SEPA
United States
Environmental Protection
Agency
Office of
Solid Waste
Washington, D C 20460
EPA/530-SW-88-0009-P
May 1988
Solid Waste
Best
Demonstrated
Available Technology
(BOAT) Background
Document for
K106
Proposed
Volume 17
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PROPOSED
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
BACKGROUND DOCUMENT FOR K106
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, D.C. 20460
James R. Berlow, Chief John Keenan
Treatment Technology Section Project Manager
May 1988
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BOAT Background Document for K106
Table of Contents
VOLUME 17 Page
Executive Summary v
BOAT Treatment Standards for K106 vi i
SECTION 1. Introduction 1
1.1 Legal Background 1
1.1.1 Requirements Under HSWA 1
1.1.2 Schedule for Developing Restrictions 4
1.2 Summary of Promulgated BOAT Methodology 5
1.2.1 Waste Treatability Groups 7
1.2.2 Demonstrated and Available Treatment Technologies .. 7
1.2.3 Collection of Performance Data 11
1.2.4 Hazardous Constituents Considered and Selected for
Regulation 17
1.2.5 Compliance with Performance Standards 30
1.2.6 Identification of BOAT 32
1.2.7 BOAT Treatment Standards for "Derived-From" and
"Mixed" Wastes 36
1.2.8 Transfer of Treatment Standards 40
1.3 Variance from the BOAT Treatment Standard 41
SECTION 2. Industries Affected and Waste Characterization 45
2.1 Industries Affected and Process Description 46
2.2 Waste Characterization 49
SECTION 3. Applicable/Demonstrated Treatment Technologies 53
3.1 Applicable Treatment Technologies 53
3.2 Demonstrated Treatment Technologies 55
3.2.1 Retorting 56
3.2.2 Chemical Precipitation Treatment System 63
3.2.2.1 Chemical Precipitation 64
3.2.2.2 Polishing Filtration 76
3.3 Performance Data for Nonwastewater 81
3.4 Performance Data for Wastewater 83
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SECTION 4. Selection of Best Demonstrated Available Technology
(BOAT) : 85
4.1 BOAT for Nonwastewaters 85
4.2 BOAT for Wastewaters 86
SECTION 5. Selection of Regulated Constituents
5.1 Nonwastewater 88
5.2 Wastewater 89
SECTION 6. Calculation of Treatment Standards 97
6.1 Nonwastewater 97
6.2 Wastewater 100
APPENDIX A Statistical Analysis 103
APPENDIX B Quality Assurance/Quality Control 113
APPENDIX C Stabilization Data for K106 117
REFERENCES 121
n
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LIST OF TABLES
Page
Tab!e 1 -1 BOAT Constituent List 20
Table 2-1 Number of Producers of Chlorine Using the Mercury Cell
Process Listed by State 47
Table 2-2 Number of Producers of Chlorine Using the Mercury Cell
Process Listed by EPA Region 47
Table 2-3 Approximate Concentrations of Major Constituents for
Untreated K106 Waste Generated by Sulfide Precipitation 50
Table 2-4 Approximate Concentrations of Major Constituents for
Untreated K106 Waste Generated by Hadrazine Treatment . 50
Table 2-5 BOAT List Constituent Concentration and Other Data for
Untreated K106 Waste Generated by Sulfide Precipitation 52
Table 3-1 Retorting Performance Data 82
Table 3-2 Sulfide Precipitation - EPA Collected Data for K071
Wastewaters 84
Table 5-1 BOAT List of Constituents Detected in Untreated K106
Generated from Sulfide Precipitation 70
Table 6-1 Calculation of Treatment Standards for K106 102
Table A-l F Distribution at the 95 Percent Confidence Level 106
Table B-l Analytical Methods 114
Table B-2 Procedures or Equipment Used in Mercury Analysis When
Alternatives or Equivalents are Allowed in the SW-846
Methods 115
Table B-3 Matrix Spike Recoveries Used to Correct Analytical Data
for K071 Mercury-Containing Wastewaters and Untreated
K106 TCLP Extract 116
Table C-l Stabilization - EPA-Collected Data Sample Set #1 118
Table C-2 Stabilization - EPA-Collected Data Sample Set #2 119
Table C-3 Stabilization - EPA-Collected Data Sample Set #3 120
iii
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LIST OF FIGURES
Page
Figure 2-1 Chlorine Manufacture by the Mercury Cell Process 48
Figure 3-1 Retorting Process (with Wastewater Discharge) 59
Figure 3-2 Retorting Process (without Wastewater Discharge) 60
Figure 3-3 Continuous Chemical Precipitation 67
Figure 3-4 Circular Clarifiers 70
Figure 3-5 Inclined Plate Settler 71
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EXECUTIVE SUMMARY
Pursuant to the Hazardous and Solid Waste Amendments (HSWA) enacted
on November 8, 1984, and in accordance with the procedures for
establishing treatment standards under Section 3004(m) of the Resource
Conservation and Recovery Act (RCRA), the following treatment standards
have been proposed as Best Demonstrated Available Technology (BOAT) for
the listed waste identified in 40 CFR Section 261.32 as K106 (wastewater
treatment sludge from the mercury cell process in chlorine production).
Compliance with these treatment standards is a prerequisite for disposal
of the waste in units designated as land disposal units according to 40
CFR Part 268.
Standards are established for one metal (mercury); these standards
are established for both nonwastewaters and wastewaters. For
nonwastewater, the standards are based on total constituent and leachate
analyses and for wastewaters the standards are based on total constituent
analyses of the waste. The leachate was obtained using the Toxicity
Characteristic Leaching Procedure (TCLP).
BOAT standards for K106 nonwastewater forms have been established
based on performance data obtained from processing of a material similar
to K106 by a retorting process. For K106 wastewaters, the BOAT treatment
standards have been based on the performance of sulfide precipitation
followed by filtration of a mercury containing wastewater similar to K106
wastewaters. The proposed effective date for these standards is August
8, 1990.
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The following table lists the specific BOAT standards for wastes
identified as K106. For the purpose of determining the applicability of
the BOAT treatment standards, 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). Wastes not
meeting this definition must comply with treatment standards for
nonwastewaters. The units for the total waste analysis are mg/kg (parts
per million on a weight by weight basis). The leachate standards are
based on analysis of a TCLP leachate and are in units of mg/1 (parts per
million on a weight by volume basis). Testing procedures for all sample
analyses performed are specifically identified in Appendix B of this
background document.
VI
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BOAT Treatment Standards for K106
Nonwastewater:
Mercury
(total concentration) 630 mg/kga
(TCLP) 0.028 mg/la
Wastewater:
Mercury
(total concentration) 0.030 mg/1
Facilities land-disposing of K106 nonwastewater must meet both the
total concentration and the TCLP standards.
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), which were
enacted on November 8, 1984, and which amended the Resource Conservation
and Recovery Act of 1976 (RCRA), impose substantial new responsibilities
on those who handle hazardous waste. In particular, the amendments
require the Agency to promulgate regulations that restrict the land
disposal of untreated hazardous wastes. In its enactment of HSWA,
Congress stated explicitly that "reliance on land disposal should be
minimized or eliminated, and land disposal, particularly landfill and
surface impoundment, should be the least favored method for managing
hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C. 6901(b)(7)J.
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:
1. Solvents and dioxins standards must be promulgated by
November 8, 1986;
2. The "California List" must be promulgated by July 8, 1987;
3. At least one-third of all listed hazardous wastes must be
promulgated by August 8, 1988 (First Third);
4. At least two-thirds of all listed hazardous wastes must be
promulgated by June 8, 1989 (Second Third); and
5. All remaining listed hazardous wastes and all hazardous wastes
identified as of November 8, 1984, by one or more of the
characteristics defined in 40 CFR Part 261 must be promulgated
by May 8, 1990 (Third Third).
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The statute specifically identified the solvent wastes as those
covered under waste codes F001, F002, F003, F004, and F005; it identified
the dioxin-containing hazardous wastes as those covered under waste codes
F020, F021, F022, and F023.
Wastes collectively known as the California List wastes, defined
under section 3004(d) of HSWA, are liquid hazardous wastes containing
metals, free cyanides, PCBs, corrosives (i.e., a pH less than or equal to
2.0), and any liquid or nonliquid hazardous waste containing halogenated
organic compounds (HOCs) above 0.1 percent by weight. Rules for the
California List were proposed on December 11, 1986, and final rules for
PCBs, corrosives, and HOC-containing wastes were established
August 12, 1987. In that rule, EPA elected not to establish standards
for metals. Therefore, the statutory limits became effective.
On May 28, 1986, EPA published a final rule (51 FR 19300) that
delineated the specific waste codes that would be addressed by the First
Third, Second Third, and Third Third. This schedule is incorporated into
40 CFR 268.10, 268.11, and 268.12.
1.2 Summary of Promulgated BOAT Methodology
In a November 7, 1986, rulemaking, EPA promulgated a technology-based
approach to establishing treatment standards under section 3004(m).
Section 3004(m) also specifies that treatment standards must "minimize"
long- and short-term threats to human health and the environment arising
from land disposal of hazardous wastes.
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Congress indicated in the legislative history accompanying the HSWA
that "[t]he requisite levels of [sic] methods of treatment established by
the Agency should be the best that has been demonstrated to be
achievable," noting that the intent is "to require utilization of
available technology" and not a "process which contemplates
technology-forcing standards" (Vol. 130 Cong. Rec. S9178 (daily ed.,
July 25, 1984)). EPA has interpreted this legislative history as
suggesting that Congress considered the requirement under section 3004(m)
to be met by application of the best demonstrated and achievable (i.e.,
available) technology prior to land disposal of wastes or treatment
residuals. Accordingly, EPA's treatment standards are generally based on
the performance of the best demonstrated available technology (BOAT)
identified for treatment of the hazardous constituents. This approach
involves the identification of potential treatment systems, the
determination of whether they are demonstrated and available, and the
collection of treatment data from 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 to be a demonstrated
technology for many waste codes containing hazardous organic
constituents, high total organic content, and high filterable solids
content, regardless of whether any facility is currently treating these
wastes. The basis for this determination is data found in literature and
data generated by EPA confirming the use of rotary kiln incineration on
wastes having the above characteristics.
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If no commercial treatment or recovery operations are identified for
a waste or wastes with similar physical or chemical characteristics that
affect treatment selection, the Agency will be unable to identify any
demonstrated treatment technologies for the waste, and, accordingly, the
waste will be prohibited from land disposal (unless handled in accordance
with the exemption and variance provisions of the rule). The Agency is,
however, committed to establishing treatment standards as soon as new or
improved treatment processes are demonstrated (and available).
Operations only available at research facilities, pilot- and bench-
scale operations, will not be considered in identifying demonstrated
treatment technologies for a waste because these technologies would not
necessarily be "demonstrated." Nevertheless, EPA may use data generated
at research facilities in assessing the performance of demonstrated
technologies.
As discussed earlier, Congress intended that technologies used to
establish treatment standards under section 3004(m) be not only
"demonstrated," but also available. To decide whether demonstrated
technologies may be considered "available," the Agency determines whether
they (1) are commercially available and (2) substantially diminish the
toxicity of the waste or substantially reduce the likelihood of migration
of hazardous constituents from the waste.
EPA will only set treatment standards based on a technology that
meets the above criteria. Thus, the decision to classify a technology as
"unavailable" will have a direct impact on the treatment standard. If
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the best technology is unavailable, the treatment standard will be based
on the next best treatment technology determined to be available. To the
extent that the resulting treatment standards are less stringent, greater
concentrations of hazardous constituents in the treatment residuals could
be placed in land disposal units.
There also may be circumstances in which EPA concludes that for a
given waste none of the demonstrated treatment technologies are
"available" for purposes of establishing the 3004(m) treatment
performance standards. Subsequently, these wastes will be prohibited
from continued placement in or on the land unless managed in accordance
with applicable exemptions and variance provisions. The Agency is,
however, committed to establishing new treatment standards as soon as new
or improved treatment processes become "available."
(1) Proprietary or patented processes. If the demonstrated
treatment technology is a proprietary or patented process that is not
generally available, EPA will not consider the technology in its
determination of the treatment standards. EPA will consider proprietary
or patented processes available if it determines that the treatment
method can be purchased or licensed from the proprietor or is a
commercially available treatment. The services of the commercial
facility offering this technology often can be purchased even if the
technology itself cannot be purchased.
(2) Substantial treatment. To be considered "available," a
demonstrated treatment technology must "substantially diminish the
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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:
Number and types of constituents treated;
Performance (concentration of the constituents in the
treatment residuals); and
Percent of constituents removed.
If none of the demonstrated treatment technologies achieve
substantial treatment of a waste, the Agency cannot establish treatment
standards for the constituents of concern in that waste.
1.2.3 Collection of Performance Data
Performance data on the demonstrated available technologies are
evaluated by the Agency to determine whether the data are representative
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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: (1) identifi-
cation of facilities for site visits, (2) an engineering site visit,
(3) a Sampling and Analysis Plan, (4) a sampling visit, and (5) an Onsite
Engineering Report.
(1) Identification of facilities for site visits. To identify
facilities that generate and/or treat the waste of concern, EPA uses a
number of information sources. These include Stanford Research
Institute's Directory of Chemical Producers; EPA's Hazardous Waste Data
Management System (HWDMS); the 1986 Treatment, Storage, Disposal Facility
(TSDF) National Screening Survey; and EPA's Industry Studies Data Base.
In addition, EPA contacts trade associations to inform them that the
Agency is considering visits to facilities in their industry and to
solicit their assistance in identifying facilities for EPA to consider in
its treatment sampling program.
After identifying facilities that treat the waste, EPA uses this
hierarchy to select sites for engineering visits: (1) generators treating
single wastes on site; (2) generators treating multiple wastes together
on site; (3) commercial treatment, storage, and disposal facilities
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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 in the preamble and background document why such
data were used and will request comments on the use of such data.
Although EPA's data bases provide information on treatment for
individual wastes, the data bases rarely provide data that support the
selection of one facility for sampling over another. In cases where
several treatment sites appear to fall into the same level of the
hierarchy, EPA selects sites for visits strictly on the basis of which
facility could most expeditiously be visited and later sampled if
justified by the engineering visit.
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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 BDAT standards should, to the extent possible, provide
sampling information similar to that acquired by EPA. Such facilities
should review the Generic Quality Assurance Project Plan for the Land
Disposal Restriction Program ("BDAT"), 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 (see Test Methods for Evaluating Solid Waste, SW-846, Third
Edition, November 1986).
After the Onsite Engineering Report is completed, the report is
submitted to the plant for review. This review provides the plant with a
final opportunity to claim any information contained in the report as
confidential. Following the review and incorporation of comments, as
appropriate, the report is made available to the public with the
exception of any material claimed as confidential by the plant.
