&EPA
United States
Environmental Protection
Agency
Office of
Solid Waste
Washington, D C. 20460
EPA/530-SW-88-0009-)
May 1988
Solid Waste
Best
Demonstrated
Available Technology
(BOAT) Background
Document for
K046
Proposed
Volume 11
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,^ BEST DEMONSTRATED AND AVAILABLE TECHNOLOGY (BOAT)
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BACKGROUND DOCUMENT
FOR K046
VOLUME 11
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, D.C. 20460
James R. Berlow, Chief Juan Baez-Martinez
Treatment Technology Section Project Manager
May 1988
U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boulevard, 12th Floor
Chicago, !L 60604-3590
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TABLE OF CONTENTS
Section Page
EXECUTIVE SUMMARY i
1.1 INTRODUCTION 1-1
1.1 Legal Background 1-1
1.1.1 Requirements Under HSWA 1-1
1.1.2 Schedule for Developing Restrictions ... 1-5
1.2 Summary of Promulgated BOAT Methodology 1-6
1.2.1 Waste Treatability Groups 1-8
1.2.2 Demonstrated and Available Treatment
Technologies 1-9
(1) Proprietary or Patented Process ... 1-12
(2) Substantial Treatment 1-12
1.2.3 Collection of Performance Data 1-13
(1) Identification of Facilities for
Site Visits 1-14
(2) Engineering Site Visit 1-16
(3) Sampling and Analysis Plan 1-17
(4) Sampling Visit 1-18
(5) Onsite Engineering Report 1-19
1.2.4 Hazardous Constituents Considered and
Selected for Regulation 1-20
(1) Development of BOAT List 1-20
(2) Constituent Selection Analysis .... 1-31
(3) Calculation of Standards 1-33
1.2.5 Compliance with Performance Standards... 1-34
1.2.6 Identification of BOAT 1-37
(1) Screening of Treatment Data 1-37
(2) Comparison of Treatment Data 1-38
(3) Quality Assurance/Quality Control.. 1-39
1.2.7 BDAT Treatment Standards for "Derived
From" and "Mixed" Wastes 1-41
(1) Wastes From Treatment Trains
Generating Multiple Residues 1-41
(2) Mixtures and Other Derived From
Residues 1-42
(3) Residues from Managing Listed
Wastes or that Contain Listed
Wastes 1-44
1.2.8 Transfer of Treatment Standards 1-45
1.3 Variance from the BDAT Treatment Standard 1-47
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TABLE OF CONTENTS (Continued)
Section Page
2.0 INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 2-1
2.1 Industry Affected and Process Description 2-2
2.1.1 Generation of K046 Waste 2-8
2 . 2 Waste Characterization 2-9
2.3 Determination of Waste Treatability Group 2-10
3.0 APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
3.1 Applicable Treatment Technologies 3-1
3.2 Demonstrated Treatment Technologies 3-3
3.3 Detailed Description of Treatment Technologies.. 3-4
3.3.1 Stabilization of Metals 3-4
4.0 IDENTIFICATION OF BEST DEMONSTRATED AND AVAILABLE
TECHNOLOGY 4-1
4.1 Review of Performance Data 4-3
4.2 Accuracy Correction of Performance Data 4-4
4.3 Statistical Comparison of Performance Data 4-6
4.4 BOAT for K046 Waste 4-8
5.0 SELECTION OF REGULATED CONSTITUENTS 5-1
5.1 BOAT List Constituents Detected in the Untreated
and Treated Waste 5-2
5.2 Constituents Detected in Untreated Waste But Not
Considered for Regulation 5-4
5.3 Constituents Selected for Regulation 5-5
6.0 CALCULATION OF TREATMENT STANDARDS 6-1
6.1 Editing the Data 6-1
6.2 Correcting the Remaining Data 6-2
6.3 Calculating Variability Factors 6-3
6.4 Calculating the Treatment Standards 6-5
REFERENCES
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TABLE OF CONTENTS (Continued)
APPENDICES
APPENDIX A Statistical Analysis A-l
APPENDIX B Analytical QA/QC B-l
APPENDIX C Detection Limits for K046 C-l
APPENDIX D Treatment Standard Calculation D-l
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LIST OF TABLES
Table page
1-1 BOAT CONSTITUENT LIST 1-21
2-1 FACILITIES PRODUCING K046 BY STATE 2-3
2-2 FACILITIES PRODUCING K046 BY EPA REGION 2-4
2-3 MAJOR CONSTITUENT COMPOSITION FOR K046 WASTE 2-11
2-4 BOAT CONSTITUENT COMPOSITION AND OTHER DATA 2-12
3-1 TREATMENT DATA FOR K046 STABILIZATION USING CEMENT . 3-13
3-2 TREATMENT DATA FOR K046 STABILIZATION USING KILN
DUST 3-14
3-3 TREATMENT DATA FOR K046 STABILIZATION USING
LIME/FLYASH 3-15
4-1 TREATMENT DATA USED FOR REGULATION OF K046 WASTE ... 4-5
5-1 BOAT LIST METALS DETECTED IN UNTREATED AND TREATED
WASTE 5-3
6-1 REGULATED CONSTITUENTS AND CALCULATED TREATMENT
STANDARDS FOR K046 WASTEWATERS 6-4
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LIST OF FIGURES
Figure Page
2-1 FACILITIES PRODUCING K046 BY STATE AND EPA
REGION 2-5
2-2 LEAD AZIDE MANUFACTURE 2-6
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EXECUTIVE SUMMARY
BOAT Treatment Standards for K046
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 K046 based on the performance of
treatment technologies determined by the Agency to represent Best
Demonstrated Available Technology (BOAT). This background
document provides the detailed analyses that support this
determination.
These BOAT treatment standards represent instantaneous
maximum acceptable concentration levels for selected hazardous
constituents in the TCLP extracts of wastes or residuals from
treatment and/or recycling. These levels are established as a
prerequisite for disposal of these wastes in units designated as
land disposal units according to 40 CFR Part 268. Wastes which,
as generated, contain the regulated constituents at
concentrations which do not exceed the treatment standards are
not restricted from land disposal units. The Agency has chosen
to set levels for these wastes rather than designating the use of
a specific treatment technology. The Agency believes that this
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allows the generators of these wastes a greater degree of
flexibility in selecting a technology or train of technologies
that can achieve these levels. These standards become effective
as of August 8, 1988, as described in the schedule set forth in
40 CFR 268.10.
According to 40 CFR 261.32 (hazardous wastes from specific
sources) waste code K046 is from the explosives industry and is
listed as follows:
K046: Wastewater treatment sludges from the manufacturing,
formulation, and loading of lead-based initiating
compounds.
Descriptions of the industry and specific processes
generating this waste, as well as descriptions of the physical
and chemical waste characteristics, are provided in Section 2.0
of this document. The four digit Standard Industrial
Classification (SIC) code most often reported for the industry
generating this waste code is 2892 (explosives industry). The
Agency estimates that 62 facilities in the United States are
actively involved in the manufacture, formulation, and loading of
lead-based initiating compounds and could generate K046 waste.
The Agency has examined the sources of this waste from the
explosives industry, the waste composition, potential applicable
and demonstrated technologies, and treatment performance, and has
determined that this waste represents a separate waste
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treatability group. While the Agency has not, at this time,
specifically identified additional wastes which would fall into
this treatability group, this does not preclude the Agency from
using the treatment performance data used to establish these
standards to establish standards for other similar wastes in the
future.
The K046 waste, as generated, is typically classified as a
nonwastewater. The Agency has proposed BDAT treatment standards
for K046 waste. These treatment standards have been proposed for
one (1) BDAT list metal constituent (lead). A detailed
discussion of the selection of constituents to be regulated is
presented in Section 5.0 of this document.
BDAT treatment standards for nonwastewater K046 are proposed
based on performance data from a treatment system which consisted
of stabilization using a Portland cement binder. Testing was
performed on representative samples of K046. Stabilization using
a Portland cement binder was determined to represent the best
demonstrated available technology (BDAT). This determination was
based on a statistical comparison of performance data. The
Agency collected performance data for treatment technologies
including stabilization using Portland cement, kiln dust, and
lime/flyash binders. A statistical comparison was done of the
performance data from these three stabilization technologies.
Based on this analysis, the Agency has determined that the data
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for stabilization using a Portland cement binder indicated the
highest level of performance.
The following table lists the specific BOAT treatment
standards for wastes identified as K046. The Agency is setting
standards based on analyses of TCLP extracts for stabilized K046
nonwastewater. The units for TCLP extract analysis are expressed
on a weight per unit volume basis (mg/1).
Testing procedures are specifically identified in the
quality assurance sections of this document. The quality
assurance analyses conducted indicate the validity of the testing
done and the conclusions made.
BOAT TREATMENT STANDARDS FOR K046 WASTE
NONWASTEWATER
Regulated Constituents TCLP Extract fmq/1)
K046
Lead 0.176
IV
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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 BDAT treatment standards.
1.1 Legal Background
1.1.1 Requirements Under HSWA
The Hazardous and Solid Waste Amendments of 1984 (HSWA),
enacted on November 8, 1984, impose substantial new
responsibilities on those who handle hazardous waste. In
particular, the amendments require the Agency to promulgate
regulations that restrict the land disposal of untreated
hazardous wastes. In its enactment of HSWA, Congress stated
explicitly that "reliance on land disposal should be minimized or
eliminated, and land disposal, particularly landfill and surface
impoundment, should be the least favored method for managing
hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C.
6901(b)(7)).
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One part of the amendments specifies dates on which
particular groups of untreated hazardous wastes will be
prohibited from land disposal unless "it has been demonstrated to
the Administrator, to a reasonable degree of certainty, that
there will be no migration of hazardous constituents from the
disposal unit or injection zone for as long as the wastes remain
hazardous" (RCRA sections 3004(d)(1), (e)(l), (g)(5), 42 U.S.C.
6924 (d)(1), (e)(l), (g)(5)).
For the purpose of the restrictions, HSWA defines land
disposal "to include, but not be limited to, any placement of ...
hazardous waste in a landfill, surface impoundment, waste pile,
injection well, land treatment facility, salt dome formation,
salt bed formation, or underground mine or cave" (RCRA section
3004(k), 42 U.S.C. 6924 (k)). Although HSWA defines land
disposal to include injection wells, such disposal of solvents,
dioxins, and certain other wastes, known as the California List
wastes, is covered on a separate schedule (RCRA section
3004(f) (2), 42 U.S.C. 6924 (f)(2)). This schedule requires that
EPA develop land disposal restrictions for deep well injection by
August 8, 1988.
The amendments also require the Agency to set "levels or
methods of treatment, if any, which substantially diminish the
toxicity of the waste or substantially reduce the likelihood of
migration of hazardous constituents from the waste so that
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short-term and long-term threats to human health and the
environment are minimized" (RCRA section 3004(m)(l), 42 U.S.C.
6924 (m)(l)). Wastes that meet treatment standards established
by EPA are not prohibited and may be land disposed. In setting
treatment standards for listed or characteristic wastes, EPA may
establish different standards for particular wastes within a
single waste code with differing treatability characteristics.
One such characteristic is the physical form of the waste. This
freguently leads to different standards for wastewaters and
nonwastewaters.
Alternatively, EPA can establish a treatment standard that
is applicable to more than one waste code when, in EPA's
judgment, all the waste can be treated to the same concentration.
In those instances where a generator can demonstrate that the
standard promulgated for the generator's waste cannot be
achieved, the Agency also can grant a variance from a treatment
standard by revising the treatment standard for that particular
waste through rulemaking procedures. (A further discussion of
treatment variances is provided in Section 1.3.)
The land disposal restrictions are effective when
promulgated unless the Administrator grants a national variance
and establishes a different date (not to exceed 2 years beyond
the statutory deadline) based on "the earliest date on which
adequate alternative treatment, recovery, or disposal capacity
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which protects human health and the environment will be
available" (RCRA section 3004(h)(2), 42 U.S.C. 6924 (h)(2)).
If EPA fails to set a treatment standard by the statutory
deadline for any hazardous waste in the First Third or Second
Third of the schedule (see section 1.1.2), the waste may not be
disposed in a landfill or surface impoundment unless the facility
is in compliance with the minimum technological requirements
specified in section 3004(o) of RCRA. In addition, prior to
disposal, the generator must certify to the Administrator that
the availability of treatment capacity has been investigated and
it has been determined that disposal in a landfill or surface
impoundment is the only practical alternative to treatment
currently available to the generator. This restriction on the
use of landfills and surface impoundments applies until EPA sets
a treatment standard for the waste or until May 8, 1990,
whichever is sooner. If the Agency fails to set a treatment
standard for any ranked hazardous waste by May 8, 1990, the waste
is automatically prohibited from land disposal unless the waste
is placed in a land disposal unit that is the subject of a
successful "no migration" demonstration (RCRA section 3004(g), 42
U.S.C. 6924(g)). "No migration" demonstrations are based on
case-specific petitions that show there will be no migration of
hazardous constituents from the unit for as long as the waste
remains hazardous.
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1.1.2 Schedule for Developing Restrictions
Under Section 3004(g) of RCRA, EPA was required to establish
a schedule for developing treatment standards for all wastes that
the Agency had listed as hazardous by November 8, 1984.
Section 3004(g) required that this schedule consider the
intrinsic hazards and volumes associated with each of these
wastes. The statute required EPA to set treatment standards
according to the following schedule:
(a) Solvents and dioxins standards must be promulgated by
November 8, 1986;
(b) The "California List" must be promulgated by July 8,
1987;
(c) At least one-third of all listed hazardous wastes must
be promulgated by August 8, 1988 (First Third);
(d) At least two-thirds of all listed hazardous wastes must
be promulgated by June 8, 1989 (Second Third); and
(e) All remaining listed hazardous wastes and all hazardous
wastes identified as of November 8, 1984, by one or
more of the characteristics defined in 40 CFR Part 261
must be promulgated by May 8, 1990 (Third Third).
The statute specifically identified the solvent wastes as
those covered under waste codes F001, F002, F003, F004, and F005;
it identified the dioxin-containing hazardous wastes as those
covered under waste codes F020, F021, F022, and F023.
Wastes collectively known as the California List wastes,
defined under section 3004(d) of RCRA, are liquid hazardous
wastes containing metals, free cyanides, PCBs, corrosives (i.e.,
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a pH less than or equal to 2.0), and any liquid or non-liquid
hazardous waste containing halogenated organic compounds (HOCs)
above 0.1 percent by weight. Rules for the California List were
proposed on December 11, 1986, and final rules for PCBs,
corrosives, and HOC-containing wastes were established
August 12, 1987. In that rule, EPA elected not to establish
standards for metals. Therefore, the statutory limits became
effective.
On May 28, 1986, EPA published a final rule (51 FR 19300)
that delineated the specific waste codes that would be addressed
by the First Third, Second Third, and Third Third. This schedule
is incorporated into 40 CFR 268.10, .11, and .12.
1.2 Summary of Promulgated BOAT Methodology
In a November 7, 1986, rulemaking, EPA promulgated a
technology-based approach to establishing treatment standards
under section 3004(m). Section 3004(m) also specifies that
treatment standards must "minimize" long- and short-term threats
to human health and the environment arising from land disposal of
hazardous wastes.
Congress indicated in the legislative history accompanying
the HSWA that "[t]he requisite levels of [sic] methods of
treatment established by the Agency should be the best that has
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been demonstrated to be achievable," noting that the intent is
"to require utilization of available technology" and not a
"process which contemplates technology-forcing standards" (Vol.
130 Cong. Rec. S9178 (daily ed., July 25, 1984)). EPA has
interpreted this legislative history as suggesting that Congress
considered the requirement under 3004(m) to be met by application
of the best demonstrated and achievable (i.e., available)
technology prior to land disposal of wastes or treatment
residuals. Accordingly, EPA's treatment standards are generally
based on the performance of the best demonstrated available
technology (BOAT) identified for 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 flexibility to develop and implement compliance
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strategies as well as an incentive to develop innovative
technologies.
