c/EPA
           United States
           Environmental Protection
           Agency
           Office of
           Solid Waste
           Washington, D.C. 20460
EPA/530-SW-88-0009-n
May 1988
           Solid Waste
Best
Demonstrated
Available Technology
(BOAT) Background
Document for
K086
Proposed
           Volume 15
           Non Confidential Business Information
           (CBI) Version

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                           PROPOSED
        BEST DEMONSTRATED AVAILABLE  TECHNOLOGY (BOAT)
                 BACKGROUND DOCUMENT FOR K086
                         SOLVENT WASH
             U.S.  Environmental Protection Agency
                    Office of  Solid  Waste
                      401 M Street, S.W.
                   Washington,  D.C.   20460
James R. Berlow, Chief                         Jose Labiosa
Treatment Technology Section                   Project Manager
                           May 1988
                                 Eb'-jT'onmsntal  Protection  -l^-^
                                 '  \  Library  (5PL-16)
                                   :-  —born  Street, Room I6?0
                                 -j,  iL   60604

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              BOAT BACKGROUND DOCUMENT  FOR  K086  SOLVENT  WASH

                             TABLE OF CONTENTS

VOLUME 15                                                            Page

EXECUTIVE SUMMARY 	        vi

1.  INTRODUCTION 	         1

1.1    Legal Background	         1
       1.1.1    Requirements Under HSWA	         1
       1.1.2    Schedule for Developing Restrictions	         4
1.2    Summary of Promulgated BOAT Methodology	         5
       1.2.1    Waste Treatability Groups	         7
       1.2.2    Demonstrated and Available Treatment
                Technologies	         7
       1.2.3    Collection of Performance Data	        11
       1.2.4    Hazardous Constituents Considered and Selected
                for Regulation 	        17
       1.2.5    Compliance with Performance Standards	        30
       1.2.6    Identification of BOAT	        32
       1.2.7    BOAT Treatment Standards for "Derived-From"
                and "Mixed" Wastes	        36
       1.2.8    Transfer of Treatment Standards	        40
1.3    Variance from the BOAT Treatment Standard	        41

2.  INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION	        46

2.1    Industry Affected and Process Description 	          47
2.2    Waste Characterization 	        50

3.  APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES	        54

3.1    Applicable Treatment Technologies 	        54
3.2    Demonstrated Treatment Technologies  	        56
       3.2.1    Incineration 	        58
       3.2.2    Fuel  Substitution 	        77
       3.2.3    Stabilization 	        93
       3.2.4    High Temperature Metals Recovery 	       100
       3.2.5    Chromium Reduction 	       108
       3.2.6    Chemical Precipitation  	       113
       3.2.7    Polishing Filtration 	       125
       3.2.8    Sludge Filtration 	       130
3.3    Performance Data 	       134
       3.3.1    Organics Performance Data 	       134
       3.3.2    Metals Treatment Data 	       136

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4.   IDENTIFICATION OF THE BEST DEMONSTRATED AVAILABLE
    TECHNOLOGY FOR K086 SOLVENT WASH 	

4.1    BOAT for Treatment of Organics 	
4.2    BOAT for Treatment of Metals 	
       4.2.1    Wastewater 	
       4.2.2    Nonwastewater 	

5.   SELECTION OF REGULATED CONSTITUENTS 	

5.1    Identification of Constituents in the Untreated Waste
       and Waste Residuals 	
5.2    Evaluation of the Process Generating the K086 Solvent
       Wash Wastes 	
5.3    Determination of Significant Treatment from BOAT 	
       5.3.1    BOAT List Organic Constituents 	
       5.3.2    BOAT List Metal Constituents 	
5.4    Rationale for Selection of Regulated Constituents 	

6.   CALCULATION OF BOAT TREATMENT STANDARDS 	

6.1    Calculation of Treatment Standards for Nonwastewater
       Forms of K086 Solvent Wash 	
       6.1.1    Organic Treatment Standards 	
       6.1.2    Metal Treatment Standards 	
6.2    Calculation of Treatment Standards for Wastewater forms
       of K086 Sol vent Wash  	
       6.2.1    Organic Treatment Standards 	
       6.2.2    Metal Treatment Standards 	

Appendix A      Statistical Methods 	

Appendix B      Analytical QA/QC 	

Appendix C      Detection Limits for the K086 Scrubber Water
                Samples  	

Appendix D      Method of Measurement for Thermal
                Conductivity  	

Appendix E      Organic Detection Limits for K086 Solvent
                Wash Nonwastewaters  	

References       	
150

150
152
152
154

157
158

159
159
160
161
161

175
175
176
178

180
180
180

183

197
212


221


226

228
                                     11

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                               LIST  OF TABLES


                                                                     Page

Table 1-1   BOAT Constituent List 	   19

Table 2-1   Number of Ink Formulators by State and by EPA Region ..   49

Table 2-2   Major Constituent Analysis of Untreated K086 Solvent
            Wash 	   52

Table 2-3   BOAT Constituent Composition and Other Data 	   53

Table 3-1   Incineration - EPA Collected Data for K086 Solvent Wash  135

Table 3-2   Chromium Reduction Chemical  Precipitation Followed by
            Vacuum Filtration - EPA Collected Data from Envirite ..  139

Table 5-1   BOAT Constituents Detected or Not Detected in the K086
            Solvent Wash and Scrubber Water Samples 	  164

Table 5-2   BOAT Constituent Concentrations in Untreated K086
            Solvent Wash Waste and Scrubber Water Residual 	  172

Table 5-3   Calculated Bond Energy for the Candidate Organic
            Constituents 	  173

Table 5-4   Candidate Constituents for Regulation of K086 Solvent
            Wash 	  174

Table 6-1   Calculation of K086 Solvent Wash Nonwastewater
            Treatment Standards 	  179

Table 6-2   Calculation of K086 Solvent Wash Wastewater Treatment
            Standards 	  181

Table A-l   95th Percentile Values for the F Distribution 	  185

Table B-l   Analytical Methods for K086 Solvent Waste Regulated
            Constituents 	  200

Table B-2   Specific Procedures or Equipment Used in Extraction
            of Organic Compounds When Alternatives or Equivalents
            Are Allowed in the SW-846 Method 	  202
                                    m

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                               LIST OF TABLES
                                (continued)
                                                                     Page
Table B-3   Specific Procedures or Equipment Used for Analysis
            of Organic and Metal Compounds When Alternatives
            or Equivalents Are Allowed in SW-846 	  204

Table B-4   Matrix Spike Recoveries Used to Calculate Correction
            Factors for K086 Solvent Wash Scrubber Water Organic
            Concentrations 	  206

Table B-5   Matrix Spike Recoveries Used to Calculate Correction
            Factor for the Envirite Wastewater and TCLP Extract
            Metal Concentrations 	  207

Table B-6   Matrix Spike Recoveries Used to Calculate Correction
            Factors for the Envirite Filter Cake Organic Detection
            Limits 	  208

Table B-7   Accuracy-Corrected Envirite Metals Data for Treated
            Wastewater from Chromium Reduction, Lime Precipitation
            and Sludge Filtration  	  209

Table B-8   Accuracy-Corrected Envirite Metals Data for Filter
            Cake Residuals from Lime Stabilization and Sludge
            Filtration 	  210

Table B-9   Accuracy-Corrected Organic Concentrations for Envirite
            Filter Cake and K086 Solvent Wash Scrubber Water  	  211

Table C-l   Detection Limits for the Scrubber Effluent Water
            Samples 	  214

Table E-l   Organic Detection  Limits for Envirite Filter Cake
            Residuals from Chromium Reduction, Chemical
            Precipitation, and Sludge Filtration 	  227
                                     IV

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                              LIST OF FIGURES

                                                                     Page
Figure 2-1  Geographical Distribution of Ink Manufacturing Sites ..   48
Figure 2-2  Ink Formulation and K086 Waste Generation 	   51
Figure 3-1  Liquid Injection Incinerator 	   62
Figure 3-2  Rotary Kiln Incinerator 	   63
Figure 3-3  Fluidized Bed Incinerator 	   65
Figure 3-4  Fixed Hearth Incinerator 	   66
Figure 3-5  Example of High Temperature Metals Recovery System ....  104
Figure 3-6  Continuous Hexavalent Chromium Reduction System 	  110
Figure 3-7  Continuous Chemical Precipitation 	  116
Figure 3-8  Circular Clarifiers 	  119
Figure 3-9  Inclined Plate Settler 	  120
Figure D-l  Schematic of the Comparative Method 	  223

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                             EXECUTIVE SUMMARY

                          BOAT  Treatment  Standards
                             K086 Solvent Wash

    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 one subcategory of the K086
listed waste.  According to 40 CFR Part 261.32, waste code K086 is
defined as "solvent washes and sludges, caustic washes and sludges, or
waterwashes and sludges, from cleaning tubs and equipment used in
formulation of ink from pigments, driers, soaps and stabilizers
containing chromium and lead."

    The Agency has determined that K086 represents three treatability
groups based on physical and chemical composition:  the solvent wash
group, the solvent sludge group, and the caustic/water wash and sludge
group.  This background document pertains to the development of treatment
standards for the K086 solvent wash treatability group.  Treatment
standards for the K086 solvent sludge treatability group and the K086
caustic/water wash and sludge treatability group have been deferred
because there is insufficient characterization data and no treatment
performance data available to the Agency such that treatment standards
can be developed.

    Treatment standards for organics are based on the performance of
incineration.  The treatment of K086 solvent wash using incineration
generates a scrubber water residual which may contain metals and require
further treatment.   Treatment of the scrubber water generates a
precipitated solids residual which may also need further treatment.
Treatment standards for metals in the scrubber water are based on
chromium reduction followed by lime precipitation and vacuum sludge
filtration; for metals in the lime-precipitated residuals,  treatment
standards are based on the TCLP leachate values following vacuum
filtration (i.e., based on lime stabilization).  These technologies were
determined by the Agency to represent the Best Demonstrated Available
Technology (BOAT) for organics and metals present in the K086 solvent
wash wastes.

    The Agency has chosen to set treatment levels for these wastes rather
than designating the use of a specific technology.  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
that, as generated, contain the regulated constituents at concentrations
that do not exceed the treatment standards are not restricted from land
disposal units.   The proposed effective date for these standards is
August 8, 1988.

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    Treatment standards have been proposed for a total  of 2 metals and
17 organics that the Agency believes are indicators of effective
treatment for all of the BOAT list hazardous constituents identified as
typically present in K086 solvent wash.  The regulated metals are total
chromium and lead.  The regulated organics include the organics found in
the tested waste, as well as all  BOAT listed organics which Agency data
indicate are organic solvents used in the ink formulation process and/or
in cleaning ink formulating equipment.   The regulated organics include
acetone, n-butyl alcohol, ethyl  acetate, ethylbenzene,  methanol, methyl
isobutyl ketone, methyl ethyl ketone, methylene chloride, toluene,
1,1,1-trichloroethane,  trichloroethylene, xylenes, bis(2-ethylhexyl)
phthalate, cyclohexanone, 1,2-dichlorobenzene, napthalene, and
nitrobenzene.

    The table at the end of this  summary lists the specific BOAT
standards for wastes identified  as K086 solvent wash.  For the purpose of
determining the applicability of  the BOAT treatment standards,
wastewaters are defined as wastes containing less than 1 percent (weight
basis) solids and less  than 1 percent (weight basis) total organic carbon
(TOC).  Wastes not meeting this  definition must comply with treatment
standards for nonwastewaters.

    The Agency is setting standards for wastewaters based on analysis of
total constituent concentration  for BOAT list organics and BOAT list
metals.  For K086 solvent waste  nonwastewaters, the standards are based
on total constituent concentration for BOAT list organics and analysis of
leachate for BOAT list  metals.  The leachate is obtained by use of the
Toxicity Characteristic Leaching  Procedure (TCLP).

    The units for total constituent concentration in the nonwastewaters
are in parts per million (mg/kg)  on a weight-by-weight basis.  The units
for total constituent concentration in the wastewaters and the leachate
are in parts per million (mg/1)  on a weight-by-volume basis.  Testing
procedures are specifically identified in the quality assurance sections
of this document.

    EPA wishes to point out that, because of facility claims of
confidentiality, this document does not contain all of the data that EPA
used  in its  regulatory decision-making process, including selection of
constituents to  regulate, determination of substantial treatment, and
development  of BOAT treatment standards.  Under 40 CFR Part 2, Subpart B,
facilities may claim any or all  of the data that are submitted to EPA as
confidential.  Any determinations regarding the validity of the
facility's claim of confidential  business information (CBI) will be done
by EPA according to 40 CFR Part 2, Subpart B.   In the meantime, the
Agency will  treat the data as CBI.  Additionally, the Agency would like
to emphasize that all the data evaluated for the development of BOAT
treatment standards for K086  solvent washes have been done according to
our methodology  presented in  Section 1 of this document.  All deletions
of confidential  business information (CBI) are noted in  the appropriate
place  in this background document.

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1844g
                                 BOAT TREATMENT STANDARDS
                                     K086  Solvent  Wash
BOAT
reference
no


222
223
225
226
228
229
34
38
43
45
47
215-217

70
232
87
121
126

159
161
BOAT list
const ituents
Organ ics
Volat i le Organics
Acetone
n-Butyl alcohol
Ethyl acetate
Ethylbenzene
Methanol
Methyl isobutyl ketone
Methyl ethyl ketone
Methylene chloride
Toluene
1,1, J-Trichlo roe thane
Tnchloroethylene
Xylene (total)
Setiwo la 1 1 le Organics
8is(2-ethylhexyl)phtna
Cyc lohexanone
1 ,2-OichloroDenzene
Naphthalene
Nitrobenzene
Met.ils
Chromium ( Tola i )
Lead
Total compos
Nonwastewater
(mg/kg)


0 37
0 37
0 37
0 031
0 37
0 37
0 37
0 037
0 031
0 044
0 031
0 015

late 0 49
0.49
0 49
0 49
0 49

NA
NA
1 1 ion
Wastewater
(mg/1)


0 015
0.031
0.031
0.015
0 031
0 031
0 031
0 031
0 029
0 031
0 029
0 015

0 044
0 022
0 044
0 044
0 044

0 32
0 037
TCLP Extract
Nonwastewater
(rag/1)


NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA

NA
NA
NA
NA
NA

0 094
0 37
NA = Not appl icable

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                              1.   INTRODUCTION



    This section of the background document presents a summary of the



legal authority pursuant to which the BOAT treatment standards were



developed,  a summary of EPA's promulgated methodology for developing



BOAT, and finally a discussion of the petition process that should be



followed to request a variance from the BOAT treatment standards.



1.1      Legal Background



1.1.1    Requirements Under HSWA



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



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



and Recovery Act of 1976 (RCRA), impose substantial new responsibilities



on those who handle hazardous waste.  In particular, the amendments



require the Agency to promulgate regulations that restrict the land



disposal of untreated hazardous wastes.   In its enactment of HSWA,



Congress stated explicitly that "reliance on land disposal should be



minimized or eliminated, and land disposal, particularly landfill and



surface impoundment, should be the least favored method for managing



hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C. 6901(b)(7)).



    One part of the amendments specifies dates on which particular groups



of untreated hazardous wastes will be prohibited from land disposal



unless "it has been demonstrated to the Administrator, to a reasonable



degree of certainty, that there will be no migration of hazardous



constituents from the disposal unit or injection zone for as long as the



wastes remain hazardous" (RCRA section 3004(d)(l), (e)(l), (g)(5),



42 U.S.C. 6924 (d)(l), (e)(l), (g)(5)).





                                     1

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    For the purpose of the restrictions, HSWA defines land disposal  "to
include, but not be limited to,  any placement of ...  hazardous waste in
a landfill, surface impoundment, waste pile, injection  well,  land
treatment facility, salt dome formation, salt bed formation,  or
underground mine or cave" (RCRA section 3004(k), 42 U.S.C. 6924(k)).
Although HSWA defines land disposal to include injection wells, such
disposal of solvents, dioxins, and certain other wastes, known as the
California List wastes, is covered on a separate schedule (RCRA section
3004(f)(2), 42 U.S.C. 6924 (f)(2)).  This schedule requires that EPA
develop land disposal restrictions for deep well injection by
August 8, 1988.
    The amendments also require the Agency to set "levels or methods of
treatment, if any, which substantially diminish the toxicity of the waste
or substantially reduce the likelihood of migration of hazardous
constituents from the waste so that short-term and long-term threats to
human health and the environment are minimized" (RCRA section 3004(m)(l),
42 U.S.C. 6924  (m)(l)).  Wastes that meet treatment standards established
by EPA  are not  prohibited and may be land disposed.  In setting treatment
standards for listed or characteristic wastes, EPA may establish
different standards for particular wastes within a single waste code with
differing treatability characteristics.  One such characteristic is the
physical  form of the waste.   This frequently leads to different standards
for wastewaters and nonwastewaters.

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    Alternatively, EPA can establish a treatment standard that is



applicable to more than one waste code when, in EPA's judgment, all the



waste can be treated to the same concentration.  In those instances where



a generator can demonstrate that the standard promulgated for the



generator's waste cannot be achieved, the Agency also can grant a



variance from a treatment standard by revising the treatment standard for



that particular waste through rulemaking procedures.  (A further



discussion of treatment variances is provided in Section 1.3.)



    The land disposal restrictions are effective when promulgated unless



the Administrator grants a national variance and establishes a different



date (not to exceed 2 years beyond the statutory deadline) based on "the



earliest date on which adequate alternative treatment, recovery, or



disposal capacity which protects human health and the environment will be



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



     If  EPA  fails  to set a treatment standard by the  statutory deadline



for  any hazardous waste in the  First Third  or Second Third of the



schedule  (see Section  1.1.2), the waste may not be disposed  in a landfill



or surface  impoundment unless the facility  is  in compliance  with the



minimum technological  requirements  specified  in section  3004(o) of RCRA.



In addition, prior  to  disposal, the generator must certify to  the



Administrator that  the availability of treatment capacity has  been



investigated, and it  has been determined that disposal in a  landfill  or



surface  impoundment  is the only practical alternative to treatment



currently  available  to the generator.  This restriction  on the use of

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landfills and surface impoundments applies until EPA sets a treatment

standard for the waste or until May 8, 1990, whichever is sooner.  If the

Agency fails to set a treatment standard for any ranked hazardous waste

by May 8, 1990, the waste is automatically prohibited from land disposal

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

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

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

specific petitions that show there will be no migration of hazardous

constituents from the unit for as long as the waste remains hazardous.

1.1.2    Schedule for Developing Restrictions

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

schedule for developing treatment standards for all wastes that the

Agency had listed as hazardous by November 8, 1984.  Section 3004(g)

required that this schedule consider the intrinsic hazards and volumes

associated with each of these wastes.  The statute required EPA to set

treatment standards according to the following  schedule:

    1.   Solvents and dioxins standards must be promulgated by
         November 8, 1986;

    2.   The "California  List" must be promulgated by July 8,  1987;

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

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

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

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    The statute specifically identified the solvent wastes as those



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



the dioxin-containing hazardous wastes as those covered under waste codes



F020, F021, F022, and F023.



    Wastes collectively known as the California List wastes, defined



under section 3004(d) of HSWA, are liquid hazardous wastes containing



metals, free cyanides, PCBs, corrosives (i.e., a pH less than or equal to



2.0), and any liquid or nonliquid hazardous waste containing halogenated



organic compounds (HOCs) above 0.1 percent by weight.  Rules for the



California List were proposed on December 11, 1986, and final rules for



PCBs, corrosives, and HOC-containing wastes were established



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



for metals.  Therefore, the statutory limits became effective.



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



delineated the  specific waste codes that would be addressed by the First



Third, Second Third, and Third Third.  This schedule is incorporated  into



40 CFR 268.10,  268.11, and  268.12.



1.2    Summary  of Promulgated BOAT Methodology



     In a November 7, 1986,  rulemaking, EPA promulgated a technology-based



approach to establishing treatment standards under section 3004(m).



Section 3004(m)  also specifies that treatment standards must "minimize"



long- and  short-term threats to human health and the environment arising



from land  disposal of hazardous wastes.

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    Congress indicated in the legislative history accompanying the HSWA
that "[t]he requisite levels of [sic]  methods of treatment established by
the Agency should be the best that has been demonstrated to be
achievable," noting that the intent is "to require utilization of
available technology" and not a "process which contemplates
technology-forcing standards"  (Vol. 130 Cong. Rec.  S9178 (daily ed.,
July 25, 1984)).  EPA has interpreted  this legislative history as
suggesting that Congress considered the requirement under section 3004(m)
to be met by application of the best demonstrated and achievable (i.e.,
available) technology prior to land disposal of wastes or treatment
residuals.  Accordingly, EPA's treatment standards are generally based on
the performance of the best demonstrated available technology (BOAT)
identified for treatment of the hazardous constituents.  This approach
involves the identification of potential treatment systems, the
determination of whether they are demonstrated and available, and the
collection of treatment data from wel1-designed and we!1-operated systems.
    The treatment standards, according to the statute, can represent
levels  or methods of treatment, if  any, that  substantially diminish the
toxicity of the waste or substantially reduce the likelihood of migration
of  hazardous constituents.  Wherever possible, the Agency prefers to
establish BOAT  treatment standards  as "levels" of treatment
(i.e.,  performance  standards), rather than  adopting an approach that
would require the use of specific treatment  "methods."  EPA believes that
concentration-based  treatment  levels offer  the regulated  community greater

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flexibility to develop and implement compliance strategies, as well as an
incentive to develop innovative technologies.
1.2.1  Waste Treatability Group
    In developing the treatment standards, EPA first characterizes the
waste(s).  As necessary, EPA may establish treatability groups for wastes
having similar physical and chemical properties.   That is, if EPA
believes that wastes represented by different waste codes could be
treated to similar concentrations using identical technologies, the
Agency combines the codes into one treatability group.  EPA generally
considers wastes to be similar when they are both generated from the same
industry and from similar processing stages.  In addition, EPA may
combine two or more separate wastes into the same treatability group when
data are available showing that the waste characteristics affecting
performance are similar or that one waste would be expected to be less
difficult to treat.
    Once the treatability groups have been established, EPA collects and
analyzes data on identified technologies used to treat the wastes in each
treatability group.  The technologies evaluated must be demonstrated on
the waste or a similar waste and must be available for use.
1.2.2    Demonstrated and Available Treatment Technologies
    Consistent with legislative history, EPA considers demonstrated
technologies to be those that are used to treat the waste of interest or
a similar waste with regard to parameters that affect treatment selection
(see November 7, 1986, 51 FR 40588).  EPA also will consider as treatment
those technologies used to separate or otherwise process chemicals and
                                     7

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other materials.  Some of these technologies clearly are applicable to



waste treatment, since the wastes are similar to raw materials processed



in industrial applications.



    For most of the waste treatability groups for which EPA will



promulgate treatment standards, EPA will identify demonstrated



technologies either through review of literature related to current waste



treatment practices or on the basis of information provided by specific



facilities currently treating the waste or similar wastes.



    In cases where the Agency does not identify any facilities treating



wastes represented by a particular waste treatability group, EPA may



transfer a finding of demonstrated treatment.  To do this, EPA will



compare the  parameters affecting treatment selection for the waste



treatability group of interest to other wastes for which demonstrated



technologies already have been determined.  The parameters affecting



treatment selection and their use for this waste are described in



Section 3.2  of  this document.  If the parameters affecting treatment



selection are similar, then the Agency will consider the treatment



technology also to be demonstrated for the waste of interest.  For



example, EPA considers rotary kiln incineration to be a demonstrated



technology for  many waste codes containing hazardous organic



constituents, high total organic content,  and high filterable solids



content, regardless of whether any facility  is currently treating  these



wastes.  The basis for this determination  is data found in literature  and



data  generated  by  EPA confirming the  use  of  rotary kiln incineration on



wastes having the  above  characteristics.





                                      8

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    If no commercial  treatment or recovery operations are identified for
a waste or wastes with similar physical or chemical characteristics that
affect treatment selection, the Agency will be unable to identify any
demonstrated treatment technologies for the waste, and, accordingly, the
waste will be prohibited from land disposal (unless handled in accordance
with the exemption and variance provisions of the rule).  The Agency is,
however, committed to establishing treatment standards as soon as new or
improved treatment processes are demonstrated (and available).
    Operations only available at research facilities, pilot- and bench-
scale operations, will not be considered in identifying demonstrated
treatment technologies for a waste because these technologies would not
necessarily be "demonstrated."  Nevertheless, EPA may use data generated
at research facilities in  assessing the performance of demonstrated
technologies.
    As discussed earlier,  Congress intended that technologies used to
establish treatment standards under section 3004(m) be not only
"demonstrated," but also available.  To decide whether demonstrated
technologies may be considered "available," the Agency determines whether
they  (1)  are commercially  available and (2) substantially diminish the
toxicity  of the waste or substantially reduce the likelihood of migration
of hazardous constituents  from the waste.
    EPA will only set treatment standards based on a technology that
meets the above criteria.  Thus, the decision to classify a technology  as
"unavailable" will have a  direct impact on the treatment standard.  If

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the best technology is unavailable,  the treatment standard will  be based



on the next best treatment technology determined to be available.   To the



extent that the resulting treatment  standards are less stringent,  greater



concentrations of hazardous constituents in the treatment residuals could



be placed in land disposal units.



    There also may be circumstances  in which EPA concludes that  for a



given waste none of the demonstrated treatment technologies are



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



performance standards.  Subsequently, these wastes will  be prohibited



from continued placement in or on the land unless managed in accordance



with applicable exemptions and variance provisions.  The Agency  is,



however, committed to establishing new treatment standards as soon as new



or improved treatment processes become "available."



    (1)  Proprietary or patented processes.  If the demonstrated



treatment technology is a proprietary or patented process that is  not



generally available, EPA will  not consider the technology in its



determination of the treatment standards.   EPA will consider proprietary



or patented processes available if it determines that the treatment



method can be purchased or licensed  from the proprietor or is a



commercially available treatment.  The services of the commercial



facility offering this technology often can be purchased even if the



technology itself cannot be purchased.



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



demonstrated treatment technology must "substantially diminish the
                                     10

-------
toxicity" of the waste or "substantially reduce the likelihood of
migration of hazardous constituents" from the waste in accordance with
section 3004(m).  By requiring that substantial treatment be achieved in
order to set a treatment standard, the statute ensures that all wastes
are adequately treated before being placed in or on the land and ensures
that the Agency does not require a treatment method that provides little
or no environmental benefit.  Treatment will always be deemed substantial
if it results in nondetectable levels of the hazardous constituents of
concern.  If nondetectable levels are not achieved, then a determination
of substantial treatment will be made on a case-by-case basis.  This
approach is necessary because of the difficulty of establishing a
meaningful guideline that can be applied broadly to the many wastes and
technologies to be considered.  EPA will consider the following factors
in an effort to evaluate whether a technology provides substantial
treatment on a case-by-case basis:
    •  Number and types of constituents treated;
    •  Performance (concentration of the constituents in the
       treatment residuals); and
    •  Percent of constituents removed.
    If none of the demonstrated treatment technologies achieve
substantial treatment of a waste, the Agency cannot establish treatment
standards for the constituents of concern in that waste.
1.2.3    Collection of Performance Data
    Performance data on the demonstrated available technologies are
evaluated by the Agency to determine whether the data are representative
                                     11

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



well-designed and well-operated systems are included in determining



BOAT.  The data evaluation includes data already collected directly by



EPA and/or data provided by industry.  In those instances where



additional data are needed to supplement existing information, EPA



collects additional data through a sampling and analysis program.  The



principal elements of this data collection program are:  (1) identifi-



cation of facilities for site visits,  (2) an engineering site visit,



(3) a Sampling and Analysis Plan, (4)  a sampling visit, and (5) an Onsite



Engineering Report.



     (1)  Identification of facilities  for site visits.  To identify



facilities that generate and/or treat  the waste of concern, EPA uses a



number of information sources.  These  include Stanford Research



Institute's Directory of Chemical Producers; EPA's Hazardous Waste Data



Management System  (HWDMS); the 1986 Treatment, Storage, Disposal Facility



(TSDF) National Screening Survey; and  EPA's Industry Studies Data Base.



In addition, EPA contacts trade associations to inform them that the



Agency is considering visits to facilities in their  industry and to



solicit  their assistance in identifying facilities for EPA to consider in



its  treatment sampling program.



     After identifying facilities that  treat the waste, EPA uses this



hierarchy to select sites for engineering visits: (1) generators treating



single wastes on site; (2) generators  treating multiple wastes together



on site;  (3) commercial  treatment, storage, and disposal facilities
                                     12

-------
(TSDFs); and (4) EPA in-house treatment.  This hierarchy is based on two



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



standards from data produced by treatment facilities handling only a



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



have had the best opportunity to optimize design parameters.  Although



excellent treatment can occur at many facilities that are not high in



this hierarchy, EPA has adopted this approach to avoid, when possible,



ambiguities related to the mixing of wastes before and during treatment.



    When possible, the Agency will evaluate treatment technologies using



commercially operated systems.  If performance data from properly



designed and operated commercial treatment methods for a particular waste



or a waste judged to be similar are not available, EPA may use data from



research facilities operations.  Whenever research facility data are



used, EPA will  explain in the preamble and background document why such



data were used and will request comments on the use of such data.



    Although EPA's data bases provide information on treatment for



individual wastes, the data bases rarely provide data that support the



selection of one facility for sampling over another.  In cases where



several treatment sites appear to fall into the same level of the



hierarchy, EPA selects sites for visits strictly on the basis of which



facility could most expeditiously be visited and later sampled if



justified by the engineering visit.
                                     13

-------
    (2)  Engineering site visit.   Once a treatment facility has been



selected, an engineering site visit is made to confirm that a candidate



for sampling meets EPA's criteria for a well-designed facility and to



ensure that the necessary sampling points can be accessed to determine



operating parameters and treatment effectiveness.  During the visit, EPA



also confirms that the facility appears to be well operated, although the



actual operation of the treatment system during sampling is the basis for



EPA's decisions regarding proper operation of the treatment unit.  In



general, the Agency considers a well-designed facility to be one that



contains the unit operations necessary to treat the various hazardous



constituents of the waste, as well as to control other nonhazardous



materials in the waste that may affect treatment performance.



    In addition to ensuring that a system is reasonably well designed,



the engineering visit examines whether the facility has a way to measure



the operating parameters that affect performance of the treatment system



during the waste treatment period.  For example, EPA may choose not to



sample a treatment system that operates in a continuous mode, for which



an  important operating parameter cannot be continuously recorded.   In



such  systems, instrumentation is  important in determining whether the



treatment system  is operating at design values during the waste treatment



period.



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



the Agency decides to sample a particular plant, the Agency will then



develop  a site-specific  Sampling  and Analysis Plan (SAP) according  to the



Generic  Quality Assurance Project  Plan  for the Land Disposal Restriction





                                     14

-------
Program ("BOAT"), EPA/530-SW-87-011.   In brief,  the SAP discusses where



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



of sampling, the constituents to be analyzed and  the method of analysis,



operational parameters to be obtained, and specific laboratory quality



control checks on the analytical results.



    The Agency will generally produce a draft of  the site-specific



Sampling and Analysis Plan within 2 to 3 weeks of the engineering visit.



The draft of the SAP is then sent to the plant for review and comment.



With few exceptions, the draft SAP should be a confirmation of data



collection activities discussed with the plant personnel  during the



engineering site visit.  EPA encourages plant personnel to recommend any



modifications to the SAP that they believe will  improve the quality of



the data.



    It is important to note that sampling of a plant by EPA does not mean



that the data will be used in the development of  treatment standards for



BOAT.   EPA's final decision on whether to use data from a sampled plant



depends on the actual analysis of the waste being treated and on the



operating conditions at the time of sampling.  Although EPA would not



plan to sample a facility that was not ostensibly well  designed and well



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



facility will not experience operating problems.   Additionally, EPA



statistically compares its test data to suitable  industry-provided data,



where available, in its determination of what data to use in developing



treatment standards.  The methodology for comparing data  is presented



later in this section.





                                     15

-------
    (Note: Facilities wishing to submit data for consideration in the
development of BOAT standards should, to the extent possible, provide
sampling information similar to that acquired by EPA.  Such facilities
should review the Generic Quality Assurance Project Plan for the Land
Disposal Restriction Program ("BOAT"), which delineates all of the
quality control and quality assurance measures associated with sampling
and analysis.  (Quality assurance and quality control procedures are
summarized in Section 1.2.6 of this document.)
    (4)  Sampling visit.  The purpose of the sampling visit is to collect
samples that characterize the performance of the treatment system and to
document the operating conditions that existed during the waste treatment
period.  At a minimum, the Agency attempts to collect sufficient samples
of the untreated waste and solid and liquid treatment residuals so that
variability in the treatment process can be accounted for  in the
development of the treatment standards.  To the extent practicable, and
within  safety constraints, EPA or its contractors collect  all samples and
ensure  that chain-of-custody procedures are conducted so that the
integrity  of  the data is maintained.
    In  general, the  samples collected during the sampling  visit will have
already been  specified  in the SAP.   In some instances, however, EPA will
not be  able to collect  all planned  samples because of changes in the
facility  operation or plant upsets;  EPA will explain any such deviations
from  the  SAP  in its  follow-up Onsite  Engineering Report.
                                     16

-------
    (5)  Onsite Engineering Report.  EPA summarizes all its data
collection activities and associated analytical results for testing at a
facility in a report referred to as the Onsite Engineering Report (OER).
This report characterizes the waste(s) treated, the treated residual
concentrations, the design and operating data, and all analytical results
including methods used and accuracy results.  This report also describes
any deviations from EPA's suggested analytical methods for hazardous
wastes (see Test Methods for Evaluating Solid Waste. SW-846, Third
Edition, November 1986).
    After the Onsite Engineering Report is completed, the report is
submitted to the plant for review.  This review provides the plant with a
final  opportunity to claim any information contained in the report as
confidential.  Following the review and incorporation of comments, as
appropriate, the report is made available to the public with the
exception of any material claimed as confidential by the plant.
1.2.4  Hazardous Constituents Considered and Selected for Regulation
    (1)  Development of BDAT list.  The list of hazardous constituents
within the waste codes that are targeted for treatment is referred to by
the Agency as the BDAT constituent list.  This list, provided as
Table 1-1, is derived from the constituents presented in 40 CFR Part 261,
Appendices VII and VIII, as well as several ignitable constituents used
as the basis of listing wastes as F003 and F005.  These sources provide a
comprehensive list of hazardous constituents specifically regulated under
RCRA.   The BDAT list consists of those constituents that can be analyzed
using methods published in SW-846, Third Edition.

