oEPA
           United States
           Environmental Protection
           Agency
           Office of
           Solid Waste
           Washington, D.C 20460
EPA/530-SW-88-0009-q
May 1988
           Solid Waste
Best
Demonstrated
Available Technology
(BOAT) Background
Document for
K022
Proposed
           Volume 18
           Non Confidential Business Information
           (CBI) Version

-------
                            DRAFT
        BEST DEMONSTRATED AVAILABLE  TECHNOLOGY (BOAT)
                 BACKGROUND DOCUMENT FOR K022
       DISTILLATION BOTTOM TARS FROM THE PRODUCTION OF
                  PHENOL/ACETONE FROM CUMENE
             U.S.  Environmental Protection Agency
                    Office of  Solid  Waste
                      401 M Street, S.W.
                   Washington,  D.C.   20460
James R. Berlow, Chief                         Jose Labiosa
Treatment Technology Section                   Project Manager
                           May 1988
                           U.S.  Environmental Protection Agency
                           *;''      -  ' ' -^.iTj- (5PL-16)
                           c.*<     .      , - -    _  _
                                             f^"t,  Room  1670

-------
                             Table of Contents
                                                                 Page
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 Promul gated BOAT Methodol ogy	     5
       1.2.1     Waste Treatabi 1 i ty Group	     7
       1.2.2     Demonstrated and Available Treatment
                Technologies	     7
                (1)   Proprietary or Patented Processes	    10
                (2)   Substantial Treatment	    10
       1.2.3     Collection of Performance Data	    11
                (1)   Identification of Facilities for
                      Site Visits	    12
                (2)   Engineering Site Visit	    14
                (3)   Sampling and Analysis Plan	    14
                (4)   Sampling Visit	    16
                (5)   Onsite Engineering Report	    17
       1.2.4     Hazardous Constituents Considered and
                Selected for Regulation	    17
                (1)   Development of BOAT List	    17
                (2)   Constituent Selection Analysis	    27
                (3)   Calculation of Standards	    29
       1.2.5     Compliance with Performance Standards	    30
       1.2.6     Identification of BOAT	    32
                (1)   Screening of Treatment Data	    32
                (2)   Comparison of Treatment Data	    33
                (3)   Quality Assurance/Quality Control	    34
       1.2.7     BOAT Treatment Standards for "Derived-from"
                and  "Mixed" Wastes	    36
                (1)   Wastes from Treatment Trains
                      Generating Multiple Residues	    36
                (2)   Mixtures and Other Derived-from
                      Residues	    37
                (3)   Residues from Managing Listed Wastes
                      or That Contain Listed Wastes	    38
       1.2.8    Transfer of Treatment Standards	    40
1.3    Variance from the BOAT Treatment Standard	    41

2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 	    46
2.1    Industry Affected and Process Description 	    46
2.2    Waste Characterization  	    50

-------
                             Table of Contents
                                (continued)
                                                                 Page

3.   APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES 	    53
3.1    Applicable Treatment Technologies 	    53
3.2    Demonstrated Treatment Technologies 	    54
       3.2.1    Fuel Substitution 	    55
                (1)   Applicability and Use of Fuel
                      Substitution 	    55
                (2)   Underlying Principles of Operation 	    58
                (3)   Description of the Fuel Substitution ...
                      Process 	    59
                (4)   Waste Characteristics Affecting
                      Performance 	    62
                (5)   Design and Operating Parameters 	    66
       3.2.2    Incineration 	    71
                (1)   Applicability and Use of Incineration ..    71
                (2)   Underlying Principles of Operation 	    72
                (3)   Description of the Incineration Process.    73
                (4)   Waste Characteristics Affecting
                      Performance 	    80
                (5)   Design and Operating Parameters 	    85
       3.2.3    Stabilization 	    90
                (1)   Applicability and Use of Stabilization  .    91
                (2)   Underlying Principles of Operation 	    91
                (3)   Description of the Stabilization Process    93
                (4)   Waste Characteristics Affecting
                      Performance 	    94
                (5)   Design and Operating Parameters 	    95
3.3    Performance Data  	    98

4.   IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
    FOR K022 WASTE  	   107

5.   SELECTION OF REGULATED CONSTITUENTS 	   Ill
5.1    Identification of BOAT List Constituents in the
       Untreated Waste  	   Ill
5.2    Elimination of Potential Regulated  Constituents Based
       on Treatabi 1 i ty  	   120
5.3    Selection of the  Regulated Constituent  	   120

6.   CALCULATION OF BOAT  TREATMENT STANDARDS  	   124

REFERENCES  	   129

APPENDIX A  	   132

-------
APPENDIX B 	   144
APPENDIX C 	   151
APPENDIX D	   173
APPENDIX E 	   176

-------
                               List  of  Tables


                                                                  Page

Table 1-1    BOAT Constituent List  	    18
Table 2-1    Facilities That Produce Phenol and Acetone from
             Cumene  - by State and EPA Region 	    47
Table 2-2    Constituent Analysis of Untreated K022 Waste 	    51
Table 2-3    BOAT Constituent Concentrations and Other Data ...    52
Table 3-1    Design Data for Use of K022 as Fuel in an
             Industrial Boiler at Plants 1 and 2 	    99
Table 3-2    Unadjusted Concentration Data for Untreated
             K022 Waste from PI ant  1 	   100
Table 3-3    Unadjusted Concentration Data for Treated Residual
             (Ash for K022) at Plant 1  	   101
Table 3-4    Unadjusted Concentration Data for Untreated
             and Treated Residual K022  Waste at Plant 2 	   103
Table 3-5    Performance Data for Raw and Stabilized F006
             Wastes Metal Concentration (ppm)  	   105
Table 4-1    F006 TCLP Data Showing Substantial Treatment
             (mg/1) 	   109
Table 5-1    Detection Status of BOAT List Constituents in
             K022 Waste from PI ants 1 and 2  	   113
Table 5-2    Concentrations of Identified Constituents in
             the Untreated Wastes and Treatment Residuals
             from PI ants 1 and 2  	   121
Table 5-3    Regulated Constituents for K022 Waste  	   123
Table 6-1    Calculation of Nonwastewater Treatment Standards
             for the Regulated Constituents Treated by Fuel
             Substitution  	   127
Table 6-2    Calculation of Treatment  Standards for the
             Regulated Constituents Treated by Stabilization  ..   128
                               List  of  Figures

 Figure  2-1    Schematic  Diagram for  Production  of Phenol  and
              Acetone  from  Cumene  	
 Figure  3-1    Liquid  Injection  Incinerator  	
 Figure  3-2    Rotary Kiln  Incinerator 	
 Figure  3-3    Fluidized  Bed Incinerator 	
 Figure  3-4    Fixed Hearth  Incinerator  	
48
75
76
78
79

-------
                             EXECUTIVE SUMMARY
                     BOAT Treatment Standards for K022
    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, the Environmental Protection Agency is
proposing best demonstrated available technology (BOAT) treatment
standards for the listed waste identified in 40 CFR Part 261.32 as K022
(distillation bottom tars from the production of phenol/acetone from
cumene).  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.
    BOAT treatment standards have been established for five organic and
two metal constituents in nonwastewater forms of K022 waste.  The
treatment standards for the organic constituents have been developed
using performance data from fuel substitution of K022 waste.  Burning of
K022 waste as a fuel results in a residual ash that contains metals.  The
treatment standards for metals have been developed by transferring
performance data from stabilization of F006 waste using cement kiln dust
as a binder.  Development of a treatment standard for sulfide  is being
reserved pending EPA's evaluation of sulfide treatment data, if available.
    The BOAT treatment standard for wastewater forms of the waste is
being proposed as "No Land Disposal" because the Agency is unaware of any

-------
wastewater residuals being generated from treatment of K022 waste.
Furthermore, no wastewaters are expected to be generated during
stabilization of the resultant ash residues.  EPA has recently learned
that some K022 wastewaters may be disposed through underground injection,
if this is the case the "No Land Disposal" standard will preclude
continued injection of untreated wastewaters unless a no migration
petition had been granted.  The Agency intends to seek clarification of
the circumstances in which K022 wastewaters are being injected
underground in order to determine whether the no land disposal standard
should be modified.  The Agency does seek comments on the circumstances
surrounding injection of K022 wastewaters and the type of wastes  being
injected.
    The following table lists the specific BOAT treatment standards for
K022 waste.  For BOAT list organics, treatment standards reflect  total
waste concentration.  The units for the total waste concentration
analyses are mg/kg  (parts per million on  a weight by weight basis) for
nonwastewaters.  For BOAT list metals in  nonwastewaters, treatment
standards reflect leachate concentration  from the TCLP.  The  units for
the TCLP leachate concentration are mg/1  (parts per million on a  weight
by volume basis).
     In  addition, a  sample of  untreated  ash  from the burning of K022 as a
fuel  substitute  was analyzed  for  isomers  of chlorinated  dibenzofurans  and
chlorinated dibenzodioxins.   A  trace  level  (parts  per  trillion)  of
tetrachlorodibenzofurans  (TCDF) was detected in this  sample.   This amount
                                     vi

-------
was determined to be below the "typical" BOAT quantification level for
these compounds.  The Agency is currently reexamining the validity of the
quantification of this analysis.  K022 wastes do not typically have any
chlorinated organics that could be the source or precursor of the TCDF.
The Agency is investigating potential mechanisms for its formation.
    Testing procedures for all sample analyses performed for the
regulated constituents are specifically identified in Appendix B of this
background document.  These standards become effective as of the proposed
date of August 8, 1988.
    EPA wishes to highlight the fact that, because of facility claims of
confidentiality, this document does not contain all of the data that EPA
used in its regulatory decision-making process, including selection of
constituents to regulate, determination of substantial treatment, and
development of BOAT treatment standards.  Under 40 CFR Part 2, Subpart B,
facilities may claim any or all of the data that are submitted to EPA as
confidential. Any determinations regarding the validity of the facility's
claim of confidential business information (CBI) will be done by EPA
according to 40 CFR Part 2, Subpart B procedures.  In the meantime, the
Agency will treat the data as CBI.  Additionally, the Agency would like
to emphasize that all the data evaluated for development of BOAT
treatment standards for K022 have been done according to the methodology
presented in Section 1 of this document.  All deletions of confidential
business information (CBI) are noted in the appropriate place in this
background document.
                                     vii

-------
1836g
                            BOAT Treatment Standards for K022
Constituent
            Nonwastewaters
Maximum for any single grab sample
                                                                            Wastewaters



Acetophenone
Phenol
Toluene
Sum of Diphenylamine and
Diphenylnitrosamine •
Sulfide
Chromium (total)
Nickel
Total waste
concentration
(ing/kg)
19
12
0.034

13
Reserved
Not Applicable
Not Applicable
TCLP leachate
concentration
(mg/1)
Not Applicable
Not Applicable
Not Applicable
"No Land
Not Applicable Disposal"
Not Applicable
3.4
0.25

-------
                              1.   INTRODUCTION
    This section of the background document presents a summary of the
legal authority pursuant to which the BOAT treatment standards were
developed, a summary of EPA's promulgated methodology for developing
BOAT, and finally a discussion of the petition process that should be
followed to request a variance from the BOAT treatment standards.
1.1      Legal Background
1.1.1    Requirements Under HSWA
    The Hazardous and Solid Waste Amendments of 1984 (HSWA), which were
enacted on November 8, 1984, and which amended the Resource Conservation
and Recovery Act of 1976 (RCRA), impose substantial new responsibilities
on those who handle hazardous waste.  In particular, the amendments
require the Agency to promulgate regulations that restrict the land
disposal of untreated hazardous wastes.  In its enactment of HSWA,
Congress stated explicitly that "reliance on land disposal should be
minimized or eliminated, and land disposal, particularly landfill and
surface impoundment, should be the least favored method for managing
hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C. 6901{b)(7)).
    One part of the amendments specifies dates on which particular groups
of untreated hazardous wastes will be prohibited from land disposal
unless  "it has been demonstrated to the Administrator, to a reasonable
degree  of certainty, that there will be no migration of hazardous
constituents from the disposal unit or injection zone for as long as the
wastes  remain hazardous" (RCRA section 3004(d)(l), (e)(l), (g)(5),
42 U.S.C. 6924 (d)(l), (e)(l), (g)(5)).

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

-------
    Alternatively, EPA can establish a treatment standard that is
applicable to more than one waste code when, in EPA's judgment, all the
waste can be treated to the same concentration.  In those instances where
a generator can demonstrate that the standard promulgated for the
generator's waste cannot be achieved, the Agency also can grant a
variance from a treatment standard by revising the treatment standard for
that particular waste through rulemaking procedures.  (A further
discussion of treatment variances is provided in Section 1.3.)
    The land disposal restrictions are effective when promulgated unless
the Administrator grants a national variance and establishes a different
date (not to exceed 2 years beyond the statutory deadline) based on "the
earliest date on which adequate alternative treatment, recovery, or
disposal capacity which protects human health and the environment will be
available" (RCRA section 3004(h)(2), 42 U.S.C. 6924 (h)(2)).
    If EPA fails to set a treatment standard by the statutory deadline
for any hazardous waste in the First Third or Second Third of the
schedule (see Section 1.1.2), the waste may not be disposed in a landfill
or surface impoundment unless the facility is in compliance with the
minimum technological requirements specified in section 3004(o) of RCRA.
In addition, prior to disposal, the generator must certify to the
Administrator that the availability of treatment capacity has been
investigated, and it has been determined that disposal in a landfill or
surface impoundment is the only practical alternative to treatment
currently available to the generator.  This restriction on the use of

-------
landfills and surface impoundments applies until EPA sets a treatment
standard for the waste or until May 8, 1990, whichever is sooner.  If the
Agency fails to set a treatment standard for any ranked hazardous waste
by May 8, 1990, the waste is automatically prohibited from land disposal
unless the waste is placed in a land disposal unit that is the subject of
a successful "no migration" demonstration (RCRA section 3004(g),
42 U.S.C. 6924(g)).  "No migration" demonstrations are based on case-
specific petitions that show there will be no migration of hazardous
constituents from the unit for as long as the waste remains hazardous.
1.1.2    Schedule for Developing Restrictions
    Under section 3004(g) of RCRA, EPA was required to establish a
schedule for developing treatment standards for all wastes that the
Agency had listed as hazardous by November 8, 1984.  Section 3004(g)
required that this schedule consider the intrinsic hazards and volumes
associated with each of these wastes.  The statute required EPA to set
treatment standards according to the following  schedule:
    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).

-------
    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 BDAT Methodology
     In a November 7, 1986, rulemaking, EPA promulgated a technology-based
approach to establishing treatment standards under section 3004(m).
Section 3004(m) also specifies that treatment standards must "minimize"
long- and short-term threats to human health and the environment arising
from land disposal of hazardous wastes.

-------
    Congress indicated in the legislative history accompanying the HSWA
that "[t]he requisite levels of [sic] methods of treatment established by
the Agency should be the best that has been demonstrated to be
achievable," noting that the intent is "to require utilization of
available technology" and not a "process which contemplates
technology-forcing standards"  (Vol.  130 Cong. Rec. S9178 (daily ed.,
July 25, 1984)).  EPA has interpreted this legislative history as
suggesting that Congress considered the requirement under 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

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

-------
other materials.  Some of these technologies clearly are applicable to
waste treatment, since the wastes are similar to raw materials processed
in industrial applications.
    For most of the waste treatability groups for which EPA will
promulgate treatment standards, EPA will identify demonstrated
technologies either through review of literature related to current waste
treatment practices or on the basis of information provided by specific
facilities currently treating the waste or similar wastes.
    In cases where the Agency does not identify any facilities treating
wastes represented by a particular waste treatability group, EPA may
transfer a finding of demonstrated treatment.  To do this, EPA will
compare the parameters affecting treatment selection for the waste
treatability group of interest to other wastes for which demonstrated
technologies already have been determined.  The parameters affecting
treatment selection and their use for this waste are described in
Section 3.2 of this document.  If the parameters affecting treatment
selection are similar, then the Agency will consider the treatment
technology also to be demonstrated for the waste of interest.  For
example, EPA considers rotary kiln incineration to be a demonstrated
technology for many waste codes containing hazardous organic
constituents, high total organic content, and high filterable solids
content, regardless of whether any facility is currently treating these
wastes.  The basis for this determination is data found in literature and
data generated by EPA confirming the use of rotary kiln incineration on
wastes having the above characteristics.
                                     8

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

-------
the best technology is unavailable, the treatment standard will  be based
on the next best treatment technology determined to be available.  To the
extent that the resulting treatment standards are less stringent, greater
concentrations of hazardous constituents in the treatment residuals could
be placed in land disposal units.
    There also may be circumstances in which EPA concludes that for a
given waste none of the demonstrated treatment technologies are
"available" for purposes of establishing the 3004(m) treatment
performance standards.  Subsequently, these wastes will be prohibited
from continued placement in or on the land unless managed in accordance
with applicable exemptions and variance provisions.  The Agency is,
however, committed to establishing new treatment standards as soon as new
or improved treatment processes become "available."
    (1)  Proprietary or patented processes.  If the demonstrated
treatment technology is a proprietary or patented process that is not
generally available, EPA will not consider the technology in its
determination of the treatment standards.  EPA will consider proprietary
or patented processes available if it determines that the treatment
method can be purchased or licensed from the proprietor or is a
commercially available treatment.  The services of the commercial
facility offering this technology often can be purchased even if the
technology itself cannot be purchased.
    (2)  Substantial treatment.  To be considered "available," a
demonstrated treatment technology must "substantially diminish the
                                     10

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

-------
of well-designed and well-operated treatment systems.  Only data from
well-designed and well-operated systems are included in determining
BOAT.  The data evaluation includes data already collected directly by
EPA and/or data provided by industry.  In those instances where
additional data are needed to supplement existing information, EPA
collects additional data through a sampling and analysis program.  The
principal elements of this data collection program are:  (1) identifi-
cation of facilities for site visits, (2) an engineering site visit,
(3) a Sampling and Analysis Plan, (4) a sampling visit, and (5) an Onsite
Engineering Report.
    (1)  Identification of facilities for site visits.  To identify
facilities that generate and/or treat the waste of concern, EPA uses a
number of information sources.  These include Stanford Research
Institute's Directory of Chemical Producers; EPA's Hazardous Waste Data
Management System  (HWDMS); the 1986 Treatment, Storage, Disposal Facility
(TSDF) National Screening Survey; and EPA's Industry Studies Data Base.
In addition, EPA contacts trade associations to inform them that the
Agency is considering visits to facilities in their  industry and to
solicit their assistance in identifying facilities for EPA to consider in
its treatment sampling program.
    After identifying facilities that treat the waste, EPA uses this
hierarchy to select sites for engineering visits: (1) generators treating
single wastes on site; (2) generators treating multiple wastes together
on site;  (3) commercial treatment, storage, and disposal facilities
                                     12

-------
(TSDFs); and (4) EPA in-house treatment.  This hierarchy is based on two
concepts:  (1)  to the extent possible, EPA should develop treatment
standards from data produced by treatment facilities handling only a
single waste, and (2) facilities that routinely treat a specific waste
have had the best opportunity to optimize design parameters.  Although
excellent treatment can occur at many facilities that are not high in
this hierarchy, EPA has adopted this approach to avoid, when possible,
ambiguities related to the mixing of wastes before and during treatment.
    When possible, the Agency will evaluate treatment technologies using
commercially operated systems.  If performance data from properly
designed and operated commercial treatment methods for a particular waste
or a waste judged to be similar are not available, EPA may use data from
research facilities operations.  Whenever research facility data are
used, EPA will  explain in the preamble and background document why such
data were used and will request comments on the use of such data.
    Although EPA's data bases provide information on treatment for
individual wastes, the data bases rarely provide data that support the
selection of one facility for sampling over another.  In cases where
several treatment sites appear to fall into the same level of the
hierarchy, EPA selects sites for visits strictly on the basis of which
facility could most expeditiously be visited and later sampled if
justified by the engineering visit.
                                     13

-------
    (2)  Engineering site visit.  Once a treatment facility has been
selected, an engineering site visit is made to confirm that a candidate
for sampling meets EPA's criteria for a well-designed facility and to
ensure that the necessary sampling points can be accessed to determine
operating parameters and treatment effectiveness.  During the visit, EPA
also confirms that the facility appears to be well operated, although the
actual operation of the treatment system during sampling is the basis for
EPA's decisions regarding proper operation of the treatment unit.  In
general, the Agency considers a well-designed facility to be one that
contains the unit operations necessary to treat the various hazardous
constituents of the waste, as well as to control other nonhazardous
materials in the waste that may affect treatment performance.
    In addition to ensuring that a system is reasonably well designed,
the engineering visit examines whether the facility has a way to measure
the operating parameters that affect performance of the treatment system
during the waste treatment period.  For example, EPA may choose not to
sample a treatment system that operates in a continuous mode, for which
an important operating parameter cannot be continuously recorded.  In
such systems, instrumentation is important in determining whether the
treatment system is operating at design values during the waste treatment
period.
    (3)  Sampling and Analysis Plan.  If after the engineering site visit
the Agency decides to sample a particular plant, the Agency will then
develop a site-specific Sampling and Analysis Plan (SAP) according to the
Generic Quality Assurance Project Plan for the Land Disposal Restriction
                                     14

-------
Program ("BOAT"), EPA/530-SW-87-011.  In brief, the SAP discusses where
the Agency plans to sample, how the samples will be taken, the frequency
of sampling, the constituents to be analyzed and the method of analysis,
operational parameters to be obtained, and specific laboratory quality
control checks on the analytical results.
    The Agency will generally produce a draft of the site-specific
Sampling and Analysis Plan within 2 to 3 weeks of the engineering visit.
The draft of the SAP is then sent to the plant for review and comment.
With few exceptions, the draft SAP should be a confirmation of data
collection activities discussed with the plant personnel during the
engineering site visit.  EPA encourages plant personnel to recommend any
modifications to the SAP that they believe will improve the quality of
the data.
    It is important to note that sampling of a plant by EPA does not mean
that the data will be used in the development of treatment standards for
BOAT.  EPA's final decision on whether to use data from a sampled plant
depends on the actual analysis of the waste being treated and on the
operating conditions at the time of sampling.  Although EPA would not
plan to sample a facility that was not ostensibly well designed and well
operated, there is no way to ensure that at the time of the sampling the
facility will not experience operating problems.  Additionally, EPA
statistically compares its test data to suitable industry-provided data,
where available, in its determination of what data to use in developing
treatment standards.  The methodology for comparing data is presented
later in this section.
                                     15

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

-------
    (5)  Onsite Engineering Report.  EPA summarizes all its data
collection activities and associated analytical results for testing at a
facility in a report referred to as the Onsite Engineering Report (OER).
This report characterizes the waste(s) treated, the treated residual
concentrations, the design and operating data, and all analytical results
including methods used and accuracy results.  This report also describes
any deviations from EPA's suggested analytical methods for hazardous
wastes (see Test Methods for Evaluating Solid Waste. SW-846, Third
Edition, November 1986).
    After the Onsite Engineering Report is completed, the report is
submitted to the plant for review.  This review provides the plant with a
final opportunity to claim any information contained in the report as
confidential.  Following the review and incorporation of comments, as
appropriate, the report is made available to the public with the
exception of any material claimed  as confidential by the plant.
1.2.4  Hazardous Constituents Considered and Selected for Regulation
     (1)  Development of 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.
                                     17

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

222.
1.
2.
3.
4.
5.
6.
223.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224.
225.
226.
30.
227.
31.
214.
32.
Parameter
Volatiles
Acetone
Acetonitri "le
Acrolein
Acrylonitri le
Benzene
Bromodichloromethane
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-Oibromo-3-chloropropane
1,2-Dibromoethane
Dibromomethane
Trans-1 ,4-Dichloro-2-butene
Dichlorodif luoromethane
1,1-Dichloroethane
1,2-Dichloroethane
1 , 1-Dichloroethy lene
Trans-1, 2-Dichloroethene
1,2-Dichloropropane
Trans-1, 3-Dichloropropene
cis-1 ,3-Dichloropropene
1.4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
CAS no.

67-64-1
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110-75-8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-95-3
110-57-6
75-71-8
75-34-3
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
Volati les (continued)
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl met hacry late
Methacrylonitrile
Methylene chloride
2-Nitropropane
Pyridine
1,1,1 , 2-Tetrachloroethane
1,1,2 , 2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1 , 1 , 1-Trichloroethane
1,1,2-Trich loroethane
Trichloroethene
Trlchloromonof luoromethane
1 ,2,3-Trichloropropane
l,l,2-Tnchloro-l,2,2-trif1uoro-
ethane
Vinyl chloride
1,2-Xylene
1.3-Xylene
1,4-Xylene
Semivolati les
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Ani line
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene
CAS no.

78-83-1
67-56-1
78-93-3
108-10-1
80-62-6
126-98-7
75-09-2
79-46-9
110-86-1
630-20-6
79-34-6
127-18-4
108-88-3
75-25-2
71-55-6
79-00-5
79-01-6
75-69-4
96-18-4
76-13-1

75-01-4
97-47-6
108-38-3
106-44-5

208-96-8
83-32-9
96-86-2
53-96-3
92-67-1
62-53-3
120-12-7
140-57-8
56-55-3
98-87-3
108-98-5

50-32-8
                                  19

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

63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
232.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
Parameter
Semivolati les (continued)
Benzo(b)f luoranthene
Benzo(ghi)perylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)methane
Bis(2-chloroethy1)ether
Bis(2-chloroisopropy1)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Buty 1-4,6-dinitrophenol
p-Chloroani 1 me
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
D ibenz( a, h) anthracene
Dibenzo(a,e)pyrene
Oibenzo(a, i jpyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2,6-Oichlorophenol
Diethyl phthalate
3,3'-Dimethoxybenzidine
p-D imethy lami noazobenzene
3,3'-Dimethylbenzidine
•2,4-Dimethylphenol
Dimethyl phthalate
Oi-n-butyl phthalate
1,4-Dinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
CAS no.