1.2.1 Waste Treatability Group
In developing the treatment standards, EPA first
characterizes the waste(s). As necessary, EPA may establish
treatability groups for wastes having similar physical and
chemical properties. That is, if EPA believes that wastes
represented by different 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
combines two 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.
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1.2.2 Demonstrated and Available Treatment Technologies
Consistent with legislative history, EPA considers
demonstrated technologies to be those that are commercially used
to treat the waste of interest or a similar waste with regard to
parameters that affect treatment selection (see November 7, 1986,
51 FR 40572). EPA also will consider as treatment those
technologies used to separate or otherwise process chemicals and
other materials. Some of these technologies clearly are
applicable to waste treatment, since the wastes are similar to
raw materials processed in industrial applications.
For most of the waste treatability groups for which EPA will
promulgate treatment standards, EPA will identify demonstrated
technologies either through review of literature related to
current waste treatment practices or on the basis of information
provided by specific facilities currently treating the waste or
similar wastes.
In cases where the Agency does not identify any facilities
treating wastes represented by a particular waste treatability
group, EPA may transfer a finding of demonstrated treatment. To
do this, EPA will compare the parameters affecting treatment
selection for the waste treatability group of interest to other
wastes for which demonstrated technologies already have been
determined. The parameters affecting treatment selection and
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their use for this waste are described in Section 3.2 of this
document. If the1 parameters affecting treatment selection are
similar, then the Agency will consider the treatment technology
also to be demonstrated for the waste of interest. For example,
EPA considers rotary kiln incineration a demonstrated technology
for many waste codes containing hazardous organic constituents,
high total organic content, and high filterable solids content,
regardless of whether any facility is currently treating these
wastes. The basis for this determination is data found in
literature and data generated by EPA confirming the use of rotary
kiln incineration on wastes having the above characteristics.
If no commercial treatment or recovery operations are
identified for a waste or wastes with similar physical or
chemical characteristics that affect treatment selection, the
Agency will be unable to identify any demonstrated treatment
technologies for the waste, and, accordingly, the waste will be
prohibited from land disposal (unless handled in accordance with
the exemption and variance provisions of the rule). The Agency
is, however, committed to establishing treatment standards as
soon as new or improved treatment processes are demonstrated (and
available).
Operations only available at research facilities will not be
considered in identifying demonstrated treatment technologies for
a waste because these technologies would not necessarily be
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commercially available. 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,
(2) substantially diminish the toxicity of the waste or
substantially reduce the likelihood of migration of hazardous
constituents from the waste.
EPA will only set treatment standards based on a technology
that meets the above criteria. Thus, the decision to classify a
technology as "unavailable" will have a direct impact on the
treatment standard. If the best technology is unavailable, the
treatment standard will be based on the next best treatment
technology determined to be available. To the extent that the
resulting treatment standards are less stringent, greater
concentrations of hazardous constituents in the treatment
residuals could be placed in land disposal units.
There also may be circumstances in which EPA concludes that
for a given waste none of the demonstrated treatment technologies
are "available" for purposes of establishing the 3004(m)
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treatment performance standards. Subsequently, these wastes will
be prohibited from continued placement in or on the land unless
managed in accordance with applicable exemptions and variance
provisions. The Agency is, however, committed to establishing
new treatment standards as soon as new or improved treatment
processes become "available."
(1) Proprietary or Patented Processes. If the demonstrated
treatment technology is a proprietary or patented process that is
not generally available, EPA will not consider the technology in
its determination of the treatment standards. EPA will consider
proprietary or patented processes available if it determines that
the treatment method can be purchased or licensed from the
proprietor or is commercially available treatment. The services
of the commercial facility offering this technology often can be
purchased even if the technology itself cannot be purchased.
(2) Substantial Treatment. To be considered "available," a
demonstrated treatment technology must "substantially diminish
the toxicity" of the waste or "substantially reduce the
likelihood of migration of hazardous constituents" from the waste
in accordance with section 3004(m). By requiring that
substantial treatment be achieved in order to set a treatment
standard, the statute ensures that all wastes are adequately
treated before being placed in or on the land and ensures that
the Agency does not require a treatment method that provides
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little or no environmental benefit. Treatment will always be
deemed substantial if it results in nondetectable levels of the
hazardous constituents of concern. If nondetectable levels are
not achieved, then a determination of substantial treatment will
be made on a case-by-case basis. This approach is necessary
because of the difficulty of establishing a meaningful guideline
that can be applied broadly to the many wastes and technologies
to be considered. EPA will consider the following factors in an
effort to evaluate whether a technology provides substantial
treatment on a case-by-case basis:
(a) Number and types of constituents treated;
(b) Performance (concentration of the constituents in the
treatment residuals); and
(c) Percent of constituents removed.
If none of the demonstrated treatment technologies achieve
substantial treatment of a waste, the Agency cannot establish
treatment standards for the constituents of concern in that
waste.
1.2.3 Collection of Performance Data
Performance data on the demonstrated available technologies
are evaluated by the Agency to determine whether the data are
representative of well-designed and well-operated treatment
systems. Only data from well-designed and well-operated systems
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are included in determining BOAT. The data evaluation includes
data already collected directly by EPA and/or data provided by
industry. In those instances where additional data are needed to
supplement existing information, EPA collects additional data
through a sampling and analysis program. The principal elements
of this data collection program are: (a) identification of
facilities for site visits, (b) engineering site visit,
(c) Sampling and Analysis Plan, (d) sampling visit, and (e)
Onsite Engineering Report.
(1) Identification of Facilities for Site Visits. To
identify facilities that generate and/or treat the waste of
concern, EPA uses a number of information sources. These include
Stanford Research Institute's Directory of Chemical Producers,
EPA's Hazardous Waste Data Management System (HWDMS), the 1986
Treatment, Storage, Disposal Facility (TSDF) National Screening
Survey, and EPA's Industry Studies Data Base. In addition, EPA
contacts trade associations to inform them that the Agency is
considering visits to facilities in their industry and to solicit
assistance in identifying facilities for EPA to consider in its
treatment sampling program.
After identifying facilities that treat the waste, EPA uses
this hierarchy to select sites for engineering visits:
(1) generators treating single wastes on site; (2) generators
treating multiple wastes together on site; (3) commercial
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treatment, storage, and disposal facilities (TSDFs); and (4) EPA
in-house treatment. This hierarchy is based on two concepts:
(1) to the extent possible, EPA should develop treatment
standards from data produced by treatment facilities handling
only a single waste, and (2) facilities that routinely treat a
specific waste have had the best opportunity to optimize design
parameters. Although excellent treatment can occur at many
facilities that are not high in this hierarchy, EPA has adopted
this approach to avoid, when possible, ambiguities related to the
mixing of wastes.
When possible, the Agency will evaluate treatment
technologies using commercially operated systems. If performance
data from properly designed and operated commercial treatment
methods for a particular waste or a waste judged to be similar
are not available, EPA may use data from research facilities
operations. Whenever research facility data are used, EPA will
explain why such data were used in the preamble and background
document and will request comments on the use of such data.
Although EPA's data bases provide information on treatment
for individual wastes, the data bases rarely provide data that
support the selection of one facility for sampling over another.
In cases where several treatment sites appear to fall into the
same level of the hierarchy, EPA selects sites for visits
strictly on the basis of which facility could most expeditiously
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be visited and later sampled if justified by the engineering
visit.
(2) Engineering Site Visit. Once a treatment facility has
been selected, an engineering site visit is made to confirm that
a candidate for sampling meets EPA's criteria for a well-designed
facility and to ensure that the necessary sampling points can be
accessed to determine operating parameters and treatment
effectiveness. During the visit, EPA also confirms that the
facility appears to be well operated, although the actual
operation of the treatment system during sampling is the basis
for EPA's decisions regarding proper operation of the treatment
unit. In general, the Agency considers a well-designed facility
to be one that contains the unit operations necessary to treat
the various hazardous constituents of the waste as well as to
control other nonhazardous materials in the waste that may affect
treatment performance.
In addition to ensuring that a system is reasonably well
designed, the engineering visit examines whether the facility has
a way to measure the operating parameters that affect performance
of the treatment system during the waste treatment period. For
example, EPA may choose not to sample a treatment system that
operates in a continuous mode, for which an important operating
parameter cannot be continuously recorded. In such systems,
instrumentation is important in determining whether the treatment
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system is operating at design values during the waste treatment
period.
(3) Sampling and Analysis Plan. If after the engineering
site visit the Agency decides to sample a particular plant, the
Agency will then develop a site-specific Sampling and Analysis
Plan (SAP) according to the Generic Quality Assurance Project
Plan for the Land Disposal Restriction Program ("BOAT"),
EPA/530-SW-87-011. In brief, the SAP discusses where the Agency
plans to sample, how the samples will be taken, the frequency of
sampling, the constituents to be analyzed and the method of
analysis, operational parameters to be obtained, and specific
laboratory quality control checks on the analytical results.
The Agency will generally produce a draft of the
site-specific Sampling and Analysis Plan within 2 to 3 weeks of
the engineering visit. The draft of the SAP is then sent to the
plant for review and comment. With few exceptions, the draft SAP
should be a confirmation of data collection activities discussed
with the plant personnel during the engineering site visit. EPA
encourages plant personnel to recommend any modifications to the
SAP that they believe will improve the quality of the data.
It is important to note that sampling of a plant by EPA does
not mean that the data will be used in the development of
treatment standards for BOAT. EPA's final decision on whether to
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use data from a sampled plant depends on the actual analysis of
the waste being treated and on the operating conditions at the
time of sampling. Although EPA would not plan to sample a
facility that was not ostensibly well-designed and well-operated,
there is no way to ensure that at the time of the sampling the
facility will not experience operating problems. Additionally,
EPA statistically compares its test data to suitable
industry-provided data, where available, in its determination of
what data to use in developing treatment standards. The
methodology for comparing data is presented later in this
section.
(Note: Facilities wishing to submit data for consideration
in the development of BDAT 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
1-18
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Agency attempts to collect sufficient samples of the untreated
waste and solid and liquid treatment residuals so that
variability in the treatment process can be accounted for in the
development of the treatment standards. To the extent
practicable, and within safety constraints, EPA or its
contractors collect all samples and ensure that chain-of-custody
procedures are conducted so that the integrity of the data is
maintained.
In general, the samples collected during the sampling visit
will have already been specified in the SAP. In some instances,
however, EPA will not be able to collect all planned samples
because of changes in the facility operation or plant upsets; EPA
will explain any such deviations from the SAP in its follow-up
Onsite Engineering Report.
(5) Onsite Engineering Report. EPA summarizes all its data
collection activities and associated analytical results for
testing at a facility in a report referred to as the Onsite
Engineering Report (OER). This report characterizes the waste(s)
treated, the treated residual concentrations, the design and
operating data, and all analytical results including methods used
and accuracy results. This report also describes any deviations
from EPA's suggested analytical methods for hazardous wastes
(Test Methods for Evaluating Solid Waste, SW-846, Third Edition,
November 1986).
1-19
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After the Orisite Engineering Report is completed, the report
is submitted to the plant for review. This review provides the
plant with a final opportunity to claim any information contained
in the report as confidential. Following the review and
incorporation of comments, as appropriate, the report is made
available to the public with the exception of any material
claimed as confidential by the plant.
1.2.4 Hazardous Constituents Considered and Selected for
Regulation
(1) Development of BOAT List. The list of hazardous
constituents within the waste codes that are targeted for
treatment is referred to by the Agency as the BOAT constituent
list. This list, provided as Table 1-1, is derived from the
constituents presented in 40 CFR Part 261, Appendix VII and
Appendix VIII, as well as several ignitable constituents used as
the basis of listing wastes as F003 and F005. These sources
provide a comprehensive list of hazardous constituents
specifically regulated under RCRA. The BOAT list consists of
those constituents that could be analyzed using methods published
in SW-846, Third Edition.
The initial BOAT constituent list was published in EPA's
Generic Quality Assurance Project Plan, March 1987
(EPA/530-SW-87-011). Additional constituents will be added to
1-20
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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
Votatiles
Acetone
Acetonitri le
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromomethane
n-Butyl alcohol
Carbon Tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-1,3-butadiene
Chi orod ibromome thane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 ,2-Dibromo-3-chloropropane
1 ,2-Dibromoethane
Dibromomethane
trans- 1,4-Dichloro-2-butene
0 i ch I orod i f I uoromethane
1 , 1 -0 i ch loroethane
1,2-Dichloroethane
1 , 1 -Oichloroethylene
trans- 1,2-0 ichloroethene
1,2-Oichl oropropane
trans-1 ,3-Oichloropropene
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
75-35-3
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
Cont i nued
1-21
-------
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
Volatiles (cont.)
Isobutyl alcohol
Met Hanoi
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methylacrylonitrile
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
T r i ch I oromonof I uromethane
1 ,2,3-Trichloropropane
1, 1, 2- Trichloro- 1,2, 2- trif tuoroethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1,4-Xylene
Semivolati les
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Ani line
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
Benzidine
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
79-34-5
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
108-98-6
92-87-5
50-32-8
Continued
1-22
-------
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
Semivolati tes (cont.)
Benzo(b)f luoranthene
Benzo( gh i )pery I ene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)ethane
Bis(2-chloroethyl)ether
8is(2-chloroisopropy)ether
8is(2-ethythexy)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthlate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroaniline
Chlorobenzilate
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitrile
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
Dibenz(a,h)anthracene
Oibenzo(a,e)pyrene
Dibenzo(a, i )pyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2,6-D ichlorophenol
Oiethyl phthalate
3,3'-Dimethyoxlbenzidine
p- Dimethyl ami noazobenzene
3,3'-Dimethylbenzidine
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1,4-Oinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
CAS No.
205-99-2
191-24-2
207-08-9
106-51-4
111-91-1
111-44-4
39638-32-9
117-81-7
101-55-3
85-68-7
88-85-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
54-27-67
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
51-28-5
Continued
1-23
-------
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
SemivolatUes (cont.)
2,4-Dinitrotoluene
2,6-Oinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine
Diphenylnitrosamine
1,2-Oiphenylhydrazine
Fluoranthene
Fluorene
Hexach I orobenzene
Hexach 1 orobutadi ene
Hexach I orocyc I opent ad i ene
Hexach I oroethane
Hexach I orophene
Hexach I oropropene
Indeno(1,2,3-cd)pyrene
Isosaf role
Methapyri lene
3-Hethycholanthrene
4,4'-Methylenebis(2-chloroaniline)
Methyl methanesulfonate
Napthalene
1 , 4 - Naph thoqu i none
1-Napthylamine
2-Napthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodi ethyl ami ne
N-Nitrosodimethylamine
N - N i t rosomethy I et hy I ami ne
N-Nitrosomorpholine
N-Nitrosopiperidine
n-Nitrosopyrrol idine
2-Methyl-5-nitroaniline
Pentach I orobenzene
Pent ach I oroethane
Pent ach I oron i t robenzene
CAS No.
121-14-2
606-20-2
117-84-0
621-64-7
122-39-4
86-30-6
122-66-7
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
70-30-4
1888-71-7
193-39-5
120-58-1
91-80-5
56-49-5
101-U-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
99-55-5
608-93-5
76-01-7
82-68-8
Cont i nued
1-24
-------
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
Semivolati les
-------
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
Organochlorine Pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chtordane
DOD
DOE
DOT
Dieldrin
Endosulfan I
Endosulfan I!
