EPA/600/R-02/020
                                                             April 2002
Stabilization  and Testing of Mercury
 Containing Wastes: Borden   Sludge
                             by
               Paul Bishop, Renee A. Rauche, Linda A. Rieser,
                   Makram T. Suidan, and Jian Zhang
             Department of Civil and Environmental Engineering
                       University of Cincinnati
                     Cincinnati, Ohio 45221-0071
                      Contract No. 68-C7-0057
                         Task Order #10
                        Task Order Manager

                          Paul Randall
              Land Remediation and Pollution Control Division
              National Risk Management Research Laboratory
                       Cincinnati, Ohio 45268
              National Risk Management Research Laboratory
                  Office of Research and Development
                  U.S. Environmental Protection Agency
                       Cincinnati, Ohio 45268

-------
                                         Notice
The U.S. Environmental Protection Agency  through its Office of Research and Development funded and
managed the research described here under Contract No. 68-C7-0057, Task Order #10, to the University of
Cincinnati. It has been subjected to the U.S. EPA's peer and administrative review and has been approved for
publication as an EPA document. Mention of trade names  or commercial products does not  constitute an
endorsement or recommendation for use.

-------
                                          Foreword

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 systems
to support and nurture life. To meet this mandate, EPA's research program is providing data and technical
support for solving environmental problems today and building a science knowledge base necessary to manage
our ecological  resources wisely, understand how pollutants  affect  our health,  and  prevent or reduce
environmental risks in the future.

The National Risk Management Research Laboratory is the Agency's center for investigation of technological
and management approaches for preventing and reducing risks from pollution that threatens human health and
the environment. The focus of the Laboratory's research program is on methods and their cost-effectiveness
forprevention and control of pollution to air, land, water, and subsurface resources; protection of water quality
in public water systems; remediation of contaminated sites,  sediments and ground water; prevention and control
of indoor air pollution; and restoration of ecosystem s.NRMRL collaborates with both public and private sec tor
partners to foster technologies that reduce the cost of compliance and to anticipate  emerging problems.
NRMRL's research provides solutions to environmental problems by: developing and promoting technologies
that protect and improve the  environment;  advancing  scientific and engineering information to  support
regulatory and  policy decisions;  and providing the technical support and information transfer to ensure
implementation of environmental regulations and strategies at the national, state, and community levels.

This publication has been produced as part of the Laboratory's strategic long-term research plan. It is published
and made available by EPA's Office of Research and Development to  assist the user community and to link
researchers with their clients.
                                                 E. Timothy Oppelt, Director
                                                 National Risk Management Research Laboratory

-------
                                           Abstract

This report details the stability assessment of a mercury containing sulfide treatment sludge. Information
contained in this report will consist of background data submitted by the generator, landfill data supplied by
EPA and characterization and leaching studies conducted by UC and contract laboratories.

Borden  Chemicals and Plastics (BCP) provided background data for the time period  June  1997 through
November 1998. Included in the data summary are total mercury, reactive sulfide, Toxicity Characterization
Leaching Procedure (TCLP) and pH information relating to their sulfide treated sludge.

BCP' s sulfide sludge is currently being disposed in a subtitle C landfill located in Carlyss, Louisiana. Data on
the leachate from the landfill was provided by EPA - OSW.

Samples obtained by UC and EPA personnel at the BCP plant on November 19, 1998 were characterized by
UC and  two contract laboratories for thermogravimetric analysis, total mercury content, pH, acidity and cation
exchange capacity, etc. Leaching  tests and analytical work performed by UC and their contract laboratories
included the toxicity characteristic leaching procedure (TCLP), solid stability in water, leaching atconstantpH
values, and acidity.

Preliminary point estimates of measured mercury concentrations in the generated leachates indicate that the
mercuric sulfide complex is very strong in low pH environments; however, higher pH conditions may result in
mercury mobilization to the aqueous phase.

This report was submitted by  the University of Cincinnati (UC) in fulfillment of  Contract No. 68-C7-Q057
under the  sponsorship of the  United States Environmental Protection Agency (EPA). This report covers a
period from October 1998 through March  1999; laboratory work was completed as of March 1999.

-------
                                      Table of Contents
Foreword  	iii
Abstract  	iv

1.0      Background  	  1
         1.1      Waste Characterization  	  1
                 1.1.1    Data Quality Discussion 	  2
         1.2      Landfill Data  	  3

2.0      Characterization of BCP Sulfide Sludge  	  4
         2.1      Thermogravimetric Analysis  	  5
                 2.1.1    Background  	  5
                 2.1.2    Method  	  5
                 2.1.3    Results   	  5
                 2.1.4    Data Quality Discussion 	  6

3.0      Leachability of Sulfide Stabilized Sludge  	  7
         3.1      Solid Stability in Water	  7
                 3.1.1  Introduction 	  7
                 3.1.2    Procedure	  7
                 3.1.3    Results   	  7
                 3.1.4    Data Quality Discussion 	  8

         3.2      Acidity   	  8
                 3.2.1    Introduction	  8
                 3.2.3    Procedure	  8
                 3.2.3    Results   	  8
                 3.2.4    Data Quality Discussion 	  9

