&EPA
           United States
           Environmental Protection
           Agency
           Office of
           Solid Waste
           Washington, D C 20460
EPA/530-SW-88-0009-0
May 1988
           Solid Waste
Best
Demonstrated
Available Technology
(BOAT) Background
Document for
K001
Proposed
           Volume 16

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                         DRAFT REPORT
        BEST DEMONSTRATED AVAILABLE TECHNOLOGY  (BOAT)
                   BACKGROUND DOCUMENT FOR
                             K001
                  (WOOD PRESERVING INDUSTRY)
             U.S.  Environmental  Protection Agency
                    Office of Solid Waste
                      4.01  M Street,  S.W.
                   Washington, D.C.   20460
James R. Berlow, Chief                         Lisa  Jones
Treatment Technology Section                   Project  Manager
                           May 1988


                                                 "•""""tnl  Protection
                                                                   670

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                     BOAT Background Document for K001
                             Table of Contents
Volume 16
ExeC'it i VP Summary 	
1.
1.1


1.2































1.3
Introduction 	
Legal Background 	
1.1.1 Requirements Under HSWA 	
1.1.2 Schedule for Developing Restrictions 	
Summary of Promulgated BOAT Methodology 	
1.2.1 Waste Treatability Groups 	
1.2.2 Demonstrated and Available Treatment
Technologies 	
(1) Proprietary or Patented Processes 	
(2) Substantial Treatment 	
1.2.3 Collection of Performance Data 	
(1) Identification of Facilities for
Site Visits 	
(2) Engineering Site Visit 	
(3) Sampling and Analysis Plan 	
(4) Sampling Visit 	
(5) Onsite Engineering Report 	
1.2.4 Hazardous Constituents Considered and
Selected for Regulation 	
( 1 ) Devel opment of BOAT Li st 	
(2) Constituent Selection Analysis 	
(3) Calculation of Standards 	
1.2.5 Compliance with Performance Standards 	
1.2.6 Identification of BOAT 	
(1) Screening of Treatment Data 	
(2) Comparison of Treatment Data 	
(3) Quality Assurance/Quality Control 	
1.2.7 BOAT Treatment Standards for "Derived From"
and "Mixed" Wastes 	
(1) Wastes from Treatment Trains
Generating Multiple Residues 	
(2) Mixtures and Other Derived From
Residues 	
(3) Residues from Managing Listed Wastes
or that Contain Listed Wastes 	
1.2.8 Transfer of Treatment Standards 	
Variance from the BOAT Treatment Standard 	

1
1
4
5
7

7
10
10
11

12
14
14
16
17

17
17
27
29
30
32
32
33
34

36

36

37

38
40
41

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                       Table of Contents (continued)
2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 	     46
2.1    Industry Affected and Process Description 	     46
2.2    Waste Characterization 	     51

3.   APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES	     56
3.1    Applicable Treatment Technologies 	     56
3.2    Demonstrated Treatment Technologies 	     59
       3.2.1  Incineration 	     60
       3.2.2  Fuel Substitution 	     79
       3.2.3  Stabilization of Metals 	     95
       3.2.4  Chemical Precipitation 	    102
       3.2.5  Sludge Filtration 	    114
3.3    Performance Data	    118
       3.3.1  BOAT List Organics Treatment Data 	    118
       3.3.2  BOAT List Metals Treatment Data 	    118

4.   IDENTIFICATION OF THE BEST DEMONSTRATED AVAILABLE
    TECHNOLOGY (BOAT) FOR K001 	    149
4.1    Review of Performance Data 	    150
4.2    Accuracy Correction of Performance Data 	    152
4.3    BOAT for Treatment of Organics 	    153
4.4    BOAT for Treatment of Metals 	    154

5.   SELECTION OF REGULATED CONSTITUENTS 	    156
5.1    BOAT List Constituents Detected in Untreated K001 Waste    156
5.2    BOAT List Constituents Detected in Treated Waste 	    164
5.3    Selection of Regulated Constituents	    171

6.   CALCULATION OF BOAT TREATMENT STANDARDS 	    172
6.1    Editing the Data 	    172
       6.1.1  BOAT List Organics Treatment 	    172
       6.1.2  BOAT List Metals Treatment 	    173
6.2    Correction of Analytical Data 	    174
       6.2.1  Correction of BOAT List Organics Data	    175
       6.2.2  Correction of BOAT List Metals Data 	    176
6.3    Calculation of Variability Factors	    180
6.4    Calculation of Treatment Standards 	    180

REFERENCES  	    182

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                       Table of Contents (continued)
APPENDICES ....
    Appendix A

    Appendix B
    Appendix C
    Appendix D

    Appendix E
Analysis of Variance Test and Variability
Factor Calculation 	
Analytical Methods and QA/QC 	
Concentration/Boiling Point/Bond
Dissociation Energy Ranking for BOAT List
Volatiles/Semivolatiles in K001 	
Analytical Method for Determining Thermal
Conductivity of a Waste 	
Calculations of Treatment Standards 	
                                                                 Page
187
200
214

216
220

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                             EXECUTIVE SUMMARY
                     BOAT Treatment Standards for K001

    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 waste K001,  based
on the performance of treatment technologies determined by the Agency to
represent Best Demonstrated Available Technology (BOAT).  According to
40 CFR 261.32 waste code K001 is defined as "bottom sediment sludge from
the treatment of wastewaters from wood preserving processes that use
creosote and/or pentachlorophenol."
    These BOAT treatment standards represent instantaneous maximum
acceptable concentration levels for disposal of these wastes in units
designated as land disposal units according to 40 CFR Part 268.  Wastes
that, 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  approach allows the generators of these wastes
a greater degree of flexibility in selecting a technology or train of
technologies that can achieve these  levels.  The proposed effective date
is August 8,  1988.

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    BOAT treatment standards for nonwastewater K001 wastes are proposed
based on performance data of rotary kiln incineration with stabilization
of the nonwastewater residual.  For the wastewater residual
(i.e., scrubber water), the standard is based on the performance of a
treatment train consisting of chemical  precipitation and sludge
filtration.  Section 3 describes all applicable treatment technologies
and presents treatment performance data which the Agency considered when
developing the K001 treatment standards.
    Treatment standards have been proposed for a total of six organic
constituents and three metals;  the Agency believes that these
constituents are indicators of effective treatment for all of the BOAT
list constituents that have been identified as being present in K001
wastes.  The BOAT list organic constituents that are proposed for
regulation are naphthalene, pentachlorophenol, phenanthrene, pyrene,
toluene, and xylenes (total).  The BOAT list metals that are proposed for
regulation are copper, lead, and zinc.   The Agency has recently become
aware of data showing that dioxins and furans may be present in some wood
preserving wastes.  EPA has not had an ample opportunity to evaluate
these data.  When the Agency completes its analysis of available data, it
will consider the regulation of these constituents.  A detailed
discussion of the selection of regulated constituents is presented  in
Section 5 of this document.

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    The following tables list the specific BOAT treatment standards for
K001 wastes.  The Agency is proposing standards based on the analysis of
total concentration for organic constituents and based on the analysis of
TCLP extracts from K001 nonwastewaters.  Standards are based on analysis
of total concentration for K001 wastewaters.  The units for total
constituent concentration are in parts per million (mg/kg) on a weight by
weight basis for nonwastewaters.  The units for TCLP extract analysis are
in parts per million (mg/1) on a weight by volume basis.

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1897g

                                  BOAT  TREATMENT  STANDARDS FOR K001

                                            Nonwastewater



Regulated Constituent        Total Concentration (mg/kg)        TCLP Concentration (mg/1)
Naphthalene
Pentachlorophenol
Phenanthrene
Pyrene
Toluene
Xylenes (total)
Copper
Lead
Zinc
7 98
36 75
7.98
7.28
0.143
0 162
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.71
0.53
0.086
NA = Not Applicable
                                             Wastewater
Regulated Constituent        Total Concentration (mg/1)          TCLP Concentration (mg/1)
Naphthalene                               0 148                        NA
Pentachlorophenol                         0 875                        NA
Pnenanthrene                              0 148                        NA
Pyrene                                    0 140                        NA
Toluene                                   0 143                        NA
Xylenes (total)                           0.161                        NA
Copper                                    0 42                         NA
Lead                                      0.037                        NA
Zinc                                      1.0                          NA
NA = Not applicable

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                              1.   INTRODUCTION
    This section of the background document presents a summary of the
legal authority pursuant to which the BOAT 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 BOAT treatment standards.
1.1      Legal Background
1.1.1    Requirements Under HSWA
    The Hazardous and Solid Waste Amendments of 1984 (HSWA), which were
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)).
    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)(l), (e)(l), (g)(5),
42 U.S.C. 6924 (d)(l), (e)(l), (g)(5)).

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    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 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.

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    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 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

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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.
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:
    1.   Solvents and dioxins standards must be promulgated by
         November 8, 1986;
    2.   The "California List" must be promulgated by July 8, 1987;
    3.   At least one-third of all listed hazardous wastes must be
         promulgated by August 8, 1988 (First Third);
    4.   At least two-thirds of all listed hazardous wastes must be
         promulgated by June 8, 1989  (Second Third); and
    5.   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).

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    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., 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,  268.11, and 268.12.
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.

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    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 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 section 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 BOAT  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

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flexibility to develop and implement compliance 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 and must be available for use.



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 affec.t 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

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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 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 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 to be 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.

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    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 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

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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) 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 a
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
                                     10

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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 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 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:
    •  Number and types of constituents treated;
    •  Performance (concentration of the constituents in the
       treatment residuals); and
    •  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
                                     11

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of well-designed and well-operated treatment systems.  Only data from
well-designed and well-operated systems 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:  (1) identifi-
cation of facilities for site visits,  (2) an engineering site visit,
(3) a Sampling and Analysis Plan,  (4)  a sampling visit, and (5) an 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  their 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  treatment, storage,  and  disposal  facilities
                                     12

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(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 in the preamble and background document why such
data were used 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 be visited  and later sampled if
justified by the engineering visit.
                                     13

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    (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 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
                                     14

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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 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.
                                     15

-------
    (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 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 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.
                                     16

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



Edition, November 1986).



    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,



Appendices VII and  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.
                                     17

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1521g
                     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
Acetomtri le
Acrolein
Acrylonitri le
Benzene
Bromodichloromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro- 1,3 -butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 , 2-Dibromo-3-chloropropane
1,2-Dibromoethane
Dibromomethane
Trans-1 ,4-Dichloro-2-butene
Dichlorodif luoromethane
1 , 1-Di Chloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
Trans-1 ,2-Dichloroethene
1 ,2-Dichloropropane
Trans-1 ,3-Dichloropropene
cis-1 ,3-Dichloropropene
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
107-02-8
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
110-80-5
141-78-6
100-41-4
107-12-0
60-29-7
97-63-2
75-21-8
74-88-4
                                 18

-------
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
Volat i les (continued)
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methacry lonitri le
Methylene chloride
2-Nitropropane
Pyridine
1 , 1 ,1,2-Tetrachloroethane
1 ,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Trichloroethane
1, 1 ,2-Trichloroethane
Trichloroethene
Trichloromonof Iuoromethane
1 ,2,3-Trichloropropane
l,l,2-Trichloro-l,2,2-trif luoro-
ethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1 ,4-Xylene
Semivolat i les
Acenaphthalene
Acenaphthene
Acetophenone
2 - Acetyl am inof luorene
4-Aminobiphenyl
Am line
Anthracene
Aramite
Benz(a)anthracene
Benzal chlorioe
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
                               19

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

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
Semwolat i les (continued)
Benzo(b)f luoranthene
Benzo(ghi Jperylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl ) ether
Bis(2-chloroisopropy 1) ether
Bis(2-ethylhexyl)phthalate
4-Bromophen> 1 phenyl ether
Butyl benzyl phthalate
2- sec -Butyl -4 , 6-dimtrophenol
p-Chloroam 1 me
Chlorobenz i late
p-Chloro-m-cresol
2-Chloronapnthalene
2-Chlorophenol
3-Chloropropionitr i le
Chrysene
ortho-Creso1
para-Cresol
Cyclohexanone
D i benz ( a, h) anthracene
Dibenzo(a,e)pyrene
Dibenzo(a , i )pyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3 ,3 '-Dichlorooenz id me
2 , 4-Dichlorophenol
2,6-Dichlorophenol
Di ethyl phthalate
3,3' -Dimethoxybenz id me
p- Dimethyl am moazobenzene
3,3 '-Dimethyl benz id me
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl pnthalate
1,4-DmitroDenzene
4,6-Dmitro-o-cresol
2,4-Dmitropnenol
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
131-11-3
84-74-2
100-25-4
534-52-1
51-26-5
                                 20

-------
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
Semivolat i les (continued)
2 ,4-Dinitrotoluene
2 ,6-Dini trotoluene
Di-n-octyl phthalate
D i -n-propy 1 n i t rosami ne
Diphenylamine
D ipheny In it rosami ne
1 ,2-Diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyc lopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
lndeno(l ,2,3-cd)pyrene
Isosafrole
Methapyri lene
3-Methylcholanthrene
4 ,4'-Methylenebis
(2-chloroam 1 me)
Methyl methanesulfonate
Naphthalene
1 ,4-Naphthoqumone
1-Naphthylamme
2-Naphthylamme
p-Nitroam 1 me
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamme
N-Nitrosodiethylamme
N-Nitrosodimethylamme
N-Nitrosomethy lethy lam me
N-Nitrosomorphol me
N-Nitrosopiperidme
n-Nitrosopyrrol id me
5-Nitro-o-toluidme
Pentachlorobenzene
Pen tachloroe thane
Pentachloronltrobenzene
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
930-55-2
99-65-8
608-93-5
76-01-7
82-68-8
                                  21

-------
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
Seroivolat i les (continued)
Pentachlorophenol
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcinol
Safrole
1 ,2, 4, 5-Tetrachlorobenzene
2,3,4, 6-Tet rachloropheno 1
1,2,4-Tnchlorobenzene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Tns(2,3-dibromopropyl)
"phosphate
Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Si Tver
Thai 1 lum
Vanadium
Zinc
Inorganics other than metals
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
7440-66-6

57-12-5
16964-48-8
8496-25-8
                                22

-------
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
Orqanochlonne pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxyacet ic acid
Si Ivex
2,4,5-T
Orqanophosphorous 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
72-20-8
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

12674-11-2
11104-28-2
11141-16-5
                                   23

-------
1521g
                          Table 1-1  (continued)
BOAT
reference          Parameter                             CAS no.
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
                                    24

-------
    The initial BOAT constituent list was published in EPA's Generic



Quality Assurance Project Plan, March 1987 (EPA/530-SW-87-011).



Additional constituents will be added to the BOAT constituent list as



more 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, 18 additional



constituents (hexavalent chromium, xylenes (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, l,l,2-trichloro-l,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 could not be readily analyzed



in an unknown  waste matrix were not included on the initial BOAT list.



As mentioned above, however, the BOAT constituent list is a continuously



growing list that does not preclude the addition of new constituents when



analytical methods are developed.
                                     25

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    There are five major reasons that constituents were not included on

the BOAT constituent list:

    1.   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.

    2.   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.

    3.   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 BOAT
         constituent  list.

    4.   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 chromatography  (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
         unknown  constituents.

     5.   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.
                                     26

-------
    Two constituents (fluoride and sulfide) are not specifically included

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

BOAT list as indicator constituents for compounds from Appendices VII and

VIII such as hydrogen fluoride and hydrogen sulfide, which ionize in

water.

    The BOAT constituent list presented in Table 1-1 is divided into the

following nine groups:

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

The constituents were placed in these categories based on their chemical

properties.  The constituents  in each group are expected to behave

similarly during treatment and are also analyzed, with the exception of

the metals and inorganics, by  using the same analytical methods.

    (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 that the constituent

will  be present.
                                     27

-------
    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, resulting in  a finding of "not detected"
when, in fact, the constituent is present in the waste.
    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.
                                     28

-------
    (3)  Calculation of standards.  The final step in the calculation of
the BOAT 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 a relaxing of section 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
                                     29

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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.
1.2.5    Compliance with Performance Standards
    All the treatment standards reflect performance achieved by the best
demonstrated available technology (BOAT).  As such, compliance with these
standards requires only  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
                                     30

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various organics compounds.  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:  EPA's land disposal restrictions for solvent waste codes
F001-F005 (51 FR 40572} use 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 Teachable; 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 disposal.
                                     31

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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:
    1.   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.)
    2.   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.
    3.   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).
    In the absence of data needed to perform the screening analysis, EPA
will make decisions on a case-by-case basis as to whether to include the
data.  The factors included in this case-by-case analysis will be the
                                     32

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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 is 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 than
the others.  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.
    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 whether  BOAT 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
                                     33

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acceptable technologies.  A detailed discussion of the treatment
selection method and an example of how EPA chooses BOAT from multiple
treatment systems is provided in Section A-l.
    (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 BOAT program are presented in EPA's Generic
Quality Assurance Project Plan for Land Disposal  Restrictions Program
("BOAT") (EPA/530-SW-87-011, 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 residual.  Once the recovery value is determined,
the following procedures are used to select the appropriate percent
recovery value to adjust the analytical data:
    1.   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.
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    2.    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 (1)  above.

    3.    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.

    4.    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 data to be transferred, the procedures outlined in (1),
         (2), and (3) above are followed.

    The analytical procedures employed to generate the data used to

calculate the treatment standards are listed in Appendix B 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 B to enforce the treatment
                                     35

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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 BOAT consists of a series of
operations, each of which generates a waste residue.  For example, the
proposed BOAT for 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 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:
    1.   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.
    2.   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
                                     36

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         to meet the treatment standard for nonwastewaters.   All
         derived-from wastes meeting the Agency definition of wastewater
         (less than 1 percent TOC 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.

    3.    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.

    (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
                                     37

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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 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
                                     38

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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 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 that



address 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.  Consequently, these residues 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.
                                     39

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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 technically valid in cases where the untested wastes
are generated from similar industries, have 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 a case where only the industry is similar, EPA more closely examines
the waste characteristics prior to deciding whether 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 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 Section 5 of this document.
                                    40

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    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 BDAT 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 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
                                     41

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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.

    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:
                                     42

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 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.

 5.   A  description of the waste sufficient for  comparison with the
     waste  considered by the Agency in developing BOAT, 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  BOAT 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 BOAT 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 BOAT.)

 9.    The dates  of  the sampling  and  testing.  •

10.    A  description of the methodologies  and  equipment used to  obtain
      representative  samples.
                                 43

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   11.    A description of the sample handling and preparation techniques,
         including techniques used for extraction,  containerization,  and
         preservation of the samples.
   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 BOAT 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 BOAT 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 for 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.
                                     44

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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.
                                     45

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             2.   INDUSTRIES  AFFECTED  AND  WASTE  CHARACTERIZATION
    The previous section discussed the BOAT program and the methodology
used by the Agency to develop treatment standards.  The purpose of this
section is to describe the industry affected by the land disposal
restrictions for K001 waste, the process generating the waste, and the
available waste characterization data.
    According to 40 CFR Part 261.32 (hazardous wastes from specific
sources), the waste identified as K001 is specifically generated from the
treatment of wastewaters from wood preserving processes that use creosote
and/or pentachlorophenol.   For the purpose of BOAT determination, the
Agency has determined that K001 wastes generated from the use of creosote
or pentachlorophenol  based wood preservatives are similar and represent
one treatability group.
2.1    Industry Affected and Process Description
    The listed waste K001  is generated in the wood preserving industry.
The four digit Standard Industrial Classification (SIC) code most often
reported for the wood preserving industry is 2491.  The Agency estimates
that at least 400 facilities have wood preserving processes that could
potentially generate K001  waste.  Table 2-1 lists the number of
facilities by State.   Table 2-2 summarizes the number of facilities for
each EPA Region.  Figure 2-1 illustrates these data geographically on a
map of the United States.
    The preservation of wood using creosote and/or pentachlorophenol
generates wastewaters containing hazardous constituents present in the
preservatives.  This process is illustrated in Figure 2-2.  Creosote is a
                                     46

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1711g/p 33
         Table 2-1   Number of  Wood  Preserving  Facilities by State*
State
AL (IV)
AK (X)
AZ (IX)
AR (VI)
CA (IX)
CO (VIII)
CT (1)
DE (III)
DC (III)
FL (IV)
GA (IV)
HI (IX)
ID (X)
IL (V)
IN (V)
IA (VII)
KS (VII)
KY (IV)
LA (VI)
ME (I)
MD (III)
MA (I)
MI (V)
MN (V)
MS (IV)
MO (VII)
Facil it les
29


17
31




25
30


11
13


12
21




12
27
22
State Facilities
MT (VI11)
NE (VII)
NV (IX)
NH (I)
NJ (II)
NM (VI)
NY (II)
NC(IV) 29
ND (VIII)
OH (V) 11
OK (VI)
OR (X) 12
PA (III) 16
RI (I)
SC (IV) 11
SD (VIII)
TN (IV) 7
TX (VI) 33
UT (VIII)
VT (I)
VA (III) 17
WA (X) 22
WV (III) 8
WI (V) 11
WY (VIII)

   Includes data for SIC code 2491 only.
   Reference.  1982 Census of Manufactures
                                   47

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1711g/p 34
      Table 2-2  Number of Wood Preserving Facilities by EPA Region*
   EPA Region                              Totals
      I
      II
      III                                   41
      IV                                   170
      V                                      58
      VI                                    81
      VII                                   22
      VIII
      IX                                    31
      X                                     _3£

                                           437
^Includes data for SIC code 2491 only.
Reference.  1982 Census of Manufactures.
                                   48

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                                                                            MA
                                                               yaffj
FIGURE  2-1.  WOOD PRESERVING FACILITIES BY STATE AND EPA REGION

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        TREATMENT  CHEMICALS
          (CREOSOTE/AND  OR
        PENTACHLOROPHENOL)
WOOD
TREATMENT
  VESSEL
                                 VAPOR
                           DRIPPINGS AND
                                               CONDENSER
                                                                 ACCUMULATOR
                            CONDENSATE
                            RECYCLE
                          PRESERVATIVES
                                   PRIMARY
                                  OIL-WATER
                                 SEPARATOR
            PRESERVATIVE
             WORK TANK
                                              WASTEWATER
                                               TREATMENT
                                                             WATER
                                                     TREATMENT
                                                      SLUDGES
                                                                  K001
                 FIGURE 2-2.  WOOD  PRESERVING  PROCESS

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derivative of coal containing a wide range of constituents including,
cresols, phenol, 2,4-dimethylphenol, naphthalene, benz(a) anthracene,
benzo(a)pyrene, fluoranthene, benzo(b)fluoranthene, chrysene,
benzo(a,h)anthracene, indeno(l,2,3-cd)pyrene, and acenaphthalene.  The
treatment by any means (including simple settling) of these wastewaters
generates the listed waste K001.
    The wood preserving process consists of two steps: (1) pretreatment
of the wood to reduce its natural moisture content, and  (2) impregnation
of the wood with preservatives  including creosote and/or
pentachlorophenol.  These agents are added to wood to increase its
resistance to natural decay, attack by insects, and microorganisms.
Drippings and condensed vapors  generated during preservation treatment
are sent to the oil-water separator.  In the oil-water separator, wood
treatment chemicals are recovered and recycled back to the preserving
process.  The wastewater, contaminated with components of creosote,
pentachlorophenol, and/or other related compounds, is pumped to
wastewater treatment.  The treatment residual generated  is the listed
waste K001.
2.2    Waste Characterization
    This section  includes all waste characterization data available to
the Agency for K001.  An estimate of the major constituents that comprise
the waste and their approximate concentrations is presented in
Table 2-3.  The percent concentration of each major constituent  in the
waste was determined by best estimates based on chemical analyses of K001
wastes from wood preservation using creosote and from pentachlorophenol
                                     51

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1711g/p.32
                 Table 2-3  Major Constituent Composition*

                            Untreated K001 Waste
Major Constituents                       Concentration (%)
Soil                                            35
BOAT List Organic Constituents
  Naphthalene                                    4 o
  Phenanthrene                                   3.5
  Fluoranthene                                   2 0
  Acenaphthene                                   2.0
  Pyrene                                         1.5
  Fluorene                                       1.5
  Anthracene                                     1 0
  Pentachlorophenol                             <1.0
  Others                                         8.5
Water                                           20
Other Organic Compounds                         14
Wood Chips                                       5
BOAT List Metals                                <1

                                              100%
* Percent concentrations presented here were determined from engineering
judgment based on chemical analyses.
                                  52