1.2.4 Hazardous Constituents Considered and Selected for Regulation
(1) Development of BOAT list. The list of hazardous constituents
within the waste codes that are targeted for treatment is referred to by
the Agency as the BOAT constituent list. This list, provided as
Table 1-1, is derived from the constituents presented in 40 CFR Part 261,
Appendices VII and VIII, as well as several ignitable constituents used
as the basis of listing wastes as F003 and F005. These sources provide a
comprehensive list of hazardous constituents specifically regulated under
RCRA. The BOAT list consists of those constituents that can be analyzed
using methods published in SW-846, Third Edition.
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1521g
Table 1-1 BOAT Constituent List
BOAT
reference
no.
222.
1.
2.
3.
4.
5.
6.
223.
7.
8
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224
225.
226.
30.
227.
31.
214.
32.
Parameter
Volatiles
Acetone
Acetomtri le
Acrolein
Acrylonitri le
Benzene
Bromodichlorome thane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-l,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 ,2-Dibromo-3-chloropropane
1,2-Dibromoethane
Dibromomethane
Trans-1 ,4-Dichloro-2-butene
Dichlorod if luoromethane
1 , 1-Dichloroethane
1,2-Dichloroethane
1 , 1-Dichloroethy lene
Trans-1, 2-Dichloroethene
1,2-Dichloropropane
Trans-1 ,3-Oichloropropene
cis-1 ,3-Oichloropropene
1 ,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
CAS no.
67-64-1
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110-75-8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-95-3
110-57-6
75-71-8
75-34-3
107-06-2
75-35-4
156-60-5
78-87-5
10061-02-6
10061-01-5
123-91-1
110-80-5
141-78-6
100-41-4
107-12-0
60-29-7
97-63-2
75-21-8
74-88-4
18
-------
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
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyridine
1,1,1, 2-Tetrachloroethane
1,1,2 , 2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Trich loroethane
1 , 1 , 2 -Trich loroethane
Trichloroethene
Trichloromonof luoromethane
1 ,2, 3 -Trich loropropane
l,l,2-Trichloro-l,2,2-tnf luoro-
ethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1,4-Xylene
Semivolat lies
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Am 1 me
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzofajpyrene
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
Semivolat i les (continued)
Benzo(b)f luoranthene
Benzofghi )pery lene
Benzo(k)f luoranthene
p-Benzoquinone
B is (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-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortno-Cresol
para-Cresol
Cyclohexanone
D i benz( a, h) anthracene
Dibenzo(a,e)pyrene
Dibenzofa, i Jpyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzidme
2,4-Dichlorophenol
2,6-Dichlorophenol
Diethyl phthalate
3,3'-Dimethoxybenzidme
p- Dimethyl ami noazobenzene
3,3 '-Dimethylbenzidine
2, 4- Dimethyl phenol
Dimethyl phthalate
Di-n-butyl phthalate
1 ,4-Dinitrobenzene
4,6-Dimtro-o-cresol
2,4-Dmitrophenol
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
Senmvolatiles (continued)
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamme
Diphenylanune
D i pheny 1 n i t rosami ne
1 ,2-Diphenylhydrazme
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadlene
Hexachloroethane
Hexachlorophene
Hexach loropropene
lndeno( 1 ,2,3-cd)pyrene
Isosafrole
Methapyri lene
3-Methylcholanthrene
4,4'-Methylenebis
(2-chloroamline)
Methyl methanesulfonate
Naphthalene
1 ,4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroam 1 me
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamme
N-Nitrosodiethylamme
N-Nitrosodi methyl am me
N -Nit rosomethyl ethyl am me
N-Nitrosomorphol me
N-Nitrosopipendme
n-Nitrosopyrrol idme
5-Nitro-o-toluidme
Pentachlorobenzene
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
-------
1521g
Table 1-1 (continued)
BOAT
reference
no
139.
140.
141.
142.
220
143.
144.
145.
146
147.
148.
149.
150
151.
152.
153.
154.
155.
156.
157.
158.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.
169.
170.
171.
Parameter
Semivplat i les (continued)
Pentachlorophenol
Phenacet in
Phenanthrene
Phenol
Phthalic anhydride
2-Picolme
Pronamide
Pyrene
Resorcinol
Safrole
1 ,2, 4, 5-Tetrachlorobenzene
2,3,4,6-Tetrachlorophenol
1,2,4-Tnchlorobenzene
2,4,5-Tnchlorophenol
2,4,6-Trichlorophenol
Tris(2,3-dibromopropyl)
phosphate
Metals
Antimony
Arsenic
Barium
Beryll lum
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
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
Orqanochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BBC
gamma-BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxyacetic 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
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
Dioxins 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
-------
The initial BOAT constituent list was published in EPA's Generic
Quality Assurance Project Plan, March 1987 (EPA/530-SW-87-011).
Additional constituents will be added to the BOAT constituent list as
more key constituents are identified for specific waste codes or as new
analytical methods are developed for hazardous constituents. For
example, since the list was published in March 1987, 18 additional
constituents (hexavalent chromium, xylenes (all three isomers), benzal
chloride, phthalic anhydride, ethylene oxide, acetone, n-butyl alcohol,
2-ethoxyethanol, ethyl acetate, ethyl benzene, ethyl ether, methanol,
methyl isobutyl ketone, 2-nitropropane, l,l,2-trichloro-l,2,2-
trifluoroethane, and cyclohexanone) have been added to the list.
Chemicals are listed in Appendix VIII if they are shown in scientific
studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on
humans or other life-forms, and they include such substances as those
identified by the Agency's Carcinogen Assessment Group as being
carcinogenic. Including a constituent in Appendix VIII means that the
constituent can be cited as a basis for listing toxic wastes.
Although Appendix VII, Appendix VIII, and the F003 and F005
ignitables provide a comprehensive list of RCRA-regulated hazardous
constituents, not all of the constituents can be analyzed in a complex
waste matrix. Therefore, constituents that could not be readily analyzed
in an unknown waste matrix were not included on the initial BOAT list.
As mentioned above, however, the BOAT constituent list is a continuously
growing list that does not preclude the addition of new constituents when
analytical methods are developed.
25
-------
There are five major reasons that constituents were not included on
the BOAT constituent list:
1. Constituents are unstable. Based on their chemical structure,
some constituents will either decompose in water or will
ionize. For example, maleic anhydride will form maleic acid
when it comes in contact with water and copper cyanide will
ionize to form copper and cyanide ions. However, EPA may choose
to regulate the decomposition or ionization products.
2. EPA-approved or verified analytical methods are not available.
Many constituents, such as 1,3,5-trinitrobenzene, are not
measured adequately or even detected using any of EPA's
analytical methods published in SW-846 Third Edition.
3. The constituent is a member of a chemical group designated in
Appendix VIII as not otherwise specified (N.O.S.). Constituents
listed as N.O.S., such as chlorinated phenols, are a generic
group of some types of chemicals for which a single analytical
procedure is not available. The individual members of each such
group need to be listed to determine whether the constituents
can be analyzed. For each N.O.S. group, all those constituents
that can be readily analyzed are included in the BOAT
constituent 1ist.
4. Available analytical procedures are not appropriate for a
complex waste matrix. Some compounds, such as auramine, can be
analyzed as a pure constituent. However, in the presence of
other constituents, the recommended analytical method does not
positively identify the constituent. The use of high pressure
liquid chromatography (HPLC) presupposes a high expectation of
finding the specific constituents of interest. In using this
procedure to screen samples, protocols would have to be
developed on a case-specific basis to verify the identity of
constituents present in the samples. Therefore, HPLC is not an
appropriate analytical procedure for complex samples containing
unknown constituents.
5. Standards for analytical instrument calibration are not
commercially available. For several constituents, such as
benz(c)acridine, commercially available standards of a
"reasonably" pure grade are not available. The unavailability
of a standard was determined by a review of catalogs from
specialty chemical manufacturers.
26
-------
Two constituents (fluoride and sulfide) are not specifically included
in Appendices VII and VIII; however, these compounds are included on the
BOAT list as indicator constituents for compounds from Appendices VII and
VIII such as hydrogen fluoride and hydrogen sulfide, which ionize in
water.
The BOAT constituent list presented in Table 1-1 is divided into the
following nine groups:
Volatile organics;
Semivolatile organics;
Metals;
Other inorganics;
Organochlorine pesticides;
Phenoxyacetic acid herbicides;
Organophosphorous insecticides;
PCBs; and
Dioxins and furans.
The constituents were placed in these categories based on their chemical
properties. The constituents in each group are expected to behave
similarly during treatment and are also analyzed, with the exception of
the metals and inorganics, by using the same analytical methods.
(2) Constituent selection analysis. The constituents that the
Agency selects for regulation in each treatability group are, in general,
those found in the untreated wastes at treatable concentrations. For
certain waste codes, the target list for the untreated waste may have
been shortened (relative to analyses performed to test treatment
technologies) because of the extreme unlikelihood that the constituent
will be present.
27
-------
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 section 3004(m)
requirements, but rather as a function of the normal variability of the
treatment processes. A treatment facility will have to be designed to
meet the mean achievable treatment performance level to ensure that the
performance levels remain within the limits of the treatment standard.
The Agency calculates a variability factor for each constituent of
concern within a waste treatability group using the statistical
calculation presented in Appendix A. The equation for calculating the
variability factor is the same as that used by EPA for the development of
numerous regulations in the Effluent Guidelines Program under the Clean
Water Act. The variability factor establishes the instantaneous maximum
based on the 99th percentile value.
There is an additional step in the calculation of the treatment
standards in those instances where the ANOVA analysis shows that more
29
-------
than one technology achieves a level of performance that represents
BOAT. In such instances, the BOAT treatment standard is calculated by
first averaging the mean performance value for each technology for each
constituent of concern and then multiplying that value by the highest
variability factor among the technologies considered. This procedure
ensures that all the BOAT technologies used as the basis for the
standards will achieve full compliance.
1.2.5 Compliance with Performance Standards
All the treatment standards reflect performance achieved by the best
demonstrated available technology (BOAT). As such, compliance with these
standards requires only that the treatment level be achieved prior to
land disposal. It does not require the use of any particular treatment
technology. While dilution of the waste as a means to comply with the
standard is prohibited, wastes that are generated in such a way as to
naturally meet the standard can be land disposed without treatment. With
the exception of treatment standards that prohibit land disposal, all
treatment standards proposed are expressed as a concentration level.
EPA has used both total constituent concentration and TCLP analyses
of the treated waste as a measure of technology performance. EPA's
rationale for when each of these analytical tests is used is explained in
the following discussion.
For all organic constituents, EPA is basing the treatment standards
on the total constituent concentration found in the treated waste. EPA
based its decision on the fact that technologies exist to destroy the
30
-------
various organics compounds. Accordingly, the best measure of performance
would be the extent to which the various organic compounds have been
destroyed or the total amount of constituent remaining after treatment.
(NOTE: EPA's land disposal restrictions for solvent waste codes
F001-F005 (51 FR 40572) use the TCLP value as a measure of performance.
At the time that EPA promulgated the treatment standards for F001-F005,
useful data were not available on total constituent concentrations in
treated residuals and, as a result, the TCLP data were considered to be
the best measure of performance.)
For all metal constituents, EPA is using both total constituent
concentration and/or the TCLP as the basis for treatment standards. The
total constituent concentration is being used when the technology basis
includes a metal recovery operation. The underlying principle of metal
recovery is the reduction of the amount of metal in a waste by separating
the metal for recovery; therefore, total constituent concentration in the
treated residual is an important measure of performance for this
technology. Additionally, EPA also believes that it is important that
any remaining metal in a treated residual waste not be in a state that is
easily leachable; accordingly, EPA is also using the TCLP as a measure of
performance. It is important to note that for wastes for which treatment
standards are based on a metal recovery process, the facility has to
comply with both the total constituent concentration and the TCLP prior
to land disposal.
31
-------
In cases where treatment standards for metals are not based on
recovery techniques but rather on stabilization, EPA is using only the
TCLP as a measure of performance. The Agency's rationale is that
stabilization is not meant to reduce the concentration of metal in a
waste but only to chemically minimize the ability of the metal to leach.
1.2.6 Identification of BOAT
(1) Screening of treatment data. This section explains how the
Agency determines which of the treatment technologies represent treatment
by BOAT. The first activity is to screen the treatment performance data
from each of the demonstrated and available technologies according to the
following criteria:
1. Design and operating data associated with the treatment data
must reflect a well-designed, well-operated system for each
treatment data point. (The specific design and operating
parameters for each demonstrated technology for this waste code
are discussed in Section 3.2 of this document.)
2. Sufficient QA/QC data must be available to determine the true
values of the data from the treated waste. This screening
criterion involves adjustment of treated data to take into
account that the type value may be different from the measured
value. This discrepancy generally is caused by other
constituents in the waste that can mask results or otherwise
interfere with the analysis of the constituent of concern.
3. The measure of performance must be consistent with EPA's
approach to evaluating treatment by type of constituents (e.g.,
total concentration data for organics, and total concentration
and TCLP for metals in the leachate from the residual).
In the absence of data needed to perform the screening analysis, EPA
will make decisions on a case-by-case basis as to whether to include the
data. The factors included in this case-by-case analysis will be the
32
-------
actual treatment levels achieved, the availability of the treatment data
and their completeness (with respect to the above criteria), and EPA's
assessment of whether the untreated waste represents the waste code of
concern. EPA's application of these screening criteria for this waste
code is provided in Section 4 of this background document.
(2) Comparison of treatment data. In cases in which EPA has
treatment data from more than one technology following the screening
activity, EPA uses the statistical method known as analysis of variance
(ANOVA) to determine if one technology performs significantly better than
the others. This statistical method (summarized in Appendix A) provides
a measure of the differences between two data sets. If EPA finds that
one technology performs significantly better (i.e., the data sets are not
homogeneous), BOAT treatment standards are the level of performance
achieved by the best technology multiplied by the corresponding
variability factor for each regulated constituent.
If the differences in the data sets are not statistically
significant, the data sets are said to be homogeneous. Specifically, EPA
uses the analysis of variance to determine whether BOAT represents a
level of performance achieved by only one technology or represents a
level of performance achieved by more than one (or all) of the
technologies. If the Agency finds that the levels of performance for one
or more technologies are not statistically different, EPA averages the
performance values achieved by each technology and then multiplies this
value by the largest variability factor associated with any of the
33
-------
acceptable technologies. A detailed discussion of the treatment
selection method and an example of how EPA chooses BOAT from multiple
treatment systems is provided in Section A-l.
(3) Quality assurance/quality control. This section presents the
principal quality assurance/quality control (QA/QC) procedures employed
in screening and adjusting the data to be used in the calculation of
treatment standards. Additional QA/QC procedures used in collecting and
screening data for the BOAT program are presented in EPA's Generic
Quality Assurance Project Plan for Land Disposal Restrictions Program
("BOAT") (EPA/530-SW-87-011, March 1987).
To calculate the treatment standards for the Land Disposal
Restriction Rules, it is first necessary to determine the recovery value
for each constituent (the amount of constituent recovered after spiking,
which is the addition of a known amount of the constituent, minus the
initial concentration in the samples divided by the amount added) for a
spike of the treated residual. Once the recovery value is determined,
the following procedures are used to select the appropriate percent
recovery value to adjust the analytical data:
1. If duplicate spike recovery values are available for the
constituent of interest, the data are adjusted by the lowest
available percent recovery value (i.e., the value that will
yield the most conservative estimate of treatment achieved).
