effluent limitation guidelines
and pretreatment standards regulating
lead (for example, the Combined Metals
Data Base and regulations for primary
lead, secondary lead and battery
manufacturing), the Agency concludes
that well designed and well operated
treatment systems can achieve total
concentrations of lead lower than the
characteristic level. As explained in
Section III.D, however, EPA has
determined not to require hazardous
wastewaters to be treated to levels less
than the characteristic level in order to
avoid significant and potentially
environmentally counterproductive
disruptions to the NPDliS/pretreatment
and UiC programs.
In addition, many commenters •
suggested that the Agency not specify a
precipitant as a method of treatment for
D008 wastewaters. Many commenters
suggest that particular precipitanls may
perform better depending on the
characteristics of the waste. For
example, Tricil Environmental points
out that phosphate is a superior
precipitant than carbonate or sulfate
because of the low solubility of lead
phosphate. The Agency agrees with the
commenters and is not promulgating a
precipitant as a method of treatment. In
fact, the Agency is promulgating the
treatment standard at the characteristic
level, thereby treaters and generators of
D008 wastewaters may select any
precipitant in order to meet the
characteristic level.
(c) Lead Acid Batteries. For lead acid
batteries, the Agency is promulgating a
standard of "Thermal recovery of lead
in secondary lead smellers (RELEAD)".
(See 5 268.42 Table 1 in today's rule for a
detailed description of the technology
standard referred to by the five letter
technology code in the parentheses.)
The Agency believes that virtually all of
127
-------
225C8 Federal Register / Vol. 55, Ko. 106 / Friday, June 1, 1990 / Ruins and Regulations
the Ircatnrs of lead acid batteries are
using a recovery process.
Incidentally, the Agency notes that
lead acid batteries themselves, when
stored, are not considered to be land
disposed because the battery is
considered to be a container (see 40 CFR
2M.314(d)(3)). Gallery storage, however,
typically is subject to the subpart J
storage standards (relating to secure
storage, secondary containment in some
instances, and other requirements). See
subpart G of part 206.
Other commcnters questioned
whether the slag or matte from recovery
processes would need further treatment
and whrthor these wastes should be
placed m monofills. The residuals from
the recovery process are a new
treatabihty group (i.e. the residues are
not lead acid batteries) and therefore
their status as prohibited or
nonprohibiled is determined at the point
the residues are generated. Such
residues would thus only be prohibited
and therefore require further treatment
if they exhibit a characteristic. See
discussion of inorganic debris in section
III.A 3.a of today's rule.
(2) P1W, U144, U145, and 111-16
Wastes. The Agency proposed
wastewater treatment standards for
lead for PHO, U144, Ul>15, U14G based on
a transfer of the performance of
pipcipilation with lime and sulfide,
filtration, and settling for KOG2
wastewaters. While these U and P codes
represent primarily organo-lead
compounds and one may consider that
th" transfer from an inorganic lead to an
organic lead is not feasible, no
comments were received indicating the
Lit k of nchievabihty. The Agency's
judgment in that the standard is
technically feasible. Therefore, the
Agenry is promulgating a standards for
lead in P110, U144. U145. U14G
wastewaters of 0.04 mg/1 as proposed.
1 lie Agency has determined that some
nonwastewnter forms of lead wastes
including Pi 10, U144. U146. and some
U008 wastes, would need to be
incinerated prior to stabilization due to
the presence of high concentrations of
organics in order to achieve a treatment
standard based on stabilization. This is
primarily because the organics typically
interfere with conventional stabilization
processes (particularly at concentrations
exceeding 1% TOC). The Agency has
data on the incineration on organic
wastes containing up to 1,000 mg/kg
lead (such as K087 wastes) followed by
stabilization of the ash. These data
indicate that the proposed standard (i.e.
0.51 mg/1 leachable lead) can be
achieved for wastes that also contain
significant concentrations of organics,
provided the organics are destroyed by
pretreatment. Lead acetate (U14-1) and
lead subacetate (U14G) are anticipated
to be less difficult (or at least of similar
difficulty) to treat than tetraethyl lead.
The Agency is Iheiefore promulgating
the 0 04 mg/1 standard for organo-lead
compounds. P110, U144, and U140.