205-99-2
191-24-2
207-08-9
106-51-4
111-91-1
111-44-4
39638-32-9
117-81-7
101-55-3
85-68-7
88-85-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
542-76-7
218-01-9
95-48-7
106-44-5
108-94-1
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
106-46-7
91-94-1
120-83-2
87-65-0
84-66-2
119-90-4
60-11-7
119-93-7
105-67-9
131-11-3
84-74-2
100-25-4
534-52-1
51-28-5
                                  20

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

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

36.
121.
122.
123.
124.
125.
126.
127.
128.
129.
130.
131.
132.
133.
134.
135.
136.
137.
138.
Parameter
Semivolati les (continued)
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylmtrosamine
Dipheny lamine
D i pheny 1 n 1 1 rosami ne
1,2-Diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Indeno( 1 , 2 , 3-cd)pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4,4'-Methylenebis
(2-chloroaniline)
Methyl methanesulfonate
Naphthalene
1 , 4-Naphthoqu i none
1-Naphthylamine
2-Naphthylamine
p-Nitroani 1 ine
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylannne
N-Nitrosodiethy lamine
N-Nitrosodimethylamine
N-Nitrosomethy lethy lam ine
N-Nitrosomorpholine
N-Nitrosopiperidme
n-Nitrosopyrrol idine
5-Nitro-o-toluidine
Pentachlorobenzene
Pentachloroethane
Pentachloronitrobenzene
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
Semivolati les (continued)
Pentachlorophenol
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pr on amide
Pyrene
Resorcinol
Safrole
1 ,2, 4, 5-Tetrach lorobenzene
2,3,4, 6-Tetrachloropheno 1
1 , 2, 4-Trich lorobenzene
2 ,4,5-Tnchlorophenol
2, 4, 6-Trich loropheno 1
Tris(2,3-dibromopropyl)
phosphate
Metals
Antimony
Arsenic
Barium
Beryl Hum
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thall lum
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
Orqanochlonne pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chlordane
000
DDE
DDT
Dieldrin
Endosulfan 1
Endosulfan 11
Endrin
Endrm aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxyacetic acid
Silvex
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-dioxms
210.           Pentachlorodibenzofurans
211.           Tetrachlorodibenzo-p-dioxins
212.           Tetrachlorodibenzofurans
213.           2,3,7,8-Tetrachlorodibenzo-p-dioxin      1746-01-6
                                   24

-------
    The initial BOAT constituent list was published in EPA's Generic
Quality Assurance Project Plan, March 1987 (EPA/530-SW-87-011).
Additional constituents will be added to the BOAT constituent list as
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 list.

    4.   Available analytical procedures are not appropriate for a
         complex waste matrix.  Some compounds, such as auramine, can be
         analyzed as a pure constituent.  However, in the presence of
         other constituents, the recommended analytical method does not
         positively identify the constituent.  The use of 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 Teachable; accordingly, EPA is also using the TCLP as a measure of
performance.  It is important to note that for wastes for which treatment
standards are based on a metal recovery process, the facility has to
comply with both the total constituent concentration and the TCLP prior
to land disposal.
                                     31

-------
    In cases where treatment standards for metals are not based on

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

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

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

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

1.2.6    Identification of BOAT

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

Agency determines which of the treatment technologies represent treatment

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

from each of the demonstrated and available technologies according to the

following criteria:

    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

-------
    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

-------
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
    (!)  Wastes from treatment trains generating multiple residues.  In a
number of instances, the proposed BOAT consists of a series of
operations, each of which generates a waste residue.  For example, the
proposed BOAT for a certain waste code is based on solvent extraction,
steam stripping, and activated carbon adsorption.  Each of these
treatment steps generates a waste requiring treatment—a
solvent-containing stream from solvent extraction, a stripper overhead,
and spent activated carbon.  Treatment of these wastes may generate
further residues; for instance, spent activated carbon (if not
regenerated) could be incinerated,  generating an ash and possibly a
scrubber water waste.  Ultimately,  additional wastes are generated that
may require land disposal.  With respect to these wastes,  the Agency
wishes to emphasize the following points:
    1.   All of the residues from treating the original listed wastes are
         likewise considered to be the listed waste by virtue of the
         derived-from rule contained in 40 CFR Part 261.3(c)(2).  (This
         point is discussed more fully in (2) below.)  Consequently, all
         of the wastes generated in the course of treatment would be
         prohibited from land disposal unless they satisfy the treatment
         standard or meet one of the exceptions to the prohibition.
    2.   The Agency's proposed treatment standards generally contain a
         concentration level for wastewaters and a concentration level
         for nonwastewaters.  The treatment standards apply to all of the
         wastes generated in treating the original prohibited waste.
         Thus, all solids generated from treating these wastes would have
                                    36

-------
         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)(1)) or the mixture rule

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

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

prohibition for  the  particular listed waste consequently applies to this

type of waste.

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

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

possible exception  of contaminated  soil and debris for which the Agency

is currently  investigating whether  it  is  appropriate to establish  a

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

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

-------
from managing California List wastes likewise are subject to the
California List prohibitions when the residues themselves exhibit a
characteristic of hazardous waste.  This determination stems directly
from the derived-from rule in 40 CFR Part 261.3(c)(2) or, in some cases,
from the fact that the waste is mixed with or otherwise contains the
listed waste.  The underlying principle stated in all of these provisions
is that listed wastes remain listed until delisted.
    The Agency's historic practice in processing delisting petitions 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

-------
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

-------
    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

-------
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

-------
 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

-------
   11.   A description of the sample handling and preparation techniques,
         including techniques used for extraction, containerization, and
         preservation of the samples.
   12.   A description of analytical procedures used, including QA/QC
         methods.
    After receiving a petition for a variance, the Administrator may
request any additional information or waste samples that may be required
to evaluate and process the petition.  Additionally, all petitioners must
certify that the information provided to the Agency is accurate under
40 CFR Part 268.4(b).
    In determining whether a variance will be granted, the Agency will
first look at the design and operation of the treatment system being
used.  If EPA determines that the technology and operation are consistent
with BOAT, the Agency will evaluate the waste to determine if the waste
matrix and/or physical parameters are such that the BOAT treatment
standards reflect treatment of this waste.  Essentially, this latter
analysis will concern the parameters affecting treatment selection and
waste characteristics affecting performance parameters.
    In cases where BOAT is based on more than one technology, the
petitioner will need to demonstrate that the treatment standard cannot be
met using any of the technologies, or that none of the technologies are
appropriate for treatment of the waste.  After the Agency has made a
determination on the petition, the Agency's findings will be published in
the Federal Register, followed by a 30-day period for public comment.
                                     44

-------
After review of the public comments, EPA will publish its final
determination in the Federal Register as an amendment to the treatment
standards in 40 CFR Part 268, Subpart D.
                                     45

-------
             2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
    The previous section presented the generic methodology for developing
BOAT standards.  The purpose of this section is to provide a complete
characterization of the K022 listed waste by describing the industry that
generates the waste, the process generating the waste, and the data
characterizing the waste.  According to 40 CFR Part 261.32 (hazardous
wastes from specific sources), the waste identified as K022 is generated
by production of phenol and acetone using the cumene process and is
listed as follows:
    K022 - Distillation bottom tars from the production of phenol/acetone
           from cumene.
2.1      Industry Affected and Process Description
    Eight facilities in the United States are known to produce phenol and
acetone from cumene.  The facilities are located in the eastern, central,
and southern States.  Table 2-1 lists these facilities and their
locations.
    The cumene process consists of the following basic steps:
(1) oxidation  of  cumene to a  concentrated cumene hydroperoxide;
(2) cleavage of the hydroperoxide to phenol and acetone along with  a
variety of other  products  (e.g, cumylphenols,  acetophenone, dimethyl
phenyl carbinol,  and alpha methyl styrene); (3) neutralization of the
cleaved products  with  sodium  hydroxide or other suitable  base or with
ion-exchange resins; and  (4)  separation  of  the phenol  and acetone using  a
series of distillation  columns.   A  flow  diagram for the cumene production
process  is presented in  Figure  2-1.
                                     46

-------
1836g
           Table 2-1  Facilities That  Produce Phenol  and Acetone
                     from Cumene~by State and EPA Region
State
EPA Region
   Facility name and location
111.
Ind.
Kans.
La.
Ohio
Pa.
Tex.
Tex.
    VII
    VI
    III
    VI
    VI
BTL Specialty Resins Corp.
Blue Island, Illinois

General Electric Company
Plastics Business Operations
Mount Vernon, Indiana

Texaco, Inc.
Texaco Chemical Company, subsidiary
El Dorado, Kansas

Georgia Gulf Corporation
Plaquemine, Louisiana

Aristech Chemical Corporation
Haver-hill, Ohio

Allied Signal, Inc.
Allied Corp., Chemical Sector
Frankford, Pennsylvania

Dow Chemical U.S.A.
Oyster Creek, Texas

Shell Oil Company
Shell Chemical Company, division
Deer Park, Texas
Reference:  SRI 1987.
                                      47

-------
      CUMENE
                                         RECOVERED
                                           CUMENE
CO
      NlCO,
      •ODIUM
      STEARATE
            HYDROPEROXIDATION
                REACTOR
              AIR
                                                                    ACETONE
                                                                                      WATER
                                   CUMENE
                                  DISTILLATION
DILUTE
NlOH
1

CLEAVAOE
REACTOR/
SEPARATOR;
NEUTRALKER/
SEPARATOR
                                                                    ACETONE
                                                                   DISTILLATION
                              WATER
                              WASH
                              TOWER
                                OR
                             DEIOWJZER
                  LIGHT ENDS
                  TO  ACETONE
                  PURIFICATION
                                                                                                                                       ACETOPHENONE
  CUMENE
DISTILLATION
  PHENOL
DISTILLATION/
PURIFICATION
ACETOPHENOL
  COLUMN
                                                                                                                                                 KOM
                                                                                                                                                WASTE
                                                                                 WASTE
                                                                                 WATER
                                                             PHENOL
                       FIGURE  2-1   SCHEMATIC DIAGRAM FOR  PRODUCTION OF PHENOL AND  ACETONE FROM  CUMENE

-------
    Cumene hydroperoxide is the first reaction product when cumene is
oxidized with air at 130°C in an aqueous sodium carbonate medium.
The reaction mix is circulated to a vacuum column where untreated cumene
is separated from the mix.  The cumene is recycled to the reactor and any
alpha methyl styrene contained in the recovered cumene is separated by
distillation.  The recovered alpha methyl styrene can undergo further
processing, be sold, or be incinerated.  The cumene hydroperoxide mixture
from the bottoms products of the vacuum column is reacted with 10 to
25 percent sulfuric acid at about 60°C and co-mixed with an inert
solvent (such as benzene) to extract organic material from the aqueous
acid.  After settling, the acid phase is separated out and recycled to
the process.  The organic phase is neutralized with sodium hydroxide (or
another suitable base) or with ion-exchange resins.  The resultant
aqueous waste stream, which contains sodium sulfate, sodium phenate,
phenol, acetone, and sodium stearate, is separated and sent to wastewater
treatment.  The crude, neutralized organic layer is sent to a series of
distillation columns where acetone, cumene, phenol, acetophenone, and the
solvent are recovered.  The first column separates a crude acetone
product overhead that is further purified by distillation.  The bottoms
from the acetone distillation column are passed through a water scrubber
to remove residual acetone and inorganic salts.  The bottoms are then
passed through a series of columns where the lower boiling hydrocarbons,
solvents, cumene, and alpha methyl styrene are removed and are then
recovered, recycled, or disposed of.  The crude phenol is refined in
                                     49

-------
the next distillation column.  The purified phenol  is removed overhead
and the bottoms may be further distilled to recover acetophenone.   The
still bottoms remaining at the completion of distillation are the waste
stream K022.
2.2      Waste Characterization
    This section includes all waste characterization data available to
the Agency for K022 waste.  The approximate percent concentrations of the
major constituents composing K022 waste are listed in Table 2-2.  The
percent concentration in the waste was determined from engineering
judgment based on analytical results and literature data.  The ranges of
BOAT constituents present in the waste and all other available parameters
affecting treatment selection data are presented in Table 2-3.  The data
show a waste with high concentrations of organic constituents
(approximately 82 to 93 percent as indicated by total organic carbon
levels), low concentrations of moisture, and low ash content.  Individual
BOAT constituent concentrations include approximately 0.1 to 50 percent
acetophenone, 0.1 to 1.0 percent phenol, and less than 0.1 percent other
BOAT list constituents.
                                     50

-------
1836g

         Table 2-2   Constituent Analysis of Untreated K022 Waste
                                         Range of concentration
Constituent                                   data (wt %)
Acetophenone                                        0.1-50
Phenol                                              0.1-10
Other BOAT constituents                            <0.1
Tars                                                1-50
Total organic carbon3                             82-93
a Includes the carbon from the acetophenone, phenol,  tars, alpha methyl
  styrene, cumyl phenol, etc.
                                       51

-------
1837g
                Table 2-3  BOAT Constituent Concentrations and Other Data
BOAT                                                       Untreated waste
ref.                                                 •     concentration (mg/kg)
no.             BOAT list constituent                Plant 1                Plant 2
                This table contains RCRA Confidential Business Information
                                              52

-------
            3.  APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
    This section describes the applicable treatment technologies,
demonstrated treatment technologies, and performance data for the
treatment of K022 waste.  Since the waste characterization data in
Section 2 reveal untreated K022 wastes containing significant BOAT list
organic concentrations and low ash content, the technologies considered
to be applicable are those that destroy the various organic compounds in
wastes.
3.1      Applicable Treatment Technologies
    The Agency has identified fuel substitution and incineration as being
applicable for BOAT list organics in K022 waste.  Fuel substitution and
incineration technologies are designed to destroy the toxic organics
present in the waste fuel.  Use of these technologies results in a
residual ash that may contain BOAT list metals, the applicable technology
for which is stabilization.  Stabilization is designed to reduce the
Teachability of BOAT metals in the treated residual.  Note that both fuel
substitution and incineration may result in a residual scrubber water.
However, the Agency is unaware of any wastewater residuals being
generated during treatment of K022 waste.  Thus, no applicable
technologies have been identified for K022 wastewaters.
    The selection of the treatment technologies applicable for treating
the BOAT constituents present in K022 waste is based on data obtained
from field testing, data submitted by industry, and current literature
sources.
                                     53

-------
3.2      Demonstrated Treatment Technologies
    The technologies demonstrated for the BOAT list organics in this
waste or in wastes with similar parameters affecting treatment selection
(i.e., high organic content, low water content, and low ash content) are
fuel substitution and incineration, including liquid injection
incineration, rotary kiln incineration, and fluidized bed incineration.
    EPA believes fuel substitution is a demonstrated treatment technology
for untreated K022 waste because fuel substitution is being used
commercially on a full-scale basis to treat this waste.  The Agency knows
of six generators using fuel substitution for treatment of K022 wastes.
Performance data collected by EPA for fuel substitution of K022 waste in
an industrial boiler are discussed in Section 3.3.  A detailed discussion
of fuel substitution treatment technology is presented in Section 3.2.1.
    EPA is not aware of any generators or TSD facilities currently using
incineration for treatment of K022 waste.  While performance data are not
available for incineration, this technology has been demonstrated on
wastes with similar waste characteristics affecting performance.  A
discussion of incineration treatment technologies is presented in
Section 3.2.2.
    EPA also is not aware of any generator or TSD facility currently
using stabilization for treatment of the residuals obtained from
treatment of K022 wastes.  However, stabilization has been demonstrated
for BOAT list metals in kiln ash residues and other nonwastewater wastes,
e.g., F006 waste and ash from incineration of K048 and K051 wastes.  The
                                     54

-------
parameters affecting treatment selection in such wastes are similar to
those of K022 ash residues.  Thus, the Agency believes that stabilization
is, for the purposes of the BOAT program, demonstrated for K022 inorganic
nonwastewaters.  A discussion of stabilization is presented in
Section 3.2.3.
3.2.1    Fuel Substitution
    Fuel substitution involves using hazardous waste as a fuel in
industrial furnaces or in boilers for generation of steam.  The hazardous
waste may be blended with other nonhazardous wastes (e.g., municipal
sludge) and/or fossil fuels.
    (1)  Applicability and use of fuel substitution.  Fuel substitution
has been used with industrial waste solvents, refinery wastes, synthetic
fibers/petrochemical wastes, and waste oils.  It can also be used when
combusting other waste types produced during the manufacturing of
Pharmaceuticals, pulp and paper, and pesticides.  These wastes can be
handled in a solid, liquid, or gaseous form.
    The most common types of units in which waste fuels are burned are
industrial furnaces and industrial boilers.  Industrial furnaces include
a diverse variety of industrial processes that produce heat and/or
products by burning fuels.  They include blast furnaces, smelters, and
coke ovens.  Industrial boilers are units wherein fuel is used to produce
steam for process and plant use.  Industrial boilers typically use coal,
oil, or gas as the primary fuel source.
                                     55

-------
    There are a number of parameters that affect the selection of fuel
substitution.  These are:
    •  Halogen content of the waste;
    •  Inorganic solids content (ash content) of the waste,
       particularly heavy metals;
    •  Heating value of the waste;
    •  Viscosity of the waste (for liquids);
    •  Filterable solids concentration (for liquids); and
    •  Sulfur content.
    If halogenated organics are burned, halogenated acids and free
halogen are among the products of combustion.  These released corrosive
gases may require subsequent treatment prior to venting to the
atmosphere.  Also, halogens and halogenated acids formed during
combustion are likely to severely corrode boiler tubes and other process
equipment.  For this reason, halogenated wastes are blended into fuels
only at very low concentrations to minimize such problems.  High chlorine
content can also lead to the incidental production  (at very low
concentrations) of other hazardous compounds such as PCBs
(polychlorinated biphenyls), PCDDs  (chlorinated dibenzo-p-dioxins), PCDFs
(chlorinated dibenzofurans), and  chlorinated phenols.
    High  inorganic solids  content (i.e., ash content) of wastes may cause
two problems:   (1) scaling in the boiler and (2) particulate  air
emissions.   Scaling  results  from  deposition  of  inorganic solids on the
walls of  the  boiler.   Particulate emissions  are produced by
                                     56

-------
noncombustible inorganic constituents that flow out of the boiler with
the gaseous combustion products.  Because of these problems, wastes with
significant concentrations of inorganic materials are usually not handled
in boilers unless they have an air pollution control system.
    Industrial furnaces vary in their tolerance to inorganic
constituents.  Heavy metal concentrations, found in both halogenated and
nonhalogenated wastes used as fuel, can cause environmental concern
because they may be emitted in the gaseous emissions from the combustion
process, in the ash residues, or in any produced solids.  The
partitioning of the heavy metals to these residual streams primarily
depends on the volatility of the metal, waste matrix, and furnace design.
    The heating value of the waste must be sufficiently high (either
alone or in combination with other fuels) to maintain combustion
temperatures consistent with efficient waste destruction and operation of
the boiler or furnace.  For many applications, only supplemental fuels
having minimum heating values of 4,400 to 5,600 kcal/kg (8,000 to
10,000 Btu/lb) are considered to be feasible.  Below this value, the
unblended fuel would not be likely to maintain a stable flame, and its
combustion would release insufficient energy to provide needed steam
generation potential in the boiler or the necessary heat for an
industrial furnace.  Some wastes with heating values of less than 4,400
kcal/kg (8,000 Btu/lb) can be used if sufficient auxiliary fuel is
employed to support combustion or if special designs are incorporated
into the combustion device.  Occasionally, for wastes with heating values
                                     57

-------
higher than virgin fuels, blending with auxiliary fuel  may be required to
prevent overheating or overcharging the combustion device.
    In combustion devices designed to burn liquid fuels, the viscosity of
liquid waste must be low enough that it can be atomized in the combustion
chamber.  If viscosity is too high, heating of storage tanks may be
required prior to combustion.  For atomization of liquids, a viscosity of
165 centistokes (750 Saybolt Seconds Universal (SSU)) or less is
typically required.
    If filterable material suspended in the liquid fuel prevents or
hinders pumping or atomization, it will be unacceptable.
    Sulfur content in the waste may prevent burning of the waste because
of the potential atmospheric emissions of sulfur oxides.  For instance,
there are proposed Federal sulfur oxide emission regulations for certain
new source industrial boilers (51 FR 22385).  Air pollution control
devices are available to remove sulfur oxides from the stack gases.
    (2)  Underlying principles of operation.  For a boiler and most
industrial furnaces there are two distinct principles of operation.
Initially, energy in the form of heat is transferred to the waste to
achieve volatilization of the various waste constituents.  For liquids,
volatilization energy may also be supplied by using pressurized
atomization.  The energy used to pressurize the liquid waste allows the
atomized waste to break  into smaller particles, thus enhancing its rate
of volatilization.  The  volatilized constituents then require additional
                                     58

-------
energy to destabilize the chemical bonds and allow the constituents to
react with oxygen to form carbon dioxide and water vapor.  The energy
needed to destabilize the chemical bonds is referred to as the energy of
activation.
    (3)  Description of the fuel substitution process.  As stated
previously, there are a number of industrial applications that can use
fuel substitution.  Therefore, there is no one process description that
will fit all of these applications.  However, the following section
provides a general description of industrial kilns (one form of
industrial furnace) and industrial boilers.
         (a)  Kilns.  Combustible wastes have the potential to be used as
fuel in kilns and, for waste liquids, are often used with oil to co-fire
kilns.  Coal-fired kilns are capable of handling some solid wastes.  In
the case of cement kilns, there are usually no residuals requiring land
disposal, since any ash formed becomes part of the product or is removed
by particulate collection systems and recycled back to the kiln.  The
only residuals may be low levels of unburned gases that escape with the
combustion products.  If this is the case, air pollution control devices
may be required.
    Three types of kilns are particularly applicable: cement kilns, lime
kilns, and lightweight aggregate kilns.
         (i)  Cement kilns.  The cement kiln is a rotary furnace that is
a refractory-lined steel shell used to calcine a mixture of calcium,
silicon, aluminum, iron, and magnesium-containing minerals.  The kiln is
                                     59

-------
normally fired by coal or oil.  Liquid and solid combustible wastes may
then serve as auxiliary fuel.  Temperatures within the kiln are typically
between 1,380 and 1,540°C (2,500 to 2,800°F).  To date, only
liquid hazardous wastes have been burned in cement kilns.
    Most cement kilns have a dry particulate collection device (i.e.,
either an electrostatic precipitator or a baghouse) with the collected
fly ash recycled back to the kiln.  Buildup of metals or other
noncombustibles is prevented through their incorporation in the product
cement.  Many types of cement require a source of chloride so that most
halogenated liquid hazardous wastes currently can be burned in cement
kilns.  Available information shows that scrubbers are not used.
         (ii)  Lime kilns.  Quick-lime (CaO) is manufactured in a
calcination process using limestone (CaCO ) or dolomite  (CaCO  and
MgCO ).  These raw materials are also heated in a refractory-lined
rotary kiln, typically to temperatures of 980 to 1,260°C (1,800 to
2,300°F).  Lime kilns are less likely to burn hazardous wastes than
are cement kilns because product lime is often added to potable water
systems.  Only one lime kiln currently burns hazardous waste in the U.S.
That particular facility sells its product lime for use as flux or as
refractory in blast furnaces.
    As with cement kilns, any collected fly ash is recycled back to the
lime kiln, resulting  in no residual streams from the kiln.  Available
information shows that scrubbers are not used.
                                     60

-------
       (iii)  Lightweight aggregate kilns.  Lightweight aggregate kilns
heat clay to produce an expanded lightweight inorganic material used in
Portland cement formulations and other applications.  The kiln has a
normal temperature range of 1,100 to 1,150°C (2,000 to 2,100°F).
Lightweight aggregate kilns are less amenable to combustion of hazardous
wastes as fuels than the other kilns described above because of the
kilns' lack of material to adsorb halogens.  As a result, burning of
halogenated organics in these kilns would likely require afterburners to
ensure complete destruction of the halogenated organics and scrubbers to
control acid gas production.  Such controls would produce a wastewater
residual stream subject to treatment standards.
         (b)  Industrial boilers.  A boiler is a closed vessel in which
water is transformed into steam by the application of heat.  Normally,
heat  is supplied by the combustion of pulverized coal, fuel oil, or gas.
These fuels are fired into a combustion chamber with nozzles and burners
that  provide mixing with air.  Liquid wastes, and granulated solid wastes
in the case of grate-fired boilers, can be burned as auxiliary fuel in a
boiler.  Few grate-fired boilers burn hazardous wastes, however.  For
liquid-fired boilers, residuals requiring land disposal are only
generated when the boiler is shut down and cleaned.  This is generally
done  once or twice per year.  Other residuals from liquid-fired boilers
would be the gas emission stream, which would consist of any products of
incomplete combustion, along with the normal combustion products.  For
                                     61

