xvEPA
           United States
           Environmental Protection
           Agency
          Office of
          Solid Waste
          Washington, D C 20460
EPA/530-SW-88-0009-g
April 1988
          Solid Waste
Best
Demonstrated
Available Technology
(BOAT) Background
Document for
Aniline Production
Treatability Group
(K103, K104)
Proposed
          Volume 7

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"*-.,
;1
X                                         FINAL
                    BEST DEMONSTRATED AVAILABLE TECHNOLOGY  (BOAT)
                        BACKGROUND DOCUMENT  FOR K103 AND K104
                                        Volume 7
                        U.  S.  Environmental Protection Agency
                                 Office of Solid Waste
                                   401 M Street,  S.W.
                                 Washington,  D.C.  20460
         James R. Berlow,  Chief
         Treatment Technology Section
                                       April  1988
                       U.S. Environmental Protection Agency
                       Keg'on 5, Library (PL-12J)
                       ff West Jackson Boulevard  12th Floor
                       <-h
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            BOAT  BACKGROUND DOCUMENT FOR K103 and K104
                        TABLE OF CONTENTS
VOLUME 7                                                     Page

Executive Summary 	      i

BOAT Treatment Standards for K103 and K104	     vii

SECTION 1.  Introduction  	     1-1

SECTION 2.  Industries Affected and Waste
            Characterization  	     2-1

SECTION 3.  Demonstrated/Applicable Treatment
            Technologies  	     3-1

SECTION 4.  Selection of BOAT	     4-1

SECTION 5.  Determination of Regulated Constituents .  .   .     5-1

SECTION 6.  Calculation of Treatment Standard   	     6-1

SECTION 7.  Conclusions 	     7-1

APPENDIX A  Statistical Analysis  	     A-l

APPENDIX B  Analysis of Variance Tests  	     B-l

APPENDIX C  Detection Limits for Constituents in the
            Untreated and Treated Waste 	     C-l

APPENDIX D  Calculation of Treatment Standards  	     D-l

APPENDIX E  Analytical QA/QC  	     E-l

APPENDIX F  Thermal Conductivity Summary  	     F-l
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                        EXECUTIVE SUMMARY







           BDAT Treatment Standards  for  K103 and K104








     Pursuant to the Hazardous and Solid Waste Amendments (HSWA)



enacted on November 8, 1984, and in accordance with the



procedures for establishing treatment standards under section



3004 (m) of the Resource Conservation and Recovery Act (RCRA),



the Environmental Protection Agency  (EPA) is proposing treatment



standards for the listed wastes, K103 and K104, based on the



performance of treatment technologies determined by the Agency to



represent Best Demonstrated Available Technology (BDAT).  This



background document provides the detailed analyses that support



this determination.







     These BDAT treatment standards represent maximum acceptable



concentration levels  for selected hazardous constituents in the



wastes or residuals from treatment and/or recycling.  These



levels are established as a prerequisite for disposal of these



wastes in units designated as land disposal units according to 40



CFR 268  (Code of Federal Regulations).  Wastes which, as



generated, contain the regulated constituents at concentrations



which do not exceed the treatment standards are not restricted



from land disposal units.  The Agency has chosen to set levels



for these wastes rather than designating the use of a specific



treatment technology.  The Agency believes that this allows the










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generators of these wastes a greater degree of flexibility in

selecting a technology or train of technologies that can achieve

these levels.  These standards become effective as of August 8,

1988, as described in the schedule set forth in 40 CFR 268.10.



     According to 40 CFR 261.32 (hazardous wastes from specific

sources) waste codes K103 and K104 are from the

nitrobenzene/aniline industry and are listed as follows:


     K103:     Process residues from aniline extraction from the
               production of aniline.

     K104:     Combined wastewater streams generated from
               nitrobenzene/aniline production.


     Descriptions of the industry and specific processes

generating these wastes, as well as descriptions of the physical

and chemical waste characteristics, are provided in Section 2.0

of this document.  The four digit Standard Industrial

Classification (SIC)  code most often reported for the industry

generating this waste code is 2869 (nitrobenzene/aniline).   The

Agency estimates that there are six facilities that may

potentially generate wastes identified as K103-K104.



     The Agency has determined that K103/K104 collectively

represent one general treatability group with two subgroups -

wastewaters and nonwastewaters.  For the purpose of the land

disposal restrictions rule,  wastewaters are defined as wastes

containing less than 1% (weight basis)  filterable solids and less
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than 1% (weight basis) total organic carbon (TOC).  For K103 and

K104 wastes, this definition was amended to include wastewaters

with a TOC content up to 4% (weight basis).  Wastes not meeting

this definition are classified as nonwastewaters.




     These treatability subgroups represent classes of wastes

that have similar physical and chemical properties within each

subgroup.  EPA believes that each waste within these subgroups

can be treated to the same concentrations when similar

technologies are applied.  The Agency has examined the sources of

these two wastes from the nitrobenzene/aniline industry, the

specific similarities in waste composition, potential applicable

and demonstrated technologies, and attainable treatment

performance in order to support a simplified regulatory approach.

While the Agency has not, at this time, specifically identified

additional wastes which would fall into this treatability group

or two subgroups, this does not preclude the Agency from

extrapolating these standards to other wastes, in the future.




     The K103 and K104 wastes, as generated, have a high water

content and are typically classified as wastewaters.  Residues

from the treatment of these wastewaters (such as spent carbon and

the nitrobenzene solvent stream from the nitrobenzene
                                        V
liquid/liquid extractor) are classified as nonwastewaters.  The

K103/K104 nonwastewaters are generated primarily as a result of

the "derived-from rule" and the "mixture-rule" as outlined in 40
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CFR 261.3 (definition of hazardous waste).



     The Agency has proposed BOAT treatment standards for the two

treatability subgroups of the K103 and K104 wastes - wastewaters

and nonwastewaters.  In general, these treatment standards have

been proposed for a total of five (5)  organic constituents. In

addition, a treatment standard has been proposed for one (1)

inorganic constituent in K104.   The organic constituents that are

proposed for regulation in K103 and K104 wastes codes are as

follows: benzene, aniline, 2,4-dinitrophenol, nitrobenzene, and

phenol.  Total cyanides were also proposed for regulation in

K104.  Sulfide was not proposed for regulation in K103 because

the Agency requires additional analytical data on sulfide to

determine if it was effectively treated by the treatment system.

A detailed discussion of the selection of constituents to be

regulated is presented in Section 5.0 of this document.



     BDAT treatment standards for wastewater K103 and K104 are

proposed based on performance data from a treatment train which

consisted of liquid/liquid extraction followed by steam stripping

and activated carbon adsorption.  Testing was performed on

representative samples of K103 and K104.  Liquid/liquid

extraction followed by steam stripping and activated carbon
                                        v-
adsorption was determined to represent the best demonstrated

available technology (BDAT).  This determination was based on a

statistical comparison of performance data.  The Agency collected




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performance data for a treatment train consisting of



liquid/liquid extraction followed by steam stripping and carbon



adsorption.  A statistical comparison was done with this



performance data from liquid/liquid extraction followed by steam



stripping and from liquid/liquid extraction alone.  Based on this



analysis, the Agency has determined that the data for



liquid/liquid extraction followed by steam stripping and



activated carbon adsorption indicated the highest level of



performance.








     BOAT treatment standards for K103 and K104 nonwastewaters



are proposed based on a transfer of treatment standards developed



for K048/K051 nonwastewaters (dissolved air flotation float and



API separator sludge from the petroleum industry).  These



standards were developed based on the incineration of K048/K051



nonwastewaters.  Treatment data were transferred on a constituent



basis from either the same constituent or from constituents



judged to be similar in physical and chemical properties.  A



detailed discussion of the transfer of the data and methodology



is presented in Section 6.0 of this document.







     The following tables list the specific BOAT treatment



standards for wastes identified as K103 and K104.  The Agency is



setting standards based on analyses of total composition for both



wastewater and nonwastewater forms of K103 and K104.  The units



for total composition analysis are in parts per million (mg/kg)
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on a weight by weight basis for nonwastewaters.   For wastewaters



the units are expressed on a weight per unit volume basis (mg/1).



Testing procedures are specifically identified in the quality



assurance sections of this document.
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          BOAT TREATMENT STANDARDS FOR K103/K104 WASTES

                           WASTEWATER
Regulated Constituents
Total Composition (mg/1)

K103             K104
Benzene
Aniline
2 , 4-Dinitrophenol
Nitrobenzene
Phenol
Total Cyanides (CN)
0.147
4.450
0.613
0.073
1.391
NR
0.147
4.450
0.613
0.073
1.391
2.683
NR = Not regulated since it is not presented at treatable levels.
                          NONWASTEWATER
      (Nonwastewater forms of K103/K104 represent spent
     carbon from the activated carbon adsorber.  Treatment
     standards were transferred from K019 for benzene,
     aniline, 2,4-dinitrophenol, nitrobenzene, and phenol
     and from K048/K051 for total cyanides).
Regulated Constituents
Total Composition (mq/kg)

K103             K10'
Benzene
Aniline
2 , 4-Dinitrophenol
Nitrobenzene
Phenol
Total Cyanides (CN)
5.96
5.44
5.44
5.44
5.44
NR
5.96
5.44
5.44
5.44
5.44
1.48
NR = Not regulated since it is not present at treatable levels.
                               VII
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                         1.  INTRODUCTION







     This section of the background document presents a summary



of the legal authority pursuant to which the BDAT treatment



standards were developed, a summary of EPA's promulgated



methodology for developing BOAT, and finally a discussion of the



petition process that should be followed to request a variance



from the BDAT treatment standards.







1.1            Legal Background



1.1.1          Requirements Under HSWA







     The Hazardous and Solid Waste Amendments of 1984 (HSWA),



enacted on November 8, 1984, and which amended the Resource



Conservation and Recovery Act of 1976 (RCRA), impose substantial



new responsibilities on those who handle hazardous waste.  In



particular, the amendments require the Agency to promulgate



regulations that restrict the land disposal of untreated



hazardous wastes.  In its enactment of HSWA, Congress stated



explicitly that "reliance on land disposal should be minimized or



eliminated, and land disposal, particularly landfill and surface



impoundment, should be the least favored method for managing



hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C.



6901(b)(7)).
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     One part of the amendments specifies dates on which



particular groups of untreated hazardous wastes will be



prohibited from land disposal unless "it has been demonstrated to



the Administrator, to a reasonable degree of certainty, that



there will be no migration of hazardous constituents from the



disposal unit or injection zone for as long as the wastes remain



hazardous" (RCRA section 3004(d)(1), (e)(1), (g)(5), 42 U.S.C.



6924 (d)(l),  (e)(1), (g)(5)).








     For the purpose of the restrictions,  HSWA defines land



disposal "to include, but not be limited to, any placement of ...



hazardous waste in a landfill,  surface impoundment, waste pile,



injection well, land treatment facility, salt dome formation,



salt bed formation, or underground mine or cave" (RCRA section



3004(k), 42 U.S.C. 6924(k)).  Although HSWA defines land disposal



to include injection wells, such disposal of solvents, dioxins,



and certain other wastes,  known as the California List wastes, is



covered on a separate schedule (RCRA section 3004(f)(2), 42



U.S.C.  6924 (f)(2)).  This schedule requires that EPA develop



land disposal restrictions for deep well injection by



August 8, 1988.







     The amendments also require the Agency to set "levels or



methods of treatment, if any, which substantially diminish the



toxicity of the waste or substantially reduce the likelihood of



migration of hazardous constituents from the waste so that
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short-term and long-term threats to human health and the



environment are minimized" (RCRA section 3004(m)(l), 42 U.S.C.



6924 (m)(l)).  Wastes that meet treatment standards established



by EPA are not prohibited and may be land disposed.  In setting



treatment standards for listed or characteristic wastes, EPA may



establish different standards for particular wastes within a



single waste code with differing treatability characteristics.



One such characteristic is the physical form of the waste.  This



frequently leads to different standards for wastewaters and



nonwastewaters.







     Alternatively, EPA can establish a treatment standard that



is applicable to more than one waste code when, in EPA's



judgment, all the waste can be treated to the same concentration.



In those instances where a generator can demonstrate that the



standard promulgated for the generator's waste cannot be



achieved, the Agency also can grant a variance from a treatment



standard by revising the treatment standard for that particular



waste through rulemaking procedures.  (A further discussion of



treatment variances is provided in Section 1.3.)







     The land disposal restrictions are effective when



promulgated unless the Administrator grants a national variance



and establishes a different date (not to exceed 2 years beyond



the statutory deadline) based on "the earliest date on which



adequate alternative treatment, recovery, or disposal capacity
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which protects human health and the environment will be



available" (RCRA section 3004(h)(2), 42 U.S.C. 6924 (h)(2)).







     If EPA fails to set a treatment standard by the statutory



deadline for any hazardous waste in the First Third or Second



Third of the schedule (see section 1.1.2),  the waste may not be



disposed in a landfill or surface impoundment unless the facility



is in compliance with the minimum technological requirements



specified in section 3004(o) of RCRA.  In addition, prior to



disposal, the generator must certify to the Administrator that



the availability of treatment capacity has been investigated and



it has been determined that disposal in a landfill or surface



impoundment is the only practical alternative to treatment



currently available to the generator.  This restriction on the



use of landfills and surface impoundments applies until EPA sets



a treatment standard for the waste or until May 8, 1990,



whichever is sooner.  If the Agency fails to set a treatment



standard for any ranked hazardous waste by May 8, 1990, the waste



is automatically prohibited from land disposal unless the waste



is placed in a land disposal unit that is the subject of a



successful "no migration" demonstration (RCRA section 3004(g), 42



U.S.C. 6924(g)).  "No migration" demonstrations are based on



case-specific petitions that show there will be no migration of



hazardous constituents from the unit for as long as the waste



remains hazardous.
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1.1.2          Schedule for Developing Restrictions



     Under Section 3004(g) of RCRA, EPA was required to establish

a schedule for developing treatment standards for all wastes that

the Agency had listed as hazardous by November 8, 1984.

Section 3004(g) required that this schedule consider the

intrinsic hazards and volumes associated with each of these

wastes.  The statute required EPA to set treatment standards

according to the following schedule:


     (a)  Solvents and dioxins standards must be promulgated by
               November 8, 1986;

     (b)  The "California List" must be promulgated by July 8,
          1987;

     (c)  At least one-third of all listed hazardous wastes must
          be promulgated by August 8, 1988 (First Third);

     (d)  At least two-thirds of all listed hazardous wastes aust
          be promulgated by June 8, 1989  (Second Third); and

     (e)  All remaining listed hazardous wastes and all hazardous
          wastes identified as of November 8, 1984, by one or
          more of the characteristics defined in 40 CFR Part 261
          must be promulgated by May 8, 1990 (Third Third).


     The statute specifically identified the solvent wastes as

those covered under waste codes F001, F002, F003, F004, and F005;

it identified the dioxin-containing hazardous wastes as those

covered under waste codes F020, F021, F022, and F023.



     Wastes collectively known as the California List wastes,

defined under Section 3004(d) of HSWA, are liquid hazardous

wastes containing metals, free cyanides, PCBs, corrosives  (i.e.,



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a pH less than or equal to 2.0), and any liquid or nonliquid



hazardous waste containing halogenated organic compounds (HOCs)



above 0.1 percent by weight.  Rules for the California List were



proposed on December 11, 1986, and final rules for PCBs,



corrosives, and HOC-containing wastes were established



August 12, 1987.  In that rule, EPA elected not to establish



standards for metals.  Therefore, the statutory limits became



effective.








     On May 28, 1986, EPA published a final rule (51 FR 19300)



that delineated the specific waste codes that would be addressed



by the First Third, Second Third, and Third Third.   This schedule



is incorporated into 40 CFR 268.10, .11, and .12.







1.2       Summary of Promulgated BOAT Methodology







     In a November 7, 1986, rulemaking, EPA promulgated a



technology-based approach to establishing treatment standards



under section 3004(m).   Section 3004(m) also specifies that



treatment standards must "minimize" long- and short-term threats



to human health and the environment arising from land disposal of



hazardous wastes.








     Congress indicated in the legislative history accompanying



the HSWA that "[t]he requisite levels of [sic]  methods of



treatment established by the Agency should be the best that has










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been demonstrated to be achievable," noting that the intent is

"to require utilization of available technology" and not a

"process which contemplates technology-forcing standards"  (Vol.

130 Cong. Rec. S9178 (daily ed., July 25, 1984)).  EPA has

interpreted this legislative history as suggesting that Congress

considered the requirement under 3004(m) to be met by application

of the best demonstrated and achievable  (i.e., available)

technology prior to land disposal of wastes or treatment

residuals.  Accordingly, EPA's treatment standards are generally

based on the performance of the best demonstrated available

technology  (BOAT) identified for treatment of the hazardous

constituents.  This approach involves the identification of

potential treatment systems, the determination of whether they

are demonstrated and available, and the collection of treatment

data from well-designed and well-operated systems.




     The treatment standards, according to the statute, can

represent levels or methods of treatment, if any, that

substantially diminish the toxicity of the waste or substantially

reduce the  likelihood of migration of hazardous constituents.

Wherever possible, the Agency prefers to establish BDAT treatment

standards as "levels" of treatment  (i.e., performance standards)

rather than adopting an approach that would require the use of
                                         *•
specific treatment "methods."  EPA believes that

concentration-based treatment levels offer the regulated

community greater flexibility to develop and implement compliance





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strategies as well as an incentive to develop innovative

technologies.




1.2.1     Waste Treatability Group




     In developing the treatment standards, EPA first

characterizes the waste(s).  As necessary, EPA may establish

treatability groups for wastes having similar physical and

chemical properties.  That is, if EPA believes that wastes


represented by different waste codes could be treated to similar

concentrations using identical technologies, the Agency combines

the codes into one treatability group.  EPA generally considers

wastes to be similar when they are both generated from the same

industry and from similar processing stages.  In addition, EPA

may combine two or more separate wastes into the same

treatability group when data are available showing that the waste

characteristics affecting performance are similar or that one

waste would be expected to be less difficult to treat.




     Once the treatability groups have been established,  EPA

collects and analyzes data on identified technologies used to

treat the wastes in each treatability group.  The technologies

evaluated must be demonstrated on the waste or a similar waste
                                        V
and must be available for use.
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1.2.2          Demonstrated and Available Treatment Technologies




     Consistent with legislative history, EPA considers

demonstrated technologies to be those that are used to treat the

waste of interest or a similar waste with regard to parameters

that affect treatment selection (see November 7, 1986, 51 FR

40588).   EPA also will consider as treatment those technologies

used to separate or otherwise process chemicals and other

materials.  Some of these technologies clearly are applicable to

waste treatment, since the wastes are similar to raw materials

processed in industrial applications.




     For most of the waste treatability groups for which EPA will

promulgate treatment standards, EPA will identify demonstrated


technologies either through review of literature related to

current waste treatment practices or on the basis of information

provided by specific facilities currently treating the waste or


similar wastes.




     In cases where the Agency does not identify any facilities

treating wastes represented by a particular waste treatability

group, EPA may transfer a finding of demonstrated treatment.  To

do this, EPA will compare the parameters affecting treatment
                                         V
selection for the waste treatability group of interest to other

wastes for which demonstrated technologies already have been


determined.  The parameters affecting treatment selection and
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their use for this waste are described in Section 3.2 of this



document.  If the parameters affecting treatment selection are



similar, then the Agency will consider the treatment technology



also to be demonstrated for the waste of interest.  For example,



EPA considers rotary kiln incineration a demonstrated technology



for many waste codes containing hazardous organic constituents,



high total organic content, and high filterable solids content,



regardless of whether any facility is currently treating these



wastes.  The basis for this determination is data found in



literature and data generated by EPA confirming the use of rotary



kiln incineration on wastes having the above characteristics.







     If no commercial treatment or recovery operations are



identified for a waste or wastes with similar physical or



chemical characteristics that  affect treatment selection, the



Agency will be unable to identify any demonstrated treatment



technologies for the waste, and, accordingly, the waste will be



prohibited from land disposal (unless handled in accordance with



the exemption and variance provisions of the rule).   The Agency



is, however, committed to establishing treatment standards as



soon as new or improved treatment processes are demonstrated (and



available).








     Operations only available at research facilities, pilot- and



bench- scale operations will not be considered in identifying



demonstrated treatment technologies for a waste because these
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technologies would not necessarily be "demonstrated."

Nevertheless, EPA may use data generated at research facilities

in assessing the performance of demonstrated technologies.




     As discussed earlier, Congress intended that technologies

used to establish treatment standards under Section 3004(m) be

not only "demonstrated," but also available.  To decide whether

demonstrated technologies may be considered "available," the

Agency determines whether they (1) are commercially available and

(2) substantially diminish the toxicity of the waste or

substantially reduce the likelihood of migration of hazardous

constituents from the waste.




     EPA will only set treatment standards based on a technology

that meets the above criteria.  Thus, the decision to classify a

technology as "unavailable" will have a direct impact on the

treatment standard.  If the best technology is unavailable, the

treatment standard will be based on the next best treatment

technology determined to be available.  To the extent that the

resulting treatment standards are less stringent, greater

concentrations of hazardous constituents in the treatment

residuals could be placed in land disposal units.



                                         «•
     There also may be circumstances in which EPA concludes that

for a given waste none of the demonstrated treatment technologies

are "available" for purposes of establishing the 3004(m)





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treatment performance standards.  Subsequently,  these wastes will

be prohibited from continued placement in or on the land unless

managed in accordance with applicable exemptions and variance

provisions.  The Agency is, however, committed to establishing

new treatment standards as soon as new or improved treatment

processes become "available."




     (1)  Proprietary or Patented Processes.  If the demonstrated

treatment technology is a proprietary or patented process that is

not generally available, EPA will not consider the technology in

its determination of the treatment standards.  EPA will consider

proprietary or patented processes available if it determines that

the treatment method can be purchased or licensed from the

proprietor or is commercially available treatment.  The services

of the commercial facility offering this technology often can be

purchased even if the technology itself cannot be purchased.




     (2)  Substantial Treatment.  To be considered "available," a

demonstrated treatment technology must "substantially diminish

the toxicity" of the waste or "substantially reduce the

likelihood of migration of hazardous constituents" from the waste

in accordance with section 3004(m).  By requiring that

substantial treatment be achieved in order to set a treatment
                                        V
standard, the statute ensures that all wastes are adequately

treated before being placed in or on the land and ensures that

the Agency does not require a treatment method that provides





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little or no environmental benefit.  Treatment will always be

deemed substantial if it results in nondetectable levels of the

hazardous constituents of concern.  If nondetectable levels are

not achieved, then a determination of substantial treatment will

be made on a case-by-case basis.  This approach is necessary

because of the difficulty of establishing a meaningful guideline

that can be applied broadly to the many wastes and technologies

to be considered.  EPA will consider the following factors in an

effort to evaluate whether a technology provides substantial

treatment on a case-by-case basis:


      (a)  Number and types of constituents treated;

      (b)  Performance  (concentration of the constituents in the
          treatment residuals); and

      (c)  Percent of constituents removed.



     If none of the demonstrated treatment technologies achieve

substantial treatment of a waste, the Agency cannot establish

treatment standards for the constituents of concern in that

waste.



1.2.3          Collection of Performance Data



     Performance data on the demonstrated available technologies

are evaluated by the Agency to determine whether the data are

representative of well-designed and well-operated treatment

systems.  Only data from well-designed and well-operated systems




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are included in determining BOAT.  The data evaluation includes



data already collected directly by EPA and/or data provided by



industry.  In those instances where additional data are needed to



supplement existing information, EPA collects additional data



through a sampling and analysis program.  The principal elements



of this data collection program are:  (a)  identification of



facilities for site visits, (b) engineering site visit,



(c) Sampling and Analysis Plan, (d) sampling visit, and (e)



Onsite Engineering Report.







     (1)  Identification of Facilities for Site Visits.  To



identify facilities that generate and/or treat the waste of



concern, EPA uses a number of information sources.  These include



Stanford Research Institute's Directory of Chemical Producers,



EPA's Hazardous Waste Data Management System (HWDMS), the 1986



Treatment, Storage, Disposal Facility (TSDF) National Screening



Survey, and EPA's Industry Studies Data Base.  In addition, EPA



contacts trade associations to inform them that the Agency is



considering visits to facilities in their industry and to solicit



assistance in identifying facilities for EPA to consider in its



treatment sampling program.







     After identifying facilities that treat the waste, EPA uses



this hierarchy to select sites for engineering visits:



(1) generators treating single wastes on site; (2) generators



treating multiple wastes together on site;  (3) commercial










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treatment, storage, and disposal facilities (TSDFs); and (4) EPA



in-house treatment.  This hierarchy is based on two concepts:



(1) to the extent possible, EPA should develop treatment



standards from data produced by treatment facilities handling



only a single waste, and (2) facilities that routinely treat a



specific waste have had the best opportunity to optimize design



parameters.  Although excellent treatment can occur at many



facilities that are not high in this hierarchy, EPA has adopted



this approach to avoid, when possible, ambiguities related to the



mixing of wastes before and during treatment.







     When possible, the Agency will evaluate treatment



technologies using commercially operated systems.  If performance



data from properly designed and operated commercial treatment



methods for a particular waste or a waste judged to be similar



are not available, EPA may use data from research  facilities



operations.  Whenever research facility data are used, EPA will



explain why such data were used in the preamble and background



document and will request comments on the use of such data.







     Although EPA's data bases provide information on treatment



for individual wastes, the data bases rarely provide data that



support the selection of one facility for sampling over another.



In cases where several treatment sites appear to fall into the



same level of the hierarchy, EPA selects sites for visits



strictly on the basis of which facility could most expeditiously










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be visited and later sampled if justified by the engineering



visit.








      (2)  Engineering Site Visit.  Once a treatment facility has



been selected, an engineering site visit is made to confirm that



a candidate for sampling meets EPA's criteria for a well-designed



facility and to ensure that the necessary sampling points can be



accessed to determine operating parameters and treatment



effectiveness.  During the visit, EPA also confirms that the



facility appears to be well operated, although the actual



operation of the treatment system during sampling is the basis



for EPA's decisions regarding proper operation of the treatment



unit.  In general, the Agency considers a well-designed facility



to be one that contains the unit operations necessary to treat



the various hazardous constituents of the waste as well as to



control other nonhazardous materials in the waste that may affect



treatment performance.







     In addition to ensuring that a system is reasonably well



designed, the engineering visit examines whether the facility has



a way to measure the operating parameters that affect performance



of the treatment system during the waste treatment period.  For



example, EPA may choose not to sample a treatment system that



operates in a continuous mode,  for which an important operating



parameter cannot be continuously recorded.   In such systems,



instrumentation is important in determining whether the treatment
                              1-16                         Rev. 3

-------
system is operating at design values during the waste treatment



period.







     (3)  Sampling and Analysis Plan.  If after the engineering



site visit the Agency decides to sample a particular plant, the



Agency will then develop a site-specific Sampling and Analysis



Plan (SAP) according to the Generic Quality Assurance Project



Plan for the Land Disposal Restriction Program ("BOAT"),



EPA/530-SW-87-011.  In brief, the SAP discusses where the Agency



plans to sample, how the samples will be taken, the frequency of



sampling, the constituents to be analyzed and the method of



analysis, operational parameters to be obtained, and specific



laboratory quality control checks on the analytical results.







     The Agency will generally produce a draft of the



site-specific Sampling and Analysis Plan within 2 to 3 weeks of



the engineering visit.  The draft of the SAP is then sent to the



plant  for review and comment.  With few exceptions, the draft SAP



should  be a confirmation of data collection activities discussed



with the plant personnel during the engineering site visit.  EPA



encourages plant personnel to recommend any modifications to the



SAP that they believe will improve the quality of the data.







     It is important to note that sampling of a plant by EPA does



not mean that the data will be used  in the development of



treatment standards for BOAT.  EPA's final decision on whether to
                               1-17                         Rev.  3

-------
use data from a sampled plant depends on the actual analysis of

the waste being treated and on the operating conditions at the

time of sampling.  Although EPA would not plan to sample a

facility that was not ostensibly well-designed and well-operated,

there is no way to ensure that at the time of the sampling the

facility will not experience operating problems.  Additionally,

EPA statistically compares its test data to suitable

industry-provided data, where available, in its determination of

what data to use in developing treatment standards.  The

methodology for comparing data is presented later in this

section.




     (Note: Facilities wishing to submit data for consideration

in the development of BOAT standards should, to the extent

possible, provide sampling information similar to that acquired

by EPA.  Such facilities should review the Generic Quality

Assurance Project Plan for the Land Disposal Restriction Program

("BOAT"), which delineates all of the quality control and quality

assurance measures associated with sampling and analysis.

Quality assurance and quality control procedures are summarized

in Section 1.2.6 of this document.)




     (4)  Sampling Visit.  The purpose of the sampling visit is
                                        v
to collect samples that characterize the performance of the

treatment system and to document the operating conditions that

existed during the waste treatment period.  At a minimum, the
                               1-18                         Rev. 3

-------
Agency attempts to collect sufficient samples of the untreated



waste and solid and liquid treatment residuals so that



variability in the treatment process can be accounted for in the



development of the treatment standards.  To the extent



practicable, and within safety constraints, EPA or its



contractors collect all samples and ensure that chain-of-custody



procedures are conducted so that the integrity of the data is



maintained.







     In general, the samples collected during the sampling visit



will have already been specified in the SAP.  In some instances,



however, EPA will not be able to collect all planned samples



because of changes in the facility operation or plant upsets; EPA



will explain any such deviations from the SAP in its follow-up



Onsite Engineering Report.







      (5)  Onsite Engineering Report.  EPA summarizes all  its data



collection activities and associated analytical results for



testing at a facility in a report referred to as the Onsite



Engineering Report  (OER).  This report characterizes the  waste(s)



treated, the treated residual concentrations, the design  and



operating data, and all analytical results including methods used



and accuracy results.  This report also describes any deviations



from EPA's suggested analytical methods for hazardous wastes



 (Test Methods  for Evaluating Solid Waste, SW-846, Third Edition,



November 1986).









                               1-19                        Rev.  3

-------
     After the Onsite Engineering Report is completed, the report



is submitted to the plant for review.  This review provides the



plant with a final opportunity to claim any information contained



in the report as confidential.  Following the review and



incorporation of comments, as appropriate, the report is made



available to the public with the exception of any material



claimed as confidential by the plant.








1.2.4     Hazardous Constituents Considered and Selected for



          Regulation








     (1)  Development of BOAT List.  The list of hazardous



constituents within the waste codes that are targeted for



treatment is referred to by the Agency as the BOAT constituent



list.  This list, provided as Table 1-1, is derived from the



constituents presented in 40 CFR Part 261, Appendix VII and



Appendix VIII, as well as several ignitable constituents used as



the basis of listing wastes as F003 and F005.   These sources



provide a comprehensive list of hazardous constituents



specifically regulated under RCRA.   The BOAT list consists of



those constituents that can be analyzed using methods published



in SW-846, Third Edition.








     The initial BOAT constituent list was published in EPA's



Generic Quality Assurance Project Plan, March 1987



(EPA/53O-SW-87-011).   Additional constituents will be added to
                              1-20                         Rev. 3

-------
ISZlg
                  Table 1-1  BOAT Constituent List
BOAT
reference
no.

222.
1.
2.
3.
4.
5.
6.
223.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224.
225.
226.
30.
227.
31.
214
32.
Parameter
Volatiles
Acetone
Acetonitri le
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-l,3-butad7ene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
l,2-Dibromo-3-ch?oropropane
1,2-Dibromoethane
Dibromomethane
Trans-1 ,4-Dichloro-2-butene
Dichlorod if luoromethane
1 , 1-Dichloroethane
1 ,2-Oichloroethane
1 ,1-Dichloroethylene
Trans-1 ,2-Oichloroethene
1,2-Oichloropropane
Trans-1 ,3-Dichloropropene
cis-1 ,3-Oichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
Cas no.

67-64-1
75-05-8
107-03-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110-75-8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-95-3
110-57-6
75-71-8
75-34-3
107-06-2
75-35-4
156-60-5
78-87-5
10061-02-6
10061-01-5
123-91-1
60-29-7
141-78-6
100-41-4
107-12-D
60-29-7
97-63-2
75-21-8
74-88-4
                                  1-21                                   Rev.  3

-------
1521g
                      Table 1-1  (continued)
BOAT
reference
no.

33.
228.
34.
229.
35.
37.
38.
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
231.

50.
215.
216.
217.

51.
52.
53.
54.
55.
56.
57.
58.
59.
218.
60.
61.
62.
Parameter
Volatl les (continued)
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyridme
1,1,1 , 2-Tetrachloroethane
1,1, 2 , 2-Tetrachloroethane
Tetrachloroethene
Toluene
Tnbromomethane
1,1, 1-Trichloroethane
1 , 1 ,2-Trichloroethane
Tnchloroethene
Trichloromonof luoromethane
1 ,2,3-Trichloropropane
l,l,2-Tnchloro-l,2,2-tnf luoro-
ethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1 ,4-Xylene
Semivolat i les
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Am 1 me
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene
Cas no.

78-83-1
67-56-1
78-93-3
108-10-1
80-62-6
126-98-7
75-09-2
79-46-9
110-86-1
630-20-6
79-34-6
127-18-4
108-88-3
75-25-2
71-55-6
79-00-5
79-01-6
75-69-4
96-18-4
76-13-1

75-01-4
97-47-6
108-38-3
106-44-5

208-96-8
83-32-9
96-86-2
53-96-3
92-67-1
62-53-3
120-12-7
140-57-8
56-55-3
98-87-3
108-98-5

50-32-8
                                 1-22                                  Rev.  3

-------
1521g
                      Table 1-1  (continued)
BOAT
reference

63.
64
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
232.
83
84
85.
86. '
87
88.
89.
90.
91.
92.
93.
94
95
96
97.
98
99
100.
101.
Parameter
Semivolatiles (continued)
Benzo ( b ) f 1 uorant hene
Benzo(ghi jperylene
Benzo(k)f luoranthene
p-Benzoquinone
B i s ( 2-ch loroethoxy ) methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
B1s(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dimtrophenol
p-Chloroam 1 me
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitn le
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
D i benz ( a, h) anthracene
Dibenzo(a,e)pyrene
Oibenzo(a, i )pyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Oichlorobenzene
3,3'-Dichlorobenzidine
2,4-Oichlorophenol
2,6-Oichlorophenol
Diethyl phthalate
3,3'-Dimethoxybenzidine
p-Oi me thy lam inoazobenzene
3,3'-Dimethylbenzidine
2,4-Dimethylphenol
Dimethyl phthalate
Oi-n-butyl phthalate
1 ,4-Dinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
CAS no.

205-99-2
191-24-2
207-08-9
106-51-4
111-91-1
111-44-4
39638-32-9
117-81-7
101-55-3
85-68-7
88-85-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
542-76-7
218-01-9
95-48-7
106-44-5
108-94-1
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
106-46-7
91-94-1
120-83-2
87-65-0
84-66-2
119-90-4
60-11-7
119-93-7
105-67-9
131-ll-*3
84-74-2
100-25-4
534-52-1
51-28-5
                                 1-23
                                                                        Rev.  3

-------
1521g
                      Table 1-1  (continued)
BOAT
reference
no.

102.
103.
104.
105.
106.
219.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.

36.
121.
122.
123.
124.
125.
126.
127.
128.
129.
130.
131.
132.
133.
134.
135.
136.
137.
138.
Parameter
Semivolati les (continued)
2,4-Oinitrotoluene
2,6-Dimtrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamme
Diphenylamine
Dipnenylmtrosamine
1,2-Oiphenylhydrazine
Fluoranthene
Fluorene
Hexach lorobenzene
Hexach lorobutad i ene
Hexachlorocyclopentadlene
Hexachloroethane
Hexach lorophene
Hexach loropropene
Indeno(l,2,3-cd)pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4,4'-Methylenebis
(2-chloroamline)
Methyl methanesulfonate
Naphthalene
1,4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N-Nitrosomorpholine
N-Nitrosopipendine
n-Nitrosopyrrolidme
5-Nitro-o-toluidine
Pentach lorobenzene
Pentach loroethane
Pentach loron 1 1 robenzene
CAS no.

121-14-2
606-20-2
117-84-0
621-64-7
122-39-4
86-30-6
122-66-7
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
70-30-4
1888-71-7
193-39-5
120-58-1
91-80-5
56-49-5

101-14-4
66-27-3
91-20-3
130-15-4
134-32-7
91-59-8
100-01-6
98-95-3
100-02-7
924-16-3
55-18-5
62-75-9
10595-95-6
59-89-2
100-75-4
930-55-7
99-65-8
608-93-5
76-01-7
82-68-8
                                 1-24                                  Rev.  3

-------
1521g
                      Table 1-1  (continued)
BOAT
reference
no.

139.
140.
141.
142
220.
143.
144.
145.
146.
147.
148.
149.
150.
151.
152.
153.


154.
155.
156.
157.
158.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168

169.
170.
171
Parameter
Semivolatiles (continued)
Pentachlorophenol
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcinol
Safrole
1 , 2 , 4 , 5-Tetrachlorobenzene
2,3,4, 6-Tetrach loropheno 1
1 ,2,4-Trichlorobenzene
2,4,5-Tnchlorophenol
2, 4, 6-Trich loropheno 1
Tr i s ( 2 , 3-d i bromopropy 1 )
phosphate
Metals
Antimony
Arsenic
Barium
Beryll ium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Inorganics
Cyanide
Fluoride
Sulf ide
CAS no.

87-86-5
62-44-2
85-01-8
108-95-2
85-44-9
109-06-8
23950-58-5
129-00-0
108-46-3
94-59-7
95-94-3
58-90-2
120-82-1
95-95-4
88-06-2

126-72-7

7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-32
-
7440-50-8
7439-92-1
7439-97-6
7440-02-0
7782-49-2
7440-22-4
7440-28-0
7440-62-2
7440-6&-6

57-12-5
16964-48-8
8496-25-8
                                 1-25
Rev.  3

-------
1521g
                      Table  1-1  (continued)
BOAT
reference
no.

172.
173.
174.
175.
176.
177.
178.
179.
180.
181.
182.
183.
184.
185.
186.
187.
188.
189.
190.
191.

192.
193.
194.

195.
196.
197.
198.
199.

200.
201.
202.
Parameter
Orqanochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
ganma-BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodnn
Kepone
Methoxyclor
Toxaphene
Phenoxvacet ic acid herbicides
2,4-Dichlorophenoxyacetic acid
Silvex
2,4,5-T
Orqanoohosphorous insecticides
Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
CAS no.

309-00-2
319-84-6
319-85-7
319-86-8
58-89-9
57-74-9
72-54-8
72-55-9
50-29-3
60-57-1
939-98-8
33213-6-5
7-2-20-8
7421-93-4
76-44-8
1024-57-3
465-73-6
143-50-0
72-43-5
8001-35-2

94-75-7
93-72-1
93-76-5

298-04-4
52-85-7
298-00-0
56-38-2
298-02-2
V
12674-11-2
11104-28-2
11141-16-5
                                1-26
Rev.  3

-------
1521g
                          Table 1-1   (continued)
BOAT
reference          Parameter                             CAS no.
               PCBs (continued)

203.           Aroclor 1242                             53469-21-9
204.           Aroclor 1248                             12672-29-6
205.           Aroclor 1254                             11097-69-1
206.           Aroclor 1260                             11096-82-5

               Dioxins and furans

207.           Hexachlorodibenzo-p-dioxins
208.           Hexachlorodibenzofurans
209.           Pentachlorodibenzo-p-dioxins
210.           Pentachlorodibenzofurans
211.           Tetrachlorodibenzo-p-dioxins
212.           Tetrachlorodibenzofurans
213.           2,3,7,8-Tetrachlorodibenzo-p-dioxin      1746-01-6
                                        1-27                                        Rev.   3

-------
the BDAT constituent list as additional key constituents are


identified for specific waste codes or as new analytical methods


are developed for hazardous constituents.  For example, since the


list was published in March 1987, eighteen additional


constituents (hexavalent chromium, xylene (all three isomers),


benzal chloride, phthalic anhydride, ethylene oxide, acetone,


n-butyl alcohol, 2-ethoxyethanol, ethyl acetate, ethyl benzene,


ethyl ether, methanol, methyl isobutyl ketone, 2-nitropropane,


1,1,2-trichloro-1,2,2-trifluoroethane, and cyclohexanone) have


been added to the list.