         3.3      Toxicity Characteristic Leaching Procedure (TCLP)  	  9
                 3.3.1    Introduction	  9
                 3.3.2    Procedure	  9
                 3.3.3    Results   	  10
                 3.3.4    Data Quality Discussion 	  10

         3.4      Constant pH Leaching Test	  10
                 3.4.1    Introduction	  10
                 3.4.2    Procedure	  10
                 3.4.3    Results	  11
                 3.4.4    Data Quality Discussion 	  11

-------
                               Table of Contents, Cont.d
4.0     Conclusions 	  12
        4.1      Background Data   	  12
        4.2      Landfill Data  	  12
        4.3      Characterization	  12
        4.4      Leaching Tests	  12
        4.5      Data Quality Discussion  	  14
                4.5.1    Background Data	  14
                4.5.2    Landfill Data  	  15
                4.5.3    Characterization Data  	  15
                4.5.4    Thermo gravimetric Analysis	  16
                4.5.5    Solid Stability in Water	  16
                4.5.6    Acidity	  16
                4.5.7    Toxicity Characteristic Leaching Procedure  	  16
                4.5.8    Constant pH Based Leaching Test	  18

Appendicies*

A       Operation Procedure for Treatment of BCP Waste
B       Analytical Data Produced by BCP
C       Thermogravimetric Data
D       Acidity Titration Curves
•D      Available from Paul Randall, Task Order Manager, U.S. EPA, at randall.paul(5jepa.gov or by calling
        513 569-7673.

-------
                           List of Tables  and Illustrations










1.1          Borden Background Data Summary	2




1.2          Landfill Leaching Data	3





2.1          Chemical Characterization of BCP Sludge	4




2.2          Physical Characterization of BCP Sludge	5




3.1          Solid Stability in Water Results  	7




3.2          Acidity Results 	8




3.3          TCLP Results 	10




3.4          Constant pH Leaching Test Results  	11





4.1          Laboratory QC Data for GCALI Total Mercury and TCLP Result	14D





4.2          Laboratory QC Data for EEI Total Mercury Result	15





4.3          Laboratory QC Data for EEI Total Mercury and TCLP Result	17D





4.4          Laboratory QC Data for EEI Total Mercury Results  	19
                                     List of Figures




3.1           Acidity vs. Sample Solid	9




4.1           Bisulfide Species as Function ofpH	13

-------
1.0     Background
                The Borden Chemicals and Plastics plant (BCP) is located in Geismar, Louisiana. The



        company produces, among other chemicals, vinyl chloride. The vinyl chloride synthesis employs a



        mercuric chloride catalyst in the process.  At intervals, the catalyst is changed resulting in some



        spillage. A diked concrete pad under the process area catches these spills along with any process



        leakage etc.  The pad is washed with water. The water collected, along with any rain water that falls



        over the process area, is diverted into two 10,000 gallon tanks.  The tank contents are adjusted to a pH



        between 3.5 and 5, treated with sodium sulfide, and dewatered with diatomaceous earth, added as a



        filtering aid.  The resulting filter cake, which is the subject of this study, is loaded into thirty-cubic-



        yard steel roll-off boxes.  When full, the contents are transported to the subtitle C landfill located in



        Carlyss, Louisiana.








        1.1 Waste Characterization



                The background BCP (Table 1.1) data provide a range  of TCLP values from 0.0120 mg/L to



        0.6540 mg/L, with two samples below the detection limit. Of eight TCLP values provided, five are



        below the TCLP regulatory limit of 0.2 mg/L mercury.  Three pH values are provided.  The values



        reported are 9.43, 1.31 and 5.32. These values indicate a highly variable and not well controlled



        treatment  process. (Complete data are provided in Appendix A, available from Paul Randall, see



        Table of Contents.)



                According to the treatment procedure supplied by BCP, the optimum pH range for this



        process before addition of sodium sulfide, is 3.5 to 5.0. The sulfide used in this process should act as



        a base.  Thus, it is unknown why the pH of the waste after sulfide treatment could be as low as 1.3.



        On the only other two sampling days  for which pH values were supplied, the pH (5.32 and 9.43) was



        higher than the maximum allowable pH (5.0).



                The analytical data provided by BCP indicate that there is a significant amount of reactive



        sulfide remaining in the samples after treatment.  The samples with higher reactive sulfide



        concentrations produced  the lowest TCLP  mercury concentrations. The two samples with high



        reactive sulfide concentrations had TCLP values that were  acceptable, while the sample with the



        lowest reactive sulfide concentration  failed the TCLP test.  Unfortunately, no pH or reactive sulfide



        concentrations were provided with the other TCLP results, so direct correlations can not be  made.  It



        is surprising, though, that one waste containing 40.0 mg/kg reactive sulfide did not bind up the



        mercury enough to prevent leaching in the TCLP test.