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based treatment chemicals.  The Agency has obtained compositional  data
from its own testing program and from numerous literature sources.  The
ranges of BOAT list constituents present in the wastes and other
available data are presented in Table 2-4.
    These data indicate the various BOAT list organic constituents
present in K001 waste.  These data display the wide ranges of
concentrations of hazardous organics that may be present in the wastes.
Such variations may be attributed to the type of preservative chemicals
used and the type of wastewater treatment systems used.  Generally, these
K001 wastes contain numerous polynuclear aromatic compounds and
chlorinated phenolics present in the wood preservatives.  No
characterization data identified in the literature for K001 had values
for BOAT list metals.  The BOAT list metals detected in samples of K001
waste collected by the Agency are presented in Section 3 of this
document.
    Analyses for dioxins  and furans were performed by the Agency on K001
wastes collected for developing treatment standards.  These compounds
were not detected in any  of the nine samples analyzed.  The Agency has
recently become aware of  waste characterization data for wood preserving
wastes showing that dioxins and furans may be present.  The Agency is
currently evaluating these data.
                                     53

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                                                Table 2-4   BOAT  List  Constituent Composition
Untreated K001 Waste Total Composition (ppm)
BOAT Constituent Source of Data (a)
Acenaphthene
Anthracene 8,410
Chrysene
Fluoranthene 5,090
Naphthalene 43,640
Pyrene 604
Phenanthrene 8,410
Pentachloropheriol 1 84
2,4-dichlorophenol 1,650
p-chloro-m-cresol 1,690
2,4-dimethyl phenol
Benzo[g,h,i] perylene
Fluorene
Dibez[a,h] anthracene
Benz[a] anthracene
Benzo[a] pyrene
Phenol
2-Chlorophenol
2,4, 6-trichlorophenol
Benzo(b and/or k) f luoranthrene
(b)
3,000
-
45
1,400
1,200
52
3,200
-
-
-
8.2
84
1,400
-
-
-
-
-
-
~
(c) (d) (e) (f)
15.000-21.000
7,300-15.000
9.29 4 5 2.1 4,100-4,800
BDL
29,000-43.000
12,000-17,000
28,000-42.000
4 8 302 58 BDL
BDL
BDL
44 3.4 BDL
BDL
12,000-18.000
0.052 - - BDL
1.25 37 0.149 BDL
5 98 - - BDL
4.5 90 16 2,400-3,900
0 30 39 1.2 BDL
25 BDL
BDL
(g)
13,000-18,000
8,500-13,000
<2, 500-3. 400
13,000-21.000
26,000-43,000
9.200-15.000
28,000-43,000
920-3,000
BDL
BDL
BDL
BDL
8,200-12,000
BDL
<2, 500-3, 400
<250-340
BDL
BDL
BDL
940-2,300
    = No Data
BDL  = Below Detection Limit
(a)  Reference -  RCRA Background Listing  Document  for K001
{b)  Reference -  RCRA Background Listing  Document  for K001
(c)  Reference -  Myers 1979
(d)  Reference -  Myers 1979
(e)  Reference -  Myers 1979
(f)  Reference -  Onsite Engineering Report  for  KOOl-Creosote
(g)  Reference -  Onsite Engineering Report  for  KOOl-Pentachlorophenol

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        1711g/p.30
                                                       Table /-4  BOAT List Constituent Composition (continued)
        BOAT  Constituent    Source of Data
                                     (n)
                                                        Untreated K001 Waste Total Composition (ppm)
                                (k)
                                            (m)
                  (n)
     (o)
Ul
Ul
Acenaphthene
Anthracene
Chrysene
Fluoranthene
Naphthalene
Pyrene
Phenanthrene
Pentachlorophenol
2,4-dichlorophenol
p-chloro-m-cresol
2,4-dimethyl phenol
Benzo[g,h,i] perylene
Fluorene
D1bez[a,h] anthracene
Benzfa]  anthracene
Benzo[a] pyrene
Phenol
2-Chlorophenol
2,4,6-trichlorophenol
2,4-Dinitrophenol
"Creosote"
                                          20,000
                                  50,000-200,000
10,000
                                                         10,000
                                                                                      1-170
0 034
                  5 043
                                                                           0.024
                                                                          10
                                                                                          3.5-900
                                             1.7-150
                                             0.17-440
                                 0.93-560

                                 0.014-0 37   1-260
55-1,500
     165
       0 17
                                              <5.0
                                                                                                                          2.5
                                                                                                                                   0 18-30
20,000-50,000
                0.45-1 6
                0 12-39 6

                0 3-0.8
           = No Data
       BDL = Below Detection Limit
        (h) Reference - USEPA 1980
        (1) Reference - DPRA 1984
        (j) Reference - Myers 1979
        (k) Reference - K.W. Brown 1981
        (1) Reference - Acurex 1982
        (m) Reference - Acurex 1982
        (n) Reference - Mitre 1981
        (o) Reference - Illinois EPA 1983

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             3.  APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
    In the previous section there was a discussion of the industries
generating K001 and the untreated waste composition.   This section
describes the applicable treatment technologies,  demonstrated treatment
technologies, and available performance data for K001.  The Agency
identified applicable treatment technologies based on available waste
composition data, contacts with industry,  and technical publications.
The technologies considered to be applicable to the untreated waste are
those that treat hazardous organic compounds by reducing their
concentration.  Additionally, treatment residuals (wastewater and
nonwastewater) are expected to contain metals in treatable
concentrations.  Treatment technologies applicable to reducing the
concentration  and/or Teachability of metals  in these  residuals were also
identified.   Included  in this section  are discussions of those treatment
technologies  that  have  been demonstrated on  a commercial basis.
Treatment  performance  data collected by the  Agency for these demonstrated
technologies  are also  presented.
3.1       Applicable  Treatment Technologies
    The  chemical composition  of  K001 waste most directly  affects  the
technologies applicable to the waste.  As  shown in Section  2,  the waste
primarily contains high concentrations of  BOAT list  organic constituents,
high  filterable  solids content,  moderate water content,  and BOAT  list
metals  at concentrations below one  percent.   Treatment  technologies are
needed  for treatment of both  BOAT list organics and  BOAT list  metals.
                                     56

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    For BOAT list organics, the Agency has identified treatment
technologies that may be applicable to K001 because the technologies are
designed to treat organic constituents in high filterable solids
matrices.  The technologies applicable to K001 are those that destroy or
remove the organics present in the untreated waste.
    The Agency has identified the following treatment technologies as
being applicable to BOAT list organic constituents in K001:  incineration
and fuel substitution.  Incineration is a destruction technology that
destroys organic constituents in wastes.  Fuel substitution, like
incineration, destroys the organic constituents of a waste while deriving
a fuel value from the waste.
    The goal of incineration is to thermally destroy (oxidize) the
organic constituents of a waste.  Typically, the types of incineration
systems that are demonstrated on wastes include fluidized bed, rotary
kiln, fixed hearth, and liquid injection.  The Agency believes that the
performance of rotary kiln incineration adequately represents the
performance achievable by other thermal destruction technologies
(including fuel substitution) that are well designed and well operated,
and can handle sludges of this type.  Rotary kiln incineration systems
are designed specifically to handle sludges, solids, tarry wastes, and
containerized liquids that are difficult to atomize through a liquid
injector.  Many rotary kiln incinerators are also designed to
simultaneously incinerate other liquid wastes or supplemental fuel.
                                     57

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    The Agency believes that solvent extraction may be applicable to K001



waste;  however, EPA has not identified any facilities using solvent



extraction on K001 or a similar waste.   The Agency does not currently



have sufficient information on waste parameters that affect treatment



selection for solvent extraction to suggest that this technology is



applicable for wastes similar to K001,  accordingly, EPA does not consider



solvent extraction to be an applicable technology.



    Incineration technologies generally result in the formation of two



treatment residuals:  ash and scrubber water.   For the BOAT list metals



present in the wastewater residual  (i.e.,  scrubber water), the applicable



treatment technologies are chemical precipitation and filtration.



Chemical precipitation removes dissolved metals from solution, and



filtration removes suspended solids that result from the use of an



underdesigned clarifier or from the generation of precipitates that do



not settle easily.  The filter cake generated  from filtration contains



BOAT list metals and requires stabilization before land disposal.



    For the BOAT list metals present in the nonwastewater residuals



(wastewater treatment filter cake and ash), the applicable treatment



technologies are high temperature metals recovery and stabilization.



High temperature metals recovery provides for  recovery of metals from



wastes primarily by volatilization of metals and subsequent condensation



and collection steps.  The process yields a metal product for reuse and



reduces the amount of waste that requires land disposal.  Stabilization
                                     58

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is designed to chemically and physically bind metal constituents of the
waste into the microstructure of a cementitious matrix and thereby reduce
their leaching potential.  A variety of reagents, including Portland
cements, cement kiln dust, hydrated limes, quick lime, fly ash, and other
pozzalanic materials, have been demonstrated to act as binding reagents
for various types of wastes containing metals.
3.2      Demonstrated Treatment Technologies
    Of the two applicable technologies for BOAT list organic
constituents, the Agency believes that rotary kiln incineration is
demonstrated to treat K001 since it is being used to treat wastes similar
to K001 with regard to parameters affecting treatment selection,
including high concentrations of BOAT list organics and high filterable
solids content.  Fuel substitution is also demonstrated on K001 because
it is demonstrated on similar wastes with regard to parameters affecting
treatment selection.  Performance data for rotary kiln incineration of
K001 are presented in Tables 3-1 to 3-9, in Section 3.3 following the
demonstrated treatment technology descriptions.
    For K001 wastewaters, the Agency believes that chemical precipitation
and filtration are demonstrated because they are demonstrated on similar
wastewater streams containing BOAT list metals.  Treatment performance
data for BOAT list metal constituents in wastewater treatment residuals
from incineration of K001 are presented in Table 3-14 in Section 3.3,
following the descriptions of the demonstrated treatment technologies.
                                     59

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    For BOAT list metals treatment, EPA believes that stabilization is
demonstrated to treat K001 nonwastewater treatment residuals because it
is being used to treat similar wastes with regard to parameters affecting
treatment selection.  The Agency does not believe that high temperature
metals recovery is demonstrated on K001 waste residuals because it is not
demonstrated specifically on K001 residuals or on similar wastes.
Specifically, at this time, EPA does not have treatment performance data
for high temperature metals recovery of K001 filter cake, incinerator
ash, or other wastes having similar types and concentrations of BOAT list
metal  constituents.  Treatment performance data for stabilization  of
filter cake or incinerator ash from incineration of K001 are presented in
Tables 3-15 through 3-17.
3.2.1     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
       (a) Liquid Injection.  Liquid injection is applicable to wastes
that have viscosity values sufficiently low so that the waste can  be
                                     60

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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.
       (b) 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
       (a) 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
                                     61

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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.
       (b) Rotary Kiln and Fixed Hearth.  There are two distinct
principles of operation for these incineration technologies, one for each
of the chambers involved.  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.
        (c) Fluidized Bed.  The principle of operation for this
incinerator technology  is somewhat different than  for rotary kiln and
fixed hearth  incineration, in that there is only one chamber which
contains  the  fluidizing  sand and  a freeboard section above  the  sand.  The
purpose of the  fluidized  bed is to both volatilize the waste and combust
the  waste.  Destruction  of the waste organics  can  be accomplished to  a
better  degree in this  chamber  than  in the  primary  chamber of the 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
                                     62

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fluidization process provides sufficient oxygen and turbulence to convert



the organics to carbon dioxide and water vapor.  The freeboard generally



does not have an afterburner;  however, additional  time is provided for



conversion of the organic constituents to carbon dioxide,  water vapor,



and hydrochloric acid if chlorine is present in the waste.



    (3) Description of Incineration Technologies



       (a) 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 3-1



illustrates a liquid injection incineration system.



       (b) Rotary Kiln.  A rotary kiln is a slowly rotating,



refractory-lined cylinder that is mounted at a slight incline from the



horizontal (see Figure 3-2).  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
                                     63

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                                                                    WATER
    AUXILIARY FUEL
 BURNER
                       AIR-
LIQUID OR  GASEOUS.
  WASTE  INJECTION
»| BURNER
              PRIMARY
            COMBUSTION
              CHAMBER
AFTERBURNER
 (SECONDARY
 COMBUSTION
  CHAMBER)
 SPRAY
CHAMBER
                                                                                     GAS TO AIR
                                                                                     POLLUTION
                                                                                     CONTROL
                             HORIZONTALLY  FIRED
                             LIQUID INJECTION
                             INCINERATOR
                                                       ASH
                                              WATER
                                            FIGURE  3-1.
                              LIQUID  INJECTION  INCINERATOR

-------
                                                              GAS TO
                                                           AIR POLLUTION
                                                             CONTROL
                       AUXILIARY
                          FUEL
                                             AFTERBURNER
   SOLID
  WASTE
INFLUENT
  FEED
MECHANISM
                                                                 COMBUSTION
                                                                 GASES
                            LIQUID OR
                            GASEOUS
                             WASTE
                            INJECTION
                                                               ASH
                                     FIGURE 3-2.
                           ROTARY  KILN INCINERATOR
                                        65

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where it can be removed.  Rotary kiln systems usually have a secondary
combustion chamber or afterburner following the kiln for further
combustion of the volatilized components of solid wastes.
       (c) 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 3-3)
        (d)  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 3-4).   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 carbon
 monoxide,  along  with the normal  products  of combustion,  pass  to  the
 secondary chamber.   Here,  additional air  is injected to complete the
                                      66

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  WASTE
INJECTION
BURNER
                              FREEBOARD
                             SAND BED
                                                        GAS TO
                                                        AIR  POLLUTION
                                                        CONTROL
                                                        MAKE-UP
                                                        SAND
                                                        AIR
                                ASH
                             FIGURE 3-3.
                   FLUIDIZED BED INCINERATOR
                                   67

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          AIR
   WASTE
INJECTION'
                                                  AIR

                                               GAS TO AIR
                                               POLLUTION
                                               CONTROL
  PRIMARY
COMBUSTION
 CHAMBER

   GRATE
                                                  SECONDARY

                                                   CHAMBER
AUXILIARY
FUEL
                                                                                         00
                                 2-STAGE FIXED  HEARTH
                                     INCINERATOR
                             ASH
                                   FIGURE 3-4.
                       FIXED  HEARTH  INCINERATOR

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combustion.  This two-stage process generally yields low stack
participate 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.
       (e) 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.
    (4) Waste Characteristics Affecting Performance (WCAP)
       (a) 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
                                     69

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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.
    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 reation).   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 (AG) for the  wide range of hazardous
constituents to be addressed by this rule.  Finally, EPA decided not to
                                     70

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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.
       (b) 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 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.
    (i)  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,
                                     71

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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 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 described in Appendix D).  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
                                     72

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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.
    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.
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    (ii)  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
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 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
       (a) 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 scrubber water residual is
generated from treatment of a particular waste.  If treatment of a
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particular waste in a liquid injection unit would not generate a



wastewater stream,  then the 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.



    (i)  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.



    (ii)  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 insufficient



oxygen is present,  then destabilized waste constituents could recombine



to the same or other BOAT list organic compounds and potentially cause



the scrubber water to contain higher concentrations of BOAT list



constituents than would be the case for a well operated unit.





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    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.



    (iii)  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.



    (iv)  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
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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.



       (b)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,



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.



    (i)  Temperature.  The primary chamber temperature is  important, in  •



that  it  provides an  indirect measure of the energy  input  (i.e., BTUs/hr)
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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.
    (ii)  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 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.
    (iii)  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.
        (c)  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
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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 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.
       (d) 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".
3.2.2    Fuel Substitution
    Fuel  substitution involves using hazardous waste as a fuel  in
industrial furnaces or in boilers for generation of steam.  The hazardous
waste may be blended with other nonhazardous wastes (e.g., municipal
sludge) and/or fossil fuels.

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    (1) Applicability and Use of This Technology

    Fuel substitution has been used with industrial waste solvents,

refinery wastes, synthetic fibers/petrochemical wastes and waste oils.

It can also be used when combusting other waste types produced during the

manufacturing of Pharmaceuticals, pulp and paper and pesticides.  These

wastes can be handled in a solid, liquid or gaseous form.

    The most common types of units in which waste fuels are burned are

industrial furnaces and industrial boilers.  Industrial furnaces include

a diverse variety of industrial processes that produce heat and/or

products by burning fuels.  They include blast furnaces, smelters, and

coke ovens.  Industrial boilers are units wherein fuel is used to produce

steam for process and plant use.  Industrial boilers typically use coal,

oil, or gas as the primary fuel source.

    There are a number of parameters that affect the selection of fuel

substitution.  These are:

    •  Halogen content of the waste.

    •  Inorganic solids content (ash content) of the waste,
       particularly heavy metals.

    •  Heating value of the waste.

    •  Viscosity of the waste (for liquids).

    •  Filterable solids concentration (for liquids).

    •  Sulfur content.

    If halogenated organics are burned, halogenated acids and free

halogen are among the products of combustion.  These released corrosive
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gases may require subsequent treatment prior to venting to the
atmosphere.  Also, halogens and halogenated acids formed during
combustion are likely to severely corrode boiler tubes and other process
equipment.  For this reason, halogenated wastes are blended into fuels
only at very low concentrations to minimize such problems.  High chlorine
content can also lead to the incidental production (at very low
concentrations) of other hazardous compounds such as PCBs
(polychlorinated biphenyls), PCDDs (chlorinated dibenzo-p-dioxins),  PCDFs
(chlorinated dibenzofurans), and chlorinated phenols.
    High  inorganic solids content (i.e., ash content) of wastes may cause
two problems:  (1) scaling  in the boiler, and  (2) particulate air
emissions.  Scaling results from deposition of inorganic solids on the
walls of  the boiler.  Particulate emissions are produced by
noncombustible inorganic constituents that flow out of the boiler with
the gaseous combustion products.  Due to these problems, wastes with
significant concentrations  of inorganic materials are not usually handled
in boilers unless they have an  air pollution control system.
    Industrial furnaces vary in their tolerance to inorganic
constituents.  Heavy metal  concentrations, found  in both halogenated and
nonhalogenated wastes used  as fuel, can cause  environmental concern
because they may  be emitted either in the gaseous emissions from the
combustion process, in the  ash  residues, or in any produced solids.  The
partitioning of the heavy metals to these residual streams primarily
depends on the volatility of the metal, waste  matrix, and furnace design.
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    The heating value of the waste must be sufficiently high (either
alone or in combination with other fuels) to maintain combustion
temperatures consistent with efficient waste destruction and operation of
the boiler or furnace.  For many applications,  only supplemental fuels
having minimum heating values of 4,400 to 5,600 kcal/kg (8,000 to 10,000
BTU/lb) are considered to be feasible.  Below this value,  the unblended
fuel would not be likely to maintain a stable flame and its combustion
would release insufficient energy to provide needed steam generation
potential in the boiler, or the necessary heat  for an industrial
furnace.  Some wastes with heating values of less than 4,400 kcal/kg
(8,000 BTU/lb) can be used if sufficient auxiliary fuel is employed to
support combustion or if special designs are incorporated into the
combustion device.  Occasionally, for wastes with heating values higher
than virgin fuels, blending with auxiliary fuel may be required to
prevent overheating or over charging the combustion device.
    In combustion devices designed to burn liquid fuels, the viscosity of
liquid waste must be low enough so that it can  be atomized in the
combustion chamber.  If viscosity is too high,  heating of storage tanks
may be required prior to combustion.  For atomization of liquids, a
viscosity of 165 centistokes (750 Saybolt Seconds Universal (SSU)) or
less is typically required.
    If filterable material suspended in the liquid fuel prevents or
hinders pumping or atomization, it will be unacceptable.
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    Sulfur content in the waste may prevent burning of the waste due to
potential atmospheric emissions of sulfur oxides.   For instance there are
proposed Federal sulfur oxide emission regulations for certain new source
industrial boilers (51 FR 22385).  Air pollution control  devices are
available to remove sulfur oxides from the stack gases.
    (2) Underlying Principles of Operation
    For a boiler and most industrial furnaces there are two distinct
principles of operation.  Initially, energy in the form of heat is
transferred to the waste to achieve volatilization of the various waste
constituents.  For liquids, volatilization energy may also be supplied by
using pressurized atomization.  The energy used to pressurize the liquid
waste allows the atomized waste to break into smaller particles thus
enhancing its rate of volatilization.  The volatilized constituents then
require additional energy to destabilize the chemical bonds and allow the
constituents to react with oxygen to form carbon dioxide and water
vapor.  The energy needed to destabilize the chemical bonds is referred
to as the energy of activation.
    (3) Physical Description of the Process
    As stated, there are a number of industrial applications that can use
fuel substitution.  Therefore, there is no one process description that
will fit all of these applications.  However, the following section
provides a general description of industrial kilns (one form of
industrial furnace) and industrial boilers.
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       (a) Kilns.  Combustible wastes have the potential  to be used as
fuel in kilns and, for waste liquids, are often used with oil  to co-fire
kilns.   Coal-fired kilns are capable of handling some solid wastes.  In
the case of cement kilns, there are usually no residuals  requiring land
disposal since any ash formed becomes part of the product or is removed
by particulate collection systems and recycled back to the kiln.  The
only residuals may be low levels of unburned gases escaping with
combustion products.  If this is the case, air pollution control devices
may be required.
    Three types of kilns are particularly applicable: cement kilns, lime
kilns,  and light-weight aggregate kilns.
    (i)  Cement kilns.  The cement kiln is a rotary furnace which  is a
refractory-lined  steel shell used to calcine a mixture of calcium,
silicon, aluminum, iron, and magnesium-containing minerals.  The kiln is
normally fired by coal or oil.  Liquid  and solid combustible wastes may
then serve as auxiliary  fuel.  Temperatures within the kiln are typically
between 1,380°C and  1,540°C  (2,500=F to 2,800°F).  To date, only liquid
hazardous wastes  have been burned in cement kilns.
    Most cement  kilns have a dry particulate collection device  (i.e.,
either  an electrostatic  precipitator or baghouse) with the collected fly
ash recycled  back to the kiln.  Build up  of metals or other
noncombustibles  is prevented through their incorporation  in the product
cement.  Many types  of cement  require a source  of chloride so  that most
halogenated  liquid hazardous wastes  currently  can be  burned in  cement
kilns.  Available information  shows  that  scrubbers  are not used.

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    (ii) Lime kilns.  Quick-lime (CaO) is manufactured in a calcination


process using limestone (CaCO ) or dolomite (CaCO  and MgCO ).
                             «j                   *5         j

These raw materials are also heated in a refractory-lined rotary kiln,


typically to temperatures of 980°C to 1,260°C (1,800°F to


2,300°F).  Lime kilns are less likely to burn hazardous wastes than


cement kilns because product lime is often added to potable water


systems.  Only one lime kiln currently burns hazardous waste in the U.S.


That particular facility sells its product lime for use as flux or as


refractory in blast furnaces.


    As with cement kilns, any collected fly ash is recycled back to the


lime kiln, resulting in no residual streams from the kiln.  Available


information shows that scrubbers are not used.