However, if a spike recovery value of less than 20 percent is
reported for a specific constituent, the data are not used to
set treatment standards because the Agency does not have
sufficient confidence in the reported value to set a national
standard.
34
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2. If data are not available for a specific constituent but are
available for an isomer, then the spike recovery data are
transferred from the isomer and the data are adjusted using the
percent recovery selected according to the procedure described
in (1) above.
3. If data are not available for a specific constituent but are
available for a similar class of constituents (e.g., volatile
organics, acid-extractable semivolatiles), then spike recovery
data available for this class of constituents are transferred.
All spike recovery values greater than or equal to 20 percent
for a spiked sample are averaged and the constituent
concentration is adjusted by the average recovery value. If
spiked recovery data are available for more than one sample, the
average is calculated for each sample and the data are adjusted
by the lowest average value.
4. If matrix spike recovery data are not available for a set of
data to be used to calculate treatment standards, then matrix
spike recovery data are transferred from a waste that the Agency
believes is a similar matrix (e.g., if the data are for an ash
from incineration, then data from other incinerator ashes could
be used). While EPA recognizes that transfer of matrix spike
recovery data from a similar waste is not an exact analysis,
this is considered the best approach for adjusting the data to
account for the fact that most analyses do not result in
extraction of 100 percent of the constituent. In assessing the
recovery data to be transferred, the procedures outlined in (1),
(2), and (3) above are followed.
The analytical procedures employed to generate the data used to
calculate the treatment standards are listed in Appendix B of this
document. In cases where alternatives or equivalent procedures and/or
equipment are allowed in EPA's SW-846, Third Edition (November 1986)
methods, the specific procedures and equipment used are also documented
in this Appendix. In addition, any deviations from the SW-846, Third
Edition, methods used to analyze the specific waste matrices are
documented. It is important to note that the Agency will use the methods
and procedures delineated in Appendix B to enforce the treatment
35
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standards presented in Section 6 of this document. Accordingly,
facilities should use these procedures in assessing the performance of
their treatment systems.
1.2.7 BOAT Treatment Standards for "Derived-From" and "Mixed" Wastes
(1) Wastes from treatment trains generating multiple residues. In a
number of instances, the proposed BOAT consists of a series of
operations, each of which generates a waste residue. For example, the
proposed BOAT for a certain waste code is based on solvent extraction,
steam stripping, and activated carbon adsorption. Each of these
treatment steps generates a waste requiring treatmenta
solvent-containing stream from solvent extraction, a stripper overhead,
and spent activated carbon. Treatment of these wastes may generate
further residues; for instance, spent activated carbon (if not
regenerated) could be incinerated, generating an ash and possibly a
scrubber water waste. Ultimately, additional wastes are generated that
may require land disposal. With respect to these wastes, the Agency
wishes to emphasize the following points:
1. All of the residues from treating the original listed wastes are
likewise considered to be the listed waste by virtue of the
derived-from rule contained in 40 CFR Part 261.3(c)(2). (This
point is discussed more fully in (2) below.) Consequently, all
of the wastes generated in the course of treatment would be
prohibited from land disposal unless they satisfy the treatment
standard or meet one of the exceptions to the prohibition.
2. The Agency's proposed treatment standards generally contain a
concentration level for wastewaters and a concentration level
for nonwastewaters. The treatment standards apply to all of the
wastes generated in treating the original prohibited waste.
Thus, all solids generated from treating these wastes would have
36
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to meet the treatment standard for nonwastewaters. All
derived-from wastes meeting the Agency definition of wastewater
(less than 1 percent TOC and less than 1 percent total
filterable solids) would have to meet the treatment standard for
wastewaters. EPA wishes to make clear that this approach is not
meant to allow partial treatment in order to comply with the
applicable standard.
3. The Agency has not performed tests, in all cases, on every waste
that can result from every part of the treatment train.
However, the Agency's treatment standards are based on treatment
of the most concentrated form of the waste. Consequently, the
Agency believes that the less concentrated wastes generated in
the course of treatment will also be able to be treated to meet
this value.
(2) Mixtures and other derived-from residues. There is a further
question as to the applicability of the BOAT treatment standards to
residues generated not from treating the waste (as discussed above), but
from other types of management. Examples are contaminated soil or
leachate that is derived from managing the waste. In these cases, the
mixture is still deemed to be the listed waste, either because of the
derived-from rule (40 CFR Part 261.3(c)(2)(i)) or the mixture rule
(40 CFR Part 261.3(a)(2)(iii) and (iv)) or because the listed waste is
contained in the matrix (see, for example, 40 CFR Part 261.33(d)). The
prohibition for the particular listed waste consequently applies to this
type of waste.
The Agency believes that the majority of these types of residues can
meet the treatment standards for the underlying listed wastes (with the
possible exception of contaminated soil and debris for which the Agency
is currently investigating whether it is appropriate to establish a
separate treatability subcategorization). For the most part, these
37
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residues will be less concentrated than the original listed waste. The
Agency's treatment standards also make a generous allowance for process
variability by assuming that all treatability values used to establish
the standard are lognormally distributed. The waste also might be
amenable to a relatively nonvariable form of treatment technology such as
incineration. Finally, and perhaps most important, the rules contain a
treatability variance that allows a petitioner to demonstrate that its
waste cannot be treated to the level specified in the rule (40 CFR Part
268.44(a)). This provision provides a safety valve that allows persons
with unusual waste matrices to demonstrate the appropriateness of a
different standard. The Agency, to date, has not received any petitions
under this provision (for example, for residues contaminated with a
prohibited solvent waste), indicating, in the Agency's view, that the
existing standards are generally achievable.
(3) Residues from managing listed wastes or that contain listed
wastes. The Agency has been asked if and when residues from managing
hazardous wastes, such as leachate and contaminated ground water, become
subject to the land disposal prohibitions. Although the Agency believes
this question to be settled by existing rules and interpretative
statements, to avoid any possible confusion the Agency will address the
question again.
Residues from managing First Third wastes, listed California List
wastes, and spent solvent and dioxin wastes are all considered to be
subject to the prohibitions for the underlying hazardous waste. Residues
38
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from managing California List wastes likewise are subject to the
California List prohibitions when the residues themselves exhibit a
characteristic of hazardous waste. This determination stems directly
from the derived-from rule in 40 CFR Part 261.3(c)(2) or, in some cases,
from the fact that the waste is mixed with or otherwise contains the
listed waste. The underlying principle stated in all of these provisions
is that listed wastes remain listed until delisted.
The Agency's historic practice in processing delisting petitions that
address mixing residuals has been to consider them to be the listed waste
and to require that delisting petitioners address all constituents for
which the derived-from waste (or other mixed waste) was listed. The
language in 40 CFR Part 260.22(b) states that mixtures or derived-from
residues can be delisted provided a delisting petitioner makes a
demonstration identical to that which a delisting petitioner would make
for the underlying waste. Consequently, these residues are treated as
the underlying listed waste for delisting purposes. The statute likewise
takes this position, indicating that soil and debris that are
contaminated with listed spent solvents or dioxin wastes are subject to
the prohibition for these wastes even though these wastes are not the
originally generated waste, but rather are a residual from management
(RCRA section 3004(e)(3)). It is EPA's view that all such residues are
covered by the existing prohibitions and treatment standards for the
listed hazardous waste that these residues contain and from which they
are derived.
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 technically valid in cases where the untested wastes
are generated from similar industries, have similar processing steps, or
have similar waste characteristics affecting performance and treatment
selection. Transfer of treatment standards to similar wastes or wastes
from similar processing steps requires little formal analysis. However,
in a case where only the industry is similar, EPA more closely examines
the waste characteristics prior to deciding whether the untested waste
constituents can be treated to levels associated with tested wastes.
EPA undertakes a two-step analysis when determining whether wastes
generated by different processes within a single industry can be treated
to the same level of performance. First, EPA reviews the 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 Section 5 of this document.
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 BOAT Treatment Standard
The Agency recognizes that there may exist unique wastes that cannot
be treated to the level specified as the treatment standard. In such a
case, a generator or owner/operator may submit a petition to the
Administrator requesting a variance from the treatment standard. A
particular waste may be significantly different from the wastes
considered in establishing treatability groups because the waste contains
a more complex matrix that makes it more difficult to treat. For
example, complex mixtures may be formed when a restricted waste is mixed
with other waste streams by spills or other forms of inadvertent mixing.
As a result, the treatability of the restricted waste may be altered such
that it cannot meet the applicable treatment standard.
Variance petitions must demonstrate that the treatment standard
established for a given waste cannot be met. This demonstration can be
41
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made by showing that attempts to treat the waste by available
technologies were not successful or by performing appropriate analyses of
the waste, including waste characteristics affecting performance, which
demonstrate that the waste cannot be treated to the specified levels.
Variances will not be granted based solely on a showing that adequate
BOAT treatment capacity is unavailable. (Such demonstrations can be made
according to the provisions in Part 268.5 of RCRA for case-by-case
extensions of the effective date.) The Agency will consider granting
generic petitions provided that representative data are submitted to
support a variance for each facility covered by the petition.
Petitioners should submit at least one copy to:
The Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
An additional copy marked "Treatability Variance" should be submitted
to:
Chief, Waste Treatment Branch
Office of Solid Waste (WH-565)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Petitions containing confidential information should be sent with
only the inner envelope marked "Treatability Variance" and "Confidential
Business Information" and with the contents marked in accordance with the
requirements of 40 CFR Part 2 (41 FR 36902, September 1, 1976, amended by
43 FR 4000).
The petition should contain the following information:
42
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1. The petitioner's name and address.
2. A statement of the petitioner's interest in the proposed action.
3. The name, address, and EPA identification number of the facility
generating the waste, and the name and telephone number of the
plant contact.
4. The process(es) and feed materials generating the waste and an
assessment of whether such process(es) or feed materials may
produce a waste that is not covered by the demonstration.
5. A description of the waste sufficient for comparison with the
waste considered by the Agency in developing BOAT, and an
estimate of the average and maximum monthly and annual
quantities of waste covered by the demonstration. (Note: The
petitioner should consult the appropriate BOAT background
document for determining the characteristics of the wastes
considered in developing treatment standards.)
6. If the waste has been treated, a description of the system used
for treating the waste, including the process design and
operating conditions. The petition should include the reasons
the treatment standards are not achievable and/or why the
petitioner believes the standards are based on inappropriate
technology for treating the waste. (Note: The petitioner should
refer to the BOAT background document as guidance for
determining the design and operating parameters that the Agency
used in developing treatment standards.)
7. A description of the alternative treatment systems examined by
the petitioner (if any); a description of the treatment system
deemed appropriate by the petitioner for the waste in question;
and, as appropriate, the concentrations in the treatment
residual or extract of the treatment residual (i.e., using the
TCLP, where appropriate, for stabilized metals) that can be
achieved by applying such treatment to the waste.
8. A description of those parameters affecting treatment selection
and waste characteristics that affect performance, including
results of all analyses. (See Section 3.0 for a discussion of
waste characteristics affecting performance that the Agency has
identified for the technology representing BOAT.)
9. The dates of the sampling and testing.
10. A description of the methodologies and equipment used to obtain
representative samples.
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.
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.
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2. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION
This section presents a description of the industries affected by
land disposal restrictions for this waste, the process generating the
waste, and a summary of available waste characterization data for the
waste. As discussed in Section 1, those wastes listed in 40 CFR
Section 261.32 are subject to the land disposal restriction provisions of
HSWA. Within that industry-specific listing of hazardous wastes are the
following three wastes generated by the chlorine industry:
K071: Brine purification muds from the mercury cell process in
chlorine production, where separately prepurified brine is not
used.
K073: Chlorinated hydrocarbon waste from the purification step of
the diaphragm cell process using graphite anodes in chlorine
production.
K106: Wastewater treatment sludge from the mercury cell process in
chlorine production.
The Agency has determined that each of the three waste codes
described above constitute a separate waste treatability group based on
the physical and chemical characteristics of the waste (see Section 1 for
a discussion of waste treatability groups). As a result, EPA has
examined each waste alone relative to the source of the waste, applicable
technologies, and treatment performance attainable.
The listed waste K071 is discussed in a separate background
document; the listed waste K073 is no longer generated from chlorine
production. This background document only addresses the development of
treatment standards for K106.
45
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2.1 Industries Affected and Process Description
Chlorine is produced primarily from the electrolytic decomposition of
either sodium chloride or potassium chloride, from which the coproducts
are sodium hydroxide (caustic soda) or potassium hydroxide. All of the
caustic soda and potassium hydroxide and over 90 percent of the chlorine
produced in the U.S. are made by the electrolytic decomposition of sodium
chloride or potassium chloride. Chlorine is also produced by other
processes, including non-electrolytic oxidation of hydrochloric acid
(HC1), from the production of sodium metal, and electrolytic production
of magnesium metal from molten magnesium chloride.
Three types of electrolytic cells are in commercial use for the
production of alkalies and chlorine: the mercury cell, the diaphragm
cell, and the membrane cell. The listed waste K106 is generated in
chlorine production by the mercury cell process. The Agency estimates
that there are 20 facilities that produce chlorine by the mercury cell
process and may generate K106 waste. The locations of these facilities
are provided in Table 2-1, listed by State, and in Table 2-2, listed by
EPA Region. Chlorine producers fall under SIC Code 2812, Alkalies and
Chlorine.
In chlorine production by the mercury cell process, a saturated salt
brine solution is prepared by dissolving sodium chloride, usually in the
form of rock salt, in the depleted brine solution recycled from the
mercury cells (see Figure 2-1).
46
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1575g/p.l
Table 2-1 Number of Producers of Chlorine Using the
Mercury Cell Process Listed by State
State
Alabama (IV)
Delaware (III)
Georgia (IV)
Kentucky (IV)
Louisiana (VI)
Maine (I)
New York (II)
North Carolina (IV)
Ohio (V)
Tennessee (IV)
Texas (VI)
Washington (X)
West Virginia (III)
Wisconsin (V)
Number of
producers
3
1
2
1
2
1
2
1
1
1
1
1
2
1
Total 20
Reference: SRI 1987.
Table 2-2 Number of Producers of Chlorine Using the Mercury
Cell Process Listed by EPA Region
EPA Region
I
II
III
IV
V
VI
X
Number of
producers
1
2
3
8
2
3
1.
Total 20
Reference: SRI 1987.
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RECYCLED DEPLETED BRINE
RAW SALT-
MAKEUP-
WATER
BRINE
SATURATOR
BRINE
PURIFICATION
K071 BRINE
PURIFICATION
MUDS
cc
ELECTROLYTIC CELLS
AND DENUDERS
OTHER CHLORINE
MANUFACTURING
WASTEWATERS
ACID LEACHING &
CHEMICAL OXIDATION
FOLLOWED BY
DEWATERING
K071
(WASTEWATER)
K071
(NONWASTEWATER)
COOLING, DRYING
PURIFICATION
AND COMPRESSION
Cl.