Endrin
Endrin aldehyde
Heptachlor
Heptachtor epoxide
Isodrin
Kepone
Mehoxychlor
Toxaphene
Phenoxyacetic Acid Herbicides
2,4-Dichlorophenoxyacetic acid
Si I vex
2,4,5-T
Organophosphorous Insecticides
Disulfoton
Fatnphur
Methyl parathion
Parathion
Phorate
PCBs
Aroctor 1016
Aroctor 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
Continued
1-26
-------
TABLE 1-1 (Continued)
BOAT
reference Parameter CAS Mo.
no.
PCBs (cont.)
203 Aroclor 1242 53469-21-9
204 Aroclor 1248 12672-29-6
205 Aroctor 1254 11097-69-1
206 Aroctor 1260 11096-82-5
Pi ox ins and Furans
207 Hexachlorodibenzo-p-dioxins
208 Hexachlorodibenzofuran
209 Pentachlorodibenzo-p-dioxins
210 Pentachlorodibenzofuran
211 Tetrachtorodibenzo-p-dioxins
212 Tetrachlorodibenzofuran
213 2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746-01-6
1-27
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the BOAT constituent list as additional key constituents are
identified for specific waste codes or as new analytical methods
are developed for hazardous constituents. For example, since the
list was published in March 1987, eighteen additional
constituents (hexavalent chromium, xylene (all three isomers),
benzal chloride, phthalic anhydride, ethylene oxide, acetone,
n-butyl alcohol, 2-ethoxyethanol, ethyl acetate, ethyl benzene,
ethyl ether, methanol, methyl isobutyl ketone, 2-nitropropane,
1,1,2-trichloro-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. The
significance of including a constituent in Appendix VIII is
threefold. First, the constituent can be cited as a basis for
listing toxic wastes. Second, permittees are required to monitor
many of these constituents under the detection, compliance, and
corrective action monitoring programs of 40 CFR 264.91(a)(2) and
(3). Third, the Principal Organic Hazardous Constituents
specified in incineration permits are drawn from Appendix VIII.
Although Appendix VII, Appendix VIII, and the F003 and F005
ignitables provide a comprehensive list of hazardous
1-28
-------
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 BDAT list. As mentioned above, however, the BDAT
constituent list is a continuously growing list that does not
preclude the addition of new constituents when analytical methods
are developed.
Constituents were dropped from the BDAT constituent list for
five major reasons:
(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
1-29
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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 constituents 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 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, high
pressure liquid chromatography (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.
1-30
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Two constituents (fluoride and sulfide) are not specifically
included in EPA constituent lists; 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:
o Volatile organics
o Semivolatile organics
o Metals
o Other inorganics
o Organochlorine pesticides
o Phenoxyacetic acid herbicides
o Organophosphorous insecticides
o PCBs
o Dioxins and furans
The constituents were placed in these categories based on their
chemical properties. The constituents in each group are expected
to behave 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 of the constituent being present.
1-31
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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.
1-32
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EPA performs this indicator analysis for two reasons: (1) it
reduces the analytical cost burdens on the treater and (2) it
facilitates implementation of the compliance and enforcement
program. EPA's rationale for selection of regulated constituents
for this waste code is presented in Section 5 of this background
document.
(3) Calculation of Standards. The final step in the
calculation of the BDAT treatment standard is the multiplication
of the average treatment value by a factor referred to by the
Agency as the variability factor. This calculation takes into
account that even well-designed and well-operated treatment
systems will experience some fluctuations in performance. EPA
expects that fluctuations will result from inherent mechanical
limitations in treatment control systems, collection of treated
samples, and analysis of these samples. All of the above
fluctuations can be expected to occur at well-designed and
well-operated treatment facilities. Therefore, setting treatment
standards utilizing a variability factor should be viewed not as
a relaxing of 3004(m) requirements, but rather as a function of
the normal variability of the treatment processes. A treatment
facility will have to be designed to meet the mean achievable
treatment performance level to ensure that the performance levels
remain within the limits of the treatment standard.
1-33
-------
The Agency calculates a variability factor for each
constituent of concern within a waste treatability group using
the statistical calculation presented in Appendix A. The
equation for calculating the variability factor is the same as
that used by EPA for the development of numerous regulations in
the Effluent Guidelines Program under the Clean Water Act. The
variability factor establishes the instantaneous maximum based on
the 99th percentile value.
There is an additional step in the calculation of the
treatment standards in those instances where the ANOVA analysis
shows that more than one technology achieves a level of
performance that represents BOAT. In such instances, the BOAT
treatment standard is calculated by first averaging the mean
performance value for each technology for each constituent of
concern and then multiplying that value by the highest
variability factor among the technologies considered. This
procedure ensures that all the BOAT technologies used as the
basis for the standards will achieve full compliance.
1.2.5 Compliance with Performance Standards
All the treatment standards reflect performance achieved by
the Best Demonstrated Available Technology (BOAT). As such,
compliance with these standards only reguires that the treatment
level be achieved prior to land disposal. It does not require
1-34
-------
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 today
are expressed as a concentration level.
EPA has used both total constituent concentration and TCLP
analyses of the treated waste as a measure of technology
performance. EPA's rationale for when each of these analytical
tests is used is explained in the following discussion.
For all organic constituents, EPA is basing the treatment
standards on the total constituent concentration found in the
treated waste. EPA based its decision on the fact that
technologies exist to destroy the various organics compounds.
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) uses the TCLP value as a measure of
performance. At the time that EPA promulgated the treatment
standards for F001-F005, useful data were not available on total
constituent concentrations in treated residuals and, as a result,
1-35
-------
the TCLP data were considered to be the best measure of
performance.)
For all metal constituents, EPA is using total constituent
concentration and/or the TCLP as the basis for treatment
standards. The total constituent concentration is being used
when the technology basis includes a metal recovery operation.
The underlying principle of metal recovery is the reduction of
the amount of metal in a waste by separating the metal for
recovery; therefore, total constituent concentration in the
treated residual is an important measure of performance for this
technology. Additionally, EPA also believes that it is important
that any remaining metal in a treated residual waste not be in a
state that is easily leachable; accordingly, EPA is also using
the TCLP as a measure of performance. It is important to note
that for wastes for which treatment standards are based on a
metal recovery process, the facility has to comply with both the
total constituent concentration and the TCLP prior to land
disposal.
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.
1-36
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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 data from each of the demonstrated and available
technologies according to the following criteria:
(a) Design and operating data associated with the treatment
data must reflect a well-designed, well-operated system
for each treatment data point. (The specific design
and operating parameters for each demonstrated
technology for this waste code are discussed in Section
3.2 of this document.)
(b) Sufficient QA/QC data must be available to determine
the true values of the treated data. This screening
criterion involves adjustment of treated data to take
into account that the true 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.
(c) The measure of performance must be consistent with
EPA's approach to evaluating treatment by type of
constituents (e.g., total composition data for
organics, and total composition 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 of
whether to include the data. The factors included in this
case-by-case analysis will be the actual treatment levels
achieved, the availability of the treatment data and their
completeness (with respect to the above criteria), and EPA's
assessment of whether the untreated waste represents the waste
1-37
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code of concern. EPA's application of these screening criteria
for this waste code are provided in Section 4 of this background
document.
(2) Comparison of Treatment Data. In cases in which EPA
has treatment data from more than one technology following the
screening activity, EPA uses the statistical method known as
analysis of variance (ANOVA) to determine if one technology
performs significantly better. This statistical method
(summarized in Appendix A) provides a measure of the differences
between two data sets. If EPA finds that one technology performs
significantly better (i.e., the data sets are not homogeneous),
BOAT is the level of performance achieved by the best technology
multiplied by its variability factor.
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 3DAT 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 (i.e., the data sets are
homogeneous), EPA averages the performance values achieved by
each technology and then multiplies this value by the largest
variability factor associated with any of the acceptable
1-38
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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 BDAT
program are presented in EPA's Generic Quality Assurance Project
Plan for Land Disposal Restrictions Program ("BOAT")
(EPA/530-SW-87-001, March 1987).
To calculate the treatment standards for the Land Disposal
Restriction Rules, it is first necessary to determine the
recovery value (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:
(a) If duplicate spike recovery values are available for
the constituent of interest, the data are adjusted by
the lowest available percent recovery value (i.e., the
value that will yield the most conservative estimate of
treatment achieved). However, if a spike recovery
value of less than 20 percent is reported for a
specific constituent, the data are not used to set
1-39
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treatment standards because the Agency does not have
sufficient confidence in the reported value to set a
national standard.
(b) If data are not available for a specific constituent
but are available for an isomer, then the spike
recovery data are transferred from the isomer and the
data are adjusted using the percent recovery selected
according to the procedure described in (a) above.
(c) If data are not available for a specific constituent
but are available for a similar class of constituents
(e.g., volatile organics, acid-extractable
semivolatiles), then spike recovery data available for
this class of constituents are transferred. All spike
recovery values greater than or equal to 20 percent for
a spiked sample are averaged and the constituent
concentration is adjusted by the average recovery
value. If spiked recovery data are available for more
than one sample, the average is calculated for each
sample and the data are adjusted by the lowest average
value.
(d) If matrix spike recovery data are not available for a
set of data to be used to calculate treatment
standards, then matrix spike recovery data are
transferred from a waste that the Agency believes is a
similar matrix (e.g., if the data are for an ash from
incineration, then data from other incinerator ashes
could be used). While EPA recognizes that transfer of
matrix spike recovery data from a similar waste is not
an exact analysis, this is considered the best approach
for adjusting the data to account for the fact that
most analyses do not result in extraction of 100
percent of the constituent. In assessing the matrix
spike data to be transferred, the procedures outlined
in (a), (b), and (c) above are followed.
The analytical procedures employed to generate the data used
to calculate the treatment standards are listed in Appendix 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
1-40
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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
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:
(a) All of the residues from treating the original listed
wastes are likewise considered to be the listed waste
1-41
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by virtue of the derived-from rule contained in 40 CFR
261.3(c)(2). (This point is discussed more fully in
(2) below.) Consequently, all of the wastes generated
in the course of treatment would be prohibited from
land disposal unless they satisfy the treatment
standard or meet one of the exceptions to the
prohibition.
(b) The Agency's proposed treatment standards generally
contain a concentration level for wastewaters and a
concentration level for nonwastewaters. The treatment
standards apply to all of the wastes generated in
treating the original prohibited waste. Thus, all
solids generated from treating these wastes would have
to meet the treatability level 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
treatability level for wastewaters. EPA wishes to make
clear that this approach is not meant to allow partial
treatment in order to comply with the applicable
standard.
(c) The Agency has not performed tests, in all cases, on
every waste that can result from every part of the
treatment train. However, the Agency's treatability
levels 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 BDAT treatment
levels 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
261.3(c)(2) (i)) or the mixture rule (40 CFR 261.3(b)(2) or
because the listed waste is contained in the matrix (see, for
1-42
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example, 40 CFR 261.33(d)). The prohibition for the particular
listed waste consequently applies to this type of waste.
The Agency believes that the majority of these types of
residues can meet the treatment standards for the underlying
listed wastes (with the possible exception of contaminated soil
and debris for which the Agency is currently investigating
whether it is appropriate to establish a separate treatability
subcategorization). For the most part, these residues will be
less concentrated than the original listed waste. The Agency's
treatability levels 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 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.
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(3) Residues from Managing Listed Wastes or that Contain
Listed Wastes. The Agency has been asked if and when residues
from managing hazardous wastes, such as leachate and contaminated
ground water, become subject to the land disposal prohibitions.
Although the Agency believes this question to be settled by
existing rules and interpretative statements, to avoid any
possible confusion the Agency will address the question again.
Residues from managing First Third wastes, listed California
List wastes, and spent solvent and dioxin wastes are all
considered to be subject to the prohibitions for the underlying
hazardous waste. Residues from managing California List wastes
likewise are subject to the California List prohibitions when the
residues themselves exhibit a characteristic of hazardous waste.
This determination stems directly from the derived-from rule in
40 CFR 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 addressing mixing residuals has been to consider them
to be the listed waste and to require that delisting petitioners
address all constituents for which the derived-from waste (or
other mixed waste) was listed as well as other constituents that
could cause the waste to be defined as hazardous. The language
1-44
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in 40 CFR 260.22(b) states that mixtures or derived-from .residues
can be delisted provided a delisting petitioner makes a
demonstration identical to that which a delisting petitioner
would make for the underlying waste. These residues consequently
are treated as the underlying listed waste for delisting
purposes. The statute likewise takes this position, indicating
that soil and debris that are contaminated with listed spent
solvents or dioxin wastes are subject to the prohibition for
these wastes even though these wastes are not the originally
generated waste, but rather are a residual from management (RCRA
section 3004(e)(3)). It is EPA's view that all such residues are
covered by the existing prohibitions and treatment standards for
the listed hazardous waste that these residues contain and from
which they are derived.
1.2.8 Transfer of Treatment Standards
EPA is proposing some treatment standards that are not based
on testing of the treatment technology of the specific waste
subject to the treatment standard. Instead, the Agency has
determined that the constituents present in the subject waste can
be treated to the same performance levels as those observed in
other wastes for which EPA has previously developed treatment
data. EPA believes that transferring treatment performance for
use in establishing treatment standards for untested wastes is
valid technically in cases where the untested wastes are
1-45
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generated from similar industries or similar processing steps.
As explained earlier, transfer of treatment standards to wastes
from similar processing steps requires little formal analysis
because of the likelihood that similar production processes will
produce a waste matrix with similar characteristics. However, in
the case where only the industry is similar, EPA more closely
examines the waste characteristics prior to concluding that the
untested waste constituents can be treated to levels associated
with tested wastes.
EPA undertakes a two-step analysis when determining whether
wastes generated by different processes within a single industry
can be treated to the same level of performance. First, EPA
reviews the available waste characteristic data to identify those
parameters that are expected to affect treatment selection. EPA
has identified some of the most important constituents and other
parameters needed to select the treatment technology appropriate
for a given waste. A detailed discussion of each analysis,
including how each parameter was selected for each waste, can be
found in the background document for each waste.
Second, when an individual analysis suggests that an
untested waste can be treated with the same technology as a waste
for which treatment performance data are already available, EPA
analyzes a more detailed list of constituents that represent some
of the most important waste characteristics that the Agency
1-46
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believes will affect the performance of the technology. By
examining and comparing these characteristics, the Agency
determines whether the untested wastes will achieve the same
level of treatment as the tested waste. Where the Agency
determines that the untested waste is easier to treat than the
tested waste, the treatment standards can be transferred. A
detailed discussion of this transfer process for each waste can
be found in later sections of this document.
1.3 Variance from the BOAT Treatment Standard
The Agency recognizes that there may exist unique wastes
that cannot be treated to the level specified as the treatment
standard. In such a case, a generator or owner/operator may
submit a petition to the Administrator requesting a variance from
the treatment standard. A particular waste may be significantly
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
1-47
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demonstration can be made by showing that attempts to treat the
waste by available technologies were not successful or by
performing appropriate analyses of the waste, including waste
characteristics affecting performance, which demonstrate that the
waste cannot be treated to the specified levels. Variances will
not be granted based solely on a showing that adequate BOAT
treatment capacity is unavailable. (Such demonstrations can be
made according to the provisions in 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
1-48
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in accordance with the requirements of 40 CFR Part 2 (41 FR
36902, September 1, 1976, amended by 43 FR 4000).
The petition should contain the following information:
(1) The petitioner's name and address.
(2) A statement of the petitioner's interest in the
proposed action.
(3) The name, address, and EPA identification number of the
facility generating the waste, and the name and
telephone number of the plant contact.
(4) The process(es) and feed materials generating the waste
and an assessment of whether such process(es) or feed
materials may produce a waste that is not covered by
the demonstration.
(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.
1-49
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(8) A description of those parameters 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.
(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 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.
1-50
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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. After
review of the public comments, EPA will publish its final
determination in the Federal Register as an amendment to the
treatment standards in Part 268, Subpart D.
