&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
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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
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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
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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
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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
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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
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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
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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
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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
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1. INTRODUCTION
This section of the background document presents a summary of the
legal authority pursuant to which the BOAT treatment standards were
developed, a summary of EPA's promulgated methodology for developing
BOAT, and finally a discussion of the petition process that should be
followed to request a variance from the BOAT treatment standards.
1.1 Legal Background
1.1.1 Requirements Under HSWA
The Hazardous and Solid Waste Amendments of 1984 (HSWA), enacted on
November 8, 1984, and which amended the Resource Conservation and
Recovery Act of 1976 (RCRA), impose substantial new responsibilities on
those who handle hazardous waste. In particular, the amendments require
the Agency to promulgate regulations -that restrict the land disposal of
untreated hazardous wastes. In its enactment of HSWA, Congress stated
explicitly that "reliance on land disposal should be minimized or
eliminated, and land disposal, particularly landfill and surface
impoundment, should be the least favored method for managing hazardous
wastes" (RCRA section 1002(b)(7), 42 U.S.C. 6901(b)(7)).
One part of the amendments specifies dates on which particular groups
of untreated hazardous wastes will be prohibited from land disposal
unless "it has been demonstrated to the Administrator, to a reasonable
degree of certainty, that there will be no migration of hazardous
constituents from the disposal unit or injection zone for as long as the
wastes remain hazardous" (RCRA section 3004(d)(l), (e)(l), (g)(5), 42
U.S.C. 6924 (d)(l), (e)(l), (g)(5)).
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For the purpose of the restrictions, HSWA defines land disposal "to
include, but not be limited to, any placement of ... hazardous waste in
a landfill, surface impoundment, waste pile, injection well, land
treatment facility, salt dome formation, salt bed formation, or
underground mine or cave" (RCRA section 3004(k), 42 U.S.C. 6924(k)).
Although HSWA defines land disposal to include injection wells, such
disposal of solvents, dioxins, and certain other wastes, known as the
California List wastes, is covered on a separate schedule (RCRA section
3004(f)(2), 42 U.S.C. 6924 (f)(2)). This schedule requires that EPA
develop land disposal restrictions for deep well injection by
August 8, 1988.
The amendments also require the Agency to set "levels or methods of
treatment, if any, which substantially diminish the toxicity of the waste
or substantially reduce the likelihood of migration of hazardous
constituents from the waste so that short-term and long-term threats to
human health and the environment are minimized" (RCRA section 3004(m)(l),
42 U.S.C. 6924 (m)(l)). Wastes that meet treatment standards established
by EPA are not prohibited and may be land disposed. In setting treatment
standards for listed or characteristic wastes, EPA may establish
different standards for particular wastes within a single waste code with
differing treatability characteristics. One such characteristic is the
physical form of the waste. This frequently leads to different standards
for wastewaters and nonwastewaters.
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alternatively, EPA can establish a treatment standard that is applicable
to more than one waste code when, in EPA's judgment, all the waste can be
treated to the same concentration. In those instances where a generator
can demonstrate that the standard promulgated for the generator's waste
cannot be achieved, the Agency also can grant a variance from a treatment
standard by revising the treatment standard for that particular waste
through rulemaking procedures. (A further discussion of treatment
variances is provided in Section 1.3.)
The land disposal restrictions are effective when promulgated unless
the Administrator grants a national variance and establishes a different
date (not to exceed 2 years beyond the statutory deadline) based on "the
earliest date on which adequate alternative treatment, recovery, or
disposal capacity which protects human health and the environment will be
available" (RCRA section 3004(h)(2), 42 U.S.C. 6924 (h)(2)).
If EPA fails to set a treatment standard by the statutory deadline
for any hazardous waste in the First Third or Second Third of the
schedule (see section 1.1.2), the waste may not be disposed in a landfill
or surface impoundment unless the facility is in compliance with the
minimum technological requirements specified in section 3004(o) of RCRA.