FILTER
NaOH.
H,
WASTEWATER
TREATMENT
K071 (TREATED
WASTEWATER)
K106 WASTEWATER TREATMENT SLUDGE
(NONWASTEWATER)
FIGURE 2-1. CHLORINE MANUFACTURE BY THE MERCURY CELL PROCESS
-------
The brine is purified, unless prepurified brine is used. The purified
saturated brine is fed to the mercury cells, where electrolytic
decomposition into sodium and chlorine occurs.
Sources of wastewater from the production of chlorine by the mercury
cell process include: (1) brine that is bled from the end boxes of the
mercury cells, (2) wastewater collected from the floor of or basement
below the room containing the mercury cells that is generated from
periodic washdown of the cell room floor and equipment, and (3) any other
wastewaters generated by the plant that may contain mercury, including
wastewaters generated during dewatering or treatment of K071 waste.
Treatment of plant process wastewaters by chemical precipitation
generates a wastewater treatment sludge, which is the listed waste K106.
With the exception of one facility, K106 is generated by sulfide
precipitation. One facility currently uses hydrazine to treat mercury-
contaminanted wastewaters; this process generates a mercurous hydroxide
compound. In the past K106 was generated by sodium hydroborate, but this
compound is no longer used to treat mercury-contaminated wastewaters.
2.2 Waste Characterization
EPA has waste characterization data for both K106 generated by
sulfide treatment and K106 generated by hydrazine treatment. The
approximate concentrations of the major constituents for both of these
K106 forms were determined from EPA analysis of the waste and other
characterization data and information submitted by industry to EPA. As
summarized in Tables 2-3 and 2-4, both forms of K106 are primarily
49
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0331g
Table 2-3 Approximate Concentrations of Major Constituents for
Untreated K106 Waste Generated by Sulfide Precipitation
Constituent
Concentration (weight percent)
Mercury sulfide
Other metal sulfides
Other solids
(diatomaceous earth filter aid)
Water
4.4
2.0
53.6
40
100/c
References-
USEPA 1988a.
USEPA 1986a
USEPA 1985.
Table 2-4 Approximate Concentrations of Major Constituents for
Untreated K106 Waste Generated by Hydrazine Treatment
Constituent
Concentration (weight percent)
Mercurous hydroxide 0.5
Water 50
Inerts (primarily diatomaceous earth and
small amounts of carbon from
filter precoating) 49.5
100%
Reference: Waste Minimization Audit Report.
5U
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comprised of water and diatomaceous earth. The K106 generated by sulfide
precipitation contains approximately 4.4 percent mercury sulfide; the
K106 generated by hydrazine treatment contains approximately 0.5 percent
mercurous hydroxide. The concentrations of BOAT list constituents
detected in the K106 waste generated from sulfide precipitation are
presented in Table 2-5.
51
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1964g/l
Table 2-5 BOAT List Constituent Concentration and Other Data for
Untreated K106 Waste Generated by Sulfide Precipitation
Analysis
Untreated K106 waste concentration (mq/kq)
(b)
(c)
(d)
(e)
BOAT List Metals
Antimony
Arsenic
Barium
Beryl 1 lum
Cadmi urn
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai lium
Vanadium
Zinc
Other Analyses
Aluminum
Calcium
Cobalt
Iron
Magnesium
Manganese
Potassium
Sod i um
Tin
Sulfide
Total solids
Total suspended solids
Paint filter test
Diatomaceous earth
Water
Sodium chloride
<3 8 -
11-
74 - -
<0.1 - - - -
2.3 - - -
63-
133 - - -
50 - - - -
25,900 2000 - 150,000 4300 - 17,000 55,000 - 146,000 5000 - 7000
14 - - -
<5.0 - - - -
131 - - -
<8.6 - - -
0 46 -
443 - -
168 - - -
478 - - -
1.3 - - - -
833 - 400 -
132 - -
6.5 - -
7,870 - - -
4,120 - - -
<5.5 - - -
_
41.5 - - -
-
Pass - - -
700,000 - 950,000 800,000 - 950,000
5000 - 20,000 50,000 - 150,000
80,000 - 100,000
- = No analysis performed.
References.
(a)
(b)
(c)
lei)
(e)
USEPA 1988a
USEPA 1986a.
USEPA 1985.
USEPA 1985
USEPA 1985
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3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
In the previous section, a discussion of the industry and process
generating K106 waste and a major constituent analysis of this waste were
presented. This section describes the applicable and demonstrated
treatment technologies and performance data for treatment of K106 waste.
The technologies that are considered applicable to the treatment of K106
waste are those that treat BOAT list metals by reducing their
concentration and/or their Teachability in the waste. Included in this
section are discussions of those applicable treatment technologies that
have been demonstrated on a commercial basis for treatment of K106 waste
or wastes similar to K106.
As shown in the previous section, K106 generated by sulfide
precipitation consists of approximately 54 percent diatomaceous earth
filter aid, 40 percent water, and 4.4 percent mercury sulfide. The K106
waste generated from hydrazine treatment consists of approximately
49.5 percent diatomaceous earth, 50 percent water, and 0.5 percent
mercurous hydroxide.
3.1 Applicable Treatment Technologies
Based on the above waste characteristics, the technologies applicable
for treatment of K106 are those that reduce the concentration of BOAT
list metals in the treated residual and/or reduce the Teachability of
these metals in the treated residual. The only technology that the
Agency has identified as applicable for treatment of K106 nonwastewaters
is retorting. Retorting volatilizes mercury at high temperatures and
53
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then condenses and collects it as the pure metal, reducing the mercury
concentration in the treatment residual from that in the untreated waste.
Stabilization was identified as potentially applicable for treatment
of K106 nonwastewaters. Stabilization binds BOAT list metals into a
solid in a form that is more resistant to leaching than the metals in the
untreated waste. EPA's testing of stabilization for treatment of K106
nonwastewaters generated by sulfide precipitation established that the
technology did not provide effective treatment. Based on this test, EPA
has concluded that stabilization does not appear to be applicable for
this form of K106. The stabilization data are summarized in Appendix C;
additional data and information on this test can be found in the K106
Administrative Record.
EPA recognizes, however, that the ineffectiveness may be a result of
the fact that the mercury is present in a form that has a low
Teachability. It is possible that stabilization may be applicable if
mercury is present in a more Teachable form in untreated K106.
The retorting process generates a wastewater that contains mercury.
Technologies applicable to this stream are chemical precipitation
followed by filtration to remove BOAT list metals and concentrate them in
the wastewater treatment sludge.
The selection of treatment technologies that are applicable for
treating BOAT list metals in K106 waste is based on information obtained
54
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from literature sources, information obtained from engineering site
visits, and information submitted by industry.
3.2 Demonstrated Treatment Technologies
The only demonstrated technology that the Agency has identified
for treatment of K106 nonwastewater is retorting. As noted above, this
technology generates a wastewater that would be classified as K106 under
EPA's "derived from" rule 40 CFR Part 261.3(c)(2). The only demonstrated
technology that the Agency has identified for treatment of K106
wastewater is chemical precipitation followed by polishing filtration.
Retorting was previously used to treat K106 at two facilities and to
treat a mixture of K071 and K106 at another facility. EPA is not aware
of any facilities currently retorting K106; however, retorting is
presently being used at one facility on mercury ores consisting primarily
of sulfide. The concentration of mercury in these unprocessed ores is
roughly 3 percent. These ores are concentrated to approximately 65
percent mercury prior to retorting. As shown in Tables 2-3 and 2-4, the
concentration of mercury in nonwastewaters K106 (generated by sulfide) is
4.4 percent and K106 (generated by hydrazine) is 0.5 percent. The Agency
believes that the unprocessed mercury ores are similar to both forms of
K106 and as a consequence, the Agency considers retorting to be
demonstrated for K106.
Chemical precipitation followed by filtration has been demonstrated
on K071 wastewater; EPA does not have characterization data on K106
wastewaters generated from retorting of K106; however, the Agency
believes that these wastes are similar to the K071 and other mercury-
55
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contaminated wastewaters currently treated by sulfide precipitation (see
Table 3-2). The concentration of mercury in the wastewaters for which
the Agency has data is approximately 40 ppm; EPA would not expect the
K106 wastewater generated from retorting to be more difficult to treat.
Sulfide precipitation followed by filtration of mercury-containing
wastewaters is used at 19 or more facilities. Therefore, the Agency
believes that sulfide precipitation is both applicable and demonstrated
for wastewater generated from treatment of K106 nonwastewaters.
The demonstrated technologies for both nonwastewater and wastewater
are described in this section, and performance data are presented in
Section 3.3 that indicate the relative effectiveness of the technologies
evaluated for treatment of K106 wastes.
3.2.1 Retorting
Retorting is a process similar to high temperature metals recovery,
in that it provides for recovery of metals from wastes primarily by
volatilization and subsequent collection of the volatilized components.
Retorting yields a metal product for reuse and significantly reduces the
quantity of metals in the residual. This technology is different from
high temperature metals recovery principally with regard to the process
chemistry. High temperature metals recovery is a reduction reaction
involving the use of carbon or coke, while this process does not use any
reducing agents. Additionally, this process differs with regard to the
form of the residue generated and possibly the Teachability; high
temperature metals recovery generates a slag, while retorting generates a
granular solid residue.
56
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Applicability
This process is applicable to any waste containing BOAT list volatile
metals in the elemental form provided that the waste has a low total
organic content. In addition to being applicable for BOAT list metals in
the elemental form, retorting is also applicable to mercury wastes where
mercury is present as an oxide, hydroxide, or a sulfide. For metals,
other than mercury, the operating temperature (700-1000°F) is not
high enough to decompose the metal compounds.
Generally, for most retorting designs there is a restriction that the
waste have a low water content to minimize generation of water vapor.
This restriction can be met by dewatering or blending. Dewatering
reduces energy consumption by minimizing the amount of water to be
evaporated and avoids problems involving separation of recovered mercury
from large volumes of water.
Underlying Principle of Operation
The theory of operation of retorting is that sufficient heat is
transferred to the waste to cause elemental metals to vaporize. In the
case of mercury present as a sulfide, hydroxide, or oxide compound,
sufficient heat must be transferred to the waste to both decompose the
compounds to the elemental form and then to volatilize the mercury. In
general, mercury wastes are present in the form of sulfides (HgS) as a
result of the use of sodium hydrosulfide treatment of mercury bearing
wastewaters. In a few instances, hydrazine has been used to treat these
same wastewaters; in such instances, a mercurous hydroxide is generated.
57
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This latter compound can be more easily treated to yield elemental
mercury. The equations for decomposition of both forms of mercury are
presented below.
1) HgS + 02 - Hg + S02
2) Hg2(OH)2 - 2Hg + H20 + 0.502
This second reaction occurs more readily than the first at the
temperatures at which the process is normally operated.
Description of the Retorting Process
The process generally consists of three unit operations:
(1) processing in the retort or oven, (2) a metals collection system, and
(3) an air pollution control system. Figures 3-1 and 3-2 show a retort
system with and without a scrubber water discharge.
(1) Wastes are placed in the retort (typically, an oven) where they
are heated and decomposition and volatilization occurs. In addition to
an oven, retorting has been carried out in multiple hearth furnaces.
Heat is typically supplied from a fossil fuel burner. Residual solids
remaining in the retort (stripped of metal contaminants) are collected
and disposed.
(2) The combustion gas stream from the retort is cooled in a
condenser to condense the gaseous metal. Alternatively, the gas may be
cooled directly in an air pollution control scrubber.
(3) If an air pollution control scrubber is not used as a condensing
device, then an air pollution control system must be provided after the
58
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WATER
PREHEATED
AIR
en
STACK
MERCURY TO RECOVERY
RETORTING PROCESS (WITH WASTEWATER DISCHARGE)
FIGURE 3-1
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PREHEATED
AIR
CTi
I AIR
POLLUTION
CONTROL
DEVICE |
STACK
MERCURY
COLLECTION
RETORTING PROCESS (WITHOUT WASTEWATER DISCHARGE)
FIGURE 3-2
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condenser to remove any residual metal in the exhaust gas stream, as well
as control other potential emissions such as SO and ash.
Waste Characteristics Affecting Performance (WCAP)
In determining whether performance standards can be transferred from
an untested waste to a previously tested waste, EPA will examine the
following waste characteristics: (1) type and concentration of metal
compounds in the waste, (2) heat transfer characteristics of the waste,
and (3) boiling point of the metal.
(1) Type and Concentration of Metal Compounds in the Waste
The presence of other volatile metals in the waste may affect the
composition of the condensed metal product by co-volatilization with the
metal of concern. Also, metals may be present as salts which are stable
at the retorting operating temperature and, therefore, would not
volatilize. In such a case, the condensed free metal may be too
contaminated for reuse. A problem sometimes encountered in the case of
mercury is the formation of amalgams between the elemental mercury formed
in the retorting process and metallic elements present in a waste.
(2) Heat Transfer Characteristics
The ability to heat constituents within a waste matrix is a function
of the heat transfer characteristics of the waste material. The metal
which is to be recovered must be heated sufficiently to volatilize.
There is no convenient direct measurement of the heat transfer
characteristics of the waste. EPA believes the best measure of heat
transfer characteristics of the waste is thermal conductivity. Thermal
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conductivity can be measured by the "Guarded, Comparative, Longitudinal
Heat Flow Technique"; this method is described in Appendix I to this
technology section.
(3) Boiling Point
EPA believes that the best measure of volatility of a specific metal
constituent is the boiling point. EPA recognizes that boiling point has
certain shortcomings, primarily the fact that boiling points are given
for pure components, while clearly the other constituents in the waste
will affect the partial pressures, and, thus, the boiling point of the
mixture. Nevertheless, EPA has not identified a parameter that can
better assess the volatility of the metal.
Design and Operating Parameters
EPA's analysis of whether a retorting process is well designed will
focus on whether sufficient energy in the form of heat is likely to be
provided to volatilize the metals content of the waste. Additionally, in
the case of mercury contaminated wastes, EPA will evaluate the blending
operation, if appropriate. The particular design parameters to be
evaluated are: (1) treated and untreated design concentrations,
(2) retort temperature and (3) residence time.
(1) Treated and Untreated Design Concentrations. In assessing the
design and operation of a retort operation, EPA will examine the treated
design concentration as part of its analysis. As the Agency can not
reasonably expect the retort to perform better than design, EPA will
evaluate whether the design is consistent with best demonstrated
practices.
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In a similar manner, EPA will examine untreated waste concentrations
to ensure that these values are consistent with design conditions.
Operation of any treatment system outside of the waste characteristics
for which it was designed can easily lead to poor performance.
(2) Retort Temperature. In order to vaporize the metal compounds,
sufficient temperatures must be provided. Excessive temperatures may
volatilize other, less volatile materials, contaminating the metal
product and inhibiting its potential for reuse. If temperatures are too
low, decomposition and volatilization may not take place. To ensure that
the system is operated at design conditions during treatment, EPA would
want a continuous temperature reading.