-------
example, chlorinated wastes would produce acid gases.  If this is the
case, air pollution control devices may be required.  For solid-fired
boilers, an ash normally is generated.  This ash may contain residual
amounts of organics from the blended waste/fuels as well as
noncombustible materials.  Land disposal of this ash would require
compliance with applicable BOAT treatment standards.
     (4)  Waste characteristics affecting performance.  For cement kilns,
lime kilns, and lightweight aggregate kilns burning nonhalogenated wastes
(i.e., no scrubber is needed to control acid gases), no residual waste
streams would be produced.  Any noncombustible material in the waste
would leave the kiln in the product stream.  As a result, in transferring
standards EPA would not examine waste characteristics affecting
performance, but rather would determine the applicability of fuel
substitution.  That is, EPA would investigate the parameters affecting
treatment selection.  For  kilns these parameters (as mentioned
previously) are Btu content, percent filterable solids, halogenated
organics content, viscosity, and sulfur content.
     Lightweight aggregate  kilns burning halogenated organics and boilers
burning wastes containing  any noncombustibles will  produce residual
streams subject to treatment standards.   In determining whether fuel
substitution is likely to  achieve the same  level of performance on an
untreated waste as on a previously treated  waste, EPA will examine:
(1)  relative volatility of the waste constituents,  (2)  the heat transfer
characteristics  (for solids), and  (3) the  activation energy for
combustion.
                                     62

-------
         (a)  Relative volatility.  The term relative volatility (a)
refers to the ease with which a substance present in a solid or liquid
waste will  vaporize from that waste upon application of heat from an
external source.  Hence, it bears a relationship to the equilibrium vapor
pressure of the substance.
    EPA recognizes that the relative volatilities cannot be measured or
calculated directly for the types of wastes generally treated in an
industrial  boiler or furnace.  The Agency believes that the best measure
of relative volatility is the boiling point of the various hazardous
constituents, and therefore will use this parameter in assessing
volatility of the organic constituents.
         (b)  Heat transfer characteristics.  Consistent with the
underlying principles of combustion in aggregate kilns or boilers, a
major factor with regard to whether a particular constituent will
volatilize is the transfer of heat through the waste.  In the case of
industrial  boilers burning solid fuels, heat is transferred through the
waste by three mechanisms:  radiation, convection, and conduction.  For a
given boiler it can be assumed that the type of waste will have a minimal
impact on the heat transferred from radiation.  With regard to
convection, EPA believes that the range of wastes treated would exhibit
similar properties with regard to the amount of heat transferred by
convection.  Therefore, EPA will not evaluate radiation convection heat
transfer properties of wastes in determining similar treatability.  For
solids, the third heat transfer mechanism, conductivity, is the one
principally operative or most likely to change between wastes.
                                     63

-------
    Using thermal conductivity measurements as part of a treatability
comparison for two different wastes through a given boiler or furnace is
most meaningful when applied to wastes that are homogeneous.  As wastes
exhibit greater degrees of nonhomogeneity, then thermal conductivity
becomes less accurate in predicting treatability because the measurement
essentially reflects heat flow through regions hav-ing the greatest
conductivity (i.e., the path of least resistance and not heat flow
through all parts of the waste).  Nevertheless, EPA has not identified a
better alternative to thermal conductivity, even for wastes that are
nonhomogeneous.
    Other parameters considered for predicting heat transfer
characteristics were Btu value, specific heat, and ash content.  These
parameters can neither better account for nonhomogeneity nor better
predict heat transferability through the waste.
          (c)  Activation energy.  Given an excess of oxygen, an organic
waste in  an industrial furnace or boiler would be expected to convert to
carbon monoxide and water provided that the activation energy is
achieved.  Activation energy is the quantity of heat (energy) needed to
destabilize molecular bonds and create reactive intermediates so that the
oxidation  (combustion) reaction will proceed to completion.  As a measure
of  activation energy, EPA is using bond dissociation energies.  In
theory, the bond dissociation energy would be  equal to the activation
energy;   in practice, however, this is not always the case.
                                     64

-------
    In some instances, bond energies will not be available and will have
to be estimated, or other energy effects (e.g., vibrational) and other
reactions will have a significant influence on activation energy.
Because of the shortcomings of bond energies in estimating activation
energy, therefore, EPA analyzed other waste characteristic parameters to
determine if these parameters would provide a better basis for
transferring treatment standards from an untested waste to a tested
waste.  These parameters included heat of combustion, heat of formation,
use of available kinetic data to predict activation energies, and general
structural class.  All of these parameters were rejected for the reasons
provided below.
    The heat of combustion measures only the difference in energy of the
products and reactants; it does not provide information on the transition
state  (i.e., the energy input needed to  initiate the reaction).  Heat of
formation is used as a predictive tool to determine whether reactions are
likely to proceed; however, data are not available for a significant
number of hazardous constituents.  Use of available kinetic data was
rejected because while these data could  be used to calculate some free
energy values  (AG), it could not be used for the wide range of
hazardous constituents.  Finally, EPA decided not to use structural
classes because the Agency believes that evaluation of bond dissociation
energies allows for a more direct comparison.
                                     65

-------
    (5)  Design and operating parameters
         (a)  Design parameters.   Cement kilns and lime kilns,  along with
aggregate kilns burning nonhalogenated wastes, produce no residual
streams.  Their design and operation is such that any wastes that are
incompletely destroyed will be contained in the product.  As a result,
the Agency will not look at design and operating values for such devices,
since treatment, per se, cannot be measured through detection of
constituents in residual streams.  In this instance, it is important
merely to ensure that the waste is appropriate for combustion in the
kilns and that the kiln is operated in a manner that will produce a
usable product.
    Specifically, cement, lime, and aggregate kilns are only demonstrated
for liquid  hazardous wastes.  Such wastes must be sufficiently free of
filterable  solids to avoid plugging the burners at the  hot end of the
kiln.  Viscosity also must be low enough to inject the  waste into the
kiln through the burners.  The sulfur content is not a  concern unless the
concentration  in the waste is sufficiently high as to exceed Federal,
State, or local  air pollution standards promulgated for industrial
boilers.
    The  design  parameters  that normally affect the operation of  an
industrial  boiler  (and  aggregate  kilns with residual streams) with
respect  to  hazardous waste treatment  are  (1)  the design temperature,
(2) the  design retention  time of  the  waste  in the combustion chamber, and
                                     66

-------
(3) turbulence in the combustion chamber.  Evaluation of these parameters
would be important in determining if an industrial boiler or industrial
furnace is adequately designed for effective treatment of hazardous
wastes.  The rationale for selection of these three parameters is given
below.
         (i)  Design temperature.  Industrial boilers are generally
designed based on their steam generation potential (Btu output).  This
factor is related to the design combustion temperature, which in turn
depends on the amount of fuel burned and its Btu value.  The fuel feed
rates and combustion temperatures of industrial boilers are generally
fixed based on the Btu values of fuels normally handled (e.g., No. 2
versus No. 6 fuel oils).  When wastes are to be blended with fossil fuels
for combustion, the blending, based on Btu values, must be such that the
resulting Btu value of the mixture is close to that of the fuel value
used in the design of the boiler.  Industrial furnaces also are designed
to operate at specific ranges of temperature in order to produce the
desired product (e.g., lightweight aggregate).  The blended waste/fuel
mixture should be capable of maintaining the design temperature range.
         (ii)  Retention time.  A sufficient retention time of combustion
products is normally necessary to ensure that the hazardous substances
being combusted (or formed during combustion) are completely oxidized.
Retention times on the order of a few seconds are generally needed at
normal operating conditions.  For industrial furnaces as well as boilers,
                                     67

-------
the retention time is a function of the size of the furnace and the fuel
feed rates.  For most boilers and furnaces the retention time usually
exceeds a few seconds.
         (iii)  Turbulence.  Boilers are designed so that fuel and air
are intimately mixed.  This helps ensure that complete combustion takes
place.  The shape of the boiler and the method of fuel and air feed
influence the turbulence required for good mixing.  Industrial furnaces
also are designed for turbulent mixing where fuel and air are mixed.
         (b)  Operating parameters.  The operating parameters that
normally affect the performance of an industrial boiler and many
industrial  furnaces with respect to treatment of hazardous wastes are (1)
air flow rate, (2) fuel feed rate, (3) steam pressure or rate of
production, and (4) temperature.  EPA believes that these four parameters
will be used to determine if an industrial boiler burning blended fuels
that contain hazardous waste constituents is properly operated.  The
rationale for selection of these four operating parameters is given
below.  Most industrial furnaces will monitor similar parameters, but
some exceptions are noted.
         (i)  Air feed rate.  An important operating parameter in boilers
and many industrial furnaces is the oxygen content in the flue gas, which
is a function of the air feed rate.  Stable combustion of a fuel
generally occurs within a specific range of air-to-fuel ratios.  An
oxygen analyzer in the combustion gases can be used to control the feed
                                     68

-------
ratio of air to fuel to assure complete thermal destruction of the waste
and efficient operation of the boiler.  When necessary, the air flow rate
can be increased or decreased to maintain proper fuel-to-oxygen ratios.
Some industrial furnaces do not completely combust fuels (e.g., coke
ovens and blast furnaces); hence, oxygen concentration in the flue gas is
a meaningless variable.
         (ii)  Fuel feed rate.  The rate at which fuel is injected into
the boiler or industrial furnace will determine the thermal output of the
system per unit of time (BTU/hr).  If steam is produced, steam pressure
monitoring will indirectly determine if the fuel feed rate is adequate.
However, various velocity and mass measurement devices can be used to
monitor fuel flow directly.
         (iii)  Steam^jijessure or rate of production.  Steam pressure in
boilers provides a direct measure of the thermal output of the system and
is directly monitored by use of in-system pressure gauges.  Increases or
decreases in steam pressure can be effected by increasing or decreasing
the fuel and air feed rates within certain operating design limits.  Most
industrial furnaces do not produce steam; instead, they produce a product
(e.g., cement, aggregate) and monitor the rate of production.
         (iv)  Temperature.  Temperatures are monitored and controlled in
industrial boilers to assure the quality and flow rate of steam.
Therefore, complex monitoring systems are frequently installed in the
combustion unit to provide a direct reading of temperature.  The
                                     69

-------
efficiency of combustion in industrial boilers is dependent on combustion
temperatures.  Temperature may be adjusted to design settings by
increasing or decreasing the air and fuel feed rates.
    Wastes should not be added to primary fuels until the boiler
temperature reaches the minimum needed for destruction of the wastes.
Temperature instrumentation and control should be designed to stop the
addition of waste in the event of process upsets.
    Monitoring and control of temperature in industrial furnaces are also
critical to the product quality, e.g., lime, cement, or aggregate kilns
that require minimum operating temperatures.  Kilns have very high
thermal inertia in the refractory and in-process product, high residence
times, and high air flow rates, so that even in the case of a momentary
stoppage of fuel flow to the kiln, organic constituents are likely to
continue to be destroyed.  The main operational control required for
wastes burned in kilns is to stop waste flow in the event of low kiln
temperature, loss of electrical power to the combustion air fan, and loss
of primary fuel flow.
         (v)  Other operating parameters.  In addition to the four
operating parameters discussed above, EPA considered and then discarded
one additional parameter -- fuel-to-waste blending ratios.  However,
while blending is done to yield a uniform Btu content fuel, blending
ratios will vary greatly depending on the Btu content of the wastes and
the fuels being used.
                                     70

-------
3.2.2    Incineration
    This section addresses the commonly used incineration technologies:
liquid injection, rotary kiln, fluidized bed, and fixed hearth.  A
discussion is provided regarding the applicability of these technologies,
their underlying principles of operation, a technology description, waste
characteristics that affect performance, and, finally, important design
and operating parameters.  As appropriate, the subsections are divided by
type of incineration unit.
    (1)  Applicability and use of incineration
         (a)  Liquid injection.  Liquid injection is applicable to wastes
that have viscosity values sufficiently low so that the waste can be
atomized in the combustion chamber.  A wide range of maximum viscosity
values have been reported in the literature, with the low being 100 SSU
and the high being 10,000 SSU.  It is important to note that viscosity is
temperature dependent; thus, while liquid injection may not be applicable
to a waste at ambient conditions, it may be applicable when the waste is
heated.  Other factors that affect the use of liquid injection are
particle size and the presence of suspended solids.  Both of these waste
parameters can cause plugging of the burner nozzle.
         (b)  Rotary kiln/fluidized bed/fixed hearth.  These incineration
technologies are applicable to a wide range of hazardous wastes.  They
can be used on wastes that contain high or low total organic content,
high or low filterable solids, various viscosity ranges, and a number of
                                     71

-------
other waste parameters.  EPA has not found these technologies to be
demonstrated on wastes that are comprised essentially of metals with low
organic concentrations.  In addition, the Agency expects that some of the
high metal content wastes may not be compatible with existing and future
air emission limits without emission controls far more extensive than
those currently practiced.
    (2)  Underlying principles of operation
         (a)  Liquid injection.  The basic operating principle of this
incineration technology is that incoming liquid wastes are first
volatilized and then additional heat is supplied to the waste to
destabilize the chemical bonds.  Once the chemical bonds are broken,
these constituents react with oxygen to form carbon dioxide and water
vapor.  The energy needed to destabilize the bonds is referred to as the
energy of activation.
         (b)  Rotary kiln and fixed hearth.  There are two distinct
principles of operation for these incineration technologies, one for each
of the chambers involved.  In the primary chamber, energy, in the form of
heat, is transferred to the waste to achieve volatilization of the
various organic waste constituents.  During this volatilization process
some of the organic constituents will oxidize to carbon dioxide and water
vapor.  In the secondary chamber, additional heat is supplied to overcome
the energy requirements needed to destabilize the chemical bonds and
allow the constituents to react with excess oxygen to form carbon dioxide
                                     72

-------
and water vapor.  The principle of operation for the secondary chamber is
similar to liquid injection.
         (c)  Fluidized bed.  The principle of operation for this
incineration technology is somewhat different than for rotary kiln and
fixed hearth incineration relative to the functions of the primary and
secondary chambers.  In fluidized bed incineration, the purpose of the
primary chamber is not only to volatilize the wastes but also to
essentially combust the waste.  Destruction of the waste organics can be
better accomplished in the primary chamber of this technology than in
rotary kiln and fixed hearth incineration because of (1) improved heat
transfer from fluidization of the waste using forced air, and (2) the
fact that the fluidization process provides sufficient oxygen and
turbulence to convert the organics to carbon dioxide and water vapor.
The secondary chamber (referred to as the freeboard) generally does not
have an afterburner;  however, additional time is provided for conversion
of the organic constituents to carbon dioxide, water vapor, and
hydrochloric acid if chlorine is present in the waste.
    (3)  Description of the incineration process
         (a)  Liquid injection.  The liquid injection system is capable
of incinerating a wide range of gases and liquids.  The combustion system
has a simple design with virtually no moving parts.  A burner or nozzle
atomizes the liquid waste and injects it into the combustion chamber
where it burns in the presence of air or oxygen.  A forced draft system
                                     73

-------
supplies the combustion chamber with air to provide oxygen for combustion
and turbulence for mixing.  The combustion chamber is usually a cylinder
lined with refractory (i.e., heat resistant) brick and can be fired
horizontally, vertically upward, or vertically downward.  Figure 3-1
illustrates a liquid injection incineration system.
         (b)  Rotary kiln.  A rotary kiln is a slowly rotating,
refractory-lined cylinder that is mounted at a slight incline from the
horizontal (see Figure 3-2).  Solid wastes enter at the high end of the
kiln, and liquid or gaseous wastes enter through atomizing nozzles in the
kiln or afterburner section.  Rotation of the kiln exposes the solids to
the heat, vaporizes them, and allows them to combust by mixing with air.
The rotation also causes the ash to move to the lower end of the kiln
where it can be removed.  Rotary kiln systems usually have a secondary
combustion chamber or afterburner following the kiln for further
combustion of the volatilized components of solid wastes.
         (c)  Fluidized bed.  A fluidized bed incinerator consists of a
column containing inert particles such as sand, which is referred to as
the bed.  Air, driven by a blower, enters the bottom of the bed to
fluidize the sand.  Air passage through the bed promotes rapid and
uniform mixing of the injected waste material within the fluidized bed.
The fluidized bed has an extremely high heat capacity (approximately
three times that of flue gas at the same temperature), thereby providing
a large heat reservoir.  The injected waste reaches the ignition
                                     74

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

-------
                                                                GAS TO
                                                             AIR  POLLUTION
                                                               CONTROL
                       AUXILIARY
                           FUEL
                                               AFTERBURNER
   SOLID
  WASTE
INFLUENT
  FEED
MECHANISM
                                                                    COMBUSTION
                                                                    GASES
                             LIQUID OR
                             GASEOUS
                              WASTE
                             INJECTION
                                                                  ASH
                                      FIGURE 3-2.
                            ROTARY KILN  INCINERATOR
                                           76

-------
temperature quickly and transfers the heat of combustion back to the
bed.  Continued bed agitation by the fluidizing air allows larger
particles to remain suspended in the combustion zone (see Figure 3-3).
         (d)  Fixed hearth incineration.  Fixed hearth incinerators, also
called controlled air or starved air incinerators, are another major
technology used for hazardous waste incineration.  Fixed hearth
incineration is a two-stage combustion process (see Figure 3-4).  Waste
is ram-fed into the first stage, or primary chamber, and burned at less
than stoichiometric conditions.  The resultant smoke and pyrolysis
products, consisting primarily of volatile hydrocarbons and carbon
monoxide, along with the normal products of combustion, pass to the
secondary chamber.  Here, additional air is injected to complete the
combustion.  This two-stage process generally yields low stack
particulate and carbon monoxide  (CO) emissions.  The primary chamber
combustion reactions and combustion gas are maintained at low levels by
the starved air conditions so that particulate entrainment and carryover
are minimized.
          (e)  Air pollution controls.   Following  incineration of
hazardous wastes, combustion gases are  generally  further treated in an
air pollution control  system.  The presence of chlorine or other halogens
in  the waste requires  a  scrubbing or absorption  step to remove hydrogen
chloride  and other  halo-acids from the  combustion  gases.  Ash in the
waste  is  not destroyed in the combustion process.  Depending on  its
                                     77

-------
  WASTE
INJECTION
                                 ASH
                              FIGURE 3-3.
                    FLUIDIZED BED INCINERATOR
                                                         GAS TO
                                                         AIR  POLLUTION
                                                         CONTROL
                                                         MAKE-UP
                                                         SAND
                                                          AIR
                                     78

-------
                                                     AIR
                                              GAS TO AIR
                                              POLLUTION
                                              CONTROL
               AIR
        WASTE
     INJECTION'
V0

  PRIMARY
COMBUSTION
 CHAMBER

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

-------
composition, ash will either exit as bottom ash, at the discharge end of
a kiln or hearth for example, or as particulate matter (fly ash)
suspended in the combustion gas stream.  Particulate emissions from most
hazardous waste combustion systems generally have particle diameters of
less than 1 micron and require high efficiency collection devices to
minimize air emissions.  In addition, scrubber systems provide an
additional buffer against accidental releases of incompletely destroyed
waste products resulting from poor combustion efficiency or combustion
upsets, such as flameouts.
     (4)  Waste characteristics affecting performance
         (a)  Liquid injection.  In determining whether liquid injection
is likely to achieve the same level of performance on an untested waste
as on a previously tested waste, the Agency will compare the dissociation
bond energies of the constituents  in the untested and tested wastes.
This parameter  is being used as  a  surrogate indicator of activation
energy, which,  as discussed  previously, destabilizes molecular bonds.   In
theory, the bond dissociation energy would be equal to the activation
energy; in  practice, however, this  is  not  always the case.  Other energy
effects  (e.g.,  vibrational,  the  formation  of  intermediates, and
interactions between different molecular bonds) may have a significant
 influence  on activation energy.
     Because of  the  shortcomings  of bond energies in estimating  activation
energy,  EPA analyzed other waste characteristic parameters to determine
                                     80

-------
if these parameters would provide a better basis for transferring
treatment standards from an untested waste to a tested waste.  These
parameters include heat of combustion, heat of formation, use of
available kinetic data to predict activation energies, and general
structural class.  All of these parameters were rejected for the reasons
provided below.
    The heat of combustion measures only the difference in energy of the
products and reactants; it does not provide information on the transition
state.  Heat of formation is used as a predictive tool to determine
whether reactions are likely to proceed; however, data are not available
for a significant number of hazardous constituents.  Use of kinetic data
was rejected because these data are limited and could not be used to
calculate free energy values (AG) for the wide range of hazardous
constituents to be addressed by this rule.  Finally, EPA decided not to
use structural classes because the Agency believes that evaluation of
bond dissociation energies allows for a more direct determination of
whether a constituent will be destabilized.
         (b)  Rotary kiln/fluidized bed/fixed hearth.  Unlike liquid
injection, these incineration technologies also generate a residual ash.
Accordingly, in determining whether these technologies are likely to
achieve the same level of performance on an untested waste as on a
previously tested waste, EPA would need to examine the waste
characteristics that affect volatilization of organics from the waste, as
                                     81

-------
well as destruction of the organics, once volatilized.  Relative to
volatilization, EPA will examine thermal conductivity of the entire waste
and the boiling point of the various constituents.  As with liquid
injection, EPA will examine bond energies in determining whether
treatment standards for scrubber water residuals can be transferred from
a tested waste to an untested waste.  Below is a discussion of how EPA
arrived at thermal conductivity and boiling point as the best method to
assess volatilization of organics from the waste; the discussion relative
to bond energies is the same for these technologies as for liquid
injection and will not be repeated here.
          (i)  Thermal conductivity.  Consistent with the underlying
principles of  incineration, a major factor with regard to whether a
particular constituent will volatilize  is the transfer of heat through
the waste.   In the case of rotary kiln,  fluidized bed, and fixed hearth
incineration,  heat is transferred through the waste by three mechanisms:
radiation, convection,  and conduction.   For a given incinerator, heat
transferred  through various wastes  by radiation is more a function of the
design and type of incinerator  than the  waste being treated.
Accordingly, the type of waste  treated  will have  a minimal impact on the
amount of heat transferred by radiation.  With regard to convection, EPA
also  believes  that the  type of  heat transfer will generally  be more a
function  of  the type and design of  incinerator than the waste  itself.
However,  EPA is examining  particle  size as  a waste characteristic that
                                     82

-------
may significantly impact the amount of heat transferred to a waste by
convection and thus impact the volatilization of the various organic
compounds.  The final type of heat transfer, conduction, is the one that
EPA believes will have the greatest impact on volatilization of organic
constituents.  To measure this characteristic, EPA will use thermal
conductivity; an explanation of this parameter, as well as how it can be
measured, is provided below.
    Heat flow by conduction is proportional to the temperature gradient
across the material.  The proportionality constant is a property of the
material and is referred to as the thermal conductivity.  (Note:  The
analytical method that EPA has identified for measurement of thermal
conductivity is named "Guarded, Comparative, Longitudinal Heat Flow
Technique"; it is described in Appendix D.)  In theory, thermal
conductivity would always provide a good indication of whether a
constituent in an untested waste would be treated to the same extent in
the primary incinerator chamber as the same constituent in a previously
tested waste.
    In practice, thermal conductivity has some limitations in assessing
the transferability of treatment standards; however, EPA has not
identified a parameter that can provide a better indication of heat
transfer characteristics of a waste.  Below is a discussion of both the
limitations associated with thermal conductivity, as well as the other
parameters considered.
                                     83

-------
    Thermal conductivity measurements, as part of a treatability
comparison for two different wastes through a single incinerator, are
most meaningful when applied to wastes that are homogeneous (i.e., major
constituents are essentially the same).  As wastes exhibit greater
degrees of nonhomogeneity (e.g., significant concentration of metals in
soil), then thermal conductivity becomes less accurate in predicting
treatability, because the measurement essentially reflects heat flow
through regions having the greatest conductivity (i.e., the path of least
resistance) and not heat flow through all parts of the waste.
    Btu value, specific heat, and ash content were also considered for
predicting heat transfer characteristics.  These parameters can no better
account for nonhomogeneity than thermal conductivity;  additionally, they
are not directly related to heat transfer characteristics.  Therefore,
these  parameters do not provide a better indication of heat transfer that
will  occur in  any  specific waste.
          (ii)  Boiling point.   Once heat is  transferred to a constituent
within a  waste, then  removal  of this  constituent from  the waste will
depend on its  volatility.  As  a surrogate of volatility,  EPA is  using  the
boiling point  of the  constituent.  Compounds with  lower boiling  points
have  higher vapor  pressures  and therefore would  be  more likely  to
vaporize.  The Agency recognizes that this  parameter does  not take  into
consideration  the  impact  of  other  compounds  in  the  waste  on  the boiling
point of  a constituent in a  mixture;  however,  the  Agency  is  not aware  of
a better  measure  of volatility that  can easily be  determined.
                                     84

-------
    (5)  Design and operating parameters
         (a)  Liquid injection.  For a liquid injection unit,  EPA's
analysis of whether the unit is well designed will focus on (1) the
likelihood that sufficient energy is provided to the waste to  overcome
the activation level for breaking molecular bonds, and (2) whether
sufficient oxygen is present to convert the waste constituents to carbon
dioxide and water vapor.  The specific design parameters that  the Agency
will evaluate to assess whether these conditions are met are temperature,
excess oxygen, and residence time.  Below is a discussion of why EPA
believes these parameters to be important, as well as a discussion of how
these parameters will be monitored during operation.
    It is important to point out that, relative to the development of
land disposal restriction standards, EPA is only concerned with these
design parameters when a quench water or scrubber water residual is
generated from treatment of a particular waste.  If treatment  of a
particular waste in a liquid injection unit would not generate a
wastewater stream, then the Agency, for purposes of land disposal
treatment standards, would only be concerned with the waste
characteristics that affect selection of the unit, not the
above-mentioned design parameters.
         (i)  Temperature.  Temperature is important in that it provides
an indirect measure of the energy available (i.e., Btus/hr) to overcome
the activation energy of waste constituents.  As the design temperature
increases, the more likely it is that the molecular bonds will be
destabilized and the reaction completed.
                                     85