     Chemicals are listed in Appendix VIII if they are shown in


scientific studies to have toxic, carcinogenic, mutagenic, or


teratogenic effects on humans or other life-forms, and they


include such substances as those identified by the Agency's


Carcinogen Assessment Group as being carcinogenic.  Including a


constituent in Appendix VIII means that the constituent can be


cited as a basis for listing toxic wastes.




     Although Appendix VII, Appendix VIII, and the F003 and F005


ignitables provide a comprehensive list of RCRA-regulated


hazardous constituents, not all of the constituents can be


analyzed in a complex waste matrix.  Therefore, constituents that

                                        V
could not be readily analyzed in an unknown waste matrix were not


included on the initial BDAT list.  As mentioned above, however,


the BDAT constituent list is a continuously growing list that






                               1-28                         Rev. 3

-------
does not preclude the addition of new constituents when

analytical methods are developed.



     There are 5 major reasons that constituents were not

included on the BOAT constituent list:
     (a)  Constituents are unstable.  Based on their chemical
          structure, some constituents will either decompose in
          water or will ionize.  For example, maleic anhydride
          will form maleic acid when it comes in contact with
          water and copper cyanide will ionize to form copper and
          cyanide ions.  However, EPA may choose to regulate the
          decomposition or ionization products.
     (b)  EPA-approved or verified analytical methods are not
          available.  Many constituents, such as
          1,3,5-trinitrobenzene, are not measured adequately or
          even detected using any of EPA's analytical methods
          published in SW-846 Third Edition.
     (c)  The constituent is a member of a chemical group
          designated in Appendix VIII as not otherwise specified
          (N.O.S.).  Constituents listed as N.O.S., such as
          chlorinated phenols, are a generic group of some types
          of chemicals for which a single analytical procedure is
          not available.  The individual members of each such
          group need to be listed to determine whether the
          constituents can be analyzed.  For each N.O.S. group,
          all those constituents that can be readily analyzed are
          included in the BDAT constituents list.
     (d)  Available analytical procedures are not appropriate for
          a complex waste matrix.  Some compounds, such as
          auramine, can be analyzed as a pure constituent.
          However, in the presence of other constituents, the
          recommended analytical method does not positively
          identify the constituent.  The use of high pressure
          liquid chromotography  (HPLC) presupposes a high
          expectation of finding the specific constituents of
          interest.  In using this procedure to screen samples,
          protocols would have to be developed on a case-specific
          basis to verify the identity of constituents present in
          the samples.  Therefore, HPLC is not an appropriate
          analytical procedure for complex samples containing
                               1-29                         Rev. 3

-------
          unkown constituents.
     (e)  Standards for analytical instrument calibration are not
          commercially available.  For several constituents, such
          as benz(c)acridine, commercially available standards of
          a "reasonably" pure grade are not available.  The
          unavailability of a standard was determined by a review
          of catalogs from specialty chemical manufacturers.
     Two constituents (fluoride and sulfide) are not specifically

included in Appendices VII and VIII; however, these compounds are

included on the BDAT list as indicator constituents for compounds

from Appendices VII and VIII such as hydrogen fluoride and

hydrogen sulfide, which ionize in water.



     The BDAT constituent list presented in Table 1-1 is divided

into the following nine groups:

          o    Volatile organics
          o    Semivolatile organics
          o    Metals
          o    Other inorganics
          o    Organochlorine pesticides
          o    Phenoxyacetic acid herbicides
          o    Organophosphorous insecticides
          o    PCBs
          o    Dioxins and furans

The constituents were placed in these categories based on their

chemical properties.  The constituents in each group are expected

to behave similarily during treatment and are also analyzed, with

the exception of the metals and inorganics, by using the same
                                        V
analytical methods.
                              1-30                         Rev. 3

-------
     (2)   Constituent Selection Analysis.  The constituents that

the Agency selects for regulation in each treatability group are,

in general, those found in the untreated wastes at treatable

concentrations.  For certain waste codes, the target list for the

untreated waste may have been shortened  (relative to analyses

performed to test treatment technologies) because of the extreme

unlikelihood of the constituent being present.




     In selecting constituents for regulation, the first step is

to summarize all the constituents that were found in the

untreated waste at treatable concentrations.  This process

involves the use of the statistical analysis of variance (ANOVA)

test, described in Section 1.2.6, to determine if constituent

reductions were significant.  The Agency interprets a significant

reduction in concentration as evidence that the technology

actually "treats" the waste.




     There are some instances where EPA may regulate constituents

that are not found in the untreated waste but are detected in the

treated residual.  This is generally the case where presence of

the constituents in the untreated waste interferes with the

quantification of the constituent of concern.  In such instances,

the detection levels of the constituent are relatively high,
                                         V
resulting in a finding of "not detected" when, in fact, the

constituent is present in the waste.
                               1-31                         Rev. 3

-------
     After determining which of the constituents in the untreated



waste are present at treatable concentrations, EPA develops a



list of potential constituents for regulation.  The Agency then



reviews this list to determine if any of these constituents can



be excluded from regulation because they would be controlled by



regulation of other constituents in the list.








     EPA performs this indicator analysis for two reasons: (1) it



reduces the analytical cost burdens on the treater and (2) it



facilitates implementation of the compliance and enforcement



program.  EPA's rationale for selection of regulated constituents



for this waste code is presented in Section 5 of this background



document.







     (3)  Calculation of Standards.  The final step in the



calculation of the BDAT treatment standard is the multiplication



of the average treatment value by a factor referred to by the



Agency as the variability factor.  This calculation takes into



account that even well-designed and well-operated treatment



systems will experience some fluctuations in performance.  EPA



expects that fluctuations will result from inherent mechanical



limitations in treatment control systems, collection of treated



samples, and analysis of these samples.  All of the above



fluctuations can be expected to occur at well-designed and



well-operated treatment facilities.  Therefore, setting treatment



standards utilizing a variability factor should be viewed not as










                               1-32                         Rev. 3

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a relaxing of 3004(m) requirements, but rather as a function of



the normal variability of the treatment processes.  A treatment



facility will have to be designed to meet the mean achievable



treatment performance level to ensure that the performance levels



remain within the limits of the treatment standard.







     The Agency calculates a variability factor for each



constituent of concern within a waste treatability group using



the statistical calculation presented in Appendix A.  The



equation for calculating the variability factor is the same as



that used by EPA for the development of numerous regulations in



the Effluent Guidelines Program under the Clean Water Act.  The



variability factor establishes the instantaneous maximum based on



the 99th percentile value.







     There is an additional step in the calculation of the



treatment standards in those instances where the ANOVA analysis



shows that more than one technology achieves a level of



performance that represents BOAT.  In such instances, the BOAT



treatment standard is calculated by first averaging the mean



performance value for each technology for each constituent of



concern and then multiplying that value by the highest



variability factor among the technologies considered.  This



procedure ensures that all the BOAT technologies used as the



basis for the standards will achieve full compliance.
                               1-33                         Rev. 3

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1.2.5          Compliance with Performance Standards




     All the treatment standards reflect performance achieved by

the Best Demonstrated Available Technology (BDAT).   As such,

compliance with these standards only requires that the treatment

level be achieved prior to land disposal.  It does not require

the use of any particular treatment technology.  While dilution

of the waste as a means to comply with the standard is

prohibited, wastes that are generated in such a way as to

naturally meet the standard can be land disposed without

treatment.  With the exception of treatment standards that

prohibit land disposal, all treatment standards proposed are

expressed as a concentration level.




     EPA has used both total constituent concentration and TCLP

analyses of the treated waste as a measure of technology


performance.  EPA's rationale for when each of these analytical

tests is used is explained in the following discussion.




     For all organic constituents, EPA is basing the treatment

standards on the total constituent concentration found in the

treated waste.  EPA based its decision on the fact that


technologies exist to destroy the various organics compounds.
                                         V
Accordingly, the best measure of performance would be the extent

to which the various organic compounds have been destroyed or the

total amount of constituent remaining after treatment.  (NOTE:





                               1-34                         Rev. 3

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EPA's land disposal restrictions for solvent waste codes


F001-F005 (51 FR 40572) uses the TCLP value as a measure of


performance.  At the time that EPA promulgated the treatment


standards for F001-F005, useful data were not available on total


constituent concentrations in treated residuals and, as a result,


the TCLP data were considered to be the best measure of


performance.)




     For all metal constituents, EPA is using both total


constituent concentration and/or the TCLP as the basis for


treatment standards.  The total constituent concentration is


being used when the technology basis includes a metal recovery


operation.  The underlying principle of metal recovery is the


reduction of the amount of metal in a waste by separating the


metal for recovery; therefore, total constituent concentration in


the treated residual is an important measure of performance for


this technology.  Additionally, EPA also believes that it is


important that any remaining metal in a treated residual waste


not be in a state that is easily leachable; accordingly, EPA is


also using the TCLP as a measure of performance.  It is important


to note that for wastes for which treatment standards are based


on a metal recovery process, the facility has to comply with both


the total constituent concentration and the TCLP prior to land

                                         V
disposal.
                               1-35                         Rev. 3

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     In cases where treatment standards for metals are not based

on recovery techniques but rather on stabilization, EPA is using

only the TCLP as a measure of performance.   The Agency's

rationale is that stabilization is not meant to reduce the

concentration of metal in a waste but only to chemically minimize

the ability of the metal to leach.



1.2.6          Identification of BOAT



     (1)  Screening of Treatment Data.  This section explains how

the Agency determines which of the treatment technologies

represent treatment by BOAT.  The first activity is to screen the

treatment performance data from each of the demonstrated and

available technologies according to the following criteria:


     (a)  Design and operating data associated with the treatment
          data must reflect a well-designed, well-operated system
          for each treatment data point.  (The specific design
          and operating parameters for each demonstrated
          technology for this waste code are discussed in Section
          3.2 of this document.)


     (b)  Sufficient QA/QC data must be available to determine
          the true values of the data from the treated waste.
          This screening criterion involves adjustment of treated
          data to take into account that the type value may be
          different from the measured value.  This discrepancy
          generally is caused by other constituents in the waste
          that can mask results or otherwise interfere with the
          analysis of the constituent of concern.
                                         V

     (c)  The measure of performance must be consistent with
          EPA's approach to evaluating treatment by type of
          constituents (e.g., total concentration data for
          organics, and total concentration and TCLP for metals
          in the leachate from the residual).



                               1-36                         Rev. 3

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     In the absence of data needed to perform the screening
analysis, EPA will make decisions on a case-by-case basis of
whether to include the data.  The factors included in this
case-by-case analysis will be the actual treatment levels
achieved, the availability of the treatment data and their
completeness (with respect to the above criteria), and EPA's
assessment of whether the untreated waste represents the waste
code of concern.  EPA's application of these screening criteria
for this waste code are provided in Section 4 of this background
document.

     (2)  Comparison of Treatment Data.  In cases in which EPA
has treatment data from more than one technology following the
screening activity, EPA uses the statistical method known as
analysis of variance (ANOVA) to determine if one technology
performs significantly better.  This statistical method
(summarized in Appendix A) provides a measure of the differences
between two data sets.  If EPA finds that one technology performs
significantly better (i.e., the data sets are not homogeneous),
BOAT treatment standards are the level of performance achieved by
the best technology multiplied by the corresponding variability
factor for each regulated constituent.
                                         V
     If the differences in the data sets are not statistically
significant, the data sets are said to be homogeneous.
Specifically, EPA uses the analysis of variance to determine

                               1-37                        Rev. 3

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whether BDAT represents a level of performance achieved by only



one technology or represents a level of performance achieved by



more than one (or all) of the technologies.  If the Agency finds



that the levels of performance for one or more technologies are



not statistically different, EPA averages the performance values



achieved by each technology and then multiplies this value by the



largest variability factor associated with any of the



acceptable technologies.  A detailed discussion of the treatment



selection method and an example of how EPA chooses BDAT from



multiple treatment systems is provided in Appendix A.







     (3)  Quality Assurance/Quality Control.  This section



presents the principal quality assurance/quality control (QA/QC)



procedures employed in screening and adjusting the data to be



used in the calculation of treatment standards.  Additional QA/QC



procedures used in collecting and screening data for the BDAT



program are presented in EPA's Generic Quality Assurance Project



Plan for Land Disposal Restrictions Program ("BOAT")



(EPA/530-SW-87-001,  March 1987).







     To calculate the treatment standards for the Land Disposal



Restriction Rules,  it is first necessary to determine the



recovery value for each constituent (the amount of constituent



recovered after spiking, which is the addition of a known amount



of the constituent,  minus the initial concentration in the



samples divided by the amount added)  for a spike of the treated










                              1-38                         Rev. 3

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residual.  Once the recovery value is determined, the following

procedures are used to select the appropriate percent recovery

value to adjust the analytical data:


     (a)  If duplicate spike recovery values are available for
          the constituent of interest, the data are adjusted by
          the lowest available percent recovery value (i.e., the
          value that will yield the most conservative estimate of
          treatment achieved).  However, if a spike recovery
          value of less than 20 percent is reported for a
          specific constituent, the data are not used to set
          treatment standards because the Agency does not have
          sufficient confidence in the reported value to set a
          national standard.
     (b)  If data are not available for a specific constituent
          but are available for an isomer, then the spike
          recovery data are transferred from the isomer and the
          data are adjusted using the percent recovery selected
          according to the procedure described in (a) above.


     (c)  If data are not available for a specific constituent
          but are available for a similar class of constituents
          (e.g., volatile organics, acid-extractable
          semivolatiles), then spike recovery data available for
          this class of constituents are transferred.  All spike
          recovery values greater than or equal to 20 percent for
          a spiked sample are averaged and the constituent
          concentration is adjusted by the average recovery
          value.  If spiked recovery data are available for more
          than one sample, the average is calculated for each
          sample and the data are adjusted by the lowest average
          value.
     (d)   If matrix spike recovery data are not available for a
          set of data to be used to calculate treatment
          standards, then matrix spike recovery data are
          transferred from a waste that the Agency believes is a
          similar matrix (e.g.,  if the data are for an ash from
          incineration,  then data from other incinerator ashes
          could be used).  While EPA recognizes that transfer of
          matrix spike recovery data from a similar waste is not
          an exact analysis, this is considered the best approach
          for adjusting the data to account for the fact that
          most analyses do not result in extraction of 100
          percent of the constituent.  In assessing the recovery
                              1-39                         Rev.  3

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          data to be transferred,  the procedures outlined in (a),
          (b), and (c) above are followed.
     The analytical procedures employed to generate the data used

to calculate the treatment standards are listed in Appendix E of

this document.  In cases where alternatives or equivalent

procedures and/or equipment are allowed in EPA's SW-846, Third

Edition (November 1986) methods, the specific procedures and

equipment used are also documented in this Appendix.  In

addition,  any deviations from the SW-846, Third Edition, methods

used to analyze the specific waste matrices are documented.  It

is important to note that the Agency will use the methods and

procedures delineated in Appendix E to enforce the treatment

standards presented in Section 6 of this document.  Accordingly,

facilities should use these procedures in assessing the

performance of their treatment systems.



1.2.7     BOAT Treatment Standards for "Derived-From" and "Mixed"

          Wastes



     (1)  Wastes from Treatment Trains Generating Multiple

Residues.  In a number of instances, the proposed BDAT consists

of a series of operations each of which generates a waste

residue.  For example, the proposed BDATvfor a certain waste code

is based on solvent extraction, steam stripping, and activated

carbon adsorption.  Each of these treatment steps generates a

waste requiring treatment — a solvent-containing stream from



                               1-40                        Rev. 3

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solvent extraction, a stripper overhead, and spent activated

carbon.  Treatment of these wastes may generate further residues;

for instance, spent activated carbon (if not regenerated) could

be incinerated, generating an ash and possibly a scrubber water

waste.  Ultimately, additional wastes are generated that may

require land disposal.  With respect to these wastes, the Agency

wishes to emphasize the following points:
     (a)  All of the residues from treating the original listed
          wastes are likewise considered to be the listed waste
          by virtue of the derived-from rule contained in 40 CFR
          Part 261.3(c)(2).  (This point is discussed more fully
          in (2) below.)  Consequently, all of the wastes
          generated in the course of treatment would be
          prohibited from land disposal unless they satisfy the
          treatment standard or meet one of the exceptions to the
          prohibition.
     (b)  The Agency's proposed treatment standards generally
          contain a concentration level for wastewaters and a
          concentration level for nonwastewaters.   The treatment
          standards apply to all of the wastes generated in
          treating the original prohibited waste.   Thus, all
          solids generated from treating these wastes would have
          to meet the treatment standard for nonwastewaters.  All
          derived-from wastes meeting the Agency definition of
          wastewater (less than 1 percent TOG and less than 1
          percent total filterable solids) would have to meet the
          treatment standard for wastewaters.  EPA wishes to make
          clear that this approach is not meant to allow partial
          treatment in order to comply with the applicable
          standard.
     (c)  The Agency has not performed tests, in all cases, on
          every waste that can result from every part of the
          treatment train.  However, the Agency's treatment
          standards are based on treatment of the most
          concentrated form of the waste.  Consequently, the
          Agency believes that the less concentrated wastes
          generated in the course of treatment will also be able
          to be treated to meet this value.
                               1-41                         Rev. 3

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     (2)  Mixtures and Other Derived-From Residues.  There is a



further question as to the applicability of the BOAT treatment



standards to residues generated not from treating the waste (as



discussed above), but from other types of management.  Examples



are contaminated soil or leachate that is derived from managing



the waste.  In these cases, the mixture is still deemed to be the



listed waste, either because of the derived-from rule (40 CFR



Part 261.3(c)(2)(i)) or the mixture rule (40 CFR Part



261.3(a)(2)(iii) and (iv) or because the listed waste is



contained in the matrix  (see, for example,  40 CFR Part



261.33(d)).  The prohibition for the particular listed waste



consequently applies to this type of waste.







     The Agency believes that the majority of these types of



residues can meet the treatment standards for the underlying



listed wastes (with the possible exception of contaminated soil



and debris for which the Agency is currently investigating



whether it is appropriate to establish a separate treatability



subcategorization).  For the most part, these residues will be



less concentrated than the original listed waste.  The Agency's



treatment standards also make a generous allowance for process



variability by assuming that all treatability values used to



establish the standard are lognormally distributed.  The waste



also might be amenable to a relatively nonvariable form of



treatment technology such as incineration.   Finally, and perhaps



most important,  the rules contain a treatability variance that









                               1-42                         Rev. 3

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allows a petitioner to demonstrate that its waste cannot be



treated to the level specified in the rule (40 CFR Part



268.44(a).  This provision provides a safety valve that allows



persons with unusual waste matrices to demonstrate the



appropriateness of a different standard.  The Agency, to date,



has not received any petitions under this provision  (for example,



for residues contaminated with a prohibited solvent waste),



indicating, in the Agency's view, that the existing standards are



generally achievable.







      (3)  Residues from Managing Listed Wastes or that Contain



Listed Wastes.  The Agency has been asked if and when residues



from managing hazardous wastes, such as leachate and contaminated



ground water, become subject to the land disposal prohibitions.



Although the Agency believes this question to be settled by



existing rules and interpretative statements, to avoid any



possible confusion the Agency will address the question again.







     Residues from managing First Third wastes, listed California



List wastes, and spent solvent and dioxin wastes are all



considered to be subject to the prohibitions for the underlying



hazardous waste.  Residues from managing California  List wastes



likewise are subject to the California List prohibitions when the



residues themselves exhibit a characteristic of hazardous waste.



This determination stems directly from the derived-from rule in



40  CFR Part 261.3(c)(2) or in some cases from the fact that the










                               1-43                         Rev.  3

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waste is mixed with or otherwise contains the listed waste.  The



underlying principle stated in all of these provisions is that



listed wastes remain listed until delisted.







     The Agency's historic practice in processing delisting



petitions addressing mixing residuals has been to consider them



to be the listed waste and to require that delisting petitioners



address all constituents for which the derived-from waste  (or



other mixed waste) was listed.  The language in 40 CFR Part



260.22(b) states that mixtures or derived-from residues can be



delisted provided a delisting petitioner makes a demonstration



identical to that which a delisting petitioner would make for the



underlying waste.  These residues consequently are treated as the



underlying listed waste for delisting purposes.  The statute



likewise takes this position, indicating that soil and debris



that are contaminated with listed spent solvents or dioxin wastes



are subject to the prohibition for these wastes even though these



wastes are not the originally generated waste, but rather are a



residual from management (RCRA section 3004(e)(3)).  It is EPA's



view that all such residues are covered by the existing



prohibitions and treatment standards for the listed hazardous



waste that these residues contain and from which they are



derived.
                               1-44                        Rev. 3

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1.2.8          Transfer of Treatment Standards







     EPA is proposing some treatment standards that are not based



on testing of the treatment technology of the specific waste



subject to the treatment standard.  Instead, the Agency has



determined that the constituents present in the subject waste can



be treated to the same performance levels as those observed in



other wastes for which EPA has previously developed treatment



data.  EPA believes that transferring treatment performance for



use in establishing treatment standards for untested wastes is



valid technically in cases where the untested wastes are



generated from similar industries, similar processing steps, or



have similar waste characteristics affecting performance and



treatment selection.  Transfer of treatment standards to similar



wastes or wastes from similar processing steps requires little



formal analysis.  However, in the case where only the industry is



similar, EPA more closely examines the waste characteristics



prior to concluding that the untested waste constituents can be



treated to levels associated with tested wastes.







     EPA undertakes a two-step analysis when determining whether



wastes generated by different processes within a single industry



can be treated to the same level of performance. First, EPA



reviews the available waste characteristic data to identify those



parameters that are expected to affect treatment selection.  EPA



has identified some of the most important constituents and other
                              1-45                         Rev.  3

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parameters needed to select the treatment technology appropriate



for a given waste.  A detailed discussion of each analysis,



including how each parameter was selected for each waste, can be



found in the background document for each waste.








     Second, when an individual analysis suggests that an



untested waste can be treated with the same technology as a waste



for which treatment performance data are already available, EPA



analyzes a more detailed list of constituents that represent some



of the most important waste characteristics that the Agency



believes will affect the performance of the technology.  By



examining and comparing these characteristics, the Agency



determines whether the untested wastes will achieve the same



level of treatment as the tested waste.  Where the Agency



determines that the untested waste is easier to treat than the



tested waste, the treatment standards can be transferred.  A



detailed discussion of this transfer process for each waste can



be found in later sections of this document.







1.3       Variance from the BOAT Treatment Standard







     The Agency recognizes that there may exist unique wastes



that cannot be treated to the level specified as the treatment



standard.  In such a case, a generator or owner/operator may



submit a petition to the Administrator requesting a variance from



the treatment standard.  A particular waste may be significantly










                               1-46                         Rev. 3

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different from the wastes considered in establishing treatability



groups because the waste contains a more complex matrix that



makes it more difficult to treat.  For example, complex mixtures



may be formed when a restricted waste is mixed with other waste



streams by spills or other forms of inadvertent mixing.  As a



result, the treatability of the restricted waste may be altered



such that it cannot meet the applicable treatment standard.







     Variance petitions must demonstrate that the treatment



standard established for a given waste cannot be met.  This



demonstration can be made by showing that attempts to treat the



waste by available technologies were not successful or by



performing appropriate analyses of the waste, including waste



characteristics affecting performance, which demonstrate that the



waste cannot be treated to the specified levels.  Variances will



not be granted based solely on a showing that adequate BOAT



treatment capacity is unavailable.  (Such demonstrations can be



made according to the provisions in Part 268.5 of RCRA for



case-by-case extensions of the effective date.)  The Agency will



consider granting generic petitions provided that representative



data are submitted to support a variance for each facility



covered by the petition.
                               1-47                         Rev. 3

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     Petitioners should submit at least one copy to:

        The Administrator
        U.S. Environmental Protection Agency
        401 M Street, S.W.
        Washington, DC  20460

     An additional copy marked "Treatability Variance" should be

submitted to:

        Chief, Waste Treatment Branch
        Office of Solid Waste (WH-565)
        U.S. Environmental Protection Agency
        401 M Street, S.W.
        Washington, DC  20460
     Petitions containing confidential information should be sent

with only the inner envelope marked "Treatability Variance" and

"Confidential Business Information" and with the contents marked

in accordance with the requirements of 40 CFR Part 2 (41 FR

36902, September 1, 1976, amended by 43 FR 4000).



     The petition should contain the following information:


      (1)  The petitioner's name and address.


      (2)  A statement of the petitioner's interest in the
          proposed action.


      (3)  The name, address, and EPA identification number of the
          facility generating the waste, and the name and
          telephone number of the plant contact.


      (4)  The process(es) and feed materials generating the waste
          and an assessment of whether such process(es) or feed
          materials may produce a waste that is not covered by
          the demonstration.
                               1-48                         Rev. 3

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 (5)  A description of the waste sufficient for comparison
     with the waste considered by the Agency in developing
     BDAT, and an estimate of the average and maximum
     monthly and annual quantities of waste covered by the
     demonstration.  (Note:  The petitioner should consult
     the appropriate BDAT background document for
     determining the characteristics of the wastes
     considered in developing treatment standards.)


 (6)  If the waste has been treated, a description of the
     system used for treating the waste, including the
     process design and operating conditions.  The petition
     should include the reasons the treatment standards are
     not achievable and/or why the petitioner believes the
     standards are based on inappropriate technology for
     treating the waste.  (Note:  The petitioner should refer
     to the BDAT background document as guidance for
     determining the design and operating parameters that
     the Agency used in developing treatment standards.)


 (7)  A description of the alternative treatment systems
     examined by the petitioner  (if any); a description of
     the treatment system deemed appropriate by the
     petitioner for the waste in question; and, as
     appropriate, the concentrations in the treatment
     residual or extract of the treatment residual  (i.e.,
     using the TCLP where appropriate for stabilized metals)
     that can be achieved by applying such treatment to the
     waste.
 (8)   A description of  those  parameters  affecting  treatment
      selection and waste  characteristics  that  affect
      performance,  including  results  of  all  analyses.   (See
      Section 3.0  for a discussion  of waste  characteristics
      affecting performance that  the  Agency  has identified
      for the technology representing BDAT.)


 (9)   The dates of the  sampling and testing.
(10)   A description of the methodologies  and equipment used
      to obtain representative samplevs.
(11)   A description of the sample handling and preparation
      techniques,  including techniques  used for extraction,
      containerization,  and preservation of the samples.
                          1-49                         Rev.  3

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    (12)  A description of analytical procedures used including
          QA/QC methods.
     After receiving a petition for a variance,  the Administrator

may request any additional information or waste samples that may

be required to evaluate and process the petition.   Additionally,

all petitioners must certify that the information provided to the

Agency is accurate under 40 CFR Part 268.4(b).



     In determining whether a variance will be granted, the

Agency will first look at the design and operation of the

treatment system being used.  If EPA determines that the

technology and operation are consistent with BOAT, the Agency

will evaluate the waste to determine if the waste matrix and/or

physical parameters are such that the BDAT treatment standards

reflect treatment of this waste.  Essentially,  this latter

analysis will concern the parameters affecting treatment

selection and waste characteristics affecting performance

parameters.



     In cases where BDAT is based on more than one technology,

the petitioner will need to demonstrate that the treatment

standard cannot be met using any of the technologies, or that

none of the technologies are appropriate vfor treatment of the

waste.  After the Agency has made a determination on the

petition, the Agency's findings will be published in the Federal

Register, followed by a 30-day period for public comment.



                               1-50                        Rev. 3

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After review of the public comments, EPA will publish its final



determination in the Federal Register as an amendment to the



treatment standards in 40 CFR Part 268, Subpart D.
                              1-51                         Rev.  3

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        2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION


     The previous section provided the background for the

Agency's study of K103 and K104 wastes.  The purpose of this

section is to describe the industry that will be affected by land

disposal restrictions on waste codes K103 and K104, and to

characterize these wastes.  This section includes a description

of the industry affected, the production processes employed in

this industry, and a discussion of how K103 and K104 wastes are

generated by these processes.  The section concludes with a

characterization of the K103 and K104 waste streams, and a

determination of the waste treatability group for these wastes.



     The full list of hazardous waste codes from specific sources

is given in 40 CFR 261.32 (see discussion in Section 1 of this

document).  Within this list, two specific hazardous waste codes

are generated by the aniline/nitrobenzene industry:
     K103:     Process residues from aniline extraction from the
               production of aniline (basis for listing:
               aniline, nitrobenzene, phenylenediamine).

     K104:     Combined wastewater streams generated from
               nitrobenzene/aniline production (basis for
               listing: aniline, benzene, diphenylamine,
               nitrobenzene, phenylenediamine).
     The Agency has determined that these waste codes (K103 and

K104) represent a separate waste treatability group.  This was

established because industry processes are similar; therefore,
                               2-1                         Rev. 3

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the wastes are expected to have similar physical and chemical

characteristics (see Section 1 for a discussion of waste

treatability groups).   In addition, these wastes are frequently

mixed in industry prior to treatment.  As a result, the Agency

has examined the sources of the wastes, applicable treatment

technologies, and treatment performance attainable in order to

support a single regulatory approach for the two wastes.




2.1  Industry Affected and Process Description




     The four digit standard industrial classification  (SIC) code

reported for the aniline/nitrobenzene industry is 2869.  The

Agency estimates that six facilities in the United States are

actively involved in aniline production which could generate

K103.  Four of these facilities are actively co-producing aniline

and nitrobenzene, and could generate K104 waste.




     Information from trade associations provide a geographic

distribution of the number of these facilities across the United

States.  Tables 2-1 and 2-2 present the location of those

facilities which may generate waste codes K103 and K104 in each

state and in each EPA region.  As can be seen in Tables 2-1 and

2-2, these facilities are concentrated in the central and eastern
                                         V
states (EPA Regions III through VI).  Figure 2-1 illustrates this

data plotted on a map of the United States.
                               2-2                         Rev. 3

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Table 2-1   Facilities Producing K103 and K104
State (EPA Region)

Louisiana (VI)
Mississippi (IV)
North Carolina  (IV)
Ohio (V)
Texas (VI)
West Virginia (III)
                              Total
Number of Facilities
     1
     1
     1
     1
     1
     1
     6
Reference;  SRI Chemical Economics Handbook, 1985
Table 2-2   Facilities Producing K103 and K104
EPA Recrion
III
IV
V
VI

Number of Facil
1
2
1
2
Total 6
ities





Reference;   SRI Chemical Economics Handbook, 1985.




     Nitrobenzene is manufactured by either liquid or vapor phase

nitration of benzene.  The liquid phase nitration process is

reported to be the more prevalent of the two processes used to

manufacture nitrobenzene.  In liquid phase nitration, benzene is

nitrated in a reactor with an aqueous mixture of sulfuric acid

and nitric acid (see Figure 2-2).  Crude .nitrobenzene is formed,

and is separated from the reactants and by-products by a series

of purification steps.
                               2-3
                   Rev. 3

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to
                                                                          A - ANILINE
                                                                            PRODUCER
                                                                          N - NITROBENZENE
                                                                            PRODUCER
       FIGURE 2-1  FACILITIES PRODUCING K103 AND K104 BY STATE AND EPA REGION

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                               LIQUID/
                               LI8UID
                             EXTRACTION
                             TO FURTHER
                             WASTEtlATER
                             TREATMENT
SOURCE:    DELISTING PETITION  FOR WASTE STREAM K104  - COMBINED
           WASTEWATER STREAMS  GENERATED FROM NITROBENZENE/ANILINE
           PRODUCTION.  PETITION NO.  0312.
                             FIGURE 2-2

      GENERATION OF K103 AND  K104  FROM NITROBENZENE/ANILINE
  PRODUCTION (LIQUID  PHASE NITRATION OF  BENZENE AND LIQUID PHASE
                    REDUCTION OF NITROBENZENE)
                                 2-5
Rev. 3

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     In the initial nitrobenzene purification step,  the product



stream from the reactor enters a separator where it is cooled and



allowed to settle and to separate by gravity into an organic and



an aqueous phase.  The aqueous phase, consisting mainly of



untreated sulfuric and nitric acid,  goes to the denitrator where



fresh benzene is added to remove trace amounts of nitric acid.



The benzene and trace amounts of nitrobenzene, formed in the



denitrator, are returned to the nitrobenzene reactor.  The acid



phase from the denitrator is sent to the waste acid stripper for



acid recovery by volatilization.  The recovered acid from the



waste acid stripper is recycled through an acid concentrator to



the reactor.







     The organic phase from the separator, consisting mainly of



nitrobenzene, is washed with water in a prewasher and with



caustic soda in a washer to remove traces of acid.  The washwater



streams from the prewasher and washer are both sent to a



wastewater extractor where nitrobenzene is recovered from the



washwater  (or wastewater).  In the final purification step, the



nitrobenzene stream from the washer is distilled in the



nitrobenzene topping column to produce a high purity nitrobenzene



product.







     Aniline is produced by reducing nitrobenzene with hydrogen



in the presence of a catalyst.  The three alternative reduction



processes currently in use are as follows:  catalytic vapor










                               2-6                         Rev. 3

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phase, catalytic liquid phase, and dissolving metal (or Bechamp)

process.  Most of the aniline in the United States is reported to

be produced by the catalytic vapor phase and catalytic liquid

phase processes.



     In the catalytic liquid phase process, nitrobenzene is

reduced by hydrogen to form aniline in the presence of a nickel

catalyst in a reactor (see Figure 2-2).   The crude aniline from

the reactor is separated from water and other by-products in a

two-stage gravity decantation process consisting of a crude

aniline separator and a separator.  The water phases from both

separators are combined and sent to the aniline liquid/liquid

extractor which recovers aniline from the residual wastewater

stream.  The aniline stream from the crude aniline separator is

distilled in a rectification column to produce a high purity

aniline product.



     The listed wastes K103 and K104 are generated in the

manufacture of aniline and aniline/nitrobenzene, respectively.

The generation of these wastes is discussed further in Sections

2.1.1 and 2.1.2.



2.1.1  Generation of K103 Waste
                                         V


     The listed waste K103 is generated in the production of

aniline in both the crude aniline separator and in the
                               2-7                         Rev. 3

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aniline/water separator after the rectifier column.  In the crude

aniline separator (see Figure 2-2),  the product stream from the

aniline reactor is cooled and allowed to settle and separate by

gravity into an organic and an aqueous phase.  The aqueous phase,

which is the listed waste K103, is pumped to the aniline

liquid/liquid extractor.




     The bottoms stream from the rectifier column that purifies

the crude aniline enters a purge recovery column which separates

water and aniline by distillation.   The aniline-containing stream

from the purge recovery columns enters a separator where it is

cooled and allowed to settle and separate by gravity into an

organic and an aqueous phase.  The organic phase, consisting

mainly of aniline, is recycled to the aniline reactor.  The

aqueous phase, which is the listed waste K103, is combined with

the aqueous phase from the crude aniline separator and pumped to

the aniline liquid/liquid extractor.  The bottoms from the purge

recovery column are stored in the tars tank and eventually

incinerated.




2.1.2  Generation of K104 Waste




     The listed waste K104 is generated in the production of
                                        V
nitrobenzene at both the prewasher and the washer  (see

Figure 2-2).  In the prewasher, water is used to remove acid from

the nitrobenzene stream coming from the separator by exploiting





                               2-8                         Rev. 3

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the relatively high solubility of the acids in water.  An organic



phase, consisting mainly of nitrobenzene, is separated from the



aqueous phase in the prewasher and is sent to the washer.  The



aqueous phase from the prewasher, which is the listed waste K104,



is sent to the nitrobenzene liquid/liquid extractor.








     In the washer, caustic soda is used to neutralize remaining



traces of acid in the nitrobenzene stream from the prewasher.  As



before, organic and aqueous phases are formed by settling and



gravity separation.  Nitrobenzene is removed with the organic



phase from the washer and enters the nitrobenzene topping column.



The aqueous phase from the washer, which is the listed waste



K104, is combined with the aqueous phase from the prewasher and



enters the nitrobenzene liquid/liquid extractor.  Other



wastewater streams from the co-production of nitrobenzene and



aniline are also considered to be K104, if they are not mixed



with the wastewater streams from the prewasher and washer. These



streams include the overhead stream from the waste acid stripper



and the wastewater stream from the aniline liquid/liquid



extractor.







2.2.  Waste Characterization







     This section includes all waste characterization data



available to the Agency for the K103 and K104 waste treatability



group.  An estimate of the major constituents which comprise each
                               2-9                         Rev. 3

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waste and their approximate concentrations is presented in



Table 2-3.  The percent concentration of each major constituent



in the waste was determined from best estimates based on chemical



analyses.  Table 2-3 shows that the major constituent of both



K103 and K104 is water (at >94.7% and >98.7%, respectively).  The



primary organic BOAT constituent in K103 is aniline, with benzene



and sulfide being the other primary BDAT constituents present



(<1.0%).  The primary organic BDAT constituent in K104 is



nitrobenzene, with benzene and cyanides being the other primary



BDAT constituents present (<1.0%).







     The ranges of BDAT constituents present in each waste and



all other available data concerning waste characterization



parameters obtained from the Onsite Engineering report for E. I.



duPont de Nemours, Beaumont, Texas, are presented by waste code



in Table 2-4.  This table lists the levels of BDAT organics



(volatile and semivolatile), metals, and inorganics present in



K103 and K104 wastes.  Other parameters analyzed in the wastes



include: total dissolved solids, total suspended solids, total



organic carbon, and chemical oxygen demand.  Tables 2-3 and 2-4



together provide a thorough characterization of K103 and K104



wastes.
                               2-10                         Rev. 3

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Table 2-3 Major Constituent Composition for K103 and K104 Wastes*
Constituent

Water
Aniline
BOAT Constituents
  (Other than Aniline)
     Total
         K103 Waste
Concentration (Wt. Percent)

             >94.7
               4.3
             100.0%
Constituent

Water
Nitrobenzene
BOAT Constituents
  (Other than Nitrobenzene)
     Total
         K104 Waste
Concentration (Wt. Percent)

             >98.7
               0.3
             100.0
* Percent concentrations presented here were determined from best
  estimates based on chemical analyses.