Additionally, the Agency received no
comments on the feasibility of the
transfer of lead in K002 wastewaters to
lead phosphate U145. Therefore, the
Agenry will promulgate as proposed
(3) K069. In today's rule, the Agency is
promulgating treatment standards for
K009 nonwastewaters in the Calcium
Sulfate Subcategory, and for wastewater
forms of K069. In addition, the Agency is
revoking the no land disposal based on
recycling as a treatment standard for the
Non Calcium Sulfate Subcategory for
K009 nonwastewaters and is
promulgating "Thermal Recovery of
Lead m Secondary Lead Smelters
(RIJEAD)". See § 208 42 Table 1 in
todiu 's rule for a detailed description of
the technology standard referred lo by
the fi\e letter technology code in the
parentheses.
For K009 wastewaters, the Agency is
promulgating treatment standards for
cadmium and lead. For cadmium, the
treatment standard is based on the
peiformance of chemical precipitation
with lime and sulfide and sludge
dew-itering for K002 wastes. For lead,
the treatment standard is based on the
performance of chemical precipitation
with magnesium hvdroxide followed by
clarification and sludge dewnlering fur
FJOOO uastewaters. This treatment data
was submitted as part of the public
comment period. The Agcn"y believes
that ttiese wastewaters better represent
a Kf>)9 wastewaler due lo the
concentration of le.id (i e up to 300
ppm) The Agency believes ;hat the
performance of both technologies can
achieve the regulated concentration due
to the fact that both precipitating agents
are hv droxides.
BDAT for KOG9 nonwaslewalers in the
Calcium Sulfate Subcalegory is
stabilization. The Agency believes that
there is only one geneiator of this wasle
and that this waste cannot be directly
recycled to recover lead. The waste
characterization data from the one
generatoi indicated that this waste
contains metal constituents such as
cadmium and lead. The metal
concentrations range up lo 3300 ppm
For the KOG9 nonwaslewaters m the
Calcium Sulfate Subcategory, the
Agency is transferring the performance
of stabilization of K061 to KOG9
nonwastewaters. This is a technically
feasible transfer because the K001 waste
is a more difficult waste to treat. In fact.
the lead concentrations in KOG1 wasle
ranges up to 20,300 ppm thus, the
performance of the treatment system
can be legitimately transferred.
(4) KlOO. In today's rule, the Agency is
promulgating treatment standards for
wastewaters and nonwastewater forms
of K100 wastes as proposed. For
cadmium and total chromium in K100
wastewaters, treatment standards are
based on a transfer of the performance
of chromium reduction followed by lime
and sulfide precipitation, and
devvatering for KOG2 wastes. For lead in
K100 wastewaters. treatment standard
is based on the performance of chemical
precipitation with magnesium hydroxide
followed by clarification and sludge
dewatering for D008 waslcwaters. The
Agency believes that both technologies
can achieve the concentration of the
regulated constituents due to the fact
that both precipitating agents are
hydroxides. For K100 nonwastewalers
treatment standards are based on the
transfer of the performance of
stabilization for F006 wastes.
Treatment standards for KlOO wastes
were originally scheduled to be
piomulgated as part of the Third Third
rulermiking. However, a treatment
standard of "No Land Disposal Based on
No Generation" for KlOO
nonwastewaters was promulgated on
August 8. 19IIR and subsequently revised
on May 2, 1989 (34 FR 18030) to be
applicable only to "Nonwastewater
forms of these wastes generated by the
process described in the listing
description and disposed after Augusl
17, 1988. and not generated in the course
of treating wastewater forms of these
wastes (Based on No Generation).' The
Agency received no comments on th"
treatment standards for KlOO wastes;
therefore, the Agency is promulgating as
proposed.
BDAT TREATMENT STANDARDS FOR D008
[Nonwastewaters)
Maximum
for any
Regulated constituent single grab
sample. EP
(mq'l)
128
-------
Federal Register / Vol. 55, No. 106 / Friday, June 1, 1990 / Rules and Regulations 225G9
BOAT TREATMENT STANDARDS FOR D008
[Wasiewalers]
Regulated constituent
Maximum
(or any
single grab
sample,
total
composition
(mg/l)
50
BOAT TREATMENT STANDARDS FOR D008
[Lead Acid Batteries]
Thermal recovery (RLEAD) of lead in secondary lead
smellors
BOAT TREATMENT STANDARDS FOR P110,
U144, U145, ANDU146
rwastewaters]
Regulated constituent
Lead
Maximum
(Of any
single grab
sample,
total
composition
(mg/l)
0040
BOAT TREATMENT STANDARDS FOR P110,
U144, U145, ANDU146
[Nonwastewaters]
Regulated constituent
Lead ..