-------
    The temperature is normally controlled automatically through the use
of instrumentation that senses the temperature and automatically adjusts
the amount of fuel and/or waste being fed.  The temperature signal
transmitted to the controller can be simultaneously transmitted to a
recording device, referred to as a strip chart, and thereby continuously
recorded.  To fully assess the operation of the unit, it is important to
know not only the exact location in the incinerator where the temperature
is being monitored but also the location of the design temperature.
         (ii)  Excess oxygen.  It is important that the incinerator
contain oxygen in excess of the stoichiometric amount necessary to
convert the organic compounds to carbon dioxide and water vapor.  If
insufficient oxygen is present, then destabilized waste constituents
could recombine to the same or other BOAT list organic compounds and
potentially cause the scrubber water to contain higher concentrations of
BOAT list constituents than would be the  case  for a well-operated unit.
    In  practice,  the  amount of oxygen fed to the  incinerator is
controlled by continuous sampling and analysis of the stack gas.   If the
amount  of oxygen  drops below  the design value, then the analyzer
transmits a  signal to the  valve controlling the air supply and  thereby
increases the flow of oxygen  to the  afterburner.  The analyzer
simultaneously transmits a signal to a  recording  device so that the
amount  of excess  oxygen  can  be continuously recorded.  Again,  as with
temperature,  it  is  important  to  know the  location  from which the
combustion gas is being  sampled.
                                     86

-------
         (iii)  Carbon monoxide.  Carbon monoxide is an important
operating parameter because it provides an indication of the extent to
which the waste organic constituents are being converted to carbon
dioxide and water vapor.  As the carbon monoxide level increases, it
indicates that greater amounts of organic waste constituents are
unreacted or partially reacted.  Increased carbon monoxide levels can
result from insufficient excess oxygen, insufficient turbulence in the
combustion zone, or insufficient residence time.
         (iv)  Waste feed rate.  The waste feed rate is important to
monitor because it is correlated to the residence time.  The residence
time is associated with a specific Btu energy value of the feed and a
specific volume of combustion gas generated.  Prior to incineration, the
Btu value of the waste is determined through the use of a laboratory
device known as a bomb calorimeter.  The volume of combustion gas
generated from the waste to be incinerated is determined from an analysis
referred to as an ultimate analysis.  This analysis determines the amount
of elemental constituents present, which include carbon, hydrogen,
sulfur, oxygen, nitrogen, and halogens.  Using this analysis plus the
total amount of air added, the volume of combustion gas can be
calculated.  Having determined both the Btu content and the expected
combustion gas volume, the feed rate can be fixed at the desired
residence time.  Continuous monitoring of the feed rate will determine
whether the unit was operated at a rate corresponding to the designed
residence time.
                                     87

-------
         (b)  Rotary kiln.  For this incineration,  EPA will  examine both
the primary and secondary chamber in evaluating the design of a
particular incinerator.  Relative to the primary chamber, EPA's
assessment of design will focus on whether it is likely that sufficient
energy will be provided to the waste in order to volatilize the waste
constituents.  For the secondary chamber,
analogous to the sole liquid injection incineration chamber, EPA will
examine the same parameters discussed previously under liquid injection
incineration.  These parameters will not be discussed again here.
    The particular design parameters to be evaluated for the primary
chamber are kiln temperature, residence time, and revolutions per
minute.  Below is a discussion of why EPA believes these parameters to be
important, as well as a discussion of how these parameters will be
monitored during operation.
         (i)  Temperature.  The primary chamber temperature is important,
since  it provides an indirect measure of the energy input (i.e., Btus/hr)
that is available for heating the waste.  The higher the temperature is
designed to be in a given kiln, the more likely it is that the
constituents will volatilize.  As discussed earlier under "Liquid
Injection," temperature  should be continuously monitored and recorded.
Additionally, it  is important to know the location of the temperature
sensing device in the  kiln.

-------
         (ii)  Residence time.  This parameter is important in that it
affects whether sufficient heat is transferred to a particular
constituent in order for volatilization to occur.  As the time that the
waste is in the kiln is increased, a greater quantity of heat is
transferred to the hazardous waste constituents.   The residence time will
be a function of the specific configuration of the rotary kiln, including
the length and diameter of the kiln, the waste feed rate, and the rate of
rotation.
         (iii)  Revolutions per minute (RPM).  This parameter provides an
indication of the turbulence that occurs in the primary chamber of a
rotary kiln.  As the turbulence increases, the quantity of heat
transferred to the waste would also be expected to increase.  As the RPM
value increases, however, the residence time decreases, resulting in a
reduction of the quantity of heat transferred to the waste.  This
parameter needs to be carefully evaluated because it provides a balance
between turbulence and residence time.
         (c)  Fluidized bed.  As discussed previously in the section on
"Underlying Principles of Operation," the primary chamber accounts for
almost all of the conversion of organic wastes to carbon dioxide, water
vapor, and acid gas if halogens are present.  The secondary chamber will
generally provide additional residence time for thermal oxidation of the
waste constituents.  Relative to the primary chamber, the parameters that
the Agency will examine in assessing the effectiveness of the design are
temperature, residence time, and bed pressure differential.  The first
                                     89

-------
two were discussed under rotary kiln incineration and will  not be
discussed here.  The last, bed pressure differential, is important in
that it provides an indication of the amount of turbulence and therefore
indirectly the amount of heat supplied to the waste.  In general, as the
pressure drop increases, both the turbulence and heat supplied increase.
The pressure drop through the bed should be continuously monitored and
recorded to ensure that the designed value is achieved.
         (d)  Fixed Hearth.  The design considerations for this
incineration unit are similar to a rotary kiln with the exception that
rate of rotation (i.e., RPMs) is not an applicable design parameter.  For
the primary chamber of this unit, the parameters that the Agency will
examine in assessing how well the unit is designed are the same as those
discussed under rotary kiln; for the secondary chamber (i.e.,
afterburner), the design and operating parameters of concern are the same
as discussed under "Liquid Injection."
3.2.3    Stabilization
    Stabilization refers to a broad class of treatment processes that
chemically reduce the mobility of hazardous constituents in a waste.
Solidification and fixation are other terms that are sometimes used
synonymously for stabilization or to describe specific variations within
the broader class of stabilization.  Related technologies are
encapsulation and thermoplastic binding; however, EPA considers these
                                     90

-------
technologies to be distinct from stabilization in that the operational
principles are significantly different.
    (1)  Applicability and use of stabilization.   Stabilization is used
when a waste contains metals that will leach from the waste when it is
contacted by water.  In general, this technology is applicable to wastes
containing BOAT list metals having a high filterable solids content, low
TOC content, and low oil and grease content.  This technology is commonly
used to treat residuals generated from treatment of electroplating
wastewaters.  For some wastes, an alternative to stabilization is metal
recovery.
    (2)  Underlying principles of operation.  The basic principle
underlying this technology is that stabilizing agents and other chemicals
are added to a waste in order to minimize the amount of metal that
leaches.  The reduced Teachability is accomplished by the formation of a
lattice structure and/or chemical bonds that bind the metals to the solid
matrix and thereby limit the amount of metal constituents that can be
leached when water or a mild acid solution comes into contact with the
waste material.
    There are two principal stabilization processes used; these are
cement-based and lime-based processes.  A brief discussion of each is
provided below.  In both cement-based and lime/pozzolan-based techniques,
the stabilizing process can be modified through the use of additives,
such as silicates, that control curing rates or enhance the properties of
the solid material.
                                     91

-------
         (a)  Portland cement-based process.  Portland cement is a
mixture of powdered oxides of calcium, silica, aluminum, and iron,
produced by kiln burning of materials rich in calcium and silica at high
temperatures (i.e., 1400 to 1500°C).  When the anhydrous cement
powder is mixed with water, hydration occurs and the cement begins to
set.  The chemistry involved is complex because many different reactions
occur depending on the composition of the cement mixture.
    As the cement begins to set, a colloidal gel of indefinite
composition and structure is formed.  Over a period of time, the gel
swells and forms a matrix composed of interlacing, thin, densely-packed
silicate fibrils.  Constituents present in the waste slurry (e.g.,
hydroxides and carbonates of various heavy metals) are incorporated into
the interstices of the cement matrix.  The high pH of the cement mixture
tends to keep metals in the form of insoluble hydroxide and carbonate
salts.  It has been hypothesized that metal ions may also be incorporated
into the crystal structure of the cement matrix, but this hypothesis has
not been verified.
         (b)  Lime/pozzolan-based process.  Pozzolan, which contains
finely divided, noncrystalline silica (e.g., fly ash or components of
cement kiln dust), is a material that is not cementitious in itself, but
becomes so upon the addition of lime.  Metals in the waste are converted
to  silicates or hydroxides, which inhibit leaching.  Additives, again,
can be used to reduce permeability and thereby  further decrease leaching
potential.
                                     92

-------
    (3)  Description of the stabilization process.  In most stabilization
processes, the waste, stabilizing agent, and other additives, if used,
are mixed and then pumped to a curing vessel or area and allowed to
cure.  The actual operation (equipment requirements and process
sequencing) will depend on several factors such as the nature of the
waste, the quantity of the waste, the location of the waste in relation
to the disposal site, the particular stabilization formulation to be
used, and the curing rate.  After curing, the solid formed is recovered
from the processing equipment and shipped for final disposal.
     In instances where waste contained  in a lagoon is to be treated,  the
material should be first transferred to mixing vessels where stabilizing
agents are added.  The mixed material is then fed to a curing pad or
vessel.  After curing, the solid  formed is removed for disposal.
Equipment commonly used also includes facilities  to store waste and
chemical additives.  Pumps can be used  to transfer liquid or light sludge
wastes to the mixing pits and pumpable  uncured wastes to the curing
site.  Stabilized wastes are then removed to a final disposal site.
     Commercial concrete mixing and handling equipment generally can be
used with wastes.  Weighing conveyors,  metering cement hoppers, and
mixers similar to concrete batching  plants  have been adapted in some
operations.  Where extremely dangerous  materials  are being treated,
remote control and  in-drum mixing equipment, such as that used with
nuclear  waste, can be employed.
                                     93

-------
    (4)  Waste characteristics affecting performance.  In determining
whether stabilization is likely to achieve the same level of performance
on an untested waste as on a previously tested waste, the Agency will
focus on the characteristics that inhibit the formation of either the
chemical bonds or the lattice structure.  The four characteristics EPA
has identified as affecting treatment performance are the presence of (1)
fine particulates, (2) oil and grease,  (3) organic compounds, and (4)
certain inorganic compounds.
         (a)  Fine particulates.  For both cement-based and
lime/pozzolan-based processes, the literature states that very fine solid
materials (i.e., those that pass through a No. 200 mesh sieve, 74 urn
particle size) can weaken the bonding between waste particles and cement
by coating the particles.  This coating can inhibit chemical bond
formation and decreases the resistance  of the material to leaching.
         (b)  Oil and grease.  The presence of oil and grease in both
cement-based and lime/pozzolan-based systems results in the coating of
waste particles and the weakening of the bonding between the particle and
the stabilizing agent.  This coating can inhibit chemical bond formation
and thereby decrease the resistance of  the material to leaching.
         (c)  Organic compounds.  The presence of organic compounds in
the waste interferes with the chemical  reactions and bond formations
which inhibit curing of the stabilized  material.  This results in a
stabilized waste having decreased resistance to leaching.
                                     94

-------
         (d)  Sulfate and chlorides.  The presence of certain inorganic
compounds will interfere with the chemical reactions, weakening bond
strength and prolonging setting and curing time.  Sulfate and chloride
compounds may reduce the dimensional stability of the cured matrix,
thereby increasing Teachability potential.
    Accordingly, EPA will examine these constituents when making
decisions regarding transfer of treatment standards based on
stabilization.
    (5)  Design and operating parameters.  In designing a stabilization
system, the principal parameters that are important to optimize so that
the amount of Teachable metal constituents is minimized are (1) selection
of stabilizing agents and other additives, (2) ratio of waste to
stabilizing agents and other additives, (3) degree of mixing, and (4)
curing conditions.
         (a)  Selection of stabilizing agents and other additives.  The
stabilizing agent and additives used will determine the chemistry and
structure of the stabilized material and therefore will affect the
Teachability of the solid material.  Stabilizing agents and additives
must be carefully selected based on the chemical and physical
characteristics of the waste to be stabilized.  For example, the amount
of sulfates in a waste must be considered when a choice is being made
between a lime/pozzolan and a Portland cement-based system.
                                     95

-------
    In order to select the type of stabilizing agents and additives, the
waste should be tested in the laboratory with a variety of materials to
determine the best combination.
         (b)  Amount of stabilizing agents and additives.  The amount of
stabilizing agents and additives is a critical parameter since sufficient
stabilizing materials are necessary in the mixture to properly bind the
waste constituents of concern, thereby making them less susceptible to
leaching.  The appropriate weight ratios of waste to stabilizing agent
and other additives are established empirically by setting up a series of
laboratory tests that allow separate leachate testing of different mix
ratios.  The ratio of water to stabilizing agent (including water in
waste) will also impact the strength and leaching characteristics of the
stabilized material.  Too much water will cause low strength; too little
will make mixing difficult and, more important, may not allow the
chemical reactions that bind the hazardous constituents to be fully
completed.
         (c)  Mixing.  The conditions of mixing include the type and
duration of mixing.  Mixing is necessary to ensure homogeneous
distribution of the waste and the stabilizing agents.  Both undermixing
and overmixing are undesirable.  The first condition results in a
nonhomogeneous mixture; therefore, areas will exist within the waste
where waste particles are neither chemically  bonded to the stabilizing
agent nor physically held within the lattice  structure.  Overmixing, on
                                     96

-------
the other hand, may inhibit gel formation and ion adsorption in some
stabilization systems.  As with the relative amounts of waste,
stabilizing agent, and additives within the system, optimal mixing
conditions generally are determined through laboratory tests.  During
treatment it is important to monitor the degree (i.e., type and duration)
of mixing to ensure that it reflects design conditions.
         (d)  Curing conditions.  The curing conditions include the
duration of curing and the ambient curing conditions (temperature and
humidity).  The duration of curing is a critical parameter to ensure that
the waste particles have had sufficient time in which to form stable
chemical bonds and/or lattice  structures.  The time necessary for
complete stabilization depends upon the waste type and the stabilization
used.  The performance of the  stabilized waste (i.e., the levels of
constituents in the leachate)  will be highly dependent upon whether
complete stabilization has occurred.  Higher temperatures and lower
humidity increase the rate of  curing by increasing the rate of
evaporation of water from the  solidification mixtures.  If temperatures
are too high, however, the evaporation rate can be excessive and result
in too little water being available for completion of the stabilization
reaction.  The duration of the curing process should also be determined
during the design stage and typically will be between 7 and 28 days.
                                     97

-------
3.3      Performance Data
    To evaluate the performance of fuel substitution for BOAT list
organic constituents, EPA collected data from three facilities.  BOAT
list metals are concentrated in the residual resulting from treatment by
fuel substitution.
    From Plant 1, the Agency collected six sets of untreated and treated
waste samples to characterize treatment of K022 using fuel substitution
in an industrial boiler.  Treatment of K022 resulted in one residual--
the ash.  The ash was collected from the boiler when it was taken out of
service for cleaning and maintenance.  The ash was generated during the
24-month period in which the boiler was in service.  The Agency believes
that the ash is representative of the residual obtained from burning the
K022 wastes and other substances that were used as fuels based on
information obtained from Plant 1 personnel.  Table 3-1 presents the
available design data.  Table 3-2 contains data for the untreated K022
waste, while Table 3-3 provides the data for the treatment residual-- the
ash.  Based on the fact that BOAT list organics are not detected in the
residual ash, EPA believes that the system was well designed and well
operated relative to treatment of this waste.  Sufficient QA/QC
information is available to adjust the analytical results for the
volatile and semivolatile organic constituents in the treated residual
data.  These data are presented in Appendix B.
    From Plant 2, the Agency collected one sample of the untreated waste
and six samples of the residual ash.  The sample for the untreated waste
is assumed to be representative of the waste burned during the 18-month
                                     98

-------
1837g
             Table 3-1  Design Data for Use of  K022  As  Fuel  in
                       an Industrial Boiler at  Plants  1 and  2
Parameter                   Design value             Operating  value
         This  table  contains RCRA Confidential Business Information
                                       99

-------
1836g

                     Table 3-2  Unadjusted Concentration Data for Untreated K022  Waste  from Plant  1
BDAT       BOAT                        	Untreated waste concentration	
ref.       list                        Sample 1      Sample 2     Sample 3       Sample 4     Sample 5       Sample 6
no.        constituent                 (mg/kg)       (mg/kg)      (mg/kg)        (mg/kg)       (mg/kg)         (mg/kg)
                               This table contains RCRA Confidential Business Information
                                                             100

-------
1837g
                Table 3-3  Unadjusted Concentration Data for Treated Residual (Ash for K022)  at  Plant  1
BOAT
ref.
no.
43
53
142
106/219

171
174
181
183
155
156
157
158
159
160
161
163
166
167
168
212









BOAT
list
constituent
Toluene
Acetophenone
Phenol
Oiphenylamine/
Diphenylnitrosamine
Sulfide
B-BHC
Dieldrin
B-Endosulfan
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Thallium
Vanadium
Zinc
Tet rach lorod i benzofuran
TCLP Extract
Barium
Cadmium
Chromium
Copper
Lead
Nickel
Silver
Zinc
Unad.iusted waste
Sample 1
(mg/kg)
<0.012
<3.8
<1.9
<2.65

200
<0.4
<0.4
<0.4
<15
15
0.1
<2.5
60
38
21
47
<15
<5
25
0.00035
(mq/1)
0.08
<0.025
0.2
NA
<0.15
NA
<0.025
NA
Sample 2
(mg/kg)
<0.012
<7.6
<3.8
<5.3

NA
NA
NA
NA
138
95
0.2
4.1
289
2110
1840
223
1930
<5
1740
NA
(mq/1)
0.066
<0.025
1.3
NA
<0.15
NA
<0.025
NA
Sample 3
(mg/kg)
<0.012
<3.8
<1.9
<2.63

NA
NA
NA
NA
<15
28
<0.1
<2.5
21
<5
<15
98
<15
13
<2.5
NA
(mo/ 11
0.27
<0.025
<0.1
NA
2.9
NA
<0.025
NA
concentration
Sample 4a
(mg/kg)
<0.012
<3.8
<1.9
<2.63

NA
NA
NA
NA
17
35
0.1
<2.5
40
12
<15
161
<15
28
<2.5
NA
(ma/1)
0.70
0.074
<0.1
NA
132
NA
<0.025
NA

Sample 5
(mg/kg)
<0.012
<3.7
<1.9
<2.6

NA
NA
NA
NA
<15
48
<0.1
<2.5
26
<5
<15
115
<15
18
<2.5
NA
(ma/1)
0.29
<0.025
0.38
NA
<0.15
NA
0.029
NA

Sample 6
(mg/kg)
<0.012
<3.8
<1.9
<2.63

NA
NA
NA
NA
45
27
0.1
2.5
344
215
105
268
181
<5
209
NA
(ma/1)
0.076
<0.025
<0.1
NA
<0.15
NA
<0.025
NA
NA - Not analyzed.
aSample 4 TCLP extract was reanalyzed.
                          The results  are  as  follows:
Arsenic
Barium
Cadmium
<0.15  mg/1
 0.66  mg/1
<0.025 mg/1
                               Chromium  -  1.7   mg/1
                               Lead      - <0.15  mg/1
                               Silver    - <0.025 mg/1
Source:  USEPA 1988a.
                                                           101

-------
operation of the boiler.  The ash was generated during the 18-month
period in which the boiler was in operation and resulted solely from the
combustion of K022 waste.  The ash was collected from the boiler when the
unit was shut down for cleaning and maintenance.  Design data are
presented in Table 3-1.  Operating data are not available for the
industrial boiler used at this facility.  Based on the analytical data
available for the residual ash, the boiler appeared to have been
well-operated, since the organic constituents present in the raw waste
were reduced to nondetectable levels.  Table 3-4 presents the data
available for the untreated waste and the residual ash.  Sufficient QA/QC
data are not available at this time to adjust the analytical results for
both the volatile and semivolatile organic constituents.
    From Plant 3, the Agency collected one data set for the boiler feed
containing a mixture of  K022 and other wastes, and one data set for the
residual ash.  (A separate sample of the K022 waste was not collected.)
The data obtained for this facility indicated that nondetectable levels
for the BOAT organic constituents were achieved.  The data, however, were
not being used to assess the treatment of K022 for three reasons.  First,
a  sample of the K022 waste itself was not obtained; therefore, from these
data  it is not possible  to identify which constituents present in the
boiler feed were contributed by  the K022 waste and which were contributed
by the other wastes also burned  in the boiler at  the  same time.  Second,
poor  recovery  values were obtained for the acid fractions of the matrix
spike and matrix spike  duplicate samples, e.g., the recovery value for
                                     102

-------
1836g
                  Table 3-4   Unadjusted Concentration Data for Untreated and Treated Residual K022
                                                  Waste at Plant 2
Concentration
BOAT
ref.
no.

43
38
53
142
156
159
160
163
167
168
186
171




BOAT
list
constituent
Total Composition
Toluene
Methylene chloride
Acetophenone
Phenol
Barium
Chromium
Copper
Nickel
Vanadium
Zinc
Heptachlor
Sulflde
TCLP Results3'
Arsenic
Barium
Chromium
Untreated
waste Sample
(mg/kg) 1

<0.012
<0.008
<1.254
<0.627
18
639
46
278
<5.0
78
<0.4
320

<0.15
0.09
43
Treated waste (mq/ka)
Sample
2

<0.06
<0.04
NA
NA
21
813
52
279
<5.0
70
NA
NA

<0.15
0.03
45
Sample
3

<0.012
<0.008
NA
NA
33
1460
50
309
<5.0
56
NA
NA

<0.15
0.1
66
Sample
4

<0.012
<0.008
NA
NA
24
753
42
284
8.7
22
NA
NA

<0.15
0.08
43
Sample
5

<0.012
<0.008
NA
NA
23
1050
52
392
<5.0
42
NA
NA

<0.15
0.08
49
Sample
6

<0.012
0.021
NA
NA
17
1540
55
776
<5.0
77
NA
NA

<0.15
0.14
47
aTCLP results are not available for copper, nickel,  zinc,  and vanadium.

NA - Not analyzed.

 Untreated waste  is RCRA Confidential Business Information.

