&EPA United States Environmental Protection Agency Office of Solid Waste Washington, D C 20460 EPA/530-SW-88-0009-I April 1988 Solid Waste Best Demonstrated Available Technology (BOAT) Background Document for K037 Proposed Volume 9 ------- PROPOSED BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT) BACKGROUND DOCUMENT FOR K037 U.S. Environmental Protection Agency Office of Solid Waste 401 M Street, S.W. Washington, D.C. 20460 Jim R. Berlow, Chief Lisa Jones Treatment Technology Section Project Manager April 1988 U.S. Environmental Protection Agency Region 5, Library (PL-12J) 77 West Jackson Boulevard, 12th floor Chicago. II 60604-3590 ------- TABLE OF CONTENTS VOLUME I Page No. Executive Summary vi BOAT Treatment Standards for K037 vi i SECTION 1. INTRODUCTION 1 1.1 Legal Background 1 1.1.1 Authori ty Under HSWA 1 1.1.2 Schedule for Developing Restrictions 4 1.2 Summary of Promulgated BOAT Methodology 5 1.2.1 Waste Treatability Group 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 SECTION 2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 46 2.1 Industry Affected and Process Description 46 2.2 Waste Characterization 48 SECTIONS. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES .. 52 3.1 Applicable Treatment Technologies 52 3.2 Demonstrated Treatment Technologies 53 3.2.1 Incineration 54 3.3 Performance Data 73 SECTION 4. IDENTIFICATION OF BEST DENONSTRATED AVAILABLE TECHNOLOGY FOR K037 81 4.1 Data Screening 82 4.2 Data Accuracy 82 i i ------- TABLE OF CONTENTS (continued) Page No. SECTION 5. SELECTION OF REGULATED CONSTITUENTS 84 5.1 Identification of Constituents in the Untreated Waste 84 5.2 Comparison of Untreated and Treated Waste Data for the Major Constituents 92 5.3 Selection of Regulated Constituents 94 SECTION 6. CALCULATION OF BOAT TREATMENT STANDARD 95 SECTION 7. CONCLUSIONS 97 APPENDIX A STATISTICAL METHODS 102 APPENDIX B ANALYTICAL QA/QC 115 APPENDIX C DETECTION LIMITS FOR K037 UNTREATED AND TREATED SAMPLES 120 APPENDIX D METHOD OF MEASUREMENT FOR THERMAL CONDUCTIVITY . 129 REFERENCES 132 ------- LIST OF TABLES Table 1-1. Table 2-1. Table 2-2. Table 3-1. Table 3-2. Table 3-3. Table 3-4. Table 3-5. Table 3-6. Table 5-1. Table 5-2. Table 6-1, Table 7-1. Table B-l. Table B-2. Table B-3. 1 BOAT Constituent List Constituent Analysis of Untreated K037 Waste BOAT List Constituent Concentration and Other Data Rotary Kiln Incineration/EPA Collected Data: Sample Set #1 Rotary Kiln Incineration/EPA Collected Data: Sampl e Set #2 Rotary Kiln Incineration/EPA Collected Data: Sampl e Set #3 Rotary Kiln Incineration/EPA Collected Data: Sampl e Set #4 Rotary Kiln Incineration/EPA Collected Data: Sampl e Set #5 Rotary Kiln Incineration/EPA Collected Data: Sampl e Set #6 BOAT Constituents Detected or Not Detected in the K037 Waste Sampl es BOAT Constituents and Their Concentrations in Untreated Waste and Treatment Residues Regulated Constituents and Calculated Treatment Standards for K037 BOAT Treatment Standards for K037 Analytical Methods for Regulated Constituents .. Matrix Spike Recoveries for K037 Treated Solids- EPA-Col 1 ected Data Matrix Spike Recoveries for K037 Scrubber Waste Sample - EPA-Coll ected Data Paqe No 18 50 51 75 76 77 78 79 80 85 93 96 98 116 117 118 ------- LIST OF FIGURES Page No. Figure 2-1. Production and Waste Schematic for Disulfoton .. 47 Figure 3-1. Liquid Injection Incinerator 58 Figure 3-2. Rotary Kiln Incinerator 59 Figure 3-3. Fluidized Bed Incinerator 61 Figure 3-4. Fixed Hearth Incinerator 62 ------- EXECUTIVE SUMMARY BOAT Treatment Performance Standards for K037 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 Act Recovery and (RCRA), treatment standards have been proposed based on the treatment performance of the Best Demonstrated Available Technology (BOAT) for the listed waste identified in 40 CFR part 261.32 (the Code of Federal Regulations) as K037 (wastewater treatment sludge from the production of disulfoton). Wastes designated as K037 must meet the standards prior to disposal in units designated as land disposal units according to 40 CFR Part 268. Standards have been established for disulfoton and toluene based on performance data using a rotary kiln incinerator. When treating K037 wastes with incineration, scrubber water and an ash residual are generated, so standards for both wastewaters and nonwastewaters have been developed. For the purpose of this proposed land disposal restrictions rule, wastewaters are defined as wastes containing less than 1 percent (weight basis) filterable solids and less than 1 percent (weight basis) total organic carbon (TOC). Nonwastewaters are waste forms containing greater than 1 weight percent filterable solids or greater than one weight percent total organic carbon. VI ------- The standards are established based on analyses conducted on the total constituent concentrations found in the treated waste residuals (i.e., ash and scrubber water). These standards become effective as of August 8, 1988, as per the schedule set forth in 40 CFR 268.10. The following table lists the specific BOAT standards for K037 wastes that have undergone treatment using a rotary kiln incinerator. The units for the total waste concentration are mg/kg (parts per million on a weight-by-weight basis). Testing procedures are specifically identified in Appendix B (QA/QC Section) of this background document. VII ------- BOAT Treatment Performance Standards K037 Organic constituents Total waste concentration Nonwastewater Wastewater (mg/kg) (mg/1) Toluene 28 0.028 Disulfoton 0.10 0.003 vm ------- 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), 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 ------- 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. ------- 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 ------- 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: (a) Solvents and dioxins standards must be promulgated by November 8, 1986; (b) The "California List" must be promulgated by July 8, 1987; (c) At least one-third of all listed hazardous wastes must be promulgated by August 8, 1988 (First Third); (d) At least two-thirds of all listed hazardous wastes must be promulgated by June 8, 1989 (Second Third); and (e) All remaining listed hazardous wastes and all hazardous wastes identified as of November 8, 1984, by one or more of the characteristics defined in 40 CFR Part 261 must be promulgated by May 8, 1990 (Third Third). ------- The statute specifically identified the solvent wastes as those covered under waste codes F001, F002, F003, F004, and F005; it identified the dioxin-containing hazardous wastes as those covered under waste codes F020, F021, F022, and F023. Wastes collectively known as the California List wastes, defined under Section 3004(d) of 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, .11, and .12. 1.2 Summary of Promulgated BOAT Methodology In a November 7, 1986, rulemaking, EPA promulgated a technology-based approach to establishing treatment standards under section 3004(m). Section 3004(m) also specifies that treatment standards must "minimize" long- and short-term threats to human health and the environment arising from land disposal of hazardous wastes. ------- Congress indicated in the legislative history accompanying the HSWA that "[t]he requisite levels of [sic] methods of treatment established by the Agency should be the best that has been demonstrated to be achievable," noting that the intent is "to require utilization of available technology" and not a "process which contemplates technology-forcing standards" (Vol. 130 Cong. Rec. S9178 (daily ed., July 25, 1984)). EPA has interpreted this legislative history as suggesting that Congress considered the requirement under 3004(m) to be met by application of the best demonstrated and achievable (i.e., available) technology prior to land disposal of wastes or treatment residuals. Accordingly, EPA's treatment standards are generally based on the performance of the best demonstrated available technology (BOAT) identified for treatment of the hazardous constituents. This approach involves the identification of potential treatment systems, the determination of whether they are demonstrated and available, and the collection of treatment data from well-designed and well-operated systems. The treatment standards, according to the statute, can represent levels or methods of treatment, if any, that substantially diminish the toxicity of the waste or substantially reduce the likelihood of migration of hazardous constituents. Wherever possible, the Agency prefers to establish BOAT treatment standards as "levels" of treatment (i.e., performance standards) rather than adopting an approach that would require the use of specific treatment "methods." EPA believes that concentration-based treatment levels offer the regulated community greater ------- flexibility to develop and implement compliance 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 ------- 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 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 ------- 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 ------- 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 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: (a) Number and types of constituents treated; (b) Performance (concentration of the constituents in the treatment residuals); and (c) Percent of constituents removed. If none of the demonstrated treatment technologies achieve substantial treatment of a waste, the Agency cannot establish treatment standards for the constituents of concern in that waste. 1.2.3 Collection of Performance Data Performance data on the demonstrated available technologies are evaluated by the Agency to determine whether the data are representative 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: (a) identifi- cation of facilities for site visits, (b) engineering site visit, (c) Sampling and Analysis Plan, (d) sampling visit, and (e) Onsite Engineering Report. (1) Identification of Facilities for Site Visits. To identify facilities that generate and/or treat the waste of concern, EPA uses a number of information sources. These include Stanford Research Institute's Directory of Chemical Producers, EPA's Hazardous Waste Data Management System (HWDMS), the 1986 Treatment, Storage, Disposal Facility (TSDF) National Screening Survey, and EPA's Industry Studies Data Base. In addition, EPA contacts trade associations to inform them that the Agency is considering visits to facilities in their industry and to solicit assistance in identifying facilities for EPA to consider in its treatment sampling program. After identifying facilities that treat the waste, EPA uses this hierarchy to select sites for engineering visits: (1) generators treating single wastes on site; (2) generators treating multiple wastes together on site; (3) commercial 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 why such data were used in the preamble and background document and will request comments on the use of such data. Although EPA's data bases provide information on treatment for individual wastes, the data bases rarely provide data that support the selection of one facility for sampling over another. In cases where several treatment sites appear to fall into the same level of the hierarchy, EPA selects sites for visits strictly on the basis of which facility could most expeditiously 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 (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, Appendix VII and Appendix VIII, as well as several ignitable constituents used as the basis of listing wastes as F003 and F005. These sources provide a comprehensive list of hazardous constituents specifically regulated under RCRA. The BDAT list consists of those constituents that can be analyzed using methods published in SW-846, Third Edition. 17 ------- 1521Q 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 16 19 20 21. 22 23 24 25 :B 27 2S 29 22-1 121 226 30 ?~ 7 >. t~ ' 31 214 32 Parameter Vc lat i les Acetone Acetomtri le Acrolein Acrylonitn le Benzene Bromocncn Ioromethane Bromomethane n-Butyl alcohol Carbon tetrachlonde Camon disulfide Chlorobenzene 2-Chloro-l ,3- butadiene Chlorodibromomethane Chloroeihane 2-Ch^croethyl vinyl ether Chlcrofcrm Chloromethane 3-Cnloropropene 1 , 2-Dit>romo-3-cnloropropane 1 ,2-DiDromoethane Dicromomethane Trans- 1 ,4-Dichloro-2-butene Dicnlorodif luoromethane 1 , 1-Dicnloroethane 1 ,2-Dicnloroethane 1 , i-Dicnioroethylene Trans -1 ,2-Dichloroethene 1,2-2 ichioroprcpane Trars-i , 3-Oichloropropene cis-., i-Dicnloropropene 1 , 4- j-.oxane 2-E:'ioxyethanol Etn, ' acetate Etn> "i cenrene ttr>: ;yaivJe Etr,.. ' ether Ethj " methacry late Ethvlene oxide Ic;jcTethane Cas no. 67-64-1 75-05-8 107-02-8 107-13-1 71-43-2 75-27-4 74-83-9 71-36-3 56-23-5 75-15-0 108-90-7 126-99-8 124-48-1 75-00-3 110-75-6 57-66-3 74-67-3 107-05-1 96-12-8 106-93-4 74-95-3 110-57-6 75-71-6 75-34-3 107-06-2 75-35-4 155-60-5 6-67-5 cce:-02-6 OC61-01-5 23-91-1 10-5C-5 4;-7S-e 100-41-4 iO'-lC-O 60-29-7 97-63-2 75-21-6 74-66-4 13 ------- 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 Volatiles (continued) Isobutyl alcohol Methanol Methyl ethyl ketone Methyl isobutyl ketone Methyl methacrylate Methacrylomtri le Methylene chloride 2-Nitropropane Pyridine 1,1,1, 2-Tetrachloroethane 1,1, 2 ,2-Tetrachloroethane Tetrachloroethene Toluene Tribromomethane 1, 1.1-Tnchloroethane 1,1, 2-Tnchloroethane Trichloroethene Tnchloromonof luoromethane 1,2,3-Trichloropropane l,1.2-Tnchloro-l,2,2-trif luoro- ethane Vinyl chloride 1,2-Xylene 1.3-Xylene 1,4-Xylene Semivolat i les Acenaphthalene Acenaphthene Acetophenone 2-Acetylammof luorene 4-Aminob)pheny 1 Am 1 me Anthracene Aramite Benz(a)anthracene Benzal chloride Benzenethiol Deleted Benzo(a)pyrene Cas no. 78-83-1 67-56-1 78-93-3 108-10-1 80-62-6 126-98-7 75-09-2 79-46-9 110-86-1 630-20-6 79-34-6 127-18-4 108-88-3 75-25-2 71-55-6 79-00-5 79-01-6 75-69-4 96-18-4 76-13-1 75-01-4 97-47-6 108-38-3 106-44-5 208-96-8 83-32-9 96-86-2 53-96-3 92-67-1 62-53-3 120-12-7 140-57-8 56-55-3 98-87-3 108-98-5 50-32-8 19 ------- 1521g Table 1-1 (continued) BOAT reference no. 63. 64 65. 66. 67. 68. 69. 70. 71. 72. 73. 74. 75 76. 77. 78. 79. 80. 81. 82. 232. 83 84. 85. 86. ' 87. 88. 89. 90. 91. 92. 93. 94 95 96. 97. 98 99 100. 101. Parameter Semivolatiles (continued) Benzol b)f luoranthene Benzo(ghi)perylene Benzo(k)f luoranthene p-Benzoquinone Bis(2-chloroethoxy)methane Bis(Z-chloroethyl)ether Bis(2-chloroisopropyl)ether Bis(2-ethylhexyl)phthalate 4-Bromophenyl phenyl ether Butyl benzyl phthalate 2-sec-Butyl-4,6-dinitrophenol p-Chloroani line Chlorobenzi late p-Chloro-m-cresol 2-Chloronaphthalene 2-Chlorophenol 3-Chloropropionitn le Chrysene ortho-Cresol para-Cresol Cyclohexanone D i benz( a, h) anthracene Dibenzo(a,e)pyrene Dibenzo(a, ijpyrene tn-D ich lorobenzene o-Dichlorobenzene p-Oich lorobenzene 3,3'-Dichlorobenzidine 2,4-Dichlorophenol 2,6-Dichlorophenol Diethyl phthalate 3,3' -D imethoxybenz id i ne p-D imethy lami noazobenzene 3,3'-Dimethylbenzidine 2,4-Dimethylphenol Dimethyl phthalate Di-n-butyl phthalate 1,4-Dinitrobenzene 4,6-Dinitro-o-cresol 2.4-Dimtrophenol CAS no. 205-99-2 191-24-2 207-08-9 106-51-4 111-91-1 111-44-4 39638-32-9 117-81-7 101-55-3 85-68-7 88-85-7 106-47-8 510-15-6 59-50-7 91-58-7 95-57-8 542-76-7 218-01-9 95-48-7 106-44-5 108-94-1 53-70-3 192-65-4 189-55-9 541-73-1 95-50-1 106-46-7 91-94-1 120-83-2 87-65-0 84-66-2 119-90-4 60-11-7 119-93-7 105-67-9 131-11-3 84-74-2 100-25-4 534-52-1 51-28-5 20 ------- 1521g Table 1-1 (continued) BOAT reference no. 102. 103. 104. 105. 106. 219. 107. 108. 109. 110. 111. 112. 113. 114. 115. 116. 117. 118. 119. 120. 36. 121. 122. 123. 124. 125. 126. 127. 128. 129. 130. 131. 132. 133. 134. 135. 136. 137. 138 Parameter Semivolati les (continued) 2,4-Dinltrotoluene 2,6-Oinitrotoluene Di-n-octyl phthalate Di-n-propylnitrosamine Dipheny lamine Diphenylnitrosamine 1.2-Oiphenyl hydraz i ne Fluoranthene Fluorene Hexachlorobenzene Hexachlorobutadiene Hexachlorocyc lopentadlene Hexachloroethane Hexachlorophene Hexach loropropene I ndeno ( 1 , 2 , 3 -cd ) py rene Isosafrole Methapyn lene 3-Methylcholanthrene 4,4'-Methylenebts (2-chloroani line) Methyl methanesulfonate Naphthalene 1 ,4-Naphthoquinone 1-Naphthy lamine 2-Naphthylamme p-Nitroani 1 me Nitrobenzene 4-Nitrophenol N-Nitrosodi-n-butylamme N-Nitrosodiethylamme N-Nitrosodimethy lamine N-Nitrosomethy let hy lamine N-Nitrosomorpholme N-Nitrosopipendine n-Nitrosopyrrolidme 5-Nitro-o-toluidine Pentach lorobenzene Pentachloroethane Pentachloronltrobenzene CAS no. 121-14-2 606-20-2 117-84-0 621-64-7 122-39-4 86-30-6 122-66-7 206-44-0 86-73-7 118-74-1 87-68-3 77-47-4 67-72-1 70-30-4 1888-71-7 193-39-5 120-58-1 91-80-5 56-49-5 101-14-4 66-27-3 91-20-3 130-15-4 134-32-7 91-59-8 100-01-6 98-95-3 100-02-7 924-16-3 55-18-5 62-75-9 10595-95-6 59-89-2 100-75-4 930-55-2 99-65-8 608-93-5 76-01-7 82-68-8 21 ------- ISZlg Table 1-1 (continued) BOAT reference no. 139. 140. 141. 142. 220. 143. 144. 145. 146. 147. 148. 149. 150. 151. 152. 153. 154. 155. 156. 157. 158. 159. 221. 160. 161. 162. 163. 164. 165. 166. 167. 168. 169 170. 