Maximum
tor any
single grab
sample.
TCLP (mg/l)
051
BOAT TREATMENT STANDARDS FOR K069
[Wastewaters]
Regulated constituent
Cadmium
Lead
Maximum tor
any single
grab sample,
total
composition
(mg/l)
1 6
051
BOAT TREATMENT STANDARDS FOR K069
CALCIUM SULFATE SUBCATEGORY
[Nonwastewaters]
Regulated constituent
Cadmium
Lead ..
Maximum
tor any
single grab
sample.
TCLP (mg/l)
014
024
BOAT TREATMENT STANDARDS FOR K069
NON-CALCIUM SULFATE SUBCATEGORY
[Nonwastowatcrs, Revised From No Land Disposal]
Thermal recovery of lead in secondary lead smelters
(RLEAD)
BOAT TREATMENT STANDARDS FOR K100
[Wastewaters; Revised From No Land Disposal]
Regulated constituent
Cadmium ..
Chromium (Total) ..
Lead
Maximum for
any single
grab sample,
total
composition
(mg/l)
1 6
032
051
BOAT TREATMENT STANDARDS FOR K100
INonwaste#alors, Revised From No Land Disposal]
Regulated constituent
Cadmium . ..
Chromium (Total). .
Load
Maximum lor
any single
grab sample.
TCLP (mg/l)
OOG6
52
Obi
" See § 268 42 Table 1 in today's rule for a de-
tailed description of the technology standard referred
to by trie five letter technology code in parentheses
g. Mercury
D009—F.P toxic fur mercury.
K071—Urine purification muds from the
mercury cell process in chlorine
production, wheie separately prepunfied
brine is not used
KlOG—Wdstewbter Ireatment sludges from
the rnurcury cell process in chlorine
production
F'065—Mercury fulminate.
l'U'12—1'henylmeu.ury acetate.
U151— Mercury.
EPA is today promulgating treatment
standards for DUO!), K1U6, P005, POU2,
and U151. EPA has revised the proposed
regulatory approach for some of these
wastes in response to comment. EPA is
also withdrawing the proposed revisions
for K071 nonwastewaters. These wastes
are described fully in the respective
Listing Background Documents.
(1) Review of BOAT for
Nonwastewaters. EPA identified
thermal recovery processes, acid
leaching, stabilization, and incineration
as BOAT for mercury wastes.
Commentera questioned whether
thermal processing of mercury should be
the basis (or the exclusive basis) for the
treatment standard. Use of thermal
processing raises issues of cross-media
transfer of mercury, as well as the
environmental benefit of thermal
processing over stabilization or land
disposal. Other comments questioned
the amenability of mercury sulfide
wastes to stabilization as well as EPA's
proposed restrictions on co-disposal of
mercury wastes with alkaline wastes.
The stabilization comments and the co-
disposal issues are addressed in section
IlI.A.S.a.
Multimedia issues raised by thermal
processing of mercury materials involve
the potential transfer of mercury and
sulfur dioxide from the retorting/
roasting chambers to downstream air
pollution control devices (APCO) and
potentially to environmental media (e.g.,
air to water). Specifically, cormnentcTs
felt that EPA had not properly
addressed the issue of mercury air
emissions from retorting and urged EPA
to quantify mercury emissions prior to
determining whether roasting or
retorting represents BOAT for mercury
and sulfide wastes (i.e., KlOfi).
The Agency acknowledges the
legitimacy of the commenters' concerns,
which the Agency shares. The Agency
discussed the issue of air controls for
mercury retorting at 54 FR 40501. In
addition, the Agency provided
calculations in the administrative record
for the proposed rule of the potential
amounts of sulfur dioxide emissions to
the air that could result from the
retorting or roasting of mercury sulfide
wastes such as K10U, based on available
performance data from a facility
thermally processing cinnabar oteS. EPA
also included the document entitled,
"Review of National Emission
Standards (NESIIAPs) lor Mercury"
(EPA 450/3-84-014, 19U-1) m the
proposed administrative record. In this
1984 document, EPA provided
quantitative analysis for the potential of
mercury air emissions from several
industrial operations that include the
thermal processing of cinnabar ores as
well as the retorting of mercury
containing wastes.