(3) Residence Time. Residence time is important because it directly
impacts the total heat supplied to the waste. The retort must be
designed to ensure the waste has sufficient time to reach the optimum
temperature and the metal receive enough heat to completely volatilize.
If the process is continuous, the residence time is a function of the
physical dimensions of the retort, and the waste feed rate. EPA would
want to monitor the waste feed rate during treatment as an indication of
the residence time.
3.2.2 Chemical Precipitation Treatment System
Any wastewater produced during treatment of K106, such as scrubber
water from retorting or wastewater removed by dewatering, can be treated
by sulfide precipitation and filtration to remove mercury and other
metals as sulfides in the wastewater treatment sludge.
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3.2.2.1 Chemical Precipitation
(1) Applicability and Use of Chemical Precipitation
Chemical precipitation is used when dissolved metals are to be
removed from solution. This technology can be applied to a wide range of
wastewaters containing dissolved BOAT list metals and other metals as
well. This treatment process has been practiced widely by industrial
facilities since the 1940s.
(2) Underlying Principles of Operation
The underlying principle of chemical precipitation is that metals in
wastewater are removed by the addition of a treatment chemical that
converts the dissolved metal to a metal precipitate. This precipitate is
less soluble than the original metal compound, and therefore settles out
of solution, leaving a lower concentration of the metal present in the
solution. The principal chemicals used to convert soluble metal
compounds to the less soluble forms include: lime (Ca(OH) ), caustic
(NaOH), sodium sulfide (Na S), and, to a lesser extent, soda ash
(Na CO ), phosphate, and ferrous sulfide (FeS). With the exception
tL o
of mercury and arsenic, the BOAT list metals are generally precipitated
with lime or caustic; mercury and arsenic are generally precipitated with
sodium sulfide or sodium hydrosulfide.
The solubility of a particular compound will depend on the extent to
which the electrostatic forces holding the ions of the compound together
can be overcome. The solubility will change significantly with
temperature; most metal compounds are more soluble as the temperature
64
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increases. Additionally, the solubility will be affected by the other
constituents present in a waste. As a general rule, nitrates, chlorides,
and sulfates are more soluble than hydroxides, sulfides, carbonates, and
phosphates.
An important concept related to hydroxide precipitation is pH; this
parameter affects other types of precipitation, such as sulfide, but does
not play as important a role in these other precipitation methods. This
parameter, pH, provides a measure of the extent to which a solution
contains either an excess of hydrogen or hydroxide ions. The pH scale
ranges from 0 to 14; with 0 being the most acidic, 14 representing the
highest alkalinity or hydroxide ion (OH ) content, and 7.0 being
neutral. When hydroxide is used to precipitate the soluble metal
compounds, the pH is frequently monitored to ensure that sufficient
treatment chemicals are added. Although pH is important in other types
of precipitation, it is generally not a good indicator of whether
sufficient treatment chemical is added. When sulfide is used, for
example, facilities might use an oxidation-reduction potential meter
(ORP) correlation to ensure that sufficient treatment chemical is used.
Following conversion of the relatively soluble metal compounds to
metal precipitates, the effectiveness of chemical precipitation is a
function of the physical removal, which usually relies on a settling, but
can consist of direct filtration. Filtration is discussed separately;
settling is discussed below as it is the most often used form of physical
removal. A particle of a specific size, shape, and composition will
65
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settle at a specific velocity, as described by Stokes' Law. For a batch
system, Stokes' law is a good predictor of settling time because the
pertinent particle parameters remain essentially constant. Nevertheless,
in practice, settling time for a batch system is normally determined by
empirical testing. For a continuous system, the theory of settling is
complicated by factors such as turbulence, short-circuting, and velocity
gradients, increasing the importance of the empirical tests.
(3) Description of the Technology
The equipment and instrumentation required for chemical precipitation
varies depending on whether the system is batch or continuous. Both
operations are discussed below; a schematic of the continuous system is
shown in Figure 3-3.
For a batch system, chemical precipitation requires only a feed
system for the treatment chemicals and a second tank where the waste can
be treated and allowed to settle. When lime is used, it is usually added
to the reaction tank in a slurry form. In a batch system, the supernate
is usually analyzed before discharge, thus minimizing the need for
instrumentation.
In a continuous system, additional tanks are necessary, as well as
instrumentation to ensure that the system is operating properly. In this
system, the first tank that the wastewater enters is referred to as an
equalization tank. This is where the waste can be mixed in order to
provide more uniformity, minimizing wide swings in the type and
concentration of constituents being sent to the reaction tank. It is
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WASTEWATER
FEED
EQUALIZATION
TANK
Ğ
Q
A.
*
9
i
7
O
TREATMENT
CHEMICAl
FEED
SYSTEM
i ,,
^1 H
NITOR
ELECTRICAL CONTROLS
WASTEWATER FLOW
MIXER
COAGULANT OR
FLOCCULANT FEED SYSTEM
EFFLUENT TO
DISCHARGE OH
SUBSEQUENT
TREATMENT
^.SLUDGE TO
OEWATERINO
FIGURE 3-3 CONTINUOUS CHEMICAL PRECIPITATION
-------
important to reduce the variability of the waste sent to the reaction
tank because control systems inherently are limited with regard to the
maximum fluctuations that can be managed.
Following equalization, the waste is pumped to a reaction tank where
treatment chemicals are added; this is done automatically by using
instrumentation that senses the pH of the system and then pneumatically
adjusts the position of the treatment chemical feed valve such that the
design pH value is achieved. Both the complexity and the effectiveness
of the automatic control system will vary depending on the variation in
the waste and the pH range that is needed to properly treat the waste.
An important aspect of the reaction tank design is that it be
well-mixed so that the waste and the treatment chemicals are both
dispersed throughout the tank, in order to ensure comingling of the
reactant and the treatment chemicals. In addition, effective dispersion
of the treatment chemicals throughout the tank is necessary to properly
monitor and, thereby, control the amount of treatment chemicals added.
After the waste is reacted with the treatment chemical, it flows to a
quiescent tank where the precipitate is allowed to settle and
subsequently be removed. Settling can be chemically assisted through the
use of flocculating compounds. Flocculants increase the particicle size
and density of the precipitated solids, both of which increase the rate
of settling. The particular flocculating agent that will best improve
settling characteristics will vary depending on the particular waste;
selection of the flocculating agent is generally accomplished by
performing laboratory bench tests. Settling can be conducted in a large
68
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tank by relying solely on gravity or be mechanically assisted through the
use of a circular clarifier or an inclined separator. Schematics of the
latter two separators are shown in Figures 3-4 and 3-5.
Filtration can be used for further removal of precipitated residuals
both in cases where the settling system is underdesigned and in cases
where the particles are difficult to settle. Polishing filtration is
discussed in a separate technology section.
(4) Waste Characteristics Affecting Performance
In determining whether chemical preciptation is likely to achieve the
same level of performance on an untested waste as a previously tested
waste, we will examine the following waste characteristics: (1) the
concentration and type of the metal(s) in the waste, (2) whether the
metal exists in the wastewater as a complex, (3) the concentration of
suspended solids (TSS), (4) the concentration of dissolved solids (IDS),
and (5) the oil and grease content. These parameters either affect the
chemical reaction of the metal compound, the solubility of the metal
precipitate, or the ability of the precipitated compound to settle. If
facilities used filtration directly following precipitation, the
discussion of the latter three waste characteristics would not be
appropriate because they apply to settling. The filtration technology
documents have a separate discussion of waste characteristics affecting
performance.
(a) Concentration and type of metals. For most metals, there is a
specific pH at which the metal hydroxide is least soluble. As a result,
-------
SLUDGE
INFLUENT
CENTER FEED CLARIFIER WITH SCRAPER SLUDGE REMOVAL SUSTEM
INFLUENT
EFFLUENT
SLUDGE
RIM FEED - CENTER TAKEOFF CLARIFIER WITH
HYDRAULIC SUCTION SLUDGE REMOVAL SYSTEM
INFLUENT
EFFLUENT
SLUDGE
RIM FEED - RIM TAKEOFF CLARIFIER
FIGURE 3-4
CIRCULAR CLARIFIERS
70
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INFLUENT
EFFLUENT
FIGURE 3-5
INCLINED PLATE SETTLER
71
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when a waste contains a mixture of many metals, it is not possible to
operate a treatment system at a single pH which is optimal for the
removal of all metals. The extent to which this affects treatment
depends on the particular metals to be removed, and their concentratibns.
An alternative can be to operate multiple precipitations, with
intermediate settling, when the optimum pH occurs at markedly different
levels for the metals present. The individual metals and their
concentrations can be measured using EPA Method 6010.
(2) Complexed metals. Metal complexes consist of a metal ion
surrounded by a group of other inorganic or organic ions or molecules
(often called ligands). In the complexed form, the metals have a greater
solubility and, therefore, may not be as effectively removed from
solution by chemical precipitation. EPA does not have an analytical
method to determine the amount of complexed metals in the waste. The
Agency believes that the best measure of complexed metals is to analyze
for some common complexing compounds (or complexing agents) generally
found in wastewater for which analytical methods are available. These
complexing agents include ammonia, cyanide, and EDTA. The analytical
method for cyanide is EPA Method 9010. The method for EDTA is ASTM
Method D3113. Ammonia can be analyzed using EPA Wastewater Test
Method 350.
(b) Concentration and type of total suspended solids (TSS). Certain
suspended solid compounds are difficult to settle because of either their
particle size or shape. Accordingly, EPA will evaluate this
72
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characteristic in assessing transfer of treatment performance. Total
suspended solids can be measured by EPA Wastewater Test Method 160.2.
(c) Concentration of total dissolved solids (TDSK Available
information shows that total dissolved solids can inhibit settling. The
literature states that poor flocculation is a consequence of high TDS and
shows that higher concentrations of total suspended solids are found in
treated residuals. Poor flocculation can adversely affect the degree to
which precipitated particles are removed. Total dissolved solids can be
measured by EPA Wastewater Test Method 160.1.
(d) Oil and grease content. The oil and grease content of a
particular waste directly inhibits the settling of the precipitate.
Suspended oil droplets float in water and tend to suspend particles such
as chemical precipitates that would otherwise settle out of the
solution. Even with the use of coagulants or flocculants, the separation
of the precipitate is less effective. Oil and grease content can be
measured by EPA Method 9071.
(5) Design and Operating Parameters
The parameters that EPA will evaluate when determining whether a
chemical precipitation system is well designed are: (1) design value for
treated metal concentrations, as well as other characteristics of the
waste used for design purposes (e.g., total suspended solids), (2) pH,
(3) ORP, (4) residence time, (5) choice of treatment chemical, (6) choice
of coagulant/flocculant, and (7) mixing. Below is an explanation of why
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EPA believes these parameters are important to a design and operating
analysis.
(a) Treated and untreated design concentrations. EPA pays close
attention to the treated concentration the system is designed to achieve
when determining whether to sample a particular facility. Since the
system will seldom out-perform its design, EPA must evaluate whether the
design is consistent with best demonstrated practice.
The untreated concentrations that the system is designed to treat are
important in evaluating any treatment system. Operation of a chemical
precipitation treatment system with untreated waste concentrations in
excess of design values can easily result in poor performance.
(b) pH. The pH is especially important for hydroxide precipitation
because it can indicate whether sufficient treatment chemical
(e.g., lime) is added to convert the metal constituents in the untreated
waste to forms that will precipitate. The pH also affects the solubility
of metal hydroxides and sulfides, and therefore directly impacts the
effectiveness of removal. In practice, the design pH is determined by
empirical bench testing, often referred to as "jar" testing. The
temperature at which the "jar" testing is conducted is important in that
it also affects the solubility of the metal precipitates. Operation of a
treatment system at temperatures above the design temperature can result
in poor performance. In assessing the operation of a chemical
precipitation system, EPA prefers continuous data on the pH and periodic
temperature conditions throughout the treatment period.
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(3) ORP
When sodium sulfide or sodium hydrosulfide is used as a precipitant,
facilities may use oxidation-reduction potential (ORP) as an indicator of
whether, and how much, excess sulfide is present. In such cases, EPA
would want to know the design value and the basis for selecting this
value. In addition, the Agency would prefer continuous data on the ORP
value during treatment to ensure that it complied with design
specifications.
(c) Residence time. The residence time is important because it
impacts the completeness of the chemical reaction to form the metal
precipitate and, to a greater extent, amount of precipitate that settles
out of solution. In practice, it is determined by "jar" testing. For
continuous systems, EPA will monitor the feed rate to ensure that the
system is operated at design conditions. For batch systems, EPA will
want information on the design parameter used to determine sufficient
settling time (e.g., total suspended solids).
(d) Choice of treatment chemical. A choice must be made as to what
type of precipitating agent (i.e., treatment chemical) will be used. The
factor that most affects this choice is the type of metal constituents to
be treated. Other design parameters, such as pH, residence time, and
choice of coagulant/flocculant agents, are based on the selection of the
treatment chemical.
(e) Choice of coagulant/flocculant. This is important because these
compounds improve the settling rate of the precipitated metals and allows
75
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for smaller systems (i.e., lower retention time) to achieve the same
degree of settling as a much larger system. In practice, the choice of
the best agent and the required amount is determined by "jar" testing.
(f) Mixing. The degree of mixing is a complex assessment which
includes, among other things, the energy supplied, the time the material
is mixed, and the related turbulence effects of the specific size and
shape of the tank. EPA will, however, consider whether mixing is
provided and whether the type of mixing device is one that could be
expected to achieve uniform mixing. For example, EPA may not use data
from a chemical precipitation treatment system where an air hose was
placed in a large tank to achieve mixing.
3.2.2.2 Polishing Filtration
Filtration is the removal of solids from wastes by a medium that
permits the flow of the fluid but retains the particles. When filtration
is conducted on wastewaters with low concentrations of solid particles
(generally below 1,000 ppm), the term "polishing" filtration is applied;
when conducted on wastes with higher concentrations of solids, the term
"sludge" filtration is applied. This section discusses "polishing"
filtration; sludge filtration is discussed separately.
Applicabilitv
Polishing filtration is used to treat wastewaters containing
relatively low concentrations of solids. Multimedia filtration, pressure
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or gravity sand filtration, and cartridge filtration are some of the
types of equipment used for polishing filtration. This type of
filtration is typically used as a polishing step for the supernatant
after precipitation and settling (clarification) of wastewaters
containing metal precipitates. In general, filtration is used to remove
particles that are difficult to settle because of shape and/or density or
to assist in removal of precipitated particles from an underdesigned
settling device.
Underlying Principle of Operation
The basic principle of filtration is the separation of particles from
a mixture of fluids and particles by a medium that permits the flow of
the fluid but retains the particles. As would be expected, larger
particles are easier to separate from the fluid than smaller particles.