Reference: Onsite Engineering Report for E. I. duPont de Nemours,
           Beaumont, Texas.  Pages 6 and 8.
                              2-11
                           Rev.  3

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                                           TABLE 2-4
                            BOAT CONSTITUENT ANALYSIS AND OTHER DATA
                                              Untreated Waste Conentration Range,  pcm*


    BOAT  ORGAN ICS                          K103                                K104

       Volatile

      4.   Benzene                             32-81                               4.5 - 320

       Semivolatile

     56.   Aniline                    33.000 -  53,000                        <150 -   <300
    101.   2,4-Dinitrophenol          <7,500 - <15,000                         750 - <1,500
    126.   Nitrobenzene               1,900 -   2,800**                     2,200 -  3,900
    142.   Phenol                      1,500 -  <3,000                        <150 -   <300

       BOAT  Metals

    155.   Arsenic                        0.01 - 21                                <0.01
    156.   Barium                          <.001                               .0015 - .017
    159.   Chromium                        <.007                               <-007 - .432
    160.   Copper                          <.006                               <.006 - .012
    161.   Lead                         <-005 - 6                                 <.020
    163.   Nickel                          <.011                               <.011 - .238
    168.   Zinc                            3 - 21                             <.038 - .079

       BOAT  Inorganics

    169.   Total Cyanides              <0.010 - 0.075                           3.06 - 6.28
    171.   Sulfide                         62 - 89                                 <1.0

       Other Parameters

          Total Dissolved Solds              +                                 10,200 - 27,200
          Total Suspended Solids           8-24                                  21-172
          Total Organic Carbon       33,500 - 36,300                           1,420 - 2,990
          Chemical  Oxygen Demand      97,800 - 111,000                          5,290 - 48,200
 * - Values obtained from Onsite  Engineering Report of Treatment Technology Performance for E. I. du Pont
     de Nemours,  Inc.,  Beaumont,  Texas.  Tables 6-6 and 6-8.
 + - Total dissolved solids could not  be analyzed since the sample flashed before an analysis could be
     completed. This was due to the amount of organics contained in the sample.
** - Value represents the treated waste from the aniline liquid/liquid extractor.  Nitrobenzene was
     used as a solvent  in the  aniline  liquid/liquid extractor.
                                                    2-12                                         Rev.  3

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2.3  Determination of Waste Treatability Group







     Fundamental to waste treatment is the concept that the type



of treatment technology used and the level of treatment achieved



depend on the physical and chemical characteristics of the waste.



In cases where EPA believes that wastes represented by different



codes can be treated to similar concentrations using the same



technologies, the Agency combines the codes into one treatability



group.  In particular, the two listed wastes (K103 and K104) from



the production of aniline and nitrobenzene were combined into a



single waste treatability group.







     These two wastes are produced in the aniline/nitrobenzene



industry and are frequently treated together in the industry



using a single waste treatment technology.  Also, the two wastes



have similar physical and chemical characteristics including:



high water content, high BDAT organic levels (benzene and aniline



or nitrobenzene),  relatively low levels of BDAT metals and



inorganics,  and low filterable solids content.  For these



reasons,  the Agency believes that the K103 and K104 wastes



represent a separate waste treatability group.
                              2-13                         Rev.  3

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        3.  APPLICABLE/DEMONSTRATED  TREATMENT  TECHNOLOGIES







     The purpose of this section is to describe applicable



treatment technologies for treatment of K103 and K104 wastes that



the Agency has identified as applicable and to describe which of



the applicable technologies the Agency has determined to be



demonstrated.  Included in this section are discussions of those



applicable treatment technologies that have been demonstrated on



a commercial basis.  The technologies which were considered to be



applicable are those which treat organic compounds by



concentration reduction.  Also, this section describes the



performance data available for these technologies.







     The previous section described the industry that will be



affected by the land disposal restrictions on K103 and K104



wastes, and presented a characterization of these wastes.



Analysis of the K103 wastewaters indicates that they primarily



consist of water (94.7 percent) and aniline (4.3 percent).   The



K104 wastewater primarily consists of water (98.7 percent),



nitrobenzene (0.3 percent) and small amounts of cyanides.  The



Agency has identified these treatment technologies which may be



applicable to K103 and K104 because the technologies are designed



to reduce the concentration of organic cojmpounds present in the



untreated waste.  The selection of the treatment technologies



applicable for treating organic compounds and cyanides in K103
                               3-1                         Rev. 3

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 and K104 wastewaters is based on information obtained from



engineering site visits and available literature sources.







3.1  Applicable Treatment Technologies








     For K103 and K104 wastewaters, the Agency has identified the



following treatment technologies as being applicable:



liquid/liquid (or solvent) extraction which separates the organic



components from the aqueous components by exploiting the relative



differential or selective solubility of the organic constituents



in a particular solvent; steam stripping, which removes organics



from the liquid phase through volatilization; activated carbon



adsorption which uses carbon granules to selectively remove



organic contaminants by adsorption; and biological treatment



which involves the use of microorganisms to degrade organic



compounds.








     The use of activated carbon adsorption in treating the



wastewaters generates a spent carbon which is nonwastewater.   The



Agency has identified rotary kiln incineration as being an



applicable treatment technology for this nonwastewater form of



K103 and K104.
                               3-2                         Rev. 3

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3.2  Demonstrated Treatment Technologies



     i.   Nonwastewaters

     The demonstrated technology that the Agency has identified

for treatment of K103 and K104 nonwastewaters is rotary kiln

incineration.  This technology has not been commercially

demonstrated for the treatment of K103 and K104 nonwastewaters,

but it has been demonstrated for wastes similar to K103 and K104

nonwastewaters.  However, the Agency does not have performance

data for this treatment technology.



     ii.  Wastewaters

     The Agency has determined that all of the applicable

technologies for wastewaters are demonstrated.  The demonstrated

treatment technologies listed above for K103 and K104 generally

are combined to form treatment systems or treatment trains which

are more effective than single technologies alone in removing and

recovering organics from wastewater.  The three treatment

technology systems which are demonstrated or are currently in

commercial use are as follows:
          liguid/liquid extraction followed by steam stripping
          and activated carbon adsorption,

          steam stripping followed by activated carbon
          adsorption, and

          steam stripping followed by biological treatment.
                               3-3                         Rev.  3

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     A more detailed discussion of the treatment technology



system for which the Agency has collected performance data is



presented in Sections 3.2.1 through 3.2.3.








3.2.1  Solvent Extraction







     Solvent extraction is a treatment technology used to remove



a constituent from a waste by mixing the waste with a solvent



that is immiscible with the waste and in which the waste



constituent of concern is preferentially soluble.  Solvent



extraction is commonly called liquid extraction or liquid-liquid



extraction.  EPA also uses this term to refer to extraction of



BDAT list organics from a solid waste.  When BOAT list metals are



extracted using acids, EPA uses the term acid leaching.







(1)  Applicability and Use of Solvent Extraction







     Theoretically, solvent extraction has broad applicability in



that it can be used for wastes that have high or low



concentrations of a range of waste characteristics including



total organic carbon, filterable solids, viscosity, and BDAT list



metals content.  The key to its use is whether the BDAT



constituents can be extracted from the waste matrix containing



the constituents of concern.  For a waste matrix with high



filterable solids this would mean that the solids could be land



disposed following solvent extraction.  For a predominately









                               3-4                         Rev.  3

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liquid waste matrix with low filterable solids, the extracted

liquid (referred to as the raffinate) could be reused.  Solvent

extraction can seldom be used without additional treatment


(e.g., incineration) of the extract; however, some industries may

be able to recycle the solvent stream contaminated with the BOAT


constituents back to the process.




(2)  Underlying Principles of Operation




     For solvent extraction to occur, the BOAT constituents of


concern in the waste stream must be preferentially soluble in the


solvent and the solvent must be essentially immiscible with the


waste stream.  In theory, the degree of separation that can be

achieved is provided by the selectivity value; this value is the

ratio of the equilibrium concentration of the constituent in the


solvent to the equilibrium concentration of the constituent in


the waste.




     The solvent and waste stream are mixed to allow mass

transfer of the constituent(s) from the waste stream to the

solvent.  The solvent and waste stream are then allowed to

separate under quiescent conditions.  The solvent solution,

containing the extracted contaminant is called the extract.  The

                                         V
extracted waste stream with the contaminants removed is called


the raffinate.  The simplest extraction system comprises three


components: (1) the solute, or the contaminant to be extracted;
                               3-5                         Rev. 3

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(2) the solvent; and (3) the nonsolute portion of the waste

stream.  For simple extractions, solute passes from the waste

stream to the solvent phase.  A density difference exists between

the solvent and waste stream phases.  The extract can be either

the heavy phase or the light phase.




(3)  Physical Description of a Solvent Extraction Process




     The simplest method of extraction is a single stage system.

The solvent and waste stream are brought together; clean effluent

and solvent are recovered without further extraction.  The clean

effluent is referred to as the raffinate, and the solvent

containing the constituents that were removed from the waste

stream are known as the extract.  The amount of solute extracted

is fixed by equilibrium relations and the quantity of solvent

used.  Single stage extraction is the least effective extraction

system.




     Another method of extraction is simple multistage contact

extraction.  In this system, the total quantity of solvent to be

used is divided into several portions.  The waste stream is

contacted with each of these portions of fresh solvent in a

series of successive steps or stages.  Raffinate from the first
                                         v
extraction stage is contacted with fresh solvent in a second

stage, and so on.
                               3-6                         Rev. 3

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     In countercurrent, multistage contact, fresh solvent and the

waste stream enter at opposite ends of a series of extraction

stages.  Extract and raffinate layers pass continuously and

countercurrently from stage to stage through the system.




     In order to achieve a reasonable approximation of phase

equilibrium, solvent extraction requires the intimate contacting

of the phases.  Several types of extraction systems are used for

contact and separation; two of these, mixer-settler systems and

column contactors, are discussed below.




     i.  Mixer-Settler Systems

     Mixer-settler systems are comprised of a mixing chamber for

phase dispersion, followed by a settling chamber for phase

separation.  The vessels may be either vertical or horizontal.


Dispersion in the mixing chamber occurs by pump circulation,

nonmechanical in-line mixing, air agitation, or mechanical

stirring.  In a two-stage mixer-settler system the dispersed

phase separates in a horizontal settler.  The extract from the

second settler is recycled to the first settler (see Figure 3-1).

Extract properties such as density or specific constituent

concentration may be monitored to determine when the extract must

be sent to solvent recovery and fresh or regenerated solvent
                                         V
added to the system.  Mixer-settler systems can handle solids or

highly viscous liquids.  Design scaleup is reliable, and

mixer-settlers can handle difficult dispersion systems.   Intense





                               3-7                         Rev. 3

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       WASTE,
 OJ

 00
              MIXER
                              A
                                RECYCLED SOLVENT FROM
                                RECOVERY/ FRESH SOLVENT
                                MAKEUP
                                      RAFFINATE
                             A
MIXER
                   (_ _ RAFFINATE	
                   y    SOLVENT
                                      RECYCLED
                                      SOLVENT
                          V
                            EXTRACT
                   _ RAFFINATE	"\
                      SOLVENT     J
                                    EXTRACT TO RECOVERY

                                      FIGURE 3-1
                              TWO-STAGE MIXER-SETTLER
                                  EXTRACION SYSTEM
(D

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agitation to provide high rates of mass transfer can produce



solvent-feed dispersions that are difficult to separate into



distinct phases.







     ii.  Column Contactors



     Packed and sieve-tray are two different types of column



contactors that do not require mechanical agitation.  Figure 3-2



presents schematics of the two types of extraction columns.







     A packed extractor contains packing materials, such as



saddles, rings, or structured packings of gauze or mesh.  Mass



transfer of the solute to the extract is promoted because of



breakup and distortion of the dispersed phase as it contacts the



packing.








     The sieve-tray extractor is similar to a sieve-tray column



used in distillation.  Tray perforations result in the formation



of liquid droplets to aid the mass transfer process.  The



improved transfer is accomplished by the fact that the droplets



allow for more intimate contact between extract and raffinate.







(4)  Waste Characteristics Affecting Performance







     In determining whether solvent extraction is likely to



achieve the same level of performance on an untested waste as a



previously tested waste, the Agency will focus on the waste










                               3-9                         Rev. 3

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     SOLVENT-LIQUID
     INTERFACE
         SOLVENT
         WASTE
                        RAFFINATE
                                         RAFFINATE
                           SOLVENT
                                 . PACKING
                                  SUPPORT/
                                  REDISTRIBUTER
                                 PACKING
                                 SUPPORT
                                                               jjr--^^r —
                                   ---•=]
                                      _ ^^ ,  ____
EXTRACT


 SOLVENT-LIQUID
' INTERFACE
                                                 DOMNCOHER
                                                 WASTE
                                                                EXTRACT
                 A. PACKED
                    EXTRACTOR
                                 B.SIEVE TRAY
                                    EXTRACTOR
                                        FIGURE 3-2
                               EXTRACTION  COLUMNS WITH
                               NONMECHANICAL AGITATION
(D

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characteristics that provide an estimate of the selectivity value



previously described.  EPA believes that the selectivity value



can best be estimated by analytically measuring the partitioning



coefficients of the waste constituents of concern and the



solubility of the waste matrix in the extraction solvent.



Accordingly, EPA will use partitioning coefficients and



solubility of the waste matrix as surrogates for the selectivity



value in making decisions regarding transfer of treatment



standards.







     For the liquid/liquid extraction system, the WCAPs are the



relative solubilities which is a measure of the partitioning



coefficient, of the various waste constituents in water and in



nitrobenzene.  The primary organic constituents of K103 and K104



(benzene, aniline, nitrobenzene, phenol, and 2,4-dinitrophenol),



along with cyanides, are all soluble in nitrobenzene at 40°C.



Phenol and cyanides are soluble in water at 40°C, while benzene,



aniline, and nitrobenzene are relatively insoluble in water



(0.137 g/100 g H2Osaturated solution at 54.5°C).  It should also



be noted that the density of nitrobenzene relative to water is



1.205 at 4°C.
                               3-11                         Rev. 3

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 (5)  Design and Operating Parameters








     EPA's analysis of whether a solvent extraction system is



well designed will focus on whether the BDAT list constituents



are likely to be effectively separated from the waste.  The



particular design and operating parameters to be evaluated are:



 (1) the selection of a solvent, (2) equilibrium data, (3)



temperature and pH, (4) mixing, and (5) settling time.








     (1)  The selection of a solvent.   In assessing the design of



a solvent extraction system, the most important aspect to



evaluate is the solvent used and the basis on which the



particular solvent was selected.  Solvent selection is important



because, as indicated previously,  different waste constituents of



concern will have different solubilities in various solvents, and



it is the extent to which the waste constituents



are preferentially soluble in the selected solvent that



determines the effectiveness of this technology.  In addition to



this information, EPA would also want to review any empirical



extraction data used to design the system.







     (2)  Equilibrium Data.   For solvent extraction systems that



are operated in a continuous mode,  the extraction process will



generally be conducted using a series of equilibrium stages as



discussed previously.   The number of equilibrium stages and the



associated flow rates of the waste and solvent will be based on
                               3-12                         Rev. 3

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empirical equilibrium data.  EPA will evaluate these data as part



of assessing the design of the system.







     (3)   Temperature and pH.  Temperature and pH changes can



affect equilibrium conditions and, consequently, the performance



of the extraction system.  Thus, EPA would attempt to monitor and



record these values on a continuous basis.







     (4)   Mixing.  For mixer-settler type extraction processes,



mixing determines the amount of contact between the two



immiscible phases and, accordingly, the degree of mass transfer



of the constituents to be extracted.  EPA would thus want to know



the type of mixers used and the basis for determining that this



system would provide sufficient mixing.







     (5)   Settling Time.  For batch systems, adequate settling



time must be allowed to ensure that separation of the phases has



been completed.  Accordingly, in assessing the design of a



system, EPA would want to know settling time allowed and the



basis for selection.
                               3-13                         Rev. 3

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3.2.2  Steam Stripping





   Steam stripping is a technology which can separate more



volatile materials from less volatile materials by a process of



vaporization and condensation.  As such, it is a type of



distillation process.








(1)     Applicability and Use of Technology








   Steam stripping is applicable to wastewaters that contain BOAT



organics that are sufficiently volatile such that they can be



removed by the application of steam.  Waste parameters affecting



treatment selection are filterable solids,  total organic carbon



(TOC),  and the presence of BDAT organics that are either not



volatile or only minimally volatile.







(2)     Underlying Principles of Operation







   The basic principle of operation for steam stripping is the



volatilization of hazardous constituents through the application



of heat.  The constituents that are volatilized are then



condensed and either reused or further treated by liquid



injection incineration.








   An integral part of the theory of steam stripping is the



principle of vapor-liquid equilibrium.  When a liquid mixture of



two or more components is heated, a vapor phase is created above







                               3-14                         Rev. 3

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the liquid phase.  The vapor phase will be more concentrated in



the constituents having the higher vapor pressure.  If the vapor



phase above the liquid phase is cooled to yield a condensate, a



partial separation of the components results.  The degree of



separation would depend on the relative differences in the vapor



pressures of the constituents; the larger the difference in the



vapor pressure, the easier the separation can be accomplished.







   If the difference between the vapor pressure is extremely



large, a single separation cycle or single equilibrium stage of



vaporization and condensation may achieve a significant



separation of the constituents.  If the difference between the



vapor pressures are small, then multiple equilibrium stages are



needed to achieve effective separation.  In practice, the



multiple equilibrium stages are obtained by stacking trays or



placing packing into a column.  The vapor phase from a tray rises



to the tray above it and the liquid phase falls to the tray below



it.  Essentially, each tray represents one equilibrium stage.  In



a packed steam stripping column, the individual equilibrium



stages are not discernible, but the number of equivalent trays



can be calculated from mathematical relationships.







   The vapor liquid equilibrium is expressed as relative



volatility or the ratio of the vapor to liquid concentration for



a constituent divided by the ratio of the vapor to liquid



concentration of the other constituent.  The relative volatility










                               3-15                         Rev.  3

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is a direct measure of the ease of separation.  If the numerical

value is 1, then separation is impossible because the

constituents have the same concentrations in the vapor and liquid

phases.  Separation becomes easier as the value of the relative

volatility becomes increasingly greater than unity.




(3)     Physical Description of the Process




   A steam stripping unit consists of a boiler, a stripping

section, a condenser, and a collection tank as shown by Figure

3-3.  The boiler provides the heat required to vaporize the

liquid fraction of the waste.  The stripping section is composed

of a set of trays or packing in a vertical column.  The feed

enters at the top.




   The stripping process uses multiple equilibrium stages, with

the initial waste mixture entering the uppermost equilibrium

stage.  The boiler is located below the lowermost equilibrium

stage so that vapor generated moves upward in the column coming

into contact with the falling liquid.  As the vapor comes into

contact with the liquid at each stage, the more volatile

components are removed or "stripped" from the liquid by the vapor


phase.  The concentration of the emerging vapor is slightly
                                         V
enriched (as it is in equilibrium with the incoming liquid), and

the liquid exiting the bottom of the boiler ("bottoms") is

considerably enriched in the lower vapor pressure constituent(s).





                               3-16                         Rev. 3

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HASTE
INFLUENT
TREATED
EFFLUENT
                                VENT OF
                          NON-CONDENSED VAPORS
                                  A
                                          CONDENSER
RECIEVER

RECOVERED
SOLVENT  FOR
REUSE OR
TREATMENT
                 FIGURE  3-3
              STEAM  STRIPPING
                         3-17
     Rev. 3

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The process of stripping is very effective for wastewaters where



the relative volatilities are large between the organics of



concern and wastewater.  Steam stripping is used to strip the



organic volatiles from wastewater.  The water effluent from the



bottom of the stripper is reduced in organic content, but in some



circumstances may require additional treatment, such as carbon



adsorption or biological treatment.  The steam and organic vapors



leaving the top of the column are condensed.  Organics in the



condensate that form a separate phase in water usually can be



separated and recovered or disposed of in a liquid injection



incinerator.  After separation the aqueous condensate is usually



recycled to the stripper.








(4)     Waste Characteristics Affecting Performance







   In determining whether steam stripping is likely to achieve



the same level of performance on an untested waste as a



previously tested waste,  EPA will focus on the following



characteristics:  boiling point, total dissolved solids,  total



dissolved volatile solids,  and oil and grease.  EPA recognizes



these characteristics have some limitations in assessing transfer



of performance; nevertheless,  the Agency believes that they



provide the best possible indicator of the preferred waste



characteristic analysis,  i.e., relative volatility.  Below is a



discussion of relative volatility, as well as, EPA's rationale



for evaluating the above described waste characteristics in
                              3-18                         Rev. 3

-------
determining transfer of treatment performance.



   As discussed earlier, the term relative volatility ( oC )

refers to the ease with which a substance present in a solid or

liquid waste will vaporize from that waste upon application of

heat from an external source.  Hence, it bears a relationship to

the equilibrium vapor pressure of the substance.
   For an ideal  binary mixture, the relative volatility ( o( ) is

expressed as:
                  fi    Iiffi
                  K.   -Y.X.


where K. and K. are equilibrium concentrations for components i

and j respectively, Y is the mole fraction of the component in

the vapor and X is the mole fraction of the component in the

liquid.
   The term "ideal" refers to whether the vapor pressures of the
   two components can be linearly related to their respective
   compositions in the liquid phase; this,, is known as Raoult's
   law.  In general, binary solutions at low pressures follow
   this law and are, therefore,  "ideal"; most mixtures do not.
                              3-19                         Rev. 3

-------
     For non- ideal binary mixtures, the relative volatility  ( 
-------
point alone would not account for any non-ideal behavior of the

solution.  Accordingly, EPA will examine the concentrations of

oil and grease, total dissolved solids, and total dissolved

volatile solids.  All of these characteristics affect the partial

pressures of the individual organic constituents of concern as

well as the solubility.  Accordingly, these characteristics will

affect relative volatility of a constituent and, hence, the

ability of the constituent to be treated using steam stripping.




     The WCAPs for the steam stripper are the vapor pressures of

the various constituents in the waste.  The higher the vapor

pressure, the more easily stripped.  At 40°C, benzene has a vapor

pressure of 182.7 mm Hg, aniline has a vapor pressure of 2.90 mm

Hg, and phenol has a vapor pressure of 2.02 mm Hg.  Nitrobenzene

has a vapor pressure of 1 mm Hg at 44.4°C, and 2,4-dinitrophenol

has a vapor pressure of 1 mm Hg at 49.3°C.  The cyanides present

are primarily solid salts, and hence have low vapor pressures or

decompose upon heating.  There are no known azeotropes among the

constituents of these wastes, and there is no known

polymerization potential upon heating these wastes.




(5)  Design and Operating Parameters



                                         *>
     EPA's analysis of whether a steam stripping system is well

designed will focus on the degree of separation the system is


designed to achieve and the controls installed to maintain the
                              3-21                         Rev.  3

-------
proper operating conditions.  The specific parameters are

presented below.




     (1)  Treated and Untreated Concentrations.  In determining

whether to sample a particular steam stripper as a candidate for

BOAT, EPA will pay close attention to the treated design

concentration of the unit to ensure that it is consistent with

best demonstrated practice.  This evaluation is important in that

a treatment system will usually not perform its design. The

various untreated waste characteristics that affect performance

are important to know, because operation of the system with

untreated waste concentrations in excess of initial design

conditions can easily result in poor performance of the treatment

unit.  In evaluating the performance of a steam stripper, EPA

would want data on the untreated waste characteristics to ensure

that they conformed with design specifications.




     (2)  Vapor-Liquid Equilibrium Data.  The vapor liquid

equilibrium data are determined in laboratory tests unless

already available.  The use of these data are required for

several reasons.  First, they are used to calculate the number of

theoretical stages required to achieve the desire separation.

Using the theoretical number of stages, the actual number of
                                         V
stages can then be determined through the use of empirical tray

efficiency data supplied by an equipment manufacturer.
                               3-22                        Rev. 3

-------
     Secondly, the vapor liquid equilibrium data are used to



determine the liquid and vapor flow rates that ensure sufficient



contact between the liquid and vapor streams.  These rates are,



in turn, used to determine the column diameter.







     (3)  Column Temperature and Pressure.  These parameters are



integrally related to the vapor liquid equilibrium conditions.



Column temperature design include performing a heat balance



around the steam stripping unit, accounting for the heat removed



in the condenser, heat input in the feed, heat input from steam



injectors and heat loss from the column.  Column pressure



influences the boiling point of the liquid.  For example, the



column temperature required to achieve the desired separation can



be reduced by operating the system under vacuum.  During



treatment, it is important to continuously monitor these



parameters to ensure that the system is operated at design



conditions.








     (4)  Column Internals.   Column internals are designed to



accommodate the physical and chemical properties of the



wastewater to be stripped.  Two types of internals may be used in



steam stripping:  trays or packing.  Tray types include bubble



cap, sieve, valve and turbo-grid.   Trays have several advantages



over packing.  Trays are less susceptible to blockage by solids,



they have a lower capital cost for large diameter columns



(greater than or equal to 3  feet),  and they accommodate a wider
                              3-23                         Rev.  3

-------
range of liquid and vapor flow rates.  Compared to trays, packing



has the advantages of having a lower pressure drop per



theoretical stage, being more resistant to corrosive materials,



having a lower capital cost for small diameter column (less than



3 feet), and finally being less susceptible to foaming because of



a more uniform flow distribution.







3.2.3   Carbon Adsorption








     Adsorption with activated carbon is an important separation



method for removing organics and some other dissolved materials



from liquids.  It occurs when the surface of the activated carbon



attracts the ions or molecules of the organic or dissolved solid



to form a layer on the carbon surface and accumulate in its



pores.








(1)  Applicability and Use of Technology







     Activated carbon treatment is used to remove dissolved



organic pollutants from aqueous streams.  To a lesser extent it



also is used to remove dissolved heavy metal and other inorganic



contaminants.  Inorganics are usually not very adsorbable, but



there are some exceptions (e.g., molybdates, gold chloride,



mercuric chloride, silver salts and iodine).  The most effective



metals removal occurs with metal/inorganic complexes, or metal



organic complexes.
                               3-24                         Rev. 3

-------
     Activated carbon treatment is not selective in the organic


contaminants it will remove.  Hence, all organics will compete

for system capacity, including organics that are not necessary to


remove.  In some systems (downflow granular activated carbon


beds),  suspended solids over 50 mg/1 cannot be tolerated and must


be removed prior to activated carbon treatment.  Activated carbon


is frequently applied as a final polishing mechanism following


other treatment technologies (e.g., biological treatment).




     These waste component separations most commonly occur in


industries manufacturing organic chemicals, inorganic chemicals,


dyes and pigments, insecticides, refineries, textiles,


explosives, food, tobacco, leather, primary metals, fabricated


metals, Pharmaceuticals, and plastics.




(2)  Underlying Principles of Operation




     Activated carbon treatment is an application of the


principle of adsorption.  Adsorption is the mass transfer of a

molecule from a liquid or gas into a solid surface.




     Activated carbon is manufactured in such a way as to produce

extremely porous carbon particles, whose internal surface area is
                                         V
very large (500 to 1400 square meters per gram of carbon).  This


porous structure, through chemical and physical forces, attracts


and holds (adsorbs) organic molecules as well as certain
                               3-25                         Rev. 3

-------
inorganic molecules.  It is not unusual for activated carbon to

adsorb from aqueous solution 0.15 grams of an organic contaminant

per gram of carbon, though 0.10 gram/gram is probably a more

realistic general estimate.  The principal factor that affects

carbon adsorption is the chemical affinity between the carbon and

the organic compound.  Other characteristics such as solubility,

temperature, pH, type of activated carbon used and presence of

other organics also influence the effectiveness of carbon

adsorption.




     The effectiveness of adsorption generally improves with

increasing contact time.  Exceptions to this rule include

chemical compounds that are not preferentially adsorbed onto the

carbon surface.  These compounds can be adsorbed from adsorption

sites in favor of compounds that have a higher affinity for the

carbon over a longer contact time.




     Once the contaminants/impurities have been removed from the

waste stream onto the carbon, two options are available.  The

activated carbon can be (1) disposed of by approved methods

(usually incineration) or  (2) regenerated by thermal or chemical

methods for further use.



                                         V
     There is a loss of performance with each regeneration step;

therefore, the activity is never restored to its original level.

The number of times that the carbon can be regenerated is
                               3-26                         Rev. 3

-------
determined by the extent of physical erosion and the loss of



adsorptive capacity.  Isotherm tests on the regenerated carbon



can be used to determine adsorptive capacity, thereby aiding in



the prediction of the number of times the carbon can be



regenerated.







(3)  Waste Characteristics Affecting Performance







     The waste characteristics that will affect an activated



carbon system's performance are as follows:  (i) type of organic



contaminants, (ii) concentration of contaminants, and (iii)



suspended solids, grease and oil concentration.







     At first, it might appear that pH and temperature would be



significant factors that would affect adsorption.  Polarity of



some organic compounds are affected by pH, and polarity changes



influence adsorption.  Particularly with heavy metals, the



activated carbon must have the proper pH to achieve satisfactory



removal.  Temperature becomes a significant factor when they



become high enough to desorb contaminants from activated carbon



(usually over 100°C).  However, these factors are considered to



be easily controlled during the actual process and, as such, are



not major hindrances to efficient adsorption.
                               3-27                         Rev. 3

-------
     i.  Type of Organic Contaminants








     All organic molecules can be adsorbed by activated carbon to



some degree.  Generally, adsorption will increase with molecular



weight until the particle size becomes too large for carbon pore



size.  However, the activated carbon usually has a greater



affinity for aromatic compounds than straight chain compounds.



Nonpolar compounds are usually easily adsorbed, whereas polar



ones are not.  Halogenated organic compounds (HOCs),  if aromatic



(such as PCBs), are readily adsorbed.  Finally, it has been



demonstrated in practice that adsorption will increase with



decreasing solubility.







     For the carbon adsorption system, the WCAPs are the



molecular weights of the constituents present.   The molecular



weights of the major constituents in the waste are as follows:



78.12 for benzene, 123.11 for nitrobenzene, 93.13 for aniline,



94.11 for phenol, and 184.11 for 2,4-dinitrophenol.  The cyanides



present are thought to be a mixture of complex organic and



inorganic cyanide compounds, and therefore the molecular weight



cannot be determined.  Other important characteristics of the



waste for the carbon adsorption unit are the total organic carbon



content (which is 444 mg/1) and the total suspended solids



content (which is 196 mg/1).  The amount of oil and grease in the



waste is not known.
                               3-28                         Rev. 3

-------
     ii.  Concentration of Contaminants







     In actual practice this process becomes ineffective at



concentrations exceeding a few thousand mg/1.  The carbon will



adsorb concentrated contaminants so fast that carbon consumption



will become excessive, and frequent disposal and/or regeneration



of carbon is likely to become a greater problem than removal of



the organic materials from the waste stream.  For excessively



concentrated waste streams, other organic compound destruction



techniques would probably be more appropriated (e.g.,



incineration or reuse as a fuel).







     iii.  Suspended Solids and Grease and Oil Concentration







     In powdered activated carbon (PAC) systems,  suspended solids



and grease concentrations in the wastewater stream have no



effect, since they are removed from the waste along with the



spent PAC.  However, in nonfluidized granular activated carbon



(GAG) systems (see Section 4.4 for a description of these



systems), the column of GAC acts as a filter for suspended



particles and greases.  It will eventually become plugged or



binded with solids, or coated with grease and oils, and not be



able to sustain the flow of wastewater.  Consequently,  the more



suspended solids or grease and oils in the GAC column influent,



the sooner it must be backwashed, hence slowing the dissolved



organic compound removal rate.
                              3-29                         Rev. 3

-------
(4)  Physical Description of the Process








     Specific designs will depend on the waste stream to be



treated and the type of end product desired.  However, a few



examples will provide some idea of how these systems work.








     i.  Systems using PAC.  PAC can be easily used in exiting



equipment such as tanks, filtration or settling apparatus.  Since



it is a fine powder, it is usually put directly into the waste



stream.  It needs lower contact times than GAC because it adsorbs



contaminants more quickly.  PAC usually has less adsorption



capacity than GAC, so more is required.  A few treatment systems



are described below.








        (a)  Batch system.  The incoming waste stream is



thoroughly stirred with the PAC, usually with some type of



mechanical agitator.  The stirring time (contact time) is usually



20 to 30 minutes in most cases.  After adsorption equilibrium is



reached, the mixture is settled and/or filtered to separate the



PAC from the wastewater.  This procedure can be separated to



increase filtrate clarity.








        (b)  Continuous system.  In a continuous system both the



waste liquid and carbon slurry enter mixing tanks simultaneously



and continuously.  Continuous settling and/or filtration again



follow the mixing.
                               3-30                         Rev. 3

-------
     ii. Systems using GAG.  In GAG systems the carbon is packed


in columns and the liquid is passed through a bed of the carbon.

The liquid flow can be either up or down through the vertical


column.  Figure 3-4 shows some common systems.




     Typically, the wastewater to be treated is passed downward


through a stationary bed of carbon.  The constituent to be


removed is adsorbed most rapidly and effectively by the upper few


layers of fresh carbon during the initial stages of operation.


These upper layers are in contact with the wastewater at its


highest concentration level.  The small amounts of target


constituent that escape adsorption in the first few layers of the


activated carbon are removed from solution in the lower or


downstream portion of the bed.  Initially, none of the


constituent to be removed escapes form the adsorbent.




     As the liquid flows down the column, the adsorption capacity


is reached in the top layers, the adsorption zone starts moving


down the column.  As the adsorption zone moves near the end of

the bed, the concentration in the effluent rapidly approaches the

influent concentration.  This point in the operation is referred


to as breakthrough.  A breakthrough curve (Figure 3-5) is the

plot of the ratio of effluent to influent concentrations versus
                                         V
time of operation.  At breakthrough the bed is exhausted and


little additional removal of the constituent will occur.  At this


point, the carbon must be replaced or regenerated.
                               3-31                         Rev. 3

-------
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       DOHNFLOH  IN SERIES
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      COCURRENT IN PARALLEL
COUNTEHCUHHENT- EXPANDED  IN  SERIES
SOURCE* RIZZO AND SHEPHARD 1987
         FIGURE  3-4  TYPICAL  COLUMN CONFIGURATIONS
                                   3-32
                             Rev. 3

-------
e  '
                                  ce-c
               RATIO  OF  EFFLUENT
               TO  INFLUENT  CONCENTRATIONS
               KITH RESPECT TO TINE
                                                                    M O
                                                                    O 3D
                                                                    Z TJ
                                                                    m -H
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-------
(5)  Design and Operating Parameters







     Design Parameters








     The system design must account for three parameters that



affect the ability of activated carbon to adsorb contaminants: i)



contact time, ii) carbon particle type and size, and iii)



wastewater flow rate.








     i.  Contact time.  For both PAC/GAC systems, contact time



must be determined by testing individual wastes with different



activated carbon samples.  Once contact time is determine for



adequate removal of contaminants, tank sizing is the next step



and it will depend on waste flow rate.








     ii.  Carbon particle type and size.  Activated carbon is



made from a variety of substances (e.g., coal, wood), ground to



many different sizes, and manufactured with "customized" pore



sizes.  A range of surface areas and individual pore sizes will



determine the carbon's adsorptive capacity.  Bench testing is



recommended to determine the most effective activated carbon



product for a particular waste stream and desired effluent.








     iii.  Wastewater flow rate.  GAG systems are designed for



upflow or downflow operation.  For both types, there are



practical limits to the liquid velocity.  Once the velocity and










                               3-34                         Rev. 3

-------
contact time are determined, the bed cross-section and depth are

sized to meet these requirements.




     Operating Parameters




     A number of parameters must be maintained during operation

to ensure that the adsorption system adheres to the design

specifications.  These are:  (i) waste liquid concentration, (ii)

suspended oils and solids, and  (iii) contact time.




     i.  Waste liquid concentration.  In GAG systems, the

concentration has a direct effect on the operation of an

adsorption system because if the concentration is significantly

higher than the design concentration, column breakthrough will

occur quickly and excessive regeneration will be required.

Conversely, if, during the operation of a column, the waste

liquid concentration decreases significantly, previously adsorbed

molecules can be desorbed from the carbon and be discharged in

the effluent stream.  Additionally, changes in the waste

composition can cause previously adsorbed molecules to be

desorbed and replaced by molecules of a different constituent if

the new constituent has a higher affinity for the carbon surface.

These types of situations can lead to effluent concentrations for
                                         V
a particular waste constituent that are higher than influent

concentrations.  Waste liquid concentration has a lesser effect

on PAC systems because the PAC is removed as it is spent.
                               3-35                         Rev. 3

-------
Desorption is not a problem.  However, if the concentration


increases significantly over the design concentrations, excessive

quantities of PAC may be required.  In any case, the effluent

must be monitored for breakthrough of contaminants.




     ii-  Suspended oils and solids.  Suspended oils and solids

are not usually a problem with PAC systems.  However, in GAC

systems, oils and suspended solids in the waste will eventually

plug the column.  If the concentration of solids is significant

(typically greater than 200 mg/1), the waste will need to be

pretreated to remove them.  In any case,  suspended solids and

greases present in the GAC column influent will necessitate

backwashing and/or column cleaning.  The need for such cleaning

can be detected with pressure gauges which monitor the degree of

plugging.




     iii.  Contact time.  Contact time requirements vary with the

type of system but must be maintained within design

specifications.  Typical contact times vary between 300 and 100

minutes for GAC systems, and are somewhat lower for PAC systems.

For GAC systems, typical downflow rates are between 20 and 330

1/min m2 of bed area.   A typical upflow rate is 610 1/min m2 of


bed area, unless the bed is fluidized in which case higher
                                        V
velocities are necessary.   Contact time is monitored by measuring

wastewater flow rate,  since system volume is predetermined.
                              3-36                         Rev. 3

-------
3.2.4  Incineration







     This section addresses the commonly used incineration



technologies: Liquid injection, rotary kiln, fluidized bed



incineration, and fixed hearth.  A discussion is provided



regarding the applicability of these technologies, the underlying



principles of operation, a technology description, waste



characteristics that affect performance, and finally important



design and operating parameters.  As appropriate the subsections



are divided by type of incineration unit.







(1)  Applicability and Use of this Technology







     i.  Liquid Injection



     Liquid injection is applicable to wastes that have viscosity



values sufficiently low so that the waste can be atomized in the



combustion chamber.  A range of literature maximum viscosity



values are reported with the low being 100 SSU and the high being



10,000 SSU.  It is important to note that viscosity is



temperature dependent so that while liquid injection may not be



applicable to a waste at ambient conditions, it may be applicable



when the waste is heated.  Other factors that affect the use of



liquid injection are particle size and the presence of suspended



solids.  Both of these waste parameters can cause plugging of the



burner nozzle.
                               3-37                         Rev. 3

-------
     ii.  Rotary Kiln/ Fluidized Bed/ Fixed Hearth



     These incineration technologies are applicable to a wide



range of hazardous wastes.  They can be used on wastes that



contain high or low total organic content, high or low filterable



solids, various viscosity ranges, and a range of other waste



parameters.  EPA has not found these technologies to be



demonstrated on wastes that are comprised essentially of metals



with low organic concentrations.  In addition, the Agency expects



that some of the high metal content wastes may not be compatible



with existing and future air emission limits without emission



controls far more extensive than currently practiced.