The available air emission
information shows that both mercury
and sulfur dioxide emissions can be
effectively controlled by well designed
and well operated air pollution control
devices that allow for the recovery of
valuable mercury. Based on available
air emission information, performance
data from the thermal processing of
cinnabar ores, and performance data
from the retorting/roasting of mercury
wastes, EPA determined that retorting/
roasting represent BOAT for mercury
wastes. EPA reaffirms this
determination in today's rule. In order to
assure that air emissions from mercury
129
-------
Federal Register / Vol. 55, No. 106 / Friday, June 1, 1990 / Rules and Regulations 22637
EPA is not granting arsenic wastewaters
a capacity variance.
(b) barium Wastes. For D005 and P013
wastewaters, EPA is promulgating
concentration standards based on
chemical precipitation; for D005 and
P013 (except us indicated below)
nonwastewaters, EPA is promulgating
concentration standards based on
stabilization.
For P013 nonwastewalers with high
levels of organics, EI'A is requiring that
these wastes be incinerated prior to
stabilization. Sufficient capacity exists
to treat surface-disposed DC05 and P013
wastes. Therefore, EPA is not granting a
national capacity variance for them.
(c) Cadmium Wastes. For DOOG
wastes, EPA is promulgating treatment
standards for three categories:
wastewaters, nonwastewaters, and
cadmium batteries.
For DOOG wastewaters, EPA is
promulgating concentration standards
based on chemical precipitation, For
UOOii nonwastewaters. EPA is
promulgating concentration standards
based on stabilization or metal
recovery. EPA believes that sufficient
capacity exists to treat surface-disposed
cadmium nonwastewaters and
wastewaters. Therelore, EPA is not
granting a national capacity variance for
them.
For DOOG cadmium batteries, EPA is
promulgating thermal recovery as the
method of treatment. In the proposed
rule, EPA proposed granting D006
cadmium batteries a national capacity
variance due to a lack of identified
recovery capacity. Uuring the public
comment period, two commenters
identified available commercial
cadmium battery recovery capacity
(these comments were available for
reply comments). EPA contacted thee>e
commenters to verify their capacity.
Based on these contacts, EPA received
additional information and determined
that adequate capacity for treating
smface-disposed cadmium batteries
exists. Therefore, EI'A is not granting
DOOli cadmium batteries a national
capacity variance.
(d) Chromium Wastes. For U007
chromium and U032 (calcium eliminate)
v.astewaters, EPA is promulgating
concentration standards based on
chromium reduction followed by
chemical precipitation; for D007 and
UO'J2 nonwastewaters, EPA is
promulgating concentration standards
based on chromium reduction followed
by stabilization. F.PA believes sufficient
tiealment capacity exists for the volume
of these wastes. Therefore, EPA is not
granting H national capacity variance for
them.
|e) Lead Wastes.
DOOB—F.P toxic for lead
P110—Telraethyl lead
U144—Leadacetale
U145—Lead phosphate
U140—Lead subacetate
KWJ—Emissision control dust/sludge from
secondary lead smelting
KlOO—Waste leaching solution from acid
leaching of emission control dust/sludge
from secondary lead smelting
For DOOU wastes, EPA is promulgating
standards for three categories:
nonwastewaters, WHStewaters, and
lead-acid batteries. For DOGS
nonwastewater lead wastes, EPA is
promulgating concentration standards
based on stabilization, except where the
waste contains significant
concentrations of organics. In this case,
these wastes may need to be incinerated
prior to stabilization. For DOUO
wastewaters, EPA is promulgating
concentration standards based on
chemical precipitation. EPA believes
sufficient capacity exists for surface-
disposed UOOfi wastewaters and
nonwastewaters. Therefore, EPA is not
granting a national capacity variance for
LJOOU wastewaters and nonwastewaters,
with the exceptions noled below.
EPA is promulgating thermal recovery
as the method of treatment for lead-acid
batteries. Secondary lead smelters have
stated that they store these wastes in
piles prior to lecovery. EPA has
indicated in a previous rulemaking that
the shells surrounding lead-acid
batteries are considered to be storage
containers (see 47 FK 1231U and 40 CFR
2G4.314(f)(3)). Therefore, to the extent
that lead-acid battery storage meets all
the requirement of the 1J1K btora;;<-
prohibitions at 40 CFR 268.50, such
storage is permissible.