In addition, prior to disposal, the generator must certify to the
Administrator that the availability of treatment capacity has been
investigated and it has been determined that disposal in a landfill or
surface impoundment is the only practical alternative to treatment
currently available to the generator. This restriction on the use of
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landfills and surface impoundments applies until EPA sets a treatment
standard for the waste or until May 8, 1990, whichever is sooner. If the
Agency fails to set a treatment standard for any ranked hazardous waste
by May 8, 1990, the waste is automatically prohibited from land disposal
unless the waste is placed in a land disposal unit that is the subject of
a successful "no migration" demonstration (RCRA section 3004(g), 42
U.S.C. 6924(g)). "No migration" demonstrations are based on case-
specific petitions that show there will be no migration of hazardous
constituents from the unit for as long as the waste remains hazardous.
1.1.2 Schedule for Developing Restrictions
Under Section 3004(g) of RCRA, EPA was required to establish a
schedule for developing treatment standards for all wastes that the
Agency had listed as hazardous by November 8, 1984. Section 3004(g)
required that this schedule consider the intrinsic hazards and volumes
associated with each of these wastes. The statute required EPA to set
treatment standards according to the following schedule:
(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).
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The statute specifically identified the solvent wastes as those
covered under waste codes F001, F002, F003, F004, and F005; it identified
the dioxin-containing hazardous wastes as those covered under waste codes
F020, F021, F022, and F023.
Wastes collectively known as the California List wastes, defined
under Section 3004(d) of HSWA, are liquid hazardous wastes containing
metals, free cyanides, PCBs, corrosives (i.e., a pH less than or equal to
2.0), and any liquid or nonliquid hazardous waste containing halogenated
organic compounds (HOCs) above 0.1 percent by weight. Rules for the
California List were proposed on December 11, 1986, and final rules for
PCBs, corrosives, and HOC-containing wastes were established
August 12, 1987. In that rule, EPA elected not to establish standards
for metals. Therefore, the statutory limits became effective.
On May 28, 1986, EPA published a final rule (51 FR 19300) that
delineated the specific waste codes that would be addressed by the First
Third, Second Third, and Third Third. This schedule is incorporated into
40 CFR 268.10, .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.
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Congress indicated in the legislative history accompanying the HSWA
that "[t]he requisite levels of [sic] methods of treatment established by
the Agency should be the best that has been demonstrated to be
achievable," noting that the intent is "to require utilization of
available technology" and not a "process which contemplates
technology-forcing standards" (Vol. 130 Cong. Rec. S9178 (daily ed.,
July 25, 1984)). EPA has interpreted this legislative history as
suggesting that Congress considered the requirement under 3004(m) to be
met by application of the best demonstrated and achievable (i.e.,
available) technology prior to land disposal of wastes or treatment
residuals. Accordingly, EPA's treatment standards are generally based on
the performance of the best demonstrated available technology (BOAT)
identified for treatment of the hazardous constituents. This approach
involves the identification of potential treatment systems, the
determination of whether they are demonstrated and available, and the
collection of treatment data from well-designed and well-operated systems.
The treatment standards, according to the statute, can represent
levels or methods of treatment, if any, that substantially diminish the
toxicity of the waste or substantially reduce the likelihood of migration
of hazardous constituents. Wherever possible, the Agency prefers to
establish BOAT treatment standards as "levels" of treatment
(i.e., performance standards) rather than adopting an approach that would
require the use of specific treatment "methods." EPA believes that
concentration-based treatment levels offer the regulated community greater
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flexibility to develop and implement compliance strategies as well as an
incentive to develop innovative technologies.
1.2.1 Waste Treatability Group
In developing the treatment standards, EPA first characterizes the
waste(s). As necessary, EPA may establish treatability groups for wastes
having similar physical and chemical properties. That is, if EPA
believes that wastes represented by different waste codes could be
treated to similar concentrations using identical technologies, the
Agency combines the codes into one treatability group. EPA generally
considers wastes to be similar when they are both generated from the same
industry and from similar processing stages. In addition, EPA may
combine two or more separate wastes into the same treatability group when
data are available showing that the waste characteristics affecting
performance are similar or that one waste would be expected to be less
difficult to treat.
Once the treatability groups have been established, EPA collects and
analyzes data on identified technologies used to treat the wastes in each
treatability group. The technologies evaluated must be demonstrated on
the waste or a similar waste and must be available for use.