                                     17

-------
1521g
                     Table 1-1  BOAT Constituent  List
BOAT
reference
no

222
1.
2
3
4
5
6.
223
7.
8.
9
10
11
12
13
14
15.
16.
17
18
19
20
21
22
L J
24
2^
L. O
27
28
29
224.
225.
226.
30
227
31.
214
32
Parameter
Volat i les
Acetone
Acetoni tn le
Aero le in
Aery Ion itn le
Benzene
Bromod ichloromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachlor ide
Carbon bisulfide
Chlorobenzene
2-Chloro-l,3-butadiene
Ch lorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 , 2-Dibromo-3-chloropropane
1 ,2-Oibromoethane
Oibromomethane
Trans-l,4-Dichloro-2-butene
0 ichlorod i f luo route thane
1 , 1 -D ich Icroetrnne
i , 2-Q '.on icrcetn.ine
1 , 1 -D icn 'orcet h\ 'ene
Tr.ins 1.2 D i< nloroet nene
; . i' D icn ' jroprcpjre
Irans 1 .JOi^h loropropene
cis-l.j-Dichloropi'cpene
1 ,4-Oioxane
2-£tho\yethanol
tthyl 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
/5-27-4
74-o3-9
71-36-3
5o-23-5
75-15-0
iOd-90-7
12o-99-8
124-48-1
7S-00-3
>i>75-8
C7-C.6-3
74-B7-3
i:7-05-l
95 -12- 6
1G6-9J-4
74-95-3
11C-57-6
7C 71 b
/ -.43
i o / '^ o - 2
/' -, - j c, - 4
1 ' ; ."0 c
1 , ; c
Ii>Lbi 02-15
10C61-01-5
123-91-1
110-aO-5
141-7b-6
100-41-4
107-12-0
60-29-7
97-63-2
75-21-8
7-1-08 4
                                     19

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

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

50
215
216
217

51
52
53
54
55
56
57.
58
59
218.
60
61
62
Parameter
Volat i les (cont inued)
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methacry lonitri le
Methylene chloride
2-Nitropropane
Pyndine
1,1,1 ,2-Tetrachloroethane
1 , 1 ,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Tnchloroe thane
1 , 1 ,2-Trichloroethane
Tr ichloroethene
Trichloromonof luoromethane
1 , 2, 3-Tr ichloropropane
l,l,2-Tnchloro-l,2,2-trifluoro-
ethane
Vinyl chloride
1 ,2-Xy lene
1 ,3-Xylene
1.4-Xylene
Semivol it i les
Acenapnthd lene
Acenaphthene
Acetophenone
2-Acety lam inof luorene
4-Aminob ipheny 1
Am 1 me
Anthracene
Arami te
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene
CAS no

78-83-1
67-56-1
78-93-3
108-10-1
30 62-6
12b-98-7
75-09-2
79-46-9
110-86-1
630-20-6
79-34-6
127-18-4
108-88-3
75-25-2
71-55-6
7:i-00-5
73-01-6
75-69-4
96-18-4
76-13-1

75-01-4
97-47-6
1C8-38-3
1CL-44-5

Jj.i .16 -o
83-32-9
96-86-2
53-96-3
92-67-1
62-53-3
120-12-7
140-57-8
56-55-3
9B-87-3
108-98-5

50-32^8
                              20

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

63.
64.
65
66
67
68.
69.
70.
71
72
73
74.
75
76
77
78
79
80.
81.
82
232
83
84
85
a6
67
aa
o9
90
91
92
93
94
95.
96.
97
98
99
100
101
Parameter
Semivolat i les (continued)
Benzo(b)f luoranthene
Benzofghi )perylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl )ether
Bis(2-chloro isopropy 1) ether
Bis(2-ethylhexy 1) phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec -Butyl--]. 6-din i trophenol
p-Chloroan i 1 me
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphtha lene
2-Chlorophenol
3-Chloropropion itn le
Chrysene
ortho-Cresol
para-Cresol
Cyc lohexanone
Oibenz(a,h)anthracene
D ibenzo(d,e)pyrene
0 ibenzo(a, i )pyrene
•n Oicr 'crcr.ervene
c- 'J icn loroue^-'erie
p-Q ich loroneruene
" , 3 ' -D ich lot oOL-tv ui me
L,4 D i c^ lorcpncnc I
i , 6-0 icn loropneno 1
Diethyl phthalate
3,3' -Dimethoxybenz id me
p-D i me thy lammoazobenzene
3,3'-Dimethylbenzidme
2 , 4-0 ime thy Ipheno 1
Dimethyl phthalate
Oi-n-butyl phthalate
1 ,4-Dmitrobenzene
4,6-Omitro-o-cresol
2 , 4-D in i tr opheno 1
CAb no

205-99-2
191^24-2
207-08-9
lCo-51-4
111-91-1
1.1--.4-4
:'-GJ6-32-9
117-81-7
lOi-55-3
d5-63-7
bB-d5-7
106-47-6
510-15-6
59-50-7
'.'1-58-7
95-57-8
542-76-7
218-01-9
95-48-7
1G6-44-5
103-94-1
53-70-3
19^-65-4
i -9-55-9
-4: 73-1
1 '01
'j - 1 lj - /
i.-94-l
. J j_ <:
o7-oL-0
o4-b6-2
119-90-4
^ 11-7
lla-93-7
1C5-67-9
Hl-11-3
K4-74-2
100-25-4
534-52-1
r-l-?8-5
                                     21

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

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

36
121
122
123
124.
125
126
127
12B
129
130
131
132.
133.
134
135.
136.
137.
138.
Parameter
Seinivolat i les (continued)
2,4-Dinitrotoluene
2, 6-Oimtrotoluene
Oi-n-octyl phthdlate
Di -n-propylnitrosamine
Oiphenylamine
Oipheny In i trosamme
1 , 2-Diphenylhydraz me
Fluoranthene
Fluorene
Hexach lorobenzene
Hexach lorobutadlene
Hexachlorocyc lopentadiene
Hexachloroethane
Hexach lorophene
Hexach loropropene
indeno( 1 , 2,3-cd)pyrene
Isosaf role
Methapyr i lene
3-Methylcholanthrene
4,4' -Methy leneb is
(2-chloroani 1 me)
Methyl methanesu Ifonate
Naphtha lene
1 , 4-Napnthcqu inone
1 - Napft n^ ! dm i re
2-Napnthy lam me
p- N 1 1 roan i 1 me
Ni trotien.'tne
4-N i t re;,rc-'~o 1
H-Mitrosocn-n-uuty lam me
N-N i trosodiethy lam me
N-N 1 1 rosod line thy lam me
N-N 1 t rosomethy lethy lam me
N-N 1 1 rosomorpho 1 me
N-Ni trosopipendme
n-Nitrosopyrrol idme
5-Nitro-o-toluidme
Pen tach lorobenzene
Pentachloroethane
Pentachloron it robenzene
CAS no

121-14-2
6G6-20-2
117-84-0
621-64-7
122-39-4
S6-jO-6
122-66-7
206-44-0
86-73-7
lld-74-1
b7-Ca-3
77-47-4
67-72-1
70-30-4
Hoo-71-7
ljS-39-5
120-58-1
91-80-5
r,e-49-5

101-14-4
6t-27-3
91-20-3
1 -j-15-4
ii4 3^-7
'-.-C.9-B
r.L-Ql-6
':i : ''- 5 - 3
i 2 w C i.' - 7
'.' i i - 1 o - 3
5^-io-S
62-75-9
1C505-95-6
bJ-59-2
100-75-4
930-55-2
99 65-8
608-93-5
76-01-7
6?-(A-8
                                       22

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

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


154
155
156
157
:5<3
159
22!
!60
161
162
163
164
165
166.
167
168.

169
170
171.
Parameter
Semi vo lat i les (continued)
Pentachlorophenol
Phenacet in
Phenanthrene
Phenol
Phtha 1 ic anhydr ide
2-Picol me
Pronamide
Pyrene
Resorcmol
Saf role
1,2,4,5-Tetrach lorobenzene
2,3,4,6-Tetrach loropheno I
1 ,2,4-Tnchlorobenzene
2,4, 5- T rich loropheno 1
2,4,6-Trichlorophenol
Tr is(2,3-dibromopropyl )
phosphate
Metals
Ant imony
Arsen ic
8a r i urn
Ber/ 1 1 ium
Cci.-in _,m
Chroin !uin ( told 1 )
Chro:i'i urn ( hex.iva ieM )
Copper
Lead
Mercury
Nickel
Selen lum
S i Iver
Ihd 1 1 lum
Vanadium
Zinc
Inorganics
Cyanide
F luor ide
Sulf ide
CAS no

B7-86-5
b2-44-2
85-01-8
108-95-2
85-44-9
109-06-8
23^50-58-5
12:1-00-0
10a-46-3
94-59-7
9c-94-3
5o-30-2
12o-d?-l
95-J5-4
Ho 05-2

126-72-7

/•J-iG-36-0
7440-36-2
744C-39-3
/4,u 41 7
7 , ;; 43-9
;'-i;C-47-32
-
74-:j 50-8
/ . > 5J-1
/4j!j-j7-6
7440-02-0
77d2-49-2
7-; 1C 22-4
/440-23-0
7440-62-2
7440-66-6

57-12-5
ie.'u4 48-8
B-l'jG-25-8
                               23

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

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

192
I'd 3

195
196
197
198
199

200
201
202
Parameter
Orqanochlorine pesticides
Aldrm
alpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chlordane
ODD
ODE
DOT
Dieldnn
Endosulfan I
Endosu If an II
Endr in
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodr in
Kepone
Methoxyclor
Toxaphene
Phenoxvacet ic acid herbicides
2, 4-Oichloropnenoxyacet ic acid
-;i Ive*
2 , 4 , <. - 1
Disu Irotcn
Famphur
Methyl parathion
Parath ion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
CAS no.

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

94-75-7
93-72-1
'.13-76-5
296-04-4
52-85-7
298-00-0
56-38-2
298-02-2

12674-11-2
11104-28-2
11141-16-5
                                    24

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

               PCBs (continued)

203.           Aroclor 1242                             53469-21-9
204            Aroclor 124a                             12672-29-6
205.           Aroclor 1254                             11097-69-1
206            Aroclor 1260                             11096-82-5

               Dioxins and fur.ins

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

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



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



Additional constituents will be added to the BOAT constituent list as



more key constituents are identified for specific waste codes or as new



analytical methods are developed for hazardous constituents.  For



example, since the list was published in March 1987, 18 additional



constituents (hexavalent chromium, xylenes (all three isomers),  benzal



chloride, phthalic anhydride, ethylene oxide, acetone, n-butyl alcohol,



2-ethoxyethanol,  ethyl acetate, ethyl benzene, ethyl ether, methanol,



methyl isobutyl ketone, 2-nitropropane,  1, l,2-trichloro-l,2,2-



trifluoroethane,  and cyclohexanone) have been added to the list.



    Chemicals are listed in Appendix VIII if they are shown in scientific



studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on



humans or other life-forms, and they include such substances as  those



identified by the Agency's Carcinogen Assessment Group as being



carcinogenic.  Including a constituent in Appendix VIII means that the



constituent can be cited as a basis for listing toxic wastes.



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



ignitables provide a comprehensive list of RCRA-regulated hazardous



constituents, not all of the constituents can be analyzed in a complex



waste matrix.  Therefore, constituents that could not be readily analyzed



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



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



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



analytical methods are developed.





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    There are five major reasons that constituents were not included on

the BOAT constituent list:

    1.    Constituents are unstable.   Based on their chemical structure,
         some constituents  will  either decompose in water or will
         ionize.  For example, maleic anhydride will form maleic acid
         when it comes in contact with water and copper cyanide will
         ionize to form copper and cyanide ions.  However, EPA may choose
         to regulate the decomposition or ionization products.

    2.    EPA-approved or verified analytical methods are not available.
         Many constituents, such as  1,3,5-trinitrobenzene, are not
         measured adequately or even detected using any of EPA's
         analytical methods published in SW-846 Third Edition.

    3.    The constituent is a member of a chemical group designated in
         Appendix VIII as not otherwise specified (N.O.S.).  Constituents
         listed as N.O.S.,  such as chlorinated phenols, are a generic
         group of some types of chemicals for which a single analytical
         procedure is not available.  The individual members of each such
         group need to be listed to determine whether the constituents
         can be analyzed.  For each N.O.S. group, all those constituents
         that can be readily analyzed are included  in the BOAT
         constituent 1ist.

    4.    Available analytical procedures are not appropriate for a
         complex waste matrix.  Some compounds, such as auramine, can  be
         analyzed as a pure constituent.  However,  in the presence of
         other constituents, the recommended analytical method does not
         positively identify the constituent.  The  use of high pressure
         liquid chromatography  (HPLC) presupposes a high expectation of
         finding the specific constituents of  interest.   In using this
         procedure to screen samples, protocols would have to be
         developed on a case-specific basis  to verify the identity of
         constituents present in the samples.  Therefore, HPLC is not  an
         appropriate analytical procedure for  complex samples containing
         unknown constituents.

    5.   Standards for analytical instrument calibration  are not
         commercially available.  For several  constituents, such as
         benz(c)acridine,  commercially  available  standards of a
         "reasonably" pure grade are not  available.  The  unavailability
         of  a  standard was determined by  a  review of catalogs from
         specialty chemical manufacturers.
                                     26

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    Two constituents (fluoride and sulfide) are not specifically included
in Appendices VII and VIII; however,  these compounds are included on the
BOAT list as indicator constituents for compounds from Appendices VII and
VIII such as hydrogen fluoride and hydrogen sulfide, which ionize in
water.
    The BOAT constituent list presented in Table 1-1 is divided into the
following nine groups:
       • Volatile organics;
       • Semivolatile organics;
       . Metals;
       • Other inorganics;
       • Organochlorine pesticides;
       • Phenoxyacetic acid herbicides;
       • Organophosphorous insecticides;
       • PCBs;  and
       • Dioxins and furans.
The constituents were placed in these categories based on their chemical
properties.  The constituents in each group are expected to behave
similarly during treatment and are also analyzed, with the exception of
the metals and inorganics, by using the same analytical methods.
    (2)  Constituent selection analysis.  The constituents that the
Agency selects for regulation in each treatability group are, in general,
those found in the untreated wastes at treatable concentrations.  For
certain waste codes, the target list for the untreated waste may have
been shortened (relative to analyses performed to test treatment
technologies) because of the extreme unlikelihood that the constituent
will be present.
                                     27

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    In selecting constituents for regulation,  the first step is to
summarize all  the constituents that were found in the untreated waste at
treatable concentrations.  This process involves the use of the
statistical analysis of variance (ANOVA) test, described in Section
1.2.6, to determine if constituent reductions  were significant.  The
Agency interprets a significant reduction in concentration as evidence
that the technology actually "treats" the waste.
    There are some instances where EPA may regulate constituents that are
not found in the untreated waste but are detected in the treated
residual.  This is generally the case where presence of the constituents
in the untreated waste interferes with the quantification of the
constituent of concern.  In such instances, the detection levels of the
constituent are relatively high, resulting in a finding of "not detected"
when, in fact, the constituent is present in the waste.
    After determining which of the constituents in the untreated waste
are present at treatable concentrations, EPA develops a list of potential
constituents for regulation.  The Agency then reviews this list to
determine  if any of these constituents can be excluded from regulation
because  they would be controlled by  regulation of other constituents  in
the list.
    EPA  performs this  indicator analysis for  two reasons:  (1)  it reduces
the analytical cost burdens on the treater and  (2)  it facilitates
implementation of  the  compliance and enforcement program.  EPA's
rationale  for  selection  of  regulated constituents for this waste code  is
presented  in Section 5 of this background document.
                                     28

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    (3)  Calculation of standards.  The final step in the calculation of
the BOAT treatment standard is the multiplication of the average
treatment value by a factor referred to by the Agency as the variability
factor.  This calculation takes into account that even well-designed and
well-operated treatment systems will experience some fluctuations in
performance.  EPA expects that fluctuations will result from inherent
mechanical limitations in treatment control systems, collection of
treated samples, and analysis of these samples.  All of the above
fluctuations can be expected to occur at well-designed and well-operated
treatment facilities.  Therefore,  setting treatment standards utilizing a
variability factor should be viewed not as a relaxing of section 3004(m)
requirements, but rather as a function of the normal variability of the
treatment processes.  A treatment facility will have to be designed to
meet the mean achievable treatment performance level to ensure that the
performance levels remain within the limits of the treatment standard.
    The Agency calculates a variability factor for each constituent of
concern within a waste treatability group using the statistical
calculation presented in Appendix A.  The equation for calculating the
variability factor is the same as that used by EPA for the development of
numerous regulations in the Effluent Guidelines Program under the Clean
Water Act.  The variability factor establishes the instantaneous maximum
based on the 99th percentile value.
    There is an additional  step in the calculation of the treatment
standards in those instances where the ANOVA analysis shows that more
                                     29

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than one technology achieves a level  of performance that represents
BOAT.   In such instances,  the BOAT treatment standard is calculated by
first  averaging the mean performance  value for each technology for each
constituent of concern and then multiplying that value by the highest
variability factor among the technologies considered.  This procedure
ensures that all  the BOAT technologies used as the basis for the
standards will achieve full  compliance.
1.2.5    Compliance with Performance  Standards
    All the treatment standards reflect performance achieved by the best
demonstrated available technology (BOAT).  As such, compliance with these
standards requires only that the treatment level be achieved prior to
land disposal.  It does not require the use of any particular treatment
technology.  While dilution of the waste as a means to comply with the
standard is prohibited, wastes that are generated  in such a way as to
naturally meet the standard can be land disposed without treatment.  With
the exception of treatment standards  that prohibit land disposal, all
treatment standards proposed are expressed as a concentration level.
    EPA has used both total constituent concentration and TCLP analyses
of  the treated waste as a measure of technology performance.  EPA's
rationale for when each of these analytical tests  is used is explained  in
the following discussion.
    For all organic constituents, EPA  is basing the  treatment standards
on  the total  constituent concentration found  in the  treated waste.   EPA
based  its decision on the fact that technologies exist  to destroy the
                                     30

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various organics compounds.  Accordingly, the best measure of performance
would be the extent to which the various organic compounds have been
destroyed or the total amount of constituent remaining after treatment.
(NOTE:  EPA's land disposal restrictions for solvent waste codes
F001-F005 (51 FR 40572) use the TCLP value as a measure of performance.
At the time that EPA promulgated the treatment standards for F001-F005,
useful data were not available on total constituent concentrations in
treated residuals and, as a result, the TCLP data were considered to be
the best measure of performance.)
    For all metal constituents, EPA is using both total constituent
concentration and/or the TCLP as the basis for treatment standards.  The
total constituent concentration is being used when the technology basis
includes a metal recovery operation.  The underlying principle of metal
recovery is the reduction of the amount of metal in a waste by separating
the metal for recovery; therefore, total constituent concentration in the
treated residual is an important measure of performance for this
technology.  Additionally, EPA also believes that it is important that
any remaining metal in a treated residual waste not be in a state that is
easily 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.
                                     31

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    In cases where treatment standards for metals are not based on

recovery techniques but rather on stabilization,  EPA is using only the

TCLP as a measure of performance.  The Agency's rationale is that

stabilization is not meant to reduce the concentration of metal in a

waste but only to chemically minimize the ability of the metal  to leach.

1.2.6    Identification of BOAT

    (1)  Screening of treatment data.  This section explains how the

Agency determines which of the treatment technologies represent treatment

by BOAT.  The first activity is to screen the treatment performance data

from each of the demonstrated and available technologies according to the

following criteria:

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

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

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

     In  the  absence of data  needed to perform the screening analysis,  EPA

will make decisions on a case-by-case basis as to whether to include  the

data.   The  factors  included  in this  case-by-case analysis will be  the
                                     32

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actual  treatment levels achieved,  the availability of the treatment data
and their completeness (with respect to the above criteria), and EPA's
assessment of whether the untreated waste represents the waste code of
concern.  EPA's application of these screening criteria for this waste
code is provided in Section 4 of this background document.
    (2)  Comparison of treatment data.  In cases in which EPA has
treatment data from more than one technology following the screening
activity, EPA uses the statistical method known as analysis of variance
(ANOVA) to determine if one technology performs significantly better than
the others.  This statistical method  (summarized in Appendix A) provides
a measure of the differences between two data sets.  If EPA finds that
one technology performs significantly better (i.e., the data sets are not
homogeneous), BOAT treatment standards are the level of performance
achieved by the best technology multiplied by the corresponding
variability factor for each regulated constituent.
    If  the differences in the data sets are not statistically
significant, the data  sets  are said to be homogeneous.  Specifically, EPA
uses the analysis of variance to determine whether BOAT represents a
level of performance achieved by only one technology or represents a
level of performance achieved by more than one (or all) of the
technologies.   If the  Agency finds that the levels of performance for one
or more technologies are not statistically different, EPA averages the
performance values achieved by each technology and then multiplies this
value by the largest variability  factor associated with any of the
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acceptable technologies.  A detailed discussion of the treatment

selection metho and an example of how EPA chooses BOAT from multiple

treatment systems is provided in Section A-l.

    (3)  Quality assurance/quality control.  This section presents the

principal quality assurance/quality control (QA/QC) procedures employed

in screening and adjusting the data to be used in the calculation of

treatment standards.  Additional QA/QC procedures used in collecting and

screening data for the BOAT program are presented in EPA's Generic

Quality Assurance Project Plan for Land Disposal  Restrictions Program

("BOAT") (EPA/530-SW-87-011, March 1987).

    To calculate the treatment standards for the Land Disposal

Restriction Rules, it is first necessary to determine the recovery value

for each constituent (the amount of constituent recovered after spiking,

which is the addition of a known amount of the constituent, minus the

initial concentration in the samples divided by the amount added) for a

spike of the treated residual.  Once the recovery value is determined,

the following procedures are used to select the appropriate percent

recovery value to adjust the analytical data:

    1.   If duplicate spike recovery values are available for the
         constituent of interest, the data are adjusted by the lowest
         available percent recovery value  (i.e., the value that will
         yield the most conservative estimate of treatment achieved).
         However, if a spike recovery value of less than 20 percent is
         reported for a specific constituent, the data are not used to
         set treatment standards because the Agency does not have
         sufficient confidence  in the reported value to set a national
         standard.
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    2.   If data are not available for a specific constituent but are
         available for an isomer, then the spike recovery data are
         transferred from the isomer and the data are adjusted using the
         percent recovery selected according to the procedure described
         in (1) above.

    3.   If data are not available for a specific constituent but are
         available for a similar class of constituents (e.g., volatile
         organics, acid-extractable semivolatiles),  then spike recovery
         data available for this class of constituents are transferred.
         All spike recovery values greater than or equal to 20 percent
         for a spiked sample are averaged and the constituent
         concentration is adjusted by the average recovery value.  If
         spiked recovery data are available for more than one sample, the
         average is calculated for each sample and the data are adjusted
         by the lowest average value.

    4.   If matrix spike recovery data are not available for a set of
         data to be used to calculate treatment standards, then matrix
         spike recovery data are transferred from a waste that the Agency
         believes is a similar matrix (e.g., if the data are for an ash
         from incineration, then data from other incinerator ashes could
         be used).  While EPA recognizes that transfer of matrix spike
         recovery data from a similar waste is not an exact analysis,
         this is considered the best approach for adjusting the data to
         account for the fact that most analyses do not result in
         extraction of 100 percent of the constituent.  In assessing the
         recovery data to be transferred, the procedures outlined in (1),
         (2), and (3) above are followed.

    The analytical procedures employed to generate the data used to

calculate the treatment standards are listed in Appendix B of this

document.  In cases where alternatives or equivalent procedures and/or

equipment are allowed in EPA's SW-846, Third Edition (November 1986)

methods, the specific procedures and equipment used are also documented

in this Appendix.  In addition, any deviations from the SW-846, Third

Edition, methods used to analyze the specific waste matrices are

documented.  It is important to note that the Agency will  use the methods

and procedures delineated in Appendix B to enforce the treatment
                                    35

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standards presented in Section 6 of this document.   Accordingly,

facilities should use these procedures in assessing the performance of

their treatment systems.

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

    (1)  Wastes from treatment trains generating multiple residues.  In a

number of instances, the proposed BOAT consists of a series of

operations, each of which generates a waste residue.  For example, the

proposed BOAT for a certain waste code is based on solvent extraction,

steam stripping, and activated carbon adsorption.  Each of these

treatment steps generates a waste requiring treatment — a

solvent-containing stream from solvent extraction,  a stripper overhead,

and spent activated carbon.  Treatment of these wastes may generate

further residues; for instance, spent activated carbon (if not

regenerated) could be incinerated, generating an ash and possibly a

scrubber water waste.  Ultimately, additional wastes are generated that

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

wishes to emphasize the  following points:

    1.   All of the residues  from treating the original listed  wastes  are
         likewise considered  to be the listed waste by virtue of  the
         derived-from rule contained  in  40 CFR Part 261.3(c)(2).   (This
         point  is discussed more fully in  (2) below.)  Consequently, all
         of the wastes generated in the  course of treatment would be
         prohibited from land  disposal unless they  satisfy the  treatment
         standard or meet one  of the  exceptions  to  the prohibition.

    2.   The Agency's proposed treatment standards  generally  contain a
         concentration  level  for wastewaters and a  concentration  level
         for nonwastewaters.   The treatment  standards  apply to  all of  the
         wastes generated  in  treating the  original  prohibited waste.
         Thus,  all  solids generated from treating these wastes  would have
                                     36

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         to meet the treatment standard for nonwastewaters.  All
         derived-from wastes meeting the Agency definition of wastewater
         (less than 1 percent TOC and less than 1 percent total
         filterable solids) would have to meet the treatment standard for
         wastewaters.  EPA wishes to make clear that this approach is not
         meant to allow partial treatment in order to comply with the
         applicable standard.

    3.   The Agency has not performed tests, in all  cases, on every waste
         that can result from every part of the treatment train.
         However, the Agency's treatment standards are based on treatment
         of the most concentrated form of the waste.  Consequently, the
         Agency believes that the less concentrated wastes generated in
         the course of treatment will also be able to be treated to meet
         this value.

    (2)  Mixtures and other derived-from residues.  There is a further

question as to the applicability of the BOAT treatment standards to

residues generated not from treating the waste (as discussed above), but

from other types of management.  Examples are contaminated soil or

leachate that is derived from managing the waste.  In these cases, the

mixture is still deemed to be the listed waste, either because of the

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

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

contained in the matrix (see, for example, 40 CFR Part 261.33(d)).  The

prohibition for the particular listed waste consequently applies to this

type of waste.

    The Agency believes that the majority of these types of residues can

meet the treatment standards for the underlying listed wastes (with the

possible exception of contaminated soil and debris for which the Agency

is currently investigating whether it is appropriate to establish a

separate treatability subcategorization).  For the most part, these
                                    37

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residues will be less concentrated than the original listed waste.  The
Agency's treatment standards also make a generous allowance for process
variability by assuming that all treatability values used to establish
the standard are lognormally distributed.  The waste also might be
amenable to a relatively nonvariable form of treatment technology such as
incineration.  Finally, and perhaps most important, the rules contain a
treatability variance that allows a petitioner to demonstrate that its
waste cannot be treated to the level specified in the rule (40 CFR Part
268.44(a)).  This provision provides a safety valve that allows persons
with unusual waste matrices to demonstrate the appropriateness of a
different standard.  The Agency, to date, has not received any petitions
under this provision (for example, for residues contaminated with a
prohibited solvent waste), indicating, in the Agency's view, that the
existing standards are generally achievable.
    (3)  Residues from managing listed wastes or that contain listed
wastes.  The Agency  has been asked if and when residues from managing
hazardous wastes, such as leachate and contaminated ground water, become
subject to the  land  disposal prohibitions.  Although the Agency believes
this question to be  settled by  existing  rules and  interpretative
statements,  to  avoid any  possible confusion the Agency will address the
question again.
    Residues from managing First Third wastes, listed California  List
wastes, and  spent solvent and dioxin wastes are all considered to be
subject to  the  prohibitions for the underlying hazardous waste.   Residues
                                     38

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from managing California List wastes likewise are subject to the
California List prohibitions when the residues themselves exhibit a
characteristic of hazardous waste.  This determination stems directly
from the derived-from rule in 40 CFR Part 261.3(c)(2) or, in some cases,
from the fact that the waste is mixed with or otherwise contains the
listed waste.  The underlying principle stated in all of these provisions
is that listed wastes remain listed until delisted.
    The Agency's historic practice in processing delisting petitions that
address mixing residuals has been to consider them to be the listed waste
and to require that delisting petitioners address all constituents for
which the derived-from waste (or other mixed waste) was listed.  The
language in 40 CFR Part 260.22(b) states that mixtures or derived-from
residues can be delisted provided a delisting petitioner makes a
demonstration identical to that which a delisting petitioner would make
for the underlying waste.  Consequently, these residues are treated as
the underlying listed waste for delisting purposes.  The statute likewise
takes this position, indicating that soil and debris that are
contaminated with listed spent solvents or dioxin wastes are subject to
the prohibition for these wastes even though these wastes are not the
originally generated waste, but rather are a residual from management
(RCRA section 3004(e)(3)).  It is EPA's view that all such residues are
covered by the existing prohibitions and treatment standards for the
listed hazardous waste that these residues contain and from which they
are derived.
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1.2.8    Transfer of Treatment Standards



    EPA is proposing some treatment standards that are not based on



testing of the treatment technology of the specific waste subject to the



treatment standard.   Instead,  the Agency has determined that the



constituents present in the subject waste can be treated to the same



performance levels as those observed in other wastes for which EPA has



previously developed treatment data.  EPA believes that transferring



treatment performance for use in establishing treatment standards for



untested wastes is technically valid in cases where the untested wastes



are generated from similar industries, have similar processing steps, or



have similar waste characteristics affecting performance and treatment



selection.  Transfer of treatment standards to similar wastes or wastes



from similar processing steps requires little formal analysis.  However,



in a case where only the industry is similar, EPA more closely examines



the waste characteristics prior to deciding whether the untested waste



constituents can be treated to levels associated with tested wastes.



    EPA undertakes a two-step analysis when determining whether wastes



generated by different processes within a single industry can be treated



to the same level of performance. First, EPA reviews the .avai1 able waste



characteristic data to identify those parameters that are expected to



affect treatment selection.  EPA has  identified some of the most



important constituents and other parameters needed to select the



treatment technology appropriate for a given waste.  A detailed



discussion of each analysis, including how each parameter was selected



for each waste, can be found in Section 5 of this document.





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    Second, when an individual analysis suggests that an untested waste



can be treated with the same technology as a waste for which treatment



performance data are already available, EPA analyzes a more detailed list



of constituents that represent some of the most important waste



characteristics that the Agency believes will  affect the performance of



the technology.  By examining and comparing these characteristics, the



Agency determines whether the untested wastes will achieve the same level



of treatment as the tested waste.  Where the Agency determines that the



untested waste is easier to treat than the tested waste, the treatment



standards can be transferred.  A detailed discussion of this transfer



process for each waste can be found in later sections of this document.



1.3    Variance from the 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 demonstration can be





                                    41

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made by showing that attempts to treat the waste by available

technologies were not successful or by performing appropriate analyses of

the waste, including waste characteristics affecting performance, which

demonstrate that the waste cannot be treated to the specified levels.

Variances will not be granted based solely on a showing that adequate

BOAT treatment capacity is unavailable.  (Such demonstrations can be made

according to the provisions in Part 268.5 of RCRA for case-by-case

extensions of the effective date.)  The Agency will consider granting

generic petitions provided that representative data are submitted to

support a variance for each facility covered by the petition.

    Petitioners should submit at least one copy to:

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

    An additional copy marked "Treatability Variance" should be  submitted

to:

       Chief, Waste Treatment Branch
       Office of Solid Waste  (WH-565)
       U.S. Environmental Protection Agency
       401 M Street, S.W.
       Washington, DC  20460

    Petitions containing  confidential  information should be  sent with

only the  inner envelope marked  "Treatability Variance"  and  "Confidential

Business  Information" and with  the contents marked  in accordance with  the

requirements of 40 CFR Part 2 (41 FR 36902, September 1, 1976, amended by

43  FR  4000).

    The  petition  should contain  the following  information:
                                     42

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 1.    The petitioner's name and address.

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

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

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

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

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

 7.    A description of the alternative treatment systems  examined by
      the petitioner (if any); a description of the treatment system
      deemed appropriate by the petitioner for the waste  in question;
      and, as appropriate, the concentrations in the treatment
      residual or extract of the treatment residual (i.e., using the
      TCLP, where appropriate, for stabilized metals) that can be
      achieved by applying such treatment to the waste.

 8.    A description of those parameters affecting treatment selection
      and waste  characteristics that affect performance,  including
      results of all analyses.  (See Section 3.0 for a discussion of
      waste characteristics affecting performance that the Agency has
      identified for the technology representing BOAT.)

 9.    The dates  of the sampling and testing.

10.    A description of the methodologies  and equipment used to obtain
      representative samples.
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   11.    A description of the sample handling and preparation techniques,
         including techniques used for extraction,  containerization, and
         preservation of the samples.

   12.    A description of analytical procedures used,  including QA/QC
         methods.

    After receiving a petition for a variance,  the Administrator may

request any additional information or waste samples that may be required

to evaluate and process the petition.   Additionally,  all petitioners must

certify that the information provided to the Agency is accurate under

40 CFR Part 268.4(b).

    In determining whether a variance will  be granted, the Agency will

first look at the design and operation of the treatment system being

used.  If EPA determines that the technology and operation are consistent

with BOAT, the Agency will evaluate the waste to determine if the waste

matrix and/or physical parameters are such that the BOAT treatment

standards reflect treatment of this waste.   Essentially, this latter

analysis will concern the parameters affecting treatment selection  and

waste characteristics affecting performance parameters.

     In cases where BOAT  is based on more than one technology, the

petitioner will need  to  demonstrate that the treatment  standard cannot be

met using any of  the  technologies,  or that none of the  technologies  are

appropriate  for treatment of the waste.  After the Agency has made  a

determination on  the  petition, the  Agency's findings will be published in

the  Federal  Register,  followed by a 30-day period for  public comment.
                                     44

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



determination in the Federal  Register as an amendment to the treatment



standards in 40 CFR Part 268, Subpart D.
                                     45

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            2.   INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION

    The previous section presents the  generic methodology for developing

BOAT standards.   The purpose of this section is  to discuss the rationale

for dividing the K086 listed waste into three treatability groups and

provide a complete characterization of the KQ86  solvent wash by

describing the industry that generates the waste,  the process generating

the waste, and the available data characterizing the waste.

    According to 40 CFR Part 261.32, the waste identified as K086 is

specifically generated by ink formulating facilities and includes washes

and sludges from both solvent cleaning and caustic/water cleaning.  These

solvent washes,  solvent sludges, and caustic/water cleaning wastes are

inherently different from a treatment  perspective  because of the chemical

and physical properties of the wastes.  These treatability groups have

been divided as follows:

    1.   K086 solvent wash treatability group -  Solvent washes from
         cleaning tubs and equipment used in formulation of ink from
         pigments, driers, soaps, and  stabilizers  containing chromium and
         lead.

    2.   K086 solvent sludge treatability group -  Solvent sludges from
         cleaning tubs and equipment used in formulation of ink from
         pigment, driers, soaps and stabilizers containing chromium and
         lead.

    3.   K086 caustic/water treatability group - Caustic washes and
         sludges, or water washes and  sludges from cleaning tubs and
         equipment used in formulation of ink from pigments, driers,
         soaps, and stabilizers containing chromium and lead.

    The solvent wash treatability group has high organics concentrations

and a  low filterable solids concentration; as a consequence, liquid

injection incineration can be applied.  The solvent sludge treatability

group  also  has a high organic content but does not allow for the use of

                                    46

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liquid injection incineration because of a high solids content.   The
caustic/water treatability group is considered by EPA as a wastewater
containing organics and metals for which EPA would evaluate technologies
other than incineration.
2.1    Industry Affected and Process Description
    The Agency estimates that there are approximately 460 facilities that
formulate ink and may generate K086 solvent wash waste.   The locations of
these facilities are provided on Figure 2-1 by State and in Table 2-1 by
State and by EPA Region.  While this waste can be generated in almost all
of the listed facilities, a large percentage of the facilities generating
K086 solvent wash are located in California, New Jersey, and States
surrounding the Great Lakes.
    Ink production involves the formulation of a desired product from
various raw materials.   The blending process takes place in mixing tubs
ranging in size from 5 gallons to over 1,000 gallons.  Because of the
demand for various types of inks having different properties,  the inks
are made in batch operations.
    Inks are a complex mixture of pigments, solvents, resins,  soaps,
plasticizers, and stabilizers, combined to give the desired properties
for application.  There are many types of pigments and dyes available to
produce any color ink,  but certain inorganic pigments are the primary
source of lead and chromium.  Chrome yellow is a compound consisting of
lead and hexavalent chromium.  Molybdate orange contains lead, chromium,
and molybdenum.
                                    47

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1484g
                 Table 2-1  Number of  Ink Formulators by
                            State and  by EPA Region
EPA Region
I



II

III



IV







V




i
VI



VII



VIII

IX


X


State
Connect icut
Massachusetts
New Hampshire
Rhode Island
New Jersey
New York
0 C.
Maryland
Pennsy Ivan la
Virgin la
Alabama
F lor ida
Georgia
Kentucky
Mississippi
North Carol ina
South Carolina
Tennessee
1 1 1 inois
Indiana
Michigan
Minnesota
Ohio
Wiscons in
Arkansas
LOJ i j Idfia
Ok lanoma
Te
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    Ink formulation consists of a batch mixing of the pigments, vehicles,



solvents, and other speciality additives (see Figure 2-2).   The pigment



may be in a powder or in a paste form.  The even dispersion is



accomplished by the use of ball mills, sand mills, or high speed mixers.



The wetted form of pigment does not require as much dispersion as the



powdered form.  After each batch, the mills, mixers, and tubs must be



washed clean of all residuals in preparation for the next batch.  The



method of equipment cleaning depends upon the type of ink produced.



    In tubs used to formulate solvent-based or oil-based ink, solvent



washes are needed to remove the residuals.  The solvent wash can be used



numerous times until the solvent becomes spent.  The spent solvent can be



used  in the next batch of ink as part of the vehicle if the color desired



is compatible with that of the previous batches;  otherwise, it is



disposed of as K086 solvent wash waste.