In the proposed rule, EPA solicited
comments on the management of other
UOOb lead material at secondary
smellers. EPA aho indicated that
storage of lead materials in waste piles
prior to smelting is a form of land
disposal, and ub biich these staging
tueas are subject to the .statutoiy
prohibiuons Du:mg the public comment
peiiod, EI'A received several comments
Irom the bt.-cond.iry lead smelting
industry regarding the btorage of battery
paits prior to smelting. Sevend
commenters expressed concern that
EPA's determination that staging piles
are a form oi land disposal could force
them to close or operate out of
compliance while staging piles are
replaced by tanks (assuming tank
storage is viable). As a result of these
comments, EPA contacted several
secondary smelltTs to asses the
potential capacity impact of required
staging area reconstruction. Because of
the large volume of batteries currently
processed ul .smelling facilities whose
continued storage operation remains in
question, EPA is granting a two-year
national capacity variance to allow
storage of the batteries preceding
smelting. EPA is also reconsidering
whether certain forms of battery parts
storage meet the meaning of "land
disposal" under section 3004(k). In
particular, if battery parts (or other
wastes) are stored in 3-sided tank-like
devices on concrete inside buildings (the
present storage method of some
secondary lead smelters) the Agency is
not certain that the language and
policies underlying section 3004(k)
warrant designating such practice as
"land disposal." Given the two-year
national capacity variance in this rule,
however, the Agency need not make a
ftmd decision on this point in this
rulemaking.
For PllO, U144, U145, and U140
wastes, EPA is promulgating
concentration standards based on
chemical oxidation followed by
chemical precipitation for waslewaters,
and stabilization for nonwastewaters.
PllO, U144, U145, and U14G
nonwastewaters containing significant
concentrations of organics may require
incineration prior to stabilization. EPA
believes sufficient capacity exists for
the small volume of these wastes that
are surface-disposed; therefore, EPA is
not granting a national capacity
variance for them.
EPA is revoking the no land disposal
standard based on recycling standard
promulgated in the First Third rule for
the iiuii-calcium sulfale subc.atcgory for
KOG'J nonwastewMe.-s. For K009 calcium
sulfale nonwastewuters, EPA is
promulgating concentration standards
based on slabihzatmn. For K069 non-
Cdlcium sulfiite n-ofiwastewaters, EPA is
promulgating recycling as tiie method of
treatment. For KOdH wa.sU'waters, EPA is
promulgating cunccinration Mt-.ndards
based on chemical precipitation. EPA
bt'hc'U-s aduuuale c,i,oacitj exists to
treat tin; volume of surf.iLe-uiopor.ed
Kudu wabtiuiiti-is niid nonwiibteualt.'^,
then-full', F.i'A is nut granting a capacity
vai Uiricc ior Ihcin
For K100 nonwastewaters, EPA is
revoking the no land disposal standard
based on the "no generation standards"
promulgated in the First Third rule.
Today, EPA is promulgating
concentration standards based on
stabilization for the nonwastewaters
and chemical precipitation for the
wastewaters. EPA believes adequate
capacity exists to treat the volume of
surface-disposed KlOO wastes.
Therefore, EPA is not granting a
capacity variance for them.
130
-------
APPENDIX D
CLEANUP LEVEL FOR LEAD IN GROUNDWATER
131
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C 20460
MEMORANDUM
SUBJECT:
FROM:
XN 2 I 1990
Cleanup Level for Lead in Grou
Henry L. Longest, Director
Office of Emergency and Reme
ter
esponse
TO:
PURPOSE
Bruce M. Diamond, Director<-,v_
Office of Waste Programs Enticement
Patrick M. Tobin, Director
Waste Management Division, Region IV
This memorandum addresses the issue of a protective cleanup
level for lead in ground water usable for drinking water, which
is a major concern for several Superfund sites in Region IV.
OBJECTIVE
The objective of this memorandum is to recommend a final
cleanup level for lead in ground water usable for drinking water
which will meet the CERCLA requirement that all Superfund
remedies be protective of human health and the environment.
BACKGROUND
The current Maximum Contaminant Level (MCL) for lead is 50
ppb and was promulgated in 1975 as an interim national primary
drinking water regulation (NPDWR) under the Safe Drinking Water
Act (SDWA). On November 13, 1985, the Agency began the process
of revising this standard by proposing a Maximum Contaminant
Level Goal (MCLG) as required by the SDWA (50 FR 46936).