Source:  USEPA 1988b.
                                                        103

-------
recovery value for phenol (a major constituent of K022 waste) in the ash
was zero.  Therefore, the analytical results could not be adjusted to
reflect recoveries.  Third, design and operating data for the boiler were
not available.  As a result, the Agency decided to withdraw these data
from further consideration.
    For treatment of F006 nonwastewaters, EPA has 56 treated and
untreated data pairs for 8 BOAT list metals using stabilization.  For the
untreated waste, EPA has total constituent and TCLP leachate data, and
for the treated waste EPA has TCLP leachate data.  These data were
submitted to EPA by industry.  The data represent a range of
electroplating industries including automotive part manufacturing,
aircraft overhauling, aerospace manufacturing, nickel plating, zinc
plating, small engine manufacturing, chromium plating, and four wastes
identified as F006 but not specifically characterized.  Table 3-5
presents the performance data for F006.  The additional data that are not
presented in this section can be found in Appendix E.
    EPA had other performance data for F006 waste obtained from EPA's
deli sting program.  These data consisted of 15 treated and untreated data
sets for cadmium, chromium, lead, and nickel.  These data are not
presented here because they represent EP toxicity results.  The BOAT
program is not using EP  test results as a measure of treatment
performance for stabilization (immobilization) technologies.  These data
can be found in the Administrative Record.
                                     104

-------
                                              Table 3-5  Performance Data for Raw and Stabilized F006 Wastes

                                                                Metal Concentrations (ppm)
O
CJ1
Mix
Source ratio3
Unknown
Unstabilized
As received
TCLP
Stabilized
TCLP 0.2
Auto part manufacture
Unstabilized
As received
TCLP
Stabi lized
TCLP 0.2
TCLP 0.5
Aircraft overhaul facility
Unstabilized
As received
TCLP
Stabilized
TCLP 0.2
TCLP 0.5
Zinc Plating
Unstabilized
As received
TCLP
Stabilized
TCLP 0.2
TCLP 1.0
Unknown
Unstabilized
As received
TCLP
Stabilized
TCLP 0.2
TCLP 0.5
Barium Cadmium


	 	
	 	

	 	


	 31.3
	 2.21

	 0.50
	 0.01


85.5 67.3
1.41 1.13

0.33 0.06
0.31 0.02


	 1.31
	 0.02

	 0.01
	 <0.01


14.3 720
0.38 23.6

0.31 3.23
0 23 0.01
Chromium Copper Lead


	 	 	
	 	 	

	 	 	


755 7030 409
0.76 368 10.7

0.40 5.4 0.40
0.39 0.25 0.36


716 	 257
0.43 	 2.26

0.08 	 0.30
0.20 	 0.41


	 1510 88.5
	 4.62 0.45

	 0.30 0.30
	 0.15 0.21


12200 160 52
25.3 1.14 0.45

0.25 0.20 0.24
0 30 0.27 0.34
Nickel


435
0.71

0.04


989
22.7

1.5
0.03


259
1.1

0.23
0.15


374
0.52

0.10
0.02


701
9.78

0.53
0 03
Si Iver


	
	

	


6.62
0.14

0.03
0.05


38.9
0.20

0.20
0.05


9.05
0.16

0.03
0.03


5.28
0.08

0.04
0 04
Zinc


1560
0.16

0.03


4020
219

36.9
0.01


631
5.41

0.05
0.03


90200
2030

32
0.01


35900
867

3.4
0.04

-------
1984g
                                                   Table 3-5  (continued)
Mix
Source ratio
Small engine manufacture
Unstabilized
As received
TCLP
Stabilized
TCLP 0.2
TCLP 0.5
Circuit board manufacture
Unstabilized
As received
TCLP
Stabi lized
TCLP 0.2
TCLP 0.5
Unknown
Unstabi 1 ized
As received
TCLP
Stabilized
TCLP 0.2
TCLP 0.5
Unknown
Unstabilized
As received
TCLP
Stabilized
TCLP 0.2
TCLP 0.5
Barium Cadmium Chromium Copper


	 7.28 3100 1220
	 0.3 38.7 31.7

	 0.02 0.21 0.21
	 0.01 0.38 0.29


5.39 42900 10600
	 0.06 360 8.69

	 0.01 3.0 0.40
	 0.01 1.21 0.42


15.3 5.81 	 17600
0.53 0.18 	 483

0.32 0.01 	 0.50
0.27 0.01 	 0.32


19.2 	 	 27400
0.28 	 	 16.9

0.19 	 	 3.18
0.08 	 	 0.46
Lead


113
3.37

0.30
0.36


156
1.0

0.30
0.38


1.69
4.22

0.31
0.37


24500
50.2

2.39
0.27
Nickel


19400
730

16.5
0.04


13000
152

0.40
0.10


23700
644

15.7
0.04


5730
16.1

1.09
0.02
Silver Zinc


4.08 27800
0.12 1200

0.03 36.3
0.06 0.03


12.5 120
0.05 0.62

0.03 0.02
0.05 0.02


8.11 15700
0.31 650

0 . 03 4 . 54
0.05 0.02


	 322
	 1.29

	 0.07
	 <0.01
aMix ratio = weight of reagent.
            waste of waste

-------
             4.   IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE
                         TECHNOLOGY FOR K022 WASTE
    In this section, EPA explains its determination of which technology
represents the "best" level of performance, as well as being demonstrated
and available.  As discussed in Section 3, the demonstrated treatment
technologies for K022 waste are fuel substitution and incineration.
    For the two technologies identified as demonstrated, the Agency has
performance data for fuel substitution only.  Accordingly, it is not
possible to perform the statistical comparison test (ANOVA) between these
technologies as discussed in Section 1 of this document.  While
performance data are not available for incineration of K022 waste, EPA
would not expect this technology to improve the destruction of BOAT list
organic constituents achieved by fuel substitution because the
concentrations of the BOAT list organics in the treated waste are at
nondetectable concentration levels.
    Demonstrated technologies are considered "available" if they (1) are
commercially available and (2) substantially diminish the toxicity of the
waste or substantially reduce the likelihood that hazardous constituents
will migrate from the waste.  In addition to meeting the criterion of
being "commercially available," fuel substitution provides "substantial"
treatment by significantly reducing the concentrations of the hazardous
organic constituents of concern to nondetectable levels.  Thus, fuel
substitution is believed to ensure adequate waste treatment by reducing
both the toxicity of the waste and the likelihood that the hazardous
                                    107

-------
constituents will migrate from the waste.  Therefore, fuel substitution
is considered "available."
    Because EPA believes that fuel substitution is "demonstrated,"
"available," and achieves the "best" performance, the technology is
deemed BOAT for K022 waste.
    For the BOAT list metals present at treatable concentrations in the
nonwastewater residual, EPA is transferring performance achieved by
stabilization of a waste judged to be similar to the K022 residual.  EPA
believes that the F006 nonwastewaters (wastewater treatment sludges from
electroplating operations) are sufficiently similar to the K022 residual
ash based on the metals content.  EPA believes that the K022 ash residual
will be easier to stabilize than F006 waste because the ash residual
contains metals in the form of oxides, which have been shown to leach
lower concentration of metals than the typical F006 metal hydroxides.
Stabilization using cement kiln dust was determined to be "best" for F006
waste because it substantially reduces the Teachability of metals  in the
waste.  To determine substantial treatment for F006 EPA examined the data
to determine if any data represented treatment by a poorly designed or
poorly operated system.  Data were deleted if the data points showed that
the binder to waste ratio was not properly designed.  Shown in Table 4-1
are the remaining data that demonstrate  substantial treatment.  These
data were then adjusted for the analytical recoveries.   (See Appendix B
for analytical recovery data).  EPA's determination of substantial
                                     108

-------
1982g
                   Table  4-1  F006 TCLP Data Showing Substantial  Treatment  (mg/1)
Manufacturing Mix
source ratio
Unknown
raw
treated 0.2
Auto part
manufacture
raw
treated 0.5
Aircraft overhaul
facility
raw
treated 0.2
Zinc plating
raw
treated 1.0
Unknown
raw
treated 0.5
Small engine
manufacture
raw
treated 0.5
Circuit board
manufacture
raw
treated 0.5
Unknown
raw
treated 0.5
Unknown
raw
treated 0.5
Cadmium Chromium Copper Lead

_



2.21 0.76 368 10.7
0.01 0.39 0.25 0.36


1.13 0.43 2.26
0.06 0.08 - 0.30

0.02 4.62 0.45
<0.01 - 0.15 0.21

23.6 25.3 1.14 0.45
0.01 0.30 0.27 0.34


0.03 38.7 31.7 3.37
0.01 0.38 0.29 0.36


0.06 360 8.69 1.0
0.01 1.21 0.42 0.38

0.18 483 4.22
0.01 - 0.32 0.37

16.9 50.2
0.46 0.27
Nickel Silver

0.71
0.04


22.7 0.14
0.03 0.05


1.1 b.20
0.23 0.20

0.52 0.16
0.02 0.03

9.78 0.08
0.03 0.04


730 0.12
0.04 0.06


152 0.05
0.10 0.05

644 0.31
0.04 0.05

16.1
0.02
Zinc

0.16
0.03


219
0.01


5.41
0.05

2030
0.01

867
0.04


1200
0.03


0.62
0.02

650
0.02

1.29
<0.01
                                                109

-------
treatment is based on the following observations for reductions in the
TCLP leachate's concentration.  Cadmium is shown to be reduced from as
much as 23.6 to 0.01 mg/1,  chromium from 360 to 1.21 mg/1,  copper from
483 to 0.32 mg/1, lead from 50.2 to 0.27 mg/1, nickel from 730 to
0.04 mg/1, silver from 0.31 to 0.03 mg/1, and zinc from 2030 to
0.012 mg/1.  The Agency believes the reduction in the range and magnitude
of these hazardous constituents to be substantial.  The technology is
considered available for K022 ash residues because it is commercially
available and substantially reduces the likelihood that hazardous metals
would leach from the waste.  Thus, stabilization is determined to be BOAT
for the BOAT list metals in K022 nonwastewaters.
                                    110

-------
                  5.   SELECTION OF REGULATED CONSTITUENTS
    As discussed in Section 1,  the Agency has developed a list of
hazardous constituents (Table 1-1) from which the constituents to be
regulated are selected.  The list is a "growing list" that does not
preclude the addition of new constituents as additional key parameters
are identified.  The list is divided into the following categories:
volatile organics, semivolatile organics, metals, inorganics,
organochlorine pesticides, phenoxyacetic acid herbicides,
organophosphorous pesticides, PCBs, and dioxins and furans.  The
constituents in each category have similar chemical properties and are
expected to behave similarly during treatment, with the exception of the
inorganics.
    This section describes the step-by-step process used to select the
constituents to be regulated.  The process involves developing a list of
potential regulated constituents and then eliminating those that would be
controlled by subsequent regulation of the remaining constituents.  Note
that the selected constituents must be present in the untreated waste and
must be treatable by the BOAT determined in Section 4.
5.1      Identification of BOAT List Constituents in the Untreated Waste
    The first step in selecting constituents to be regulated is to
identify the BOAT list constituents that are present in the waste or are
likely to be present in the waste.  A particular BOAT list constituent is
identified if it meets any of the criteria listed below.
                                    Ill

-------
    1. The constituent is detected in the untreated waste above the
       detection limit.
    2. The constituent is detected in any of the treated residuals above
       the detection limit.  (Detection limits in untreated waste are
       often high because of analytical problems.  Thus, a constituent
       detected in a treated residual but not detected in the untreated
       waste is likely to be present in the untreated waste.)
    3. The constituent is likely to be present in detectable
       concentrations in the waste based on EPA's analysis of the waste
       generating process.
    As discussed in Sections 2 and 3, the Agency has characterization
data as well as performance data from the use of K022 waste for fuel
substitution.  These data have been used to identify the K022 BOAT list
constituents.  For samples collected from Plant 1 and Plant 2, Table 5-1
indicates which constituents were analyzed and, of those, which were
detected or not detected.  (Tables C-l and C-2 in Appendix C show the
detection limits for the data from the two plants.)  EPA analyzed the
waste for 214 of the 231 BOAT list constituents.  Another 17 compounds
were not analyzed because they were not BOAT pollutants at the time of
analysis; EPA believes that these compounds are also unlikely to be
present in the waste because there is no in-process source for these
constituents.
    In the samples collected for K022 wastes from Plant 1, eight organic
and two inorganic constituents were detected in the untreated waste.  In
the treated residual, nine metals were detected.  In the samples
collected from Plant 2, five organics, one inorganic, and one metal were
detected in the untreated waste.  In the treated residual, an additional
organic and an additional four metals were detected.
                                    112

-------
1837g
           Table 5-1  Detection Status of BOAT List Constituents in  K022  Waste
                                   from Plants 1 and 2
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.
Constituent
Volatiles
Acetone
Acetonitrile
Acrolein
Acrylonitri le
Benzene
Bromodichloromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-l,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
l,2-Dibromo-3-chloropropane
1,2-Dibromoethane
Dibromomethane
trans-1. 4-Dichloro-2-butene
Dichlorodif luoromethane
1 , 1-Dichloroethane
1,2-Oichloroethane
1 , 1-Dichloroethy lene
trans-1 . 2-Dichloroethene
1 ,2-Dichloropropane
trans-1 ,3-Dichloropropene
cis-1 ,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
CAS no.

67-64-1
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110-75-8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-95-3
110-57-6
75-71-8
75-34-3
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
Detection
status for
Plant 1

NA
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
D
ND
NA
ND
NA
ND
Detection
status for
Plant 2

NA
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
NA
ND
NA
ND
NA
ND
                                                113

-------
1837g
                                  Table 5-1  (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.

Constituent
Volati les (continued)
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methacrylonitrile
Methylene chloride
2-Nitropropane
Pyridine
1,1,1, 2-Tetrachloroethane
1,1,2 , 2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Tr ichloroethane
1,1, 2-Tr ichloroethane
Trichloroethene
Tnchloromonof luoromethane
1,2,3-Trichloropropane
l.l,2-Tnchloro-l,2,2-
tnf luoroethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1,4-Xylene
Semivolatiles
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Aniline
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene

CAS no.

78-83-1
67-56-1
78-93-3
108-10-1
80-62-6
126-98-7
75-09-2
79-46-9
110-86-1
630-20-6
79-34-6
127-18-4
108-88-3
75-25-2
71-55-6
79-00-5
79-01-6
75-69-4
96-18-4

76-13-1
75-01-4
97-47-6
108-38-3
106-44-5

208-96-8
83-32-9
96-86-2
53-96-3
92-67-1
62-53-3
120-12-7
140-57-8
56-55-3
98-87-3
108-98-5

50-32-8
114
Detection
status for
Plant 1

ND
NA
ND
NA
ND
ND
ND
NA
ND
ND
ND
ND
D
ND
ND
ND
ND
ND
ND

NA
ND
NA
NA
NA

ND
ND
D
ND
ND
ND
ND
ND
ND
NA
ND

ND

Detection
status for
Plant 2

ND
NA
ND
NA
ND
ND
D
NA
ND
ND
ND
ND
D
ND
ND
ND
ND
ND
ND

NA
ND
NA
NA
NA

ND
ND
D
ND
ND
ND
ND
ND
ND
NA
ND

ND


-------
1837g
                                 Table 5-1  (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.
Constituent
Semi vo tat lies (continued)
Benzo(b)f luoranthene
Benzo(ghi )perylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)ethane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroani line
Chlorobenzilate
p-Chloro-m-cresol
• 2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitrl le
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
D ibenz( a, h) anthracene
Dibenzo(a,e)pyrene
Dibenzo(a, i)pyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Oichlorophenol
2,6-Dichlorophenol
Diethyl phthalate
3,3' -D imethoxybenz i d i ne
p-Dimethylaminoazobenzene
3,3'-Dimethylben2idine
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1.4-Dinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
CAS no.

205-99-2
191-24-2
207-08-9
106-51-4
111-91-1
111-44-4
39638-32-9
117-81-7
101-55-3
85-68-7
88-85-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
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
Detection
status for
Plant 1

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detection
status for
Plant 2

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
                                           115

-------
1837g
                                Table 5-1   (continued)
BOAT
reference
no.

102.
103.
104.
105.
106. 7219

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.
Constituent
Semivolat i les (continued)
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Oi-n-propylnitrosamine
Diphenylamine/
Diphenylmtrosamine
1 , 2-Diphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadlene
Hexachlorocyclopentadlene
Hexachloroethane
Hexachlorophene
Hexach loropropene
Indenofl ,2,3-cd)pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4,4'-Methylenebis
(2-chloroani line)
Methyl methanesulfonate
Naphthalene
1 ,4-Naphthoquinone
1-Naphthylamine
2-Naphthy lamine
p-Nitroam line
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-rt-buty lamine
N-N i trosodi ethyl ami ne
N-Nitrosodimethy lamine
N-Nitrosomethylethylamine
N-Nitrosomorpholine
N-Nitrosopiperidine
n-Nitrosopyrrolidine
5-Nitro-o-toluidine
Pentachlorobenzene
Pentach loroethane
Pentachloronitrobenzene
CAS no.

121-14-2
606-20-2
117-84-0
621-64-7
122-39-47
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
1QO-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
Detection
status for
Plant 1

NO
ND
ND
ND

D
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
Detection
status for
Plant 2

ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
                                           116

-------
1837g
                                 Table 5-1   (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.
Constituent
Semivolatiles (continued)
Pentach 1 oropheno 1
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcinol
Safrole
1,2,4, 5-Tetrachlorobenzene
2,3,4, 6-Tetrachloropheno 1
1,2,4-Trichlorobenzene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
Tr i s ( 2 , 3-d i bromopropy 1 )
phosphate
Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Inorganics
Cyanide
Fluoride
Sulfide
CAS no.

87-86-5
62-44-2
85-01-8
108-95-2
85-44-9
109-06-8
23950-58-5
129-00-0
108-46-3
94-59-7
95-94-3
58-90-2
120-82-1
95-95-4
88-06-2

126-72-7

7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-32
-
7440-50-8
7439-92-1
7439-97-6
7440-02-0
7782-49-2
7440-22-4
7440-28-0
7440-62-2
7440-66-6

57-12-5
16964-48-8
8496-25-8
Detection
status for
Plant 1

ND
NO
ND
D
NA
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
D
D
D
D
D
NA
D
D
ND
D
ND
ND
D
D
D

ND
D
D
Detection
status for
Plant 2

ND
NO
ND
D
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND

ND
ND
D
ND
ND
D
NA
D
ND
ND
D
ND
ND
ND
D
D

ND
ND
D
                                            117

-------
1837g
                                Table 5-1  (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.
Constituent
Orqanochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
Qaima-BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxychlor
Toxaphene
Phenoxvacetic acid herbicides
2,4-Dichlorophenoxyacetic acid
Silvex
2,4,5-T
Orqanoohosohorous 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
Detection
status for
Plant 1

ND
NO
D
ND
ND
ND
ND
ND
ND
D
ND
D
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
Detection
status for
Plant 2

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
D
ND
ND
ND
ND
ND

ND
ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
                                         118

-------
1837g
                                  Table 5-1   (continued)
BOAT
reference Constituent
no.


CAS no. Detection
status for
Plant 1

Detection
status for
Plant 2
               PCBs (continued)
203.
204.
205.
206.
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
53469-21-9
12672-29-6
11097-69-1
11096-82-5
NO
ND
NO
ND
ND
ND
ND
ND
207.
208.
209.
210.
211.
212.
213.
Dioxins and furans

Hexachlorodibenzo-p-dioxins
Hexachlorodi benzofurans
Pentachlorodibenzo-p-dioxins
Pentachlorod i benzofurans
Tetrachlorodi benzo-p-d ioxi ns
Tetrachlorodibenzofurans
2,3,7,8-Tetrachlorodibenzo-p-
  dioxin
                                              1746-01-6
                 ND
                 ND
                 ND
                 ND
                 ND
                 ND

                 ND
               ND
               ND
               ND
               ND
               ND
               D

               ND
ND = Not detected.
 D = Detected.
NA = Not analyzed.
                                            119

-------
5.2      Elimination of Potential Regulated Constituents Based on
         Treatabilitv
    The next step in selecting the constituents to be regulated is to
eliminate those identified constituents in the waste that are not present
in treatable quantities and therefore cannot be significantly treated by
the technologies designated as BOAT.  Table 5-2 shows the concentrations
of the identified constituents in the untreated waste and incineration
treatment residuals.  The data show that BOAT for the organics in K022
waste, fuel substitution, significantly reduced the levels of the
identified organic constituents.
    As discussed in Section 4, BOAT for organics in K022 waste produces a
nonwastewater residual that may require treatment for metals.  Analytical
results from the two plants show that barium, chromium, copper, nickel,
zinc, vanadium, beryllium, and lead may be present in the waste and may
be present in quantities that are conceivably treatable by stabilization.
5.3      Selection of the Regulated Constituent
    All the constituents listed on Table 5-2 that may be present in
treatable quantities could be regulated in K022 waste.  EPA has chosen to
regulate one volatile organic, all four semivolatile organics, and two
metals.  Two of the semivolatile constituents--diphenylamine and
diphenylnitrosamine--are regulated as the sum of these constituents
because these two compounds cannot be distinguished using EPA's standard
analytical testing procedures.  Of the three volatiles detected in the
untreated waste (toluene, ethyl benzene, and methylene chloride), the
Agency selected toluene.  Methylene chloride is present in the untreated
                                    120

-------
1837g
                    Table 5-2  Concentrations of Identified Constituents in the Untreated Wastes and
                                         Treatment  Residuals  from Plants  1  and  2
Constituent
Toluene
Ethylbenzene
Methylene chloride
Acetophenone
Phenol
Di pheny lam ine/
D i pheny 1 n i t rosam i ne
Arsenic
Barium
Beryllium
Cadmium
Chromium
Copper
Lead
Nickel
Silver
Vanad i urn
Zinc
Sulfide
B-BHC
Dieldrin
B-Endosulfan
Heptachlor
Tetrachlorod i benzof uran
Plant 1
Untreated waste Ash
(mg/kg)a (mg/kg)
<0.012
NA
<0.008
<3.7-<7.6
<1.9-<3.8

<2.6-<5.3
<15
15-95
<0.1-0.2
<2.5
21-344
<5-2110
<15-1840
47-268
<2.5
<5-28
25-1740
200
<0.4
<0.4
<0.4
<0.4
0.00035

[Ash TCLP]a
(mg/D







[NA]
[0.066-0.70]
[NA]
[<0. 025-0. 074]
[<0.1-1.3]
[NA]
[<0. 15-132]
[NA]
[<0. 025-0. 029]
[NA]
[NA]






Plant 2
Untreated waste Ash
(mg/kg)a (mg/kg)
<0.012-<0.06
NA
<0. 008-0. 04
<1.254
<0.627

<0.875
<15
17-33
<0.5
<2.5
639-1,540
42-55
<15
278-776
<2.5
<5-8.7
22-78
320
<0.4
<0.4
<0.4
<0.4
ND

[Ash TCLP]b
(mg/1)







[<0. 15-0. 48]
[0.03-0.14]
[NA]
[<0.025]
[43-66]
[NA]
[<0.15]
[NA]
[<0.025]
[NA]
[NA]






Note:  Data are not adjusted for accuracy.

aContains RCRA Confidential Business Information.

 TCLP extracts are analyzed for metals only.

ND = Not detected.
NA = Not analyzed.
                                                           121

-------
waste at lower concentrations according to the data, and the compound is
expected to be easier to treat based on its boiling point (40 to 42 C for
methylene chloride versus 111 C for toluene).  Ethyl benzene is not being
regulated because this constituent was not analyzed for the treated
residual; therefore, treatment data for this constituent are not
available.
    Of the metals, chromium and nickel are present in the ash at the
highest concentrations for most of the ash samples relative to the other
metals detected.  The Agency believes that stabilization of chromium and
nickel is necessary to reduce the Teachability of these two constituents
in the ash.  Also, the Agency believes that stabilization of these two
BOAT list metals will also reduce the Teachability of the remaining BOAT
list metals present in the ash residual.  The remaining metals in the
treatment residual will also be treated by stabilization.
    The four pesticides, B-BHC, dieldrin,  B-endosulfan, and heptachlor,
were not selected for regulation because (1) they are present at
concentrations significantly lower than the volatiles and semivolatile
organics, and (2) it is believed that they will be treated along with the
regulated constituent based on their relatively low initial
concentrations.
    The Agency has not completed its evaluation of the waste
characterization for sulfide; therefore, it is proposing to reserve
setting a standard for sulfide until this evaluaton is completed.
    Table 5-3 lists the constituents to be regulated in K022 waste.
                                    122

-------
1836g

             Table 5-3  Regulated Constituents for K022 Waste



                         BOAT Volatile Organics

                         Toluene
                                 *i

                         BOAT Seinivolatl 1e Orqanics

                         Acetophenone
                         Phenol
                         Sum of Diphenylamine and
                           Diphenylnitrosaminea


                         BOAT Metals

                         Chromium
                         Nickel
   The standard for diphenylamine and diphenylmtrosamine will be
   calculated as the sum of these two constituents because the two
   constituents cannot be distinguished using EPA's standard analytical
   testing procedure.
                                      123

-------
                6.  CALCULATION OF BOAT TREATMENT STANDARDS
    This section details the calculations of treatment standards for the
regulated constituents selected in Section 5.  EPA is setting treatment
standards based on performance data from (1) fuel substitution and
(2) stabilization (using a cement kiln dust binder) of a nonwastewater
similar to the ash residual generated from use of K022 as a fuel
substitute.
    For treatment of BOAT list organics, all six data points from Plant 1
were used to calculate the treatment standards.  The treatment data from
this plant are believed to have been obtained from a well-designed and
well-operated treatment system, since the organic constituents present in
the untreated wastes were reduced to nondetectable levels in the
treatment residual.  Furthermore, they are accompanied by sufficient
QA/QC data to develop treatment standards.  Thus, the data points meet
the requirements for setting treatment standards.  The data from Plant 2
were not used to set treatment standards because sufficient QA/QC data
were not available at this time to adjust the data for both the volatile
and semivolatile organic constituents.
    Five of the data points from stabilization of F006 waste show
treatment of chromium;  nine data points show treatment of nickel.  These
data points were used to calculate the metal treatment standards for K022
waste.  The performance data from stabilization of the F006 waste using a
cement kiln dust binder reflect treatment in a well-designed,
                                    124

-------
well-operated system;  the data also are accompanied by sufficient QA/QC
information.  Thus, the data meet the requirements for setting treatment
standards.
    As discussed in Section 1, the calculation of a treatment standard
for a constituent to be regulated involves (1) adjusting the data points
for accuracy, (2) determining the mean (arithmetic average) and
variability factor (see Appendix A) for the data points, and
(3) multiplying the mean and the variability factor together to determine
the treatment standard.
    The procedure for adjusting the data points is discussed in detail in
Section 1.2.6(3).  The data from each of the demonstrated technologies
are adjusted in Appendix B.  The unadjusted and accuracy corrected values
for the regulated constituents are presented again in Tables 6-1 and 6-2,
along with the accuracy correction factors, means of the accuracy
corrected values, and finally, treatment standards.
    As discussed in Section 3, the Agency is unaware of wastewaters
(i.e., scrubber waters) generated from treatment of K022 waste.
Furthermore, no wastewaters are expected to be generated during
stabilization of resultant ash residues.  The Agency is therefore
proposing a "treatment standard" for K022 wastewaters of "No Land
Disposal."  EPA has recently learned that some K022 wastewaters may be
disposed through underground injection, if this is the case, the "No Land
Disposal" standard will preclude continued injection of untreated
wastewaters unless a no migration petition has been granted.  The Agency
                                    125

-------
intends to seek clarification of the circumstances in which K022
wastewaters are being injected underground in order to determine whether
the no land disposal standard should be modified.   The Agency does seek
comments on the circumstances surrounding injection of K022 wastewaters
and the type of wastes being injected.
                                     126

-------
          1836g

                              Table 6-1   Calculation of Nonwastewater Treatment Standards for the Regulated Constituents Treated by Fuel Substitution
                                                                                 Correc-
                                        Unadjusted concentration  (mg/kg)          tion       Accuracy corrected concentration  (mg/kg)      Mean     Variability  Treatment
                                 	Sample Set #	  factor 	Sample Set  t	  (mg/kg)     factor     standard
                                    123456                 123456                            (mg/kg)


          BOAT Volatlles Organics

          Toluene                <0.012  <0.012  <0.012  <0.012   <0.012   <0.012   1.0  <0.012   <0.012   <0.012  <0.012   <0.012   <0.012    <0.012      2.8         0.034

          BOAT Semivolatile Orqanics
!—•
ro
"-1        Acetophenone           <3.8    <7.6    <3.8    <3.8    <3.7     <3.8    1/0.65  <5.8  <11.69    <5.8     <5.8    <5.7     <5.8       6.77       2.8         19

          Phenol                 <1.9    <3.8    <1.9    <1.9    <1.9     <1.9    1/0.51  <3.7    <7.25    <3.7     <3.7    <3.7     <3.7       4.29       2.8         12

          Diphenylamine/         <2.65   <5.3    <2.63    <2.63    <2.6     <2.63   1/0.65  <4.1    <8.2     <4.1     <4.1    <4.0     <4.1       4.77       2.8         13
            diphenylnitrosamine

-------
1982g
        Table 6-2   Calculation  of  Treatment  Standards for the Regulated
                   Constituents Treated  by Stabilization
                         Chromium                   Nickel  '

0.46
0.09
--
0.35
0.44
1.4
--
--
0.04
0.03
0.26
0.02
0.03
0.04
0.11
0.04
0.02
Average                     0.55                    0.066

N = Sample                  5                       9
    numbers

Variability                 6.9                     4.7
  factor

Treatment                   3.8                     0.31
  standard
                                   128

-------
                                 REFERENCES
Ackerman DG, McGaughey JF, Wagoner D.E., "At sea incineration of
  PCB-containing wastes on board the M/T Vulcanus," USEPA, 600/7-83-024,
  April 1983.

