x>EPA United States Environmental Protection Agency Office of Solid Waste Washington, D C 20460 EPA/530-SW-88-0009-6 April 1988 Solid Waste Best Demonstrated Available Technology (BOAT) Background Document for K062 Proposed Volumes ------- EPA/530-SW-88-0009E Volume V BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT) BACKGROUND DOCUMENT FOR K062 (IRON AND STEEL INDUSTRY) U.S. Environmental Protection Agency Office of Solid Waste 401 M Street, S.W. Washington, D.C. 20460 James R. Berlow, Chief Treatment Technology Section John Keenan Project Manager April 1988 U.S. environmental Protection Agency Region 5, Library (PL-12J) 77 West Jackson Boulevard, 12th Floor Chicago, II 60604-3590 ------- BOAT Background Document for K062 Spent Pickle Liquor from the Steel Industry Table of Contents Section Page No, EXECUTIVE SUMMARY 1. INTRODUCTION 1 1.1 Legal Background 1 1.1.1 Requirements Under HSWA 1 1.1.2 Schedule for Developing Restrictions 4 1.2 Summary of Promulgated BOAT Methodology 5 1.2.1 Waste Treatabi 1 i ty Groups 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 ------- Table of Contents (Continued) Section Page 2. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION 46 2.1 Industries Affected and Process Description 46 2.2 Waste Characterization 48 3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES 59 3.1 Applicable Treatment Technologies 59 3.2 Demonstrated Treatment Technologies 61 3.2.1 Chromium Reduction 61 (1) Applicability and Use of This Technology 61 (2) Underlying Principles of Operation 62 (3) Description of Chromium Reduction Processes 63 (4) Waste Characteristics Affecting Performance 63 (5) Design and Operating Parameters 65 3.2.2 Chemical Precipitation 67 (1) Applicability and Use of Chemical Precipitation 67 (2) Underlying Principles of Operation 67 (3) Description of Chemical Precipitation .. 69 (4) Waste Characteristics Affecting Performance 72 (5) Design and Operating Parameters 77 3.2.3 Sludge Filtration 79 (1) Applicability and Use of This Technology 79 (2) Underlying Principles of Operation 80 (3) Description of Sludge Filtration 80 (4) Waste Characteristics Affecting Performance 81 (5) Design and Operating Variables That Affect Performance 82 3.2.4 High Temperature Metals Recovery 84 (1) Applicability and Use of This Technology 84 (2) Underlying Principles of Operation 85 (3) Description of High Temperature Metals Recovery Processes 87 (4) Waste Characteristics Affecting Performance 89 (5) Design and Operating Parameters 91 ------- Table of Contents (Continued) Section Page 3.2.5 Stabilization 92 (1) Applicability and Use of Stabilization . 93 (2) Underlying Principles of Operation 93 (3) Description of Stabilization Processes . 95 (4) Waste Characteristics Affecting Performance 96 (5) Design and Operating Parameters 97 3.3 Data Base 100 4. IDENTIFICATION OF BEST DEMONSTRATED AND AVAILABLE TECHNOLOGY FOR K062 114 4.1 Introduction 114 4.1.1 Wastewaters 114 4.1.2 Nonwastewaters 115 4.2 Determination of "Available" 115 4.3 BOAT for K062 Wastes 116 5. SELECTION OF REGULATED CONSTITUENTS 117 5.1 Introduction 117 5.2 Identification of Major Constituents in K062 . 117 5.3 Selection of Regulated Constituents 118 6. CALCULATION OF BOAT TREATMENT STANDARDS 127 6.1 Correction of Analytical Data 127 6.2 Calculation of Variability Factors and Treatment Standards 128 7. CONCLUSIONS 136 REFERENCES 141 APPENDICES Appendix A - Analysis of Variance Test and Variability Factor Calculation 144 Appendix B - Analytical Methods and QA/QC 158 Appendix C - Analytical Method for Determining Thermal Conductivity of a Waste 161 ------- List of Tables Table Page No. 1-1 BOAT Constituent List 18 2-1 to 2-5 Census Data (1982) for Number of Facilities in Each State and EPA Region 49 2-6 Number of Facilities in each EPA Region 54 2-7 Major Constituent Analysis-Untreated K062 Waste 56 2-8 BOAT List Constituent Composition 56 3-1 to 3-11 Summary of Treatment Performance Data for K062 -EPA Collected Data 103 5-1 BOAT Constituents List 120 6-1 Calculation of Corrected Values for Regulated Constituents - for Treated Wastewaters 130 6-2 Calculation of Corrected Values for Regulated Constituents - for Treated Nonwastewaters 132 6-3 Calculation of Treatment Standards for the Regulated Constituents - Treated Wastewaters 133 6-4 Calculation of Treatment Standards for the Regulated Constituents - Treated Nonwastewaters 135 7-1 BOAT Treatment Standards for Nonwastewater K062 Wastes ... 140 7-2 BOAT Treatment Standards for Wastewater K062 Wastes 140 ------- List of Figures Figure Page No. 2-1 Facilities Producing K062 Waste by EPA Region 55 2-2 Example of Continuous (Countercurrent) Pickling Process and Generation of K062 57 2-3 Example of Batch Pickling Process and Generation of K062 .. 58 3-1 Continuous Hexavalent Chromium Reduction System 64 3-2 Continuous Chemical Precipitation 70 3-3 Circular Clarifiers 73 3-4 Inclined Plate Settler 74 3-5 Example High Temperature Metals Recovery System 88 3-6 Schematic Diagram of Treatment Process for K062 Wastes 102 ------- Executive Summary BOAT Treatment Standards for K062 Pursuant to the Hazardous and Solid Waste Amendments (HSWA) enacted on November 8, 1984, and in accordance with the procedures for establishing treatment standards under Section 3004(m) of the Resource, Conservation, and Recovery Act (RCRA), the Environmental Protection Agency (EPA) is proposing treatment standards for the listed waste, K062, based on the performance of a treatment technology train (consisting of chromium reduction, chemical precipitation, and dewatering of the precipitate) determined by the Agency to represent Best Demonstrated Available Technology (BOAT). This background document provides the detailed analyses that support this determination of Best Demonstrated Available Technology (BOAT). These BOAT treatment standards represent maximum acceptable concentration levels for selected hazardous constituents in the wastes or residuals from the treatment process. The levels are established as a prerequisite for disposal of these wastes in units designated as land disposal units according to 40 CFR Part 268 (Code of Federal Regulations). Wastes that contain the regulated constituents at concentrations which do not exceed the treatment standards are not restricted from land disposal units. The Agency has chosen to set levels for these wastes rather than to designate the use of a specific technology. ------- These standards will become effective as of August 8, 1988, as described in the schedule set forth in 40 CFR 268.10. According to 40 CFR Part 261.32 (hazardous wastes from specific sources), waste code K062 is listed as spent pickle liquor generated by steel finishing operations of facilities within the iron and steel industry (SIC codes 331 and 332). Descriptions of the industry, the specific processes generating these wastes, and the physical and chemical waste characteristics are provided in Section 2.0 of this document. The Agency estimates that approximately 978 facilities have the potential to generate wastes identified as K062. The Agency has determined that K062 represents a single treatability group based on its physical and chemical composition. This group consists of two subgroups - wastewaters and nonwastewaters. For the purpose of the land disposal restrictions rule, wastewaters are defined as wastes containing less than 1 percent (weight basis) filterable solids and less than 1 percent (weight basis) total organic carbon (TOC). Wastes not meeting this definition are classified as nonwastewaters. While the Agency has not, at this time, specifically identified additional wastes that would fall into this treatability group or subgroup, this does not preclude the Agency from extrapolating these standards to other wastes in the future. K062 wastes, as generated, are spent pickling liquor having dissolved BOAT List metals, high water content, and low organic content. ------- The Agency has proposed BOAT treatment standards for the treatability subgroups of K062 wastes identified as wastewaters and nonwastewaters. In general, these treatment standards have been proposed for four metals that the Agency believes are indicators of effective treatment for all of the BOAT List hazardous constituents identified as typically present in K062 wastes. These regulated metals are chromium, copper, lead, and nickel. A detailed discussion of the selection of constituents to be regulated is presented in Section 5 of this document. BOAT treatment standards for wastewater and nonwastewater forms of K062 have been proposed based on the performance data using a chromium reduction, chemical precipitation, and precipitate dewatering treatment train. Wastewater standards are established for total concentration of four metals: chromium, copper, lead, and nickel. Nonwastewater standards are established for the Teachability of two metals, chromium and lead. The following table lists the specific BOAT treatment standards for K062 wastes. The Agency is setting standards based on analysis of the total composition of K062 wastewaters and analysis of leachate for K062 nonwastewaters. The leachate concentrations are obtained by the use of the Toxicity Characteristic Leaching Procedure (TCLP). The units for total concentration analysis are in parts per million (mg/1) on a weight by volume basis. The units for leachate analysis are also in parts per million (mg/1) on a weight by volume basis. Testing procedures are specifically identified in Appendix B. ------- 1556g BOAT Treatment Standards for Nonwastewater K062 Wastes Regulated metal constituents TCLP (mg/1) Chromium (total) 0.094 Lead 0.37 BOAT Treatment Standards for Wastewater K062 Wastes Regulated metal constituents Total concentration (mg/1) Chromium (total) 0.32 Copper 0.42 Lead 0.04 Nickel 0 44 ------- 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 1S84 (HSWA), enacted on November 8, 1984, and which amended the Resource Conservation and Recovery Act of 1976 (RCRA), impose substantial new responsibilities on those who handle hazardous waste. In particular, the amendments require the Agency to promulgate regulations that restrict the land disposal of untreated hazardous wastes. In its enactment of HSWA, Congress stated explicitly that "reliance on land disposal should be minimized or eliminated, and land disposal, particularly landfill and surface impoundment, should be the least favored method for managing hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C. 6901(b)(7)). One part of the amendments specifies dates on which particular groups of untreated hazardous wastes will be prohibited from land disposal unless "it has been demonstrated to the Administrator, to a reasonable degree of certainty, that there will be no migration of hazardous constituents from the disposal unit or injection zone for as long as the wastes remain hazardous" (RCRA section 3004(d)(l), (e)(l), (g)(5), 42 U.S.C. 6924 (d)(l), (e)(l), (g)(5)). ------- For the purpose of the restrictions, HSWA defines land disposal "to include, but not be limited to, any placement of ... hazardous waste in a landfill, surface impoundment, waste pile, injection well, land treatment facility, salt dome formation, salt bed formation, or underground mine or cave" (RCRA section 3004(k), 42 U.S.C. 6924(k)). Although HSWA defines land disposal to include injection wells, such disposal of solvents, dioxins, and certain other wastes, known as the California List wastes, is covered on a separate schedule (RCRA section 3004(f)(2), 42 U.S.C. 6924 (f)(2)). This schedule requires that EPA develop land disposal restrictions for deep well injection by August 8, 1988. The amendments also require the Agency to set "levels or methods of treatment, if any, which substantially diminish the toxicity of the waste or substantially reduce the likelihood of migration of hazardous constituents from the waste so that short-term and long-term threats to human health and the environment are minimized" (RCRA section 3004(m)(l), 42 U.S.C. 6924 (m)(l)). Wastes that meet treatment standards established by EPA are not prohibited and may be land disposed. In setting treatment standards for listed or characteristic wastes, EPA may establish different standards for particular wastes within a single waste code with differing treatability characteristics. One such characteristic is the physical form of the waste. This frequently leads to different standards for wastewaters and nonwastewaters. ------- alternatively, EPA can establish a treatment standard that is applicable to more than one waste code when, in EPA's judgment, all the waste can be treated to the same concentration. In those instances where a generator can demonstrate that the standard promulgated for the generator's waste cannot be achieved, the Agency also can grant a variance from a treatment standard by revising the treatment standard for that particular waste through rulemaking procedures. (A further discussion of treatment variances is provided in Section 1.3.) The land disposal restrictions are effective when promulgated unless the Administrator grants a national variance and establishes a different date (not to exceed 2 years beyond the statutory deadline) based on "the earliest date on which adequate alternative treatment, recovery, or disposal capacity which protects human health and the environment will be available" (RCRA section 3004(h)(2), 42 U.S.C. 6924 (h)(2)). If EPA fails to set a treatment standard by the statutory deadline for any hazardous waste in the First Third or Second Third of the schedule (see section 1.1.2), the waste may not be disposed in a landfill or surface impoundment unless the facility is in compliance with the minimum technological requirements specified in section 3004(o) of RCRA. In addition, prior to disposal, the generator must certify to the Administrator that the availability of treatment capacity has been investigated and it has been determined that disposal in a landfill or surface impoundment is the only practical alternative to treatment currently available to the generator. This restriction on the use of ------- landfills and surface impoundments applies until EPA sets a treatment standard for the waste or until May 8, 1990, whichever is sooner. If the Agency fails to set a treatment standard for any ranked hazardous waste by May 8, 1990, the waste is automatically prohibited from land disposal unless the waste is placed in a land disposal unit that is the subject of a successful "no migration" demonstration (RCRA section 3004(g), 42 U.S.C. 6924(g)). "No migration" demonstrations are based on case- specific petitions that show there will be no migration of hazardous constituents from the unit for as long as the waste remains hazardous. 1.1.2 Schedule for Developing Restrictions Under Section 3004(g) of RCRA, EPA was required to establish a schedule for developing treatment standards for all wastes that the Agency had listed as hazardous by November 8, 1984. Section 3004(g) required that this schedule consider the intrinsic hazards and volumes associated with each of these wastes. The statute required EPA to set treatment standards according to the following schedule: (a) Solvents and dioxins standards must be promulgated by November 8, 1986; (b) The "California List" must be promulgated by July 8, 1987; (c) At least one-third of all listed hazardous wastes must be promulgated by August 8, 1988 (First Third); (d) At least two-thirds of all listed hazardous wastes must be promulgated by June 8, 1989 (Second Third); and (e) All remaining listed hazardous wastes and all hazardous wastes identified as of November 8, 1984, by one or more of the characteristics defined in 40 CFR Part 261 must be promulgated by May 8, 1990 (Third Third). ------- The statute specifically identified the solvent wastes as those covered under waste codes F001, F002, F003, F004, and F005; it identified the dioxin-containing hazardous wastes as those covered under waste codes F020, F021, F022, and F023. Wastes collectively known as the California List wastes, defined under Section 3004(d) of HSWA, are liquid hazardous wastes containing metals, free cyanides, PCBs, corrosives (i.e., a pH less than or equal to 2.0), and any liquid or nonliquid hazardous waste containing hafagenated organic compounds (HOCs) above 0.1 percent by weight. Rules for the California List were proposed on December 11, 1986, and final rules for PCBs, corrosives, and HOC-containing wastes were established August 12, 1987. In that rule, EPA elected not to establish standards for metals. Therefore, the statutory limits became effective. On May 28, 1986, EPA published a final rule (51 FR 19300) that delineated the specific waste codes that would be addressed by the First Third, Second Third, and Third Third. This schedule is incorporated into 40 CFR 268.10, .11, and .12. 1.2 Summary of Promulgated 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 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 Groups In developing the treatment standards, EPA first characterizes the waste(s). As necessary, EPA may establish treatability groups for wastes having similar physical and chemical properties. That is, if EPA believes that wastes represented by different waste codes could be treated to similar concentrations using identical technologies, the Agency combines the codes into one treatability group. EPA generally considers wastes to be similar when they are both generated from the same industry and from similar processing stages. In addition, EPA may combine two or more separate wastes into the same treatability group when data are available showing that the waste characteristics affecting performance are similar or that one waste would be expected to be less difficult to treat. Once the treatability groups have been established, EPA collects and analyzes data on identified technologies used to treat the wastes in each treatability group. The technologies evaluated must be demonstrated on the waste or a similar waste and must be available for use. 1.2.2 Demonstrated and Available Treatment Technologies Consistent with legislative history, EPA considers demonstrated technologies to be those that are used to treat the waste of interest or a similar waste with regard to parameters that affect treatment selection (see November 7, 1986, 51 FR 40588). EPA also will consider as treatment those technologies used to separate or otherwise process chemicals and ------- other materials. Some of these technologies clearly are applicable to waste treatment, since the wastes are similar to raw materials processed in industrial applications. For most of the waste treatability groups for which EPA will promulgate treatment standards, EPA will identify demonstrated technologies either through review of literature related to current waste treatment practices or on the basis of information provided by specific facilities currently treating the waste or similar wastes. In cases where the Agency does not identify any facilities treating wastes represented by a particular waste treatability group, EPA may transfer a finding of demonstrated treatment. To do this, EPA will compare the parameters affecting treatment selection for the waste treatability group of interest to other wastes for which demonstrated technologies already have been determined. The parameters affecting treatment selection and their use for this waste are described in Section 3.2 of this document. If the parameters affecting treatment selection are similar, then the Agency will consider the treatment technology also to be demonstrated for the waste of interest. For example, EPA considers rotary kiln incineration a demonstrated technology for many waste codes containing hazardous organic constituents, high total organic content, and high filterable solids content, regardless of whether any facility is currently treating these wastes. The basis for this determination is data found in literature and data generated by EPA confirming the use of rotary kiln incineration on wastes having the above characteristics. 8 ------- If no commercial treatment or recovery operations are identified for a waste or wastes with similar physical or chemical characteristics that affect treatment selection, the Agency will be unable to identify any demonstrated treatment technologies for the waste, and, accordingly, the waste will be prohibited from land disposal (unless handled in accordance with the exemption and variance provisions of the rule). The Agency is, however, committed to establishing treatment standards as soon as new or improved treatment processes are demonstrated (and available). Operations only available at research facilities, pilot- and bench- scale operations will not be considered in identifying demonstrated treatment technologies for a waste because these technologies would not necessarily be "demonstrated." Nevertheless, EPA may use data generated at research facilities in assessing the performance of demonstrated technologies. As discussed earlier, Congress intended that technologies used to establish treatment standards under Section 3004(m) be not only "demonstrated," but also available. To decide whether demonstrated technologies may be considered "available," the Agency determines whether they (1) are commercially available and (2) substantially diminish the toxicity of the waste or substantially reduce the likelihood of migration of hazardous constituents from the waste. EPA will only set treatment standards based on a technology that meets the above criteria. Thus, the decision to classify a technology as "unavailable" will have a direct impact on the treatment standard. If ------- the best technology is unavailable, the treatment standard will be based on the next best treatment technology determined to be available. To the extent that the resulting treatment standards are less stringent, greater concentrations of hazardous constituents in the treatment residuals could be placed in land disposal units. There also may be circumstances in which EPA concludes that for a given waste none of the demonstrated treatment technologies are "available" for purposes of establishing the 3004(m) treatment performance standards. Subsequently, these wastes will be prohibited from continued placement in or on the land unless managed in accordance with applicable exemptions and variance provisions. The Agency is, however, committed to establishing new treatment standards as soon as new or improved treatment processes become "available." (1) Proprietary or patented processes. If the demonstrated treatment technology is a proprietary or patented process that is not generally available, EPA will not consider the technology in its determination of the treatment standards. EPA will consider proprietary or patented processes available if it determines that the treatment method can be purchased or licensed from the proprietor or is commercially available treatment. The services of the commercial facility offering this technology often can be purchased even if the technology itself cannot be purchased. (2) Substantial treatment. To be considered "available," a demonstrated treatment technology must "substantially diminish the 10 ------- toxicity" of the waste or "substantially reduce the likelihood of migration of hazardous constituents" from the waste in accordance with section 3004(m). By requiring that substantial treatment be achieved in order to set a treatment standard, the statute ensures that all wastes are adequately treated before being placed in or on the land and ensures that the Agency does not require a treatment method that provides little or no environmental benefit. Treatment will always be deemed substantial if it results in nondetectable levels of the hazardous constituents of concern. If nondetectable levels are not achieved, then a determination of substantial treatment will be made on a case-by-case basis. This approach is necessary because of the difficulty of establishing a meaningful guideline that can be applied broadly to the many wastes and technologies to be considered. EPA will consider the following factors in an effort to evaluate whether a technology provides substantial treatment on a case-by-case basis: (a) Number and types of constituents treated; (b) Performance (concentration of the constituents in the treatment residuals); and (c) Percent of constituents removed. If none of the demonstrated treatment technologies achieve substantial treatment of a waste, the Agency cannot establish treatment standards for the constituents of concern in that waste. 