On August 18, 1988 EPA proposed an MCLG for lead at zero and
an MCL of 5 ppb (53 FR 31516). Also, since the primary cause of
lead-contaminated drinking water is corrosion of lead-bearing
pipes in public water supply (PWS) distribution systems and/or
household plumbing, the proposed rule would direct PWSs to meet
treatment technique requirements and to deliver public education
to reduce and minimize exposures to lead in drinking water.
132
-------
-2-
These requirements would be triggered when an action level
is exceeded at consumers' taps throughout the water distribution
system. The Agency proposed an action level of 10 ppb, on
average, to trigger corrosion control and public education.
Another lead action level of 20 ppb, measured at the 95
percentile of samples, was proposed as a trigger for public
education.
The Agency is considering promulgation of treatment
technique requirements which may include additional source water
treatment, lead service connection replacement, and public
education if lead concentrations at the tap exceed an action
level. Any such technological treatment targets will provide
substantial health protection. A final rule is being worked on,
and is scheduled for promulgation in December 1990.
DISCUSSION
No cancer potency factor or reference dose has been
promulgated for lead; therefore, an assessment of protective
levels of lead in ground water that may be used for drinking
water purposes will be based on current data. The Agency has
identified 10 micrograms per deciliter (ug/dl) as a blood lead
level of concern in young children. Blood lead levels above 10
ug/dl are associated with increased risks of potentially adverse
effects on neurological development and diverse physiological
functions.
Attached is available data that support the recommended
final cleanup level for lead in drinking water at Superfund
sites. This information includes the June 15, 1990, EPA draft
final report entitled, "Contributions To a Risk Assessment For
Lead in Drinking Water" and the June 1986, EPA draft final report
entitled, "Air Quality Criteria for Lead" (Volume III of IV, p.
11-129). Based on these data, lead levels in drinking water of
15 ppb and lower should correlate to blood lead levels below the
concern level of 10 ug/dl. The Agency estimates that steady
exposure to a water lead concentration of 15 ppb would
contribute, at most, 2-3 ug/dl to a child's blood lead. Sources
of lead other than drinking water (e.g. food, air, soil, dusts)
typically contribute approximately 4-5 ug/dl to children's blood
lead. Accounting for the variability inherent
in childhood behavior, nutrition, and physiology, it is
estimated that total lead exposure, given 15 ppb in drinking
water, would result in blood lead levels below 10 ug/dl in
133
-------
-3-
roughly 99 percent of young children who are not exposed to
excessive lead paint hazards or heavily contaminated soils.
Therefore, a 15 ppb cleanup level would provide substantial
health protection for the majority of young children. Most of
the remaining lead problem will continue to be contaminated
soils and old lead-painted housing.
In an April 10, 1989, Federal Register notice (54 FR
14316) , EPA announced the availability of a guidance document and
testing protocol entitled, "Lead in School's Drinking Water," to
assist schools in determining the source and degree of lead
contamination in school drinking water supplies and how to remedy
such contamination. That document, which is also attached,
recommends that schools take remedial steps whenever the lead
level at any drinking water outlet exceeds 20 ppb.
RECOMMENDATION
Based on a review of these and other studies, it is
recommended that a final cleanup level of 15 ppb for lead in
ground water usable for drinking water is protective. If water
used for drinking purposes subsequent to achieving the cleanup
goal in the aquifer may need further treatment to account for
lead contributions related to the distribution of water through
pipes, the responsibility for this additional treatment or the
replacement of lead-bearing water pipes lies with the persons who
are using or distributing the water. A concentration of lead of
15 ppb in drinking water should generally correlate with a blood
lead level below the concern level of 10 ug/dl. In some
situations, lower cleanup levels may be appropriate based on
site-specific factors, such as multiple pathways of exposure
caused by lead from the site.
If the remedial action will include treatment and supplying
water directly to the public for drinking water consumption,
compliance with a 15 ppb action level should be met at 90 percent
of the taps to ensure that the remedy is protective. When the
lead NPDWR is promulgated, applicable or relevant and appropriate
requirements of that rule should be met.
FUTURE GUIDANCE
After promulgation of the lead NPDWR, guidance will be
issued discussing those provisions of the rule that may be
applicable or relevant and appropriate for Superfund actions.
For further information, please contact Tish Zimmerman at
FTS 382-2461 or Neilima Senjalia at FTS 475-7027.
134
-------
-4-
DISCLAIMER
The recommendations in this document are intended solely as
guidance. They are not intended and cannot be relied upon to
create any rights, substantive or procedural, enforceable by any
party in litigation with the United States. EPA reserves the
right to act at variance with these recommendations and to
change them at any time without public notice.