                Based on these results, it appears that it is possible for the Borden company to produce waste



        forms that will pass the TCLP test. The characteristics of the treated sludge are highly variable and



        indicate the need for additional process quality control.
                                                  -1-

-------
        1.1.1 Data Quality Discussion

                The background data presented came from several sources and are considered secondary data

        by EPA Order 5360.1 CHG 1, July 1998. Some QA information is available for the Gulf Coast

        Analytical Laboratories data (see Appendix A, Table of Contents) and a summary of this information

        is presented in Section 4.5. No QA information was available for the SAIC data.
                           Table 1.1: Borden Background Data Summary
Sample Date
10/27/97
10/27/97
10/27/97
10/27/97
02/13/98
02/13/98
02/13/98
05/15/98
05/15/98
05/15/98
11/11/98
11/11/98
11/11/98
11/20/98
06/04/97
06/04/97
06/04/97
06/04/97
Test Date
10/31/97
10/31/97
10/31/97
10/31/97
02/16/98
02/17/98
02/20/98
05/19/98
05/19/98
05/26/98
11/13/98
11/13/98
11/14/98
11/23/98




06/14/97
06/11/97
Type of Analysis
Total Hg
TCLP Hg
Total Hg
TCLP Hg
pH Extract
Reactivity Sulfide
TCLP Hg
pH Extract
Reactivity Sulfide
TCLP Hg
pH Extract
Reactivity Sulfide
TCLP Hg
TCLP Hg
Total Hg
TCLP Hg
Total Hg
TCLP Hg
Results
2.27 mg/kg
<0.0002mg/L
21.4 mg/kg
<0.0002mg/L
9.43
165 mg/kg
0.0160mg/L
1.31
120 mg/kg
0.0120 mg/L
5.32
40.0 mg/kg
0.3520 mg/L
0.0422 mg/L
2 1,1 00 mg/kg
0.2600 mg/L
17, 700 mg/kg
0.6540mg/L
Sample Designation
97102900091
97102900091
97102900101
97102900101
98021301041
98021301041
98021301041
98051800941
98051800941
98051800941
98111101241
98111101241
98111101241
98112000321
BGO62
BGO62
BGO63
BGO63
(1) Provided by BCP-analysis by Gulf Coast Analytical Laboratories Inc., 7979 GSRI Ave., Baton Rouge, LA.
(2) Provided by EPA-analysis by SAIC
(3) Provided by EPA-analysis by Gulf Coast Analytical Laboratories INC.

-------
1.2 Landfill Data

        Data supplied by EPA-OSW on the landfill leachate from cells containing the BCP sludge

are listed in Table 1.2.


                         Table 1.2 Landfill Leaching Data
Cell '
5
6
14
Mercury (jig/L)
ND2
0.94
0.57
PH3
—
9.51 (average)
—
           (l)Cell - the isolated location within the landfill of the stored waste
           (2)ND - No data on detection limit value was supplied
           (3) Supplied by EPA-OSW
        The data in Table 1.2 indicate that the mercury concentration in landfill leachate generated in

the vicinity of the Borden waste is highly variable, ranging from 0.94 jig/L to non-detectable. These

are actual leachate concentrations before dilution with groundwater, and the values can not be

compared directly to TCLP values. TCLP leachate concentrations are based on a leachate/waste ratio

of 20:1 (w/w) and TCLP leachate concentrations for  this landfill material may be much lower than

those actually observed for in situ leachate. Typically, voids occupied by leachant in a TCLP test are

an order of magnitude greater than that recorded for  in situ samples, meaning that there may be much

more leachant in the TCLP test than in the field, per  unit volume of waste. Therefore, the TCLP

concentration could be lower.  Consequently, these landfill samples may pass the TCLP test,  even

though their field leachate concentrations may be higher than the TCLP limit.
1.2.1 Data Quality Discussion

        The data presented in Table 1.2 supplied by EPA-OSW, were defined as secondary data by

EPA Order 5360.1 CHG 1, July 1998. No QC information is available. No detection limit value is

available. No information is available on the generation of leachate. Only a single pH value was

provided and was labeled as an average. Insufficient detail is available to assess the secondary data.

-------
2.0
Characterization of BCP Sulfide Sludge
                On November 19, 1998, 12 two-liter samples of dewatered sludge were collected from BCP

        at the Geismar, Louisiana plant by UC and EPA personnel.  The samples were obtained by random

        collection from a full thirty-cubic-yard transport container labeled 4279-30 LCHCWM. Before mixing

        6 of the 2 L bottles were sampled for TCLP to assess variability of the waste. To obtain a

        representative sample, 6 of the partially  full 2L bottles were mixed in a five-gallon container for 24

        hours prior to sampling. Only one sample was analyzed for total Hg from the homogenized mixture,

        consequently no statement can be made  concerning the effectiveness of the homogenization process.
        The following characterization data (Tables 2.1 and 2.2) were generated for this waste:


                         Table 2.1 Chemical Characterization of BCP Sludge*
Chemical Parameter
Total Mercury
Calcium
Magnesium
Sodium
Potassium
Hydrogen
pH
pH
Redox Potential @ 22 C
Redox Potential @ 22 C
Acidity
Cation Exchange Capacity
Concentration
8,100mg/kg
300 mg/kg
30 mg/kg
660 mg/kg
29 mg/kg
89 mg/kg
3.1
3.8
+393
+420
7.07 mg CaCO3 per g of sample
13.6 meq/lOOg
Method of Analysis
SW-846-7470A14
Extraction with Ammonium acetate2
Extraction with Ammonium acetate2
Extraction with Ammonium acetate2
Extraction with Ammonium acetate2
Measuring pH in Adams Evans Buffer Soln.
pH electrode2
pH electrode3
Redox electrode with Ag/AgCl2 used as
reference2
Redox electrode with Ag/AgCl2 used as
reference3
Standard Methods3
Summation of Cations (SSSA)2
*A11 values are point estimates.
(1) Analysis performed by Environmental Enterprises Incorporated, Cincinnati, Ohio
(2) Analysis performed by Agvise Laboratories, Northwood, North Dakota - No QA/QC data available
(3) Analysis performed by University of Cincinnati, Cincinnati, Ohio
(4) See section 4.5.3 for data quality analysis
                                                 -4-