2.2    Waste Characterization



    This section includes all waste characterization data available to



the Agency for the untreated K086 solvent wash waste.  The approximate



percent concentrations of major constituents making up K086 solvent wash



are listed in Table 2-2.  The percent concentration in the waste was



determined from the analyses of K086  solvent wash wastes presented in



Table 2-3.   It is  important to realize  that the composition of the waste



can vary depending upon which  solvent or  solvents are used to clean the



ink formulating equipment.
                                     50

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             SOLVENT
               WASH
    SOLVENT
     WASH
SOLVENTS
PIGMENTS
VEHICLES
              MIXING
                                  MILLING
                                                     REDUCING
DUALITY
CONTROL


FILLING AND
SHIPPING


                                                                                     PRODUCT
           KOB6
          SOI VENT
           WASH
  K086
SOLVENT
  WASH
        Figure 2-2.    INK FORMULATION AND K006 WASTE  GENERATION

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1484g
                   Table 2-2  Major Constituent Analysis of
                              Untreated K086 Solvent Wash
                                                            Solvent wash
Major constituent                                       concentration (wt  %)
Water                                                           <0 5

BOAT list metal constituents (including lead and chromium)      <0.1

Spent solvents (may be BOAT list organic constituents)          97 0

Total Solids*                                                    2 4
*  These are volatile and nonvolatile solids remaining after the waste
   has been heated to 1Q3-105"C.  The solids may be organic ink pigments

Reference   USEPA 1985

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1599g
             Table 2-3  BOAT Constituent Composition and Other Data
BOAT
Reference
No.


222
226
225
229
38
43
215-217

70
232
121

154
156
158
159
160
221
161
163
164
165
168

169
171











Analysis

BOAT Volat i 1e Organ ics
Acetone
Ethylbenzene
Ethyl acetate
Methyl isobutyl ketone
Methylene chloride
Toluene
Xylene (Total)
BOAT Semivolat i le Orqanics
bis (2-E thy Ihexyljphtha late
Cyclohexanone
Napthalene
BDAT Metals
Ant imony
Barium
Cadmium
Chromium
Copper
Hexavalent chromium
Lead
Nickel
Se lenium
S i Iver
Z me
Otrer bC-V ! i-yi nan !.:•,
Cyanide
Sulf ide
Otner Pai -ureters
pH
Total solids
Water content
Heating value (Btu/ Ib)
Total organic carbon
Ash content
Organic ink pigments
Ethyl alcohol
High flash point naptha
compounds
Untreated K086 solvent
waste charcterization
(a)


CBI
CBI
CBI
CBI
CBI
CBI
CBI

CBI
CBI
CBI

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI

CBI
CBI

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI

CBI
wash
(mq/kq)
(b)


-
-
256,000
-
-
-
-

-
-
-

-
0 54
4.3
116
17
-
1 06
2.4
0 05
0 32
1 I

-
-

6 3
5,700
-
13,600
-
-
77,000
667,000

-
CBI - Confidential Business Information
    = No analysis performed
(a)  Reference   USCPA I9«7a
(b)  Reference   USEPA ly»5

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             3.  APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES



    This section describes the applicable treatment technologies,



demonstrated treatment technologies, and any available performance data



pertinent to the treatment of K086 solvent wash.  Since the waste



characterization data in Section 2 reveal  that K086 solvent wash wastes



contain both BOAT list organics and BOAT list metals,  the technologies



considered applicable are those that destroy or recover the various BOAT



list organic compounds and stabilize or remove the various BOAT list



metals present in the K086 solvent wash wastes.



3.1      Applicable Treatment Technologies



    The methodology used to determine the applicable technologies is



called analysis of parameters affecting treatment selection.  This



analysis involves the identification of applicable treatment technologies



based on the physical and chemical composition of the waste.  The K086



solvent wash wastes primarily consist of the particular solvent(s) used



in the cleaning process; these wastes also contain water, BOAT list



metals, and  solids with boiling points higher than 1053C.  The waste



also has a high heating value, a high total organic carbon (TOC) content,



and a nondetectable ash content.



    The applicable technologies that the Agency has identified for



treatment of BOAT list organics are incineration, batch distillation,



fractional distillation, and  fuel  substitution  systems with air  pollution



control devices.  Incineration is  a technology  that destroys the organic



components  in  the waste.  Batch distillation and fractional distillation
                                     54

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can be used to separate and recover components having different boiling
points.   The distillation technologies reduce the amount of material to
be treated; nevertheless, residues from these processes still contain
BOAT list organic concentrations and would still require further
treatment prior to land disposal.  Fuel substitution, like incineration,
destroys the organic constituents in the waste.  In fuel substitution,
however, fuel value is also derived from the waste.  The fuel
substitution unit should be equipped with an air pollution control device
to eliminate potential emissions of lead and chromium in the stack gas.
    Incineration of K086 solvent wash results in the formation of a
scrubber water treatment residual that may need metals treatment.  For
the BOAT list metals present in the wastewater residual (i.e., scrubber
water),  the applicable treatment technologies are chromium reduction
followed by chemical precipitation and removal of precipitated solids,
using settling or sludge filtration.  Polishing filtration may also be
applicable  if the solids formed are difficult to settle or remove by the
sludge filtration process.  The chromium reduction process converts
hexavalent  chromium to trivalent chromium.  Chemical precipitation
removes dissolved metals from solution, and settling/sludge filtration
removes suspended solids.
    Treatment of the scrubber water generates a precipitated solids
residual that may also require treatment.  For the BOAT list metals
present in  these solid residuals, potentially applicable treatment
technologies are stabilization and high temperature metals recovery.
Stabilization immobilizes the metal constituents to minimize leaching.

                                     55

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High temperature metals recovery provides for recovery of metals from
wastes primarily by volatilization of some of the metals, subsequent
condensation, and collection.  The process yields a metal product for
reuse and reduces the amount of waste that needs to be land disposed.
    It is important to mention that stabilization can be incorporated as
part of the chemical precipitation process by the addition of excess lime
in concentrations significantly greater than the stoichiometric amount;
this treatment is sometimes referred to as lime stabilization.  In some
instances, when lime stabilization of the precipitated residual is
performed as part of the chemical precipitation process, sludge
filtration is the only additional treatment step necessary to minimize
the Teachability of the metals in the precipitated/stabilized waste.  EPA
considers the combined process to be effectively the same as
stabilization of the precipitated residuals and will refer to the
combination process as stabilization in the context of treatment for
nonwastewaters.  Relative to wastewaters, this treatment is chemical
precipitation, as already discussed.
3.2       Demonstrated Treatment Technologies
    The Agency believes that all the applicable technologies  for organics
treatment are demonstrated  to treat K086  solvent wash since they are
currently used to treat such wastes.  The Agency has identified at  least
one facility using  incineration, one facility using batch distillation,
one facility using  fractional distillation, and one facility  using  fuel
substitution.
                                     56

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    The Agency has not identified any facilities using chromium reduction
followed by chemical  precipitation and settling or sludge filtration on
the scrubber water generated by incineration of K086 solvent wash.  This
treatment, however, is demonstrated on a metal-bearing wastewater that
has similar parameters affecting treatment selection, and thus the Agency
considers the treatment to be demonstrated for the K086 scrubber water.
Sections 3.2.5 through 3.2.8 describe chromium reduction, chemical
precipitation, settling filtration, and the parameters affecting
selection of these treatment technologies.  Performance data for chromium
reduction precipitation and sludge filtration of the metal bearing
wastewater are presented in Section 3.3.  A comparison of these data to
those of the K086  scrubber water shows that the parameters affecting
treatment selection are similar.
    The Agency has not identified any facilities using stabilization on
the precipitate that would be generated by treatment of K086 scrubber
water generated during incineration of K086 solvent wash.  Stabilization,
however,  is used  to treat metals  in wastes  (e.g., Envirite wastewater
treatment precipitates) that have similar parameters affecting treatment
selection.  Thus,  the Agency considers stabilization to be demonstrated
for K086 wastewater treatment precipitates.  Stabilization is described
in Section 3.2.3.  Performance data for stabilization of waste are
presented  in  Section  3.3.
    High  temperature  metals recovery  has  been  identified  as potentially
applicable for treatment of K086  precipitated  solids.  At this time, EPA
                                     57

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does not have any treatment performance data for high temperature metals



recovery of wastewater treatment precipitated solids; however, the data



have been requested.  When the data are received, EPA will continue to



investigate the application and demonstration of high temperature metals



recovery for treatment of the K086 solvent wash nonwastewaters such as



the precipitated solids residual from wastewater treatment.



    Detailed discussions of the high temperature metals recovery and the



demonstrated technologies, including incineration, fuel substitution,



stabilization, chromium reduction, chemical precipitation, polishing



filtration, and sludge filtration, are presented below.  Following the



technology discussions is the technology performance data base for



treatment of K086 solvent wash wastes.



3.2.1    Incineration



    This section addresses the commonly used incineration technologies:



liquid injection, rotary kiln, fluidized bed, and fixed hearth.  A



discussion is provided regarding the applicability of these technologies,



the underlying principles of operation, a technology description, waste



characteristics that affect performance, and finally important design and



operating parameters.  As appropriate the subsections are divided by type



of  incineration unit.



    (1)  Applicability and use of this technology



         (a)  Liquid injection.  Liquid injection is applicable to wastes



that have viscosity values sufficiently low so that  the waste can be



atomized in the combustion chamber.  A range of  literature maximum



viscosity values are reported, with the low being 100 Saybolt seconds





                                     58

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universal  (SSU) and the high being 10,000 SSU.   It is important to note



that viscosity is temperature dependent; while  liquid injection may not



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



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



injection are particle size and the presence of  suspended solids.  Both



of these waste parameters can cause plugging of  the burner nozzle.



         (b)  Rotary kiln/fluidized bed/fixed hearth.  These incineration



technologies are applicable to a wide range of hazardous wastes.  They



can be used on wastes that contain high or low total organic content,



high or low filterable solids, various viscosity ranges, and a range of



other waste parameters.  EPA has not found these technologies to be



demonstrated on wastes that are composed essentially of metals with low



organic concentrations.  In addition, the Agency expects that some of the



high metal content wastes may not be compatible  with existing and future



air emission limits without emission controls far more extensive than



those currently  in use.



    (2)  Underlying principles of operation



          (a)   Liquid injection.  The basic operating principle of this



incineration technology  is that incoming liquid wastes are volatilized



and then additional heat is supplied to the waste to destabilize the



chemical bonds.  Once the chemical bonds are broken, these constituents



react with oxygen  to form carbon dioxide and water vapor.  The energy



needed to destabilize the bonds is referred to as the energy of



activation.
                                     59

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         (b)  Rotary kiln and fixed hearth.   There are two distinct
principles of operation for these incineration technologies, one for each
of the chambers involved.  In the primary chamber, energy, in the form of
heat, is transferred to the waste to achieve volatilization of the
various organic waste constituents.  During this volatilization process
some of the organic constituents oxidize to carbon dioxide and water
vapor.  In the secondary chamber, additional heat is supplied to overcome
the energy requirements needed to destabilize the chemical bonds and
allow the constituents to react with excess oxygen to form carbon dioxide
and water vapor.  The principle of operation for the secondary chamber is
similar to that of liquid injection.
         (c)  Fluidized bed.  The principle of operation for this
incinerator technology is somewhat different from that for rotary kiln
and  fixed hearth incineration, in that there is only one chamber, which
contains the fluidizing sand and a freeboard section above the sand.  The
purpose of the fluidized bed is to both volatilize and combust the
waste.  Destruction of the waste organics can be accomplished to a better
degree  in this chamber than  in the primary  chamber of the  rotary kiln and
fixed hearth because of  (1)  improved heat transfer from the  fluidization
of  the  waste using forced air and  (2) the fact that  the fluidization
process provides sufficient  oxygen and turbulence to convert the organics
to  carbon dioxide  and water  vapor.  The freeboard generally  does not have
an  afterburner; however, additional time  is  provided for  conversion of
                                     60

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the organic constituents to carbon dioxide,  water vapor,  and hydrochloric



acid if chlorine is present in the waste.



    (3)  Description of incineration technologies



         (a)  Liquid injection.  The liquid  injection system is capable



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



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



atomizes the liquid waste and injects it into the combustion chamber,



where it burns in the presence of air or oxygen.   A forced draft system



supplies the combustion chamber with air to  provide oxygen for combustion



and turbulence for mixing.  The combustion chamber is usually a cylinder



lined with refractory (i.e., heat-resistant) brick and can be fired



horizontally, vertically upward, or vertically downward.   Figure 3-1



illustrates a liquid injection incineration  system.



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



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



horizontal (see Figure 3-2).  Solid wastes enter at the high end of the



kiln, and liquid or gaseous wastes enter through atomizing nozzles in the



kiln or afterburner section.  Rotation of  the kiln exposes the solids to



the heat, vaporizes them, and allows them  to combust by mixing with air.



The rotation also causes the ash to move to  the lower end of the kiln,



where it can be removed.  Rotary kiln systems usually have a secondary



combustion chamber or afterburner following  the kiln for further



combustion of the volatilized components of  solid wastes.
                                    61

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

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                                                                   GAS TO
                                                               AIR POLLUTION
                                                                  CONTROL
                        AUXILIARY
                            FUEL
                                                AFTERBURNER
   SOLID
  WASTE
INFLUENT
   FEED
MECHANISM
                                                                      COMBUSTION
                                                                      GASES
                              LIQUID  OR
                              GASEOUS
                               WASTE
                              INJECTION
                                                                    ASH
                                       FIGURE   3-2
                             ROTARY KILN INCINERATOR
                                           b3

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         (c)  Fluidized bed.   A fluidized bed incinerator consists of a
column containing inert particles such as sand,  which is referred to as
the bed.  Air, driven by a blower,  enters the bottom of the bed to
fluidize the sand.  Air passage through the bed  promotes rapid and
uniform mixing of the injected waste material within the fluidized bed.
The fluidized bed has an extremely high heat capacity (approximately
three times that of flue gas at the same temperature), thereby providing
a large heat reservoir.  The injected waste reaches ignition temperature
quickly and transfers the heat of combustion back to the bed.  Continued
bed agitation by the fluidizing air allows larger particles to remain
suspended in the combustion zone (See Figure 3-3).
         (d)  Fixed hearth.  Fixed hearth incinerators, also called
controlled  air or starved air incinerators, are another major technology
used  for hazardous waste incineration.  Fixed hearth incineration is a
two-stage combustion process (see Figure 3-4).  Waste is ram-fed  into the
first stage, or  primary chamber, and burned at less than stoichiometric
conditions.  The  resultant smoke and pyrolysis products, consisting
primarily of volatile hydrocarbons and carbon monoxide, along with the
normal  products  of combustion, pass to the secondary chamber.  Here,
additional  air  is injected to complete the combustion.  This two-stage
process generally yields low stack particulate and  carbon monoxide
emissions.  The  primary chamber  combustion reactions  and combustion gas
are maintained  at low  levels by  the starved  air conditions  so that
particulate entrainment and carryover  are minimized.
                                     64

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  WASTE
INJECTION
BURNER
                              FREEBOARD
                              SAND BED
                                                          GAS TO
                                                          AIR POLLUTION
                                                          CONTROL
                                                          MAKE-UP
                                                          SAND
                                                          AIR
                                 ASH
                              FIGURE 3-3
                    FLUIDIZED BED  INCINERATOR
                                        65

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                                                AIR
                                                       GAS TO AIR
                                                       POLLUTION
                                                       CONTROL
                                                1
          AIR
   WASTE
INJECTION
BURNER
  PRIMARY
COMBUSTION
 CHAMBER

   GRATE
                                                SECONDARY
                                                COMBUSTION
                                                 CHAMBER
                                                       AUXILIARY
                                                       FUEL
                               2-STAGE FIXED  HEARTH
                                   INCINERATOR
                            ASH
                                 FIGURE  3-4
                      FIXED HEARTH  INCINERATOR

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         (e)  Air pollution controls.  Following incineration of
hazardous wastes, combustion gases are generally further treated in an
air pollution control  system.  The presence of chlorine or other halogens
in the waste requires a scrubbing or absorption step to remover
hydrochloric acid and other halo-acids from the combustion gases.  Ash in
the waste is not destroyed in the combustion process.  Depending on its
composition, ash will  either exit as bottom ash, at the discharge end of
a kiln or hearth, for example, or as particulate matter (fly ash)
suspended in the combustion gas stream.  Particulate emissions from most
hazardous waste combustion systems generally have particle diameters of
less than one micron and require high-efficiency collection devices to
minimize air emissions.  In addition, scrubber systems provide an
additional buffer against accidental releases of incompletely destroyed
waste products as a result of poor combustion efficiency or combustion
upsets, such as flameouts.
    (4)  Waste characteristics affecting performance (WCAP)
         (a)  Liquid injection.  In determining whether liquid injection
is likely to achieve the same level of performance on an untested waste
as on a previously tested waste, the Agency will compare dissociation
bond energies of the constituents in the untested and tested waste.  This
parameter is being used as a surrogate indicator of activation energy,
which, as discussed previously, destabilizes molecular bonds.  In theory,
the bond dissociation energy would be equal to the activation energy;
                                     67

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however, in practice this is not always the case.  Other energy effects



(e.g.,  vibrational  effects,  the formation of intermediates, and



interactions between different molecular bonds) may have a significant



influence on activation energy.



    Because of the shortcomings of bond energies in estimating activation



energy, EPA analyzed other waste characteristic parameters to determine



if these parameters would provide a better basis for transferring



treatment standards from an untested waste to a tested waste.  These



parameters include heat of combustion, heat of formation,  use of



available kinetic data to predict activation energies, and general



structural class.  All of these were rejected for reasons  provided below.



    The heat of combustion measures only the difference in energy of the



products and reactants; it does not provide information on the transition



state  (i.e., the energy input needed to initiate the reaction).  Heat of



formation is used as a predictive tool for whether reactions are likely



to proceed; however, these data are not available for a significant



number of hazardous constituents.  Use of kinetic data was rejected



because these data are limited and could not be used to calculate free



energy values (AG) for the wide range of hazardous constituents to be



addressed by this rule.  Finally, EPA decided not to use structural



classes because the Agency believes that evaluation of bond dissociation



energies allows for a more direct determination of whether a constituent



will be destabilized.
                                     68

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         (b)  Rotary kiln/fluidized bed/fixed hearth.  Unlike liquid
injection,  these incineration technologies also generate a residual ash.
Accordingly, in determining whether these technologies are likely to
achieve the same level  of performance on an untested waste as on a
previously tested waste, EPA would need to examine the waste
characteristics that affect volatilization of organics from the waste, as
well as destruction of the organics, once volatilized.  Relative to
volatilization, EPA will examine thermal conductivity of the entire waste
and boiling point of the various constituents.  As with liquid injection,
EPA will examine bond energies in determining whether treatment standards
for scrubber water residuals can be transferred from a tested waste to an
untested waste.  Below is a discussion of how EPA arrived at thermal
conductivity and boiling point as the best methods to assess
volatilization of organics from the waste; the discussion relative to
bond energies is the same for these technologies as for liquid injection
and will not be repeated here.
         (i)  Thermal conductivity.  Consistent with the underlying
principles of incineration, a major factor with regard to whether a
particular constituent will volatilize is the transfer of heat through
the waste.   In the case of rotary kiln, fluidized bed, and fixed hearth
incineration, heat is transferred through the waste by three mechanisms:
radiation,  convection,  and conduction.  For a given incinerator, heat
transferred through various wastes by radiation is more a function of the
design and type of incinerator than of the waste being treated.
Accordingly, the type of waste treated will have a minimal impact on the

                                     69

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amount of heat transferred by radiation.   With regard to convection, EPA



also believes that the type of heat transfer will  generally be more a



function of the type and design of incinerator than of the waste itself.



However, EPA is examining particle size as a waste characteristic that



may significantly impact the amount of heat transferred to a waste by



convection and thus impact volatilization of the various organic



compounds.  EPA believes that the final type of heat transfer,



conduction, will have the greatest impact on volatilization of organic



constituents.  To measure this characteristic, EPA will use thermal



conductivity; an explanation of this parameter, as well as how it can be



measured,  is provided below.



    Heat flow by conduction is proportional to the temperature gradient



across  the material.  The proportionality constant, which is a property



of the  material, is referred .to as the thermal conductivity.  (Note:  The



analytical method that EPA has identified for measurement of thermal



conductivity is named "Guarded, Comparative, Longitudinal Heat Flow



Technique";  it  is described in Appendix D.)   In theory, thermal



conductivity would  always provide a good  indication of whether a



constituent  in  an untested waste would be treated  to the same extent  in



the primary  incinerator  chamber as the same constituent in a previously



tested  waste.



    In  practice, thermal  conductivity  has some limitations in assessing



the transferability of treatment standards; however, EPA has not



identified a parameter that can provide a better  indication of heat



transfer  characteristics of a  waste.   Below is a  discussion of both  the





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limitations associated with thermal conductivity, as well as other
parameters considered.
    Thermal conductivity measurements, as part of a treatability
comparison for two different wastes through a single incinerator, are
most meaningful when applied to wastes that are homogeneous (i.e., major
constituents are essentially the same).  As wastes exhibit greater
degrees of nonhomogeneity (e.g., significant concentration of metals in
soil), thermal conductivity becomes less accurate in predicting
treatability because the measurement essentially reflects heat flow
through regions having the greatest conductivity (i.e., the path of least
resistance) and not heat flow through all parts of the waste.
    Btu value, specific heat, and ash content were also considered for
predicting heat transfer characteristics.  These parameters can no better
account for nonhomogeneity than thermal conductivity;  additionally, they
are not directly related to heat transfer characteristics.  Therefore,
these parameters do not provide a better indication of the heat transfer
that will occur in any specific waste.
         (ii)  Boi1 ing point.  Once heat is transferred to a constituent
within a waste, then removal of this constituent from the waste will
depend on its volatility.  As a surrogate for volatility, EPA is using
boiling point of the constituent.  Compounds with lower boiling points
have higher vapor pressures and, therefore, would be more likely to
vaporize.  The Agency recognizes that this parameter does not take into
consideration the impact of other compounds in the waste on the boiling
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point of a constituent in a mixture; however, the Agency is not aware of



a better measure of volatility that can easily be determined.



    (5)  Incineration design and operating parameters



         (a)  Liquid injection.  For a liquid injection unit,  EPA's



analysis of whether the unit is well designed will focus on (1) the



likelihood that sufficient energy is provided to the waste to overcome



the activation level for breaking molecular bonds and (2) whether



sufficient oxygen is present to convert the waste constituents to carbon



dioxide and water vapor.  The specific design parameters that the Agency



will evaluate to assess whether these conditions are met are temperature,



excess oxygen, and residence time.  Below is a discussion of why EPA



believes these parameters to be important, as well as a discussion of how



these parameters will be monitored during operation.



    It is important to point out that, relative to the development of



land disposal restriction standards, EPA  is concerned with these design



parameters only when a quench water or scrubber water residual is



generated from treatment of a particular  waste.   If treatment of a



particular waste in a liquid injection unit would not generate a



wastewater  stream, then  the Agency, for purposes of land disposal



treatment standards, would be concerned only with the waste



characteristics that affect selection of  the unit, not with the



above-mentioned design parameters.
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         (i)   Temperature.   Temperature is important in that it provides



an indirect measure of the  energy available (i.e.,  Btu/hr)  to overcome



the activation energy of waste constituents.   As the design temperature



increases,  the more likely  it is that the molecular bonds will  be



destabilized and the reaction completed.



    The temperature is normally controlled automatically through the use



of instrumentation that senses the temperature and automatically adjusts



the amount of fuel and/or waste being fed.  The temperature signal



transmitted to the controller can be simultaneously transmitted to a



recording device, referred  to as a strip chart, and thereby continuously



recorded.  To fully assess  the operation of the unit, it is important to



know not only the exact location in the incinerator at which the



temperature is being monitored but also the location of the design



temperature.



         (ii)  Excess oxygen.  It is important that the incinerator



contain oxygen in excess of the stiochiometric amount necessary to



convert the organic compounds to carbon dioxide and water vapor.  If



insufficient oxygen is present, then destabilized waste constituents



could  recombine  to the same or other BOAT list organic compounds and



potentially cause the scrubber water to contain higher concentrations of



BOAT list  constituents than would be the case  for a wel1-operated unit.



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



controlled by continuous sampling and  analysis of the stack gas.  If the



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



transmits  a signal to the valve controlling the air supply, thereby





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increasing the flow of oxygen to the afterburner.   The analyzer



simultaneously transmits a signal  to a recording device so that the



amount of excess oxygen can be continuously recorded.   Again,  as with



temperature, it is important to know the location  from which the



combustion gas is being sampled.



         (iii)  Carbon monoxide.  Carbon monoxide  is an important



operating parameter because it provides an indication  of the extent to



which the waste organic constituents are being converted to carbon



dioxide and water vapor.  An increase in the carbon monoxide level



indicates that greater amounts of organic waste constituents are



unreacted or partially reacted.  Increased carbon  monoxide levels can



result from insufficient excess oxygen, insufficient turbulence in the



combustion zone, or insufficient residence time.



         (iv)  Waste feed rate.  The waste feed rate is important to



monitor because it is correlated to the residence  time.  The residence



time is associated with a specific Btu energy value of the feed and a



specific volume of combustion gas generated.  Prior to incineration, the



Btu value of the waste  is determined through the use of a laboratory



device known as a bomb calorimeter.  The volume of combustion gas



generated from the waste to be incinerated is determined from an analysis



referred to as an ultimate analysis.  This analysis determines the amount



of elemental constituents present, which include carbon, hydrogen,



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



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



calculated.  After both the Btu content and the expected combustion gas





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volume have been determined, the feed rate can be fixed at the desired



residence time.  Continuous monitoring of the feed rate will determine



whether the unit was operated at a rate corresponding to the designed



residence time.



         (b)  Rotary kiln.  For this incineration, EPA will examine both



the primary and secondary chamber in evaluating the design of a



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



assessment of design will focus on whether it is likely that sufficient



energy will be provided to the waste to volatilize the waste



constituents.  For the secondary chamber, analogous to the sole liquid



injection incineration chamber, EPA will examine the same parameters



discussed previously under liquid injection incineration.  These



parameters will not be discussed again here.



    The particular design parameters to be evaluated for the primary



chamber are kiln temperature, residence time, and revolutions per



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



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



monitored during operation.



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



in that it provides an indirect measure of the energy input (i.e.,



Btu/hr) available for heating the waste.  The higher the temperature is



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



constituents will volatilize.  As discussed earlier under "Liquid



Injection," temperature should be continuously monitored and recorded.
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Additionally, it is important to know the location of the



temperature-sensing device in the kiln.



         (ii)  Residence time.  This parameter is important in that it



affects whether sufficient heat is transferred to a particular



constituent for volatilization to occur.  As the time that the waste is



in the kiln is increased, a greater quantity of heat is transferred to



the hazardous waste constituents.  The residence time will be a function



of the specific configuration of the rotary kiln, including the length



and diameter of the kiln, the waste feed rate, and the rate of rotation.



         (iii)  Revolutions per minute (RPM).  This parameter provides an



indication of the turbulence that occurs in the primary chamber of a



rotary kiln.  As the turbulence increases, the quantity of heat



transferred to the waste is also be expected to increase.  However, as



the RPM value increases, the residence time decreases, resulting in a



reduction of the quantity of heat transferred to the waste.  This



parameter needs to be carefully evaluated because it provides a balance



between turbulence and residence time.



         (c)  Fluidized  bed.  As discussed previously, in the section on



"Underlying principles of operation," the primary chamber accounts for



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



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



will  generally provide additional residence  time for thermal oxidation of



the waste constituents.  Relative to the primary chamber, the parameters



that  the Agency will examine  in  assessing the effectiveness of the design
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are temperature, residence time, and bed pressure differential.  The



first two were discussed under "Rotary kiln" and will not be discussed



here.  The last, bed pressure differential, is important in that it



provides an indication of the amount of turbulence and, therefore,



indirectly the amount of heat supplied to the waste.  In general, as the



pressure drop increases, both the turbulence and heat supplied increase.



The pressure drop through the bed should be continuously monitored and



recorded to ensure that the design value is achieved.



         (d)  Fixed hearth.  The design considerations for this



incineration unit are similar to those for a rotary kiln with the



exception that rate of rotation (i.e., RPM) is not an applicable design



parameter.  For the primary chamber of this unit, the parameters that the



Agency will examine in assessing how well the unit is designed are the



same as those discussed under "Rotary kiln"; for the secondary chamber



(i.e., afterburner), the design and operating parameters of concern are



the same as those previously discussed under "Liquid injection."



3.2.2  Fuel Substitution



    Fuel substitution involves using hazardous waste as a fuel in



industrial furnaces or in boilers for generation of steam.  The hazardous



waste may be blended with nonhazardous wastes (e.g., municipal sludge)



and/or fossil fuels.



    (1)  Applicability and use of technology.  Fuel substitution has been



used with industrial waste solvents, refinery wastes, synthetic



fibers/petrochemical wastes, and waste oils.  It can also be used when
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combusting other waste types produced during the manufacturing of
Pharmaceuticals, pulp and paper, and pesticides.  These wastes can be
handled in a solid, liquid, or gaseous form.
    The most common types of units in which waste fuels are burned are
industrial furnaces and industrial boilers.  Industrial furnaces include
a diverse variety of industrial processes that produce heat and/or
products by burning fuels.  They include blast furnaces, smelters, and
coke ovens.  Industrial boilers are units wherein fuel is used to produce
steam for process and plant use.  Industrial boilers typically use coal,
oil, or gas as the primary fuel source.
    A number of parameters affect the selection of fuel substitution.
These are:
    •  Halogen content of the waste;
    •  Inorganic solids content (ash content) of the waste,
       particularly heavy metals;
    •  Heating value of the waste;
    •  Viscosity of the waste  (for liquids);
    •  Filterable solids concentration (for liquids);  and
    •  Sulfur content.
    If halogenated organics are burned, halogenated acids and free
halogen are among the products of combustion.  These released corrosive
gases may require subsequent treatment prior to venting to the
atmosphere.  Also, halogens and halogenated acids formed during
combustion are  likely to severely corrode boiler tubes and other process
equipment.  For this reason, halogenated wastes are blended into fuels
                                     78

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only at very low concentrations to minimize such problems.  High chlorine
content can also lead to the incidental production (at very low
concentrations) of other hazardous compounds such as polychlorinated
biphenyls (PCBs), polychlorinated dibenzo-p-dioxins (PCDDs), chlorinated
dibenzofurans  (PCDFs), and polychlorinated phenols.
    High inorganic solids content (i.e., ash content) of wastes may cause
two problems:  (1) scaling in the boiler and (2) particulate air
emissions.  Scaling results from deposition of inorganic solids on the
walls of the boiler.  Particulate emissions are produced by
noncombustible inorganic constituents that flow out of the boiler with
the gaseous combustion products.  Because of these problems, wastes with
significant concentrations of inorganic materials are not usually handled
in a boiler unless the boiler has an air pollution control system.
    Industrial furnaces vary in their tolerance to inorganic
constituents.  Heavy metal concentrations, found in both halogenated and
nonhalogenated wastes used as fuel, can cause environmental concern
because  they may  be emitted in  the gaseous emissions from the combustion
process,  in the  ash residues, or  in any produced solids.  The
partitioning of  the heavy metals  to these residual streams primarily
depends  on  the volatility of the  metal, waste matrix, and furnace design.
    The  heating  value of the waste must be sufficiently high  (either
alone  or in combination with other fuels) to maintain combustion
temperatures consistent with efficient waste destruction  and  operation of
the boiler  or  furnace.  For many  applications, only  supplemental  fuels
                                     79

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having minimum heating values of 4,400 to 5,600 kcal/kg (8,000 to 10,000



Btu/lb) are considered to be feasible.  Below this value,  the unblended



fuel would not be likely to maintain a stable flame and its combustion



would release insufficient energy to provide needed steam generation



potential in the boiler or the necessary heat for an industrial  furnace.



Some wastes with heating values of less than 4,400 kcal/kg (8,000 Btu/lb)



can be used if sufficient auxiliary fuel is employed to support



combustion or if special designs are incorporated into the combustion



device.  Occasionally, for wastes with heating values higher than those



of virgin fuels, blending with auxiliary fuel may be required to prevent



overheating or overcharging the combustion device.



    In combustion devices designed to burn liquid fuels, the viscosity of



liquid waste must be low enough so that it can be atomized in the



combustion chamber.  If viscosity is too high, heating of storage tanks



may be required prior to combustion.  For atomization of liquids, a



viscosity of  165 centistokes  (750 SSU) or less is typically required.



     If filterable material  suspended  in the  liquid fuel prevents or



hinders  pumping or atomization, unacceptable combustion conditions may



result.



     Sulfur content in the waste may prevent  burning of the waste because



of  potential  atmospheric emissions of sulfur oxides.   For  instance,  there



are  proposed  Federal sulfur oxide emission  regulations for certain new



source industrial  boilers  (51  FR 22385).  Air  pollution control devices



are  available to remove  sulfur oxides from  the stack gases.
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    (2)  Underlying principles of operation.  For a boiler and most
industrial  furnaces there are two distinct principles of operation.
Initially,  energy in the form of heat is transferred to the waste to
achieve volatilization of the various waste constituents.  For liquids,
volatilization energy may also be supplied by using pressurized
atomization.   The energy used to pressurize the liquid waste allows the
atomized waste to break into smaller particles, thus enhancing its rate
of volatilization.  The volatilized constituents then require additional
energy to destabilize the chemical bonds and allow the constituents to
react with oxygen to form carbon dioxide and water vapor.  The energy
needed to destabilize the chemical bonds is referred to as the energy of
activation.
    (3)  Physical description of the process.  As stated, a number of
industrial  applications can use fuel substitution.  Therefore, there is
no one process description that will fit all of these applications.
However, the following section provides a general description of
industrial  kilns (one form of industrial furnace) and industrial
boi1ers.
         (a)   Kilns.  Combustible wastes have the potential to be used as
fuel  in kilns and, for waste liquids, are often used with oil to co-fire
kilns.  Coal-fired kilns are capable of handling some solid wastes.  In
the case of cement kilns, there are usually no residuals requiring land
disposal since any ash formed becomes part of the product or is removed
by particulate collection systems and recycled back to the kiln.   The
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only residuals may be low levels of unburned gases escaping with



combustion products.  If this is the case, air pollution control devices



may be required.



    Three types of kilns are particularly applicable:  cement kilns, lime



kilns, and lightweight aggregate kilns.



         (i)  Cement kilns.  The cement kiln is a rotary furnace, which



is a refractory-lined steel shell used to calcine a mixture of calcium,



silicon, aluminum, iron, and magnesium-containing minerals.  The kiln is



normally fired by coal or oil.  Liquid and solid combustible wastes may



then serve as auxiliary fuel.  Temperatures within the kiln are typically



between 1,380°C and 1,540°C (2,500°F to 2,800°F).  To date, only



liquid hazardous wastes have been burned  in cement kilns.



    Most cement kilns have a dry particulate collection device (i.e.,



either an electrostatic precipitator or a baghouse) with the collected



fly ash recycled back to the kiln.  Buildup of metals or other



noncombustibles is prevented through their incorporation in the product



cement.  Since many types of cement require a source of chloride, most



halogenated liquid hazardous wastes currently can be burned in cement



kilns.  Available information shows that  scrubbers are not used.



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



calcination process using limestone (CaCO ) or dolomite  (CaCO  and



MgCO  ).  These raw materials are also  heated in a refractory-lined



rotary kiln, typically to temperatures of 980°C to 1,260°C



(1,800°F to 2,300°F).  Lime kilns are  less likely to burn
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hazardous wastes than cement kilns because product lime is often added to
potable water systems.  Only one lime kiln currently burns hazardous
waste in the U.S.  That particular facility sells its product lime for
use as flux or as refractory in blast furnaces.
    As with cement kilns, any collected fly ash is recycled back to the
lime kiln, resulting in no residual streams from the kiln.  Available
information shows that scrubbers are not used.
         (iii)  Lightweight aggregate kilns.  Lightweight aggregate kilns
heat clay to produce an expanded lightweight inorganic material  used in
Portland cement formulations and other applications.  The kiln has a
normal temperature range of 1,100°C to 1,150°C (2,000°F to 2,100°F).
Lightweight aggregate kilns are less amenable to combustion of hazardous
wastes as fuels than the other kilns described above because of the lack
of material in the kiln to adsorb halogens.  As a result, burning of
halogenated organics in these kilns would likely require afterburners to
ensure complete destruction of the halogenated organics and scrubbers to
control acid gas production.  Such controls would produce a wastewater
residual stream subject to treatment standards.
         (b)  Industrial boilers.  A boiler is a closed vessel in which
water is transformed into steam by the application of heat.  Normally,
heat is supplied by the combustion of pulverized coal, fuel oil,  or gas.
These fuels are fired into a combustion chamber with nozzles and burners
that provide mixing with air.   Liquid wastes and granulated solid wastes
(in the case of grate-fired boilers) can be burned as auxiliary fuel in a
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boiler.  Few grate-fired boilers burn hazardous wastes,  however.   For



liquid-fired boilers,  residuals requiring land disposal  are generated



only when the boiler is shut down and cleaned.  This is  generally done



once or twice per year.  Other residuals from liquid-fired boilers would



be the gas emission stream, which would consist of any products of



incomplete combustion,  along with the normal combustion  products.  For



example, chlorinated wastes would produce acid gases.  In this case, air



pollution control devices may be required.   For solid fired boilers, an



ash normally is generated.  This ash may contain residual amounts of



organics from the blended waste/fuels, as well as noncombustible



materials.  Land disposal of this ash would require compliance with



applicable BOAT treatment standards.