Attachments
cc: Directors, Waste Management Division, Regions I, V, VII, VIII
Directors, Emergency and Remedial Response Division, Region
II
Directors, Hazardous Waste Management Division, Regions III,
VI, IX
Directors, Hazardous Waste Division, Region X
135
-------
APPENDIX E
INTERIM GUIDANCE ON ESTABLISHING SOIL LEAD CLEANUP
LEVELS AT SUPERFUND SITES
136
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
SOL'9
EVt°GHV
MEMORANDUM
SUBJECT:
FROM:
TO:
PURPOSE
OSWER Directive #9355.4-02
Interim Guidance on Establishing Soil Lead Cleanup
Levels at Superfund Sites. / /
1* /
Henry L. Longest II, Director //•-fV
Office of Emergency and Remedial Response
Bruce Diamond, Director-
Office of Waste Programs Enforcement
Directors, Waste Management Division, Regions I, II,
IV, V, VII and VIII
Director, Emergency and Remedial Response Division,
Region II
Directors, Hazardous Waste Management Division,
Regions III and VI
Director, Toxic Waste Management Division,
Region IX
Director, Hazardous Waste Division, Region X
The purpose of this directive is to set forth an interim soil
cleanup level for total lead, at 500 to 1000 ppm, which the Office
of Emergency and Remedial Response and the Office of Waste Programs
Enforcement consider protective for direct contact at residential
settings. Ibis range is to be used at both Fund-lead and
Enforcement-load CERCLA sites. Further guidance will be developed
after the Agency has developed a verified Cancer Potency Factor
and/or a Reference Dose for lead.
BACKGROUND
Lead is commonly found at hazardous waste sites and is a
contaminant of concern at approximately one-third of the sites on
the National Priorities List (NPL). Applicable or relevant and
appropriate requirements (ARARs) are available to provide cleanup
levels for lead in air and water but not in soil. The current
137
-------
National Anbient Air Quality Standard for lead is 1.5 ug/m3.
While the existing Maximum Contaminant Level (MCL) for lead is
50 ppb, the Agency has proposed lowering the MCL for lead to 10 ppb
at the tap and to 5 ppb at the treatment plant(1). A Maximum
Contaminant Level Goal (MCLG) for lead of zero was proposed in
1988(2). At the present time, there are no Agency-verified
toxicological values (Reference Dose and Cancer Potency Factor,
ie., slope factor), that can be used to perform a risk assessment
and to develop protective soil cleanup levels for lead.
Efforts are underway by the Agency to develop a Cancer
Potency Factor (CPF) and Reference Dose (RfD), (or similar
approach), for lead. Recently, the Science Advisory Board
strongly suggested that the Human Health Assessment Group (HHAG)
of the Office of Research and Development (ORD) develop a CPF for
lead, which was designated by the Agency as a B2 carcinogen in
1988. The HHAG is in the process of selecting studies to derive
such a level. The level and documentation package will then be
sent to the Agency's Carcinogen Risk Assessment Verification
Exercise (CRAVE) workgroup for verification. It is expected that
the documentation package will be sent to CRAVE by the end of
1989. The Office of Emergency and Remedial Response, the Office-
of Waste Programs Enforcement and other Agency programs are
working with ORD in conjunction with the Office of Air Quality
Planning and Standards (OAQPS) to develop an RfD, (or similar
approach), for lead. The Office of Research and Development and
OAQPS will develop a level to protect the most sensitive
populations, namely young children and pregnant women, and submit.
a documentation package to the Reference Dose workgroup for
verification. It is anticipated that the documentation package
will be available for review by the fall of 1989.
IMPLEMENTATION
The following guidance is to be implemented for remedial
actions until further guidance can be developed based on an Agency
verified Cancer Potency Factor and/or Reference Dose for lead.
Guidance
This guidance adopts the recommendation contained in the 1985
Centers for Disease Control (CDC) statement on childhood lead
poisoning**) and is to be followed when the current or predicted
land use im residential. The CDC recommendation states that
"...lead in soil and dust appears to be responsible for blood
levels in children increasing above background levels when the
concentration in the soil or dust exceeds 500 to 1000 ppm".
Site-specific conditions may warrant the use of soil cleanup
levels below the 500 ppm level or somewhat above the 1000 ppm
level. The administrative record should include background
documents on the toxicology of lead and information related to
site-specific conditions.