    (iii) Lightweight aggregate kilns.  Lightweight aggregate kilns heat


clay to produce an expanded lightweight inorganic material used in


Portland cement formulations and other applications.  The kiln has a


normal temperature range of 1,100°C to 1,150°C (2,000°F


to 2,100°F).  Lightweight aggregate kilns are less amenable to


combustion of hazardous wastes as fuels than other kilns described above


due to their lack of material in the kiln to adsorb halogens.  As a


result burning of halogenated organics in these kilns would likely


require afterburners to ensure complete destruction of the halogenated


organics and scrubbers to control acid gas production.  Such controls


would produce a wastewater residual stream subject to treatment standards,
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       (b) Industrial Boilers.  A boiler is a closed vessel  in which
water is transformed into steam by the application of heat.   Normally,
heat is supplied by the combustion of pulverized coal, fuel  oil, or gas.
These fuels are fired into a combustion chamber with nozzles and burners
that provide mixing with air.  Liquid wastes, and granulated solid wastes
in the case of grate-fired boilers, can be burned as auxiliary fuel in a
boiler.  Few grate-fired boilers burn hazardous wastes, however.  For
liquid-fired boilers, residuals requiring land disposal are only
generated when the boiler is shut down and cleaned.  This is generally
done once or twice per year.  Other residuals from liquid-fired boilers
would be the gas emission stream which would consist of any products of
incomplete combustion, along with the normal combustion products.  For
example, chlorinated wastes would produce acid gases.  If this  is the
case, air pollution  control devices may be required.   For solid fired
boilers, an ash normally is generated.  This ash may contain residual
amounts of organics  from the  blended waste/fuels as well as
noncombustible materials.   Land disposal of  this ash would  require
compliance with applicable  BOAT treatment  standards.
     (4) Waste Characteristics Affecting Performance
     For cement kilns and lime kilns, and lightweight  aggregate  kilns
burning nonhalogenated wastes  (i.e., no scrubber  is needed  to control
acid gases), no residual waste  streams would be produced.   Any
noncombustible material  in  the  waste would  leave  the  kiln  in  the  product
stream.   As  a  result,  in transferring  standards EPA would not examine
                                     86

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waste characteristics affecting performance but rather would determine
the applicability of fuel substitution.  That is, EPA would investigate
the parameters affecting treatment selection.  For kilns these parameters
(as mentioned previously) are Btu content, percent filterable solids,
halogenated organics content, viscosity, and sulfur content.
    Lightweight aggregate kilns burning halogenated organics and boilers
burning wastes containing any noncombustibles will produce residual
streams subject to treatment standards.  In determining whether fuel
substitution is likely to achieve the  same level of performance on an
untreated waste as a previously treated waste, EPA will examine:
(a) relative volatility of the waste constituents, (b) the heat transfer
characteristics (for solids); and (c)  the activation energy for
combustion.
        (a) Relative volatility.  The term relative volatility (a)
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.
    EPA recognizes that the  relative volatilities can not be measured or
calculated directly for the  types of wastes generally treated in an
industrial boiler or furnace.  The Agency believes that the best measure
of relative volatility is the boiling  point of the various hazardous
constituents and will, therefore, use  this parameter in assessing
volatility of the organic constituents.
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       (b) Heat transfer characteristics.  Consistent with the underlying
principles of combustion in aggregate kilns or boilers,  a major factor
with regard to whether a particular constituent will  volatilize is the
transfer of heat through the waste.  In the case of industrial boilers
burning solid fuels, heat is transferred through the waste by three
mechanisms:  radiation, convection, and conduction.  For a given boiler
it can be assumed that the type of waste will have a minimal impact on
the heat transferred from radiation.  With regard to convection, EPA
believes that the range of wastes treated would exhibit similar
properties with regard to the amount of heat transferred by convection.
Therefore, EPA will not evaluate radiation convection heat transfer
properties of wastes in determining similar treatability.  For solids,
the third heat transfer mechanism, conductivity, is the one principally
operative or most likely to change between wastes.  The method that EPA
believes can be used to determine thermal conductivity of a nonwastewater
can be found in Appendix D.
    Using thermal conductivity measurements  as part of a treatability
comparison for two  different wastes through  a given boiler or furnace  is
most meaningful when applied to wastes that  are homogeneous.  As wastes
exhibit greater degrees of  non-homogeneity,  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).   Nevertheless, EPA  has  not  identified a
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better alternative to thermal conductivity, even for wastes that are
non-homogeneous.
    Other parameters considered for predicting heat transfer
characteristics were Btu value, specific heat, and ash content.  These
parameters can neither better account for non-homogeneity nor better
predict heat transferability through the waste.
       (c) Activation energy.  Given an excess of oxygen, an organic
waste in an industrial furnace or boiler would be expected to convert to
CO  and HO provided that the activation energy is achieved.
Activation energy is the quantity of heat  (energy) needed to destabilize
molecular bonds and create reactive intermediates so that the oxidation
(combustion) reaction will proceed to completion.  As a measure of
activation energy, EPA is using bond dissociation energies.  In theory,
the bond dissociation energy would be equal to the activation energy;
however, in practice this is not always the case.
    In some instances, bond energies will not be available and will have
to be estimated or other energy effects (e.g., vibrational) and other
reactions will 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 included 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.
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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 available
kinetic data were rejected because while it could be used to calculate
some free energy values (AG), it could not be used for the wide range
of hazardous constituents.  Finally, EPA decided not to use structural
classes because the Agency believes that evaluation of bond dissociation
energies allows for a more direct comparison.
    (5)   Design and Operating Parameters
       (a) Design Parameters.  Cement kilns and lime kilns, along with
aggregate kilns burning nonhalogenated wastes produce no residual
streams.  Their design and operation is such that any wastes that are
incompletely destroyed will be contained in the product.  As a result,
the Agency will not look at design and operating values for such devices
since treatment, per se, cannot be measured through detection of
constituents in residual streams.  In this instance it is important
merely to ensure the waste is appropriate for combustion in the kilns and
the kiln is operated in a manner that will produce a useable product.
    Specifically, cement, lime, and aggregate kilns are only demonstrated
on liquid hazardous wastes.  Such wastes must be sufficiently free of
filterable solids to avoid plugging the burners at the hot end of the
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kiln.   Viscosity also must be low enough to inject the waste into the
kiln through the burners.  The sulfur content is not a concern unless the
concentration in the waste is sufficiently high as to exceed federal,
state, or local  air pollution standards promulgated for industrial
boilers.
    The design parameters which normally affect the operation of an
industrial boiler (and aggregate kilns with residual streams) with
respect to hazardous waste treatment are (i) the design temperature,
(ii) the design retention time of the waste in the combustion chamber,
and (iii) turbulence in  the combustion chamber.  Evaluation of these
parameters would be  important in determining if an industrial boiler or
industrial furnace  is adequately designed for effective treatment of
hazardous wastes.   The rationale for selection of three parameters  is
given below.
        (i) Design temperature.   Industrial  boilers are generally designed
based on their  steam generation  potential  (BTU output).  This factor  is
related to the  design combustion temperature, which  in turn depends  on
the amount of fuel  burned, and  its  BTU  value.  The fuel feed  rates  and
combustion temperatures  of industrial  boilers are generally fixed based
on  the  BTU values of fuels normally handled (e.g., No. 2 versus  No.  6
fuel  oils).  When wastes are  to  be  blended  with fossil fuels  for
combustion,  the blending, based  on  BTU  values, must  be such that the
resulting BTU value of the mixture  is  close to that  of the  fuel  value
used  in design  of the boiler.   Industrial  furnaces  also are designed  to
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operate at specific ranges of temperature in order to produce the desired
product (e.g., lightweight aggregate).  The blended waste/fuel mixture
should be capable of maintaining the design temperature range.
    (ii) Retention time.  A sufficient retention time of combustion
products is normally necessary to ensure that the hazardous substances
being combusted (or formed during combustion) are completely oxidized.
Retention times on the order of a few seconds are normally needed at
normal operating conditions.  For industrial furnaces, as well as
boilers, the retention time is a function of the size of the furnace and
the fuel feed rates.  For most boilers and furnaces the retention time
usually exceeds a few seconds.
    (iii) Turbulence.  Boilers are designed so that fuel and air are
intimately mixed.  This helps ensure that complete combustion takes
place.  The shape of the boiler, and the method of fuel and air feed
influence the turbulence required for good mixing.  Industrial furnaces
also  are designed for turbulent mixing where fuel and air are mixed.
        (b) Operating Parameters.  The operating parameters which normally
affect  the performance  of an  industrial  boiler and many industrial
furnaces with respect to treatment of hazardous wastes  are  (i) air  flow
rate,  (ii) fuel feed rate,  (iii) steam pressure or rate of production,
and  (iv) temperature.   EPA  believes  that these four parameters will  be
used  to determine  if an  industrial boiler  burning blended fuels
containing hazardous waste  constituents  is  properly operated.  The
rationale  for selection  of  these four operating parameters  is given
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below.  Most industrial furnaces will monitor similar parameters, but
some exceptions are noted below.
    (i)  Air feed rate.  An important operating parameter in boilers and
many industrial furnaces is the oxygen content in the flue gas which is a
function of the air feed rate.  Stable combustion of a fuel generally
occurs within a specific range of air-to-fuel ratios.  An oxygen analyzer
in the combustion gases can be used to control the feed ratio of air to
fuel to assure complete thermal destruction of the waste and efficient
operation of the boiler.  When necessary, the air flow rate can be
increased or decreased to maintain proper fuel to oxygen ratios.  Some
industrial furnaces do not completely combust fuels  (e.g., coke ovens and
blast furnaces) hence oxygen concentration in the flue gas is a
meaningless variable.
    (ii) Fuel feed rate.  The  rate at which fuel is  injected into the
boiler or industrial furnace will determine the thermal output of the
system per unit of time  (BTU/hr).  If steam is produced, steam pressure
monitoring will indirectly determine if the fuel feed rate is adequate.
However, various velocity and  mass measurement devices can be used to
monitor fuel flow directly.
    (iii) Steam pressure or rate of  production.  Steam pressure  in
boilers provides a direct measure of the thermal output of the system and
is directly monitored  by use of  in-system pressure gauges.  Increases or
decreases in steam pressure can  be effected by increasing or decreasing-
the fuel and air feed  rates within certain operating design limits.  Most
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industrial furnaces do not produce steam, but instead a product (e.g.,
cement, aggregate) and monitor the rate of production.
    (iv) Temperature.  Temperatures are monitored and controlled in
industrial boilers to assure the quality and flow rate of steam.
Therefore, complex monitoring systems are frequently installed in the
combustion unit to provide a direct reading of temperature.  The
efficiency of combustion in industrial boilers is dependent on combustion
temperatures.  Temperature may be adjusted to design settings by
increasing or decreasing air and fuel feed rate.
    Wastes should not be added to primary fuels until the boiler
temperature reaches the minimum needed for destruction of the wastes.
Temperature instrumentation and control  should be designed to stop waste
addition  in the event of process upsets.
    Monitoring and control of temperature in industrial furnaces are  also
critical  to the product quality; e.g., lime, cement, or aggregate kilns,
that require minimum operating temperatures.  Kilns  have very high
thermal inertia in the refractory and  in-process product, high  residence
times,  and high air  flow rates, so that  even in the  case of a momentary
stoppage  of fuel  flow to the kiln, organic constituents are likely to
continue  to be destroyed.  The main  operational control required for
wastes  burned  in  kilns is  to stop waste  flow in the  event of  low kiln
temperature, loss  of the electrical  power to the combustion air fan,  and
loss of primary fuel flow.
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       (c) Other Operating Parameters.  In addition to the four operating
parameters discussed above, EPA considered and then discarded one
additional parameter.  Fuel to waste blending ratios were also
considered.  However, while the blending is done to yield a uniform BTU
content fuel, blending ratios will vary on a wide range dependent on the
BTU content of the wastes and fuels being used.
3.2.3    Stabilization of Metals
    Stabilization refers to a broad class of treatment processes that
chemically reduce the mobility of hazardous constituents in a waste.
Solidification and fixation are other terms that are sometimes used
synonymously for stabilization or to describe specific variations within
the broader class of stabilization.  Related technologies are
encapsulation and thermoplastic binding; however, EPA considers these
technologies to be distinct from  stabilization in that the operational
principles are significantly different.
    (1) Applicability and Use of  This Technology
    Stabilization is used when a  waste contains metals that will leach
from the waste when  it is contacted by water.  In general, this
technology is applicable to wastes containing BOAT list metals, having a
high filterable solids content, low TOC content, and low oil and grease
content.  This technology  is commonly used to treat residuals generated
from treatment of electroplating  wastewaters.  For some wastes, an
alternative to stabilization is metal recovery.
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    (2)  Underlying Principles of Operation
    The  basic principle underlying this technology is that stabilizing
agents and other chemicals are added to a waste in order to minimize the
amount of metal  that leaches.  The reduced Teachability is accomplished
by the formation of a lattice structure and/or chemical bonds that bind
the metals to the solid matrix and, thereby,  limit the amount of metal
constituents that can be leached when water or a mild acid solution comes
into contact with the waste material.
    There are two principal stabilization processes used; these are
cement based and lime based.  A brief discussion of each is provided
below.   In both cement-based or lime/pozzolan-based techniques, the
stabilizing process can be modified through the use of additives, such as
silicates, that control curing rates or enhance the properties of the
sol id material.
        (a) Portland Cement-Based  Process.   Portland cement  is a mixture
of  powdered oxides  of  calcium,  silica, aluminum,  and iron, produced  by
kiln  burning of materials  rich  in  calcium and  silica at  high temperatures
(i.e.,  1400°C to  1500°C).   When  the anhydrous  cement powder  is
mixed with water,  hydration  occurs and the cement  begins to  set.  The
chemistry involved  is  complex  because  many different  reactions occur
depending on  the  composition of the cement mixture.
     As  the  cement begins  to set,  a colloidal  gel  of  indefinite
composition  and  structure is formed.   Over a  period  of time,  the gel
swells  and  forms  a matrix composed of  interlacing, thin, densely-packed
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silicate fibrils.  Constituents present in the waste slurry (e.g.,
hydroxides and carbonates of various heavy metals, are incorporated into
the interstices of the cement matrix.  The high pH of the cement mixture
tends to keep metals in the form of insoluble hydroxide and carbonate
salts.)  It has been hypothesized that metal ions may also be
incorporated into the crystal structure of the cement matrix, but this
hypothesis has not been verified.
       (b) Lime/Pozzolan-Based Process.  Pozzolan, which contains finely
divided, noncrystalline silica (e.g., fly ash or components of cement
kiln dust), is a material that is not cementitious in itself, but becomes
so upon the addition of lime.  Metals in the waste are converted to
silicates or hydroxides which inhibit leaching.  Additives, again, can be
used to reduce permeability and thereby further decrease leaching
potential.
     (3) Description of Stabilization Processes
     In most stabilization processes, the waste, stabilizing agent, and
other additives, if used, are mixed and then pumped to a curing vessel or
area and  allowed to cure.  The actual operation (equipment requirements
and  process sequencing) will depend on several factors such as the nature
of the waste, the quantity of the waste, the location of the waste in
relation  to the  disposal site, the particular stabilization formulation
to be used, and  the curing rate.After curing, the solid formed is
recovered from the  processing equipment and shipped for final disposal.
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    In instances where waste contained in a lagoon is to be treated, the
material should be first transferred to mixing vessels where stabilizing
agents are added.  The mixed material is then fed to a curing pad or
vessel.  After curing, the solid formed is removed for disposal.
Equipment commonly used also includes facilities to store waste and
chemical additives.  Pumps can be used to transfer liquid or light sludge
wastes to the mixing pits and pumpable uncured wastes to the curing
site.  Stabilized wastes are then removed to a final disposal site.
    Commercial concrete mixing and handling equipment generally can be
used with wastes.  Weighing conveyors, metering cement hoppers, and
mixers similar to concrete batching  plants have been adapted in some
operations.  Where extremely dangerous materials are being treated,
remote-control and in-drum mixing equipment, such as that used with
nuclear waste, can be employed.
     (4) Waste Characteristics Affecting  Performance
     In determining whether stabilization  is likely to achieve the  same
level  of performance  on an untested  waste  as on a previously tested
waste,  the Agency will  focus on  the  characteristics  that  inhibit the
formation of  either the chemical  bonds  or  the  lattice structure.   The
four  characteristics  EPA  has  identified  as  affecting  treatment
performance  are  the presence  of  (a)  fine particulates,  (b)  oil  and
grease,  (c)  organic compounds,  and  (d)  certain inorganic  compounds.
        (a)  Fine  Particulates.   For  both  cement-based and
1ime/pozzolan-based processes,  the  literature  states that very  fine solid
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materials (i.e., those that pass through a No. 200 mesh sieve, 74 urn
particle size) can weaken the bonding between waste particles and cement
by coating the particles.  This coating can inhibit chemical bond
formation and decreases the resistance of the material to leaching.
       (b) Oil and Grease.   The presence of oil and grease in both
cement-based and lime/pozzolan-based systems results in the coating of
waste particles and the weakening of the bonding between the particle and
the stabilizing agent.  This coating can inhibit chemical bond formation
and thereby, decrease the resistance of the material to leaching.
       (c) Organic Compounds.  The presence of organic compounds in the
waste interferes with the chemical reactions and bond formation which
inhibit curing of the stabilized material.  This results in a stabilized
waste having decreased resistance to leaching.
       (d) Sulfate and Chlorides.  The presence of certain inorganic
compounds will interfere with the chemical reactions, weakening bond
strength and prolonging setting and curing time.  Sulfate and chloride
compounds may reduce the dimensional stability of the cured matrix,
thereby increasing Teachability potential.
    Accordingly, EPA will examine these constituents when making
decisions regarding transfer of treatment standards based on
stabilization.
    (5) Design and Operating Parameters
    In designing a stabilization system, the principal parameters that
are important to optimize so that the amount of Teachable metal
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constituents is minimized are (a) selection of stabilizing agents and
other additives, (b) ratio of waste to stabilizing agents and other
additives, (c) degree of mixing, and (d) curing conditions.
       (a) Selection of stabilizing agents and other additives.  The
stabilizing agent and additives used will determine the chemistry and
structure of the stabilized material and, therefore, will affect the
Teachability of the solid material.  Stabilizing agents and additives
must be carefully selected based on the chemical and physical
characteristics of the waste to be stabilized.  For example, the amount
of sulfates in a waste must be considered when a choice is being made
between a 1ime/pozzolan and a Portland cement-based system.
    In order to select the type of stabilizing agents and additives, the
waste should be tested in the laboratory with a variety of materials to
determine the best combination.
       (b) Amount of stabilizing agents and additives.  The amount of
stabilizing agents and additives is a critical parameter in that
sufficient stabilizing materials are necessary in the mixture  to bind the
waste constituents of concern properly, thereby making them less
susceptible to  leaching.  The appropriate weight ratios of waste to
stabilizing agent and other additives are established empirically by
setting up a  series of laboratory  tests that  allow  separate leachate  -
testing of different mix  ratios.   The ratio of water to  stabilizing agent
(including water in waste) will  also  impact the strength and leaching
characteristics of  the stabilized  material.   Too much water will cause
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low strength; too little will  make mixing difficult and,  more
importantly, may not allow the chemical reactions that bind the hazardous
constituents to be fully completed.
       (c) Mixing.  The conditions of mixing include the type and
duration of mixing.  Mixing is necessary to ensure homogeneous
distribution of the waste and the stabilizing agents.  Both undermixing
and overmixing are undesirable.  The first condition results in a
nonhomogeneous mixture; therefore, areas will exist within the waste.
where waste particles are neither chemically bonded to the stabilizing
agent nor physically held within the lattice structure.  Overmixing, on
the other hand, may inhibit gel formation and ion adsorption in some
stabilization systems.  As with the relative amounts of waste,
stabilizing agent, and additives within the system, optimal mixing
conditions generally are determined through laboratory tests.  During
treatment it is important to monitor the degree  (i.e., type and duration)
of mixing to ensure that it reflects design conditions.
        (d) Curing  conditions.  The curing conditions include the duration
of curing and the  ambient curing conditions  (temperature and humidity).
The duration of curing is a critical parameter to ensure that the waste
particles have had sufficient time in  which to form stable chemical bonds
and/or lattice structures.  The time necessary for complete stabilization
depends upon the waste type and the stabilization used.  The performance
of the stabilized  waste  (i.e., the levels of constituents  in the
leachate) will be  highly dependent upon whether  complete stabilization
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has occurred.  Higher temperatures and lower humidity increase the rate
of curing by increasing the rate of evaporation of water from the
solidification mixtures.  However, if temperatures are too high,  the
evaporation rate can be excessive and result in too little water being
available for completion of the stabilization reaction.  The duration of
the curing process should also be determined during the design stage and
typically will be between 7 and 28 days.
3.2.4    Chemical Precipitation
    (1) Applicability and Use of This Technology
    Chemical precipitation is used when dissolved metals are to be
removed from solution.  This technology can be applied to a wide range of
wastewaters containing dissolved BOAT list metals and other metals as
well.  This treatment process has been practiced widely by industrial
facilities since the  1940s.
    (2) Underlying Principles of Operation
    The underlying principle of chemical precipitation is that metals  in
wastewater are removed  by the addition of a treatment chemical that
converts the dissolved  metal to a metal precipitate.  This precipitate is
less  soluble than the original metal  compound, and therefore  settles out
of  solution, leaving  a  lower concentration of  the metal present  in the
solution.  The principal chemicals  used to convert soluble metal
compounds  to the  less  soluble forms  include: lime  (Ca(OH)  ),  caustic
(NaOH),  sodium  sulfide  (Na S),  and,  to  a lesser  extent, soda  ash
(Na CO ),  phosphate,  and ferrous  sulfide  (FeS).
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    The solubility of a particular compound will depend on the extent to
which the electrostatic forces holding the ions of the compound together
can be overcome.  The solubility will change significantly with
temperature; most metal compounds are more soluble as the temperature
increases.  Additionally, the solubility will be affected by the other
constituents present in a waste.  As a general rule, nitrates, chlorides,
and sulfates are more soluble than hydroxides, sulfides, carbonates, and
phosphates.
    An important concept related to treatment of the soluble metal
compounds is pH.  This term provides a measure of the extent to which a
solution contains either an excess of hydrogen or hydroxide ions.  The pH
scale ranges from 0 to 14; with 0 being the most acidic, 14 representing
the highest alkalinity or hydroxide  ion (OH  ) content, and 7.0 being
neutral.
    When hydroxide  is used, as  is often the case, to precipitate the
soluble metal compounds, the pH is frequently monitored to ensure that
sufficient treatment chemicals  are added.  It is important to point out
that pH is not  a good measure of treatment chemical addition for
compounds other than hydroxides; when sulfide is used, for example,
facilities might use an oxidation-reduction  potential meter (ORP)
correlation to  ensure that sufficient treatment chemical is used.
    Following conversion of the relatively soluble metal compounds to
metal precipitates, the effectiveness of chemical precipitation  is a
function of the physical removal, which usually relies on a settling
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process.  A particle of a specific size, shape, and composition will
settle at a specific velocity, as described by Stokes' Law.   For a batch
system, Stokes' law is a good predictor of settling time because the
pertinent particle parameters remain essentially constant.  Nevertheless,
in practice, settling time for a batch system is normally determined by
empirical testing.  For a continuous system,  the theory of settling is
complicated by factors such as turbulence, short-circuting, and velocity
gradients, increasing the importance of the empirical  tests.
    (3) Description of the Technology
    The equipment and instrumentation required for chemical precipitation
varies depending on whether the system is batch or continuous.  Both
operations are discussed below; a schematic of the continuous system is
shown in Figure'3-5.
    For a batch system,  chemical  precipitation requires only  a feed
system for the treatment chemicals and a second tank where the waste can
be treated and allowed to settle.  When lime  is used,  it is usually added
to the reaction tank in  a slurry form.  In a  batch system, the supernate
is usually analyzed before discharge, thus minimizing  the need for
instrumentation.
    In a continuous system,  additional tanks  are necessary, as well  as
instrumentation to ensure that the system is  operating properly.  In this
system, the first tank that the wastewater enters is referred to as an
equalization tank.  This is where the waste can be mixed in order to
provide more uniformity, minimizing wide swings in the type and
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WASTEWATER
FEED   	
             EQUALIZATION
               TANK
ELECTRICAL CONTROLS

WASTEWATER FLOW


MIXER
ATMENT
EMICAL
:EED
rSTEM


COAGULANT OR
FLOCCULANT FEED SYSTEM


                                                                                          EFFLUENT TO
                                                                                          DISCHARGE OR
                                                                                          SUBSEQUENT
                                                                                          TREATMENT
                                                                                            SLUDGE TO
                                                                                            DEWATERING
                            FIGURE  3-5.
                                 CONTINUOUS CHEMICAL PRECIPITATION

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concentration of constituents being sent to the reaction tank.   It is
important to reduce the variability of the waste sent to the reaction
tank because control systems inherently are limited with regard to the
maximum fluctuations that can be managed.
    Following equalization, the waste is pumped to a reaction tank where
treatment chemicals are added; this is done automatically by using
instrumentation that senses the pH of the system and then pneumatically
adjusts the position of the treatment chemical feed valve such that the
design pH value is achieved.  Both the complexity and the effectiveness
of the automatic control system will vary depending on the variation in
the waste and the pH range that is needed to properly treat the waste.
    An important aspect of the reaction tank design is that it be
well-mixed so that the waste and the treatment chemicals are both
dispersed throughout the tank, in order to ensure coming!ing of the
reactant and the treatment chemicals.  In addition, effective dispersion
of the treatment chemicals throughout the tank is necessary to properly
monitor and, thereby, control the amount of treatment chemicals added.
    After the waste is reacted with the treatment chemical, it flows to a
quiescent tank where the precipitate is allowed to settle and
subsequently be removed.   Settling can be chemically assisted through the
use of flocculating compounds.  Flocculants increase the particicle  size
and density of the  precipitated solids, both of which increase the rate
of settling.  The particular  flocculating agent that will best improve
settling characteristics will vary depending on the particular waste;
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selection of the flocculating agent is generally accomplished by
performing laboratory bench tests.  Settling can be conducted in a large
tank by relying solely on gravity or be mechanically assisted through the
use of a circular clarifier or an inclinded separator.  Schematics of the
latter two separators are shown in Figures 3-6 and 3-7.
    Filtration can be used for further removal of precipitated residuals
both in cases where the settling system is underdesigned and in cases
where the particles are difficult to settle.  Polishing filtration is
discussed in a separate technology section.
    (4) Waste Characteristics Affecting Performance
    In determining whether chemical preciptation is likely to achieve the
same level of performance on an untested waste as a previously tested
waste, we will examine the following waste characteristics:  (a) the
concentration and type of the metal(s) in the waste,  (b) the
concentration of suspended solids  (TSS),  (c) the concentration of
dissolved solids (IDS), (d) whether the metal exists  in the wastewater as
a complex, and (e) the oil and grease content.  These  parameters either
affect the chemical reaction of the metal compound, the solubility of the
metal precipitate, or the ability of the  precipitated  compound to settle.
      (a) Concentration and type of metals.  For most  metals, there  is a
specific pH at which the metal hydroxide  is least soluble.  As a result,
when a waste contains a mixture of many metals, it  is  not  possible to
operate a treatment system at a single pH which is  optimal for the
removal of all metals.  The extent to which this affects treatment
depends on the particular metals to be removed, and their