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2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
The previous section provided the background for the
Agency's study of K046 waste. The purpose of this section is to
describe the industry that will be affected by land disposal
restrictions on waste code K046, and to characterize this waste.
This section includes a description of the industry affected and
the production processes employed in this industry. Also
included is a discussion of how K046 wastes are generated by
these processes. This section concludes with a characterization
of the K046 waste streams, and a determination of the waste
treatability group for this waste.
The full list of hazardous waste codes from specific sources
is given in 40 CFR 261.32 (see discussion in Section 1 of this
document). Within this list, four specific hazardous waste codes
are generated by the explosives industry. One of these is the
listed waste K046.
2.1 Industry Affected and Process Description
According to 40 CFR 261.32 (hazardous wastes from specific
sources), waste code K046 is specifically generated from the
manufacture, formulation, and loading of lead-based initiating
compounds. This waste is listed as follows:
2-1
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K046: Wastewater treatment sludges from the manufacturing,
formulation, and loading of lead-based initiating
compounds.
The four digit standard industrial classification (SIC) code
reported for the explosives industry is 2892 and includes both
commercial firms and government-owned plants operated by private
firms.
The Agency estimates that 62 facilities in the United States
are actively involved in the manufacture, formulation, and
loading of lead-based initiating compounds and could generate
K046 waste. Information from EPA's HWDMS data base provides a
geographic distribution of the number of these facilities across
the United States.
Tables 2-1 and 2-2 present the location of those facilities
which may generate waste code K046 in each state and in each EPA
region. As can be seen in Tables 2-1 and 2-2, these facilities
are concentrated in EPA Regions II, III, V, and VI. Figure 2-1
illustrates these data plotted on a map of the United States.
2-2
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Table 2-1 Facilities Producing K046 by State
State (EPA Region) Number of Facilities
Arkansas (IV) 2
California (IX) 4
Colorado (VIII) 1
Connecticut (I) 1
Idaho (X) 3
Illinois (V) 3
Indiana (V) 2
Iowa (VII) 1
Louisiana (VI) 5
Maryland (III) 2
Massachusetts (I) 1
Michigan (V) 2
Minnesota (IV) 2
Missouri (VII) 2
New Jersey (II) 5
New York (II) 3
North Carolina (IV) 1
Ohio (V) 4
Oregon (X) 1
Pennsylvania (III) 3
Texas (VI) 9
Virginia (III) 2
West Virginia (III) 1
Wisconsin (V) 1
Puerto Rico (II) 1
Total 62
Reference: HWDMS, January, 1986.
2-3
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Table 2-2 Facilities Producing K046 by EPA Region
EPA Region Number of Facilities
I 2
II 9
III 8
IV 1
V 14
VI 16
VII 3
VIII 1
IX 4
X _4
Total 62
Reference; HWDMS, January, 1986
2-4
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NJ
I
Ol
FIGURE 2-1 FACUTES PRODUCINQ K046 BY STATE AND EPA REGION
-------
Initiating compounds are generally organic- or lead-based. The
major organic-based initiating compounds are as follows:
tetracene, trinitroresorcinol (TNR), tetry, and nitromannite.
The major lead-based initiating compounds are as follows: lead
azide, lead styphnate, and lead mononitroresorcinate (LMR).
One manufacturing process for the production of lead azide
is presented below.
The listed waste K046 is generated in the production of lead
azide, and also in other processes. As shown in Figure 2-2, one
process for producing lead azide is by reacting lead nitrate or
lead acetate with sodium azide. The reaction takes place in a
precipitator where the lead azide product is precipitated and
separated from the reaction by-products. The precipitate,
consisting mainly of lead azide, is washed with water to remove
traces of impurities and is removed from the washer as the lead
azide product. The wash water (wastewater) is further treated
and discharged.
The filtrate from the precipitator goes to a treatment tank
where chemicals are added to chemically transform traces of lead
azide. Sodium carbonate, sodium nitrite, and nitric acid are
generally used as treatment chemicals in the treatment tank.
These chemicals convert the lead azide into a mixture of lead
carbonate and lead nitrate. Water is also added to the treatment
2-6
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10
WATER
LEAD NITRATE
or LEAD ACETATE
SODIUM AZIDE
PRECIPITATOR
WATER
PRECIPITATE
WASHER
LEAD AZIDE
PRODUCT
FILTRATE
SODIUM CARBONATE,
MI en,
T .T T
NITRIC ACID
SODIUM NITRATE
TREATMENT
TANK
I
WASTEWATER TO
FURTHER TREATMENT
WASTEWATER TO
FURTHER TREATMENT
SLUDGES FROM
TREATMENT OF
WASTEWATER IS
ALSO K046
LEAD CARBONATE
SLUDGE
(K046)
Reference: USEPA Effluent Guidelines Division. Office of Water and Hazardous
Materials. Washington. D. C. EPA No. 4-40/176-060. March 1976.
JEG REV.1 MAR. 26. 1988
FIGURE 2-2 LEAD AZDE MANUFACTURE
-------
tank to wash the filtrate stream from the precipitator. The
sludge from the treatment tank is removed and sent to disposal or
further treatment. This is the listed waste K046. The
wastewater from the treatment tank is further treated and
discharged. Sludges from the treatment of these wastewaters also
constitute K046 waste.
2.1.1 Generation of K046 Waste
The listed waste K046 is generated in the production of
initiating compounds such as lead azide. In the production of
lead azide, K046 is generated at the treatment tank. The
filtrate (wastewater) from the precipitator flows to the
treatment tank where chemicals such as nitric acid, sodium
nitrite, and sodium carbonate are added to chemically transform
lead azide in the wastewater to a mixture of lead nitrate and
lead carbonate. A sludge, consisting mainly of lead carbonate
and other insoluble lead salts, is formed in the treatment tank.
This sludge, which is the listed waste K046, is removed from the
treatment tank and sent to disposal.
Wastewater treatment sludges are also generated in the
manufacture and processing of other lead-based initiators, such
as lead styphnate and lead mononitroresorcinate (LMR). The
Agency has no data regarding the physical and chemical
characteristics of the wastewater treatment sludges generated by
2-8
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these processes. However, the Agency has no reason to believe
that the wastewater treatment sludges generated by these
processes are different from the K046 waste generated by lead
azide production. Therefore, the Agency will use the K046 waste
generated by lead azide manufacture to represent the wastewater
treatment sludges generated by the above processes.
2.2 Waste Characterization
This section includes all waste characterization data
available to the Agency for the K046 waste treatability group.
An estimate of the major constituents which comprise this waste
and their approximate concentrations is presented in Table 2-3.
The percent concentration of each major constituent in the waste
was determined from best estimates based on chemical analyses.
Table 2-3 shows that the major constituent in K046 is water (95
percent). The primary BOAT list metal constituent present in
K046 is lead.
The ranges of BOAT list constituents present in the waste
and all other available data concerning parameters affecting
treatment selection are presented in Table 2-4. This table lists
the levels of BDAT list metals present in K046 waste. Other
parameters analyzed in the waste are also given (sulfate,
sulfide, total oil and grease, pH, and total organic carbon).
2-9
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Familiarization samples of K046 were taken by the Agency
prior to the sampling visit. No BOAT list organics were detected
in these samples. Tables 2-3 and 2-4 together provide a thorough
characterization of the K046 waste.
2.3 Determination of Waste Treatabilitv Group
Fundamental to waste treatment is the concept that the type
of treatment technology used and the level of treatment achieved
depend on the physical and chemical characteristics of the waste.
In cases where EPA believes that wastes represented by different
waste codes can be treated to similar concentration using the
same technologies, the Agency combines the codes into one
treatability group. In this case, the K046 waste from the
manufacturing, processing, and loading of lead-based initiating
compounds was determined to represent a single waste treatability
group.
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Table 2-3 Major Constituent Composition for K046 Wastes*
K046 Waste
Constituent Concentration (Wt. Percent)
Water 95
Lead <1
Other BOAT List Metals <1
Sodium Sulfide/Sodium Hydroxide >3
TOTAL 100
*Percent concentrations presented here were determined based on
chemical analyses.
Table 2-4
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TABLE 2-4 BOAT CONSTITUENT COMPOSITION AND OTHER DATA
BOAT CONSTITUENTS
DETECTION
LIMIT
UNTREATED WASTE K046*
TOTAL
TCLP
Metals (tng/l)
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
0.02
0.01
0.2
0.005
0.01
0.02
0.025
0.01
0.0003
0.04
0.005
0.05
0.01
0.05
0.05
Other Parameters (mg/l)
0.022
ND
ND
ND
ND
ND
ND
967
0.00084
ND
ND
ND
ND
ND
0.295
ND
ND
0.228
ND
ND
ND
ND
103
ND
ND
ND
ND
ND
ND
0.335
Sulfate 2
Sulfide 1
Oil & Grease
Total Organic Carbon (Avg.)
PH
190
ND
3.8
461
11.91
NA
NA
NA
NA
NA
* - Values obtained from Onsite Engineering Report for K046 (Waterways
Experiment Station).
NA - Not analyzed.
ND - Not detected.
Note:
Only one sample of K046 was analyzed. Total organic carbon results
are an average of four analyses on the same sample.
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3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
The previous section described the industry that will be
affected by restrictions on K046 waste, and presented a
characterization of this waste. The purpose of this section is to
describe treatment technologies for K046 waste that EPA has
identified as applicable, and to describe which of the applicable
technologies EPA has determined to be demonstrated. The
performance data available for these technologies are also
presented.
3.1 Applicable Treatment Technologies
Familiarization samples taken by the EPA prior to the
sampling visit showed that K046 waste consists primarily of
water, with BOAT list metals present at treatable concentrations
and BOAT list organics present at untreatable (de minimis)
concentrations. Because the levels of BOAT list metals were
treatable, while the levels of BOAT list organics were
untreatable, the treatment technologies considered applicable for
treatment of K046 waste are those which treat BOAT list metals.
No treatment for BDAT list organics is required.
The EPA has therefore identified the following applicable
technology for treatment of K046 waste: stabilization using
various binder materials (cement, kiln dust and lime/flyash).
3-1
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Metals recovery is not judged to be an applicable technology due
to the low metal concentrations present.
Analysis of the K046 sludge indicates that it consists
mainly of water (95 percent). BOAT constituents constitute less
than two percent, and non-BDAT constituents (sodium sulfide and
sodium hydroxide) constitute greater than three percent of the
K046 waste. Of the BOAT list metals present, lead is present in
the highest concentration. The selection of the treatment
technologies applicable for stabilizing metal constituents in
K046 waste is based on available literature sources and field
testing.
For K046 waste, the Agency has identified the following
stabilization technologies as being applicable: cement-based
processes, which use cement binder additives to chemically bind
the metal constituents in a solidified waste matrix; lime-based
processes, which use lime and other additives to chemically bind
the metal constituents in a solidified waste matrix; kiln dust
(or pozzolan) processes, which use flyash from cement kilns and
lime to chemically bind metal components in a solidified waste
matrix.
3-2
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3.2 Demonstrated Treatment Technologies
The Agency believes that none of the above applicable
technologies are currently in commercial use for treating K046
waste. The Agency therefore decided to collect performance data
for treatment systems that are demonstrated commercially for
wastes similar to K046.
Three stabilization processes were tested by the Agency as
follows:
o cement-based process;
o kiln dust process; and
o lime/flyash process
These three stabilization systems were chosen by the EPA for
collecting performance data because they are currently being used
to stabilize wastes similar to K046 (in terms of parameters
affecting treatment selection) on a commercial basis.
Performance data collected by EPA for the three
stabilization processes, namely cement, kiln dust, and
lime/flyash, are presented in Tables 3-1 to 3-3. Tables 3-1
through 3-3 present the analytical data for samples sets 1
through 3 for waste code K046 collected during the Agency's
sampling visit. The untreated K046 waste and the treated
(stabilized) K046 waste for each sample set were analyzed for
BOAT metals, inorganics, and other parameters. Also included in
Tables 3-1 through 3-3 are the design values and actual operating
3-3
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ranges for the key operating parameters of the cement, kiln dust,
and lime/flyash processes. A more detailed discussion of the
treatment technology systems for which the Agency has collected
performance data follows.
3.3 Detailed Description of Treatment Technologies
3.3.1 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.
Applicability and Use of Stabilization
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 BDAT list
metals, having a high filterable solids content, low TOC content,
and low oil and grease content. This technology is commonly used
3-4
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to treat residuals generated from treatment of electroplating
wastewaters. For some wastes, an alternative to stabilization is
meta1 recovery.
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
leachability 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 solid material.
Portland Cement-Based Process
Portland cement is a mixture of powdered oxides of calcium,
silica, aluminum, and iron, produced by kiln burning of materials
3-5
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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 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.
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,
3-6
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again, can be used to reduce permeability and thereby further
decrease leaching potential.
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 (eguipment 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.
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.
3-7
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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.
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
(1) fine particulates, (2) oil and grease, (3) organic compounds,
and (4) certain inorganic compounds.
Fine Particulates
For both cement-based and lime/pozzolan-based processes, the
literature states that very fine solid 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.
3-8
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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.
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.
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 leachability potential.
3-9
-------
Accordingly, EPA will examine these constituents when making
decisions regarding transfer of treatment standards based on
stabilization.
Design and Operating Parameters
In designing a stabilization system, the principal
parameters that are important to optimize so that the amount of
leachable metal constituents is minimized are (1) selection of
stabilizing agents and other additives, (2) ratio of waste to
stabilizing agents and other additives, (3) degree of mixing, and
(4) curing conditions.
(1) 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 leachability 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 lime/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.
3-10
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(2) 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 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.
(3) 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
under-mixing 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
3-11
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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.
(4) 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 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.
3-12
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TABLE 3-1 TREATMENT DATA FOR K046 STABILIZATION USING CEMENT
UNTREATED WASTE
BOAT CONSTITUENTS
Metals (mg/l)
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
Other Parameters (mg/t)
Sulfate
Sulfide
Oi 1 & Grease
Total Organic Carbon (Avg.)
pH
* - Treated waste data reflect
NA - Kot analyzed.
NO - Not detected (see Appendix
TOTAL
0.022
NO
ND
ND
ND
ND
ND
967
0.00084
ND
ND
ND
ND
ND
0.295
190
ND
3.8
461
11.91
analysis of TCLP
C for detection
TCLP
ND
ND
0.228
ND
ND
ND
ND
103
ND
ND
ND
ND
ND
ND
0.335
NA
NA
NA
NA
NA
extracts.
limits).
TREATED WASTE*
SS 1
ND
ND
1.8
ND
ND
0.033
ND
0.072
0.0003
ND
ND
ND
ND
ND
0.036
NA
NA
NA
NA
NA
SS 2
ND
ND
1.8
ND
ND
ND
ND
0.1
ND
ND
ND
ND
ND
ND
0.027
NA
NA
NA
NA
NA
SS 3
ND
ND
1.8
ND
ND
.03
0.019
0.062
ND
ND
ND
ND
ND
ND
0.112
NA
NA
NA
NA
NA
OPERATING PARAMETERS
Binder to
Waste Ratio Run
1.2 A
1.2 8
1.2 C
Dry Waste +
Water Weight
(9)
600
600
600
Binder
Weight
(9)
720
720
720
Mixture pH
(standard
units)
12.35
12.35
12.35
3-13
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TABLE 3-2 TREATMENT DATA FOR K046 STABILIZATION USING KILN DUST
UNTREATED WASTE
BOAT CONSTITUENTS
Metals (mg/t)
154 Antimony
155 Arsenic
156 Barium
157 Beryl lium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc-
Other Parameters
600
600
600
Binder
Weight
840
840
840
Mixture pH
(standard
units)
12.25
12.15
12.35
3-14
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TABLE 3-3 TREATMENT DATA FOR K046 STABILIZATION USING LIME/FLYASH
BOAT CONSTITUENTS
UNTREATED WASTE
TOTAL TCLP
TREATED WASTE*
SS 1 SS 2 SS 3
Metals (mg/t)
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
Other Parameters (mg/l)
Sulfate
Sulfide
Oi 1 & Grease
Total Organic Carbon (Avg.)
pH
* - Treated waste data reflect
NA - Not analyzed.