    (4)  Waste characteristics affecting performance.  For cement kilns



and lime kilns and for lightweight aggregate  kilns burning nonhalogenated



wastes  (i.e., no scrubber  is needed to control acid gases), no residual



waste  streams would be produced.  Any noncombustible material  in the



waste  would leave the  kiln  in the product stream.  As a  result,  in



transferring standards EPA  would not  examine  waste characteristics



affecting performance  but  rather would determine the applicability  of



fuel  substitution.  That  is, EPA would investigate the parameters



affecting treatment selection.  As mentioned  previously,  for  kilns  these



parameters  are Btu content, percent filterable solids, halogenated



organics content, viscosity, and sulfur  content.
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    Lightweight aggregate kilns burning halogenated organics and boilers



burning wastes containing any noncombustibles will produce residual



streams subject to treatment standards.  In determining whether fuel



substitution is likely to achieve the same level  of performance on an



untreated waste as on a previously treated waste,  EPA will examine



(1) relative volatility of the waste constituents, (2) the heat transfer



characteristics (for solids) and (3) the activation energy for combustion.



         (a)  Relative volatility.  The term relative volatility (a)



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



waste will  vaporize from that waste upon application of heat from an



external source.  Hence, it bears a relationship  to the equilibrium vapor



pressure of the substance.



    EPA recognizes that the relative volatilities  cannot be measured or



calculated directly for the types of wastes generally treated in an



industrial  boiler or furnace.  The Agency believes that the best measure



of relative volatility is the boiling point of the various hazardous



constituents and will, therefore, use this parameter in assessing



volatility of the organic constituents.



         (b)  Heat transfer characteristics.  Consistent with the



underlying principles of combustion in aggregate  kilns or boilers,  a



major factor with regard to whether a particular  constituent will



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



industrial  boilers burning solid fuels, heat is transferred through the



waste by three mechanisms:   radiation, convection, and conduction.   For a
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given boiler, it can be assumed that the type of waste will have a



minimal impact on the heat transferred from radiation.  With regard to



convection, EPA believes that the range of wastes treated would exhibit



similar properties with regard to the amount of heat transferred by



convection.  Therefore, EPA will not evaluate radiation convection heat



transfer properties of wastes in determining similar treatability.  For



solids, the third heat transfer mechanism, conductivity, is the one



principally operative or most likely to change between wastes.



    Using thermal conductivity measurements as part of a treatability



comparison for two different wastes through a given boiler or furnace is



most meaningful when applied to wastes that are homogeneous.  As wastes



exhibit greater degrees of nonhomogeneity, thermal conductivity becomes



less accurate  in predicting treatability because the measurement



essentially  reflects heat flow through regions having the greatest



conductivity  (i.e., the path of least resistance and not heat flow



through all  parts of the waste).  Nevertheless, EPA has not identified a



better alternative to thermal conductivity, even for wastes that are



nonhomogeneous.



    Other  parameters considered for predicting heat transfer



characteristics were Btu value, specific heat, and ash content.  These



parameters can neither  better account for  nonhomogeneity nor  better



predict heat  transferability through  the waste.



          (c)   Activation energy.  Given an excess  of  oxygen,  an organic



waste  in  an  industrial  furnace  or boiler would be  expected  to  convert to
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carbon dioxide and water vapor, provided that the activation energy is



achieved.  Activation energy is the quantity of heat (energy) needed to



destabilize molecular bonds and create reactive intermediates so that the



oxidation (combustion) reaction will proceed to completion.  As a measure



of activation energy, EPA is using bond dissociation energies.  In



theory, the bond dissociation energy would be equal  to the activation



energy;  however, in practice this is not always the case.



    In some instances, bond energies will not be available and will have



to be estimated or other energy effects  (e.g.,  vibrational effects) and



other reactions will have a significant  influence on activation energy.



Because of the shortcomings of bond energies in estimating activation



energy, EPA analyzed other waste characteristic parameters to determine



whether these parameters would provide a better basis for transferring



treatment standards from an untested waste to a tested waste.  These



parameters included heat of combustion,  heat of formation, use of



available kinetic data to predict activation energies, and general



structural class.  All of these were rejected for the reasons provided



below.



    The heat of combustion measures only the difference in energy of the



products and reactants; it does not provide information on the transition



state  (i.e., the energy input needed to  initiate the reaction).  Heat of



formation is used as a predictive tool for whether reactions are likely



to proceed; however, there are a significant number of hazardous



constituents for which these data are not available.  Use of available
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kinetic data was rejected because while such data could be used to
calculate some free energy values (AG), they could not be used for
the wide range of hazardous constituents.   Finally, EPA decided not to
use structural classes because the Agency believes that evaluation of
bond dissociation energies allows for a more direct comparison.
    (5)  Design and operating parameters
         (a)  Design parameters.   Cement kilns and lime kilns, along with
aggregate kilns burning nonhalogenated wastes, produce no residual
streams.  Their design and operation are such that any wastes that are
incompletely destroyed will be contained in the product.  As a result,
the Agency will not look at design and operating values for such devices
since treatment, per se, cannot be measured through detection of
constituents  in residual streams.  In this instance it is important
merely to ensure that the waste is appropriate for combustion in the
kilns and that the kiln is operated in a manner that will produce a
usable product.
    Specifically, cement, lime, and aggregate kilns are only demonstrated
on liquid hazardous wastes.  Such wastes must be sufficiently free of
filterable solids to avoid plugging the burners at the hot end of the
kiln.  Viscosity also must be low enough to inject the waste into the
kiln through  the burners.  The sulfur content is not a concern unless the
concentration  in the waste is high enough to exceed Federal, State, or
local air pollution standards promulgated for industrial boilers.
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    The design parameters that normally affect the operation of an
industrial  boiler (and aggregate kilns with residual  streams) with
respect to hazardous waste treatment are (1) the design temperature,
(2) the design retention time of the waste in the combustion chamber, and
(3) the turbulence in the combustion chamber.  Evaluation of these
parameters would be important in determining whether an industrial boiler
or industrial furnace is adequately designed for effective treatment of
hazardous wastes.  The rationale for selection of three parameters is
given below.
         (i)  Design temperature.  Industrial boilers are generally
designed based on their steam generation potential (Btu output).  This
factor is related to the design combustion temperature, which in turn
depends on the amount of fuel burned and its Btu value.  The fuel  feed
rates and combustion temperatures of industrial  boilers are generally
fixed based on the Btu values of fuels normally handled (e.g.,  No. 2
versus No.  6 fuel oils).  When wastes are to be blended with fossil fuels
for combustion, the blending, based on Btu values, must be such that the
resulting Btu value of the mixture is close to that of the fuel value
used in design of the boiler.  Industrial furnaces also are designed to
operate at specific ranges of temperature to produce the desired product
(e.g., lightweight aggregate).  The blended waste/fuel  mixture  should be
capable of maintaining the design temperature range.
         (ii)  Retention time.  A sufficient retention time of  combustion
products is normally necessary to ensure that the hazardous substances
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being combusted (or formed during combustion) are completely oxidized.



Retention times on the order of a few seconds are normally needed at



normal operating conditions.  For industrial furnaces, as well as



boilers, the retention time is a function of the size of the furnace and



the fuel feed rates.  For most boilers and furnaces, the retention time



usually exceeds a few seconds.



         (iii)  Turbulence.  Boilers are designed so that fuel and air



are intimately mixed.  This helps ensure that complete combustion takes



place.  The shape of the boiler and the method of fuel and air feed



influence the turbulence required for good mixing.   Industrial furnaces



also  are designed for turbulent mixing where fuel and air are mixed.



         (b)  Operating parameters.  The operating  parameters that



normally affect the performance of an industrial boiler and many



industrial  furnaces with respect to treatment of hazardous wastes are



(1) air flow rate,  (2) fuel feed rate, (3)  steam pressure or rate of



production, and (4) temperature.  EPA believes that  these four parameters



will  be used to determine whether an  industrial boiler burning blended



fuels containing  hazardous  waste constituents is properly operated.  The



rationale for  selection of  these four operating parameters



is  given below.   Most  industrial furnaces will monitor similar



parameters, but some exceptions  are noted below.



          (i)   Air feed rate.  An important  operating parameter  in boilers



and many  industrial  furnaces  is  the oxygen  content  in  the flue gas,  which



is  a  function  of  the air  feed rate.   Stable combustion of a  fuel
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generally occurs within a specific range of air-to-fuel ratios.  An
oxygen analyzer in the combustion gases can be used to control the feed
ratio of air to fuel to ensure complete thermal destruction of the waste
and efficient operation of the boiler.  When necessary, the air flow rate
can be increased or decreased to maintain proper fuel-to-oxygen ratios.
Some industrial furnaces do not completely combust fuels (e.g., coke
ovens and blast furnaces); hence, oxygen concentration in the flue gas is
a meaningless variable.
         (ii)  Fuel feed rate.  The rate at which fuel is injected into
the boiler or industrial furnace will determine the thermal  output of the
system per unit of time (Btu/hr).  If steam is produced, steam pressure
monitoring will indirectly determine if the fuel feed rate is adequate.
However, various velocity and mass measurement devices can be used to
monitor fuel flow directly.
         (iii)  Steam pressure or rate of production.  Steam pressure in
boilers provides a direct measure of the thermal output of the system and
is directly monitored by use of in-system pressure gauges.  Increases or
decreases in steam pressure can be effected by increasing or decreasing
the fuel and air feed rates within certain operating design limits.  Most
industrial furnaces do not produce steam, but  instead produce a product
(e.g., cement, aggregate) and monitor the rate of production.
         (iv)  Temperature.  Temperatures are monitored and controlled in
industrial boilers to ensure the quality and flow rate of steam.
Therefore, complex monitoring systems are frequently installed in the
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combustion unit to provide a direct reading of temperature.  The



efficiency of combustion in industrial boilers is dependent on combustion



temperatures.  Temperature may be adjusted to design settings by



increasing or decreasing air and fuel feed rate.



    Wastes should not be added to primary fuels until the boiler



temperature reaches the minimum needed for destruction of the wastes.



Temperature instrumentation and control  should be designed to stop waste



addition in the event of process upsets.



    Monitoring and control of temperature in industrial furnaces are also



critical to the product quality; e.g., lime, cement, or aggregate kilns,



which require minimum operating temperatures.  Kilns have very high



thermal inertia in the refractory and in-process product, high residence



times, and high air flow rates, so that even in the case of a momentary



stoppage of fuel flow to the kiln, organic constituents are likely to



continue to be destroyed.  The main operational control required for



wastes burned in kilns is to stop waste flow in the event of low kiln



temperature, loss of the electrical power to the combustion air fan, and



loss of primary fuel flow.



         (v)  Other Operating Parameters.   In addition to the four



operating parameters discussed above, EPA considered and then discarded



one additional parameter.  Fuel-to-waste blending ratios were also



considered.  However, while the blending is done to yield a uniform.Btu



content fuel, blending ratios will vary widely, depending on the Btu



content of the wastes and fuels being used.
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3.2.3    Stabilization
    Stabilization refers to a broad class of treatment processes that
chemically reduce the mobility of hazardous constituents in a waste.
Solidification and fixation are other terms that are sometimes used
synonymously for stabilization or to describe specific variations within
the broader class of stabilization.  Related technologies are
encapsulation and thermoplastic binding; however, EPA considers these
technologies to be distinct from stabilization in that the operational
principles are significantly different.
    (1)  Applicability and use of 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 BOAT list metals and having  a high filterable solids content,
low TOC content, and low oil and grease content.  This technology is
commonly used to treat residuals generated from treatment of
electroplating wastewaters.  For some wastes, an alternative to
stabilization is metal recovery.
    (2)  Underlying  principles of operation.  The basic principle
underlying this technology is that stabilizing agents and other chemicals
are added to a waste in order to minimize the amount of metal that
leaches.  The reduced Teachability is accomplished by the formation of a
lattice structure and/or chemical bonds that bind the metals to the solid
matrix and, thereby, limit the amount of metal constituents that can be
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leached when water or a mild acid solution comes into contact with the
waste material.
    There are two principal stabilization processes used--cement-based
and lime-based.   A brief discussion of each is provided below.  In both
cement-based and 1ime/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.
         (a)  Portland cement-based process.  Portland cement is a
mixture of powdered oxides of calcium, silica, aluminum, and iron,
produced by kiln burning of materials rich in calcium and silica at high
temperatures  (i.e., 1400°C to 1500°C or 2550°F to 2730°F).  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
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into the crystal structure of the cement matrix, but this hypothesis has
not been verified.
         (b)  Lime/pozzolan-based process.  Pozzolan, which contains
finely divided,  noncrystalline silica (e.g., fly ash or components of
cement kiln dust),  is a material that is not cementitious in itself but
becomes so upon the addition of lime.  Metals in the waste are converted
to silicates or hydroxides, which inhibit leaching.  Additives, again,
can be used to reduce permeability and thereby further decrease leaching
potential.
    (3)  Description of the stabilization process.   In most stabilization
processes, the waste, stabilizing agent, and other additives,  if used,
are mixed and then pumped to a curing vessel or area and allowed to
cure.  The actual operation (equipment requirements  and process
sequencing) will depend on several factors such as the nature  of the
waste, the quantity of the waste, the location of the waste in relation
to the disposal  site, the particular stabilization formulation to be
used, and the curing rate.  After curing, the solid  formed is  recovered
from the processing equipment and shipped for final  disposal.
    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
                                     95

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wastes to the mixing pits and pumpable uncured wastes to the curing
site.  Stabilized wastes are then removed to a final disposal site.
    Commercial concrete mixing and handling equipment generally can be
used with wastes.  Weighing conveyors, metering cement hoppers, and
mixers similar to concrete batching plants have been adapted in some
operations.  Where extremely dangerous materials are being treated,
remote-control and in-drum mixing equipment, such as that used with
nuclear waste, can be employed.
     (4)  Waste characteristics affecting performance.  In determining
whether stabilization is likely to achieve the same level of performance
on an untested waste as on a previously tested waste, the Agency will
focus on the characteristics that inhibit the formation of either the
chemical bonds or the lattice structure.  The four characteristics EPA
has  identified as affecting treatment performance are the presence of (1)
fine particulates, (2) oil and grease, (3) organic compounds, and (4)
certain inorganic compounds.
         (a)  Fine particulates.  For both cement-based and
1ime/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 decrease the resistance of the material to leaching.
         (b)  Oil and grease.  The presence of oil  and grease  in both
cement-based  and 1ime/pozzolan-based  systems results in the  coating of
                                     96

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waste particles and the weakening of the bonding between the particle and



the stabilizing agent.  This coating can inhibit chemical bond formation,



thereby decreasing the resistance of the material to leaching.



         (c)  Organic compounds.  The presence of organic compounds in



the waste interferes with the chemical reactions and bond formation,



which inhibits curing of the stabilized material.  This results in a



stabilized waste having decreased resistance to leaching.



         (d)  Sulfate and chlorides.  The presence of certain inorganic



compounds will interfere with the chemical reactions, weakening bond



strength and prolonging setting and curing time.  Sulfate and chloride



compounds may reduce the dimensional stability of the cured matrix,



thereby increasing Teachability potential.



    Accordingly, EPA will examine these constituents when making



decisions regarding transfer of treatment standards based on



stabilization.



    (5)  Design and operating parameters.  In designing a stabilization



system, the principal parameters that are important to optimize so that



the amount of 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.



         (a)  Selection of stabilizing agents and other additives.  The



stabilizing agent and additives used will determine the chemistry  and



structure of the stabilized material and, therefore, will affect the
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Teachability of the solid material.  Stabilizing agents and additives



must be carefully selected based on the chemical and physical



characteristics of the waste to be stabilized.  For example, the amount



of sulfates in a waste must be considered when a choice is being made



between a 1ime/pozzolan-based system and a port!and cement-based system.



    To select the type of stabilizing agents and additives, the waste



should be tested in the laboratory with a variety of materials to



determine the best combination.



         (b)  Amount of stabilizing agents and additives.  The amount of



stabilizing agents and additives is a critical parameter in that



sufficient stabilizing materials are necessary in the mixture to bind the



waste constituents of concern properly, thereby making them less



susceptible to leaching.  The appropriate weight ratios of waste to



stabilizing agent and other additives are established empirically by



setting up a series of laboratory  tests that allow separate leachate



testing of different mix ratios.   The ratio of water to stabilizing agent



(including water in waste) will also impact the strength and leaching



characteristics of the stabilized  material.  Too much water will cause



low strength; too little will make mixing difficult and, more



importantly, may not allow the chemical reactions that bind the hazardous



constituents to be fully completed.



         (c)  Mixing.  The conditions of mixing include the type and



duration of mixing.  Mixing  is necessary to ensure homogeneous



distribution of the waste  and  the  stabilizing agents.  Both undermixing
                                     98

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and overtaxing are undesirable.  The first condition results in a
nonhomogeneous mixture; therefore, areas will exist within the waste
where waste particles are neither chemically bonded to the stabilizing
agent nor physically held within the lattice structure.  Overmixing, on
the other hand, may inhibit gel formation and ion adsorption in some
stabilization systems.  As with the relative amounts of waste,
stabilizing agent, and additives within the system, optimal mixing
conditions generally are determined through laboratory tests.  During
treatment it is important to monitor the degree (i.e., type and duration)
of mixing to ensure that it reflects design conditions.
         (d)  Curing conditions.  The curing conditions include the
duration of curing and the ambient curing conditions  (temperature and
humidity).  The duration of curing is a critical parameter to ensure that
the waste particles have had sufficient time in which to form stable
chemical bonds and/or lattice  structures.  The time necessary for
complete stabilization depends upon the waste type and the stabilization
used.  The performance of the  stabilized waste (i.e., the levels of
constituents in the leachate)  will be highly dependent upon whether
complete stabilization has occurred.  Higher temperatures and lower
humidity increase the rate of  curing by increasing the rate of
evaporation of water from the  solidification mixtures.  If temperatures
are too high, however, the evaporation rate can be excessive and result
in too little water being available for completion of the stabilization
                                     99

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reaction.  The duration of the curing process should also be determined
during the design stage and typically will be between 7 and 28 days.
3.2.4    High Temperature Metals Recovery
    High temperature metals recovery (HTMR) provides for recovery of
metals from wastes primarily by volatilization and collection.  The
process yields a metal product or products for reuse and reduces the
concentration of metals in the residual.  This process also significantly
reduces the amount of treated waste that needs to be land disposed.
    There are a number of different types of high temperature metals
recovery systems.  These systems generally differ from one another
relative to the source of energy and the method of recovery.  Such HTMR
systems  include the rotary kiln process, plasma arc reactor,  rotary
hearth/electric furnace system, molten  slag reactor, and flame reactor.
This  technology is different from retorting in that HTMR is conducted  in
a carbon reducing atmosphere, while the retorting process simply
vaporizes the untreated metal.  Retorting  is discussed in a separate
technology  section.
     (1)  Applicability and use of high  temperature metals recovery.  This
process  is  applicable to wastes containing BOAT list metals,  low water
content  (or a water content  that can be either blended to the required
level  or lowered  by dewatering), and low  concentration of organics.  This
technology  is applicable to  a wide  range  of metal salts  including
cadmium, chromium,  lead, mercury, nickel,  and zinc.
                                     100

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    HTMR is generally not used for mercury-containing wastes even though



mercury will volatilize readily at the process temperatures present in



high temperature units.  The rotary kiln recovery process is one example



of this technology; it has been applied to zinc-bearing wastes as an



upgrading step that yields a zinc oxide product for further refinement



and subsequent reuse.  Although this technology was originally developed



in the 1920s for upgrading zinc from ores, it has recently been applied



to electric furnace dust from the steel-making industry.



    (2)  Underlying principles of operation.  The basic principle of



operation for this technology is that metals are separated from a waste



through volatilization in a reducing atmosphere in which carbon is the



reducing compound.  An example chemical reaction would be:



                           2ZnO + C - 2Zn + CO



    In some cases, the waste contains not only BOAT list metal



constituents that  can  be volatilized but also nonvolatile BOAT list



metals as well.   In such cases, the HTMR process can yield two



recoverable product streams.  Whether such recovery can be accomplished,



however, depends on the type and concentration of metals in the original



waste  stream.  Below  is a discussion of the recovery techniques for the



volatile stream, as well as for the waste material that is not



volatilized.



         (a)  Recovery of volatilized metals.  The volatilized metals can



be recovered in the metallic form or as an oxide.  In the case of the



metallic form, recovery is accomplished by condensation alone, while in
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the case of an oxide, it is accomplished by reoxidation, condensation,



and the subsequent collection of the metal oxide particulates in a



baghouse.  There is no difference between these two types of metal



product recovery systems relative to the kinds of waste that can be



treated; the difference is simply reflected in a facility's preference



relative to product purity.  In the former case, the direct condensation



of metals, while more costly, allows for the separation and collection of



metals in a relatively uncontaminated form; in the latter case, the



metals are collected as a combination of several metal oxides.  If



necessary, this combination of metal oxides could be further processed to



produce  individual metal products of increased purity.



          (b)  Less volatile treatment residual.  The fraction of the



waste that is not originally volatilized has three possible



dispositions:   (1) the material can be used directly as.a product  (e.g.,



a waste  residual containing mostly metallic iron can be reused directly



in steel  making);  (2) the material can be  reused after  further processing



(e.g.,  a  waste  residual containing oxides  of iron, chromium, and nickel



can  be  reduced  to  the metallic  form and  then recovered  for  use in  the



manufacture of  stainless  steel);  and (3)  the material has no recoverable



value and is  land  disposed as  a  slag.



     (3)   Description of high temperature metals  recovery process.   The



process  essentially  consists of four operations:  (1)  a  blending operation



to control feed parameters,  (2)  high temperature  processing,  (3)  a



product  collection  system, and (4)  handling of the less  volatile  treated
                                     102

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residual.  A generic schematic diagram for high temperature metals



recovery is shown in Figure 3-5.



         (a)  Blending.  For the system shown, variations in feeds are



minimized by blending wastes from different sources.  Prior to feeding



the kiln, fluxing agents are added to the waste.  Carbon is also added to



the waste as required.  The fluxes (limestone or sand) are added to react



with certain waste components in order to prevent their volatilization



and thus improve the purity of the desired metals recovered.  In



addition, the moisture content is adjusted by either adding water or



blending various wastes.



         (b)  High temperature processing.  These materials are fed to



the furnace where they are heated and the chemical reactions take place.



The combination of residence time and turbulence helps ensure maximum



volatilization of metal constituents.



         (c)  Product collecting.  As discussed previously, the product



collection  system can consist of either a condenser or a combination



condenser and baghouse.  As noted earlier, the particular system depends



on whether  the metal  is to be collected in the metallic form or as an



oxide.



         (d)  Handling of residual.  The equipment needed to handle the



less volatile metal treated residual depends on the final disposition of



the material.  If further recovery is performed, then the waste would be



treated  in  another furnace.  If the material were to be land disposed,



the final process step would generally consist of quenching.
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K061
CARBON
FLUXES
(ADDITIVES)
                 FEED
               BLENDING
    HIGH
TEMPERATURE
 PROCESSING
 PRODUCT
COLLECTION
                                                                                   REUSE
                                         RESIDUAL
                                       COLLECTION
                                            I
                                        REUSE  OR
                                      LAND DISPOSAL
              FIGURE 3-5    EXAMPLE HIGH TEMPERATURE METALS RECOVERY SYSTEM

-------
    (4)  Waste characteristics affecting performance.  In determining
whether high temperature metals recovery technologies are likely to
achieve the same level of performance on an untested waste as on a
previously tested waste, EPA will examine the following three waste
characteristics that have an impact on treatability: (1) type and
concentrations of metals in the waste, (2) relative volatility of the
metals, and (3) heat transfer characteristics of the waste.
         (a)  Type and concentrations of metals in the waste.  Because
this is a metals recovery process, the product must meet certain
requirements for recovery.  If the waste contains other volatile metals
that are difficult to separate and whose presence may affect the ability
to refine the product for subsequent reuse, high temperature metals
recovery may provide less effective treatment.  Analytical methods for
metals can be found in SW-846.
         (b)  Boiling point.  The relative volatilities of the metals in
the waste also affect the ability to separate various metals.  There is
no conventional measurement technique for determining the relative
volatility of a particular constituent in a given waste.  EPA believes
that the best measure of volatility of a specific metal constituent  is
the boiling point.  EPA recognizes that the boiling point has certain
shortcomings; in particular, boiling points are given for pure
components, even though the other constituents  in the waste will affect
partial pressures and thus the boiling point of the mixture.  EPA has not
identified a parameter that can better assess relative volatility.
Boiling points of metals can be determined from the literature.
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         (c)  Heat transfer characteristics.  The ability to heat



constituents within a waste matrix is a function of the heat transfer



characteristics of a heterogeneous waste material.  The constituents



being recovered from the waste must be heated near or above their boiling



points in order for them to be volatilized and recovered.  Whether



sufficient heat will be transferred to the particular constituent to



cause the metal to volatilize will depend on the heat transfer



characteristics of the waste.  There is no conventional direct



measurement of the heat transfer characteristics of a waste.  EPA



believes that the best measure of the heat transfer characteristics of



the waste is thermal conductivity.  The analytical method that EPA has



identified for measurement of thermal conductivity is named "Guarded,



Comparative, Longitudinal Heat Flow Technique";  it is described  in



Appendix D.



     (5)  Design and operating parameters.  The parameters that EPA will



evaluate when determining whether a high temperature metals recovery



system is well designed and well operated are  (1) the furnace



temperature,  (2)  the furnace  residence time,  (3)  the amount and  ratio of



the  feed blending materials,  and  (4) mixing.   Below  is an explanation of



why  EPA  believes  these  parameters are  important  to an analysis of the



design and  operation of the  system.



          (a)   Furnace temperature.   In order  for sufficient heat to  be



transferred  to the  waste  for  volatilization,  high temperatures must  be



provided.   The higher the  temperature  in the  furnace,  the more likely  it
                                     106

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is that the constituents will react with carbon to form free metals and



volatilize.  The temperature must be approximately equal to or greater



than the boiling point of the metals being volatilized.  Excessive



temperatures could volatilize unwanted metals into the product, possibly



inhibiting the potential for reuse of the volatilized product.  In



assessing performance during the treatment period, EPA would want



continuous temperature data.



         (b)  Furnace residence time.  Furnaces must be designed to



ensure that the waste has sufficient time to be heated to the boiling



point of the metals to be volatilized.  The time necessary for complete



volatilization of these constituents is dependent on the furnace



temperature and the heat transfer characteristics of the waste.  The



residence time is a function of the physical dimensions of the furnace



(i.e., length, diameter, and slope (for rotary kilns)), the rate of



rotation (if applicable), and the feed rate.



         (c)  Amount and ratio of feed blending materials.  For the



maximum volatilization of the metals being recovered, the following feed



parameters must be controlled by the addition of carbon, fluxes, and



other agents, if necessary.  Blending of these feed components is also



needed to adjust the following feed parameters to the required volume:



carbon content, moisture content, calcium-to-silica ratio, and the



initial concentration of the metals to be recovered.  These parameters



all affect the rate of the reduction reaction and volatilization.  EPA



will examine blending ratios during treatment to ensure that they comply



with design conditions.
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         (d)  Mixing.  Effective mixing of the total  components is


necessary to ensure that a uniform waste is being treated.  Turbulence in


the furnace also ensures that no "pockets" of waste go untreated.


Accordingly, EPA will examine the type and degree of mixing involved when


assessing treatment design and performance.


3.2.5    Hexavalent Chromium Reduction


    (1)  Applicability and use of hexavalent chromium reduction.  The

                                  6+
process of hexavalent chromium (Cr  ) reduction involves conversion


from the hexavalent form to the trivalent form of chromium.  This


technology has wide application to hexavalent chromium wastes, including


plating solutions, stainless steel acid baths and rinses, "chrome


conversion" coating process rinses, and chromium pigment manufacturing


wastes.  Because this technology requires the pH to be in the acidic


range, it would not be applicable to a waste that contains significant


amounts of cyanide or sulfide.  In such cases, lowering of the pH can


generate toxic gases such as hydrogen cyanide or hydrogen sulfide.   It is


important to note that additional treatment is required to remove


trivalent chromium from solution.


     (2)  Underlying  principles of operation.  The basic principle of


treatment is to reduce the valence of chromium in solution (in the form


of  chromate or dichromate ions) from the  valence state of six  (+6) to the


trivalent (+3) state.   "Reducing  agents"  used to effect the reduction


include  sodium bisulfite, sodium  metabisulfite,  sulfur dioxide, sodium


hydrosulfide, or  the ferrous  form of iron.
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    A typical reduction equation, using sodium sulfite as the reducing



agent, is:



    H2Cr207 + 3Na2S03 + (S04)3 -> Cr2(S04)3 + 3Na2S04 + 4H20.





The reaction is usually accomplished at pH values in the range of 2 to 3.



    At the completion of the chromium reduction step, the trivalent



chromium compounds are precipitated from solution by raising the pH to a



value exceeding about 8.  The less soluble trivalent chromium (in the



form of chromium hydroxide) is then allowed to settle from solution.  The



precipitation reaction is as follows:



                   Cr2(S04)3 + 3Ca(OH)2 - 2Cr(OH)3 + CaS04.





    (3)  Description of chromium reduction process.  The chromium



reduction treatment process can be operated in a batch or a continuous



mode.  A batch system will consist of a reaction tank, a mixer to



homogenize the contents of the tank, a supply of reducing agent, and a



source of acid and base for pH control.



    A continuous chromium reduction treatment system, as shown in



Figure 3-6, will usually include a holding tank upstream of the reaction



tank for flow and concentration equalization.  It will also include



instrumentation to automatically control the amount of reducing agent



added and the pH of the reaction tank.  The amount of reducing agent is



controlled by the use of a sensor called an oxidation-reduction potential



(ORP) cell.  The ORP sensor electronically measures, in millivolts, the



level to which the redox reaction has proceeded at any given time.  It
                                    109

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                 REDUCING
                  AGENT
                   FEED
                  SYSTEM
                                  ACID
                                  FEED
                                SYSTEM
                     L-
-------
must be noted, though, that the ORP reading is very pH dependent.



Consequently, if the pH is not maintained at a steady value, the ORP will



vary somewhat, regardless of the level of chromate reduction.



    (4)  Waste characteristics affecting performance.  In determining



whether chromium reduction can treat an untested waste to the same level



of performance as a previously tested waste, EPA will examine waste



characteristics that affect the reaction involved with either lowering



the pH or reducing the hexavalent chromium.  EPA believes that such



characteristics include the oil and grease content of the waste, total



dissolved solids, and the presence of other compounds that would undergo



reduction reaction.



          (a)  Oil and grease.  EPA believes that these compounds could



potentially  interfere with the oxidation-reduction reactions, as well as



cause  monitoring problems by  fouling  the instrumentation  (e.g.,



electrodes).  Oil and grease  concentrations can be measured  by EPA



Methods 9070  and 9071.



          (b)  Total dissolved  solids.   These compounds can  interfere with



the addition  of treatment chemicals  into solution  and can possibly cause



monitoring  problems.



          (c)  Other reducible  compounds.   These compounds would  generally



consist of  other metals  in the waste.   Accordingly,  EPA will  evaluate the



type  and  concentration of other metals  in  the  waste  when  evaluating



transfer  of treatment  performances.
                                     Ill

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    (5)  Design and operating parameters.  The parameters that EPA will
examine in assessing the design and operation of a chromium reduction
treatment system are discussed below.
         (a)  Treated and untreated design concentration.  EPA will need
to know the level of performance that the facility is designed to achieve
in order to ensure that the design is consistent with best demonstrated
practices.  This parameter is important because a system will not usually
perform better than its design.  Along with knowledge of the treated
design concentration, it is also important to know the characteristics of
the untreated waste that the system  is designed to handle.  Thus, EPA
will obtain data on the untreated wastes to ensure that the waste
characteristics  fall within the design specifications.
          (b)  Reducing agent.  The choice of  a reducing agent establishes
the chemical reaction upon which the chromium reduction system is based.
The amount  of reducing agent needs to be monitored and controlled in both
batch  and continuous systems.  In batch  systems, the  reducing agent  is
usually controlled  by an analysis of the hexavalent chromium remaining  in
solution.   For continuous  systems, the ORP reading is used to monitor  and
control the addition of the  reducing agent.
    The ORP reading will change  slowly until  the correct  amount  of
reducing  agent has  been added, at which  point the ORP will change
rapidly,  indicating  the reaction has been completed.  The  set point  for
the ORP monitor  is  generally  the reading just after  the  rapid change has
begun.  The reduction  system  must  then be monitored  periodically to
determine whether  the  selected  set point  needs  further  adjustment.
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         (c)  pH.   For batch and continuous systems, pH is an important



parameter because  of its effect on the reduction reaction.  For a batch



system,  pH can be  monitored intermittently during treatment.  For a



continuous system, it should be monitored continuously because of its



effect on the ORP  reading.  In evaluating the design and operation of a



continuous chromium reduction system, it is important to know the pH on



which the design ORP value is based, as well as the designed ORP value.



         (d)  Retention time.  Retention time should be adequate to



ensure that the hexavalent chromium reduction reaction goes to



completion.  In the case of the batch reactor, the retention time is



varied by adjusting the treatment time in the reaction tank.  If the



process is continuous, it is important to monitor the feed rate to ensure



that the designed residence time  is achieved.



3.2.6    Chemical  Precipitation



     (1)  Applicability and use of chemical precipitation.  Chemical



precipitation is  used when dissolved metals are to be removed from



solution.  This technology can be applied to a wide range of wastewaters



containing dissolved BOAT list metals and other metals as well.  This



treatment process has been practiced widely by industrial facilities



since the 1940s.



     (2)  Underlying principles of operation.  The underlying principle of



chemical precipitation  is that metals in wastewater are removed by the



addition of a treatment chemical  that converts the dissolved metal to  a



metal precipitate.  This  precipitate is less soluble than the original
                                     113

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metal compound and therefore settles out of solution, leaving a lower
concentration of the metal present in the solution.  The principal
chemicals used to convert soluble metal compounds to the less soluble
forms include: lime (Ca(OH) ), caustic (NaOH), sodium sulfide (Na S),
and, to a lesser extent, soda ash (Na CO ), phosphate, and ferrous
sulfide (FeS).
    The solubility of a particular compound will depend on the extent to
which the electrostatic forces holding the ions of the compound together
can be overcome.  The solubility will change significantly with
temperature; most metal compounds are more soluble as the temperature
increases.  Additionally, the solubility will be affected by the other
constituents present in a waste.  As a general rule, nitrates, chlorides,
and  sulfates are more soluble than hydroxides, sulfides, carbonates, and
phosphates.
    An important concept  related to  treatment of the soluble metal
compounds  is pH.   In general, pH provides a measure  of the extent to
which a solution contains either an  excess of hydrogen or hydroxide
ions.  The  pH  scale ranges  from 0 to 14; with 0 being the most acidic,  14
representing  the highest  alkalinity  or hydroxide ion  (OH  ) content,  and
7.0  being  neutral.
     When  hydroxide  is used,  as  is often  the case,  to  precipitate  the
soluble metal  compounds,  the  pH  is frequently monitored to ensure that
sufficient  treatment chemicals  are added.   It is important to point  out
that  pH  is  not  a good measure of the addition of treatment chemicals  for
                                     114

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compounds other than hydroxides; when sulfide is used, for example,
facilities might use an oxidation-reduction potential meter (ORP)
correlation to ensure that sufficient treatment chemicals are used.
    Following conversion of the relatively soluble metal compounds to
metal  precipitates, the effectiveness of chemical precipitation is a
function of the physical removal, which usually relies on a settling
process.  A particle of a specific size, shape, and composition will
settle at a specific velocity, as described by Stokes' Law.   For a batch
system, Stokes' Law is a good predictor of settling time because the
pertinent particle parameters remain essentially constant.  Nevertheless,
in practice, settling time for a batch system is normally determined by
empirical testing.  For a continuous system, the theory of settling is
complicated by factors such as turbulence, short-circuiting,  and velocity
gradients, thereby increasing the importance of the empirical  tests.
    (3)  Description of the chemical precipitation process.  The
equipment and instrumentation required for chemical precipitation vary
depending on whether the system is batch or continuous.  Both operations
are discussed below; a schematic of the continuous system is  shown in
Figure 3-7.
    For a batch system, chemical precipitation requires only  a feed
system for the treatment chemicals and a second tank where the waste can
be treated and allowed to settle.  When lime is used, it is generally
added to the reaction tank in a slurry form.  In a batch system, the
supernate is usually analyzed before discharge, thus minimizing the need
for instrumentation.
                                    115

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                                                                                            SLUDGE TO
                                                                                            DEWATEHING
                            FIGURE  3-7     CONTINUOUS CHEMICAL PRECIPITATION

-------
    In a continuous system,  additional  tanks are necessary, as well as



the instrumentation to ensure that the system is operating properly.  In



this system, the first tank that the wastewater enters is referred to as



an equalization tank.  This is where the waste is mixed in order to



provide more uniformity, thereby minimizing the wide swings in the type



and concentration of constituents being sent to the reaction tank.  It is



important to reduce the variability of the waste sent to the reaction



tank because control systems inherently are limited with regard to the



maximum fluctuations that can be managed.