Ajax Floor Products Corp. n.d.   Product literature:  technical data
  sheets, Hazardous Waste Disposal System.  P.O. Box 161, Great Meadows,
  N.J. 07838.

Austin, G.T. 1984. Shreve's chemical process industries, 5th ed.
  New York:  McGraw-Hill.

Bishop, P.L., Ransom, S.B., and Grass, D.L.  1983.  Fixation mechanisms
  in solidification/stabilization of inorganic hazardous wastes.  In
  Proceedings of the 38th Industrial Waste Conference, 10-12 May 1983, at
  Purdue University, West Lafayette, Indiana.

Bonner TA, et al., Engineering handbook for hazardous waste incineration.
  SW-889. Prepared by Monsanto Research Corporation for U.S. EPA NTIS PB
  81-248163. June 1981.

Castaldini C, et al., Disposal of hazardous wastes  in industrial boilers
  on furnaces. Noyes Publications: New Jersey, 1986.

Conner, J.R.  1986.  Fixation and solidification of wastes.  Chemical
  Engineering.  Nov. 10,  1986.

Cull inane, M.J., Jr., Jones, L.W., and Malone, P.G.  1986.  Handbook for
  stabilization/solidification of hazardous waste.  U.S. Army Engineer
  Waterways Experiment Station.  EPA report No. 540/2-86/001.
  Cincinnati, Ohio:  U.S. Environmental Protection Agency.

CWM.  1987.  Chemical Waste Management.  Technical note 87-117,
  Stabilization treatment of selected metals containing wastes.
  September 22, 1987.  Chemical Waste Management, 150 West 137th Street,
  Riverdale, IL.

CWM.  1988.  Memorandum from Jesse R. Conner, Chemical Waste Management
  to R. Turner, EPA-HWERL, concerning matrix spike recoveries of treated
  waste. Memorandum date January 1988.

Electric Power Research Institute. 1980. FGD sludge disposal manual,
  2nd ed. Prepared by Michael Baker Jr., Inc. EPRI CS-1515 Project 1685-1
  Palo Alto, California: Electric Power Research Institute.
                                    129

-------
Malone, P.G., Jones, L.W., and Burkes, J.P.  Application of
  solidification/stabilization technology to electroplating wastes.
  Office of Water and Waste Management.  SW-872.  Washington, D.C.:  U.S.
  Environmental Protection Agency.

Mishuck, E. Taylor, D.R., Telles, R. and Lubowitz, H.  1984.
  Encapsulation/ fixation  (E/F) mechanisms.  Report No.
  DRXTH-TE-CR-84298.  Prepared by S-Cubed under Contract No.
  DAAK11-81-C-0164.

Mitre Corp. "Guidance manual for hazardous waste incinerator permits."
  NTIS PB84-100577. July  1983.

Novak RG, Troxler WL, Dehnke TH, "Recovering energy from hazardous waste
  incineration," Chemical Engineering  Progress 91:146 (1984).

Oppelt ET, "Incineration  of hazardous  waste";  JAPCA;  Volume 37, No. 5;
  May 1987.

Pojasek RB. 1979.  "Solid-Waste Disposal:  Solidification"   Chemical
  Engineering 86(17):   141-145.

Santoleri JJ,  "Energy recovery-A by-product of hazardous waste
  incineration  systems,"  in Proceedings of the 15th Mid-Atlantic
  Industrial Waste  Conference on Toxic and Hazardous Waste,  1983.

USEPA.   1980.   U.S.  Environmental Protection Agency.  U.S.  Army Engineer
  Waterways Experiment  Station.  Guide to the disposal of chemically
  stabilized and solidified waste.   Prepared for MERL/ORD under
  Interagency  Agreement No. EPA-IAG-D4-0569.  PB81-181505.
  Cincinnati,  Ohio.

USEPA.   1986a.  U.S.  Environmental  Protection Agency, Office of Solid
  Waste  and  Emergency Response.  Test  methods for  evaluating solid
  waste.   SW-846 Third  Edition.  Washington, D.C.:  U.S. Environmental
  Protection Agency,  November,  1986.

USEPA.   1986b.  U.S.  Environmental  Protection Agency, Office of Solid
  Waste.   Hazardous  waste  management  systems,  land disposal
  restrictions, final rule, Appendix I to  Part  268 - Toxicity
  Characteristic Leaching Procedure (TCLP).  51  FR 40643-40654.   November
  7,  1986..

USEPA.   1986c.  "Best demonstrated  available technology  (BOAT)  background
  document for F001-F005 spent  solvents,"  Volume 1,  EPA/530-SW-86-056,
  November 1986.
                                     130

-------
USEPA.  1987.  U.S. Environmental Protection Agency, Office of Solid
Waste.  Generic quality assurance project plan for land disposal
restrictions program ("BOAT"). Washington, D.C.:  U.S. Environmental
Protection Agency. EPA/530-SW-87-011. March 1987.

USEPA.  1988a.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Draft onsite engineering report of treatment technology
  performance and operation for Plant 1.  Washington, D.C.:  U.S.
  Environmental Protection Agency, March, 1988.

USEPA.  1988b.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Draft onsite engineering report of treatment technology
  performance and pperation for Plant 2.  Washington, D.C.:  U.S.
  Environmental Protection Agency, March, 1988.

USEPA.  1988c.  U.S. Environmental Protection Agency, Office of Solid
  Waste.  Draft onsite engineering report of treatment technology
  performance and operation of Plant 3.  Washington, D.C.:  U.S.
  Environmental Protection Agency, March, 1988.

Versar.  1984.  Estimating PMN incineration results  (Draft).  U.S.
  Environmental Protection Agency, Exposure Evaluation Division, Office
  of Toxic Substances, Washington, DC.  EPA Contract No. 68-01-6271, Task
  No. 66.

Vogel G, et al., "Incineration and cement kiln capacity for hazardous
  waste treatment," in Proceedings of the 12th Annual Research Symposium.
  Incineration and Treatment of Hazardous Wastes. Cincinnati, Ohio.
  April 1986.
                                    131

-------
                                APPENDIX A

A.I  F Value Determination for ANOVA Test
    As noted earlier in Section 1, EPA is using the statistical method
known as analysis of variance (ANOVA) 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 computational table below)  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).
                                     132

-------
    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 log transformed.
    (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 (SS6) is computed:


SSB =

«»
k
i-1
„
' T!
n .
ni


.




'


.
" k
y y .
i-1
N
c "*


f
where:
k = number of treatment technologies
    n^ = number of data points for technology i
    N = number of data points for all technologies
    T.J = sum of natural logtransformed data points for each technology.
    (iv)  The sum of the squares within data sets  (SSW) is computed:
     SSW
where:
x
                  I   I  x
                 i=l j-1
2. .
 i,J
  k
- I
                                        Ti2l
     .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.
                                    133

-------
    (vi)  Using the above parameters, the F value is calculated as
follows:
                                  MSB
                              F = MSW
    where:
    MSB = SSB/(k-l) and
    MSW = SSW/(N-k).
    A computational table summarizing the above parameters is shown below.

                    Computational Table for the F Value
Source
Between
Within
Degrees of
freedom
K-l
N-k
Sum of
squares
SSB
SSW
Mean square
MSB = SSB/k-1
MSW = SSW/N-k
F
MSB/MSW
    Below are three examples of the ANOVA calculation.  The first two
represent treatment by different technologies that achieve statistically
similar treatment; the last example represents a case in which one
technology achieves significantly better treatment than the other
technology.
                                    134

-------
1790g
                                                            Example  1
                                                       Methylene Chloride
Steam stripping
Influent Effluent
Ug/1)
1E5C 00
1290 00
1640.00
5100.00
1450 00
4600 00
1760.00
2400.00
4800.00
12100.00
Ug/i)
10 00
10.00
10.00
12.00
10.00
10.00
10.00
10.00
10.00
10.00
Biological treatment
In(effluent) [1n(eff luent)]Z 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/1) 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)]

5.2S
5.29
5.29
10.63
5.29





 Sum:
                                 23.18
                                 53.76
                                                                                             12.46
                                                                                                31.79
 Sample  Size:
     10            10
                10
 Mean:
   3669
10.2
2.32
                                             Z378
                                             13.2
                                                                             2.49
 Standard  Deviation:
   3328.67          .63
                  .06
                                              923.04
                                              7.15
                                                                              .43
 Variability Factor:
                   1.15
                                                                                 2.48
ANOVA Calculations:
SSB •=
SSW *
U-l
,=1 [ n, J j
JJi*2l'J.
MSB = SSB/(k-l)
HSU = SSW/(N-k)

f I « T^2 I
-1
1 L N J J
-I fTl2l
i-l I n, J


                                                             135

-------
1790g
                                     Example 1  (continued)
F   = MSB/MSW

wnere:

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)
nj = 10, nz « 5. N « 15. k - 2, T  - 23.18, T  = 12.46, T « 35.64. T = 1270.21
     537.31  T    155.25
       537.31   155.251    1270.21
                                              0.10
                              15
SSW. (53.76* 31.79)- |_^1 + 155.25'
                           10
                                                     0.77
MSB = 0.10/1 « 0.10

MSW = 0.77/13 = 0.06

      0.10
               1.67
      0.06
                                    ANOVA Table

Source
Between(B)
Within(W)
Degrees of
freedom
1
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.
                                               136

-------
1790g
                                                          Example 2
                                                      Tnchloroethylene
Steam strippinc Biological treatment
Influent Effluent In(effluent) [In (effluent)]2 Influent Effluent In(effluent) [Infeff luent}]
Us/l) Us/1)
1650.00 10.00
5200.00 10.00
5000.00 10.00
1720.00 10.00
1560.00 10.00
10300.00 10.00
210.00 10.00
1600.00 27.00
204.00 85.00
160.00 10.00
Sum:
-
Sample Size:
10 10
Mean :
2760 19.2
Standard Deviation:
3209.6 23.7
Variabi lity Factor:
Ug/1) Ug/1)
2.30 5.29 200.00 10.00 2.30 5.29
2.30 5.29 224.00 10.00 2.30 5.29
2.30 5.29 134.00 10.00 2.30 5.29
2.30 5.29 150.00 10.00 2.30 5.2S
2.30 5.29 484.00 16.25 2.79 7.78
2.30 5.29 163.00 10.00 2.30 5.29
2.30 5.29 182.00 10.00 2.30 5. 25
3.30 10.89
4.44 19.71
2.30 5.29

26.14 72.92 - - 16.59 39.52

10 - 7 7 7

2.61 - 220 10.89 2.37

.71 - 120.5 2.36 .19

3.70 - - - 1.53
ANOVA Calculations:
SSB.f U-l
i=l ni 1
ssw. r r1 x2,,j
L l«l 3*1 |J

[,1,'f]
hU^l
 MSB * SSB/(k-l)

 MSW - SSU/(N-k)
                                                           137

-------
1790g


                                     Example 2  (continued)

F   = HSB/MSW

where:

k   = numoer of treatment technologies

n  •= number of data points for technology i

N   = numOer 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)


N  = 10, N  « 7, N = 17, k = 2. T  = 26.14, T  = 16.59, T = 42.73, T2= 1825.85, T2 = 683.30,


T2 = 275.23
S5B
      '683.30      275.23  1   1825.85
       10
SSW = (72.92 f 39.52) -


MSB = 0.25/1 = 0.25

MSW = 4.79/15 = 0.32
7    J      17

     683.30   275.23
       10
7
                                                 0.25
                             4.79
             0.78
    0.32
                                    ANOVA Table
Degrees of
Source freedom
Between (B) 1
Within(U) 15

SS
0.25
4.79

MS
0.25
0.32

F
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 may differ
       depending upon the number of decimal places used  in each step of the calculations.
                                             138

-------
1790g

Example 3



Chlorobenzene
Activated sludae followed bv carbon adsorption
Influent Effluent In(effluent) [ln(eff luent)]2
IMQ/l) U9/1)
7200.00 80.00 4.38 19.18
6500.00 70.00 4.25 18.06
6075.00 35.00 3.56 12.67
3040.00 10 00 2.30 5.29



Sum:
.14.49 55.20
Sample Size:
444
Mean:
5703 49 3.62
Biolocncal
Influent
(«/l)
9206.00
16646.00
49775.00
14731.00
3159.00
6756.00
3040.00

-

7

14759
treatment
Effluent
Ug/i)
1083.00
709.50
460.00
142.00
603.00
153.00
17.00

-

7

452.5

ln(eff luent)

6.99
6.56
6.13
4.96
6.40
5.03
2.83

38.90

7

5.56

In [(effluent)]

46.86
43.03
37.56
24. 6C
40.96
25.30
8.01

228.34



-
Standard Deviation:


   1835.4        32.24




Variability Factor:

                  7.00
                                    .95
                                                             16311.66
                                                                              379.04
                                                                                15.79
                                                                                                1.42
ANOVA Calculations:





SSB-flfld
        i-l   n,



      F  k   ni
ssw =    i   r  x'




MSB'- SSB/(k-l)




MSU « SSW/(N-k)




F   * MSB/MSW
                                Ti
                                                              139

-------
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) for treatment  technology (i)


Nj = 4.  iy 7, N = 11.  k = 2, T  = 14.49, T  = 38.90, T = 53.39,  T2= 2850.49,  T2  = 209.96
SSB
     1513.21
                                                 9.52
SSW = (55.20 + 228.34)  -
                            *>9.96    15132
MSB = 9.52/1 = 9.52

MSW = 14.88/9 « 1.65

F = 9.52/1.65 = 5.77
                                    ANOVA 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.
                                                140

-------
A.2.  Variability Factor
                        VF =     Cqq
                                Mean
                              VF = Mean
    where:
     VF   = estimate of daily maximum variability factor determined from
            a sample population of daily data.
    Cgg *   Estimate of performance values below which 99 percent of the
            daily observations will be below.  Cgg is calculated using
            the following equation:  Cgq = Exp(y + 2.33 Sy) where y and
            Sy are the mean and standard deviation, respectively, of the
            logtransformed data.
    Mean  = average of the individual performance values.
    EPA is establishing this figure as an instantaneous maximum because
the Agency believes that on a day-to-day basis the waste should meet the
applicable treatment standards.  In addition, establishing this
requirement makes it easier to check compliance on a single day.  The
99th percentile is appropriate because it accounts for almost all process
variability.
    In several cases, all the results from analysis of the residuals from
BOAT treatment are found at concentrations less than the detection
limit.  In such cases, all the actual concentration values are considered
unknown and, hence, cannot be used to estimate the variability factor of
the analytical results.  Below is a description of EPA's approach for
calculating the variability factor for such cases with all concentrations
below the detection limit.
    It has been postulated as a general rule that a lognormal
distribution adequately describes the variation among concentrations.
Agency data show that the treatment residual concentrations are
                                     141

-------
distributed approximately lognormally.  Therefore, the lognormal model
has been used routinely in the EPA development of numerous regulations in
the Effluent Guidelines program and is being used in the BOAT program.
The variability factor (VF) was defined as the ratio of the 99th
percentile (C  ) of the lognormal distribution to its arithmetic mean
(Mean).
           VF =     C99                                            t1)
                   Mean
    The relationship between the parameters of the lognormal distribution
and the parameters of the normal distribution created by taking the
natural logarithms of the lognormally distributed concentrations can be
found in most mathematical statistics texts (see for example:
Distribution in Statistics-Volume 1 by Johnson and Kotz, 1970).  The mean
of the lognormal distribution can be expressed in terms of the
mean (n) and standard deviation  (a) of the normal distribution as
follows:
         C9g    =  Exp (M +  2.33a)                             (2)
         Mean   =  Exp (M +  0.5o2)                             (3)
    Substituting (2) and  (3) in  (1) the variability factor can then be
expressed in terms of a as follows:
         VF = Exp  (2.33 o - 0.5a2)                             (4)
    For residuals with concentrations that are not all below the
detection limit, the 99   percentile and the mean can be estimated from
the actual analytical data and accordingly, the variability factor (VF)
can be estimated using equation  (1).  For residuals with concentrations
                                     142

-------
that are below the detection limit, the above equations can be used in
conjunction with the assumptions below to develop a variability factor.
Step 1:  The actual concentrations follow a lognormal distribution.  The
upper limit (UL) is equal to the detection limit.  The lower limit (LL)
is assumed to be equal to one-tenth of the detection limit.  This
assumption is based on the fact that data from well-designed and
well-operated treatment systems generally falls within one order of
magnitude.
Step 2:  The natural logarithms of the concentrations have a normal
distribution with an upper limit equal to In (UL) and a lower limit equal
to In  (LL).
Step 3:  The standard deviation (a) of the normal distribution is
approximated by
    a  = [(In (UL) - In (LL)] /  [(2)(2.33)] - [ln(UL/LL)] / 4.66
    when LL « (0.1)(UL) then a  = (InlO) / 4.66 - 0.494
Step 4:  Substitution of the value from Step 3 in equation (4) yields the
variability factor, VF.
    VF = 2.8
                                    143

-------
                                APPENDIX  B
                             ANALYTICAL QA/QC
    This appendix presents QA/QC information for the available
performance data presented in Section 3.3 and identifies the methods and
procedures used for analyzing the constituents to be regulated.  The
QA/QC information includes matrix spike recovery data, which are used for
adjusting the analytical results for accuracy.  In general, the adjusted
analytical results (referred to as accuracy corrected concentrations) are
used for comparing the performance of one technology to that of another
and for calculating treatment standards for those constituents to be
regulated.
B.I      Accuracy Correction
    The accuracy corrected concentration for a constituent in a matrix is
the analytical result multiplied by the correction factor  (the reciprocal
                         *
of the recovery fraction;  i.e., the correction factor is  100 divided
by the percent recovery).  For example, if Compound A is measured at
2.55 mg/1 and the percent recovery is 85 percent, the accuracy corrected
concentration is 3.00 mg/1:
    2.55 mg/1             x  1/0.85               =   3.00 mg/1
    (analytical result)      (correction factor)      (accuracy corrected
                                                       concentration)
     The recovery fraction is the ratio of (1) the measured amount of the
     constituent in a spiked aliquot minus the measured amount of the
     constituent in the original unspiked aliquot to (2) the known amount
     of the constituent added to spike the original aliquot (refer to the
     Generic Quality Assurance Project Plan for the Land Disposal
     Restriction Program ("BOAT")).
                                    144

-------
The appropriate recovery values are selected according to the procedures
specified in Section 1.2.6(3).
    Tables B-l and B-2 present matrix spike recovery data for K022
waste.  Using these analytical recovery values, the data points were
corrected for accuracy.  Table B-3 presents recovery data for F006 waste
from which the standards for K022 metals were transferred.
B.2      Methods and Procedures Employed to Generate the Data Used in
         Calculating Treatment Standards
    Table B-4 lists the methods used for analyzing the constituents to be
regulated in K022 waste.  Most of these methods are specified in SW-846
(USEPA 1986a).  For some analyses, the SW-846 methods were modified;
these modifications are presented in Table B-5.  The Agency plans to use
these methods and procedures to enforce the treatment standards for K022
waste.
                                    145

-------
1836g
               Table B-l  Matrix Spike Recovery Data for Kiln Ash Residuals
                          from  Plant  1
                                                   Sample              Duplicate
Constituent                                   percent recovery     percent recovery
Volatile Orqanics

1.1-Dichloroethane                                  77                     77
Trichloroethene                                     89                     87
Chlorobenzene                                      101                    100
Toluene                                            106                    110
Benzene                                            102                    104
(Average of volatiles)                             (95)                   (95.6)

Semivolatile Orqanics (acid extractable)

Pentachlorophenol                                   14 a                   18 a
Phenol                                              53                     51
2-Chlorophenol                                      47                     48
4-Chloro-3-methylphenol                             30                     34
4-Nitrophenol                                       13 a                   12 a
(Average of acid extractables)                     (43.3)                 (44.3)

Semivolatile Orqanics (base/neutral extractable)
1,2,4-Trichlorobenzene
Acenaphthene
2,4-Dinitrotoluene
Pyrene
N-Nitroso-di-n-propylamine
1.4-Dichlorobenzene
(Average of base/neutral extractables)
74
40
60
14 a
74
76
(64.8)
71
43
63
18 a
73
76
(65.2)
 Source:   USEPA  1988a.

 aThese data are not acceptable because the percent recovery is less than 20 percent.
                                                146

-------
1836g
                    Table B-2  Matrix Spike Recovery Data for Kiln Ash
                               Residuals from Plant 2
                                                   Sample              Duplicate
Constituent                                   percent recovery     percent recovery
Volatile Organics

1,1-Dichloroethane                                  88                     90
Trichloroethene                                     76                     80
Chlorobenzene                                      102                    104
Toluene                                            104                    100
Benzene                                            102                    104
(Average of volatiles)                             (94.5)                 (95.6)

Semivolatile Oroanics  (acid extractable)

Pentachlorophenol                                   NA                     NA
Phenol                                              NA                     NA
2-Chlorophenol                                      NA                     NA
4-Chloro-3-methylphenol                             NA                     NA
4-Nitrophenol                                       NA                     NA
(Average of acid extractables)                     (NA)                   (NA)

Semivolatile Orqanics  (base/neutral extractable)

1,2,4-Trichlorobenzene                             NA                     NA
Acenaphthene                                        NA                     NA
2,4-Dinitrotoluene                                  NA                     NA
Pyrene                                              NA                     NA
N-Nitroso-di-n-propylamine                          NA                     NA
1,4-Dichlorobenzene                                 NA                     NA
(Average of base/neutral  extractables)             (NA)                   (NA)
 Source:   USEPA 1988b.

 NA =  Not  available.
                                                      147

-------
1982g
                                  Table B-3  Matrix Spike  Recoveries  for  Treated  Waste
Constituent
Arsenic
Barium

Cadmium

Chromium

Copper

Lead

Mercury

Nickel

Selenium0

Silver0

Zinc

Original
amount
found
(ppm)
0.101a
0.01b
0.3737
0.2765
0.0075
2.9034
0.3494
0.2213
0.2247
0.1526
0.3226
0.2142
0.001
0.001
0.028
0.4742
0.101
0.043
0.0437
0.0344
0.0133
27.202
Duplicate
(ppm)
0.01
0.01
0.3326
0.222
0.0069
0.7555
0.4226
0.2653
0.2211
0.1462
0.3091
0.2287
0.001
0.001
0.0264
0.0859
0.12
0.053
0.0399
0.0411
0.0238
3.65
% Error
0.0
0.0
5.82
10.9
4.17
58.7
9.48
9.0
0.81
2.14
2.14
3.27
0.0
0.0
6.87
69.3
8.6
10.4
4.55
8.87
28.3
76.3
Actual
spike
0.086
0.068
4.9474
5.1462
4.9010
6.5448
4.6780
4.5709
4.8494
4.9981
4.9619
4.6930
0.0034
0.0045
4.5400
4.6093
0.175
0.095
4.2837
0.081
5.0910
19.818
% Recovery
94.5
104
91.9
97.9
97.9
94.3
85.8
86.6
92.5
97.0
92.9
89.4
92
110
90.3
86.6
86
66**
84.8
0.87**
101.4
87.8
Accuracy
correction
factor*
1.06
0 96
1 09
1.02
1 02
1 06
1.17
1 15
1 08
1.03
1.08
1.12
1.09
0.91
1.11
1 15
1.16
0 96
1.18
114.9
0.99
1.14
 *Accuracy correction factor = 100 * percent recovery.
**This value  is not considered in the calculation for the accuracy correction factor.

aAt a mix ratio of 0.5.
bAt a mix ratio of 0.2
cFor a mix ratio of 0.2, correction factors of 1.16 and 1.18 were used when correcting for selenium and silver
 concentrations, respectively.

