&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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                                          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
                               1-7

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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)
                               1-11

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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
                               1-12

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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
                               1-13

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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
                               1-14

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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
                               1-15

-------
be visited and later sampled if justified by the engineering
visit.

      (2)  Engineering Site Visit.  Once a treatment facility has
been selected, an engineering site visit is made to confirm that
a candidate for sampling meets EPA's criteria for a well-designed
facility and to ensure that the necessary sampling points can be
accessed to determine operating parameters and treatment
effectiveness.  During the visit, EPA also confirms that the
facility appears to be well operated, although the actual
operation of the treatment system during sampling is the basis
for EPA's decisions regarding proper operation of the treatment
unit.   In general, the Agency considers a well-designed facility
to be one that contains the unit operations necessary to treat
the various hazardous constituents of the waste as well as to
control other nonhazardous materials in the waste that may affect
treatment performance.

      In addition to ensuring that a  system  is reasonably well
designed, the engineering visit  examines whether the facility has
a way to measure the operating parameters that affect performance
of the  treatment system during the waste treatment period.  For
example, EPA  may choose not to sample a treatment system that
operates  in a continuous mode, for which an important operating
parameter cannot be continuously recorded.   In such systems,
instrumentation  is  important  in  determining whether the treatment
                               1-16

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



period.








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



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



Agency will then develop a site-specific Sampling and Analysis



Plan (SAP) according to the Generic Quality Assurance Project



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



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



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



sampling, the constituents to be analyzed and the method of



analysis, operational parameters to be obtained,  and specific



laboratory quality control checks on the analytical results.








     The Agency will generally produce a draft of the



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



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



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



should be a confirmation of data collection activities discussed



with the plant personnel during the engineering site visit.  EPA



encourages plant personnel to recommend any modifications to the



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







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



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



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

-------
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

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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

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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

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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

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                            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

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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

-------
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

-------
     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

-------
     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

-------
     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

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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

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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.
                               1-43

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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.
                               1-51

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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

-------
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

-------
     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.
                               2-10

-------
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
                               2-11

-------
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.
                                           2-12

-------
      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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
     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

-------
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

-------
     (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

-------
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

-------
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

-------
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

-------
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

-------

-------
 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

-------
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

-------
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

-------
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

-------
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

-------
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

-------
     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

-------
              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

-------
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

-------
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

-------