    Following equalization,  the waste is pumped to a reaction tank where



treatment chemicals are added; this is done automatically by using



instrumentation that senses the pH of the system and then pneumatically



adjusts the position of the treatment chemical feed valve such that the



design pH value is achieved.  Both the complexity and the effectiveness



of the automatic control system will vary depending on the variation in



the waste and the pH range that is needed to properly treat the waste.



    An important aspect of the reaction tank design is that it be well



mixed so that the waste and the treatment chemicals are dispersed



throughout  the tank, in order to ensure commingling of the reactant and



the treatment chemicals.  In addition,  effective dispersion of the



treatment chemicals throughout the tank is necessary to properly monitor



and thereby control the amount of treatment chemicals added.



    After the waste is reacted with the treatment chemical, it flows to a



quiescent tank where the precipitate is allowed to settle and then be
                                    117

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subsequently removed.   Settling can be chemically assisted through the
use of flocculating compounds.  Flocculants increase the particle size
and the density of the precipitated solids, both of which increase the
rate of settling.  The flocculating agent that will best improve settling
characteristics will vary depending on the particular waste; selection of
the flocculating agent is generally accomplished by performing laboratory
bench tests.  Settling can be conducted in a large tank by relying solely
on gravity or can be mechanically assisted through the use of a circular
clarifier or an  inclined separator.  Schematics of two separators are
shown in Figures 3-8 and 3-9.
    Filtration can be used for further removal of precipitated residuals
both  in cases where the settling system is underdesigned and in cases
where the particles are difficult to settle.  Polishing filtration is
discussed in a separate technology section.
     (4)  Waste characteristics affecting  performance.  In determining
whether chemical precipitation is likely  to achieve the same level of
performance on an  untested waste as on a  previously tested waste, we will
examine the following waste  characteristics:   (1)  the concentration and
type  of the metal(s)  in the  waste, (2) the concentration of suspended
solids  (TSS),  (3)  the concentration of dissolved  solids  (IDS),
(4)  whether the  metal exists in  the wastewater  as  a complex, and  (5) the
oil  and grease content.   These parameters may  affect  the chemical
reaction  of the  metal compound,  the solubility  of the metal precipitate,
or the  ability of  the precipitated compound to  settle.
                                      lib

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      SLUDGE
                                                 INFLUENT
   CENTER FEED CLARIFIER WITH SCRAPER SLUDGE REMOVAL SUSTEM
INFLUENT
                                                            SLUDGE
               RIM FEED - CENTER TAKEOFF CLARIFIER WITH
            HYDRAULIC  SUCTION  SLUDGE REMOVAL SYSTEM
                                                              INFLUENT
                                             SLUDGE
                 RIM FEED - RIM TAKEOFF CLARIFIER
                             FIGURE  3-8
                      CIRCULAR  CLARsFIERS

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INFLUENT
                                                EFFLUENT
                        FIGURE  3-9
                INCLINED PLATE SETTLER
                           120

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         (a)   Concentration and type of metals.   For most metals,  there
is a specific pH at which the metal  hydroxide is least soluble.   As a
result,  when  a waste contains a mixture of many  metals,  it is not
possible to operate a treatment system at a single pH that is optimal for
the removal of all  metals.   The extent to which  this situation affects
treatment depends on the particular metals to be removed and their
concentrations.  One approach is to operate multiple precipitations,  with
intermediate  settling,  when the optimum pH occurs at markedly different
levels for the metals present.  The individual  metals and their
concentrations can  be measured using EPA Method  6010.
         (b)   Concentration and type of total suspended  solids (TSS).
Certain suspended solid compounds are difficult  to settle because of
their particle size or shape.  Accordingly, EPA  will evaluate this
characteristic in assessing the transfer of treatment performance.  Total
suspended solids can be measured by EPA Wastewater Test  Method 160.2.
         (c)   Concentration of total dissolved  solids (TDS).  Available
information shows that total dissolved solids can inhibit settling.  The
literature states that poor flocculation is a consequence of high TDS and
shows that higher concentrations of total suspended solids are found in
treated residuals.   Poor flocculation can adversely affect the degree to
which precipitated  particles are removed.  Total dissolved solids can be
measured by EPA Wastewater Test Method 160.1.
         (d)   Complexed metals.  Metal complexes consist of a metal ion
surrounded by a group of other inorganic or organic ions or molecules
                                    121

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(often called ligands).   In the complexed form,  the metals have a greater
solubility and therefore may not be as effectively removed from solution
by chemical precipitation.   EPA does not have an analytical method to
determine the amount of complexed metals in the waste.  The Agency
believes that the best measure of complexed metals is to analyze for some
common complexing compounds (or complexing agents) generally found in
wastewater for which analytical methods are available.  These complexing
agents include ammonia,  cyanide, and EDTA.  The analytical method for
cyanide is EPA Method 9010.  The method for EDTA is ASTM Method D3113.
Ammonia can be analyzed using EPA Wastewater Test Method 350.
         (e)  Oil and grease content.  The oil and grease content of a
particular waste directly  inhibits the settling of the precipitate.
Suspended  oil droplets  float in water and tend to suspend particles such
as chemical precipitates that would otherwise settle out of the
solution.  Even with the use of coagulants or flocculants, the separation
of the precipitate  is less  effective.  Oil and grease content can be
measured by EPA Method  9071.
     (5)  Design and operating  parameters.  The parameters that EPA will
evaluate when determining  whether  a chemical  precipitation system  is well
designed are: (1) design value  for treated metal concentrations,  as well
as other characteristics of the waste used for design purposes (e.g.,
total  suspended  solids); (2) pH;  (3)  residence time;  (4)  choice  of
treatment  chemical;  (5)  choice  of  coagulant/flocculant;  and  (6)  mixing.
The  reasons why  EPA believes these parameters are  important  to a  design
                                     122

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analysis are cited below, along with an explanation of why other design



criteria are not included in this analysis.



         (a)  Treated and untreated design concentrations.  When



determining whether to sample a particular facility, EPA pays close



attention to the treated concentration the system is designed to



achieve.  Since the system will seldom outperform its design, EPA must



evaluate whether the design is consistent with best demonstrated practice.



    The untreated concentrations that the system is designed to treat are



important in evaluating any treatment system.  Operation of a chemical



precipitation treatment system with untreated waste concentrations in



excess of design values can easily result in poor performance.



         (b)  pH.  The pH is important because it can indicate whether



sufficient treatment chemical  (e.g., lime) has been added in order to



convert the metal constituents in the untreated waste to forms that will



precipitate.  The pH also affects the solubility of metal hydroxides and



sulfides and thus directly impacts the effectiveness of removal.  In



practice, the design pH  is determined by empirical bench testing, often



referred to as  "jar" testing.  The temperature at which the "jar" testing



is conducted is  important since it also affects the solubility of the



metal precipitates.  Operation of a treatment system at temperatures



above the design temperature can result in poor performance.  In



assessing the operation of a chemical precipitation system, EPA prefers



to use continuous data on the  pH and periodic temperature conditions



throughout the  treatment period.
                                    123

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         (c)   Residence time.   Residence time is important because it
impacts the completeness of the chemical reaction to form the metal
precipitate and,  to a greater extent,  the amount of precipitate that
settles out of solution.  In practice,  it is determined by "jar"
testing.  For continuous systems,  EPA will  monitor the feed rate to
ensure that the system is operated at design conditions.   For batch
systems, EPA will  want information on the design parameter used to
determine sufficient settling time (e.g., total  suspended solids).
         (d)   Choice of treatment chemical.  A choice must be made as to
what type of precipitating agent (i.e., treatment chemical) will be
used.  The factor that most affects this choice is the type of metal
constituents to be treated.  Other design parameters, such as pH,
residence time, and choice of coagulant/flocculant agents, are based on
the selection of the treatment chemical.
         (e)  Choice of coagulant/flocculant.  This parameter is
important because these compounds improve the settling rate of the
precipitated metals and allow smaller systems (i.e., lower retention
time)  to achieve the same degree of settling as much larger systems.   In
practice, the choice of the best agent  and  the required amount  is
determined by "jar" testing.
         (f)  Mixing.   The degree of mixing  is a complex  assessment  that
includes the energy supplied, the time  the  material  is mixed, and the
related turbulence effects of the specific  size  and  shape  of the  tank.
In  its  analysis, EPA will consider whether  mixing  is provided and whether
                                     124

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the type of mixing device used is one that could be expected to achieve



uniform mixing.  For example, EPA may not use data from a chemical



precipitation treatment system in which an air hose was placed in a large



tank to achieve mixing.



3.2.7    Polishing Filtration



   Filtration is the removal of solids from wastes by a medium that



permits the flow of the fluid but retains the particles.  When filtration



is conducted on wastewaters with low concentrations of solid particles



(generally below 1,000 ppm), the term "polishing" filtration is applied;



when conducted on wastes with higher concentrations of solids, the term



"sludge" filtration is applied.  This section discusses "polishing"



filtration; sludge filtration is discussed separately.



   (1)   Applicability and use of polishing filtration.  Polishing



filtration is used to treat wastewaters containing relatively low



concentrations of solids.  Multimedia filtration, pressure or gravity



sand filtration, and cartridge filtration are some of the types of



equipment used for polishing filtration.   This type of filtration is



typically used as a polishing step for the supernatant after



precipitation and settling (clarification) of wastewaters containing



metal precipitates.  In general, filtration is used to remove particles



that are difficult to settle because of shape and/or density or to assist



in removal of precipitated particles from an underdesigned settling



device.
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   (2)    Underlying principle of operation.   The basic principle of



filtration is the separation of particles from a mixture of fluids and



particles by a medium that permits the flow of the fluid but retains the



particles.  As would be expected, larger particles are easier to separate



from the fluid than are smaller particles.



   Extremely small particles in the colloidal range may not be filtered



effectively in a polishing filter and may appear in the treated



wastewater.  To mitigate this problem, the wastewater should be treated



prior to filtration in order to modify the particle size distribution in



favor of the larger particles, by the use of appropriate precipitants,



coagulants, flocculants, and filter aids.  The selection of the



appropriate precipitant or coagulant  is important because it affects the



particles  formed.  For example,  lime  neutralization usually produces



larger,  less gelatinous particles than does caustic soda precipitation.



For larger particles that become too  small to filter effectively because



of poor  resistance to  shearing,  shear resistance can be improved by the



use of coagulants  and  flocculants.  Also, if pumps are used to feed the



filter,  shear can  be minimized by designing  for a lower pump speed, or by



use of a  pump with an  impeller design that minimizes shearing.



   Filter  aids  such as diatomaceous earth are used to precoat  the



cloth-type filter  material  and provide an initial filter cake  onto which



additional  solids  will be deposited during the  filtration process.  The



presence of  the  precoat allows for removal of small particles  from the



solution being  filtered.  Smaller  particles  will mechanically  adhere  to



the precoat  solids during the  filtration  process.
                                     126

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   (3)    Description of polishing filtration system.  For relatively low



flows,  a cartridge filter can be used.   In this case a cylindrically



shaped  cartridge, such as a matted cloth,  is placed within a sealed metal



vessel.   Wastewater is pumped through the cartridge until the flow drops



excessively because the filter media are plugged.  The sealed vessel is



then opened and the plugged cartridge is removed and replaced with a new



cartridge.  The plugged cartridge is then disposed of.



   For  relatively large volume flows, granulated media (such as sand or



anthracite coal) are used to trap suspended solids within the pore spaces



of the  media.  Wastewater is filtered until excessive pressure is



required to maintain the flow or until  the flow drops to an unacceptable



level.   Granular media filters are cleaned by backwashing with filtered



water that has been stored for that purpose.  (Backwashing is always



upflow to loosen the media granules and resuspend the entrapped solids.)



The backwash water, which may be as much as 10 percent of the volume of



the filtered wastewater, is then returned to the treatment system, so



that the solids  in the backwash water can be settled  in the system



clari fi er.



   (4)    Waste characteristics affecting performance.  To determine



whether filtration would achieve a level of performance on an untested



waste similar to that on a tested waste, EPA will examine the following



waste characteristics:   (1) size of suspended particles and (2) type of



particles.
                                    127

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         (a)  Size of particles.  Extremely small particles in the
colloidal range may not be filtered effectively in a polishing filter and
may appear in the filtrate.  Accordingly, EPA would examine the particle
size in assessing transfer of performance.  Particle size can be
determined using ASTM Method D422, Particle Size Distribution.
         (b)  Particle type.  Some suspended solids are gelatinous in
nature and are difficult to filter.  When assessing transfer of
performance, therefore, EPA will assess the type of suspended solids
particles present.  EPA is not aware of any specific quantitative method
to measure the particle type; accordingly, such an assessment will be
based on a qualitative engineering analysis of the suspended solids
particles.
   (5)   Design and operating parameters.  The design and operating
parameters that EPA will evaluate  in assessing the performance of
polishing filtration are:   (1) treated and untreated design
concentrations, (2) type of filter,  (3) pore size, (4) waste feed
pressure, and  (5)  use  and  type of  filter  aids.   Each of these parameters
is discussed below.
          (a)   Treated  and  untreated  design concentrations.  As with  other
technologies,  it  is  important to  know  the  level  of performance that  the
particular  unit was designed  to achieve  in order  to ensure  that  the
design  value represents best  demonstrated  practice.  Additionally,  EPA
would  want  to  evaluate feed characteristics  to the filter  during
treatment to ensure  that  the  unit  was  operated within design
                                     128

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specifications.  Operation of the filter in -excess of feed conditions



could easily lead to poor performance.



         (b)  Type of filter.  There are several different types of



polishing filters, including granular media, cartridge filters, and



pressure filters such as plate and frame.  Factors that affect filter



selection include the concentration of suspended solids, particle type



and size, process conditions (including flow rate and pressure), and



whether the treatment system is operated on a batch or a continuous



process.  While more than one type of filter will generally work, it is



important to know which filter is used, as well as the basis for



selecting that filter.



         (c)  Pore size.  The pore size determines the particle size that



will be effectively removed; accordingly, it is an important factor in



assessing filtration effectiveness on a particular waste.  EPA will need



to know the pore size used as well as the basis for its selection.



         (d)  Pressure drop  across the filter.  An important filter



design specification is the  pressure drop across the filter.  A pressure



drop that is higher than the filter design can  force solid particles



through the filter and thus  reduce the filter's effectiveness.  During



treatment,  EPA will periodically examine pressure readings in order to



ensure that the filter is being operated within design specifications.



         (e)  Use and type of filter aids.  As  previously discussed,



filter aids improve the effectiveness of filtering gelatinous particles



and increase the time that the filter can stay  on line.  In assessing
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filtration performance, it is important to know both the type of filter



aid used and the basis for selection.



3.2.8    Sludge Filtration



   (1)   Applicability and use of sludge filtration.  Sludge filtration,



also known as sludge dewatering or cake formation filtration, is a



technology used on wastes that contain high concentrations of suspended



solids generally higher than 1 percent.  The remainder of the waste is



essentially water.  Sludge filtration is applied to sludges, typically



those that have settled to the bottom of clarifiers, for dewatering.



After filtration, these sludges can be dewatered to 20 to 50 percent



sol ids.



   (2)   Underlying principle of operation.  The basic principle of



filtration is the separation of particles from a mixture of  fluids and



particles by a medium  that permits the flow of the  fluid but retains the



particles.  As would be expected, larger particles  are easier to separate



from  the  fluid than are smaller particles.  Extremely small  particles in



the colloidal range may not  be filtered effectively and may  appear  in the



treated waste.  To mitigate  this problem, the wastewater should be



treated prior to  filtration  to modify  the particle  size distribution in



favor of  the larger particles, by the  use of appropriate precipitants,



coagulants,  flocculants,  and filter  aids.  The selection of  the



appropriate  precipitant or coagulant  is  important  because  it affects the



particles  formed.   For example, lime  neutralization usually  produces



larger, less gelatinous particles than does caustic soda precipitation.
                                     130

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For larger particles that become too small  to filter effectively because
of poor resistance to shearing, shear resistance can be improved by the
use of coagulants and flocculants.  Also, if pumps are used to feed the
filter, shear can be minimized by designing for a lower pump speed or by
use of a low shear type of pump.
   (3)   Description of the sludge filtration process.  For sludge
filtration, settled sludge is either pumped through a cloth-type filter
medium (such as  in a plate and frame filter that allows solid "cake" to
build up on the  medium) or the sludge is drawn by vacuum through the
cloth medium (such as on a drum or vacuum filter, which also allows the
solids to  build).  In both cases  the solids themselves act as a filter
for subsequent solids removal.  For a plate and frame type filter,
removal of the solids is accomplished by taking the unit off line,
opening the filter, and  scraping  the solids off.  For the vacuum type
filter, the cake is removed continuously.   For a specific sludge,  the
plate  and  frame  type filter will  usually produce a drier cake than will  a
vacuum filter.   Other types of  sludge filters, such as belt filters, are
also  used  for  effective  sludge  dewatering.
    (4)    Waste characteristics  affecting performance.  The  following
characteristics  of  the waste  will  affect the  performance of a sludge
filtration unit: (1) size  of  particles  and  (2) type of particles.
          (a)   Size  of particles.   The smaller the particle  size,  the more
the  particles  tend  to go through  the filter media.  This  is especially
true  for  a vacuum filter.   For a  pressure  filter  (like a plate  and
                                     131

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frame),  smaller particles may require higher pressures for equivalent



throughput, since the smaller pore spaces between particles create



resistance to flow.



         (b)  Type of particles.  Some solids formed during metal



precipitation are gelatinous in nature and cannot be dewatered well by



cake formation filtration.  In fact, for vacuum filtration a cake may not



form at all.  In most cases, solids can be made less gelatinous by use of



the appropriate coagulants and coagulant dosage prior to clarification,



or after clarification but prior to filtration.  In addition, the use of



lime instead of caustic soda in metal precipitation will reduce the



formation of gelatinous solids.  Also, the addition of filter aids to a



gelatinous  sludge, such as lime or diatomaceous earth, will help



significantly.  Finally,  precoating the filter with diatomaceous earth



prior to sludge filtration will assist in dewatering gelatinous sludges.



    (5)   Design and operating parameters.  For sludge filtration, the



following design  and operating  variables affect performance:  (1) type of



filter  selected,  (2) size of filter selected,  (3) feed pressure, and



(4) use of  coagulants or  filter aids.



          (a)  Type of filter.   Typically, pressure type filters  (such  as



a  plate and frame) will yield  a drier cake than will  a vacuum type



filter; they will  also  be more  tolerant of variations in  influent  sludge



characteristics.   Pressure  type filters, however, are batch  operations,



so that when the  cake  is  built  up  to  the maximum depth physically



possible  (constrained by  filter geometry), or  to the  maximum design
                                     132

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pressure, the filter is turned off while the cake is removed.  A vacuum
filter is a continuous device (i.e., cake discharges continuously), but
will usually be much larger than a pressure filter with the same
capacity.  A hybrid device is a belt filter, which mechanically squeezes
sludge between two continuous fabric belts.
         (b)  Size of filter.  As with in-depth filters, the larger the
filter, the greater its hydraulic capacity and the longer the filter runs
between cake discharge.
         (c)  Feed pressure.  This parameter impacts both the design pore
size of the filter and the design flow rate.  In treating waste it is
important that the design feed pressure not be exceeded; otherwise,
particles may be forced through the filter medium, resulting in
ineffective treatment.
         (d)  Use of coagulants.  Coagulants and filter aids may be mixed
with filter feed prior to filtration.  Their effect is particularly
significant for vacuum filtration since in this instance they may make
the difference between no cake and a relatively dry cake.   In a pressure
filter, coagulants and filter aids will also significantly  improve
hydraulic capacity and cake dryness.  Filter aids, such as  diatomaceous
earth, can  be precoated on filters  (vacuum or pressure) for sludges that
are particularly difficult to filter.  The precoat layer acts somewhat
like an  in-depth filter,  in that sludge solids are trapped  in the precoat
pore spaces.  Use of precoats and most coagulants or filter aids
significantly increases the amount of sludge solids to be disposed of.
                                    133

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However, polyelectrolyte coagulant usage usually does not increase sludge



volume significantly because the dosage is low.



3.3      Performance Data Base



3.3.1    Organics Treatment Data



    The Agency does not have performance data for treatment of the



organics present in K086 solvent wash using batch distillation,



fractional distillation, or fuel substitution.  To help develop organic



treatment standards, EPA tested incineration to demonstrate the actual



performance achievable by this technology for treatment of K086 solvent



wash.  Since EPA is not aware of any generator or TSD facilities



currently using incineration for treatment of wastes containing high



percentages of K086 solvent wash, the K086 solvent wash was collected



from a generator and incinerated at EPA's test facility.  The rationale



for selecting the generator chosen for waste collection is presented  in a



memorandum dated March 21, 1988, located in the Administrative Record for



K086 solvent wash.



    EPA has six untreated and treated data sets for K086 solvent wash



using  incineration.  These data are shown in Table 3-1.  Although a



rotary  kiln incinerator was used to treat the K086 solvent wash, the  data



effectively represent  liquid injection because the waste was fed through



the liquid injection nozzle on  the rotary kiln unit.  Each of the six



data sets provides  performance  for the nine BOAT list organics detected



in the  untreated K086  solvent wash; therefore, the total number of



treated data points is  54.  The treated data  represent  total waste
                                     134

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                                                                  Table 3-1  Incineration
                                                                     EPA Collected Data
                                                                      K066  Solvent  Wash
A"jl,t iral Dote,
BDAT Oraanic Constituent Concent
Sample Set »1 Sample °,
k086
solvent
wash
BOAT List Constituents (mg/kg)
Vo1?! ' le Orga^ >rs
Acetcr.e CBI
Ethylbenzene CBI
Methyl isobutyi ketone CBI
Me thy 'ene chlo- u:e CBI
lolue-e CBI
Xylene (total) CBI
^PTIIVC Vt i le Or games
i is(2-ethylhe/, Ijphthalate CBI
f vc Ic'iexanone CBI
t^phtidlene CBI
kObt
Scrubber solvent
water wash
(mg/1) (mg/kq)

<0 005 CBI
<0 005 CBI
<0 010 CBI
<0 010 Cbl
<0 010 CBI
<0 005 CBI

-0 010 CBI
•0 OCci CB1
-0 010 Cfl
ft «2 Sample Set #3 Sample
KOB6
Scrubber solvent
water wash
(mg/1) (mg/kg)

<0 005 CBI
•-0 005 CBI
•-0 010 CBI

-------
concentration found in the scrubber water.  EPA's analyses of these data



for the development of organic treatment standards for K086 solvent wash



can be found in Sections 4 and 6.



3.3.2    Metals Treatment Data



    (1)  Wastewater.  The Agency does not have performance data on



treatment of the BOAT metals in the scrubber water generated specifically



from the incineration of K086 solvent wash.  However, EPA does have data



from EPA's testing of Envirite Corporation that the Agency believes



represent a level of treatment performance that can be achieved for the



K086 solvent wash scrubber water by using chromium reduction, followed by



lime precipitation and vacuum sludge filtration.



    EPA believes that the Envirite treatment process could be used to



treat K086 scrubber water because the treatment system consists of



chromium reduction followed by lime precipitation and vacuum sludge



filtration.



    The data collected for the Envirite treatment system consist of 11



untreated and treated sample sets.  The untreated waste  is a



metal-containing wastewater that is a mixture of F006, D002, D003, and



K062 wastewaters.  The two treated streams are the filtrate and the



filter cake generated from vacuum dewatering.  The performance data for



the  Envirite wastewater  treatment system  are shown in Table 3-2.



     EPA reviewed the characterization data for K086  scrubber water, also



presented  in Table  3-2,  as well  as data on parameters that would affect



the  performance  of  the Envirite  treatment  system  (i.e.,  sulfide
                                     136

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concentration, oil and grease content, total solids content, complex



metal concentration, and type and concentration of metals).  The only



data available for evaluation were type and concentration of metals and



oil and grease content (using total organic carbon as an indicator).



    The concentrations of untreated metals in the Envirite wastewater are



greater than the metal concentrations in the K086 solvent wash scrubber



water.  Specifically, the principal metals in the K086 scrubber water are



present at concentrations less than 0.193 mg/1 for chromium and 1.52 mg/1



for lead.  In the Envirite metal-containing wastewater, the



concentrations for chromium range from 395 to 2,581 mg/1 and the



concentrations for lead range from 10 to 212 mg/1.  Both the Envirite



wastewater and the K086 scrubber water have low oil and grease contents



(i.e., less than 0.3 percent total organic carbon).  In conclusion, these



data show that the K086 scrubber water could be treated to the same



levels as the Envirite metal-containing wastewaters.



     (2)  Nonwastewater.  The Agency does not have performance data on



treatment of the BOAT metals in the precipitate from treatment of K086



scrubber water.  However, EPA does have data from EPA's testing of



Envirite Corporation that the Agency  believes represent a level of



treatment performance that can be achieved for the K086 precipitate by



using  lime stabilization followed by  sludge filtration.



    The Envirite treatment process incorporates the lime precipitation



process with lime stabilization before sludge dewatering to reduce the



Teachability of the metals in the precipitate.
                                     137

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    Since the Agency has established that the Envirite wastewaters are



similar to K086 scrubber waters,  it is reasonable to expect that the



Envirite filtered precipitate (i.e., filter cake) is similar to the K086



filtered precipitate.
                                     138

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IcbSg
                            Idble 3-2   Chromium Reduction  Chemical  Precipitation,
                                        Followed by Vacuum Filtration
                                       EPA Collected Data  from Envirite



Const i tuent
•30AT Met.i's
Ant imony
Arsen ic
Barium
Beryl 1 ium
Cadmium
Chromium (nexavalent)
Chrom ium (total)
Copper
_ecid
Me re i. ry
N icr. carl, or.
Tota 1 en iOr icies
totd ' org-.n ic n3 1 ides
::•".••:
->

ph
P(_M|,.L irg itjent
Rut'C ct reducing agent
Lre'rr:. a1 r'rec ip i tat ion
pH
Prec ipit.it ing agents
Fi ltr,t '0''
fype (jl t :ter
Sample Set »1
KOSF solvent wash Untreated Envirite Filter cake
scrubber water wastewater Filtrate Total TCLP
(nig/1) (mg/1) (mg/1) (ing/kg) (mg/1)

0 Oo3-0 107 -.10 <1 <10
0 059-0 093 -1 <0 1 <1 <0 010
0 226-0 287 -.10 <1 25 0 23
<0 001 <2 
-------
Ioo3g
                                            Table 3-2  (continued)



Const i tuent
bDA! Metals
Ant imony
Arser. ic
Bar ium
ber> 1 1 ium
Cadmium
Cnromium ( r.exava lent )
Chromium (total)
Lopper
Lend
Mercury
"iickel
;e len i urn
c, i tver
Tna 1 1 ium
Zinc
0-r.(,r p ,,, .,,,ter-,
"otil orgaric c.jrbc.i
Tota 1 SOl 1'JS
rot j 1 chloi ides
Tct 1 1 orcjnri ic na 1 idps
C/dn ide
_ u "i f Kie
-
-vr • '. '•" t L"i ";•• ."
Re ' u c ui'j n.jert
Ratio of reducing agent
' rr IDK... 1 ?• ci i [y 1 1.: t ion
pH
Precipi tat ing agents
f , 1 1 r.it ion
T/pe of f i Her
I Cu leu i n t ur t er encti
- ,'iOt r ' 1 /ZC'.'I

KOB6 solvent wash
scrubber water
(ing/ U

0 Ob3-0 107
0 059 0 0~<3
0 ^'C-0 267
•0 001
'0 004
<0 010-0 014
0 099-0 193
0 il-j-0. 1 jO
0 d27-l 52
=0 0002
= 0 Oil
• 0 00 j
•;0 006-0 007
0 022-0 027
0 laO-0 216

1 97-S 36
y:oC-4iuO
1 2-101
0 Olc-0 072
'-0 OlO
-0 5



to he/ovalent chromium







Sample Set »2
Untreated Envinte Filter cake
wdstewdter Filtrdte Total TCLP
(mg/1) (mg/1) (mg/kg) (mg/1)

=10 <1 '10
-1 ^01 1 -0 010
10 
-------
lB83g
                                           Table  3-2   (continued)



Const i tuent
BOAT Met i !-,
Ant nnony
Arsenic
Barium
Bery 1 1 ium
Cadmium
Chromium (nexavalent)
Chromium (total)
Copper
Lead
Mercury
'( icke 1
-,e ' en i L..II
:. i Iver
Tha 1 1 ium
Zinc
0; npr P ir ,i';oter~
Total organic carbon
Tota 1 sol ids
I old i en I'ji ides
'ota'i organic ha 1 ules
C ,-an ine
^ LJ i i de
DC' :- 'T, ] " r-r:,' - -; !\v
,
Reaucirig 3gent
Ratio of reducing agent
Cnpmir.il Proripu.iMon
ph
Precipitating agents
F i ltr.it ion
Type of f i Iter

K0»6 solvent wash
scrubber water
(mg/1)

0 0&3-0 107
0 059-0 093
0 226-0 2b7
•0 001

-------
lB83g
                                                3-2  (conl inued)



Const i tuent
BOAT Metals
Ant imony
Arsen ic
Bdl 1UI11
Beryl 1 mm
Cadmium
Chromium (hexavalent)
Chromium (total)
Cooper
Lead
Mercury
N icke 1
5e ien lum
S i Ker
T ha 1 1 lum
Z IMC
Qtner P;. r-j^eters
Total organic carbon
fctd 1 ^0 i 'ClS
Total chlorides
~otai organic haliaes
I/on ide
.jit ,ile
_.f . IT" -" 1 jC=r~ t "'I ' • '
'•
KeJjC'rg aCi&Pt
"it 10 of reducing dyerit
CreiiTical Precipitation
pH
Prec ip i tdt ing agents
f i It rat 'on
Type of f i Iter

K066 solvent wash
scrubber water
(mq/1)

0 OB3-0 107
0 OC9-0 093
0 ^26-0 2b7
<0 001
<0 004
--0 010-0 014
0 093-0 193
0 11S-0 130
0 627-1 52
-0 OOOd
*0.011
<0 005
<0 006-0 007
0. 022-0. Q27
0 1BO-0 216

i ii -a 3C
;-,oO-41t,Q
: 2-101
j 015-C 072
--0 010
• 0 5


to hexaVdleit chromium





Sample Set »4
Untreated Envirite Filter
wastewater Filtrate Total
(mq/1) (mq/1) (mg/kq)

•'10 - =10
-' 1 < 1 2
-10 -10 
-------
                                Table 3-2  (continued)



Const i tuent
FDAT Met ill
Ant imon>
r\i sen ic
Bar lum
Ber-y 1 1 mm
Cadmium
Chromium (hexavalent)
Chromium ( tot j 1 )
Copper
Lead
Mercury
:, iCKel
~,e- i en i .nil
•^ i Iver
T ha 1 1 lum
L me
Otr.er Parameters
Total organic Caroon
Tola ! so 1 ids
Total cnlcrices
Tota 1 organ ic na 1 ides
Cyanide
••"''•'"

' < . \, • • ' Crr -,,-1 ' /:•
r^educ , ng jger.t
•^-ilio of r eduL i ny ayeril
L neTi •-_-;' P rec i P i T 1 1 ion
fl
Pi eL ip ' td t mg dgents
F i it r it ion
Type of f i Iter

KOH6 solvent wash
scrubher water
(mg/1)

0 Os3 0 107
0 059-0 09j
0 226-0 2b7
-0 001
<0 004
-0.010-0 014
0 099-0 193
0 115-0 130
0 d27-l 52
<0 0002
• 0 Oil
^0 005
ron
n ,2-10

d-10
1 line

vacuum f i Iter
interference
   ^tPA  TiHoa
                                              L43

-------
1883g
                                           Table 3-2   (continued)



Const ituent
BOAT Men Is
Ant imony
Arsen ic
Barium
Ber_v 1 1 mm
Cadmium
Chromium (hexavd lent )
Chromium ( tota 1 )
Copper
Lead
Mercury
Nickel
Se len i uiVi
S i Iver
Tha 1 1 lum
1 me
Otier Parameters
fold 1 organic Carbon
Tot d 1 '^o 1 ids
Total en 'or ides
Total orqanic ha"; ides
Cyan ide
Suit me
Ofc . ' J' v J Ouc • - ' \ 'iu r -. :
_,...,,,, fp!S,..,
Stl
•'educ. fig =yent
H.itio of reducing .iyent
Chemical Precipitation
pH
Preu ip i td t my dyents
F i Itrat ion
lype of f i Her

K086 solvent wash
scrubber water
(mg/1)

0 Obj-0 107
0 Ob'd-0 093
0 226-0 287
<0 001
< 0.004

-------
Iaa3g
                                           Table 3-2  (continued)



Const i tuent
BOAT Metals
Ant imony
Arsen ic
Bar ium
beryl 1 ium
Cadmium
Chromium (hexava l(?nt )
Chromium (total)
Copper
Lead
Mercury
Nickel
Se ien ium
S i Iver
Tha 1 1 ium
Zinc
Other Parameters
Tot j 1 org,in ic carhon
Tcta 1 so i icis
Total cnlorides
Iota 1 organic hd 1 ides
Cydn ide
-3ulf ide
1 - - "
, _ _^
^
ReuuL my ,iyent
Ritio of Deducing agent
LhemiLdl Pr ec ip i tdt ion
pH
Precipitat ing agents
F i Itrat ion
Type of f i Her

K036 solvent wash
scrubber water
(ing/ I)

0 OH3-0 107
0 059-0 093
0 226-0 2a7
<0.001
<0 004
<0 OlO-O 014
0 099-0 193
0 115-0 130
0 «27-l 52
••0 0002
 2-1 0

8-10
1 ime

vacuum f i Her
i  - Color  interference
Reference   UiEPA 19b6a
                                                         i4b

-------
iaa3g
                                            Table 3-2   (continued)



Coribt i tuent
BOA I Metals
Ant imony
Arsen ic
Barium
Bery 1 1 lum
Cadmium
Chromium (hexavalent)
Chromium (total)
Cooper
Lea.:
Mercury
II icke 1
ie len ium
Silver
Tha 1 1 ium
Zinc
Other P-inmeters
Tcti' orjinic carbon
Total so lias
Tota 1 ch lorides
Tot -, } or y-in ic hd 1 ides
Cy..n ine
iu'f icie
- __, , '. ^ , ' , 1 . r. ,, P •

(
' r^
Ratio cf reducing agent
( iM'iu ii.,, i Pr cc i u . ' it ion
pH
Prec ipi tat ing agents
P i 1 1 r at ion
Type of f i Iter

K086 solvent wash
scrubber water
(mg/ I )

0 OH3-0 107
0 050-0 013
0 226-0 2e7
<0.001
«0 004
<0 010-0 014
0 099-0 193
0 115-0.130
0 627-1 52
-.0 0002
<0 Oil
^0.005
<0 006-0 007
0 022-0 027
0 180-0.216

1 :<7-
-------
l«83g
                                           Table 3-2  (continued)



Const itucnt
BOAT Met ,1-,
Ant imony
Arsenic
Barium
Bery 1 1 lum
Cadmium
Chromium (hexavalent)
Chromium (total)
Cooper
Leju
Mercury-
Nickel
Selenium
S i 1 ver
Tha 1 1 lum
Zinc
Other Parameters
Tcta 1 orqanic carbon
Tota 1 sol ids
7c, t j 1 cr: lor ides
Tcta 1 organ ic ha 1 ides
L ,-iniae
^u if icie
3-:-; 'an r,.; Zr*' it irn P -,
"• • ' , , ,C' 1 L!" „!!"..•!
pn
Peciucinn aqent
Katio of reducing agent
f"einirni Precipitation
pri
Prec ip i tat ing agents
F i 1 1 rvit ion
Type of f i Iter