171. Parameter Semi volat lies (continued) Pentachlorophenol Phenacetm Phenanthrene Phenol Phthalic anhydride 2-Picoline Pronamide Pyrene Resorcinol Safrole 1,2,4, 5-Tetrach lorobenzene 2,3,4, 6-Tetrachloropheno 1 1 ,2,4-Trichlorobenzene 2.4,5-Tnchlorophenol 2,4,6-Trichlorophenol Tris(2,3-dibromopropy 1} phosphate Metals Antimony Arsenic Barium Beryllium Cadmium Chromium (total) Chromium (hexavalent) Copper Lead Mercury Nickel Selenium Silver Thallium Vanadium Zinc Inorganics Cyanide Fluoride Sulfide CAS no. 87-86-5 62-44-2 85-01-8 108-95-2 85-44-9 109-06-8 23950-58-5 129-00-0 108-46-3 94-59-7 95-94-3 58-90-2 120-82-1 95-95-4 88-06-2 126-72-7 7440-36-0 7440-38-2 7440-39-3 7440-41-7 7440-43-9 7440-47-32 - 7440-50-8 7439-92-1 7439-97-6 7440-02-0 7782-49-2 7440-22-4 7440-28-0 7440-62-2 7440-66-6 57-12-5 16964-48-8 8496-25-8 22 ------- 1521g Table 1-1 (continued) BOAT reference no. 172. 173. 174. 175. 176. 177. 178. 179. 180. 181. 182. 183. 184. 185. 186. 187. 188. 189. 190. 191. 192. 193. 194. 195. 196. 197. 198. 199. 200. 201. 202 Parameter Oraanochlonne pesticides Aldnn alpha-BHC beta-BHC delta-BHC gamna-BHC Chlordane ODD DDE DOT Dieldrin Endosulfan I Endosulfan II Endnn Endrin aldehyde Heptachlor Heptachlor epoxide Isodrin Kepone Methoxyclor Toxaphene Phenoxyacetic acid herbicides 2, 4 -Dich lorophenoxyacet ic acid Si Ivex 2,4,5-T Orqanophosphorous insecticides Disulfoton Famphur Methyl parathion Parathion Phorate PCBs Aroclor 1016 Aroclor 1221 Aroclor 1232 CAS no. 309-00-2 319-84-6 319-85-7 319-86-8 58-89-9 57-74-9 72-54-8 72-55-9 50-29-3 60-57-1 939-98-8 33213-6-5 72-20-8 7421-93-4 76-44-8 1024-57-3 465-73-6 143-50-0 72-43-5 8001-35-2 1 94-75-7 93-72-1 93-76-5 298-04-4 52-85-7 298-00-0 56-38-2 298-02-2 12674-11-2 11104-28-2 11141-16-5 23 ------- 1521g Table 1-1 (continued) BOAT reference Parameter CAS no. no. PCBs (continued) 203. Aroclor 1242 53469-21-9 204. Aroclor 1248 12672-29-6 205. Aroclor 1254 11097-69-1 206. Aroclor 1260 11096-82-5 Oioxins and furans 207. Hexachlorodibenzo-p-dioxins 208. Hexachlorodibenzofurans 209. Pentachlorodibenzo-p-dioxins 210. Pentachlorodibenzofurans 211. Tetrachlorodibenzo-p-dioxins 212. Tetrachlorodibenzofurans 213. 2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746-01-6 24 ------- The initial BOAT constituent list was published in EPA's Generic Quality Assurance Project Plan, March 1987 (EPA/530-SW-87-011). Additional constituents will be added to the BOAT constituent list as additional key constituents are identified for specific waste codes or as new analytical methods are developed for hazardous constituents. For example, since the list was published in March 1987, eighteen additional constituents (hexavalent chromium, xylene (all three isomers), benzal chloride, phthalic anhydride, ethylene oxide, acetone, n-butyl alcohol, 2-ethoxyethanol, ethyl acetate, ethyl benzene, ethyl ether, methanol, methyl isobutyl ketone, 2-nitropropane, 1,1,2-trichloro-l,2,2- trifluoroethane, and cyclohexanone) have been added to the list. Chemicals are listed in Appendix VIII if they are shown in scientific studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on humans or other life-forms, and they include such substances as those identified by the Agency's Carcinogen Assessment Group as being carcinogenic. Including a constituent in Appendix VIII means that the constituent can be cited as a basis for listing toxic wastes. Although Appendix VII, Appendix VIII, and the F003 and F005 ignitables provide a comprehensive list of RCRA-regulated hazardous constituents, not all of the constituents can be analyzed in a complex waste matrix. Therefore, constituents that could not be readily analyzed in an unknown waste matrix were not included on the initial BOAT list. As mentioned above, however, the BOAT constituent list is a continuously growing list that does not preclude the addition of new constituents when analytical methods are developed. 25 ------- There are 5 major reasons that constituents were not included on the BOAT constituent list: (a) Constituents are unstable. Based on their chemical structure, some constituents will either decompose in water or will ionize. For example, maleic anhydride will form maleic acid when it comes in contact with water and copper cyanide will ionize to form copper and cyanide ions. However, EPA may choose to regulate the decomposition or ionization products. (b) EPA-approved or verified analytical methods are not available. Many constituents, such as 1,3,5-trinitrobenzene, are not measured adequately or even detected using any of EPA's analytical methods published in SW-846 Third Edition. (c) The constituent is a member of a chemical group designated in Appendix VIII as not otherwise specified (N.O.S.). Constituents listed as N.O.S., such as chlorinated phenols, are a generic group of some types of chemicals for which a single analytical procedure is not available. The individual members of each such group need to be listed to determine whether the constituents can be analyzed. For each N.O.S. group, all those constituents that can be readily analyzed are included in the BOAT constituents list. (d) Available analytical procedures are not appropriate for a complex waste matrix. Some compounds, such as auramine, can be analyzed as a pure constituent. However, in the presence of other constituents, the recommended analytical method does not positively identify the constituent. The use of high pressure liquid chromotography (HPLC) presupposes a high expectation of finding the specific constituents of interest. In using this procedure to screen samples, protocols would have to be developed on a case-specific basis to verify the identity of constituents present in the samples. Therefore, HPLC is not an appropriate analytical procedure for complex samples containing unkown constituents. (e) Standards for analytical instrument calibration are not commercially available. For several constituents, such as benz(c)acridine, commercially available standards of a "reasonably" pure grade are not available. The unavailability of a standard was determined by a review of catalogs from specialty chemical manufacturers. 26 ------- Two constituents (fluoride and sulfide) are not specifically included in Appendices VII and VIII; however, these compounds are included on the BOAT list as indicator constituents for compounds from Appendices VII and VIII such as hydrogen fluoride and hydrogen sulfide, which ionize in water. The BOAT constituent list presented in Table 1-1 is divided into the following nine groups: Volatile organics Semivolatile organics Metals Other inorganics Organochlorine pesticides Phenoxyacetic acid herbicides Organophosphorous insecticides PCBs Dioxins and furans The constituents were placed in these categories based on their chemical properties. The constituents in each group are expected to behave similarily during treatment and are also analyzed, with the exception of the metals and inorganics, by using the same analytical methods. (2) Constituent Selection Analysis. The constituents that the Agency selects for regulation in each treatability group are, in general, those found in the untreated wastes at treatable concentrations. For certain waste codes, the target list for the untreated waste may have been shortened (relative to analyses performed to test treatment technologies) because of the extreme unlikelihood of the constituent being present. 27 ------- In selecting constituents for regulation, the first step is to summarize all the constituents that were found in the untreated waste at treatable concentrations. This process involves the use of the statistical analysis of variance (ANOVA) test, described in Section 1.2.6, to determine if constituent reductions were significant. The Agency interprets a significant reduction in concentration as evidence that the technology actually "treats" the waste. There are some instances where EPA may regulate constituents that are not found in the untreated waste but are detected in the treated residual. This is generally the case where presence of the constituents in the untreated waste interferes with the quantification of the constituent of concern. In such instances, the detection levels of the constituent are relatively high, resulting in a finding of "not detected" when, in fact, the constituent is present in the waste. After determining which of the constituents in the untreated waste are present at treatable concentrations, EPA develops a list of potential constituents for regulation. The Agency then reviews this list to determine if any of these constituents can be excluded from regulation because they would be controlled by regulation of other constituents in the list. EPA performs this indicator analysis for two reasons: (1) it reduces the analytical cost burdens on the treater and (2) it facilitates implementation of the compliance and enforcement program. EPA's rationale for selection of regulated constituents for this waste code is presented in Section 5 of this background document. 28 ------- (3) Calculation of Standards. The final step in the calculation of the BOAT treatment standard is the multiplication of the average treatment value by a factor referred to by the Agency as the variability factor. This calculation takes into account that even well-designed and well-operated treatment systems will experience some fluctuations in performance. EPA expects that fluctuations will result from inherent mechanical limitations in treatment control systems, collection of treated samples, and analysis of these samples. All of the above fluctuations can be expected to occur at well-designed and well-operated treatment facilities. Therefore, setting treatment standards utilizing a variability factor should be viewed not as a relaxing of 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 ------- than one technology achieves a level of performance that represents BOAT. In such instances, the BOAT treatment standard is calculated by first averaging the mean performance value for each technology for each constituent of concern and then multiplying that value by the highest variability factor among the technologies considered. This procedure ensures that all the BOAT technologies used as the basis for the standards will achieve full compliance. 1.2.5 Compliance with Performance Standards All the treatment standards reflect performance achieved by the Best Demonstrated Available Technology (BOAT). As such, compliance with these standards only requires that the treatment level be achieved prior to land disposal. It does not require the use of any particular treatment technology. While dilution of the waste as a means to comply with the standard is prohibited, wastes that are generated in such a way as to naturally meet the standard can be land disposed without treatment. With the exception of treatment standards that prohibit land disposal, all treatment standards proposed are expressed as a concentration level. EPA has used both total constituent concentration and TCLP analyses of the treated waste as a measure of technology performance. EPA's rationale for when each of these analytical tests is used is explained in the following discussion. For all organic constituents, EPA is basing the treatment standards on the total constituent concentration found in the treated waste. EPA based its decision on the fact that technologies exist to destroy the 30 ------- various organics compounds. Accordingly, the best measure of performance would be the extent to which the various organic compounds have been destroyed or the total amount of constituent remaining after treatment. (NOTE: EPA's land disposal restrictions for solvent waste codes F001-F005 (51 FR 40572) uses the TCLP value as a measure of performance. At the time that EPA promulgated the treatment standards for F001-F005, useful data were not available on total constituent concentrations in treated residuals and, as a result, the TCLP data were considered to be the best measure of performance.) For all metal constituents, EPA is using both total constituent concentration and/or the TCLP as the basis for treatment standards. The total constituent concentration is being used when the technology basis includes a metal recovery operation. The underlying principle of metal recovery is the reduction of the amount of metal in a waste by separating the metal for recovery; therefore, total constituent concentration in the treated residual is an important measure of performance for this technology. Additionally, EPA also believes that it is important that any remaining metal in a treated residual waste not be in a state that is easily Teachable; accordingly, EPA is also using the TCLP as a measure of performance. It is important to note that for wastes for which treatment standards are based on a metal recovery process, the facility has to comply with both the total constituent concentration and the TCLP prior to land disposal. 31 ------- In cases where treatment standards for metals are not based on recovery techniques but rather on stabilization, EPA is using only the TCLP as a measure of performance. The Agency's rationale is that stabilization is not meant to reduce the concentration of metal in a waste but only to chemically minimize the ability of the metal to leach. 1.2.6 Identification of BOAT (1) Screening of Treatment Data. This section explains how the Agency determines which of the treatment technologies represent treatment by BOAT. The first activity is to screen the treatment performance data from each of the demonstrated and available technologies according to the following criteria: (a) Design and operating data associated with the treatment data must reflect a well-designed, well-operated system for each treatment data point. (The specific design and operating parameters for each demonstrated technology for this waste code are discussed in Section 3.2 of this document.) (b) Sufficient QA/QC data must be available to determine the true values of the data from the treated waste. This screening criterion involves adjustment of treated data to take into account that the type value may be different from the measured value. This discrepancy generally is caused by other constituents in the waste that can mask results or otherwise interfere with the analysis of the constituent of concern. (c) The measure of performance must be consistent with EPA's approach to evaluating treatment by type of constituents (e.g., total concentration data for organics, and total concentration and TCLP for metals in the leachate from the residual). In the absence of data needed to perform the screening analysis, EPA will make decisions on a case-by-case basis of whether to include the data. The factors included in this case-by-case analysis will be the 32 ------- actual treatment levels achieved, the availability of the treatment data and their completeness (with respect to the above criteria), and EPA's assessment of whether the untreated waste represents the waste code of concern. EPA's application of these screening criteria for this waste code are provided in Section 4 of this background document. (2) Comparison of Treatment Data. In cases in which EPA has treatment data from more than one technology following the screening activity, EPA uses the statistical method known as analysis of variance (ANOVA) to determine if one technology performs significantly better. This statistical method (summarized in Appendix A) provides a measure of the differences between two data sets. If EPA finds that one technology performs significantly better (i.e., the data sets are not homogeneous), BOAT treatment standards are the level of performance achieved by the best technology multiplied by the corresponding variability factor for each regulated constituent. If the differences in the data sets are not statistically significant, the data sets are said to be homogeneous. Specifically, EPA uses the analysis of variance to determine whether BOAT represents a level of performance achieved by only one technology or represents a level of performance achieved by more than one (or all) of the technologies. If the Agency finds that the levels of performance for one or more technologies are not statistically different, EPA averages the performance values achieved by each technology and then multiplies this value by the largest variability factor associated with any of the 33 ------- acceptable technologies. A detailed discussion of the treatment selection method and an example of how EPA chooses BOAT from multiple treatment systems is provided in Section A-l. (3) Quality Assurance/Quality Control. This section presents the principal quality assurance/quality control (QA/QC) procedures employed in screening and adjusting the data to be used in the calculation of treatment standards. Additional QA/QC procedures used in collecting and screening data for the BOAT program are presented in EPA's Generic Quality Assurance Project Plan for Land Disposal Restrictions Program ("BOAT") (EPA/530-SW-87-001, March 1987). To calculate the treatment standards for the Land Disposal Restriction Rules, it is first necessary to determine the recovery value for each constituent (the amount of constituent recovered after spiking, which is the addition of a known amount of the constituent, minus the initial concentration in the samples divided by the amount added) for a spike of the treated residual. Once the recovery value is determined, the following procedures are used to select the appropriate percent recovery value to adjust the analytical data: (a) If duplicate spike recovery values are available for the constituent of interest, the data are adjusted by the lowest available percent recovery value (i.e., the value that will yield the most conservative estimate of treatment achieved). However, if a spike recovery value of less than 20 percent is reported for a specific constituent, the data are not used to set treatment standards because the Agency does not have sufficient confidence in the reported value to set a national standard. 