1.2.2 Demonstrated and Available Treatment Technologies
Consistent with legislative history, EPA considers demonstrated
technologies to be those that are used to treat the waste of interest or
a similar waste with regard to parameters that 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
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other materials. Some of these technologies clearly are applicable to
waste treatment, since the wastes are similar to raw materials processed
in industrial applications.
For most of the waste treatability groups for which EPA will
promulgate treatment standards, EPA will identify demonstrated
technologies either through review of literature related to current waste
treatment practices or on the basis of information provided by specific
facilities currently treating the waste or similar wastes.
In cases where the Agency does not identify any facilities treating
wastes represented by a particular waste treatability group, EPA may
transfer a finding of demonstrated treatment. To do this, EPA will
compare the parameters affecting treatment selection for the waste
treatability group of interest to other wastes for which demonstrated
technologies already have been determined. The parameters affecting
treatment selection and their use for this waste are described in
Section 3.2 of this document. If the parameters affecting treatment
selection are similar, then the Agency will consider the treatment
technology also to be demonstrated for the waste of interest. For
example, EPA considers rotary kiln incineration a demonstrated technology
for many waste codes containing hazardous organic constituents, high
total organic content, and high filterable solids content, regardless of
whether any facility is currently treating these wastes. The basis for
this determination is data found in literature and data generated by EPA
confirming the use of rotary kiln incineration on wastes having the above
characteristics.
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If no commercial treatment or recovery operations are identified for
a waste or wastes with similar physical or chemical characteristics that
affect treatment selection, the Agency will be unable to identify any
demonstrated treatment technologies for the waste, and, accordingly, the
waste will be prohibited from land disposal (unless handled in accordance
with the exemption and variance provisions of the rule). The Agency is,
however, committed to establishing treatment standards as soon as new or
improved treatment processes are demonstrated (and available).
Operations only available at research facilities, pilot- and bench-
scale operations will not be considered in identifying demonstrated
treatment technologies for a waste because these technologies would not
necessarily be "demonstrated." Nevertheless, EPA may use data generated
at research facilities in assessing the performance of demonstrated
technologies.
As discussed earlier, Congress intended that technologies used to
establish treatment standards under Section 3004(m) be not only
"demonstrated," but also available. To decide whether demonstrated
technologies may be considered "available," the Agency determines whether
they (1) are commercially available and (2) substantially diminish the
toxicity of the waste or substantially reduce the likelihood of migration
of hazardous constituents from the waste.
EPA will only set treatment standards based on a technology that
meets the above criteria. Thus, the decision to classify a technology as
"unavailable" will have a direct impact on the treatment standard. If
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the best technology is unavailable, the treatment standard will be based
on the next best treatment technology determined to be available. To the
extent that the resulting treatment standards are less stringent, greater
concentrations of hazardous constituents in the treatment residuals could
be placed in land disposal units.
There also may be circumstances in which EPA concludes that for a
given waste none of the demonstrated treatment technologies are
"available" for purposes of establishing the 3004(m) treatment
performance standards. Subsequently, these wastes will be prohibited
from continued placement in or on the land unless managed in accordance
with applicable exemptions and variance provisions. The Agency is,
however, committed to establishing new treatment standards as soon as new
or improved treatment processes become "available."
(1) Proprietary or Patented Processes. If the demonstrated
treatment technology is a proprietary or patented process that is not
generally available, EPA will not consider the technology in its
determination of the treatment standards. EPA will consider proprietary
or patented processes available if it determines that the treatment
method can be purchased or licensed from the proprietor or is
commercially available treatment. The services of the commercial
facility offering this technology often can be purchased even if the
technology itself cannot be purchased.