-------
                 Table 2.2 Physical Characterization of BCP Sludge
Physical Parameter
0.5 - 2mm
0.002 - 0.5mm
0.0002-0.002mm
Moisture at 1/3 bar
Organic Matter
Bulk Density (disturbed)
Weight Percent
14.5
74.8
10.7
50.7
43
0.35 gm/cc
Method of Analysis
Pipette Method
Pipette Method
Pipette Method
Gravimetric loss upon drying
Furnace Method
Weight Ratios
* All values are point estimates












2,1 Thermogravimetric Analysis (TGA)





2.1.1  Background





        Thermogravimetry measures the weight change in a specimen as a function of temperature



and time. The mode of Thermo gravimetry used for this study is known as dynamic thermogravimetry,



in which different specimen types are heated in an environment whose temperature is changing in a



pre-determined manner at a linear rate. The resulting mass-change verus  temperature curve provides



information concerning the thermal stability and composition of the specimen.








2.1.2  Method



        Thermo gravimetric analysis was run on two  100 mg samples of BCP sulfide treated sludge.



Samples were warmed with dry nitrogen gas to 50°C for about 10 minutes. A small amount of the



sample was lost (probably moisture) during this initial warming in an inert medium. Following this,



the heating program was  initiated at a constant heating rate of 10°C/min until a temperature of 1000°C



was reached.  The thermal curves and derivative thermal curves were recorded for each sample by the



data acquisition unit of the instrument. (These curves are provided in Appendix B, see Table of



Contents.)








2.1.3 Results



        The TGA data,  generated in duplicate, show four basic inflection points at 167°C, 252°C,



331°C, and 425°C. The  initial weight loss between room temperature and 167°C is largely due to loss



of moisture. These data  indicate a thermally stable waste form. Heat generated in processing or long



term storage is unlikely to affect long term stability of the waste.
                                         -5-

-------
        Between 167°C and 425°C, organic constituents are decomposing rapidly, affecting changes



in the waste form.  The inflection point at 252°C is most likely the loss of sulfur from the system. The



cause of the 331°C inflection point is unknown at this time.  Above 450°C little change occurs.








2.1.4 Data Quality Discussion



        Plans for conducting thermogravimetric analyses were not included in the EPA approved



Quality Assurance Project Plan.



        The thermogravimetric analyzer was calibrated according to  the procedures outlined in the



Perkin-Elmer manual. Initial calibration was performed on September 9, 1997.  There were three



calibration procedures performed, two for temperature and one for weight.  The temperature



calibration involved a furnace calibration and a two point standard curie temperature calibration. The



furnace calibration performs a nine point  temperature calibration between lower and  upper



temperature (100 C to 1350 C) limits. The thermocouple temperature is matched to the furnace




temperature when the calibration is complete.  The two point standard curie temperature calibration



was  performed using Nickel (magnetic transition temperature 354 C)  and Hisat-50 (magnetic




transition  temperature 1000 C) magnetic  standards to perform the curie point temperature calibration.




        The weight calibration was performed using a 100 milligram class M calibration standard



provided by Perkin-Elmer. Once these calibrations were completed, the results were permanently



stored in the computer and incorporated into all runs. Recalibration is necessary only if the



equipment is moved, computer software is reinstalled or a new gas supply is used.
                                         -6-

-------
3.0     Leachability of Sulfide Stabilized Sludge





        3.1 Solid Stability in Water





        3.1.1  Introduction



                 This test varies the liquid/solid mass ratio during leaching to study the effect of the aqueous



        contaminant concentration on the diffusion of contaminants from the waste form. If the amount of



        contaminant released from the waste form  decreases as the liquid/solid ratio decreases, then the



        contaminant concentration in the leachate may be great enough to reduce the concentration gradient



        between the waste form and the leachate and impede its diffusion from the waste.








        3.1.2  Procedure



                 Samples collected on November 19, 1998 from BCP were dried at room temperature for 24



        hours in an exhaust hood/1' Four tests were run using 10, 20, 50 and 100 grams of waste. Each solid



        sample was placed in a 2 liter Nalgene HDPE bottle and then filled with 2 liters of deionized water



        corresponding to 5, 10, 25 and 50 g of waste per liter, as reported in Table 3.1.  The bottles were



        capped and tumbled  for 18  hours and then each  leachate sample was  filtered through a 0.45jim filter



        and placed in a sample container. Each leachate sample was acidified to a pH  of less than 2 with



        HNO3 and stored at 4°C until  analyzed within the 28 day holding-time requirement. Mercury



        concentrations were  measured by cold vapor atomic absorption spectroscopy (CVAAS).