34 ------- (b) If data are not available for a specific constituent but are available for an isomer, then the spike recovery data are transferred from the isomer and the data are adjusted using the percent recovery selected according to the procedure described in (a) above. (c) If data are not available for a specific constituent but are available for a similar class of constituents (e.g., volatile organics, acid-extractable semivolatiles), then spike recovery data available for this class of constituents are transferred. All spike recovery values greater than or equal to 20 percent for a spiked sample are averaged and the constituent concentration is adjusted by the average recovery value. If spiked recovery data are available for more than one sample, the average is calculated for each sample and the data are adjusted by the lowest average value. (d) If matrix spike recovery data are not available for a set of data to be used to calculate treatment standards, then matrix spike recovery data are transferred from a waste that the Agency believes is a similar matrix (e.g., if the data are for an ash from incineration, then data from other incinerator ashes could be used). While EPA recognizes that transfer of matrix spike recovery data from a similar waste is not an exact analysis, this is considered the best approach for adjusting the data to account for the fact that most analyses do not result in extraction of 100 percent of the constituent. In assessing the recovery data to be transferred, the procedures outlined in (a), (b), and (c) above are followed. The analytical procedures employed to generate the data used to calculate the treatment standards are listed in Appendix B of this document. In cases where alternatives or equivalent procedures and/or equipment are allowed in EPA's SW-846, Third Edition (November 1986) methods, the specific procedures and equipment used are also documented in this Appendix. In 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 ------- standards presented in Section 6 of this document. Accordingly, facilities should use these procedures in assessing the performance of their treatment systems. 1.2.7 BOAT Treatment Standards for "Derived-From" and "Mixed" Wastes (1) Wastes from Treatment Trains Generating Multiple Residues. In a number of instances, the proposed BOAT consists of a series of operations each of which generates a waste residue. For example, the proposed BOAT for a certain waste code is based on solvent extraction, steam stripping, and activated carbon adsorption. Each of these treatment steps generates a waste requiring treatment -- a solvent-containing stream from solvent extraction, a stripper overhead, and spent activated carbon. Treatment of these wastes may generate further residues; for instance, spent activated carbon (.if not regenerated) could be incinerated, generating an ash and possibly a scrubber water waste. Ultimately, additional wastes are generated that may require land disposal. With respect to these wastes, the Agency wishes to emphasize the following points: (a) All of the residues from treating the original listed wastes are likewise considered to be the listed waste by virtue of the derived-from rule contained in 40 CFR Part 261.3(c)(2). (This point is discussed more fully in (2) below.) Consequently, all of the wastes generated in the course of treatment would be prohibited from land disposal unless they satisfy the treatment standard or meet one of the exceptions to the prohibition. (b) The Agency's proposed treatment standards generally contain a concentration level for wastewaters and a concentration level for nonwastewaters. The treatment standards apply to all of the wastes generated in treating the original prohibited waste. Thus, all solids generated from treating these wastes would have 36 ------- 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. (c) The Agency has not performed tests, in all cases, on every waste that can result from every part of the treatment train. However, the Agency's treatment standards are based on treatment of the most concentrated form of the waste. Consequently, the Agency believes that the less concentrated wastes generated in the course of treatment will also be able to be treated to meet this value. (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 ------- 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 ------- 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 addressing mixing residuals has been to consider them to be the listed waste and to require that delisting petitioners address all constituents for which the derived-from waste (or other mixed waste) was listed. The language in 40 CFR Part 260.22(b) states that mixtures or derived-from residues can be delisted provided a delisting petitioner makes a demonstration identical to that which a delisting petitioner would make for the underlying waste. These residues consequently are treated as the underlying listed waste for delisting purposes. The statute likewise takes this position, indicating that soil and debris that are contaminated with listed spent solvents or dioxin wastes are subject to the prohibition for these wastes even though these wastes are not the originally generated waste, but rather are a residual from management (RCRA section 3004(e)(3)). It is EPA's view that all such residues are covered by the existing prohibitions and treatment standards for the listed hazardous waste that these residues contain and from which they are derived. 39 ------- 1.2.8 Transfer of Treatment Standards EPA is proposing some treatment standards that are not based on testing of the treatment technology of the specific waste subject to the treatment standard. Instead, the Agency has determined that the constituents present in the subject waste can be treated to the same performance levels as those observed in other wastes for which EPA has previously developed treatment data. EPA believes that transferring treatment performance for use in establishing treatment standards for untested wastes is valid technically in cases where the untested wastes are generated from similar industries, similar processing steps, or have similar waste characteristics affecting performance and treatment selection. Transfer of treatment standards to similar wastes or wastes from similar processing steps requires little formal analysis. However, in the case where only the industry is similar, EPA more closely examines the waste characteristics prior to concluding that the untested waste constituents can be treated to levels associated with tested wastes. EPA undertakes a two-step analysis when determining whether wastes generated by different processes within a single industry can be treated to the same level of performance. First, EPA reviews the available waste characteristic data to identify those parameters that are expected to affect treatment selection. EPA has identified some of the most important constituents and other parameters needed to select the treatment technology appropriate for a given waste. A detailed discussion of each analysis, including how each parameter was selected for each waste, can be found in the background document for each waste. 40 ------- Second, when an individual analysis suggests that an untested waste can be treated with the same technology as a waste for which treatment performance data are already available, EPA analyzes a more detailed list of constituents that represent some of the most important waste characteristics that the Agency believes will affect the performance of the technology. By examining and comparing these characteristics, the Agency determines whether the untested wastes will achieve the same level of treatment as the tested waste. Where the Agency determines that the untested waste is easier to treat than the tested waste, the treatment standards can be transferred. A detailed discussion of this transfer process for each waste can be found in later sections of this document. 1.3 Variance from the BDAT Treatment Standard The Agency recognizes that there may exist unique wastes that cannot be treated to the level specified as the treatment standard. In such a case, a generator or owner/operator may submit a petition to the Administrator requesting a variance from the treatment standard. A particular waste may be significantly different from the wastes considered in establishing treatability groups because the waste contains a more complex matrix that makes it more difficult to treat. For example, complex mixtures may be formed when a restricted waste is mixed with other waste streams by spills or other forms of inadvertent mixing. As a result, the treatability of the restricted waste may be altered such that it cannot meet the applicable treatment standard. Variance petitions must demonstrate that the treatment standard established for a given waste cannot be met. This demonstration can be 41 ------- 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 PR 36902, September 1, 1976, amended by 43 FR 4000). The petition should contain the following information: 42 ------- (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 BDAT background document for determining the characteristics of the wastes considered in developing treatment standards.) (6) If the waste has been treated, a description of the system used for treating the waste, including the process design and operating conditions. The petition should include the reasons the treatment standards are not achievable and/or why the petitioner believes the standards are based on inappropriate technology for treating the waste. (Note: The petitioner should refer to the BDAT background document as guidance for determining the design and operating parameters that the Agency used in developing treatment standards.) (7) A description of the alternative treatment systems examined by the petitioner (if any); a description of the treatment system deemed appropriate by the petitioner for the waste in question; and, as appropriate, the concentrations in the treatment residual or extract of the treatment residual (i.e., using the TCLP where appropriate for stabilized metals) that can be achieved by applying such treatment to the waste. (8) A description of those parameters affecting treatment selection and waste characteristics that affect performance, including results of all analyses. (See Section 3.0 for a discussion of waste characteristics affecting performance that the Agency has identified for the technology representing BDAT.) (9) The dates of the sampling and testing. (10) A description of the methodologies and equipment used to obtain representative samples. 43 ------- (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 ------- 2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION The previous section presented the generic methodology for developing BOAT standards. The purpose of this section is to provide a complete characterization of the K037 listed waste by describing the industry that generates the waste, the process generating the waste and the data characterizing the waste. According to 40 CFR Part 261.32 (hazardous wastes from specific sources), the waste identified as K037 is specifically generated by the manufacturers of disulfoton and is listed as follows: K037 - Wastewater treatment sludge from the production of disulfoton. 2.1 Industry Affected and Process Description Only one facility-in the United States is known to produce disulfoton. It is located in EPA Region VII, in the State of Missouri. The disulfoton production process consists of three basic steps: (1) the formation of diethyl salt (DES), (2) the formation of chlorothio alcohol (CTA), and (3) the reaction of DES and CTA to form disulfoton. A flow diagram for the disulfoton production process is presented in Figure 2-1. In the first step of the process, diethyl phosphorodithioic acid is formed in the DES unit from the reaction of PS and ethanol in Ł 3 toluene. The major side product of this reaction is the 0,0,0-triethylester of the phosphorodithioic acid. The diethyl phosphorodithioic acid is next reacted in the same vessel with caustic 46 ------- NOlOdinSKI IIOJ OIIVWUIIOS ZUSVM QNV NOIlOMUOUcI 113 WM ionoou.1 Dooms jrnm.vjuL UJIV/A:llliVA\(l) IJrIIVM 1 . 4^ AIIDAOOHIJ JN-IA HI;; !'-- A inn i t" 'VI3 In) HI in VJ'J UHIVM DltiVM s:io JUKI AuriAOon I ^ I ... ^ JvUinn ^ ,trr, 11 ** snn SDQ ' ^ ^iL II 11 HJ') ^^^^^j 4 noNvma j JHHAIOSi 1OIIOD1V Ollll ' ^«ia.i ------- soda to form DES. The overall reaction for both subreactions is as follows: Toluene P S +4C H OH+2NaOH ---- > 2(C H 0) P(S)SNa+H S+2H 0. Ł 0 t D c 0 t c t Ethanol DES The DES is then separated from the reaction mix, which is sent to a toluene recovery unit. The recovered toluene is recycled back to the DES unit. The second step of the disulfoton production process takes place in the CTA unit, where PCI and thio-alcohol are reacted to form CTA as O follows: In the final step of the process DES and CTA are reacted in the disyston unit to form disulfoton and sodium chloride: (C2H50)2P(S)SNa+C1C2H4"S'C2H5 "^ (C2H50)2P(S)~S~C2H4"S~C2H5+NaC1 Process water from the disyston unit is sent, along with wastewater from the toluene recovery unit, to the disyston solvent recovery unit, where disulfoton is recovered and recycled to the disyston unit. Wastewater from the disyston solvent recovery unit is circulated to wastewater treatment. The sludges generated from wastewater treatment are the waste stream K037. 2.2 Waste Characterization This section includes all waste characterization data available to the Agency for K037 waste. The approximate percent concentrations of 48 ------- the major constituents composing K037 waste are listed in Table 2-1. The percent concentration in the waste was determined from engineering judgment based on analytical analyses and plant information. The ranges of BOAT list constituents present in the waste and all other available parameters affecting treatment selection data are presented in Table 2-2. The data show a waste with high concentrations of solids (75 percent), low concentrations of water (less than 5 percent), approximately 20 percent disulfoton, 0.2 percent toluene, and less than 0.1 percent other BOAT list constituents. According to the data, no BOAT list inorganics other than metals, BOAT list organochlorine pesticides, BOAT list phenoxyacetic acid herbicides, PCBs, or dioxins and furans should be present in K037 wastes. 49 ------- Table 2-1 Constituent Analysis of Untreated K037 Waste Constituent Concentration (wt. "/) Oisulfoton 20 Toluene 0-2 Water 4.7 Solids (filter paper and diatomaceous earth filter aid) 75 Other BOAT-list constituents <0 1 Total 100 % References: 1 USEPA 1987a Onsite Engineering Report for K037 2 Personal Communication. 50 ------- Table 2-2 BOAT List Constituent Concentration anrl Other Data BOAT Untreated K037 waste concentration (mg/kg) Reference No BOAT list constituent (a) (b) Volati1e Orqanics 43 Toluene 201-2,000 <25,000 Semivolati1e Organics 70 bis(2-ethylhexyl) phthalate <250-500 Metals 155 156 158 159 160 161 163 167 168 Arsenic Barium Cadmium Chromium Copper Lead Nickel Vanadium Zinc OraanophosDhorous Insecticides -2.0-3.1 18-39 3.3-10 43-93 7.0-24 5.6-28 46-130 7-10 89-190 195 Disulfoton 104,000-246,000 0-100,000 Other Parameters Solids (filter paper and diatomaceous earth filter aid) - <750,000 Water - 125,000-225,000 References. a USEPA 1987a Onsite Engineering Report for K037 b Personal Communication 51 ------- 3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES This section describes the applicable treatment technologies, demonstrated treatment technologies, and performance data for the treatment of K037. Since the waste characterization data in Section 2 reveals untreated K037 wastes containing high BOAT list organic concentrations and high filterable solids, the technologies considered to be applicable are those that destroy or remove the various organic compounds in wastes with high filterable solids. 3.1 Applicable Treatment Technologies The Agency has identified the following treatment technologies as being applicable for K037: batch distillation, incineration, and solvent extraction. Batch distillation can be used to separate components having widely different boiling points. Incineration technologies destroy the organic components in the waste feed. Solvent extraction removes organic constituents from a waste by exploiting the relatively high solubilities of the waste constituents in a particular solvent. As stated previously, the Agency has identified these treatment technologies as applicable for treatment of K037 because the technologies are designed to destroy or remove the toxic organics present in untreated wastes with high filterable solids. The selection of the treatment technologies applicable for treating BOAT list organics in K037 waste is based on data submitted by industry, current literature sources, and field testing. 