1.2.3 Collection of Performance Data Performance data on the demonstrated available technologies are evaluated by the Agency to determine whether the data are representative 11 ------- of well-designed and well-operated treatment systems. Only data from well-designed and well-operated systems are included in determining BOAT. The data evaluation includes data already collected directly by EPA and/or data provided by industry. In those instances where additional data are needed to supplement existing information, EPA collects additional data through a sampling and analysis program. The principal elements of this data collection program are: (a) identifi- cation of facilities for site visits, (b) engineering site visit, (c) Sampling and Analysis Plan, (d) sampling visit, and (e) Onsite Engineering Report. (1) Identification of facilities for site visits. To identify facilities that generate and/or treat the waste of concern, EPA uses a number of information sources. These include Stanford Research Institute's Directory of Chemical Producers, EPA's Hazardous Waste Data Management System (HWDMS), the 1986 Treatment, Storage, Disposal Facility (TSDF) National Screening Survey, and EPA's Industry Studies Data Base. In addition, EPA contacts trade associations to inform them that the Agency is considering visits to facilities in their industry and to solicit assistance in identifying facilities for EPA to consider in its treatment sampling program. After identifying facilities that treat the waste, EPA uses this hierarchy to select sites for engineering visits: (1) generators treating single wastes on site; (2) generators treating multiple wastes together on site; (3) commercial treatment, storage, and disposal facilities 12 ------- (TSDFs); and (4) EPA in-house treatment. This hierarchy is based on two concepts: (1) to the extent possible, EPA should develop treatment standards from data produced by treatment facilities handling only a single waste, and (2) facilities that routinely treat a specific waste have had the best opportunity to optimize design parameters. Although excellent treatment can occur at many facilities that are not high in this hierarchy, EPA has adopted this approach to avoid, when possible, ambiguities related to the mixing of wastes before and during treatment. When possible, the Agency will evaluate treatment technologies using commercially operated systems. If performance data from properly designed and operated commercial treatment methods for a particular waste or a waste judged to be similar are not available, EPA may use data from research facilities operations. Whenever research facility data are used, EPA will explain why such data were used in the preamble and background document and will request comments on the use of such data. Although EPA's data bases provide information on treatment for individual wastes, the data bases rarely provide data that support the selection of one facility for sampling over another. In cases where several treatment sites appear to fall into the same level of the hierarchy, EPA selects sites for visits strictly on the basis of which facility could most expeditiously be visited and later sampled if justified by the engineering visit. 13 ------- (2) Engineering site visit. Once a treatment facility has been selected, an engineering site visit is made to confirm that a candidate for sampling meets EPA's criteria for a well-designed facility and to ensure that the necessary sampling points can be accessed to determine operating parameters and treatment effectiveness. During the visit, EPA also confirms that the facility appears to be well operated, although the actual operation of the treatment system during sampling is the basis for EPA's decisions regarding proper operation of the treatment unit. In general, the Agency considers a well-designed facility to be one that contains the unit operations necessary to treat the various hazardous constituents of the waste as well as to control other nonhazardous materials in the waste that may affect treatment performance. In addition to ensuring that a system is reasonably well designed, the engineering visit examines whether the facility has a way to measure the operating parameters that affect performance of the treatment system during the waste treatment period. For example, EPA may choose not to sample a treatment system that operates in a continuous mode, for which an important operating parameter cannot be continuously recorded. In such systems, instrumentation is important in determining whether the treatment system is operating at design values during the waste treatment period. (3) Sampling and Analysis Plan. If after the engineering site visit the Agency decides to sample a particular plant, the Agency will then develop a site-specific Sampling and Analysis Plan (SAP) according to the Generic Quality Assurance Project Plan for the Land Disposal Restriction 14 ------- Program ("BOAT"), EPA/530-SW-87-011. In brief, the SAP discusses where the Agency plans to sample, how the samples will be taken, the frequency of sampling, the constituents to be analyzed and the method of analysis, operational parameters to be obtained, and specific laboratory quality control checks on the analytical results. The Agency will generally produce a draft of the site-specific Sampling and Analysis Plan within 2 to 3 weeks of the engineering visit. The draft of the SAP is then sent to the plant for review and comment. With few exceptions, the draft SAP should be a confirmation of data collection activities discussed with the plant personnel during the engineering site visit. EPA encourages plant personnel to recommend any modifications to the SAP that they believe will improve the quality of the data. It is important to note that sampling of a plant by EPA does not mean that the data will be used in the development of treatment standards for BOAT. EPA's final decision on whether to use data from a sampled plant depends on the actual analysis of the waste being treated and on the operating conditions at the time of sampling. Although EPA would not plan to sample a facility that was not ostensibly well-designed and well-operated, there is no way to ensure that at the time of the sampling the facility will not experience operating problems. Additionally, EPA statistically compares its test data to suitable industry-provided data, where available, in its determination of what data to use in developing treatment standards. The methodology for comparing data is presented later in this section. 15 ------- (Note: Facilities wishing to submit data for consideration in the development of BOAT standards should, to the extent possible, provide sampling information similar to that acquired by EPA. Such facilities should review the Generic Quality Assurance Project Plan for the Land Disposal Restriction Program ("BOAT"), which delineates all of the quality control and quality assurance measures associated with sampling and analysis. Quality assurance and quality control procedures are summarized in Section 1.2.6 of this document.) (4) Sampling visit. The purpose of the sampling visit is to collect samples that characterize the performance of the treatment system and to document the operating conditions that existed during the waste treatment period. At a minimum, the Agency attempts to collect sufficient samples of the untreated waste and solid and liquid treatment residuals so that variability in the treatment process can be accounted for in the development of the treatment standards. To the extent practicable, and within safety constraints, EPA or its contractors collect all samples and ensure that chain-of-custody procedures are conducted so that the integrity of the data is maintained. In general, the samples collected during the sampling visit will have already been specified in the SAP. In some instances, however, EPA will not be able to collect all planned samples because of changes in the facility operation or plant upsets; EPA will explain any such deviations from the SAP in its follow-up Onsite Engineering Report. 16 ------- (5) Qnsite Engineering Report. EPA summarizes all its data collection activities and associated analytical results for testing at a facility in a report referred to as the Onsite Engineering Report (OER). This report characterizes the waste(s) treated, the treated residual concentrations, the design and operating data, and all analytical results including methods used and accuracy results. This report also describes any deviations from EPA's suggested analytical methods for hazardous wastes (Test Methods for Evaluating Solid Waste, SW-846, Third Edition, November 1986). After the Onsite Engineering Report is completed, the report is submitted to the plant for review. This review provides the plant with a final opportunity to claim any information contained in the report as confidential. Following the review and incorporation of comments, as appropriate, the report is made available to the public with the exception of any material claimed as confidential by the plant. 1.2.4 Hazardous Constituents Considered and Selected for Regulation (1) Development of 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, Appendix VII and Appendix VIII, as well as several ignitable constituents used as the basis of listing wastes as F003 and F005. These sources provide a comprehensive list of hazardous constituents specifically regulated under RCRA. The 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 Acetonitn le Acrolein Acrylonitri le Benzene Bromodichloromethane Bromomethane n-Butyl alcohol Carbon tetrachloride Carbon disulfide Chlorobenzene 2-Chloro-l ,3-butadiene Chlorodlbromomethane Chloroethane 2-Chloroethyl vinyl ether Chloroform Chloromethane 3-Chloropropene 1 , 2-Dibromo-3-chloropropane 1 , 2-Dibromoethane Dibromomethane Trans- 1 ,4-Oichloro-2-butene Dichlorodif luoromethane 1 , 1-Dichloroethane 1,2-Dichloroethane 1 , 1-Dichloroethy lene Trans -1,2-Dichloroethene 1,2-Oichloropropane 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 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 ------- 1521g Table 1-1 (continued) BOAT reference no. 33. 228. 34. 229. 35. 37. 38. 230. 39. 40. 41. 42. 43. 44. 45. 46. 47. 48. 49. 231. 50. 215. 216. 217. 51. 52. 53. 54. 55. 56. 57. 58. 59. 218. 60. 61. 62. Parameter Volatiles (continued) Isobutyl alcohol Methanol Methyl ethyl ketone Methyl isobutyl ketone Methyl methacry late Methacrylonitrile Methylene chloride 2-Nitropropane Pyridine 1,1,1, 2-Tetrachloroethane 1 , 1 ,2, 2-Tetrachloroethane Tetrachloroethene Toluene Tnbromomethane 1,1 ,1-Trichloroethane 1 , 1 ,2-Trichloroethane Tnchloroethene Trichloromonof luoromethane 1 , 2 , 3-Trlch loropropane l,l,2-Trichloro-l,2,2-trif luoro- ethane Vinyl chloride 1,2-Xylene 1,3-Xylene 1,4-Xylene Semivolat i les Acenaphthalene Acenaphthene Acetophenone 2 -Acety lam inof luorene 4-Aminobiphenyl An i 1 me Anthracene Aramite Benz(a)anthracene Benzal chloride Benzenethiol Deleted Benzo(a)pyrene CAS no. 78-83-1 67-56-1 78-93-3 108-10-1 80-62-6 126-98-7 75-09-2 79-46-9 110-86-1 630-20-6 79-34-6 127-18-4 108-88-3 75-25-2 71-55-6 79-00-5 79-01-6 75-69-4 96-18-4 76-13-1 75-01-4 97-47-6 108-38-3 106-44-5 208-96-8 83-32-9 96-86-2 53-96-3 92-67-1 62-53-3 120-12-7 140-57-8 56-55-3 98-87-3 108-98-5 50-32-8 19 ------- 1521g Table 1-1 (continued) BOAT reference no 63 64. 65. 66. 67 68. 69. 70. 71. 72. 73. 74. 75. 76. 77. 78. 79. 80. 81. 82. 232. 83. 84. 85. 86. 87 88. 89. 90. 91. 92. 93. 94. 95. 96. 97. 98. 99. 100. 101. Parameter Semwolatiles (continued) Benzo(b)f luoranthene Benzo(ghi)perylene Benzo(k)f luoranthene p-Benzoquinone B i s ( 2-ch loroethoxy (methane Bis(2-chloroethyl)ether Bis(2-chloroisopropy 1 )ether Bis(2-ethylhexyl)phthalate 4-Bromophenyl phenyl ether Butyl benzyl phthalate 2-sec-Butyl-4,6-dinitrophenol p-Chloroani 1 ine Chlorobenzi late p-Chloro-m-cresol 2-Chloronaphthalene 2-Chlorophenol 3-Chloropropionitri le Chrysene ortho-Cresol para-Cresol Cyclohexanone 0 1 benz ( a , h ) anthracene Dibenzo(a,e)pyrene Dibenzo(a, i)pyrene m-Dichlorobenzene o-Oichlorobenzene p-Oichlorobenzene 3,3 '-Dichlorobenzidine 2,4-Oichlorophenol 2,6-Dichlorophenol Diethyl phthalate 3,3'-Dimethoxybenzidine p-Dimethylaminoazobenzene 3 ,3 '-Dimethylbenzidine 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 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-Dinitrotol uene 2, 6-Dinitrotoluene Di-n-octyl phthalate Di-n-propy Initrosamine Diphenylamine D i pheny 1 n i t rosami ne 1,2-Oiphenylhydrazine Fluoranthene Fluorene Hexach lorobenzene Hexachlorobutadiene Hexachlorocyc lopentadlene Hexach loroethane Hexach lorophene Hexach loropropene Indeno( 1 ,2,3-cd)pyrene Isosafrole Methapyri lene 3-Methy Icho lanthrene 4,4'-Methylenebis (2-chloroani line) Methyl methanesulfonate Naphthalene 1,4-Naphthoquinone 1-Naphthylamine 2-Naphthylamine p-Nitroani line Nitrobenzene 4-Nitrophenol N-Nitrosodi-n-butylamine N-Nitrosodiethylamme N-Nitrosodimethylamine N-Nitrosomethylethylamine N-Nitrosomorphol me N-Nitrosopipendine n-Nitrosopyrrol idme 5-Nitro-o-toluidine Pentach lorobenzene Pentach loroethane Pentach loron i trobenzene 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 Semwolati les (continued) Pentach loropheno 1 Phenacetin Phenanthrene Phenol Phthalic anhydride 2-Picoline Pronamide Pyrene Resorcinol Safrole 1 , 2,4,5-Tetrachlorobenzene 2,3,4, 6-Tet rach loropheno 1 1,2,4-Trich lorobenzene 2, 4, 5-Trich loropheno 1 2, 4, 6-Tnch loropheno 1 Tris(2,3-dibromopropyl) phosphate Metals Antimony Arsenic Barium Beryllium Cadmium Chromium (total) Chromium (hexavalent) Copper Lead Mercury Nickel Selenium Silver Thai 1 lum Vanadium Zinc Inorganics Cyanide Fluoride Sulf ide 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 Aldr in alpha-BHC beta-BHC delta-BHC gamma-BHC Chlordane ODD DDE DOT Dieldrin Endosulfan I Endosulfan II Endrin Endrin aldehyde Heptachlor Heptachlor epoxide Isodrin Kepone Methoxyclor Toxaphene Phenoxyacetic acid herbicides 2,4-Oichlorophenoxyacetic acid Si Ivex 2.4,5-T Orqanoohosphorous insecticides Oisulfoton Famphur Methyl parathion Parathion Phorate PCBjs 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. rio PCBs (continued) 203. Aroclor 1242 53469-21-9 204 Aroclor 1248 12672-29-6 205. Aroclor 1254 11097-69-1 206. Aroclor 1260 11096-82-5 Oioxins and furans 207. Hexachlorodibenzo-p-dioxins 208. Hexachlorodibenzofurans 209. Pentachlorodibenzo-p-dioxins 210. Pentachlorodibenzofurans 211. Tetrachlorodibenzo-p-dioxins 212 Tetrachlorodlbenzofurans 213. 2,3,7,8-Tetrachlorodibenzo-p-dioxin 1746-01-6 24 ------- The initial BOAT constituent list was published in EPA's Generic Quality Assurance Project Plan, March 1987 (EPA/530-SW-87-011). Additional constituents will be added to the BOAT constituent list as additional key constituents are identified for specific waste codes or as new analytical methods are developed for hazardous constituents. For example, since the list was published in March 1987, eighteen additional constituents (hexavalent chromium, xylene (all three isomers), benzal chloride, phthalic anhydride, ethylene oxide, acetone, n-butyl alcohol, 2-ethoxyethanol, ethyl acetate, ethyl benzene, ethyl ether, methanol, methyl isobutyl ketone, 2-nitropropane, 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 why constituents were not included on the BOAT constituent list: (a) Constituents are unstable. Based on their chemical structure, some constituents will either decompose in water or will ionize. For example, maleic anhydride will form maleic acid when it comes in contact with water and copper cyanide will ionize to form copper and cyanide ions. However, EPA may choose to regulate the decomposition or ionization products. (b) EPA-approved or verified analytical methods are not available. Many constituents, such as 1,3,5-trinitrobenzene, are not measured adequately or even detected using any of EPA's analytical methods published in SW-846 Third Edition. (c) The constituent is a member of a chemical group designated in Appendix VIII as not otherwise specified (N.O.S.). Constituents listed as N.O.S., such as chlorinated phenols, are a generic group of some types of chemicals for which a single analytical procedure is not available. The individual members of each such group need to be listed to determine whether the constituents can be analyzed. For each N.O.S. group, all those constituents that can be readily analyzed are included in the BOAT constituents list. (d) Available analytical procedures are not appropriate for a complex waste matrix. Some compounds, such as auramine, can be analyzed as a pure constituent. However, in the presence of other constituents, the recommended analytical method does not positively identify the constituent. The use of high pressure liquid chromotography (HPLC) presupposes a high expectation of finding the specific constituents of interest. In using this procedure to screen samples, protocols would have to be developed on a case-specific basis to verify the identity of constituents present in the samples. Therefore, HPLC is not an appropriate analytical procedure for complex samples containing unkown constituents. (e) Standards for analytical instrument calibration are not commercially available. For several constituents, such as benz(c)acridine, commercially available standards of a "reasonably" pure grade are not available. The unavailability of a standard was determined by a review of catalogs from specialty chemical manufacturers. 26 ------- Two constituents (fluoride and sulfide) are not specifically included in Appendices VII and VIII; however, these compounds are included on the BOAT list as indicator constituents for compounds from Appendices VII and VIII such as hydrogen fluoride and hydrogen sulfide, which ionize in water. The BOAT constituent list presented in Table 1-1 is divided into the following nine groups: Volatile organics Semivolatile organics Metals Other inorganics Organochlorine pesticides Phenoxyacetic acid herbicides Organophosphorous insecticides PCBs Dioxins and furans. The constituents were placed in these categories based on their chemical properties. The constituents in each group are expected to behave similarily during treatment and are also analyzed, with the exception of the metals and inorganics, by using the same analytical methods. (2) Constituent selection analysis. The constituents that the Agency selects for regulation in each treatability group are, in general, those found in the untreated wastes at treatable concentrations. For certain waste codes, the target list for the untreated waste may have been shortened (relative to analyses performed to test treatment technologies) because of the extreme unlikelihood of the constituent being present. 27 ------- In selecting constituents for regulation, the first step is to summarize all the constituents that were found in the untreated waste at treatable concentrations. This process involves the use of the statistical analysis of variance (ANOVA) test, described in Section 1.2.6, to determine if constituent reductions were significant. The Agency interprets a significant reduction in concentration as evidence that the technology actually "treats" the waste. There are some instances where EPA may regulate constituents that are not found in the untreated waste but are detected in the treated residual. This is generally the case where presence of the constituents in the untreated waste interferes with the quantification of the constituent of concern. In such instances, the detection levels of the constituent are relatively high, resulting in a finding of "not detected" when, in fact, the constituent is present in the waste. After determining which of the constituents in the untreated waste are present at treatable concentrations, EPA develops a list of potential constituents for regulation. The Agency then reviews this list to determine if any of these constituents can be excluded from regulation because they would be controlled by regulation of other constituents in the list. EPA performs this indicator analysis for two reasons: (1) it reduces the analytical cost burdens on the treater and (2) it facilitates implementation of the compliance and enforcement program. EPA's rationale for selection of regulated constituents for this waste code is presented in Section 5 of this background document. 