        3.1.3  Results



                 As shown in Table 3.1, mercury present in the  leachate did not increase with greater volumes



        of leachant. Mercury released from Sample 1 was less than the reported detection limit of 0.001



        mg/L. In terms of total mercury leached from the waste, the other three samples released similar



        amounts of mercury. Consequently, it is likely that mercury concentration gradients between the waste



        form and the leachant do  not control leaching rates.








                              Table 3.1 Solid Stability in Water Results1

Liquid/Solid Mass Ratio
Waste (g/L)/Mercury (mg)
Mercury in Leachate(mg/L)
Total Mercury Leached (%)
Sample 1
200:1
5/40.5
< 0.00100
—
Sample 2
100:1
10/81.0
0.00100
0.00120
Sample 3
40:1
25/203
0.00116
0.00054
Sample 4
20:1
50/405
0.00304
0.00074
        (1) Mercury analysis performed by Environmental Enterprises Incorporated, Cincinnati, Ohio
                                                  -7-

-------
(1) Samples were dried in an exhaust hood rather than by oven drying as required by the QAPP. The



modification was made to avoid heating of the wastes to the point where mobility of contaminants



could be increased



3.1.4 Data Quality Discussion



         The solid stability-in-water test provides only single point indicators as leachates were



measured at a single time point (18 hours). There is no information on whether the interval was



sufficient to establish mercuric equilibrium between solid and solution phases. Section 4.5.5 provides



the data quality analysis for Solid Stability in Water Results.








3.2  Acidity



3.2.1  Introduction



         Acidity is related to the capacity of a material to react with a strong base. An acidity titration



was run on each leachate produced from the solid-stability-in-water tests to assess the acid-generating



capacity of the waste.  Each sample was titrated with a strong base to an end point pH of 9 to obtain a



smooth titration curve. Construction of the titration curve identifies the inflection points and thus



determines the buffering capacity of the leachate.








3.2.2  Procedure



         A known volume of leachate (40 mL) from the solid-stability-in-water test was placed in a



breaker and a 0.1N  sodium hydroxide titrant was added to the sample in incremental amounts until the



acidity end point was obtained. The amount of sodium hydroxide required to neutralize the acidity of



the sample is expressed as equivalent milligrams (mg) of CaCO3 relative to a liter (L) of leachate and



normalized to a gram (g) of the waste. An Orion electrode was used to measure the pH.








3.2.3  Results



         The titration curves are shown in Appendix C (see  Table of Contents).  The resulting acidity



for each sample is shown in Table 3.2, and Figure 3.1 shows measured acidity in the leachate versus



mass of the waste.



                               Table 3.2 Acidity Results1
Liquid/Solid Ratio (w/w)
Acidity (as mg CaCO3/L)
Normalized (mg CaCO3/g)
20:1
753.8
15.08
40:1
397.5
15.90
100:1
206.3
20.63
200:1
103.8
20.76
     (1) Analysis performed by University of Cincinnati, Cincinnati, Ohio

-------
                          Figure 3.1 Acidity vs. Sample Solid
    soo

    700 H
o
O  500  -


'op  400  -


^  300  -


'$  200  -


    100  -


      0
         0
                                                           = 7.Q727x + 47.041

                                                              R2 = 0.9979
                    20
40
    60

Sample (g)
80
100
120
        The values were normalized to sample weight in order to compare them on a per gram of sample


basis. Results suggest that the sample has some buffering capacity in low pH ranges, dropping off above


pH 6. The low buffer capacity of the waste may explain the wide variation in pH values reported both for


the waste and for the landfill leachate.





3.2.4 Data Quality Discussion


        Data generated in acidity analyses consist of single point estimates. Section 4.5.6 provides the


data quality analysis for the Acidity data.





3.3 Toxicity Characteristic Leaching Procedure (TCLP)


3.3.1  Introduction


        This test attempts to determine the potential mobility of contaminants in an acetic acid solution


that is intended to serve as simulated leachate under landfill conditions.





3.3.2  Procedure


        Prior to performing the TCLP analysis, an initial pH measurement of the waste must be made to


determine the appropriate pH of the extraction fluid (4.93 or 2.88) that must be used in the test. The pH of
                                            -9-

-------
the BCP waste was 3.8, which is well below pH 5, thus the TCLP method dictates that the extraction fluid

corresponding to a pH  of 4.93 must be used.

        A total of 100 grams of dried waste were added to a 2 liter container with 2 liters of extraction

fluid to yield essentially no head space in the container. The containers were sealed and then rotated end-

over-end for  18 hours.  Each leachate sample was then filtered through a 0.70 Jim filter and placed in a

sample container. The leachate samples were acidified to a pH of less than 2  with HNO3 and stored at 4°C

until analyzed within the 28 day holding-time requirement. Mercury concentrations were measured by

CVAAS.


3.3.3  Results

        Table 3.3 summarizes the analytical results for the TCLP test of the  material obtained from BCP

on November 19, 1998 prior to mixing. TCLP  results fall in a range of values from 0.00247 mg/L to

0.06555 mg/L, all well below the regulatory limit (0.2 mg/L). The sample pH was within the acceptable

range for waste treatment. It appears that the mercury in this sample was well stabilized.