NO - Not detected (see Appendix
OPERATING PARAMETERS
Lime Flyash
to to
Waste Waste
Ratio Ratio Run
0.7 0.7 A
0.7 0.7 B
0.7 0.7 C
0.022
ND
ND
ND
ND
ND
ND
967
0.00084
ND
ND
ND
ND
ND
0.295
190
ND
3.8
461
11.91
analysis of TCLP
C for detection
Dry Waste +
Water Weight
(9)
600
600
600
ND
ND
0.228
ND
ND
ND
ND
103
ND
ND
NO
ND
ND
ND
0.335
NA
NA
NA
NA
NA
extracts.
limits).
Lime
Weight
(9)
420
420
420
ND
ND
3.7
ND
ND
ND
0.008
0.4
ND
ND
ND
ND
0.001
ND
0.04
NA
NA
NA
NA
NA
Flyash
Weight
(9)
420
420
420
ND
ND
3.5
ND
ND
ND
ND
0.4
ND
0.07
ND
ND
0.002
ND
ND
NA
NA
NA
NA
NA
ND
ND
3.5
ND
ND
ND
0.01
0.4
ND
ND
ND
ND
0.002
ND
ND
NA
NA
NA
NA
NA
Mixture pH
(standard
units)
12.95
13.05
12.95
3-15
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4. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TREATMENT
TECHNOLOGY FOR K046
The previous section described applicable treatment
technologies for waste code K046, and the available performance
data for these technologies. This section describes how the
performance data collected by the Agency were evaluated to
determine which treatment technology system should be considered
BOAT for waste code K046. Three stabilization techniques are
considered in this section in the selection of BOAT for K046
nonwastewater. These techniques are:
o stabilization using a Portland cement binder,
o stabilization using a kiln dust binder, and
o stabilization using a lime/flyash binder.
As discussed in Section 3, the Agency collected performance
data for the treatment of waste code K046 from these three
stabilization systems.
No additional performance data were available for the
treatment of K046 waste.
The topics covered in this section include descriptions of
the data screening process employed for selecting BOAT, the
methods used to ensure accuracy of the analytical data, and the
4-1
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analysis of variance .(ANOVA) tests performed in identifying the
best technology for the treatment of K046 waste.
In general, performance data are screened according to the
following three conditions:
o proper design and operation of the treatment system;
o the existence of quality assurance/quality control
measures in the data analysis; and
o the use of proper analytical tests in assessing
treatment performance.
Sets of performance data which do not meet these three
conditions are not considered in the selection of BOAT. In
addition, if performance data indicate that the treatment system
was not well-designed and well-operated at the time of testing,
these data would also not be used.
The remaining performance data are then corrected to account
for incomplete recovery of certain constituents during the
analyses. ' Finally, in cases where the Agency has adequate
performance data for treatment of the waste by more than one
technology, an analysis of variance (ANOVA) test is used to
select the best treatment technology.
4-2
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4.1 Review of Performance Data
In the selection of BDAT for treatment of K046
nonwastewater, the only performance data available were those
collected during the Agency's sampling visit. Three data sets
were collected by the Agency for treatment of the nonwastewater
by stabilization using each of the following binder materials:
Portland cement, kiln dust, and lime/flyash. These data were
evaluated to determine whether any of the data represented poor
design or operation of the system. None of the data sets were
deleted due to poor operation of the stabilization system during
the time data were being collected. Therefore, all data sets
were used in the selection of BDAT and the development of
treatment standards for K046 nonwastewater.
Toxic Characteristic Leaching Procedure (TCLP) data were
used in setting treatment standards for waste code K046, since
BDAT list metals were present in the untreated waste at treatable
levels. For a discussion on the use of TCLP data in setting
treatment standards, refer to Section 1 of this background
document.
In instances where a selected constituent was not detected
in the treated waste, the treated value for that constituent was
assumed to be the practical guantification level. This was the
case for several of the BDAT list metal constituents. Analytical
4-3
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values for the BOAT list metals of concern in the treated waste
are presented in Table 4-1. These numbers are taken from Tables
3-1 to 3-3 of this document.
4.2 Accuracy Correction of Performance Data
After the analytical data were screened as described above,
the Agency adjusted the remaining data using analytical recovery
values in order to take into account analytical interferences and
incomplete recoveries associated with the chemical makeup of the
sample. The Agency developed the recovery data (also referred to
as accuracy data), by first analyzing a waste sample for a given
constituent and then adding 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. At least two recovery values were calculated for spiked
constituents, and the analytical data were adjusted for accuracy
using the lowest recovery value for each constituent.
Adjustment of the analytical data was accomplished by
calculating an accuracy factor from the percent recoveries for
each selected constituent. The reciprocal of the lower of the
two recovery values divided by 100, yields the accuracy factor.
The corrected concentration for each sample set is obtained by
4-4
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TABLE 4-1 Treatment Data Used for Regulation of K046 Waste
BOAT List
Constituent
Cement:
Barium
Lead
Zinc
^ Kiln Oust:
1
Ul _ .
Barium
Lead
Zinc
Lime/Flyash:
Barium
Lead
Zinc
Analytical
SS1
(TCLP)
(mg/l)
1.8
0.072
0.036
0.3
0.9
<0.02
3.7
0.4
0.04
Concentrations
SS2
(TCLP)
(mg/l)
1.8
0.1
0.027
0.4
1.1
<0.02
3.5
0.4
<0.02
(1)
SS3
(TCLP)
(mg/l)
1.8
0.061
0.112
0.3
0.68
<0.02
3.5
0.56
<0.02
Matrix
Spi ke
(TCLP)
(X recovery)
104
77.4
96
108
90.5
69
99
69.5
67
Matrix
Spike
Duplicate Accuracy
(TCLP) Correction
(X recovery) Factor
110 0.96
77.4 1.29
98 1.04
106 0.94
94.5 1.10
72 1.45
84 1.19
77.2 1.44
74 1.49
Accuracy- Corrected
SS1 SS2
(TCLP) (TCLP)
(mg/t) (mg/t)
1.728 1.728
0.093 0.129
0.038 0.028
0.282 0.376
0.994 1.215
0.029 0.029
4.140 4.165
0.576 0.576
0.060 0.030
Concentrations
SS3
(TCLP)
(mg/t)
1.728
0.080
0.117
0.282
1.105
0.029
4.165
0.576
0.030
(2)
Average
(TCLP)
(mg/l)
1.728 .
0.101
0.061
0.313
1.105
0.029
4.157
0.576
0.040
1. Onsite Engineering Report for K046 (Waterways Experiment Station).
2. A sample calculation is shown in Appendix B of this Background Document.
-------
multiplying the accuracy factor by the uncorrected data value.
The actual recovery values for the selected constituents are
presented in Table 4-1 along with the calculated accuracy
factors.
The accuracy factors calculated for the selected
constituents in K046 varied from a high value of 1.29 for lead to
a low value of 0.96 for barium. The corrected concentration
values for the selected constituents in the waste are shown for
the three treatment systems in Table 4-1. These corrected
concentration values were obtained by multiplying the accuracy
factors by the uncorrected concentration values for the selected
constituents in the treated waste. An arithmetic average value,
representing the treated waste concentration, was calculated for
each selected constituent from the three corrected values. These
averages are presented in Table 4-1. These adjusted values for
the three stabilization techniques tested were then used to
determine BOAT for waste code K046.
4.3 Statistical Comparison of Performance Data
In cases where the Agency has adequate performance data on
treatment of the same or similar wastes using more than one
technology, an analysis of variance (ANOVA) test is performed to
determine if one of the technologies provides significantly the
best treatment compared to the others. In cases where a
4-6
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particular treatment technology is shown to provide the best
treatment, the treatment standards will be based on this best
technology. The procedure followed for the analysis of variance
(ANOVA) test is described in Appendix A.
In order to determine BOAT for waste code K046, three
demonstrated technologies, for which adequate performance data
were available, were considered for the treatment of these
wastes:
o stabilization using a Portland cement binder,
o stabilization using a kiln dust binder, and
o stabilization using a lime/flyash binder.
The corrected data for all sample sets were used to perform
analysis of variance (ANOVA) tests to compare these three
stabilization technologies. The three treatment technologies
were compared based on the concentration of primary waste
constituents (lead and zinc) in the treated waste. The rationale
for selecting these constituents for the ANOVA comparison is
presented in Section 5. The ANOVA calculations are summarized in
Appendix D.
4-7
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The statistical -results of the ANOVA test for K046 waste
indicate the following:
1) Stabilization using a Portland cement binder gives
better treatment for lead in K046 than stabilization
using a kiln dust or lime/flyash binder.
2) All three stabilization techniques achieved equivalent
treatment for zinc in K046.
4.4 BOAT for K046 Waste
Stabilization using a Portland cement binder provides
significantly better or equivalent treatment overall for the
primary constituents present in waste code K046 when compared to
either stabilization using a kiln dust binder or stabilization
using a lime/flyash binder. Therefore, the Agency determined
stabilization using a Portland cement binder to be BDAT for waste
code K046.
Stabilization is judged to be available to treat K046
nonwastewater. The Agency believes this technology to be
available because (1) this technology is commercially available;
and (2) this technology provides a substantial reduction in the
levels of BDAT list constituents present in waste K046.
4-8
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5. SELECTION OF REGULATED CONSTITUENTS
In the previous section, the best demonstrated available
technology (BOAT) for treating waste code K046 was determined to
be stabilization using a Portland cement binder material. In
this section, the necessary constituents are identified for
assuring the most effective treatment of the wastes. This is
done by following a four-step procedure:
o selecting those BOAT list constituents which will be
analyzed;
o identifying the BOAT list constituents found in both
the untreated and treated waste;
o determining the BOAT list constituents which are
present at treatable levels, and
o selecting the regulated constituents.
As discussed in Section 1, the Agency has developed a list
of hazardous constituents (Table 1-1) from which the constituents
to be regulated are selected. The list is a "growing list" that
does not preclude the addition of new constituents as additional
key parameters are identified. The list is divided into the
following categories: volatile organics, semivolatile organics,
metals, inorganics, organochlorine pesticides, phenoxyacetic acid
herbicides, organophosphorous pesticides, PCBs, and dioxins and
furans. The constituents in each category have similar chemical
properties and are expected to behave similarly during treatment,
with the exception of the inorganics.
5-1
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5.1 BOAT List Constituents Detected in the Untreated and Treated
Waste
Using EPA-collected data, the Agency identified those
constituents that were detected in the untreated and treated K046
waste. The BOAT list of constituents (see Table 1-1, Section 1)
provided the target list of constituents. EPA collected nine
sets of data at one facility (see the Onsite Engineering Report
for K046 for more details) to evaluate the treatment of waste
code K046 by stabilization. These nine data sets were used to
identify the constituents detected in the untreated and treated
waste. The detection limits for the BOAT list of constituents
are presented in Appendix C.
The familiarization sample of K046 taken by the Agency prior
to the sampling visit indicated that the organic and inorganic
classes of BOAT list constituents (other than metals) are not
present at treatable concentrations in the untreated waste (see
Section 2). Therefore, the untreated and treated waste samples
of K046 taken during the sampling visit were not analyzed for any
of the classes of BOAT list organics (volatiles, semivolatiles,
organochlorine pesticides, phenoxyacetic acid herbicides,
organophosphorus pesticides, PCBs, and dioxins/furans), or for
BOAT list inorganics (other than metals).
Table 5-1 indicates which of the BOAT list metals were
detected in the untreated and treated waste. The following
5-2
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TABLE 5-1 BOAT List Hetals Detected in Untreated and Treated Waste
Parameter
Untreated
K046
Total
Untreated
K046
TCLP
Treated
K046
TCLP
Hetals
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
Antimony
Arsenic
Bariun
Beryllium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
D
NO
NO
ND
NO
ND
0
0
ND
ND
ND
ND
ND
ND
D
ND
ND
D
ND
ND
ND
ND
D
ND
ND
ND
ND
ND
ND
D
ND
ND
D
ND
ND
D
D
D
D
ND
ND
ND
ND
ND
D
D - Detected
ND - Not detected
5-3
-------
constituents were detected in the untreated waste K046:
antimony, lead, mercury, and zinc. The TCLP extract for
untreated K046 contained barium, lead, and zinc. The following
constituents were detected in the TCLP extract of treated waste
K046: barium, chromium, copper, lead, mercury, and zinc.
The Agency believes that copper and mercury were present in
the TCLP extract from untreated K046 waste, but were not detected
due to the detection limits (0.025 mg/1 and 0.0003 mg/1,
respectively). The chromium in treated K046 is thought to have
come from the cement binder used. However, no analysis for BOAT
list metals was performed on the cement binder to determine if
chromium was present in the cement binder.
5.2 Constituents Detected in Untreated Waste But Not Considered
for Regulation
The Agency evaluated the analytical data for each
constituent to determine if the constituent should be selected
for regulation. The Agency was guided by the criteria for
selecting regulated constituents as described in Section 1 of
this background document.
The metals detected in the TCLP extract for untreated K046
were barium, lead, and zinc. ANOVA calculations were performed
to determine which of these BDAT list metals were treated by the
treatment system. The results of these calculations follow.
5-4
-------
Barium was present in the TCLP extract for untreated K046
waste at 0.228 mg/1. The concentration of barium in the TCLP
extract for stabilized K046 was 1.8 mg/1. Barium was not
selected as a regulated constituent for K046 because it was not
treated by the treatment system.
Zinc was present in the TCLP extract for untreated K046
waste at 0.335 mg/1. The concentration of zinc in the TCLP
extract for treated K046 waste ranged from 0.027 to 0.112 mg/1.
Zinc was not selected as a regulated constituent for waste code
K046 because it was not treated significantly by the treatment
system. Also, stabilization of the selected constituent serves
as an effective surrogate for the treatment of zinc.
5.3 Constituents Selected for Regulation
Lead was present in the TCLP extract for untreated K046
waste at 103 mg/1. The concentration of lead in the TCLP extract
for treated K046 waste ranged from 0.061 to 0.100 mg/1. Lead was
selected as a regulated constituent for K046 waste because it was
present in the untreated waste at significant levels and its
regulation will control the concentration of other metals present
in the untreated waste.
5-5
-------
6. CALCULATION OF BDAT TREATMENT STANDARDS
In this section, the actual treatment standards for waste
code K046 are presented. These standards were calculated based
on the performance of the demonstrated treatment system which was
determined by the Agency to be the best for treating both waste
codes. In Section 4, BDAT for waste code K046 was determined to
be stabilization using a Portland cement binder. The previous
section identified the constituents to be regulated for waste
code K046.
As discussed in Section 1, the Agency calculated the BDAT
treatment standards for waste code K046 by following a four-step
procedure: (1) editing the data; (2) correcting the remaining
data for analytical interference; (3) calculating adjustment
factors (variability factors) to account for process variability;
and (4) calculating the actual treatment standards using
variability factors and average treatment values. The four steps
in this procedure are discussed in detail in Sections 6.1 through
6.4.
6.1 Editing the Data
Three sets of treatment data for waste code K046 were
collected by the Agency at one facility which operated a
treatment system consisting of stabilization using a Portland
6-1
-------
cement binder. The Agency evaluated the three data sets to
determine if the treatment system was well operated at the time
of the sampling visit. The operating data collected indicate
that the treatment system was well operated during the collection
of all data sets. For further details on the three data sets,
see the Onsite Engineering Report for K046. All of the available
data sets were used to calculate treatment standards.