52 ------- 3.2 Demonstrated Treatment Technologies The technologies demonstrated on this waste or on waste with similar parameters affecting treatment selection (i.e., high organic content, low water content, and high filterable solids content) are batch distillation and incineration including rotary kiln incineration and fluidized bed incineration. The Agency believes that solvent extraction is potentially applicable to the treatment of K037 waste; however, EPA does not have data on the characteristics of K037 waste that would allow the Agency to conclude that solvent extraction is "demonstrated" on similar wastes. The Agency does not believe that other technologies are applicable because various physical and chemical characteristics of this waste would not allow treatment to occur. EPA believes batch distillation and fluidized bed incineration to be demonstrated treatment technologies for K037 because both have been used to treat wastes with similar characteristics. The Agency knows of at least one facility using batch distillation and one facility using fluidized bed incineration for treatment of wastes similar to K037. However, EPA is not aware of any generator or TSD facility currently using either technology for treatment of wastes containing a large percentage of K037; nor are there performance data that demonstrate their effectiveness in treating the BOAT list constituents in K037 waste. The Agency believes rotary kiln incineration is demonstrated to treat K037 since it is being used to treat wastes similar to K037 with regard to parameters affecting treatment selection, including low water content, 53 ------- high organic content, and high solids concentration. To help develop treatment standards, EPA tested rotary kiln incineration to demonstrate the actual performance achievability. Since the Agency is not aware of any generator or TSD facilities currently using rotary kiln incineration for treatment of wastes containing a large percentage of K037, the K037 was incinerated in EPA's own in-house rotary kiln. Performance data collected by EPA for incineration of K037 using a rotary kiln incinerator are shown in Tables 3-1 through 3-6. A detailed discussion of incineration is presented in Section 3.2.1. 3.2.1. Incineration This section addresses the commonly used incineration technologies: Liquid injection, rotary kiln, fluidized bed incineration, and fixed hearth. A discussion is provided regarding the applicability of these technologies, the underlying principles of operation, a technology description, waste characteristics that affect performance, and finally important design and operating parameters. As appropriate the subsections are divided by type of incineration unit. (1) Applicability and Use of This Technology (a) Liquid Injection Liquid injection is applicable to wastes that have viscosity values sufficiently low so that the waste can be atomized in the combustion chamber. A range of literature maximum viscosity values are reported with the low being 100 SSU and the high being 10,000 SSU. It is important to note that viscosity is temperature dependent so that while 54 ------- liquid injection may not be applicable to a waste at ambient conditions, it may be applicable when the waste is heated. Other factors that affect the use of liquid injection are particle size and the presence of suspended solids. Both of these waste parameters can cause plugging of the burner nozzle. (b) Rotary Kiln/Fluidized Bed/Fixed Hearth These incineration technologies are applicable to a wide range of hazardous wastes. They can be used on wastes that contain high or low total organic content, high or low filterable solids, various viscosity ranges, and a range of other waste parameters. EPA has not found these technologies to be demonstrated on wastes that are comprised essentially of metals with low organic concentrations. In addition, the Agency expects that some of the high metal content wastes may not be compatible with existing and future air emission limits without emission controls far more extensive than currently practiced. (2) Underlying Principles of Operation (a) Liquid Injection The basic operating principle of this incineration technology is that incoming liquid wastes are volatilized and then additional heat is supplied to the waste to destabilize the chemical bonds. Once the chemical bonds are broken, these constituents 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. 55 ------- (b) Rotary Kiln and Fixed Hearth There are two distinct principles of operation for these incineration technologies, one for each of the chambers involved. In the primary chamber, energy, in the form of heat, is transferred to the waste to achieve volatilization of the various organic waste constituents. During this volatilization process some of the organic constituents will oxidize to CO and water vapor. In the secondary chamber, additional heat is supplied to overcome the energy requirements needed to destabilize the chemical bonds and allow the constituents to react with excess oxygen to form carbon dioxide and water vapor. The principle of operation for the secondary chamber is similar to liquid injection. (c) Fluidized Bed The principle of operation for this incinerator technology is somewhat different than for rotary kiln and fixed hearth incineration, in that there is only one chamber that contains the fluidizing sand and a freeboard section above the sand. The purpose of the fluidized bed is to both volatilize the waste and combust the waste. Destruction of the waste organics can be accomplished to a better degree in the primary chamber of this technology than for rotary kiln and fixed hearth because of 1) improved heat transfer from fluidization of the waste using forced air and 2) the fact that the fluidization process provides sufficient oxygen and turbulence to convert the organics to carbon dioxide and water vapor. The freeboard generally does not have an afterburner; however, 56 ------- additional time is provided for conversion of the organic constituents to carbon dioxide, water vapor, and hydrochloric acid if chlorine is present in the waste. (3) Description of Incineration Technologies (a) Liquid Injection The liquid injection system is capable of incinerating a wide range of gases and liquids. The combustion system has a simple design with virtually no moving parts. A burner or nozzle atomizes the liquid waste and injects it into the combustion chamber where it burns in the presence of air or oxygen. A forced draft system supplies the combustion chamber with air to provide oxygen for combustion and turbulence for mixing. The combustion chamber is usually a cylinder lined with refractory (i.e., heat resistant) brick and can be fired horizontally, vertically upward, or vertically downward. Figure 3-1 illustrates a liquid injection incineration system. (b) Rotary Kiln A rotary kiln is a slowly rotating, refractory-lined cylinder that is mounted at a slight incline from the horizontal (see Figure 3-2). Solid wastes enter at the high end of the kiln, and liquid or gaseous wastes enter through atomizing nozzles in the kiln or afterburner section. Rotation of the kiln exposes the solids to the heat, vaporizes them, and allows them to combust by mixing with air. The rotation also causes the ash to move to the lower end of the kiln where it can be removed. Rotary 57 ------- WATER AUXILIARY FUEL HBURNER AIR- en 00 LIQUID OR GASEOUS. WASTE INJECTION PRIMARY COMBUSTION CHAMBER AFTERBURNER (SECONDARY COMBUSTION CHAMBER) SPRAY CHAMBER GAS TO AIR POLLUTION CONTROL HORIZONTALLY FIRED LIQUID INJECTION INCINERATOR ASH WATER FIGURE 3-1 LIQUID INJECTION INCINERATOR ------- GAS TO AIR POLLUTION CONTROL AUXILIARY FUEL AFTERBURNER SOLID WASTE INFLUENT FEED MECHANISM COMBUSTION GASES LIQUID OR GASEOUS WASTE INJECTION ASH FIGURE 3-2 ROTARY KILN INCINERATOR 59 ------- kiln systems usually have a secondary combustion chamber or afterburner following the kiln for further combustion of the volatilized components of sol id wastes. (c) Fluidized Bed A fluidized bed incinerator consists of a column containing inert particles such as sand which is referred to as the bed. Air, driven by a blower, enters the bottom of the bed to fluidize the sand. Air passage through the bed promotes rapid and uniform mixing of the injected waste material within the fluidized bed. The fluidized bed has an extremely high heat capacity (approximately three times that of flue gas at the same temperature), thereby providing a large heat reservoir. The injected waste reaches ignition temperature quickly and transfers the heat of combustion back to the bed. Continued bed agitation by the fluidizing air allows larger particles to remain suspended in the combustion zone. (See Figure 3-3) (d) Fixed Hearth Incineration Fixed hearth incinerators, also called controlled air or starved air incinerators, are another major technology used for hazardous waste incineration. Fixed hearth incineration is a two-stage combustion process (see Figure 3-4). Waste is ram-fed into the first stage, or primary chamber, and burned at less than stoichiometric conditions. The resultant smoke and pyrolysis products, consisting primarily of volatile hydrocarbons and carbon monoxide, along with the normal products of combustion, pass to the secondary chamber. Here, additional air is injected to complete the combustion. This two-stage process generally 60 ------- WASTE INJECTION BURNER FREEBOARD SAND BED GAS TO AIR POLLUTION CONTROL MAKE-UP SAND AIR ASH FIGURE 3-3 FLUIDIZED BED INCINERATOR 61 ------- AIR WASTE INJECTION -^BURNER cr> ro AIR 1 GAS TO AIR POLLUTION CONTROL PRIMARY COMBUSTION CHAMBER GRATE SECONDARY COMBUSTION CHAMBER AUXILIARY FUEL 2-STAGE FIXED HEARTH INCINERATOR ASH FIGURE 3-4, FIXED HEARTH INCINERATOR ------- yields low stack participate and carbon monoxide (CO) emissions. The primary chamber combustion reactions and combustion gas are maintained at low levels by the starved air conditions so that particulate entrainment and carryover are minimized. (e) Air Pollution Controls Following incineration of hazardous wastes, combustion gases are generally further treated in an air pollution control system. The presence of chlorine or other halogens in the waste requires a scrubbing or absorption step to remover HC1 and other halo-acids from the combustion gases. Ash in the waste is not destroyed in the combustion process. Depending on its composition, ash will either exit as bottom ash, at the discharge end of a kiln or hearth for example, or as- particulate matter (fly ash) suspended in the combustion gas stream. Particulate emissions from most hazardous waste combustion systems generally have particle diameters less than one micron and require high efficiency collection devices to minimize air emissions. In addition, scrubber systems provide additional buffer against accidental releases of incompletely destroyed waste products due to poor combustion efficiency or combustion upsets, such as flame outs. (4) Waste Characteristics Affecting Performance (WCAP) (a) Liquid Injection In determining whether liquid injection is likely to achieve the same level of performance on an untested waste as a previously tested waste, the Agency will compare dissociation bond energies of the constituents in 63 ------- the untested and tested waste. This parameter is being used as a surrogate indicator of activation energy which, as discussed previously, destabilizes molecular bonds. In theory, the bond dissociation energy would be equal to the activation energy; however, in practice this is not always the case. Other energy effects (e.g., vibrational, the formation of intermediates, and interactions between different molecular bonds) may have a significant influence on activation energy. Because of the shortcomings of bond energies in estimating activation energy, EPA analyzed other waste characteristic parameters to determine if these parameters would provide a better basis for transferring treatment standards from an untested waste to a tested waste. These parameters include heat of combustion, heat of formation, use of available kinetic data to predict activation energies, and general structural class. All of these were rejected for reasons provided below. The heat of combustion only measures the difference in energy of the products and reactants; it does not provide information on the transition state (i.e., the energy input needed to initiate the reaction). Heat of formation is used as a predictive tool for whether reactions are likely to proceed; however, there are a significant number of hazardous constituents for which these data are not available. Use of kinetic data were rejected because these data are limited and could not be used to calculate free energy values (AG) for the wide range of hazardous constituents to be addressed by this rule. Finally, EPA decided not to 64 ------- use structural classes because the Agency believes that evaluation of bond dissociation energies allows for a more direct determination of whether a constituent will be destabilized. (b) Rotary Kiln/Fluidized Bed/Fixed Hearth Unlike liquid injection, these incineration technologies also generate a residual ash. Accordingly, in determining whether these technologies are likely to achieve the same level of performance on an untested waste as a previously tested waste, EPA would need to examine the waste characteristics that affect volatilization of organics from the waste, as well as, destruction of the organics, once volatilized. Relative to volatilization, EPA will examine thermal conductivity of the entire waste and boiling point of the various constituents. As with liquid injection, EPA will examine bond energies in determining whether treatment standards for scrubber water residuals can be transferred from a tested waste to an untested waste. Below is a discussion of how EPA arrived at thermal conductivity and boiling point as the best method to assess volatilization of organics from the waste; the discussion relative to bond energies is the same for these technologies as for liquid injection and will not be repeated here. 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 65 ------- through various wastes by radiation is more a function of the design and type of incinerator than the waste being treated. Accordingly, the type of waste treated will have a minimal impact on the amount of heat transferred by radiation. With regard to convection, EPA also believes that the type of heat transfer will generally be more a function of the type and design of incinerator than the waste itself. However, EPA is examining particle size as a waste characteristic that may significantly impact the amount of heat transferred to a waste by convection and thus impact volatilization of the various organic compounds. The final type of heat transfer, conduction, is the one that EPA believes will have the greatest impact on volatilization of organic constituents. To measure this characteristic, EPA will use thermal conductivity; an explanation of this parameter, as well as, how it can be measured is provided below. Heat flow by conduction is proportional to the temperature gradient across the material. The proportionality constant is a property of the material and referred to as the thermal conductivity. (Note: The analytical method that EPA has identified for measurement of thermal conductivity is named "Guarded, Comparative, Longitudinal Heat Flow Technique"; it is described 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. 