28 ------- (3) Calculation of standards. The final step in the calculation of the BOAT treatment standard is the multiplication of the average treatment value by a factor referred to by the Agency as the variability factor. This calculation takes into account that even well-designed and well-operated treatment systems will experience some fluctuations in performance. EPA expects that fluctuations will result from inherent mechanical limitations in treatment control systems, collection of treated samples, and analysis of these samples. All of the above fluctuations can be expected to occur at well-designed and well-operated treatment facilities. Therefore, setting treatment standards utilizing a variability factor should be viewed not as a relaxing of 3004(m) requirements, but rather as a function of the normal variability of the treatment processes. A treatment facility will have to be designed to meet the mean achievable treatment performance level to ensure that the performance levels remain within the limits of the treatment standard. The Agency calculates a variability factor for each constituent of concern within a waste treatability group using the statistical calculation presented in Appendix A. The equation for calculating the variability factor is the same as that used by EPA for the development of numerous regulations in the Effluent Guidelines Program under the Clean Water Act. The variability factor establishes the instantaneous maximum based on the 99th percent!le value. There is an additional step in the calculation of the treatment standards in those instances where the ANOVA analysis shows that more 29 ------- than one technology achieves a level of performance that represents BOAT. In such instances, the BOAT treatment standard is calculated by first averaging the mean performance value for each technology for each constituent of concern and then multiplying that value by the highest variability factor among the technologies considered. This procedure ensures that all the BOAT technologies used as the basis for the standards will achieve full compliance. 1.2.5 Compliance with Performance Standards All the treatment standards reflect performance achieved by the Best Demonstrated Available Technology (BOAT). As such, compliance with these standards only requires that the treatment level be achieved prior to land disposal. It does not require the use of any particular treatment technology. While dilution of the waste as a means to comply with the standard is prohibited, wastes that are generated in such a way as to naturally meet the standard can be land disposed without treatment. With the exception of treatment standards that prohibit land disposal, all treatment standards proposed are expressed as a concentration level. EPA has used both total constituent concentration and TCLP analyses of the treated waste as a measure of technology performance. EPA's rationale for when each of these analytical tests is used is explained in the following discussion. For all organic constituents, EPA is basing the treatment standards on the total constituent concentration found in the treated waste. EPA based its decision on the fact that technologies exist to destroy the 30 ------- various organics compounds. Accordingly, the best measure of performance would be the extent to which the various organic compounds have been destroyed or the total amount of constituent remaining after treatment. (NOTE: EPA's land disposal restrictions for solvent waste codes F001-F005 (51 FR 40572) uses the TCLP value as a measure of performance. At the time that EPA promulgated the treatment standards for F001-F005, useful data were not available on total constituent concentrations in treated residuals and, as a result, the TCLP data were considered to be the best measure of performance.) For all metal constituents, EPA is using both total constituent concentration and/or the TCLP as the basis for treatment standards. The total constituent concentration is being used when the technology basis includes a metal recovery operation. The underlying principle of metal recovery is the reduction of the amount of metal in a waste by separating the metal for recovery; therefore, total constituent concentration in the treated residual is an important measure of performance for this technology. Additionally, EPA also believes that it is important that any remaining metal in a treated residual waste not be in a state that is easily Teachable; accordingly, EPA is also using the TCLP as a measure of performance. It is important to note that for wastes for which treatment standards are based on a metal recovery process, the facility has to comply with both the total constituent concentration and the TCLP prior to land disposal. 31 ------- In cases where treatment standards for metals are not based on recovery techniques but rather on stabilization, EPA is using only the TCLP as a measure of performance. The Agency's rationale is that stabilization is not meant to reduce the concentration of metal in a waste but only to chemically minimize the ability of the metal to leach. 1.2.6 Identification of BOAT (1) Screening of treatment data. This section explains how the Agency determines which of the treatment technologies represent treatment by BOAT. The first activity is to screen the treatment performance data from each of the demonstrated and available technologies according to the following criteria: (a) Design and operating data associated with the treatment data must reflect a well-designed, well-operated system for each treatment data point. (The specific design and operating parameters for each demonstrated technology for this waste code are discussed in Section 3.2 of this document.) (b) Sufficient QA/QC data must be available to determine the true values of the data from the treated waste. This screening criterion involves adjustment of treated data to take into account that the type value may be different from the measured value. This discrepancy generally is caused by other constituents in the waste that can mask results or otherwise interfere with the analysis of the constituent of concern. (c) The measure of performance must be consistent with EPA's approach to evaluating treatment by type of constituents (e.g., total concentration data for organics, and total concentration and TCLP for metals in the leachate from the residual). In the absence of data needed to perform the screening analysis, EPA will make decisions on a case-by-case basis of whether to include the data. The factors included in this case-by-case analysis will be the 32 ------- actual treatment levels achieved, the availability of the treatment data and their completeness (with respect to the above criteria), and EPA's assessment of whether the untreated waste represents the waste code of concern. EPA's application of these screening criteria for this waste code are provided in Section 4 of this background document. (2) Comparison of treatment data. In cases in which EPA has treatment data from more than one technology following the screening activity, EPA uses the statistical method known as analysis of variance (ANOVA) to determine if one technology performs significantly better. This statistical method (summarized in Appendix A) provides a measure of the differences between two data sets. If EPA finds that one technology performs significantly better (i.e., the data sets are not homogeneous), BOAT treatment standards are the level of performance achieved by the best technology multiplied by the corresponding variability factor for each regulated constituent. If the differences in the data sets are not statistically significant, the data sets are said to be homogeneous. Specifically, EPA uses the analysis of variance to determine whether BOAT represents a level of performance achieved by only one technology or represents a level of performance achieved by more than one (or all) of the technologies. If the Agency finds that the levels of performance for one or more technologies are not statistically different, EPA averages the performance values achieved by each technology and then multiplies this value by the largest variability factor associated with any of the 33 ------- acceptable technologies. A detailed discussion of the treatment selection method and an example of how EPA chooses BOAT from multiple treatment systems is provided in Section A-l. (3) Quality assurance/aualitv control. This section presents the principal quality assurance/quality control (QA/QC) procedures employed in screening and adjusting the data to be used in the calculation of treatment standards. Additional QA/QC procedures used in collecting and screening data for the BOAT program are presented in EPA's Generic Quality Assurance Project Plan for Land Disposal Restrictions Program ("BOAT") (EPA/530-SW-87-001, March 1987). To calculate the treatment standards for the Land Disposal Restriction Rules, it is first necessary to determine the recovery value for each constituent (the amount of constituent recovered after spiking, which is the addition of a known amount of the constituent, minus the initial concentration in the samples divided by the amount added) for a spike of the treated residual. Once the recovery value is determined, the following procedures are used to select the appropriate percent recovery value to adjust the analytical data: (a) If duplicate spike recovery values are available for the constituent of interest, the data are adjusted by the lowest available percent recovery value (i.e., the value that will yield the most conservative estimate of treatment achieved). However, if a spike recovery value of less than 20 percent is reported for a specific constituent, the data are not used to set treatment standards because the Agency does not have sufficient confidence in the reported value to set a national standard. 34 ------- (b) If data are not available for a specific constituent but are available for an isomer, then the spike recovery data are transferred from the isomer and the data are adjusted using the percent recovery selected according to the procedure described in (a) above. (c) If data are not available for a specific constituent but are available for a similar class of constituents (e.g., volatile organics, acid-extractable semivolatiles), then spike recovery data available for this class of constituents are transferred. All spike recovery values greater than or equal to 20 percent for a spiked sample are averaged and the constituent concentration is adjusted by the average recovery value. If spiked recovery data are available for more than one sample, the average is calculated for each sample and the data are adjusted by the lowest average value. (d) If matrix spike recovery data are not available for a set of data to be used to calculate treatment standards, then matrix spike recovery data are transferred from a waste that the Agency believes is a similar matrix (e.g., if the data are for an ash from incineration, then data from other incinerator ashes could be used). While EPA recognizes that transfer of matrix spike recovery data from a similar waste is not an exact analysis, this is considered the best approach for adjusting the data to account for the fact that most analyses do not result in extraction of 100 percent of the constituent. In assessing the recovery data to be transferred, the procedures outlined in (a), (b), and (c) above are followed. The analytical procedures employed to generate the data used to calculate the treatment standards are listed in Appendix B of this document. In cases where alternatives or equivalent procedures and/or equipment are allowed in EPA's SW-846, Third Edition (November 1986) methods, the specific procedures and equipment used are also documented in this Appendix. In addition, any deviations from the SW-846, Third Edition, methods used to analyze the specific waste matrices are documented. It is important to note that the Agency will use the methods and procedures delineated in Appendix B to enforce the treatment 35 ------- standards presented in Section 6 of this document. Accordingly, facilities should use these procedures in assessing the performance of their treatment systems. 1.2.7 BOAT Treatment Standards for "Derived-From" and "Mixed" Wastes (1) Wastes from treatment trains generating multiple residues. In a number of instances, the proposed BOAT consists of a series of operations each of which generates a waste residue. For example, the proposed BOAT for a certain waste code is based on solvent extraction, steam stripping, and activated carbon adsorption. Each of these treatment steps generates a waste requiring treatment -- a solvent-containing stream from solvent extraction, a stripper overhead, and spent activated carbon. Treatment of these wastes may generate further residues; for instance, spent activated carbon (if not regenerated) could be incinerated, generating an ash and possibly a scrubber water waste. Ultimately, additional wastes are generated that may require land disposal. With respect to these wastes, the Agency wishes to emphasize the following points: (a) All of the residues from treating the original listed wastes are likewise considered to be the listed waste by virtue of the derived-from rule contained in 40 CFR Part 261.3(c)(2). (This point is discussed more fully in (2) below.) Consequently, all of the wastes generated in the course of treatment would be prohibited from land disposal unless they satisfy the treatment standard or meet one of the exceptions to the prohibition. (b) The Agency's proposed treatment standards generally contain a concentration level for wastewaters and a concentration level for nonwastewaters. The treatment standards apply to all of the wastes generated in treating the original prohibited waste. Thus, all solids generated from treating these wastes would have 36 ------- to meet the treatment standard for nonwastewaters. All derived-from wastes meeting the Agency definition of wastewater (less than 1 percent TOC and less than 1 percent total filterable solids) would have to meet the treatment standard for wastewaters. EPA wishes to make clear that this approach is not meant to allow partial treatment in order to comply with the applicable standard. (c) The Agency has not performed tests, in all cases, on every waste that can result from every part of the treatment train. However, the Agency's treatment standards are based on treatment of the most concentrated form of the waste. Consequently, the Agency believes that the less concentrated wastes generated in the course of treatment will also be able to be treated to meet this value. (2) Mixtures and other derived-from residues. There is a further question as to the applicability of the BOAT treatment standards to residues generated not from treating the waste (as discussed above), but from other types of management. Examples are contaminated soil or leachate that is derived from managing the waste. In these cases, the mixture is still deemed to be the listed waste, either because of the derived-from rule (40 CFR Part 261.3(c)(2)(i)) or the mixture rule (40 CFR Part 261.3(a)(2)(iii) and (iv) or because the listed waste is contained in the matrix (see, for example, 40 CFR Part 261.33(d)). The prohibition for the particular listed waste consequently applies to this type of waste. The Agency believes that the majority of these types of residues can meet the treatment standards for the underlying listed wastes (with the possible exception of contaminated soil and debris for which the Agency is currently investigating whether it is appropriate to establish a separate treatability subcategorization). For the most part, these 37 ------- residues will be less concentrated than the original listed waste. The Agency's treatment standards also make a generous allowance for process variability by assuming that all treatability values used to establish the standard are lognormally distributed. The waste also might be amenable to a relatively nonvariable form of treatment technology such as incineration. Finally, and perhaps most important, the rules contain a treatability variance that allows a petitioner to demonstrate that its waste cannot be treated to the level specified in the rule (40 CFR Part 268.44(a). This provision provides a safety valve that allows persons with unusual waste matrices to demonstrate the appropriateness of a different standard. The Agency, to date, has not received any petitions under this provision (for example, for residues contaminated with a prohibited solvent waste), indicating, in the Agency's view, that the existing standards are generally achievable. (3) Residues from managing listed wastes or that contain listed wastes. The Agency has been asked if and when residues from managing hazardous wastes, such as leachate and contaminated ground water, become subject to the land disposal prohibitions. Although the Agency believes this question to be settled by existing rules and interpretative statements, to avoid any possible confusion the Agency will address the question again. Residues from managing First Third wastes, listed California List wastes, and spent solvent and dioxin wastes are all considered to be subject to the prohibitions for the underlying hazardous waste. Residues 38 ------- from managing California List wastes likewise are subject to the California List prohibitions when the residues themselves exhibit a characteristic of hazardous waste. This determination stems directly from the derived-from rule in 40 CFR Part 261.3(c)(2) or in some cases from the fact that the waste is mixed with or otherwise contains the listed waste. The underlying principle stated in all of these provisions is that listed wastes remain listed until delisted. The Agency's historic practice in processing delisting petitions addressing mixing residuals has been to consider them to be the listed waste and to require that delisting petitioners address all constituents for which the derived-from waste (or other mixed waste) was listed. The language in 40 CFR Part 260.22(b) states that mixtures or derived-from residues can be delisted provided a delisting petitioner makes a demonstration identical to that which a delisting petitioner would make for the underlying waste. These residues consequently are treated as the underlying listed waste for delisting purposes. The statute likewise takes this position, indicating that soil and debris that are contaminated with listed spent solvents or dioxin wastes are subject to the prohibition for these wastes even though these wastes are not the originally generated waste, but rather are a residual from management (RCRA section 3004(e)(3)). It is EPA's view that all such residues are covered by the existing prohibitions and treatment standards for the listed hazardous waste that these residues contain and from which they are derived. 39 ------- 1.2.8 Transfer of Treatment Standards EPA is proposing some treatment standards that are not based on testing of the treatment technology of the specific waste subject to the treatment standard. Instead, the Agency has determined that the constituents present in the subject waste can be treated to the same performance levels as those observed in other wastes for which EPA has previously developed treatment data. EPA believes that transferring treatment performance for use in establishing treatment standards for untested wastes is valid technically in cases where the untested wastes are generated from similar industries, similar processing steps, or have similar waste characteristics affecting performance and treatment selection. Transfer of treatment standards to similar wastes or wastes from similar processing steps requires little formal analysis. However, in the case where only the industry is similar, EPA more closely examines the waste characteristics prior to concluding that the untested waste constituents can be treated to levels associated with tested wastes. EPA undertakes a two-step analysis when determining whether wastes generated by different processes within a single industry can be treated to the same level of performance. First, EPA reviews the available waste characteristic data to identify those parameters that are expected to affect treatment selection. EPA has identified some of the most important constituents and other parameters needed to select the treatment technology appropriate for a given waste. A detailed discussion of each analysis, including how each parameter was selected for each waste, can be found in the background document for each waste. 40 ------- Second, when an individual analysis suggests that an untested waste can be treated with the same technology as a waste for which treatment performance data are already available, EPA analyzes a more detailed list of constituents that represent some of the most important waste characteristics that the Agency believes will affect the performance of the technology. By examining and comparing these characteristics, the Agency determines whether the untested wastes will achieve the same level of treatment as the tested waste. Where the Agency determines that the untested waste is easier to treat than the tested waste, the treatment standards can be transferred. A detailed discussion of this transfer process for each waste can be found in later sections of this document. 1.3 Variance from the 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. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION The previous section discussed the BOAT program and the methodology used by the Agency to develop treatment standards. The purpose of this section is to describe the industries affected by the land disposal restrictions for K062 wastes, the processes generating the wastes, and the available waste characterization data for K062 wastes. According to 40 CFR Part 261.32 (hazardous wastes from specific sources), the waste identified as K062 is spent pickle liquor generated by steel finishing operations of facilities within the iron and steel industry (SIC codes 331 and 332). 2.1 Industries Affected and Process Description The listed waste K062 is generated by the steel industry from steel finishing operations. The Agency estimates that approximately 978 facilities have steel finishing operations that could generate the K062 waste. Tables 2-1 to 2-6 and Figure 2-1 present the location of these facilities by State and EPA region. The facilities that may generate spent pickle liquor (K062) from steel finishing operations are those that fall under the SIC codes 331 and 332. In the steel industry, steel products are exposed to the atmosphere during forming and finishing operations, causing oxide scale to form on their surfaces. This scale must be removed prior to additional processing in order to prepare the surface for protective coatings and cold rolling. Acid pickling is the method used most widely by the steel industry to remove the oxide scale. In addition, the steel surface must 46 ------- be cleaned (by pickling) at various stages throughout the steel production process to ensure that oxides forming on the surface are not worked into the finished product. The pickling operation involves the immersion of the oxidized steel product into a heated solution of concentrated acid or acids (the pickling agent). There are generally three types of pickling agents: (1) sulfuric acid, (2) hydrochloric acid, and (3) combined acids. The type of pickling agent used in a finishing operation depends on the type of steel being processed and the surface quality desired. When a certain concentration of metal ions builds up in the pickling bath, the solution is considered spent and must be replaced. This spent pickle liquor is the listed waste K062. Pickling is accomplished in either continuous (Figure 2-2) or batch operations (Figure 2-3): • Continuous pickling. Continuous pickling is the method predominantly used for pickling steel products. As shown in Figure 2-2, steel products are continuously fed through a series of pickling tanks containing acid solution. The pickling solution flows in one direction, while the steel product travels in the opposite direction, i.e., countercurrent. A fresh acid solution is added to the last tank in a series of tanks and flows through the tanks to an overflow located in the first tank. The acid overflow from the first tank is the waste stream K062. • Batch pickling. Batch operations typically utilize large, open tanks, holding the pickling agent. As shown in Figure 2-3, steel products are dipped in the pickling tank for the removal of scale. After continual use, the free acid content of the pickling tank decreases and the metal ion concentration increases. When the free acid level falls to a specified value or the metal ion concentration reaches a specified value, the pickling agent is considered spent and is dumped as a batch. This spent batch of pickling solution is K062 waste. 