Toxic Characteristic Leaching Procedure (TCLP) data were
used in setting treatment standards for waste code K046, since
BOAT list metals were present in the untreated waste at
relatively high concentrations. For a discussion on the use of
TCLP data in setting treatment standards, refer to Section 1 of
this background document.
In instances where a selected constituent was not detected
in the treated waste, the treated value for that constituent was
assumed to be the Practical Quantification Level. This was not
the case for any of the regulated constituents in K046.
Analytical values for the treated waste are presented in Section
3, Tables 3-1 through 3-3 of this report.
6.2 Correcting the Remaining Data
Data values for the constituents selected for regulation
were taken from the three data sets. These values were corrected
6-2
-------
in order to take into account analytical interferences associated
with the chemical make-up of the treated sample. This was
accomplished by calculating an accuracy factor from the percent
recoveries for each selected constituent. The reciprocal of the
lower of the two recovery values divided by 100, yields the
accuracy factor. The corrected concentration for each
constituent in each sample set is obtained by multiplying the
accuracy factor by the uncorrected data value. The calculation
of recovery values is described in Section 1 of this background
document. The actual recovery values and accuracy factors for
the selected constituents are presented in Table 4-1.
The accuracy factor calculated for lead in K046 was 1.29.
The corrected concentration values for the selected constituent
are shown for the three data sets for cement stabilization in
Table 6-1. These corrected concentration values were obtained by
multiplying the accuracy factors by the concentration values for
the selected constituent in the treated waste. An arithmetic
average value, representing the treated waste concentration, was
calculated for the selected constituent from the three corrected
values. This average is presented in Table 6-1.
6.3 Calculating Variability Factors
It is expected that in normal operation of a well-designed
and well-operated treatment system there will be some variability
6-3
-------
1
Table 6-1 Regulated Constituents and Calculated Treatment Standards for K046 Wastewaters
Accuracy-Corrected Concentration (mg/l)
Constituent
Sample
Set #1
Sample
Set #2
Sample
Set #3
Average
Treated
Waste
Concentration
(mg/l)
Variability
Factor
(VF)
Treatment
Standard
(mg/l)
(Average
X VF)
Lead 0.093 0.129 0.079 0.100 1.76 0.176
1 - Accuracy Correction Factors and Variability Factors were determined as discussed in Appendix D.
-------
in performance. Based on the test data, a measure of this
variability is expressed by the variability factor (see Appendix
A). This factor was calculated for the selected regulated
constituent. The methodology for calculating variability factors
is explained in Appendix A of this report. Table 6-1 presents
the results of calculations for the selected constituent.
Appendix D of this report shows how the actual value in Table
6-1 was calculated.
The variability factor calculated for lead in K046 was 1.76.
For comparison, a variability factor of 1.0 represents test data
from a process measured without variation and analytical
interferences.
6.4 Calculating the Treatment Standards
The treatment standard for the selected constituent was
calculated by multiplying the variability factor by the average
concentration value for the treated waste. The treatment
standard is presented in Table 6-1.
The BOAT Treatment Standard for waste code K046 is as
follows:
Constituent TCLP Extract (mg/1)
Lead 0.176
6-5
-------
REFERENCES
Ajax Floor Products Corp. n.d. Product literature: technical
data sheets, Hazardous Waste Disposal System. P.O. Box 161,
Great Meadows, N.J. 07838.
Austin, G.T. 1984. Shreve's chemical process industries, 5th ed.
New York: McGraw-Hill.
Bishop, P.L., Ransom, S.B., and Grass, D.L. 1983. Fixation
Mechanisms in Solidification/Stabilization of Inorganic
Hazardous Wastes. In Proceedings of the 38th Industrial Waste
Conference, 10-12 May 1983, at Purdue University, West
Lafayette, Indiana.
Conner, J.R. 1986. Fixation and Solidification of Wastes.
Chemical Engineering. Nov. 10, 1986.
Cullinane, M.J., Jr., Jones, L.W., and Malone, P.G. 1986.
Handbook for stabilization/solidification of hazardous waste.
U.S. Army Engineer Waterways Experiment Station. EPA report
No. 540/2-86/001. Cincinnati, Ohio: U.S. Environmental
Protection Agency.
Electric Power Research Institute. 1980. FGD sludge disposal
manual, 2nd ed. Prepared by Michael Baker Jr., Inc. EPRI
CS-1515 Project 1685-1 Palo Alto, California: Electric Power
Research Institute.
Malone, P.G., Jones, L.W., and Burkes, J.P. Application of
solidification/stabilization technology to electroplating
wastes. Office of Water and Waste Management. SW-872.
Washington, B.C.: U.S. Environmental Protection Agency.
Mishuck, E. Taylor, D.R., Telles, R. and Lubowitz, H. 1984.
Encapsulation/ Fixation (E/F) mechanisms. Report No.
DRXTH-TE-CR-84298. Prepared by S-Cubed under Contract No.
DAAK11-81-C-0164.
Pojasek, R.B. 1979. "Solid-Waste Disposal: Solidification"
Chemical Engineering 86(17): 141-145.
USEPA. 1980. U.S. Environmental Protection Agency. U.S. Army
Engineer Waterways Experiment Station. Guide to the disposal
of chemically stabilized and solidified waste. Prepared for
MERL/ORD under Interagency Agreement No. EPA-IAG-D4-0569.
PB81-181505. Cincinnati, Ohio.
-------
APPENDIX A - STATISTICAL ANALYSIS
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
Appendix A-l
-------
values are available in most statistics texts (see, for example,
Statistical Concepts and Methods by Bhattacharyya and Johnson,
1977, John Wiley Publications, New York).
Where the F value is less than the critical value, all
treatment data sets are homogeneous. If the F value exceeds the
critical value, it is necessary to perform a "pair wise F" test
to determine if any of the sets are homogeneous. The "pair wise
F" test must be done for all of the various combinations of data
sets using the same method and equation as the general F test.
The F value is calculated as follows:
(i) All data are natural logtransformed.
(ii) The sum of the data points for each data set is
computed (T.).
(iii) The statistical parameter known as the sum of the
squares between data sets (SSB) is computed:
SSB
k
i
i-1
Ti2'
"T
—
r •< i
&TI
N
i. -
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 logtrans formed data points for each
1 technology.
Appendix A-2
-------
(iv) The sum of the squares within data sets (SSW) is
computed:
SSW =
k n^
. 1=1 j=l
X2. .
k
- z
1 = 1
where:
x. . = the natural logtransformed observations (j) for
1'-' treatment technology (i) .
(v) The degrees of freedom corresponding to SSB and SSW are
calculated. For SSB, the degree of freedom is given by
k-1. For SSW, the degree of freedom is given by N-k.
(vi) Using the above parameters, the F value is calculated
as follows:
where:
MSB = SSB/(k-1) and
MSW = SSW/(N-k).
MSB
F = MSW
Appendix A-3
-------
A computational table summarizing the above parameters is
shown below.
Computational Table for the F Value
Source
Between
Within
Degrees of
freedom
K-l
N-k
Sum of
squares
SSB
SSW
Mean
MSB
MSW
square
= SSB/k-1
= SSW/N-k
F
MSB/MSW
Below are three examples of the ANOVA calculation. The
first two represent treatment by different technologies that
achieve statistically similar treatment; the last example
represents a case where one technology achieves significantly
better treatment than the other technology.
Appendix A-4
-------
Table A-l
F Distribution at the 95 Percent Confidence Level
Denominator
degrees ol
freedom 1
1 161 4
2 1851
3 10 13
4 7 71
5 6 61
6 599
7 5 59
8 532
9 5.12
10 496
11
12
13
14
15
16
1 7
18
19
20
21
22
22
24
34
75
67
60
54
49
45
41
38
35
32
30
28
26
25 424
26 423
27 421
28 4:0
29 418
30 417
40 408
60 400
120 392
oo 3.84
2
1995
1900
955
694
5 79
514
4 74
446
426
4 10
398
339
381
374
368
363
359
355
352
349
347
344
342
340
339
337
335
334
333
332
323
3.15
307
3.00
3
215 7
19 16
928
659
541
4 76
435
407
336
3 71
359
349
341
334
329
324
320
316
3 13
310
307
305
303
301
299
298
296
295
293
292
284
276
268
2.60
Numerator degrees ol freedom
456
2246
1925
912
639
519
453
4 12
384
363
348
336
326
318
311
306
301
296
293
290
287
234
282
280
278
276
274
273
271
270
269
261
253
245
237
2302
1930
901
626
505
439
397
369
348
333
320
311
303
296
290
285
281
2 77
274
2 71
268
266
264
262
260
259
257
256
255
253
245
237
229
2.21
2340
1933
894
6 16
495
428
387
358
337
322
309
300
292
2.85
2.79
2 74
2.70
266
263
260
2.S7
255
2.53
251
249
247
246
245
243
242
234
2.25
2.17
2.10
7
2368
1935
889
609
488
421
379
350
329
3.14
301
291
283
2.76
271
266
261
258
254
251
249
246
244
2.42
240
2.39
2.37
2.36
235
2.33
225
2.17
2.09
2.01
8
2389
1937
885
604
432
4 15
3 73
344
323
3.07
295
2.85
2 77
270
2.64
2.59
255
251
248
245
242
240
2.37
236
234
232
231
229
228
2.27
2.18
2.10
202
1 94
9
2405
1938
881
600
477
4 10
368
339
318
302
290
230
271
265
259
254
249
246
242
239
237
234
232
230
228
227
225
224
222
221
212
204
1 96
1 88
Appendix A-5
-------
Example 1
Methylene Chloride
Steam stripping
Influent
(mg/o
1550.00
1290.00
1640.00
5100.00
U50.00
4600.00
1760.00
2400.00
4800.00
12100.00
Effluent
(mg/l)
10.00
10.00
10.00
12.00
10.00
10.00
10.00
10.00
10.00
10.00
In(effluent)
2.30
2.30
2.30
2.48
2.30
2.30
2.30
2.30
2.30
2.30
[ln(ef fluent)]
5.29
5.29
5.29
6.15
5.29
5.29
5.29
5.29
5.29
5.29
Influent
(mg/l)
1960.00
2568.00
1817.00
1640.00
3907.00
Biological treatment
Effluent In(effluent) tln(ef fluent)]2
(mg/l)
10.00 2.30 5.29
10.00 2.30 5.29
10.00 2.30 5.29
26.00 3.26 10.63
10.00 2.30 5.29
Sum:
23.18
53.76
12.46
31.79
Sample Size:
10 10
Mean:
3669
10.2
Standard Deviation:
3328.67 .63
Variability Factor:
10
2.32
.06
2378
923.04
1.15
13.2
7.15
2.48
2.49
.43
ANOVA Calculations:
sse
k
Z
ni
ssu <
MSB = SSB/U-1)
HSU = SSU/(N-k)
,ll
k M,2
Appendix A-6
-------
Example 1 (continued)
F = HSB/MSU
where:
k = nunber of treatment technologies
n. = number of data points for technology i
N = nunber of natural log transformed data points for all technologies
T. = sun 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 = Z3.18, T = 12.46, T = 35.64, T = 1270.21
T = 537.31 T = 155.25
SSB
f 537.31 155.25
=I +
I 10
SSU * (53.76 * 31.79) -
1270.21
15
537 31 155.25'
10
0.10
= 0.77
MSB = 0.10/1 = 0.10
MSU = 0.77/13 = 0.06
0.10
F =
0.06
= 1.67
AMOVA Table
Source
Degrees of
freedom
SS
MS
Between(B)
Uithin(U)
1
13
0.10
0.77
0.10
0.06
1.67
The critical value of the F test at the 0.05 significance level is 4.67. Since the
f value is less than the critical value, the means are not significantly different
(i.e., they are homogeneous).
Mote: All calculations were rounded to two decimal places. Results may differ
depending upon the nunber of decimal places used in each step of the calculations.
Appendix A-7
-------
Example 2
Trichlorocthylene
Steam stripping
Influent
(ing/ 1)
1650.00
5200.00
5000.00
1720.00
1560.00
10300.00
210.00
1600.00
204.00
160.00
Effluent
(mg/l)
10.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
85.00
10.00
In(effluent)
2.30
2.30
2.30
2.30
2.30
2.30
2.30
3.30
4.44
2.30
2
Cln(ef fluent)]
5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5.29
Biological treatment
Influent
(mg/l)
200.00
224.00
134.00
150.00
484.00
163.00
182.00
Effluent
(mg/l)
10.00
10.00
10.00
10.00
16.25
10.00
10.00
ln( effluent)
2.30
2.30
2.30
2.30
2.79
2.30
2.30
2
1 1 n( effluent)]
5.29
5.29
5.29
5.29
7.78
5.29
5.29
Sum:
Sample Size:
10 10
Mean:
2760
19.2
Standard Deviation:
3209.6 23.7
Variability Factor:
3.70
26.14
10
2.61
.71
72.92
220
120.5
10.89
2.36
1.53
16.59
2.37
.19
39.52
ANOVA Calculations:
SSB = ~
t T,
F k n, , I k f T,Z }
ssy - z, i x2,.j - i _L
t "I J»l J J i = l I n, J
MSB = SSB/(k-1)
HSU = SSW/(N-k)
Appendix A-8
-------
Example 2 (continued)
F r HSB/WSW
where:
k = number of treatment technologies
n. = number of data points for technology i
N = number of data points for all technologies
T. = sun of natural log transformed data points for each technology
X = the natural log transformed observations (j) for treatment technology (i)
N = 10, N = 7, N = 17, k = 2, T = 26.14, T = 16.59, T * 42.73, T = 1825.85, T = 683.30,
T = 275.23
SSB
683 30
10
275.23
7
1825.85
17
= 0.25
SSW., 72.92* 39.52)-
1 10
= 4.79
MSB = 0.25/1 = 0.25
MSW = 4.79/15 = 0.32
0.25
F = = 0.78
0.32
ANOVA Table
Degrees of
Source freedom
Between(B) 1
Within(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.
Appendix A-9
-------
Example 3
Ch I orobenzene
Activated sludge followed
Influent
(mg/l)
7200.00
6500.00
6075.00
3040.00
Effluent
(mg/l)
80.00
70.00
35.00
10.00
by carbon adsorption
2
In(effluent) [ln(ef fluent)]
4.38 19.18
4.25 18.06
3.56 12.67
2.30 5.29
Biological treatment
Influent
(mg/O
9206.00
16646.00
49775.00
14731.00
3159.00
6756.00
3040.00
Effluent
(mg/l)
1083.00
709.50
460.00
142.00
603.00
153.00
17.00
I r\( effluent)
6.99
6.56
6.13
4.96
6.40
5.03
2.83
2
InUef fluent))
48.86
43.03
37.58
24.60
40.96
25.30
8.01
Sun:
Sample Size:
4 4
Mean:
5703
49
Standard Deviation:
1835.4 32.24
Variability Factor:
7.00
14.49
3.62
.95
55.20
14759
16311.86
452.5
379.04
15.79
38.90
5.56
1.42
228.34
ANOVA Calculations:
SS6
i-l I n,
SSW •
MSB = SSB/(k-1)
MSW = SSU/(N-k)
F = MSB/HSU
ld
—
Appendix A-10
-------
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. = sun of natural log transformed data points for each technology
X.. = the natural log transformed observations
-------
A.2. Variability Factor
C99
VF = Mean
where:
VF = estimate of daily maximum variability factor
determined from a sample population of daily data.
Cgg = Estimate of performance values for which 99 percent
of the daily observations will be below. c is
calculated using the following equation:
C = Exp(y +2.33 Sy) where y and Sy are the mean
ana standard deviation, respectively, of the
logtransformed data.
Mean = average of the individual performance values.