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                                                           EFFLUENT
      SLUDGE
                                                INFLUENT
   CENTER FEED CLARIFIER WITH SCRAPER SLUDGE REMOVAL SUSTEM
INFLUENT
                                                              EFFLUENT
                                                         *• SLUDGE
               RIM FEED - CENTER TAKEOFF CLARIFIER WITH
            HYDRAULIC  SUCTION  SLUDGE REMOVAL SYSTEM
                                                              INFLUENT
                                                              EFFLUENT
                                             SLUDGE
                  RIM FEED - RIM TAKEOFF CLARIFIER
                             FIGURE  3-6
                      CIRCULAR  CLARIFIERS
                                 108

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I? INFLUENT
I
                                                     EFFLUENT
                            FIGURE  3-7
                   INCLINED  PLATE SETTLER
                               109

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concentrations.  An alternative can be to operate multiple
precipitations, with intermediate settling, when the optimum pH occurs at
markedly different levels for the metals present.  The individual metals
and their concentrations can be measured using EPA Method 6010.
      (b) Concentration and type of total suspended solids (TSS).
Certain suspended solid compounds are difficult to settle because of
either their particle size or shape.  Accordingly, EPA will evaluate this
characteristic in assessing transfer of treatment performance.  Total
suspended solids can be measured by EPA Wastewater Test Method 160.2.
      (c) Concentration of total dissolved solids (TDS).  Available
information shows that total dissolved solids can inhibit settling.  The
literature states that poor flocculation is a consequence of high TDS and
shows that higher concentrations of total  suspended solids are found in
treated residuals.   Poor flocculation can  adversely affect the degree to
which precipitated  particles are removed.  Total  dissolved solids can be
measured  by EPA  Wastewater Test Method  160.1.
       (d) Complexed metals.  Metal  complexes  consist  of  a metal  ion
surrounded by  a  group of other  inorganic or organic ions  or molecules
(often  called  ligands).   In  the complexed  form,  the metals have  a greater
solubility and,  therefore, may  not  be as effectively  removed  from
solution  by chemical  precipitation.   EPA does not have  an  analytical
method  to determine the  amount  of  complexed metals  in the  waste.  The
Agency  believes  that the  best  measure of complexed  metals  is  to  analyze
for some common  complexing  compounds  (or complexing agents) generally
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found in wastewater for which analytical methods are available.  These
complexing agents include ammonia, cyanide, and EDTA.  The analytical
method for cyanide is EPA Method 9010.  The method for EDTA is ASTM
Method D3113.  Ammonia can be analyzed using EPA Wastewater Test
Method 350.
      (e) Oil and grease content.  The oil and grease content of a
particular waste directly inhibits the settling of the precipitate.
Suspended oil droplets float in water and tend to suspend particles such
as chemical precipitates that would otherwise settle out of the
solution.  Even with the use of coagulants or flocculants, the separation
of the precipitate is less effective.  Oil and grease content can be
measured by EPA Method 9071.
     (5) Design and Operating Parameters
    The parameters that EPA will evaluate when determining whether a
chemical precipitation system is well designed are:  (a) design value for
treated metal concentrations, as well as other characteristics of the
waste used for design purposes  (e.g., total suspended solids), (b) pH,
(c) residence time, (d) choice  of treatment chemical, (e) choice of
coagulant/flocculant, and (f) mixing.  Below is an explanation of why EPA
believes these parameters are important to a design  analysis;  in
addition, EPA explains why other design criteria are not included in
EPA's analysis.
      (a) Treated and untreated design concentrations.  EPA pays close
attention to the treated concentration the system is designed to achieve
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when determining whether to sample a particular facility.  Since the
system will seldom out-perform its design, EPA must evaluate whether the
design is consistent with best demonstrated practice.
    The untreated concentrations that the system is designed to treat are
important in evaluating any treatment system.  Operation of a chemical
precipitation treatment system with untreated waste concentrations in
excess of design values can easily result in poor performance.
       (b) pH.  The pH is important, because it can indicate that
sufficient treatment chemical (e.g., lime) is added to convert the metal
constituents in the untreated waste to forms that will precipitate.  The
pH  also affects the solubility of metal hydroxides and sulfides, and
therefore directly impacts the effectiveness of removal.  In practice,
.the design pH  is determined by empirical  bench testing,  often referred  to
as  "jar" testing.  The  temperature at which the "jar" testing is
conducted  is important  in  that it  also affects the solubility of the
metal  precipitates.  Operation of  a treatment  system  at  temperatures
above  the  design temperature  can  result  in poor performance.  In
assessing  the  operation of a  chemical  precipitation  system,  EPA prefers
continuous data  on the  pH  and periodic temperature conditions throughout
the treatment  period.
       (c)  Residence  time.  The  residence  time  is  important  because it
 impacts  the  completeness of  the  chemical  reaction  to form the metal
 precipitate  and,  to  a  greater extent,  amount  of  precipitate that  settles
 out of solution.   In  practice,  it is  determined  by "jar" testing.   For
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found in wastewater for which analytical methods are available.  These
complexing agents include ammonia, cyanide, and EDTA.  The analytical
method for cyanide is EPA Method 9010.  The method for EDTA is ASTM
Method D3113.  Ammonia can be analyzed using EPA Wastewater Test
Method 350.
      (e) Oil and grease content.  The oil and grease content of a
particular waste directly inhibits the settling of the precipitate.
Suspended oil droplets float in water and tend to suspend particles such
as chemical precipitates that would otherwise settle out of the
solution.  Even with the use of coagulants or flocculants, the separation
of the precipitate is less effective.  Oil and grease content can  be
measured by EPA Method 9071.
     (5) Design and Operating Parameters
     The parameters that EPA will evaluate when determining whether a
chemical precipitation system is well designed are:  (a) design value  for
treated metal concentrations, as well as  other characteristics of  the
waste used for design purposes  (e.g., total suspended solids), (b) pH,
(c)  residence time,  (d) choice  of  treatment chemical, (e) choice of
coagulant/flocculant, and  (f) mixing.   Below  is an explanation of  why  EPA
believes these parameters  are important to a  design  analysis;  in
addition,  EPA explains why other  design criteria  are not  included  in
EPA's analysis.
      (a)  Treated  and untreated design  concentrations.  EPA pays close
attention  to the  treated  concentration  the system is designed  to achieve
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when determining whether to sample a particular facility.   Since the
system will seldom out-perform its design, EPA must evaluate whether the
design is consistent with best demonstrated practice.
    The untreated concentrations that the system is designed to treat are
important in evaluating any treatment system.  Operation of a chemical
precipitation treatment system with untreated waste concentrations in
excess of design values can easily result in poor performance.
      (b) pH.  The pH is important, because it can indicate that
sufficient treatment chemical (e.g., lime) is added to convert the metal
constituents in the untreated waste to forms that will precipitate.  The
pH also affects the solubility of metal hydroxides and sulfides, and
therefore directly impacts the effectiveness of removal.   In practice,
the design pH  is determined by empirical  bench testing, often referred to
as "jar" testing.  The temperature at which the "jar" testing is
conducted  is important  in  that it also affects the solubility of the
metal precipitates.  Operation of a treatment system  at temperatures
above the  design temperature  can result  in poor performance.  In
assessing  the  operation of a  chemical precipitation  system,  EPA prefers
continuous data on the  pH  and periodic temperature conditions throughout
the treatment  period.
       (c)  Residence time.  The residence  time  is  important because  it
impacts  the  completeness  of  the  chemical  reaction  to  form  the metal
precipitate  and, to a  greater extent,  amount  of precipitate that  settles
out of  solution.   In  practice,  it  is  determined by  "jar" testing.   For
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continuous systems, EPA will monitor the feed rate to ensure that the
system is operated at design conditions.  For batch systems, EPA will
want information on the design parameter used to determine sufficient
settling time (e.g., total suspended solids).
      (d) Choice of treatment chemical.  A choice must be made as to what
type of precipitating agent (i.e., treatment chemical) will be used.  The
factor that most affects this choice is the type of metal constituents to
be treated.  Other design parameters, such as pH, residence time, and
choice of coagulant/f1occulant agents, are based on the selection of the
treatment chemical.
      (e) Choice of coagulant/f1occulant.  This is important because
these compounds improve the settling rate of the precipitated metals and
allows for smaller systems  (i.e., lower retention time) to achieve the
same degree of settling as a much larger system.  In practice, the choice
of the best agent and the required amount is determined by "jar" testing.
      (f) Mixing.  The degree of mixing is a complex assessment which
includes, among other things, the energy supplied, the time the material
is mixed, and the related turbulence effects of the specific size and
shape of the tank.  EPA will, however, consider whether mixing is
provided and whether the type of mixing device is one that could be
expected to achieve uniform mixing.  For example, EPA may not use data
from a chemical precipitation treatment system where an air hose was
placed in a large tank to achieve mixing.
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3.2.5    Sludge Filtration
    (1) Applicability and Use of This Technology
    Sludge filtration, also known as sludge dewatering or cake-formation
filtration, is a technology used on wastes that contain high
concentrations of suspended solids, generally higher than one percent.
The remainder of the waste is essentially water.  Sludge filtration is
applied to sludges, typically those that have settled to the bottom of
clarifiers, for dewatering.  After filtration,  these sludges can be
dewatered to 20 to 50 percent solids.
    (2) Underlying Principle of Operation
    The basic principle of filtration is the separation of particles from
a mixture of fluids and particles by a medium that permits the flow of
the fluid but retains the particles.  As would  be expected,  larger
particles are easier to separate from the fluid than smaller particles.
Extremely small particles, in the colloidal range, may not be filtered
effectively and may appear in the treated waste.  To mitigate this
problem, the wastewater should be treated prior to filtration to modify
the particle size distribution in favor of the  larger particles, by the
use of appropriate precipitants, coagulants, flocculants, and filter
aids.  The selection of the appropriate precipitant or coagulant is
important because it affects the particles formed.  For example, lime
neutralization usually produces larger, less gelatinous particles than
does caustic soda precipitation.  For larger particles that become too
small to filter effectively because of poor resistance to shearing, shear
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resistance can be improved by the use of coagulants and flocculants.
Also, if pumps are used to feed the filter, shear can be minimized by
designing for a lower pump speed, or by use of a low shear type of pump.
     (3) Technology Description
     For sludge filtration, settled sludge is either pumped through a
cloth-type filter media (such as in a plate and frame filter that allows
solid "cake" to build up on the media) or the sludge is drawn by vacuum
through the cloth media (such as on a drum or vacuum filter, which also
allows the solids to build).  In both cases the solids themselves act as
a filter for subsequent solids removal.  For a plate and frame type
filter, removal of the solids is accomplished by taking the unit off
line, opening the filter and scraping the solids off.  For the vacuum
type filter, cake is removed continuously.  For a specific sludge, the
plate and frame type filter will usually produce a drier cake than a
vacuum filter.  Other types of sludge filters, such as belt filters, are
also used for effective sludge dewatering.
     (4) Waste Characteristics Affecting Performance
     The following characteristics of the waste will affect performance of
a sludge filtration unit:
     • size of particles and
     • type of particles.
     (a)  Size of  particles.  The smaller the particle  size, the more the
particles tend to go through the filter media.  This  is especially true
for  a vacuum  filter.   For  a pressure filter  (like a plate and frame),
                                     115

-------
smaller particles may require higher pressures for equivalent throughput,
since the smaller pore spaces between particles create resistance to flow.
    (b)  Type of particles.  Some solids formed during metal
precipitation are gelatinous in nature and cannot be dewatered well  by
cake-formation filtration.  In fact, for vacuum filtration a  cake may not
form at all.  In most cases solids can be made less gelatinous by use of
the appropriate coagulants and coagulant dosage prior to clarification,
or after clarification but prior to filtration.  In addition, the use of
lime instead of caustic soda in metal precipitation will reduce the
formation of gelatinous solids.  Also the addition of filter  aids to a
gelatinous sludge, such as lime or diatomaceous earth, will help
significantly.  Finally, precoating the filter with diatomaceous earth
prior to sludge filtration will assist in dewatering gelatinous sludges.
    (5) Design and Operating Parameters
    For sludge filtration, the following design and operating variables
affect performance:
    • type of filter selected,
    • size of filter selected,
    • feed pressure, and
    • use of coagulants or filter aids.
    (a)  Type of filter.  Typically, pressure type filters (such as a
plate and frame) will yield a drier cake than a vacuum type filter and
will also be more tolerant of variations in influent sludge
characteristics.  Pressure type filters, however, are batch operations,
                                    116

-------
so that when cake is built up to the maximum depth physically possible
(constrained by filter geometry), or to the maximum design pressure, the
filter is turned off while the cake is removed.  A vacuum filter is a
continuous device (i.e., cake discharges continuously), but will usually
be much larger than a pressure filter with the same capacity.  A hybrid
device is a belt filter, which mechanically squeezes sludge between two
continuous fabric belts.
    (b) Size of filter.  As with in-depth filters, the larger the filter,
the greater its hydraulic capacity and the longer the filter runs between
cake discharge.
    (c) Feed pressure.  This parameter impacts both the design pore size
of the filter and the design flow rate.  It is important that in treating
waste that the design feed pressure not be exceeded, otherwise particles-
may be forced through the filter medium resulting in ineffective
treatment.
    (c) Use of coagulants.  Coagulants and filter aids may be mixed with
filter feed prior to filtration.  Their effect is particularly
significant for vacuum  filtration in that it may make the difference  in a
vacuum filter between no cake and a relatively dry cake.  In a pressure
filter, coagulants  and  filter aids will also significantly improve
hydraulic capacity  and  cake dryness.   Filter aids, such as diatomaceous
earth, can be precoated on filters  (vacuum or  pressure) for  particularly
difficult to filter sludges.  The precoat layer acts somewhat like  an
in-depth  filter  in  that sludge  solids  are trapped in the precoat pore
                                     117

-------
spaces.  Use of precoats and most coagulants or filter aids significantly
increases the amount of sludge solids to be disposed of.   However,
polyelectrolyte coagulant usage usually does not increase sludge volume
significantly because the dosage is low.
3.3   Performance Data
3.3.1    BOAT List Organics Treatment Data
    The Agency collected nine data sets (untreated and treated waste
data) to characterize the treatment performance of rotary kiln
incineration on K001.  Six of these data sets are from K001 wastes from
wood preservation processes using creosote based preservative chemicals
and three are from K001 wastes containing pentachlorophenol.   The data
presented include BOAT list volatile, semivolatile, and metal
constituents detected in the untreated K001, the ash  (nonwastewater
residual),  and scrubber water  (wastewater residual) from rotary kiln
incineration.  Tables 3-1 through 3-9 present the nine data sets for the
BOAT list constituents detected  in the  untreated and  treated waste
samples  from rotary  kiln incineration.  Operating data collected during
the  incineration  test burns are  presented  in Tables 3-10 to 3-13.
3.3.2     BOAT  List Metals Treatment  Data
     The  Agency does  not  have  performance data  specifically for  treatment
of the BOAT list  metals  in  the ash and  scrubber water generated from
rotary kiln incineration of K001.  However,  EPA does  have  treatment
performance data  on  wastes  that  the  Agency  believes are  sufficiently
                                     118

-------
similar to these residuals with regard to parameters affecting treatment
selection.  In these cases, the treatment performance data for BOAT list
metals in similar wastes were available for transfer for the development
of BOAT treatment standards for K001.
    (1)  Wastewater residuals.  The performance data that the Agency has
for wastewaters include 11 data sets from the Onsite Engineering Report
for Envirite Corporation.   We believe these data can be used to transfer
levels of performance because they contain the constituents of concern in
concentrations at least as high as the concentrations expected to be in
K001 scrubber water.  These data are presented in Table 3-14.
    (2)  Nonwastewater residuals.   The performance data for stabilization
of K001 nonwastewater residuals were transferred from stabilization of
F006.   EPA examined all available treatment performance data from wastes
that are considered to be similar with regard to the parameters affecting
treatment selection.  Based on the BOAT list metals present in the
untreated waste and the treated residuals, as well as the waste
characteristics of the residuals treatment data were identified from
wastes similar to K001 treated scrubber water residuals and incinerator
ash.  F006 are the wastewater treatment sludges from electroplating which
the Agency believes to be similar to the nonwastewaters from treatment of
K001 wastewaters and incinerator ash.  These treatment performance data
are presented in Tables 3-15 to 3-17.  The BOAT list metals present in
K001 nonwastewater residuals are generally lower in concentration than
                                    119

-------
the BOAT list metals in F006.  Further, the metals in K001 residuals are
likely to be present in the oxide form since they have resulted from an
incineration process.  Metals in F006 are typically in the hydroxide
form.  The Agency believes that metals in the form of oxides are more
readily immobilized (less Teachable) than metals in the form of
hydroxide.  For these reasons the Agency believes that treatment
standards for F006 can be attained even more readily for K001
nonwastewater residuals.
                                     120

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1711g/p.8
          Table 3-1  Rotary kiln Incineration of K001 - Creosote

                             Sample Set No  1



BOAT List
Const ituent


Untreated
waste
(ppb)
Treated
nonwastewater
(ash)
Total
(ppb)

Treated
wastewater
( scrubber water]
(ug/1)
Volatile Orqanics

Benzene
Toluene
Ethyl benzene
Xylenes
 56
110
 57
120
<50
<50
<50
<50
<50
<50
<50
<50
                        Untreated
                          waste
                          (ppm)
            Treated
          nonwastewater
             (ash)
             Tota'
             (ppm)
               Treated
              wastewater
           (scrubber water)
                (ug/1)
Semivolati le Organics

Acenaphthalene            <4600
Acenaphthene             2!,OOC
Anthracene               15,000
Chrysene                   4800
Fluorene                 15,000
Naphthalene              42,000
Phenanthrene             41,000
Phenol                     2400
Pyrene                   17,000
                 -1  15
                 
-------
l/llg./p 9
                             Table  3-1   (continued)

                                Sample  Set  No   1
BOAT List
Constituent
Untreated
  waste
  (ppm)
     Treated
nonwastewater (ash)
Total        TCLP
(ppm)       (mg/1)
    Treated
   wastewater
(scrubber  water)
     (mg/1)
Metals
Antimony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Selenium
Si Iver
Thall lum
Vanadium
Zinc
<17
2 6
63
^Q 5
3.4
5 0
35
0.35
2 1
170
i 5
0 5
7 7
<4 0
170
<17
5.3
81
<0.5
<2.0
6 1
86
<1 25
3 6
<21
2 3
<3 5
<2 5
4 4
1 9
0 035
<0 020
0 38
<0.005
0.020
<0 035
0.020
<0 0025
<0 075
<0 21
<0.020

-------
1711g/p 10
          Table 3-2  Rotary Kiln Incineration of K001 - Creosote

                             Sample Set No. 2
BOAT List
Constituent
                        Untreated
                          waste
                          (ppb)
  Treated
nonwastewater
   (ash)
   Total
   (ppb)
    Treated
   wastewater
(scrubber water)
     (ug/1)
Volat 11e Orqamcs
Benzene
Toluene
Ethyl benzene
Xylenes

60
120
56
13C
Unt reated
waste
(ppm)
-50
-50
<50
Treated
nonwastewater
(as")
Tot a',
(ppm)
<50
<50
<50
<50
Treated
wastewater
(scrubber water)
(ug/1)
Seirnvolat 11e Orqanics

Acenaphthdlene             100G
Acenaphthene             15,000
Anthracene                  7300
Chrysene                   4200
Fluorene                 12,000
Naphthalene              40,000
Phenanthrene             32,000
Phenol                     3700
Pyrene                   13,000
       --1.15
       -0 65
       <0 65
       <0.85
       <0 65
       -0 55
       <1.80
       <0.50
       <0.65
                                                               <20
                                                               ^30
                                    123

-------
                            Table 3-2   (continued)





                               Sample  Set  No   2
BOAT List
Constituent
Metals
Ant imony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Selenium
Si Iver
Thai 1 lum
Vanadium
Zinc
Untreated
waste
(ppm)

<17
<2 0
56
<0 5
5 4
4 &
32
C 35
-7 5
160
1 4
<3 5
« 0
<-4 0
170
Treated Treated
nonwastewater (ash) wastewater
Total TCLP (scruboer water)
(ppm) (mg/1) (mg/1)

--17
5 3
74
<0 5
<2.0
5 3
100
-'1 25
4.o
-21
1 9
<3 5
<2.5
4 1
1 8

--0 17
<0 02
0 57
<0.005
-0 02
<0 035
0 030
<0 OC25
-0 075
<0.21
<0 02
<0 035
<0 025
<0 04
0 050

<0 170
0 15
0.80
<0.005
-0.99
0 74
0 50
0 06C
0.5i
4 5
0 11
0 010
2.4
0.060
7.1
Reference.   Onsite  Engineering Report for KOOl-Creosote
                                   124

-------
1711g/p 12
          Table 3-3  Rotary kiln Incineration of kOOl - Creosote

                             Sample Set No  3
BOAT List
Constituent
                        Untreated
                          waste
                          (ppb)
  Treated
nonwastewater
   (ash)
   Totdl
   (ppb)
    Treated
   wastewater
(scrubber  water)
     (ug/1)
Volatile Orqanics
Benzene
Toluene
Ethyl benzene
Xylenes





61
100
55
120


Untreated
waste
(ppm)
<50
<50
<50
<50
Treated
nonwastewater
(ash)
Tota 1
(ppm)
<50
<50
<50
<50

Treated
wastewater
(scrubber water)
(•ug/1)
Sermvolatile Qrqanics

Acenaphthalene            '4600
Acenaphthene             19,000
Anthracene               12,000
Chrysene                   4800
Fluorene                 16,000
Naphthalene              40,000
Phenanthrene             37,000
Phenol                     3600
Pyrene                   16,000
       <1 15
       <0.65
       <0 65
       -0 85
       <0 65
       <0 55
       <1.80
       
-------
1711g/p 13
Metals
                             Table  3-3   (continued)





                                Sample  Set No  3


BOAT List
Const ituent

Untreated
waste
(ppm)
Treated
nonwastewater (ash)
Total TCLP
(ppm) (mg/1)
Treated
wastewater
(scrubber water)
(mg/1)
Ant imony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium
Copper-
Mercury
Nickel
Lead
Selenium
Si Iver
Thallium
Vanadium
Zinc
<17
2 1
70
-0 5
"; i
6 4
39
-I 25
2 1
15C
1 2
*- o 5
6 8
<4 0
160
<17
9.0
61
<0.5
<2 0
5.8
98
<1 25
5 0
<21
l.b
<3.5
<2 5
4.1
3.2
0 040
<0.02
0.53
<0.005
<0 02
<0 035
0.030
<0.002S
0 020
<0 21
<0.020
<0.035
<0 025
<0 040
0.080
<0 17
0 16
0 56
0.001
0 95
0 60
0 43
O.OOb
0 56
3 5
0 090
0 010
2 6
0 040
9 1
Reference.   Onsite Engineering  Report  for  KOOl-Creosote.
                                    126

-------
1711g/p.l4
          Table 3-4  Rotary Kiln  Incineration of K.001 - Creosote

                             Sample Set No  4
BOAT List
Const nuent
                        Untreated
                          waste
                          (ppb)
               Treated
             nonwastewater
                (ash)
                Total
                (ppb)
              Treated
             wastewater
          (scrubber  water)
               (ug/1)
Volat i le Organ icr.
Benzene
Toluene
Ethyl benzene
Xylenes
                             51
                            110
                             72
                            130
                   <50

                   <50
                   <50
                  <50
                  <50
                  <50
                  <50
                        Untreated
                          waste
                          (ppm)
                                        Treated
                                      nonwastewater

                                         Total
                                         (ppm)
                                  Treated
                                 wastewater
                              (scrubber  water
                                   (ug/1)
Semivolat i le Orqanicr.
Acenaphthalene
Acenaphthene
Anthracene
Chrysene
F luorene
Naphthalene
Phenanthrene
Phenol
Pyrene
 <4600
16,000
  8500
  4100
14.000
32.000
29,000
  3900
12,000
--1 15
-0 65
<0 65
<0 »5
<0 65
<0 55
•-1 80
<0 50
<0.65
                                                               •<30
                                    127

-------
mig/p  15
                            Table 3-4  (continued)





                               Sample Set No  4
BOAT List
Const ituent
Metals
Ant imony
Arsen ic
Barium
Beryl 1 lum
Cadmium
Chroinum
Copper
Mercury
Nickel
Lead
Selen urn
S i Iver
Thai 1 lum
Vanadium
Zinc
Untreated
waste
(ppm)