Extremely small particles, in the colloidal range, may not be
filtered effectively in a polishing filter and may appear in the treated
wastewater. To mitigate this problem, the wastewater should be treated
prior to filtration to modify the particle size distribution in favor of
the larger particles, by the use of appropriate precipitants, coagulants,
flocculants, and filter aids. The selection of the appropriate
precipitant or coagulant is important because it affects the particles
formed. For example, lime neutralization usually produces larger, less
gelatinous particles than does caustic soda precipitation. For larger
particles that become too small to filter effectively because of poor
resistance to shearing, shear resistance can be improved by the use of
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coagulants and flocculants. Also, if pumps are used to feed the filter,
shear can be minimized by designing for a lower pump speed, or by use of
a pump with an impeller design that minimizes shearing.
Filter aids such as diatomaceous earth are used to precoat the
cloth-type filter material and provide an initial filter cake onto which
additional solids will be deposited during the filtration process. The
presence of the precoat allows for removal of small particles from the
solution being filtered. Smaller particles will mechanically adhere to
the precoat solids during the filtration process.
Description of Polishing Filtration System
For relatively low flows, a cartridge filter can be used. In this
case a cylindrically shaped cartridge, such as a matted cloth, is placed
within a sealed metal vessel. Wastewater is pumped through the cartridge
until the flow drops excessively because of plugging of the filter
media. The sealed vessel is then opened and the plugged cartridge
removed and replaced with a new cartridge. The plugged cartridge is then
disposed.
For relatively large volume flows, granulated media (such as sand or
anthracite coal) are used to trap suspended solids within the pore spaces
of the media. Wastewater is filtered until excessive pressure is
required to maintain the flow or until the flow drops to an unacceptable
level. Granular media filters are cleaned, by backwashing with filtered
water that has been stored for that purpose. (Backwashing is always
upflow to loosen the media granuals and resuspend the entrapped solids.)
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The backwash water, which may be as much as 10 percent of the volume of
the filtered wastewater, is then returned to the treatment system, so
that the solids in the backwash water can be settled in the system
clarifier.
Waste Characteristics Affecting Performance
To determine whether filtration would achieve a level of performance
on an untested waste similar to that of a tested waste, EPA will examine
the following waste characteristics: (1) size of suspended particles and
(2) type of particles.
Size of particles
Extremely small particles, in the colloidal range, may not be
filtered effectively in a polishing filter and may appear in the
filtrate. Accordingly, EPA would examine the particle size in assessing
transfer of performance. Particle size can be determined using ASTM
Method D422, Particle Size Distribution.
Particle type
Some suspended solids are gelatinous in nature and are, therefore,
difficult to filter. To the extent possible, EPA will assess the type of
suspended solids particles that are present in assessing transfer of
performance. EPA is not aware of any specific quantitative method to
measure the particle type; accordingly, such an assessment will be based
on a qualitative engineering analysis of the suspended solids particles.
Design and Operating Parameters
The design and operating parameters that EPA will evaluate in
assessing the performance of polishing filtration are: (1) treated and
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untreated design concentrations, (2) type of filter, (3) pore size,
(4) waste feed pressure, and (5) use and type of filter aids. Each of
these parameters is discussed below,
(1) Treated and untreated design concentrations
As with other technologies, it is important to know the level of
performance that the particular unit was designed to achieve in order to
ensure that the design value represents best demonstrated practice.
Additionally, EPA would want to evaluate feed characteristics to the
filter during treatment to ensure that the unit was operated within
design specifications. Operation of the filter in excess of feed
conditions could easily lead to poor performance.
(2) Type of filter
There are several different types of polishing filters including
granular media, cartridge filters, and pressure filters such as plate and
frame. Factors that affect filter selection include the concentration of
suspended solids, particle type and size, process conditions (including
flow rate and pressure), and whether the treatment system is operated on
a batch or continuous process. While more than one type will generally
work, it is important to know the type of filter used, as well as the
basis for selecting that filter.
(3) Pore size
The pore size determines the particle size that will be effectively
removed; accordingly, it is an important factor in assessing filtration
effectiveness on a particular waste. EPA will need to know the pore size
used as well as the basis for selection.
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(4) Pressure Drop Across the Filter
An important filter design specification is the pressure drop across
the filter. A pressure drop that is higher than the filter design can
force solid particles through the filter and thus reduce the filter
effectiveness. During treatment, EPA will examine pressure readings
periodically to ensure that the filter is being operated within design
specifications.
(5) Use and type of filter aids
As previously discussed, filter aids improve the effectiveness of
filtering gelatinous particles, as well as increase the time that the
filter can stay on line. In assessing filtration performance it is
important to know both the type of filter aid used and the basis for
selection.
3.3 Performance Data for Nonwastewater
For treatment of K106 nonwastewater, EPA has the following retorting
performance data. These performance data are described below and
summarized in Table 3-1.
The Agency has five untreated and treated data sets from a literature
source on the treatment of a combined K071/K106 nonwastewater using
dewatering followed by retorting. The K106 wastes comprised 0.5 percent
of the feed to the retort furnace.
The Agency has four treated and untreated data points from one
facility for the treatment of K106 by retorting. The waste retorted at
this facility was a wastewater treatment sludge generated from hydrazine
treatment of mercury-contaminated wastewaters.
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1964g/l
Table 3-1 Retorting Performance Data
Retorting Data Submitted by Industry for K071/K106 Nonwastewater
Untreated waste
BOAT List Metal Total concentration
Mercury
Mercury ^
Mercury
Mercury
Mercury
Reference: USEPA 1974.
(ppm)
345
255
290
438
370
Treated waste
Total concentration
(ppm)
0.5 - 0.8
1.6 - 3.1
1.7 - 2.6
2 - 7.2
1.6
Retorting Data Submitted by Industry for K106
Generated From Hydrazine Treatment
BOAT List Metal
Mercury
Mercury
Mercury
Mercury
Reference: Occidental
Untreated waste
Total concentration
(ppm)
4300
5500
2500
2000
Chemical Corporation. 1987.
Treated waste
Total concentration
(ppm)
100
90
47
41
Retorting Data Submitted by Industry for Mercury Ores
Untreated waste Treated waste
BOAT List Metal Total concentration Total concentration
(ppm) (ppm)
Mercury 650,000 500
Reference: McOermitt Mine 1988.
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The Agency has one treated and untreated data point from the
retorting of mercury sulfide ores. As previously discussed in this
section, the Agency believes that these ores are similar to K106 and
accordingly these data represent performance that can be achieved by
retorting K106.
3.4 Performance Data for Wastewater
EPA does not have analytical data on K106 wastewater generated as
part of retorting operations. However, EPA believes that this wastewater
would be similar in chemical and physical characteristics to wastewaters
generated in treatment of K071 waste by acid leaching and other mercury-
containing wastewaters. The Agency collected three data sets of
untreated and treated data for treatment of K071 wastewater in a sulfide
precipitation and filtration treatment system. The treatment performance
data for K071 wastewaters are presented in Table 3-2.
83
-------
1893g
oc
Table 3-2 SulHde Precipitation - EPA-Collected Data for K071 Wastewaters
ANALYTICAL DATA:
BOAT list constituent
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Si Iver
Vanadium
Zinc
DESIGN AND OPERATING
Parameter
Excess sulfide
Sample
Untreated
wastewater
(mg/1)
<0.2
0.248
<0.03
<0 06
0.097
<0.66
23.7
0.157
0.148
<0.04
0.615
PARAMETERS:
Set #1
Treated
wastewater
(mg/1)
<0.2
0.103
<0.06
0.553
<0.16
<1.32
0.028
0 275
<0.1
<0.08
0.047
Design value
>40 mg/1
Sample
Untreated
wastewater
(mg/1)
<0.1
0.226
<0.06
0.189
<0.16
<1.32
9.25
<0.26
0.1
<0.08
0.88
Set #2
Treated
wastewater
(mg/1)
<0.1
0.158
<0.06
<0.12
<0.16
<1.32
0.027
<0.26
<0.1
<0.08
<0.04
Sample Set 11
85 mg/1
Sample Set #3
Untreated
Treated
wastewater wastewater
(mg/1)
<0.1
0.293
<0.06
<0.12
<0.16
<1.32
77.2
<0.26
0.12
<0.08
0.535
(nig/1)
<0.1
0.144
<0.06
<0.12
<0.16
<1.32
0.028
<0.26
<0.1
<0.08
0 064
Operating values
Sample Set #2
101 mg/1
Filter cake (K106)a
(total)
(mg/kg)
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
Sample Set
96 mg/1
(TCLP)
(mg/1)
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
13
a Only one sample was collected of the ilter (fake (K.106).
Reference: USEPA 1988a.
-------
4. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE
TECHNOLOGY (BOAT)
This section presents the rationale for the determination of best
demonstrated available technology (BOAT) for K106 nonwastewaters and
wastewaters. As discussed in Section 1 and summarized here, the Agency
examines all the available data for the demonstrated technologies to
determine if one of the technologies performs significantly better than
another. Next, the "best" performing treatment technology is evaluated
to determine if the resulting treatment is substantial. If the "best"
technology provides substantial treatment and it has been determined that
the technology is also available to the affected industry, then the
technology represents BOAT.
4.1 BDAT for Nonwastewater
As discussed in the previous section, EPA has identified retorting as
the only demonstrated technology for treatment of K106 nonwastewaters.
This technology is the only demonstrated technology and is, therefore,
the "best" performing technology. Consistent with EPA's methodology for
determining BDAT as summarized above, the Agency also evaluated the
performance data presented in Section 3 to determine whether retorting
also provided substantial treatment for K106 nonwastewaters. All the
available retorting treatment performance data were submitted by industry.
As a first step, EPA examined the data to determine if any data
represented treatment by a poorly designed or poorly operated system.
EPA did not find any such data and, therefore, used all the data in its
determination of substantial treatment.
85
-------
After this step, the Agency examined the treated values to ensure
that the data represented accuracy corrected data. EPA requested but did
not receive accuracy correction values; therefore, the Agency is assuming
that these data were corrected for analytical accuracy prior to being
submitted to EPA. Accordingly, no adjustments were made to the
performance data shown in Table 3-1 prior to their use in EPA's
determination of substantial treatment.
EPA's determination of substantial treatment is based on the
reduction in total mercury concentration from 650,000 ppm to 500 ppm in
mercury sulfide ores considered by EPA to be similar to K106
nonwastewaters.
The Agency believes that this reduction of hazardous constituents is
substantial and that retorting is available to treat K106 wastes because
it is commercially available; therefore, retorting represents BOAT for
K106 nonwastewaters.
4.2 BOAT for Wastewaters
EPA has identified sulfide precipitation followed by filtration as
the only demonstrated technology for treatment of K106 wastewaters. This
technology is the only demonstrated technology and is, therefore, the
"best" performing technology. As discussed earlier, EPA does not have
treatment data for K106 wastewaters generated from retorting; however,
EPA does have treatment data for K071 mercury containing wastewaters
believed to be similar to K106 wastewaters.
86
-------
Data collected by the Agency on treatment of K071 wastewater by
sulfide precipitation and filtration are shown in Table 3-2. Operating
data collected during treatment of this waste show that these data
represent the performance of a well-designed, well-operated treatment
system.
Next, EPA adjusted the data values based on the analytical recovery
values in order to take into account analytical interferences associated
with the chemical makeup of the treated sample. In developing recovery
data (also referred to as accuracy data), EPA first analyzed a waste for
a constituent and then added a known amount of the same constituent
(i.e., spike) to the waste material. The total amount recovered after
spiking minus the initial concentration in the sample divided by the
amount added is the recovery value. Percent recovery values for BOAT
list metals used in adjustment of the performance data are presented in
Appendix B. The analytical data were adjusted for accuracy using the
lowest recovery value for each constituent.
EPA's determination of substantial treatment is based on the observed
reduction in total mercury concentration from 77.2 ppm to 0.28 ppm in the
K071 mercury-containing wastewaters considered by EPA to be similar to
K106 wastewaters.
The Agency believes that this reduction of hazardous constituents is
substantial and that sulfide precipitation followed by filtration is
available to treat K106 wastes because it is commercially available;
therefore, sulfide precipitation followed by filtration represents BOAT
for K106 wastewaters.
87
-------
5. SELECTION OF REGULATED CONSTITUENTS
This section describes, step by step, the process used to select the
constituents to be regulated for K106. The selected constituents must be
present in the untreated waste at concentrations that are treatable by
the chosen BOAT discussed in Section 4.
As discussed in Section 1, the Agency has developed a list of
hazardous constituents (Table 1-1) from which the constituents to be
regulated are selected. The list is a "growing list" that does not
preclude the addition of new constituents as additional key parameters
are identified. The list is divided into the following categories:
volatile organics, semivolatile organics, metals, inorganics other than
metals, organochlorine pesticides, phenoxyacetic acid herbicides,
organophosphorous insecticides, PCBs, and dioxins and furans.
*
5.1 Nonwastewaters
Table 5-1 presents the BOAT constituent list and indicates which of
the BOAT list constituents were analyzed for in the untreated K106 waste
and which of unanalyzed constituents were detected in the untreated K106
waste.
The untreated waste sample was not analyzed for the organic compounds
on the BOAT list (volatiles, semivolatiles, organochlorine pesticides,
phenoxyacetic acid herbicides, organophosphorous insecticides, PCBs, and
dioxins and furans) because the Agency is not aware of any in-process
source of these constituents and would, therefore, not expect any of
these constituents to be present at treatable concentrations. Inorganics
88
-------
other than metals on the BOAT list (i.e., fluoride, sulfide, and cyanide)
were not analyzed. Even though these constituents were not analyzed, EPA
would not expect fluoride or cyanide to be present at treatable
concentrations. However, sulfide would clearly be present in the K106
wastes generated by sulfide precipitation. EPA is not proposing
regulations for sulfide in K106 wastes.
Of the 16 metals on the BOAT list of constituents, EPA analyzed for
15. Of the 15 metals analyzed, 11 were detected in the total
concentration analysis and six of these metals were detected in the TCLP
leachate analysis. Of the 11 metals detected in K106 waste, EPA's review
of the data showed the following ten metals were not present at treatable
concentrations; six of these metals (barium, copper, lead, nickel,
silver, and zinc) were present in total concentrations ranging from 14
ppm for nickel to 443 ppm for zinc. EPA is not aware of a technology
that can further treat these metals when found in combination with
mercury at the concentrations found in K106 (roughly 44,000 ppm). For
this reason and because mercury was also present at the highest
concentration (44,000 ppm), mercury has been selected as the only
regulated constituent for K106 nonwastewaters.
5.2 Wastewater
EPA does not have data on K106 wastewaters generated from retorting.
However, EPA would not expect any BOAT constituent other than mercury to
be present in treatable quantities in the K106 wastewater for reasons
already presented under nonwastewaters. Therefore, mercury has been
selected as a regulated constituent for K106 wastewaters.
89
-------
1543g
Table 5-1 BOAT List, of Constituents Detected in Untreated K106
Generated from Sulfide Precipitation
BOAT
reference
no.
Volatiles
222.
1.
2.
3.
4.
5.
6.
223.
7.
8
9.
10.
11.
12.
13
14.
15.
16
17.
IB.
19
20.
21.
22.
23.
24.
25
26.
27.
28
29.
224.
225.
226.
30.
227
31.