EPA is establishing this figure as an instantaneous maximum
because the Agency believes that on a day-to-day basis the waste
should meet the applicable treatment standards. In addition,
establishing this requirement makes it easier to check compliance
on a single day. The 99th percentile is appropriate because it
accounts for almost all process variability.
In several cases, all the results from analysis of the
residuals from BOAT treatment are found at concentrations less
than the detection limit. In such cases, all the actual
concentration values are considered unknown and hence, cannot be
used to estimate the variability factor of the analytical
results. Below is a description of EPA's approach for
calculating the variability factor for such cases with all
concentrations below the detection limit.
Appendix A-12
-------
It has been postulated as a general rule that a lognormal
distribution adequately describes the variation among
concentrations. Therefore, the lognormal model has been used
routinely in the EPA development of numerous regulations in the
Effluent Guidelines program and is being used in the BOAT
program. The variability factor (VF) was defined as the ratio of
the 99th percentile (Cgg) 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 (jj^)
and standard deviation ( CT ) of the normal distribution as
follows:
Cg9 = Exp ( JJi + 2.334(T) (2)
Mean = Exp ( u + .54a2) (3)
Substituting (2) and (3) in (1) the variability factor can
then be expressed in terms of
-------
VF = Exp (2.33CT - .54(T2) (4)
For residuals with concentrations that are not all below the
detection limit, the 99th percentile and the mean can be
estimated from the actual analytical data and accordingly, the
variability factor (VF) can be estimated using equation (1). For
residuals with concentrations that are below the detection limit,
the above equations can be used in conjunction with the
assumptions below to develop a variability factor.
Step 1: The actual concentrations follow a lognormal
distribution. The upper limit (UL) is equal to the detection
limit. The lower limit (LL) is assumed to be equal to one tenth
of the detection limit. This assumption is based on the fact
that data from well-designed and well-operated treatment systems
generally falls within one order of magnitude.
Step 2: The natural logarithms of the concentrations have a
normal distribution with an upper limit equal to In (UL) and a
lower limit equal to In (LL).
Step 3: The standard deviation ( Q- ) of the normal distribution
is approximated by
QT = [(In (UL) - In (LL)] / [(2) (2.33)] = [ln(UL/LL)] /4.66
when LL = (0.1)(UL) then (T = (InlO) / 4.66 = 0.494
Appendix A-14
-------
Step 4: Substitution of the value from Step 3 in equation (4)
yields the variability factor, VF.
VF = 2.8
Appendix A-15
-------
APPENDIX B - ANALYTICAL QA/QC
The analytical methods used for analysis of the regulated
constituents identified in Section 5 are listed in Table B-l.
SW-846 methods (EPA's Test Methods for Evaluating Solid Waste;
Physical/Chemical Methods, SW-846. Third Edition, November 1986)
are used in most cases for determining total waste
concentrations.
SW-846 allows for the use of alternative or equivalent
procedures or equipment; these are described in Table B-2. These
alternatives or equivalents included use of alternative sample
preparation methods and/or use of different extraction techniques
to reduce sample matrix interferences.
The accuracy factor determination for a constituent is based
on the matrix spike recovery values. Table B-3 present the
matrix spike recovery values for TCLP extract concentrations of
BOAT lis-c metals and non-BDAT list metals for K046.
The accuracy correction factors were determined in
accordance with the general methodology presented in the
Introduction. For example, for lead, actual spike recovery data
were obtained for analysis of liquid matrices, and the lowest
percent recovery value was used to calculate the accuracy
correction factor. An example of the calculation of the
Appendix B-l
-------
corrected concentration value for lead in K046 (using a cement
binder) is shown below. The analytical value is the uncorrected
concentration from Table 4-1 (or Table B-3). The percent
recovery value is taken from Table B-3.
Analytical Correction Corrected
Value % Recovery Factor Value
0.061 mg/1 77 100 = 1.30 1.30 x 0.061 = 0.079 mg/1
77
Appendix B - 2
-------
1705g
TABLE B-1 Analytical Methods
Analytical Method
Method No.
Reference
Inductively Coupled Plasma
Atomic Emission Spectroscopy
(aluminum/antimony/banum/beryll ium/
cadmium/calcium/chromium/cobaIt/copper/
iron/magnesium/manganese/nickel/siIver/
sodium/tin/vanadium/zinc/lead)
6010
Arsenic (Atomic Absorption, Furnace Technique)
Selenium (Atomic Absorption, Furnace Technique)
Mercury in Liquid Waste (Manual Cold-
Vapor Technique
Lead (Atomic Absorption, Furnace Technique)
Thallium (Atomic Absorption, Furnace Technique)
Hexava lent Chromium
TCLP
TOC
Chloride
Sulfate
Oi 1 and Grease
Particle Size Distribution
7060
7740
7470
7421
7841
7196
51 FR 40643
9060
9252
9038
9071
0 422
1
1
1
1
1
1
2
1
1
1
1
3
References.
1. U.S. Environmental Protection Agency. 1986. Test Methodology for
Evaluating Solid Waste. Third Edition, U.S.E.P.A. Office of Solid Waste
and Emergency Response, November 1986.
2. Federal Register. 1986. Hazardous Waste Management Systems; Land Disposal
Restrictions; Final Rule; Appendix 1 to Part 268 - Toxicity Leaching
Procedure (TCLP). Vol. 51, No. 216. November 7. 1986. pp. 40643-40654.
3. American Society for Testing and Materials. 1986. Annual Book of ASTM
Standards. Philadelphia, PA. 1986.
Appendix B - 3
-------
170Sg
TABLE B-2 Specific Procedures or Equipment Used in Preparation and Analysis of Metals
When Alternative or Equivalents Allowed in the SW-846 Methods
Analysis
SW-846
Method
Equipment
Alternative or Equivalent
Allowed by SW-846 Methods
Specific Procedures or
Equipment Used
Inductively coupled
plasma atomic
emission spectroscopy
6010
Meta Is by Furnace AA
lha 1 lum
Selenium
Lead
Arsenic
7841
7740
7421
7060
Perk in Elmer
Plasma II Emission
Spectrophotometers
(1) Perkin Elmer 560
(2) Perk in Elmer HGA
2200 Graphite
Furnaces
Operate equipment following
instructions provided by
instrument's manufacturer.
For operation with organic
solvents, auxiliary argon gas
inlet is recommended.
Operate equipment following
instructions provided by
instrument's manufacturer.
Equipment operated using
procedures specified in the
Perkin Elmer Plasma II
Emission Spectrophotometer
Operator's Manua1
Auxiliary argon gas was not
required for sample matrix.
Equipment operated using
procedures specified in
Perkin Elmer instruction
manuals.
Mercury
7471
.Perkin Elmer 560
For background correction,
use either continuous
correction or alternatives,
e.g., Zseman correction
If samples contain a large
amount of organic material,
they should be oxidized by
conventional acid digestion
before being analyzed.
Operate equipment following
instructions by instrument's
manufacturer
Cold vapor apparatus is
described in SW-846 or an
equivalent apparatus may be
used.
Sample may be prepared using
the water bath method or the
autoclave method described in
SW-846.
Background detection was
used.
Sample preparation using a
hydrochloric acid digestion
was not used.
Equipment operated using
procedures specified in Pertun
Elmer 560 Instruction Manual.
Mercury was analyzed by cold
vapor method using the
apparatus as specified in
SW-846.
Samples were prepared using
the water bath method.
Appendix B - 4
-------
170Sg
TABLE B-3 - Matrix Spike for Metals for the TCLP Extract
for the Cement Binder
K.046
Spike
Constituent
BOAT Metals
Ant imony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium-total
Chromium-hexava lent
Copper
Lead
Mercury
Nickel
Selenium
Si Tver
Thall mm
Vanadium
Z me
Non-BDAT Metals
Aluminum
Calcium
Cobalt
Iron
Magnesium
Manganese
Sod i urn
Tin
Original
Amount
Found
(mg/1)
<0.017
<0.003
1.8
<0.002
<0.005
0.03
0.06
0.019
0.061
<0 0003
<0.03
<0.002
<0.006
<0.001
<0.008
<0 02
0 311
2140
<0.04
0.112
0 025
<0 002
331
<0.983
Amount
Spiked
(mg/1)
1
0 1
1
1
1
1
1
1
1
0.05
1
0.05
1
1
1
1
1
1
1
1
1
1
1
1
Matrix
Amount
Found
(mg/1)
0.96
0 118
2.84
0.89
0.96
0.98
0.38
0.86
0 82
0.0471
0.88
0.054
0.25
0.20
0 91
1 07
1.20
NC
0.93
0.93
0.92
0.93
NC
0 60
Spike
Percent
Recovery*
96
118
104
89
96
95
94
84
77
94
88
108
25
20
91
96
69
NC
93
82
90
93
NC
60
Matrix Spike
Amount
Found
(n>9/l)
0.95
0.113
2.90
0.96
0.99
0.98
NA
0.82
0.82
0.0505
0.98
0.043
0.42
0.15
0.95
1 09
1.19
NC
0.90
0.98
0.99
0.96
NC
0 76
Duplicate
Percent
Recovery*
95
113
110
96
99
95
NA
81
77
101
98
87
42
15
95
98
88
NC
90
86
96
96
NC
76
Relative
Percent
Recovery**
1
4
6
8
3
0
NC
4
0
7
11
22
51
29
4
2
1
NC
3
5
6
3
NC
24
NA - Not Analyzed
NC - Not Calculatable
•Percent Recovery = 100 (Ci - CQ)/Ct. where CQ is the initial concentration, C, is the concentration of
the spiked aliquot, and Ct is the concentration of the spike added.
"Relative Percent Difference - 100 (Dj - D2/(Dj + D2)/2), where D. is the larger of the two observed
values for Percent Recovery.
Appendix B - 5
Continued
-------
170Sg
TABLE B-3 - Matrix Spike for Metals for the TCLP Extract
for the kiIn Oust
IC046
Spike
Constituent
BOAT Metals
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium-total
Chromium-hexava lent
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Tha 11 urn
Vanadium
Zinc
Non-BDAT Metals
Aluminum
Calcium
Cobalt
Iron
Magnes lum
Manganese
Sodium
Tin
Original
Amount
Found
(mg/1)
<0.017
<0.003
0.3
<0.002
<0 005
0 06
0 06
<0.006
0.68
<0 0003
<0.03
0.012
<0.006
0.007
<0 008
<0.002
<0.016
2134
<0.04
<0.02
0 02
<0 002
201
<0.983
Amount
Spiked
(mg/1)
1
0.1
1
1
1
1
1
1
1
0.05
1
0.05
1
1
1
1
1
1
1
1
1
1
1
1
Matrix
Amount
Found
(
-------
1705g
TABLE B-3 - Matrix Spike for Metals for the TCLP Extract
for the Lime Fly Ash Binder
K.046
Spike
Constituent
BOAT Metals
Antimony
Arsenic
Ba r i urn
Beryll mm
C a dm i urn
Chromium-total
Chromium-hexava lent
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Z me
Non-BDAT Metals
Aluminum
Calcium
Cobalt
Iron
Magnesium
Manganese
Sodium
Tm
Original
Amount
Found
(mg/1)
<0.017
<0.003
3.5
<0 002
<0 005
<0 02
<0.064
0 01
0.56
<0.0003
<0.03
<0 002
<0.006
0.002
<0 008
<0 02
0.2
2366
<0.04
<0.02
0.003
<0.002
280
<0.9B3
Amount
Spiked
(mg/1)
1
0.1
1
1
1
1
1
1
1
0.05
1
0 05
1
1
1
1
1
1
1
1
1
1
1
1
Matrix
Amount
Found
(mg/1)
0.74
0 122
4.49
0 66
0 69
0.75
0.94
0 84
1.08
0.0489
0.67
0.037
0.22
0.68
0.87
0.67
1.16
NC
0.77
0.76
0.79
0.78
NC
0 77
Spike
Percent
Recovery*
74
122
99
66
69
75
94
83
70
98
67
75
22
67
87 .
67
96
NC
77
76
79
78
NC
77
Matrix Spike
Amount
Found
(mg/1)
0.77
0.124
4.34
0.72
0.69
0.82
NA
0.83
1.20
0.0458
0.74
0.037
0.39
0.71
0.86
0 74
1.12
NC
0.79
0.75
0.77
0.77
NC
0.70
Duplicate
Percent
Recovery*
77
124
84
72
69
82
NA
82
77
92
75
74
39
71
86
74
92
NC
79
75
77
77
NC
70
Relative
Percent
Recovery**
4
2
16
9
0
9
NC
1
10
6
11
1
56
6
1
9
4
NC
3
1
3
1
NC
10
NA - Not Analyzed
NC - Not Calculable
"Percent Recovery » 100 (Ci - CQ)/Ct, where CQ is the initial concentration. C, is the concentration of
the spiked aliquot, and Ct is the concentration of the spike added.
"Relative Percent Difference - 100 (Dj - D2/(Dj + D2)/2), where 0, is the larger of the two observed
values for Percent Recovery.
Appendix B - 7
Continued
-------
-------
TABLE C-1 DETECTION LIMITS FOR UNTREATED K046
BOAT CONSTITUENTS
DETECTION LIMIT
(mg/l)
UNTREATED K046
Metals
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
0.02
0.01
0.2
0.005
0.01
0.02
0.025
0.01
0.0003
0.04
0.005
0.05
0.01
0.05
0.05
Appendix C-1
-------
TABLE C-2 DETECTION LIMITS FOR TREATED K046
BDAT CONSTITUENTS
Hetals
154 Antimony
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
162 Mercury
163 Nickel
164 Selenium
165 Silver
166 Thallium
167 Vanadium
168 Zinc
CEMENT
0.17
0.003
0.002
0.002
0.005
0.02
0.006
0.002
0.0003
0.03
0.002
0.006
0.0007
0.008
0.02
DETECTION LIMIT
(mg/l)
KILN DUST
0.17
0.003
0.002
0.002
0.005
0.02
0.006
0.002
0.0003
0.03
0.002
0.006
0.0007
0.008
0.02
LIME/FLYASH
0.17
0.003
0.002
0.002
0.005
0.02
0.006
0.002
0.0003
0.03
0.002
0.006
0.0007
0.008
0.02
Appendix C-2
-------
APPENDIX 0 CALCULATION OF TREATMENT STANDARDS
Constituent: Lead
1
Treated (TCLP)
Sample Set Concent rat ion
(mg/l)
1 0.072
2 0.100
3 0.061
3 4
2 Accuracy Corrected
Percent Correction Concentration
Recovery Factor (mg/l)
77.4 1.29 0.093
77.4 1.29 0.129
77.4 1.29 0.079
x = 0.100 y
s
5
Log
Transform
-2.375
-2.048
-2.538
= -2.320
= 0.250
1 - Obtained from the Onsite Engineering Report for K046 (Waterways Experiment Station).
2 - Obtained from the Onsite Engineering Report for K046 (Waterways Experiment Station).
3 - Accuracy Correction Factor = 100 / Percent Recovery.
4 - Corrected Concentration = Effluent Concentration X Accuracy Correction Factor.
5 - Log Transform using the natural logarithm, In, of the Corrected Concentration.
Treatment Standard = Corrected Effluent Mean X VF
Calculation of Variability Factor (VF):
C99 = exp (y + 2.33s)
where
y = the mean of the log transforms
s = the standard deviation of the log transforms.
Therefore, C99 = exp (-2.320 + 0.583)
= exp (-1.737)
= 0.176
and VF = C99 / x
where
x = the mean of the corrected effluent concentrations.