66 ------- In practice, thermal conductivity has some limitations in assessing the transferability of treatment standards; however, EPA has not identified a parameter that can provide a better indication of heat transfer characteristics of a waste. Below is a discussion of both the limitations associated with thermal conductivity, as well as other parameters considered. Thermal conductivity measurements, as part of a treatability comparison for two different wastes through a single incinerator, are most meaningful when applied to wastes that are homogeneous (i.e., major constituents are essentially the same). As wastes exhibit greater degrees of non-homogeneity (e.g., significant concentration of metals in soil), then thermal conductivity becomes less accurate in predicting treatability because the measurement essentially reflects heat flow through regions having the greatest conductivity (i.e., the path of least resistance) and not heat flow through all parts of the waste. Btu value, specific heat, and ash content were also considered for predicting heat transfer characteristics. These parameters can no better account for non-homogeneity than thermal conductivity; additionally, they are not directly related to heat transfer characteristics. Therefore, these parameters do not provide a better indication of heat transfer that will occur in any specific waste. Boiling Point. Once heat is transferred to a constituent within a waste, then removal of this constituent from the waste will depend on its volatility. As a surrogate of volatility, EPA is using boiling point 67 ------- of the constituent. Compounds with lower boiling points have higher vapor pressures and, therefore, would be more likely to vaporize. The Agency recognizes that this parameter does not take into consideration the impact of other compounds in the waste on the boiling point of a constituent in a mixture; however, the Agency is not aware of a better measure of volatility that can easily be determined. (5) Incineration Design and Operating Parameters (a) Liquid Injection For a liquid injection unit, EPA's analysis of whether the unit is well designed will focus on (1) the likelihood that sufficient energy is provided to the waste to overcome the activation level for breaking molecular bonds and (2) whether sufficient oxygen is present to convert the waste constituents to carbon dioxide and water vapor. The specific design parameters that the Agency will evaluate to assess whether these conditions are met are: temperature, excess oxygen, and residence time. Below is a discussion of why EPA believes these parameters to be important, as well as a discussion of how these parameters will be monitored during operation. It is important to point out that, relative to the development of land disposed restriction standards, EPA is only concerned with these design parameters when a quench water or scrubber water residual is generated from treatment of a particular waste. If treatment of a particular waste in a liquid injection unit would not generate a wastewater stream, then the Agency, for purposes of land disposal 68 ------- treatment standards, would only be concerned with the waste characteristics that affect selection of the unit, not the above-mentioned design parameters. Temperature. Temperature is important in that it provides an indirect measure of the energy available (i.e., Btus/hr) to overcome the activation energy of waste constituents. As the design temperature increases, the more likely it is that the molecular bonds will be destabilized and the reaction completed. The temperature is normally controlled automatically through the use of instrumentation which senses the temperature and automatically adjusts the amount of fuel and/or waste being fed. The temperature signal transmitted to the controller can be simultaneously transmitted to a recording device, referred to as a strip chart, and thereby continuously recorded. To fully assess the operation of the unit, it is important to know not only the exact location in the incinerator that the temperature is being monitored but also the location of the design temperature. Excess Oxygen. It is important that the incinerator contain oxygen in excess of the stiochiometric amount necessary to convert the organic compounds to carbon dioxide and water vapor. If insufficient oxygen is present, then destabilized waste constituents could recombine to the same or other BOAT list organic compounds and potentially cause the scrubber water to contain higher concentrations of BOAT list constituents than would be the case for a well operated unit. 69 ------- In practice, the amount of oxygen fed to the incinerator is controlled by continuous sampling and analysis of the stack gas. If the amount of oxygen drops below the design value, then the analyzer transmits a signal to the valve controlling the air supply and thereby increases the flow of oxygen to the afterburner. The analyzer simultaneously transmits a signal to a recording device so that the amount of excess oxygen can be continuously recorded. Again, as with temperature, it is important to know the location from which the combustion gas is being sampled. Carbon Monoxide. Carbon monoxide is an important operating parameter because it provides an indication of the extent to which the waste organic constituents are being converted to CO and water vapor. As the carbon monoxide level increases, it indicates that greater amounts of organic waste constituents are unreacted or partially reacted. Increased carbon monoxide levels can result from insufficient excess oxygen, insufficient turbulence in the combustion zone, or insufficient residence time. 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 70 ------- ultimate analysis. This analysis determines the amount of elemental constituents present which include carbon, hydrogen, sulfur, oxygen, nitrogen, and halogens. Using this analysis plus the total amount of air added, the volume of combustion gas can be calculated. Having determined both the Btu content and the expected combustion gas volume, the feed rate can be fixed at the desired residence time. Continuous monitoring of the feed rate will determine whether the unit was operated at a rate corresponding to the designed residence time. (b) Rotary Kiln For this incineration, EPA will examine both the primary and secondary chamber in evaluating the design of a particular incinerator. Relative to the primary chamber, EPA's assessment of design will focus on whether it is likely that sufficient energy will be provided to the waste in order to volatilize the waste constituents. Eor 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. Temperature. The primary chamber temperature is important, in that it provides an indirect measure of the energy input (i.e., BTUs/hr) that is available for heating the waste. The higher the temperature is 71 ------- designed to be in a given kiln, the more likely it is that the constituents will volatilize. As discussed earlier under "Liquid Injection", temperature should be continuously monitored and recorded. Additionally, it is important to know the location of the temperature sensing device in the kiln. Residence Time. This parameter is important in that it affects whether sufficient heat is transferred to a particular constituent in order for volatilization to occur. As the time that the waste is in the kiln is increased, a greater quantity of heat is transferred to the hazardous waste constituents. The residence time will be a function of the specific configuration of the rotary kiln including the length and diameter of the kiln, the waste feed rate, and the rate of rotation. Revolutions Per Minute (RPM). This parameter provides an indication of the turbulence that occurs in the primary chamber of a rotary kiln. As the turbulence increases, the quantity of heat transferred to the waste would also be expected to increase. However, as the RPM value increases, the residence time decreases resulting in a reduction of the quantity of heat transferred to the waste. This parameter needs to be carefully evaluated because it provides a balance between turbulence and residence time. (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 72 ------- halogens are present. The secondary chamber will generally provide additional residence time for thermal oxidation of the waste constituents. Relative to the primary chamber, the parameters that the Agency will examine in assessing the effectiveness of the design are temperature, residence time, and bed pressure differential. The first two were discussed under rotary kiln and will not be discussed here. The latter, bed pressure differential, is important in that it provides an indication of the amount of turbulence and, therefore, indirectly the amount of heat supplied to the waste. In general, as the pressure drop increases, both the turbulence and heat supplied increase. The pressure drop through the bed should be continuously monitored and recorded to ensure that the designed valued is achieved. (d) Fixed Hearth The design considerations for this incineration unit are similar to a rotary kiln with the exception that rate of rotation (i.e., RPMs) is not an applicable design parameter. For the primary chamber of this unit, the parameters that the Agency will examine in assessing how well the unit is designed are the same as discussed under rotary kiln; for the secondary chamber (i.e., afterburner), the design and operating parameters of concern are the same as previously discussed under "Liquid Injection". 3.3 Performance Data The Agency collected the six data sets of data for untreated and treated wastes to characterize treatment of K037 using a rotary kiln 73 ------- treatment system. Treatment of K037 resulted in two treatment residuals: ash and scrubber water. Tables 3-1 through 3-6 present the six data sets of total waste concentration analyses for K037 waste samples, and the design and operating data for the treatment system. As shown by the operating data taken during collection of the samples, all six data sets reflect treatment by a well-operated system. Furthermore, all the data sets show treatment of the organic BOAT list constituents detected in the untreated wastes to non-detected levels in the treatment residuals. 74 ------- Table 3-1 Rotary Kiln Incineration EPA Collected Data Sample Set fl ANALYTICAL DATA. Treated BOAT Reference BOAT list No. constituent 43 Toluene 70 Bis(2-ethylhexyl)phthalate 155 Arsenic 156 Barium 157 Beryllium 158 Cadmium 1559 Chromium 160 Copper 161 Lead 163 Nickel 166 Thallium 167 Vanadium 168 Zinc 195 Disulfoton Untreated waste (mg/kg) 640 <250 3.1 26 <0.5 3.9 70 24 28 130 <2.5 8 190 171,000 Treated waste (mg/kg) <10 <2.0 10 150 0.54 2.1 80 610 54 110 <2.5 82 290 <0 0335 waste TCLP (mg/1) NA NA <0.01 <0.045 <0.005 <0.015 0.079 3.3 0.029 0.20 <0.015 0.93 0.64 NA Scrubber water (1*9/1) <10 <50 0.10 0.91 <0.005 0.059 0.15 4.7 6.6 0.10 <0.015 <0.1 16 <1.00 DESIGN AND OPERATING DATA: kiln Design Value Temperature 1832°F Revolutions per minute 0.2 rpm Afterburner Temperature 2200°F Excess oxygen 6-8% Carbon monoxide <1000 ppm Operating Value 1776-1818T 0.2 rpm 2043-2063'F 8% <1 ppm NA - Not Applicable Reference. USEPA. 1987. Onsite Engineering Report for K037. 75 ------- 14HVJ Table 3-2 Rotary kiln Incineration EPA Collected Data Sample Set *2 ANALYTICAL DATA Treated BOAT Reference BOAT list No constituent 43 Toluene 70 Bis(2-ethylhexyl)phthalate 155 Arsenic 156 Barium 157 Beryllium 158 Cadmium 159 Chromium 160 Copper 161 Lead 163 Nickel 166 Thallium 167 Vanadium 168 Zinc 195 Disulfoton Untreated waste (mg/kg) 530 <250 2.4 39 <0.5 3.9 73 12 12 90 <2.5 7 89 104,000 Treated waste (mg/kg) <10 <2.0 5.0 140 0.51 <2.0 93 940 66 110 <2.5 80 330 <0.0335 waste TCLP (mg/1) NA NA <0.01 <0.045 <0.005 <0.015 0.22 10 0.013 0.58 <0.015 1.8 0.45 NA Scrubber water Ug/D <10 <50 0.26 0.19 <0.005 0.062 0.21 4.7 11 <0.1 <0.015 <0.1 4.2 <1 00 DESIGN AND OPERATING DATA: Ki In Desiqn Value Temperature 1832°F Revolutions per minute 0.2 rpm Afterburner Temperature 2200"F Excess oxygen 6-8% Carbon monoxide <1000 ppm Operating Value 1778-1818T 0.2 rpm 2043-2063T 8% <1 ppm NA - Not Applicable Reference USEPA 1987 Onsite Engineering Report for K037. 76 ------- Table 3-3 Rotary Kiln Incineration EPA Collected Data Sample Set #3 ANALYTICAL DATA Treated BOAT Reference BOAT list No. constituent 43 Toluene 70 Bis(2-ethylhexyl)phthalate 155 Arsenic 156 Barium 157 Beryllium 158 Cadmium 159 Chromium 160 Copper 161 Lead 163 Nickel 166 Thallium 167 Vanadium 168 Zinc 195 Disulfoton Untreated waste (mg/kg) 1,300 <250 <2.0 18 <0 5 3 8 43 7.0 5.6 46 <2.5 7 110 246,000 Treated waste (mg/kg) <10 <2.0 25 130 <0.5 <2 0 100 630 25 180 <2.5 61 840 <0.0335 waste TCLP (mg/1) NA NA 0.022 0.049 <0.005 <0.015 0.13 1.1 <0.01 0.19 <0.015 0.97 0.75 NA Scrubber water Ug/D <10 <50 0.22 0.22 <0.005 0.073 0.19 3.9 9.6 <0.1 <0.015 <0.1 2.7 <1.00 DESIGN AND OPERATING DATA. Kiln Design Value Temperature 1832"F Revolutions per minute 0 2 rpm Afterburner Temperature 2200°F Excess oxygen 6-8% Carbon monoxide ^1000 ppm Operating Value 1778-1818-F 0.2 rpm 2043-2063T 87. <1 ppm NA - Not Applicable Reference USEPA 1967. Onsite Engineering Report for K037. 77 ------- Table 3-4 Rotary Kiln Incineration EPA Collected Data Sample Set f4 ANALYTICAL DATA. BOAT Reference BOAT list No. constituent 43 Toluene 70 Bis(2-ethylhexyl)phthalate 155 Arsenic 156 Barium 157 Beryllium 158 Cadmium 159 Chromium 160 Copper 161 Lead 163 Nickel 166 Thallium 167 Vanadium 168 Zinc 195 Disulfoton Untreated waste (mg/kg) 630 <250 <2.0 28 <0.5 5.3 85 21 22 120 <2.5 9 180 186,000 Treated waste (mg/kg) <10 <2.0 15 150 <0.5 <2.0 110 460 15 160 <2.5 78 620 Treated waste TCLP (mg/1) NA NA <0.01 0.075 <0.005 <0.015 0.074 3.0 0 017 0.24 <0.015 1.1 2.7 <0.0335 NA Scrubber water Ug/D <10 <50 0.23 0 18 <0.005 0.063 0.090 4.0 4.0 <0.1 <0.015 <0.1 0.97 <1.00 DESIGN AND OPERATING DATA: ki In Desiqn Value Temperature 1832*F Revolutions per minute 0.2 rpm Afterburner Temperature 2200"F Excess oxygen 6-8/f Carbon monoxide <1000 ppm Operat ing 1830-1897 0 2 rpm 2043-2063 8% <1 ppm Value "F "F NA - Not Applicable Reference- IISEPA 1987 Onsite Engineering Report for K037. 78 ------- 14b'ju Table 3-5 Rotary kiln Incineration EPA Collected Data Sample Set #5 ANALYTICAL DATA Treated BOAT Reference BOAT list No const i tuent 43 Toluene 70 6is(2-ethylhexyl)phthalate 155 Arsenic 156 Barium 157 Beryllium 15B Cadmium 159 Chromium 160 Copper 161 Lead 163 Nickel 166 Thallium 167 Vanadium 168 Zinc 195 Disulfoton Untreated waste (mg/kg) 201 -250 <2 0 22 <0.5 3 3 50 15 12 61 ^2.5 10 110 181,000 Treated waste (mg/kg) <10 <2.0 5 0 140 <0.5 <2.0 88 380 15 110 <2.5 77 450 -0 0335 waste TCLP (mg/1) NA NA <0.01 1.1 <0.005 <0.015 0 26 4.3 0.021 0.41 <0.015 1.8 4.8 NA Scrubber water Ug/D <10 <50 0.29 0.30 <0 005 0.11 0.13 6.2 6 8 <0 1 0.02 <0 1 1.7 <1.00 DESIGN AND OPERATING DATA Kiln Design Value Temperature 1832°F Revolutions per minute 0.2 rpm Afterburner Temperature 2200T Excess oxygen 6-8X Carbon monoxide <1000 ppm Operating Value 1830-1897-F 0.2 rpm 2043-2063-F 8-/_ <1 ppm NA - Not Applicable Reference USEPA 1987 Onsite Engineering Report for K037. 79 ------- 14Bbq Table 3-6 Rotary kiln Incineration EPA Collected Data Sample Set #6 ANALYTICAL DATA Treated BOAT Reference BOAT list No constituent 43 Toluene 70 Bis(2-ethylhexyl)phthalate 155 Arsenic !56 Barium 157 Beryllium 158 Cadmium 159 Chromium 160 Copper 161 Lead 163 Nickel 166 Thai 1 lum 167 Vanadium 168 Zinc 195 Disulfoton Untreated waste (mg/kg) 2000 500 <2.0 33 <0.5 10 93 16 8 2 120 <2.5 8 120 192,000 Treated waste (mg/kg) <10 <2.0 20 170 0.71 <2.0 87 240 20 110 <2.5 88 330 <0.0335 waste TCLP (mg/1) NA NA <0.01 0 1 <0 005 <0 015 <0.045 0.15 <0.01 0.59 <0.015 0.25 0.16 NA Scrubber water Ug/D <10 <50 0.45 0.39 <0 005 0.16 0.17 6.3 11 0.11 0.02 <0 1 2.3 <1,00 DESIGN AND OPERATING DATA. ki In Desiqn Value Temperature 1832T Revolutions per minute 0 2 rpm Afterburner Temperature 2200"F Excess oxygen 6-8% Carbon monoxide <1000 ppm Operating Value 1830-1897'F 0.2 rpm 2043-2063"F 8% <1 ppm NA - Not Applicable. Reference. USEPA 1987 Onsite Engineering Report for K037. 80 ------- 4. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY FOR K037 This section presents the rationale for selection of the best technology from the technologies that have been identified in Section 3 as demonstrated technologies for treatment of K037. The demonstrated technologies are: (1) batch distillation, and (2) incineration. As stated previously in the introduction, BOAT is selected based on the evaluation of treatment technology performance data. These data are evaluated based on the following procedure. First, the design and operating data reported for each data set (paired influent/effluent data) are examined, and data points or data sets that reflect a poorly designed treatment system or a system that was not well operated at the time of data collection are eliminated. Once these data have been deleted, all remaining data are adjusted using analytical recovery values based on laboratory quality assurance/quality control (QA/QC) analyses. This adjustment takes into account analytical interferences associated with the sample. Finally, in cases where the Agency has data on treatment of a listed waste using more than one technology, the treatment values are compared by the analysis of variance test (ANOVA), as presented in Appendix A. This test determines if one technology performs significantly better than another. The only treatment performance data available to the Agency are for treatment of K037 using rotary kiln incineration. The Agency believes that rotary kiln incineration achieves better treatment of the organics 81 ------- in K037 waste than batch distillation. This is because incineration destroys the hazardous components, whereas distillation only places them into a lower volume, more concentrated mixture, which itself may require incineration. Also, it is expected that fluidized bed incineration could not achieve better treatment than rotary kiln incineration since the operating temperatures are lower. Furthermore, as a result of the data analysis described above and in detail below in sections 4.1 through 4.3, EPA has chosen rotary kiln incineration as the best demonstrated technology. Rotary kiln incineration is also believed to be "available" because it is commercially available, not proprietary, and substantially diminishes waste toxicity and migration potential for hazardous constituents. 