47 ------- 2.2 Waste Characterization This section includes all of the waste characterization data available to the Agency for K062 wastes. Table 2-7 provides an estimate of the major constituents present in the waste, along with their approximate concentrations. The percent concentration of each major constituent in the waste was determined using engineering judgment based on chemical analyses. The Agency has obtained waste composition data from its own testing program and from numerous industry sources. BOAT list constituents had a concentration of approximately 1 percent, while water and other inorganics had concentrations of approximately 93 and 6 percent, respectively. The ranges of BOAT List constituents in the untreated waste are presented in Table 2-8. The constituents detected in the untreated K062 waste are BOAT list metals, namely, arsenic, chromium, copper, lead, nickel, and zinc. Chromium, copper, and nickel appear in the highest concentrations in the K062 waste tested by the Agency. The Agency has data showing that lead may also be present in K062 wastes generated from pickling operations involving leaded steels. No organics were analyzed for in the untreated and treated K062 waste; however, the Agency does not believe that they will be present in treatable concentrations in the untreated K062 wastes. 48 ------- 1008g Table 2-1 Census Data (1982) for Number of Facilities in Each State and EPA Region Blast Furnaces and Steel Mills3 State AL (IV) AK (X) AZ (IX) AR (VI) CA (IX) CO (VIII) CT (1) DE (III) DC (III) FL (IV) GA (IV) HI (IX) ID (X) IL (V) IN (V) IA (VII) KS (VII) KY (IV) LA (VI) ME (I) MD (III) MA (I) MI (V) MN (V) MS (IV) MO (VIII) Faci lities 15 1 19 2 1 1 5 4 19 11 1 8 5 3 15 3 2 4 State MT NE NV NH NJ NM NY NC NO OH OK OR PA RI SC SD TN TX LIT VT VA WA UV WI WY (VIII) (VII) (IX) (I) (ID (VI) (ID (IV) (VIII) (V) (VI) (X) (III) (I) (IV) (VIII) (IV) (VI) (VIII) (I) (HI) (X) (III) (V) (VIII) Facilities EPA Region I 1 II III IV 6 V VI 20 VII 3 VIII IX 26 X 5 5 52 5 7 14 2 7 5 4 4 Totals 1 26 67 49 78 24 2 8 20 10 285 alncludes data for SIC code 3312 only. Source: 1982 Census of Manufacturers. 49 ------- 1008g Table 2-2 Census Data (1982) for Number of Facilities in Each State and EPA Region Electrometallurgical Products3 State Facilities State Facilities AL (IV) AK (X) AZ (IX) AR (VI) CA (IX) CO (VIII) CT (I) DE (III) DC (III) FL (IV) GA (IV) HI (IX) ID (X) IL (V) IN (V) IA (VII) KS (VII) KY (IV) LA (VI) ME (I) MO (III) MA (I) MI (V) MN (V) MS (IV) MO (VIII) MT (VIII) NE (VII) NV (IX) NH (I) NJ (II) 3 NM (VI) NY (II) NC (IV) ND (VIII) OH (V) 8 OK (VI) OR (X) 2 PA (III) 1 RI (I) SC (IV) 2 1 SO (VIII) TN (IV) 4 1 TX (VI) UT (VIII) VT (I) VA (III) WA (X) WV (III) 4 WI (V) WY (VIII) EPA Region Totals I II 3 III 5 IV 7 V 8 VI VII 1 VIII IX X _2 26 Includes data for SIC code 3313 only. Source 1982 Census of Manufacturers. 50 ------- 1003g Table 2-3 Census Data (1982) for Number of Facilities in Each State and EPA Region Steel Wire and Related Products3 State AL (IV) AK (X) AZ (IX) AR (VI) CA (IX) CO (VIII) CT (I) DE (III) DC (III) FL (IV) GA (IV) HI (IX) ID (X) IL (V) IN (V) IA (VII) KS (VII) KY (IV) LA (VI) ME (I) MD (III) MA (I) MI (V) MN (V) MS (IV) MO (VIII) Faci 1 it IBS 6 2 34 15 2 13 6 30 10 4 3 4 19 12 2 4 7 State Facilities MT NE NV NH NJ NM NY NC NO OH OK OR PA RI SC SO TN TX UT VT VA WA WV WI WY (VIII) (VII) (IX) (I) (II) 16 (VI) (ID 15 (IV) 5 (VIII) (V) 21 (VI) 3 (X) (III) 25 (I) (IV) 6 (VIII) (IV) 5 (VI) 22 (VIII) (I) (III) 2 (X) (III) (V) 4 (VIII) EPA Region Totals I 34 II 31 III 33 IV 49 V 79 VI 30 VII VIII 7 IX 34 X 297 alncludes data for SIC code 3315 only. Source: 1982 Census of Manufacturers. 51 ------- lOOHg Table 2-4 Census Data (1982) for Number of Facilities in Each State and EPA Region Cold Finishing of Steel Shapes State Facilities AL (IV) AK (X) AZ (IX) AR (VI) CA (IX) 12 CO (VIII) 10 CT (I) DE (III) DC (III) FL (IV) GA (IV) HI (IX) ID (X) IL (V) 18 IN (V) 7 IA (VII) KS (VII) KY (IV) LA (VI) ME (I) MD (III) 2 MA (I) 4 MI (V) 22 MN (V) MS (IV) 6 MO (VIII) State Facilities MT (VIII) NE (VII) NV (IX) NH (I) NJ (II) 9 NM (VI) NY (II) 8 NC (IV) ND (VIII) OH (V) 24 OK (VI) OR (X) PA (III) 23 RI (I) SC (IV) SO (VIII) TN (IV) TX (VI) 10 UT (VIII) VT (I) VA (III) WA (X) WV (III) WI (V) 5 WY (VIII) EPA Region Totals I 4 II 17 III 25 IV 6 V 76 VI 10 VII VIII 10 IX 12 X 160 alncludes data for SIC code 3316 only. Source- 1982 Census of Manufacturers. 52 ------- 1008g Table 2-5 Census Data (1982) for Number of Facilities in Each State and EPA Region Steel Pi le and Tubes3 State AL (IV) AK (X) AZ (IX) AR (VI) CA (IX) CO (VIII) CT (I) DE (III) DC (III) Ft (IV) GA (IV) HI (IX) ID (X) IL (V) IN (V) IA (VII) KS (VII) KY (IV) LA (VI) ME (I) MO (III) MA (I) MI (V) MN (V) MS (IV) MO (VIII) Faci 1 ities 2 2 26 3 3 19 13 1 3 3 2 25 3 4 State Facilities MT (VIII) NE (VII) NV (IX) NH (I) NJ (II) 8 NM (VI) NY (II) 7 NC (IV) NO (VIII) OH (V) 26 OK (VI) 5 OR (X) PA (III) 27 RI (I) SC (IV) SD (VIII) TN (IV) 6 TX (VI) 12 UT (VIII) VT (I) VA (III) WA (X) 1 WV (III) 2 WI (V) 7 WY (VIII) EPA Region Totals I II 15 III 31 IV 14 V 93 VI 22 VII 1 VIII 7 IX 26 X 1 210 Includes data for SIC code 3317 only. Source: 1982 Census of Manufacturers. 53 ------- 1008g Table 2-6 Number of Facilities in Each EPA Region EPA Region Totals I 39 II 92 III 161 IV 125 V 334 VI 86 VII 4 VIII 32 IX 92 X 13 978 54 ------- en en MA FIGURE 2-1 FACILITIES PRODUCING K062 WASTE BY EPA REGION ------- 1008g Table 2-7 Major Constituent Analysis Untreated K062 Waste Constituent Concentration % BOAT List Constituents (primarily chromium, copper, and nickel) Water Other Inorganics Total 93 6 100% Source: U.S. Environmental Protection Agency. 1986. Onsite Engineering Report of Treatment Technology Performance and Operation for Envirite Corporation. Table 2-8 BOAT List Constituent Composition BOAT metals Untreated waste concentration, ppm (a) (b) Arsenic Barium Cadmium Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc <0.1 to 3 <10 <5 0.079 to 1 6 to 7000 5 to 865 <10 4 to 100,310 <0.4 to 9 - - - 0.005 2 to - 0.12 - - to 19 12,400 to 1550 Source: (a) U.S. Environmental Protection Agency. 1986. Onsite Engineering Report of Treatment Technology Performance and Operation for Envirite Corporation, Tables 6-1 to 6-12. (b) U.S. Environmental Protection Agency - Characterization of Waste Streams Listed in 40 CFR 261 Waste Profiles, pp. 299 and 300. 56 ------- STEEL PRODUCT \- (®) *" •' ®v /®~ xa er TANK NO. 1 *\ /* \3 f/ TANK NO. i ~©y /€T NO & TANK NO. 1 ^ *J \ FRESH ACID f r ) * i uC (CONSTANT > FEED RATE) r WATER (CONSTANT FEED RATE) -Q>- JS. \^ dt TANK NO. 4 *• PICKLING TANKS Ln CONSTANT OVERFLOW (CASCADE) ^ OF SPENT PICKLE LIQUOR - KO62 ACID 1 fwATE* "®yAA^€T *\B/i L WATER SUPPLY fwATER a ^» ». * \a_e/ RINSE WATER DISCHARGE FIGURE 2-2 EXAMPLE OF CONTINUOUS (COUNTERCURRENT) PICKLING PROCESS AND GENERATION OF KO62 REFERENCE: U.S. ENVIRONMENTAL PROTECTION AGENCY 1982. ------- VVVVNXNX en Co PERIODIC OVERFLOW DISCHARGE -SPENT ACID (DUMP) DISCHARGE SPENT PICKLE LIQUOR K062 WATER (MAKEUP) STEEL PRODUCT WATER SUPPLY WATER * (CONTINUOUS FLOW) DIP RINSE TANK -ACID RINSE WATER CONTINUOUS DISCHARGE FIGURE 2-3 EXAMPLE OF BATCH PICKLING PROCESS AND GENERATION OF KO62 REFERENCE: U.S. ENVIRONMENTAL PROTECTION AGENCY 1082. ------- 3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES The previous section discussed the industries generating K062 and the composition of the untreated waste. This section describes the applicable treatment technologies and presents performance data for the treatment of K062 waste. The Agency identified the applicable treatment technologies based on the waste composition. The technologies considered to be applicable are those that treat BOAT list metals by reducing their concentration and/or their Teachability. Included in this section are discussions of those treatment technologies that have been demonstrated on a commercial basis. The treatment technology tested by the Agency, along with its associated performance data, is presented in the following sections. A schematic diagram of the treatment system for K062 tested by the Agency (chromium reduction and chemical precipitation, followed by dewatering of the precipitate) is shown in Figure 3-6. 3.1 Applicable Treatment Technologies The methodology used to determine the applicable technologies is called analysis of parameters affecting treatment selection (PATS). This methodology involves the identification of applicable treatment technologies based on the composition of the waste. A description of the PATS methodology and a discussion of the parameters are provided in Volume I, Background Document for BOAT Treatment Technologies. As shown in Section 2, the tested waste primarily contains BOAT list metals, water, and other inorganic constituents. Some of the BOAT list metals reported in the untreated K062 are arsenic, chromium (hexavalent), 59 ------- chromium (total), copper, lead, nickel, and zinc. Other waste characteristics that may affect treatment selection for K062 are filterable solids and oil and grease content. Filterable solids are 0.01 percent (100 mg/1) or less; oil and grease content is less than 10 mg/1. The Agency has identified treatment technologies that may be applicable to K062 because they are designed to reduce the concentration of BOAT list metals present in the treated residual and/or reduce the leachability of BOAT list metals in the treated residual. The selection of the treatment technologies applicable for treating BOAT list metals in K062 is based on current literature sources and field testing. K062 wastes tested by EPA contain dissolved BOAT list metals (approximately 1 percent), low oil and grease content (<0.2 to 6 mg/1), and low filterable solids (<1 to 100 mg/1). Hence, chemical precipitation followed by dewatering of the precipitated solids is an applicable technology for the removal of the dissolved metals from K062. Applicable treatment for the solids precipitated includes stabilization or metals recovery. Additionally, the presence of hexavalent chromium indicates the need for chromium reduction to convert hexavalent chromium to trivalent chromium prior to precipitation. Dewatering of the precipitated solids results in a nonwastewater stream called filter cake and a wastewater stream called filtrate. The filtrate may be further processed by polishing filtration, such as multimedia filtration, to remove the remaining suspended solids. Stabilization of the filter cake 60 ------- may be used to reduce the Teachability of the BOAT list metals. Metals recovery from the filter cake may be used to reduce the total concentration of the metals in the filter cake. 3.2 Demonstrated Treatment Technologies All of the applicable technologies are demonstrated. Hexavalent chromium reduction, chemical precipitation, and dewatering by settling and/or filtration are widely practiced as a metals treatment technology. In addition, polishing filtration is a well-documented technology. The use of dewatering by vacuum filtration only, as a substitute for settling, is a less commonly practiced technology, but was used on a full-scale basis at a facility tested by EPA. Regarding treatment of precipitated solids, stabilization is well demonstrated on K062 wastes. EPA also has information showing that high temperature metals recovery is a demonstrated technology for K062 wastes. Of the demonstrated treatment technologies, chromium reduction, chemical precipitation, sludge filtration, stabilization, and high temperature metals recovery are discussed below. 3.2.1 Chromium Reduction (1) Applicability and use of this technology. The process of 6+ hexavalent chromium (Cr ) reduction involves conversion from the hexavalent form to the trivalent form of chromium. This technology has wide application to hexavalent chromium wastes, including plating solutions, stainless steel acid baths and rinses, "chrome conversion" 61 ------- coating process rinses, and chromium pigment manufacturing wastes. Because this technology requires the pH to be in the acidic range, it would not be applicable to a waste that contains significant amounts of cyanide or sulfide. In such cases, lowering of the pH can generate toxic gases such as hydrogen cyanide or hydrogen sulfide. It is important to note that additional treatment is required to remove trivalent chromium from solution. (2) Underlying principles of operation. The basic principle of treatment is to reduce the valence of chromium in solution (in the form of chromate or dichromate ions) from the valence state of six (+6) to the trivalent (+3) state. "Reducing agents" used to effect the reduction include sodium bisulfite, sodium metabisulfite, sulfur dioxide, sodium hydrosulfide, or the ferrous form of iron. A typical reduction equation, using sodium sulfite as the reducing agent, is: H2Cr20? + 3Na2S03 + (SO^ -» Cr^SO^ + SNa^ + 4^0. The reaction is usually accomplished at pH values in the range of 2 to 3. At the completion of the chromium reduction step, the trivalent chromium compounds are precipitated from solution by raising the pH to a value exceeding about 8. The less soluble trivalent chromium (in the form of chromium hydroxide) is then allowed to settle from solution. The precipitation reaction is as follows: Cr (SO ) + 3Ca(OH) - 2Cr(OH) + CaSO . 62 ------- (3) Description of chromium reduction process. The chromium reduction treatment process can be operated in a batch or a continuous mode. A batch system will consist of a reaction tank, a mixer to homogenize the contents of the tank, a supply of reducing agent, and a source of acid and base for pH control. A continuous chromium reduction treatment system, as shown in Figure 3-1, will usually include a holding tank upstream of the reaction tank for flow and concentration equalization. It will also include instrumentation to automatically control the amount of reducing agent added and the pH of the reaction tank. The amount of reducing agent is controlled by the use of a sensor called an oxidation reduction potential (ORP) cell. The ORP sensor electronically measures, in millivolts, the level to which the redox reaction has proceeded at any given time. It must be noted, though, that the ORP reading is very pH dependent. Consequently, if the pH is not maintained at a steady value, the ORP will vary somewhat, regardless of the level of chromate reduction. (4) Waste characteristics affecting performance. In determining whether chromium reduction can treat an untested waste to the same level of performance as a previously tested waste, EPA will examine waste characteristics that affect the reaction involved with either lowering the pH or reducing the hexavalent chromium. EPA believes that such characteristics include the oil and grease content of the waste, total dissolved solids, and the presence of other compounds that would undergo reduction reaction. 63 ------- REDUCING AGENT FEED SYSTEM ACID FEED SYSTEM HEXAVALENT- CHROMIUM CONTAINING WASTEWATER "(8^ ALKALI FEED SYSTEM r DD ORP pH SENSORS TO SETTLING REDUCTION PRECIPITATION ELECTRICAL CONTROLS o MIXER FIGURE 3-1 CONTINUOUS HEXAVALENT CHROMIUM REDUCTION SYSTEM ------- (a) Oil and grease. EPA believes that these compounds could potentially interfere with the oxidation-reduction reactions, as well as cause monitoring problems by fouling the instrumentation (e.g., electrodes). Oil and grease concentrations can be measured by EPA Methods 9070 and 9071. (b) Total dissolved solids. These compounds can interfere with the addition of treatment chemicals into solution and possibly cause monitoring problems. (c) Other reducible compounds. These compounds would generally consist of other metals in the waste. Accordingly EPA will evaluate the type and concentration of other metals in the waste in evaluating transfer of treatment performances. (5) Design and operating parameters. The parameters that EPA will examine in assessing the design and operation of a chromium reduction treatment system are discussed below. (a) Treated and untreated design concentration. EPA will need to know the level of performance that the facility is designed to achieve in order to ensure that the design is consistent with best demonstrated practices. This parameter is important in that a system will not usually perform better than the design. In addition to awareness of the treated design concentration, it is also important to know the characteristics of the untreated waste that the system is designed to handle. Accordingly, EPA will obtain data on the untreated wastes to ensure that the waste characteristics fall within the design specifications. 65 ------- (b) Reducing agent. The choice of a reducing agent establishes the chemical reaction upon which the chromium reduction system is based. The amount of reducing agent must be monitored and controlled in both batch and continuous systems. In batch systems, the reducing agent is usually controlled by an analysis of the hexavalent chromium remaining in the solution. For continuous systems, the ORP reading is used to monitor and control the addition of a reducing agent. The reading ORP will change slowly until the correct amount of reducing agent has been added, at which point the reading will change more rapidly, indicating that the reaction has been completed. The setpoint for the ORP monitor is approximately the reading just after the rapid change has begun. The reduction system must then be monitored periodically to determine whether the selected setpoint needs further adjustment. (c) £H. For both batch and continuous systems, pH is an important parameter because of its effect on the reduction reaction. While it can be monitored intermittently during treatment for a batch system, the pH should be continuously monitored for continuous systems because of its effect on the ORP. In evaluating the design and operation of a < continuous chromium reduction system, it is important to know the pH on which the design ORP value is based, as well as the designed ORP value. (d) Retention time. Retention time should be adequate to ensure that the hexavalent chromium reduction reaction goes to completion. In the case of the batch reactor, the retention time is varied by adjusting 66 ------- the treatment time in the reaction tank. If the process is continuous, it is important to monitor the feed rate to ensure that the designed residence time is achieved. The chromium reduction process which provides data for treating K062 used iron-bearing (ferrous) acid wastes to reduce hexavalent chromium to trivalent chromium in a single stage batch reaction. Each treatment tank used a mechanical mixing system. According to plant personnel, the weight ratio of ferrous iron to hexavalent chromium required for complete reduction is 3.2 to 1.0. Some industrial treatment facilities, however, often use other amounts of iron to ensure complete reduction of the hexavalent chromium. Completion of the chromium reduction step was checked by measuring the hexavalent chromium concentration until it was no longer detected in the treatment tank. 3.2.2 Chemical Precipitation (1) Applicability and use of this technology. Chemical precipitation is used when dissolved metals are to be removed from solution. This technology can be applied to a wide range of wastewaters containing dissolved BOAT list metals and other metals as well. This treatment process has been practiced widely by industrial facilities since the 1940s. (2) Underlying principles of operation. The underlying principle of chemical precipitation is that metals in wastewater are removed by the addition of a treatment chemical that converts the dissolved metal to a 67 ------- metal precipitate. This precipitate is less soluble than the original metal compound and therefore settles out of solution, leaving a lower concentration of the metal present in the solution. The primary chemicals used to convert soluble metal compounds to less soluble forms include: lime (Ca(OH) ), caustic (NaOH), sodium sulfide (Na S), and, to a lesser extent, soda ash (Na CO ), phosphate, and ferrous sulfide £ 0 (FeS). The solubility of a particular compound will depend on the extent to which the electrostatic forces holding the ions of the compound together can be overcome. The solubility will change significantly with temperature; most metal compounds are more soluble as the temperature increases. Additionally, the solubility will be affected by the other constituents present in a waste. As a general rule, nitrates, chlorides, and sulfates are more soluble than hydroxides, sulfides, carbonates, and phosphates. An important concept related to treatment of the soluble metal compounds is pH. This term provides a measure of the extent to which a solution contains either an excess of hydrogen or hydroxide ions. The pH scale ranges from 0 to 14, with 0 being the most acidic, 14 representing the highest alkalinity or hydroxide ion (OH ) content, and 7.0 being neutral. When hydroxide is used, as is often the case, to precipitate the soluble metal compounds, the pH is frequently monitored to ensure that 68 ------- sufficient treatment chemicals are added. It is important to point out that pH is not a good measure of treatment chemical addition for compounds other than hydroxides. When sulfide is used, for example, facilities might use an oxidation-reduction potential meter (ORP) correlation to ensure that sufficient treatment chemical is used. Following conversion of the relatively soluble metal compounds to metal precipitates, the effectiveness of chemical precipitation is a function of the physical removal, which usually relies on a settling process. A particle of a specific size, shape, and composition will settle at a specific velocity, as described by Stokes' Law. For a batch system, Stokes' law is a good predictor of settling time because the pertinent particle parameters remain essentially