(2)  Underlying Principles of Operation








     i.  Liquid Injection



     The basic operating principle of this incineration



technology is that incoming liquid wastes are volatilized and



then additional heat is supplied to the waste to destabilize the



chemical bonds.  Once the chemical bonds are broken, these



constituents react with oxygen to form carbon dioxide and water



vapor.  The energy needed to destabilize the bonds is referred to



as the energy of activation.








     ii.  Rotary Kiln and Fixed Hearth



     There are two distinct principles of operation for these



incineration technologies, one for each of the chambers involved.
                               3-38                         Rev. 3

-------
In the primary chamber, energy, in the form of heat, is

transferred to the waste to achieve volatilization of the various

organic waste constituents.  During this volatilization process

some of the organic constituents will oxidize to CO  and water

vapor.  In the secondary chamber, additional heat is supplied to

overcome the energy requirements needed to destabilize the

chemical bonds and allow the constituents to react with excess

oxygen to form carbon dioxide and water vapor.  The principle of

operation for the secondary chamber is similar to liquid

injection.




     iii.  Fluidized Bed

     The principle of operation for this incinerator technology

is somewhat different than for rotary kiln and fixed hearth

incineration relative to the functions of the primary and

secondary chambers.  In fluidized bed, the purpose of the primary

chamber is not only to volatilize the wastes but also to

essentially combust the waste.  Destruction of the waste organics

can be accomplished to a better degree in the primary chamber of

this technology than for rotary kiln and fixed hearth because of

1) improved heat transfer from fluidization of the waste using

forced air and 2) the fact that the fluidization process provides

sufficient oxygen and turbulence to convert the organics to
                                         V
carbon dioxide and water vapor.  The secondary chamber (referred

to as the freeboard) generally does not have an afterburner;

however, additional time is provided for conversion of the
                               3-39                         Rev. 3

-------
organic constituents to carbon dioxide, water vapor, and



hydrochloric acid if chlorine is present in the waste.



(3)  Description of Incineration Technologies








     i.  Liquid Injection



     The liquid injection system is capable of incinerating a



wide range of gases and liquids.  The combustion system has a



simple design with virtually no moving parts.  A burner or nozzle



atomizes the liquid waste and injects it into the combustion



chamber where it burns in the presence of air or oxygen.  A



forced draft system supplies the combustion chamber with air to



provide oxygen for combustion and turbulence for mixing.  The



combustion chamber is usually a cylinder lined with refractory



(i.e., heat resistant) brick and can be fired horizontally,



vertically upward, or vertically downward.   Figure 3-6



illustrates a liquid injection incineration system.







     ii.  Rotary Kiln



     A rotary kiln is a slowly rotating, refractory-lined



cylinder that is mounted at a slight incline from the horizontal



(see Figure 3-7).  Solid wastes enter at the high end of the



kiln, and liquid or gaseous wastes enter through atomizing



nozzles in the kiln or afterburner section.  Rotation of the kiln



exposes the solids to the heat, vaporizes them, and allows them



to combust by mixing with air.  The rotation also causes the ash



to move to the lower end of the kiln where it can be removed.
                               3-40                         Rev. 3

-------
                                                    WATER
  AUXILIARY-
    FUEL
BURNER
I
it*
  LIQUID OR
  GASEOUS
   WASTE
  INJECTION
BURNER
          PRIMARY
         COMBUSTION
          CHAMBER
AETERBURNER
(SECONDARY
COMBUSTION
  CHAMBER)
                          ASH
                                                   SPRAY
                                                  CHAMBER
                                        T
                                                                 GAS TO AIR
                                                                 POLLUTION
                                                                 CONTROL
                        HORIZONTALLY FIRED
                        LIQUID INJECTION
                        INCINERATOR
                                                    WATER
(D
                   FIGURE 3-6
           LIQUID INJECTION INCINERATOR

-------
                                                 GAS TO
                                               AIR POLLUTION
                                                 CONTROL
              AUXILIARY
               FUEL
SOLID WASTE
  INFLUENT
              FEED
             MECHANISM
AFTERBURNER
 COMBUSTION
     GASES
                     LIQUID OR
                     GASEOUS
                  WASTE INJECTION
 ASH
          FIGURE 3-7   ROTARY KILN INCINERATOR
                              3-42
                                                         Rev. 3

-------
Rotary kiln systems usually have a secondary combustion chamber


or afterburner following the kiln for further combustion of the

volatilized components of solid wastes.




     iii.  Fluidized Bed


     A fluidized bed incinerator consists of a column containing


inert particles such as sand which is referred to as the bed.


Air, driven by a blower, enters the bottom of the bed to fluidize


the sand.  Air passage through the bed promotes rapid and uniform


mixing of the injected waste material within the fluidized bed.


The fluidized bed has an extremely high heat capacity


(approximately three times that of flue gas at the same


temperature), thereby providing a large heat reservoir.  The


injected waste reaches ignition temperature quickly and transfers


the heat of combustion back to the bed.  Continued bed agitation


by the fluidizing air allows larger particles to remain suspended


in the combustion zone.  (See Figure 3-8).




     iv.  Fixed Hearth Incineration


     Fixed hearth incinerators, also called controlled air or

starved air incinerators, are another major technology used for


hazardous waste incineration.  Fixed hearth incineration is a


two-stage combustion process (see Figure 3-9).   Waste is ram-fed
                                         *•
into the first stage, or primary chamber, and burned at less than


stoichiometric conditions.   The resultant smoke and pyrolysis


products, consisting primarily of volatile hydrocarbons and
                              3-43                         Rev. 3

-------
WASTE
INJECTION
                       FREEBOARD
                                            GAS TO AIR
                                            POLLUTION
                                            CONTROL
                                               MAKE-UP
                                               SAND
                                              AIR
                          ASH
                       FIGURE 3-8

                FLUIDIZED BED INCINERATOR
                           3-44
Rev. 3

-------
                                                      AIR
                                                                            GAS TO AIR
                                                                            POLLUTION
                                                                             CONTROL
        AIR
u>
*fc
in
       WASTE
     INJECTION
                    BURNER
  PRIMARY
COMBUSTION
  CHAMBER

    GRATE
 SECONDARY
COMBUSTION
  CHAMBER
                                                                                t
                  AUXILIARY
                    EUEL
                                        2 - STAGE EIXED HEARTH
                                              INCINERATOR
                                   ASH
o>
                              FIGURE 3-9  FIXED HEARTH INCINERATOR

-------
carbon monoxide, along with the normal products of combustion,

pass to the secondary chamber.  Here,  additional air is injected

to complete the combustion.  This two-stage process generally

yields low stack particulate and carbon monoxide (CO)  emissions.

The primary chamber combustion reactions and combustion gas are

maintained at low levels by the starved air conditions so that

particulate entrainment and carryover are minimized.




     v.  Air Pollution Controls

     Following incineration of hazardous wastes, combustion gases

are generally further treated in an air pollution control system.

The presence of chlorine or other halogens in the waste requires

a scrubbing or absorption step to remover HC1 and other

halo-acids from the combustion gases.   Ash in the waste is not

destroyed in the combustion process.  Depending on its

composition, ash will either exit as bottom ash, at the discharge

end of a kiln or hearth for example, or as particulate matter

(fly ash) suspended in the combustion gas stream.  Particulate

emissions from most hazardous waste combustion systems generally

have particle diameters less than one micron and require high

efficiency collection devices to minimize air emissions.  In

addition, scrubber systems provide additional buffer against

accidental releases of incompletely destroyed waste products due
                                        *
to poor combustion efficiency or combustion upsets, such as flame

outs.
                               3-46                        Rev. 3

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(4)  Waste Characteristics Affecting Performance (WCAP)







     i.  Liquid Injection



     In determining whether liquid injection is likely to achieve



the same level of performance on an untested waste as a



previously tested waste, the Agency will compare dissociation



bond energies of the constituents in the untested and tested



waste.  This parameter is being used as a surrogate indicator of



activation energy which, as discussed previously, destabilizes



molecular bonds.  In theory, the bond dissociation energy would



be equal to the activation energy; however, in practice this is



not always the case.Other energy effects (e.g., vibrational, the



formation of intermediates, and interactions between different



molecular bonds) may have a significant influence on activation



energy.








     Because of the shortcomings of bond energies in estimating



activation energy, EPA analyzed other waste characteristic



parameters to determine if these parameters would provide a



better basis for transferring treatment standards from an



untested waste to a tested waste.  These parameters include heat



of combustion, heat of formation, use of available kinetic data



to predict activation energies, and general structural class.



All of these were rejected for reasons provided below.
                              3-47                         Rev. 3

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     The heat of combustion only measures the difference in



energy of the products and reactants; it does not provide



information on the transition state  (i.e., the energy input



needed to initiate the reaction).  Heat of formation is used as a



predictive tool for whether reactions are likely to proceed;



however, there are a significant number of hazardous constituents



for which these data are not available.  Use of kinetic data were



rejected because these data are limited and could not be used to



calculate free energy values (A G) for the wide range of



hazardous constituents to be addressed by this rule.  Finally,



EPA decided not to use structural classes because the Agency



believes that evaluation of bond dissociation energies allows for



a more direct determination of whether a constituent will be



destabilized.








     ii.  Rotary Kiln/Fluidized Bed/Fixed Hearth



     Unlike liquid injection,  these incineration technologies



also generate a residual ash.   Accordingly,  in determining



whether these technologies are likely to achieve the same level



of performance on an untested waste as a previously tested waste,



EPA would need to examine the waste characteristics that affect



volatilization of organics from the waste, as well as,



destruction of the organics,  once volatilized.  Relative to



volatilization, EPA will examine thermal conductivity of the



entire waste and boiling point of the various constituents.  As



with liquid injection,  EPA will examine bond energies in
                              3-48                         Rev. 3

-------
determining whether treatment standards for scrubber water



residuals can be transferred from a tested waste to an untested



waste.  Below is a discussion of how EPA arrived at thermal



conductivity and boiling point as the best method to assess



volatilization of organics from the waste; the discussion



relative to bond energies is the same for these technologies as



for liquid injection and will not be repeated here.
     Thermal Conductivity



     Consistent with the underlying principles of incineration, a



major factor with regard to whether a particular constituent will



volatilize is the transfer of heat through the waste.  In the



case of rotary kiln, fluidized bed, and fixed hearth



incineration, heat is transferred through the waste by three



mechanisms:  radiation, convection, and conduction.  For a given



incinerator, heat transferred through various wastes by radiation



is more a function of the design and type of incinerator than the



waste being treated.  Accordingly, the type of waste treated will



have a minimal impact on the amount of heat transferred by



radiation.  With regard to convection, EPA also believes that the



type of heat transfer will generally be more a function of the



type and design of incinerator than the waste itself.  However,



EPA is examining particle size as a waste characteristic that may



significantly impact the amount of heat transferred to a waste by



convection and thus impact volatilization of the various organic










                               3-49                        Rev. 3

-------
compounds.  The final type of heat transfer, conduction, is the



one that EPA believes will have the greatest impact on



volatilization of organic constituents.   To measure this



characteristic, EPA will use thermal conductivity; an explanation



of this parameter, as well as, how it can be measured is provided



below.








     Heat flow by conduction is proportional to the temperature



gradient across the material.  The proportionality constant is a



property of the material and referred to as the thermal



conductivity.  (Note:  The analytical method that EPA has



identified for measurement of thermal conductivity is named



"Guarded, Comparative, Longitudinal Heat Flow Technique"; it is



described in Appendix F.)  In theory, thermal conductivity would



always provide a good indication of whether a constituent in an



untested waste would be treated to the same extent in the primary



incinerator chamber as the same constituent in a previously



tested waste.







     In practice, thermal conductivity has some limitations in



assessing the transferability of treatment standards; however,



EPA has not identified a parameter that can provide a better



indication of heat transfer characteristics of a waste.  Below is



a discussion of both the limitations associated with thermal



conductivity, as well as other parameters considered.
                               3-50                         Rev. 3

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     Thermal conductivity measurements, as part of a treatability

comparison for two different wastes through a single incinerator,

are most meaningful when applied to wastes that are homogeneous

(i.e., major constituents are essentially the same).  As wastes

exhibit greater degrees of non-homogeneity (e.g., significant

concentration of metals in soil), then thermal conductivity

becomes less accurate in predicting treatability because the

measurement essentially reflects heat flow through regions having

the greatest conductivity (i.e., the path of least resistance)

and not heat flow through all parts of the waste.




     BTU value, specific heat, and ash content were also

considered for predicting heat transfer characteristics.  These

parameters can no better account for non-homogeneity than thermal

conductivity; additionally,  they are not directly related to heat

transfer characteristics.  Therefore, these parameters do not

provide a better indication of heat transfer that will occur in

any specific waste.




     Boiling Point

     Once heat is transferred to a constituent within a waste,

then removal of this constituent from the waste will depend on

its volatility.  As a surrogate of volatility, EPA is using
                                         V
boiling point of the constituent.  Compounds with lower boiling

points have higher vapor pressures and, therefore, would be more

likely to vaporize.  The Agency recognizes that this parameter
                               3-51                         Rev. 3

-------
does not take into consideration the impact of other compounds in

the waste on the boiling point of a constituent in a mixture;

however, the Agency is not aware of a better measure of

volatility that can easily be determined.




(5)  Incineration Design and Operating Parameters




     i.  Liquid Injection

     For a liquid injection unit, EPA's analysis of whether the

unit is well designed will focus on (1) the likelihood that

sufficient energy is provided to the waste to overcome the

activation level for breaking molecular bonds and (2)  whether

sufficient oxygen is present to convert the waste constituents to

carbon dioxide and water vapor.  The specific design parameters

that the Agency will evaluate to assess whether these conditions

are met are:  temperature, excess oxygen,  and residence time.

Below is a discussion of why EPA believes  these parameters to be

important, as well as a discussion of how  these parameters will

be monitored during operation.




     It is important to point out that, relative to the

development of land disposed restriction standards,  EPA is only

concerned with these design parameters when a quench water or
                                        v
scrubber water residual is generated from  treatment of a

particular waste.  If treatment of a particular waste in a liquid

injection unit would not generate a wastewater stream, then the
                              3-52                         Rev. 3

-------
Agency, for purposes of land disposal treatment standards, would



only be concerned with the waste characteristics that affect



selection of the unit, not the above-mentioned design parameters.







     Temperature



     Temperature is important in that it provides an indirect



measure of the energy available (i.e., BTUs/hr) to overcome the



activation energy of waste constituents.  As the design



temperature increases, the more likely it is that the molecular



bonds will be destabilized and the reaction completed.







     The temperature is normally controlled automatically through



the use of instrumentation which senses the temperature and



automatically adjusts the amount of fuel and/or waste being fed.



The temperature signal transmitted to the controller can be



simultaneously transmitted to a recording device, referred to as



a strip chart, and thereby continuously recorded.  To fully



assess the operation of the unit,  it is important to know not



only the exact location in the incinerator that the temperature



is being monitored but also the location of the design



temperature.







     Excess Oxygen



     It is important that the incinerator contain oxygen in



excess of the stiochiometric amount necessary to convert the



organic compounds to carbon dioxide and water vapor.  If










                              3-53                         Rev.  3

-------
insufficient oxygen is present,  then destabilized waste



constituents could recombine to the same or other BDAT list



organic compounds and potentially cause the scrubber water to



contain higher concentrations of BDAT list constituents than



would be the case for a well operated unit.







     In practice, the amount of oxygen fed to the incinerator is



controlled by continuous sampling and analysis of the stack gas.



If the amount of oxygen drops below the design value, then the



analyzer transmits a signal to the valve controlling the air



supply and thereby increases the flow of oxygen to the



afterburner.  The analyzer simultaneously transmits a signal to a



recording device so that the amount of excess oxygen can be



continuously recorded.  Again, as with temperature, it is



important to know the location from which the combustion gas is



being sampled.







     Carbon Monoxide



     Carbon monoxide is an important operating parameter because



it provides an indication of the extent to which the waste



organic constituents are being converted to CO- and water vapor.



As the carbon monoxide level increases, it indicates that greater



amounts of organic waste constituents are unreacted or partially



reacted.  Increased carbon monoxide levels can result from



insufficient excess oxygen, insufficient turbulence in the



combustion zone, or insufficient residence time.










                               3-54                        Rev. 3

-------
     Waste Feed Rate



     The waste feed rate is important to monitor because it is



correlated to the residence time.  The residence time is



associated with a specific BTU energy value of the feed and a



specific volume of combustion gas generated.  Prior to



incineration, the BTU value of the waste is determined through



the use of a laboratory device known as a bomb calorimeter.  The



volume of combustion gas generated from the waste to be



incinerated is determined from an analysis referred to as an



ultimate analysis.  This analysis determines the amount of



elemental constituents present which include carbon, hydrogen,



sulfur, oxygen, nitrogen, and halogens.  Using this analysis plus



the total amount of air added, the volume of combustion gas can



be calculated.  Having determined both the BTU content and the



expected combustion gas volume, the feed rate can be fixed at the



desired residence time.  Continuous monitoring of the feed rate



will determine whether the unit was operated at a rate



corresponding to the designed residence time.







     ii.  Rotary Kiln



     For this incineration, EPA will examine both the primary and



secondary chamber in evaluating the design of a particular



incinerator.  Relative to the primary chamber, EPA's assessment



of design will focus on whether it is likely that sufficient



energy will be provided to the waste in order to volatilize the



waste constituents.  For the secondary chamber,
                               3-55                         Rev. 3

-------
analogous to the sole liquid injection incineration chamber, EPA



will examine the same parameters discussed previously under



liquid injection incineration.  These parameters will not be



discussed again here.







     The particular design parameters to be evaluated for the



primary chamber are:  kiln temperature, residence time, and



revolutions per minute.  Below is a discussion of why EPA



believes these parameters to be important, as well as a



discussion of how these parameters will be monitored during



operation.







     Temperature



     The primary chamber temperature is important, in that it



provides an indirect measure of the energy input  (i.e., BTUs/hr)



that is available for heating the waste.  The higher the



temperature is designed to be in a given kiln, the more likely it



is that the constituents will volatilize.  As discussed earlier



under "Liquid Injection", temperature should be continuously



monitored and recorded.  Additionally, it is important to know



the location of the temperature sensing device in the kiln.








     Residence Time



     This parameter is important in that it affects whether



sufficient heat is transferred to a particular constituent in



order for volatilization to occur.  As the time that the waste is
                               3-56                        Rev. 3

-------
in the kiln is increased, a greater quantity of heat is



transferred to the hazardous waste constituents.  The residence



time will be a function of the specific configuration of the



rotary kiln including the length and diameter of the kiln, the



waste feed rate, and the rate of rotation.







     Revolutions Per Minute (RPM)



     This parameter provides an indication of the turbulence that



occurs in the primary chamber of a rotary kiln.  As the



turbulence increases, the quantity of heat transferred to the



waste would also be expected to increase.  However, as



the RPM value increases, the residence time decreases resulting



in a reduction of the quantity of heat transferred to the waste.



This parameter needs to be carefully evaluated because it



provides a balance between turbulence and residence time.








     iii.  Fluidized Bed



     As discussed previously, in the section on "Underlying



Principles of Operation", the primary chamber accounts for almost



all of the conversion of organic wastes to carbon dioxide, water



vapor, and acid gas if halogens are present.  The secondary



chamber will generally provide additional residence time for



thermal oxidation of the waste constituents.  Relative to the



primary chamber, the parameters that the Agency will examine in



assessing the effectiveness of the design are temperature,



residence time, and bed pressure differential.  The first two
                               3-57                         Rev. 3

-------
were discussed under rotary kiln and will not be discussed here.



The latter, bed pressure differential, is important in that it



provides an indication of the amount of turbulence and,



therefore, indirectly the amount of heat supplied to the waste.



In general, as the pressure drop increases, both the turbulence



and heat supplied increase.  The pressure drop through the bed



should be continuously monitored and recorded to ensure that the



designed valued is achieved.








     iv.  Fixed Hearth



     The design considerations for this incineration unit are



similar to a rotary kiln with the exception that rate of rotation



(i.e., RPMs) is not an applicable design parameter.  For the



primary chamber of this unit, the parameters that the Agency will



examine in assessing how well the unit is designed are the same



as discussed under rotary kiln; for the secondary chamber (i.e.,



afterburner), the design and operating parameters of concern are



the same as previously discussed under "Liquid Injection".
                               3-58                         Rev. 3

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3.3  Performance Data for Wastewaters




     Of the three demonstrated treatment technology systems

defined in Section 3.2, the Agency collected performance data for

the system consisting of liquid/liquid extraction followed by

steam stripping and activated carbon adsorption.  This treatment

system was chosen by the EPA for collecting performance data

because the liquid/liquid extraction step in this three-step


treatment process provides an incremental reduction in the level

of organics over that obtained by either of the other two

treatment processes.




     Performance data collected by EPA for liquid/liquid

extraction followed by stream stripping and carbon adsorption are

presented in Tables 3-1 to 3-5.  Tables 3-1 through 3-5 present

the analytical data for sample sets I through 5 collected during

the Agency's sampling visit.  The untreated K103 and K104 wastes

and the combined treated steam leaving the carbon adsorption beds

for each sample set were analyzed for BOAT volatile and

semivolatile organic compounds, metals, inorganic compounds, and

other parameters.




     Included in Tables 3-1 through 3-5 are the design values and
                                         *•
actual operating ranges for the key operating parameters of the

aniline liquid/liquid extractor, nitrobenzene liquid/liquid
                               3-59                         Rev. 3

-------
TABLE  3-1  TREATMENT DATA FOR  LIQUID/LIQUID EXTRACTION  FOLLOWED BY STEAM STRIPPING AND
          ACTIVATED CARBON ADSORPTION - EPA COLLECTED  DATA
                                          SAMPLE  SET  1
BOAT CONSTITUENTS DETECTED
Volatile Organic Compounds
4 Benzene
48 Trichloromonof luoromethane
Semi volatile Organic Compounds
56 Aniline
101 2,4-Dinitrophenol
126 Nitrobenzene
142 Phenol
Metals
155 Arsenic
156 Barium
159 Chromium
160 Copper
161 Lead
163 Nickel
167 Vanadium
168 Zinc
Inorganics
169 Total Cyanides
170 Fluorides
171 Sulfides
UNTREATED
K103
(mg/l)

81
<2.5

51,000
<7,500
<1.500
<1,500

<0.010
<0.001
<0.007
<0.006
<0.005
<0.011
<0.006
0.021

0.0748
<0.20
89.0
WASTE
K104

240
<10

<150
<750
2,700
<150

<0.010
0.0078
0.432
0.012
<0.050
0.238
<0.006
0.079

6.28
<0.20
<1.0*
TREATED WASTE
(mg/l)

0.042
0.007

<0.030
0.380
<0.030
<0.030

<0.010
0.032
0.0097
<0.006
<0.500
<0.011
0.014
0.058

0.565
0.590
<1.0*
  * - Negative Interference Value
                                                                                          Continued
                                                  3-60
Rev.  3

-------
TABLE 3-1  (Continued) TREATMENT DATA FOR LIQUID/LIQUID  EXTRACTION FOLLOWED BY STEAM
           STRIPPING AND ACTIVATED CARBON ADSORPTION  - EPA  COLLECTED DATA
                                            SAMPLE  SET  1
OPERATING PARAMETERS
      Design Value
Operating Range
Aniline Liquid/Liquid Extractor :

Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
                o
     Extractor ( C)
      7,000 - 25,000
          9 - 10**

          40.0**
14,400 - 14,500
      10.3

      13.0
Nitrobenzene Liquid/Liquid Extractor
Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
     Extractor ( C)
     27,000 - 35,000
         Max. 2.4

        25.0 - 65.0
21,300 - 46,000
       0.2

      39.0
Steam Stripper :

                        o
Top Column Temperature ( C)
Pressure Drop Across the
     ColumnCinches of water)
Feed Rate to Steam Stripper(Ibs/hr)

Activated Carbon Adsorption:

Feed Rate to the System (Ibs/hr)
Feed pH to the System
Feed Temperature to the
     System (°C)
Total Organic Carbon in treated
     waste (mg/l)
Calculated Residence time (minutes)
         Min. 95.0

         Max. 90.0
Min. 20,000,  Max.  90,000
         Max. 65,300
         Min. 7.0

            40.0**
         Max. 250
         Instantaneous
         Min. 85
      95***

 44.26 - 51.00
59,400 - 59,480
61,600 - 68,600
      10.6

      25.0
      79.3

    81 - 90
  a - Onsite Engineering Report  for  E.  I. duPont de Nemours, Inc., Beaumont, Texas,
      Tables 4-1 through 4-3,  6-6, 6-8,  and  6-14.
 ** - Not controlled.   Normal  operating  value  is given.
*** - Mid column substituted for top column  temperature due to technical difficulties.
                                                    3-61
                                                       Rev.  3

-------
TABLE  3-2  TREATMENT DATA FOR LIQUID/LIQUID EXTRACTION  FOLLOWED BY STEAM STRIPPING AND
          ACTIVATED CARBON ADSORPTION - EPA COLLECTED  DATA8
                                          SAMPLE SET  2
BOAT CONSTITUENTS DETECTED
Volatile Organic Compounds
4 Benzene
48 Trichloromonof luoromethane
Semivolati le Organic Compounds
56 Aniline
101 2,4-Dinitrophenol
126 Nitrobenzene
142 Phenol
Metals
155 Arsenic
156 Barium
159 Chromium
160 Copper
161 Lead
163 Nickel
167 Vanadium
168 Zinc
Inorganics
169 Total Cyanides
170 Fluorides
171 Sulfides
UNTREATED
K103
(mg/l)

73
<5

33.000
<7,500
<1,500
<1,500

<0.010
<0.001
<0.007
<0.006
<0.005
<0.011
<0.006
0.003

0.0595
<0.20
89.0
WASTE
K104

320
<20

<150
<750
2.200
<150

<0.100
0.0015
0.097
<0.006
<0.100
0.055
<0.006
0.011

3.30
<0.20
<1.0*
TREATED WASTE
(mg/l)

<0.005
0.010

<0.030
0.320
O.030
<0.030

<0.100
0.042
0.024
<0.006
<0.050
<0.011
0.012
0.052

0.597
0.420
<1.0*
  * - Negative Interference Value
                                                                                          Cont i nued
                                                   3-62
                                                                                                Rev.  3

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TABLE 3-2  (Continued)  TREATMENT DATA  FOR LIQUID/LIQUID EXTRACTION FOLLOWED BY STEAM
           STRIPPING AND  ACTIVATED  CARBON ADSORPTION - EPA COLLECTED DATA
                                           SAMPLE SET 2
OPERATING PARAMETERS
      Design Value
Operating Range
Aniline Liquid/Liquid Extractor  :

Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
     Extractor ( C)
      7,000 -  25,000
          9 -  10**

          40.0**
15,900 - 16,000
      10.3

      22.0
Nitrobenzene Liquid/Liquid Extractor
Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
     Extractor ( C)
     27,000 - 35,000
         Max. 2.4

        25.0 - 65.0
 9,800 - 26,000
      0.2

      43.0
Steam Stripper :
                        o
Top Column Temperature ( C)
Pressure Drop Across the
     ColumnCinches of water)
Feed Rate to Steam Stripper(lbs/hr)
         Min.  95.0

         Max.  90.0
Min. 20,000,  Max.  90,000
  102.2 - 103.3

 42.40 - 58.00
49,000 - 60,100
Activated Carbon Adsorption:
Feed Rate to the System (Ibs/hr)
Feed pH to the System
Feed Temperature to the
o
System ( C)
Total Organic Carbon in treated
waste (mg/l)
Calculated Residence time (minutes)
Max. 65,300
Min. 7.0


40.0**
Max. 250
Instantaneous
Min. 85
63,000 - 76,
4.6


28.0

73.5
73 - 88
000







  a - Onsite Engineering Report  for  E.  I. duPont de Nemours, Inc., Beaumont, Texas,
      Tables 4-1 through 4-3,  6-6, 6-8,  and 6-14.
 ** - Not controlled.   Normal  operating  value  is given.
                                                    3-63
                                                       Rev.  3

-------
TABLE 3-3   TREATMENT DATA FOR LIQUID/LIQUID EXTRACTION FOLLOWED  BY  STEAM STRIPPING AND
           ACTIVATED CARBON ADSORPTION -  EPA COLLECTED DATA
                                          SAMPLE SET 3
BOAT CONSTITUENTS DETECTED
Volatile Organic Compounds
4 Benzene
48 Trichlorof luoromethane
Semi volatile Organic Compounds
56 Aniline
101 2,4-Dinitrophenol
126 Nitrobenzene
142 Phenol
Metals
155 Arsenic
156 Barium
159 Chromium
160 Copper
161 Lead
163 Nickel
167 Vanadium
168 Zinc
Inorganics
169 Total Cyanides
170 Fluorides
171 Sulfides
UNTREATED
K103
(mg/l)

65
<2.5

39,000
<15,000
<3,000
<3,000

<0.010
<0.001
<0.007
<0.006
<0.005
<0.011
<0.006
0.0099

0.0411
<0.20
74.0
WASTE
K104

70
<5

<150
<750
2,300
<150

<0.010
0.011
<0.007
0.0075
<0.005
<0.011
<0.006
0.031

5.70
<0.20
<1.0*
TREATED WASTE
(mg/l)

0.018
O.005

4.20
<0.760
<0.150
<0.150

<0.010
0.068
0.008
<0.006
<0.005
<0.011
0.0091
0.016

0.201
0.220
<1.0*
  * -  Negative  Interference Value
                                                                                           Continued
                                                   3-64
Rev.  3

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TABLE 3-3  (Continued)  TREATMENT  DATA  FOR  LIQUID/LIQUID EXTRACTION FOLLOWED BY STEAM
           STRIPPING AND  ACTIVATED  CARBON  ADSORPTION - EPA COLLECTED DATA3
                                           SAMPLE SET 3
OPERATING PARAMETERS
      Design Value
Operating Range
Aniline Liquid/Liquid Extractor :

Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
     Extractor ( C)
      7,000 - 25,000
          9 - 10**

          40.0**
17,600 - 17,800
      10.1

     24.0
Nitrobenzene Liquid/Liquid Extractor
Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
     Extractor ( C)
     27,000 - 35,000
         Max. 2.4

        25.0 - 65.0
24,100 - 33,000
       5.7

      42.5
Steam Stripper :

                        o
Top Column Temperature ( C)
Pressure Drop Across the
     ColumnCinches of water)
Feed Rate to Steam Stripper(Ibs/hr)
         Min.  95.0

         Max.  90.0
Min. 20,000, Max.  90,000
 102.6 - 103.0

 46.42 - 50.33
60,200 - 60,400
Activated Carbon Adsorption:
Feed Rate to the System (Ibs/hr)
Feed pH to the System
Feed Temperature to the
o
System ( C)
Total Organic Carbon in treated
waste (mg/l)
Calculated Residence time (minutes)
Max. 65,300
Min. 7.0


40.0**
Max. 250
Instantaneous
Min. 85
57,700 - 58,140
3.1


44.0
10.8

96 - 97
  a - Onsite Engineering  Report  for E.  I. duPont de Nemours, Inc., Beaumont,  Texas,
      Tables 4-1  through  4-3, 6-6, 6-8, and 6-14.
 ** - Not controlled.   Normal operating value is given.
                                                    3-65
                                                       Rev.   3

-------
TABLE 3-4   TREATMENT DATA FOR LIQUID/LIQUID EXTRACTION FOLLOWED  BY STEAM STRIPPING AND
           ACTIVATED CARBON ADSORPTION  - EPA COLLECTED DATA8
  *  - Negative Interference Value
                                          SAMPLE SET 4
BOAT CONSTITUENTS DETECTED
Volatile Organic Compounds
4 Benzene
48 Trichlorof luoromethane
Semi volatile Organic Compounds
56 Aniline
101 2,4-Dinitrophenol
126 Nitrobenzene
142 Phenol
Metals
155 Arsenic
156 Barium
159 Chromium
160 Copper
161 Lead
163 Nickel
167 Vanadium
168 Zinc
Inorganics
169 Total Cyanides
170 Fluorides
171 Sulfides
UNTREATED
K103
(mg/l)

55
<2.5

39.000
<15.000
<3.000
<3.000

0.021
<0.001
<0.007
<0.006
<0.005
<0.011
<0.006
0.018

<0.0100
<0.20
62.0
WASTE
K104

11
<0.5

<300
<1,500
2,900
<300

<0.010
0.017
<0.007
<0.006
<0.005
<0.011
<0.006
0.064

3.06
<0.20
<1.0*
TREATED WASTE
(mg/l)

0.019
<0.005

<0.030
0.260
<0.030
<0.030

<0.500
0.076
<0.007
<0.006
<0.005
0.015
<0.006
0.033

0.156
0.220
<1.0*
                                                                                          Cont i nued
                                                  3-66
Rev.  3

-------
TABLE 3-4  (Continued)  TREATMENT  DATA  FOR  LIQUID/LIQUID EXTRACTION FOLLOWED BY STEAM
           STRIPPING AND  ACTIVATED  CARBON  ADSORPTION - EPA COLLECTED DATA
                                           SAMPLE SET 4
OPERATING PARAMETERS
      Design Value
Operating Range
Aniline Liquid/Liquid Extractor  :

Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
                o
     Extractor ( C)
      7,000 - 25,000
          9 - 10**

          40.0**
14,900 - 15,200
      10.0

      31.0
Nitrobenzene Liquid/Liquid Extractor
Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
     Extractor <°C>
     27,000 - 35,000
         Max. 2.4

        25.0 - 65.0
12,800 - 35,000
       0.8

      50.0
Steam Stripper :

                        o
Top Column Temperature ( C)
Pressure Drop Across the
     ColumnCinches of water)
Feed Rate to Steam Stripper(Ibs/hr)

Activated Carbon Adsorption:

Feed Rate to the System (Ibs/hr)
Feed pH to the System
Feed Temperature to the
     System (°C)
Total Organic Carbon in treated
     waste (mg/l)
Calculated Residence time (minutes)
         Min. 95.0

         Max. 90.0
Min. 20,000,  Max.  90,000
         Max.  65,300
         Min.  7.0

            40.0**
         Max.  250
         Instantaneous
         Min.  85
 102.9 - 103.0

 44.05 - 46.10
     60,300
59,900 - 60,000
      4.0

     38.0
      10.0

    90 - 93
  a - Onsite Engineering Report  for  E.  I. duPont de Nemours, Inc., Beaumont, Texas,
      Tables 4-1  through 4-3,  6-6, 6-8,  and 6-14.
 ** - Not controlled.   Normal  operating  value  is given.
                                                    3-67
                                                       Rev.   3

-------
TABLE 3-5   TREATMENT DATA FOR LIQUID/LIQUID EXTRACTION FOLLOWED  BY STEAM STRIPPING AND
           ACTIVATED CARBON ADSORPTION  - EPA COLLECTED DATA°
                                          SAMPLE SET 5
BOAT CONSTITUENTS DETECTED
Volatile Organic Compounds
4 Benzene
48 Trichlorof luoromethane
Semi volatile Organic Compounds
56 Aniline
101 2,4-Dinitrophenol
126 Nitrobenzene
142 Phenol
Metals
155 Arsenic
156 Barium
159 Chromium
160 Copper
161 Lead
163 Nickel
167 Vanadium
168 Zinc
Inorganics
169 Total Cyanides
170 Fluorides
171 Sulfides
UNTREATED WASTE
K103 K104
(mg/l)

32
<2.5

53,000
<15,000
<3,000
<3,000

<0.500
O.001
<0.007
<0.006
0.006
<0.011
<0.006
0.014

0.0384
<0.20
80.0

4.5
<0.25

<300
<1,500
3,900
<300

<0.500
0.013
0.0071
<0.006
<0.050
0.014
<0.006
0.014

4.44
<0.20
<1.0*
TREATED WASTE
(mg/l)

0.011
<0.005

0.960
0.230
O.030
0.150

<0.010
0.073
0.017
<0.006
<0.100
0.030
<0.006
0.012

0.129
0.620
<1.0*
  * -  Negative  Interference Value
                                                                                           Cont i nued
                                                  3-68
Rev.  3

-------
TABLE 3-5  (Continued)  TREATMENT DATA  FOR LIQUID/LIQUID EXTRACTION FOLLOWED BY STEAM
           STRIPPING AND  ACTIVATED  CARBON ADSORPTION - EPA COLLECTED DATA
                                           SAMPLE SET 5
OPERATING PARAMETERS
      Design Value
Operating Range
Aniline Liquid/Liquid Extractor :

Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
                o
     Extractor ( C)
      7,000 -  25,000
          9 -  10**

          40.0**
14,800 - 14,900
      10.2

      28.0
Nitrobenzene Liquid/Liquid Extractor
Feed Rate to the Extractor (Ibs/hr)
Feed pH to the Extractor
Feed Temperature to the
     Extractor (°C)
     27,000 -  35,000
         Max.  2.4

        Z5.0 - 65.0
24,700 - 31,500
       1.5

      47.5
Steam Stripper :

                        o
Top Column Temperature ( C)
Pressure Drop Across the
     Column(inches of water)
Feed Rate to Steam Stripper(Ibs/hr)
         Min.  95.0

         Max.  90.0
Min. 20,000,  Max.  90,000
  102.6 - 102.7

 44.80 - 51.80
57,590 - 57,660
Activated Carbon Adsorption:
Feed Rate to the System (Ibs/hr)
Feed pH to the System
Feed Temperature to the
o
System ( C)
Total Organic Carbon in treated
waste (mg/l)
Calculated Residence time (minutes)
Max. 65,300
Min. 7.0


40.0**
Max. 250
Instantaneous
Min. 85
52,200 - 61,500
3.5


33.5
7.0

91 - 107
  a - Onsite Engineering Report for E.  I.  duPont de Nemours, Inc., Beaumont, Texas,
      Tables 4-1 through 4-3,  6-6,  6-8,  and  6-14.
 ** - Not controlled.  Normal  operating  value  is given.
                                                    3-69
                                                       Rev.   3

-------
extractor, steam stripper, and activated carbon adsorption beds



for each sample set collected.







3.4  Other Applicable Treatment Technologies







     The Agency does not believe that other technologies are



applicable for treatment of K103 and K104 wastewaters because of



various physical and chemical characteristics of the wastewaters.



For a detailed description of the physical and chemical



characteristics affecting treatment selection, see BOAT



Background Document for the First Third Wastes,.  Volume 1,



Section 2.








     Liquid/liquid extraction followed by steam stripping and



activated carbon adsorption is judged to be available to treat



K103 and K104 wastewaters, and incineration is judged to be



available to treat K103 and K104 nonwastewaters.  The Agency



believes these technologies to be available because (1)  the



Agency does not have information showing that this technology



poses a greater total risk to human health and the environment



that land disposal; (2) this technology is commercially



available; and (3)  this technology provides a substantial



reduction  in the levels of BOAT constituents present in waste



K103 and K104.
                              3-70                         Rev. 3

-------
4.  IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TREATMENT
                  TECHNOLOGY FOR K103 AND K104
4.1  Introduction



     The previous section described applicable treatment

technologies for waste codes K103 and K104, and the available

performance data for these technologies.  This section describes

how the performance data collected by the Agency was evaluated to

determine which treatment technology system should be considered

BOAT for waste codes K103 and K104.  Several treatment trains are

considered in this section as BOAT for wastewaters.  They consist

of:

     o    liquid/liquid extraction,

     o    liquid/liquid extraction followed by steam stripping,

     o    liquid/liquid extraction followed by steam stripping

          and activated carbon adsorption.



     The use of activated carbon adsorption for treatment of K103

and K104 wastewaters generates a nonwastewater, spent carbon.

The treatment considered in this section as BOAT for the

nonwastewaters is rotary kiln incineration.



     The topics covered in this section include descriptions of
                                         V
the data screening process employed for selecting BOAT, the

methods used to ensure accuracy of the analytical data, and the
                               4-1                         Rev. 3

-------
analysis of variance (ANOVA)  tests performed in identifying the

best technology for the treatment of K103 and K104 wastes.



     As discussed in Section 3, the Agency collected performance

data for the treatment of waste codes K103 and K104 from one

treatment technology system:   liquid/liquid extraction followed

by steam stripping and activated carbon adsorption.  No

additional performance data were available for the treatment of

K103 and K104 wastes.  However, the Agency is using and comparing

data taken from various components of the treatment train to

determine BOAT.  Performance data were not available for the

treatment of K103 and K104 nonwastewaters.