4.1 Data Screening The available treatment data for K037 were reviewed and assessed with regard to the design and operation of the system, the quality assurance/ quality control analyses of the data, and the analytical tests used to assess treatment performance. No performance data were deleted for treatment of K037 using rotary kiln incineration. 4.2 Data Accuracy After the screening tests, EPA adjusted the data values based on the analytical recovery values to take into account analytical interferences associated with the chemical makeup of the treated sample. In developing 82 ------- 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. The analytical data were adjusted for accuracy using the lowest recovery value for each constituent. These adjusted values for rotary kiln incineration were then used to determine BOAT for K037. (See Appendix B for calculation of the adjusted values.) 83 ------- 5. SELECTION OF REGULATED CONSTITUENTS As discussed in Section 1, the Agency has developed a BOAT list of hazardous constituents (Table 1-1) from which the constituents to be regulated are selected. The list is an expanding list that does not preclude the addition of new constituents as additional key parameters. The list is divided into the following categories: volatile organics, semivolatile organics, metals, inorganics other than metals, pesticides, PCBs, and dioxins and furans. This section describes the step-by-step process used to select the pollutants to be regulated. The selected constituents must be present in the untreated waste and must be treatable by the chosen BOAT, rotary kiln incineration, as discussed in Section 4. Moreover, the regulated constituents are those compounds that are significantly reduced, and such reduction ensures that the recommended BOAT is the most effective treatment for the K037 waste. Using this definition and the major BOAT list constituents identified in Section 2, two constituents, toluene and disulfoton, are selected as the regulated constituents for K037 for which treatment standards are developed in Section 6 of this report. 5.1 Identification of Constituents in the Untreated Waste Table 5-1 presents the BOAT list as discussed in Section 1 and indicates which of the BOAT list constituents were analyzed for in the untreated waste and treated waste, and which of those that were analyzed for were detected. Of the 232 BOAT constituents, 213 were analyzed and the only constituents that were detected include toluene and 84 ------- 1544g Table 5 1 BOAT List Constituents Detected or Not Detected in the K037 Waste Samples BOAT Reference No Parameter Volat i le *1 22 1 9 3 . 4 C 6 223 7 b 9 10 11 12 13 14 15 16 17 la 19 20. 21 22 23 24 25 26. 27. 2b. 29 224 225. 226 Orriarncs Acetone Aceton itn le Acrolein Acrylonitri le Benzene Bromod ich loi'omethane Bromomethane n-But> 1 alcohol Carbon Tet rachlor ide Carbon disu It ide Ch loroben^e^e 2-Chloro-l , 3-butadiene Chlorodibromomethane Ch loroethane 2-Chloroethyl vinyl ether Chloroform Chloromethane 3 -Ch loropropene ,2-Dibromo-3-chloropropane 1 , 2-Dibromoethane D ibromomethane T rails -1 , 4-Dichloro-2-butene Dichlorodif luoromethane 1 , 1-Dichloroethane 1 , 2-Dichloroethane 1 , 1-Dichloroethy lene Trans- 1 , 2-Dirhloroethene 1 ,2 -Dichloropropane Trans- 1 , 3-D ich loropropene c is-1 , 3-D ich loropropene 1 ,4-Dioxane n-Butyl alcohol 2-Ethoxyethancl 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 75-15-0 108-90-7 108-90-7 108-90-7 75-00-3 110-75-8 67-66-3 74-87-3 107-05-1 96-12-8 106-93-4 74-95-3 110-57-6 75-71-8 75-35-3 105-06-2 75-35-4 156-60-5 78-87-5 10061-02-6 10061-01-5 123-91-1 71-36-3 110-80-5 141-78-6 100-41-4 Untreated Waste (mg/kg) NL ND NO ND ND ND ND NL ND ND ND ND NO ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL NL NL NL Treated Waste (mg/kg) NL ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL NL NL NL Treated Waste TCLP (mg/1) NL ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL NL NL NL Scrubber Water Ug/i) NL ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL NL NL NL 85 ------- Table 5-1 (Continued) BOAT Reference No Parameter CAS no. Untreated Waste (mg/kg) Treated Waste (mg/kg) Treated Waste TCLP (mg/1) Scrubber Water Ug/D Volatile Orqanics (continued) jO 227 31 214 32 33 228 34 229 35 3h 37 JB 39 40 41 42 4o 44 45 4b. 47 4 a 49. 231 50 215 216. 217 Semi volat 51 52 53 54 Ethyl cyanide Ethyl ether Ethyl methacrylate Ethylene Oxide lodomethane Isobutyl alcohol Metnanol Methyl ethyl ketone Methyl isobutyl ketone Methyl methdcryldte Methyl methanebulfonate Methylacrvlomtrile Methylene chloride Pyr id me 1,1,1 ,2-Tetrachloroethane 1,1,2, 2-Tetrachloroethane Tet rachloroethene To luene Tr ihromomet hane 1.1,1 -Trichloroethane 1,1, 2- Trichloroethane Tr ichloroethene Tr ichloromonof luoromethane 1 , 2 , 3-Tr ichloropropane l,l,2-Trichloro-l,2,2- tr it luoroethane Vinyl chloride 1 ,2 -Xylene 1 ,3-Xylene 1 ,4-Xy lene i les Acenaphtha lene Acenaphthene Acetophenone 2-Acetylaminof luorene 10712-0 60-29-7 97-63-2 75-21-8 74-88-4 78-83-1 67-56-1 78-93-3 108-10-1 80-62-6 66-27-3 126-98-7 75-09-2 110-86-1 630-20-6 79-34-5 127-18-4 108-88-3 75-25-2 71-55-6 79-00-5 79-01-6 75-69-4 96-18-4 76-13-1 75-01-4 97-47-6 108-38-3 106-44-5 208-96-8 83-32-9 96-86-2 53-96-3 ND NL ND NL ND ND NL ND NL ND ND ND ND - ND ND ND D ND ND ND ND ND ND NL ND NL NL NL ND ND ND ND ND NL ND NL ND ND NL I NL ND ND ND ND - ND ND ND ND ND ND ND ND ND ND NL ND NL NL NL ND ND ND ND ND NL ND NL ND ND NL ND NL ND ND ND ND - ND ND ND ND ND ND ND ND ND ND NL ND NL NL NL ND ND ND ND ND NL ND NL ND ND NL ND NL ND ND ND ND - ND ND ND ND ND ND ND ND ND ND NL ND NL NL NL ND ND ND ND 86 ------- 1544g Table 5-1. (Continued) BOAT Reference No. Parameter CAS no tern i vo 5S 56 57 58 59 ?1« CO 61 62 63 64 65. f,6. 67 CtJ b9 70 71 72 73 74 75 70. 77 76 79 BO 81 62 232 63 84. 85. 86 87. BB b9 90 lat i les (continued) 4-Aminohipheny 1 Am 1 me Anthracene Arami te Benz(a)anthracene Benza 1 chloride Benza 1 chloride Benzenethiol Benzo(a)pyrene Benzo(b)f luoranthene Benzo(grn jperylene Benzo( k ) f luoranthene p-Benzoqumone Bis(2-chloroethoxy)methane Bis(2-chloroethyl)ether 8is(2-chloroisopropy 1 Jet her Bis(2-ethylhexyl)phthalate 4-Bromophenyl phenyl ether Butyl benzyl phthalate 2-sec-b'uty 1-4 , 6-din i trophenol p-Ch loroani 1 me Chlorobenzi late p-Chloro-m-cresol 2-Chloronaphthalene 2-Chlorophenol 3-Chloropropionitn le Chrysene ortho-Cresol para-Cresol Cyclohexanone Dibenz(a,h)anthracene Dibenzo(a,e)pyrene Dibenzo(a, i Jpyrene m-Dichlorobenzene o-Dichlorobenzene p-Dichlorobenzene 3,3 ' -Dichlorobenz id me 2,4-Dichlorophenol 92-67-1 62-53-3 120-12-7 140-57-8 56-55-3 98-87-3 98-87-3 108-98-5 50-32-8 205-99-2 191-24-2 207-08-9 106-51-4 111-91-1 111-44-4 39638-32-9 117-81-7 101-55-3 85-68-7 88-85-7 106-47-8 510-15-6 59-50-7 91-58-7 95-57-8 542-76-7 218-01-9 95-46-7 106-44-5 108-94-1 53-70-3 192-65-4 189-55-9 541-73-1 95-50-1 106-46-7 91-94-1 120-63-2 Untreated Treated Waste Waste (mg/kg) (mg/kg) ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND D ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND Treated Waste TCLP (mg/1) ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND Scrubber Water Ug/l) ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND 87 ------- l'j44q Table 5-1 (Continued) BOAT Reference No Semivolat i 91 92 to 94 95 96 97 9h '19 IOC 101. 102 105 104 105 106 219 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 133 124 125 126 Parameter )es (continued) 2,6 -Dichlorophenol Diethyl phthalate 3, j '-Dimethoxybenz id me p-Dimethyldmmoazobenzene 3,3' -Dimethylbenz idme 2 ,4-Dimethy Iphenol Dimethyl phthalate Di-n-butyl phthalate 1 ,4-Dimtrobenzene 4,6-Dimtro-o-cresol 2 ,4-Dinitrophenol 2 ,4-Dm itrotoluene 2,6-Dinitrotoluene Di-n-octyl phthalate Di-n-propy In i trosamlne D ipheny lam me Dipheny Ini t rosartiine 1 ,2-Dipheny Ihydrazme F luoranthene F luorene Hexach lorobenzene hexachlorobutadlene Hexach lorocyclopentadiene Hex ac hi or oe thane Hexachlorophene Hexach loropropane Indeno(l , 2 ,3-cd)pyrene Isosaf role Methapyri lene 3-Methylcholanthrene 4,4' -Methylenebis (2-chloroani 1 me) Naphthalene 1,4-Naphthoqumone 1-Naphthy lamine 2-Naphthylamme p-Nitroam 1 me Nitrobenzene CAS no 87-65-0 84-66-2 119-90-4 60-11-7 119-93-7 105-67-9 131-11-3 84-74-2 100-25-4 534-52-1 51-28-5 121-14-2 606-20-2 117-84-0 621-64-7 122-39-4 86-30-6 122-66-7 206-44-0 86-73-7 118-74-1 87-68-3 77-47-4 67-72-1 70-30-4 1888-71-7 193-39-5 120-58-1 91-80-5 56-49-5 101-14-4 91-20-3 130-15-4 134-32-7 91-59-8 100-01-6 98-95-3 Untreated Waste (mg/kg) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND' ND ND NL ND ND ND ND ND ND ND ND ND ND ND Treated Waste (ing/kg) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL NO ND ND ND ND ND ND ND ND ND ND Treated Waste TCLP (nig/1) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND Scrubber Water Ug/D ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND 88 ------- iS44q Table 5-1. (Cont niued) BOAT Reference No Semi vo lat i 127 126 129. 130 131 132 133 134 135 136 137 138 139 140 141. 142 220 143 144 145 146 147 148 149 150 151 152 153 Metals 154. 155. 156 157 158 159 Parameter leb (continued) 4-Nitrophenol N-Nit rosodi-n-buty lamine N-Nitrosodiethylamtne N-N itrosodimethy lamine N-Niti osomethy let hy lam me N-Nit rosomorphol me N-Nitrosopiperidine n-Nurosopyrrol id me 5-N itro-o-toluidme Pentachlorobenzene Pentachloroethane Pentachloronltrobenzene Pentachlorophenol Phenacet in Phenanthrene Phenol Phthd 1 IL anh>dr ide 2-Picol me Pronamule Pyrene Resorc mol Siif role 1,2,4, 5-Tetrachlorobenzene 2,3,4 ,6-Tetrachlorophenol 1 ,2,4-Trichlorobenzene 2,4, 5-Tncnlorophenol 2,4,G-Trichlorophenol Tns(2 ,3-dibromopropy 1) phosphate Ant imony Arsenic Barium Beryl 1 lum Cadmium Chromium (total) CAS no. 100-02-7 924-16-3 55-18-5 62-75-9 10595-95-6 59-89-2 100-75-4 930-55-2 99-65-8 608-93-5 76-01-7 82-68-8 87-86-5 62-44-2 85-01-8 108-95-2 85-44-9 109-06-8 23950-58-5 129-00-0 108-46-3 94-59-7 95-94-3 58-90-2 120-82-1 95-95-4 88-06-2 126-72-7 7440-36-0 7440-38-2 7440-39-3 7440-41-7 7440-43-9 7440-47-32 Untreated Waste (mg/kg) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND D D ND D D Treated Wdbte {dig/kg ) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND NO ND D D D D D Treated Waste TCLP (mg/1) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND D D ND ND D Scrubber Water Ug/l) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL ND ND ND ND ND ND ND ND ND ND ND ND D D ND D D 89 ------- Table 5-1 (Continued) BOAT Reference No Parameter Metdls (cont ) 221 Chromium (hexavalent) 160 Copper 161 Lead 162. Mercury 163 Nickel 164 Selenium 115 Silver 166 Thai 1 lum 167 Vanadium 166 Zinc Inorganics 169 Cyanide 170 Fluoride 171 Sulfide Orqanochlorme Pesticides 172 Aldrin 173 alpha-BHC 174 beta-BHC 175 delta-BHC 176 gamma -BHC 177 Chlordane 178 ODD 179 DDE 1HO DDT Ibl Dieldrin 1S2 Endosulfan 1 183 Endosulfan II 184. Endrin 185 Endrin aldehyde 186 Heptachlor 187 Heptachlor epoxide 188 Isodrin 189 Kepone 190 Methoxyclor 191 Toxaphene CAS no. NA 7440-50-8 7439-92-1 7439-97-6 7440-02-0 7782-49-2 7440-22-4 7440-28-0 7440-62-2 7440-66-6 57-12-5 16964-48-8 8496-25-8 309-00-2 319-84-6 319-85-7 319-86-8 58-89-9 57-74-9 72-54-8 72-55-9 50-29-3 60-57-1 939-98-8 33213-6-5 72-20-8 7421-93-4 76-44-8 1024-57-3 465-73-6 143-50-0 72-43-5 8001-35-2 Untreated Waste (mg/kg) NL D D ND D ND ND ND D D . - - ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND Treated Treated Waste Waste TCLP (mg/kg) (mg/1) NL NL D D D D ND ND D D ND ND ND ND ND ND D D D D . - - ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND Scrubber Water Ug/i) NL D D ND D ND ND D ND D D D D ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND 90 ------- iS44g Table 5-1 (Continued) BOAT Reference No Parameter Phenoxyacet ic Acid Herbicides 192 2,4-Dichlorophenoxyacet ic acid 193 Silvex 194 2,4,5-T Organophosphorous Insect icides 195 Disulfoton 196 Famphur 197 Methyl parathion 198 Parathion 199. Phorate PCB? 200. Aroclor 1016 201 Aroclor 1221 202 Aroclor 1232 203 Aroclor 1242 204. Aroclor 1248 205 Aroclor 1254 206. Aroclor 1260 Dioxins and Furans 207 Hexachlorodibenzo-p-dioxins 208 Hexachlorodibenzof uran 209. Pentachlorodibenzo-p-dioxins 210. Pentachlorodibenzofuran 211 Tetrachlorodibenzo-p-dioxins 212 Tetrachlorodlbenzofuran 213. 2,3,7,8-Tetrachlorodi- benzo-p-dioxin CAS no. 94-75-7 93-72-1 93-76-5 298-04-4 52-85-7 298-00-0 56-38-2 298-02-2 12674-11-2 11104-28-2 11141-16-5 53469-21-9 12672-29-6 11097-69-1 11096-82-5 NA NA NA NA NA NA NA Untreated Waste (mg/kg) ND ND ND D ND ND ND ND ND ND ND ND ND ND NO ND NO ND ND ND ND ND Treated Treated Waste Waste TCLP (mg/kg) (mg/1) ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND Scrubber Water Ug/D ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NL = Not on list at the time analysis was performed. ND = Not Detected D = Detected = No Analysis Performed NA - Not Applicable 1 = Interference caused by Lab Contamination Reference: IISEPA lfir.7 Onsite Engineering Report for K037 91 ------- bis(2-ethylhexy1)phthalate; certain metals such as arsenic, barium, cadmium, chromium, copper, lead, nickel, vanadium, and zinc; and the organophosphorous insecticide disulfoton. Eighteen constituents were not analyzed for because at the time the analysis was performed those constituents were not on the BOAT constituent list. For those constituents identified as not detected (ND), it was assumed that they were present at or below detection limits or that some constituents were present in the untreated waste but masking or interference prevented their detection. Detection limits for K037 constituents in treated and untreated wastes are provided in Appendix C. A summary of the detected constituents and their concentrations is given in Table 5-2. 5.2 Comparison of Untreated and Treated Waste Data for the Ma.ior Constituents Table 5-2 also presents the concentrations of major constituents in the treated waste residues, namely ash and scrubber water. The treated waste data demonstrate that the three detected organics toluene, disulfoton, and bis(2-ethylhexyl)phthalate were reduced significantly. This further indicates that the BOAT identified is effective in reducing the major organic constituents to nontreatable levels, and the treatment residues do not need any additional organic treatment. Because the concentrations of toluene, bis(2-ethylhexyl)phthalate, and disulfoton were reduced substantially, these compounds were regarded as potential regulated constituents. For constituents for which substantial reduction was not achieved, the Agency requires further analysis to determine if the reduction is significant. Statistical 92 ------- Table 5-2 BOAT Lis>t Constituents and Their Concentrations in Untreated Waste and Treatment Rt-bKlues BOAT Reference No 43 70 155 156 157. 15H 159 150. 161 163 166 167 Ibtt 195 BOAT List Const ituent Toluene bis(2-ethylhexyl)- phthalate Arsen ic Barium Beryl 1 lum Cadmium Chromium Copper Lead Nickel Tnal 1 lum Vanadium Zinc Disulfoton Untreated waste (rag/kg) 201-2,000 <250-500 <2-3.1 18-39 <0.5 3.3-10 43-93 7-24 5.6-28 46-130 <2.5 7-10 89-190 104,000-246,000 Treated waste residue Ash (mg/kg) <10 <2.0 5.25 130-170 <0.5-0.54 <2. 0-2.1 80-110 380-940 15-66 110-180 <2 5 61-88 290-840 <0 0335 Ash TLCP (mg/1) NA NA <0 01-0.022 <0 045-1.1 <0.005 <2.0 <0. 045-0. 26 0.15-10 <0. 01-0. 029 0.19-0.59 0.015 0.25-1.8 0.45-4.8 NA Scrubber water (ug/1) <10 <50 0.1-0.45 0.18-0 91 <0.005 0.059-0 16 0.09-0.21 3.9-6.3 4-11 <0.1-0 11 <0.015 <0.1 0.97-16 <1.0 NA - Not Applicable Reference USFPA 1987. Onsite Engineering Report for K037 93 ------- analysis would be required for this determination. As seen in Table 5-2, this step was not necessary. Untreatable concentrations of metals were detected in the scrubber water and ash residuals. The amounts are too low to warrant metals treatment. Furthermore, since none of the detected BOAT list metals were treated by rotary kiln incineration, none were regarded as potential regulated constituents. 5.3 Selection of Regulated Constituents Toluene and disulfoton are only two BOAT list constituents selected as regulated constituents for K037. Using the analytical data for these constituents, BOAT treatment standards are developed in the following section. The Agency did not select bis(2-ethylhexyl)phthalate as a regulated constituents, because it is believed that regulation of toluene and disulfoton will control other organics present, in the untreated waste. 94 ------- 6. CALCULATION OF BOAT TREATMENT STANDARD The purpose of this section is to calculate the actual treatment standards for the regulated constituents determined in Section 5. EPA has six sets of influent and effluent data from one facility for treatment of K037 using rotary kiln incineration. As discussed in the introduction, the following steps were taken to derive the BOAT treatment standards for K037. 1. The Agency evaluated the data collected from the rotary kiln treatment system to determine whether any of the data represented poor design or operation of the treatment system. The available data show that none of the six data sets represent poor design or operation. All six data sets for rotary kiln incineration are used for regulation of the K037 waste. 