214
32
33
228
34
Parameter
Acetone
Acetonitnle
Acrolein
Acrylomtri le
Benzene
Bromodichloromethane
Bromome thane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-l,3-butadiene
Ch lorod i bromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 , 2-Dibromo-3-chloropropane
1 , 2-Dibromoethane
Qibromomethane
trans-1 ,4-Dichloro-2-butene
D i ch lorod i f 1 uoromethane
1 . 1-Dichloroethane
1 ,2-Dichloroethane
1 . 1-Dichloroethylene
trans-l,2-0ichloroethene
1 , 2-Dichloropropane
trans-1 ,3-Oichloropropene
cis-1 ,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyltaenzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Eth> iene oxide
lodomethane
IsoDutyl alcohol
Methanol
Methyl ethyl ketone
CAS no. Detection status
67-64-1
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110-75-8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-95-3
110-57-6
75-71-8
75-34-3
107-06-2
75-35-4
156-60-5
78-87-5
10061-02-6
10061-01-5
123-91-1
110-80-5
141-78-6
100-41-4
107-12-0
60-29-7
97-63-2
75-21-8
74-88-4
78-83-1
67-56-1
78-93-3
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
MA
NA
NA
NA
NA
90
-------
1543g
Table 5-1 (continued)
BOAT
reference
no.
Volatiles
229.
35.
37.
38.
230.
39
40.
41.
42.
43.
44
45.
46.
47.
48
49.
231.
50.
215.
216.
217
Parameter
(continued)
Methyl isobutyl ketone
Methyl methacrylate
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyriaine
1,1,1, 2-Tetrachloroethane
1,1,2 , 2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Trichloroethane
1 ,1,2-Tnchloroethane
Trichloroethene
Tr i ch loromonof 1 uoromethane
1 , Z ,i-Tnchloropropane
l,l,2-Trichloro-l,2,2-trif luoro-
ethane
Vinyl chloride
1,2-Xylene
1 ,3-Xy lene
1 ,4-Xylene
CAS no. Detection status
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
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Semivolat i les
51.
52.
53.
54.
55.
56.
57.
58.
218
59.
60.
61.
63
65
64.
62
66
Acenaphthalene
Acenaphthene
Acetophenone
2 - Acetyl am inof luorene
4-Aminobipheny 1
An 1 1 me
Anthracene
Aramite
Benzal chloride
Benz(a)anthracene
Benzenethiol
Deleted
Benzo(b)f luoranthene
Benzo(k)f luoranthene
Benzo(ghi )pery lene
Benzo(a)pyrene
p-Benzoquincne
208-96-8
83-32-9
96-86-2
53-96-3
92-67-1
62-53-3
120-12-7
140-57-8
98-87-3
56-55-3
106-98-5
205-99-2
207-08-9
191-24-2
50-32-8
106-51-4
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
91
-------
1543g
Table 5-1 (continued)
BOAT
reference Parameter
no.
CAS no. Detection status
Semivolati les (continued)
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.
102
103
104.
105.
ioe
219
Bis(2-chloroethoxy)methane
BisU-chloroethyl) ether
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl) phthalate
4-Bromophenyl phenyl ether
Butylbenzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroani 1 me
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
o-Cresol
p-Cresol
Cyclohexanone
D i benz( a, h) anthracene
0 1 benzo { a , e ) py rene
Dibenzofa, ijpyrene
1,3-Dichlorobenzene
1,2-Dichlorobenzene
1 ,4-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2.6-Dichlorophenol
Diethyl phthalate
3,3 '-Oimethoxybenzidme
p-Di met hy lamlnoazobenzene
3,3'-Dimethylbenzidme
2,4-Dimethylphenol
Dimethyl phthaldte
Di-n-butyl phthalate
1 ,4-Dinitrobenzene
4,6-Dimtro-o-cresol
2,4-D mi trophenol
2,4-Dini trotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Dt-n-propyln ttrosamine
Dipheny lam me
Oipnenylnitrosamme
111-91-1
111-44-4
39638-32-9
117-81-7
101-55-3
85-68-7
88-S5-7
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
121-14-2
606-20-2
117-84-0
621-64-7
122-39-4
86-30-6
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
1543g
Table 5-1 (continued)
BOAT
reference Parameter
no.
CAS no. Detection status
Semivolati les (continued)
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.
139.
140.
141.
142
220.
143.
144.
145
146.
1 , 2 - D i pheny 1 hydraz i ne
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorophene
Hexach loropropene
I ndeno ( 1 , 2 , 3- cd ) py rene
Isosaf role
Methapyr i lene
3-Methylcholanthrene
4,4'-Methylenebis (2-chloroani line)
Methyl methanesulfonate
Naphthalene
1 , 4-Naphthoqumone
1-Naphthylairnne
2-Naphthylamine
p-Nitroani 1 me
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethy lamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N-Nitrosomorphol me
N-Nitrosopi pen dine
N-Nitrosopyrrolidme
5-Nitro-o-toluidme
Pentach lorobenzene
Pentach loroethane
Pentach loromtrobenzene
Pentachlorophenol
Phenacet in
Phenanthrene
Phenol
Phthalic anhydride
2-Picol me
Pronamide
Pyrene
Resorcmol
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
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
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
-------
1543g
Table 5-1 (continued)
BOAT
reference Parameter
no.
Semivolati les (continued)
147 Safrole
148 1,2,4,5-Tetrachlorobenzene
149. 2,3,4,6-Tetrachlorophenol
150. 1,2,4-Trichlorobenzene
151. 2,4, 5-Trichlorophenol
152. 2,4,6-Trichlorophenol
153. Tns(2,3-dibromopropyl)
phosphate
Metals
154. Antimony
155. Arsenic
156. Barium
157. Beryllium
1 58 . Cadm i urn
159. Chromium (total)
221 Chromium (hexavalent)
160. Copper
161. Lead
162. Mercury
163. Nickel
164. Selenium
165. Silver
166. Tha 1 1 lum
167. Vanadium
168. Zinc
Inorqamcs other than Metals
169. Cyanide
170. Fluoride
171. Sulfide
Orqanochlorine Pesticides
172. Aldrin
173 alpha-BHC
174 beta-BHC
175. delta-BHC
CAS no. Detection status
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
309-00-2
319-84-6
319-85-7
319-86-8
NA
NA
NA
NA
NA
NA
NA
NO
D
D
NO
0
D
NA
D
D
D
0
ND
D
ND
D
D
NA
NA
NA
NA
NA
NA
NA
-------
1543g
Table 5-1 (continued)
BOAT
reference Parameter
no
Oraanochlorlne Pesticides (continued)
176. gamma-BHC
177. Chlordane
178. ODD
179. DDE
180. DDT
181. Dieldrin
182. Endosulfan I
183. Endosulfan II
184. Endnn
185. Endrin aldehyde
186. Heptachlor
187 Heptachlor epoxide
188 Isodrin
189 Kepone
190. Methoxychlor
191 Toxaphene
Phenoxvacetlc Acid Herbicides
192 2,4-Dichlorophenoxyacetic acid
193 Silvex
194. 2,4,5-T
Orqanophosohorous Insecticides
195 Disulfoton
196. Famphur
197. Methyl parathion
198 Parathion
199 Phorate
PCBs
200. Aroclor 1016
201. Aroclor 1221
202 Aroclor 1232
203 Aroclor 1242
204. Aroclor 1246
205. Aroclor 1254
206 Aroclor 1260
CAS no. Detection status
58-89-9
57-74-9
72-54-8
72-55-9
50-29-3
60-57-1
939-98-8
33213-6-5
72-20-8
7421-93-4
76-44-8
1024-57-3
465-73-6
143-50-0
72-43-5
8001-35-2
94-75-7
93-72-1
93-76-5
298-04-4
52-85-7
298-00-0
56-38-2
298-02-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
95
-------
1543g
Table 5-1 (continued)
BOAT
reference Parameter CAS no. Detection status
no.
Dioxins and Furans
207. Hexachlorodibenzo-p-dioxins
20B. Hexachlorodibenzofurans
209. Pentachlorodibenzo-p-dioxins
210. Pentachlorodibenzofurans
211 Tetrachlorodibenzo-p-dioxins
212. Tetrachlorodibenzofurans
213. 2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746-01-6
D = Detected.
NO = Not detected.
NA = Not analyzed
NA
NA
NA
NA
NA
NA
NA
-------
6. CALCULATION OF TREATMENT STANDARDS
In this section, the performance level of the best technology for
treatment of K106 waste is calculated. For nonwastewater, this
calculation is based on the treatment data presented in Table 3-3 for
retorting. For wastewater, this calculation is based on the treatment
data presented in Tables 3-4 through 3-6 for a treatment system
consisting of sulfide precipitation followed by filtration. In
Section 5, mercury was selected as the regulated constituent for both
nonwastewater and wastewater forms of K106.
6.1 Nonwastewater
As discussed in Sections 4 and 5, retorting represents BOAT for
treatment of mercury in K106 nonwastewaters. As noted earlier in
Section 3 of this document, EPA is aware of two forms of K106 as
generated; one type is K106 generated from sulfide precipitation and the
other type is K106 generated from hydrazine treatment. The mercury
present in K106 generated by hydrazine can be treated to a significantly
lower concentration than the mercury present in K106 generated by sulfide
precipitation. However, the Agency is not establishing a separate
treatability group for the K106 generated by hydrazine for the following
reasons:
1. EPA has had conversations with plant personnel that indicate when
sulfide is not used to treat mercury in wastewaters there can be
problems with complying with wastewater treatment standards for
mercury. This information suggests that the hydrazine treatment
for mercury-containing wastewaters may be discontinued.
2. Nineteen of the twenty facilities currently generating K106
generate a mercury sulfide sludge or residual. Only one facility
generates K106 from hydrazine treatment.
97
-------
Below are discussions of how the two BOAT treatment standards for
mercury were developed for K106 nonwastewaters. The first discussion
concerns the development of the standard for total mercury concentration
and the next discussion addresses the development of the standard for
mercury concentration in the TCLP leachate.
(1) Total waste concentration. EPA first examined all the
performance data for retorting of K106 to determine if any data should
not be used in the calculation of the treatment data. Based on this
examination, EPA did not include treatment data from the facility that
treated the combined K071/K106 wastes. This is because K106 represented
only a very small fraction of the waste being treated (roughly 0.5
percent). Additionally, the four treated data points that represent
treatment of K106 generated by hydrazine were not included because the
Agency believes that the hydrazine treatment process may be discontinued
and that only one facility currently generates K106 from hydrazine
treatment.
After the above analysis, EPA was left with one data point
representing total mercury concentration in the residual from retorting
of mercury sulfide ores similar to K106. (EPA has already presented its
rationale for why these wastes are similar in Section 3) The Agency has
no reason to believe that this data point does not represent a
well-designed and well-operated system.
EPA requested but did not receive accuracy correction values;
therefore, the Agency is assuming that these data were corrected for
analytical accuracy prior to being submitted to EPA. The BOAT standard
98
-------
was calculated by multiplying the total mercury concentration value by a
factor, referred to by EPA as a variability factor, that represents
variations in treatment performance, untreated waste composition, and
sampling and analysis of treated waste. EPA could not calculate the
variability factor from the performance data used to establish the
average performance value because this data consisted of only one point.
The variability factor used is 1.26; this value was determined from
the retorting data for the K071/K106 waste mixture. EPA believes that
the variability associated with treatment of the K071/K106 mixed waste
would be similar to the variability of the waste representing treatment
of K106, even though use of the actual performance concentration for this
mixed waste would not be appropriate. The method used to calculate the
variability factor is presented in Appendix A and the calculation can be
found in the K106 Administrative Record. The BOAT treatment calculation
for K106 is shown in Table 6-1.
(2) TCLP leachate standard. EPA has no data representing TCLP
leachate concentrations from residuals using retorting. EPA has one data
point (0.01 mg/1) representing the TCLP leachate concentration of mercury
in untreated K106 generated by sulfide precipitation treatment. EPA
would expect that the same level of performance to be achieved in the
residual from retorting of K106 because:
1. For the 19 of the 20 affected facilities, the retorting residual
would have been derived from treatment of the K106 generated by
sulfide precipitation. Since the total mercury concentration of
the retort residual would be significantly lower than the
untreated K106 total mercury concentration, it is reasonable to
expect that the retorting residual would leach mercury in
concentrations no greater than the untreated K106 waste.
99
-------
2. One facility generates K106 from hydrazine treatment. Even
though the residual from retorting this waste will not be in the
mercury sulfide form, EPA would expect the TCLP leachate value
to be no greater than the untreated K106 generated from sulfide
precipitation. EPA's assessment is based on the fact that the
initial mercury concentration in the hydrazine retort residual
for K106 generated from hydrazine treatment is much lower
(approximately 75 ppm) than the untreated K106 (approximately
44,000 ppm).
The BOAT treatment standard representing the TCLP leachate
concentration K106 nonwastewaters was determined by multiplying the
0.01 mg/1 mercury leachate value by a variability factor of 2.8.
Appendix A presents the method used to calculate the variability factor,
and the actual concentration can be found in the Administrative Record
for K106. The calculation of the treatment standard is shown in Table
6-1.
6.2 Wastewater
EPA collected three sets of untreated and treated K071 wastewater
data from one facility using sulfide precipitation followed by
filtration. No data were submitted by industry for the treatment of K071
wastewater. The following steps were taken to derive the BOAT treatment
standards for K106 wastewaters:
1. The Agency evaluated the data collected from the sulfide
precipitation treatment system to determine whether any of the
data represented poor design or poor operation of the treatment
system. The available data show that all three data sets
collected from the Agency testing for wastewater do not represent
poor design or poor operation.
2. Accuracy-corrected constituent concentrations were calculated for
all BOAT list constituents for wastewater. An arithmetic average
concentration level and a variability factor were determined for
the BOAT list constituent (i.e., mercury) regulated in this waste.
100
-------
3. The BOAT treatment standard for mercury was determined by
multiplying the average accuracy-corrected total concentration by
the 1.05 variability factor.
Table 6-1 summarizes the calculation of the treatment standards for
K106 wastewaters.
101
-------
1575g/p.l
Table 6-1 Calculation of Treatment Standards for K106
Constituent
Sample Sample
Set #1 Set 12
Average
corrected
Sample treated waste
Set 13 concentration
Variability
factor
Treatment
standard
Avg. x VF
Wastewater
Mercury (mg/1)
Nonwastewater3
Mercury
(Total concen-
tration) (mg/kg)
(TLCP) (mg/1)
0.0295 0.0284 0.0295 0.0288
500
0.01
500
0.01
1.05
1.25
2.8
0.030
630
0.028
a Facilities land disposing of K.106 nonwastewater must comply with both the total
concentration and the TCLP standards.
102
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APPENDIX A STATISTICAL ANALYSIS
A.I F Value Determination for ANOVA Test
As noted in Section 1, 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).
103
-------
Where the F value is less than the critical value, all treatment data
sets are homogeneous. If the F value exceeds the critical value, it is
necessary to perform a "pair wise F" test to determine if any of the sets
are homogeneous. The "pair wise F" test must be done for all of the
various combinations of data sets using the same method and equation as
the general F test.