constant. Nevertheless, in practice, settling time for a batch system is normally determined by empirical testing. For a continuous system, the theory of settling is complicated by factors such as turbulence, short-circuiting, and velocity gradients, increasing the importance of the empirical tests. (3) Description of chemical precipitation. The equipment and instrumentation required for chemical precipitation vary depending on whether the system is batch or continuous. Both operations are discussed below; a schematic of the continuous system is shown in Figure 3-2. For a batch system, chemical precipitation requires only a feed system for the treatment chemicals and a second tank where the waste can be treated and allowed to settle. When lime is used, it is generally 69 ------- TREATMENT CHEMICAL FEED SYSTEM COAGULANT OR FLOCCULANT FEED SYSTEM WASTEWATER FEED EFFLUENT TO DISCHARGE OR SUBSEQUENT TREATMENT ELECTRICAL CONTROLS WASTEWATER FLOW MIXER .SLUDGE TO DEWATERING FIGURE 3-2 CONTINUOUS CHEMICAL PRECIPITATION ------- added to the reaction tank in a slurry form. In a batch system, the supernate is usually analyzed before discharge, thus minimizing the need for instrumentation. In a continuous system, additional tanks and instrumentation are necessary to ensure that the system is operating properly. In this system, the first tank that the wastewater enters is referred to as an equalization tank. This is where the waste can be mixed in order to provide more uniformity, minimizing wide swings in the type and concentration of constituents being sent to the reaction tank. It is important to reduce the variability of the waste sent to the reaction tank because control systems inherently are limited with regard to the maximum fluctuations that can be managed. Following equalization, the waste is pumped to a reaction tank where treatment chemicals are added; this is done automatically by using instrumentation that senses the pH of the system and then pneumatically adjusts the position of the treatment chemical feed valve such that the design pH value is achieved. Both the complexity and the effectiveness of the automatic control system will vary depending on the variation in the waste and the pH range that is needed to properly treat the waste. An important aspect of the reaction tank design is that it be well-mixed so that the waste and the treatment chemicals are both dispersed throughout the tank, in order to ensure comingling of the reactant and the treatment chemicals. In addition, effective dispersion 71 ------- of the treatment chemicals throughout the tank is necessary to properly monitor and thereby control the amount of treatment chemicals added. After the waste is reacted with the treatment chemical, it flows to a quiescent tank where the precipitate is allowed to settle and subsequently be removed. Settling can be chemically assisted through the use of flocculating compounds. Flocculants increase the particicle size and density of the precipitated solids, both of which increase the rate of settling. The particular flocculating agent that will best improve settling characteristics will vary depending on the particular waste; selection of the flocculating agent is generally accomplished by performing laboratory bench tests. Settling can be conducted in a large tank by relying solely on gravity or can be mechanically assisted through the use of a circular clarifier or an inclined separator. Schematics of the latter two separators are shown in Figures 3-3 and 3-4. Filtration can be used for further removal of precipitated residuals both in cases where the settling system is underdesigned and in those in which the particles are difficult to settle. Polishing filtration is discussed in a separate technology section. (4) Waste characteristics affecting performance. In determining whether chemical precipitation is likely to achieve the same level of performance on an untested waste as on a previously tested waste, we will examine the following waste characteristics: (1) the concentration and type of the metal(s) in the waste, (2) the concentration of suspended 72 ------- SLUDGE INFLUENT CENTER FEED CLARIFIER WITH SCRAPER SLUDGE REMOVAL SUSTEM INFLUENT EFFLUENT SLUDGE RIM FEED - CENTER TAKEOFF CLARIFIER WITH HYDRAULIC SUCTION SLUDGE REMOVAL SYSTEM INFLUENT EFFLUENT SLUDGE RIM FEED - RIM TAKEOFF CLARIFIER FIGURE 3-3 CIRCULAR CLARIFIERS 73 ------- INFLUENT EFFLUENT FIGURE 3-4 INCLINED PLATE SETTLER 74 ------- solids (TSS), (3) the concentration of dissolved solids (IDS), (4) whether the metal exists in the wastewater as a complex, and (5) the oil and grease content. These parameters affect the chemical reaction of the metal compound, the solubility of the metal precipitate, or the ability of the precipitated compound to settle. (a) Concentration and type of metals. For most metals, there is a specific pH at which the metal hydroxide is least soluble. As a result, when a waste contains a mixture of many metals, it is not possible to operate a treatment system at a single pH that is optimal for the removal of all metals. The extent to which this affects treatment depends on the particular metals to be removed and their concentrations. An alternative can be to operate multiple precipitations, with intermediate settling, when the optimum pH occurs at markedly different levels for the metals present. The individual metals and their concentrations can be measured using EPA Method 6010. (b) Concentration and type of total suspended solids (TSS). Certain suspended solid compounds are difficult to settle because of their particle size or shape. Accordingly, EPA will evaluate this characteristic in assessing transfer of treatment performance. Total suspended solids can be measured by EPA Wastewater Test Method 160.2. (c) Concentration of total dissolved solids (TDS). Available information shows that total dissolved solids can inhibit settling. The literature states that poor flocculation is a consequence of high TDS, 75 ------- and shows that higher concentrations of total suspended solids are found in treated residuals. Poor flocculation can adversely affect the degree to which precipitated particles are removed. Total dissolved solids can be measured by EPA Wastewater Test Method 160.1. (d) Complexed metals. Metal complexes consist of a metal ion surrounded by a group of other inorganic or organic ions or molecules (often called ligands). In the complexed form, the metals have a greater solubility and therefore may not be as effectively removed from solution by chemical precipitation. EPA does not have an analytical method to determine the amount of complexed metals in the waste. The Agency believes that the best measure of complexed metals is to analyze for some common complexing compounds (or complexing agents) generally found in wastewater for which analytical methods are available. These complexing agents include ammonia, cyanide, and EDTA. The analytical method for cyanide is EPA Method 9010. The method for EDTA is ASTM Method D3113. Ammonia can be analyzed using EPA Wastewater Test Method 350. (e) Oil and grease content. The oil and grease content of a particular waste directly inhibits the settling of the precipitate. Suspended oil droplets float in water and tend to suspend particles such as chemical precipitates that would otherwise settle out of the solution. Even with the use of coagulants or flocculants, the separation of the precipitate is less effective. Oil and grease content can be measured by EPA Method 9071. 76 ------- (5) Design and operating parameters. The parameters that EPA will evaluate when determining whether a chemical precipitation system is well designed are: (1) design value for treated metal concentrations, as well as other characteristics of the waste used for design purposes (e.g., total suspended solids), (2) pH, (3) residence time, (4) choice of treatment chemical, and (5) choice of coagulant/flocculant. Below is an explanation of why EPA believes these parameters are important to a design analysis; in addition, EPA explains why other design criteria are not included in EPA's analysis. (a) Treated and untreated design concentrations. EPA pays close attention to the treated concentration the system is designed to achieve when determining whether to sample a particular facility. Since the system will seldom out-perform its design, EPA must evaluate whether the design is consistent with best demonstrated practice. The untreated concentrations that the system is designed to treat are important in evaluating any treatment system. Operation of a chemical precipitation treatment system with untreated waste concentrations in excess of design values can easily result in poor performance. (b) pH. The pH is important because it can indicate that sufficient treatment chemical (e.g., lime) is added to convert the metal constituents in the untreated waste to forms that will precipitate. The pH also affects the solubility of metal hydroxides and sulfides, and therefore directly impacts the effectiveness of removal. In practice, 77 ------- the design pH is determined by empirical bench testing, often referred to as "jar" testing. The temperature at which the "jar" testing is conducted is important in that it also affects the solubility of the metal precipitates. Operation of a treatment system at temperatures above the design temperature can result in poor performance. In assessing the operation of a chemical precipitation system, EPA prefers continuous data on the pH and periodic temperature conditions throughout the treatment period. (c) Residence time. The residence time is important because it impacts the completeness of the chemical reaction to form the metal precipitate and, to a greater extent, the amount of precipitate that settles out of solution. In practice, it is determined by "jar" testing. For continuous systems, EPA will monitor the feed rate to ensure that the system is operated at design conditions. For batch systems, EPA will want information on the design parameter used to determine sufficient settling time (e.g., total suspended solids). (d) Choice of treatment chemical. A choice must be made as to what type of precipitating agent (i.e., treatment chemical) will be used. The factor that most affects this choice is the type of metal constituents to be treated. Other design parameters, such as pH, residence time, and choice of coagulant/flocculant agents, are based on the selection of the treatment chemical. 78 ------- (e) Choice of coagulant/flocculant. This parameter is important because these compounds improve the settling rate of the precipitated metals and allows for smaller systems (i.e., lower retention time) to achieve the same degree of settling as a much larger system. In practice, the choice of the best agent and the required amount is determined by "jar" testing. (f) Mixing. The degree of mixing is a complex assessment that includes, among other things, the energy supplied, the time the material is mixed, and the related turbulence effects of the specific size and shape of the tank. EPA will, however, consider whether mixing is provided and whether the type of mixing device is one that could be expected to achieve uniform mixing. For example, EPA may not use data from a chemical precipitation treatment system where an air hose was placed in a large tank to achieve mixing. 3.2.3 Sludge Filtration (1) Applicability and use of this technology. Sludge filtration, also known as sludge dewatering or cake-formation filtration, is a technology used on wastes that contain high concentrations of suspended solids, generally higher than 1 percent. The remainder of the waste is essentially water. Sludge filtration is applied to sludges, typically those that have settled to the bottom of clarifiers, for dewatering. After filtration, these sludges can be dewatered to 20 to 50 percent solids. 79 ------- (2) Underlying principle of operation. The basic principle of filtration is the separation of particles from a mixture of fluids and particles by a medium that permits the flow of the fluid but retains the particles. As would be expected, larger particles are easier to separate from the fluid than smaller particles. Extremely small particles, in the colloidal range, may not be filtered effectively and may appear in the treated waste. To mitigate this problem, the wastewater should be treated prior to filtration to modify the particle size distribution in favor of the larger particles, by the use of appropriate precipitants, coagulants, flocculants, and filter aids. The selection of the appropriate precipitant or coagulant is important because it affects the particles formed. For example, lime neutralization usually produces larger, less gelatinous particles than does caustic soda precipitation. For larger particles that become too small to filter effectively because of poor resistance to shearing, shear resistance can be improved by the use of coagulants and flocculants. Also, if pumps are used to feed the filter, shear can be minimized by designing for a lower pump speed, or by use of a low shear type of pump. (3) Description of sludge filtration. For sludge filtration, settled sludge is either pumped through a cloth-type filter media (such as in a plate and frame filter that allows solid "cake" to build up on the media) or the sludge is drawn by vacuum through the cloth media (such as on a drum or vacuum filter, which also allows the solids to build). 80 ------- In both cases the solids themselves act as a filter for subsequent solids removal. For a plate and frame type filter, removal of the solids is accomplished by taking the unit off line, opening the filter, and scraping the solids off. For the vacuum type filter, cake is removed continuously. For a specific sludge, the plate and frame type filter will usually produce a drier cake than a vacuum filter. Other types of sludge filters, such as belt filters, are also used for effective sludge dewatering. (4) Waste characteristics affecting performance. The following characteristics of the waste will affect performance of a sludge filtration unit: (a) size of particles and (b) type of particles. (a) Size of particles. The smaller the particle size, the more the particles tend to go through the filter media. This is especially true for a vacuum filter. For a pressure filter (like a plate and frame), smaller particles may require higher pressures for equivalent throughput, since the smaller pore spaces between particles create resistance to flow. (b) Type of particles. Some solids formed during metal precipitation are gelatinous in nature and cannot be dewatered well by cake-formation filtration. In fact, for vacuum filtration a cake may not form at all. In most cases, solids can be made less gelatinous by use of the appropriate coagulants and coagulant dosage prior to clarification, or after clarification but prior to filtration. In addition, the use of lime instead of caustic soda in metal precipitation will reduce the 81 ------- formation of gelatinous solids. Also, the addition of filter aids to a gelatinous sludge, such as lime or diatomaceous earth, will help significantly. Finally, precoating the filter with diatomaceous earth prior to sludge filtration will assist in dewatering gelatinous sludges. (5) Design and operating variables that affect performance. For sludge filtration, the following design and operating variables affect performance: • Type of filter selected; • Size of filter selected; • Feed pressure; and • Use of coagulants or filter aids. (a) Type of filter. Typically, pressure type filters (such as a plate and frame) will yield a drier cake than a vacuum type filter and will also be more tolerant of variations in influent sludge characteristics. Pressure type filters, however, are batch operations, so that when cake is built up to the maximum depth physically possible (constrained by filter geometry), or to the maximum design pressure, the filter is turned off while the cake is removed. A vacuum filter is a continuous device (i.e., cake discharges continuously), but will usually be much larger than a pressure filter with the same capacity. A hybrid device is a belt filter, which mechanically squeezes sludge between two continuous fabric belts. 82 ------- (b) Size of filter. As with in-depth filters, the larger the filter, the greater its hydraulic capacity and the longer the filter runs between cake discharge. (c) Feed pressure. This parameter impacts both the design pore size of the filter and the design flow rate. It is important that in treating waste the design feed pressure not be exceeded; otherwise, particles may be forced through the filter medium, resulting in ineffective treatment. (d) Use of coagulants. Coagulants and filter aids may be mixed with filter feed prior to filtration. Their effect is particularly significant for vacuum filtration since they may make the difference between no cake and a relatively dry cake in a vacuum filter. In a pressure filter, coagulants and filter aids will also significantly improve hydraulic capacity and cake dryness. Filter aids, such as diatomaceous earth, can be precoated on filters (vacuum or pressure) for particularly difficult to filter sludges. The precoat layer acts somewhat like an in-depth filter in that sludge solids are trapped in the precoat pore spaces. Use of precoats and most coagulants or filter aids significantly increases the amount of sludge solids to be disposed of. However, polyelectrolyte coagulant usage usually does not increase sludge volume substantially because the dosage is low. Two rotary drum vacuum filters were used for the separation of solids after the precipitation step. These filters operated between 18 and 83 ------- 26 inches Hg vacuum, with filter cake being discharged continuously. The filter cake contained about 20 to 40 weight percent total dry solids. The filtration rate was about 40 gpm. The vacuum filters were precoated with diatomaceous earth and rotated at 1.07 to 1.3 rpm. 3.2.4 High Temperature Metals Recovery High temperature metals recovery (HTMR) provides for recovery of metals from wastes primarily by volatilization and collection. The process yields a metal product or products for reuse and reduces the concentration of metals in the residual. This process also significantly reduces the amount of treated waste that needs to be land disposed. There are a number of different types of high temperature metals recovery systems. These systems generally differ from one another relative to the source of energy and the method of recovery. Such HTMR systems include the rotary kiln process, plasma arc reactor, the rotary hearth/electric furnace system, molten slag reactor, and flame reactor. This technology is different from retorting in that HTMR is conducted in a carbon reducing atmosphere, while the retorting process simply vaporizes the untreated metal. Retorting is discussed in a separate technology section. (1) Applicability and use of this technology. This process is applicable to wastes containing BOAT list metals, low water content (or a water content that can be either blended to the required level or lowered by dewatering), and low concentration of organics. This technology is 84 ------- applicable to a wide range of metal salts including cadmium, chromium, lead, mercury, nickel, and zinc. This process is generally not used for mercury-containing wastes even though mercury will volatilize readily at the process temperatures present in high temperature units. The rotary kiln recovery process is one example of the technology, and has been applied to zinc-bearing wastes as an upgrading step that yields a zinc oxide product for further refinement and subsequent reuse. Although this technology was originally developed in the 1920s for upgrading zinc from ores, it has recently been applied to electric furnace dust from the steel-making industry. (2) Underlying principles of operation. The underlying principle of operation for this technology is that metals are separated from a waste through volatilization in a reducing atmosphere where carbon is the reducing compound. An example chemical reaction would be: 2ZnO + C - 2Zn + CO . In some cases, the waste contains not only BOAT list metal constituents that can be volatilized but also nonvolatile BOAT list metals as well. In such cases, the HTMR process can yield two recoverable product streams. Whether such recovery can be accomplished, however, depends on the type and concentration of metals in the original wastestream. Below is a discussion of the recovery techniques for the volatile stream, as well as the waste material that is not volatilized. 85 ------- (a) Recovery of volatilized metals. The volatilized metals can be recovered in the metallic form or as an oxide. Recovery is accomplished in the case of the metallic form by condensation alone, and in the case of the oxide by reoxidation, condensation, and subsequent collection of the metal oxide particulates in a baghouse. There is no difference between these two types of metal product recovery systems relative to the kinds of waste that can be treated; the difference is simply reflected in a facility's preference relative to product purity. In the former case, the direct condensation of metals, while more costly, allows for the separation and collection of metals in a relatively uncontaminated form; in the latter case, the metals are collected as a combination of several metal oxides. If necessary, this combination of metal oxides could be further processed to produce individual metal products of increased purity. (b) Less volatile treatment residual. The fraction of the waste that is not originally volatilized has three possible dispositions: (1) the material is such that it can be used directly as a product (e.g., a waste residual containing mostly metallic iron can be reused directly in steelmaking); (2) the material can be reused after further processing (e.g., a waste residual containing oxides of iron, chromium, and nickel can be reduced to the metallic form and then recovered for use in the manufacture of stainless steel); and (3) the material has no recoverable value and is land disposed as a slag. 86 ------- (3) Description of the high temperature metals recovery process. The process essentially consists of four operations: (1) a blending operation to control feed parameters, (2) high temperature processing, (3) a product collection system, and (4) handling of the less volatile treated residual. A generic schematic diagram for high temperature metals recovery is shown in Figure 3-5. (a) Blending operation. For the system shown, variations in feeds are minimized by blending wastes from different sources. Prior to feeding the kiln, fluxing agents are added to the waste. Carbon is also added to the waste as required. The fluxes (limestone or sand) are added to react with certain waste components to prevent their volatilization, thus improving the purity of the desired metals recovered. In addition, the moisture content is adjusted by either adding water or blending various wastes. (b) High temperature processing. These materials are fed to the furnace where they are heated and the chemical reactions take place. The combination of residence time and turbulence helps to ensure the maximum volatilization of the metal constituents. (c) Product collection system. The product collection system can consist of either a condenser or a combination condenser and baghouse. As noted previously, the particular system depends on whether the metal is to be collected in the metallic form or as an oxide. 