Therefore, VF = C99 / x
= 0.176 / 0.100
= 1.76
Treatment Standard = Corrected Effluent Mean X VF
= 0.100 X 1.76
= 0.176 mg/l
Appendix D-l
-------
I. DETERMINE ACCURACY FACTORS
ANOVA FOR K046
Component
Lead
Zinc
MS
'.4
96
CEMENT
MSD
77.4
98
KILN DUST
AF
1.29
1.04
MS
90.5
69
HSD
94.5
72
AF
1.10
1.45
LIME/FLYASH
MS
69.5
67
MSD
77.2
74
AF
1.44
1.49
II. CORRECT AND LOG-TRANSFORM ALL DATA
(all results are in mg/L)
TJ
(D
3
X
a
Component A
Lead
Raw 0.072
Correct 0.093
Log -2.375
Log2 5.640
CEMENT
B
0.100 0.062
0.129 0.080
-2.046 -2.524
4.188 6.373
KILN DUST
A B
0.900 1.100 1.000
0.994 1.215 1.105
-0.006 0.195 0.100
0.000 0.038 0.010
LIME/FLYASH
A B
0.400 0.400 0.400
0.576 0.576 0.576
-0.552 -0.552 -0.552
0.305 0.305 0.305
Zinc
Raw 0.036
Correct 0.038
Log -3.283
Log2 10.781
0.027 0.112
0.028 0.117
-3.571 -2.148
12.753 4.616
0.020 0.020 0.020
0.029 0.029 0.029
-3.541 -3.541 -3.541
12.538 12.538 12.538
0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512
7.943 12.331 12.331
-------
III. USE F-TEST TO COMPARE ALL TREATMENTS
n>
a
H-
X
D
U)
1) Lead
Units =
mg/l
Component
Lead
Raw
Correct
Log
Log2
k =
n1 =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
MSW =
A
0.072
0.093
-2.375
5.640
3
3
3
3
9
9.34
4.67
0.14
0.02
CEMENT
B
0.100
0.129
-2.046
4.186
nunber
number
nunber
nunber
number
C
0.062
0.080
-2.524
6.373
SUM
-6.946
16.201
KILN DUST
A B C SUM
0.900 1.100 1.000
0.994 1.215 1.105
-0.006 0.195 0.100 0.289
0.000 0.038 0.010 0.048
of treatments
of data
of data
of data
of data
points for
points for
points for
points for
technology 1 (cement)
technology 2 (kiln dust)
technology 3 (lime/f lyash)
all technologies
LIME/FLYASH
A B
SUM
0.400 0.400 0.400
0.576 0.576 0.576
-0.552 -0.552 -0.552 -1.657
0.305 0.305 0.305 0.916
F = 200.61
F = F(2,6.0.05)
5.14
-------
2) Zinc
Units =
mg/l
•O
T3
(T>
3
a-
a
i
Component
Zinc
Raw
Correct
Log
LogZ
k =
n1 =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
MSU =
A
0.036
0.038
-3.283
10.781
3
3
3
3
9
0.44
0.22
1.45
0.24
CEMENT KILN DUST
B C SUM A B C SUM
0.027 0.112 0.020 0.020 0.020
0.028 0.117 0.029 0.029 0.029
-3.571 -2.148 -9.003 -3.541 -3.541 -3.541 -10.623
12.753 4.616 28.149 12.538 12.538 12.538 37.615
number of treatments
number of data points for technology 1 (cement)
number of data points for technology 2 (kiln dust)
number of data points for technology 3 (lime/f lyash)
number of data points for all technologies
LIME/FLYASH
A B
F = 0.90
F(k-1.N-k,0.05) = F(2,6,0.05) =
SUM
0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512 -9.841
7.943 12.331 12.331 32.605
5.14
-------
I. DETERMINE ACCURACY FACTORS
ANOVA FOR K046 (CEMENT/KILN DUST)
CEMENT
Component MS MSO AF
Lead 77.4 77.4 1.29
Zinc 96 98 1.04
KILN DUST
MS
90.5
69
MSD
94.5
72
AF
1.10
1.45
LIME/FLYASH
MS
69.5
67
MSD
77.2
74
AF
1.44
1.49
13
•O
(D
X
D
I
Ui
II. CORRECT AND LOG-TRANSFORM ALL DATA
(all results are in mg/L)
Component A
Lead
Raw 0.072
Correct 0.093
Log -2.375
Log2 5.640
Zinc
Raw 0.036
Correct 0.038
Log -3.283
Log2 10.781
CEMENT
B
0.100
0.129
-2.046
4.188
0.027
0.028
-3.571
12.753
KILN DUST
C
0.062
0.080
-2.524
6.373
0.112
0.117
-2.148
4.616
A
0.900
0.994
-0.006
0.000
0.020
0.029
-3.541
12.538
B
1.100
1.215
0.195
0.038
0.020
0.029
-3.541
12.538
C
1.000
1.105
0.100
0.010
0.020
0.029
-3.541
12.538
LIME/FLYASH
A B
0.400 0.400 0.400
0.576 0.576 0.576
-0.552 -0.552 -0.552
0.305 0.305 0.305
0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512
7.943 12.331 12.331
-------
III. USE F-TEST TO COMPARE TWO TREATMENTS
1) Lead
Units =
mg/l
13
•a
<0
H-
X
a
i
a\
Component
Lead
Raw
Correct
Log
Log2
k =
nl =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
MSU =
A
0.072
0.093
-2.375
5.640
2
3
3
0
6
8.72
8.72
0.14
0.03
CEMENT KILN DUST
B C SUM A B C SUM
0.100 0.062 0.900 1.100 1.000
0.129 0.080 0.994 1.215 1.105
-2.046 -2.524 -6.946 -0.006 0.195 0.100 0.289
4.188 6.373 16.201 0.000 0.038 0.010 0.048
number of treatments
number of data points for technology 1 (cement)
number of data points for technology 2 (kiln dust)
number of data points for technology 3 (lime/f lyash)
number of data points for all technologies
F = 249.72
F(k-1.N-k.0.05) = F(1,4,0.05) =
7.71
-------
(D
CL
H-
X
2) Zinc
Units =
Component
Zinc
Raw
Correct
Log
Log2
k =
n1 =
n2 =
n3 =
N =
SSB =
MSB =
SSW =
MSU =
mg/l
A
0.036
0.038
-3.283
10.781
2
3
3
0
6
0.44
0.44
1.13
0.28
CEMENT
B
0.027
0.028
-3.571
12.753
number
number
number
number
number
C SUM
0.112
0.117
-2.148 -9.003
4.616 28.149
of treatments
of data points for
of data points for
of data points for
of data points for
KILN OUST
ABC
0.020 0.020 0.020
0.029 0.029 0.029
-3.541 -3.541 -3.541
12.538 12.538 12.538
technology 1 (cement)
technology 2 (kiln dust)
technology 3 (lime/f lyash)
all technologies
SUM
-10.623
37.615
F = 1.55
F(k-1,N-k,0.05) = F(1,4,0.05)
7.71
-------
ANOVA FOR K046 (CEMENT/LIME)
I. DETERMINE ACCURACY FACTORS
Component
Lead
Zinc
MS
'.4
96
CEMENT
MSD
77.4
98
KILN DUST
AF
1.29
1.04
MS
90.5
69
MSD
94.5
72
AF
1.10
1.45
LIME/FLYASH
MS MSD AF
69.5 77.2 1.44
67 74 1.49
•O
fl>
o-
H-
x
o
I
oo
II. CORRECT AND LOG-TRANSFORM ALL DATA
(all results are in mg/L)
Component A
Lead
Raw 0.072
Correct 0.093
Log -2.375
Log2 5.640
Zinc
Raw 0.036
Correct 0.038
Log -3.283
Log2 10.781
CEMENT
B
0.100
0.129
-2.046
4.188
0.027
0.028
-3.571
12.753
KILN DUST
C
0.062
0.080
-2.524
6.373
0.112
0.117
-2.148
4.616
A
0.900
0.994
-0.006
0.000
0.020
0.029
-3.541
12.538
B
1.100
1.215
0.195
0.038
0.020
0.029
-3.541
12.538
C
1.000
1.105
0.100
0.010
0.020
0.029
-3.541
12.538
LIME/FLYASH
A
0.400
0.576
-0.552
0.305
0.040
0.060
-2.818
7.943
B
0.400
0.576
-0.552
0.305
0.020
0.030
-3.512
12.331
C
0.400
0.576
-0.552
0.305
0.020
0.030
-3.512
12.331
-------
•o
•o
ID
3
a
H-
X
a
10
III. USE F-TEST TO COMPARE TWO TREATMENTS (CEMENT AND LIME/FLYASH)
1) Lead
Units
mg/l
Component
Lead
Raw
Correct
Log
Log2
k =
n1 =
n2 =
n3 =
N =
SS8 =
MSB =
SSU =
MSU =
A
0.072
0.093
-2.375
5.640
2
3
0
3
6
4.66
4.66
0.12
0.03
CEMENT
B
0.100
0.129
-2.046
4.188
number
number
number
number
number
C SUM
0.062
0.080
-2.524 -6.946
6.373 16.201
of treatments
of data points for
of data points for
of data points for
of data points for
LIME/FLYASH
ABC
0.400 0.400 0.400
0.576 0.576 0.576
-0.552 -0.552 -0.552
0.305 0.305 0.305
technology 1 (cement)
technology 2 (kiln dust)
technology 3 (lime/f lyash)
all technologies
SUM
-1.657
0.916
F = 155.90
F(k-1,N-k,0.05) = F(1.4,0.05)
7.71
-------
(D
3
CL
H-
X
o
I
2) Zinc
Units =
Component
Zinc
Raw
Correct
Log
Log2
k =
n1 =
n2 =
n3 =
N =
SSB -
MSB =
SSU =
MSU =
mg/l
A
0.036
0.038
-3.283
10.781
2
3
0
3
6
0.12
0.12
1.45
0.36
CEMENT
B
0.027
0.028
-3.571
12.753
number
number
number
number
number
C • SUM
0.112
0.117
-2.148 -9.003
4.616 28.149
of treatments
of data points for
of data points for
of data points for
of data points for
LIME/FLYASH
ABC
0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512
7.943 12.331 12.331
technology 1 (cement)
technology 2 (kiln dust)
technology 3 (lime/f lyash)
all technologies
SUM
-9.841
32.605
F = 0.32
F(k-1,N-k,0.05) = F(1,4,0.05) =
7.71
-------
ANOVA FOR K046 (KILN DUST/LIHE)
I. DETERMINE ACCURACY FACTORS
Component
Lead
Zinc
MS
77.4
96
CEMENT
MSO
77.4
98
KILN DUST
AF
1.29
1.04
MS
90.5
69
MSD
94.5
72
AF
1.10
1.45
LIME/FLYASH
MS
69.5
67
MSD
77.2
74
AF
1.44
1.49
II. CORRECT AND LOG-TRANSFORM ALL DATA
(all results are in mg/L)
•o
(D
X
a
Component A
Lead
Raw 0.072
Correct 0.093
Log -2.375
Log2 5.640
Zinc
Raw 0.036
Correct 0.038
Log -3.283
Log2 10.781
CEMENT
B
0.100
0.129
-2.046
4.188
0.027
0.028
-3.571
12.753
KILN DUST
C
0.062
0.080
-2.524
6.373
0.112
0.117
-2.148
4.616
A
0.900
0.994
-0.006
0.000
0.020
0.029
-3.541
12.538
B
1.100
1.215
0.195
0.038
0.020
0.029
-3.541
12.538
C
1.000
1.105
0.100
0.010
0.020
0.029
-3.541
12.538
LIME/FLYASH
A B
0.400 0.400 0.400
0.576 0.576 0.576
-0.552 -0.552 -0.552
0.305 0.305 0.305
0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512
7.943 12.331 12.331
-------
ID
CL
H-
X
a
i
H»
to
III. USE F-TEST TO COMPARE TWO TREATMENTS (KILN DUST AND LIME/FLYASH)
1) Lead
Units =
mg/l
Component
Lead
Raw
Correct
Log
Log2
k =
n1 =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
MSU =
A
0.900
0.994
-0.006
0.000
2
0
3
3
6
0.63
0.63
0.02
0.01
KILN DUST
B
1.100
1.215
0.195
0.038
number
number
number
number
number
C SUM
1.000
1.105
0.100 0.289
0.010 0.048
of treatments
of data points for
of data points for
of data points for
of data points for
LIME/FLYASH
ABC
0.400 0.400 0.400
0.576 0.576 0.576
-0.552 -0.552 -0.552
0.305 0.305 0.305
technology 1 (cement)
technology 2 (kiln dust)
technology 3 (lime/f lyash)
all technologies
SUM
-1.657
0.916
F = 125.38
F(k-1,N-k.0.05) = F(1.4,0.05) =
7.71
-------
2) Zinc
Units = mg/t
KILN DUST
Component A
Zinc
Raw 0.020
Correct 0.029
Log -3.541
Log2
>
xj
(D
3
a
H*
X
a
i
U)
k =
n1 =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
MSU =
2
0
3
3
6
0.10
0.10
0.32
0.08
0.020
0.029
-3.541
SUM
0.020
0.029
-3.541 -10.623
12.538 12.538 12.538 37.615
LIME/FLYASH
A B
SUM
0.040 0.020 0.020
0.060 0.030 0.030
-2.818 -3.512 -3.512 -9.841
7.943 12.331 12.331 32.605
nunber of treatments
number of data points for technology 1 (cement)
number of data points for technology 2 (kiln dust)
number of data points for technology 3 (lime/flyash)
number of data points for all technologies
F = 1.27
F(k-1.N-k,0.05) = F(1,4,0.05) =
7.71
-------
DETERMINATION OF SIGNIFICANT TREATMENT
I. DETERMINE ACCURACY FACTORS
Component
Lead
Zinc
CEMENT
MS MSD
77.4
96
77.4
98
AF
1.29
1.04
II. CORRECT AND LOG-TRANSFORM ALL DATA
(all results are in mg/l)
Component
Lead
Raw
Correct
Log
Log2
Zinc
Raw
Correct
Log
Log2
UNTREATED
TCLP
103
133.075
4.891
23.921
0.335
0.349
-1.053
1.108
CEMENT
B
0.072 0.100 0.061
0.093 0.129 0.079
-2.375 -2.046 -2.541
5.640 4.188 6.455
0.036 0.027 0.112
0.038 0.028 0.117
-3.283 -3.571 -2.148
10.781 12.753 4.616
Appendix D-14
-------
III. USE F-TEST TO COMPARE UNTREATED AND TREATED WASTE (FOR CEMENT BINDER)
1) Lead
Units =
Component
Lead
Raw
Correct
Log
Log2
k =
n1 =
n2 =
n3 =
N =
SSB =
MSB =
SSU =
HSU *
103.000
133.075
A. 891
23.921
mg/l
39.01
39.01
0.13
0.06
F = 616.31
F(k-1,N-k,0.05) = F(1,2,0.05) =
CEMENT
C
SUM
0.072 0.100 0.061
0.093 0.129 0.079
-2.375 -2.046 -2.541 -6.962
5.640 4.188 6.455 16.283
2 number of treatments
1 number of data points for technology 1 (untreated)
3 number of data points for technology 2 (treated)
0 number of data points for technology 3
4 number of data points for all technologies
18.5
Appendix D-15
-------
2) Zinc
Units 3
mg/l
Component
Zinc
Raw
Correct
Log
Log2
k =
nl =
n2 =
n3 =
N =
SSB =
MSB =
0.335
0.349
-1.053
1.108
2.85
2.85
0.036 0.027
0.038 0.028
-3.283 -3.571
10.781 12.753
CEMENT
C
SUM
0.112
0.117
-2.148 -9.003
4.616 28.149
2 number of treatments
1 number of data points for technology 1 (untreated)
3 number of data points for technology 2 (treated)
0 number of data points for technology 3
4 number of data points for all technologies
SSW
MSU
1.13
0.57
5.03
F(k-1.N-k,0.05) * F(1.2.0.05) =
18.5
Appendix D-16
------- |