KOU6 solvent wash
scrubber water
(mg/1)

0 083-0 107
0 059-0.093
0 226-0 287
<0 001
<0 004
<0 010-0 014
0 099-0.193
0 115-0 130
0 o27-l 52
<0 0002
--o on
• 0 005
<0 006-0 007
0 022-0 027
0 180-0 216

1 97-8 36
35oO-41CO
1 2-101
0 015-0 072
<0 010
•0 5
r.,,:^



to hexavalent chromium





Sample Set »9
Untreated Envinte Filter cake
wastewater Filtrate Total TCLP
(mg/1) (mg/D (mg/kg) (mg/1)

'-10 <1 <10
<1 <0 1 3 0 Oil
--10 <1 <10 0 20
•2 <0 2 -2
'5 <0 5 6 <0 020
0 07 0 041 I
939 0 10 3400 <0 050
225 0 03 775
•-10 <0.01 85 ^0 10
<1 <0 1 <1 <0 0002
940 0 33 3500
• 1 0 - 1 -10 • 0 j 1 0
--2 --0 2 <2 
-------
18«3g
                                            Table  j-Z   (continued)



Const i tuent
H)AT Met 1 Is
Ant unony
Arsen ic
Barium
Beryl I ium
Cadmium
Chromium (hexavalent)
Chromium (tota I )
Copper
Lead
Mercury
NiCKel
3e leri i uin
5 i Iver
Tha I I ium
line
Other Parameters
Total organic carbon
Tota I so I ids
'ota I Lh ior idfc^
Totul organic nalides
C/aniae
^u 'f ide
^ ^ r _ , , , ^ r n -

pH
Reducing agent
Ratio of reducing agent
Chemical Prrr i n i tat ion
pH
Precipitating agents
F i It rat ion
T/pe of f i Iter

K0a6 solvent wash
scrubber water
(mg/l)

0 083-0 107
0 059-0 093
0 226-0 28/
-Q 001
<0 004
<0 010-0 014
0 099-0 193
0 115-0 130
0 627-1 52
<0 0002

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



Const i tuent
PDAT Met.^s
Ant imony
Arsen ic
Bar ium
Beryl 1 ium
Cadmium
Chromium (hexavalent)
Chromium (total)
Cooper
Lt^U
Mercurv
N i c < e 1
* 6 SI 1 ulTl
i i vei
Thd i 1 ium
Z;nc
Other fit ameters
"ot 1 I or ._: in ic carbon
Tot 3 "' cr 'or :06S
fold1. jrgdfilC hdlldtt,
C/rin ine
- jlf irie

i- - ' '!',,('* ' '!'; r 1 '

CM
SL-LIUL , ng -igent
R.itio -f reducing agent
Lnem ' Cd ^rec imitation
Precipitating agents
(• i It i at ion
Type of f i Her

K0b6 solvent wash
scrubber water
(rug/ I)

0 03J-0 107
0 059-0 093
0 226-0 2H7
<0 001
-0 004
<0 010-0.014
0 099-0 193
0 115-0 130
0 o27-1.62
'-0 0002
<0 Oil

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           4.  IDENTIFICATION OF THE BEST DEMONSTRATED AVAILABLE
                     TECHNOLOGY  FOR K086 SOLVENT WASH

    This section presents the rationale for the determination of best
demonstrated available technology (BOAT) for K086 organics and metals
treatment.  As discussed in Section 1  and summarized here, the Agency
examines all the available data for the demonstrated technologies to
determine whether one of the technologies performs  significantly better
than another.  Next, the "best" performing treatment technology is
evaluated to determine whether the resulting treatment is substantial.
If the "best" technology provides substantial treatment and it has been
determined that the technology is also available to the affected
industry, then the technology represents BOAT.
4.1      BOAT for Treatment of Orqanics
    The only demonstrated technology for treatment  of K086 solvent wash
that the Agency has data for is liquid injection incinerator where the
liquid was  injected in the nozzle on the rotary kiln unit.  Nevertheless,
the Agency believes that the other demonstrated treatment technologies,
including liquid injection on other incinerators, would not improve the
level of performance for K086; therefore EPA believes that incineration
is "best."   EPA's rationale  is provided below.
    Although the Agency encourages recycling to minimize  the amount of
waste that  needs to be land disposed,  batch  and fractional distillation
could not improve the level of performance because the distillation
                                     150

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process leaves behind still bottoms that need additional treatment for
organics.  EPA believes that well-designed and well-operated fuel
substitution systems would not achieve better results because such
systems operate at approximately the same temperature with similar
residence times and turbulence patterns as incineration systems.
    Consistent with EPA's methodology for determining BOAT, the Agency
evaluated the incineration performance data to determine whether
incineration provides substantial treatment for K086 solvent wash.  As a
first step, EPA examined the data to determine whether any data
represented treatment by a poorly designed or poorly operated system.
EPA did not find any such data and, therefore, used all the data in its
determination of substantial treatment.
    Next, EPA adjusted the data values based on the analytical  recovery
values in order to take into account analytical interferences associated
with the chemical makeup of the treated sample.  In developing  recovery
data (also referred to as accuracy data), EPA first analyzed a  waste for
a constituent and then added a known amount of the same constituent
(i.e., spike) to the waste material.  The total amount recovered after
spiking minus the initial concentration in the sample divided by the
amount added is the recovery value.  Percent recovery values for BOAT
list metals used in adjustment of the performance data are presented in
Appendix B.  The analytical data were adjusted for accuracy using the
lowest recovery value for each constituent.
                                    151

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    EPA's determination of substantial  is based on the reduction of BOAT
list organic constituents from levels as high as (CBI) ppm to
nondetectable levels (i.e., 0.10 ppm) in the scrubber water residual.
The Agency believes that the reduction of hazardous organic constituents
is substantial and that incineration is available to treat organics
present in K086 solvent wash wastes because it is commercially
available.  Therefore,  incineration represents BOAT for the organics
present in K086 solvent wash.
4.2      BOAT for Treatment of Metals
    Treatment of the organics present in K086 solvent wash using
incineration generates a scrubber water (i.e., wastewater residual) that
may need treatment for metals.  Treatment of the scrubber water may
generate a precipitate (i.e., nonwastewater residual) that also needs
treatment for metals.
4.2.1    Wastewater
    The only demonstrated  technology identified for treatment of metals
in K086 scrubber water that  the Agency has data for chromium reduction
followed by lime precipitation and sludge filtration.  The Agency has no
reason to expect that the  other chemical precipitation processes could
improve the level of performance;  therefore, chromium reduction followed
by lime precipitation and  sludge filtration is the "best" performing
technology.  As discussed  earlier, EPA does not have treatment data  for
K086  solvent wash wastewaters generated from  incineration; however,  EPA
does  have treatment data for metal-containing wastewaters (Envirite)
believed to be similar to  K086 solvent wash scrubber waters.
                                     152

-------
    Data collected by the Agency on treatment of the Envirite wastewater
by chromium reduction lime precipitation and vacuum sludge filtration are
shown in Table 3-2.  Operating data collected during treatment of this
waste show that these data represent the performance of a well-designed,
well-operated treatment system;  therefore, all data were used to
determine substantial treatment.
    EPA adjusted the data values based on the analytical recovery values
in order to take into account analytical interferences associated with
the chemical makeup of the treated sample.   In developing recovery data
(also referred to as accuracy data), EPA first analyzed a waste for a
constituent and then added a known amount of the same constituent (i.e.,
spike) to the waste material.  The total amount recovered after spiking
minus the initial concentration in the sample divided by the amount added
is the recovery value.  Percent recovery values for BOAT list metals used
in adjustment of the performance data are presented in Appendix B.  The
analytical data were adjusted for accuracy using the lowest recovery
value for each constituent.
    EPA's determination of substantial wastewater treatment for the
Envirite treatment system is based on the reductions of hexavalent
chromium from 917 mg/1 to 0.058 mg/1, chromium from 2,581 mg/1 to
0.12 mg/1, lead from 212 mg/1 to 0.01 mg/1, copper from 225 mg/1 to
0.08 mg/1, nickel from 16,330 mg/1 to 0.33 mg/1, and zinc from 171 mg/1
to 0.115 mg/1.
                                    153

-------
    The Agency believes that these reductions of hazardous constituents
are substantial and that chromium reduction followed by lime
precipitation and sludge filtration is available to treat K086 scrubber
waters because it is commercially available; therefore, chromium
reduction followed by lime precipitation and sludge filtration represents
BOAT for K086 scrubber waters.
4,2.2    Nonwastewaters
    For BOAT list metals in the K086 wastewater treatment precipitate,
the addition of excess lime (i.e., lime stabilization) during the
precipitation process followed by sludge filtration has been identified
as the only demonstrated technology for which the Agency has data.  The
Agency has no reason to believe that other stabilization processes could
improve the level of performance;  therefore, lime stabilization followed
by sludge filtration is the "best" performing technology for treatment of
the precipitate generated during treatment of the K086 scrubber water.
The Agency does not have treatment data for the precipitate specifically
generated during treatment of the K086 scrubber waters;  however, EPA
does have treatment data for a metal-containing precipitate (Envirite)
believed to be similar to the K086 wastewater treatment precipitate.
    Data collected by the Agency on treatment of the Envirite precipitate
by lime stabilization and sludge filtration are shown  in Table 3-2.
Operating data collected during treatment of this waste show that these
data represent the performance of a well-designed, well-operated
treatment system;  therefore, all these data were used to determine
substantial treatment.
                                     154

-------
    EPA adjusted the data values based on the analytical recovery values



in order to take into account analytical  interferences associated with



the chemical makeup of the treated sample.   In developing recovery data



(also referred to as accuracy data),  EPA first analyzed a waste for a



constituent and then added a known amount of the same constituent (i.e.,



spike) to the waste material.  The total  amount recovered after spiking



minus the initial concentration in the sample divided by the amount added



is the recovery value.  Percent recovery values for BOAT list metals used



in adjustment of the performance data are presented in Appendix B.  The



analytical data were adjusted for accuracy using the lowest recovery



value for each constituent.



    EPA does not have the TCLP leachate values of the untreated waste to



compare to the TCLP leachate values of the treated waste.  The Agency



believes that theoretical TCLP leachate values for the treated waste can



be calculated by dividing the total metal concentrations of the treated



waste by a dilution factor of 20.  This dilution factor accounts for the



amount of waste and extraction fluid used in the test.  A discussion of



the dilution factor can be found in "Best Demonstrated Available



Technology  (BOAT) Background Document for F001-F005 Spent Solvents."



    EPA compared the theoretical leachate value of 815 mg/1 to the actual



TCLP leachate value of 0.050 mg/1 for chromium and the theoretical



leachate value of 140 mg/1 to the actual leachate value of 0.10 mg/1 for



lead.  Based on these comparisons, the Agency believes that lime
                                    155

-------
stabilization followed by sludge filtration provides substantial
treatment.
    The Agency believes that these reductions of hazardous constituents
are substantial and that lime stabilization followed by sludge filtration
is available to treat K086 precipitated wastes because it is commercially
available; therefore, lime stabilization followed by sludge filtration
represents BOAT for K086 precipitated wastes.
                                     156

-------
                  5.  SELECTION OF REGULATED CONSTITUENTS



    This section presents the rationale for selection of the regulated



constituents, from the BOAT list of constituents, for the K086 solvent



wash treatability group.   In the previous section, incineration was



determined to achieve a level of performance that represents BOAT for



treatment of organics present in K086 solvent wash.   Chromium reduction



followed by chemical precipitation and filtration was determined to



achieve a level of performance that represents BOAT for treatment of



metals present in K086 scrubber waters, and lime stabilization followed



by sludge filtration was determined to achieve a level of performance



that represents BOAT for treatment of metals present in the precipitate



from treatment of the K086 scrubber water.  Therefore, performance data



from the determined BOAT for organics treatment and BOAT for metals



treatment will be used to help select the regulated constituents.



    When developing performance data for treatment technologies,  the



Agency analyzes untreated and treated wastes for the constituents



presented in Table 1-1.  The list is referred to by EPA as the BOAT list



of constituents and is an expanding 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 other than metals,



pesticides, PCBs, and dioxins and furans.
                                    157

-------
5.1      Identification of Constituents in the Untreated Waste
         and Waste Residuals
    The first step in selecting candidate constituents to be regulated is
to identify the BOAT list constituents present in the untreated K086
solvent wash wastes (i.e., the waste as generated,  the scrubber water).
The regulated constituent must demonstrate one of two criteria:
    1.   The constituent is detected in the untreated waste above its
         detection limit.  (A detection limit is defined as the practical
         quantification limit, PQL,  that is the method detection limit
         achievable when using an EPA-approved analytical method
         specified for a particular  analysis in SW-846, 3rd Edition.)
    2.   The constituent could not be detected in the untreated waste due
         to high detection limits caused by analytical interference, but
         is detected in any of the treatment residuals and is likely to
         be present in the untreated waste.
    Table 5-1 (at the end of this section) shows which of the 231 BOAT
list constituents were detected, not detected, and not analyzed in the
K086 solvent wash and scrubber water incineration residual.  Of the 231
BOAT constituents, the Agency analyzed for 193.  None of the 28 pesticide
constituents were analyzed because of the extreme unlikelihood of their
presence.  Another 10 volatile and semivolatile organic constituents were
analyzed for because at the time the analysis was performed, these
constituents were not on the BOAT pollutant list.  Of the
193 constituents analyzed 19 were detected in the K086 solvent wash.
These  19 constituents concentrations are given in Table 5-2 (at the end
of this section).
    For those constituents not detected (NO) in the untreated waste, but
detected in the  scrubber water  (i.e., arsenic, silver, vanadium), it was
assumed that such constituents may very well be present in the K086
                                    158

-------
solvent wash, but were undetected because of masking or interference by



other constituents in the K086 solvent wash.  These three constituent



concentrations are also given in Table 5-2.  Detection limits for the



analytical methods used to analyze K086 solvent wash have been classified



as confidential information by the generator.  The analytical detection



limits for the scrubber water are given in Appendix C.



5.2      Evaluation of the Process Generating the K086 Solvent Wash Wastes



    EPA has examined the K086 waste-generating process and believes that



solvents other than those found in the tested waste can be used to clean



ink formulating equipment or can be used in the formulation of inks



containing lead and chromium.  Furthermore, the Agency has data



indicating that the following 8 BOAT list organic solvents are used in



the ink formulation process and/or in cleaning ink formulating



equipment:  n-butyl alcohol, 1,2-dichlorobenzene, ethyl acetate,



methanol,  methyl ethyl ketone, nitrobenzene, 1,1,1-trichloroethane, and



trichloroethylene.  EPA is concerned that by not considering these other



solvents not found in the tested waste, the Agency would not only be



presenting an  incentive to switch to these solvents, but would also be



sending an erroneous signal that EPA is not concerned about land disposal



of these other constituents.



5.3      Determination of Significant Treatment from BOAT



    The next step  in selecting the constituents to be regulated is to



eliminate those identified constituents in the waste that were not



significantly  treated by the technologies designated as BOAT.
                                    159

-------
5.3.1    BOAT List Organic Constituents
    Table 5-2 presents the concentrations of constituents in the organics
treatment residual from incineration, i.e., scrubber water.   The data
demonstrate that all  the organic constituents detected in the K086
solvent wash are reduced signficantly, especially in the cases of
acetone, bis(2-ethylhexyl) phthalate, napthalene, cyclohexanone, and
xylene.  This indicates that incineration, the BOAT identified for
organics treatment, is effective in reducing organic constituents to
nondetectable levels in the scrubber water.  The performance data also
show incineration as treatment for the small quantities of cyanide and
sulfide present in the K086 solvent wash.
    As discussed  in Section 3.2.1, the Agency is using theoretical bond
energies as a surrogate for measuring combustiblity.  In general, the
higher the bond energy for a constituent, the more difficult it  is to
combust that constituent.  Out of all the BOAT list organics either
determined to be  present  in K086 solvent wash by examining the waste
generating-process or  actually detected  in K086  solvent wash by
analytical analyses, bis(2-ethylhexyl)phthalate, napthalene, xylene and
ethyl  benzene rank as  the most difficult  to treat based on their high
bond energies.  Since  these four constituents were  actually treated to
nondetectable concentrations  in the  K086  scrubber water, EPA believes
that the other  organic constituents  can  be  treated  to nondetectable
levels.   (Table 5-3,  at the end of this  section, shows the calculated
bond energies for the  candidate organic  constituents.)
                                     160

-------
5.3.2    BOAT List Metal Constituents
    The data show a scrubber water with no treatable levels of organics,
but treatable amounts of metals.  The detected metals in the K086 solvent
wash scrubber water include antimony, arsenic, barium,  chromium,  copper,
hexavalent chromium, lead, silver, vanadium, and zinc.   The Agency does
not have treatment data for K086 scrubber water;  however,  EPA has
treatment data using chromium reduction, followed by chemical
precipitation incorporated with lime stabilization and  sludge filtration,
of a waste similar (i.e., Envirite wastewaters).  Treatment of the metals
present in the Envirite wastewaters is demonstrated by  the significant
reduction of cadmium, hexavalent chromium, chromium, copper, lead,
nickel, and zinc in the filtrate and in the filter cake leachate.
However, the untreated Envirite wastewaters do not contain detectable
levels of antimony, arsenic, barium, silver, and vanadium.   Therefore,
even though these metals may be present in quantities below the detection
levels, one cannot determine whether these metals were  treated since the
amounts present cannot be measured.
5.4      Rationale for Selection of Regulated Constituents
    Table 5-4 (at the end of this section) presents all of the candidate
constituents that were detected in the untreated waste, used in the waste
generating process, and treated with the identified BOAT.  Note that all
25 could be regulated;  however, the Agency believes that regulation of
fewer constituents will have the same desired effect if the constituents
are selected carefully.
                                    161

-------
    EPA is regulating all the organic constituents detected in K086
solvent wash and all the BOAT list organic constituents that were not
detected but could be present in other solvent washes generated in
cleaning of ink formulating equipment.  Since K086 solvent washes can
vary depending on the type of solvent or solvents used to clean ink
formulating equipment, the Agency has chosen to regulate all the
candidate organics because regulation of a few may not control land
disposal of the others.  Acetone, n-butyl alcohol, ethyl acetate,
ethylbenzene, methanol, methyl isobutyl ketone, methyl ethyl ketone,
methylene chloride, toluene, 1,1,1-trichloroethane, trichloroethylene,
xylene, bis(2-ethylhexyl) phthalate, cyclohexanone, 1,2-dichlorobenzene,
napthalene, and nitrobenzene are the 17 BOAT list organic constituents
selected as the regulated organic constituents for wastewater and
nonwastewater forms of K086 solvent wash.  Cyanide and sulfide were not
chosen  as regulated constituents because they are present in small
quantities and EPA  believes that they will be controlled by regulation of
the other constituents.
    In  selecting metal constituents to regulate,  EPA  considered both  the
concentration of the  metal  in the incinerator residual  (i.e., scrubber
water)  and the concentration of  the metal in the  K086  solvent wash.   By
using  metal  concentrations  in the K086 solvent wash as  part of the  basis
for selecting metal constituents to regulate, EPA has  included some
metals  that  were not  in  the  scrubber water at treatable concentrations.
EPA's  rationale  for this selection  approach  is discussed below.
                                     162

-------
    An incinerator is not specifically designed to treat metals.
Accordingly, the concentration of metals found in the scrubber water and
in the ash will depend on the specific design and operating parameters
selected for volatilization and destruction of the organic constituents
in the waste.  For example, an incinerator that operates at a higher
temperature would be expected to have higher metal concentrations in the
scrubber water than an incinerator that operates at a lower temperature.
If EPA relied solely on the residual metal concentrations in one, or even
several, incinerator test(s) in making decisions on which constituents to
regulate, the Agency could easily decide not to regulate metal
constituents that would appear at significant concentrations in another
incinerator treating the same waste under different design and operating
parameters.  In addition to metal residual concentrations varying from
one incinerator to the next because of different operating temperatures,
residence times, and turbulence effects, residual metal  concentrations
will also vary because the K086 solvent wash can have different
concentrations of a particular metal constituent.  In particular, lead
and chromium concentrations can vary in K086 solvent wash relative to the
amounts added to a particular ink batch.
    For the above reasons, EPA is selecting constituents for lead and
chromium based on both the metal concentration in the K086 solvent wash
and scrubber water residual.  Facilities are reminded that if the
incinerator scrubber water residual as generated already complies with
the BOAT treatment standards, the residual does not need to be treated.
                                    163

-------
1599g
            Table  5-1    BOAT Constituents Detected or Not Detected in the
                        K086 Solvent Wash and Scrubber Water Samples
BOAT
reference
no

222
I
2
3
4
5
6
223
7
a
9
10
11
12
13
14
15
16
17
Ib
I'J
20
<- 1
22
L 3
24
25
26
27
28
29
224
225
226
Parameter
Volat i le Orqanics
Acetone
Aceton i tr t le
Acrolein
Acrylonitr i le
Benzene
Bromodichlorome thane
Bromomethane
n-Butyl alcohol
Carbon tetrachlor ide
Carbon disulfide
Chlorobenzene
2-Chloro-l ,3- butadiene
Ch lorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chtoropropene
1 , 2-Dibromo-3-chloropropane
1 . 2-Oibromoethdine
D; Dromometndne
Trin--, - ! ,4-3;c:h loro-r1 r/utenp
Dichlorod f iuoromern.ine
I . 1 -D'chloroethane
1 . 2-D-ch loroetrMne
1 , 1 -D icn lo roe thy lent
Trans-l,2-Dicnloroethent
1 , 2-Dichloropropane
Trans-l,3-Dichloropropene
cis-l,3-0ichloropropene
1 ,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
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
103-90-7
108-90-7
75-00-3
110-75-d
67-66-3
74-87-3
107-05-1
96-12-8
1C6-95-4
/4-.-5-J
i 10-57-h
75-71 o
7 •; - _. 5 - j
105 Ob-.-
/-. -,S-4
1-.6 60 -5
73-a7-5
10061-02-6
10061-01-5
123-91-1
110-HO-5
141-78-6
100-41-4
K086
solvent
wash
(mg/kg)

D
ND
NO
ND
ND
ND
NO
ML
NO
ND
NO
ND
NO
ND
NO
ND
NO
ND
ND
ND
ND
NO
ND
ND
ND
HO
ND
NO
NO
ND
ND
NL
HI
D
Scrubber
water
Ug/D

ND
NO
ND
NO
ND
NO
ND
NL
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
NL
NL
ND
                                            lb4

-------
1599g
                                 Table  5-1.   (Continued)
BOAT
reference
no

30
227
31
214
32
33
228
34
229
35
36
37
38
230
39
40
41
42
43
44
45
46
47
4«
49
23!

50
215
216
217

51
52
Parameter
Volatile Orqanics (continued)
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
loaoinethane
Isobutyl alcohol
Methano 1
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methyl methaneiu If ana te
Methy lacry Ion i tn le
Methylene chloride
2-N i tropropane
Pyr idine
1,1,1 , 2-Tetrachloroethane
1 , 1 ,2, 2-Tetrachloroethane
Tetrachloroethene
loluene
Tr ibromomethane
1 , 1 , 1-Trichloroethane
1 , 1 , 2-Tr ichloroethane
Tr ich loroethene
T r >Lh loromonot Vi'jrc.T'i t n me
1 ,2,3-TricnlorsproO'jne
1 , 1 , 2-Tr ich loro- 1.2,2-
t ; . t !^ci rju thane
Vinyl c n 1 o r : de
1 ,2-Xy lene
1 ,3-Xylene
1 ,4-Xylene
Semi volat i les
Acenaphtha lene
Acenaphthene
CAS no

10712-0
60-29-7
97-63-2
75-21-8
74-88-4
78-83-1
b/-56-l
7H-93-3
108-10-1
80-62-6
66-27-3
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
7--01-6
7 5 r, i - 4
": i a - -i

; • i i - 1
7 ' C ! 4
>i7 47 -c
lGd--S-3
106-44-5

208-96-8
83-32-9
K086
solvent
wash
(mg/kg)

NO
NL
NO
NL
ND
ND
NL
ND
D
ND
NO
ND
D
NL
NO
ND
ND
NO
D
ND
ND
ND
ND
ND
ND

NL
ND
D
D
D

ND
ND
Scrubber
water
Ug/D

ND
NL
ND
NL
NO
ND
NL
ND
ND
ND
ND
NO
ND
NL
ND
NO
NO
ND
ND
NO
NO
ND
NO
ND
ND

NL
NO
ND
NO
NO

ND
ND
                                          165

-------
1599g
                                 Table  5-1.   (Continued)
BOAT
reference
no.

53
54
55
56
57
58
59
218
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
76
79
oO
81
82
232
83
S4
85
86
87
Parameter
Semivolat i les (continued)
Acetophenone
2-Acetylaminof luorene
4-Aminobipheny 1
Am 1 me
Anthracene
Arami te
Benz(a)anthracene
Benzal chloride
Benzal chloride
Benzenethiol
8enzo(a)pyrene
Benzo(b)f luoranthene
Benzofghi )perylene
Benzo(k)f luoranthene
p-8enzoquinone
Bis (2-chloroethoxy) me thane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromopheny 1 phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dimtrophenol
p-Ch loroan i 1 me
Ch lorobenz i Kite
p-Ch ioro-m-c-esol
2-Cn loronapnthd iene
2-Ch loropheno 1
3-Chloroprop ion 1 1 r i le
Cnr>sene
ortho-Cresol
para-Creso 1
Cyc lohexanone
Oibenz(a ,h)anthracene
Dibenzo(a,e)pyrene
Oibenzofa, i Jpyrene
m-Oichlorobenzene
o-Dichlorobenzene
CAS no.

96-86-2
53-96-3
92-67-1
62-53-3
120-12-7
140-57-a
56-55-3
98-87-3
98-87-3
108-98-1;
50-32-8
205-99-?
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
«8-a5-7
106-47-b
510-15-6
r'-50-7
'jl-5o-7
95-57-8
M?-76-7
J 1 6 0 i - :•
95-4H-7
106-44-5
108-94-1
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
K086
solvent
wash
(mg/kg)

NO
NO
NO
NO
NO
NO
NO
NL
NO
NO
NO
ND
NO
ND
NO
ND
ND
ND
D
ND
NO
ND
ND
ND
NO
NO
ND
ND
ND
ND
NO
D
NO
ND
ND
NO
NO
Scrubber
water
(M9/1)

ND
NO
ND
ND
NO
ND
ND
NL
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
NO
                                       166

-------
1599g
                                 Table 5-1.  (Continued)
BOAT
reference
no

88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
219
107
108
109
110
11!
112
113
114
115
116
117
118
119
120
121
122
123
Parameter
Semivolat i les (continued)
p-Oichlorobenzene
3,3 ' -Dichlorobenz id me
2,4-Dichlorophenol
2,6-Dichlorophenol
Diethyl phthalate
3,3' -Dimethoxybenz id me
p-Dimethy lammoazobenzene
3,3' -Dime thy Ibenz id me
2 ,4-Oimethy Iphenol
Dimethyl phthalate
Di-n-butyl phthalate
1 ,4-Dmitrobenzene
4,6-Dmitro-o-cresol
2,4-Dmitrophenol
2,4-Dmitrotoluene
2,6-Dmitrotoluene
Di-n-octyl phthalate
Di-n-propy Initrosarame
Dipheny lamine
Diphenylnitrosamme
1 , 2-0 iphenyl hydra z me
F luoranthene
F luorene
Hexacn lorobenzene
Hexachlorobutadiere
nexacn lorocyc lope»t'id lene
Hexachloroethdne
Hexacn ioropnene
lndeno( 1 , i , ;-ol)p/rvi e
Isosat ro le
Methapyr i lene
3-Methylcholanthrene
4,4' -Methy lenebis
(2-chloroani 1 me)
Naphthalene
1 ,4-Naphthoqinnone
1-Maphthy lamine
CAS no

106-46-7
91-94-1
120-63-2
87-65-0
84-66-2
119-90-4
60-11-7
119-93-7
105-67-9
131-11-j
84-74-2
100-25-4
534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
621-64-7
122-39-4
86-30-6
122-66-7
206-44-0
B6-73-/
lla-74-1
87-68-3
77-47 -1
F.7-72-1
70 jC-4
1 :" _ ~ ' -
120-r,a-l
C'l-BO-5
56-49-5

101-14-4
91-20-3
130-15-4
1J4-32-7
K086
solvent
wash
(mg/kg)

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

NO
D
ND
ND
Scrubber
water
Ug/D

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

ND
ND
ND
ND
                                          Ib7

-------
1599g
                                 Table 5-1.   (Continued)
BOAT
reference
no.

124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
220
143
144
145
146
147
.46
149
,r,0
151
152
153


154
155
Parameter
Seinivo Idt i Iris (continued)
2-Naphthy lamme
p-N i troani 1 me
N i trobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamme
N-N itrosodiethy lamme
N-N i trosod line thy lamme
N-Ni trosomethy let hy lamme
N-Nitrosomorphol me
N-N i trosop i per id me
n-N i trosopyrro 1 id me
5-Nitro-o-toluidme
Pentachlorobenzene
Pentachloroethane
Pentach loron 1 1 robenzene
Pentachlorophenol
Phenacet m
Phenanthrene
Phenol
Phtha 1 ic anhydride
2-Picol me
Pronamide
Pyrene
Resorc mo 1
Suf ro le
! ,2 , 4 . 'j-Tetrach loi cijeruene
2 , 3 . 4 , t-Tet i'dch loropneno 1
, , ? , 4 Tr icr; iorohen.-ene
2 . 4 . 5- fr icn'oropheriOl
2,4,6-Tnunlorophenol
Tr is(2,3-dibromopropy 1 )
phosphate
Metals
Ant imony
Arsenic
CAS no

91-59-8
100-01-6
98-95-3
100-02-;
924-16-3
55-18-5
62-75-9
10595-95-6
59-69-2
100-/5-4
930-55-2
99-65-a
608-93-5
76-01-7
82-68-8
87-86-5
62-44-2
85-01-8
108-95-2
rf5-44-9
109-06-B
23950-56-5
129-00-0
108-46-3
"i4 '.:< !
>5-y4-j
5b-yo-2
120 ,V 1
1 ' '.' *. ^
oo-Cb-2

126-72-7

7440-36-0
7440-38-2
K086
solvent
wash
(mg/kg)

NO
NO
NO
NO
NO
NO
NO
NO
ND
NO
NO
NO
ND
ND
ND
NO
NO
NO
ND
NL
NO
NO
ND
ND
NO
NO
ND
ND
ND
ND

ND

D
ND
Scrubber
water
Ug/D

ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
NL
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND

ND

D
D
                                       Iba

-------
1599g
                                 Table 5-1.   (Continued)
BOAT
reference
no.

156
157
158
159
160
221
161
162
163
164
165
166
157
168

169
170
171

Jt
' 7"
174
175
17o
:??
17d
179
1«0
1S1
182
1S3
184
185
Parameter
Metals (continued)
Barium
Beryl 1 lum
Cadmium
Chromium
Copper
Hexavalent Chromium
Lead
Mercury
Nickel
Selen lum
Si Tver
T ha 1 1 lum
Vanad lum
Zinc
Inorqan ics
Cyanide
F luor ide
Su If itie
Orqanoch lor me Pesticides
Alarm
I'rih <-RHC
netd-EHC
aelt 3-BrtC
gdinnd-Bnl
Cnloraane
ODD
DDE
DDT
Dieldr in
Endosulfan I
Endosulfan II
Endr in
Endrin aldehyde
CAS no

7440-39-3
7440-41-7
7440-43-9
7440-47-32
7440-50-8
NA
7439-92-1
7439-97-6
7440-02-0
7782-49-2
7440-22-4
7440-28-0
7440-62-2
7440-66-6

57-12-5
16964-48-8
3496-25-b

:0'.i-CO-^
-, l°i-*4 c.
^ 1 ' ' ', ' '
' - C 'j ' ~
• - . f j - :-.
' . / - / \ '
72-54-3
7 2 - rj ^ - J
SO-2'-«-j
r.O ^7-1
939-98-ci
33213-6-5
72-20-8
7421-93-4
K086
solvent
wash
(mg/kg)

D
NO
NO
0
D
D
0
NO
D
NO
ND
NO
ND
0

D
ND
D


-
-
-
-


-
-
-
-
-
-
-
Scrubber
water
Ug/D

D
ND
ND
D
0
0
D
ND
ND
ND
D
ND
D
0

NO
ND
ND


-
-
-
-

-
-
-
-
-
-
-
-
                                       169

-------
1599g
                                 Table 5-1.   (Continued)
BOAT
reference
no

186
la?
188
189
190
191

192
193
194

195
196
197
198
199

200
:01
232
t_ 0 J
2C4
205
206

207
208
209
210
Parameter
Orqanochlor me Pesticides (continued)
Heptachlor
Heptacnlor epoxide
Isodrin
Kepone
Methoxyc lor
Toxaphene
Phenoxvacet ic Acid Herbicides
2.4-0 ich lorophenoxyacet ic ac id
S i Ivex
2,4,5-T
Orqanophosphorous Insecticides
Disulfoton
Fainphur
Methyl parathion
Parathion
Phorate
PCBs
A roc lor 1C 10
trader I,-'?!
A r oc 1 o r 1232
Aroclor 1242
Aroclor 1-M8
ArOLlor 1254
Aroclor 1260
Oioxins and Furans
Hexachlorodibenzo-p-dioxins
Hexachlorodibenzofuran
Pentachlorodibenzo-p-diox ins
Pentachlorodlbenzofuran
CAS no

76-44-8
1024-57-3
465-73-6
143-SO-O
72-43-5
bOOl-35-2

94-75-7
93-72-1
yj-76-0

298-04-4
52-85-7
298-00-0
56-38-2
298-02-2

12o/4-ll-2
: 1104-2^-?
! 1 1 4 1 >, - 5
c: JtO-21 9
; 'o/J-.^-L.
1 1: .7-1'- i
HC'jt.-o2-5

NA
NA
NA
NA
K086
solvent Scrubber
wash water
(mg/kg) Ug/1)

_
-
-
-
-
-

.
-
-

.
-
-
-
-

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

ND ND
ND ND
ND ND
ND ND
                                        170

-------
1599g
                                  Table 5-1.  (Continued)

BOAT
reference
no

211
212
213



Parameter CAS no
Oioxins and Fur-ans (continued)
Tetrachlorodibenzo-p-dioxins NA
Tetrachlorodibenzofuran NA
2,3,7 ,8-Tetrachlorodibenzo-p-dioxin NA
K086
solvent
wash
(mg/kg)

NO
NO
NO

Scrubber
water
Ug/D

ND
ND
ND
NL - Not on list at the time of analysis
ND = Not detected
D  = Detected
   = No analysis performed because of the low likelihood of  its  presence.
NA = Not appl icable

Reference-   USEPA 1987a
                                            171

-------
 1599g
               Table 5-2  BOAT Constituent Concentrations in Untreated K086
                      Solvent Wash Waste  and Scrubber Water Residual
BOAT
reference
no.

222
226
229
38
43
215-217

70
232
121

154
155
156
159
221
160
161
163
165
167
168

169
171
Constituent
Volat i le orqanics
Acetone
Ethy 1 benzene
Methyl isobutyl ketone
Methylene Chloride
Toluene
Xylene (total)
Semivolat i le orqanics
Bis(2-ethylhexyl)phthalate
Cyc lohexanone
Naphthalene
Metals
Antimony
Arsenic
Barium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Nickel
Si Iver
Vanadium
Z me
! norqan ics
Cyanide
Sulf ide
K086 solvent wash
Untreated waste
(mg/1)

CBI
CBI
CBI
CBI
CBI
CBI

CBI
CBI
CBI

CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI

CBI
CBI
Scrubber water
(mg/1)

<0.010
<0.005
<0.010
<0.010
<0.010
<0.005

•=0.010
<0.005
<0.010

0.083-0
0 059-0
0.226-0.
0.099-0,
<0. 010-0,
0 115-0
0.827-1
<0.011
<0. 006-0.
0.022-0.
0.180-0.