<17
2 5
59

-------
1711g/p 16
          Table 3-5  Rotary kiln Incineration of K001 - Creosote

                             Sample Set No. 5
BOAT List
Coiibt i tuent
                        Untreated
                          waste
                                        Treated
                                      nonwastewater
                                         (ash)
                                         Total
                                         (ppb)
              Treated
             wastewater
          (scrubber  water)
               (ug/D
Volatile Orqanics
Benzene
Toluene
Ethyl benzene
Xy lenes

58
110
71
130
Untreated
waste
(ppm)
<50
<50
<50
<50
Treated
nonwastewater
(ash)
Total
(ppm)
<50
<50
<50
<50
Treated
wastewater
(scrubber water)
(ug/1)
Semivoldtile Orqanics

Acenaphthalene            <4600
Acenaphthene             19,000
Anthracene                  7400
Chrysene                   4200
Fluorene                 16,000
Naphthalene              29.000
Phenanthrene             32,000
Phenol                     2400
Pyrene                   15,000
<1  15
<0  65
<0.65
<0  85
<0.65
<0  55
<1.80
<0.50
<0  65
                                                               <20
                                                               <30
                                   129

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mig/p 17
Metals
                            Table 3-5   (continued)





                               Sample Set No  5
BOAT List
Constituent
Untreated
waste
(ppra)
Treated
nonwastewater (ash)
Total TCLP
(ppm) (mg/1)
Treated
wastewater
(scrubber water)
(mg/1)
Ant imotiy
Arsenic
Barium
Beryl 1 ium
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Selenium
S i iver
Tha 1 1 ium
Vanadium
Zinc
<17
0 7
12
<0 5
0.79
1 6
12
0 79
1 6
37
0 3
-3 5
2.2
<4.0
40
<17
13
56
<0.5
<2 0
10
130
<1.2S
6 8
<21
2 6
<3.5
<-2 5
5 2
3 0
0 040
0.025
0.22
<0 005
<0 020
<0 035
0 008
<0 0025
<0 075
<0.210
0 004
-0 035
^0 025
0 020
0 030
<0 170
0 25
0 90
0.002
0 45
0 65
0.45
0 19
0 70
3.3
C 03a
0 010
3.6
0.050
8.2
 Reference-  Onsite Engineering Report for KOOl-Creosote
                                    130

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1711g/p.l8
          Table  3-6  Rotar> Kiln  Incineration of K001 - Creosote
                              Sample  Set No  6
BOAT List
Constituent
                        Untreated
                          waste
                          (ppb)
               Treated
             nonwastewater
                (ash)
                Total
                (ppb)
              Treated
             wastewater
          (scrubber water)
               (ug/1)
Volatile Organics
Benzene
Toluene
Ethyl benzene
Xylenes
                             83
                            170
                             87
                            170
                   <50
                   <50
                   <50
                   <50
                  <50
                  <50

                  <50
                        Urit-eated
                          i.'iste
                          (ppm)
                                        Treated
                                      nonwastewater
                                         (ash)
                                         Total
                                         (ppm)
                                  Treated
                                 wastewater
                              (scrubber wate-
                                   (ug/1)
Semivo kit i le Orqanics
Acenapnthalene
Acenapnthene
Anthracene
Chrysene
Fluorene
Naphtha lene
Phenanthrene
Phenol
Pyrene
 -4600
17,000
  9100
  4300
14,000
4o,000
36,000
  3300
13,000
<1 15
<0 65
^0 65
<0 85
<0 65
<0 55
<1 60
<0 50
<0 65
                                                               <20
                                    131

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1711g/p.l9
Meta is
                             Table  3-6   (continued)





                                Sample  Set  No  6
BOAT List
Const i tuent
Untreated
waste
(ppm)
Treated
nonwastewater (ash)
Total TCLP
(ppm) (mg/1)
Treated
wastewater •
(scrubber water)
(mg/1)
Ant imony
Arsenic
Bar lum
Beryl " mm
Cadmiu™
Chromi um
Coppe-
Mercury
NiCNe 1
Leaa
Selen lum
Si Iver
Thai 1 lum
Vanadium
Zinc
<17
2.
150
<0
3.
8
38
0
4
190
1
<3
3
1
200

6

5
5
6

64
b

.1
5
3
.9

<17
11
72
<0
<2
7
86

-------
1711g/p 20
             Table 3-7  Rotary Kiln Incineration  of  K001  -  PCP

                              Sample Set No  7
BOAT List
Constituent
                Treated
Untreated     nonwastewater      Treated
  waste          Total          wastewater
  (ppb)          (ppb)            (ug/1)
Volat 11e Organ ics

Toluene
     16
                        Unt recited
                          waste
                          (ppm)
               Treated
              nonwastewater
                 Total
                 (ppm)
 Treated
wastev.ater
  (ug/1)
Sem i vc lat11e Orqanics

Acenapnthene             li.OOO
Anthracene                9,300
Benz(aJanthracene        
-------
1711g/p 21
                          Table 3-7  (continued)

                             Sample Set No. 7
BOAT List
Constituent
Untreated
  waste
  (ppm)
    Treated
 nonwastewater
Total     TCLP
(ppm)    (mg/1)
 Treated
wastewater
  (mg/1)
Metals
Ant unony
Arsenic
Barium
Beryl 1 lum
Cadmium
Cnrom i urn
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai 1 ium
Vanadium
Zinc
<30
2 9
30
<0 5
0.5
1.5
6.7
7.6
0.11
<10
<2 5
< A ^

-------
1711g/p 22
             Table 3-8  Rotary Kiln Incineration  of  K001  -  PCP

                              Sample Set No  8
BOAT List
Constituent
                Treated
Untreated     nonwastewater     Treated
  waste          Total          wastewater
  (ppb)          (ppb)            (ug/1)
Volati1e Orqanics

Toluene
                             10
                        Un* -eated
                          (ppm)
                Treated
              nonwastewatei"
                 Total
                 (ppm)
 Treated
wastewater
  (ug/ 1)
Semivo1ati1e Orqamcs
Acenaptnene              It, 000
Antnracene               1J.OOO
Benz(a (anthracene         :,400
Benzo(a)pyrene              940
Benzo( b &/or K)
  f luroanthrene           .-,300
Chrysene                  . ,600
F luoranthrene            21,000
Fluorene                 12,000
Naphthalene              43,000
Pentachlorophenol         3,000
Phenanthrene             42,000
Pyrene                   15,000
                     <2 5
                     <2 5
                     <2 5
                     <2 5

                     <2 5
                     <2 5
                     <2.5
                     <2 5
                     <2 5
                    <12 5
                     <2 5
                     <2 5
        <50
        <50
        <10
        <50

        <50
        <50
        <50
       <250
        <50
                                    135

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1711g/p.23
                          Table 3-8  (continued)

                             Sample Set No  8
BOAT List
Constituent
Untreated
  waste
  (ppm)
    Treated
 nonwastewater
Total     TCLP
(ppm)    (mg/1)
 Treated
wastewater
  (mg/1)
Metals
Antimony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai 1 lum
Vanadium
Zinc
<30
2.3
19
<0 5
0 6
2 7
11
11
0 16
<10
<2 5
<4 5
<1.5
<10
58
<30
0.6
21
<0 5
<1 5
1 1
3.0
1 2
<0 001
<10
-2 5
<4 5
<1 5
<10
2.1
<0.3
<0.015
0.19
<0.005
<0.015
<0.045
<0.05
<0 01
<0 001
<0.1
<0.025
<0 045
<0 05
<0.1
<0.03
<0 3
0 12
0 24
<0 005
<0 015
<0 045
0 09
0 16
<0 001
<0 1
<0 025
^0 045
<0 015
<0 1
0 61
Reference:  Onsite Engineering Report  for KOOl-Pentachlorophenol
                                   136

-------
1711g'p 24
             Table 3-9  Rotary Kiln Incineration  of  K001  -  PCP

                              Sample Set No  9
BOAT List
Constituent
                Treated
Untreated     nonwastewater     Treated
  waste          Tota'l          wastewater
  (ppb)          (ppb)            (ug/1)
Volati1e Orqanics

Toluene
     39
                        Untreated
                          uaste
                           Jppm)
                Treated
              nonwastewater
                 Total
                 (ppm)
 Treated
wastewater
  (ug/1)
 Semivolatile Orqanics

 Acenapthene               14,000
 Anthracene                 3,500
 Benz(a)anthracene          2,500
 Benzo(a)pyrene               620
 Benzotb  &/or k)
   fluroanthrene            1,600
 Chrysene                 -:,500
 Fluoranthrene             15,000
 Fluorene                  9,000
 Naphthalene               37,000
 Pentachlorophenol            920
 Phenanthrene              32,000
 Pyrene                   11,000
                     <2.5
                     <2 5
                     <2 5
                     <2.5

                     <2.5
                     <2 5
                     <2.5
                     <2 5
                     -2 5
                    <12 5
                     <2 5
                     <2 5
        <50
        <50
        <50
        <50
        <50
        <50
        <50
       <250
        <50
        <50
                                     137

-------
1711g/p 25
                          Table 5-9  (continued)

                             Sample Set No. 9
BOAT List
Constituent
                Treated
Untreated    nonwastewater      Treated
  waste     Total      TCLP     wastewater
  (ppm)     (ppm)     (mg/1)       (mg/1)
Metdh
Ant imony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium
Copper
Lead
Mercur>
Selenium
Si Iver
Thai 1 lum
Vanadium
Zinc
<30
1.1
17
<0.5
0.4
2 1
10
6.3
0.064
<2 5
<4 5
<1.5
-=10
30
<30
0 4
21
<0 5
<1 5
1 2
2
0 96
<0.001
<2.5
<4 5
<1.5
<10
2.1
<0.3
<0.015
0.25
<0.005
<0.015
<0.045
<0 05
<0.01
<0.001
<0 025
<0.045
<0.05
<0.1
<0.03
<0.3
0 11
0 39
<0 005
<0.015
0.045
0 07
0 20
0.003
<0 025
<0 045
<0.015
<0.1
0.88
Reference   Onsite Engineering Report for KOOl-Pentachlorophenol.
                                    138

-------
        1948g
                                             Table  3-10   Incinerator Operating Data for K001 - Creosote Sample Set Number 1 and 2
LO
VO
Parameter
10/5/87
Ki In shakedown
(before K001-C feed)
10/6/87
Start feed 11:03
Begin test 12:10
12:30
13-00
13:30
13 40

14:00
14:30
15.00
15-25

KOOl-creosote
feed rate,
Sample col lected Ib/h

Scrubber pretest water 0


180
Feed (a) 180
180
180
180
Ash 180
Recycle (b)
Feed (a) 180
180
180
Ash 180
Recycle (b)
Temperature, °F
Ki In

1720-1917



1694-1873
1771-1886
1828-1863
1835-1874
1835-1838

1790-1860
1800-1913
1838-1906
1795-1838

Afterburner

1984-2019



1932-2016
2008-2031
2014-2031
2014-2035
2030-2033

1996-2033
1996-2034
2019-2035
2006-2019

Kiln
rotation
speed, rpm

0 25


0.25
0.25
0.25
0.25
0 25
0.25

0.25
0.25
0.25
0.25

Stack qas concentrations
02, 7





4-9
4-12
4-20
5-8
6-8

5-9
5-8
6-8
7-9

CO, ppm





12-27
22-32
18-33
30-34
32-34

32-37
32-37
34-37
30-37

C0?. 7-





8-12
3-11
5-12
1-11
9-10

8-11
9-11
8-11
8-10

        (a) The feed samples were collected while the fiber packs were being packed.   Six drums were used for the two days of testing.  K001-C waste from two drums
           was incinerated for each sample set.

        (b) The scrubber recycle tank was not blown down during the test series.   Makeup water was added to replace water loss through the exhaust system.   No
           chemicals were added to the scrubber water system.   The recycle water samples were taken from the scrubber recirculation line.

        Reference   Onsite Engineering Report for KOOl-Creosote

-------
1948g
                                     Table 3-11   Incinerator  Operating  Data  for  K001  -  Creosote  Sample Set  Number 3 and 4
    Parameter
Sample collected
                                              KOOl-creosote
                                              feed rate,
                                              Ib/h
                                               Temperature,  ' F	
                                                Ki In       Afterburner
Ki In
rotation
speed,  rpm
02,  /
       Stack gas concentrations
CO, ppm
C02,  /
10/6/87
Continued feed
17 10
17 30
18:00
18-30
18:40

19:00
19-30
2 -00
20:15
Feed (a)



Ash
Recycle (b)
Feed (a)

0 Recycle (b)
Ash
180
180
180
180
180

180
180
180
180

1775-1840
1827-1875
1R27-1875
1822-1871

1819-1826
1825-1878
1859-2028
1824-1859

1985-2002
2002-2026
2007-2026
1993-2009

1993-1997
1997-2008
1995-2093
1986-1995
0 25
0 25
0 25
0 25
0.25

0 25
0 25
0 25
0.25

6-10
6-9
6-9
7-9

7-9
7-9
4-9
7-10

39-42
31-42
39-41
39-41

37-41
31-42
39-720
35-38

8-10
8-11
8-10
8-9

8-10
8-11
8-13
8-10
(a) The feed samples were collected while the fiber packs  were  being  packed.   Six  drums  were  used  for  the  two  days  of  testing.   K001-C waste from two drums
    was incinerated for each sample set.

(b) The scrubber recycle tank was not blown down during  the  test  series   Makeup water was  added to  replace  water  loss through  the  exhaust  system   No
    chemicals were added to the scrubber  water system   The  recycle water samples  were taken  from  the  scrubber  recirculation  line.
Reference:   Onsite Engineering Report for KOOl-Creosote.

-------
1948g
                                     Table  3  12   Incinerator  Operating  fj.ita  for  K001  -  Creosote  Sample  Set  Number 5 and C


Parameter
10/7/87
Start feed 11.00
Begin test 11 30
12-00
12.30

13:00
13:30
14-00
14 30
14 45

15 00
KOOl-creosote
feed rate,
Sample collected Ib/h

180
Feed (a) 180
180
Ash 180
Recycle (b)
Feed (a) 180
180
180
180
Ash 180
Recycle (b)
180

Temperature
Ki In


180C 1841
1823-1912
1830-1886

1845-1910
1829-1845
1827-1838
1827-1857
1844-1899

1896-1900

, "f
Afterburner


201?-2020
2017-2039
2019-2025

2011-2025
1999-2011
1997-2009
1999-2022
2022-2034

202C-2033
Ki In
rotation
speed, rpni

0 25
0 25
0.25
0 25

0.25
0 25
0 25
0 25
0 25

0 25


o?, -/


4-8
2-9
4-8

5-9
6-9
7-9
7-9
5-8

5-9

Stack qas concentrat
10, ppm


15-18
15-30
17-24

19-25
18-22
18-22
15-23
22-25

22-25

ions
co2, •/


9-12
9-13
9-11

9-10
9-10
9-10
9-10
9-10

9-11
(a) The feed samples were collected while  the  fiber  packs  were  being  packed    Six  drums  were  used  for  the  two  days  of  testing   K001-C  waste from two drums
    was incinerated for each sample set

(b) The scrubber recycle tank was not  blown  down  during  the  test  series    Makeup water was  added to  replace  water loss through the exhaust  system   No
    chemicals were added to the scrubber water  system.   The  recycle water  samples  were taken  from  the  scrubber recirculation line.

Reference:   Onsite Engineering Report  for  K001-Creosote.

-------
1947g
                               Table 3-13  Incinerator Operating Data for K001-PCP
                                                Sample Sets  #7  -  #9
                                                   Sample Set  #7
Sample
Parameter collected
6/26/87
Start feed (86 Ib/h) Feed (a)
drum #1 15 30 Makeup water
15 45
16 00
16 15
16 30
16 45
17 00
17 15
17 30
17 45
18 00
18 15
18 30 (b)
18 45 (b)
19 00 (b)
19 15 (b) Slowdown
Ash (c)
Temperature, 4 IF
Kiln




1650-1682
1720-1503
1767-1826
1777-1820
1801-1873
1813-1899
1793-1936
1861-1914
1823-1914
1782-1892
1877
1924
1970
2046

Afterburner




1840-1869
1823-1866
1869-1875
1872-1879
1876-1895
1889-1903
1890-1914
1885-1912
1868-1888 .
1859-1871
1839
1846
1857
2033

Kiln rotation
speed, rpm




0.2
0.2
0.2
0.2
0.2
0.2
0 2
0 2
0 2
0 2
0.2
0.2
0.2
0.2

Stack qas concentrations
02, %




5-9
5-8
5-9
6-8
5-8
4-9
4-9
6-8
5-16
4-16
3-8
3-8
3-9
3-10

CO, ppm C02, %




<1 4->10
<1 7->10
<1 6->10
<1 8-10
<} 9->10
<1 8->10
<1 8->10
<1 S->10
<1 ' 9->iO
<1 9->10
<1 8->10
<1 8->10
<1 8->10
<1 8->10

 (a)   The feed  samples were collected while the fiber packs were being packed   Sample number CK01P-1-AX'represents
      feed fed  to the kiln during sample set 7, sample number CK01P-2-AX represents feed to the kiln during sample
      set 8, and sample  number CK01P-3-AX represents feed to the kiln during sample set 9

 (b)   Only one  temperature value was available during this time period.

 (c)   The ash samples were collected from the ash bin after the ash cooled.

 Reference   Onsite  Engineering Report  for KOOl-Pentachlorophenol.
                                                           142

-------
1897g
Total organic carbon
Total solids
Total chlorides
Total organic halides
                                                   Table  3-14   Performance  Data  for  Chemical  Precipitation
                                                              and Filtration  on Mixed Waste Sampled by EPA
Concentration (ppm)
Constituent/parameter
BOAT Metals
Ant imony
Arsenic
Bar lum
Beryll lum
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai lium
Zinc
Other Parameters
Sample
Treatment
tank composite

<10
<1
<10
<2
13
893
2.581
138
64
<1
471
<10
<2
<10
116

Set #1
Filtrate

<1
<0 1
<1
<0.2
cQ.5
0.011
0 12
0 21
<0 01
<0.1
0.33
<1
<0 2
<1
0 125

Sample
Treatment
tank composite

<10
<1
<10
<2
10
807
2,279
133
54
<1
470
<10
2
'10
4

Set #2
Filtrate

<1
<0 1
'1
<0 2
<0.5
0.190
0 12
0 15
<0 01
<0.1
0 33
<1
<0 2
<1
0 115

Sample
Treatment
tank composite

<10
<1
<10
<2
<5
775
1,990
133
<10
<1
16,330
<10
<2
<10
3 9

Set i»3
Filtrate

<1
<0.1
3 5
<0 2
<0.5
a
0 20
0 21
<0 01
<0 1
0.33
<1
'0 3
<1
0 140

Sample Set #4
Treatment
tank composite Filtrate

<10
<1 <1
<10 <10
<2 <2
<5 <5
06 0 042
556 0 10
88 0 07
<10 <0 01
<1 <1
6,610 0 33
<10 <10
<2 <2
<10 <10
84 1 62

2700
2500
                               2800
                               3600
                                                                                                 500
                                                                                                                                2900
                                                                                                900

-------
1897g
                                                                   Table  3-14   (Continued)
Concentration (ppm)
Const ituent/parameter
BOAT Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thall lum
Zinc
Other Parameters
Sample
Treatment
tank composite

<10
<1
<10
<2
<5
917
2,236
91
18
1
1.414
<10
<2
<10
71

Set #5
Filtrate


-------
 1897g
                                                                    Table 3-14  (Continued)



Const ituent/parameter
BOAT Metals
Ant imony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai 1 lum
Zinc

Sample
Treatment
tank composite

<10
<1
<10
<2
<5
0.07
939
225
<10
<1
940
<10
<2
<10
5

Set *9

Filtrate

<1
<0 1
<1
<0 2
<0 5
0.041
0.10
0.08
<0.01
<0.1
0 33
<1.0
<0.2
<1.0
0.06

Sample
Treatment
tank composite

<10
<1
<10
<2
<5
0.08
395
191
<10
<1
712
<10
<2
<10
5
Concentrat
Set #10

Filtrate

<1
<0.1
<1
<0.2
<0,5
0.106
0.12
0 14
<0.01
<0 1
0.33

-------
1897g
                                       Table 3-15  EPA  Collected  Total  Composition  Data  for  Untreated F006 Waste
Constituent
#1
Barium
Cadmium
Chromium
Copper
Lead
Nickel 435
Silver
Zinc 1560
Concentration in
#2
„
31.3
755
7030
409
989
6 62
4020
#3
85 5
67.3
716
693
257
259
38 9
631
#4

1 31
--
1510
88 5
374
9 05
90200
Raw Waste Sample - F006 (ppm)
#5
14.3
720
12200
160
52
701
5 28
35900
#6

7.28
3100
1220
113
19400
4.08
27800
#7

5.39
42900
10600
156
13000
12 5
120
#8
15.3
5.81
--
17600
1.69
23700
8.11
15700
#9
19 2
--
--
27,400
24,500
5730
--
322
 1 - Wastewater treatment sludge cake - no free liquid
 2 - Site closure excavation mud at auto part manufacturer.
 3 - Waste treatment sludge from aircraft overhaul facility.
 4 - Zinc electroplating sludge.
 5 - Filter cake from electroplating wastewater treatment
 6 - Sludge from treatment of Cr. Cu, Ni, and Zn plating
 7 - Wastewater treatment sludge from plating on plastics
 8 - Wastewater treatment sludge
 9 - To be provided
Reference:  CWM Technical Note 87-117.
The waste sample is a mixture of F006 and F007.
 The waste sample is a mixture of F006,  D006, D007, and D008.

-------
1897g
                              Table 3-16  EPA Collected TCLP  Data  for  Untreated F006 Waste3
Const ituent
#1 ff2
Barium
Cadmium
Chromium
Copper
Lead
Nickel
S i Iver
Zinc

2.21
0 76
368
10 7
0.71 22 7
0.14
0 16 219
»3
1 41
1 13
0.43
--
2 26
1.1
0.20
5 41
f 4

0.02
--
4.62
0 45
0 52
0 16
2030
TCLP Concentration (ppm)
#5 f6 . f7 »8
0 38
23.6
25 3
1 14
0 45
9 78
0 08
867

0.03
38.7
31 7
3 37
730
0.12
1200

0.06
360
8 69
1 0
152
0.05
0.62
0 53
0 18
--
483
4 22
644
0 31
650
»9
0 28
--
--
16 9
50 2
16 1
--
1 29
 See Table 3-15 for sample descriptions.





Reference   CWM Technical Note 87-117
                                                              147

-------
1897g
                           Table 3-17  EPA Collected TCLP  Data  for  F006  Stabilized Residues3
     Constituent
                #1
   Concentration (ppm)
#5           #6
#7
Mix ratio 0.2
Barium
Cadmium
Chromium
Copper
Lead
Nickel 0 04
Silver
Zinc 0 03
0.5
-_
0.01
0.39
0.25
0.36
0.03
0.05
0 01
0.2
0.33
0.06
0 08
--
0 30
0 23
0 20
0.05
1 0
--
0.01
--
0 15
0 21
0 02
0 03
0 01
0.5
0.23
0.01
0.03
0.27
0 34
0.03
0.04
0.04
0.5
_-
0.01
0.38
0 29
0.36
0.04
0.06
0.03
0.5
-_
0.01
1.21
0.42
0.38
0.10
0.05
0.02
0.5
0 27
0.01
--
0.32
0.37
0.04
0.05
0.02
0.5
0.08
--
--
0 46
0 27
0 02
--
<0.01
aSee Table 3-15 for sample descriptions of  all  of  the  samples of  raw waste.

Reference   CWM Technical Report 87-117
                                                              148

-------
             4.  IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE
                TECHNOLOGY (BOAT) FOR K001

    This section presents the Agency's methodology for identifying the

best demonstrated available technology (BOAT) for treatment of K001 based

on the performance data presented in Section 3.  The demonstrated

technologies for treatment of BOAT list organic constituents present in

K001 wastes are incineration and fuel substitution.  For BOAT list metals

in nonwastewater forms such as scrubber water treatment nonwastewater

residuals and incinerator ash, the demonstrated treatment technology is

stabilization.  Chemical precipitation and filtration is the demonstrated

treatment train for BOAT list metals in wastewater forms of K001 such as

scrubber water from incineration.