2. Accuracy-corrected constituent concentrations were calculated for all BDAT-list constituents. An arithmetic average concentration level and a variability factor were determined for each BOAT list constituent regulated in this waste, as shown in Table 6-1. The calculation of the variability factor is presented in Appendix A. 3. The BOAT treatment standard for each constituent regulated in this rulemaking was determined by multiplying the average accuracy-corrected total composition by the appropriate variability factor. Table 6-1 summarizes the calculation of the treatment standards for K037 nonwastewaters and wastewaters. EPA believes the treated constituent concentrations substantially diminish the toxicity of K037. 95 ------- 14H5'g Table 6-1 Regulated Constituents and Calculated Treatment Standards for K037 Accuracy-Corrected Concentration Matrix Nonwastewaters Wastewaters Const ituent (units) Disulfoton (mg/kg) Toluene (mg/kg) Disulfoton (mg/1) Toluene (mg/1) Sample set #1 0.04 10 0.0011 0.01 Sample set n 0.04 10 0 0011 0.01 Sample set #3 0 04 10 0 0011 0.01 Sample set #4 0.04 10 o.oon 0.01 Sample set #5 0.04 10 0.0011 0.01 Sample set #6 0.04 10 0.0011 0.01 Average Treated Waste Concentration 0.04 10 0.0011 0.01 Var labi 1 ity Factor (VF) 2.8 2.8 2.8 2 8 Treatment Standard (Average x VF) 0 10 28 0 003 0 028 CTt ------- 7. CONCLUSIONS The Agency has proposed treatment standards for the listed waste code K037. Standards for nonwastewater and wastewater forms of this waste are presented in Table 7-1. The treatment standards proposed for K037 have been developed consistent with EPA's promulgated methodology for BOAT (November 7, 1986, 51FR 40572). This waste is generated by the treatment of wastewater from disulfoton production. Only one facility is known to produce disulfoton and to generate K037 waste. The BOAT list constituents generally present in the K037 waste are disulfoton and toluene. Through available data bases, EPA's technology testing program, and data submitted by industry, the Agency has identified the following demonstrated technologies for treatment of organic constituents present in the K037 waste: batch distillation and incineration, including fluidized bed and rotary kiln incineration. Regulated constituents were selected based on a careful evaluation of the constituents fo'und at treatable levels in the untreated wastes and the constituents detected in the treated wastes. All available waste characterization data and applicable treatment data consistent with the type and quality of data required by the Agency for this program were used to make this determination. For K037 these constituents also represent the BOAT list constituents present at the highest concentrations. However, if the performance data for the technology 97 ------- 14dSg Table 7-1 BOAT Treatment Performance Standards for K037 Total Waste Concentration Organic Constituents Nonwastewater Wastewater (mg/kg) (mg/1) Toluene 28 0.028 Disulfoton 0 10 0.003 98 ------- selected as BOAT indicated that the constituent was not treated, then that constituent was not regulated. In the development of treatment standards for these wastes, the Agency examined all available treatment data. The Agency also conducted tests on a rotary kiln incinerator treating K037 wastes. Design and operating data collected during the testing of the technology indicate that the technology was properly operated during each sample set; accordingly, all of the treatment performance data collected during the tests were used in the development of the BOAT treatment standards. Two categories of treatment standards were developed for K037 waste: wastewater and nonwastewater wastes. (For the purpose of the land disposal restrictions rule, wastewaters are defined as wastes containing less than 1 percent (weight basis) filterable solids and less than 1 percent (weight basis) total organic carbon.) Nonwastewater standards for organic constituents in K037 are based on the treatment data from EPA's test of rotary kiln incineration. Wastewater standards for organic constituents in K037 are based on treatment performance as reflected by the scrubber water data collected during the rotary kiln incineration of K037 waste. Treatment standards for these wastes were derived after adjustment of laboratory data to account for recovery. Subsequently, the mean of the adjusted data points was multiplied by a variability factor to derive the standard. The variability factor represents the variability inherent in the treatment process and sampling and analytical methods. Variability 99 ------- factors were determined by statistically calculating the variability seen for a number of data points for a given constituent. For constituents for which specific variability factors could not be calculated, a variability factor of 2.8 was used. Wastes determined to be K037 waste may be land disposed if they meet the standards at the point of disposal. The BOAT upon which the treatment standards are based, rotary kiln incineration, need not be specifically utilized prior to land disposal, provided the alternate technology utilized achieves the standards and does not pose a greater risk to human health and the environment than land disposal. These standards become effective as of August 8, 1988, as per the schedule set forth in 40 CFR 268.10. Consistent with Executive Order 12291, EPA prepared a regulatory impact analysis (RIA) to assess the economic effect of compliance with this proposed rule. The RIA prepared for this proposal rule is available in the Administrative Record for the First Sixths' Rule. 100 ------- APPENDIX A 101 ------- 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 102 ------- Table A-l 95fh PERCENTILE VALUES FOR THE F DISTRIBUTION KJ = degrees of freedom for numerator «2 = degrees of freedom for denominator ,^X FK V 1 « 3 4 5 G 1 8 9 10 11 12 12 14 15 16 17 IS 19 20 oo 2-5 25 2S 30 40 50 60 70 80 100 150 200 400 03 1 1G1.4 18.51 10.13 7.71 6.61 5.99 5.59 5.32 5.12 4.96 4.84 4.75 4.67 4.60 4.54 4.49 4.45 4.41 4.38 4.35 4.30 4.26 4.23 4.20 4.17 4.08 4.03 4.00 3.98 3.96 3.94 3.91 3.89 3.86 3.84 2 199.5 19.00 9.55 6.94 5.79 5.14 4.74 4.46 4.26 4.10 3.98 3.89 3.S1 3.74 3.68 3.63 3.59 3.55 3.52 3.49 3.44 3.40 3.37 3.34 3.32 3.23 3.18 3.15 3.13 3.11 3.09 3.06 3.04 3.02 2.99 3 215.7 19.16 9.28 6.59 5.41 4.76 4.35 4.07 3.86 3.71 3.59 3.49 3.41 3.34 3.29 3.24 3.20 3.16 3.13 3.10 3.05 3.01 2.98 2.95 2.92 2.84 2.79 2.76 2.74 2.72 2.70 2.67 2.65 2.62 2.60 4 224.6 19.25 9.12 6.39 5.19 4.53 4.12 3.84 3.G3 3.48 3.36 3.26 3.18 3.11 3.06 3.01 2.96 2.93 2.90 2.87 2.82 2.78 ' 2.74 2.71 - 2.69 2.61 2.56 2.53 2.50 2.48 2.46 2.43 2.41 2.39 2.37 5 230.2 19.30 9.01 6.26 5.05 4.39 3.97 3.69 3.48 3.33 3.20 3.11 3.03 2.96 2.90 2.85 2.81 2.77 2.74 2.71 2.66 2.62 2.59 2.56 ' 2.53 2.45 2.40 2.37 2.35 2.33 2.30 2.27 2.26 2.23 2.21 6 234.0 19.33 8.94 6.16 4.95 4.28 3.87 3.58 3.37 300 .MArf 3.09 3.00 2.92 2.85 2.79 2.74 2.70 2.66 2.63 2.60 2.55 2.51 2.47 2.45 2.42 2.34 0 OQ *»«.7 2.25 2.23 2.21 2.19 2.16 2.14 2.12 2.09 8 238.9 19.37 8.85 6.04 4.82 4.15 3.73 3.44 3.23 3.07 2.95 2.85 2.77 2.70 2.64 2.59 2.55 2.51 2.48 2.45 2.40 2.36 2.32 O on O oy 2.18 2.13 2.10 2.07 2.05 2.03 2.00 1.98 1.96 1.94 12 243.9 19.41 8.74 5.91 4.68 4.00 3.57 3.28 3.07 2.91 2.79 2.69 2.60 2.53 2.48 2.42 2.38 2.34 2.31 2.28 2.23 2.18 2.15 2.12 2.09 2.00 1.95 1.92 1.89 1.88 1.85 1.82 1.80 1.78 1.75 16 24C.3 19.43 8.69 5.84 4.60 3.92 3.49 3.20 2.98 2.82 2.70 2.60 2.51 2.44 2.39 2.33 2 °9 o or *..«d 2 "1 2.18 2.13 2.09 2.05 2.02 1.99 1.90\ 1.85 1.81 1.79 1.77 1.75 1.71 1.69 1.67 1.64 20 248.0 19.45 8.66 5.80 4.56 3.87 3.44 3.15 2.93 2.77 2.65 2.54 2.46 2.39 2.33 2.28 2.23 2.19 2.15 2.12 2.07 2.03 1.99 1.96 1.93 1.84 1.78 1.75 1.72 1.70 1.68 1.64 1.62 1.60 1.57 30 250.1 19.46 8.62 5.75 4.50 3.81 2.38 3.08 2.86 2.70 2.57 2.46 2.38 2.31 2.25 2.20 2.15 2.11 2.07 2.04 1.98 1.94 1.90 1.S7 1.84 1.74 1.69 1.65 1.62 1.60 1.57 1.54 1.52 1.49 1.46 40 251.1 19.46 8.GO 5.71 4.46 3.77 3.34 3.05 2.22 2.67 2.53 2.42 2.34 2.27 2 °1 2.16 2.11 2.07 2.02 1.99 1.93 1.S9 1.85 1.81 1.79 1.69 1.63 1.59 1.56 1.54 1.51 1.47 1.45 1.42 1.40 50 252.2 19.47 8.58 5.70 4.44 3.75 3.32 3.03 2.80 2.64 2.50 2.40 2.32 2.24 2.18 2.13 2.08 2.04 2.00 1.96 1.91 1.86 1.82 1.78 1.76 1.66 1.60 1.56 1.53 1.51 1.48 1.44 1.42 1.38 1.32 100 253.0 19.49 8.56 5.6G 4.40 3.71 3.28 2.98 2.76 2.59 2.45 2.35 2.26 2.19 2.12 2.07 2.02 1.98 1.94 1.90 1.84 1.80 1.76 1.72 1.69 1.59 1.52 1.48 1.45 1.42 1.39 1.34 1.32 1.28 1.24 K 254.3 19.50 S.53 5.G3 4.36 3.67 9 O" M..O 2.93 2.71 2.54 2.40 2.30 2 "1 2.13 2.07 2.01 1.95 1.92 l.SS 1.84 1.78 1.73 1.69 1.65 1.62 1.51 1.44 1.39 1.35 1.32 1.2S 1 on 1.19 1.13 1.00 ------- necessary to perform a "pair wise F" test to determine if any of the sets are homogeneous. The "pair wise F" test must be done for all of the various combinations of data sets using the same method and equation as the general F test. The F value is calculated as follows: (i) All data are natural logtransformed. (ii) The sum of the data points for each data set is computed (T.). (iii) The statistical parameter known as the sum of the squares between data sets (SSB) is computed: SSB = where: k = number of treatment technologies n^ = number of data points for technology i N = number of data points for all technologies T.J = sum of natural logtransformed data points for each technology. (iv) The sum of the squares within data sets (SSW) is computed: k I i 1 [Ti2] ni ' k ŁT< N L ^ SSW = k n ! ? Ł Ł x i,j . 1=1 j=l k - z where: x-jj = 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. 103 ------- (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 square MSB = SSB/k-1 MSW = SSW/N-k F MSB/MSW Below are three examples of the ANOVA calculation. The first two represent treatment by different technologies that achieve statistically similar treatment; the last example represents a case where one technology achieves significantly better treatment than the other technology. 104 ------- 1790g Example 1 Methylene Chloride Steam Stripping Influent (M9/D i 550. 00 1290.00 1640 00 5100 00 1450.00 4600 00 1760.00 3400.00 4800.00 12100.00 Effluent Ug/i) 10.00 10.00 10 00 12.00 10.00 10.00 10 00 10.00 10.00 10.00 In(eff luent) 2.30 2.30 2.30 2.48 2 30 2.30 2.30 2.30 2.30 2.30 [In(effluent)]2 5.29 5.29 5.29 6.15 5.29 5.29 5.29 5.29 5.29 5.29 Influent Ug/D 1960.00 2568.00 1817.00 1640.00 3907.00 Biological Treatment Effluent In(effluent) [ln(eff luent)]2 Ug/D 10.00 2.30 5.29 10.00 2.30 5.29 10.00 2.30 5.29 26.00 3.26 10 6 10.00 2.30 5.29 Sum. Sample Size 10 10 Mean: 3669 10.2 Standard Deviation' 3328 67 .63 Variabi1ity Factor' 23.18 10 2.32 .06 53.8 2378 923.04 1.14 13.2 7 15 2.48 12.46 2.49 .43 31.8 ANOVA Calculations: SSB = . n SSW- MSB = SSB/(k-l) MSW - SSW/(N-k) 105 ------- 1790g Example 1 (continued) F = MSB/MSW Where. k = number of treatment technologies n = number of data points for technology i N = number of natural log transformed data points for all technologies T = sum of log transformed data points for each technology 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) n = 10, n = 5, N = 15, k = 2, T = 23.18, T = 12.46. T = 35.64, T2= 1270, T2 = 537.3, T2 = 155.2. SSB -[ 537'3 + 155-2 ] - "" = 0.1233 10 5 I 15 SSW - (53.8 * 31.81 - I 537'3 + 155'31 =0.7600 10 5 MSB = 0.1233/1 = 0.1233 MSW = 0.76/13 = 0.0584 ANOVA Table F - - - 2 109 0.0584 Source Between (B) WUhin(W) Degrees of freedom 1 13 SS 0.1233 0.7600 MS 0.1233 0.0584 F 2.109 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). 106 ------- 1790g Example 2 TrichloToetnylene Steam Stri pp i ng Influent Ug/i) 1650.00 5200.00 5000.00 1720.00 1560.00 10300.00 210 00 1600.00 204.00 160.00 Effluent Ug/D 10.00 10.00 10 00 10 00 10.00 10 00 10 00 27.00 85.00 10.00 ln(eff luent) 2.30 2.30 2.30 2.30 2.30 2.30 2.30 3.30 4.44 2.30 O(effluent)]2 5.29 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 Ug/D 10.00 10.00 10.00 10.00 16.25 10.00 10.00 In(effluent) 2.30 2.30 2.30 2.30 2.79 2.30 2.30 O(efnuent)]2 5.29 5.29 5.29 5.29 7.78 5.29 5.29 Sum Sample Size 10 10 Mean. 2760 19.2 Standard Deviation- 3209 6 23 7 Var iabi 1 ity Factor- 26.14 10 2.61 71 72.9 220 120.5 3 76 10.89 2.36 1.51 16.59 2.37 .18 39.5 ANOVA Calculations: SSB = MSB = SSB/(k-l) MSW = SSW/(N-k) 107 ------- 1790g Example 2 (continued) F = MSB/MSW Where, k = number of treatment technologies n = number of data points for technology 1 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 = 10, N = 7, N = 17, k = 2. T = 26.14, T = 16.59. T = 42.73, 275.2. 1826, T = 683.3 10 1826 17 0.2325 10 = 4.856 MSB = 0.2325/1 = 0.2325 MSW = 4.856/15 * 0.3237 F. =0.7183 0.3237 ANOVA Table Source Between ( B) Uithin(U) Degrees of freedom 1 15 SS 0.2325 4.856 MS f 0.2325 0.7183 0.3237 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 , they are homogeneous) -108 ------- 1790g Example 3 Chlorobenzene Activated Sludge Followed by Carbon Influent Effluent In(effluent) Ug/1) Ug/D Sum: Sample Size. 4 Mean- 5703 [ln(eff luent)]2 Influent 49 Standard Deviation. 1835 4 32.24 Vanabi 1 ity Factor- 14.49 3.63 95 Biological Treatment Effluent In(effluent) (M9/D 55.3 14759 16311.86 7 00 452.5 379.04 15.79 38.90 5.56 1.42 [In (effluent)]2 7200.00 80.00 6500 00 70.00 6075.00 35.00 3040 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 8.01 228.4 ANOVA Calculations SSB = SSW - in MSB = SSB/(k-l) MSW = SSU/(N-k) F = MSB/MSW Where, 109 ------- 1790g Example 3 (continued) k = number of treatment technologies n = number of data points for technology i N = number of data points for all technologies T = sum of natural log transformed data points for each technology 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, J2= 2850. T2 = 210.0 T = 1513, n SSV = (55.3 + 228.4) i . + =14.96 MSB = 9.552/1 = 9.552 MSW = 14.96/9 = 1.662 F = 9.552/1.662 = 5.75 ANOVA Table Degrees of Source freedom Between (B) 1 Uithin(W) 9 SS MS F 9.552 9.552 5.75 14.96 1.662 The critical value of the F test at 0.05 significance level is 5.12. Since F value is larger than the critical value, the means are significantly different (i.e., they are heterogeneous). 110 ------- A.2. Variability Factor Cog 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: Cgq = 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 111 ------- has been used routinely in the EPA development of numerous regulations in the Effluent Guidelines program and in the BOAT program. The variability factor (VF) was defined as the ratio of the 99th percentile (C ) of the lognormal distribution to its arithmetic mean (Mean). VF = C99 (1) Mean The relationship between the parameters of the lognormal distribution and the parameters of the normal distribution created by taking the natural logarithms of the lognormally-distributed concentrations can be found in most mathematical statistics texts (see for example: Distribution in Statistics-Volume 1 by Johnson and Kotz, 1970). The mean of the lognormal distribution can be expressed in terms of the mean (n) and standard deviation (a) of the normal distribution as fol1ows: C9g = Exp (/, + 2.33a) (2) Mean = Exp (» + ,5a2) (3) Substituting (2) and (3) in (1) the variability factor can then be expressed in terms of a as follows: VF = Exp (2.33 a - .5a2) (4) For residuals with concentrations that are not all below the detection limit, the 99 percentile and the mean can be estimated from the actual analytical data and accordingly, the variability factor (VF) 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. 112 ------- 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 = 2.8 113 ------- APPENDIX B 114 ------- 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 of Waste; Physical/Chemical Methods, SW-846, Third Edition, November 1986) are used in most cases for determining total constituent concentrations. The accuracy determination for a constituent is based on the matrix spike recovery values. Tables B-2 and B-3 present the matrix spike recoveries for disulfoton and toluene total composition analyses for K037 residuals for the EPA-collected data. The accuracy correction factors for disulfoton and toluene for each treatment residual are summarized in Tables B-2 and B-3. The accuracy correction factors were determined in accordance with the general methodology presented in the Introduction. For example, for disulfoton actual spike recovery data were obtained for analysis of both solid and liquid matrices, and the lowest percent recovery value was used to calculate the accuracy correction factor. An example of the calculation of a corrected constituent concentration value is shown below. Analytical Correction Corrected Value % Recovery Factor Value 0.0335 ppm 91 100 =1 10 1.10 x 0.0335 = 0.04 ppm 91 115 ------- 148bg Table B-l Analytical Methods for Regulated Constituents Analytical Regulated constituent Extraction method method Reference TOTAL COMPOSITION Disulfoton Specified in analytical method 8140 3 Toluene Specified in analytical method 5030, 8240 3 116 ------- Table B-2 Matrix Spike Recoveries for K037 Treated Solids - EPA-Collected Data Set BOAT Original amount Spike added Spike result Percent constituent found (ug/1) (ug/1) (ug/1) recovery* Sample Set *5 Duplicate jpike added (ug/1) Spike result (ug/1) Percent recovery' Accu^acv correct ion factor "* Disulfoton Toluene <0 007 NC 0 173 0.157 NC 91 166 0 173 25 0 164 NC 165 1 10 1 00 NC = Not calculable because the only values available were the spike amount and the percent recovery 'Percent Recovery = [(Spike Result - Original Amount)/Spike Added] "Accuracy Correction Factor = 100/Percent Recovery (using the lowest percent recovery value) Reference USEPA 19d7 Onsite Engineering Report for K037. ------- Table B-5 Matrix Spike Recoveries for K037 Scrubber Water Sample - EPA-Col lecteci Data Sample Set *5 Sample Set *5 Duplicate BDAT Original amount Spike added Spike result Percent Spike added Spike result Percent constituent found (ug/1) (uci/1) (ug/1) recovery* (ug/1) (ug 1) recovery' Disulfoton <0.2 5.18 4 66 94 5.16 5 2H 1C? Toluene NC 25 NC 109 25 NC 116 Accurar v correct ion factor ' ' 1 06 1 00 NC = Not calculable because the only values available were the spike amount and the percent recovery. 