87 ------- K061 CARBON FLUXES (ADDITIVES). FEED BLENDING HIGH TEMPERATURE PROCESSING PRODUCT COLLECTION REUSE RESIDUAL COLLECTION REUSE OR LAND DISPOSAL FIGURE 3-5 EXAMPLE HIGH TEMPERATURE METALS RECOVERY SYSTEM 88 ------- (d) Handling the less volatile treated residual. The equipment needed to handle the less volatile metal-treated residual depends on the final disposition of the material. If further recovery is performed, then the waste would be treated in another furnace. If the material were to be land disposed, the final process step would generally consist of quenching. (4) Vlaste characteristics affecting performance. In determining whether high temperature metals recovery technologies are likely to achieve the same level of performance on an untested waste as on a previously tested waste, EPA will examine the following three waste characteristics that have an impact on treatability: (1) type and concentrations of metals in the waste, (2) relative volatility of the metals, and (3) heat transfer characteristics of the waste. (a) Type and concentrations of metals in the waste.. Because this is a metals recovery process, the product must meet certain requirements for recovery. If the waste contains other volatile metals that are difficult to separate and whose presence may affect the ability to refine the product for subsequent reuse, high temperature metals recovery may provide less effective treatment. Analytical methods for metals can be found in SW-846. (b) Boiling point. The relative volatilities of the metals in the waste also affect the ability to separate various metals. There is no conventional measurement technique for determining the relative 89 ------- volatility of a particular constituent in a given waste. EPA believes that the best measure of volatility of a specific metal constituent is the boiling point. EPA recognizes that the boiling point has certain shortcomings, primarily the fact that boiling points are given for pure components, while it is clear that other constituents in the waste will also affect partial pressures and thus the boiling point of the mixture. EPA has not identified a parameter that can better assess relative volatility. Boiling points of metals can be determined from the literature. (c) Heat transfer characteristics. The ability to heat constituents within a waste matrix is a function of the heat transfer characteristics of a heterogeneous waste material. The constituents being recovered from the waste must be heated near or above their boiling points in order for them to be volatilized and recovered. Whether sufficient heat will be transferred to the particular constituent to cause the metal to volatilize will depend on the heat transfer characteristics of the waste. There is no conventional direct measurement of the heat transfer characteristics of a waste. EPA believes that the best measure of heat transfer characteristics of the waste is thermal conductivity. The analytical method that EPA has identified for measurement of thermal conductivity is named "Guarded, Comparative, Longitudinal Heat Flow Technique"; it is described in Appendix C of this document. 90 ------- (5) Design and operating parameters. The parameters that EPA will evaluate when determining whether a high temperature metals recovery system is well designed and well operated are (a) the furnace temperature, (b) the furnace residence time, (c) the amount and ratio of the feed blending materials, and (d) mixing. Below is an explanation of why EPA believes these parameters are important to an analysis of the design and operation of the system. (a) Furnace temperature. In order for sufficient heat to be transferred to the waste for volatilization, high temperatures must be provided. The higher the temperature in the furnace, the more likely the constituents are to react with carbon to form free metals and volatilize. The temperature must be approximately equal to or greater than the boiling point of the metals being volatilized. Excessive temperatures could volatilize unwanted metals into the product, possibly inhibiting the potential for reuse of the volatilized product. In assessing performance during the treatment period, EPA would want continuous temperature data. (b) Furnace residence time. Furnaces must be designed to ensure that the waste has sufficient time to be heated to the boiling point of the metals to be volatilized. The time necessary for complete volatilization of these constituents is dependent on the furnace temperature and the heat transfer characteristics of the waste. The 91 ------- residence time is a function of the physical dimensions of the furnace (length, diameter, and slope (for rotary kilns)), the rate of rotation (if applicable), and the feed rate. (c) Amount and ratio of feed blending materials. For the maximum volatilization of the metals being recovered, the following feed parameters must be controlled by the addition of carbon, fluxes, and other agents, if necessary. Blending of these feed components is also needed to adjust the following feed parameters to the required volume: carbon content, moisture content, calcium-to-silica ratio, and the initial concentration of the metals to be recovered. These parameters all affect the rate of the reduction reaction and volatilization. EPA will examine blending ratios during treatment to ensure that they comply with design conditions. (d) Mixing. Effective mixing of the total components is necessary to ensure that a uniform waste is being treated. Turbulence in the furnace also ensures that no "pockets" of waste go untreated. Accordingly, EPA will examine the type and degree of mixing involved when assessing treatment design and performance. 3.2.5 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 92 ------- the broader class of stabilization. Related technologies are encapsulation and thermoplastic binding; however, EPA considers these technologies to be distinct from stabilization in that the operational principles are significantly different. (1) Applicability and use of this technology. 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 that contain BOAT list metals and have 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. A brief discussion of each is provided below. In both cement-based or lime/pozzolan-based techniques, the 93 ------- stabilizing process can be modified through the use of additives, such as silicates, that control curing rates or enhance the properties of the solid material. (a) Portland cement-based process. Portland cement is a mixture of powdered oxides of calcium, silica, aluminum, and iron, produced by kiln burning of materials rich in calcium and silica at high temperatures (i.e., 1400 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 94 ------- so upon the addition of lime. Metals in the waste are converted to silicates or hydroxides that inhibit leaching. Additives, again, can be used to reduce permeability and thereby further decrease leaching potential. (3) Description of stabilization processes. 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 95 ------- mixers similar to concrete batching plants have been adapted in some operations. Where extremely dangerous materials are being treated, remote-control and in-drum mixing equipment, such as that used with nuclear waste, can be employed. (4) Waste characteristics affecting performance. In determining whether stabilization is likely to achieve the same level of performance on an untested waste as on a previously tested waste, the Agency will focus on the characteristics that inhibit the formation of either the chemical bonds or the lattice structure. The four characteristics EPA has identified as affecting treatment performance are the presence of (1) fine particulates, (2) oil and grease, (3) organic compounds, and (4) certain inorganic compounds. (a) Fine particulates. For both cement-based and 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 decrease the resistance of the material to leaching. (b) Oil and grease. The presence of oil and grease in both cement-based and 1ime/pozzolan-based systems results in the coating of 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. 96 ------- (c) Organic compounds. The presence of organic compounds in the waste interferes with the chemical reactions and bond formation that inhibit curing of the stabilized material. This results in a stabilized waste that has decreased resistance to leaching. (d) Sulfate and chlorides. The presence of certain inorganic compounds will interfere with the chemical reactions, weakening bond strength and prolonging setting and curing time. Sulfate and chloride • compounds may reduce the dimensional stability of the cured matrix, thereby increasing Teachability potential. Accordingly, EPA will examine these constituents when making decisions regarding transfer of treatment standards based on stabilization. (5) Design and operating parameters. In designing a stabilization system, the principal parameters that must be optimized so that the amount of Teachable metal constituents is minimized are (a) selection of stabilizing agents and other additives, (b) ratio of waste to stabilizing agents and other additives, (c) degree of mixing, and (d) 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 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 97 ------- 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. 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 in that 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. Mixing is necessary to ensure homogeneous distribution of the waste and the stabilizing agents. Conditions include the type and duration of mixing. Both undermixing and overmixing are undesirable. The first condition results in a nonhomogeneous mixture; therefore, areas 98 ------- will exist within the waste where waste particles are neither chemically bonded to the stabilizing agent nor physically held within the lattice structure. Overmixing, on the other hand, may inhibit gel formation and ion adsorption in some stabilization systems. As with the relative amounts of waste, stabilizing agent, and additives within the system, optimal mixing conditions generally are determined through laboratory tests. During treatment it is important to monitor the degree (i.e., type and duration) of mixing to ensure that it reflects design conditions, (d) Curing conditions. The curing conditions include the duration of curing and 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. 99 ------- 3.3 Data Base For the treatment system tested by the Agency, Tables 3-1 to 3-11 provide concentrations of BOAT list metals present in the untreated waste streams, the treated wastewater, and the total concentration and the TCLP values of the treated nonwastewater (cake). The untreated waste streams are mixed and then processed in the treatment system. The composition of the waste stream resulting from the mixing is also shown in Tables 3-1 to 3-11. The treated K062 wastewater is the filtrate from the vacuum filter, and the treated K062 nonwastewater (cake) is the filter cake from the vacuum filter. In the data from the 11 sample sets, chromium, copper, and nickel were present in the highest concentrations in the untreated K062 waste. The concentration data for the untreated waste also show that arsenic and zinc were present in much lower concentrations. The chemical precipitation treatment operations on all 11 sets were carried out in the design pH range of 8 to 10. As described in Section 3.2, the waste characteristics affecting chromium reduction, chemical precipitation, and precipitate dewatering for the untreated waste K062 are suspended solids concentration, dissolved solids concentration, oil and grease content, and complexed metal concentration. For suspended solids, the observed concentrations in the untreated waste were <1 to 100 mg/1; for dissolved solids, 1900 to 118,100 mg/1; and for oil and grease, <0.2 to 6 mg/1; tests for metal complexes were not performed. 100 ------- A comment received on the Notice of Availability and Request for Comments on the California List Constituents (51 FR 2991) suggested that K062 wastewaters and nonwastewaters can be treated by high temperature metals recovery. The Agency, therefore, is including high temperature metals recovery as a demonstrated treatment technology for K062 nonwastewaters. The Agency has requested data describing the performance achievable by high temperature metals recovery. Upon review of the data submitted, the Agency may promulgate final standards based on high temperature metals recovery. The performance data for the system tested by the Agency indicate that the system appears to be well designed and well operated. The low concentration of BOAT list metals in treated wastewaters and low TCLP metal values for treated nonwastewaters show that the K062 waste was effectively treated. Therefore, chromium reduction and chemical precipitation, followed by dewatering of the precipitate, is a demonstrated technology for K062 wastes. 101 ------- IRON-BEARING ACID LIME SLURRY 1 o WASTE ^ STREAM K062 ^ CHROMIUM REDUCTION ^ CHEMICAL PRECIPITATION »- VACUUM FILTRATION »- FILTRATE TO ^•MUNICIPAL SEWER CAKE TO METALS RECOVERY FIGURE 3-6 SCHEMATIC DIAGRAM OF TREATMENT PROCESS FOR KO62 WASTES ------- 1665g Table 3-1 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #1 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 801 3 I 1800 865 <10 3200 <2 Design Untreated K062 waste (mg/1) Sample no. 802 <1 I 7000 306 <10 2600 <2 Design value Untreated waste composite (mg/1) Sample no. 805 <1 893 2581 138 64 471 116 Treated waste (wastewater) (rag/D Sample no. 806 <0.1 0.011 0.12 0.21 <0.01 0.33 0.125 Treated waste K.062 (nonwastewater) Total TCLP (mg/kg) (mg/1) Sample no. 807 807 <1 1.43 7300 380 2800 1400 1300 <0.010 - <0.050 - <0.10 - - and Operating Data Operating value 8-10 aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 103 ------- 1665g Table 3-2 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #2 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 801 3 I 1800 865 <10 3200 <2 Desiqn Untreated K062 waste (mg/1) Sample no. 802 <1 I 7000 306 <10 2600 <2 Design value Untreated waste compos itea (mg/1) Sample no. 813 <1 807 2279 133 54 470 4 and Operating Treated waste (wastewater) (mg/1) Sample no. 814 <0.1 0.12 0.19 0.15 <0.01 0.33 0.115 Data Treated waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 815 815 1 1.04 7400 400 1200 1200 2100 <0.010 - <0.050 - <0.10 - - Operating value 8-10 aThe untreated waste composite is a mixture of the untreated K.062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 104 ------- 1665g Table 3-3 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #3 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 817 3 I 1700 425 <10 100310 7 Design Untreated K.062 waste (mg/1) Sample no. 802 <1 I 7000 306 <10 2600 <2 Design value Untreated waste composite3 (mg/D Sample no. 821 <1 775 1990 133 <10 16330 3.9 Treated waste (wastewater) (mg/1) Sample no. 822 <0.1 I 0.20 0.21 <0.01 0.33 0.140 Treated waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 823 823 2 I 4000 445 118 3900 112 0.012 - <0.050 - <0.10 - - and Operating Data Operating value pH 8-10 10 aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 105 ------- 1665g Table 3-4 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #4 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 827 2 1 142 42 <10 650 3 Design Untreated K062 waste (mg/D Sample no. 802 <1 I 7000 306 <10 2600 <2 Design value Untreated K062 waste (mg/1) Sample no. 817 3 I 1700 425 <10 41000 7 Untreated waste composite3 (mg/1) Sample no. 829 <1 0.6 556 88 <10 6610 84 Treated waste (wastewater) (mg/1) Sample no. 830 <1 0.042 0.10 0.07 <0.01 0.33 1.62 Treated Waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 831 831 2 0.92 2400 292 99 2700 1200 0.015 - 0.068 - <0.10 - - and Operating Data Operat ing value pH 8-10 aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 106 ------- Ib6bg Table 3-5 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #5 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K.062 waste (mg/1) Sample no. 801 3 I 1800 865 <10 3200 <2 Design Untreated K062 waste (mg/1) Sample no. 802 <1 I 7000 306 <10 2600 <2 Design value Untreated K062 waste (mg/1) Sample no. 817 3 I 1700 425 <10 41000 7 Untreated waste composite3 (mg/1) Sample no. 837 <1 917 2236 91 18 1414 71 Treated waste (wastewater) (mg/1) Sample no. 838 <0.1 0.058 0.11 180.14 0.01 0.31 0.125 Treated waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 839 839 1 0.741 11500 375 525 3300 410 <0.010 - <0.050 - <0.10 - - and Operating Data Operating value pH 8-10 aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 107 ------- 1665g Table 3-6 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #6 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 801 3 I 1800 865 <10 3200 <2 Untreated K062 waste (mg/1) Sample no. 802 <1 I 7000 306 <10 2600 <2 Design Untreated waste composite3 (mg/1) Sample no. 845 <1 734 2548 149 <10 588 4 and Operating Treated waste (wastewater) (mg/1) Sample no. 846 <0.1 I 0.10 0.12 <0.01 0.33 0.095 Data Treated waste Total (mg/kg) K062 TCLP (mg/1) Sample no. 847 1 1.775 10000 432 42 1600 68 847 <0.010 - <0.050 - <0.10 - - pH Design value 8-10 Operating value aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K.062 waste streams. I = Color Interference. - = Not Analyzed. 108 ------- 1665g Table 3-7 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #7 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 801 3 I 1800 865 <10 3200 <2 Design Untreated K.062 waste (mg/1) Sample no. 802 <1 I 7000 306 <10 2600 <2 Design value Untreated waste composite3 (mg/1) Sample no. 853 <1 769 2314 72 108 426 171 Treated waste (wastewater) (mg/1) Sample no. 854 <0.1 0.12 0.12 0.16 <0.01 0.40 0.115 Treated Waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 855 855 1 I 16300 330 375 1700 375 <0.010 - <0.050 - <0.10 - - and Operating Data Operating value 8-10 The untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 109 ------- 1665g Table 3-8 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #8 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 859 <1 0.220 15 151 <10 90 7 Design Untreated K062 waste (mg/1) Sample no. 801 3 I 1800 865 <10 3200 9 Design value Untreated waste composite3 (mg/1) Sample no. 861 <1 0.13 831 217 212 669 151 and Operating Treated waste (wastewater) (mg/1) Sample no. 862 <0.1 <0.01 0.15 0.16 <0.01 0.36 0.130 Data Treated Waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 863 863 4 0.116 2800 688 300 2600 420 0.011 - <0.050 - <0.10 - - Operating value 8-10 The untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 110 ------- i665g Table 3-9 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #9 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/D Sample no. 867 <0.1 0.079 6 5 <1 4 0.4 Untreated K062 waste (mg/D Sample no. 801 3 I 1800 865 <10 3200 <2 Design Untreated K062 waste (mg/D Sample no. 802 <1 I 7000 306 <10 2600 <2 and Operating Untreated waste composite (mg/1) Sample no. 869 <1 0.07 939 225 <10 940 5 Data Treated waste (wastewater) (mg/1) Sample no. 870 <0.1 0.041 0.10 0.08 <0.01 0.33 0.06 Treated Waste K062 Total (mg/kg) Sample 871 3 I 3400 775 85 3500 150 TCLP (mg/1) no. 871 0.011 - <0.050 - <0.10 - - PH Design value 8-10 Operating value 10 The untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. Ill ------- 1665g Table 3-10 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #10 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 801 <3 I 1800 865 <10 3200 <2 Design Untreated waste compos i te (mg/1) Sample no. 885 <1 0.08 395 191 <10 712 5 Design and value Treated waste (wastewater) (mg/1) Sample no. 862 <0.10 0.106 0.12 0.14 <0.01 0.33 0.070 Operating Data Operating Treated Waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 863 863 5 0.078 4400 758 28 4700 43 value 0.016 - <0.050 - <0.10 - - pH 8-10 aThe untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. ii'2 ------- 1665g Table 3-11 Treatment Performance Data for K062 - EPA-Collected Data Sample Set #11 Constituent Arsenic Chromium (hexavalent) Chromium (total) Copper Lead Nickel Zinc Untreated K062 waste (mg/1) Sample no. 801 3 I 1800 865 <10 3200 <2 Design Untreated K062 waste (mg/1) Sample no. 859 <1 0.220 15 151 <10 90 7 Design value Untreated waste composite3 (mg/1) Sample no. 893 <1 0.30 617 137 136 382 135 Treated waste (wastewater) (mg/1) Sample no. 894 <0.10 <0.01 0.18 0.24 <0.01 0.39 0.100 Treated Waste K062 Total TCLP (mg/kg) (mg/1) Sample no. 895 895 3 1.240 2100 388 200 1600 325 <0.010 - <0.050 - <0.10 - - and Operating Data Operating value pH 8-10 The untreated waste composite is a mixture of the untreated K062 waste streams shown on this table, along with other non-K062 waste streams. I = Color Interference. - = Not Analyzed. 113 ------- 4. IDENTIFICATION OF BEST DEMONSTRATED AND AVAILABLE TECHNOLOGY (BOAT) 4.1 Introduction This section presents the methodology for identifying BOAT based on the treatment performance data collected for the demonstrated technologies described in Section 3. This section provides EPA's rationale for determining which of the demonstrated technologies represents BOAT. As discussed in the previous section, the demonstrated technologies for K062 are chromium reduction followed by chemical precipitation and dewatering of the precipitate. In addition, the wastewaters can be further treated using polishing filtration. For the precipitated solids, i.e., the nonwastewaters, the demonstrated technologies include metals recovery and stabilization. EPA tested a treatment system consisting of chromium reduction, chemical precipitation, and dewatering by vacuum filtration. We believe the performance achieved by this treatment train represents BOAT; our rationale is provided below. 4.1.1 Wastewaters Regarding the wastewaters, the only applicable and demonstrated technology beyond the tested technology is polishing filtration. EPA does not expect this technology to significantly reduce the BOAT list metals concentration to less than that achieved by the tested technology. Therefore, EPA believes that this treatment train is the "best" demonstrated technology for K062 wastewaters; that is, additional treatment would not be expected to significantly improve the performance. 