    As stated in the Introduction, BOAT is selected based on treatment

performance data available to the Agency.  Prior to being used to

establish treatment standards, performance data are screened to determine

whether they meet the requirements of the BOAT program.  First, the

design and operating data collected  for each data  set are examined, and

data points or data sets that reflect a poorly designed treatment system,

or a system that was not well operated at the time of data collection,

are not used  in the development  of treatment standards.  In addition,

data are screened with regard to the quality assurance/quality control

measures (QA/QC) and whether the appropriate analytical methods were used

to assess the performance of the treatment technology.  All remaining

performance data are then adjusted based  on  analytical recovery
                                    149

-------
values, which, in turn are based on laboratory quality assurance/quality
control analyses in order to take into account analytical  interferences
associated with the chemical makeup of the sample.   Finally, in cases
where the Agency has performance data on treatment  of a listed waste
using more than one demonstrated technology,  the treatment values are
compared by the analysis of variance test (ANOVA),  as presented in
Appendix A.  This test will determine if one technology performs
significantly better than another.  This was not the case with K001,
since data from only one treatment technology were  available.
4.1    Review of Performance Data
    The available treatment data described in Section 3.0 were reviewed
and assessed with regard to the design and operation of the treatment
systems, the analytical testing, and the quality assurance/quality
control analyses of the data.  In general, all of the performance data
collected for rotary kiln incineration of K001 were of sufficient quality
to develop treatment standards.  Design and operating data were collected
for the rotary kiln incineration systems used for destroying BOAT list
organic constituents in K001 wastes.  These data indicate that the
systems were well designed  and well operated during the test burns.  In
addition, the proper analytical tests were performed for the untreated
wastes and the treated residuals.  Specifically, because incineration  is
a destruction technology for organics, total constituent concentration of
organics is used to measure treatment performance.
                                     150

-------
    In one instance, the analytical quality assurance/quality control



data collected during the analyses of the K001 incineration samples were



not of sufficient quality for use in developing BOAT treatment



standards.  Specifically, the matrix spike recoveries for



pentachlorophenol in the scrubber water from the K001-PCP test burn were



below acceptable limits  (20%), and therefore, could not be used to



develop treatment standards.  In this case, recovery data for



pentachlorophenol in the scrubber water were transferred from the most



appropriate source, KOOl-creosote.  Section 6 of this document presents



the recovery data used in each case and Appendix B contains all recovery



data developed for K001 waste.



    The performance data transferred from stabilization testing of F006



contained the required data on design and operation, QA/QC, and the



proper analytical testing (total composition and TCLP for the untreated



waste and TCLP for the treated waste).  These treatment data were used in



the development  of treatment  standards for K001.  None of the eleven data



sets for treatment of the wastewaters by chemical precipitation and



filtration were  deleted.  Design and operating data collected during the



sampling of this treatment  system did not indicate that the system was



poorly designed  or operated.  In addition, analyses were performed for



total composition  in the untreated wastes as well as the treated waste.



However, matrix  spike recovery data were not available for the BOAT  list-



metal constituents  in these waste  streams.  Matrix spike recovery data
                                     151

-------
were transferred from the Onsite Engineering Report for Horsehead
Resource Development Co. for K061.  The recovery data from the TCLP
extracts of the treated K061 residuals were used because the waste
matrices were determined to be similar.
4.2    Accuracy Correction of Performance Data
    After the screening tests, EPA adjusted the data values based on the
analytical recovery values in order to take into account analytical
interferences associated with the chemical makeup of the treated sample.
In developing recovery  data (also referred to as accuracy data), EPA
first analyzed the  sample for a constituent and then added a known amount
of the  same constituent  (i.e., spike)  to  the waste material.  The total
amount  recovered after  spiking minus  the.initial concentration  in the
sample  divided by the  amount  added is  the recovery value.
     In  general, a matrix  spike recovery  is determined  from the  result  of
one  matrix  spike performed  for each  individual  constituent.  Such  is the
case  for  BOAT list  metals and selected BOAT list volatile and
semivolatile constituents.  However,  for constituents  for which no matrix
spike recovery was  performed, the recovery  data were determined from the
average matrix  spike  recoveries  of the appropriate group of  constituents
for  which recovery  data were  available.   For  example,  no matrix spike  was
performed for  xylenes;  the  matrix spike  recovery data  used  for  xylenes
were the  result  obtained by averaging the matrix  spike recoveries  for  all
BOAT list volatile  constituents  that had recovery  data.
                                     152

-------
    In one instance, the analytical quality assurance/quality control



data collected during the analyses of the K001 incineration samples were



not of sufficient quality for use in developing BOAT treatment



standards.  Specifically, the matrix spike recoveries for



pentachlorophenol in the scrubber water from the K001-PCP test burn were



below acceptable limits (20%), and therefore, could not be used to



develop treatment standards.  In this case, recovery data for



pentachlorophenol in the scrubber water were transferred from the most



appropriate source, KOOl-creosote.  Section 6 of this document presents



the recovery data used in each case and Appendix B contains all recovery



data developed for K001 waste.



    The performance data transferred from stabilization testing of F006



contained the required data on design and operation, QA/QC, and the



proper analytical testing (total composition and TCLP for the untreated



waste and TCLP for the treated waste).  These treatment data were used in



the development of treatment standards for K001.  None of the eleven data



sets for treatment of the wastewaters by chemical precipitation and



filtration were deleted.  Design and operating data collected during the



sampling of this treatment system did not indicate that the system was



poorly designed or operated.  In addition, analyses were performed for



total composition in the untreated wastes as well as the treated waste.



However, matrix spike recovery data were not available for the BOAT list-



metal constituents in these waste streams.  Matrix spike recovery data
                                    151

-------
were transferred from the Onsite Engineering Report for Horsehead
Resource Development Co. for K061.  The recovery data from the TCLP
extracts of the treated K061 residuals were used because the waste
matrices were determined to be similar.
4.2    Accuracy Correction of Performance Data
    After the screening tests, EPA adjusted the data values based on the
analytical recovery values in order to take into account analytical
interferences associated with the chemical makeup of the treated sample.
In developing recovery data (also referred to as accuracy data), EPA
first analyzed the sample for a constituent and then added a known amount
of the same constituent (i.e., spike) to the waste material.  The total
amount recovered after spiking minus the.initial concentration  in the
sample divided by the amount added is the recovery value.
    In general, a matrix spike recovery is determined from the  result of
one matrix spike performed for each  individual constituent.  Such is the
case for  BOAT list metals and selected BOAT list volatile and
semivolatile constituents.  However, for constituents for which no matrix
spike recovery was performed, the recovery data were determined from the
average matrix spike recoveries of the appropriate group of constituents
for which recovery data were  available.  For example, no matrix spike was
performed for xylenes;  the matrix spike recovery data used for  xylenes
were the  result obtained by averaging  the matrix spike  recoveries for all
BOAT list volatile constituents that had recovery data.
                                     152

-------
    Where matrix spikes were not performed for a BOAT list semivolatile



constituent, a matrix spike recovery for that constituent was calculated



based on semivolatile constituents for which there were recovery data for



two matrix spikes.  The lower of the two average matrix spike recoveries



of semivolatile constituents was used in this case.  For example, no



matrix spike recovery was performed for naphthalene, a base/neutral



fraction semivolatile.  The recovery data for naphthalene were developed



after averaging the matrix spike recoveries calculated for all



base/neutral fraction semivolatiles in both the first matrix spike and



the duplicate spike.  The lower average matrix spike recovery was



selected to calculate the correction factor for naphthalene.



    The accuracy correction factors are calculated from the recovery



data.  In general, the reciprocal of the lower recovery value, divided by



100, yields the correction factor.  The accuracy corrected values are



obtained by multiplying the uncorrected data value by the correction



factor.  These adjusted values were then used to calculate treatment



standards for BOAT list constituents as presented  in Section 6.



Appendix B presents the analytical methods and quality assurance/quality



control data used to develop the recovery values for each constituent.



4.3    BDAT for Treatment of Organics



    After analyzing the accuracy corrected data, EPA has determined that



rotary kiln incineration achieves a level of performance that represents



organic treatment by BDAT for K001.  EPA would not expect the level of
                                     153

-------
performance to be improved by other forms of incineration such as
fluidized bed or fixed hearth systems because rotary kiln incineration
destroyed BOAT list organics to concentrations below their detection
limits.  In addition, EPA believes that well-designed and well-operated
fuel substitution systems could not achieve better treatment since they
operate at approximately the same temperatures and turbulent conditions
as an incineration system.
    In addition to being the "best demonstrated" technology for BOAT list
organics in K001, rotary kiln incineration is also "available" because it
is commercially available or can be purchased from a proprietor,  and it
provides substantial  reduction of the concentration of the BOAT list
organics.  Because EPA has determined that rotary kiln incineration is
"best," "demonstrated," and "available," it is the technology basis for
treatment standards for BOAT list organic constituents present in K001
wastes.
4.4    BOAT for Treatment of Metals
    EPA has determined that stabilization achieves a level of performance
that represents treatment by BOAT for BOAT list metals in nonwastewater
K001 treatment residuals such as wastewater treatment nonwastewater
residuals and incinerator ash.  The Agency has no reason to expect that
the level of performance could be improved, since stabilization is the
only demonstrated treatment technology identified by EPA.  For BOAT list
metals in the wastewater residual, only one technology treatment  train
                                    154

-------
was identified as being demonstrated (i.e., precipitation and



filtration).  For BOAT list metals in scrubber water, therefore, this



treatment train is designated as BOAT.  The Agency has no reason to



expect that the level of performance for BOAT list metals in wastewaters



could be improved beyond the specified BOAT treatment level.



    Stabilization of the nonwastewater treatment residuals and filtration



of the wastewater are judged to be available to treat BOAT list metals



present in K001 treatment residues because the treatments are



commercially available or can be purchased from a proprietor and these



treatments provide substantial reduction of the concentration and/or



Teachability of hazardous metal constituents.  As a  result, stabilization



of K001 nonwastewater residuals and chemical precipitation and filtration



for K001 wastewaters are the technology basis for BOAT list metals in



K001 wastes.
                                     155

-------
                  5.   SELECTION OF REGULATED CONSTITUENTS
    This section presents the methodology and rationale for selection of
the constituents that are being proposed for regulation in wastewater and
nonwastewater forms of K001 wastes.
    As discussed in Section 1, the Agency has developed a list of
hazardous constituents (Table 1-1) from which the pollutants to be
regulated are selected.  The list is a "growing list" that does not
preclude the addition of new constituents as additional key data and
information parameters become available.  The list is divided into the
following categories:  volatile organics, semivolatile organics, metals,
inorganics other than metals, organochlorine pesticides, phenoxyacetic
acid herbicides, organophosphorus pesticides, PCBs, and dioxins and
furans.  Also discussed  in Section 1 is  EPA's process for selecting
constituents to regulate.  In general, this  process consists of
identifying constituents in the untreated waste that are present at
treatable concentrations and  then  regulating the constituents in that
group  necessary to ensure  effective treatment.  Below  is a discussion
that details how EPA  arrived  at the list of  constituents to be  regulated
for K001.
5.1       BOAT  List Constituents Detected in  Untreated  K001 Waste
    Of the  232  constituents  on  the BOAT  list,  31 were  detected  in  the
untreated  K001  waste.   Table  5-1  shows  the  specific  constituents that
were  analyzed  and  detected in the untreated  K001,  as well  as  the
detection  limits.   For the constituents  not  detected,  it was  assumed that
                                     156

-------
1962g
                Table 5-1  BOAT List Constituents in Untreated K001  Waste*
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
2B.
29.
224
225
226.
30.
227
31
214
32.
Parameter
Volatiles
Acetone
Acetomtrile
Aero le in
Aery lonitr i le
Benzene
Bromodichlorome thane
Bromomethane
n-Butyl alcohol
Carbon tetrachlonde
Carbon disulfide
Chlorobenzene
2-Chloro-l ,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethy 1 vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 , 2-Dibroii)o-3-chloropropane
1 ,2-Dibromoethane
Dibromomethane
Trans-1, 4-Dichloro-2-butene
Dichlorodif luoromethane
1 , 1-Dichloroethane
1 ,2-Dichloroethane
1 , 1-Dichloroethylene
Trans-1 , 2-Dichloroethene
1 , 2-Dichloropropane
Trans-1 ,3-Dichloropropene
cis-1 ,3-Dichloropropene
1 ,4-Dioxane
,?-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
Units

ppb
PPb
PPb
ppb
ppb
ppo
ppb
ppb
PPb
ppb
ppb
PPb
ppb
PPb
PPO
PPb
ppo
ppb
PPO
ppb
ppo
ppb
PPb
PPb
ppb
PPb
PPO
ppb
PPb
PPb
PPb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
PPb
D = Detected
ND = Not detected
NA = Not analyzed

ND
ND
ND
ND
D
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
ND
D
ND
ND
ND
ND
ND
Detection
1 imit

250
1000
2500
50
50
50
50
-
50
50
50
0 25
50
50
500
50
50
50
50
50
50
50
50
50
50
50
50
50
50
50
250
-
50
10
0.5
250
250
250
100
   Untreated K001 was sampled on two occasions and originally presented
   in two Onsite Engineering Reports (OER)    These data reflect the
   constituents detected in any of the samples while the detection limit
   listed is the highest of the two presented in the OERs for tCOCl

   No detection limit available.
                                            157

-------
                                 Table 5-1  (continued)
BOAT D = Detected
reference ND = Not detected
no ' Parameter Units NA = Not analyzed

33
228.
34
229
35
37
3b
230
39
40.
41
42
43
44
45
46
47
46
49
L 3 1 ,

c <-,
~> J
2!5
216
2i7.

51
52 .
C-,
54
55
56.
57.
58
59.
218
60
61.
62
Volatiles (continued)
Isobutyl alcohol
Met ha no 1
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyridine
1,1,1 ,2-Tetrach loroethane
1 , 1 , 2, 2-Tetrach loroethane
Tetrachloroethene
Toluene
Tribromomethane
1 , 1 , 1-Tr ich loroethane
1,1, 2 -Trich loroethane
Trichloroethene
Trichloromonof luoromethane
1 , 2 ,3-Tr ichloropropane
1 , 1 , 2-Trichloro-l , 2 , 2-\r if luoro-
ethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1,4-Xylene
Semivolat i les
Acenaphthalene
Acenaphthene
Acetophenone
2-Acety)aminof luorene
4-Amjnobiphenyl
Am 1 me
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene

ppb
ppb
ppb
PPb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
PPb
ppb
ppb
ppb
ppb
ppb
pph

ppb
ppb
ppb
ppb

ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm

ppm

ND
NA
ND
ND
ND
ND
ND
NA
ND
ND
ND
ND
D
ND
ND
ND
ND
ND
ND
NA

ND
D*
D*
D*

D
D
ND
ND
ND
ND
D
ND
D
NA
ND

D
Detection
1 imit

1
-
250
50
250
1
250
-
25
50
50
50
10
50
50
50
50
50
250
-

50
50
50
50

4,600
2.500
3,700
8,500
5,000
13,000
2,500
-
2,500
-
-

250
   No detection  limit  available
*   Analyzed as total xylenes
                                            158

-------
Table 5-1   (continued)
BOAT
reference
no

63 '
64
65.
66.
6?
6a
69
70.
71.
72
73
74.
75
76.
77
78.
79
80
61
H2
232
83
84.
85
86
87
88
89
90
91
92
93.
94
95
96.
97
98
99
100.
101
Parameter
Semivolat i les (continued)
Benzo(b)f luoranthene
Benzo(ghi Iperylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-ch1oroisopropyl Jet her
Bis(2-ethylhexyl)phthalate
4-Bromopheny 1 phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroani 1 me
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropion itr i le
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
D i benz ( a, h) anthracene
Dibenzo(a,e)pyrene
Dibenzo(a, Opyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3.3'-Dichlorobenzidine
2,4-Dichlorophenol
2,6-Dichlorophenol
Oiethyl phthalate
3 , 3 ' -D imet hoxybenz i d i ne
p- Dimethyl ami noazobenzene
3,3' -Dimethylbenzidine
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1 ,4-Dinitrobenzene
4,6-Dimtro-o-cresol
2,4-Dimtrophenol
D
ND
UniU NA

ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
PPb
ppb
= Detected
= Not detected
= Not analyzed

D
ND
D
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
NA
D
ND
ND
NA
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detection
1 imit

250
5,500
250
5,000
7,000
7.500
7,500
3,300
2,500
3,300
-
13,000
5,500
5,000
2,500
2,500
-
2,500
13,000
13,000
-
3,300
2,500
2,500
2,500
2,500
6,000
5,000
3,550
5,000
2,500
22.000
5,000
5,000
3,500
2,500
33,000
5,000
31,500
55,000
            159

-------
Table  5-1   (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
125
124
125
126
127
128.
129.
130.
131.
132.
133.
134
135.
136.
137.
138.
Parameter
Semwolat i les (continued)
2,4-Dmitrotoluene
2, 6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamme
Diphenyln itrosamine
1 , 2-Diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyc lopentadlene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Indeno(l , 2,3-cd)pyrene
Isosaf role
Methapyri lene
3-Methylcholanthrene
4 ,4'-Methylenebis
(2-chloroani 1 me)
Methyl methanesulfonate
Naphthalene
1 ,4-Naphthoqumone
1-Naphthylamine
2-Naphthy lamine
p-Nitroam 1 me
Nitrobenzene
4-Nitrophenol
N-N itrosodi-n-buty lamine
N-Nitrosod lethy lam me
N-Nitrosodimethylamme
N-N Itrosomethy lethy lam me
N-Nitrosomorphol me
N-Nitrosopiperidme
n-Nitrosopyrrolidme
5-Nitro-o-toluidme
Pentachlorobenzene
Pentachloroethane
Pentachloronltrobenzene
Units

PPb
ppb
ppb
PPb
ppb
ppb
ppb
ppb
ppb
PPb
ppb
ppb
ppb
ppb
ppb
Ppb
ppb
ppb
ppb

ppb
Ppb
ppo
PPb
ppb
PPb
ppb
ppb
PPb
ppb
PPb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
D = Detected
NO = Not detected
NA = Not analyzed

ND
ND
ND
ND
ND
ND
ND
D
D
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND

ND
NA
D
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detect ion
1 imit

7,500
5,000
3,300
2,650
5,000
5,000
2,500
2,500
2,500
5,000
8,000
5,000
5,000
-
7,500
4,900
5.000
16,000
4,600

5,000
-
2,500
5,000
7,500
17,000
65,000
2,500
5,000
5,000
5,000
13,000
5,000
5,000
5,000
5,000
5,000
5,000
5,000
5,000
           160

-------
Table  5-1  (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
Semivolat i les (continued)
Pentachlorophenol
Phenacet in
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronannde
Pyrene
Resorcinol
Safrole
1,2,4, 5-Tetrachlorobenzene
2,3,4, 6-Tet rach loropheno 1
1,2,4-Tnchlorobenzene
2,4,5-Tnchlorophenol
2,4,6-Trichlorophenol
Tris(2,3-dibromopropyl)
phosphate

Metals
Antimony
Arsenic
Barium
Beryl! lum
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai 1 lum
Vanadium
Zinc

Inorganics
Cyanide
Fluoride
Sulf ide

Units


ppb
ppb
ppb
ppb
PPb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb
ppb

ppb


m
m
m
m
m
m
m
m
m
m
m
m
m
m
m
m


ppm
ppm
ppm
D = Detected
ND = Not detected
NA = Not analyzed


0
ND
0
D
NA
ND
ND
D
ND
ND
ND
ND
ND
ND
ND

NA


ND
D
D
ND
D
D
NA
D
D
D
D
D
ND
D
0
D


ND
D
D
Detection
1 imit


25
5,000
2.500
2.000
-
5,000
5.000
2,500
5.000
5,000
2,500
9,000
2,500
13,000
3,650

-


30
0 01
0.045
0 5
0.015
0.045
-
0.05
O.Q1
0.001
7.5
2.0
4.5
1.5
4.0
0.03


0.25
D 95
0 51
          161

-------
Table  5-1   (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
gamma -BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan 11
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxyacet ic acid
Si Ivex
2,4,5-T
Organophosphorous insecticides
Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Units

ppm.
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm
ppm

ppb
ppb
ppb

ppm
ppm
Ppm
Ppm
ppm

ppm
ppm
ppm
D = Detected
ND = Not detected
NA = Not analyzed

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
NO
ND
ND

ND
ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
Detection
1 imit

7.5
4.0
7 5
7.5
5.0
100
15
7 5
15
7.5
7.5
7.5
7 5
15
5.0
7.5
7.5
40
25
100

0.25
0.75
0.75

0.20
0.50
0 20
0.15
0.10

1,000
1,000
1,000
         162

-------
                                  Table 5-1   (continued)
BOAT
reference
no.

203.
204
205.
206
Parameter
PCBs (continued)
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
D = Detected
ND = Not detected
Units NA = Not analvzed

ppm ND
ppm ND
ppm ND
ppm ND
Detection
1 imit

1,000
1,000
300
400
207
208.
209.
210
211.
212.
213.
Dioxins and furans

Hexachlorodibenzo-p-dioxins          ppt
Hexachlorodibenzofurans              ppt
Pentachlorodibenzo-p-dioxins         ppt
Pentachlorodibenzofurans             ppt
Tetrachlorodibenzo-p-dioxins         ppt
Tetrachlorodibenzofurans             ppt
2,3,7,8-Tetrachlorodibenzo-          ppt
  p-dioxin
ND
ND
ND
ND
ND
ND
ND*
129
 87
 48
 41
 52
 39
* Dioxin analyses were not isomer specific,  therefore 2,3,7,8-TCDD was  analyzed  with
  al1 tetrachlorodibenzo-p-dioxins.
                                            163

-------
they were present at or below their detection limits,  or that some
constituents may be present such that masking or interference has
resulted in the inability to detect them.   The Agency  analyzed for
dioxins and furans in the K001 waste and treatment residuals and did not
detect them in any of the waste streams.  The Agency has recently become
aware of waste characterization data showing that dioxins and furans may
be present in some wood preserving wastes.  EPA has not had an ample
opportunity to evaluate these data.  When EPA completes its analysis of
available data it will consider the regulation of these constituents.
Therefore, the Agency is reserving the standards for dioxins and furans
for a later date.  Table 5-2 presents the BOAT list constituents that
were present in the untreated KOOl-Creosote waste and  the ranges of
concentrations.  Table 5-3 presents similar data for K001-PCP.  In
general, K001 waste primarily consists of BOAT list semivolatile
constituents, with BOAT list metals and volatiles also being present.
All BOAT list constituents that were detected in the untreated K001 waste
were considered for regulation unless the constituent  was not present at
treatable levels or treatment performance data demonstrating effective
treatment by BOAT were not available for that constituent in the waste or
for a waste judged to be similar.
5.2      BOAT List Constituents Detected in the Treated Waste
    The treatment performance data demonstrate that all of the BOAT list
organic constituents are significantly reduced by rotary kiln
incineration.  Specifically, all BOAT list volatile and semivolatile
                                    164

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1711g/p.26
                   Table 5-2   Untreated  KOOl-Credsote -
                             BOAT  List Constituents Detected
BOAT List  Constituent
                                      Range of Concentrations (ppm)
Volat i les
Benzene
Toluene
Ethyl Benzene
Xy lenes
Semivolat i les
Acenaphthalene
Acenaphthene
Anthracene
Chrysene
Fluorene
Naphthalene
Phenanthrene
Phenol
Pyrene
Metals
Arsenic
Barium
Cadmium
Chromium
Copper
Mercury
Nickel
Lead
Selenium
Thai 1 lum
Vanadium
Zinc

51- 63
100-170
55- 87
120-170

1,000-<4,600
15,000-21,000
7,300-15,000
4,100- 4,800
12,000-16,000
29,000-43,000
29,000-41,000
2,400- 3,900
12,000-17,000

0.7 - 2 6
12 - 150
0 79- 3 5
1.6 - 8.6
12 - 39
0.35- 1 64
18-75
37 - 190
0.3 - 1 5
2.2 - 8 0
0.82- 4.0
40 - 200
                                  165

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1711g/p.27
                      Table  5-3   Untreated  K001-PCP  -
                                BOAT  List Constituents  Detected
BOAT List Constituent                  Range of  Concentrations  (ppm)
Volatiles
Toluene                                          10-39

Semivolatiles
Acenaphthene                                 13,000-18,000
Anthracene                                    8,500-13,000
Benz(a)anthracene                            <2,500- 3,400
Benzo(a)pyrene                                 <250-   940
Benzo(b and/sr k)fluoranthrene                  940- 3,300
Chrysene                                     <2,500- 3.600
Fluoranthene                                 13,000-21,000
Fluorene                                      8,200-12,000
Naphthalene                                  26,000-43,000
Pentachlorophenol                               920- 3,000
Phenanthrene                                 28,000-42,000
Pyrene                                        9,200-15,000

Metals
Arsenic                                        11-29
Barium                                          17  - 30
Cadmium                                        0.4  - 0 6
Chromium                                       15-27
Copper                                         67-11
Lead                                           6.3  - 11
Mercury                                      0.0064  - 0 11
Zinc                                            30  - 64
                                     166

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constituents detected in the untreated waste are reduced to
concentrations below their detection limits.  Because all of the BOAT
list volatiles and semivolatile constituents detected in the untreated
waste were reduced to concentrations below their detection limits by
rotary kiln incineration, these compounds were regarded as potential
regulated constituents, as they are indicators of effective treatment for
K001 waste.
    As explained in Section 1, the Agency is not proposing to regulate
all of the BOAT list constituents considered for regulation.  In general,
the Agency has considered whether some constituents are adequately
controlled by the regulation of another constituent.  For organic
constituents, determination of adequate control was based on an
evaluation of the characteristics of the constituents that would affect
treatment performance of rotary kiln incineration.  Specifically, the
waste characteristics affecting performance, as discussed in the
incineration discussion  in Section 3.2.1, include the volatility (boiling
point) and bond dissociation energies of the constituents of a waste.
Consistent with the theory of combustion, constituents having higher
boiling points and higher bond dissociation energies are the most
difficult to destroy.  Also, BOAT list organic constituents present in
the untreated waste in the highest concentrations are believed to be
among the constituents that are most difficult to treat to nondetectable
levels.
                                    167

-------
    For K001 organic treatment by rotary kiln incineration,  the
constituents proposed for regulation are naphthalene,  pentachlorophenol,
phenathrene, pyrene, toluene and xylenes (total).   These constituents
were selected because they are indications of effective treatment and it
is believed that other BOAT list organics will be treated to levels
equivalent to or lower than these constituents.  In general, these
constituents are present in the untreated waste in the highest
concentrations, have high bond dissociation energies,  and/or high boiling
points.  Table C-l  in Appendix C contains a ranking of the BOAT list
organic constituents based on concentration, boiling point, and bond
dissociation energy.  Specifically, these constituents were selected for
the following reasons:
    (1)  Napthalene  - BOAT list constituent present in the untreated
waste  in the highest concentration.
    (2)  Pentachlorophenol  -  Highly chlorinated constituent which will
serve  as indicator  for  all  chlorinated  BOAT  list organics.
    (3)  Phenanthene  -  BOAT  list constituent  present  in  the untreated
waste  in the highest  concentration  second to  naphthalene, with moderate
boiling point,  and  bond dissociation  energy.
    (4)   Pyrene  - BOAT  list  semivolatile with  bond dissociation  energy
among  the  highest of any BOAT list  semivolatile  organic,  high  boiling
point, and present  in  higher concentrations  than  other  constituents  with
comparable bond  dissociation energies and boiling  points.
     (5)   Toluene -  BOAT list volatile organic constituent present  in
highest concentration.