(2) Substantial Treatment. To be considered "available," a
demonstrated treatment technology must "substantially diminish the
10
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toxicity" of the waste or "substantially reduce the likelihood of
migration of hazardous constituents" from the waste in accordance with
section 3004(m). By requiring that substantial treatment be achieved in
order to set a treatment standard, the statute ensures that all wastes
are adequately treated before being placed in or on the land and ensures
that the Agency does not require a treatment method that provides little
or no environmental benefit. Treatment will always be deemed substantial
if it results in nondetectable levels of the hazardous constituents of
concern. If nondetectable levels are not achieved, then a determination
of substantial treatment will be made on a case-by-case basis. This
approach is necessary because of the difficulty of establishing a
meaningful guideline that can be applied broadly to the many wastes and
technologies to be considered. EPA will consider the following factors
in an effort to evaluate whether a technology provides substantial
treatment on a case-by-case basis:
(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
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of well-designed and well-operated treatment systems. Only data from
well-designed and well-operated systems are included in determining
BOAT. The data evaluation includes data already collected directly by
EPA and/or data provided by industry. In those instances where
additional data are needed to supplement existing information, EPA
collects additional data through a sampling and analysis program. The
principal elements of this data collection program are: (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
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(TSDFs); and (4) EPA in-house treatment. This hierarchy is based on two
concepts: (1) to the extent possible, EPA should develop treatment
standards from data produced by treatment facilities handling only a
single waste, and (2) facilities that routinely treat a specific waste
have had the best opportunity to optimize design parameters. Although
excellent treatment can occur at many facilities that are not high in
this hierarchy, EPA has adopted this approach to avoid, when possible,
ambiguities related to the mixing of wastes before and during treatment.
When possible, the Agency will evaluate treatment technologies using
commercially operated systems. If performance data from properly
designed and operated commercial treatment methods for a particular waste
or a waste judged to be similar are not available, EPA may use data from
research facilities operations. Whenever research facility data are
used, EPA will explain 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.
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(2) Engineering Site Visit. Once a treatment facility has been
selected, an engineering site visit is made to confirm that a candidate
for sampling meets EPA's criteria for a well-designed facility and to
ensure that the necessary sampling points can be accessed to determine
operating parameters and treatment effectiveness. During the visit, EPA
also confirms that the facility appears to be well operated, although the
actual operation of the treatment system during sampling is the basis for
EPA's decisions regarding proper operation of the treatment unit. In
general, the Agency considers a well-designed facility to be one that
contains the unit operations necessary to treat the various hazardous
constituents of the waste as well as to control other nonhazardous
materials in the waste that may affect treatment performance.
In addition to ensuring that a system is reasonably well designed,
the engineering visit examines whether the facility has a way to measure
the operating parameters that affect performance of the treatment system
during the waste treatment period. For example, EPA may choose not to
sample a treatment system that operates in a continuous mode, for which
an important operating parameter cannot be continuously recorded. In
such systems, instrumentation is important in determining whether the
treatment system is operating at design values during the waste treatment
period.
(3) Sampling and Analysis Plan. If after the engineering site visit
the Agency decides to sample a particular plant, the Agency will then
develop a site-specific Sampling and Analysis Plan (SAP) according to the
Generic Quality Assurance Project Plan for the Land Disposal Restriction
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Program ("BOAT"), EPA/530-SW-87-011. In brief, the SAP discusses where
the Agency plans to sample, how the samples will be taken, the frequency
of sampling, the constituents to be analyzed and the method of analysis,
operational parameters to be obtained, and specific laboratory quality
control checks on the analytical results.
The Agency will generally produce a draft of the site-specific
Sampling and Analysis Plan within 2 to 3 weeks of the engineering visit.
The draft of the SAP is then sent to the plant for review and comment.
With few exceptions, the draft SAP should be a confirmation of data
collection activities discussed with the plant personnel during the
engineering site visit. EPA encourages plant personnel to recommend any
modifications to the SAP that they believe will improve the quality of
the data.
It is important to note that sampling of a plant by EPA does not mean
that the data will be used in the development of treatment standards for
BOAT. EPA's final decision on whether to use data from a sampled plant
depends on the actual analysis of the waste being treated and on the
operating conditions at the time of sampling. Although EPA would not
plan to sample a facility that was not ostensibly well-designed and
well-operated, there is no way to ensure that at the time of the sampling
the facility will not experience operating problems. Additionally, EPA
statistically compares its test data to suitable industry-provided data,
where available, in its determination of what data to use in developing
treatment standards. The methodology for comparing data is presented
later in this section.
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(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.
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(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.
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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
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acceptable technologies. A detailed discussion of the treatment
selection method and an example of how EPA chooses BOAT from multiple
treatment systems is provided in Section A-l.