The F value is calculated as follows:
(i) All data are natural logtransformed.
(ii) The sum of the data points for each data set is computed (T.).
(iii) The statistical parameter known as the sum of the squares
between data sets (SSB) is computed:
SSB -
where:
k = number of treatment technologies
n-j = number of data points for technology i
N = number of data points for all technologies
Ti = sum of natural logtransformed data points for each technology.
(iv) The sum of the squares within data sets (SSW) is computed:
'
k
.Z
TI
1
" k
.£ Ti
N
^ ^
ecu
oow
where:
' k
1-1
Y1 x2
>. iğJ
Jğl
k
- Z
i = l
fTi
u
x.j j = the natural logtransformed observations (j) for treatment
' technology (i).
(v) The degrees of freedom corresponding to SSB and SSW are
calculated. For SSB, the degree of freedom is given by k-1. For SSW,
the degree of freedom is given by N-k.
104
-------
(vi) Using the above parameters, the F value is calculated as
fol1ows:
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.
105
-------
Table A-l
F Distribution at the 95 Percent Confidence Level
Denominator
degrees of
freedom 1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
22
24
25
26
27
28
23
30
40
60
120
03
161 4
18 51
10 13
7 71
6.61
5.99
559
5.32
5.12
496
434
4 75
467
4 60
4 54
4 49
445
441
438
435
432
430
428
426
4 24
423
421
4 20
418
4 17
408
400
392
3.84
2
1995
1900
955
694
5.79
5.14
474
446
426
410
3.98
3.89
3.31
374
3.68
363
3.59
3.55
3.52
349
347
344
3.42
340
3.39
337
3.35
334
3.33
3.32
3.23
315
3.07
3.00
3
2157
1916
923
6=9
541
4 76
435
407
3.36
3.71
359
349
341
3.34
3:9
324
3.:o
316
313
310
307
305
303
301
2 99
293
296
295
2.93
2.92
2.34
2.75
2.63
2.60
Numeralar degrees of freedom
4567
2246
19.25
912
6.39
5.19
453
412
3.84
3.63
3.48
3.36
3.26
3.18
3.11
3.06
301
2.96
2.93
2.90
2.37
284
2.82
2.80
2.78
276
2.74
2.73
271
2.70
269
2.61
2.53
2.45
2.37
2302
19.30
9.01
6.26
5.05
439
3.97
3.69
3.48
3.33
3.20
3.11
3.03
2.96
2.90
2.85
2.81
2.77
274
2.71
2.68
2.66
2.64
2.62
260
2.59
2.57
256
2.55
2.53
2.45
2.37
2.29
2.21
234.0
19.33
8.94
6.16
4.95
4.28
3.87
3.58
3.37
3.22
3.09
3.00
2.92
2.85
2.79
2.74
2.70
2.66
2.63
2.60
2.57
2.55
2.53
2.51
2.49
2.47
2.46
2.45
2.43
2.42
2.34
2.25
2.17
2.10
236.3
19.35
8.89
6.09
488
4.21
3.79
3.50
3.29
3.14
3.01
2.91
2.83
2.76
2.71
2.66
2.61
2.58
2.54
2.51
2.49
2.46
2.44
2.42
2.40
2.39
2.37
2.36
2.35
2.33
2.25
2.17
2.09
2.01
8
2389
1937
885
6.04
482
415
3.73
344
3.23
3.07
2.95
2.85
2.77
2.70
2.64
2.59
2.55
2.51
2.48
2.4S
2.42
2.40
2.37
2.36
2.34
2.32
2.31
2.29
2.28
2.27
2.18
2.10
2.02
1 94
9
2405
1938
881
6.00
4.77
4 10
3.68
3.39
3.18
3.02
2.90
2.80
2.71
2.65
2.59
2.54
2.49
246
2.42
2.39
2.37
2.34
2.32
2.30
2.28
2.27
2.25
2.24
2.22
2.21
2.12
2.04
1 96
1 88
106
-------
1790g
Example 1
Methylene Chloride
Steam stripping
Influent Effluent
Ug/D
1550.00
1290.00
1640.00
5100.00
1-150.00
4600.00
1760.00
2400.00
4800.00
12100.00
Ug/D
10.00
10.00
10 00
12.00
10 00
10.00
10.00
10.00
10.00
10.00
Biological treatment
In(effluent) [Infeff luent)]2 Influent Effluent In(effluent)
2.30
2.30
2.30
2.48
2.30
2.30
2.30
2.30
2.30
2.30
Ug/D Ug/D
5.29 1960.00 10.00 2.30
5.29 2568.00 10.00 2.30
5.29 1817.00 10.00 2.30
6.15 1640.00 26.00 3.26
5.29 3907.00 10.00 2.30
5.29
5.29
5.29
5.29
5.29
[In(effluent)]2
5.29
5.29
5.29
10.63
5.29
bum
23.18
53.76
12.46
31.79
Sample Size.
10 10
Mean-
3C69
10.2
Standard Deviation-
3326 67 .63
Var ial)i 1 ity Factor
10 '
2.32
.06
2378
923.04
1.15
13.2
7.15
2.48
2.49
.43
ANOVA Calculations-
SSB= * rT<2
ssw =
MSB = SSB/(k-l)
MSW = SSW/(N-k)
1 = 1
T,
N
k f T,2
~
107
-------
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
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. T - 1270.21
T = 537.31 T = 155.25
SSB =
10
SSW = (53.76+31.79) -
MSB = 0.10/1 * 0.10
MSU = 0.77/13 = 0.06
0.10
1270.21
15
537.31 155.25'
+
^^^M^V .flHB^H
10 5
0.10
0.77
1.67
0.06
ANOVA Table
Degrees of
Source freedom
Between (B) 1
Withm(U) 13
SS MS F
0.10 0.10 1.67
.0.77 0.06
The critical value of the F test at the 0.05 significance level is 4.67. Since
the F value is less than the critical value, the means are not significantly
different (i.e., they are homogeneous).
Note: All calculations were rounded to two decimal places. Results may differ
depending upon the number of decimal places used in each step of the calculations.
108
-------
1790g
Example 2
Trichloroethylene
Steam stripping
Influent
Ug/1)
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
[In(effluent)]2
5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5.29
Biological treatment
Influent
Ug/D
200.00
224.00
134.00
150.00
484 . 00
163.00
182.00
Effluent
(M9/D
10.00
10.00
10.00
10.00
16.25
10.00
10.00
ln(eff luent)
2.30
2.30
2.30
2.30
2.79
2.30
2.30
[ln(ef fluent)]2
5.29
5.29
5.29
5.29
7.78
5.29
5.29
Sample Size:
10 10
Mean
2760
19.2
Standard Deviation:
3209.6 23.7
Variabi1ity Factor:
3 70
26.14
10
2.61
.71
72.92
16.59
39.52
220
120.5
10.89
2.36
1.53
2.37
.19
ANOVA Calculations:
SSB
k
n,
t "i
SSW =
MSB = SSB/(k-l)
MSU = SSW/(N-k)
109
-------
1790g
Example 2 (continued)
F * MSB/MSW
where:
k = number of treatment technologies
n = numoer of data points for technology i
N = number of data points for all technologies
T = sum of natural log transformed data points for each technology
X = the natural log transformed observations (j) for treatment technology (i)
NI = 10, N2 = 7, N = 17. k = 2. TI = 26.14. T = 16.59. T = 42.73. T2= 1825.85. T2 = 683.30,
T2 = 275.23
SSB =f683'30
U
0.25
SSU- (72.92 +39.521-
10
4.79
MSB = 0 25/1 = 0.25
MSW = 4.79/15 = 0.32
0.78
0.32
Degrees of
Source freedom
ANOVA Table
SS
MS
Between(B)
Within(W)
1
15
0.25
4.79
0.25
0.32
0.78
The critical value of the F test at the 0.05 significance level is 4.54. Since
the F value is less than the critical value, the means are not significantly
different (i.e., they are homogeneous).
Note All calculations were rounded to two decimal places. Results nay differ
depending upon the number of decimal places used in each step of the calculations.
110
-------
1790g
Example 3
Chlorobenzene
Activated sludae followed
Influent Effluent
Ug/D Ug/1)
7200.00 80.00
6500.00 70.00
6075.00 35.00
3040.00 10.00
Sum
Sample Size
4 4
Mean
5703 49
bv carbon adsorption Bioloqical
In(effluent) [ln(eff luent)]2 Influent
Ug/D
4.38 19.18 9206.00
4.25 18.06 16646.00
3.56 12.67 49775.00
2.30 5.29 14731.00
3159.00
6756.00
3040.00
14.49 55.20
4 - 7
3.62 - 14759
treatment
Effluent
Ug/D
1083.00
709.50
460.00
142.00
603.00
153.00
17.00
-
7
452.5
ln(ef fluent)
6.99
6.56
6.13
4.96
6.40
5.03
2.83
38.90
7
5.56
ln[(effluent)]2
46.86
43.03
37.58
24.60
40.96
25.30
8.01
228.34
-
Standard Deviation.
183S 4 32.24
Vanabi lity Factor-
.95
16311.86
7.00
379.04
15.79
1.42
ANOVA Calculations.
SSB =
ni
ssw =
MSB = SSB/(k-l)
MSW = SSW/(N-k)
F = MSB/MSW
Z. T,
1=1
in
-------
1790g
where,
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
X = the natural log transformed observations (j) tfor treatment technology (i)
N = 4, N - 7, N = 11. k = 2. T = 14.49. T Ğ 38.90. T Ğ 53.39, J2= 2850.49. T2 = 209.96
I2 = 1513.21
SSB
9.52
SSW . (55.20 * 228.34) _
'09.96 15131
MSB = 9.52/1 = 9.52
MSW = 14.88/9 = 1.65
F = 9.52/1.65 = 5.77
ANDVA Table
Degrees of
Source freedom
SS
MS
Between (B)
Within(W)
1
9
9.53
14.89
9.53
1.65
5.77
The critical value of the F test at the 0.05 significance level is 5.12. Since
the F value is larger than the critical value, the means are significantly
different (i.e , they are heterogeneous).
Note: All calculations were rounded to two decimal places. Results may differ depending
upon the number of decimal places used in each step of the calculations.
112
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APPENDIX B QUALITY ASSURANCE/QUALITY CONTROL
B.I Analytical Methods.
The analytical methods used for analysis of the regulated pollutants
identified in Section 5 are listed in Table B-l. SW-846 methods (EPA's
Test Methods for Evaluating Solid Waste; Physical/Chemical Methods,
SW-846, Third Edition, November 1986) are used in most cases, except for
the TCLP extraction procedure (published in 51 FR 40643, November 7,
1986, as Appendix I to Part 268 - Hazardous Waste Management System;
Land Disposal Restrictions; Final Rule.)
Specific procedures or equipment used for preparing or analyzing the
regulated pollutants when alternatives or equivalents are allowed by
SW-846 are listed in Table B-2.
B.2 Accuracy Determination.
The accuracy determination for a pollutant is based on the matrix
spike recovery values. The accuracy correction factors were determined
in accordance with the general methodology presented in Section 1. For
example, for most BOAT list metals, actual spike recovery data were
obtained for each individual TCLP sample and the lowest value was used to
calculate the accuracy corrected value. Table B-3 presents the matrix
spike recoveries and the accuracy correction factor used to correct the
concentration of mercury in the waste similar to K106 wastewaters (i.e.,
K071 mercury containing wastewaters), and in the untreated K106 TCLP
extract.
113
-------
1575g/p.2
Table B-l Analytical Methods
Analysis/Methods Method
Mercury in Liquid Waste (Manual Cold-Vapor Technique) 7470
Mercury in Solid or Semisolid Waste (Manual Cold-Vapor 7471
Technique)
TCLP 40 CFR Part
268,
Appendix I
114
-------
1967g
Table B-2 Specific Procedures or Equipment Used in Mercury Analysis
When Alternatives or Equivalents are Allowed In the SU-846 Methods
Analysis/Method Equipment
Alternatives or equipment
allowed by SW-846 method
Specific procedures
or equipment used
Mercury 7470
7471
Perkin Elmer 50A
Equipment should be operated
following instructions by
instrument manufacturer.
Equipment was operated using
procedures specified in Perkin Elmer 50A
Instructions Manual.
Cold vapor apparatus as described in
SW-846 or equivalent apparatus may
be used.
Mercury was analyzed by cold vapor
method using the apparatus as
specified in SW-846, except that there
was no scrubber.
Samples may be prepared using the water
bath method or the autoclave method.
both described in SW-846.
Samples were prepared using the water
bath method.
Reference: USEPA. 1988a. Table 6-7.
115
-------
1575g/p.l
Table B-3 Matrix Spike Recoveries Used To Correct Analytical Data for K071
Mercury Containing Wastewaters and Untreated K106 TCLP Extract
Sample Set ğ6 Sample Set *6 Duplicate Accuracy
BOAT Original amount Spike added Spike result Percent Spike added Spike result Percent correction
constituent found (ug/1) (ug/1) (ug/1) recovery3 (ug/1) (ug/1) recovery3 factor6
Mercury 1.6 4.0 5.4 95 4.0 5.5 98 1.05
NC = Not calculable.
3Percent Recovery = [(Spike Result - Original Amount)/Spike Added].
Accuracy Correction Factor = 100/Percent Recovery (using the lowest percent recovery value).
Reference: USEJPA. 1988a. Table 6-16.
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APPENDIX C STABILIZATION DATA FOR K106
The Agency collected nine sets of untreated and treated data for
treatment of K106 nonwastewater by stabilization. Stabilization tests
consisted of three sets of three tests on the same untreated waste using
three different binder materials. These data show no significant
reduction in the Teachability of mercury in the K106 waste tested.
117
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1971g
Table C-l Stabilization - EPA-Collected Data
Sample Set #1
BOAT metals
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Vanadium
Zinc
Untreated
Total
(ppm)
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
waste
TCLP
l*/D
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Treated waste
TCLP
(mg/D
<0.004
0.326
<0.003
<0.02
<0.003
<0.006
0.0096
<0.025
0.007
<0.007
<0.013
Reference: USEPA 1988b.
118
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1971g
Table C-2 Stabilization - EPA-Collected Data
Sample Set #2
BOAT metals
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Si Iver
Vanadium
Zinc
Untreated
Total
(ppm)
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
waste
TCLP
(rog/D
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Treated waste
TCLP
(rag/1)
<0.004
0.362
0.004
<0.02
<0.003
<0.0076
0.023
<0.025
<0.006
<0.007
<0.013
Reference: USEPA 1988b.
119
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1971g
Table C-3 Stabilization - EPA-Collected Data
Sample Set #3
BOAT metals
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Vanadium
Zinc
. Untreated
Total
(ppm)
1.1
74
2.3
6.3
133
50
25,900
14
131
0.46
443
waste
TCLP
(mg/D
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Treated waste
TCLP
(rag/1)
<0.004
0.355
<0.003
<0.02
0.005
<0.006
0.0093
0.027
Ğ0.006
<0.007
<0.013
Reference: USEPA 1988b.
120
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123
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