114 ------- 4.1.2 Nonwastewaters For nonwastewaters, the only applicable and demonstrated technologies to be considered, in addition to the technology tested (i.e., chemical precipitation), are stabilization and metals recovery. The Agency is aware of a high temperature metals recovery process for the treatment of K062 nonwastewaters. The Agency has requested data describing the performance achievable by metals recovery and will reconsider this technology when the data are received. Additional treatment by stabilization is not expected to significantly reduce the Teachability of the BOAT list metals present in treated K062 nonwastewaters. As described in Section 1, the best demonstrated available technology (BOAT) for treatment of these wastes is determined based on the performance data presented in Section 3. Performance data are screened for poor design and poor operation and are adjusted on the basis of the analytical recovery values. Based on the performance data for the treatment train, chromium reduction, chemical precipitation, and precipitate dewatering, the Agency believes that the performance achieved by this treatment train represents BOAT. 4.2 Determination of "Available" As described in Secion 1, treatment standards will be based on technologies that are determined to be available. Chromium reduction and chemical precipitation followed by dewatering of the precipitate has been determined to be demonstrated and available treatment technology since (1) they are not proprietary or patented processes that cannot be 115 ------- purchased or licensed from the proprietor; and (2) they represent substantial treatment since they significantly diminish the toxicity of the waste or substantially reduce the likelihood that hazardous constituents will migrate from the waste. 4.3 BOAT for K062 Wastes The best demonstrated and available technology for K062 wastes has been determined to be chromium reduction and chemical precipitation, followed by dewatering of the precipitated solids. A schematic diagram of this BOAT treatment train is presented in Figure 3-6. 116 ------- 5. SELECTION OF REGULATED CONSTITUENTS 5.1 Introduction 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," which means it 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, other inorganics, organochlorine pesticides, phenoxyacetic acid herbicides, organophosphorous pesticides, PCBs, and dioxins and furans. This section describes the step by step process used to select the pollutants to be regulated. The selected pollutants must be present in the untreated waste and must be treatable by the chosen BOAT, as discussed in Section 4. 5.2 Identification of Ma.lor Constituents in K062 In the previous section, the Agency selected the best demonstrated treatment technology for treating K062 wastes. The constituents chosen by the Agency for regulation are found in untreated wastes at treatable concentrations for the selected BOAT. Based on the analysis of the processes generating K062 wastes, as shown on the list of BOAT constituents presented in Table 5-1 (232 in number), the Agency does not expect that the following categories (containing 213 constituents) will be present in K062 wastes: volatile organics, semivolatile organics, organochlorine pesticides, phenoxyacetic acid herbicides, 117 ------- organophosphorous pesticides, PCBs, and dioxins and furans. Therefore, the abovementioned categories were not analyzed for in the K062 wastes tested by the Agency. Furthermore, the Agency has no data indicating that these categories would be present in K062 wastes. The remaining 19 constituents fall into the categories of metals and other inorganics. 5.2 Selection of Regulated Constituents As discussed in Section 2, K062 primarily contains metals, other inorganics, and water. Of the 16 metals in the BOAT list of constituents, the Agency has data showing that antimony, barium, beryllium, cadmium, mercury, selenium, silver, and thallium, are present below detectable levels in K062 wastes. However, the Agency does not believe that these metals are present at levels treatable by the chosen BOAT. Although vanadium was not analyzed for in the K062 waste tested by the Agency, it is not expected that vanadium will be present in K062 wastes at treatable levels. The metals found in treatable concentrations in the untreated K062 waste tested by the Agency are chromium, copper, and nickel. Data are also available that indicate that lead may be present at significant (i.e., treatable) concentrations in K062 wastes from pickling operations from leaded steels. Arsenic and zinc were detected at relatively low concentrations in the untreated waste tested by the Agency, and are expected to be treated along with the metals present at higher concentrations. Hexavalent chromium was detected at less than 1 mg/1 in the untreated K062 waste for some data sets; for 118 ------- others, color interference prevented the analyses for hexavalent chromium. Based on these findings, the Agency has selected for regulation the following metals from the BOAT list of constituents: chromium, copper, lead, and nickel. The solubilities of all these metals are lowest within the design and operating pH range for the BOAT, i.e., a pH range of 8 to 10. For hexavalent chromium, the Agency expects that a well-designed and well-operated chromium reduction system, included in the selected BOAT treatment train, will treat any hexavalent chromium. The Agency is not regulating any of the other three BOAT list inorganic constituents that may be present in K062 wastes, as they will not be treated by the chosen BOAT. If in the future the Agency finds that these other inorganics require treatment, it will set treatment standards at that time. The following table shows the constituents to be regulated and concentration ranges at which they have been reported in the data available to the Agency. Range present in the List of regulated constituents untreated K062 waste (mq/1) Chromium 6 to 7000 Copper 5 to 865 Lead 0.12 to 1550 Nickel 4 to 100,310 119 ------- 1556g Table 5-1 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 Acrylomtrile Benzene Bromodichloromethane Bromomethane n-Butyl alcohol Carbon tetrachloride Carbon disulfide Chlorobenzene 2-Chloro-l,3-butadiene Chlo rod ibromome thane Chloroethane 2-Chloroethyl vinyl ether Chloroform Chloromethane 3-Chloropropene 1 , 2-Oibromo-3-chloropropane 1 , 2-0 i bromoethane Dibromomethane Trans- l,4-Dichloro-2-butene Dlchlorodif luoromethane 1,1-Oichloroethane 1,2-Dichloroethane 1 , 1-Dichloroethy lene Trans-1 ,2-Oichloroethene 1 . 2-Dichloropropane Trans-1 ,3-Dichloropropene cis-1 ,3-Oichloropropene 1,4-Oioxane 2-£thoxyethanol Ethyl acetate Ethyl benzene Ethyl cyanide Ethyl ether Ethyl methacrylate Ethylene oxide lodomethane Units ppb ppb ppb PPb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppfa ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb 0 = Detected NO = Not detected NA = Not analyzed 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 120 ------- 1556g 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. Parameter Volati les (continued) Isobutyl alcohol Methanol Methyl ethyl ketone Methyl isobutyl ketone Methyl methacrylate Methacrylomtri le Methylene chloride 2-Nitropropane Pyndine 1,1,1, 2-Tetrachloroethane 1,1,2 , 2-Tetrach loroethane Tetrach loroethene Toluene Tribromomethane 1,1 ,1-Trich loroethane 1,1,2-Trichloroethane Trichloroethene Trichloromonof luoromethane 1,2,3-Tnchloropropane l,l,2-Trichloro-l,2,2-trif luoro- ethane Vinyl chloride 1,2-Xylene 1,3-Xylene 1,4-Xylene Semivolatiles Acenaphthalene Acenaphthene Acetophenone 2-Acetylaminof luorene 4-Aminobiphenyl Am 1 me Anthracene Aramite Benz(a)anthracene Benzal chloride Benzenethiol Deleted Benzo(a)pyrene Units ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb . ppb ppb D = Detected ND = Not detected NA = Not anal>>ed 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 121 ------- 1556g 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 Parameter Semivolati les (continued) Benzo(b)f luoranthene Benzofghi Jperylene Benzo(k)f luoranthene p-Benzoquinone B i s ( 2-ch loroethoxy Jinethane Bis(2-chloroethyl) ether Bis(2-chloroisopropyl) ether Bis(2-ethylhexyl)phthalate 4-Bromophenyl phenyl ether Butyl benzyl phthalate 2-sec-Butyl-4,6-dimtrophenol p-Chloroam 1 ine Chlorobenzilate p-Chloro-m-cresol 2-Chloronaphthalene 2-Chlorophenol 3-Chloropropionitri le Chrysene ortho-Cresol para-Cresol Cyclohexanone D i benz ( a , h ) anthracene Dibenzo(a,e)pyrene Dibenzo(a, i Ipyrene m-Dichlorobenzene o-Dichlorobenzene p-Oichlorobenzene 3,3'-Oichlorobenzidine 2,4-Dichlorophenol 2,6-Dichlorophenol 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-Dimtro-o-cresol 2,4-Dinitrophenol Units ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb D = Detected ND = Not detected NA = Not analyzed 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 122 ------- 1556g Table 5-1 (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-Oinitrotoluene 2,6-Oimtrotoluene Di-n-octyl phthalate Di-n-propylnitrosamine Diphenylamme D i pheny 1 n 1 1 rosam i ne 1 ,2-Diphenylhydrazine Fluoranthene Fluorene Hexach lorobenzene Hexachlorobutadiene Hexachlorocycl open tad lene Hexach loroethane Hexach lorophene Hexach loropropene lndeno(l,2,3-cd)pyrene Isosafrole Methapyri lene 3-Methylcholanthrene 4,4'-Methylenebis (2-chloroam 1 me) Methyl methanesulfonate Naphthalene 1 , 4-Naphthoqu i none 1-Naphthylamine 2-Naphthylamme p-Nitroani line Nitrobenzene 4-Nitrophenol N-Nitrosodi-n-butylamme N-Nitrosodiethylamine N-N i t rosodi methyl am ine N-Nitrosomethylethylamme N-Nitrosomorphol me N-Nitrosopipendme n-Nitrosopyrrol idine 5-Nitro-o-toluidme Pentach lorobenzene Pentach loroethane Pentach loron i t robenzene Units ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb 0 = Detected NO = Not detected NA = Not analyzed 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 123 ------- 1556g 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. Parameter Semivolati les (continued) Pentachlorophenol Phenacetin Phenanthrene Phenol Phthalic anhydride 2-Picoline Pronamide Pyrene Resorcinol Safrole 1,2,4, 5-Tetrachlorobenzene 2 , 3 , 4 , 6-Tet rach loropheno 1 1 ,2,4-Trichlorobenzene 2,4,5-Trichlorophenol 2,4,6-Trichlorophenol Tr i s ( 2 , 3-d i bromopropy 1 ) phosphate Hetals Ant imony Arsenic Barium Beryllium Cadmium Chromium (total) Chromium (hexavalent) Copper Lead Mercury Nickel Selenium Si Iver Thall lum Vanadium Zinc Inorganics Cyanide Fluoride Sulf ide Units ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb 10 * 10 2 5 10 1 10 2 10 2 D = Detected ND = Not detected NA = Not analyzed NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA NA ND D ND ND ND D D D ND ND D ND ND ND NA D ND NA D 124 ------- 1556g 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. 196 137. 198. 199 200. 201 202. Parameter Oroanochlorine pesticides Aldnn alpha-BHC beta-BHC delta-BHC gamma-BHC Chlordane ODD DDE DDT Dieldrin Endosulfan I Endosulfan II Endrin Endnn aldehyde Heptachlor Heptachlor epoxide Isodrin Kepone Methoxyclor Toxaphene Phenoxyacetic acid herbicides 2,4-Dichlorophenoxyacetic acid Si Ivex 2,4.5-T Orqanoohosphorous insecticides Disulfoton Famphur Methyl parathion Parathion Phorate PCBs Aroclor 1016 Aroclor 1221 Aroclor 1232 Units ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb ppb D = Detected NO = Not detected NA = Not analyzed 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 125 ------- 1556g Table 5-1 (continued) BOAT reference no. Parameter D = Detected Unit ND = Not detected NA = Not analyzed PCBs (continued) 203. 204. 205. 206. Aroclor 1242 Aroclor 1248 Aroclor 1254 Aroclor 1260 ppb ppb ppb ppb NA NA NA NA 207. 208. 209 210. 211. 212. 213. Dioxins and furans Hexachlorodibenzo-p-dioxins ppb Hexachlorodibenzofurans ppb Pentachlorodibenzo-p-dioxins ppb Pentachlorodlbenzofurans ppb Tetrachlorodibenzo-p-dioxins ppb Tetrachlorodibenzofurans ppb 2,3,7,8-Tetrachlorodibenzo-p-dioxin ppb NA NA NA NA NA NA NA * Five samples had a detection limit of 1 mg/1 and one had 0.1 mg/1 D = Detected ND = Not detected NA = Not analyzed 126 ------- 6. CALCULATION OF BOAT TREATMENT STANDARDS In the previous section, EPA chose the constituents in the untreated i K062 waste to be regulated. The purpose of this section is to calculate treatment standards for those regulated constituents. Details of the methodology are provided in "Generic Quality Assurance Project Plan (QAPP) for the Land Disposal Restriction Program (BOAT)," March 1987. As discussed in Section 5, the regulated constituents are chromium, copper, lead, and nickel. The BOAT treatment standards (1) are reflective of treatment data from a well-designed and well-operated treatment system, (2) account for analytical limitations, and (3) have been adjusted for variability owing to treatment, sampling, and analytical techniques and procedures. The BOAT treatment standards for K062 were derived as follows. 6.1 Correction of the Analytical Data The raw analytical data for the regulated constituents for K062 were corrected for the analytical recovery by multiplying by their respective recovery-correction factors. The recovery-correction factors are obtained by dividing 100 by the corresponding percent recovery of the constituents. Presently the percent recovery values for the regulated K062 constituents are being taken from the Onsite Engineering Report for Horsehead for K061 (USEPA 1987), since percent recovery values are not available for metal spikes and metal spike duplicates from the treatment data on K062. This is being done since all the metals that are being regulated in K062 were also analyzed for in K061. However, for K061, 127 ------- ICP Method 6010 (SW-846) was used to analyze for chromium, copper, lead, and nickel, whereas for K062, analysis for chromium was by Method 7190 (atomic absorption), copper by Method 220.1 (atomic absorption), lead by Method 7420 (atomic absorption), and nickel by Method 7520 (atomic absorption). The transferred percent recovery values for total composition are 68, 83, 76, and 93 percent for chromium, copper, lead, and nickel, respectively. The transferred percent recovery value for TCLP for chromium and lead are 68 and 76 percent, respectively. The corrected concentration values for the regulated constituents in the treated wastewater residuals are presented in Table 6-1. The corrected TCLP values in the treated nonwastewater residuals are provided in Table 6-2. 6.2 Calculation of Variability Factors and Treatment Standards Details of the treatment standard calculation methodology are given in Section 1. In summary, average values of corrected concentrations of the regulated pollutants in the treated residuals for the 11 data sets were calculated. Variability factors were then calculated by determining the logarithm of the concentration values of the regulated constituents in the treated wastewater residual stream and also for the TCLP values of the treated nonwastewater residual stream. Following this, their logarithmic mean and logarithmic standard deviation were calculated. All these values were then applied to the formula for variability factor calculation (given in Appendix A). Table 6-3 presents the concentration of the regulated constituents for each treated wastewater sample. The table also shows the mean value, the calculated variability factor, and 128 ------- the treatment standard. The treatment standard is the product of the mean concentration and the variability factor. Table 6-4 shows the same procedure for the treated nonwastewater residual leachate (TCLP). The Agency does not have treatment performance data on the treatment of K062 wastes containing lead. Therefore, the Agency is transferring treatment data for lead from lead-containing non-K062 wastes treated at Envirite, along with the K062 wastes tested by the Agency. The Agency expects that the mixed wastes referred to above, are at least as difficult to treat as K062 wastes containing lead. Accordingly, EPA believes that the level of performance achieved for lead in the wastes treated in the treatment system tested by the Agency, can be transferred to lead in K062 wastes. EPA requests comments on its assertion that the waste for which we have treatment data would be as difficult to treat as lead-containing K062 wastes. In summary, the BOAT treatment standards for K062 are as follows: Treated residual Treated residual (wastewater) (nonwastewater) Constituent total concentration (mq/1) TCLP (mq/1) Chromium (total) 0.32 0.094 Copper 0.42 Lead 0.04 0.37 Nickel 0.44 129 ------- 1666g Table 6-1 Calculation of Corrected Values for Regulated Constituents for Treated Wastewaters - Total Composition Treated waste Constituent (ntg/1) Chromium (total) 0.12 0.12 0.20 0.10 0.11 0.10 0.12 0.15 0.10 0.12 0.18 Copper 0.21 0.15 0.21 0.07 0.14 0.12 0.16 0.16 0.08 0.14 0.24 Lead <0.01 <0.01 <0.01 <0.01 0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 Percent3 Correction Corrected value recovery factor (mg/1) 68 1.47 0.1764 0.1764 0.294 0.147 0.162 0.147 0.1764 0.2205 0.147 0.1764 0.2646 83 1.205 0.253 0.181 0.253 0.084 0.1687 0.145 0.193 0.193 0.096 0.1687 0.2892 76 1.316 <0.0132 <0.0132 <0.0132 <0.0132 0.0132 <0.0132 <0.0132 <0.0132 <0.0132 <0.0132 <0.0132 130 ------- 1666g Table 6-1 (continued) Treated waste Constituent (mg/1) Nickel 0.33 0.33 0.33 0.33 0.31 0.33 0.40 0.36 0.33 0.33 0.39 Percent3 Correction Corrected value recovery factor ' (mg/1) 93 1.075 0.35 0.35 0.35 0.35 0.33 0.35 0.43 0.39 0.35 0.35 0.42 aThe percent recovery has been taken from Table 7-14 of the Onsite Engineering Report from Horsehead Resource Development Company. U.S. EPA 1987. 131 ------- 1666g Table 6-2 Calculation of Corrected Values for Regulated Constituents for Treated Nonwastewaters - TCLP Values Treated waste Constituent (cake) TCLP(mg/l) Chromium (total) <0.050 <0.050 <0.050 0.068 <0.050 <0.050 <0.050 <0.050 <0.050 <0.050 <0.050 Lead <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 <0.10 Percent3 Correction Corrected recovery factor value (ing/1) 68 1.47 <0.0735 <0.0735 <0.0735 0.1000 <0.0735 <0.0735 <0.0735 <0.0735 <0.0735 <0.0735 <0.0735 76 1.316 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 aThe percent recovery has been taken from Table 7-14 of the Onsite Engineering Report from Horsehead Resource Development Company. U.S. EPA 1987. 132 ------- 1535g Table 6-3 Calculation of the Treatment Standards for the Regulated Constituents - Treated Wastewaters Treatment standard Regulated total concentration constituent Cone. Mean VF (mg/1) Chromium (total) .1765 .1898 1.69 0,32 .1765 .2941 .1471 .1618 .1471 .1765 .2206 .1471 .1765 .2647 Copper .2530 .1840 2.30 0.42 .1807 .2530 .0843 .1687 .1446 .1928 .1928 .0964 .1687 .2892 Lead <0.0132 0.0132 2.8a 0.04 <0.0132 <0.0132 <0.0132 0.0132 <0.0132 <0.0132 <0.0132 <0.0132 <0.0132 <0.0132 133 ------- 1535g Table 6-3 (continued) Treatment standard Regulated total concentration constituent Cone. Mean VF (mg/1) Nickel .3548 .3685 1.20 0.44 .3548 .3548 .3548 .3333 .3548 .4301 .3871 .3548 .3548 .4194 aFor cases in which all values are at or below the detection limit, the variability factor is taken as 2.8. 134 ------- 1535g Table 6-4 Calculation of the Treatment Standards for the Regulated Constituent - Treated Nonwastewaters Regulated constituent Chromium (total) Lead Cone . Mean VF <0.0735 0.0759 1.24 <0.0735 <0.0735 0.1 <0.0735 <0.0735 <0.0735 <0.0735 <0.0735 <0.0735 <0.0735 <0.132 0.132 2.8a <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 <0.132 Treatment standard TCLP values (mg/1) 0.094 0.37 For cases in which all values are at or below the detection limit, the variability factor is taken as 2.8. 135 ------- 7. CONCLUSION The Agency has proposed treatment standards for the listed waste code K062 from the steel industry. Standards for nonwastewater forms of these wastes are presented in Table 7-1, while standards for wastewater forms of these wastes are shown in Table 7-2. The treatment standards proposed for K062 have been developed consistent with EPA's promulgated methodology for BOAT (November 7, 1986, 51 FR 40572). K062 wastes are generated by the steel industry from steel finishing operations. K062 wastes are primarily comprised of BOAT list metals, water, and other inorganics. Although the concentrations of specific constituents will vary from facility to facility, all of the wastes are expected to contain similar BOAT list metals, have low filterable solids content, and are expected to be treatable to the same levels using the same technology. The BOAT list constituents generally present in K062 wastes are chromium, copper, lead, and nickel. Through EPA's technology testing program, the Agency has identified the following demonstrated technology for the treatment of metal constituents present in the K062 wastes: chromium reduction, chemical precipitation, and dewatering of the precipitate. Stabilization is a potentially applicable process for treatment of BOAT list metal constituents in nonwastewater residues resulting from the dewatering of the precipitated solids. Metals recovery from the filter cake resulting from the dewatering step in the treatment of K062 waste is an applicable and demonstrated technology for the recovery of metals. The Agency is 136 ------- presently collecting treatment data from the high temperature metals recovery process for the recovery of metals from the filter cake from the treatment of K062. For wastewaters resulting from the dewatering step, polishing filtration is an applicable and demonstrated technology to remove any BOAT list metals contained in the suspended solids in the wastewaters. Regulated constituents were selected based on a careful evaluation of the constituents found at treatable levels in the untreated wastes and constituents detected in the treated wastes. All available waste characterization and applicable treatment data, consistent with the type and quality of data needed by the Agency on this program, were used to make this determination. Those constituents that were most indicative of a well-designed, well-operated treatment system were chosen as the regulated constituents. For K062 waste, those constituents also represent the BOAT list constituents that the Agency believes will be present at the highest concentrations. Some constituents present at treatable concentrations in the untreated waste were not regulated if it was determined that they would be adequately controlled by the regulation of another constituent. In the development of treatment standards for these wastes, the Agency examined all available treatment data. The Agency conducted tests on a full-scale treatment system consisting of chromium reduction, chemical precipitation, and precipitate dewatering for K062 wastes. Design and operating data collected during the testing of the treatment technology train indicate that the treatment system was properly operated 137 ------- during each sample set. Accordingly, all of the treatment performance data collected during the tests were used in the development of the BOAT treatment standards. Two categories of treatment standards were developed for wastes in the K062 treatability group: wastewater and nonwastewater wastes. (For the purpose of the land disposal restrictions rule, wastewaters are defined as wastes containing less than 1 percent (weight basis) filterable solids and less than 1 percent (weight basis) total organic carbon.) Treatment standards for these wastes were derived after adjustment of laboratory data to account for recovery. The percent recovery values are being transferred from testing and analysis results for K061 (emission dust from electric arc furnaces) for corresponding metal constituents. This was necessary because the laboratory results for percent recovery values for the K062 treatment tests are not available. Subsequently, the mean of the adjusted data points was multiplied by a variability factor to derive the standard. The variability factor represents the variability inherent in the treatment process and sampling and analytical methods. Variability factors were determined by statistically calculating the variability seen for a number of data points for a given constituent. Wastes determined to be K062 wastes may be land disposed if they meet the standards at the point of disposal. The BOAT upon which the treatment standards are based (chromium reduction and chemical precipitation followed by precipitate dewatering) need not be 138 ------- specifically utilized prior to land disposal, provided an alternative technology achieves the standards. These standards become effective as of August 8, 1988, as per the schedule set forth in 40 CFR 268.10. Consistent with Executive Order 12291, EPA prepared a regulatory impact analysis (RIA) to assess the economic effect of compliance with this proposed rule. The RIA prepared for this proposed rule is available in the Administrative Record for the First Sixths' Rule. 139 ------- 1556g Table 7-1 BOAT Treatment Standards for Nonwastewater K062 Wastes Regulated Metal Constituents TCLP (mg/1) Chromium (total) 0.094 Lead 0.37 Table 7-2 BOAT Treatment Standards for Wastewater K062 Wastes Regulated metal constituents Total concentration (mg/1) Chromium (total) 0.32 Copper 0.42 Lead 0.04 Nickel 0.44 140 ------- REFERENCES Ajax Floor Products Corp. n.d. Product literature: technical data sheets, Hazardous waste disposal system. P.O. Box 161, Great Meadows, N.J. 07838. Aldrich, James R. 1985. Effects of pH and proportioning of ferrous and sulfide reduction chemicals on electroplating waste treatment sludge production. In Proceeding of the 39th Purdue Industrial Waste Conference, May 8, 9, 10, 1984. Stoneham, Mass: Butterworth Publishers. 