Source:  Memo to R. Turner, U.S. EPA/HWERL from Jesse R. Conner, Chemical Waste Management, dated January 20,  1988.
                                                     148

-------
1956g
       Table  B-4  Analytical Methods for Regulated Constituents Analysis
               Analysis/Methods                       Method      Reference
Semivolatile Organics:

    Continuous liquid-liquid extraction                3520           1
    Soxhlet extraction                                 3540           1
    Gas chromatography/mass spectrometry for
      semivolatile organics:  Capillary Column
      Technique                                        8270           1

Volatile Organics:

    Purge and trap                                     5030           1
    Gas chromatography/mass spectrometry for
      volatile organics                                8240           1

Metals:

    Digestion
      All solids                                       3050           1

    Inductively coupled  plasma atomic emission
      spectroscopy  (chromium and  nickel)               6010           1

    Sulfide                                            9030           1

TCLP                                                51 FR 40643        2
 References:

 1.   USEPA.   1986a.   U.S.  Environmental  Protection  Agency,  Office  of  Solid
     Waste and Emergency Response.   Test methods  for  evaluating  solid waste.
     SW-846 Third Edition.   November 1986.

 2.   USEPA.   1986b.   U.S.  Environmental  Protection  Agency.  Office  of  Solid
     Waste.   Hazardous waste management  systems;  land disposal restrictions;
     final rule;  Appendix I  to Part  268  - Toxicity  Leaching Procedure (TCLP).
     51 FR 40643-40654.   November 7, 1986.
                                         149

-------
1956g
              Table B-5  Method Modifications Used to Analyze K022
                         Untreated and Treated Samples
                              Method modifications
Volatile Organics

    In the volatiles analyses,  methanol extractions of the samples were
performed, with the methanol extract ultimately diluted into the actual
purging water.  Surrogate and matrix spikes were added at the extraction
stage.  In general, 1,000-fold and greater dilutions were required in the
volatiles analyses.  This level allowed major list constituents to be
characterized and effected some control over late eluting hydrocarbons that
might tend to foul the system.

Semivolatile Orqanics

    Because of the high hydrocarbon nature of the matrix, some modifications
were necessary in the semivolatile preparation procedure:  The samples were
originally extracted (pitch) or diluted (oil and raw waste) from approximately
1 gram to 5 ml in an attempt to achieve as low a detection limit as possible.
However, further dilution was found to be necessary before quantitative work
was possible; the sample extract was dark and highly concentrated.  The
modification made was that additional surrogates and matrix spikes were added
prior to the further dilution in order that they might be measurable in the
final aliquot.  Accounting was made for any spikes already present.  In
general, 25-fold and greater dilutions were required  in the semivolatiles
analyses.
                                      150

-------
                                APPENDIX C
    Appendix C contains the detection limits for the untreated waste and
treated residual for Plants 1 and 2.  Table C-l contains the detection
limits for the untreated waste for Plant 1.  Table C-2 contains the
detection limits for the kiln ash for Plant 1.  Table C-3 contains the
detection limits for the untreated waste and the kiln ash for Plant 2.
                                    151

-------
1955g
               Table C-l.   Detection Status of BOAT  List  Constituents  in  K022 Untreated Waste for Plant 1
BOAT
reference Constituent
no.

R-l
(mg/kg)
Untreated waste*
R-2 R-3 R-4 R-5
(mg/kg) (mg/kg) (mg/kg) (mg/k"g)

R-6
(mg/kg)
               Volatile Organics                  *Detection  limits  for  the  untreated waste are RCRA Confidential
                                                   Business  Information  (CBI).
222.           Acetone
1.             Acetonitrile
2.             Acrolein
3.             Acrylomtri le
4.             Benzene
5.             Bromodichloromethane
6.             Bromomethane
223.           n-Butyl alcohol
7.             Carbon tetrachloride '
8.             Carbon disulfide
9.             Chlorobenzene
10.            2-Ch1oro-l,3-butadiene
11.            Chlorodibromomethane
12.            Chloroethane
13.            2-Chloroethyl vinyl ether
14.            Chloroform
15.            Chloromethane
16.            3-Chloropropene
17.            1,2-Dibromo-3-chloropropane
18.            1,2-Dibromoethane
19.            Dibromomethane
20.            trans-1,4-Dichloro-2-butene
21.            Dlchlorodlfluoromethane
22.            1,1-Dichloroethane
23.            1,2-Dichloroethane
24.            1,1-Dichloroethylene
25.            trans-1,2-Dichloroethene
26.            1,2-Dichloropropane
27.            trans-1,3-Dichloropropene
28.            cis-l,3-Dichloropropene
29.            1,4-Dioxane
224.           2-Ethoxyethanol
225.           Ethyl acetate
226.           Ethyl benzene
30.            Ethyl cyanide
227.           Ethyl ether
31.            Ethyl methacrylate
214.           Ethylene oxide
32.            lodomethane
                                                                        152

-------
1955g


                                                Table C-l.  (continued)
BOAT
reference Constituent
no.
Untreated waste*
R-l
(mg/kg)
R-2
(mg/kg)
R-3
(mg/kg)
R-4
(mg/kg)
R-5
(mg/kg)
R-6
(mg/kg)
              Volatile Organics (continued)       *Detection limits  for the untreated  waste  are  RCRA  Confidential
                                                   Business Information (CBI).

33.            Isobutyl alcohol
228.           Methanol
34.            Methyl ethyl ketone
229.           Methyl isobutyl ketone
35.            Methyl methacrylate
37.            Methacrylomtrile
38.            Methylene chloride
230.           2-Nitropropane
39.            Pyridine
40.            1,1,1.2-Tetrachloroethane
41.            1,1,2,2-Tetrachloroethane
42.            Tetrachloroetnene
43.            Toluene
44.            Tribromomethane
45.            1,1,1-Trichloroethane
46.            1,1,2-Trichloroethane
47.            Trichloroethene
48.            Tnchloromonof luoromethane
49.            1,2,3-Trichloropropane
231.           l,l,2-Trichloro-1.2,2-
                 trifluoroethane
50.            Vinyl chloride
215.           1,2-Xylene
216.           1,3-Xylene
217.           1.4-Xylene

               Semivolatiles

51.            Acenaphthalene
52.            Acenaphthene
53.            Acetophenone
54.            2-Acetylaminofluorene
55.            4-Aminobiphenyl
56.            Aniline
57.            Anthracene
58.            Aramite
59.            Benz(a)anthracene
218.           Benzal chloride
60.            Benzenethiol
61.            Deleted
62.            Benzo(a)pyrene
                                                                   153

-------
1955g
                                                Table C-l.  (continued)
BOAT
reference Constituent
no.
Untreated waste*
R-l R-2 R-3 R-4
(mg/kg) (mg/kg) (mg/kg) (mg/kg)

R-5
(mg/kg)

R-6
(mg/kg)
             Semivolatile Orqanics (continued)     *0etection  limits  for  the  untreated waste are RCRA Confidential
                                                   Business  Information  (CBI).

63.             Benzo(b)fluoranthene
64.             Benzo(ghi)perylene
65.             Benzo(k)fluoranthene
66.             p-Benzoquinone
67.             Bis(2-chloroethoxy)methane
68.             Bis(2-ch1oroethyl)ether
69.             Bis(2-chloroisopropyl)ether
70.             Bis(2-ethylhexyl)phtha1ate
71.             4-Bromophenyl phenyl ether
72.             Butyl benzyl phthalate
73.             2-sec-Butyl-4,6-dinitrophenol
74.             p-Chloroamline
75.             Chlorobenzilate
76.             p-Chloro-m-cresol
77.             2-Chloronaphthalene
78.             2-Chlorophenol
79.             3-Chloropropiomtrile
80.             Chrysene
81.             ortho-Cresol
82.             para-Cresol
232.           Cyclohexanone
83.             Dibenz(a,h)anthracene
84.             Dibenzo(a,e)pyrene
85.             Dibenzo(a,i)pyrene
86.             m-Dichlorobenzene
87.             o-Dichlorobenzene
88.             p-Dichlorobenzene
89.             3,3'-Dich1orobenzidine
90.             2,4-Dichlorophenol
91.             2,6-Dichlorophenol
92.             Diethyl phthalate
93.             3,3'-Dimethoxybenzidine
94.             p-Dimethylaminoazobenzene
95.             3,3'-Dimethy1benzidine
96.             2,4-Dimethylphenol
97.             Dimethyl phthalate
98.             Di-n-butyl phthalate
99.             1,4-Dinitrobenzene
100.           4,6-Dinitro-o-cresol
101.           2,4-Dinitrophenol
                                                                  154

-------
1955g


                                                Table C-l.  (continued)
BOAT
reference Constituent
no.
Untreated waste*
R-l
(mg/kg)
R-2
(mg/kg)
R-3
(mg/kg)
R-4
(mg/kg)
R-5
(mg/kg)
R-6
(mg/kg)
            Semivolati le Orqanics (continued)      *Detection limits  for  the  untreated  waste  are RCRA  Confidential
                                                   Business Information  (CBI).

102.           2,4-Dimtrotoluene
103.           2,6-Dimtrotoluene
104.           Di-n-octyl phthalate
105.           Di-n-propylnitrosamine
106.           Diphenylamine
219.           Diphenylmtrosamine
107.           1,2-Diphenylhydrazine
108.           Fluoranthene
109.           Fluorene
110.           Hexachlorobenzene
111.           Hexachlorobutadiene
112.           Hexachlorocyclopentadlene
113.           Hexachloroethane
114.           Hexachlorophene
115.           Hexachloropropene
116.           Indeno(l,2,3-cd)pyrene
117.           Isosafrole
118.           Methapyrilene
119.           3-Methylcholanthrene
120.           4,4'-Methylenebis
                 (2-chloroaniline)
36.            Methyl methanesulfonate
121.           Naphthalene
122.           1,4-Naphthoquinone
123.           1-Naphthylamine
124.           2-Naphthylamine
125.           p-Nitroaniline
126.           Nitrobenzene
127.           4-Nitrophenol
128.           N-Nitrosodi-n-butylamine
129.           N-Nitrosodiethylamine
130.           N-Nitrosodimethylamine
131.           N-Nitrosomethylethylamine
132.           N-Nitrosomorpholine
133.           N-Nitrosopiperidine
134.           n-Nitrosopyrrolidine
135.           5-Nitro-o-toluidine
136.           Pentachlorobenzene
137.           Pentachloroethane
138.           Pentachloronltrobenzene
                                                                     155

-------
1955g
                                                Table C-l.   (continued)
BOAT
reference Constituent
no.
Untreated waste*
R-l R-2 R-3 R-4 R-5 R-6
(mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg)
            Semivolati 1e Orqamcs  (continued)      *Detection  limits for the untreated waste are RCRA Confidential
                                                   Business Information (CBI).

139.            Pentachlorophenol
140.            Phenacetin
141.            Phenanthrene
142.            Phenol
220.            Phthalic anhydride
143.            2-Picoline
144.            Pronamide
145.            Pyrene
146.            Resorcinol
147.            Safrole
148.            1,2,4,5-Tetrachlorobenzene
149.            2,3,4,6-Tetrachlorophenol
150.            1,2,4-Tnchlorobenzene
151.            2,4,5-Trichlorophenol
152.            2,4,6-Tnchlorophenol
153.            Tns(2,3-dibromopropyl)
                 phosphate

               Metals

154.            Antimony
155.            Arsenic
156.            Barium
157.            Beryllium
158.            Cadmium
159.            Chromium (total)
221.            Chromium (hexavalent)
160.            Copper
161.            Lead
162.            Mercury
163.            Nickel
164.            Selenium
165.            Silver
166.            Thallium
167.            Vanadium
168.            Zinc

               Inorganics

169.            Cyanide
170.            Fluoride
171.            Sulfide
                                                                   156

-------
1955g


                                                Table C-l.   (continued)
BOAT
reference Constituent
no.
Untreated waste*
R-l R-2
(mg/kg) (mg/kg)
R-3 R-4 R-5 R-6
(mg/kg) (mg/kg) (mg/kg) (mg/kg)
               Orqanochlorme  pesticides          *Detection  limits for the untreated waste are RCRA Confidential
                                                  Business Information (CBI).

172.           Aldnn
173.           alpha-BHC
174.           beta-BHC
175.           delta-BHC
176.           gamma-BHC
177.           Chlordane
178.           ODD
179.           DDE
180.           DDT
181.           Dieldrin
182.           Endosulfan I
183.           Endosulfan II
184.           Endnn
185.           Endnn aldehyde
186.           Heptachlor
187.           Heptachlor epoxide
188.           Isodnn
189.           Kepone
190.           Methoxyclor
191.           Toxaphene

               Phenoxvacetic acid herbicides

192.           2,4-Dichlorophenoxyacetic acid
193.           Silvex
194.           2,4,5-T

               Orqanophosphorous insecticides

195.           Disulfoton
196.           Famphur
197.           Methyl parathion
198.           Parathion
199.           Phorate

               PCBs

200.           Aroclor  1016
201.           Aroclor  1221
202.           Aroclor  1232
                                                                 157

-------
1955g


                                                Table C-l.  (continued)
BOAT
reference Constituent
no.
Untreated waste*
R-l
(mg/kg)
R-2
(mg/kg)
R-3
(mg/kg)
R-4
(mg/kg)
R-5
(mg/kg)
R-6
(mg/kg)
               PCBs (continued)                    *Detection  limits  for  the  untreated waste are RCRA Confidential
                                                   Business  Information  (CBI).
203.            Aroclor 1242
204.            Aroclor 1248
205.            Aroclor 1254
206.            Aroclor 1260

               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
ND = Not detected
 D = Detected
NA = Not analyzed
                                                                158

-------
1954g
                       Table C-2  Detection Status of BOAT List Constituents in Kiln Ash for Plant 1
BOAT
reference
no.
Constituent
  A-l
(mg/kg)
  A-2
(mg/kg)
  A-3
(mg/kg)
  A-4
(mg/kg)
  A-5
(mg/kg)
  A-6
(mg/kg)
               Volatiles Oroanics
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.
Acetone
Acetonitrile
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
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-l,4-Dichloro-2-butene
Dich lorodifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
trans-l,2-Dichloroethene
1,2-Dichloropropane
trans-l,3-Dichloropropene
cis-1,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
NA
0.420
0.065
0.0375
0.014
"0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0135
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.909
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.015
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.0150
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
                                                                159

-------
1954g
                                                   Table  C-2   (continued)
BOAT
reference Constituent
no.

A-l
(mg/kg)

A-2
(mg/kg)

A-3
(mg/kg)

A-4
(mg/kg)

A-5
(mg/kg)

A-6
(mg/kg)
              Volatile orqanlcs (continued)
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.
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methacrylomtrile
Methylene chloride
2-Nitropropane
Pyridine
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethene
Tr i chloromonof1uoromet hane
1,2,3-Trichloropropane
l,l,2-Trichloro-l,2,2-
  trifluoroethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1,4-Xylene

Semivolatiles

Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminofluorene
4-Aminobiphenyl
Ani11ne
Anthracene
Aram He
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene
1.0
NA
0.0225
NA
0.5
1.15
0.008
NA
0.5
0.018
0.0115
0.017
0.012
0.0135
0.013
0.0115
0.0125
0.0295
0.0385
NA
0.0395
NA
NA
NA
3.02
1.51
3.80
4.20
1.30
6.00
1.10
3.10
0.80
NA
210
NA
3.50
1.0
NA
0.0225
NA
0.5
1.15
0.008
NA
0.5
0.108
0.0115
0.017
0.012
0.0135
0.013
0.0115
0.0125
0.0295
0.0385
NA
0.0395
NA
NA
NA
6.04
3.02
7.60
8.40
2.60
12.00
2.20
6.20
1.60
NA
420
NA
7.00
1.0
NA
0.0225
NA
0.5
1.15
0.008
NA
0.5
0.108
0.0115
0.017
0.012
0.0135
0.013
0.0115
0.0125
0.0295 -
0.0385
NA
0.0395
NA
NA
NA
2.96
1.48
3.76
4.16
1.29
5.94
1.09
3.07
0.79
NA
207.9
NA
3.46
1.0
NA
0.0225
NA
0.5
1.15
0.008
NA
0.5
0.018
0.0115
0.017
0.012
0.0135
0.013
0.0115
0.0125
0.0295
' 0.0385
NA
0.0395
NA
NA
NA
2.96
1.48
3.76
4.16
1.29
5.94
1.09
3.07
0.79
NA
207.9
NA
3.46
1.0
NA
0.0225
NA
0.5
1.15
0.008
NA
0.5
0.018
0.0115
0.017
0.012
0.0135
0.013
0.0115
0.0125
0.0295
0.0385
NA
0.0395
NA
NA
NA
2.94
1.47
3.724
4.116
1.274
5.88
1.078
3.038
0.784
NA
205.8
NA
3.43
1.0
NA
0.0225
NA
0.5
1.15
0.008
NA
0.5
0.018
0.0115
0.017
0 012
0.0135
0.013
0 0115
0.0125
0.0295
0.0385
NA
0.0395
NA
NA
NA
2.96
1.48
3.76
4.16
1.29
5.94
1.09
3.07
0.79
NA
207.9
NA
3.46
                                                                  160

-------
1954g
                                                 Table C-2  (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.
Constituent
Semwolatile orqanics
(Continued)
Benzo(b)f luoranthene
Benzo(ghi)perylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroani line
Chlorobenzilate
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropiomtri le
Chrysene
ortho-Cresol
para-Cresol
Cyc lohexanone
D ibenzo( a, h) anthracene
Dibenzo(a,e)pyrene
Dibenzo(a. i)pyrene
m-Dichlorobenzene
o-Dtchlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2,6-Dichlorophenol
Diethyl phthalate
3,3 '-Dimethoxybenzidine
p- D i met hy 1 am i noazobenzene
3,3'-Dimethylbenzidine
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1 , 4-D i n i trobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
A-l
(mg/kg)


3.85
2.30
1.45
18.49
0.60
2.05
2.50
2.79
2.65
3.20
5.25
2.50
2.90
5.50
1.50
1.58
5.00
2.40
2.45
2.45
NA
4.10
3.75
4.50
1.65
1.65
1.65
5.50
11.73
2.24
1.30
90
7.50
12.5
0.50
2.05
4.40
2.50
1.35
1.55
A-2
(mg/kg)


7.70
4.60
2.90
36.99
1.2
4.10
5.00
5.59
5.30
6.41
10.51
5.00
5.80
11.00
3.00
3.16
10.00
4.79
4.90
4.90
NA
8.20
7.51
9.00
3.30
3.30
3.30
11.00
23.46
4.49
2.59
180
14.99
25.1
1.00
4.10
8.79
5.00
2.69
3.10
A-3
(mg/kg)


3.81
2.28
1.44
18.31
0.59
2.03
2.47
2.77
2.63
3.17
5.20
2.47
2.87
5.44
1.48
•1.57
4.95
2.37
2.42
2.42
NA
4.06
3.72
4.45
1.64
1.64
1.64
5.44
11.62
2.22
1.28
89.08
7.42
12.42
0.49
2.03
4.35
2.47
1.33
1.54
A-4
(mg/kg)


3.81
2.28
1.44
18.31
0.59
2.03
2.47
2.77
2.63
3.17
5.20
2.47
2.87
5.44
1.48
1.57
4.95
2.37
2.42
2.42
NA •
4.06
3.72
4.45
1.64
1.64
1.64
5.44
11.62
2.22
1.28
89.08
7.42
12.42
0.49
2.03
4.35
2.47
1.33
1.54
A-5
(mg/kg)


3.773
2.254
1.421
18.13
0.588
2.009
2.45
2.74
2.6
3.14
5.15
2.45
2.842
5.39
1.47
1.55
4.9
2.35
2.4
2.4
NA
4.02
3.68
4.41
1.62
1.62
1.62
5.39
11.5
2.2
1.27
88.2
7.35
12.3
0.49
2.01
4.31
2.45
1.32
1.52
A- 6
(mg/kg)


3.81
2.28
1.44
18.31
0.59
2.03
2.47
2.77
2.63
3.17
5.20
2.47
2.87
5.44
1.48
1.57
4.95
2.37
2.42
2.42
NA
4.06
3.72
4.45
1.64
1.64
1.64
5.44
11.62
2.22
1.28
89.08
7.42
12.42
0.49
2.03
4.35
2.47
1.33
1.54
                                                                   161

-------
1954g
              Semwolati 1e orqanics
                   (Continued)
                                                   Table C-2  (continued)
BOAT
reference Constituent
no.

A-l
(mg/kg)

A-2
(mg/kg)

A-3
(mg/kg)

A-4
(mg/kg)

A-5
(mg/kg)

A-6
(mg/kg)
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.
2,4-Dinitrotoluene
2,6-Dimtrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine
D i pheny 1 n 11 rosam i ne
1,2 - D i pheny 1 hydraz i ne
Fluoranthene
Fluorene
Hexach lorobenzene
Hexachlorobutadiene
Hexach Iorocyclopentadlene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Indeno(1,2,3-cd)pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4,4'-Methylenebis
  (2-chloroaniline)
Methyl methanesulfonate
Naphthalene
1,4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N-Nitrosomorpholine
N-Nitrosopiperidine
n-Nitrosopyrrolidine
5-Nitro-o-toluidine
Pentachlorobenzene
Pentachloroethane
Pentachloron i trobenzene
 8.39
            16.79
                         8.31
                         8.31
                                                 8.23
                                                 8.31
2.79
1.90
2.65
2.65
3.45
3.00
1.55
3.40
1.55
1.45
0.80
7.00
2.95
2.20
11.53
6.50
5.59
3.79
5.30
5.30
6.90
6.00
3.10
6.79
3.10
2.90
1.59
13.99
5.90
4.41
23.05
13.0
2.77
1.88
2.63
2.63
3.41
2.97
1.54
3.36
1.54
1.43
0.79
6.93
2.92
2.18
11.41
6.43
2.77
1.88
2.63
2.63
3.41
2.97
1.54
3.36
1.54
1.43
0.79
6.93
2.92
2.18
11.41
6.43
2.74
1.86
2.6
2.6
3.38
2.94
1.52
3.33
1.52
1.42
0.78
6.86
2.89
2.16
11.3
6.37
2.77
1.88
2.63
2.63
3.41
2.97
1.54
3.36
1.54
1.43
0.79
6.93
2.92
2.18
11.41
6.43
35
70
                        34.64
                        34.64
                                                34.3
                                                34.64
0.55
0.5
36
50
4.15
5.50
3.35
6
1
8.50
1.85
0.85
2.00
1.50
4.55
4.7
0.80
4.75
1.10
1
72
100
8.30
11.00
6.69
12
2
17
3.69
1.70
4.00
3.00
9
9.4
1.60
9.51
0.54
0.49
35.65
49.5
4.11
5.44
3.31
5.94
1
8.41
1.3
0.84
1.98
1.48
4.50
4.65
0.79
4.71
0.54
0.49
35.65
49.5
4.11
5.44
3.31
5.94
1
8.41
1.3
0.84
1.98
1.48
4.50
4.65
0.79
4.71
0.539
0.49 •
35.3
49
4.07
5.39
3.28
5.88
0.98
8.33
1.81
0.833
1.96
1.47
4.46
4.6
0.784
4.66
0.54
0.49
35.65
49.5
4.11
5.44
3.31
5.94
1
8.41
1.3
0.84
1.98
1.48
4.50
4.65
0.79
4.71
                                                                      162

-------
1954g
                                                 Table C-2  (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.