     In general, performance data are screened according to the

following three conditions:

     o    proper design and operation of the treatment system;

     o    the existence of quality assurance/quality control
          measures in the data analysis; and

     o    the use of proper analytical tests in assessing
          treatment performance.

Sets of performance data which do not meet these three conditions

are not considered in the selection of BDAT.  In addition, if

performance data indicate that the treatment system was not well-

designed and well-operated at the time of testing, these data
                                        V
would also not be used.
                               4-2                         Rev. 3

-------
     The remaining performance data are then corrected to account

for incomplete recovery of certain constituents during the

analyses.  Finally, in cases where the Agency has adequate

performance data for treatment of the waste by more than one

technology, an analysis of variance (ANOVA) test is used to

select the best treatment technology.



4.2  Data Screening



     In the selection of BOAT for treatment of K103 and K104

wastewaters, the only performance data available were those

collected during the Agency's sampling visit.  Five data sets

were collected by the Agency for treatment of the wastewaters by

liquid/liquid extraction followed by steam stripping and carbon

adsorption.  These data were evaluated to determine whether any

of the data represented poor design or operation of the system.

One of the data sets (Sample Set #3)  was deleted due to poor

operation of the carbon adsorption unit during the time data were

being collected.  This was indicated by a higher than normal

system temperature and a relatively high aniline concentration in

the treated waste.   The four remaining data sets were used for

the development of treatment standards for K103 and K104

wastewaters.  These data sets are sample sets 1,  2,  4 and 5.
                                         V


     Toxic Characteristic Leaching Procedure (TCLP)  data were not

used in setting treatment standards for waste codes K103 and K104
                               4-3                         Rev.  3

-------
because metals were not identified as one of the classes of BDAT

list constituents for regulation (see Section 5 for further

details).   For a discussion on the use of TCLP data in setting

treatment standards, refer to Section 1 of this background

document.




     In instances where a selected constituent was not detected

in the treated waste, the treated value for that constituent was

assumed to be the practical quantification level.   This was the

case for the following constituents:  (1) benzene in Sample Set

#2; (2) aniline in Sample Sets #1,  #2, and #4; (3) nitrobenzene

in Sample Sets #1, #2, #4, and #5;  (4) phenol in Sample Sets #1,

#2, and #4.  Analytical values for the treated waste are

presented in Table 4-1.




4.3.  Data Accuracy




     After data were eliminated from consideration for analysis

of BDAT based on the screening tests, the Agency adjusted the

remaining data using analytical recovery values in order to take

into account analytical interferences and incomplete recoveries

associated with the chemical makeup of the sample.  The Agency

developed the recovery data (also referred to as accuracy data),
                                        V
by first analyzing a waste for a given constituent and then by

adding a known amount of the same constituent (i.e., spike) to


the waste material.  The total amount recovered after spiking,
                               4-4                         Rev. 3

-------
TABLE 4-1   Treatment Data Used for Regulation of K103 and K104  Uastewaters
                                 ANALYTICAL CONCENTRATIONS (1)
BOAT List
Const i tuent
Benzene
Aniline
2,4-Dinitrophenol
Nitrobenzene
Phenol
Total Cyanides
Sample Set 1
(total)
(mg/l)
0.042
<0.030
0.380
<0.030
<0.030
0.565
Sample Set 2
(total)
(mg/l)
<0.005
<0.030
0.320
<0.030
<0.030
0.597
Sample Set 4
(total)
(mg/l)
0.019
<0.030
0.260
<0.030
<0.030
0.156
Sample Set 5
(total)
(mg/l)
0.011
0.960
0.230
<0.030
0.150
0.129
ACCURACY-CORRECTED CONCENTRATIONS (2)
BOAT List
Constituent
Benzene
Aniline
2,4-Dinitrophenol
Nitrobenzene
Phenol
Total Cyanides
Sample Set 1
(total)
(mg/l)
0.055
0.033
0.475
0.026
0.143
0.785
Sample Set 2
(total)
(mg/l)
0.007
0.033
0.400
0.026
0.143
0.830
Sample Set 4
(total)
(mg/l)
0.025
0.033
0.325
0.026
0.143
0.217
Sample Set 5
(total)
(mg/l)
0.015
1.056
0.288
0.026
0.714
0.179
   1.   Onsite  Engineering Report for E.I. du Pont de Nemours,  Inc., Beaumont,
       Texas,  Tables 6-14.

   2.   Calculations shown in Appendix D of this Background Document.

                                               4-5
Rev.  3

-------
minus the initial concentration in the sample, divided by the



amount added, is the recovery value.  At least two recovery



values were calculated for spiked constituents, and the



analytical data were adjusted for accuracy using the lowest



recovery value for each constituent.







     This was accomplished by calculating an accuracy factor from



the percent recoveries for each selected constituent.  The



reciprocal of the lower of the two recovery values divided by



100, yields the accuracy factor.  The corrected concentration for



each sample set is obtained by multiplying the accuracy factor by



the raw data value.  The actual recovery values and accuracy



factors for the selected constituents are presented in



Appendix E.








     The accuracy factors calculated for the selected



constituents varied from a high value of 4.76 for phenol to a low



value of 0.87 for nitrobenzene.  The corrected concentration



values for the selected constituents are shown for the four data



sets in Table 6-1.  These corrected concentrations values were



obtained by multiplying the accuracy factors (Appendix E) by the



concentration values for the selected constituents in the treated



waste.  An arithmetic average value, representing the treated



waste concentration, was calculated for each selected constituent



from the four corrected values.  These averages are presented in



Table 6-1.  These adjusted values for the treatment technology
                               4-6                         Rev. 3

-------
system consisting of liquid/liquid extraction followed by steam

stripping and activated carbon adsorption were then used to

determine BOAT for waste codes K103 and K104.



4.4  Analysis of Variance



     In cases where the Agency has adequate performance data on

treatment of the same or similar wastes using more than one

technology, an analysis of variance (ANOVA) test is performed to

determine if one of the technologies provides significantly the

best treatment than the others.  In cases where a particular

treatment technology is shown to provide better treatment, the

treatment standards will be used on this best technology.  The

procedure followed for the analysis of variance (ANOVA) test is

described in  Appendix A.



     In order to determine BDAT for waste codes K103 and K104,

three combinations of demonstrated technologies, for which

adequate performance data were available, were considered for the

treatment of these wastes:

     o    Liquid/liquid extraction,

     o    Liquid/liquid extraction followed by steam stripping,
          and

     o    Liquid/liquid extraction followed by steam stripping
          and activated carbon adsorption.
                               4-7                         Rev.  3

-------
     The corrected data for sample sets 1, 2, 4, and 5 were used

to perform analysis of variance (ANOVA) tests to compare these

three technology combinations.  The three combinations of

treatment technologies were compared based on the concentration

of primary waste constituents (benzene, aniline, nitrobenzene,

phenol, 2,4-dinitrophenol, and total cyanides) in the treated

waste.  The rationale for selecting these constituents for the

ANOVA comparison is presented in Section 6.




     The statistical results of the ANOVA test for liquid/liquid

extraction followed by steam stripping versus liquid/liquid

extraction indicate the following:




     1)   Liquid/liquid extraction followed by steam stripping

          provides significantly better treatment for benzene and

          nitrobenzene in waste codes K103 and K104 than

          liquid/liquid extraction alone.




     2)   Liquid/liquid extraction followed by steam stripping

          provides equivalent treatment for total cyanides in

          waste codes K103 and K104 compared to liquid/liquid

          extraction alone.



                                        *•
     3)   Insufficient data exist to compare the treatment for

          phenol,  aniline, and 2,4-dinitrophenol achieved by
                               4-8                         Rev. 3

-------
          liquid/liquid extraction alone with that achieved by

          liquid/liquid extraction followed by steam stripping.



     The statistical results of the ANOVA test of liquid/liquid

extraction followed by steam stripping and activated carbon

adsorption versus liquid/liquid extraction followed by steam

stripping indicate the following:



     1)    Liquid/liquid extraction followed by steam stripping

          and activated carbon adsorption provides significantly

          better treatment for aniline, 2,4-dinitrophenol, phenol

          and total cyanides in waste codes K103 and K104 than

          liquid/liquid extraction followed by steam stripping.




     2)    Liquid/liquid extraction followed by steam stripping

          and activated carbon adsorption provides equivalent

          treatment for benzene in waste codes K103 and K104

          compared to liquid/liquid extraction followed by steam

          stripping.



     3)    Insufficient data exist to compare the treatment for

          nitrobenzene achieved by liquid/liquid extraction

          followed by steam stripping with that achieved by
                                         V
          liquid/liquid extraction followed by steam stripping

          and activated carbon adsorption.
                               4-9                         Rev.  3

-------
     The three-step treatment technology system consisting of



liquid/liquid extraction followed by steam stripping and



activated carbon adsorption provides significantly better or



equivalent treatment overall for the primary constituents present



in waste codes K103 and K104 when compared either liquid/liquid



extraction alone or liquid/liquid extraction followed by steam



stripping.  Therefore, the Agency has chosen this three-step



treatment system to be BOAT for waste codes K103 and K104.
                               4-10                         Rev. 3

-------
              5.  SELECTION OF REGULATED CONSTITUENTS
     In the previous section, the best demonstrated available



technology (BDAT) for treating the wastewater forms of waste



codes K103 and K104 was determined to be liquid/liquid extraction



followed by steam stripping and activated carbon adsorption.







     The two nonwastewater forms of K103 and K104 are as follows:



spent carbon from the activated carbon adsorber and the solvent-



extract stream from the nitrobenzene liquid/liquid extractor.



Based on analysis of the influent and effluent streams (see



Tables 6-13 and 6-14 in the OER for K103 and K104) from the



activated carbon adsorber, the Agency expects the spent carbon to



contain the following constituents:  benzene, aniline, 2,4-



dinitrophenol, nitrobenzene, phenol, and cyanides.  Rotary kiln



incineration has been demonstrated on wastes that are similar to



the spent carbon from the activated carbon adsorber.  Therefore,



the Agency believes that rotary kiln incineration is BDAT for the



spent carbon from the activated carbon adsorber.







     Rotary kiln incineration has also been demonstrated on



wastes that are similar to the solvent-extract stream from the



nitrobenzene liquid/liquid extractor.  Therefore, the Agency



believes that rotary kiln incineration is BDAT for the solvent-



extract from the nitrobenzene liquid/liquid extractor.  In this



section, the necessary constituents are identified for assuring







                               5-1                         Rev. 3

-------
the most effective treatment of the wastes.  This is done by

following a three-step procedure:



     o    identifying the BOAT list constituents found in both
          the untreated and treated waste;

     o    determining the classes of BOAT list constituents
          present, and

     o    selecting the regulated constituents.


     As discussed in Section 1, the Agency has developed a list

of hazardous constituents (Table 1-1) from which the constituents

to be regulated are selected.  The list is a "growing list" that

does not preclude the addition of new constituents as additional

key parameters are identified.  The list is divided into the

following categories:  volatile organics, semivolatile organics,

metals, inorganics, organochlorine pesticides, phenoxyacetic acid

herbicides, organophosphorous pesticides, PCBs, and dioxins and

furans.  The constituents in each category have similar chemical

properties and are expected to behave similarly during treatment,

with the exception of the inorganics.


5.1  Identification of BOAT List Constituents in the Untreated
     and Treated Waste


     Using EPA-collected data, the Agency identified those

constituents that were detected in the untreated and treated

waste.  The BOAT list of constituents (see Table 1-1, Section

1.0) provided the target list of constituents.  EPA collected

five sets of data at one facility (see the Onsite Engineering
                               5-2                         Rev. 3

-------
Report for K103 and K104 for more details) to evaluate the

treatment of the wastewater forms of waste codes K103 and K104 by

liquid/liquid extraction followed by steam stripping and

activated carbon adsorption.  One of the five data sets (data set

#3) was eliminated because the activated carbon adsorber was not

well-operated during the sampling interval.  Poor operation of

the activated carbon adsorption system was indicated by a higher

than normal system temperature and a relatively high aniline

concentration in the treated waste.  The remaining four data sets

were used to identify the constituents detected in the untreated

and treated waste.  The detection limits for the BDAT list of

constituents are presented in Appendix C.



     Table 5-1 presents the BDAT list as discussed in Section 1.

It indicates which of the BDAT list constituents were analyzed in

the untreated and treated waste.  This table also gives the

concentrations of those BDAT list constituents which were

detected.  As shown in Table 5-1, the following constituents were

detected in the untreated waste K103: benzene, aniline, arsenic,

lead, zinc, total cyanides, and sulfides.  The following

constituents were detected in the untreated waste K104: benzene,

nitrobenzene, barium, chromium, copper, nickel, zinc, total

cyanides, and sulfides.  The following constituents were detected
                                        V
in the treated waste (K103 and K104): benzene, aniline,

2,4-dinitrophenol, trichloromonofluoromethane, phenol, barium,

chromium, nickel, vanadium, zinc, total cyanides, and fluorides.
                               5-3                         Rev. 3

-------
TABLE 5-1   BOAT List Constituents in Untreated and Treated Waste
Parameter
Untreated
K103
(mg/l)
Untreated
K104
(mg/l)
Treated
K103/K104
(mg/l)
Volatiles
222
1
2
3
4
5
6
223
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
224
225
226
30
227
31
214
32
Acetone
Acetonitrile
Acrolein
Acrylonitrile
Benzene
Bromodi ch I oromethane
Bromomethane
n-Butyl alcohol
Carbon Tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-1,3-butadiene
Ch lorodibromomethane
Chloroe thane
2-Chloroethyl vinyl ether
Chloroform
Chi oromethane
3 - Ch I oropr opene
1 ,2-Dibromo-3-chloropropane
1 , 2-D i bromoethane
Dibromomethane
trans- 1,4-Dichloro-2-butene
Dichlorodif luoromethane
1,1-Dichloroethene
1 , 2 - D i ch I oroethane
1,1-Dichloroethylene
trans-1,2-Dichloroethene
1,2-Dichloropropane
trans- 1 , 3-D i ch loropropene
cis-1,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
ND
ND
ND
ND
32 - 81
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
4.5 - 320
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.011 - 0.042
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND -  Not detected
                                                                                        Cont i nued
                                             5-4
                                                                                         Rev.   3

-------
TABLE 5-1   BOAT  List Constituents in Untreated and Treated Waste (Continued)
Parameter
Volatiles (continued)
33 Isobutyl alcohol
228 Methanol
34 Methyl ethyl ketone
229 Methyl isobutyl ketone
35 Methyl methacrylate
37 Methylacrylom'trile
38 Methylene chloride
230 2-Nitropropane
39 Pyridine
40 1,1,1,2-Tetrachloroethane
41 1, 1.2,2-Tetrachloroethane
42 Tetrachloroethene
43 Toluene
44 Tribromome thane
45 1,1,1-Trichloroethane
46 1,1,2-Trichloroethane
47 Trichloroethene
48 Trichloromonof luromethane
49 1,2,3-Trichloropropane
231 1, 1,2-Trichloro- 1,2, 2- trif luoroethane
50 Vinyl chloride
215 1,2-Xylene
216 1,3-Xylene
217 1,4-Xylene
Semivolatiles
51 Acenaphthalene
52 Acenaphthene
53 Acetophenone
54 2-Acetylaminof luorene
55 4-Aminobiphenyl
56 Aniline
57 Anthracene
58 Aramite
59 Benz(a)anthracene
218 Benzal chloride
60 Benzenethiol
61 Benzidine
62 Benzo(a)pyrene
Untreated Untreated
K103 K104
(mg/l) (mg/l)

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
33000 - 53000
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Treated
K103/K104
(mg/l)

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.007 - 0.010
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
0.96**
ND
ND
ND
ND
ND
ND
ND
 ND -  Not  detected
 ** -  Indicates  that only one sample contained this  constituent at detectable levels.

                                                5-5
Cont i nued

 Rev.   3

-------
TABLE 5-1  BOAT List Constituents in Untreated and Treated Waste (Continued)
Parameter
Untreated
K103
(mg/l)
Untreated
K104
(mg/l)
Treated
K103/K104
(mg/l)
Semivolatiles (continued)
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
232
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
Benzo(b) f I uoranthene
Benzo(ghi )perylene
Benzo( k) f t uoranthene
p-Benzoquinone
Bis(2-chloroethoxy)ethane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropy)ether
Bis(2-ethylhexy)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthlate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroaniline
Chlorobenzilate
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitrile
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
Dibenz(a,h)anthracene
Dibenzo(a,e)pyrene
Dibenzo(a, i )pyrene
m-D i ch I orobenzene
o-Dichlorobenzene
p- D i ch I orobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2,6-Dichlorophenol
Di ethyl phthalate
3,3'-Dimethyoxlbenzidine
p-D i methyl ami noazobenzene
3,3'-Dimethylbenzidine
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1,4-Dinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
0.23 - 0.38
ND -  Not detected
                                             5-6
                                                                                         Rev.   3

-------
TABLE 5-1   BOAT List Constituents in Untreated and Treated Waste (Continued)
Parameter
Untreated
K103
(mg/l)
Untreated
K104
(mg/l)
Treated
K103/K104
(mg/l)
Semivotatiles (cont.)
102
103
104
105
106
219
107
108
109
110
111
112
113
114
115
116
117
118
119
120
36
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine
Diphenylni trosamine
1,2-Diphenylhydrazine
Fluoranthene
Fluorene
Hexach I orobenzene
Hexach 1 orobutadi ene
Hexach I orocyc I opentadi ene
Hexach I oroethane
Hexach loroph ene
Hexach I oropropene
Indeno(1,2,3-cd)pyrene
Isosafrole
Hethapyrilene
3-Methycholanthrene
4,4'-Methylenebis(2-chloroaniline)
Methyl methanesulfonate
Napthalene
1,4-Naphthoquinone
1-Napthylamine
2-Napthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N-N i trosomorphol ine
N-Nitrosopiperidine
n-Nitrosopyrrol idine
5-Nitro-o-toluidine
Pentach I orobenzene
Pentach loroethane
Pentach t oroni t robenzene
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
2200 - 3900
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND -  Not detected
                                             5-7
                                                                                         Rev.   3

-------
TABLE 5-1  BOAT List  Constituents in Untreated and Treated Waste (Continued)
Parameter
Semivolatiles (cont.)
139 Pentachlorophenol
140 Phenacetin
141 Phenanthrene
142 Phenol
220 Phthalic anhydride
143 2-Picoline
144 Pronamide
145 Pyrene
146 Resorcinol
147 Safrole
148 1,2,4,5-Tetrachlorobenzene
149 2, 3, 4, 6-Tetrachlorophenol
150 1,2,4-Trichlorobenzene
151 2,4,5-Trichlorophenol
152 2,4,6-Trichlorophenol
153 Tris(2,3-dibromopropyl)phosphate
Metals
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
221 Chromium (hexavalent)
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Si Iver
166 Thallium
167 Vanadium
168 Zinc
Inorganics
169 Cyanide
170 Fluoride
171 Sulfide
Untreated
K103
(mg/l)

NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
0.021**
ND
ND
ND
ND
ND
ND
0.006**
ND
ND
ND
ND
ND
ND
0.003 - 0.021

0.038 - 0.075
ND
62.0 - 89.0
Untreated
K104
(mg/l)

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
0.0015 - 0.017
ND
ND
0.007 - 0.432
ND
0.012**
ND
ND
0.014 - 0.238
ND
ND
ND
ND
0.011 - 0.079

3.06 - 6.28
ND
ND
Treated
K103/K104
(mg/l)

ND
ND
ND
0.15**
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
0.032 - 0.076
ND
ND
0.0097 - 0.024
ND
ND
ND
ND
0.015 - 0.030
ND
ND
ND
0.012 - 0.014
0.012 - 0.058

0.129 - 0.597
0.220 - 0.620
ND
** - Indicates that only one sample contained this constituent at detectable levels.




                                              5-8
Cont i nued




 Rev.  3

-------
TABLE 5-1   BOAT List Constituents  in Untreated and Treated Waste (Continued)
Parameter
Organochlorine Pesticides
172 Aldrin
173 alpha-BHC
174 beta-BHC
175 delta-BHC
176 gamma -BHC
177 Chlordane
178 ODD
179 DDE
180 DDT
181 Dieldrin
182 Endosulfan I
183 Endosulfan II
184 Endrin
185 Endrin aldehyde
186 Heptachlor
187 Heptachlor epoxide
188 Isodrin
189 Kepone
190 Mehoxychlor
191 Toxaphene
Phenoxyacetic Acid Herbicides
192 2,4-Dichlorophenoxyacetic acid
193 Si I vex
194 2,4, 5-T
Organophosphorous Insecticides
195 Disulfoton
196 Famphur
197 Methyl parathion
198 Paration
199 Phorate
PCBs
200 Aroclor 1016
201 Aroclor 1221
202 Aroclor 1232
Untreated
K103
(ing/ 1)

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA

NA
NA
NA
NA
NA

ND
ND
ND
Untreated
K104
(mg/l)

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA

NA
NA
NA
NA
NA
V
ND
ND
ND
Treated
K103/K104
(mg/l)

NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA

NA
NA
NA
NA
NA

ND
ND
ND
ND - Not  detected
NA - Not  analyzed
                                              5-9
                                                                                          Rev.   3

-------
TABLE 5-1  BOAT List Constituents in Untreated and Treated Waste (Continued)
Parameter
PCBs (continued)
203 Aroclor 1242
204 Aroclor 1248
205 Aroclor 1254
206 Aroclor 1260
Dioxins and Furans
207 Hexachlorodibenzo-p-dioxins
208 Hexachlorodibenzofuran
209 Pentachlorodibenzo-p-dioxins
210 Pentachlorodibenzofuran
211 Tetrachlorodibenzo-p-dioxins
212 Tetrachlorodibenzofuran
213 2,3,7,8-Tetrachlorodibenzo-p-dioxin
Untreated
K103
dug/ 1)

ND
NO
ND
ND

ND
ND
ND
ND
ND
ND
ND
Untreated
K104
(ing/ 1)

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
Treated
K103/K104
(ing/ 1)

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND - Not detected
                                            5-10
Rev.  3

-------
Since the waste codes K103 and K104 are mixed before the steam

stripping step, the analytical data for the treated waste are the

same for both waste codes.




     The untreated and treated waste samples were not analyzed

for other classes of BDAT organics (organochlorine pesticides,

phenoxyacetic acid herbicides, and organophosphorus pesticides)

because there is no in-process source of these constituents and

because of the extreme unlikelihood of finding these constituents

at treatable levels in the waste.




5.2  Determination of Classes of Constituents




     The BDAT list constituents in waste codes K103 and K104

belong to the following four classes: volatiles, semivolatiles,

metals, and inorganics  (See Table 5-1).  Two volatile

constituents, benzene and trichloromonofluoromethane, were

detected.  Four semivolatile constituents, aniline,

2,4-dinitrophenol, nitrobenzene, and phenol were also detected.

Six metal constituents were also detected: arsenic, chromium,

lead, nickel, vanadium, and zinc.  The inorganic pollutants

detected were cyanide,  fluoride, and sulfide.



                                         v
     The metal constituents were present in untreatable

concentrations in the untreated waste  codes K103 and K104.  None

of the metals  in either untreated K103 or untreated K104 were
                               5-11                        Rev.  3

-------
detected at a concentration level higher than 1 mg/1.  Also, by

comparing the concentration of metals in the untreated and

treated waste for both waste codes K103 and K104, the Agency

concluded that metals were not substantially treated.  For a

discussion of how the Agency decides when treatment is

substantial, see Section 1 of this background document.




     The BDAT metal constituents in K103 and K104 were not

present at treatable levels in the waste.  Therefore, metals were

eliminated as a class of BDAT list constituents to be regulated

in waste codes K103 and K104.  However, the remaining three

classes of pollutants, namely, volatiles, semivolatiles, and

inorganics, were generally present at treatable concentration

levels in the untreated wastes and were judged to be

substantially treated when the untreated and treated constituent

data were compared for both waste codes.




5.3  Selecting the Regulated Constituents




     The Agency evaluated the analytical data for each

constituent to determine if the constituent should be selected

for regulation.  In general, the Agency was guided by the

criteria for selecting regulated constituents as described in
                                         »•
Section 1 of this background document.
                              5-12                         Rev. 3

-------
     The rationale for selecting the regulated constituents from

the four classes of constituents is presented below.




     Volatiles




     Benzene was present in significant concentrations in both

the untreated K103 and untreated K104 streams.  Benzene was

selected as a regulated constituent for waste codes K103 and K104

because it was substantially treated in both waste codes. The

benzene concentration in untreated K103 and untreated K104 was

reduced by the treatment system to below treatable levels.




     Trichloromonofluoromethane was not detected in either

untreated K103 or untreated K104, but was detected in the treated

waste.  Although this compound was reported as not detected in

the untreated waste, the Agency has judged that it was present,

but was masked due to high concentrations of aniline and

nitrobenzene.  The Agency believes that effective treatment of

benzene will effectively treat trichloromonofluoromethane as

well.  Trichloromonofluoromethane is less soluble in water than

benzene, and is soluble in nitrobenzene.  This indicates that

trichloromonofluoromethane will also be effectively treated by

the solvent extraction step of the treatment system.
                                         V
Trichloromonofluoromethane has a higher vapor pressure than

benzene at 40°C, which indicates that trichloromonofluoromethane

will be effectively treated by the steam stripping step of the
                               5-13                         Rev. 3

-------
treatment system. As a result, trichloromonofluoromethane was not

selected as a regulated constituent for either waste code K103 or

waste code K104, because treatment for benzene will also treat

trichloromonofluoromethane.




     Semivolatiles




     Aniline was detected in untreated K103 at high concentration

levels.  Aniline was reported as not detected in untreated K104

but it was found in the treated waste at low concentration

levels.  Based on data analysis, the concentration of aniline in

the untreated K103 waste was substantially reduced (to be below

treatable levels) by the treatment system.  The Agency assumes

aniline was not detected in untreated K104 because the Practical

Quantification Levels were high due to matrix interferences.  The

Agency believes that aniline was present in untreated K104 and

that it was effectively treated by the treatment system.  As a

result, aniline was selected as a regulated constituent for both

waste codes K103 and K104.




     The BOAT list constituent 2,4-dinitrophenol was not detected

in either untreated K103 or untreated K104.  It was, however,

detected in the treated waste.  The Agency assumes that
                                        V-
2,4-dinitrophenol was not detected in both untreated K103 and

untreated K104 because the Practical Quantification Levels were

high (see Appendix C) due to matrix interferences.  The Agency





                               5-14                        Rev. 3

-------
believes that 2,4-dinitrophenol was present in both untreated

K103 and untreated K104 and that it was effectively treated by

the treatment system.  As a result, 2,4-dinitrophenol was

selected as a regulated constituent for both waste codes K103 and

K104.




     Nitrobenzene was not detected in untreated K103.  It was

detected in untreated K104, and it was not detected in the

treated waste.  The concentration of nitrobenzene in untreated

K104 was substantially reduced by the treatment system.  The

Agency assumes that nitrobenzene was not detected in untreated

K103 because the Practical Quantification Levels were high (see

Appendix C) due to matrix interferences.  The Agency believes

that nitrobenzene was present in untreated K103 and that it was

effectively treated by the treatment system.  As a result,

nitrobenzene was selected as a regulated constituent for both

waste codes K103 and K104.




     Phenol was not detected in either untreated K103 or

untreated K104.  It was detected,  however, in the treated waste.

The Agency assumes that phenol was not detected in both untreated

K103 and untreated K104 because the Practical Quantification

Levels were high (see Appendix C)  due to matrix interferences.
                                         V-
The Agency believes that phenol was present in both untreated

K103 and untreated K104 and that it was effectively treated by
                              5-15                         Rev. 3

-------
the treatment system.  As a result, phenol was selected as a



regulated constituent for both waste codes K103 and K104.







     Inorganics








     Cyanide was detected in untreated K103 and untreated K104,



and also in the treated waste.  Because the concentration of



cyanide in untreated K103 increased when the waste was treated,



the Agency concluded that cyanide in untreated K103 was not



effectively treated.  This apparent increase in cyanide



concentration for waste code K103 was thought to be due to the



mixing with waste code K104.  The cyanide concentration was



higher in untreated K104 than in untreated K103.  The



concentration of cyanide in untreated K104 was substantially



reduced by the treatment system.  Therefore, the Agency believes



that cyanide in untreated K104 was effectively treated by the



treatment system.  As a result, the Agency selected cyanide as a



regulated constituent for K104 but not for K103.







     Fluoride was not detected in either untreated K103 or



untreated K104.  It was, however, detected in the treated waste.



The Agency has judged that fluoride was present in both untreated



K103 and untreated K104 at concentration levels below the



Practical Quantification Level for the untreated waste matrix and



that it was not effectively treated by the treatment system.  As
                              5-16                         Rev. 3

-------
a result, fluoride was not selected as a regulated constituent

for either waste code K103 or waste code K104.



     Sulfide was detected in untreated K103, but was not detected

in either untreated K104 or in the treated waste. The Agency

recognizes that the sulfide concentration was diminished in the

treated waste, but considers this an incidental treatment since

the treatment technology tested is not demonstrated for the

treatment of sulfides.  As a result, sulfide was not selected as

a regulated constituent for either waste code K103 or waste code

K104.



     The regulated constituents for K103 are as follows:

     o    benzene
     o    aniline
     o    2,4-dinitrophenol
     o    nitrobenzene
     o    phenol


     The regulated constituents for K104 are as follows:

     o    benzene
     o    aniline
     o    2,4-dinitrophenol
     o    nitrobenzene
     o    phenol
     o    total cyanides


     For the nonwastewater forms of K103 and K104,  the same BOAT

list constituents were chosen for regulation as shown above for

wastewaters.  This was done because the Agency did not have any

data available for determining the concentration of BOAT list

constituents in the nonwastewaters.



                              5-17                         Rev.  3

-------
           6.  CALCULATION OF BOAT TREATMENT STANDARDS








     In this section, the actual treatment standards for waste



codes K103 and K104 are presented.  These standards were



calculated based on the performance of the demonstrated treatment



system which was determined by the Agency to be the best for



treating both waste codes.  In Section 4, BOAT for the wastewater



forms of waste codes K103 and K104 was determined to be



liquid/liquid extraction followed by steam stripping and



activated carbon adsorption.  BOAT for the nonwastewater forms of



K103 and K104 was determined to be incineration.  The previous



section identified the constituents to be regulated for the



wastewater and nonwastewater forms of K103 and K104 wastes.








     As discussed in Section 1, the Agency calculated the BOAT



treatment standards for waste codes K103 and K104 by following a



four-step procedure: (1) editing the data; (2) correcting the



remaining data for analytical interference; (3) calculating



adjustment factors  (variability factors) to account for process



variability; and (4) calculating the actual treatment standards



using variability factors and average treatment values.  The four



steps in this procedure are discussed in detail in Sections 6.1



through 6.4.
                               6-1                         Rev. 3

-------
6 .1  Editing the Data







     Five sets of treatment data for waste codes K103 and K104



were collected by the Agency at one facility which operated a



treatment system consisting of liquid/liquid extraction followed



by steam stripping and activated carbon adsorption.  The Agency



evaluated the five data sets to determine if the treatment system



was well operated at the time of the sampling visit.  The Agency



eliminated one data set, sample set #3, because the treatment



system was not well operated when the samples were collected (as



discussed in Section 5).  For further details on the five data



sets, see the Onsite Engineering Report for K103 and K104.  The



remaining four data sets were used to calculate treatment



standards.







     Toxic Characteristic Leaching Procedure (TCLP) data were not



used in setting treatment standards for waste codes K103 and K104



because metals were not one of the classes of BOAT list



constituents identified for regulation (see Section 5 for further



details). For a discussion on the use of TCLP data in setting



treatment standards, refer to Section 1 of this background



document.







     In instances where a selected constituent was not detected



in the treated waste, the treated value for that constituent was



assumed to be the Practical Quantification Level.  This was the









                               6-2                         Rev. 3

-------
case for the following constituents: (1) benzene in sample set

#2; (2) aniline in sample sets #1, #2,  and #4; (3) nitrobenzene

in sample sets #1, #2, #4, and #5; (4)  phenol in sample sets #1,

#2, and #4.  Analytical values for the treated waste are

presented in Section 3, Tables 3-1 through 3-5 of this report.




6.2  Correcting the Remaining Data




     Data values for the constituents selected for regulation

were taken from the four data sets (sample sets 1, 2, 4 and 5).

These values were corrected in order to take into account

analytical interferences associated with the chemical make-up of

the treated sample.  This was accomplished by calculating an

accuracy factor from the percent recoveries for each selected

constituent.  The reciprocal of the lower of the two recovery

values divided by 100, yields the accuracy factor.  The corrected

concentration for each sample set is obtained by multiplying the

accuracy factor by the uncorrected data value.  The calculation

of recovery values is described in Section 1 of this background

document.   The actual recovery values and accuracy factors for

the selected constituents are presented in Appendix E.




     The accuracy factors calculated for the selected
                                         V
constituents varied from a high value of 4.76 for phenol to a low

value of 0.87 for nitrobenzene.  The corrected concentration

values for the selected constituents are shown for the four data
                               6-3                         Rev. 3

-------
sets in Table 6-1.  These corrected concentration values were



obtained by multiplying the accuracy factors (Appendix E) by the



concentration values for the selected constituents in the treated



waste.  An arithmetic average value, representing the treated



waste concentration, was calculated for each selected constituent



from the four corrected values.  These averages are presented in



Table 6-1.








6.3  Calculating Variability Factors








     It is expected that in normal operation of a well-designed



and well-operated treatment system there will be some variability



in performance.  Based on the test data, a measure of this



variability is expressed by the variability factor (see Appendix



A).  These factors were calculated for each of the selected



regulated constituents.  The methodology for calculating



variability factors is explained in Appendix A of this report.



Table 6-1 presents the results of calculations for the selected



constituents.  Appendix D of this report shows how the actual



values in Table 6-1 were calculated.








     The variability factors calculated for the selected



constituents vary from a high value of 15.40 for aniline to a low



value of 1.65 for 2,4-dinitrophenol.  A variability factor of i.o



represents test data from a process measured without variation



and analytical interferences.  Nitrobenzene was not detected in
                               6-4                         Rev. 3

-------
                                                                                                                                      1
0\
 I
en
                                    Table 6-1  Regulated Constituents and Calculated Treatment Standards for K103 and IC104 Wastewaters
Accuracy-Corrected Concentration (mg/l)
Sample Sample Sample Sample
Set #1 Set #2 Set #4 Set #5
Constituent
Volatiles:
4. Benzene 0.055 0.007 0.025 0.015
Semivolati les:
56. Aniline 0.033 0.033 0.033 1.056
101. 2,4-Dinitrophenol* 0.475 0.400 0.325 0.288
126. Nitrobenzene 0.026 0.026 0.026 0.026
142. Phenol » 0.143 0.143 0.143 0.714
Inorganics:
169. Total Cyanides** 0.785 0.830 0.217 0.179
Average
T f»Aa^ &s4
i reateo
Waste
Concentration
(mg/l)

0.026

0.289
0.372
0.026
0.286

0.503

Variability
Factor
(VF)

5.654

15.398
1.648
2.800
4.864

5.334
Treatment
C +• arwlo r*ek
standard
(mg/l)
(Average
X VF)

0.147

4.450
0.613
0.073
1.391

2.683
               1  -  Accuracy Corrrection Factors and Variability Factors were determined as discussed in Appendix D.

               *  -  Percent recovery of 4-Nitrophenol was used in the calculation of the standard for 2,4-Dinitrophenol.

              **  -  Total  cyanides are regulated for K104 only.

-------
the treated waste, and concentration values for the treated waste

were set at the Practical Quantification Level for nitrobenzene.

This resulted in no apparent variation among the treated values

and a calculated variability factor of 1.0.  Instead of using the

calculated value of 1.0, the variability factor for nitrobenzene

was fixed at 2.8 as justified in Appendix D of this document.



6.4  Calculating the Treatment Standards



     The treatment standards for the selected constituents were

calculated by multiplying the variability factors by the average

concentration values for the treated waste.  The treatment

standards are presented in Table 6-1.  Standards were calculated

for wastewaters only.  The treatment standards for K103 and K104

nonwastewaters are transferred from the treatment tests of K019

and K048/K051 wastes.



     The BOAT Wastewater Treatment Standard for waste code K103

is as follows:



  Constituent                 Total Composition (mg/1)

Benzene                               0.147
Aniline                               4.450
2,4-Dinitrophenol                     0.613
Nitrobenzene                          O.Q73
Phenol                                1.391
                               6-6                         Rev. 3

-------
     The BOAT Wastewater Treatment Standard for waste code K104

is as follows:



  Constituent                 Total Composition (mcf/1)

Benzene                               0.147
Aniline                               4.450
2,4-Dinitrophenol                     0.613
Nitrobenzene                          0.073
Phenol                                1.391
Total Cyanides (CN)                   2.683



     The treatment standards for waste codes K103 and K104 vary

from 4.45 mg/1 for aniline to 0.073 mg/1 for nitrobenzene.



     Nonwastewater treatment standards for waste codes K103 and

and K104 were also determined by the Agency.  These treatment

standards apply to the spent carbon from the carbon adsorber;

these treatment standards do not apply to the nitrobenzene

solvent from the liquid/liquid extractor because the Agency

believes that no ash is formed when this stream is incinerated.



     No performance data were available for the treatment of K103

and K104 nonwastewaters.  The Agency therefore decided to

transfer treatment standards from the treatment of wastes which

were determined to be similar to K103 and K104 nonwastewaters

based on waste characteristics affecting ^performance.  The

nonwastewater treatment standards for waste codes K103 and K104

were transferred from treatment data for wastes K019 and

K048/K051.  The thermal conductivities of wastes K019, K048, and



                               6-7                         Rev. 3

-------
K051 were compared with the thermal conductivities of waste codes



K103 and K104.  Waste K019 was selected for transferring



treatment standards to wastes K103 and K104 because its thermal



conductivity was lower than that of both wastes K103 and K104.



The treated waste concentrations and treatment standards for K019



are presented in Table 6-2.  The boiling points of the selected



constituents in waste codes K103 and K104 were compared to the



boiling points of the regulated constituents in waste code K019.



Constituents were matched as closely as possible on the basis of



the boiling point (see Table 6-2).







     Chlorinated organic constituents in K019 with three or more



chlorine atoms in their structure were eliminated from



consideration for this matching.  All chlorinated organics with



three or more chlorine atoms were below detectable levels in



treated K019.  The treated concentrations were therefore set at



the detection limit for these constituents.  However,  the



detection limits for these constituents were abnormally high in



treated K019 due to matrix interferences, leading to high



treatment standards.  Therefore, chlorinated organic constituents



with three or more chlorine atoms were not considered when



matching constituents from K103 and K104 with those from K019.



The remaining constituents in K019 were matched as closely as



possible with those in K103 and K104 on the basis of boiling
                               6-8                         Rev. 3

-------
                                Table 6-2  Regulated Constituents and Calculated Treatment Standards  for K019 Nonwasteuaters
 I
vo
JO
(D




Constituent
Volatiles:
9. Chlorobenzene
14. Chloroform
23. 1,2-Dichloroethane
42. Tetrachloroethene*
45. 1,1,1-Trichloroethane*
Semivolati les:
68. Bis(2-chloroethyl)ether
113. Hexachloroethane*
121. Naphthalene
141. Phenanthrene
150. 1,2,4-Trichlorobenzene*
Treated
Waste
Concentration
Range
(mg/kg)

<2
<2
<2
<2
<2

<2
<2
<2
<2
<5
Average
Corrected
Waste
Concentration
(mg/kg)

2.02
2.13
2.13
2.13
2.13

1.94
9.71
1.94
1.94
6.68


Variability
Factor
(VF)

2.8
2.8
2.8
2.8
2.8

2.8
2.8
2.8
2.8
2.8
Treatment
Standard
(mg/kg)
(Average
X VF)

5.66
5.96
5.96
5.96
5.96

5.44
27.2
5.44
5.44
18.7


Boiling
Point
(deg. C)

132
61.7
83.5
121
74.1

116
186
218
340
213.5
              2  - Treatment  standard  calculations are described  in detail  in the Background Document for K019.