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. Center for Metals Production. 1985. Electric arc furnace dust-disposal, recycle and recovery, Pittsburgh, Pa: May 1985. Cherry, Kenneth F. 1982. Plating waste treatment, pp. 45-67. Ann Arbor, Mich.: Ann Arbor Science Publishers, Inc. Conner, J.R. 1986. Fixation and solidification of wastes. Chemical Engineering Nov. 10, 1986. Cullinane, 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. Cushnie, George C., Jr. 1984. Removal of metals from wastewater: neutralization and precipitation, pp. 55-97. Park Ridge, N.J.: Noyes Publications. Cushnie, George C., Jr. 1985. Electroplating wastewater pollution control technology, pp. 48-62, 84-90. Park Ridge, N.J.: Noyes Publications. Duby, Paul. 1980. Extractive metallurgy. In Kirk-Othmer encyclopedia of chemical technology. Vol. 9, p. 741. New York: John Wiley and Sons. Eckenfelder, W.W. 1985. Wastewater Treatment. Chemical Engineering 85:72. 141 ------- 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. Grain, Richard W. Solids 1981. Removal and concentration. In Third Conference on Advanced Pollution Control for the Metal Finishing Industry. Cincinnati, Ohio. U.S. Environmental Protection Agency. pp. 56-62. Gurnham, C.F. 1955. Principles of industrial waste treatment. New York; John Wiley and Sons. pp. 224-234. Kirk-Othmer. 1980. Encyclopedia of chemical technology. 3rd ed. Vol. 10. New York: John Wiley and Sons. Lanouette, Kenneth H. 1977. Heavy metals removal. Chemical Engineering October 17, 1977, pp. 73-80. Lloyd, Thomas. 1980. Zinc compounds. In Kirk-Othmer encyclopedia of chemical technology. 3rd ed. Vol. 24, p. 856. New York: John Wiley and Sons. Lloyd, Thomas, and Showak, Walter, 1980. Zinc and zinc alloys. In Kirk-Othmer encyclopedia of chemical technology. 3rd ed. Vol. 24, p. 824. New York: John Wiley and Sons. Maczek, Helmut, and Kola, Rolf. 1980. Recovery of zinc and lead from electric furnace steelmaking dust at Berzelius. Journal of Metals 32:53-58. 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. Patterson, James W. 1985. Industrial wastewater treatment technology. 2nd ed. Stoneham, Mass.: Butterworth Publishers. Perry, Robert H. and Chilton. Cecil H. 1973. Chemical engineers' handbook. 5th ed. Section 19. New York: McGraw Hill, Inc. Pojasek, R.B. 1979. Sol id-waste disposal: solidification. Chemical Engineering 86(17):141-145. Price, Laurence. 1986. Tensions mount in EAF dust bowl. Metal producing. February 1986. 142 ------- Rudolfs, William. 1953. Industrial wastes. Their disposal and treatment, p. 294. Valley Stream, N.Y.: L.E.C. Publishers Inc. U.S. Department of Commerce, Bureau of the Census. 1984. 1982 Census of manufacturers. USEPA. 1980a. 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. 1980b. U.S. Environmental Protection Agency. RCRA listing background document. Waste Code K062. USEPA. 1982. U.S. Environmental Protection Agency. Final development document for effluent limitations guidelines and standards for the iron and steel manufacturing point source category salt bath descaling subcategorv. Volume V. 440/1-82/024. Washington, D.C.: EPA Effluent Guidelines Division. May 1982. USEPA. 1983. U.S. Environmental Protection Agency. Treatability manual, Volume III, Technology for control/removal of pollutants. EPA-600/2-82/001C, January 1983. pp. III.3.1.3.2. USEPA. 1986. U.S. Environmental Protection Agency. Qnsite engineering report of treatment technology performance and operation for Envirite Corporation. Prepared by Versar for Office of Solid Waste, USEPA, under Contract No. 68-01-7053. December 1986. USEPA. 1987. U.S. Environmental Protection Agency. Office of Solid Waste, Onsite engineering report of treatment technology performance and operation for Horsehead Resource Development Company. Washington, D.C.: U.S. Environmental Protection Agency. USEPA. U.S. Environmental Protection Agency. Characterization of waste streams listed in 40 CFR Section 261 waste profiles. Volume II. Prepared by Environ Corporation for Waste Identification Branch, Characterization and Assessment Division, U.S. Environmental Protection Agency. 143 ------- APPENDIX A - Analysis of Variance Test and Variability Factor Calculation 144 ------- 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 in the determination of the level of performance that represents "best" treatment where more than one technology is demonstrated. This method provides a measure of the differences between data sets. If the differences are not statistically significant, the data sets are said to be homogeneous. If the Agency found that the levels of performance for one or more technologies are not statistically different (i.e., the data sets are homogeneous), EPA would average the long-term performance values achieved by each technology and then multiply this value by the largest variability factor associated with any of the acceptable technologies. If EPA found that one technology performs significantly better (i.e., the data sets are not homogeneous), BOAT would be the level of performance achieved by the best technology multiplied by its variability factor. To determine whether any or all of the treatment performance data sets are homogeneous using the analysis of variance method, it is necessary to compare a calculated "F value" to what is known as a "critical value." (See Table A-l.) These critical values are available in most statistics texts (see, for example, Statistical Concepts and Methods by Bhattacharyya and Johnson, 1977, John Wiley Publications, New York). Where the F value is less than the critical value, all treatment data sets are homogeneous. If the F value exceeds the critical value, it is 145 ------- Table A-l » ... 95th PERCENTILE VALUES FOR THE F DISTRIBUTION ni — degrees of freedom for numerator nz = degrees of freedom for denominator _ . . . (shaded area = .95) /^ FM V 1 2 3 4 5 6 I 8 9 10 11 12 13 14 15 16 17 18 19 20 2° 24 26 28 30 40 50 60 70 80 100 150 200 400 00 1 161.4 18.51 10.13 7.71 6.61 5.99 5.59 5.32 5.12 4.96 4.84 4.75 4.67 4.60 4.54 4.49 4.45 4.41 4.38 4.35 4.30 4.26 4.23 4.20 4.17 4.08 4.03 4.00 3.98 3.96 3.94 3.91 3.89 3.86 3.84 2 199.5 19.00 9.55 6.94 5.79 5.14 4.74 4.46 4.26 4.10 3.98 3.89 3.81 3.74 3.68 3.63 3.59 3.55 3.52 3.49 3.44 3.40 3.37 3.34 3.32 3.23 3.18 3.15 3.13 3.11 3.09 3.06 3.04 3.02 2.99 3 215.7 19.16 9.28 6.59 5.41 4.76 4.35 4.07 3.86 3.71 3.59 3.49 3.41 3.34 3.29 3.24 3.20 3.16 3.13 3.10 3.05 3.01 2.98 2.95 2.92 2.84 2.79 2.76 2.74 2.72 2.70 2.67 2.65 2.62 2.60 4 224.6 19.25 9.12 6.39 5.19 4.53 4.12 3.84 3.63 3.48 3.36 3.26 3.18 3.11 3.06 3.01 2.96 2.93 2.90 2.87 2.82 . 2.78 2.74 2.71 2.69 2.61 2.56 2.53 2.50 2.48 2.46 2.43 2.41 2.39 2.37 5 230.2 19.30 9.01 6.26 5.05 4.39 3.97 3.69 3.48 3.33 3.20 3.11 3.03 2.96 2.90 2.85 2.81 2.77 2.74 2.71 2.66 2.62 2.59 2.56 2.53 2.45 2.40 2.37 2.35 2.33 2.30 2.27 2.26 2.23 2.21 6 234.0 19.33 8.94 6.16 4.95 4.28 3.87 3.58 3.37 3.22 3.09 3.00 2.92 2.85 2.79 2.74 2.70 2.66 2.63 2.60 2.55 2.51 2.47 2.45 2.42 2.34 2.29 2.25 2.23 2.21 2.19 2.16 2.14 2.12 2.09 8 238.9 19.37 8.85 6.04 4.82 4.15 3.73 3.44 3.23 3.07 2.95 2.85 2.77 2.70 2.64 2.59 2.55 2.51 2.48 2.45 2.40 2.36 2.32 2.29 2.27 2.18 2.13 2.10 2.07 2.05 2.03 2.00 1.98 1.96 1.94 12 243.9 19.41 8.74 5.91 4.68 4.00 3.57 3.28 3.07 2.91 2.79 2.69 2.60 2.53 2.48 2.42 2.38 2.34 2.31 2.28 2.23 2.18 2.15 2.12 2.09 2.00 1.95 1.92 1.89 1.88 1.85 1.82 1.80 1.78 1.75 16 246.3 19.43 8.69 5.84 4.60 3.92 3.49 3.20 2.98 2.82 2.70 2.60 2.51 2.44 2.39 2.33 2.29 2.25 2.21 2.18 2.13 2.09 2.05 2.02 1.99 1.90 1.85 1.81 1.79 1.77 1.75 1.71 1.69 1.67 1.64 20 248.0 19.45 8.66 5.80 4.56 3.87 3.44 3.15 2.93 2.77 2.65 2.54 2.46 2.39 2.33 2.28 2.23 2.19 2.15 2.12 2.07 2.03 1.99 1.96 1.93 1.84 1.78 1.75 1.72 1.70 1.68 1.64 1.62 1.60 1.57 30 250.1 19.46 8.62 5.75 4.50 3.81 3.38 3.08 2.86 2.70 2.57 2.46 2.38 2.31 2.25 2.20 2.15 2.11 2.07 2.04 1.98 1.94 1.90 1.S7 1.84 1.74 1.69 1.65 1.62 1.60 1.57 1.54 1.52 1.49 1.46 40 251.1 19.46 8.60 5.71 4.46 3.77 3.34 3.05 2.82 2.67 2.53 2.42 2.34 2.27 2.21 2.16 2.11 2.07 2.02 1.99 1.93 1.89 1.85 1.81 1.79 1.69 1.63 1.59 1.56 1.54 1.51 1.47 1.45 1.42 1.40 50 252.2 19.47 8.58 5.70 4.44 3.75 3.32 3.03 2.80 2.64 2.50 2.40 2.32 2.24 2.18 2.13 2.08 2.04 2.00 1.96 1.91 1.86 1.82 1.78 1.76 1.66 1.60 1.56 1.53 1.51 1.48 1.44 1.42 1.38 1.32 100 253.0 19.49 8.56 5.66 4.40 3.71 3.28 2.98 2.76 2.59 2.45 2.35 2.26 2.19 2.12 2.07 2.02 1.98 1.94 1.90 1.84 1.80 1.76 1.72 1.69 1.59 1.52 1.48 1.45 1.42 1.39 1.34 1.32 1.28 1.24 OC 254.3 19.50 8.53 5.63 4.35 3.67 3.23 2.93 2.71 2.54 2.40 2.30 2.2i 2.13 2.07 2.01 1.96 1.92 1.88 1.84 1.78 1.73 1.69 1.65 1.62 1.51 1.44 1.39 1.35 1.32 1.28 1.22 1.19 1.13 1.00 146 ------- necessary to perform a "pair wise F" test to determine if any of the sets are homogeneous. The "pair wise F" test must be done for all of the various combinations of data sets using the same method and equation as the general F test. The F value is calculated as follows: (i) All data are natural logtransformed. (ii) The sum of the data points for each data set is computed (T.). (iii) The statistical parameter known as the sum of the squares between data sets (SSB) is computed: SSB = where: k = number of treatment technologies n^ = number of data points for technology i N = number of data points for all technologies T^ = sum of natural logtransformed data points for each technology. (iv) The sum of the squares within data sets (SSW) is computed: k I i-l V' "T r k •E, TI 1=1 N i ^ SSW = where: ' k .1 I1 j=l 1,J k - I i=l x-jj = the natural logtransformed observations (j) for treatment technology (i). (v) The degrees of freedom corresponding to SSB and SSW are calculated. For SSB, the degree of freedom is given by k-1. For SSW, the degree of freedom is given by N-k. ------- (vi) Using the above parameters, the F value is calculated as follows: MSB F = MSW where: MSB = SSB/(k-l) and MSW = SSW/(N-k). A computational table summarizing the above parameters is shown below. Computational Table for the F Value Source Between Within Degrees of freedom K-l N-k Sum of squares SSB SSW Mean square MSB = SSB/k-1 MSW = SSW/N-k F MSB/MSW Below are three examples of the ANOVA calculation. The first two represent treatment by different technologies that achieve statistically similar treatment; the last example represents a case where one technology achieves significantly better treatment than the other technology. 148 ------- 1 790g Example 1 Methylene Chloride Steam stripping Influent Effluent Ug/U 1550.00 1290 00 1640 00 5100.00 1450.00 4600 00 1760 00 2400.00 4800.00 12100.00 (M9/D 10.00 10.00 10.00 12.00 10.00 10.00 10.00 10.00 10.00 10.00 Biological treatment In(effluent) [ln(eff luent)]2 Influent Effluent ln(ef fluent) 2.30 2.30 2.30 2.48 2.30 2.30 2.30 2.30 2.30 2.30 Ug/1) Ug/1) 5.29 1960.00 10.00 2.30 5.29 2568.00 10.00 2.30 5.29 1817.00 10.00 2.30 6.15 1640.00 26.00 3.26 5.29 3907.00 10.00 2.30 5.29 5.29 5.29 5.29 5.29 [In(effluent)]2 5.29 5.29 5.29 10.63 5.29 Sum. 23.18 53.76 12.46 31.79 Sample Size: 10 10 Mean: 3669 10 2 Standard Deviation- 3328 67 .63 Variability Factor: 10 2.32 .06 2378 923.04 1.15 13.2 7.15 2.48 2.49 .43 ANQVA Calculations. SSB = k n, 2 X 1=1 ssw = MSB = SSB/(k-l) MSW = SSW/(N-k) '• 1) k H'2 it n, 149 ------- 1790g Example 1 (continued) F = MSB/MSW where. k = number of treatment technologies n = number of data points for technology i N = number of natural log transformed data points for all technologies T = sum of log transformed data points for each technology i X = the nat. log transformed observations (j) for treatment technology (i) U n = 10. n = 5, N = 15, k = 2. T = 23.18. T = 12.46. T = 35.64, T = 1270.21 T2 = 537.31 T2 = 155.25 . 537.31 155.25 SSB =j + 10 5 1270.21 15 = 0.10 10 = 0.77 MSB = 0.10/1 = 0.10 MSW = 0.77/13 = 0.06 0 10 F = 0.06 = 1.67 ANOVA Table Source Degrees of freedom SS MS Between(B) Within(W) 1 13 0.10 0.77 0.10 0.06 1.67 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. 150 ------- 1790g Example 2 Trichloroethylene ^team stripeing Influent Ug/D 1650.00 5200.00 5000.00 1720.00 1560 00 10300.00 210.00 1600.00 204 00 160.00 Effluent Ug/D 10 00 10.00 10.00 10.00 10.00 10.00 10.00 27.00 85.00 10.00 ln(eff luent) 2.30 2.30 2.30 2.30 2.30 2.30 2.30 3.30 4.44 2.30 O(effluent)]2 5.29 5.29 5.29 5.29 5.29 5.29 5.29 10.89 19.71 5.29 Influent Ug/D 200.00 224.00 134.00 150.00 484 . 00 163.00 182.00 Biological treatment Effluent Ug/D 10.00 10.00 10.00 10.00 16.25 10.00 10.00 In(effluent) 2.30 2.30 2.30 2.30 2 79 2.30 2.30 [In(effluent)]2 5.29 5.29 5.29 5.29 7.78 5.29 5.29 bum: Sample Size- 10 10 Mean: 2760 19.2 Standard Deviation: 3209 6 23.7 Variability Factor: 26.14 10 2.61 .71 72.92 220 120.5 3.70 10.89 2.36 1.53 16.59 2.37 .19 39.52 ANOVA Calculations: SSB = SSW = MSB = SSB/(k-l) MSW = SSW/(N-k) 151 ------- 1790g Example 2 (continued) F = MSB/MSW where. 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) N = 10, N = 7, N = 17, k = 2. T = 26.14, T = 16.59, T = 42.73, T = 1825.85, T = 683.30. T = 275.23 (683.30 275.23 SSB =| + 10 7 1825.85 17 = 0.25 SSW= (72.92. 39.52) - 10 = 4.79 MSB = 0.25/1 = 0.25 MSW = 4.79/15 = 0.32 F=!f_=0.78 0.32 ANOVA Table Source Degrees of freedom SS MS Between(B) Within(W) 1 15 0.25 4.79 0.25 0.32 0.78 The critical value of the F test at the 0.05 significance level is 4.54. Since the F value is less than the critical value, the means are not significantly different (i.e., they are homogeneous). Note: All calculations were rounded to two decimal places. Results may differ depending upon the number of decimal places used in each step of the calculations. 152 ------- 1790g Example 3 Chlorobenzene Activated sludqe followed Influent Effluent Ug/D Ug/1) 7200.00 80.00 6500.00 70.00 6075.00 35.00 3040.00 10.00 bv carbon adsorption Bioloqical treatment In(effluent) [ln(eff luent)]2 Influent Ug/D 4.38 19.18 9206.00 4.25 18.06 16646.00 3.56 12.67 49775.00 2.30 5.29 14731.00 3159.00 6756.00 3040.00 Effluent (M9/1) 1083.00 709 . 50 460.00 142.00 603 . 00 153.00 17.00 In(effluent) 6.99 6.56 6.13 4.96 6.40 5.03 2.83 ln[(effluent)]2 48.86 43.03 37.58 24.60 40.96 25.30 8.01 Sum- Sample Size: 4 Mean: 5703 49 Standard Deviation: 1835.4 32.24 Variabi1ity Factor: 14.49 3.62 .95 55.20 14759 16311.86 7 00 452.5 379.04 15.79 38.90 5.56 1.42 228.34 ANOVA Calculations: SSB = HI A " SSW - MSB = SSB/(k-l) MSW = SSW/(N-k) F = MSB/MSW 153 ------- 1790g Example 3 (continued) where, 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) N = 4, N = 7, N = 11, k = 2, T = 14 49, T = 38.90, T = 53.39, J2= 2850.49, T2 = 209.96 T = 1513.21 SSB =1 + I = 9.52 4 7 j 11 [209 96 ~T~ 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 Between (B) 1 Within(W) 9 SS MS F 9.53 9.53 5.77 14.89 1.65 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. 154 ------- A.2 Variability Factor -£99- VF = Mean where: VF = estimate of daily maximum variability factor determined from a sample population of daily data. Cgg = Estimate of performance values for which 99 percent of the daily observations will be below. Cgg is calculated using the following equation: 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 155 ------- 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 (1) Mean The relationship between the parameters of the lognormal distribution and the parameters of the normal distribution created by taking the natural logarithms of the lognormally distributed concentrations can be found in most mathematical statistics texts (see for example: Distribution in Statistics-Volume 1 by Johnson and Kotz, 1970). The mean of the lognormal distribution can be expressed in terms of the mean (^) and standard deviation (a) of the normal distribution as follows: C99 = Exp (M + 2.33a) (2) Mean = Exp (M + .5a2). (3) Substituting (2) and (3) in (1) the variability factor can then be expressed in terms of a as follows: VF = Exp (2.33 a - .5a2). (4) For residuals with concentrations that are not all below the detection limit, the 99th percentile and the mean can be estimated from the actual analytical data and, accordingly, the variability factor (VF) 156 ------- can be estimated using equation (1). For residuals with concentrations that are below the detection limit, the above equations can be used in conjunction with the assumptions below to develop a variability factor. 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)J / 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. 157 ------- APPENDIX B - Analytical Methods and QA/QC From Onsite Engineering Report for Envirite Corporation 158 ------- APPENDIX B The analytical methods used for analysis of the regulated constituents identified in Section 5 are listed in Table B-l. SW-846 methods (EPA's Test Methods for Evaluating Solid Waste; Physical/Chemical Methods, SW-846, Second Edition, July 1982) are used in most cases for determining total constituent concentrations. Leachate concentrations were determined using the Toxicity Characteristic Leaching Procedure (TCLP), published in 51 FR 1750, January 14, 1986. 159 ------- 1833g Table B-l Analytical Methods for Regulated Constituents Regulated constituent Extraction method TOTAL COMPOSITION Chromium Specified in analytical method Copper Lead Nickel TCLP EXTRACT Chromium Lead Specified in analytical method Specified in analytical method Specified in analytical method Analytical method Chromium (atomic absorption, direct aspiration method) Copper (atomic absorption, direct aspiration method) Lead (atomic absorption, direct aspiration method) Nickel (atomic absorption, direct aspiration method) Toxicity Characteristic Leaching Procedure (TCLP) Toxicity Characteristic Leaching Procedure (TCLP) Reference 7190 220.1 7420 7520 51 FR 1750 2 51 FR 1750 2 References: 1. Environmental Protection Agency. 1982. Test Methods for Evaluating Solid Waste. Second Edition. U.S. EPA. Office of Solid Waste. July 1982. 2. Federal Register. 1986. Hazardous Waste Management Systems; Land Disposal Restrictions; Proposed Rule; Appendix I to Part 260 - Toxicity Leaching Procedure (TCLP). Vol. 51, No. 9. January 14. 1986. pp. 1750-1755. 3. Environmental Protection Agency. 1983. Methods for Chemical Analysis of Water and Wastes. U.S. EPA Office of Solid Waste. EPA-600/4-79-020. ------- APPENDIX C - Analytical Method for Determining Thermal Conductivity of a Waste 161 ------- APPENDIX C 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 that 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 in a cell consisting of a top and bottom of a Pyrex 7740 and a containment ring of marinite. The sample is 2 inches in diameter and .5 inch thick. Thermocouples are not placed in the sample; rather, the temperatures measured in the Pyrex are 162 ------- GUARD GRADIENT. STACK GRADIENT THERMOCOUPLE CLAMP UPPER STACK HEATER 1 TOP REFERENCE SAMPLE 1 TESTAMPLE J BOTTOM REFERENCE SAMPLE 1 LOWER STACK HEATER 1 LIQUID 'COOLED HEAT SINK 1 HEAT FLOW DIRECTION Figure 1. SCHEMATIC DIAGRAM OF THE COMPARATIVE METHOD UPPER GUARD HEATER LOWER GUARD HEATER Reference: VSR-1 163 January 1988 ------- 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. The stack is clamped with a reproducible load to ensure intimate contact between the components. In order to produce a linear flow of heat down the stack and reduce the amount of heat that flows radially, a guard tube is placed around the stack, and the intervening space is filled with insulating grains or powder. The temperature gradient in the guard tube is matched to that in the stack to further reduce radial heat flow. The comparative method is a steady state method of measuring thermal conductivity. When equilibrium is reached, the heat flux (analogous to current flow) down the stack can be determined from the references. The heat into the sample is given by Q. = A^ (dT/dxh in top top and the heat out of the sample is given by out = A (dT/dx) bottom bottom where: A = thermal conductivity dT/dx = temperature gradient 164 ------- and top refers to the upper reference, while bottom refers to the lower reference. If the heat was confined to flow down the stack, then 0 in and Q would be equal. If Q and Q are in reasonable out in out agreement, the average heat flow is calculated from Q ' (Qin + "out'/2' The sample thermal conductivity is then found from A . = Q/(dT/dx) . sample sample 165 ------- |