                                     168

-------
    (6)  Xylene - BOAT list volatile constituent present in untreated



waste with highest bond dissociation energy and boiling point and



concentrations similar to toluene.



    EPA believes that the other BOAT list organic constituents present in



K001 wastes will be adequately controlled by rotary kiln incineration if



these regulated constituents are controlled to concentrations below their



detection limits.



    Several BOAT metal constituents were detected in the untreated waste



collected by the Agency with zinc, lead, barium, and copper being present



in the highest concentrations.  Rotary kiln incineration is not designed



to treat metals, however, metal constituents present in the untreated



waste will be present in the incinerator ash, scrubber water and scrubber



water treatment nonwastewater residuals.  Generally, the metals present



in the highest concentrations in the untreated waste are also present in



these residuals at the highest concentrations.  Whether a BOAT list metal



constituent present in the untreated waste will be detected in the ash or



the scrubber waste will depend on the volatility of the constituent and



the operating temperature of the rotary kiln incinerator.  In this case



of K001 as tested by the Agency, the BOAT list metal constituents present



in the highest concentration in the untreated waste were also among the



constituents most prevalent in both wastewaters and nonwastewater



residuals.  These constituents, including zinc, lead, barium, and copper,



were regarded as potential regulated constituents.
                                    169

-------
    All stabilization data from wastes similar to K001 nonwastewaters
were examined, and none of the data showed effective treatment for
barium.  As a result, the three BOAT list metals present in the waste in
the highest concentrations, zinc, lead, and copper,  were selected as
regulated constituents because available stabilization performance showed
effective treatment for these constituents.  The Agency believes that
other BOAT list metals will be adequately controlled by the regulation of
these constituents because the others are typically  present at
significantly lower concentrations.
    For the K001 scrubber waters, zinc and lead were generally present in
the highest concentrations.  Several other BOAT list metals including
barium, copper, and thallium were also present.  EPA examined available
treatment performance data for chemical precipitation and filtration for
which design and operating data were available.  The performance data
identified from the Agency's testing at Envirite did not indicate
treatment of thallium or barium in wastewaters.  However, these data for
chemical precipitation and filtration did show effective treatment for
lead, copper, and zinc.  The Agency believes that the regulation of zinc,
lead, and copper, will adequately control other BOAT list metals present
in wastewater forms of K001.
                                    170

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5.3    Selection of Regulated Constituents

    The regulated constituents proposed for K001 are as follows:

    K001 - Nonwastewater               K001 - Wastewater
    Naphthalene
    Pentachlorophenol
    Phenanthrene
    Pyrene
    Toluene
    Xylenes (total)
    Copper
    Lead
    Zinc
Naphthalene
Pentachlorophenol
Phenanthrene
Pyrene
Toluene
Xylenes (total)
Copper
Lead
Zinc
                                    171

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                6.   CALCULATION OF BOAT TREATMENT STANDARDS
    The purpose of this section is to present the actual  treatment
standards for the regulated constituents selected in Section 5.   The
standards were calculated based on the performance data from the
treatment technologies determined in Section 4 to represent BOAT.
Included in this section is a detailed discussion of the calculation of
treatment standards for the nonwastewater and wastewater forms of K001.
    As discussed in Section 1, the Agency calculated the BOAT treatment
standards for K001 by following a four-step procedure:  (1) editing the
data,  (2) correcting the data using recovery data,  (3) calculating
variability factors, and (4) calculating the actual treatment standards
by multiplying the average accuracy corrected composition data by the
appropriate variability factor.   The four steps  in  this procedure are
discussed in detail in Sections 6.1 through 6.4.
6.1      Editing the Data
6.1.1    BOAT  List Organics Treatment
     As discussed  in Section 3,  the  Agency collected nine data sets  for
rotary kiln  incineration of K001  waste at two separate test  facilities.
The  Agency evaluated  the nine  data  sets  and  determined that  the  treatment
systems were  well  operated during the  sampling  periods.  These  data sets
also included  the  appropriate  analytical  tests  to evaluate treatment
performance  of incineration.   Because  incineration is a  destruction
technology  for organics,  total  constituent  concentration  is  the best
measure of  performance.   The  quality assurance/quality control
                                     172

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data were also available for the BOAT list organics and metals, as



previously discussed in detail, in Section 4.



6.1.2    BOAT List Metals Treatment



    Incineration of K001 results in the generation of two treatment



residuals:  ash (nonwastewater K001 residual) and scrubber water



(wastewater K001 residual).  Because the untreated K001 waste contains



BOAT list metal constituents, these treatment residuals also contain



metals at treatable concentrations.  As discussed in Section 3, the



Agency does not have treatment performance data specifically for BOAT



list metals in the wastewater and nonwastewater forms of K001.  However,



EPA does have treatment performance data for wastes that the Agency



believes are similar to these K001 residuals.



    For the wastewater form of K001 (scrubber water), treatment



performance data were available for the treatment system consisting of



chemical precipitation and filtration.  Eleven data sets were available



for treatment of zinc, lead, and copper containing wastewaters.  The



design operating data collected for this treatment system indicate that



it was well designed and well operated during the time of sampling.   In



addition, the analytical testing data for total composition of BOAT list



metals were the appropriate tests for this technology.  However, recovery



values are not available for metal spikes and metal spike duplicates  from



the treatment data transferred from the Onsite Engineering Report for



Envirite Co.  The recovery data are being transferred from the Onsite



Engineering Report for Horsehead Resource Development Co. for K061.   This
                                     173

-------
is being done because zinc, lead, and copper are present in both wastes
and the TCLP extracts from the treated K061 residual  is a similar waste
matrix to the wastewaters tested at Envirite.
    For nonwastewater residuals containing BOAT list metals requiring
stabilization such as nonwastewater residuals from scrubber water
treatment by chemical precipitation and filtration or incinerator ash,
the Agency identified performance data for zinc, lead, and copper.  The
treatment data transferred from  F006 stabilization data for K001
wastewater treatment nonwastewater residuals and incinerator ash  included
design and operating data, the appropriate analytical testing to  evaluate
the performance of stabilization (total composition and TCLP for
untreated waste and TCLP  for the treated waste), and the required QA/QC
analyses.  As a result, all of these data  were  used to develop  treatment
standards for the BOAT  list metals zinc, lead,  and copper  for
nonwastewater forms  of  K001.
6.2      Correction  of  Analytical  Data
    The  analytical data used to  determine  BOAT  and calculate treatment
standards were  adjusted for accuracy  in order  to take  into account  the
analytical  interferences  associated  with the chemical  composition of  the
sample.  This was  accomplished  by  calculating  a correction factor from
percent  recovery  data  for each  regulated  constituent.   The accuracy
adjusted concentration  was calculated  by  multiplying  the uncorrected  data
value by the correction factor.   The calculation  of  corrected  data  based
on recoveries  is  detailed below for  the  regulated  constituents.
                                     174

-------
6.2.1    Correction of BOAT List Organics Data
    As previously discussed, the BOAT list organic constituents proposed
for regulation include naphthalene, pentachlorophenol,  phenanthrene,
pyrene, toluene,  and xylenes (total).  All of these constituents were
detected in the untreated K001 waste and were destroyed by rotary kiln
incineration to concentrations below their detection limits in the nine
data sets collected by the Agency.  However, the detection limits
attainable for these BOAT list organic constituents in the treatment
residuals varied.  Generally, where this occurred, the Agency selected
the highest detection limit measured for each regulated constituent in
each waste matrix (wastewater and nonwastewater).   The treatment
standards were developed using these high detection limit because lower
detection limits may not be consistently achievable.  The treatment
performance data for the proposed regulated organic presented in this
section and used to calculate the treatment standards reflect this change.
    The recovery data used to develop accuracy-corrected data for BOAT
list organics in K001 treatment residuals were from the accompanying
matrix spike recoveries from the data with the higher detection limits.
As noted in Section 4, it was necessary in one instance to transfer
recovery data for pentachlorophenol  in the scrubber water.  The detection
limit used to calculate the standard was from the treatment of the
KOOl-pentachlorophenol waste, while  the recovery data used were
transferred from the matrix spike recovery performed for
pentachlorophenol in the scrubber water from the KOOl-creosote waste.
                                    175

-------
The accuracy correction factors used for all  regulated organic
constituents in both the wastewater and nonwastewater residuals are
summarized in Table 6-1.  The matrix spike recovery data used to correct
the data used in calculating the treatment standards are presented in
Appendix B.
6.2.2    Correction of BOAT List Metals Data
    For K001 nonwastewater residuals the Agency is proposing treatment
standards for zinc, lead, and copper.  As stated previously, the
performance data for stabilization of these constituents were transferred
from F006 stabilization data.  As a result, the matrix spike recovery
values used to correct the data were developed with the analytical data
for those F006 wastes.  The correction factors used and calculations of
the corrected values for the proposed regulated BOAT list metals  in the
nonwastewater residuals are presented in Table 6-2.
    The Agency is  proposing to regulate zinc, lead, and copper  in the
K001 wastewater residual (scrubber water) from rotary kiln  incineration.
The treatment performance data for treatment by chemical precipitation
and filtration were transferred from the Onsite Engineering  Report for
Envirite.  The recovery data were transferred from  the Onsite  Engineering
Report  for Horsehead Resource  Development Co. for K061.  The correction
of the  analytical  data  and  the correction factors used are  presented  in
Table 6-3.
                                     176

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L897g
                        Table 6-1  Corrected Values  for  BOAT List Organics
BOAT List Uncorrected Detection
Constituent Limit (ppm)
Naphthalene (ash)
Naphthalene (water)
Pentachlorophenol (ash)
Pentachlorophenol (water)
Phenanthrene (ash)
Phenanthrene (water)
Pyrene (ash)
Pyrene (water)
Toluene (ash)
Toluene (water)
Xylenes (ash)
Xylenes (water)
<2.5
<0 050
<12 5
<0.250
<2.5
<0.050
<2.5
<0.050
<0.050
<0.050
<0.050
<0 050
Correction
Factor
1.14
1.06
1 05
1.25
1.14
1.06
1.04
1 00
1.01
1.01
1.16
1.15
Accuracy Corrected
Value
2.85
0.053
13.125
0.313
2.85
0 053
2.60
0.050
0.051
0.051
0.056
0.058
                                                       177

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                     1711g/p 28
                                                             Table  6  2   Corrected  Valuii,  for  Regulated  Metal  Constituents
                                                                        Treated by Stabilisation

Const ituent
1
BOAT List
Metals
Copper
Lead
Zinc 0.03
Accuracy-Corrected Concentration
Sample Set #
? 3 4


0 27 - O.lfi
0 39 0 34 0 23
0 01 0.05 0 01
(ppm)

5


0 29
0 37
0 04
Mean
(com)
6789


0.31 0 45 0 35 ' 0.50 0.33
0.39 0 41 0 40 0.29 0.35
0.03 0 02 0.02 0.01 0.024
oo

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1711g/p.32
             Table 6-3  Corrected Values  for  Regulated  Metal  Constituents  Treated  by  Chemical  Precipitation  and  Filtration
Accuracy-corrected concentration (mg/1)
Correction Sample Set #
Constituent factor 1234567!



3 9 10 11 Mean
(mg/D
BOAT Metals





Copper            1  20     0.25     0.18      0.25      0.08      0.17     0  14      0.19      0.19      0.10      0.17       0  29      0.18





Lead              1.32    <0.013   <0.013   <0.013    <0.013   <0.013   <0.013   <0.013    <0.013    <0.013    <0.013     <0.013     0.013





Zinc              1.02     0 128    0.117     0.143     1.653     0  128    0  097     0.117     0.133     0.061     0.071      0  102     0.250

-------
6.3      Calculation of Variability Factors
    The variability factor represents the variability inherent in the
treatment process and the sampling and analytical  methods.   Variability
factors are calculated based on the treatment data for each of the
regulated constituents.  The general  methodology for calculating
variablity factors is presented in Appendix A.  In cases where all of the
treated values for a constituent are below the detection limits, a
detection limit of 2.8 was used.  The methodology used to calculate this
variability factor is presented in Appendix A.  The variability factors
calculated for the regulated constituents for K001 are presented in Table
6-4.  Appendix E of this report presents these calculations.
6.4      Calculation of Treatment Standards
    The treatment standards for the proposed regulated constituents were
calculated by multiplying the average accuracy corrected values by the
appropriate variability factor.  The proposed treatment standards for
BOAT are presented in Table 6-4.
                                     180

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1711g/p.30
                   Table  6-4  Calculation of Treatment Standards  for  K001
Regulated Average Treated
Constituent Concentration
(mg/kg, mg/1)
Naphthalene (ash)
Naphthalene (water)
Pentachlorophenol (ash)
Pentachlorophenol (water)
Phenanthrene (ash)
Phenanthrene (water)
Pyrene (ash)
Pyrene (water)
Toluene (ash)
Toluene (water)
Xylenes (ash)
Xylenes (water)
Copper (nonwastewater)
Copper (wastewater)
Lead (nonwastewater)
Lead (wastewater)
Zinc (nonwastewater)
Zinc (wastewater)
2.85
C 053
13.13
0.313
2 85
0 053
2 60
0.050
0 051
0 051
0.058
0 058
0.33
0.18
0 35
0.013
0.024
0.250
Variabi 1 ity
Factor
(VF)
2.8
2 8
2.8
2 8
2.8
2 &
2.8
2 8
2.8
2 &
2.8
2 8
2 2
2.31
1 5
2.8
3.6
4 13
Treatment
Standard
(VF x Average)
7 98
0 148
36 75
0 875
7.98
0 148
7.28
0.140
0 143
0 143
0.16
0.16
0 71
0.42
0 53
0 037
0.086
1.0
                                            181

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Bonner TA, et  al., Engineering Handbook for Hazardous Waste
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                                    183

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REFERENCES - (continued)

Handbook of Industrial Waste Compositions in California, 1978.   (as cited
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Illinois EPA, 1983.  Special Waste Authorization File,  (as cited by
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Kirk-Othmer.  1980.  Encyclopedia of Chemical Technology, 3rd ed.,
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Assignment No. 38, April 1986).

Mitre Corp.   "Guidance Manual for Hazardous Waste Incinerator Permits."
NTIS PB84-100577.  July  1983.

Myers,  L.H.,  et  al.,  1979.   Indicatory  Fate Study.  EPA  OGC2-78-179.   (as
cited by Summary of Available Waste Composition Data  from Review of
Literature  and Data  Bases for Use  in Treatment Technology Application and
Evaluation  for  "California  List" Waste  Streams.  Prepared for EPA Office
of Solid Waste  by  Versar,  Inc.  under Contract No. 68-01-7053, Work
Assignment  No. 38, April 1986).

Novak RG,  Troxler  WL,  Oehnke TH,  "Recovering  Energy  from  Hazardous  Waste
Incineration,"  Chemical  Engineering Progress  91:146  (1984).
                                     184

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REFERENCES - (continued)

Oppelt ET, "Incineration of Hazardous Waste"; JAPCA; Volume 37, No. 5;
May 1987.

Patterson, James W.  1985.  Industrial Wastewater Treatment Technology.
2nd Ed.  Butterworth Publishers; Stoneham, MA.

Perry, Robert H. and Chilton, Cecil H.  1973.  Chemical Engineers'
Handbook.  Fifth Edition.  New York:  McGraw Hill,  Inc., Section 19.

Pojasek RB.  1979.  "Sol id-Waste Disposal:  Solidification"  Chemical
Engineering 86(17):  141-145.

Rudolfs, William.  1953.  Industrial Wastes.  Their Disposal and
Treatment.  L.E.C.  Publishers Inc., Valley Stream, NY.  p. 294

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.

U.S. Department  of Commerce, 1982 Census  of Manufacturers  - Miscellaneous
Chemical Products.  December 1984.

USEPA.   1980.  U.S. Environmental Protection Agency.   RCRA Listing
Background Document Waste Code K001.

USEPA.   1980a.   U.S. Environmental Protection Agency.  U.S. Army Engineer
Waterways Experiment Station.  Guide to the disposal of chemically
stabilized and solidified waste.  Prepared for HWERL/ORD under
Interagency Agreement No. EPA-IAG-D4-0569.  PB81-181505.   Cincinnati,
Ohio.

USEPA.   1983.  Treatability Manual, Volume III, Technology for
Control/Removal  of Pollutants.   EPA-600/2-82-001C,  January 1983.
pp  111.3.1.3-2.

USEPA.   1985.  Characterization  of Waste  Streams Listed in 40 CFR;
Section  261, Waste Profiles.  Prepared for the Waste Identification
Branch,  Characterization and Assessment Division, U.S. EPA.  Prepared  by
Environ  Corporation, Washington, D.C. 1985.

USEPA.   1986.  Onsite Engineering Report  of Treatment  Technology
Performance and  Operation for Envirite Corporation. York,  Pennsylvania.
Washington, D.C.:  U.S.  Environmental Protection Agency.
                                     185

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REFERENCES - (continued)

USEPA.  1986.  Test Methods for Evaluating Solid Waste; physical/chemical
methods.  Third Edition.  U.S. EPA.  Office of Solid Waste and Emergency
Response.  November 1986.

USEPA.  1988.  Onsite Engineering Report for Horsehead Resource
Development Co., Inc. Palmerton, Pennsylvania for K061. Washington,
D.C.:  U.S. Environmental Protection Agency.

U.S. EPA.  1987.  United States Environmental Protection Agency, Office
of Solid Waste.  Onsite  Engineering Report for K001 - Creosote.
November 23, 1987.

U.S. EPA.  1987.  United States Environmental Protection Agency, Office
of Solid Waste.  Onsite  Engineering Report for K001 - PCP.
November 12, 1987.

Versar  Inc.  1984.  Estimating PMN  Incineration Results (Draft).  U.S.
Environmental  Protection AGency, Exposure Evaluation Division, Office of
Toxic Substances, Washington, DC.   EPA Contract No. 68-01-6271, Task
No. 66.

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.
                                     186

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APPENDIX A
    187

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                                APPENDIX A

A.I  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), BOAT 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 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 values are available
in most statistics texts  (see, for example, Statistical Concepts and
Methods by  Bhattacharyya and Johnson,  1977, John Wiley Publications, New
York).
                                     188

-------
    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 =
    where:
    k = number of treatment technologies
    n^ = number of data points for technology i
    N = number of data points for all technologies
    T.J = sum of natural logtransformed data points for each technology.
    (iv)  The sum of the squares within data sets (SSW) is computed:

k
I
i-1

" TI

ni







—






" k
I T.J
i = l

J
£ ""



N J
     SSW =
where:
x
                  I   Z
                            1,J
  k
- I
     .j j = the natural logtransformed observations  (j) for treatment
           technology  (i).
                                     189

-------
    (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).

    A computational table summarizing the above parameters  is shown below.


                    Computational Table for the F Value
Source
Between
Within
Degrees of
freedom
K-1
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.
                                     190

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1790g
                                                            Example 1
                                                        Methylene Chloride
Steam stripping
Influent Effluent
Wl)
1550 00
129C 00
164C 00
5100 00
1450.00
4600 00
1760 00
2400.00
4800 00
12100 00
Ug/D
10 00
10 00
10 00
12.00
10.00
10.00
10.00
10.00
10.00
10.00
Biological treatment
In(effluent) [ln(eff luent )]2 Influent Effluent In(effluent)

2 30
2.30
2.30
2 48
2.30
2 30
2.30
2.30
2.30
2 30
Ug/i) Ug/D
5.29 1960.00 10.00 2 30
5 29 2568.00 10 00 2.30
5.29 1817.00 10 00 2.30
6.15 1640.00 26.00 3.26
5.29 3907.00 10.00 2.30
5.29
5.29
5.29
5 29
5 29
[In(effluent)]2

5 29
5 29
5 29
10 63
5.29





Sum
                                 23.18
                                                   53.76
                                                                                             12 46
                                                                                                                  31  79
Sample Size:
    10           10
Mean
  3669
                 10.2
Standard Deviation
  332b.67           63
Variability Factor.
                                 10
                                  2.32
                                   .06
                                                               2378
                                                                923.04
                  1.15
                                                                               13.2
                                                                                7.15
                                                                                2.48
                                                                                              2.49
                                                                                                43
ANOVA Calculations.
SSB =
         k   n,
ssw =

MSB = SSB/(k-l)

MSW = SSW/(N-k)
                           1 = 1
                                                                191

-------
1790g


                                     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 all  technologies
T   = sum of log transformed data points for each technology

X   = the nat  log transformed observations (j)  for treatment  technology  (i)
n  = 10, n  = 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
SSW = (53.76 + 31.79) -


MSB = 0.10/1 = 0 10

MSW = 0 77/13 = 0.06
                            1270.21
                              15
                          537.31   155.25
                                           =  0.10
10
                        =  0  77
F  =
      0.06
             -1.67
                                    ANOVA Table
Degrees of
Source freedom
Between (B) 1
Within(W) 13

SS MS
0.10 0 10
0 77 0 06

F
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.
                                            192

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1790g
                                                            Example  2
                                                        Inch loroethylene
Steam stripping
Influent
Ug/D
1650 00
5200 00
5000.00
1720 00
1560 00
10300 00
210.00
1600.00
204 00
160 00
Effluent
Ug/D
10.00
10 00
10 00
10 00
10 00
10.00
10.00
27 00
85 00
10 00
ln(eff luent)

2.30
2 30
2 30
2.30
2 30
2.30
2 30
3.30
4 44
2 30
[In(effluent)]2

5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5 29
Influent
Ug/l)
200 00
224.00
134.00
150.00
484.00
163.00
182.00



Biological treatment
Effluent
Ug/1)
10 00
10.00
10 00
10.00
16.25
10.00
10 00



ln(eff luent)

2 30
2.30
2.30
2.30
2.79
2.30
2.30



[In(effluent)]2

5 29
5 29
5.29
5 29
7 76
5 29
5.29



Sum
Sample Size'
      10          10
Mean
    2760
                 19.2
 Standard Deviation
    3209 6        23 7
 Variabi1ity Factor.
                                 26.14
                                 10
                                  2.61
                                   .71
                                                  72 92
                                                               220
                                                               120.5
                  3 70
                                                                               10 89
2.36
                                                                                1.53
                                                                                              16 59
                                                                                               2 37
                                                                                                .19
                                                                                                                 39.52
ANOVA Calculations

SSB=    »  'T'2

ssw =

MSB = SSB/(k-l)

MSW = SSW/(N-k)
                               n,
                                                                193

-------
1790g


                                     Example  2   (continued)

F   = MSB/MSW

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 log transformed data points for  each  technology

X   = the natural log transformed observations  (j)  for treatment  technology  (i)


                                                                    2             2
N  =  10, N  = 7. N = 17, k = 2, T  = 26.14,  T  = 16 59,  T  =  42.73,  T =  1825  85,  T  =  683  30,


T2 =  275.23


SSB =f683-30  +   275'23  1 - 1825 85         -  0.25
       10            7    I      17
SSW.(72.92 + 3952)-|J!L^!±!a      =4.79
                            10
MSB = 0.25/1 = 0 25

MSW = 4.79/15 = 0.32

F= !_!!_= 0.78
    0.32
                                    ANOVA Table
Degrees of
Source freedom
Between(B) 1
Withm(W) 15

SS MS F
0.25 0.25 0.78
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.
                                            194

-------
1790g
Example 3
Chlorobenzene
Activated sludqe followed
Influent Effluent
(«g/l) Ug/1)
7200 00 80.00
6500 00 70.00
6075 00 35.00
3040 00 10.00



by carbon adsorption Biological treatment
In(effluent) [ln(eff luent)] 2 Influent
Ug/1)
4.38 19.18 9206 00
4.25 18.06 16646 00
3.56 12.67 49775.00
2.30 5.29 14731.00
3159 00
6756.00
3040.00
Effluent
Ug/D
1083.00
709.50
460.00
142.00
603 00
153 00
17.00
ln(eff luent)

6.99
6.56
6 13
4.96
6 40
5.03
2.83
ln[(effluent)]2

4b H6
43 03
37 5B
24 60
40 96
25 30
8 01
Sum
Sample Size:
      4           4
Mean-
    5703
                 49
Stanaatd Deviation:
    Ib35 4        32.24
Vanabi 1 ity Factor
                                 14 49
                                                   55.20
3 62
  95
                           14759
                           16311.86
                  7.00
452.5
                                            379.04
                                                                               15 79
                                                                                              38.90
                                                             5 56
                                                             1 42
                                                                                22t>  34
ANOVA Calculations


SSB =

SSW =
k
2
1 = 1
k
.i5i.