              *  - The Agency believes the detection  limits for these constituents were abnormally high due to matrix  interferences.  These

                  constituents were therefore eliminated from consideration when transferring treatment standards to  K103 and K104 nonwastewaters.

-------
point.1  Treatment standards were then transferred from waste

code K019 to the matched constituent.  Cyanide treatment

standards were transferred from the treatment of K048/K051, since

cyanide was not present in K019 waste.



     The BOAT nonwastewater treatment standards for waste codes

K103 and K104 are as follows:
Constituent
Benzene
Aniline
2,4-Dinitrophenol
Nitrobenzene
Phenol
Total Cyanides (CN)
Total Composition (mg/kg)

K103                K104
5,
5,
5,
 .96
 .44
 .44
5.44
5.44
 NR
5,
5,
 .96
 .44
5.44
5.44
5.44
1.48
NR - Not regulated for this waste code.
1.   The removal of highly chlorinated organic constituents in
     K019 from consideration for transfer affected the treatment
     standards for the following constituents in K103 and K104:
     nitrobenzene (naphthalene was used rather than 1,2,4-tri-
     chlorobenzene) ,  aniline,  and phenol (naphthalene was used
     rather than hexachloroethane or 1,2,4-trichlorobenzene).
                              6-10
                             Rev. 3

-------
                         7.  CONCLUSIONS







     The Agency has proposed treatment standards for waste codes



K103 and K104 generated by the nitrobenzene/aniline industry.



Standards for wastewater and nonwastewater forms of these wastes



are presented in Tables 7-1 and 7-2 respectively.







     The treatment standards proposed for waste code K103 and



K104 have been developed consistent with EPA's promulgated



methodology for BOAT (November 7, 1986, 51 FR 40572).  Both waste



codes are generated by the treatment of process wastewaters from



the nitrobenzene/aniline industry.  Based on a careful review of



available data for the industrial processes which generate these



wastes and all available data characterizing these wastes, the



Agency has determined that these two waste codes represent a



separate waste treatability group.  Wastes in this treatability



group are primarily comprised of water, with nitrobenzene or



aniline present in smaller but significant quantities.  Although



the concentrations of specific constituents will vary from



facility to facility, all of the wastes are expected to contain



similar BOAT list organics and are expected to be treatable to



the same levels using the same technology.







     The BOAT list constituents generally present in wastes of



this treatability group are benzene, aniline, 2,4-dinitrophenol,



nitrobenzene,  phenol, and cyanides.   Additionally the Agency
                               7-1                         Rev. 3

-------
TABLE 7-1  BOAT TREATMENT STANDARDS FOR WASTEWATER:  K103 AND
             K104 WASTES
Regulated Constituents             Total Composition  (mg/1)
                                   K103           K104
Benzene
Aniline
2 , 4-Dinitrophenol
Nitrobenzene
Phenol
Total Cyanides
0.147
4.450
0.613
0.073
1.391
NR
0.147
4.450
0.613
0.073
1.391
2.683
NR - Not regulated for this waste code.
TABLE 7-2  BOAT TREATMENT STANDARDS FOR NONWASTEWATER:
             K103 AND K104 WASTES
Regulated Constituents             Total Composition  (rag/kg)
                                   K103           K104

Benzene                            5.96           5.96
Aniline                            5.44           5.44
2,4-Dinitrophenol                  5.44           5.44
Nitrobenzene                       5.44           5.44
Phenol                             5.44           5.44
Total Cyanides                      NR            1.48
NR - Not regulated for this waste code.
                               7-2                         Rev.  3

-------
expects that these wastes could be mixed together prior to



treatment.  As a result, EPA has examined the sources of the



wastes, applicable technologies, and waste treatment performance



in order to support a single regulatory approach for these six



waste constituents.  Through available data bases, the Agency has



identified the following demonstrated technologies for treatment



of constituents present in the wastes which are part of this



treatability group: solvent (liquid/liquid) extraction, steam



stripping, activated carbon adsorption, and biological treatment.







     In the development of treatment standards for these wastes,



the Agency examined all available treatment data.  The Agency



also conducted performance tests on a commercial scale treatment



system consisting of liquid/liquid extraction followed by steam



stripping and activated carbon adsorption for waste codes K103



and K104.  Design and operating data collected during the testing



of the treatment system indicate that the treatment system was



properly operated during four of the five sample sets.



Accordingly, the treatment performance data from four sample sets



were used in the development of the BOAT treatment standards.







     Two categories of treatment standards were developed for



wastes in the K103 and K104 treatability group: wastewater and



nonwastewater wastes.  (For the purpose of the land disposal



restrictions rule, wastewaters are defined as wastes containing
                               7-3                         Rev. 3

-------
less than 1% by weight filterable solids and less than 4% by

weight total organic carbon.  For K103 and K104 wastes, this

definition was amended to include wastewaters with a TOC content

up to 4%).




     BOAT for the wastewater forms of waste codes K103 and K104

was determined to be liquid/liquid extraction followed by steam

stripping and activated carbon adsorption.  This was based on a

statistical comparison of the Agency's test and performance data

from this treatment train to other available treatment data.  The

wastewater treatment standards for waste codes K103 and K104 are

based on EPA's test of liquid/liquid extraction followed by steam

stripping and activated carbon adsorption.




     Two nonwastewater forms of waste codes K103 and K104 were

identified by the Agency as spent carbon from the activated

carbon adsorber and nitrobenzene solvent from the nitrobenzene

liquid/liquid extractor.




     Incineration was determined to be BDAT for the nonwastewater

forms of wastes K103 and K104.  Nonwastewater treatment standards

for K103 and K104 are based on a transfer of treatment data from

K019 and K048/K051 wastes.  BDAT for wastes K019 and K048/K051
                                        v
was determined to be rotary kiln incineration.  Treatment data

for BDAT list organics were transferred from waste K019 based on

a comparison of the thermal conductivities between waste code





                               7-4                         Rev. 3

-------
K019 and waste codes K103 and K104.   Data were transferred for

constituents selected for regulation on a constituent by

constituent basis.  This was done by matching constituents on the

basis of boiling points.  Treatment standards for cyanide were

transferred from the treatment of K048/K051, since cyanide was

not present in K019 waste.




     Nonwastewater standards are established only for the spent

carbon from the activated carbon adsorber because the Agency

believes that the incineration of the nitrobenzene solvent from

the nitrobenzene liquid/liquid extractor will not produce ash.

The transfer of data for these nonwastewaters was determined to

be appropriate due to the similarity in physical and chemical

composition of the wastes such that the wastes would be expected

to be treated to similar levels by the same technology.




     Regulated constituents were selected on the basis of

substantial treatment, which was determined by comparing the

constituent concentrations detected in the untreated and treated

wastes.  All waste characterization data and applicable treatment

data consistent with the type and quality of data needed by the

Agency in this program were used to make this determination.  For

waste codes K103 and K104, the regulated constituents also
                                         V
represent the BDAT list constituents present at the highest

concentrations.  However, if the performance data for the

technology selected as BDAT indicated that the constituent was





                               7-5                         Rev. 3

-------
not significantly treated, then that constituent was not



regulated.  Some constituents present at treatable concentrations



in the untreated waste were not regulated if it was determined



that they would be adequately controlled by regulation of another



constituent.







     Treatment standards for these wastes were derived after



correction of laboratory data to account for recovery



(Section 6). Subsequently, the mean of the corrected data points



was multiplied by a variability factor to derive the standards.



The variability factor corrects the lab data for reasonable



variations measured in the treatment process and imprecision in



sampling and analytical methods. Variability factors were



determined using a statistical method which accounts for



variability in the results for a number of data points for a



given constituent.  A variability factor of 2.8 was chosen for



constituents for which a specific variability factor could not be



calculated (See Appendix A for justification).







     Wastewater and nonwastewater forms of waste codes K103 and



K104 may be land disposed if they meet the concentration



standards at the point of disposal.  The BOAT technology upon



which the treatment standards are based (liquid/liquid extraction



followed by steam stripping and activated carbon adsorption for



wastewater, and incineration for nonwastewater) need not be



specifically utilized prior to land disposal, provided that the










                               7-6                         Rev. 3

-------
actual technology utilized meets the standard, does not involve



dilution or other methods deemed unacceptable by the Agency, and



does not pose a greater risk to human health and the environment



than land disposal.








     These standards become effective as of August 8, 1988, as



per the schedule set forth in 40 CFR 268.10.  The Agency



estimates that there is a lack of nationwide treatment capacity



at this time for the nonwastewater forms of waste codes K103 and



K104.  Therefore, the Agency has proposed to grant a 2-year



nationwide variance to the effective date of the land disposal



ban for these wastes.  A detailed discussion of the Agency's



determination that a lack of nationwide incineration capacity



exists is presented in the Capacity Background Document which is



available in the Administrative Record for the First Sixths7



Rule.








     Consistent with Executive Order 12291, EPA prepared a



regulatory impact analysis (RIA) to assess the economic effect of



compliance with this proposed rule.  The RIA prepared for this



proposal rule is available in the Administrative Record for the



First Sixths' Rule.
                               7-7                         Rev.  3

-------
                            REFERENCES
Ackerman D.G., J.F. McGaughey, D.E. Wagoner, "At Sea Incineration
     of PCB-Containing Wastes on Board the M/T Vulcanus."  USEPA
     600/7-83-024, April 1983.

Authur D. Little, Inc. (1977).  "Physical, Chemical and
     Biological Treatment Techniques for Industrial Wastes."
     Vol. I - NTIS PB275-054.  pp. 1-1 to 1-18 and 1-37 to 1-41.

Bonner T.A., et al., Engineering Handbook for Hazardous Waste
     Incineration.  SW889.  Prepared by Monsanto Research
     Corporation for U.S. EPA, NTIS PB 81-248163. June 1981.

De Renzo, D.J.   (editor).  (1978).  Unit Operations for Treatment
     of Hazardous Industrial Wastes.  Noyes Data Corporation,
     Park Ridge, New Jersey.

Enckenfelder, W., et al.  (September 2,1985).  "Wastewater
     Treatment."   Chemical Engineering.

Gallacher, Lawrence V.   (February 1981).  "Liquid Ion Exchange in
     Metal Recovery and Recycling."  3rd Conference on Advanced
     Pollution Control for the Metal Finishing Industry.  U.S.
     EPA 600/2-81-028.  pp. 39-41.

GCA Corp.   (October 1984).  Technical Assessment of Treatment
     Alternatives for Wastes Containing Halogenated Organics.
     Prepared for USEPA, Contract 68-01-6871.  pp. 150-160.

Hackman, Ellsworth.  (1978).  Toxic Organic Chemicals.
     Destruction and Waste Treatment.  Noyes Data Corporation,
     Park Ridge, New Jersey, pp. 109-111.

Hanson, Carl.  (August 26, 1968).  "Solvent Extraction Theory,
     Equipment, Commercial Operations, and Economics."  Chemical
     Engineering,  p. 81.

Hutchins, R.  (1979).  "Activated Carbon Systems for Separation
     of Liquids."  pp. 1-415 through 1-486 as published in
     Handbook of Separation Techniques for Chemical Engineers.
     Philip A. Schweitzer (editor).  McGraw-Hill.

Humphrey, Jimmy L., J. Antonia Rocha, and James R. Fair.
     (September 17, 1984).  "The Essentials of Extraction."
     Chemical Engineering,  pp. 76-95.

Kirk & Othmer.   (1965).  Encyclopedia of Chemical Technology.
     2nd ed., Vol. 7, John Wiley and Sons, New York.  pp. 204-
     248.
                                                           Rev. 3

-------
                      REFERENCES  (Continued)


Kirk & Othmer.  Encyclopedia of Chemical Technology.  Volume 2
     (p. 37-361), Vol. 15 (p. 916-925).

Ku, W. and Peters, R.W. (May 1987).  "Innovative Uses or Carbon
     Adsorption of Heavy Metals from Plating Wastewaters:
     I. Activated Carbon Polishing Treatment."  Environmental
     Progress.

Lo, Teh C., Malcolm H. I. Baird,  and Carl Manson (editors). 1983.
     Handbook of Solvent Extraction.  John Wiley and Sons.  New
     York. pp. 53-89.

McCabe, Warren L., Julian C. Smith, and Peter Harriot.   (1985).
     Unit Operations of Chemical Engineering.  McGraw-Hill Book
     Company, New York.  pp. 533-606.

Metcalf and Eddy Inc.  (1985).   "Briefing, Technologies
     Applicable to Hazardous Waste."  Prepared for USEPA, ORD,
     HWERL.  Section 2.13.

Mitre Corp.  "Guidance Manual for Waste Incinerator Permits."
     NTIS PB84-100577.  July 1983.

Novak R.G., W.L. Troxler, T.H.  Dehnke, "Recovering Energy from
     Hazardous Waste Incineration."  Chemical Engineering
     Progress 91:146  (1984).

Oppelt E.T., "Incineration of Hazardous Waste."  JAPCA, Volume
     37, No. 5.  May 1987.

Patterson, J. (1985).  Industrial Wastewater Treatment
     Technology.  2nd ed., Butterworth Pub. pp. 329-340.

Perry, Robert H. and Cecil H. Chilton.  (1973).  Chemical
     Engineer's Handbook. 5th edition.  McGraw-Hill Book Company,
     New York. pp. 13-1 to 13-60 and pp. 15-1 to 15-24.

Rose, L.M.   (1985).  Distillation Design in Practice.  Elsevier,
     New York. pp. 1-307.

Santoleri J.J., "Energy Recovery-A By-Product of Hazardous Waste
     Incineration Systems."  In Proceedings of the 15th Mid-
     Atlantic Industrial Waste Conference, on Toxic and Hazardous
     Waste, 1983.

SRI.   (1985).  Stanford Research Institute.  Chemical Economics
     Handbook (CEH). Menlo Park.  California.
                                                           Rev. 3

-------
                      REFERENCES (Continued)


Touhill, Shuckrow & Assoc.  (February 1981).  "Concentration
     Technologies for Hazardous Aqueous Waste Treatment."  NTIS
     PB81-150583. pp. 53-55.

U. S. Environmental Protection Agency.  (May 1981).
     Identification and Listing Hazardous Waste under RCRA.
     Subtitle C. Section 3001, Background  Document.

U.S.  EPA.   (1987).  Onsite Engineering Report of Treatment
     Technology Performance and Operation for E.I, du Pont de
     Nemours & Co.. Inc. - Beaumont. TX.

USEPA   (October 1973).  Process Design Manual for Carbon
     Adsorption.  NTIS PB227-157.  pp. 3-21 and 53.

USEPA   (1986).  Best Demonstrated Available Technology  (BOAT)
     Background  Document for F001-F005 Spent Solvents. Vol. 1.
     EPA/530-SW-86-056, November, 1986.

Van Winkle, Matthew.  (1967).  Distillation.  McGraw-Hill Book
     Company, New York.  pp. 1-684.

Versar  (1985).  Versar, Inc.  An Overview of Carbon Adsorption.
     Draft Final Report.  U.S. Environmental Protection Agency:
     Exposure Evaluation Division Office of Toxic Substances,
     Washington, D.C.  EPA Contract No. 68-02-3968, Task No. 58.

Vogel G.,  et al., "Incineration and Cement Kiln Capacity for
     Hazardous Waste Treatment."  In Proceedings of the 12th
     Annual Research Symposium.  Incineration and Treatment of
     Hazardous Wastes.  Cincinnati, Ohio.   April 1986.

Water Chemical Corporation. (August 1984).  Process Design Manual
     of Stripping of Organics.  NTIS PB84-232628.  Prepared for
     the Industrial Environmental Research Laboratory Office of
     Research and Development, U.S. Environmental Protection
     Agency.  pp. 1-1 to F4.
                                                           Rev. 3

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                APPENDIX A - STATISTICAL ANALYSIS




A.1  F Value Determination for ANOVA Test




     As noted earlier in Section 1.0, EPA is using the


statistical method known as analysis of variance in the


determination of the level of performance that represents "best"


treatment where more than one technology is demonstrated.  This


method provides a measure of the differences between data sets.


If the differences are not statistically significant, the data


sets are said to be homogeneous.




     If the Agency found that the levels of performance for one


or more technologies are not statistically different (i.e., the


data sets are homogeneous), EPA would average the long term


performance values achieved by each technology and then multiply


this value by the largest variability factor associated with any


of the acceptable technologies.  If EPA found that one technology


performs significantly better (i.e., the data sets are not


homogeneous), BDAT would be the level of performance achieved by


the best technology multiplied by its variability factor.




     To determine whether any or all of the treatment performance

                                         V
data sets are homogeneous using the analysis of variance method,


it is necessary to compare a calculated "F value" to what is


known as a "critical value."  (See Table A-l.)  These critical






                          Appendix  A-l                     Rev. 3

-------
values are available in most statistics texts (see, for example,

Statistical Concepts and Methods by Bhattacharyya and Johnson,

1977, John Wiley Publications, New York).



     Where the F value is less than the critical value, all

treatment data sets are homogeneous.  If the F value exceeds the

critical value, it is necessary to perform a "pair wise F" test

to determine if any of the sets are homogeneous.  The "pair wise

F" test must be done for all of the various combinations of data

sets using the same method and equation as the general F test.



     The F value is calculated as follows:



     (i)  All data are natural logtransformed.

     (ii)  The sum of the data points for each data set is

            computed (T.) .

     (iii)  The statistical parameter known as the sum of the

            squares between data sets (SSB) is computed:
     SSB =
k
I
i = l
i i
r Ti2i

n •
1





—






f I T-'
i=l

N
Z •



     where:
     k  = number of treatment technologies
     n. = number of data points for technology i
     N  = number of data points for all technologies
     T. = sum of natural logtransformed data points for each
          technology.
                          Appendix A-2
Rev. 3

-------
(iv)  The sum of the squares within data sets  (SSW)  is
      computed:
     SSW =
k n;
l
I X
. 1=1 j=l
"
*2i,j

k
-.1
i s 1
' T •
	
ni -
where:



x.  . = the natural logtransformed observations  (j) for
 1'-1   treatment technology  (i) .



(v)  The degrees of freedom  corresponding to SSB and SSW  are

     calculated.  For SSB, the  degree of freedom is given by

     k-1.  For SSW, the degree  of freedom is given by N-k.



(vi)  Using the above parameters, the F value is calculated

     as follows:
                              MSB
                          F = MSW
where:


MSB = SSB/(k-1) and

MSW = SSW/(N-k).
                      Appendix A-3
Rev. 3

-------
     A computational table summarizing the above parameters is
shown below.
               Computational Table for the F Value
Source
Between
Within
Degrees of
freedom
K-l
N-k
Sum of
squares
SSB
SSW
Mean square
MSB = SSB/k-1
MSW = SSW/N-k
F
MSB/MSW
     Below are three examples of the ANOVA calculation.  The

first two represent treatment by different technologies that

achieve statistically similar treatment;  the last example

represents a case where one technology achieves significantly

better treatment than the other technology.
                          Appendix A-4
Rev. 3

-------
                   Table A-l
F Distribution at the 95 Percent Confidence Level
Denominator
degree! of
freedom 1
1
2
3
4
S
6
7
8
9
10
11
12
13
14
15
16
' 17
18
19
20
21
22
23
24
25
26
27
28
29
30
40
60
120
00
161 4
1851
1013
7 71
661
599
559
532
5.12
496
484
4 75
467
460
454
449
445
4 41
438
435
432
430
428
426
424
423
421
420
4 18
417
408
400
392
3.84
2
1995
1900
955
694
579
5.14
474
446
426
410
398
389
381
374
368
363
359
355
352
349
347
344
3.42
340
3.39
337
335
334
333
3.32
323
3.15
307
300
Numerator degrees of freedom
34567
2157
1916
928
659
5.41
4 76
435
407
386
3.71
3 59
349
341
334
329
324
320
316
313
310
307
305
303
301
299
298
296
295
2.93
292
284
2.76
2.68
2.60
2246
1925
912
639
5.19
453
412
384
363
348
336
3.26
3.18
311
306
301
296
293
290
287
284
282
280
278
276
274
273
271
2.70
269
2.61
253
245
237
2302
19.30
901
626
5.05
439
397
3.69
3.48
3.33
320
311
3.03
2.96
290
2.85
2.81
2.77
274
271
268
266
2.64
262
260
259
257
256
255
253
2.45
237
2.29
2.21
2340
1933
894
616
495
428
3.87
3.58
337
3.22
3.09
3.00
2.92
2.85
2.79
2.74
2.70
266
263
260
2.57
255
2.53
2.51
249
247
246
2.45
243
2.42
234
2.25
2.17
2.10
2368
1935
889
609
488
421
3.79
3.50
3.29
3.14
3.01
2.91
2.83
2.76
2.71
2.66
2.61
2.58
2.54
2.51
249
2.46
244
242
2.40
2.39
2.37
2.36
2.35
2.33
225
* 2.17
2.09
2.01
8
2389
1937
885
604
482
415
3.73
344
3.23
3.07
2.95
2.85
2.77
2.70
2.64
2.59
2.55
2.51
2.48
2.45
2.42
2.40
2.37
236
234
2.32
231
2.29
2.28
2.27
2.18
2.10
2.02
1 94
9
2405
1938
881
600
477
410
368
339
3.18
302
290
280
2.71
265
259
254
249
246
242
239
237
234
232
2.30
228
2.27
225
224
2.22
221
212
204
1 96
188
                   Appendix A-5
Rev.  3

-------
                                                       Example  1
                                                   Hethylene Chloride
Steam stripping
Influent
(mg/l)
1550.00
1290.00
1640.00
5100.00
1450.00
4600.00
1760.00
2400.00
4800.00
12100.00
Effluent
(mg/l)
10.00
10.00
10.00
12.00
10.00
10.00
10.00
10.00
10.00
10.00
In(effluent)

2.30
2.30
2.30
2.48
2.30
2.30
2.30
2.30
2.30
2.30
2
[ln(ef fluent)]

5.29
5.29
5.29
6.15
5.29
5.29
5.29
5.29
5.29
5.29

Influent
(mg/l)
1960.00
2568.00
1817.00
1640.00
3907.00





Biological treatment
Effluent In(effluent)
(mg/l)
10.00 2.30
10.00 2.30
10.00 2.30
26.00 3.26
10.00 2.30





2
tln( effluent)]

5.29
5.29
5.29
10.63
5.29





Sum:
                              23.18
                                               53.76
                                                                                       12.46
                                                                                                          31.79
Sample Size:
    10           10
                              10
Mean:
  3669
                10.2
Standard Deviation:
  3328.67          .63

Variability Factor:
                 1.15
                               2.32
                                 .06
                                                          2378
                                                           923.04
                                                                          13.2
                                                                           7.15
                                                                           2.48
                                                                                        2.49
                                                                                         .43
ANOVA Calculations:
 SSB
         £  'Ti2
         k
         .2,
SSW

MSB = SSB/(k-1)

MSU = SSU/(N-k)
                          A"
                              Hi
                              nt
                                                Appendix  A-6
                                                                                                   Rev.  3

-------
                                    Example 1   (continued)

F   = MSB/MSW

where:

k   = number of  treatment  technologies

n.  = number of  data points  for  technology  i

N   = number of  natural  log  transformed data points for  alt technologies

T.  = sum of log transformed data points for each technology

X   = the nat.  log transformed observations (j) for treatment technology (i)
 ij
n  = 10, n2 = 5,  N = 15,  k =  2,  T  = 23.18, T  = 12.46,  T = 35.64, T = 1270.21


T  = 537.31  T  = 155.25
„„„
SSB
537.31   155.25

 10        5
1270.21

  15
                           =  0.10
       (53.76 +  31.79)  -
                            10
                                   = 0.77
MSB = 0.10/1  = 0.10

MSW = 0.77/13 = 0.06

      0.10
F  =
      0.06
             = 1.67
        Source
Degrees of
  freedom
      Between(B)
      Uithin(U)
       1
      13
                                   ANOVA Table
                                         SS
                                 0.10
                                 0.77
                                                        MS
                          0.10
                          0.06
1.67
      The critical  value  of  the  F test at the 0.05 significance level is 4.67.   Since the
      F value is less  than the critical value, the means are not significantly different
      (i.e.,  they are  homogeneous).

Note:   All calculations were rounded to two decimal places.  Results may differ
       depending upon  the number of decimal places used in each step of the calculations.
                                                  Appendix  A-7
                                                                                      Rev.  3

-------
                                                   Example 2
                                                Trichloroethylene
Steam stripping

Influent
(mg/l)
1650.00
5200.00
5000.00
1720.00
1560.00
10300.00
210.00
1600.00
204.00
160.00

Effluent
(mg/l)
10.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
85.00
10.00

In(effluent)

2.30
2.30
2.30
2.30
2.30
2.30
2.30
3.30
4.44
2.30

2
[In(effluent)]

5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5.29
Biological treatment

Influent
(mg/l)
200.00
224.00
134.00
150.00
484.00
163.00
182.00




Effluent
(mg/l)
10.00
10.00
10.00
10.00
16.25
10.00
10.00




ln( effluent)

2.30
2.30
2.30
2.30
2.79
2.30
2.30



2
Cln( effluent)]

5.29
5.29
5.29
5.29
7.78
5.29
5.29



Sum:
Sample Size:
    10         10
Mean:
   2760
       19.2
Standard Deviation:
   3209.6       23.7

Variability Factor:
                3.70
                            26.14
                     10
    2.61
                              .71
                                   72.92
                                               220
                                               120.5
                                            10.89
                                                                     2.36
                                                                     1.53
                                                                                 16.59
                                                                                  2.37
                                                          .19
                                                                          39.52
ANOVA Calculations:
SSB
             Ti?
 k
 z,  . _
i-l   n,
SSW '

MSB = SSB/(k-1)

MSW = SSW/(N-k)
Z,  Ti
              •&(£)
                                            Appendix A-8
                                                                                     Rev.  3

-------
                                   Example 2  (continued)

F   = HSB/MSW

where:

k   = number of  treatment technologies

n.  = number of  data  points for technology i

M   = number of  data  points for all technologies

T   = sum of natural  log transformed data points  for each technology
 i
X   = the natural  log transformed observations (j)  for treatment technology (i)
 U


N  = 10, N  =  7, N =  17, k = 2, T  = 26.14, T  =  16.59, T = 42.73, T = 1825.85,  T   = 683.30,


I2 = 275.23


SSB »[683'30  *   275'23    -      '              - 0.25
       10            7    I      17
SSWM72.92 + 39.52) - LIi::*-—!          = *'79
                        I   10        7

MSB = 0.25/1 = 0.25

MSU = 4.79/15 = 0.32
    0.32

                                   ANOVA Table

Source
Between(B)
Within(W)
Degrees of
freedom SS MS f
1 0.25 0.25 0.78
15 4.79 0.32
      The critical  value of  the f test at the 0.05 significance level is 4.54.   Since  the
      F value is less than  the critical value, the means are not significantly  different
      (i.e., they are homogeneous).
Note:  All calculations  were  rounded to two decimal  places.  Results may differ
       depending upon the  number of decimal places used  in each step of the calculations.
                                                 Appendix A-9                                   Rev.  3

-------


Example 3



Chlorobenzene
Activated sludge

followed by carbon adsorption
2
Influent Effluent In(effluent) [InCeff luent)]"
(mg/l)
7200.00
6500.00
6075.00
3040.00



(mg/l)
80.00 4.38 19.18
70.00 4.25 18.06
35.00 3.56 12.67
10.00 2.30 5.29



Biological

Influent
(mg/l)
9206.00
16646.00
49775.00
14731.00
3159.00
6756.00
3040.00
treatment

Effluent
(mg/l)
1083.00
709.50
460.00
142.00
603.00
153.00
17.00


ln( effluent)

6.99
6.56
6.13
4.96
6.40
5.03
2.83

2
InC(effluent)]

48.86
43.03
37.58
24.60
40.96
25.30
8.01
Sum:
Sample Size:
     4

Mean:
   5703
49
Standard Deviation:
   1835.4       32.24

Variability Factor:
                7.00
                              14.49
                              55.20
3.62
                .95
                                       14759
                        16311.86
                                        452.5
                                                       379.04
                                                        15.79
                                                                                     38.90
                                                                       5.56
                                                       1.42
                                                                                        228.34
ANOVA Calculations:
SSB
ssw
             n.
         -1 J.1
MSB =  SSB/(k-1)

MSW =  SSW/(N-k)

F   =  MSB/HSW
       -i  fid]
        i=l I nTj
                                              Appendix A-10
                                                                                 Rev.  3

-------
                                    Example 3  (continued)
where,

k   = lumber of treatment technologies
n.  = number of data  points for technology i
N   = number of data  points for all technologies
T.  = sun of natural  log transformed data points for each technology

X   = the natural  log transformed observations  (j)  for treatment technology (i)
 ij

N  = 4, N = 7,  N = 11,  k = 2, T  = 14.49, T  =  38.90, T = 53.39, J2= 2850.49,  T2 = 209.96


T2 = 1513.21

     (209.96     1513.21   }    2850.49
SS8 "!	  +  	  I  - 	            =  9.52
                                11

                          .  209.96    1513.2H
SSW = (55.20 + 228.34)  - 	+                     =14.88
MSB = 9.52/1  = 9.52

MSW = 14.88/9 = 1.65

F = 9.52/1.65 = 5.77

                                   ANOVA Table
Degrees of
Source freedom
Between(B) 1
Uithin(U) 9

SS MS F
9.53 9.53 5.77
14.89 1.65
      The critical  value of the F test at  the 0.05 significance level  is 5.12.  Since the
      F value is larger than the critical  value, the means are significantly different
      (i.e.,  they are heterogeneous).
Note:  All  calculations were rounded to two decimal places.  Results may differ depending
       upon the number of decimal places used  in each step of the calculations.
                                                Appendix A-ll                                 Rev.   3

-------
A.2.  Variability Factor

                                     C99
                               VF = Mean

     where:

      VF =   estimate of daily maximum variability factor
             determined from a sample population of daily data.
     Cgg =   Estimate of performance values for which 99 percent
             of the daily observations will be below.  C   is
             calculated using the following equation:
             C   = Exp(y +2.33 Sy) where y and Sy are the mean
             and standard deviation, respectively, of the
             logtransformed data.
     Mean =  average of the individual performance values.
     EPA is establishing this figure as an instantaneous maximum

because the Agency believes that on a day-to-day basis the waste

should meet the applicable treatment standards.  In addition,

establishing this requirement makes it easier to check compliance

on a single day.  The 99th percentile is appropriate because it

accounts for almost all process variability.



     In several cases, all the results from analysis of the

residuals from BOAT treatment are found at concentrations less

than the detection limit.  In such cases,  all the actual

concentration values are considered unknown and hence, cannot be

used to estimate the variability factor of the analytical

results.  Below is a description of EPA's,  approach for

calculating the variability factor for such cases with all

concentrations below the detection limit.
                          Appendix A-12                    Rev. 3

-------
     It has been postulated as a general rule that a lognormal

distribution adequately describes the variation among

concentrations.  Therefore, the lognormal model has been used

routinely in the EPA development of numerous regulations in the

Effluent Guidelines program and is being used in the BDAT

program.  The variability factor (VF) was defined as the ratio of

the 99th percentile (C_q) of the lognormal distribution to its

arithmetic mean (Mean) .
           VF =      99                                        (1)
                   Mean

     The relationship between the parameters of the lognormal

distribution and the parameters of the normal distribution

created by taking the natural logarithms of the

lognormally-distributed concentrations can be found in most

mathematical statistics texts (see for example:  Distribution  in

Statistics-Volume 1 by Johnson and Kotz, 1970) .  The mean of the

lognormal distribution can be expressed in terms of the mean (ju. )

and standard deviation ( g- )  of the normal distribution as

follows:
         Cgg    =  Exp ( JU  +  2.334CT)                        (2)


          Mean   =  Exp  ( ^  +   • 54 
-------
          VF = Exp   (2.33 CT   -   .54cr2)                       (4)

     For residuals with concentrations that are not all below  the

detection limit, the 99th percentile and the mean can be

estimated from the actual analytical data and accordingly, the

variability factor (VF) can be estimated using equation  (1).   For

residuals with concentrations that are below the detection limit,

the above equations can be used in conjunction with the

assumptions below to develop a variability factor.


Step 1: The actual concentrations follow a lognormal

distribution.  The upper limit (UL) is equal to the detection

limit.  The lower limit (LL)  is assumed to be equal to one tenth

of the detection limit.  This assumption is based on the fact

that data from well-designed and well-operated treatment systems

generally falls within one order of magnitude.


Step 2: The natural logarithms of the concentrations have a

normal distribution with an upper limit equal to In (UL) and a

lower limit equal to In (LL).


Step 3: The standard deviation ( cr )  of the normal distribution

is approximated by
                                        V

    CT = [(In (UL)  - In (LL)]  / [(2)(2.33)] = [ln(UL/LL)] /4.66

     when LL = (0.1) (UL)  then  cr = (InlO)  / 4.66 = 0.494



                          Appendix A-14                    Rev. 3

-------
Step 4: Substitution of the value from Step 3 in equation (4)



yields the variability factor, VF.








     VF = 2.8
                          Appendix A-15                    Rev. 3

-------
             APPENDIX B - ANALYSIS OF VARIANCE TESTS
ANOVA #1

Comparison  of L/L  Extraction  with L/L  Extraction  Followed by
Steam Stripping

Compare  sample  point  SD-5  (Untreated  Waste to  Steam Stripper)
with sample point SD-6 (Treated Waste From Steam Stripper)

Regulated Constituents:  Benzene
                         Nitrobenzene
                         2,4-Dinitrophenol
                         Phenol
                         Aniline
                         Cyanide


Regulated Constituents Present in Untreated Waste (SD-5):

                         Benzene
                         Nitrobenzene
                         Cyanide

Regulated Constituents Present in Treated Waste (SD-6):

                         Benzene
                         2,4-Dinitrophenol (*)
                         Cyanide


* -  An   ANOVA   analysis  could   not  be   completed   on  this
     constituent,  since  no  information  is  available  on  the
     concentration  of this  constituent  in  the  untreated waste
     (SD-5).
                         Appendix B  -  1                    Rev. 3

-------
1) Benzene (ug/1)
    AF = 1.32
Raw   SD-5
Corr. SD-5

Raw   SD-6
Corr. SD-6
170,000
224,400

  (5)
  6.6
2) Nitrobenzene (ug/1)
    AF = 0.87
Raw   SD-5
Corr. SD-5

Raw   SD-6
Corr. SD-6
3) Cyanide (mg/1)
    AF = 1.39
190,000
250,800

   8
 10.6
26,000
34,320

  (5)
  6.6
17,000
22,440

  (5)
  6.6
2.3X106
2.0X106
(3000)
2610
2.8X106
2.4X106
(3000)
2610
2.0X106
1.7X106
(1500)
1305
2.0X10
1.7x10
(3000)
2610
Raw   SD-5     4.36
Corr. SD-5     6.06
             3.45
             4.80
           2.54
           3.53
           2.27
           3.16
Raw   SD-6     4.77
Corr. SD-6     6.63
             3.87
             5.38
           2.08
           2.89
           1.70
           2.36
Note;     Numbers  in  parentheses indicate that  the compound was
          not detected  in this sample.   The detection limit has
          been  used  in  place  of  the  actual   value for  this
          compound.

(Above  raw values  are  taken  from  the EPA's  Onsite  Engineering
Report for K103 and K104. Tables 6-10 and 6-11).
                          Appendix B - 2
                                              Rev. 3

-------
1) Benzene

          Treatment 1    Treatment 2    	x1—     	x2_
SSI         224,400          6.6        12.32       1.89
SS2         250,800         10.6        12.43       2.36
SS4          34,320          6.6        10.44       1.89
SS5          22,440          6.6        10.02       1.89

k = 2
n^ = 4  n2 = 4
N = 8

SSB = (T12/n1 + T22/n2) - T2/N
    = (2043.94/4 + 64.48/4) - 2834.5/8
    = (510.99 +16.12) - 354.31
    = 527.11 - 354.31
    = 172/80

MSB = SSB/k-1 = 172.80/1 = 172.80

SSW = E E Xi i2 - 527.11
    = 531.97- 527.11
    = 4.86

MSW = SSW/N-k = 4.86/6 =0.81

F = MSB/MSW = 172.80/0.81 = 213.3

Fk-l N-k = Fl 6 = 5-" (critical value for 95% confidence)
                          Appendix B - 3                    Rev.  3

-------
2) Nitrobenzene


          Treatment 1    Treatment 2    _x1	       x2
SSI         2.00X106          2610      14.51      7.87
SS2         2.44X106          2610      14.71      7.87
SS4         1.74X106          1305      14.37      7.17
SS5         1.74X106          2610      14.37      7.87

k = 2
nl = 4  n2 = 4
N = 8

SSB = (T12/n1 + T22/n2) - T2/N
    = (3359.36/4 + 947.41/4) - 7874.79/8
    = (839.84 + 236.85) - 984.35
    = 1076.69 - 984.35
    = 92.34

MSB = SSB/k-1 = 92.34/1 = 92.34

SSW = E E Xi j2 - 1076.69
    = 1077.l4 - 1076.69
    = .45

MSW = SSW/N-k = 0.45/6 =0.08

F = MSB/MSW = 92.34/0.08 = 1154.25

Fk-l N-k = Fl 6 = 5-99 (critical value for 95% confidence)
                          Appendix B - 4                    Rev.  3

-------
3) Cyanide


          Treatment 1    Treatment 2    _xi_        X2
SSI          6.06           6.63        1.80       1.89
SS2          4.80           5.38        1.57       1.68
SS4          3.53           2.89        1.26       1.06
SS5          3.16           2.36        1.15       0.86

k = 2
n^ = 4  n2 = 4
N = 8

SSB = (T12/n1 + T22/n2) - T2/N
    = (33.41/4 + 30.14/4) - 127.01/8
    = (8.35 + 7.54) - 15.88
    = 15.89 - 15.88
    = 0.01

MSB = SSB/k-1 = 0.01/1 =0.01

SSW = E E Xi i2 - 15.89
    = 16.87 - 15.89
    = 0.98

MSW = SSW/N-k = 0.98/6 =0.16

F = MSB/MSW = 0.01/0.16 =0.06

^k-1 N-k = Fl 6 = 5.99 (critical value for 95% confidence)
                          Appendix B - 5                    Rev.  3

-------
                  Computational Table for the F Value
Constituent
Benzene
Nitrobenzene
Total Cyanides
Source
Between
Within
Between
Within
Between
Within
Sum of
Squares
172.80
4.86
92.34
0.45
0.01
0.98
Degrees of
Freedom
1
6
1
6
1
6
Mean
Square
172.80
0.81
92.34
0.08
0.01
0.16
F
213.3*
1154.25*
0.06
* - Indicates that the calculated F value exceeds the critical value.
  Conclusion

  L/L Extraction followed  by  steam stripping is more  efficient at
  reducing  the  concentration  of  benzene   and   nitrobenzene  in
  K103/K104 than L/L extraction alone,  but is not  more efficient at
  reducing the  concentration  of total  cyanides in K103/K104  than
  L/L extraction alone.
                           Appendix B - 6
Rev. 3

-------
ANOVA #2

Comparison of L/L Extraction Followed by Steam Stripping with L/L
Extraction  Followed  by Steam  Stripping  Followed by  Activated
Carbon Adsorption

Compare  sample  point SD-8  (Untreated Waste to  Activated Carbon
Adsorption  Beds)  with  sample  point  SD-9  (Treated  Waste  from
Carbon Adsorption System)

Regulated Constituents:   Benzene
                         Nitrobenzene
                         2,4-Dinitrophenol
                         Phenol
                         Aniline
                         Cyanide

Regulated Constituents Present in Untreated Waste  (SD-8):

                         Benzene
                         Aniline
                         2,4-Dinitrophenol
                         Phenol
                         Cyanide

Regulated Constituents Present in Treated Waste  (SD-9):

                         Benzene
                         Aniline
                         2,4-Dinitrophenol
                         Phenol
                         Cyanide
                         Appendix  B  -  7                    Rev. 3

-------
1) Benzene (ug/1)
    AF = 1.32
Raw   SD-8
Corr. SD-8

Raw   SD-9
Corr. SD-9
  880
1161.60

  42
 55.44
2) Aniline (ug/1)
    AF = 1.10
Raw   SD-8
Corr. SD-8

Raw   SD-9
Corr. SD-9
 57000
 62700

  (30)
   33
  130
171.60

  (5)
  6.6
   ND
   ND

  (30)
   33
3) 2,4-Dinitrophenol (ug/1)
     AF = 1.25
  39
51.48

  19
25.08
56000
61600

 (30)
  33
  20
26.40

  11
14.52
300000
330000

 960
 1056
Raw   SD-8
Corr. SD-8
 53000
 66250
   ND
   ND
24000
30000
24000
30000
Raw   SD-9     380
Corr. SD-9     475
              320
              400
           260
           325
           230
           288
          Numbers  in  parentheses indicate that  the compound was
          not detected  in this sample.   The  detection limit has
          been  used  in  place  of  the  actual  value for  this
          compound.   "ND" indicates  that this  compound  was not
          detected in the untreated  waste (SD-8),  and hence this
          reading was not used in the ANOVA calculations.
                          Appendix B -  8
                                              Rev. 3

-------
4) Phenol (ug/1)
     AF = 4.76
Raw   SD-8     ND
Corr. SD-8     ND
                    29000
                    138040
                    39000
                    185640
                   41000
                   195160
Raw   SD-9    (30)
Corr. SD-9    142.8
                     (30)
                     142.8
                    (30)
                    142.8
                    150
                    714
5) Cyanide (mg/1)
     AF = 1.39
Raw
Corr.
SD-8
SD-8
 1

6.850
9.52
4.590
6.38
3.470
4.82
0.952
1.32
Raw   SD-9
Corr. SD-9
        0.565
        0.79
            0.597
            0.83
         0.156
         0.22
          0.129
          0.18
Note;     Numbers  in  parentheses indicate that  the compound was
          not detected  in this sample.   The detection limit has
          been  used  in  place  of  the  actual   value  for  this
          compound.   "ND"  indicates  that this  compound was not
          detected in the untreated waste (SD-8), and hence this
          reading was not used in the ANOVA calculations.