(3) Quality Assurance/Quality Control. This section presents the
principal quality assurance/quality control (QA/QC) procedures employed
in screening and adjusting the data to be used in the calculation of
treatment standards. Additional QA/QC procedures used in collecting and
screening data for the BOAT program are presented in EPA's Generic
Quality Assurance Project Plan for Land Disposal Restrictions Program
("BOAT") (EPA/530-SW-87-001, 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
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(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
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standards presented in Section 6 of this document. Accordingly,
facilities should use these procedures in assessing the performance of
their treatment systems.
1.2.7 BOAT Treatment Standards for "Derived-From" and "Mixed" Wastes
(1) Wastes from Treatment Trains Generating Multiple Residues. In a
number of instances, the proposed BOAT consists of a series of operations
each of which generates a waste residue. For example, the proposed BOAT
for a certain waste code is based on solvent extraction, steam stripping,
and activated carbon adsorption. Each of these treatment steps generates
a waste requiring treatment -- a solvent-containing stream from solvent
extraction, a stripper overhead, and spent activated carbon. Treatment
of these wastes may generate further residues; for instance, spent
activated carbon (.if not regenerated) could be incinerated, generating an
ash and possibly a scrubber water waste. Ultimately, additional wastes
are generated that may require land disposal. With respect to these
wastes, the Agency wishes to emphasize the following points:
(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
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to meet the treatment standard for nonwastewaters. All
derived-from wastes meeting the Agency definition of wastewater
(less than 1 percent TOC and less than 1 percent total
filterable solids) would have to meet the treatment standard for
wastewaters. EPA wishes to make clear that this approach is not
meant to allow partial treatment in order to comply with the
applicable standard.
(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
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residues will be less concentrated than the original listed waste. The
Agency's treatment standards also make a generous allowance for process
variability by assuming that all treatability values used to establish
the standard are lognormally distributed. The waste also might be
amenable to a relatively nonvariable form of treatment technology such as
incineration. Finally, and perhaps most important, the rules contain a
treatability variance that allows a petitioner to demonstrate that its
waste cannot be treated to the level specified in the rule (40 CFR Part
268.44(a). This provision provides a safety valve that allows persons
with unusual waste matrices to demonstrate the appropriateness of a
different standard. The Agency, to date, has not received any petitions
under this provision (for example, for residues contaminated with a
prohibited solvent waste), indicating, in the Agency's view, that the
existing standards are generally achievable.
(3) Residues from Managing Listed Wastes or that Contain Listed
Wastes. The Agency has been asked if and when residues from
managing hazardous wastes, such as leachate and contaminated ground
water, become subject to the land disposal prohibitions. Although the
Agency believes this question to be settled by existing rules and
interpretative statements, to avoid any possible confusion the Agency
will address the question again.
Residues from managing First Third wastes, listed California List
wastes, and spent solvent and dioxin wastes are all considered to be
subject to the prohibitions for the underlying hazardous waste. Residues
38
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from managing California List wastes likewise are subject to the
California List prohibitions when the residues themselves exhibit a
characteristic of hazardous waste. This determination stems directly
from the derived-from rule in 40 CFR Part 261.3(c)(2) or in some cases
from the fact that the waste is mixed with or otherwise contains the
listed waste. The underlying principle stated in all of these provisions
is that listed wastes remain listed until delisted.
The Agency's historic practice in processing delisting petitions
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
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1.2.8 Transfer of Treatment Standards
EPA is proposing some treatment standards that are not based on
testing of the treatment technology of the specific waste subject to the
treatment standard. Instead, the Agency has determined that the
constituents present in the subject waste can be treated to the same
performance levels as those observed in other wastes for which EPA has
previously developed treatment data. EPA believes that transferring
treatment performance for use in establishing treatment standards for
untested wastes is 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
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Second, when an individual analysis suggests that an untested waste
can be treated with the same technology as a waste for which treatment
performance data are already available, EPA analyzes a more detailed list
of constituents that represent some of the most important waste
characteristics that the Agency believes will affect the performance of
the technology. By examining and comparing these characteristics, the
Agency determines whether the untested wastes will achieve the same level
of treatment as the tested waste. Where the Agency determines that the
untested waste is easier to treat than the tested waste, the treatment
standards can be transferred. A detailed discussion of this transfer
process for each waste can be found in later sections of this document.