^0 010
<0 5












.107
.093
.287
,193
,014
130
52

007
027
216



CBI = Confidential Business Information

Reference:  USEPA 1987a
                                     17 Z

-------
1599g
            Table 5-3  Calculated Bond Energy for the Candidate
                       Organic Constituents
                                  Calculated bond energy
Constituent                             (kcal/mol)
BOAT Volati 1e Orqanics
Acetone                                      945
n-Butyl alcohol                             1350
Ethyl acetate                               1655
Ethyl benzene                               1900
Methanol                                     495
Methyl  isobutyl ketone                      IbOO
Methyl ethyl  ketone                         1230
Methylene chloride                           355
Toluene                                     1615
1,1,1-Trichloroethane                        625
Trichloroethylene                            485
Xylenes (total)                             1900

BOAT Semivol.Uile Organ ics
Bis(2-eth>Ihexyljphthalate                  6620
Cyc lohexanone                               1685
1,2-Oichlorobenzene                         1320
Naphthalene                                  2140
Nitrobenzene                                 1430
Reference   Sanderson 1971
                                        173

-------
159yq
    Table  5-4   Candidate Constituents for Regulation of kOdt jolvent Woih
BOAT reference no
      Constituent
   Volat i le
        jb
        43
        45
        47
       215-217

    tiennvolat i le  Organics
        70
       232
        B7
       121
       126
Ai-L'tcriL1
n but,1 d Icohci
Crn,1 acetate
Ltny li^en^erit
Mel t-Ki'.u I
Mftn, '  i -,or.u; » i Ketone
Metny  etn/1 ketone
Mttth., lurie th lor ide
Toluene
1,1,1-Trichloroethane
Trichloroethylene
Xylene  (total)
Bis(2-ethy1hexyl)pnthalate
Cyclohexanone
1,2-Dichlorobenzene
Naphthalene
Nitrobenzene
       Metals
       159
       221
       160
       161
       163
       168
 Chromium  (total)
 Chromium  (hexavalent)
 Copper
 Lead
 Nickel
 2 me
       Inorganics
       169
       171
 Cyanide
 Sulf ide
                                      174

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                6.   CALCULATION OF BOAT TREATMENT STANDARDS

    The purpose of this section is to calculate the actual  treatment-

standards using analytical  treatment data for the regulated constituents

selected in Section 5.   As  discussed in the Introduction,  the following

steps are taken to derive the BOAT treatment standards:

    1.   The Agency evaluates the available data for the  BOAT treatment
        technologies and deletes any data representing poor design or
        operation of the treatment systems.

    2.   Next,  averages  for  accuracy-corrected constituent  concentrations
        are calculated  and  a variability factor are also determined for
        each constituent selected for regulation.

    3.   The BOAT treatment  standard for each constituent selected for
        regulation is determined by multiplying the average
        accuracy-corrected  total composition by the appropriate
        variability factor.

    Using these three steps, the following sections discuss the

calculation of the BOAT list organic and metal  treatment standards for

K086 solvent wash nonwastewaters and wastewaters.  Appendix B presents

the calculation of the  corrected average concentrations  and the quality

assurance/quality control data used to calculate the values.  The method

for calculation of the  variability factors is presented  in Appendix A,

and the actual calculations can be found in the Administrative Record for

K086 solvent wash.

6.1      Calculation of Treatment Standards for Nonwastewater Forms of
         K086 Solvent Wash

    For purposes of describing the applicability of the  BOAT treatment

standards,  EPA has defined  nonwastewaters as wastes that contain greater

than 1  percent filterable solids or greater than 1 percent total organic
                                    175

-------
carbon (TOC).   For K086 solvent wash,  EPA is proposing nonwastewater



standards that would apply to untreated K086 solvent wash (considered to



be a nonwastewater because the TOC value would be greater than one



percent) and to the precipitated residual generated from treatment of



K086 incinerator scrubber waters (a nonwastewater based on the filterable



solids content).  Below is a description of how the BOAT treatment



standards were calculated for BOAT list organics and metals in K086



nonwastewaers.



6.1.1  Organic Treatment Standards



    Section 5.4 describes the specific organic constituents that EPA has



selected for regulation.  In general,  the BOAT list organic treatment



standards for nonwastewaters are derived from ash residual data when BOAT



represents incineration.  In the case of K086 solvent wash, EPA could not



base nonwastewater standards on residual ash concentrations because



incineration of this waste did not result in an ash residual.  In order



to establish standards for the BOAT list organics in nonwastewaters, EPA



related the treatment performance represented by the scrubber water



organic concentrations to the BOAT list  organic concentrations that would



be expected in  nonwastewater residuals generated from treatment of K086



scrubber water.  This relationship is discussed in more detail below.



    The Agency  does not have data on the filtered precipitate generated



specifically from treatment of K086 solvent wash scrubber waters.  The



incineration data presented  in Section 5 show that organic levels  in the
                                     176

-------
K086 solvent wash scrubber water are nondetectable.   The Agency believes



that metals treatment of the K086 solvent wash scrubber waters can



generate a nonwastewater, the filtered precipitate,  that will  also have



nondetectable levels of organics.  Therefore,  K086 solvent wash treatment



standards for organic constituents in a nonwastewater matrix were



calculated based on the organic detection limits of a wastewater



treatment filter cake  (Envirite) determined to be similar to the K086



solvent wash filter cake.



    In estimating the analytical detection levels of organics for the



precipitated residual waste, EPA examined available data on detection



levels for 15 chemically precipitated wastes believed to be most similar



to the waste that would be generated by metals treatment of K086 scrubber



water.  These data are presented in Appendix E and consist of detection



levels for 7 of the 12 volatile constituents selected for regulation.



Detection levels were not available for the 5 semivolatile constituents



selected for regulation.  For the 5 volatile constituents and the



5 semivolatile constituents where EPA does not have detection levels, the



Agency is proposing the highest volatile detection level observed in the



similar wastes.  EPA believes that this approach provides a conservative



estimate of the detection levels.



    No data were deleted because of poor design or operation of the



treatment system.  The corrected average concentrations, determined



variability factors, and calculated organic standards for K086



nonwastewaters are present in Table 6-1.
                                    177

-------
6.1.2  Metal Treatment Standards



    As stated previously, the Agency does not have data for the filtered



precipitate generated specifically from treatment of K086 scrubber



water.  Therefore, the Agency is transferring levels of performance from



a similar waste treated at Envirite.



    The best measure of metals in a nonwastewater matrix that may migrate



into the environment is the analysis of the toxicity characteristics



leaching procedure (TCLP) extract.  Therefore, BOAT treatment standards



for metals were calculated based on TCLP data from the Envirite filter



cake determined to be similar to K086 solvent wash filter cake.



    The data used for calculation of the K086 solvent wash nonwastewater



metal standards is presented in Table 3-2.  None of the data were deleted



because of poor design or operation of the treatment system.  Hence, all



11 data points are used for regulation of K086 solvent wash nonwastewater.



    Next, the accuracy-corrected constituent concentrations were



calculated for all selected BOAT list constituents.  The arithmetic



average concentration and a variability factor were determined for each



BOAT  for the lead and chromium data.  Finally, the BOAT performance



standard for lead and chromium were determined by multiplying the average



accuracy-corrected total composition by the  appropriate variability



factor  as shown in Table 6-1.
                                     178

-------
Ib44g
       Table  6-1  Calculation of kOtiG Solvent Wash NonwdStewdter Treatment Standard:,
BOAT
reference
no
Approx irnate
BOAT list accuracy-corrected
constituents average concentration"
Approx imate
vanabi 1 ity
factor**

Treatment
standard***
              Volati1e Orqanics
222           Acetone                      0 13
223           n-Butyl alcohol              0 13
225           Ethyl acetate                0 13
226           Ethylbenzene                 0 Oil
228           Methanol                     0 13
229           Methyl   tsobutyl ketone       0 13
 34           Methyl  ethyl ketone          0 13
 38           Methylene chloride           0 313
 43           Toluene                      0 01 ]
 45           1,1,1-Tr ichloroethdne        0 OIL
 4/           Tr ich loroetru lurit-            0 Oil
215-217       Xjlene   (total)                C 0055

              Semivolatile Orqanics
 70           Bis(2-ethylhex>Ijphthalate   0 IB
232           Cyclohexanone                0 18
 87           1,2-Dichlorobenzene          0 18
121           Naphthalene                  0.18
126           Nitrobenzene                 0 18

              Metals

159           Chromium (Total)              0 076
161           Lead                         0 013
2 8
2 8
2 8
2 8
2 8
2 8
2 8
? B
2 b
L d
i o
2 b
2 8
2 8
2 3
2 8
2 b
1.24
2 8
0 37
0 37
0 37
0 031
0 37
0 37
0 37
C 037
: 031
0 49
0 49
0 49
0.49
0.49
0.094
0 37
'Calculation for the accuracy corrected average concentration is  shown  in  Appendix  B

**Method used for calculation of the variability factor  is  shown  in  Appendix  A

""Treatment Standard = (accuracy-corrected,  average concentration)  x  (variability
   factor)   The value for the treatment  standard was rounded to  two significant
   figures at the end of the calculation
                                             179

-------
6.2      Calculation of Treatment Standards for Wastewater Forms of K086
         Solvent Mash
    As defined in Section 1.0, wastewater forms of K086 solvent wash are
those wastes that contain less than one percent filterable solids and
less than one percent total  organic carbon.  The only data available to
the Agency characterizing wastewater forms of K086 solvent wash is the
scrubber water data generated during incineration of the K086 solvent
wash.
6.2.1    Organic Treatment Standards
    The data characterizing K086 solvent wash scrubber waters show
nondetectable levels of the regulated organic constituents that were
detected in the untreated K086 solvent wash.  Therefore, the organic
treatment standard's will be based on the analytical detection levels.
All six data points were used in development of the treatment standards.
The Agency has detection levels for 10 volatiles and all 5 semivolatiles.
Two volatiles, n-butyl alcohol and ethyl acetate, were not analyzed  for
because they were not on the  list at the time of the analysis.  For  these
volatile organics,  EPA is proposing the highest volatile detection
observed in the K086 scrubber water.  The  calculations of the wastewater
organic treatment standards for K086 solvent wash are  presented in Table
6-2.
6.2.2    Metal Treatment Standards
     The Agency does  not  have  any treatment  performance data  on  treatment
of K086 solvent wash scrubber waters.  Therefore, the  Agency is
                                     180

-------
lB44g
        Table 6-2  Calculation of K086 Solvent  Wash Wastewater  Treatment  Standards
BOAT
reference
  no.
   BOAT list
  constituents
     Approximate
 accuracy-corrected
average concentration*
Approximate
variabi1ity
  factor**
Treatment
standard***
              Volat i1e Orqanics
222           Acetone                      0 0055
223           n-Butyl alcohol              0.011
225           Ethyl acetate                0.011
226           Ethylbenzene                 0 0055
228           Methanol                     0 Oil
229           Methyl  isobutyl ketone       0 Oil
 34           Methyl  ethyl ketone          0 Oil
 38           Methylene chloride           0 Oil
 43           Toluene                      0 010
 45           1,1.1-Tnchloroethone        0011
 47           Trichloroethyiene            0 010
215-217       Xylene  (total)                0 0055

              Semivolatile Orqanics
 70           Bis(2-ethylhexyl)phthalate   0 016
232           Cyclohexanone                0 007&
 87           1,2-Dichlorobenzene          0.016
121           Naphthalene                  0.016
126           Nitrobenzene                 0.016
159
161
Metals

Chromium (Total)
Lead
           0 19
           0.013
                                              2.8
                                              2  8
                                              2.8
                                              2  8
                                              2  8
                                              2  8
                                              2  B
                                              2  b
                                              2  8
                                              2  6
                                              2  B
                                              2  6
                                              2.8
                                              2  8
                                              2  8
                                              2.6
                                              2.8
   1 69
   2 8
                                              0 015
                                              0 031
                                              0 031
                                              0 015
                                              0 031
                                              0 031
                                              C 031
                                              0 031
                                              0 025
                                              0 031
                                              0 029
                                              0 015
                                              0 044
                                              0 022
                                              0 044
                                              0 044
                                              0 044
   0 32
   0 037
*Calculation for the accuracy corrected average concentration is shown in Appendix B

**Method used for calculation of the variability factor is shown in Appendix  A.

'"Treatment. Standard = (accuracy-corrected,  average concentration) x (variability
   factor).  The value for the treatment standard was rounded to two significant
   figures at the end of the calculation
                                           181

-------
transferring treatment data from a similar wastewater treated at
Envirite.  The Agency expects that the Envirite wastewaters are at least
as difficult to treat as the K086 solvent wash scrubber waters since the
Envirite untreated metal concentrations are higher.   Accordingly,  EPA
believes that the level of performance achieved for lead and chromium in
the wastes treated in the Envirite treatment system can be transferred
for lead and chromium levels in the K086 solvent wash wastewaters.  The
data consist of 11 influent and effluent sample sets.  All effluent data
were used in development of the treatment standards.   The calculations of
the wastewater metal  treatment standards for K086 solvent wash are
presented in Table 6-2.
                                     182

-------
APPENDIX A
    183

-------
                                 APPENDIX A
                            STATISTICAL  METHODS
A.I  F Value Determination for ANOVA Test
    As noted earlier in Section  1.0, EPA  is using the statistical method
known as analysis of variance in the determination of the level of
performance that represents "best" treatment where more than one
technology is demonstrated.  This method  provides a measure of the
differences between data sets.   If the differences are not statistically
significant, the data sets are said to be homogeneous.
    If the Agency found that the levels of performance for one or more
technologies are not statistically different (i.e.,  the data sets are
homogeneous), EPA would average the long  term performance values achieved
by each technology and then multiply this value by the largest
variability factor associated with any of the acceptable technologies.
If EPA found that one technology performs significantly better (i.e., the
data sets are not homogeneous),  BOAT would be the level  of performance
achieved by the best technology multiplied by its variability factor.
    To determine whether any or all  of the treatment performance data
sets are homogeneous using the analysis of variance  method,  it is
necessary to compare a calculated "F value" to what  is known as a
"critical value."  (See Table A-l.)   These critical  values are available
in most statistics texts (see, for example, Statistical  Concepts and
Methods by Bhattacharyya and Johnson,  1977, John Wiley Publications, New
York).
    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
                                     184

-------
Table A-l

95th PERCENTILE VALUES FOR
• THE F DISTRIBUTION
ni = degrees of freedom for numerator
«2 = degrees of freedom for denominator
(shaded area = .95)

/~\
*is
A'! i
1 101.4
2 IS. 51
3 , 10.13
4
5
G
•"
S
Q
10
11
12
1C
14
15
16
17
IS
19
20
fjn
O '
-.1
26
2S
30
40
50
60
70
80
100
150
200
400
CO
*~ ~ 1
6.51
5. 99
5.59
5.32
"to
4.96
4.S4
4.75
4.57
4. GO
4.54
4.49
4.45
4.41
4.38
4.25
4.30
4.25
< rt ^
•»._O
4.20
4.17
4.08
4.03
4.00
3.93
3.96
3.94
3.91
3.S9
3.S6
3.S4
o
199.5
19.00
9.55
6.94
5.79
5.14
1. i -»
4.4G
4.2G
4.10
3.9S
3.S9
3.S1
O *. 1
O. ;4
o — ^
•3.00
3.53
3.59
3— —
.00
3.52
3.49
3.44
3.40
3.37
3-t »
-w*
•? ->o
3.23
3.1S
3.15
3.13
3.11
3.09
3.06
3.04
3.02
2.99
3
215.7
19.16
O 1C
*• ...G
6.59
5.41
4.76
4.25
4.07
3.86
3.71
3.59
3.49
3.41
3.34
O OQ
U.-.y
0 O 4
O.-.1
3.20
3.16
3.13
3.10
3.05
3.01
2.98
2.95
2 92
2.S4
2.79
2.76
2.74
O »7O
2.70
2.G7
2.G5
2.G2
2.GO
4
224.6
19.25
9.12
6.29
5.19
4.53
4.12
3.34
3.G3
3.4S
3.36
' °fi
U._U
3.18
3.11
3.06
3.01
2.96
2.03
2.90
2.S7
o po
*».*J«
2. 78 '
2.74
2.71
2.69
2.61
2.55
2.53
2.50
2.48
2.46
2.43
2.41
2.39
2.37
E
220.2
19.30
9.01
6.25
5.05
4.29
3.27
n ~ o
o.ua
3. 48
3.33
3.20
3.11
3.03
2.96
2.90
2.S5
2.S1
2.77
2.74
2.71
2.66
2.62
2.59
2.56
2.53
2.45
2.40
2.37
0 1Z
4_.ot?
2.33
2.30
2.27
2.26
r> nn
tf.^tj
2.21
6
234.0
19.23
8.94
6.16
4.95
4.28
3.S7
3.58
3.37
3.22
3.09
3.00
2.92
2.S5
2.79
2.74
2.70
2.66
2.53
2.60
2.55
2.51
2.47
2.45
2.42
2.34
o no
o or
*..«3
O TJ
O Ot
O 1 Q
2.16
2.14
2.12
2.09
8
OOQ Q
19.37
8.S5
6.04
4.S2
4.15
3.73
ft 4 4
a,44
3O»*
. — «J
3.07
2.95
2.S5
O — »*
2.70
2.64
2.59
2.55
2.51
2.4S
2.45
2.40
2.26
O *?1
O OQ
2.27
2.1S
2.: 3
2.10
2.07
2.05
2.03
2.00
1.2S
1.96
1.94
12
O * O Q
19.41
8.74
5.91
4. Go
4.00
3.57
•7 no
u.~3
rt n*"
o.U i
2.91
2.79
2.69
2.60
2.53
2.4S
O «O
o r>o
•..OO
O 0 *
•..1^1
2.31
O 00
o._O
O 0«J
mfrf^tj
2.18
2.15
O 1 O
2.09
2.00
1.95
1 °2
1.89
l.SS
1.85
1.82
1.80
1.78
1.75
16
24G.3
19.43
8.59
5.S4
4. GO
3.92
3.49
3.20
2.98
O QO
2.70
2.60
2.51
2.44
O ^Q
*..o J
O «0
«.i_f 0>
0 OQ
2.25
O O^
2.18
2.13
2.09
2.05
2 02
1.99
1.90
1.35
1.31
1.79
1.77
1.75
1.71
1.59
1.67
1.64
20
248.0
19.45
8.66
5. SO
4.56
3.S7
3.44
3.15
2.93
2.77
2.65
2.54
2.46
2.39
o •?•?
*>.oo
O OO
*>.HiD
o 03
2.19
2.15
O 10
2.07
2.03
1.99
1.96
1.93
1.S4
1.78
1.75
1.72
1.70
1.68
1.64
1.62
1.60
1.57
30
250.1
19.46
S.62
5.75
4.50
2.S1
2.38
3.08
2. 36
2.70
2.57
2.46
0 TO
— ..-•O
2.21
2.25
2.20
2.15
2.11
2.07
2.04
1.98
1.94
1.90
1.87
1.84
1.74
1.69
1.65
1.62
1.60
1.57
1.54
1.52
1.49
1.46
40
251.1
19.46
8. GO
5.71
4.4G
3.77
*) O 4
W.01
2.05
O CO
2.67
2.53
2.42
0 0 i
~.bl t
O OT
O 15
2.16
2.11
2.07
O ,"| O
1.99
1.93
1.S9
1.85
1.81
1.79
1.69
1.53
1.59
1.56
1.54
1.51
1.47
1.45
1.42
1.40
50
oro n
19.47
8. 53
5.70
4.44
3.75
3.22
3.03
2.80
2.64
2.50
2.40
O OO
O o *
2.18
2.13
2.08
2.04
2.00
1.96
1.91
1.86
1 22
1.78
1.76
1.66
1.50
1.56
1.53
1.51
1.48
1.44
1.42
1.38
1.22
100
252.0
19.4P
8.56
5.6C
4.40
2.71
3.2S
2.98
2.76
2.59
2.45
2.25
2.26
2 19
2 •» o
2.07
2.02
1.98
1.94
1.90
1.84
1.80
1.76
1.72
1.69
1.59
1.52
1.48
1.45
1.42
1.29
1.24
T oo
1.28
1.24
•T
or • ->
_ i>-i .0
19.30
S.53
5.C2
4.25
3.67
•5 o-
2.93
2.71
2.54
2.40
2.30
*> OT
2.13
2.07
2.01
1.25
1 o'*
l.SS
1.34
1.78
1.73
1.59
1.65
1.52
1.51
1.44
1.29
1.35
1.22
1.2S
^ no
1.19
1.13
1.00
     185

-------
necessary to perform a "pair wise F" test to determine if any of the sets

are homogeneous.  The "pair wise F" test must be done for all of the

various combinations of data sets using the same method and equation as

the general F test.

    The F value is calculated as follows:

    (i)  All data are natural logtransformed.

    (ii)  The sum of the data points for each data set is computed (T.).

    (iii)  The statistical  parameter known as the sum of the squares

between data sets (SSB) is  computed:
    SSB =
where:

k = number of treatment technologies
n^ = number of data points for technology i
N = number of data points for all  technologies
T.J = sum of natural logtransformed data points for each technology.

(iv)  The sum of the squares within data sets (SSW) is computed:

              k   n^
k

f T-2 1
. >

—

" k
.1 Ti
N
t. -
     SSW =

where:
                                   k
                                 -  I
                                        n.
    x-j j = the natural logtransformed observations (j) for 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.
                                     186

-------
    (vi)   Using the above parameters,  the F value is calculated as

follows:

                                  MSB
                              F = MSW

    where:

    MSB = SSB/(k-l) and
    MSW = SSW/(N-k).

    A computational table summarizing the above parameters is shown below.


                    Computational Table for the F Value
Source
Between
Within
Degrees of
freedom
K-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.
                                     187

-------
1790g
                                                          Example 1
                                                      Methylene Chloride
Steam Stripping
Influent Effluent
Ug/l)
1550.00
1290.00
1640 00
5100 00
1-550 00
4600 00
176C Co
2400 00
• c An A A
•* 0 u w U U
•?-nr. QO

Ug/ 1 )
10.00
10.00
10 00
12 00
10 00
10 00
10 CO
10 00
10 00
10 00
Biological Treatment
In(effluent) [In(effluent)]2 Influent Effluent In(effluent)

2.30
2.30
2 30
2 48
2.30
2 30
2.30
2.30
2.30
2.30
Ug/l) Ug/l)
5.29 1960.00 10.00 2.30
5.29 2568.00 10.00 2.30
5.29 1817.00 10.00 2.30
6.15 1640 00 26.00 3.26
5.29 3907.00 10.00 2.30
5 29
5 29
5 29
5.29
5.29
[In(effluent)]2

5.29
5.29
5.29
1C 6
S 29




Sum
                                23 18
                                                  53 8
                                                                                           12 46
  r.P '6 2 1Z6
     10
10
                10
Mean
  3669
10.2
2.32
                                            2378
                                            13.2
2.49
Stanaara Deviation
  3328 67           63
                  06
                                             923.04
                                             7.15
                                                                            .43
    laoi 1 i ty factor
                  1  14
                                                                               2.48
ANOVA Calculations.
SSB =
          .  n
                              N
 SSW r
 HSU = SSU/(M-k.)
                                                                 188

-------
1790g


                                  Example 1  (continued)
F   = MSB/MSU
Where.
k * number of treatment technologies
n  * numoer of data points for technology i

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

T  = Total sum of all the natural log transformed data points for all technologies
X   = the nat  log transformed observations (j) for treatment technology (i)
   - 10.  n  = 5.  N = 15.  k = 2.  T  = 23 18,  T  = 12 46.  T = 35.64.  T = 1270.
   = 537 3,   T  j 155.2.
537 3   155.2
 10       5
                          1270
                           15
=  0 1233
Si. - !53 6 - 31  8)  -
                        537.3   155 3
                         10
         = 0 7600
MSB = 0.1233/1  = 0.1233
MSW * 0 76/13 = 0.0584
F .
            . 2 109
    0.0584
                                    ANOVA Table

Source
Between! B)
Within(W)
Degrees of
freedom
1
13

SS MS F
0.1233 0.1233 2.109
0 7600 0.0584
      The  critical  value  of  the  F  test  at  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)
                                           189

-------
1790g
                                                      Example 2
                                                  Tnchloroethy lene
Steam Stripping
Influent
Ug/D
1650.00
5200.00
5000 00
172C 00
1560 00
1030C 00
21C 00
160C OC
20-* 00
16C 00
Effluent
U9/1)
10.00
10.00
10 00
10 00
10 00
10 00
10 00
27 00
85 00
10 OC
In(effluent)

2.30
2.30
2.30
2.30
2 30
2.30
2 30
3 30
4 44
2.30
[In(effluent)]2

5.Z9
5.29
5.29
5.29
5.29
5.29
5.29
10.9
19 7
5.29
Influent
Ug/D
200.00
224.00
134.00
150.00
484.00
163.00
182.00



Biological Treatment
Effluent In(effluent)
l«/U
10.00
10.00
10.00
10.00
16.25
10.00
10.00




2.30
2.30
2.30
2.30
2.79
2.30
2.30



(In(effluent)]2

5.29
5.29
5.29
5.29
7 78
5.29
5.29



                              26 14
                                             72.9
                                                                                     16 5S
                                                                                                       3S
idnc ie b ne
     10
 10
Mean
   2760         19 2

Stsnaaro Deviation
   3209 6       23 7
Var ;ac i ! i ty ractor
                10
                 2.61
                  71
                                           220
                                           120.5
                3 76
10.89
                                                          2.36
                                                                         1.51
2.37
                                                                         .18
ANOVA Calculations
SSB =
G?)
 ssw  -
 MSB -- SiS/lk-i)

 MiW = $SW/(N-k.)
                                                         190

-------
1790g
                                  Example  2   (continued)


F   = MSB/HSU


Where,


k. = numoer of treatment  technologies


n  = number of data  points for technology  i
 i


N = number of data points for all  technologies


T  = sum of natural  log  transformed data points  for  each  technology
 i


T = total sum of all the natural  log  transformed data  points  for  all  technologies


X   = the natural log transformed  ooservations  (j)  for treatment  technology  (i)
                                                                                    .IT;
N  = iO. N  = 7.  N = 17,  k = 2,  T   =  26.14.  T   =  16  59.  T  »  42.73.  T  =  1826, T  = 665.3
T = 275.2.
2
683 3
SSE =

_____ »
10


275 2
_____
7
1826
~ ^_^^^_
17
                                            0.2325
SS'w = ! 72 9  •>  39  5)
                        683 3   275 2


                         10
                                  7
                                                4 856
MSB = 0 2325/1 = 0 2325


MSW = 4 856/15 = 0.3237


.   0 2325
           = 0 7163
    0 3237
                   Degrees of

          Source     freedom
                                    ANOVA Table
                                          SS
                                                         MS
Between(B)
Withm(W)
1
15
0 2325
4 856
0.2325
0.3237
0.7183
      The critical value of the F test at 0.05 significance level  is  4  54    Since  f

      value  is  less than the critical value,  the means are not  significantly different

      (i e  . thev are homogeneous)
                                             191

-------
1790g
                                                          Example  3
                                                        Chlorobenzene
  Activated Sludge Followed bv  Carbon
Influent       Effluent      In(effluent)
 Ug/1)         Ug/1)
                                          [ln(effluent)]'
                           Influent
                            Ug/1)
                                                        iological Treatment
                                                          Effluent      In(effluent)
                                                       [In (effluent)]2
   7200.00
   6500  00
   6075  00
   3040  00
 80.00
 70.00
 35 00
 10 00
4 38
4.25
3.56
2.30
19.2
18.1
12.7
 5.29
                                                           9206.00
                                                           16646.00
                                                           49775.00
                                                           14731.00
                                                           3159.00
                                                           6756.00
                                                           3040 00
1083.00
 709.50
 460.00
 142.00
 603.00
 153.00
  17 00
6.99
6.56
6.13
4 96
6 40
5.03
2.83
48.9
43.0
37.6
24 6
41 0
25.3
 8 01
                                   49
                                                 55.
                                                                                           38 90
                                                                                                              226 4
Sams ie 5ize
Mean
                 4S
                                                           14759
                                                             452.5
                                                                                            5.56
Standard Oev lation
   i£35 4        32.24
Var iat) i 1 i ty factor
                  7  00
                   .95
                                            16311.86
                                           379.04
                                                                             15.79
                                                                             1.42
ANDVA Calculations
SS5  =
G?)
 ssw -
 ^i£  = SS5/(K-i)

 MSw  = SSU/(S-k)

 F    = MSB/MSW
 Where.
                                                         192

-------
1790g
                                  Example 3   (continued)

k = numoer of treatment technologies
n  = numoer of data points for technology i

N * number of data points for all technologies
T  * sum of natural log transformed data points for each technology                  •

T = total sum of all the natural  log transformed data points for all technologies «
X   = the natural log transformed observations (j) for treatment technology (i)
N  = 4,  N = 7.  N • 11.  k • 2.  T  « 14.49,  T  * 38.90.  T » 53.39.  T?« 2850,  T2
                                                                                210.0
T" = 1513.
                1513
                          2850
                                          9 552
SSW = (55 3 » 228 4)
                          210.0    1513
                                •f
                            4        7
14  96
MSB = 9.552/1 = 9 552
MSw = 14 96/9 = 1 662

'  = 9 552/1 662 = 5 75
                                    ANOVA Table
                   Degrees of
          Source    freedom
                                          SS
      MS
Between(B)
Within(U)
1
9
9 552
14 96
9.552
1.662
5.75
      The critical  value of the F test at 0 OS significance  level  is  5.12.   Since  f
      value is  larger than the critical value,  the means  are  significantly  different
      (i  e .  they are heterogeneous)
                                           193

-------
has been used routinely in the EPA development of numerous regulations in
the Effluent Guidelines program and in the BOAT program.  The variability
factor (VF) was defined as the ratio of the 99th percentile (C  ) of
the lognormal distribution to its arithmetic mean (Mean).
           VF =     C99                                             (])
                   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 (p) and standard deviation (a) of the normal distribution as
follows:
         C99    =  Exp („ +  2.33a)                         (2)
         Mean   =  Exp U +   -5a2)                         (3)
    Substituting (2) and  (3) in (1) the variability factor can then be
expressed  in terms of a as follows:
         VF = Exp  (2.33  a •  .So2)                         (4)
    For residuals with concentrations that are not all  below the
detection  limit, the 99   percentile and the mean can be estimated from
the actual analytical data and  accordingly, the variability factor (VF)
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.
                                      194

-------
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 (a) of the normal distribution is
approximated by
    a = [(In (UL) -  In (LL)] /  [(2)(2.33)] = [ln(UL/LL)] / 4.66
    when LL = (0.1)(UL) then a  = (InlO) / 4.66 = 0.494
Step 4:  Substitution of the value from Step 3 in equation (4) yields the
variability factor,  VF.
    VF = 2.8
                                      195

-------
A.2.  Variability  Factor
                                   -£99-
                              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.  Cgg  is calculated using
            the following equation:  Cgg = Exp(y +  2.33 Sy) where y and
            Sy are the mean and standard deviation, respectively, of the
            logtransformed data.
    Mean =  average of the individual performance  values.

    EPA is establishing this figure as an instantaneous maximum because

the Agency believes that on a day-to-day basis the  waste should meet the

applicable treatment  standards.   In addition, establishing this

requirement makes it  easier to check compliance on  a single day.  The

99th percentile is appropriate because it accounts  for almost all process

variability.

    In several cases, all the results from analysis of the residuals from

BOAT treatment are found at concentrations less than the detection

limit.  In such cases, all the actual concentration values are considered

unknown and hence, cannot be used to estimate the variability factor of

the analytical results.  Below is a description of  EPA's approach for

calculating the variability factor for such cases with all concentrations

below the detection limit.

    It has been postulated as a general rule that a lognormal

distribution adequately describes the variation among concentrations.

Agency data shows that the treatment residual concentrations are

distributed approximately lognormally.  Therefore,  the lognormal model
                                      196

-------
APPENDIX B
    197

-------
                                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 Evaluation Solid Waste; Physical/Chemical
Methods, SW-846, Third Edition, November 1986) are used in most cases for
determining total constituent concentrations.  Leachate concentrations
were determined using the Toxicity Characteristic Leaching Procedure
(TCLP), published in 51 FR 1750, November 7, 1986.
    In some instances SW-846 allows for the use of alternative or
equivalent procedures or equipment.  Table B-2 presents the specific
procedures or equipment used in extraction of organic compounds.  The
specific procedures or equipment used for anlaysis of organic and metal
compounds are shown in Table B-3.
    As stated in the introduction, all concentrations for the regulated
constituents will be corrected  to account for analytical interference
associated with the chemical makeup of the waste matrix.  The correction
factor for a constituent is based on the matrix spike recovery values.
Table  B-4 present the organic matrix spike recoveries used to determine
the correction  factor for the  EPA-collected organic data for the K086
scrubber water  residual.  Since spikes were not performed for every
organic compound, it was necessary to calculate an average recovery  value
for volatile organics, base/neutral semivolatile organics and acid
semivolatile organics.
    Since no matrix spike recovery values were available for the Envirite
data,  matrix spike recovery values for a  similar wastewater  (i.e.,  K061
                                    198

-------
TCLP extract) and nonwastewater (i.e., K061) matrix have been used to
correct the Envirite data.  The recoveries used to correct the Envirite
wastewaters and TCLP extract metal concentrations are shown in Table B-5.
Table B-6 presents the recoveries used to correct the Envirite filter
cake organic detection limits.  It was necessary to calculate average
recovery values since spikes were not performed for every organic
constituent.
    The accuracy-corrected, average concentrations for the Envirite
wastewater metal concentrations are calculated in Table B-7.  Table B-8
presents the accuracy-corrected,  average concentrations for the Envirite
filter cake metal TCLP concentrations.  The accuracy-corrected, average
concentrations  for the regulated  organic constituents in the K086 solvent
wash wastewater and filter cake residual are presented in Table B-9.   In
cases where all the concentrations reported are the detection limits,  the
highest detection limit was selected  as the average concentration.
                                     199

-------
1900g
                                      Table  B-l  Analytical Methods for K.08C  Solvent  Waste  Regulated  Constituents
BOAT
reference
number
222
223
225
226
228
229
34
38
43
45
47
215-217

70

232

87

121

126


Regulated
const ituent
Volat i le Orqanics
Acetone
n-Butyl alcohol
Ethyl acetate
Ethyl benzene
Methanol
Methyl isobutyl ketone
Methyl ethyl ketone
Methylene chloride
Toluene
1,1,1-Tnchloroe thane
Tr ichloroethy lene
Xylene (total)
Semivolatile Organic
Bis(2-ethyl hexy 1 Jphtha late

Cyc lohexanone

1 ,2-Dichlorobenzene

Naphthalene

Nitrobenzene

Metals
Extraction
method
Purge and Trap
Purge and Trap
Purge and Trap
Purge and Trap
No extraction
Purge and Trap
Purge and Trap
Purge and Trap
Purge and Trap
Purge and Trap
Purge and Trap
Purge and Trap

Continuous liquid/
1 iquid extraction
Continuous liquid/
liquid extract ion
Continuous liquid/
1 iquid extraction
Continuous liquid/
1 iquid extract ion
Continuous liquid/
liquid extract ion

Method
number
5030
5030
5030
5030

5030
5030
5030
5030
5030
5030
5030

3520

3520

3520

3520

3520


Analytical method
Gas
Gas
Gas
Gas
Gas
Gas
Gas
fa-,
fa-,
Gas
Gas
Gas

fa".

fa-

fa:,

Gas

Gas


Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass
Chromatography/Mass

Chroma tography/M^ss

Chromatography/Mass

Chromatography/Mass

Chromatography/Mass

Chromatography/Mass


Spectrometry
Spectrometry
Spectrometry
Spect rometry
Spectrometry
E pect rometry
Spect romet r /
Spectrometry
Soect romet ry
Spectrometry
Spect romet ry
-pect rometry

'•pect ro^etry

pect rorrc-t i >

Spect romet r y

Spectrometry

: pect rometry


Method number
8240
8240
8240
8240
8240
8240
8240
8240
8240
8240
8240
8240

8270

8270

8270

8270

8270


Reference
1
1
1
1
1
1
1
1
1
1
1
1

1

1

1

1

1


159         Chromium (total  composition)   Specified  in
                                          analytical method
161         Lead  (total  composition)       Specified  in
                                          analytical method
Chromium (atomic absorption,  direct
aspirat ion method)
lead  (atomic absorption,  direct
aspiration method)
7190

7420

-------
           1900g
                                                                           Table B-l   (continued)
           BOAT
           reference   Regulated
           number      constituent
Extract ion
method
Method
number
Analytical method
                                                                           Method number      Reference
                       Metals  (continued)
           159         Chromium  (TCLP extract)

           161         Lead  (TCLP extract)
Specified in
analytical method
Specified in
analytical method
           Toxicity Characteristic Leaching
           Procedure (TCLP)
           Toxicity Characteristic Leaching
           Procedure (TCLP)
                                    51 FR 1750         2