(Above raw values  are taken from the EPA's Onsite Engineering
Report for K103 and K104. Tables 6-13 and 6-14).
                          Appendix B - 9
                                                     Rev. 3

-------
1) Benzene

          Treatment 1    Treatment 2     _*i_       x2
SSI          1161.6         55.4         7.06      4.01
SS2           171.6          6.6         5.15      1.89
SS4            51.5         25.1         3.94      3.22
SS5            26.4         14.5         3.27      2.67

k = 2
nl = 4  n2 = 4
N = 8

SSB = (T12/n1 + T22/n2) - T2/N
    = (377.14/4 + 139.00/4) - 974.06/8
    = (94.29 + 34.75) - 121.76
    = 129.04 - 121.76
    = 7.28

MSB = SSB/k-1 = 7.28/1 =7.28

SSW = E E Xi -j2 - 129.04
    - 139.73- 129.04
    = 10.69

MSW = SSW/N-k = 10.69/6 =1.78

F = MSB/MSW = 7.28/1.78 =4.09

Fk-l,N-k = Fl,6 = 5-99 (critical value for 95% confidence)
                         Appendix B - 10                    Rev.  3

-------
2)  Aniline
          Treatment 1    Treatment 2
SSI          62700           33          11.05     3.50
SS2            ND            33            ND      3.50
SS4          61600           33          11.03     3.50
SS5         330000          1056         12.71     6.96

k = 2
n^ = 3  r\2 = 4
N = 7

SSB = (T12/n1 + T22/n2) - T2/N
    = (1210.34/3 + 304.85/4) - 2730.06/7
    = (403.45 + 76.21) - 390.01
    = 479.66 - 390.01
    = 89.65

MSB = SSB/k-1 = 89.65/1 = 89.65

SSW = E E Xji2 - 479.66
    = 490.49- 479.66
    = 10.83

MSW = SSW/N-k = 10.83/5 =2.17

F = MSB/MSW = 89.65/2.17 = 41.31

Fk-l N-k ~ Fl 5 = 6-61 (critical value for 95% confidence)
                         Appendix B - 11                    Rev.  3

-------
3) 2,4-Dinitrophenol

          Treatment 1    Treatment 2     	x^_       x2
SSI          66250           475         11.10      6.16
SS2            ND            400           ND       5.99
SS4          30000           325         10.31      5.78
SS5          30000           288         10.31      5.66

k = 2
HI = 3  n2 = 4
N = 7

SSB = (T^/n! + T22/n2) ~ T2/N
    = (1006.16/3 + 556.49/4) - 3059.20/7
    = (335.39 + 139.12) - 437.03
    = 474.51 - 437.03
    = 37.48

MSB = SSB/k-1 = 37.48/1 = 37.48

SSW = E E Xi -j2 - 474.51
    = 475.07 - 474.51
    = 0.56

MSW = SSW/N-k = 0.56/5 =0.11

F = MSB/MSW = 37.48/0.11 = 340.73

Fk-l,N-k = Fl,5 = 6.61 (critical value for 95% confidence)
                         Appendix B - 12                    Rev.  3

-------
4)  Phenol

          Treatment 1    Treatment 2     	x1—      x2
SSI            ND           142.8          ND      4.96
SS2          138040         142.8        11.84     4.96
SS4          185640         142.8        12.13     4.96
SS5          195160         714.0        12.18     6.57

k = 2
R! = 3  n2 = 4
N = 7

SSB = (T12/n1 + T22/n2) - T2/N
    = (1306.82/3 + 460.10/4) - 3317.76/7
    = (435.61 + 115.02) - 473.97
    = 550.63 - 473.97
    = 76.66

MSB = SSB/k-1 = 76.66/1 = 76.66

SSW = E E Xji2 - 550.63
    = 552.64- 550.63
    = 2.01

MSW = SSW/N-k = 2.01/5 =0.40

F = MSB/MSW = 76.66/0.40 = 191.65

Fk-l N-k = Fl 5 = 6-61 (critical value for 95% confidence)
                         Appendix B - 13                    Rev.  3

-------
5) Cyanide

          Treatment 1    Treatment 2       Xj       	x2_
SSI          9.52            0.79         2.25      -0.24
SS2          6.38            0.83         1.85      -0.19
SS4          4.82            0.22         1.57      -1.51
SS5          1.32            0.18         0.28      -1.71

k = 2
n± = 4  n2 = 4
N = 8

SSB = (T^/n! + T22/n2) - T2/N
    = (35.4/4 + 13.3/4) - 5.29/8
    = (8.85 + 3.33) - 0.66
    = 12.18 - 0.66
    = 11.52

MSB = SSB/k-1 = 11.52/1 = 11.52

SSW = E E Xi -j2 - 12.18
    = 16.33 - 12.18
    = 4.15

MSW = SSW/N-k = 4.15/6 =0.69

F = MSB/MSW = 11.52/0.69 = 16.70

Fk-l,N-k = Fl 6 = 5-99 (critical value for 95%  confidence)
                         Appendix B - 14                    Rev.  3

-------
                  Computational Table for the F Value
Constituent
Benzene
Aniline
2,4-Dinitro-
phenol
Phenol
Total Cyanides
Source
Between
Within
Between
Within
Between
Within
Between
Within
Between
Within
Sum of
Squares
7.28
10.69
89.65
10.83
37.48
0.56
76.66
2.01
11.52
4.15
Degrees of
Freedom
1
6
1
5
1
5
1
5
1
6
Mean
Square
7.28
1.78
89.65
2.17
37.48
0.11
76.66
0.40
11.52
0.69
F
4.09
41.31*
340.73*
191.65*
16.70*
* - Indicates that the calculated F value exceeds the critical value.
  Conclusion

  L/L extraction followed  by  steam stripping and  activated  carbon
  adsorption is  more efficient  at reducing  the  concentration  of
  aniline,  2,4-dinitrophenol,  phenol and cyanide in K103/K104  than
  L/L extraction followed by steam stripping alone, but is not  more
  efficient at reducing  the concentration  of benzene  in  K103/K104
  than L/L extraction followed by steam stripping alone.
                           Appendix B - 15
Rev. 3

-------
    APPENDIX  C
                          DETECTION  LIMITS FOR CONSTITUENTS  IN THE UNTREATED
                                 AND TREATED WASTE OF SAMPLE SET 1
(D
3
a
H-
X
o
I
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
BOAT
CONSTITUENT
VOLATILE ORGANICS(ug/L)
Acetonitrile
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromomethane
Carbon Tetrachloride
Carbon Disulfide
Chlorobenzene
2-Chloro-l, 3-Butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethylvinylether
Chloroform
Chloromethane
3 -Chloropropene
1 , 2-Dibromo-3-Chloropropane
1 , 2-Dibromoethane
Dibromomethane
Trans-1 , 4-Dichloro-2-Butene
Dichlorodif luoromethane
1, 1-Dichloroethane
1 , 2-Dichloroethane
1 , 1-Dichloroethene
Trans-1 , 2-Dichloroethene
1 , 2-Dichloropropane
Trans-1 , 3-Dichloropropene
cis-1 , 3 , Dichloropropene
1 , 4-Dioxane
Ethyl Cyanide
Ethyl Methacrylate
lodomethane
Isobutyl Alcohol
Methyl ethyl ketone
Methyl Methacrylate

UNTREATED
K103

10000
10000
10000
500
500
1000
500
500
500
10000
500
1000
1000
500
1000
10000
1000
500
500
10000
1000
500
500
500
500
500
500
500
20000
10000
10000
5000
20000
10000
10000

UNTREATED
K104

10000
10000
10000
500
500
1000
500
500
500
10000
500
1000
1000
500
1000
10000
1000
500
500
10000
1000
500
500
500
500
500
500
500
20000
10000
10000
5000
20000
10000
10000

TREATED
K103 & K104

100
100
100
5
5
10
5
5
5
100
5
10
10
5
10
100
10
5
5
100
10
5
5
5
5
5
5
5
200
100
100
50
200
100
100
(Continued)

-------
          APPENDIX C
DETECTION LIMITS FOR CONSTITUENTS  IN THE UNTREATED
       AND TREATED WASTE OF  SAMPLE SET 1
X
o
 I


36
37
38
39
40
41
42
43
44
45
46
47
48
49
50

51
52
53
54
55
56
57
58
59
60
61
62
63
BOAT
CONSTITUENT
VOLATILE ORGANICS (ug/L) (Continued)
Methyl Methanesulfonate*
Methacrylonitrile
Methylene Chloride
Pyridine
1,1,1,2 -Tetrachloroe thane
1,1,2, 2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromome thane
1,1, 1-Trichloroethane
1,1, 2-Trichloroethane
Trichloroethene
Trichloromonof luoromethane
1,2, 3-Trichloropropane
Vinyl Chloride
SEMI -VOLATILE ORGANICS (ug/L)
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminofluorene
4-Aminobiphenyl
Aniline
Anthracene
Aramite
Benzo (a) anthracene
Benzenethiol
Benzidine
Benzo ( a ) py rene
Benzo (b) fluoranthene
UNTREATED
K103

ND
10000
500
40000
500
500
500
500
500
500
500
500
500
500
1000

1500000
1500000
3000000
3000000
3000000
1500000
1500000
NA
1500000
ND
7500000
1500000
1500000
UNTREATED
K104

ND
10000
500
40000
500
500
500
500
500
500
500
500
500
500
1000

150000
150000
300000
300000
300000
150000
150000
NA
150000
ND
750000
150000
150000
TREATED
K103 & K104

ND
100
5
400
5
5
5
5
5
5
5
5
5
5
10

30
30
60
60
60
30
30
NA
30
ND
150
30
30
                                                                              (Continued)

-------
    APPENDIX  C
                          DETECTION LIMITS FOR CONSTITUENTS  IN  THE UNTREATED
                                 AND TREATED WASTE OF SAMPLE SET 1
T)
(D

H-
X
O
I
u>
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
BOAT
CONSTITUENT
UNTREATED
K103
UNTREATED
K104
TREATED
K103 & K104
SEMI-VOLATILE ORGANICS (ug/L) (Continued)
Benzo(g,h,i) perylene
Benzo(k) fluoranthene
p-Benzoquinone
Bis (2-Chloroethoxy) methane
Bis (2 -Chloroethy 1) Ether
Bis (2-chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-Sec-Butyl-4 , 6-Dinitrophenol
p-Chloroaniline
Chi orobenzi late
p-Chloro-m-cresol
2 -Chloronaphthalene
2 -Chlorophenol
3-Chloropropionitrile
Chrysene
Ortho-cresol
para-cresol
Dibenz (a,h) anthracene
Dibenzo (a,e, ) Pyrene
Dibenzo(a,i) Pyrene
1 , 3-Dichlorobenzene
1 , 2-Dichlorobenzene
1 , 4-Dichlorobenzene
3,3' Dichlorobenzidine
2 , 4-Dichlorophenol
2 , 6-Dichlorophenol
Diethyl phthalate
3,3' -Dimethoxybenzidine
p-Dimethylaminoazobenzene
3,3' -Dimethylbenzidine
2 , 4-Dimethylphenol

1500000
1500000
ND
1500000
1500000
1500000
1500000
1500000
1500000
7500000
1500000
NA
1500000
1500000
1500000
NA
1500000
1500000
1500000
1500000
NA
NA
1500000
1500000
1500000
3000000
1500000
ND
1500000
1500000
3000000
ND
1500000

150000
150000
ND
150000
150000
150000
150000
150000
150000
750000
150000
NA
150000
150000
150000
NA
150000
150000
150000
150000
NA
NA
150000
150000
150000
300000
150000
ND
150000
150000
300000
ND
150000

30
30
ND
30
30
30
30
30
30
150
30
NA
30
30
30
NA
30
30
30
30
NA
NA
30
30
30
60
30
ND
30
30
60
ND
30
(Continued)

-------






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Appendix C  - 5

-------
         APPENDIX C
DETECTION LIMITS FOR CONSTITUENTS IN THE UNTREATED
       AND TREATED WASTE OF SAMPLE SET 1
•a

3
a
H-
X
o
I


**
**

154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
BOAT
CONSTITUENT
SEMI-VOLATILE ORGANICS (ug/L)
3-Nitroaniline
2-Nitrophenol
METALS (ug/L)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
UNTREATED
K103
(Continued)
7500000
1500000

32.0
10.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
5.0
6.0
10.0
6.0
2.0
UNTREATED
K104

750000
150000

32.0
10.0
1.0
1.0
4.0
7.0
6.0
50.0
20.0
11.0
500.0
6.0
10.0
6.0
2.0
TREATED
K103 & K104

150
30

32.0
10.0
1.0
1.0
4.0
7.0
6.0
500.0
20.0
11.0
50.0
6.0
1000.0
6.0
2.0
         ND  -  Constituent was not Detected, however, a matrix detection limit has not
                been determined.
         NA  -  The standard is not available;compound was searched using an NBS library of
                42,000 compounds.
          *  -  This constituent was analyzed as a semivolatile by Method 8270. The Generic Quality
                Assurance Project Plan for Land Disposal Restrictions Program("BOAT"),EPA/530-SW-87
                -Oil,March 1987,lists this compound as a Volatile ,however,it may be  analyzed as
                either a volatile or semivolatile organic
         **  -  This constituent is not on the list of constituents in the Generic
                Quality Assurance Project Plan for Land Disposal Restrictions Program ("BOAT"),
                EPA/530-SW-011,March 1987. It is a ground-water monitoring constituent as listed
                in Appendix IX, Page 26639, of the Fedral Register,Vol. 51, No.142.

-------


















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Appendix C - 7

-------
APPENDIX C
DETECTION LIMITS FOR CONSTITUENTS  IN THE UNTREATED
       AND TREATED WASTE OF  SAMPLE SET 2











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36
37
38
39
40
41
42
43
44
45
46
47
48
49
50



51
52
53
54
55
56
57
58
59
60
61
62
63

BOAT
CONSTITUENT
VOLATILE ORGANICS (ug/L)
Methyl Methanesul f onate*
Methacrylonitrile
Methylene Chloride
Pyridine
1,1,1,2 -Tetrachloroethane
1,1,2, 2 -Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Trichloroethane
1,1, 2-Trichloroethane
Trichloroethene
Trichloromonof luoromethane
1,2, 3 -Tr ichloropropane
Vinyl Chloride

SEMI-VOLATILE ORGANICS (ug/L)

Acenaphthalene
Acenaphthene
Acetophenone
2 -Acety laminof luorene
4-Aminobiphenyl
Aniline
Anthracene
Aramite
Benzo ( a ) anthracene
Benzenethiol
Benzidine
Benzo(a)pyrene
Benzo (b) fluoranthene

UNTREATED
K103

ND
10000
500
40000
500
500
500
500
500
500
500
500
500
500
1000



1500000
1500000
3000000
3000000
3000000
1500000
1500000
NA
1500000
ND
7500000
1500000
1500000

UNTREATED
K104

ND
10000
500
40000
500
500
500
500
500
500
500
500
500
500
1000



150000
150000
300000
300000
300000
150000
150000
NA
150000
ND
750000
150000
150000

TREATED
K103 & K104

ND
100
5
400
5
5
5
5
5
5
5
5
5
5
10



30
30
60
60
60
30
30
NA
30
ND
150
30
30
(Continued)

-------
         APPENDIX C
                    DETECTION LIMITS FOR CONSTITUENTS  IN  THE  UNTREATED
                           AND TREATED WASTE OF SAMPLE SET  2
•O
•a
a>
3
a
o
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
BOAT
CONSTITUENT
UNTREATED
K103
UNTREATED
K104
TREATED
K103 & K104
SEMI-VOLATILE ORGANICS (ug/L) (Continued)
Benzo(g,h,i) perylene
Benzo(k) fluoranthene
p-Benzoquinone
Bis(2-Chloroethoxy) methane
Bis(2-Chloroethyl) Ether
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-Sec-Butyl-4 , 6-Dinitrophenol
p-Chloroaniline
Chlorobenzilate
p-Chloro-m-cresol
2 -Chloronaphthalene
2 -Chlorophenol
3-Chloropropionitrile
Chrysene
Ortho-cresol
para-cresol
Dibenz ( a , h) anthracene
Dibenzo(a,e, ) Pyrene
Dibenzo(a,i) Pyrene
1, 3-Dichlorobenzene
1 , 2-Dichlorobenzene
1 , 4-Dichlorobenzene
3,3' Dichlorobenz idine
2 , 4-Dichlorophenol
2 , 6-Dichlorophenol
Diethyl phthalate
3,3' -Dimethoxybenz idine
p-Dimethylaminoazobenzene
3,3' -Dimethylbenz idine
2 , 4-Dimethylphenol

1500000
1500000
ND
1500000
1500000
1500000
1500000
1500000
1500000
7500000
1500000
NA
1500000
1500000
1500000
NA
1500000
1500000
1500000
1500000
NA
NA
1500000
1500000
1500000
3000000
1500000
ND
1500000
1500000
3000000
ND
1500000

150000
150000
ND
150000
150000
150000
150000
150000
150000
750000
150000
NA
150000
150000
150000
NA
150000
150000
150000
150000
NA
NA
150000
150000
150000
300000
150000
ND
150000
150000
300000
ND
150000

30
30
ND
30
30
30
30
30
30
150
30
NA
30
30
30
NA
30
30
30
30
NA
NA
30
30
30
60
30
ND
30
30
60
ND
30
(Continued)

-------
     APPENDIX  C
                        DETECTION  LIMITS FOR CONSTITUENTS  IN THE UNTREATED
                                AND TREATED WASTE OF SAMPLE SET 2
•O
"g
3
O
,
 97
 98
 99
100
101
102
103
104
105
106
107
108
109
110
ill
112
113
H4
115
116
117
118
119
120
121
122
123
124
125
126
127
128
BOAT UNTREATED
CONSTITUENT K103
UNTREATED
K104
TREATED
K103 & K104
SEMI -VOLATILE ORGANICS (ug/L) (Continued)
Dimethyl Phthalate
Di-n-butyl phthalate
1 , 4-Dinitrobenzene
4 , 6-dinitro-o-cresol
2 , 4-Dinitrophenol
2 , 4-Dinitrotoluene
2 , 6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosoamine
Diphenylamine (1)
1,2, -Diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Indeno(l,2,3,-cd) Pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4,4' -Methylene-bis- (2-chloroaniline)
Naphthalene
1 , 4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroanil ine
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine

1500000
1500000
7500000
7500000
7500000
1500000
1500000
1500000
1500000
3000000
7500000
1500000
1500000
1500000
1500000
1500000
1500000
NA
ND
1500000
3000000
NA
3000000
3000000
1500000
NA
7500000
7500000
7500000
1500000
7500000
ND

150000
150000
750000
750000
750000
150000
150000
150000
150000
300000
750000
150000
150000
150000
150000
150000
150000
NA
ND
150000
300000
NA
300000
300000
150000
NA
750000
750000
750000
150000
750000
ND

30
30
150
150
150
30
30
30
30
60
150
30
30
30
30
30
30
NA
ND
30
60
NA
60
60
30
NA
150
150
150
30
150
ND
(Continued)

-------








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                   Appendix C  - 11

-------
         APPENDIX  C
DETECTION LIMITS FOR CONSTITUENTS IN THE UNTREATED
       AND TREATED WASTE OF SAMPLE SET 2
x
o
I
M
N)


**
**

154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
BOAT
CONSTITUENT
SEMI -VOLATILE ORGANICS (ug/L)
3-Nitroaniline
2-Nitrophenol
METALS (ug/L)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
UNTREATED
K103
(Continued)
7500000
1500000

32.0
10.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
5.0
6.0
10.0
6.0
2.0
UNTREATED
K104

750000
150000

32.0
100.0
1.0
1.0
4.0
7.0
6.0
100.0
20.0
11.0
50.0
6.0
10.0
6.0
2.0
TREATED
K103 & K104

150
30

32.0
100.0
1.0
1.0
4.0
7.0
6.0
50.0
20.0
11.0
50.0
6.0
100.0
6.0
2.0
         ND   -   Constituent was not Detected,  however,  a matrix detection limit has not
                been determined.
         NA   -   The standard is not available;compound  was searched using an NBS library of
                42,000 compounds.
          *   -   This constituent was analyzed  as  a  semivolatile by Method 8270.  The Generic Quality
                Assurance Project  Plan  for Land Disposal Restrictions Program("BOAT"),EPA/530-SW-87
                -Oil,March 1987,lists this compound as  a Volatile ,however,it may be analyzed as
                either a volatile  or semivolatile organic
         **   -   This constituent is not on the list of  constituents in the Generic
                Quality Assurance  Project  Plan for  Land Disposal Restrictions Program ("BOAT"),
                EPA/530-SW-011,March 1987.  It  is  a  ground-water monitoring constituent as listed
                in Appendix IX,  Page 26639,  of the  Fedral Register,Vol.  51,  No.142.

-------
    APPENDIX C
                        DETECTION  LIMITS  FOR CONSTITUENTS IN THE UNTREATED
                               AND TREATED WASTE OF SAMPLE SET 3
p-
X
o
 I
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
BOAT
CONSTITUENT
VOLATILE ORGANICS (ug/L)
Acetonitrile
Acrolein
Acrylonitrile
Benzene
Bromodichlorome thane
Bromomethane
Carbon Tetrachloride
Carbon Disulfide
Chlorobenzene
2-Chloro-l , 3-Butadiene
Chi or odibromome thane
Chloroethane
2-Chloroethylvinylether
Chloroform
Chloromethane
3 -Chloropropene
1 , 2-Dibromo-3-Chloropropane
1 , 2-Dibromoethane
Dibromomethane
Trans-1, 4-Dichloro-2-Butene
Dichlorodif luorome thane
1 , l-Dichloroethane
1 , 2-Dichloroethane
1 , 1-Dichloroethene
Trans-1 , 2-Dichloroethene
1 , 2-Dichloropropane
Trans-1, 3-Dichloropropene
cis-1 , 3 , Dichloropropene
1,4-Dioxane
Ethyl Cyanide
Ethyl Methacrylate
lodomethane
Isobutyl Alcohol
Methyl ethyl ketone
Methyl Methacrylate

UNTREATED
K103

50000
50000
50000
2500
2500
5000
2500
2500
2500
50000
2500
5000
5000
2500
5000
50000
5000
2500
2500
50000
5000
2500
2500
2500
2500
2500
2500
2500
100000
50000
50000
25000
100000
50000
50000

UNTREATED
K104

20000
20000
20000
1000
1000
2000
1000
1000
1000
20000
1000
2000
2000
1000
2000
20000
2000
1000
1000
20000
2000
1000
1000
1000
1000
1000
1000
1000
40000
20000
20000
10000
40000
20000
20000

TREATED
K103 & K104

100
100
100
5
5
10
5
5
5
100
5
10
10
5
10
100
10
5
5
100
10
5
5
5
5
5
5
5
200
100
100
50
200
100
100
(Continued)

-------
        APPENDIX C
DETECTION LIMITS  FOR  CONSTITUENTS IN THE UNTREATED

       AND TREATED WASTE OF SAMPLE SET 3
•o
•o
X


o

 I


36
37
38
39
40
41
42
43
44
45
46
47
48
49
50

51
52
53
54
55
56
57
58
59
60
61
62
63
BOAT
CONSTITUENT
VOLATILE ORGANICS(ug/L) (Continued)
Methyl Methanesulfonate*
Methacrylonitrile
Methylene Chloride
Pyridine
1,1,1, 2 -Tetrachloroethane
1,1,2,2 -Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Tr ichloroethane
1,1, 2-Trichloroethane
Trichloroethene
Trichloromonof luoromethane
1,2, 3-Trichloropropane
Vinyl Chloride
SEMI -VOLATILE ORGANICS (ug/L)
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Aniline
Anthracene
Aramite
Benzo (a) anthracene
Benzenethiol
Benzidine
Benzo ( a ) pyrene
Benzo (b) fluoranthene
UNTREATED
K103

ND
50000
2500
200000
2500
2500
2500
2500
2500
2500
2500
2500
2500
2500
5000

3000000
3000000
6000000
6000000
6000000
3000000
3000000
NA
3000000
ND
15000000
3000000
3000000
UNTREATED
K104

ND
20000
1000
80000
1000
1000
1000
1000
1000
1000
1000
1000
1000
1000
2000

150000
150000
300000
300000
300000
150000
150000
NA
150000
ND
750000
150000
150000
TREATED
K103 & K104

ND
100
5
400
5
5
5
5
5
5
5
5
5
5
10

150
150
300
300
300
150
150
NA
150
ND
750
150
150
                                                                             (Continued)

-------
        APPENDIX C
                    DETECTION LIMITS  FOR CONSTITUENTS IN THE  UNTREATED
                           AND TREATED WASTE OF SAMPLE SET  3
TJ
fl>
3
a
H-
x
0
 I
H
U)
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
BOAT
CONSTITUENT
UNTREATED
K103
UNTREATED
K104
TREATED
K103 & K104
SEMI-VOLATILE ORGANICS (ug/L) (Continued)
Benzo(g,h,i) perylene
Benzo(k) fluoranthene
p-Benzoquinone
Bis(2-Chloroethoxy) methane
Bis(2-Chloroethyl) Ether
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-Sec-Butyl-4 , 6-Dinitrophenol
p-Chloroaniline
Chlorobenzilate
p-Chloro-m-cresol
2 -Chloronaphthalene
2-Chlorophenol
3 -Chloropropionitrile
Chrysene
Ortho-cresol
para-cresol
Dibenz (a,h) anthracene
Dibenzo(a,e, ) Pyrene
Dibenzo(a,i) Pyrene
1, 3-Dichlorobenzene
1 , 2-Dichlorobenzene
1 , 4-Dichlorobenzene
3,3' Dichlorobenzidine
2 , 4-Dichlorophenol
2 , 6-Dichlorophenol
Diethyl phthalate
3,3' -Dimethoxybenz idine
p-Dimethylaminoazobenzene
3,3' -Dimethylbenzidine
2 , 4-Dimethylphenol
3000000
3000000
ND
3000000
3000000
3000000
3000000
3000000
3000000
15000000
3000000
NA
3000000
3000000
3000000
NA
3000000
3000000
3000000
3000000
NA
NA
3000000
3000000
3000000
6000000
3000000
ND
3000000
3000000
6000000
ND
3000000
150000
150000
ND
150000
150000
150000
150000
150000
150000
750000
150000
NA
150000
150000
150000
NA
150000
150000
150000
150000
NA
NA
150000
150000
150000
300000
150000
ND
150000
150000
300000
ND
150000
150
150
ND
150
150
150
150
150
150
750
150
NA
150
150
150
NA
150
150
150
150
NA
ND
150
150
150
300
150
ND
150
150
300
ND
150
                                                                             (Continued)

-------
         APPENDIX C
                     DETECTION LIMITS  FOR CONSTITUENTS IN THE  UNTREATED
                            AND TREATED WASTE OF SAMPLE SET  3
T)
T)
0»
3
x
o
 I
 97
 98
 99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
123
124
125
126
127
128
BOAT
CONSTITUENT
SEMI-VOLATILE ORGANICS (ug/L)
Dimethyl Phthalate
Di-n-butyl phthalate
1 , 4-Dinitrobenzene
4 , 6-dinitro-o-cresol
2 , 4-Dinitrophenol
2 , 4-Dinitrotoluene
2 , 6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosoamine
Diphenylamine (1)
1,2, -Diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Indeno(l, 2 , 3 , -cd) Pyrene
Isosaf role
Methapyrilene
3 -Methy Icholanthrene
UNTREATED
K103
(Continued)
3000000
3000000
15000000
15000000
15000000
3000000
3000000
3000000
3000000
6000000
15000000
3000000
3000000
3000000
3000000
3000000
3000000
NA
ND
3000000
6000000
NA
6000000
4,4' -Methylene-bis- (2-chloroaniline) 6000000
Naphthalene
1 , 4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
3000000
NA
15000000
15000000
15000000
3000000
15000000
ND
UNTREATED
K104

150000
150000
750000
750000
750000
150000
150000
150000
150000
300000
750000
150000
150000
150000
150000
150000
150000
NA
ND
150000
300000
NA
300000
300000
150000
NA
750000
750000
750000
150000
750000
ND
TREATED
K103 & K104

150
150
750
760
760
150
150
150
150
300
750
150
150
150
150
150
150
NA
ND
150
300
NA
300
300
150
NA
750
750
760
150
760
ND
                                                                              (Continued)

-------









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               Appendix C - 17

-------
        APPENDIX C
               DETECTION LIMITS FOR CONSTITUENTS IN THE UNTREATED
                      AND TREATED WASTE OF SAMPLE SET 3






Append j
X
o
1

154
155
156
157
158
159
160
161
162
163
164
165
166
167
168

BOAT
CONSTITUENT
METALS (ug/L)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
ND - Constituent was not
UNTREATED
K103

32.0
10.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
5.0
6.0
10.0
6.0
2.0
Detected, however, a
UNTREATED
K104
32.0
10.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
50.0
6.0
10.0
6.0
2.0
matrix detection
TREATED
K103 & K104
32.0
10.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
50.0
6.0
10.0
6.0
2.0
limit has







not
oo
       been determined.
NA  - 'The standard is not available,'compound was searched using an NBS library of
       42,000 compounds.
 *  -  This constituent was analyzed as a semivolatile by Method 8270. The Generic Quality
       Assurance Project Plan for Land Disposal Restrictions Program("BOAT"),EPA/530-SW-87
       -Oil,March 1987,lists this compound as a Volatile ,however,it may be analyzed as
       either a volatile or semivolatile organic
**  -  This constituent is not on the list of constituents in the Generic
       Quality Assurance Project Plan for Land Disposal Restrictions Program  ("BOAT"),
       EPA/53O-SW-011,March 1987. It is a ground-water monitoring constituent as listed
       in Appendix IX, Page 26639, of the Fedral Register,Vol. 51, No.142.

-------
    APPENDIX C
                        DETECTION  LIMITS FOR CONSTITUENTS  IN THE UNTREATED
                                AND TREATED WASTE OF SAMPLE SET 4
3
a
H-
x
o
I
 1
 2
 3
 4
 5
 6
 7
 8
 9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
BOAT
CONSTITUENT
VOLATILE ORGANICS(ug/L)
Acetonitrile
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromomethane
Carbon Tetrachloride
Carbon Disulfide
Chlorobenzene
2-Chloro-l, 3-Butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethylvinylether
Chloroform
Chloromethane
3 -Chloropropene
1 , 2-Dibromo-3-Chloropropane
1 , 2-Dibromoethane
Dibromomethane
Trans-l,4-Dichloro-2-Butene
Dichlorodif luoromethane
1 , l-Dichloroethane
1 , 2-Dichloroethane
1 , 1-Dichloroethene
Trans-1 , 2-Dichloroethene
1 , 2-Dichloropropane
Trans-1 , 3-Dichloropropene
cis-1 , 3 , Dichloropropene
1, 4-Dioxane
Ethyl Cyanide
Ethyl Methacrylate
lodomethane
Isobutyl Alcohol
Methyl ethyl ketone
Methyl Methacrylate

UNTREATED
K103

50000
50000
50000
2500
2500
5000
2500
2500
2500
50000
2500
5000
5000
2500
5000
50000
5000
2500
2500
50000
5000
2500
2500
2500
2500
2500
2500
2500
100000
50000
50000
25000
100000
50000
50000

UNTREATED
K104

10000
10000
10000
500
500
1000
500
500
500
10000
500
1000
1000
500
1000
10000
1000
500
500
10000
1000
500
500
500
500
500
500
500
20000
10000
10000
5000
20000
10000
10000

TREATED
K103 & K104

100
100
100
5
5
10
5
5
5
100
5
10
10
5
10
100
10
5
5
100
10
5
5
5
5
5
5
5
200
100
100
50
200
100
100
(Continued)

-------
APPENDIX C
DETECTION LIMITS FOR CONSTITUENTS  IN THE UNTREATED
       AND TREATED WASTE OF  SAMPLE SET 4










T3
3
a
H-
X
o
1
to
o













36
37
38
39
40
41
42
43
44
45
46
47
48
49
50



51
52
53
54
55
56
57
58
59
60
61
62
63
BOAT
CONSTITUENT
VOLATILE ORGANICS(ug/L) (Continued)
Methyl Methanesulfonate*
Methacrylonitrile
Methylene Chloride
Pyridine
1,1,1,2 -Tetrachloroethane
1,1,2, 2 -Tetrachloroethane
Tetrachloroethene
Toluene
Tribroroome thane
1,1, 1-Trichloroethane
1,1, 2-Trichloroethane
Trichloroethene
Trichloromonof luoromethane
1,2, 3-Trichloropropane
Vinyl Chloride
SEMI-VOLATILE ORGANICS (ug/L)
Acenaphthylene
Acenaphthene
Acetophenone
2-Acetylaminofluorene
4-Aminobiphenyl
Aniline
Anthracene
Aramite
Benzo ( a ) anthracene
Benzenethiol
Benzidine
Benzo (a) Pyrene
Benzo (b) Fluoranthene
UNTREATED
K103

ND
50000
2500
200000
2500
2500
2500
2500
2500
2500
2500
2500
2500
2500
5000

3000000
3000000
6000000
6000000
6000000
3000000
3000000
NA
3000000
ND
15000000
3000000
3000000
UNTREATED
K104

ND
10000
500
40000
500
500
500
500
500
500
500
500
500
500
1000

300000
300000
600000
600000
600000
300000
300000
NA
300000
ND
1500000
300000
300000
TREATED
K103 & K104

ND
100
5
400
5
5
5
5
5
5
5
5
5
5
10

30
30
60
60
60
30
30
NA
30
ND
150
30
30
                                                                    (Continued)

-------
    APPENDIX C
                       DETECTION LIMITS FOR CONSTITUENTS  IN THE UNTREATED
                              AND TREATED WASTE OF  SAMPLE SET 4
•o

a
H-
X
o
 I
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
BOAT
CONSTITUENT
SEMI-VOLATILE ORGANICS (ug/L)
Benzo(g,h,i) perylene
Benzo(k) fluoranthene
p-Benzoquinone
Bis (2-Chloroethoxy) methane
Bis(2-Chloroethyl) Ether
Bis (2-chloroisopropyl) ether
Bis (2-ethylhexyl) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-Sec-Butyl-4 , 6-Dinitrophenol
p-Chloroaniline
Chlorobenzilate
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitrile
Chrysene
Ortho-cresol
para-cresol
Dibenz (a,h) anthracene
Dibenzo(a, e, ) Pyrene
Dibenzo(a,i) Pyrene
1 , 3-Dichlorobenzene
1 , 2-Dichlorobenzene
1 , 4-Dichlorobenzene
3,3' Dichlorobenzidine
2 , 4-Dichlorophenol
2 , 6-Dichlorophenol
Diethyl phthalate
3,3' -Dimethoxybenzidine
p-Dimethylaminoazobenzene
3,3' -Dimethylbenzidine
2 , 4-Dimethylphenol

UNTREATED
K103
(Continued)
3000000
3000000
ND
3000000
3000000
3000000
3000000
3000000
3000000
15000000
3000000
NA
3000000
3000000
3000000
NA
3000000
3000000
3000000
3000000
NA
NA
3000000
3000000
3000000
6000000
3000000
ND
3000000
3000000
6000000
ND
3000000

UNTREATED
K104

300000
300000
ND
300000
300000
300000
300000
300000
300000
1500000
300000
NA
300000
300000
300000
NA
300000
300000
300000
300000
NA
NA
300000
300000
300000
600000
300000
ND
300000
300000
600000
ND
300000

TREATED
K103 & K104

30
30
ND
30
30
30
30
30
30
150
30
NA
30
30
30
NA
30
30
30
30
NA
NA
30
30
30
60
30
ND
30
30
60
ND
30
(Continued)

-------








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-------
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                                                          Appendix  C  -  23

-------
        APPENDIX  C
DETECTION LIMITS FOR CONSTITUENTS IN THE UNTREATED
       AND TREATED WASTE OF SAMPLE SET 4
n
<0
a
H-
X
o
NJ
**
**
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
BOAT
CONSTITUENT
SEMI -VOLATILE ORGANICS (ug/L)
3-Nitroaniline
2-Nitrophenol
METALS (ug/L)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
UNTREATED
K103
(Continued)
15000000
3000000

32.0
10.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
5.0
6.0
10.0
6.0
2.0
UNTREATED
K104
1500000
300000
32.0
10.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
50.0
6.0
10.0
6.0
2.0
TREATED
K103 & K104
150
30
32.0
500.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
50.0
6.0
10.0
6.0
2.0
        ND   -   Constituent was not Detected,  however,  a matrix detection limit has not
                been determined.
        NA   -   The standard is not available;compound  was searched using an NBS library of
                42,000 compounds.
          *   -   This constituent was analyzed  as a semivolatile by Method 8270. The Generic Quality
                Assurance Project Plan for Land Disposal Restrictions Program("BOAT"),EPA/53O-SW-87
                -Oil,March 1987,lists this compound as  a Volatile ,however,it may be analyzed as
                either a volatile or semivolatile organic
        **   -   This constituent is not on the list of  constituents in the Generic
                Quality Assurance Project Plan for Land Disposal Restrictions Program ("BOAT"),
                EPA/530-SW-011,March 1987. It  is a ground-water monitoring constituent as listed
                in Appendix IX, Page 26639,  of the Fedral Register,Vol.  51,  No.142.