1.3 Variance from the BDAT Treatment Standard
The Agency recognizes that there may exist unique wastes that cannot
be treated to the level specified as the treatment standard. In such a
case, a generator or owner/operator may submit a petition to the
Administrator requesting a variance from the treatment standard. A
particular waste may be significantly different from the wastes
considered in establishing treatability groups because the waste contains
a more complex matrix that makes it more difficult to treat. For
example, complex mixtures may be formed when a restricted waste is mixed
with other waste streams by spills or other forms of inadvertent mixing.
As a result, the treatability of the restricted waste may be altered such
that it cannot meet the applicable treatment standard.
Variance petitions must demonstrate that the treatment standard
established for a given waste cannot be met. This demonstration can be
41
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made by showing that attempts to treat the waste by available
technologies were not successful or by performing appropriate analyses of
the waste, including waste characteristics affecting performance, which
demonstrate that the waste cannot be treated to the specified levels.
Variances will not be granted based solely on a showing that adequate
BOAT treatment capacity is unavailable. (Such demonstrations can be made
according to the provisions in Part 268.5 of RCRA for case-by-case
extensions of the effective date.) The Agency will consider granting
generic petitions provided that representative data are submitted to
support a variance for each facility covered by the petition.
Petitioners should submit at least one copy to:
The Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
An additional copy marked "Treatability Variance" should be submitted
to:
Chief, Waste Treatment Branch
Office of Solid Waste (WH-565)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Petitions containing confidential information should be sent with
only the inner envelope marked "Treatability Variance" and "Confidential
Business Information" and with the contents marked in accordance with the
requirements of 40 CFR Part 2 (41 PR 36902, September 1, 1976, amended by
43 FR 4000).
The petition should contain the following information:
42
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(1) The petitioner's name and address.
(2) A statement of the petitioner's interest in the proposed action.
(3) The name, address, and EPA identification number of the facility
generating the waste, and the name and telephone number of the
plant contact.
(4) The process(es) and feed materials generating the waste and an
assessment of whether such process(es) or feed materials may
produce a waste that is not covered by the demonstration.
(5) A description of the waste sufficient for comparison with the
waste considered by the Agency in developing BOAT, and an
estimate of the average and maximum monthly and annual
quantities of waste covered by the demonstration. (Note: The
petitioner should consult the appropriate 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
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(11) A description of the sample handling and preparation techniques,
including techniques used for extraction, containerization, and
preservation of the samples.
(12) A description of analytical procedures used including QA/QC
methods.
After receiving a petition for a variance, the Administrator may
request any additional information or waste samples that may be required
to evaluate and process the petition. Additionally, all petitioners must
certify that the information provided to the Agency is accurate under
40 CFR Part 268.4(b).
In determining whether a variance will be granted, the Agency will
first look at the design and operation of the treatment system being
used. If EPA determines that the technology and operation are consistent
with BOAT, the Agency will evaluate the waste to determine if the waste
matrix and/or physical parameters are such that the BOAT treatment
standards reflect treatment of this waste. Essentially, this latter
analysis will concern the parameters affecting treatment selection and
waste characteristics affecting performance parameters.
In cases where BOAT is based on more than one technology, the
petitioner will need to demonstrate that the treatment standard cannot be
met using any of the technologies, or that none of the technologies are
appropriate for treatment of the waste. After the Agency has made a
determination on the petition, the Agency's findings will be published in
the Federal Register, followed by a 30-day period for public comment.
44
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After review of the public comments, EPA will publish its final
determination in the Federal Register as an amendment to the treatment
standards in 40 CFR Part 268, Subpart D.
45
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2. 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
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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
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I
^ I
... ^ JvUinn ^ ,trr,
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-------
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
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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
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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
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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
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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.
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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
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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
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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
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(b) Rotary Kiln and Fixed Hearth
There are two distinct principles of operation for these incineration
technologies, one for each of the chambers involved. In the primary
chamber, energy, in the form of heat, is transferred to the waste to
achieve volatilization of the various organic waste constituents. During
this volatilization process some of the organic constituents 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
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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
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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
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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
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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
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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
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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
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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
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