1" (_
	
n i
i;-2



i,



-]



k
I T,
i = l

2



i=l [ n! J





MSB  =  SSB/(k-l)

MSW  =  SSW/(N-k)

F    =  MSB/MSW
                                                                195

-------
1790g
                                     Example 3  (continued)
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 log transformed data  points for  each  technology

X   = the natural log transformed observations  (j)  for  treatment  technology  (i)


NI = 4,  N2= 7,  N = 11,  k = 2,  T  = 14 49,  T   =  38  90, T =  53  39,  T2=  2850.49,  T2  -  209.96


T2 = 1513.21

     f209.96     1513.21  }   2850 49
SSB = 	  +  	    -  	         =  9.52
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

Source
Between(B)
Within(W)
Degrees of
freedom
1
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.
                                            196

-------
A.2.  Variability Factor
    where:
                                   -£-99-
                              VF = Mean
     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.  Cgg is calculated using
            the following equation:  Cgg = 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.
    It has been postulated as a general rule that a lognormal
distribution adequately describes the variation among concentrations.  As
a general rule for the BOAT program, empiric observations on
                                    197

-------
concentrations for several constituents showed that the treatment

residual concentrations were distributed approximately lognormally.

Therefore, the lognormal model has been used routinely in the EPA

development of numerous regulations in the Effluent Guidelines program

and in the BOAT program.  The variability factor (VF) was defined as the

ratio of the 99th percentile  (C  ) of the lognormal distribution to its

arithmetic mean (Mean).


           VF =     C99                                             (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  (/^) and standard deviation (a) of the normal distribution as

follows:

         C99    =  Exp  U +   2.33a)                          (2)

         Mean   =  Exp  U +   -5a2)                          (3)

    Substituting (2) and  (3)  in (1) the variability  factor can then be

expressed  in terms of a as follows:


         VF = Exp  (2.33 a -  .5a2)                          (4)

    For residuals with  concentrations that are not all below the

detection  limit, the 99   percentile and the mean can be estimated  from

the actual analytical data and  accordingly, the  variability  factor  (VF)
                                     198

-------
can be estimated using equation (1).  For residuals with concentrations
that are below the detection limit the following steps demonstrated the
approach that is used to approximate the value of a and, hence,
calculate the VF using equation (4).
Step 1:  The actual concentrations follow a lognormal distribution
(truncated).  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 (truncated) with an upper limit equal to In (UL) and a lower
1imit equal to In  (LL).
Step 3:  The standard deviation (a) of the normal distribution  is
approximated by
    a = [(In (UL)  - In  (LL)] / [(2)(2.33)] = [ln(UL/LL)j / 4.66
    when LL = (0.1)(UL) then a =  (InlO) / 4.66 = 0.494
Step 4:  Substitution of the value  from Step 3 in equation (4) yields the
variability factor, VF.
    VF  = 2.8
                                     199

-------
Table A-l

95th PERCENTILE VALUES FOR
THE F DISTRIBUTION
?i: = degrees of freedom for numerator
nz — degrees of freedom for denominator
(shaded area = .95)

/^V
FM
X
1
2
n
O
•i
5
C
-
8
p
10
11
12
13
14
15
16
17
18
19
20
on
24
26
28
30
40
50
60
70
80
100
150
200
400
m
i
1C1.4
18.51
10.13
7.71
6.61
5.99
5.59
5.32
5.12
4.96
4.84
4:75
4.67
4.60
4.54
4.49
4.45
4.41
4.38
4.35
4.30
4.26
4.23
4.20
4.17
4.08
4.03
4.00
3.98
3.96
3.94
3.91
3.89
3.86
3.84
2
199.5
19.00
9.55
6.94
5.79
5.14
4.74
4.46
4.26
4.10
3.98
3.89
3.81
3.74
3.68
3.63
3.59
3.55
3.52
3.49
3.44
3.40
3.37
3.34
3.32
3.23
3.18
3.15
3.13
3.11
3.09
3.06
3.04
3.02
2.99
3
215.7
19.16
D.28
6.59
5.41
4.76
4.35
4.07
3.86
3.71
3.59
3.49
3.41
3.34
3.29
3.24
3.20
3.16
3.13
3.10
3.05
3.01
2.98
2.95
2.92
2.84
2.79
2.76
2.74
2.72
2.70
2.67
2.65
2.62
2.60
4
224.6
19.25
9.12
6.39
5.19
4.53
4.12
3.84
3.G3
3.48
3.36
3.26
3.18
3.11
3.06
3.01
2.96
2.93
2.90
2.87
2.82
2.78
2.74
2.71
2.69
2.61
2.56
2.53
2.50
2.48
2.46
2.43
2.41
2.39
2.37
5
230.2
19.30
9.01
6.26
5.05
4.39
3.97
3.69
3.48
3.33
3.20
3.11
3.03
2.96
2.90
2.85
2.81
2.77
2.74
2.71
2.66
2.62
2.59
2.56
2.53
2.45
2.40
2.37
2.35
2.33
2.30
2.27
2.26
2.23
221
6
234.0
19.33
8.94
6.16
4.95
4.28
3.87
3.58
3.37
3.22
3.09
3.00
2.92
2.85
2.79
2.74
2.70
2.66
2.63
2.60
2.55
2,51
2.47
2.45
2.42
2.34
2.29
2.25
2.23
2.21
2.19
2.16
2.14
2.12
2.09
8
238.9
19.37
8.85
6.04
4.82
4.15
3.73
3.44
3.23
3.07
2.95
2.85
2.77
2.70
2.64
2.59
2.55
2.51
2.48
2.45
2.40
2.36
2.32
2.29
2.27
2.18
2.13
2.10
2.07
2.05
2.03
2.00
1.98
1.96
1.94
12
243.9
19.41
8.74
5.91
4.68
4.00
3.57
3.28
3.07
2.91
2.79
2.69
2.60
2.53
2.48
2.42
2.38
2.34
2.31
2.28
2.23
2.18
2,15
2.12
2.09
2.00
1.95
1.92
1.89
1.88
1.85
1.82
1.80
1.78
1.75
16
24C.3
19.43
8.69
5.84
4.GO
3.92
3.49
3.20
2.98
2.82
2.70
2.60
2.51
2.44
2.39
2.33
2.29
2.25
2.21
2.18
2.13
2.09
2.05
2.02
1.99
1.90
1.85
1.81
1.79
1.77
1.75
1.71
1.69
1.67
1.64
20
248.0
19.45
8.66
5.80
4.56
3.87
3.44
3.15
2.93
2.77
2.65
2.54
2.46
2.39
2.33
2.28
223
2.19
2.15
2.12
2.07
2.03
1.99
1.96
1.93
1.84
1.78
1.75
1.72
1.70
1.68
1.64
1.62
1.60
1.57
30
250.1
19.46
8.62
5.75
4.50
3.81
2.38
3.08
2.86
2.70
2.57
2.46
2.38
2.31
2.25
2.20
2.15
2.11
2.07
2.04
1.98
1.94
1.90
1.87
1.84
1.74
1.69
1.65
1.62
1.60
1.57
1.54
1.52
1.49
1.46
40
251.1
19.46
8.GO
5.71
4.46
3.77
3.34
3.05
2.82
2.67
2.53
2.42
2.34
2.27
2.21
2.16
2.11
2.07
2.02
1.99
1.93
1.89
1.85
1.81
1.79
1.69
1.63
1.59
1.56
1.54
1.51
1.47
1.45
1.42
1.40
50
252.2
19.47
8.58
5.70
4.44
3.75
3.32
3.03
2.80
2.64
2.50
2.40
2.32
2.24
2.18
2.13
2.08
2.04
2.00
1.96
1.91
1.86
1.82
1.78
1.76
1.66
1.60
1.56
1.53
1.51
1.48
1.44
1.42
1.38
1.32
100
253.0
19.49
8.56
5.66
4.40
3.71
3.28
2.98
2.76
2.59
2.45
2.35
2.26
2.19
2.12
2.07
2.02
1.98
1.94
1.90
1.84
1.80
1.76
1.72
1.69
1.59
1.52
1.48
1.45
1.42
1.39
1.34
1.32
1.28
1.24
«
254.3
19.50
8.53
5.6S
4.36
3.67
3.23
2.93
2.71
2.54
2.40
2.30
2.21
2.13
2.07
2.01
1.96
1.92
1.88
1.84
1.78
1.73
1.69
1.65
1.62
1.51
1.44
1.39
1.35
1.32
1.28
1.22
1.19
1.13
1.00
          200

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APPENDIX B
    201

-------
1711g/p.33
                  B-l  Analytical Methods for K001 Regulated Organic Constituents
Regulated Constituent    Extraction Method     Method  Number    Analytical Method/Method No.

Volatile Orqamcs
Toluene                  Purge and trap            5030

Xylenes (total)          Purge and trap            5030

Semivolati 1e Orqamcs

Naphthalene              Continuous Liquid/        3580
                         Extraction

Pentachlorophenol        Continuous Liquid/        3580
                         Extraction
Phenanthrene
 Pyrene
Continuous Liquid/         3580
Extraction

Continuous Liquid/         3580
Extract ion
GC/MS

GC/MS



GC/MS


GC/MS


GC/MS


GC/MS
8240

8240



8270


8270


8270


8270
 References:   U.S.  EPA.   Test Methods for Evaluating Solid Waste, SW-846 Third Edition, Office of
              Solid Waste and Emergency Response, Washington, O.C.  November, 1986.
                                                 202

-------
1711g/p.34
                 Table B-2.  K001 - Matrix Spike Recoveries Used to Calculate
                                    Correction  Factors for  Regulated Organic Constituents
Requlated Constituent
Volatile Organic;
Toluene (ash)
Toluene (water)
Xylenes (ash)
Xylenes (water)
Semivolat i 1e Orqamcs
Naphthalene (ash)
Naphthalene (water)
Pentachlorophenol (ash)
Pentachlorophenol (water)
Phenanthrene (ash)
Phenanthrene (water)
Pyrene (ash)
Pyrene (water)
Percent Recovery
Sample Duplicate

99 110
103 99
86.4 (average) 96.4 (average)
100 (average) 94 (average)

88 (average) 93 (average)
94 (average) 96 (average)
95 105
80 0
88 (average) 93 (average)
94 (average) 96 (average)
96 100
110 110
Correction Factor Used

1.01
1.01
1.16
1.15

1.14
1.06
1.05
1.25
1 14
1.06
1.04
1.00
Reference:  Onsite Engineering Report for K.001-Creosote
                                               203

-------
1965g
    Table  B-3  K001 Creosote Water Sample Volatile Organics
              Matrix Spike Recoveries ("/.)



1 , 1-Dichloroethene
Toluene
Ch lorobenzene
Benzene
Trlchloroethylene
Spike
level
(ug/1)
25
25
25
25
25


#1 #2 RPD
100 97 3.0
103 99 4.0
95 90 5.4
90 85 57
69 64 7.5
Reference:  Onsite Engineering Report for KOOl-Creosote
                            204

-------
1965g
    Table B-4  K001 Creosote Ash Sample Volatile Organics
               Matrix Spike Recoveries (Y.)



1 , 1-Dichloroethene
Toluene
Chlorobenzene
Benzene
Trichloroethylene
Spike
level
(ug/1)
25
25
25
25
25


#1 »2 RPD
86 95 9.9
99 110 10
102 112 9.3
76 88 12
67 77 14
Reference:  Onsite Engineering Report  for KOOl-Creosote
                           205

-------
1965g
            Table B-5  K001 Creosote Water Sample Semivolatile
                       Organic  Matrix  Spike Recoveries  (%)
Compound
Phenol
2-Chlorophenol
1 ,4-Dichlorobenzene
N-nitroso-di-n-propylamine
1 ,2,4-Tnchlorobenzene
4 -Chloro- 3 -methyl phenol
Acenaphthene
4-Nitrophenol
2,4-Dinitrotoluene
Pentachlorophenol
Pyrene
Initial Amount
cone. added
(ug/1) (ug/1)
<10 100
<10 100
<10 50
<100 50
<10 50
<10 100
<10 50
<50 100
<10 50
<50 100
<10 50
% Recovery
#1 n
65 61
61 65
61 51
70 56
72 54
80 73
81 66
0 0
21 17
80 85
62 60
RPD
6
6
16
20
25
9
19
NC
19
6
3
Reference:  Onsite Engineering Report for KOOl-Creosote

NC  - Not calculated.
                           206

-------
1965g
             Table B-6  K001 Creosote Ash Sample Semivolatile
                        Organics  Matrix  Spike Recoveries  (%)
Initial
cone.
Compound (ug/g)
Phenol <4
2-Chlorophenol <4
1 ,4-Dichlorobenzene <4
N-nitroso-di-n-propylamine <4
1 ,2,4-Tnchlorobenzene <4
4-Chloro-3-meth>lphenol <4
Acenaphthene <4
4-Nitrophenol <20
2,4-Dimtrotoluene <4
Pentachlorophenol <20
Pyrene <4
Amount
added
(ug/g)
67
67
33
33
33
67
33
67
33
67
33
% Recovery
#1 #2 RPD
72
59
48
67
30
35
0
1.2
0
0
0
65 9.7
53 10
46 4.2
62 7.5
30 0
68 48
3.4 100
2.6 54
0 NC
0 NC
0 NC
Reference:  Onsite Engineering Report for KOOl-Creosote

NC - Not calculated.
                             207

-------
1966g
                         Table B-7   K001-PCP Ash  Duplicate Matrix Spike Data,
                                    Volatile Organic Analyses




Compound
Toluene
Chloroflenzene
Benzene
Trichloroethene

Original
amount
present,
ng/ liter
3
<2
<2
<2


Amount
spiked,
/tg/1 iter
25
25
25
25
Amount
recovered, %
mq'l liter Recovery

No 1 No 2 No 1 No. 2
30 30 106 108
31 30 124 120
22 22 88 88
22 21 88 84
Reference   Onsite Fngineering  Report  for  KOOl-Pentachlorophenol
                                              208

-------
1966g
                   Table  B-8   K001-PCP  TCLP Ash  Duplicate Matrix Spike Data,
                              Volatile Organic Analyses

Original
amount
present ,
Compound ng/ liter
1 , 1-Dichloroethylene <2
Toluene <2
Chlorobenzene <2
Benzene <2
Trichloroethene <2
Amount
recovered, %
Amount mq/1 liter Recovery
spiked,
ng/ liter No. 1 No. 2 No 1 No. 2
25 23 28 92 112
25 30 30 120 120
25 30 26 120 104
25 23 30 92 120
25 21 21 84 84
Reference:  Onsite Engineering Report for KOOl-Pentachlorophenol
                                                209

-------
1966g
                   Table B-9   K001-PCP  TCLP  Ash  Duplicate  Matrix Spike  Data,
                              Volatile Organic Analyses
Initial
concen-
tration,
Compound ^g/ liter
Phenol 2
2-Chlorophenol <2
1 ,4-Dichlorobenzene <2
N-Nitrosodinipropyl- <5
amine
1 ,2, 4-Tr ichlorobenzene <5
4-Chloro-3-methylphenol <5
Acenaphthene 14,000
4-Nitrophenol <10
2,4-Dinitrotoluene <50
Pentachlorophenol <50
Pyrene 11,000
Amount
added,
jig/ liter
10,000
10,000
5,000
5,000

5,000
10,000
5,000
10,000
5,000
10,000
5,000
Amount
recovered, 7.
mq/1 liter Recovery
No. 1 No. 2 No. 1
10,000 10,000 100
10,000 11,000 100
5,500 5,500 110
6,500 7,000 130

4,700 4,600 94
8,000 9,000 80
20,000 20,000 120
8,400 7, BOO 84
6,000 6,000 120
10,000 10,000 100
15,000 16,000 80
No 2
100
110
110
140

92
90
120
75
120
100
100
 Reference:   Onsite  Engineer-ing Report for KOOl-Pentachlorophenol
                                               210

-------
1966g
                  Table B-10  K001-PCP TCLP Ash Duplicate Matrix  Spike  Data,
                              Volatile Organic Analyses
Initial
concen-
tration.
Compound ^g/ liter
Phenol 2
2-Chlorophenol <2
1 ,4-Dichlorobenzene <2
N-Nitrosodinipropyl- <5
am me
1 ,2,4-Tnchlorobenzene <5
4-Chloro-3-meth> Iphenol <5
Acenapnthene <5
4-Nitrophenol <10
2,4-Oinitrotoluene <50
Pentachlorophenol <50
Pyrene <2
Amount
added,
Mg/1 iter
200
200
100
100

100
200
100
200
100
200
100
Amount
recovered, %
mq/1 liter Recovery
No. 1 No. 2 No. 1 No. 2
170 160 85 80
200 210 100 105
94 94 94 94
81 82 81 82

95 100 95 100
180 190 90 95
120 120 120 120
200 180 100 90
120 120 120 120
190 210 95 105
96 100 96 100
Reference:  Onsite Engineering Report for KOOl-Pentachlorophenol
                                              211

-------
1966g
                Table B-ll   K001-PCP  Scrubber Water Duplicate Matrix Spike Data
                           Semivolatile Organic Analyses
Initial
concen-
tration,
Compound ^g/ liter
Phenol <2
2-Chlorophenol <2
1 ,4-Dichlorobenzene 
-------
1966g
                    Table B-12  Matrix Spike Recoveries for Stabilized F006 Nonwastewater  Residuals


Const ituent
Copper

Lead

Zinc

Original
amount
found
(ppm)
0 2247
0 1526
0 3226
0.2142
0.0133
27.202

Duplicate
(ppm)
0 2211
0.1462
0.3091
0.2287
0.0238
3.65


« Error
0.81
2.14
2.14
3.27
28.3
76.3

Actual
Spike
4 8494
4 9981
4 9619
4.6930
5 0910
19 818


% Recovery
92.5
97 0
92.9
89.4
101.4
87 8
Accuracy
correction
factor*
1.08
1.03
1.08
1.12
0.99
1.14
 *Accuracy correction factor = 100 - percent  recovery.

Reference:  Memo to R  Turner, U.S.  EPA/H.W.E R.L   from Jesse  R.  Conner, Chemical Waste Management dated
            January 20,  1988
                                                           213

-------
19G6g
                                 Table B-13  Matrix Spike Recovery for Metals for the TCLP Extract for K061
                                                   for Horsehead Resource Development Co
BOAT constituent
                                                       Sample  set  4
Original sample    Spike added    Spike  result     Percent
    (ug/1)           (ug/1)          (ug/1)         recovery*
                                                 Sample set  duplicate 4
                                               Spike result     Percent
                                                  (ug/1)        recovery*
                                                              Relative percent
                                                              difference (RPD)*
Copper

Lead

Zinc
       <4 0

       <5 0

    2,640
   125

    25

10,000
   107

    22

12,600
 86

 88

100
   104

    19

12,400
83

76

98
 4

15

 2
 * Percent Recovery = [(Spike Result - Original Amount)/Spike  Amount]  x  100

**RPD = [(Sl-S2)/(Sl+S2)/2)]  x 100, where SI is the larger  of  the  two  percent  recovery.

Reference:  Onsite Engineering Report for Horsehead Resource Development  Co.

-------
APPENDIX C
    215

-------
1790g
                                            Table C-l

    Methodology used by Agency to select  regulated  constituents for K001 Volatiles and
Semivolatiles is based on WCAPs for  rotary  kiln  incineration   Namely, the concentration, boiling
point,  and  bond dissociation energies  are the  basis  for  selection of  regulated constituents.
    Concentrat ion
    Volat i les (ppb)
Boi linq Point
  Volat i les
                                                                          Bond  Dissociation  Energy
1.
2
3.
4
Xylenes
Toluene
Ethylbenzene
Benzene
120-170
10-170
55-87
51-83
Semivolat i les (ppra)
1.

2.
3 .
4
5.
6.
7.
8
9
10.
11.
12

13
Naphthalene

Phenanthrene
Acenaphthalene
Fluoranthene
Fluorene
Pyrene
Anthracene
Chrysene
Phenol
Benz(a)anthracene
Pentachlorophenol
Benzo(b/k)
f luoranthrene
Benzo(a)pyrene
26

28
13
13
8
12
7
2
2
2



,000-43

,000-42
,000-21
,000-21
,200-18
,000-17
,300-15
,500-4,
,400-3,
,500-3,
920-3,

940-2,
,000

,000
,000
,000
,000
,000
,000
800
900
400
000

300
1
2
3
4
Xylenes
Ethylbenzene
Toluene
Benzene
140
136
111
80
Boiling point
1

2
3 .
4
5
6
7
8
9
10.
11.
12.
13.
Benzol b/k)
f luoranthrene
Chrysene
Benz(a)anthracene
Pyrene
Fluoranthene
Anthrecene
Phenanthrene
Benzo(a)pyrene
Pentachlorophenol
Fluorene
Acenaphthene
Naphthalene
Phenol
480

44b
435
404
375
342
340
311
309
295
279
218
182
250-940


1
2.
3
4.


1.

2
3.
4
5.
6.
7.
8.
9.
10
11
12
13
(Kcal/mol)
Volatiles
Xylenes
Ethylbenzene
Toluene
Benzene
Bond Dissociation
(Kcal/mol)
Benzo(b/k
f luoranthrene
Benzo(c)pyrene
Chrysene
Benz(a)anthracene
Pyrene
Fluoranthene
Phenanthrene
Fluorene
Anthracene
Acenaphene
Naphthalene
Phenol
. Pentachlorophenol


1
1
1
1


,905
,905
,620
,335
Energy

4

4
3
3
3
3
2
2
2
2
2
1
1

,140

,030
.775
,680
,240
,130
,900
,725
,715
,570
,025
,435
,410
                                            216

-------
             APPENDIX  D

Analytical Method for Determining the
   Thermal Conductivity of a Waste
                217

-------
                               APPENDIX D
    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.
    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.
                                 218

-------
   GUARD
GRADIENT.
   STACK
GRADIENT.
              THERMOCOUPLE
                                        CLAMP
                                      I
                                 I
                           UPPER STACK
                              HEATER
                          TOP  REFERENCE
                              SAMPLE
                                 I
                                 J
      •   /
TEST/SAMPLE
                             / r  I
 BOTTOM
REFERENCE
  SAMPLE
                                 I
                           LOWER STACK
                              HEATER
                                 I
                          LIQUID 'COOLED
                             HEAT SINK
                                 I
             7
    	•£

.
HEAT  FLOW
DIRECTION
                             Figure D-l

                   SCHEMATIC DIAGRAM OF THE COMPARATIVE METHOD
                              UPPER
                              GUARD
                              HEATER
                              LOWER
                              GUARD
                              HEATER
                                 219

-------
    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 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
                            Q.   = v   (dT/dxL
                             in    top       top
and the heat out of the sample  is given by
                        Qout =  AU  _  (dT/dx),  „
                                bottom       bottom
where
                          A - 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   and Q    would be  equal.   If Q.   and  Q   . are in  reasonable
  in      out                       in      out
agreement,  the  average heat  flow  is calculated from
                             Q • 
-------
            APPENDIX  E



CALCULATIONS OF TREATMENT STANDARDS
                221

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DATE
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