-------










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Appendix C - 25

-------
        APPENDIX C
DETECTION LIMITS  FOR CONSTITUENTS  IN  THE UNTREATED
       AND TREATED WASTE OF SAMPLE SET 5
(0
3
X
o
I
to
CT*


36
37
38
39
40
41
42
43
44
45
46
47
48
49
50

51
52
53
54
55
56
57
58
59
60
61
62
63
BOAT
CONSTITUENT
VOLATILE ORGANICS(ug/L) (Continued)
Methyl Methanesulfonate*
Methacrylonitrile
Methylene Chloride
Pyridine
1,1,1, 2-Tetrachloroethane
1,1,2,2 -Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, l-Trichloroethane
1,1, 2-Trichloroethane
Trichloroethene
Trichloromonof luoromethane
1,2, 3-Trichloropropane
Vinyl Chloride
SEMI-VOLATILE ORGANICS (ug/L)
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminofluorene
4 -Aminobipheny 1
Aniline
Anthracene
Aramite
Benz o ( a ) anthracene
Benzenethiol
Benzidine
Benzo(a) pyrene
Benzo(b) fluoranthene
UNTREATED
K103

ND
50000
2500
200000
2500
2500
2500
2500
2500
2500
2500
2500
2500
2500
5000

3000000
3000000
6000000
6000000
6000000
3000000
3000000
NA
3000000
ND
15000000
3000000
3000000
UNTREATED
K104

ND
5000
250
20000
250
250
250
250
250
250
250
250
250
250
500

300000
300000
600000
600000
600000
300000
300000
NA
300000
ND
1500000
300000
300000
TREATED
K103 & K104

ND
100
5
400
5
5
5
5
5
5
5
5
5
5
10

30
30
60
60
60
30
30
NA
30
ND
150
30
30
                                                                             (Continued)

-------
        APPENDIX  C
                    DETECTION  LIMITS FOR CONSTITUENTS IN THE UNTREATED
                          AND TREATED WASTE OF SAMPLE SET 5
T)
(D
X
o
 I
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
BOAT
CONSTITUENT
SEMI-VOLATILE ORGANICS (ug/L)
Benzo(g,h,i) perylene
Benzo(k) fluoranthene
p-Benzoquinone
Bis(2-Chloroethoxy) methane
Bis(2-Chloroethyl) Ether
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-Sec-Butyl-4 , 6-Dinitrophenol
p-Chloroaniline
Chlorobenzilate
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitrile
Chrysene
Ortho-cresol
para-cresol
Dibenz (a , h) anthracene
Dibenzo(a,e, ) Pyrene
Dibenzo(a,i) Pyrene
1, 3-Dichlorobenzene
1 , 2-Dichlorobenzene
1 , 4-Dichlorobenzene
3,3' Dichlorobenz idine
2 , 4-Dichlorophenol
2 , 6-Dichlorophenol
Diethyl phthalate
3,3' -Dimethoxybenz idine
p-Dimethylaminoazobenzene
3,3' -Dimethylbenz idine
2 , 4-Dimethylphenol

UNTREATED
K103
(Continued)
3000000
3000000
ND
3000000
3000000
3000000
3000000
3000000
3000000
15000000
3000000
NA
3000000
3000000
3000000
NA
3000000
3000000
3000000
3000000
NA
NA
3000000
3000000
3000000
6000000
3000000
ND
3000000
3000000
6000000
ND
3000000

UNTREATED
K104

300000
300000
ND
300000
300000
300000
300000
300000
300000
1500000
300000
NA
300000
300000
300000
NA
300000
300000
300000
300000
NA
NA
300000
300000
300000
600000
300000
ND
300000
300000
600000
ND
300000

TREATED
K103 & K104

30
30
ND
30
30
30
30
30
30
150
30
NA
30
30
30
NA
30
30
30
30
NA
NA
30
30
30
60
30
ND
30
30
60
ND
30
(Continued)

-------








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                           Appendix  C  -  28

-------
APPENDIX C
DETECTION LIMITS FOR CONSTITUENTS IN THE UNTREATED
       AND TREATED WASTE OF SAMPLE SET 5


BOAT
CONSTITUENT
UNTREATED
K103
UNTREATED
K104
TREATED
K103 & K104
SEMI -VOLATILE ORGANICS (ug/L) (Continued)











>
13
'O
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**
a
H-
X


1
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129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
**
**
**
**
**
**
**
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N-Nit r osomorphol ine
1-Nitrosopiperidine
N-Nitrosopyrrolidine
5-Nitro-o-toluidine
Pentachlorobenzene
Pentachloroethane
Pentachloronitrobenzene
Pentachlorophenol
Phenacetin
Phenanthrene
Phenol
2-Picoline
Pronamide
Pyrene
Resorcinol
Safrole
1,2,4, 5-Tetrachlorobenzene
2,3,4, 6-Tetrachlorophenol
1,2, 4-Trichlorobenzene
2,4, 5-Trichlorophenol
2,4, 6-Trichlorophenol
Tris (2, 3-dibromopropyl) phosphate
Benzoic Acid
Benzyl Alcohol
1 , 2-Diaminobenzene
1 , 3-Diaminobenzene
1 , 4-Diaminobenzene
Diphenylnitrosoamine
2-Nitroaniline
ND
3000000
3000000
6000000
3000000
15000000
3000000
ND
NA
30000000
15000000
6000000
3000000
3000000
3000000
ND
3000000
NA
15000000
6000000
ND
3000000
15000000
3000000
ND
15000000
3000000
ND
ND
ND
15000000
15000000
ND
300000
300000
600000
300000
1500000
300000
ND
NA
3000000
1500000
600000
300000
300000
300000
ND
300000
NA
1500000
600000
ND
300000
1500000
300000
ND
1500000
300000
ND
ND
ND
1500000
1500000
ND
30
30
60
30
150
60
ND
NA
300
150
60
30
30
30
ND
30
NA
150
60
ND
30
150
30
ND
150
30
ND
ND
ND
150
150
                                                                   (Continued)

-------
         APPENDIX C
         DETECTION  LIMITS  FOR  CONSTITUENTS  IN THE UNTREATED
               AND TREATED WASTE  OF  SAMPLE SET 5
(D
a
M-
X
o
I
U)
o


**
**

154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
BOAT
CONSTITUENT
SEMI-VOLATILE ORGANICS (ug/L)
3-Nitroaniline
2 -Nitrophenol
METALS (ug/L)
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
UNTREATED
K103
(Continued)
15000000
3000000

32.0
500.0
1.0
1.0
4.0
7.0
6.0
5.0
20.0
11.0
5.0
6.0
10.0
6.0
2.0
UNTREATED
K104

1500000
300000

32.0
500.0
1.0
1.0
4.0
7.0
6.0
50.0
20.0
11.0
50.0
6.0
10.0
6.0
2.0
TREATED
K103 & K104

150
30

32.0
10.0
1.0
1.0
4.0
7.0
6.0
100.0
20.0
11.0
50.0
6.0
10.0
6.0
2.0
        ND

        NA
        **  —
been determined.
The standard is not available;compound was searched using an NBS library of
42,000 compounds.
This constituent was analyzed as a semivolatile by Method 8270. The Generic Quality
Assurance Project Plan for Land Disposal Restrictions Program("BOAT"),EPA/530-SW-87
-Oil,March 1987,lists this compound as a Volatile ,however,it may be  analyzed as
either a volatile or semivolatile organic
This constituent is not on the list of constituents in the Generic
Quality Assurance Project Plan for Land Disposal Restrictions Program ("BOAT"),
EPA/530-SW-011,March 1987. It is a ground-water monitoring constituent as listed
in Appendix IX, Page 26639, of the Fedral Register,Vol.  51, No.142.

-------
APPENDIX 0    Calculation of  Treatment Standards
Constituent:  Benzene
Effluent 1 Accuracy 3 Corrected 4
Sample Set Concentration Percent 2 Correction Concentration Log 5
(ing/ 1) Recovery Factor (ing/ 1) Transform
1 0.042 76 1.32 0.055
2 0.005 76 1.32 0.007
4 0.019 76 1.32 0.025
5 0.011 76 1.32 0.015
x = 0.026 y =
s =
-2.900
-4.962
-3.689
-4.200
-3.938
0.867
1 - Obtained from the Onsite Engineering Report, E. I . du Pont de Nemours,  Table 6-14.
2 - Obtained from the Onsite Engineering Report, E. I . du Pont de Nemours,  Table 7-12.
3 - Accuracy Correction Factor  =  100  / Percent Recovery.
4 - Corrected Concentration = Effluent Concentration X Accuracy Correction Factor.
5 - Log Transform using the natural  logarithm. In, of the Corrected Concentration.

Treatment Standard = Corrected  Effluent Mean X VF

Calculation of Variability Factor (VF):

c   = exp 
      where
            y = the mean of  the log  transforms
            s = the standard deviation of the  log transforms.
Therefore,  C   = exp (-3.938 +  2.33(0.867))
                   = exp (-1.918)
                   = 0.147
        and VF = C   /  x
                  99
      where
            x = the mean  of  the  corrected effluent concentrations.
Therefore,   VF = C   /  x
               = 0?147  /  0.026
               = 5.654
Treatment Standard =  Corrected  Effluent Mean X VF
                   =  0.026  X  5.654
                   =  0.147  mg/l
                                       Appendix  D  -   1

-------
APPENDIX D    Calculation of  Treatment Standards
Constituent:  Aniline

Sample Set

Effluent 1
Concentration
(ing/ 1)
I
Percent 2
Recovery
Accuracy 3
Correction
Factor
Corrected 4
Concentration
(mg/l)

Log 5
Transform
                    0.030
                    0.030
                    0.030
                    0.960
91
91
91
91
1.10
1.10
1.10
1.10
0.033
0.033
0.033
1.056
-3.411
-3.411
-3.411
 0.054
                                                     x =
                              0.289 y =
                                    s =
                            -2.545
                             1.733
1 - Obtained from the Onsite Engineering Report, E. J . du Pont de Nemours, Table 6-14.
2 - Obtained from the Onsite Engineering Report, E. I. du Pont de Nemours, Table 7-13.
3 - Accuracy Correction Factor  =  100 / Percent Recovery.
4 - Corrected Concentration = Effluent Concentration X Accuracy Correction Factor.
5 - Log Transform using the natural logarithm, In, of the Corrected Concentration.

Treatment Standard = Corrected  Effluent Mean X VF

Calculation of Variability Factor (VF):

C   = exp (y * 2-33s)
      where
            y = the mean of  the  log  transforms
            s = the standard deviation of the log transforms.
Therefore,  C   = exp (-2.545  +  2.33(1.733))
                = exp (1.493)
                = 4.450
        and  VF = C   / x
      where
              x = the mean of  the  corrected effluent concentrations.
Therefore,   VF = C   / x
                = 4?450 / 0.289
                = 15.398
Treatment Standard = Corrected Effluent Mean X VF
                   = 0.289 X  15.398
                   = 4.450 mg/t
                                      Appendix  D  -  2

-------
APPENDIX P    Calculation of  Treatment Standards
Constituent:  2,4-Dinitrophenol
Effluent
Sample Set Concentration
(mg/l)
1 0.380
2 0.320
4 0.260
5 0.230


I
Percent 2*
Recovery
80
80
80
80


Accuracy 3
Correction
Factor
1.25
1.25
1.25
1.25
X

Corrected 4
Concentration
(mg/l)
0.475
0.400
0.325
0.288
0.372 y
s

Log 5
Transform
-0.744
-0.916
-1.124
-1.245
= -1.007
= 0.222
1 - Obtained from the Onsite Engineering  Report, E.  I. du Pont de Nemours, Table 6-14.
2 - Obtained from the Onsite Engineering  Report, E.  I. du Pont de Nemours, Table 7-13.
     * - Average of Percent Recovery for  Semivolatiles with greater than or equal to
         20% recovery as listed in Table  7-13.
3 - Accuracy Correction Factor = 100 /  Percent  Recovery.
4 - Corrected Concentration = Effluent  Concentration X Accuracy Correction Factor.
5 - Log Transform using the natural logarithm,  In,  of the Corrected Concentration.

Treatment Standard = Corrected Effluent Mean  X  VF

Calculation of Variability Factor (VF):

C   = exp (y + 2.33s)
      where
            y = the mean of the log transforms
            s = the standard deviation  of the log  transforms.
Therefore,  C   = exp (-1.007 + 2.33(0.222))
                = exp (-0.490)
                = 0.613
        and  VF = C   / x
      where
              x = the mean of the corrected effluent  concentrations.
Therefore,  VF = C   / x
               = 0.613 / 0.372
               = 1.648
Treatment Standard = Corrected Effluent  Mean X  VF
                   = 0.372 X 1.648
                   = 0.613 mg/l
                                       Appendix  D  -  3

-------
APPENDIX D   Calculation of Treatment Standards

Constituent:      Nitrobenzene
Effluent 1 Accuracy 3 Corrected 4
Sample Set Concentration Percent 2 Correction Concentration Log 5
(mg/l) Recovery Factor (ing/ 1) Transform
1 0.03 115 0.87 0.026
2 0.03 115 0.87 0.026
4 0.03 115 0.87 0.026
5 0.03 115 0.87 0.026
x = 0.026 y =
s =
-3.650
-3.650
-3.650
-3.650
-3.650
0.000
1 - Obtained from the Onsite Engineering Report, E.  I. du Pont de Nemours, Table 6-H.
2 - Obtained from the Onsite Engineering Report, E.  I. du Pont de Nemours, Table 7-13.
3 - Accuracy Correction Factor = 100 / Percent  Recovery.
4 - Corrected Concentration = Effluent Concentration X Accuracy Correction Factor.
5 - Log Transform using the natural logarithm.  In, of the Corrected Concentration.

Treatment Standard = Corrected Effluent Mean X  VF

Calculation of Variability Factor (VF):

C   = exp (y + 2.33s)
          where
                y = the mean of the log transforms
                s = the standard deviation of the log transforms.
Therefore,
                 99
= exp (-3.650 + 2.33(0))
= exp (-3.650)
= 0.026
            and  VF = C   / x
          where
                  x = the mean of the corrected effluent concentrations.

Therefore,       VF = C   / x
                    = 0?026 / 0.026
                    = 1
A variability factor of one was not used  in calculating the treatment standards.
The variability factor of 2.80 was substituted for the value 1.
                 VF = 2.80
Treatment Standard
                     Corrected Effluent Mean X VF
                       = 0.026 X 2.80
                       = 0.073 mg/t
                                      Appendix  D  -  4

-------
APPENDIX 0
              Calculation of Treatment  Standards
Constituent:  Phenol

Sample Set

Effluent 1
Concentration
(mg/l)

Percent 2
Recovery
Accuracy 3
Correction
Factor
Corrected 4
Concentration
(mg/D

Log 5
Transform
                    0.030
                    0.030
                    0.030
                    0.150
21
21
21
21
4.76
4.76
4.76
4.76
0.143
0.143
0.143
0.714
-1.945
-1.945
-1.945
-0.337
                                                                 0.286 y =
                                                                       s =
                                         -1.543
                                         0.804
1 - Obtained from the Onsite Engineering Report,  E.  I.  du Pont de Nemours, Table 6-14.
2 - Obtained from the Onsite Engineering Report,  E.  I.  du Pont de Nemours, Table 7-13.
3 - Accuracy Correction Factor = 100 / Percent  Recovery.
4 - Corrected Concentration = Effluent Concentration X  Accuracy  Correction Factor.
5 - Log Transform using the natural logarithm.  In, of the Corrected  Concentration.

Treatment Standard = Corrected Effluent Mean X  VF

Calculation of Variability Factor (VF):

C   = exp (y + 2.33s)
      where
            y = the mean of the log transforms
            s = the standard deviation of the log transforms.

Therefore,  C   = exp (-1.543 + 2.33(0.804))
                = exp (0.330)
                = 1.391

        and  VF = C   / x
      where
              x = the mean of the corrected effluent concentrations.

Therefore,   VF = C   / x
                = 1?391 /  0.286
                = 4.864
Treatment Standard = Corrected Effluent Mean X VF
                   = 0.286 X 4.864
                   = 1.391 mg/l
                                               Appendix  D  -  5

-------
APPENDIX D    Calculation of  Treatment Standards
Constituent:  Total Cyanides

Sample Set

Effluent
Concentration
(mg/l)
1
Percent 2
Recovery
Accuracy 3
Correction
Factor
Corrected 4
Concentration
(mg/l)

Log 5
Transform
                    0.565
                    0.597
                    0.156
                    0.129
                       72
                       72
                       72
                       72
1.39
1.39
1.39
1.39
0.785
0.830
0.217
0.179
-0.242
-0.186
-1.528
-1.720
                                                                 0.503 y =
                                                                       s =
                                                                -0.919
                                                                 0.818
1 - Obtained from the Onsite Engineering Report, E.  I. du Pont de Nemours, Table 6-K.
2 - Obtained from the Onsite Engineering Report, E.  I. du Pont de Nemours, Table 7-14.
3 - Accuracy Correction Factor = 100 / Percent Recovery.
4 - Corrected Concentration = Effluent Concentration  X Accuracy Correction Factor.
5 - Log Transform using the natural  logarithm, In, of the Corrected Concentration.

Treatment Standard = Corrected Effluent Mean X VF

Calculation of Variability Factor (VF):

C   = exp (y + 2.33s)
      where
            y = the mean of the log  transforms
            s = the standard deviation of  the  log  transforms.

Therefore,  C   = exp (-0.919 + 2.33(0.818))
                = exp (0.987)
                = 2.683

        and VF = C   / x
      where
             x = the mean of the corrected effluent  concentrations.
Therefore,
VF - C   / x
   = 2.683 / 0.503
   = 5.334
Treatment Standard = Corrected Effluent  Mean  X  VF
                   = 0.503 X 5.334
                   = 2.683 mg/l
                                      Appendix  D  -  6

-------
                  APPENDIX E - ANALYTICAL QA/QC



     The  analytical methods used  for analysis  of the regulated



constituents  identified in  Section 5 are  listed  in  Table E-l.



SW-846  methods (EPA's  Test  Methods for Evaluating Solid Waste;



Physical/Chemical Methods. SW-846.  Third Edition, November 1986)



are   used   in   most   cases   for   determining  total   waste



concentrations.








     Deviations  from  SW-846  methods required  to analyze  the



sample  matrix are  listed  in  Table E-2.   These  deviations  are



approved  methods  for determining constituent concentrations.



SW-846  also  allows for  the  use  of  alternative  or  equivalent



procedures  or  equipment;   these  are described  in  Tables  E-3



through E-5.   These alternatives or  equivalents included use of



alternative  sample  preparation  methods  and/or  use  of  different



extraction techniques to reduce sample matrix interferences.







     The accuracy determination for a constituent is based on the



matrix spike recovery values.  Table E-6 present the matrix spike



recovery  values  for  total  waste  concentrations  of  benzene,



aniline,  nitrobenzene,  and  phenol  for  K103/K104  and  for  total



cyanides  for  K104  for  the  EPA-collected data.   Because



2,4-dinitrophenol matrix spike recoveries were not collected,  the



average of  the percent recoveries  equal' to or  greater  than  20%



for all  semivolatiles  was  used as  the  percent  recovery for



2,4-dinitrophenol.






                         Appendix E-l

-------
     The   accuracy   correction    factors   for   the   regulated

constituents for the  treatment residuals are  presented in Table

E-6.    The  accuracy  correction   factors  were  determined  in

accordance  with   the  general  methodology  presented   in  the

Introduction.    For example,  for  benzene,  actual  spike  recovery

data were obtained for analysis of liquid matrices and the lowest

percent  recovery  value  was  used  to  calculate  the  accuracy

correction  factor.    An  example  of  the  calculation  of  the

corrected concentration value for benzene is shown below.
Analytical                Correction             Corrected
  Value      % Recovery     Factor      	Value	

0.042 mg/1       76       100 =1.32    1.32 x 0.042 = 0.055 mg/1
                           76
                         Appendix E - 2

-------
     Table E-1  Analytical  Methods for Regulated Constituents
Regulated Constituent
   Analytical  Method
Method Number
Volatiles

   Benzene
Purge and Trap                   5030

Gas Chromatography/Mass           8240
Spectrometry for  Volatile
Organics
Semivolatiles

   Aniline
   2,4-Dinitrophenol
   Nitrobenzene
   Phenol
Continuous Liquid/Liquid         3520
Extraction

Gas Chromatography/Mass          8270
Spectrometry Column
Technique
Inorganics

   Cyanides
Total  and Amenable Cyanides      9012
a - Environmental  Protection Agency.  1986.  Test Methods for
    Evaluating Solid Waste.  Third Edition. U.  S. EPA.   Office of
    Solid Waste and Emergency Response.   November 1986.
                       Appendix  E  -   3

-------
                                                                    Table  E-2  Deviations from SW-846
                                                                                                        a
                Ana l>s is
                                    Method
                   SW 846  specificat ion
                                                                                                  Deviation from SW B46
                                                                                                                                         Rationale for deviation
         1   Con! muous  tiquid/
            L iquul  f xt ract ion
•d
 (D
 3
 H-
 X
 M
 I
 ^
35?0     A  The internal  standards  are  prepared
            by dissolving them in carbon
            bisulfide and then diluting to
            volume so that  the final  solvent  is
            20V, carlinn disulfide and  80/
            methytene chlor ide

         B  The extracts  are concentrated to  a
            final volume  of 1-2 ml
                                               C   The  samples are extracted  initially
                                                  (base/neutral) extracted at pH >11
                                                  and  the  secondary  (acid) extraction
                                                  is at  pH <2
The preparation of the internal
standards was changed to eliminate the
use of carbon disulfide   The internal
standards were prepared in methylene
chloride only
Due to the high organic content in
many samples, the extracts could not
be reduced to the 1-2 ml final
volume   The increased sample volume
in the extract was taken into account
when the dilutions were made and when
the concentrations values were
calculated.  Final sample volume
varied depending upon the sample
However, for most samples the final
volume was 6-7 ml   For sample point
1. the final volume was 7S-100 ml.

For samples from SD3. SD4, and S010,
the acid extraction was completed
first, followed by the base/neutral
extraction.
                                                                                                                                    Final volume of sample extracts
                                                                                                                                    was increased to keep all organic
                                                                                                                                    material in solution.  When the
                                                                                                                                    final volume was decreased, the
                                                                                                                                    samples crystallized
                                                                                               The acid extraction  was  completed
                                                                                               first  due to the acidity of  the
                                                                                               samples.   The pHs for  these
                                                                                               samples were between 0 and 2.
                                                                                               Therefore,  to prevent  potential
                                                                                               sample contamination and to
                                                                                               prevent adding large volumes of
                                                                                               acid and base solution to change
                                                                                               the pH to basic  and  then back to
                                                                                               acidic, the acid extraction was
                                                                                               completed first.   The  pH of
                                                                                               samples from Sample  Point 11
                                                                                               could  not be raised  to pH 11
                                                                                               (200 ml of  NaOH  were added to the

-------
                                                                             Table E-2   (Continued)
                  Ana lysis
Method
                    SW-846  specification
                                                                                                    Oeviat ion from SW-846
     Rationale for deviation
'O
 (D
 3
 a
 H-
 x
 w
 I
 01
            1  Continuous Liquid/
              L iquid Extract ion
                (Continued)
                                                0  The samples are extracted for
                                                   base/neutral and for acid
                                                   extractables
                                                    For SO 10. the one sample taken was
                                                    extracted for the acid extraction only
1'iter sample and the pH did  not
change from the initial pH of
zero.)

The sample contained about 60X
nitrobenzene, therefore,  to
obtain information on the
presence of the acid extractable
compounds, the analysis was
completed only on the acid
extractables.  The high quantity
of nitrobenzene in the
base/neutral fraction would  have
required extremely high dilution
of the material to prevent column
saturation and to bring the
concentration level into the ppb
linear range of the Method.
Therefore, only the level of
nitrobenzene could have been
quantified.
        a  -  Onsite Engineering Report of Treatment Technology Performance  for E. I. duPont
             de Nemours,  Inc.,  Beaumont, Texas.   Table 7-4.

-------
                                Table E-3  Specific  Procedures or Equipment Used in Extraction of Organic  Compounds  When
                                           Alternatives or Equivalents  are Allowed in the  SW-846 Methods
      Ana l
                       SW-846 Method
                                                     Sample Aliquot
Alternatives or  Equivalents Allowed
         by SW-846  Methods
     Specific  Procedures or
          Equipment  Used
Purge and  Trap
                             5030
                                               5 mi 1li liters of liquid
V
ID
3
H-
X
w
 I
o\
Continuous Liquid-
Liquid Extraction
                             3520
                                               1 liter of liquid
  The purge and trap device to be
  used is specified in the method in
  Figure 1, the desorber to be used
  is described in Figures 2 and 3.
  and the packing materials are
  described in Section 4.10.2   The
  method allows equivalents of this
  equipment or materials to be used.

  The method specifies that the
  trap must be at  least 25 cm  long
  and have an  inside diameter of at
  least 0.105  in.

  The surrogates recommended are
  toIuene-d8,4-bromofluorobenzene.
  and l,2-dichloroethane-d4.  The
  recommended  concentration level is
  50 ug/1.

    Acid and base/neutral extracts
    are usually combined before
    analysis by GC/MS.  However,
    under  some situations, they may
    be extracted and analyzed
    separately.
The purge and trap equipment and
the desorber used were as specified
in SW-846.  The purge and trap
equipment is a Teckmar ISC-2 with
standard purging chambers (Supelco
cat. 2-0293).  The packing materials
for the traps were 1/3 silica gel
and 2/3 2,6-diphenylene.

The length of the trap was 30 cm
and the diameter was 0.105 cm.
                                                                                                                     The surrogates were added as
                                                                                                                     specified in SW-846.
Acid and base/neutral extracts
were combined.
                                                                            The base/neutral surrogates
                                                                            recommended are 2-fluorobiphenyl,
                                                                            nitrobenzene-dS, terphenyl-d!4.
                                                                            The acid surrogates recommended
                                                                            are 2-fluorophenol,
                                                                            2,4,6-tribromophenol, and
                                                                            phenol-d6.  Additional compounds
                                                                                                                           Surrogates were the same as those
                                                                                                                           recommended by SW-846.  The volume
                                                                                                                           of the surrogates added was
                                                                                                                           increased due to the sample matrix.
                                                                                                                           All samples except, the one sample
                                                                                                                           from Sample Point 10 had 3 ml of the
                                                                                                                           surrogates containing 100 ppm of the

-------
                                                                          Table E-3  (Continued)
 I
-o
               Ana lysis
                       SW-846 Method
Sample Al iquot
Alternatives or Equivalents Allowed
         by SW-846 Methods
Specific Procedures or
     Equipment Used
         Continuous L iqu id-
         Liquid Extract ion
         (Continued)
                                                                             may be used for surrogates   The
                                                                             recommended concentrations for
                                                                             low-medium concentration level
                                                                             samples are 100 ppm for acid
                                                                             surrogates and 200 ppm for
                                                                             base/neutral surrogates.   Volume
                                                                             of surrogate may be adjusted
                                                                        base  neutral  surrogate and 200 ppm
                                                                        of  the  acid surrogates added   To
                                                                        the one sample  from  Sample Point
                                                                        10, 10  ml of  the  surrogates were
                                                                        added.
tJ
V
ro
a
H-
X
a - Onsite Engineering Report of  Treatment  Technology Performance for E. I. duPont
    de Nemours, Inc., Beaumont, Texas.   Table  7-5.

-------
                                      Table  E-4  Special Procedures or Equipment Used for Analysis of Organic  Compounds  When
                                                 Alternatives or Equivalents are Allowed in  the  SW-846 Methods
     Analys is
SW-846
Method
Sample
Preparation
Method
Alternatives  or  Equivalents
   Allowed in SW-846  for
 fquipment or in Procedure
Specific Equipment  or  Procedures Used
                                                 Recommended GC/MS operating conditions
                                                                                       Actual GC/MS operating conditions.
  Gas Chro'tiatography/
    Mass Spectromet ry
    for volatile
    01 cjan ics
                             8240
                                     5030
3
I-1-
X

 I
co
                        E lectron enerqy
                        Mass range
                        Scan time

                        Initial  column temperature
                        Initial  column holding time
                        Column temperature piogram
                        Final column temperature
                        Final column holding time'
                        Injector temperature-
                        Source temperature

                        Transfer line temperature'
                        Carrier gas
                                           70 vols (nominal)
                                           35-260 amu
                                           To give 5 scans/peak  but
                                             not to exceed 7  sec/scan
                                           45'C
                                           3 mm
                                           8'C/m\n
                                           200"C
                                           15 mm
                                           200-225'C
                                           According to manufacturer's
                                           specification
                                           250-300'C
                                           Hydrogen at 50 cm/sec or
                                           hellum at 30 cm/sec
                                                 • The column should be 6-ft  x  0.1  in  1.0.  glass,
                                                   packed with I'/ SP-1000 on  Carbopaclj B (60/80 mesh) or
                                                   an equivalent

                                                 • Samples may be analyzed by purge and trap technique
                                                   or by direct injection
                                                    I lectron energy:
                                                    Mass  range-
                                                    Scan  time.

                                                    Initial column temperature:
                                                    Initial column  holding time:
                                                    Column  temperature program:
                                                    Final column  temperature:
                                                    Final column  holding  time:
                                                    Injector  temperature:
                                                    Source  temperature:
                                                    Transfer  line temperature:
                                                    Carrier gas:
                          70 ev
                          35 - 260 amu
                          2.5 sec/scan

                          38'C
                          2 mm
                          10'C/min
                          225'C
                          30 mm or xylene elutes
                          225'C
                          lOO'C
                          275'C
                          Helium * 30 ml/mm.
                                                                                      •Additional  Information  on  Actual  System Used
                                                                                         Equipment:   Finnegan  model  5100 6C/MS/OS  system
                                                                                         Data  system:   SUPER1NCOS Autoquan
                                                                                         Mode:  Electron  impact
                                                                                         N6S  library  available
                                                                                         Interface  to MS  -  Jet separator

                                                                                      •    The column used  was an 8-ft.  x 0  1  in.  1.0.  glass.
                                                                                           packed with  IX SP-1000 on Carbopack B  (60/80 mesh).

                                                                                      •    All samples  were analyzed using the purge and trap
                                                                                           technique.

-------
                                                                      Table E-4  (Continued)
      Analys is
SW-846
Method
Sample
Preparation
Method
Alternatives  or  Equivalents
   Allowed in SW-846  for
 Equipment or in Procedure
                                                                                                                         Specific  Equipment or Procedures Used
                                                  Recommended GC/MS operating  conditions
   Gas Chromatogrttph)/
     Mass Speci ro'iet ry
     for  semivolat i le
     organ ics  capi1 lai v
     column technique
  «270   3520-Liquids
tJ
•a
(D
3
a
             Mass range
             Scan time
             Initial  column  temperature
             Initial  column  holding time
             Column  temperature program-

             Final column temperature hold
                       Injector temperature
                       Transfer line temperature-
                       Source temperature.
                                                  In lector
                                                  Sample volume
                                                  Carrier gas.
                3b-500 amu
                1 sec/scan
                40'C
                4 mm
                40-270'C at
                ICTC/min
                270"C  (unt)l
                benzo[g,h.i,]perylene has
                eluted)
                250-300'C
                250-300"C
                According to
                manufacturer's
                specification
                Grob-type, split less
                1-2 uL
                Hydrogen at 50 cm/sec or
                helturn at 30 cm/sec
                                                    The column should be 30 m by 0 25 mm  I.D..  1-um film
                                                    thickness silicon-coated fused silica capillary column
                                                    (J6W Scientific DB-5 or equivalent).
Actual GC/MS operating conditions

Mass range:
Scan time:
Initial column temperature:
Initial column holding time:
Column temperature program:


Final column temperature hold
Injector temperature:
Transfer  line temperature
Source temperature:
Injector:
Sample volume
Carrier gas.
35 - 500 amu
1 sec/scan
30'C
4 mm
8'C/min to 275'
and 10'C/min until
305'C
305'C
240-260'C
300'C
Non-heated
Grob-type. spitless
1 uL of sample extract
Helium 9 40 cm/sec.
                                                                                      •Additional  Information on Actual  System Used
                                                                                         Equipment:  Finnegan model  5100  GC/MS/DS system
                                                                                         Software Package:   SUPER I NCOS AUTOQUAH

                                                                                         The column used was a 30  m  x 0 32 mm  I D.
                                                                                         RTx -5 (5% phenyl  methyl  silicone)  FSCC
  a  - Onsite Engineering  Report  of  Treatment  Technology  Performance  for  E.  I.  doPont
      de Nemours,  Inc., Beaumont, Texas.   Table  7-6.

-------
                Table E-5  Specific Procedures or Equipment  Used  for Analysis of
                           Cyanides When Alternatives or Equivalents are Allowed
                           in the  SW-846 Methods
Analysis
Total and
amenable
cyanide
SU-846 Sample
Method Aliquot
9012 500 ml
Alternatives or Equivalent
Allowed by SW-846 Methods
Hydrogen sulfide treatment
may be required.
Specific
Procedures Used
Hydrogen sulfide
treatment was not
requ i red .
                                     A Fisher-Mulligan absorber
                                     or equivalent should be used.
A Wheaton Distilling
Apparatus absorber was
used.
a - Onsite Engineering Report of Treatment Technology Performance for E. I. duPont
    de Nemours,  Inc.,  Beaumont, Texas.  Table 7-8.
                                     Appendix  E  -  10

-------
                                                      Table E-6  Matrix Spike Recoveries for Treated Waste
TJ

a
\->-
X
BOAT Constituent
Volatile
4 . Benzene
Semivolati le
56. Aniline
+ +
Original Amount Sample Set Sample Set Duplicate
Found Spike Added Spike Result Percent Spike Added Spike Result Percent Accuracy
(ug/L) (ug/L) (ug/L) Recovery* (ug/L) (ug/L) Recovery* Factor**

18 50 56 76 50 65 94 1.32

NO 200 194 97 200 182 91 1.10
101.  2,4-Dinitrophenol***


126.  Nitrobenzene


142.  Phenol

Inorganics
                    ++
169.  Total Cyanides
                                    129
                                                     200
                                                     200
                                                    100
                                                                   232
                                                                    63
                                                                  201
                                                                                    85
                                                                                   116
                                                                                    21
                                                                                  72
                                                                                                     200
200
                    229
                                                                                                                         51
                                                                                                                                          80
                                                                                                                                         115
                                                                                                                                          26
                                                                                                                                                               1.25
                                                                                                                                                               0.87
                                                                                                                                                               4.76
                                                                                                                                                               1.39
a =  From Onsite Engineering Report of Treatment Technology Performance for E. I. du Pont de Nemours, Inc., Beaumont,  Texas.  Tables 7-12 through 7-14.

 'Percent Recovery = [(Spike Result - Original Amount)/Spike Amount)] x 100.
"Accuracy Correction Factor = 100/(Percent Recovery), using the lower of the two percent recovery values.

 ND = Not detected.  Value assumed to be zero in calculation for percent recovery.

*** = The matrix spike recovery values presented for 2,4-Dinitrophenol are actually the average of the percent recoveries greater than 20% for all semivolatiles.

  + « For the matrix spike recoveries presented: Volatiles from Sample Set 3(even though this sample set was deleted from the final development of treatment standards,
      the matrix spike recoveries were not affected.), Semivolatiles from Sample Set 1, and Inorganics from Sample Set 4.
   = Total cyanides are regulated for K104 only.

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          The comparative method of measuring thermal
conductivity has been proposed as an ASTM test method under
the name "Guarded, Comparative, Longitudinal Heat Flow
Technique".  A thermal heat flow circuit is used which is
the analog of an electrical circuit with resistances in
series.  A reference material is chosen to have a thermal
conductivity close to that estimated for the sample.
Reference standards (also known as heat meters)  having the
same cross-sectional dimensions as the sample are placed
above and below the sample.   An upper heater, a lower
heater, and a heat sink are  added to the "stack" to complete
the heat flow circuit.   See  Figure 1.
                      Appendix F -  1

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GUARD
GRADIENT
STACK
GRADIENT"
               THERMOCOUPLE
                           UPPER
                             HEATER
     STACK
                                       CLAMP
  BOTTOM
REEER-ENCE
 SAMPLE
                            LOWER; STACK
                             HEATER
                           LIQUID
                            HEAT
     :OOLED
     SINK
             HEAT ELOW
             DIRECTION

^ — -
UPPER
GUARD
HEATER
X
K
/v

/
K


LOWER
GUARD
HEATER
      FIGURE 1  SCHEMATIC DIAGRAM OF THE COMPARATIVE METHOD

                          Appendix F - 2

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          The temperature gradients  (analogous to potential
differences) along the stack are measured with type K
(chromel/alumel) thermocouples placed at known separations.
The thermocouples are placed into holes or grooves in the
references and also in the sample whenever the sample is
thick enough to accommodate them.

          For molten samples, pastes, greases, and other
materials that must be contained, the material is placed
into a cell consisting of a top and bottom of Pyrex 7740 and
a containment ring of marinite.  The sample is 2 inch in
diameter and .5 inch thick.  Thermocouples are not placed
into the sample but rather the temperatures measured in the
Pyrex are extrapolated to give the temperature at the top
and bottom surfaces of the sample material.  The Pyrex disks
also serve as the thermal conductivity reference material.

          The stack is clamped with a reproducible load to
insure intimate contact between the components.  In order to
produce a linear flow of heat down the stack and reduce the
amount of heat that flows radially, a guard tube is placed
around the stack and the intervening space is filled with
insulating grains or powder.  The temperature gradient in
the guard is matched to that in the stack to further reduce
radial heat flow.

          The comparative method is a steady state method of
                                       V-
measuring thermal conductivity.  When equilibrium is reached
the heat flux (analogous to current flow)  down the stack can
be determined from the references.  The heat into the sample
is given by
                        Appendix F - 3              January 1988

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                          >WdT/dx)top
and the heat out of the sample is given by
                    Qout ~ xbottom(dT/dx) bottom
where
                    X = thermal conductivity
                dT/dx = temperature gradient
and top refers to the upper reference while bottom refers to
the lower reference.  If the heat was confined to flow just
down the stack, then Q^n and Qout would be equal.  If Q^n
and Qout are in reasonable agreement, the average heat flow
is calculated from
The sample thermal conductivity is then found from
                       Appendix F - 4
                         **                         January 1988

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                    ^sample = Q/(dT/dx)sample
          The result for the K102 Activated Charcoal Waste
tested here is given in Table 1.   The sample was held at an
average temperature of 42C with a 53C temperature drop
across the sample for approximately 20 hours before the
temperature profile became steady and the conductivity
measured.  At the conclusion of the test it appeared that
some "drying" of the sample had occurred.
                        Appendix F  -  5

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