Constituent
• Semivolatile orqanlcs
(Continued)
Pentach loropheno 1
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picol1ne
Pronamide
Pyrene
Resorcinol
Safrole
1,2,4, 5-Tetrachlorobenzene
2,3,4, 6-Tet rach lorophenol
1,2,4-Trichlorobenzene
2,4,5-Trichlorophenol
2, 4, 6-Trich lorophenol
Tr i s ( 2 , 3-d ibromopropy 1 )
phosphate
Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Metals TCLPa
Arsenic
Barium
A-l
(mg/kg)


1.85
4.7
2.50
1.9
NA
18.5
11.5
2.3
38.5
2.4
3.2
15.5
0.95
1.10
1.65

4.70

15
15
1
0.05
2.5
5
NA
5
15
0.5
10
30
2.5
15
5
2.5

0.15
0.01
A-2
(mg/kg)


3.69
9.4
5.00
3.8
NA
36.9
23
4.59
76.9
4.79
6.41
31.1
1.90
2.20
3.30

9.40

15
15
1
0.05
2.5
5
NA
5
15
0.5
10
30
2.5
15
5
2.5

0.015
0.01
A-3
(mg/kg)


1.83
4.65
2.47
1.88
NA
18.28
11.41
2.27
38.01
2.37
3.17
15.35
0.94
1.09
1.64

4.70

15
15
1
0.5
2.5
5
NA
5
15
0.5
10
30
2.5
15
5
2.5

0.015
0.01
A-4
(mg/kg)


1.83
4.65
2.47
1.88
NA
18.28
11.41
2.27
38.01
2.37
3.17
15.35
0.94
1.09
1.64

4.70

15
15
1
0.05
2.5
5
NA
5
15
0.5
10
30
2.5
15
5
2.5

0.015
0.01
A- 5
(mg/kg)


1.81
4.6
2.45
1.66
NA
18.1
11.3
2.25
37.7
2.35
3.14
15.2
0.931
1.08
1.62

4.61

15
15
1
0.05
2.5
5
NA
5
15
0.5
10
30
2.5
15
5
2.5

0.015
0.01
A-6
(mg/kg)


1.83
4.65
2.47
1.88
NA
18.28
11.41
2.27
38.01
2.37
3.17
15.35
0.94
1.09
1.64

4.66

15
15
1
0.05
2.5
5
NA
5
15
0.5
10
30
2.5
15
5
2.5

0.015
0.01
                                                                163

-------
1954g
                                                   Table  C-2   (continued)
BOAT
reference
no.
Constituent
                                       A-l
                                     (mg/kg)
                A-2
              (mg/kg)
              A-3
            (mg/kg)
               A-4
             (nig/kg)
               A-5
             (mg/kg)
               A-6
             (mg/kg)
               Metals TCLPa (continued)

               Cadmium
               Chromium
               Lead
               Mercury
               Selenium
               SiIver

               Inorganics
0.025
0.025
0.15
0.005
0.3
0.025
0.025
0.025
0.15
0.005
0.3
0.025
0.025
0.025
0.15
0.005
0.5
0.025
0.025
0.025
0.15
0.005
0.5
0.025
0.025
0.025
0.15
0.005
0.5
0.025
0.025
0.025
0.15
0.005
0.5
0.025
169.
170.
171.
Cyanide
Fluoride
Sulfide
  1.25
 10
200
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
               Orqanochlonne pesticides
172.
173.
174.
175.
176.
177.
178.
179.
180.
181.
182.
183.
184.
185.
186.
187.
188.
189.
190.
191.
Aldrin
alpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
0.4
0.4
0.4
0.4
0.4
0.8
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.8
0.4
0.4
0.4
0.4
NA
0.4
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
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
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
               Phenoxvacetic acid herbicides
192.
193.
194.
2,4-Dichlorophenoxyacetic acid       0.02       NA
Silvex                               0.01       NA
2,4,5-T                              0.01       NA
                         NA
                         NA
                         NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                                                                  164

-------
1954g
                                                   Table C-2  (continued)
BOAT
reference
no.
Constituent
  A-l
(mg/kg)
  A-2
(mg/kg)
  A-3
(mg/kg)
  A-4
(mg/kg)
  A-5
(mg/kg)
  A-6
(mg/kg)
               Orqanophosphorous insecticides
195.
196.
197.
198.
199.

200.
201.
202.
203.
204.
205.
206.

207.
208.
209.
210.
211.
212.
213.

Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Dioxins and furans
Hexach lorod i benzo-p-d i ox ins
Hexach lorod i benzof urans
Pentach lorod i benzo-p-d i ox i ns
Pentach lorod i benzof urans
Tetrachlorodibenzo-p-dioxins
Tetrachlorodi benzof urans
2,3,7, 8-Tetrachlorod i benzo-p-
dioxin
 - = No detection  limit specified.

 NA = Not analyzed

 a = Units are mg/1.
0.05
0.04
0.05
0.05
0.05
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
0.8
0.8
0.8
0.8
0.8
0.8
0.8
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
0.00007
-
0.0002
0.000068
0.000022
0.000028
0.00036
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
                                                                  165

-------
1903g
                Table C-3  Detection Limits of BOAT List Constituents
                           Analyzed in K022 Waste from Plant 2
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.
Constituent
Volatiles
Acetone
Acetonitri le
Acrolein
Acrylonitrile
Benzene
Brotnodichloromethane
Bromomethane
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
l,2-Dibromo-3-chloropropane
1,2-Dibromoethane
Di bromomethane
trans-1 ,4-Dichloro-2-butene
D ich lorod if luoromethane
1,1-Dichloroethane
1 , 2-Dichloroethane
1,1-Dichloroethylene
trans-1 ,2-Dichloroethene
1.2-Dichloropropane
trans-1, 3-Dichloropropene
cis-l,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
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
Detection limit (mq/kq)
Untreated Ash
waste** residual*

NA
0.42
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.02
0.0115
0.0375
0.0025
0.025
0.02
0.017
0.09
0.235
0.0155
0.0135
0.011
0.01
0.015
0.0145
0.0135
0.5
NA
NA
NA
1.5
NA
0.5
* NOTE:  Six ash samples were analyzed for volatile organics.  The detection limits
  listed are applicable for five of the six samples.  For one sample, the detection
  limits are five times higher.

"Detection  limits for the untreated waste are RCRA Confidential Business
  Information  (CBI).
                                             166

-------
1903g
                                Table C-3  (continued)
BOAT
reference
no.
 Constituent
               Detection limit (mg/kq)
CAS no.         Untreated      Ash
                 waste**    residual
               Volatiles
214.
32.
33.
228.
34.
229.
35.
37.
38.
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
231.

50.
215.
216.
217.
Ethylene oxide                 75-21-8
lodomethane                    74-88-4
Isobutyl alcohol               78-83-1
Methanol                       67-56-1
Methyl ethyl ketone            78-93-3
Methyl isobutyl ketone         108-10-1
Methyl methacrylate            80-62-6
Methacrylonitrile              126-98-7
Methylene chloride             75-09-2
2-Nitropropane                 79-46-9
Pyridine                       110-86-1
1,1,1,2-Tetrachloroethane      630-20-6
1,1,2,2-Tetrach loroethane      79-34-6
Tetrachloroethene              127-18-4
Toluene                        108-88-3
Tribromomethane                75-25-2
1,1,1-Tnchloroethane          71-55-6
1,1,2-Trichloroethane          79-00-5
Trichloroethene                79-01-6
Trlchloromonofluoromethane     75-69-4
1,2,3-Trichloropropane         96-18-4
l,l,2-Trichloro-l,2,2-         76-13-1
  trifluoroethane
Vinyl chloride                 75-01-4
1,2-Xylene                     97-47-6
1,3-Xylene                     108-38-3
1,4-Xylene                     106-44-5
                              NA
                               0.0465
                               1.0
                              NA
                               0.0225
                              NA
                               0.5
                               1.15
                               0.008
                              NA
                               0.5
                               0.018
                               0.115
                               0.017
                               0.012
                               0.0135
                               0.013
                               0.0115
                               0.0125
                               0.0295
                               0.0385
                              NA

                               0.0395
                              NA
                              NA
                              NA
               Semivolatiles
51.
52.
53.
54.
55.
56.
57.
58.
59.
218.
60.
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminofluorene
4-Aminobiphenyl
Aniline
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
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
 0.99
 0.495
 1.254
 1.396
 0.429
 1.98
 0.363
 1.023
 0.264
NA
69.3
 "Detection  limits for the untreated waste are RCRA Confidential Business
   Information  (CBI).
                                             167

-------
1903g
                                Table C-3   (continued)
BOAT
reference Constituent
no.
Detection limit (ma/kal
CAS no. Untreated Ash
waste** residual
61.
62.
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.
Semivolatiles  (continued)

Deleted
Benzo(a)pyrene                 50-32-8
Benzo(b)fluoranthene           205-99-2
Benzo(ghi)perylene             191-24-2
Benzo(k)fluoranthene           207-08-9
p-Benzoquinone                 106-51-4
Bis(2-chloroethoxy)methane      111-91-1
Bis(2-chloroethyl)ether        111-44-4
Bis(2-chloroisopropyl)ether    39638-32-9
Bis(2-ethylhexyl)phthalate      117-81-7
4-Bromophenyl phenyl ether      101-55-3
Butyl benzyl phthalate         85-68-7
2-sec-Butyl-4,6-dimtrophenol  88-85-7
p-Chloroamline                106-47-8
Chlorobenzilate                510-15-6
p-Chloro-m-cresol              59-50-7
2-Chloronaphthalene            91-58-7
2-Chlorophenol                 95-57-8
3-Chloropropionitnle          542-76-7
Chrysene                       218-01-9
ortho-Cresol                   95-48-7
para-Cresol                    106-44-5
Cyclohexanone                  108-94-1
Dibenz(a,h)anthracene          53-70-3
Dibenzo(a,e)pyrene             192-65-4
Dibenzo(a,i)pyrene             189-55-9
m-Dichlorobenzene              541-73-1
o-Dichlorobenzene              95-50-1
p-Dichlorobenzene              106-46-7
3,3'-Dichlorobenzidine         91-94-1
2,4-Dichlorophenol             120-83-2
2,6-Dichlorophenol             87-65-0
Diethyl phthalate              84-66-2
3,3'-Dimethoxybenzidine        119-90-4
p-Dimethylaminoazobenzene      60-11-7
3,3'-Dimethylbenzidine         119-93-7
2,4-Dimethylphenol             105-67-9
Dimethyl phthalate             131-11-3
Di-n-butyl phthalate           84-74-2
1,4-Dinitrobenzene             100-25-4
 1.155
 1.271
 0.759
 0.479
 6.105
 0.198
 0.677
 0.825
 0.924
 0.875
 1.056
 1.733
 0.825
 0.957
 1.815
 0.495
 0.611
 1.650
 0.792
 0.809
 0.809
NA
 1.353
 1.238
 1.485
 0.545
 0.545
 0.545
 1.815
 0.561
 0.743
 0.429
29.7
 2.475
 4.125
 0.165
 0.677
 1.452
 0.825
"Detection  limits for the untreated waste are RCRA Confidential Business
   Information (CBI).
                                             168

-------
1903g
                                Table  C-3   (continued)
BOAT
reference
no.

100.
101.
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.
Constituent
Semivolatiles (continued)
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine/
Diphenylnitrosamine
1 ,2-Diphenylhydrazine
Fluoranthene
Fluorene
Hexach "lorobenzene
Hexach lorobutadi ene
Hexach lorocyc lopentad i ene
Hexach loroethane
Hexach lorophene
Hexach loropropene
lndeno(l,2,3-cd)pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4,4'-Methylenebis
(2-chloroaniline)
Methyl methanesulfonate
Naphthalene
1,4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N - N i t rosomor pho line
N-N i t rosop i per i d i ne
n-Nitrosopyrrol idine
5-Nitro-o-toluidine
CAS no.

534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
621-64-7
122-39-4/
86-30-6
122-66-7
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
70-30-4
1888-71-7
193-39-5
120-58-1
91-80-5
56-49-5

101-14-4
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
Detection limit (mq/kq)
Untreated Ash
waste** residual

0.446
0.512
2.792
-
0.924
0.627

0.875
1.139
0.990
0.512
1.122
0.512
0.479
0.264
'
2.310
0.974
0.726
3.795
2.145

11.55
-
0.182
0.165
11.88
16.5
1.37
0.182
1.106
1.98
0.33
2.805
0.61
0.281
0.66
0.495
1.502
 "Detection limits for the untreated waste  are RCRA Confidential Business
   Information (CBI).

                                              169

-------
1903g
                                Table C-3  (continued)
BOAT
reference
no.
 Constituent
                               CAS  no.
Detection limit (nig/kg)
Untreated      Ash
                                                waste*
             residual
136.
137.
138.
139.
140.
141.
142.
220.
143.
144.
145.
146.
147.
148.
149.
150.
151.
152.
153.
Semivolatiles  (continued)

Pentachlorobenzene             608-93-5
Pentachloroethane              76-01-7
Pentachloronitrobenzene        82-68-8
Pentachlorophenol              87-86-5
Phenacetin                     62-44-2
Phenanthrene                   85-01-8
Phenol                         108-95-2
Phthalic anhydride             85-44-9
2-Picoline                     109-06-8
Pronamide                      23950-58-5
Pyrene                         129-00-0
Resorcinol                     108-46-3
Safrole                        94-59-7
1,2,4. 5-Tetrachlorobenzene     95-94-3
2,3,4,6-Tetrachlorophenol      58-90-2
1,2,4-Trichlorobenzene         120-82-1
2,4,5-Tnchlorophenol          95-95-4
2,4,6-Trichlorophenol          88-06-2
Tris(2,3-dibromopropyl)
  phosphate                    126-72-7

Meta_1s
                1.551
                0.264
                1.568
                0.611
                1.551
                0.825
                0.627
               NA
                6.105
                3.795
                0.759
               12.705
                0.792
                1.056
                0.512
                0.314
                0.363
                0.545

               15.51
154.
155.
156.
157.
158.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.
Ant imony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Tha 1 1 i urn
Vanadium
Zinc
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
                                                                             15
                                                                             15
                                                                              1
                                                                              0.5
                                                                              2.5
                                                                              5
                                                                             NA
                                                                              5
                                                                             15
                                                                              1
                                                                             10
                                                                             30
                                                                              2.5
                                                                             15
                                                                              5
                                                                              2.5
 Note:  Six samples were analyzed for metals.

 "Detection  limits for the untreated waste are RCRA Confidential Business
    Information  (CBI).
                                               170

-------
1903g
                               Table C-3  (continued)
BOAT
reference
no.










169.
170.
171.

172.
173.
174.
175.
176.
177.
178.
179.
180.
181.
182.
183.
184.
185.
186.
187.
188.
189.
190.
191.
Constituent
Metals TCLPa
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Inorganics
Cyanide
Fluoride
Sulfide
Organochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
gamma-BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
CAS no.










57-12-5
16964-48-8
8496-25-8

309-00-2
319-84-6
319-85-7
319-86-8
58-89-9
57-74-9
72-54-8
72-55-9
50-29-3
60-57-1
939-98-8
33213-6-5
72-20-8
7421-93-4
76-44-8
1024-57-3
465-73-6
143-50-0
72-43-5
8001-35-2
Detection limit (mq/kq)
Untreated Ash
waste** residual

0.15
0.01
0.025
0.025
0.15
0.005
0.3
0.025

2.5
-
-

0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.8
0.4
0.4
0.4
0.4
0.4
0.4
"Detection limits for the untreated waste  are RCRA Confidential Business
   Information (CBI).
                                               171

-------
1903g
                               Table C-3  (continued)
BOAT
reference
no.

192.
193.
194.

195.
196.
197.
198.
199.

200.
201.
202.
203.
204.
205.
206.

207.
208.
209.
210.
211.
212.
213.

Constituent
Phenoxvacet 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
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Dioxins and furans
Hexachlorodibenzo-p-dioxins
Hexach lorod ibenzofurans
Pentachlorodibenzo-p-dioxins
Pentach lorod ibenzofurans
Tetrachlorodibenzo-p-dioxins
Tet rach lorod ibenzofurans
2,3,7, 8-Tet rach lorod i benzo-p-
dioxin
CAS no.

94-75-7
93-72-1
93-76-5

298-04-4
52-85-7
298-00-0
56-38-2
298-02-2

12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-83-5

-
-
-
-
-
-

1746-01-6
Detection limit (mq/kq)
Untreated Ash
waste** residual

0.01
0.01
0.01

0.05
0.05
0.5
0.05
0.05

0.4
0.4
0.4
0.4
0.4
0.4
0.4

0.000053
0.000036
0.000052
0.000049
0.000062
0.000062

0.00012
NA = Not analyzed
 - = No detection limit specified
 a = Units are mg/1

"Detection limits for the untreated  waste  are  RCRA Confidential Business
  Information (CBI).
                                              172

-------
                                APPENDIX D

                        THERMAL CONDUCTIVITY  METHOD

    The comparative method of measuring thermal conductivity has been
proposed as an ASTM test method under the name "Guarded, Comparative,
Longitudinal Heat Flow Technique."  A thermal heat flow circuit is used
which is the analog of an electrical circuit with resistances in series.
A reference material is chosen to have a thermal conductivity close to
that estimated for the sample.  Reference standards (also known as heat
meters) having the same cross-sectional dimensions as the sample are
placed above and below the sample.  An upper heater, a lower heater, and
a heat sink are added to the "stack" to complete the heat flow circuit.
See Figure 1.
    The temperature gradients  (analogous to potential differences) along
the stack are measured with type K  (chromel/alumel) thermocouples placed
at known separations.  The thermocouples are placed into holes or grooves
in the references and also in the sample whenever the sample is thick
enough to accommodate them.
    For molten samples, pastes, greases, and other materials that must be
contained, the material is placed into a cell consisting of a top and
bottom of Pyrex 7740 and a containment ring of marinite.  The sample is 2
inch in diameter and .5 inch thick.  Thermocouples are not placed into
the sample but rather the temperatures measured in the Pyrex are
extrapolated to give the temperature at the top and bottom surfaces of
the sample material.  The Pyrex disks also serve as the thermal
conductivity reference material.

                                  173

-------
   GUARD
GRADIENT,
   STACK
GRADIENT-
              THERMOCOUPLE
                                        CLAMP
                           UPPER STACK
                              HEATER
                                 I

                          TOP REFERENCE
                              SAMPLE
                                 I   x
                                J
TEST/SAMPLE
                                J
 BOTTOM
REFERENCE
  SAMPLE
                                 I
                           LOWER STACK
                              HEATER
                                 I
                          LIQUID 'COOLED
                             HEAT SINK
                                 I
                              UPPER
                              GUARD
                              HEATER
HEAT  FLOW
DIRECTION

                              LOWER
                              GUARD
                              HEATER
    Figure D-l
                   SCHEMATIC DIAGRAM OF THE COMPARATIVE HETEOD
                                 174

-------
    The stack is clamped with a reproducible load to insure intimate
contact between the components.  In order to produce a linear flow of
heat down the stack and reduce the amount of heat that flows radially, a
guard tube is placed around the stack and the intervening space is filled
with insulating grains or powder.  The temperature gradient in the guard
is matched to that in the stack to further reduce radial heat flow.
    The comparative method is a steady state method of measuring thermal
conductivity.  When equilibrium is reached the heat flux (analogous to
current flow) down the stack can be determined from the references.  The
heat into the sample is given by
                            Q.   -  v   (dT/dxh
                             in    top       top
and the heat out of the sample is given by
                        Qout - AU ^  (dT/dx)u ^
                                bottom       bottom
where
                          A  * thermal  conductivity
                        dT/dx - temperature  gradient
and top refers to the upper reference while bottom refers to the lower
reference.   If the heat was confined to flow just down the stack, then
Q   and Q    would be equal.   If Q.  and Q  A are in reasonable
 in      out                      in      out
agreement, the average heat flow is calculated from
                             " - (Qin  +  "out'/2
The sample thermal conductivity is then found from
                         A    .  - Q/(dT/dx)    .  •
                          sample            sample
                                    175

-------
                                APPENDIX  E
    This appendix presents Tables  E-l and E-2 for F006 treatment
performance data provided by two facilities treating F006 wastes while
Table E-3 presents F006 data that  were not used in Section 3.3 of this
report.
                                     176

-------
1982g
                         Table E-l   Composition Data  and  TCLP  Data  for
                                   Lime Stabilized F006 Waste

Constituents




Raw waste
Composition
(ppm)
Sample 3 Sample 3

Antimony
Arsenic
Barium
Beryl lium
Cadmium
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Zinc

<10
2
20
<2
10
Ia
3,200
90
134
<1
7.300
<10
<2
<10
68
Duplicate
<10
5
45
<2
20
0.14
7,500
775
85
<1
4,900
<10
<2
<10
3.700
Treated
TCLP
(ma/D
Sample 3

.
0.020
<0.10
-
<0.020
-
0.63
-
<0.10
<0.0002
-
<0.40
0.16
-

sludqe


Sample 3
Duplicate

0.015
0.13
-
<0.020
-
0.15
-
<0.10
<0.0002
-
<0.20
<0.020
-

Source:  Table 6-13,  Onsite Engineering Report  for  Envirite Corporation, 1986.

al = Color interference.
                                                177

-------
                1984g
                                          Table E-2  Composition and TCLP Data for Lime  Stabilized Phosphated  Solids--F006
00
Raw waste
Constituents
Antimony
Arsenic
Barium
Beryllium
Cadm i urn
Chromium (hexavalent)
Chromium (total)
Copper
Lead
Mercury
Nickel
Selenium
Si Tver
Thallium
Zinc
Composition
(ppm)
Sample la Sample 2a
<0.4
28.8
-
0.37
-
1650
-
184
<0.2
11.8
<0.03
-
-
-
-
-
1.75
-
2625
187
365
-
17
-
-
-
3,687
Sample la
0.004
<0.002
-
<0.003
-
<0.020
-
<0.083
<0.0003
<0.006
<0.003
-
-
-
Treated sludqe
TCLP
(mg/1)
Sample 2a
-
-
0.03
-
0.11
0 11
0.47
-
0.13
-
-
-
0.30
Sample 3
-
-
0.06
-
0.09
1.17
0.41
-
0.45
-
-
-
1.45
Sample 4
-
-
0.04
-
0.08
0.09
0.25
-
0.72
-
-
-
1.78
                 Memo to Ron Turner,  EPA/HWERL  from R.D. Gritelueschen, John Deere Company, dated  15 January 1988.

-------
             1983g
                                                             Table E-3  Performance Data*  for Stabilization  of  F006 Waste
IO
Concentration (ppm)

Constituent




Arsenic



Barium



Cadmium



Chromium



Copper



Lead .




Stream




Untreated total
Untreated TCLP
Treated TCLP8
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP*
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP8
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP8
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP8
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP8
Treated TCLPb

1 2 3

Aircraft
Auto part overhaul
Unknown manufacture f ac 1 1 1 ty

<0.01 <0.01 <0.01
<0.01 <0.01 <0.01
<0.01 <0.01
36.4 21.6
0.08 0.32
0.12 0.50
0.42
1.3
0.01
0.01

1270
0.34
0.51
-
40.2 - 693
0.15 - 1.33
0.20 - 1.64
1.84
35.5
0.26
0.30

	 Sample
4
Aerospace
manufacture
mixture of
F006 ft F007
<0.01
<0.01
<0.01C
<0.01d
0.74
0.83
0.52C
1.18d
1.69
0.66
<0.01C
0.01d
12.9
7.58
0.40°
0.34d
18.6
4.12
0.23C
0.19d
11.4
6.86
O.ZOC
0.36d
Set i 	
5 6 7


Nickel plating Zinc
solution plating Unknown

<0.01
<0.01C <0.01 <0.01
<0.01 <0.01
1.5 - 14.3
0.21 - 0.38
0.9C - 0.31
0.23
0.97
0.69
<0.01C
-
2.0 1.10
0.3 0.02
0.08C 0.23
0.08
1.4
0.39
0.15C
.
16
10.1
0.21C
.

8 9 10

Small Circuit
engine board
manufacture manufacture Unknown
.
<0.01 <0.01 <0.01
<0.01 <0.01 <0.01
<0.01 <0.01 
-------
 19S3g
                                                                    Table E-3   (continued)
Concentration (ppm)
Sairole Set 1
Constituent Stream ] 2 3

Aircraft
Auto part overhaul
Unknown manufacture facility
Mercury Untreated total - -
Untreated TCLP <0.01 <0.01 <0 01
Treated TCLP8 <0.01 <0.01 <0.01
Treated TCLPb - <0.01 <0.01
Nickel Untreated total
Untreated TCLP
Treated TClPa
00 Treated TCLPb
O
Selenium Untreated total - -
Untreated TCLP <0.01 <0.01
Treated TUP* 0.06 0.06 0.07
Treated TCLPb - 0.11 Oil
Silver Untreated total 2.3
Untreated TCLP 0.01
Treated TCLPa 0.03
Treated TCLPb
Zinc Untreated total -
Untreated TCLP
Treated TCLP"
Treated TCLPb
4
Aerospace
manufacture
mixture of
F006 ft F007

0.003
<0.001C
<0.001d
234
158
4.35C
Z.47d
.
<0.01
0.17C
0.20d
6.26
1.64
0.09C
0.15d
8.86
2.28
0.05C
0.03d
5 67


Nickel plating Zinc
solution plating Unknown
16 16
10.1 10.1 <0.01
0 21° 0.21C <0.01
<0 01
3700
3950
0.02C
-
<0.01
0.01° 0.08 0.04
0.01 0.14
0.51
0.60
0.03C
16.0
10.8
0.01C
8 9 10 11

Small Circuit
engine board
manufacture manufacture Unknown Unknown

-•0.01 <0.01 <0.001 <0 001
<0.01 <0.01 <0.001 «0.001
<0.01 <0.01 <0 001 <0 001
-
-
_
-
<0.01 <0.01 <0.01 <0 45
0.05 0.04 0.07 <0.01
0.09 0.07 0.07 <0.01
19.1
<0 01
«0.01
<0.01
19.1
<0.01
<0.01
«0.01
Source:  CUM Technical Note 87-117.  Table 1.
* - F006 data not presented (n Section 3
aM1x ratio is 0.2
"Mix ratio Is 0.5 with the exception of Sample Set 16 in which mix ratio  is 1.0
cM1x ratio is 1.0
•fclx ration is 1.5
Binder type:   Cement Kiln dust

-------
                   Errata  - BOAT Treatment Standards  for K022
                                    Nonwastewaters                Wastewaters
Constituent                 Maximum for any single grab sample



Acetophenone
Phenol
Toluene
Sum of Oipheny lamine and
Diphenylnitrosaimne
Sulfide
Chromium (total)
Nickel
Total waste
concentration
(mg/kg)
19
12
0.034

13
Reserved
Not Appl icable
Not Appl icable
TCLP leachate
concentration
(rng/1)
Not Applicable
Not Appl icable
Not Appl icable
"No Land
Not Applicable Disposal"
Not Applicable
3.8
0.31
                                           U .:- ,  T""--'rnn^ontal  Protection Agency
                                           *:•  '     •     •  -jr.,,  f:,?L-l£}
                                           ?        >     •  • '  :    -ot,  R':gm 1670

-------