                                 Table 3.3 TCLP Results1
Sample
TCLP (mg/L)
Total Mercury (mg/kg)
TCLP Limit
0.2

1
0.00247
8,870
2
0.00879
8,020
3
0.04100
4,830
4
0.06555
3,890
5
0.00498
4,290
6
0.041672
3,330
  (1) Mercury analysis performed by Environmental Enterprises Incorporated, Cincinnati, Ohio
  (2) The datum represents an undiluted result that exceeds the highest calibration standard (0.04000 mg/L).


3.3.4 Data Quality Discussion

        Section 4.5.7 provides the data quality analysis for TCLP data.


3.4 Constant pH Leaching Test

3.4.1  Introduction

        Constant pH leaching tests are a means to determine the effect pH has on mobilizing

contaminants found in waste samples. The basic premise of this test is to  leach samples in a constant pH

solution, adjusting the sample pH to the  set point as necessary.


3.4.2  Procedure

        Constant leaching tests were run at pH values of 2, 4, 6, 8, and 10, using 500 ml ofdeionized

water and 25 grams of dried solid to produced  a liquid/solid mass ratio of 20:1. A duplicate test was run at

a pH value of 8. The samples were stirred using stirring bars on  stir plates throughout the experiment. The
                                           -10-

-------
 pH was maintained at the initial value for a 24 hour period, with samples being extracted for analysis at 2,
 10 and 24 hours.  Each sample was filtered through a 0.7 Jim glassfiber filter, acidified to a pH of less than
 2 with HNO3 and stored at 4°C until analyzed within the 28 day holding-time requirement. Mercury
 concentrations were measured by C VAAS.

 3.4.3  Results
         Table 3.4 summarizes the reported mercury concentrations for each distinct pH test carried out.
 As can be seen, leachate mercury concentrations were well below regulatory limits in all samples when the
 leachant pH was 6.0 or lower. With higher pH leachants, the leachate mercury concentrations dramatically
 increased.  At pH 10,  the highest amount of mercury was leached. At a pH of 2, a steady-state condition
 may have been reached between 10 and 24 hours, as the mercury concentrations for these time intervals
 are within 15 percent of each other. At pH 4 and 6, mercury concentrations fluctuated  between the 10 and
 24 hour leaching times, but remained within the same order of magnitude. For other pH values, it is hard to
 tell if a steady-state condition was reached because mercury concentrations continued  to increase through
 the entire time interval. A longer testing period is recommended for future research. All test blanks except
 those for a pH of 8 are below the reported detection limit of 0.00100 mg/L. Even for the blanks at pH 8,
 there is no  significant  bias,  given the comparatively high mercury concentrations reported for the leachate
 samples.

                        Table 3.4 Constant pH Leaching Test Results1


2hr
10 hr
24 hr
Blank
Leachate Mercury, mg/L
pH 2
0.01090
0.01480
0.01310
< 0.00100
pH 4
0.00634
0.00616
0.00274
< 0.00100
pH 6
0.00218
0.00286
0.00582
< 0.00100
pH8(l)
< 0.00100
0.02060
0.11600
0.00274
pH 8 (2)2
missing
0.01350
0.40600
0.00106
pH 10
0.17400
0.37200
1.63000
< 0.00100
(1) Mercury analysis performed by Environmental Enterprises Incorporated, Cincinnati, Ohio
(2) Test duplicate.
 3.4.4 Data Quality Discussion
          Section 4.5.8 provides the data quality analysis for Constant pH Leaching Test results.
                                            -11-

-------
4.0 Conclusions



        4,1 Background Data



                Background data supplied by BCP and EPA indicate that it is possible for BCP to produce waste



        forms that will pass TCLP; however, process quality control needs improvement (data quality analysis,



        Section 4.5.1).








        4.2 Landfill Data



                BCP waste landfill samples were highly variable, with leachate mercury concentrations ranging



        from 0.94 jig/L to non-detectable (data quality analysis, Section 4.5.2).








        4.3 Characterization



                A thorough physical and chemical characterization of the BCP waste sample proved useful



        throughout the testing process. Compositional data was used for background information  (data quality



        analysis, Section 4.5.3).








        4.4 Leaching Tests



                The preliminary tests generated single point estimates. Therefore, the following discussion is



        intended to provide preliminary observations only. Preliminary observations should be qualified based on



        the QA/QC data quality discussions provided in 4.5.5 (Solid Stability in Water), 4.5.6 (Acidity), 4.5.7



        (TCLP) and 4.5.8 (Constant pH Leaching).



                Based on solid-stability-in-water tests,  it is likely that mercury concentration gradients between



        the waste form and the leachant do not control leaching rates. A total of six TCLP  tests were performed.



        Mercury concentrations ranged from 0.00247 mg/L to 0.06555 mg/L, all well below the regulatory limit



        (0.2 mg/L).  Acidity testing indicates a small amount of buffering capacity in low pH regions and very



        little above pH 6.  Constant pH leaching revealed mercury concentrations below 0.025 mg/L in all samples



        where the pH of the sample was 6.0 or lower.  With higher pH leachants, soluble mercury concentrations



        dramatically increased.