138
-------
The range of 500 to 1000 ppm refers to levels for total lead,
as measured by protocols developed by the Superfund Contract
Laboratory Program. Issues have been raised concerning the role
that the bioavailability of lead in various chemical forms and
particle sizes should play in assessing the health risks posed by
exposure to lead in soil. At this time, the Agency has not
developed a position regarding the bioavailability issue and
believes that additional information is needed to develop a
position. This guidance may be revised as additional information
becomes available regarding the bioavailability of lead in soil.
Blood-lead testing should not be used as the sole criterion
for evaluating the need for long-term remedial action at sites that
do not already have an extensive, long-term blood-lead data
based).
EFFECTIVE DATE OF THIS GUIDANCE
This interim guidance shall take effect immediately. The
guidance does not require that cleanup levels already entered into
Records of Decisions, prior to this date, be revised to conform •
with this guidance.
1 In one case, a biokinetic uptake model developed by the Office
of Air Quality Planning and Standards was used for a site-
specific risk assessment. This approach was reviewed and
approved by Headquarters for use at the site, based on the
adequacy of data (due to continuing CDC studies conducted over
many years). These data included all children's blood-lead
levels collected over a period of several years, as well as
family socio-economic status, dietary conditions, conditions of
homes and extensive environmental lead data, also collected over
several years. This amount of data allowed the Agency to use the
model without a need for extensive default values. Use of the
model thus allowed a more precise calculation of the level of
cleanup needed to reduce risk to children based on the amount of
contamination from all other sources, and the effect of
contamination levels on blood-lead levels of children.
REFERENCES
1. 53 FR 31516, August 18, 1988.
2. 53 FR 31521, August 18, 1988.
3. Preventing Lead Poisoning in Young Children, January
U.S. Department of Health and Human Services, Center-
Disease Control, 99-2230.
139
-------
APPENDIX F
U.S. PRIMARY AND SECONDARY LEAD SMELTERS
140
-------
TABLE F-1. LIST OF U.S. PRIMARY AND SECONDARY LEAD SMELTERS
Primary Smelters
ASARCO
ASARCO
ASARCO
Doe Run
Doe Run
Secondary Smelters
ALCO Metals
East Penn Mfg.
Exide Corp.
Exide Corp.
Exide Corp.
GNB, Inc.
GNB, Inc.
GNB, Inc.
General Smelting & Refining
Gopher Smelting & Refining
Gulf Coast Lead
Interstate Lead
Master Metals
Pacific Chloride
Refined Metals
Refined Metals
Ross Metals
Roth Brothers
RSR Corp.
RSR Corp.
RSR Corp.
Sanders Lead
Schuylkill Metals
Schuylkill Metals
Standard Industries
Tara Corp.
Omaha, NE
Glover, MO
E. Helena, MT
Boss, MO
Herculaneum, MO
Los Angeles, CA
Lyon Station, PA
Reading, PA (General Battery Corp.)
Muncie, IN
Dallas, TX (Dixie Metals Corp.)
Columbus, GA
Frisco, TX
Los Angeles, CA
Cottage Grove, TN
Minneapolis, MN
Tampa, FL
Leeds, AL
Cleveland, OH
Columbus, GA
Beech Grove, IN
Memphis, TN
Rossville, TN
Syracuse, NY
Middletown, NY
Indianapolis, IN
Los Angeles, CA
Troy, AL
Baton Rouge, LA
Cannon Hollow, MO
San Antonio, TX (Reliable Battery)
Granite City, IL
Source: Fox, Weinberg, and Bennett, Washington, D.C.; U.S Bureau of Mines.
141
-------
LEGEND
Primay smelters-refineries
A Operating
A Shutdown
Secondary smelters
• Operating
O Shutdown
^o /
A \ f-
V
0
o
•
/
7
\ -IT"
i • >*-
1
— ^ •/
! \
I )o
\ t-n,
' * CJ;f
rv--^--JvxJ^L
A *-tx-^/X^
-T
0
.^' ,JQ_
\ • _^ \
i ° \ ° x-
1 \ v
'* /
' ^--4
~M>~~-*^~. \
!*>
*J° *?•»«> Vi
Scole.miln \
Figure F-1. Location of primary and secondary smelters.
Source: Isherwood. et al. U.S. Bureau of Mines.
Open File Report 55-88. 1988.
------- |