                                    51 FR 1750         2
           References:   1    USEPA  1982
                         2.   Federal Register 1986
rv>

-------
         1900g
                                          Table B-2  Specific  Procedures  or  Equipment  Used in Extraction  of  Organic  Compounds When
                                                    Alternatives or Equivalents are Allowed  in the SW-646 Methods
              Analysis
SW-846 method
      Sample  al iquot
Alternatives or equivalents allowed
         by SW-846 methods
     Specific procedures or
          equipment used
         Purge  and  trap
      5030        5 mi Hi liters  of liquid
                                 The  purge  and  trap  device  to  be
                                 used is  specified  in  the method  in
                                 Figure  1,  the  desorber  to  be  used
                                 is described  in  Figures 2  and 3,
                                 and  the  packing  materials  are
                                 described  in Section  4  10  2    The
                                 method allows  equivalents  of  this
                                 equipment  or materials  to  be  user!
                                             The purge and trap equipment and
                                             the desorber used were as specified
                                             in SW-846.  The purge and trap
                                             equipment is a Teckmar LSC-2 with
                                             standard purging chambers (Supelco
                                             cat. 2-0293).  The packing materials
                                             for the traps were 1/3 silica gel
                                             and 2/3 2,6-diphenylene
ro
c
ro
                                                   The  method specifies  that  the
                                                   trap must  be  at  least  25 cm  long
                                                   and  have  an inside  diameter  of  at
                                                   least  0  105 cm

                                                   The  surrogates recommended are
                                                   toIuene-d8,4-bromofluorobenzene,
                                                   and  1 , 2-dichloroethane-cf"    The
                                                   recommended concent rat icf  level  is
                                                   50 ug/1
                                                                                                                             The  length of the trap was 30 cm
                                                                                                                              nd  headiaraeter was 0.105 cm.
                                                                            The  surrogates were  added  as
                                                                            specified  in  SW-846
         Continuous  liquid-
         1iquid  extraction
      3520
1  liter of  1iquid
    Acid and base/neutral extracts
    are usually combined before
    analysis by GC/MS   However,
    under some situations,  they may
    lie extracted and analyzed
    separately.
Acid and base/neutral extracts
were combined.
                                                                                    The base/neutral surrogates
                                                                                    recommended are 2-fluorobipheny1,
                                                                                    M 11 roben?ene-d5. terphcnyl d!4
                                                                                    The acid surrogates recommended
                                                                                    are 2-fluorophenol,
                                                                                    ".4,6-tribromopheno1.  and
                                                                                    l>hrMol-d6   Add 11 londl c o^pouncl''
                                                                                              Surrogates were the same as  those
                                                                                              recommended by SW-846. with  the
                                                                                              exception that phenol-dS was
                                                                                              substituted for phenol-d6    The
                                                                                              concentrations used were tne
                                                                                              concentrations recommended  >r>  ,-W-Mf,

-------
         1900g
                                                                           Table  B-2   (continued)
               Analysis
 SW-846 method
                         Sample aliquot
Alternatives or equivalents allowed
         by SW-846 methods
Specific procedures or
     equipment used
         Continuous  liquid-
         1iquid extract ion
         (Continued)
                                                   may be used for  surrogates   The
                                                   recommended concentrations for
                                                   low-medium concentration  level
                                                   samples are 100  ppm  for acid
                                                   surrogates and 200 ppm for
                                                   base/neutral surrogates   Volume
                                                   of surrogate may be  adjusted
         Solvent  Extraction
3540
INJ
O
CO
  The internal standards aie
  prepared by dissolving them
  in carbon disulfide and then
  diluting to volume so thdt
  the f inal solvent is 20
  ca'iion disulfide and 8C
  mp'hylene chloride
  The preparation of the
  internal standards was
  changed to eliminate the
  use of carbon disulfide
  The internal standards
  weie prepared in
  methylene chloride only
         Reference:   USEPA    1987a

-------
      J901g
                                      Table B-3   Specific Procedures or Equipment  IKed for Analysis of Or CMP
                                                  When  Alternatives or Equivalents Allowed  in SW-846
                                                                                  arid  Metal  Compounds
         Analysis
SW-846
Method
Sample
preparation
method
Alternatives or equivalents
   al lowed in SW-fc46 for
 equipment or in procedure
                                                                                                                       Specific equipment or procedures used
      Organic  Compounds

      Gas  Chromatography/
        Mass Spectrometry
        for volatile
        organics
  8240
5030
re
cr
                      Recommended GC/MS  operating  conditions:
                        Electron energy-
                        Mass range
                        Scan time

                        Initial  column  temperature
                        Initial  column  holding time
                        Column temperature program
                        Final column  temperature:
                        Final column  holding time:
                        Injector temperature:
                        Source temperature-

                        Transfer line temperature-
                        Carrier  gas:
                                           70  ev  (nominal)
                                           35-260  amu
                                           To  give 5 scans/peak  but
                                            not to exceed  7  sec/scan
                                           4S  C
                                           3 mm
                                           8"C/min
                                           200"C
                                           I1)  mm
                                           200-225-C
                                           According to manufacturer's
                                           spec ification
                                           ?%-300'C
                                           Hydrogen at 50 cm/sec or
                                           hellum  at 30 cm/sec
                                                     The column should  be  6-ft  x  0  1  in.  I.D.  glass.
                                                     packed with 1% SP-1000 on  Carbopack  B  (60/80 mesh) or
                                                     an equivalent

                                                     Samples may be analyzed by purcie and trap  technique
                                                     or by direct  injection
                                                                        Actual GC/MS operating conditions-
                                                Electron  energy.
                                                Mass  range
                                                Scan  time
70 ev
35 - 260 amu
2 5 sec/scar,
                                                                                                                   Initial  column temperature:   38°C
                                                                                                                   Initial  column holding  time   2  mm
                                                                                                                   Column  temperature  program:   10'C/mm
                                                                                                                   Final column  temperature:
                                                                                                                   Final column  holding  time:
                                                                                                                   In lector temperature:
                                                                                                                   Source  temperature
                                                                                                                   Transfer  line  temperature:
                                                                                                                   Carrier gas
                                                                            225X
                                                                            30 mm or xylene elutes
                                                                            225'C
                                                                            manufacturer's recommended
                                                                            va lue of IOC C
                                                                            275'C
                                                                            Hel lum (B 30 ml/mm
                                                                                  •Additional Information on Actual  System Used
                                                                                     Equipment    Finnegan model  5100 GC/MS/DS system
                                                                                     Data  system:   SUPERINCOS Autoquan
                                                                                     Mode.   Electron  impact
                                                                                     NBS  library available
                                                                                     Interface  to MS  -  Jet separator

                                                                                  •The  column used was  an 8-ft.  x  0  1  in   ID  glass,
                                                                                     packed  with 1% SP-1000  on Carbopack  E  (60 'yo mesh)

                                                                                  •The  samples  were analyzed using the purqe  end trap technique

-------
       1901g
                                                                           Table  B-3    (Continued)
          Analysis
SW-846
method
Sample
preparation
method
Alternatives or equivalents
   allowed in SW-846 for
 equipment or in procedure
                                                                                          Specific equipment or procedures Used
                                                      Recommended GC/MS operating conditions
                                                                                   Actu.il  GC/MS  operating conditions
       Gas Chromatography/
         Mass Spectrometry
         for semivolati le
         organics: capillary
         column technique
  8270   3520-Liquids
rv
o
en
             Mass range
             Scan time
             Initial  column temperature'
             Initial  column holding time.
             Column temperature program'

             Final column temperature hold
                                                      Injector temperature
                                                      Transfer line temperature
                                                      Source temperature
                                                      Injector
                                                      Sample volume
                                                      Carrier gas
                35-500 amu
                1 sec/scan
                40"C
                4 mm
                40-270'C at
                10'C/min
                ?70'C  (until
                benzofg.h, i ,]perylene has
                fluted)
                250-300*C
                250-300°C
                According to
                "Mnuf ac t urer ' s
                •-pec if icat ion
                broh-type, splitless
                1-2 uL
                Hvdrogen at 50 cm/sec or
                he 1 lum at 30 cm/sec
                                                      • The column should be 30 m by 0 ?5 mm I  D ,  1-um film
                                                        thickness s licon-ooated fused silica capillary column
                                                        (J&W Scientific  DB-5 or equivalent)
                                 35 - 5CO an-u
                                 1 sec/scan
                                 30'C
                                 4 mm
                                 8'C/mir to 275 '
                                 and 10'C/m"i until
                                 305'C
Final column temperature hold:   305 C
Mass range
Scan time
Initial column temperature
Initial column holding time
Column temperature program
                                                                                   injector  temperature:
                                                                                   Transfer  line  temperature'
                                                                                   Source  temperature
                                                                                   1 •' iec to1"
                                                                                   Sample  volume
                                                                                   Carrier aas
                                                                                                          240-2GC'C
                                                                                                          300 C
                                                                                                          Manufact jre' 's
                                                                                                          recomTerid^t ion
                                                                                                          (non-heate;')
                                                                                                          Grch-1 ,v.-.  -sit less
                                                                                                          1  ul  o'  ' A~\  e extract
                                                                                                          Hel urn  k  £C  c'T'sec
       Metals
                                                                                     cicitional  Information  on Actual  Syste1" _;-r'
                                                                                      Fquipment    Finnegan  model  5100 GC''M> 3j  system
                                                                                      Software  Package    SUPERINCOS AUTOQU^N

                                                                                      The  column  used was a 30 m  x  0  32  rrm ]  D
                                                                                      Rl.  -5  (5/-  phenyl  methyl silicone) FSC',
       Inductively coupled
6010
               Operate  equipment  following  instructions
               provided by  instrument's  manufacturer
                                                                                  • Equipment operated  using  procedures  spe.'fied
                                                                                      in  the  Jarrell  Ash (JA)  1140  Operator's  Manual
                                                        For  operation  with  organic  solvents,
                                                        auxilliary  argon  gas  inlet  i •. recommended
                                                                                   • Auxiliary  argon  gas was  not  required  'c"  S
                                                                                     11' 11 r i x

-------
1900g
                                      Table B-4   Matrix  Spike  Recoveries  used to Calculate Correction lactori, for
                                                K086 Solvent Wash Scrubber Water Organic Concentrations
Sample Qjplicate Ac<
BOAT List Original
Constituent amount found
Ug/i)
Volat i 1e Orqanics
1. 1-Dichloroethane
Trichloroethene
Chlorobenzene
Toluene
Benzene
Other volatile organics
Semivolat i 1e Orqanics
Base/Neutrals
1 ,2 , 4 -Tri chlorobenzene
Acenaphthene
2 , 4-0 in i trotoluene
Pyrene
N-Nitrosodi-n-propylamine
1 , 4 -Di chlorobenzene
Other base/neutral
semivolatile organics
Acids
Pentachlorophenol
Phenol
2-Chlorophenol
4-Chloro-3-methyl phenol
4-Nitrophenol
Other acid semivolatile
organics

ND
ND
ND
ND
ND



ND
ND
ND
ND
ND
ND



ND
ND
ND
ND
ND


Amount
spiked
Ug/i)

50
50
50
50
50



100
100
100
100
100
100



200
200
200
200
200


Amount
recovered
Ug/l)

37
49
50
48
42



36
61
75
92
85
42



167
169
157
161
173


Percent Amount
Recovery" recovered
Uq/1)

74 36
98 53
100 53
96 49
84 42
90.4 (average)


36 -1
61 r7
75 r\
92 c-">
85 c'
42 ;i,

65 2 (averaae)

83 139
84 1 V-i
79 14«
81 169
87 165

82 8 (averaae)
Percent coi
recovery* 1

72
106
106
98
84
93 2 (average)


31
57
81
94
83
36

63 7 (average)

70
79
74
85
83

78 2 (averaae)
:uracy
rrect ic-
Factor' '

1 39
1 02
1 CD
1 C4
i r-
1 i!


3 21
1 7r
i :-:
1 C°
1 23
2 7r

1 C-'

1 "'
1 'll
1 '^
\ 7-
1 <~C

1 2t
*Percent Recovery =  [(Spike Result  -  Original  Amount)/Spike Added]
"Accuracy Correction  Factor =  100/Percent  Recovery  (using the  lowest percent  recovery values)

Reference   USEPA  1987a

-------
        1900g
                                               Table B-5  Matrix Spike Recoveries Use,I  to Calculate Correction Factors for the
                                                           Envirite Wastewater and  TCLP  Extract  Metal  Concentrations
re
Sample
Constituent
Antimony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai 1 lum
Zinc
Original
Ug/
<21
<10
1,420
1
4
<10
<4
<4
<5
'0
203
<25
<4
<10
sample
1)



4
2

0
0
0
2


0

2.640
Spike added
Ug/i)
300
50
5,000
25
25
50
50
125
25
1 0
1,000
25
50
50
10,000
Spike result
275
70
5.980
25
26
53
35
107
22
0 rj
1.140
12
42
51
12,600
Percent
recovery*
92
140
91
94
87
106
70
86
88
90
94
48
84
102
100
Dupl icate
Spike result
276
66
'..940
24
27
54
?-
104
19
1 1
1 , 12H
•?r>
-•<$
4K
12.400
Percent
recovery*
92
132
90
90
91
108
68
83
76
110
93
NC
76
96
98
Accuracy
Correct ion
factor"
1
0
1
1
1
0
1
1
1
1
1
2
1
1
1
09
76
11
11
IS
94
•"
20
31
11
Od
C6
32
G-
°'
         *Percent  recovery  =  [(Spike  Result  - Original Amount)/Spike Amount] x 100
         "Accuracy  Correction  Factor =  100/Percent Recovery (using the lowest percent recovery values)

         Reference   USEPA  1987c

-------
1900g
                      Table B-6  Matrix Spike Recoveries  Used to Calculate Correction  Factors
                                for the Envirite Filter Cake Organic Detection  Limits
Const ituent
Volat lies
Toluene-8
Bromof luorobenzene
1 ,2-Dichloroethane
Other volatile organics
Semwolat i les
Base/neutrals
Nitrobenzene-ri5
2-F luorobiphen> 1
Terpheny l-d!4
Other base/ neutral semi
volflt i le organ ics
Acids
Phenol-d5
2-Fluorophenol
2,4 , 6-Tr ibromophenol
Other acid semwolatile
organics
Original amount
found Ug/1)
NO
ND
ND



ND
ND
HD
-


ND
ND
ND


Spike added
(/«g/D
50
50
50



100
100
100



200
200
200


Spike result
(/
-------
1900g
                                         Table B-7  Accuracy-Corrected Envir .te Metals Data for Treated Wa'tewater
                                            from Chromium Reduction, Lime Precipitation and Sludge filtration
Constituent
Antimony
Arsenic
Barium
Beryl lium
Cadmium
Chromium (hexavalent)
Chromium (Total)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai 1 lum
Zinc
Correct ion
factor
1 09
0.76
1.11
1.11
1.15
0 94
1 47
1 20
1 31
1.11
1 08
2 08
1.33
1 04
1 0?
Accuracy -corrected
Accuracy-corrected concentration* (mg/1) average
Sample Set # concentration
123456789 10 11
(No substantial treatment)
(No substantial treatment)
<1.1 '11 <3 9 <11 <1 1 <1 1 '11 <1 1 '11 <1.1 <1.1
(No substantial treatment)
<0.57 '0.57 <0 57 <5.7 <0 57 '0 57 '0 57 --C 57 <0.57 <0.57 <5.7
0 010 0 179 ** 0 040 0 055 ** 0 114 -c 009 0 039 0 100 '0 009
0.176 0 176 0 294 0 147 0 162 0 147 P 176 C 221 0 147 0 176 0 265
0 253 0 181 0 253 0 084 0 169 0 145 0 193 C 193 0 096 0 169 0 289
'0013 <0.013 '0013 <0.013 '0013 '0013 '0013 -0013 '0.013 <0 013 <0 013
(No substantial treatment)
0.355 0 355 0 355 0 355 0 333 0 355 0 430 0 387 0 355 0 355 0.419
(No substantial treatment)
(No substantial treatment)
(No substantial treatment)
0 128 0 117 0 143 1.653 0 128 0 097 0 117 0 133 0 061 0.071 0 102
(mg/1)


'„

-5 7
0 56
0 19
0 18
-0 013

0 37



0 25
 *  Accuracy-corrected  concentration =  (uncorrected concentration presented in Table 3-2) x (roirp-tm-i 'ac
"  fnnrpntrat inn  rnuld not  hp measured because of analytical interference

-------
1900g
                                         Table B-8   Accuracy-Corrected  Envirite  Metals  Data  for  Fillet  Cake-
                                                          from  Lime  Stabilization  and Sludge Filtration
BOAT list
constituent
Arsenic
Barium
Cadmium
Chromium (Total)
Lead
Mercury
Selen ium
ro
c
Silver
Correct ion
factor
0.76
1.11
1.15
1 47
1.31
1.11
2 08
1.33
Accuracy-corrected concentration"1 (mo/1)
Sample Set f
123456789 10
(No substantial treatment)
0.255 0 31 0.50 <0 11 <0 83 <0 11 0 20 0 12 0 22 0 33
<0.023 <0.023 <0.023 <0.023 <0 023 <0 023 '.0 023 <0 023 <0 023 <0.023
<0.074 0 074 <0 074 0 10 '0 074 <0.074 -0 074 --0 074 <0 074 <0 074
<0.13 <0 13 <0 13 <0 13 <0 13 <0 13 <0 13 -9 13 <0 13 <0 13
(No substantial treatment)
(No substantial treatment)
(No substantial treatment)
Accuracy-corrected
average
concept rat ion
11 (rog/1)

0 31 0 30
<0.023 <0 023
<0 074 0 076

-------
1900g
                                          Table B-9  Accuracy-Corrected Organic Concentrations foi tn
                                                     Filter Cake and K086  Solvent  Wash  Scrubber Water
BOAT list
Const ituent
Volatile Orqamcs
Acetone
n-Butyl alcohol
Ethyl acetate
Ethyl benzene
Methanol
Methyl isobutyl ketone
Methyl ethyl ketone
Methylene chloride
Toluene
1 , 1 , 1-Trichloroethane
Trichloroethy lene
Xylene (total)
Semivoleti 1e Organic
Bis(2-ethyl hexy 1 )phtha late
Cyc lohexanone
1 ,2-Dichlorobenzene
Naphthalene
Nitrobenzene
K086 Solvent
Correction
factor

1.11
1.11
1.11
1.11
1 11
1 11
1.11
1 11
1 04
1.11
1.02
1 11

1 57
1 57
1 57
1.57
1.57
Wash Scrubber Water
Accuracy-corrected
Concentrat ion*
(mg/1)

0.0055
0 Oil
0.011
0 0055
0 Oil
0.011
0.011
0.011
0.010
0 Oil
0 010
0 Oil

0 016
0.0078
0 016
0 016
0.016

for rec t ion
factor

1 11
1 11
1 11
1 11
1 11
1 11
1 !1
1 1!
1 11
1 11
1 :1
1 11

1 4f
1 Ji
1 .46
1 46
1 1C
Fi Her Cake
Accuracy-corrected
concentrat ion**
(mg/1)

0.13
0.13
0 13
0.011
0.13
0 13
0.13
0.13
0.011
0 016
0.011
0 0055

0 Ib
0 16
0 18
0.18
0 18
 'Accuracy-corrected concentration = (highest  detection  limit  present  in  Table  3-1)  y  (correction  'ertor)
"Accuracy-corrected concentration =  (highest  detection  limit  present  in  Tab
tot )

-------
APPENDIX C
      21?

-------
                                Appendix C







                         Detection Limits for the



                        K086 Scrubber Water  Samples







    The detection limits for the analyses of the K086 solvent  wash



samples have been classified as confidential  by  the  generator.   The



detection limits for analyses of the scrubber effluent water samples  are



1isted on Table C-l.
                                      213

-------
1015g
                     Table C-l   Detection Limit1-, tor tin SLT-UI.U" fffluent Wdter
BOAT
reference
no

222
1
2
3
4
5
6
• -> i
1
ti
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
33
228
34
229
35
Constituents (units)
BOAT Volatile Orqanics (mq/1)
Acetone
Acetomtr i le
Acrolein
Aery Ion it r i le
Benzene
bronioU ich loroinethdne
Bromometnane
n-But y 1 a Icohol
Carbon tetracn lor \cie
Carbon disulfiae
Chlorobenzene
2-Chloro-l ,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroet hy 1 vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 , 2-Dibromo-3-chloropropane
1 , 2-Dibromoethane
Dibromomethane
Trans-1 ,4-dichloro-2-butene
Dichlorod if luoromethane
1 , 1-Dichloroethane
1 , 2-Dichloroethane
1 , 1-Dichloroethylene
Trans-1 ,2-dichloroethene
1 , 2-Dichloropropane
Trans-1 , 3 -dich loropropene
cis-1 , 3 -Dich loropropene
1 ,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethy Ibenzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Scrubber effluent
water sample #1
detect ion 1 imits

0 005
0 200
0 200
0 2CG
o o;:
G C1C
o cro
NL
G oic
0 010
0 010
0 200
0 010
0 020
0 0?0
0 010
0 020
0 200
0 020
0 010
0.010
0 200
0.020
0 010
0 010
0 010
0.010
0 010
0.010
0.010
0 400
NL
NL
0 005
0 200
NL
0.200
NL
0.100
0 400
NL
0.010
0.010
0.200
icrubber ef f luent
water sample 12,
*3, *4 #5, and 16
detection limits

0 005
0 100
0 100
0 ICO
0 Gj5
0 00 1
0 010
NL
0 OCfj
0 005
0 005
0 100
0 005
0 010
0 010
0 005
0 010
0.100
0.010
0 005
0.005
0 100
0.010
0.005
0.005
0 005
0.005
0 005
0.005
0.005
0 200
NL
NL
0 005
0.100
NL
0 100
NL
0.050
0 200
NL
0 010
0.010
0 100
                                                         214

-------
lG15g
                                            T.ti.lc
                                                        (LOM!
   BOAT
reference
   no
Constituents (units)
Scrubber effluent
water sample *1
detect ion 1 units
Scrubber et t luent
water sample ttZ,
#3. «<4,  ?5.  and »
detection limits
          BOAT Volatile Orqanics (mq/1) (continued)
   36     Methyl methanesu Itonate                   0 400
   37     Metnylacrylonitrile                       0 ,00
   38     Methylene chloride                        0 110
  23C     2-Nitropropane                            NL
          P> i id ;:ie                                  C cJO
   -1C     1,1,1,2-Tetrachloroethane                 0
   •ij     1, 1 ,2,2-Tetrachloroethane                 0
   4.'     let rdcnloroethene                         C
   4j     Toluene                                   0
   J-I     Tr i oroinomethane                           0
   45     1,1,1-Trichloroethane                     0010
   47     1,1,2-Trichloroethane                     0010
   4b     Trichloroetnene                           0 010
   4:i     Tr ichloromonof Iuoromethane                0 010
  231     1 , 1 ,2-tnchloro-l  ,2,2-tnf luoroethane     NL
   r.C     1 , L , 3-Tr ich loropropane                    0 210
          Vinyl chloride                            0 C20
  215     l,2-X>lene                                0 005
  216     1,3-Xylene                                0 005
  217     1,4-Xylene                                0 005
                                                                  0 200
                                                                  0 100
                                                                  0 005
                                                                   NL
                                                                  0 400
                                                                  0 005
                                                                  0 005
                                                                  0 OC1
                                                                  0 00;,
                                                                  0 005
                                                                  0 005
                                                                  0 005
                                                                  0 005
                                                                  0 005
                                                                   NL
                                                                  0 005
                                                                  0 010
                                                                  0 005
                                                                  0 005
                                                                  0 005
                                                         215

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1615g
                                               C i    (c^nt i
BOAT
reference
no

51
52
53
54
55
56
57
5b
59
216
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
232
Constituents (units)
BOAT Semwolatile Orqanics (mq'l)
Acenaphtha lene
Acenaphthene
Acetophenone
2-Acety laminof luorene
4 - Am i nob i phen> 1
Am 1 me
Anthracene
Araii'ii te
Ben? (a) anthracene
Benzdl chloride
Benzenethiol
Benz idine
Benzo(a)pyrene
Benzo(b)f luoranthene
Benzo(ghi Jperylene
6en;o(k)fluoranthene
p-Benzoquinone
Bis(2-chloroethoxy)ethane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromopheny 1 phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroam 1 me
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphtha lene
2-Cnlorophenol
3-Chloropropiomtri le
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
Scrubber effluent
water (all samples)
detect ion 1 imits

0 010
0 010
0 010
1 000
0 200
0 020
0 010
NA
0 010
NL
NA
1 000
0 010
0 010
0 010
0 010
NA
0.010
0.010
0 010
0 010
0.010
0.010
0.100
0 100
NA
0.010
0.010
0 010
NA
0 010
0 010
0 010
0 005
         NA = Not available
                                                      216

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1615g
                                                IL- C -1    (i out irun .!)
BOAT
reference
no

83
84
85
tfb
b/
bH
89
90
Ql
92
93
94
95
96
97
9a
99
100
101
.102
103
104
105
106
219
107
108
109
"no
111
112
113
114
Constituents (units)
BOAT Semivolat i le Orqanics (mq/1) (continued)
Dibenz(a,h)anthracene
Dibenzo(a,e)pyrene
Dibenzo(a, i )pyrene
m-Dichlorobenzene
o-D icnloroneiiZene
p-Dichlorobenzene
3,3 ' -Dicnlorobenz idine
2 ,4-Dichloropnenol
2 , 6-D ichloropheno 1
Diethyl phthalate
3,3' -Dimethoxybenzidine
p- Dimethyl am inoazobenzene
3,3 '-Dimethylbenzidme
2 ,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1 ,4-Dinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2 ,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
D i - n - propy 1 n i t rosam i ne
Diphenylamine
Diphenylnitrosamine
1 ,2-Diphenylhydrazme
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyc lopentadiene
Hexachloroethane
Hexachlorophene
Scrubber effluent
water (all samples)
detection limits

0.010
NA
0 050
0 010
0 QIC
0 CIO
0 020
0 010
NA
0 01C
10 000
0.200
NA
0 010
0 010
0 010
0 100
0 050
0 050
0 010
0 010
0 010
0.010

0 010
0 010
0.010
0.010
0.010
0.010
0 010
0 010
NA
           NA = Not avai Table
                                                          217

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1615Q
                                               le C 1    (com iriuc;:)
BOAT
reference
no

115
116
117
116
119
120

in
122
123
124
125
126
127
128
129
130
131
132
.133
134
135
136
137
138
139
140
141
142
220
143
144
145
146
Constituents (units)
BOAT Semivolat i le Orqanics (mq/1) (continued)
Hexach loropropene
Indeno( 1,2, 3-cd)pyrene
Isosaf role
Methapyr i lene
3-Methy Ichc iant hrene
4,4' -Met hy lenotiis
( 2 -chloroan i 1 me)
Naphtha lene
1 , 4-Naphthoqu mone
1 -Naphthy lamme
2-Naphthy lamme
p-Nitroani 1 me
N itrobenzene
4-Ni t rophenoi
N-Nitrosodi-n-butylamme
N-Nitrosodiethy lamme
N-N i trosod ime thy lam ine
N-Nitrosomethylethy lamme
N-Nitrosomorphol me
N-Nitrosopiperidme
n-Ni trosopyrrol id me
5-Nitro-o-toluidme
Pentachlorobenzene
Pentachloroethane
Pentachloronltrobenzene
Pentachlorophenol
Phenacet in
Phenanthrene
Phenol
Phthalic anhydride
2-Picol me
Pronamide
Pyrene
Resorcmol
Scrubber effluent
water (all samples)
detection limits

NA
0 010
0 100
NA
c i:c

0 200
0 GIG
NA
0 100
0 100
0 050
0 010
0 050
NA
NA
0 100
0 100
0 200
0.200
0.200
0 200
NA
NA
0.100
0.050
0.100
0.010
0 010
NL
0 100
NA
0 010
NA
          NA = Not ava i lable
                                                      218

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1615g
BOAT
reference
no.

147
148
149
150
151
152
155


154
155
156
157
15«
159
221
160
.161
162
163
164
165
166
167
168

169
170
171
Constituents (units)
BOAT Semwolatile Orqanics (mq/1) (continued)
Saf role
1,2,4, 5-Tetrachlorobenzene
2,3, 4,6-Tetrach lorophenol
1 , ?, 4-Tr ichlorobenzene
2 , 4 , 5-Tr ichloropheno 1
2,4, 6-Trich lorophenol
T r i s ( 2 , 3-d i bromopropy 1 )
phosphate
BOAT Metals (mq/1)
Ant imony
Arsenic
Barium
Bery 1 1 lum
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
S i Iver
Tha 1 1 lum
Vanadium
Z me
BDAT Inorganics (mq/1)
Cyanide
F luor ide
Sulf ide
Scrubber effluent
water (all samples)
detection limits

0 100
0 010
NA
C 010
0 050
0 010

NA

0 032
0 010
0 001
0 001
0 004
0.007
0 010
0 006
0 005
0 0002
0 Oil
0 005
0 006
0 010
0 006
0 002

0 010
0 2
0 5
         NA = Not available
                                                    219

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1615g
                                           Idlj le C  1    (corit inuei.:)
   BOAT                                                                   Scrubber  effluent
reference                                                                 water  (all  samples)
   no          Constituents (units)                                       detection limits
          BOAT PCBs (rnq/1)

  200     Aroclor 1016                                                              0 0015
  201     Aroclor 1221                                                              0 0015
  202     Aroclor 1232                                                              0 0015
  203     Aroclor 1242                                                              0 0015
  2C4     Aroclor 124o                                                              C Gui,
  205     Aroclor 1254                                                              0 0015
  206     Aroclor 1260                                                              0 0015

          BOAT R'o.ins/Furans (mq'1)

  207     hexachlorodibenzo-p-dioxins                                               0 1
  208     Hexachlorodibenzofuran                                                    0 04
  209     Pentachlorodibenzo-p-dioxins                                              0 11
  210'    Pentachlorodibenzofuran                                                   0 05
  211     Tetrachlorodibenzo-p-dioxins                                              0 1
  212     Tetrachlorodibenzofuran                                                   0 04
  213     2,3,7,8-Tetrachlorodibenzo-p-dioxin                                       0 13

          Other Analyses  (mq/1)

          Iron                                                                      0 006
          Magnesium                                                                 0.001
          Manganese                                                                 0 003
          Titanium                                                                  0 003
          Chloride                                                                   1 000
          Total solids                                                               1 000
          Total organic carbon                                                       1.000
          Total organic halides                                                      0 010
           Reference   USEPA  1987a
                                                           220

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APPENDIX D
     221

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                                 Appendix D
               METHOD OF MEASUREMENT FOR THERMAL CONDUCTIVITY
    The comparative method of measuring  thermal  conductivity  has  been
proposed  as  an ASTM test method  under  the  name  "Guarded, Comparative,
Longitudinal Heat Flow  Technique."  A  thermal heat  flow circuit  is  used
which is  the analog of  an electrical circuit with resistances  in  series.
A reference  material  is chosen to have a thermal conductivity  close to
that estimated for the  sample.   Reference  standards  (also known  as  heat
meters) having the same cross-sectional dimensions  as the sample  are
placed above and below  the sample.  An upper heater, a lower  heater, and
a heat sink  are added to the "stack" to complete the heat flow circuit.
See Figure 1.
    The temperature gradients (analogous to potential differences)  along
the stack are measured with type K  (chromel/alumel) thermocouples placed
at known  separations.  The thermocouples are placed into holes or grooves
in the references and also in the sample whenever the sample  is thick
enough to accommodate them.
    For molten samples,  pastes,  greases, and other materials that must be
contained, the material  is placed into a cell consisting of a top and
bottom of Pyrex 7740 and a containment ring of marinite.   The sample is 2
inch in diameter and .5 inch thick.   Thermocouples are not placed into
the sample but rather the temperatures measured in the Pyrex are
extrapolated to give the temperature at the top and bottom surfaces of
the sample material.   The Pyrex  disks also serve as the thermal
conductivity reference material.
                                      222

-------
   GUARD
GRADIENT.
   STACK
GRADIENT-
                                                          o,
               THERMOCOUPLE
                                           CLAMP
                             UPPER STACK
                                HEATER
                            TOP  REFERENCE
                                SAMPLE
                                   J
TESTySAMPLE
  BOTTOM
REFERENCE
  SAMPLE
                                   I
                             LOWER STACK
                               HEATER
                            LIQUID 'COOLED
                              HEAT SINK
HEAT FLOW
DIRECTION
                                Figure 1.

                    SCHEMATIC DIAGRAM OF THE COMPARATIVE METHOD
                                UPPER
                                GUARD
                                HEATER
                                LOWER
                                GUARD
                                HEATER
                                    223

-------
    The  stack  is clamped with a reproducible  load to ensure  intimate

contact  between the components.   In order to  produce a linear flow of

heat down the  stack and reduce the amount of  heat that flows radially, a

guard tube  is  placed around the stack and the  intervening space is filled

with insulating grains or powder.  The temperature gradient  in the guard

is matched  to  that in the stack to further reduce radial heat flow.

    The  comparative method is a steady state method of measuring thermal

conductivity.  When equilibrium is reached the heat flux (analogous to

current  flow)  down the stack can be determined from the references.  The
heat into the  sample is given by

                           Q.  =  A    (dT/dx)
                             in    top        top
and the  heat out of the sample is given by
                        Q
                         out = AL     (dT/dx)
                                bottom       bottom
where

                         x - thermal conductivity

                       dT/dx = temperature gradient

and top refers to the upper reference while bottom refers to the lower
reference.   If the heat were confined to  flow just  down  the  stack,  then

Q   and Q    would be equal.   If Q   and Q    are in reasonable
 in      out                      in      out
agreement,  the average heat flow is  calculated from

                            Q =  (Q.  + Q  J/2
                                  in    out
The sample  thermal  conductivity is then  found from

                         \        = Q/(dT/dx)     .
                          sample             sample
                                     224

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APPENDIX E
     225

-------
                                APPENDIX E







       Organic Detection Limits for K086 Solvent Wash Nonwastewaters





    Since the Agency does not have treatment data for K086 solvent wash



scrubber waters,  organic detection limits for the filter cake generated



specifically from chromium reduction followed by chemical  precipitation



and sludge filtration of the K086 solvent wash scrubber waters are not



available.  However, EPA does have organic detection limits for wastes



that the Agency believes are sufficiently similar to K086 solvent wash



filtered precipitate.



    The data consist of organic detection limits for 15 chemically



precipitated wastes.  These data are shown  in Table E-l.  The highest



detection limit has been selected as the level for each regulated organic



constituent.   In the cases of n-butyl alcohol, ethyl acetate, methanol,



methyl  isobutyl ketone, methyl ethyl ketone, bis(2-ethylhexyl)phthalate,



cyclohexanone, 1,2-dichlorobenzene, naphthalene, and nitrobenzene where



no detection  limits were reported, the  overall highest  level  of detection



(i.e,  120 ug/1) has been selected as the detection limit  for  those



constituents.
                                     226

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       1839g
                                                   Table E-l  Organic  Detection  Limits  for  Envrite  Filter  Cake Rf, id.ji I1:
                                                               from Lime  Stabilization and Sludge Filtration
ro
ro
—i
BOAT list
constituent
Volatile orqanics
Acetone
n-Butyl alcohol
Ethyl acetate
Ethyl benzene
Methanol
Methyl isobutyl ketone
Methyl ethyl ketone
Methylene chloride
Toluene
1 , 1 , 1-Tr ichloroethane
Tr ichloroethylene
Xylene (total)
Semivolatile orgamcs
Bis(2-ethylhexyl)phthalate
Cyclohexanone
1 ,2-Dichlorobenzene
Naphthalene
Nitrobenzene
Determined
Total concentration (ug/1) level of
Sample Set # ' detection
1 2 34 5 6 7 8 9 10 11 12 13 14 IS (uq/1)

79 84 - 120 120 120 12C
120
120
32- - - - - 10 34- 49 - 48 10
120
120
120
8.6 8 9 7 1 7 9 8 2 - - 798310 8 4 * ? 12 12 12 12
2 8 3 2 3 3 - - - 1C 3 4 - 49 - 46 10
14 3 2 - - - 1C -• 4 49 - - 14
3.4- 28323332- - - 1C - 49 49 40 10
32----- - 4r-t- - 49

120
120
120
120
120
        -  =  No detection  limit  reported
        Reference    USEPA    1986a

-------
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Castaldini C., et al., Disposal of Hazardous Wastes in Industrial Boilers
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                                      229

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Mitre Corp.  Guidance Manual for Hazardous Waste Incinerator Permits
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                                      230

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USEPA.   1983,
  Control/Removal
  pp 111.3.1.3-2.
Treatabllity Manual,  Volume III, Technology for
                   EPA-600/2-82-001C, January 1983,
of Pollutants.
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USEPA.   1987a.  Onsite Engineering Report  of  Treatment Technology
  Performance and Operation for Incineration  of K086 Solvent Wash Waste
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   Station,  Vicksburg,  Mississippi  for K048 and K051.

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