                These results may be explained using thermodynamic data for mercuric sulfide.  Mercuric sulfide



        (HgS) is very insoluble in water, with a solubility product, Ksp, of 1Q"52 (Bard, 1966)1.  However, the



        solubility of HgS in water can be increased measurably by association with various hydrogen sulfide



        species to form a number of mercuric-hydrogen-sulfide ions that enhance the solubility of HgS  in water



        (Clever et al,  1985)2. These  associations can lead to the formation of HgS-2H2S°, Hg(HS)3", HgS-2HS",
          Bard, A.J., Chemical Equilibrium, Harper and Row, Publishers, New York, 1966.
                                                   -12-

-------
and HgS22". HgS-2H2S° is the dominant water soluble form at pH values less than 6.2, while Hg(HS)3" is
the most soluble form between the pH values of 6.2 and 7. HgS-2HS" is the most soluble mercuric sulfide
association between the pH of 7 and 8.3, and HgS2 " is the most soluble form of mercuric sulfide above a
pH of 8.3. In fact, the solubility of HgS22" increases linearly with the hydroxyl ion concentration for pH
values over 8.3. Figure 4.1 presents a detailed distribution of the various bisulfide species as a function of
pH (Clever etal, 1985).
                                       Figure 4.12
     E
     o
        -5.OO
         6.OO -
        -TOO -
        -a.och
        -9.OQ
        -IQOO
 -LOO
- -200
                                                                  10.0
Clever, H.L., S.A. Johnson, and M .E. Derrick, "The Solubility of Mercury and Some Sparingly Soluble
Mercury Salts in Water and Aqueous Electrolyte Solutions," J. Phys. Chem. Ref. Data, Vol. 14, No.3,
1985.
                                          -13-

-------
        The above discussion and Figure 4.1  serve to illustrate the effect of pH on the solubility of Hg(II)



in water. Furthermore, the figure illustrates the importance of maintaining a pH less  than 6 for



precipitation of HgS in order to minimize the mobilization of mercury into the aqueous phase.








4.5 Data Quality Discussion





        Unprocessed analytical data generated by EEI are provided in Appendix D, see Table of





Contents.





4.5.1 Background Data





        The background data presented are considered secondary data by EPA Order 5360.1 CHG 1, July





1998. Some QA information is available for the Gulf Coast Analytical Laboratories data (Table 4.1).





However, no QA information was available for the SAIC data.





         The limited QC data for Gulf Coast Analytical Laboratory Inc. (GCALI) show results for the





laboratory control  standard (LCS) and an occasional spike sample (Table 4.1). There is no information on





initial calibration/blank and continuing calibration/blank or laboratory duplicates. All LCS samples meet





the QC criterion of ±15 percent of the true value, with the exception of the 10/27/87 TCLP sample.











        Table 4.1 Laboratory QC Data for GCALI Total Mercury and TCLP Result
Sample ID
True
VOfL
Found
\Ug/L
Percent
Recovery
EPD
%
Dilution
Factor
Reported Re suit
M-g/L
TCLP Re suits
LCS 10/27/97
Spike 10/27/97
LCS 02/13/98
LCS 05/15/98
LCS 11/14/98
LCS 11/23/98
5.00
5.00
5.00
5.00
5.00
5.00
4.20
4.50
4.95
4.90
4.57
4.40
84.0
90.0
99.0
98.0
91.4
88.0
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
nr
Total Mercury Results
LCS 10/27/97
Spike 10/27/97
5.00
5.00
4.70
4.95
94.0
99.0
nr
nr
nr
nr
nr
nr
  nr = not reported
                                           -14-

-------
4.5.2 Landfill Data





        The data presented in Table 1.2, are defined as secondary data by EPA Order 5360.1 CHG 1, July





1998. No QC information is available. No detection limit value is available. No information is available





on the generation of leachate. Only a single  pH value was provided and labeled as an average. Insufficient





detail is available to assess these secondary data.





4.5.3 Characterization Data





        Twelve samples of BCP sludge were collected by UC and EPA on November 19, 1998 and





composited prior to sending off a sample to  Environmental Enterprises Inc. (EEI) for total mercury





analysis. Table 4.2 summarizes the laboratory QC data for the single mercury result reported in Table 2.1.





The calibration  curve was established using  mercury standards of 0.50, 2.00, 5.00, 10.00 and 40.00 Jig/L,





with a corresponding correlation coefficient of 0.9993. Initial and continuing calibration standards and





blanks were within the control limits. The mercury recovery on the LCS was below the lower limit of 85





percent, and the RPD for the sample and duplicate exceeds the limit of 25 percent. Data pertaining to a





laboratory spike were absent.





               Table 4.2 Laboratory QC Data  for EEI Total Mercury Result
Sample ID
True
M-S/L
Found
M€^
Percent
Recovery
RPD
%
Dilution
Factor
Reported Result
LLg/kg
Work Order 99-02-413: T otal Mercury Results
ICV
CCV1
CCV2
CCV3
LCS
ICB
CCB1
CCB2
CCB3
01A
OlA-du plicate
5.00
5.00
5.00
5.00
3,300
<0.50
<0.50
<0.50
<0.50
—
—
4.78
4.64
4.58
4.58
2,764
<0.5Q
<0.5Q
<0.5Q
<0.50
9.24
6.96
95.6
92.8
91.6
91.6
83.8
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
28.2
—
—
—
—
—
—
—
—
—
1,000,000
1,000,000
—
—
—
—
—
—
—
—
—
9,240,000
6,960,000
   A sample spike was not performed.
                                           -15-

-------
4.5.4 Thermo gravimetric Analysis





        Plans for conducting thermogravimetric analyses were not included in the EPA approved Quality





Assurance Project Plan. Calibration information is provided in Section 2.1.4.