'Percent Recovery = [(Spike Result - Original Amount)/Spike Added]. *'Accuracy Correction Factor = 100/Percent Recovery (using the lowest percent recovery value) 00 R eference USEPA 1987 Onsite Engineering Report for K037 ------- APPENDIX C 119 ------- Appendix Detection Limits for K037 Untreated and Treated Samples BOAT Ret No 222 1 2 3 4 5. 6 223 7 b 9. 10 11. 12. 13 14 15 16. 17 18. 19 20 21 22 23 24 25 26. 27 2b 29 224. Pjrameter Volrft i les Acetone Aceton 1 1 n le Act o lei n Aery lonitri le Benzene Bromodichloromethane Bromomethdne n-Butyl alcohol Carbon Tetrachloride Carbon bisulfide Chlorobenzene 2-Ch loro- 1 , 3-butabiene Chlorodibromomethane Chloroethane 2-Ch loroethy 1 vinyl ether Chloroform Chloromethane 3-Chloropropene l,2-Dibromo-3-chloropropane 1 ,2-Dibromoethane Dibromomethane Trans-l,4-Dichloro-2-butene Dichlorodif luoromethane 1 , 1-Dichloroethane 1 ,2-Dichloroethane 1 , 1-Dich loroethy lene Trans- 1 ,2-Dichloroethene 1 ,2-Dichloropropane Trans- 1 ,3-Dichloropropene cis-1 ,3-Dichloropropene 1 ,4-Dioxane 2-Ethoxyethanol CAS no 67-64-1 75-05-8 107-02-8 107-13-1 71-43-2 75-27-4 74-83-9 71-36-3 56-23-5 75-15-0 108-90-7 126-99-8 124-48-1 75-00-3 110-75-8 67-66-3 74-87-3 107-05-1 96-12-8 106-93-4 74-95-3 110-57-6 75-34-3 107-06-2 75-35-4 156-60-5 78-87-5 10061-02-6 10061-01-5 123-91-1 107-12-0 110-80-5 Untreated Waste (mg/kg) NL 10,000 25,000 500 100 100 500 NL 100 500 100 2500 100 500 10,000 100 500 100 100 100 100 2500 100 100 100 100 100 250 250 250 NA NL Treated Waste (mg/kg) NL 1000 2500 50 10 10 50 NL 10 50 10 250 10 50 1000 10 50 10 10 10 10 250 10 10 10 10 10 25 25 25 NA NL Treated Waste TCLP (mg/1) NL 1000 2500 50 10 10 50 NL 10 50 10 250 10 50 1000 10 50 10 10 10 10 250 10 10 10 10 10 25 25 25 NA NL Scrubber Water Ug/D NL 1000 2500 50 10 10 50 NL 10 50 10 250 10 50 1000 10 50 10 10 10 10 250 10 10 10 10 10 25 25 25 NA NL 120 ------- Appendix C (Continued) BOAT Ref No 225 226 30 227 31 214 32 3-, 22b ^4 229 35 36 37 3t> 230 30 40 41 42 43 44. 45 46. 47 48 4y 231 50 215 216 217 Parameter Voldt i les (cont inued) Eth>l acetate Ethyl benzene Ethyl cyanide Ethy 1 ether Fth> 1 methacrylate Ethylene oxide lodomethane Isobutyl alcohol Methano 1 Methyl ethyl ketone Methyl isobutyl ketone Methyl methacrylate Methyl methanesulf onate Methacrylomtr i le Methylene chloride i-N i tropropane Pyr id me 1,1,1 ,2-Tetrachloroethane 1 , 1 ,2,2-Tetrachloroethane Tetrach loroethene Toluene Tribroinomethane 1,1,1-Tnchloroe thane 1,1, 2-Trichloroethane Trichloroethene Trichloromonof luorome thane 1 ,2.3-Tnchloropropane l,l,2-Tnchloro-l,2,2- trif luoroethane Vinyl chloride 1,2-Xylene 1,3-Xylene 1 , 4-Xy lene CAS no. 141-78-6 100-41-4 97-63-2 60-29-7 75-21-8 75-21-8 74-8B.-4 78-83-1 67-56-1 78-93-3 108-10-1 80-62-6 66-27-3 ' 126-98-7 75-09-2 79-46-9 110-86-1 630-20-6 79-34-6 127-18-4 108-88-3 75-25-2 71-55-6 79-00-5 79-01-6 75-69-4 96-18-4 76-13-1 75-01-4 97-47-6 108-38-3 106-44-5 Untreated Waste (ing/kg) NL NL NA NL 500 NL 100 NA NL 2500 NL 500 NA NA 2500 NL - 100 100 100 100 100 100 100 100 100 2500 NL 500 NL NL NL Treated Waste (mg/kg) NL NL NA NL 50 NL 10 NA NL 250 NL 50 NA NA 250 NL - 10 10 10 10 10 10 10 10 10 250 NL 50 NL NL NL Treated Waste TCLP (mg/1) Nl NL NA NL 50 NL 10 NA NL 250 NL 50 NA NA 250 NL - 10 10 10 10 10 10 10 10 10 250 NL 50 NL NL NL Scrubber Water Ug/i) NL NL NA NL 50 NL 10 NA NL 250 NL 50 NA NA 250 NL - 10 10 10 10 10 10 10 10 10 250 NL 50 NL NL NL 121 ------- Appendix C (Continued) BOAT Ref No 51 52 53 b4. Sc, 56 57 5b 59 218 60 61. 62. 63. 64 65. 66. 67 68. 69. 70. 71 72. 73. 74 75. 76. 77 76 79. 80. 81 82. Parameter Semivolat i les Acendphthalene Acenaphthene Acetophenone 2-Acety laminof luorene 4-Aminobiphenyl Am 1 me Anthracene Aramite benz(a)anthracene Benzal chloride Benzal chloride Benzenethiol Benzo(a)pyrene Benzo(b)f luoranthene Benzo(ghi Iperylene Benzo(k)f luoranthene p-Benzoquinone Bis(2-chloroethoxy)methane Bis(2-chloroethyl)ether Bis(2-chloroisopropyl)ether Bis(2-ethylhexyl)phthalate 4-Bromophenyl phenyl ether Butyl benzyl phthalate 2-sec-Butyl-4,6-dimtrophenol p-Chloroam 1 me Chlorobenzi late p-Chloro-m-cresol 2-Chloronaphtha lene 2-Chlorophenol 3-Chloropropionitrile Chrysene ortho-Cresol para-Cresol CAS no. 208-96-8 83-32-9 96-86-2 53-96-3 92-67-1 62-53-3 120-12-7 140-57-8 56-55-3 98-87-3 98-87-3 108-98-5 50-32-8 205-99-2 191-24-2 207-08-9 106-51-4 111-91-1 111-44-4 39638-32-9 117-81-7 101-55-3 85-68-7 88-85-7 106-47-8 510-15-6 59-50-7 91-58-7 95-57-8 542-76-7 218-01-9 95-48-7 106-44-5 Untreated Waste (mg/kg) 250 250 250 25,000 5,000 500 250 NA 250 NL NA 25,000 250 250 250 250 25,000 250 250 250 250 250 250 NA 2,500 NA 250 250 250 NA 250 250 250 Treated Waste (mg/kg) 2.0 2.0 2.0 200.0 35 0 3.5 2.0 NA 2.0 NL NA 200 0 2 0 2.0 2.0 2.0 200.0 2.0 2.0 2.0 2.0 2.0 2.0 NA 2.0 NA 2 0 2.0 2.0 NA 2.0 2.0 2.0 Treated Waste TCLP (mg/1) 50 50 50 5,000 1,000 100 50 NA 50 NL NA 5,000 50 50 50 50 5,000 50 50 50 50 50 50 NA 500 NA 50 50 50 NA 50 50 50 Scrubber Water Ug/D 50 50 50 5,000 1,000 100 50 NA 50 NL NA 5,000 50 50 50 50 5,000 50 50 50 50 50 50 NA 500 NA 50 50 50 NA 50 50 50 122 ------- Appendix C (Continued) BOAT Ret- No 23': bo 84 85 bt. b7 88 89 90 91 9? 93 94 95 96 97 98 99 100 101 102 103 104 105 106. 219 107 106 109 110 111 112 113 Parameter semivolflt i les (continued) Cyc lohexanone Dibenz(d,h)anthraLene Dibenzo(a,e)pyrene Dibenzo(a, i )pyrene m-D ichlorobenzene o-Dichlorobenzerie p-Dichlorobenzene 3,3 ' -Dichlorobenzidine I , 4-Dich lorophenol 2 , 6-D ich lorophenol Diethyl phthalate 3,3 ' -Dnnethoxybenzidine p- 0 1 methyl am moazobenzene 3,3 ' -Dimethy Ibenzidine 2,4-Dimethylphenol Dimethyl phthalate Di-n-butyl phthalate 1 ,4-Dimtrobenzene 4,6-Dinitro-o-cresol 2,4-Dinitrophenol 2, 4-0 in i trotoluene 2, 6-Dini trotoluene Di-n-octyl phthalate Di-n-propylnitrosamme Dipheny lamine Diphenyln itrosamine 1 ,2-Diphenylhydrazine Fluoranthene F luorene Hexachlorobenzene Hexachlorobutadiene Hexachlorocyc lopentadlene Hexachloroethane CAS no. 108-94-1 53-70-3 192-65-4 189-55-9 541-73-1 95-50-1 106-46-7 91-94-1 120-83-2 87-65-0 84-66-2 119-90-4 60-11-7 119-93-7 105-67-9 131-11-3 84-74-2 100-25-4 534-52-1 51-28-5 121-14-2 606-20-2 117-84-0 621-64-7 122-39-4 86-30-6 122-66-7 206-44-0 B6-73-7 118-74-1 87-68-3 77-47-4 67-72-1 Untreated Waste (mg/kg) NL 250 250 250 250 250 250 500 250 250 250 250,000 5,000 250,000 250 250 250 2,500 1,250 1,250 250 250 250 - 250 250 250 250 250 250 250 250 250 Treated Waste (mg/kg) NL 2.0 2.0 2.0 2.0 2 0 2.0 3.5 2.0 2 0 2.0 2000.0 35.0 2000 0 2 0 2 0 2.0 20 0 10.0 10.0 2 0 2.0 2 0 - 2.0 2.0 2.0 2.0 2.0 2.0 2 0 2 0 2.0 Treated Waste TCLP (mg/1) NL 50 50 50 50 50 50 100 50 50 50 50,000 1,000 50,000 50 50 50 500 250 250 50 50 50 - 50 50 50 50 50 50 50 50 50 Scrubber Water Ug/D NL 50 50 50 50 50 50 100 50 50 50 50,000 1,000 50,000 50 50 50 500 250 250 50 50 50 - 50 50 50 50 50 50 50 50 50 123 ------- Appendix C. (Continued) BOAT Ret No 114. 115 116 117 lib. 119 120 in 122 123 124 125 126. 127. 126 129 130 131 132 133 134 135 136 137 138 139 140 141 142 220 143 Parameter c.emi vcltit i IPS (cont mued) Hexachlorophene Hexach loropropene Indeno( 1 ,2,3-cd)pyrene Isosaf role Methapyr ) lene 3-Methy kholanthrene 4,4' -Methylenebis (2-chloroani 1 me) Naphtha lene 1 ,4-Ndphthoqumone l-Niipnthylamine 2-Naphthylamine p-Nitroani 1 me Nitrobenzene 4-Nitrophenol N-Nitrosodi-n-butylamme N-Nitrosodiethylamme N-Nitrosodimethylamine N-Nitrosomethylethylamme N-N itrosomorphol me N-Nitrosopiperidme n-NitrobOpyrrol id me 5-Nitro-o-toluidine Pentachlorobenzene Pentachloroethane Pentachloronltrobenzene Pentachlorophenol Phenacet in Phenanthrene Phenol Phtha 1 ic anhydride 2-Picolme CAS no 70-30-4 1888-71-7 193-39-5 120-58-1 91-80-5 56-49-5 101-14-4 91-20-3 130-15-4 134-32-7 91-59-8 100-01-6 98-95-3 100-02-7 924-16-3 55-18-5 62-75-9 10595-95-6 59-89-2 100-75-4 930-55-2 99-65-8 608-93-5 76-01-7 82-68-8 87-86-5 62-44-2 85-01-8 108-95-2 85-44-9 109-06-8 Untreated Waste (mg/kg) NA 250 250 2.500 NA 2500 5,000 250 2,500 2,500 2,500 1,250 250 1,250 2,500 2,500 2,500 2,500 5,000 5,000 5,000 5,000 250 250 2,500 1,250 2,500 250 250 NL 2 , 500 Treated waste (mg/kg) NA 2.0 2.0 20.0 NA 20 0 35.0 2.0 20 0 20.0 20.0 10.0 2.0 10.0 20.0 20.0 20.0 20.0 35.0 35 0 35.0 35.0 2.0 2.0 20.0 10.0 20.0 2 0 2.0 NL 20.0 Treated Waste TCLP (mg/1) NA 50 50 500 NA 500 1,000 50 500 500 500 250 50 250 500 500 500 500 1,000 1,000 1,000 1,000 50 50 500 250 500 50 50 NL 500 Scrubber Water (wg/l) NA 50 50 500 NA 500 1,000 50 500 500 500 250 50 250 500 500 500 500 1.000 1,000 " 1,000 1.000 50 50 500 250 500 50 50 NL 500 ------- 1553g Appendix C (Continued) BOAT Ref No 144 145 146 147 14B 149 150 151 152 153 154 155 156. 157. 158 159 221. 160 161 162 163. 164 165 166 167 168 Parameter Semtvolat i les (cont ) Pronamide Pyrene Resorcinol Saf role 1 , 2,4,5- Tetrachlorobenzene 2 ,3, 4, 6- let rath loropheno 1 1 ,2,4-Trichlorohen?ene 2,4. 5-Tnch loropheno 1 2 ,4, 6-Tr ichlorophenol Tris(2,3-dibromopropyl ) phosphate Metals Ant imony Arsenic Barium bery 1 1 lum Cadmium Chromium (total) Chromium (hexavalent) Copper Lead Mercury Nickel Selenium Si Iver Thai 1 lum Vanadium Z me CAS no 23950-58-5 129-00-0 108-46-3 94-59-7 95-94-3 58-90-2 120-82-1 95-95-4 88-06-2 126-72-7 7440-36-0 7440-38-2 7440-39-3 7440-41-7 7440-43-9 7440-47-32 7440-50-8 7439-92-1 7439-97-6 7440-02-0 7782-49-2 7440-22-4 7440-28-0 7440-62-2 7440-66-6 Untreated Waste (mg/kg) 2,500 250 25,000 2,500 2,500 2,500 250 1,250 250 NA 17.0 2.0 1.0 0.5 2 0 3.5 NL 3.0 1 0 1.25 7.5 2 0 3.5 2.5 4.0 1 0 Treated Waste (mg/kg) 20.0 2.0 2000.0 20.0 2.0 20.0 2.0 10.0 2.0 NA 17.0 2.0 1.0 0.5 2.0 3.5 NL 3.0 1.0 1.25 7.5 2.0 3.5 2.5 4.0 1 0 Treated Waste TCLP (mg/1) 500 50 5,000 500 50 500 50 250 50 NA 0.3 0.01 0.045 0.005 0.015 0.045 NL 0.05 0.01 0.001 0.1 0.015 0.045 0.015 0.1 0.03 Scrubber Water (Mg/1) 500 50 5,000 500 50 500 50 250 50 NA 0.3 0.01 0.045 0.005 0.015 0.045 NL 0.05 0.01 0.001 0.1 0 015 0.045 0 015 0.1 0 03 125 ------- 1553g Appendix C (Continued) BOAT Ref . No 169 170 171 172 173 174 175 176. 177. 178 179 ISO 1B1 Ib2 Ib3 Ib4 IBS 186. 187 180 1B9. 190 191 192 193. 194 Parameter Inorganics Cyanide Fluoride Sulf ids Orqanochlor me Pesticides Aldrin alpha-BHC heta-BHC delta-BHC gamma -BHC Chlorddfie ODD DDE DDT Die Idr in Endosultan I Endosu If an 1 1 Endr in Endrin aldehyde HeptacMor Heptacnlor epoxide Isodr in Kepone Methoxyc lor Toxaphene Phenox vjcet ic Acid Herbicides 2 , 4-Dichlorophenoxyacet ic acid S i Ivex 2,4,5-1 CAS no 57-12-5 16964-48-8 8496-25-8 309-00-2 319-84-6 319-85-7 319-86-8 58-89-9 57-74-9 72-54-8 72-55-9 50-29-3 60-57-1 939-98-8 33213-6-5 72-20-8 7421-93-4 76-44-8 1024-57-3 465-73-6 143-50-0 72-43-5 8001-35-2 94-75-7 93-72-1 93-76-5 Untreated Waste (mg/kg) - - - 7.5 4 0 7 5 7 5 5.0 100 15.0 7 5 15.0 7 5 7 5 7 5 7.5 15.0 5 0 7.5 7.5 40.0 25.0 1.000 0 385 0.385 0.385 Treated Treated Waste Waste TCLP (mg/kg) (mg/1) - - - 5.0 2.5 5.0 5.0 5.0 75 10.0 5.0 10.0 5.0 5.0 5.0 5.0 10.0 5.0 5.0 5.0 30.0 15 0 500 0 10 0 10 0.10 Scrubber Water Ug/D 0.05 0.05 5 0.15 0.10 0.15 0.15 0.10 1.00 0.30 0.15 0.30 0.15 0.15 0.15 0.15 0.30 0.10 0.15 0.15 0.80 0 50 10 0 2 5 2.5 2.5 126 ------- Appendix C (Continued) BDA1 Ref No 1^5 Un6 197 198 199 200 201. 202 203 204 205 206 207. 208 209. 210. 211 212 213 Parameter Orq.incpnosphorous Insect ic ides Diiu Itoton Fainphur Methyl pcirathion Parathion Phorate PCBs Aroclor 1016 Aroclor 1221 Aroclor 1232 Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 Dioxins and Furans Hexach 1 o rod ibenzo-p-di ox ins Hexach lorodibenzofu ran Pentachlorodibenzo-p-dioxins Pentachlorodibenzoturan Tetrachlorodibenzo-p-dioxlns Tetrach lorodibenzofu ran CAS no 298-04-4 52-85-7 298-00-0 56-38-2 298-02-2 12674-11-2 11104-28-2 11141-16-5 53469-21-9 12672-29-6 11097-69-1 11096-82-5 Untreated Uaste (mg/kq) 5,000 12,500 5,000 3,750 2,500 1,000 1,000 1.000 1,000 1,000 300 400 NA NA NA NA 0 53* NA Treated Treated Waste Waste TCLP (mg/kg) (mg/1) 0.0335 0 085 0 0335 0 0250 0.0165 500 500 500 500 500 250 250 0 15* 0.87* 0 51* 0.35* 0.39* 0.22* Scrubber Water Ug/D 1.00 2.50 1.00 0.75 0.50 10.0 10.0 10.0 10 0 10 0 3.00 4.00 5.6** 3 7** 2 4** 2 1** 2 6** 1.6** 2,3,7,8-Tetrachlorodibenzo-p-dioxin - NL = Not on list at the time analysis was performed - = No analysis performed * = Units are ng/'g ** = Units are ng/1 NA = Not detected, however, surrogates not recovered and detection limits cannot be calculated Reference USEPA 1987 Onsite Engineering Report. 127 ------- APPENDIX D 128 ------- 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. 129 ------- rO THERMOCOUPLE GUARD GRADIENT STACK GRADIENT CLAMP UPPER STACK HEATER TOP REFERENCE SAMPLE 1 ' / TESTSAMPLE \jjF ' +-J BOTTOM REFERENCE SAMPLE 1 LOWER STACK HEATER 1 LIQUID 'COOLED HEAT SINK 1 HEAT FLOW DIRECTION Figure 1. SCHEMATIC DIAGRAM OF THE COMPARATIVE METHOD UPPER GUARD HEATER 3C LOWER GUARD HEATER 130 ------- The stack is clamped with a reproducible load to insure intimate contact between the components. In order to produce a linear flow of heat down the stack and reduce the amount of heat that flows radially, a guard tube is placed around the stack and the intervening space is filled with insulating grains or powder. The temperature gradient in the guard is matched to that in the stack to further reduce radial heat flow. The comparative method is a steady state method of measuring thermal conductivity. When equilibrium is reached the heat flux (analogous to current flow) down the stack can be determined from the references. The heat into the sample is given by Q. = A+ (dT/dx). in top top and the heat out of the sample is given by Qout = AU _ (dT/dx), bottom bottom where A = thermal conductivity dT/dx = temperature gradient and top refers to the upper reference while bottom refers to the lower reference. If the heat was confined to flow just down the stack, then Q and Q would be equal. If Q. and Q are in reasonable in out in out agreement, the average heat flow is calculated from 0 ' '"in + Qout)/2 The sample thermal conductivity is then found from A . = Q/(dT/dx) sample sample 131 ------- REFERENCES 1. Ackerman DG, McGaughey JF, Wagoner D.E., "At Sea Incineration of PCB-Containing Wastes on Board the M/T Vulcanus," USEPA, 600/7-83-024, April 1983. 2. Bonner TA, et al., Engineering Handbook for Hazardous Waste Incineration. Prepared by Monsanto Research Corporation for U.S. EPA NTIS PB 81-248163. June 1981. 3. Novak RG, Troxler WL, Dehnke TH, "Recovering Energy from Hazardous Waste Incineration," Chemical Engineering Progress 91:146 (1984). 4. Oppelt ET, "Incineration of Hazardous Waste"; JAPCA; Volume 37, No. 5; May 1987. 5. Personal communication with Jack J. Lonsinger, Environmental Control Manager, Mobay Corporation Agricultural Chemicals Division, February 9, 1987. 6. Santoleri JJ, "Energy Recovery-A By-Product of Hazardous Waste Incineration Systems," in Proceedings of the 15th Mid-Atlantic Industrial Waste Conference on Toxic and Hazardous Waste, 1983. 7. SRI. 1986. Stanford Research Institute. Directory of chemical producers - United States of America. Menlo Park, California: Stanford Research Institute International. 8. USEPA. 1980. U.S. Environmental Protection Agency. RCRA listing background document, waste code K036/K037. 9. USEPA. 1986a. "Best Demonstrated Available Technology (BOAT) Background Document for F001-F005 Spent Solvents," Volume 1, EPA/530-SW-86-056, November 1986. 10. USEPA. 1986b. U.S. Environmental Protection Agency, Office of Solid Waste and Emergency Response. Test methods for evaluating solid waste. Third Edition. Washington, D.C.: U.S. Environmental Protection Agency. 132 ------- 11. USEPA. 1987a. Onsite engineering report of treatment technology performance and operation for incineration of K037 waste at the Combustion Research Facility. Draft Report. Washington, D.C.: U.S. Environmental Protection Agency. 12. USEPA. 1987b. Onsite Engineering Report of Treatment Technology Performance and Operation for Safety-Kleen Corporation, Hebron, Ohio. CBI Report. Washington, D.C.: U.S. Environmental Protection Agency. 13. USEPA 1987c. Onsite Engineering Report of Treatment Technology Performance and Operation for Amoco Oil Company, Whiting, Indiana. Draft Report. Washington, D.C.: U.S. Environmental Protection Agency. 14. Vogel G, et al., "Incineration and Cement Kiln Capacity for Hazardous Waste Treatment," in Proceedings of the 12th Annual Research Symposium. Incineration and Treatment of Hazardous Wastes. Cincinnati, Ohio. April 1986. 133 ------- |