4.5.5 Solid Stability in Water





        Prior to use,  the pH meter was calibrated using a two-point calibration with certified calibration





standards, pH 4 and pH 10. The calibration efficiency, defined as the measured value divided by the





known value, is 1.0097, which is in the range of 1.05 to 0.95 from the QAPP. The experimental blank was





run with other samples, but not sent out for Hg analysis. For Hg analysis, these samples were grouped with





samples from the  constant pH leaching test. Therefore, QC results of this grouping are  presented in Section





4.5.7.





4.5.6 Acidity





        Prior to the titration, the pH meter was calibrated using a two-point calibration with certified





calibration standards,  pH 4 and pH 10. The calibration efficiency has a value of 1.02 and is in the range of





1.05 to 0.95, per the QAPP.





4.5. 7 Toxicity Characteristic Leaching Procedure





        TCLP was performed on six separate grab BCP sludge samples. The pH meter calibration





efficiency is 0.98, and is in the range of 1.05 to 0.95, per the QAPP. Mercury concentration  of the method





blank is <0.50 jig/L.





        Table 4.3 summarizes the laboratory QC data for the total mercury in the solid and  TCLP results





reported in Table 3.3. The calibration curve was established using mercury standards of 0.50, 2.00, 5.00,





10.00 and 40.00 jig/L, with a corresponding correlation coefficient of 0.9993 for  total mercury results and





0.9997 for TCLP  results. Initial and continuing calibration standards and blank-16-s were within the





control limits, as was  the LCS. The RPD  for the TCLP sample and duplicate exceeds the  limit of 25





percent. Data pertaining to a laboratory spike were absent.
                                            -16-

-------
      Table 4.3 Laboratory QC Data for EEI Total Mercury and TCLP Result
Sample ID
True
Hg
-------
4.5.8 Constant pH Based Leaching Test





        Prior to titration, the pH meter was calibrated using a two-point calibration with certified calibra-





tion standards, pH 4 and pH 10. All calibration efficiencies are in the range of 1.05 to 0.95 from the





QAPP.





        A test duplicate  was run for pH 8. The sample collected at 2 hours for the duplicate run was not





analyzed.  The RPDs for 10 hours and 24 hours are 42% and 111% respectively, which reflects the





variability in homogeneity of the BCP sludge.





        Hg concentrations for all experimental blanks are <1.00 jig/L, except for pH 8 runs. The





experimental blanks forpH 8 have Hg concentration of 2.74 jig/L and 1.06 Jig/L (test duplicates), which





indicates very low contamination.





        Table 4.4 summarizes the laboratory QC data for the total mercury and TCLP results reported in





Tables 3.1 and 3.4. The calibration curve was established using mercury standards of 0.50, 2.00, 5.00,





10.00 and 40.00 jig/L, with a corresponding correlation coefficient of 0.9996 for Work Order 99-03-404





and 0.9997 for the other work orders. Initial and continuing calibration standards and blanks were within





the control limits, as was  the LCS. There were no RPD or spike results reported for Work Order 99-03-





404. The sample and duplicate for the remaining work orders contained mercury below the detection limit





of 0.50 jig/L, and no RPD value was calculated. Results for the spike are within control limits.
                                           -18-

-------
                      Table 4.4 Laboratory QC Data for EEI Total Mercury Results
Sample ID
True
H-8/L
Found
[ig/L
Percent
Recovery
RPD
%
Dilution
Factor
Reported Result
M-g/L
Work Order 99 03-404
ICV
CCV1
CCV2
CCV3
CCV4
LCS
ICB
CCB1
CCB2
CCB3
CCB4
5.00
5.00
5.00
5.00
5.00
10.00
<0.50
<0.50
<0.50
<0.50
<0.50
5. Id
4.95
4.78
4.84
4.64
9.82
<0.50
<0.50
<0.50
<0.50
<0.50
103
99.0
95.6
96.8
92.8
98.2
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
Work Orders 99 03 494 & 99-03-556
ICV
CCV1
CCV2
CCV3
CCV4
LCS
ICB
CCB1
CCB2
CCB3
CCB4
03A
03 A -duplicate
03A-spike
5.00
5.00
5.00
5.00
5.00
10.00
<0.50
<0.5Q
<0.50
<0.50
<0.5Q
—
—
5.00
4.92
4.84
4.89
4.82
4.55
9.15
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
5.10
98.4
96.8
97.8
96.4
91.0
91.5
—
—
—
—
—
—
—
102
—
—
—
—
—
—
—
—
—
—
—
NC
NC
—
—
—
—
—
—
—
—
—
—
—
—
2
2
—
—
—
—
—
—
—
—
—
—
—
—
<1.00
<1.00
—
A sample duplicate and spike are not available for samples associated with Work Order 99-03-404.




NC - not calculated because sample and duplicate are below the detection limit.
                                                  -19-

-------