, US EPA Headquarters Library
404-14 SfcซSW .(3404) .
Waskn^r'OC) ฑ130 ..:''
'". . '- .; <-:. FINAL ' .' . _ :'."
BEST ^^DEMONSTRATED AVAILABLE TECHNOLOGY (BDAT)
BACKGROUND DOCIJMENT
'''".' \
.'''.-.': FOR
NEWLY LISTED WASTES
K107, K108, K109, K110, '
Kill, K112, U328, U353, .
K117, K118, K136, ..
. K123, K124, 'K125,- K126,
'.' '.-:" K131, K132, ' . .
--.' .' '.. ' .U359 ". ' ' . -
Richard Kinch ,
Chief, Waste Treatment Branch
Lisa Jones
Project Manager
US/ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste
' ' -, 2800 Crystal Drive
Arlington, Virginia 22202
June 30,1992
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TABLE OF CONTENTS _ x
. '. '.- : ''..' " ' PaSe
1.0 INTRODUCTION..,...:/..-.-..;.'..; ,..'..:./I..'. 1-1
2.0 UDMH PRODUCTION WASTES (K107, K108, K109, K110) 2-1
2.1. Industry Affected and Waste Characterization 2-1
2.1.1 Industry Affected and Process Description 2-1
2.1.2 Waste Characterization .....-.- - 2-2
2.2 Applicable and Demonstrated Treatment Technologies ...... 2-3
2.2.1 Applicable Treatment Technologies .'-.... 2-3
2.2.2 Demonstrated Treatment Technologies 2-5
2.3 Identification of Best Demonstrated Available
Technology (BOAT) -. . ....... .... 2-10
2.3.1 Nonwastewaters ....!! 2-10.
2.3.2 Wastewaters ... ...; ซ 2-11
3.0 DNT AND TDA PRODUCTION WASTES (Kl 11, Kl 12) AND U328
AND U353 y 3-1
3.1 Industry Affected and Waste Characterization ......'....... 3-1
3.1.1 Industry Affected and Process Description ....;...... 3-1
3.1.2 Waste Characterization ... 3-4
3.2 Applicable and Demonstrated Treatment Technologies 3-4
3.2.1 Applicable Treatment Technologies . 3-5
3.2.2 Demonstrated Treatment Technologies '.. 3-7
3.3 Treatment Performance Data ....>...... 3-11
3.3.1 Treatment of Organic Constituents in Kill
Nonwastewaters ...:... 3-12
3.3.2 Treatment of Organic Constituents in Kill
Wastewaters .\ ....... 3-12
3.4 Identification of Best Demonstrated Available
Technology (BOAT) . . 3-14
. 3.4.1 Nonwastewaters 3-15
3.4.2 Wastewaters :.. 3-17
3.5 Selection of Regulated Constituents in Kill 3-20
3.6 Calculation of BDAT Treatment Standards for Kill ......... 3-21
3.6.1 Nonwastewaters '. 3-22
3.6,2 Wastewaters 3-24
4.0 EDB PRODUCTION WASTES (K117, K118, K136) W
4.1 Industry Affected and Waste Characterization 4-1
4.1.1 Industry Affected and Process Description i.. 4-1
4.1.2 Waste Characterization ; 4-3
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TABLE OF CONTENTS (Continued)
Page
4.2 Applicable and Demonstrated Treatment Technologies 4-3
. 4.2.1 Applicable Treatment Technologies 4-3
4.2.2 Demonstrated Treatment Technologies 4-5
4.3 Treatment Performance Data 4-7
4.3.1 Treatment of Organic Constituents in
: ' ' Nonwastewaters 4-8
4.3.2 Treatment of Organic Constituents in
Wastewaters 4-9
4.4 Identification of Best Demonstrated Available
Technology (BDAT) . . V .. 4-13
4.4.1 Nonwastewaters '.; 4-14
4.4.2 Wastewaters '..'..' 4-15
4.5 Selection of Regulated Constituents ;.. .. 4-16
4.6 Calculation of BDAT Treatment Standards 4-18
4.6.1 Nonwastewaters 4-18
4.6.2 Wastewaters ... 4-20
5;0 EBDC PRODUCTION WASTES (K123, K124, K125, K126) 5-1
5.1 Industry Affected and Waste Characterization ;'. 5-1
5.1.1 Industry Affected and Process Description ..; ,.. 5-1
5.1.2 Waste Characterization 5-3
5.2 Applicable and Demonstrated Treatment Technologies 5-3
. 5.2.1 Applicable Treatment Technologies ~ 5-4
5.2.2 Demonstrated Treatment Technologies 5-6
5.3 Identification of Best Demonstrated Available
Technology (BDAT) '. , 5-12
5.3.1' Nonwastewaters . .^ 5-13
5.3.2 Wastewaters 5-14
6.0 METHYL BROMIDE PRODUCTION WASTES (K131, K132) .... 6-1
6.1 Industry Affected and Waste Characterization 6-1
6.1.1 Industry Affected and Process Description 6-1
6.1.2 Waste Characterization ; .-. 6-4
6.2 Applicable and Demonstrated Treatment Technologies 6-4
6.2.1 Applicable Treatment Technologies 6-5
6.2.2 Demonstrated Treatment Technologies ,. 6-6
6.3 Treatment Performance Data 6-8
6.3.1 Treatment of Organic Constituents in
Nonwastewaters .' 6-8
6.3.2 Treatment of Organic Constituents in
Wastewaters ; ; ;...'. 6-9
'.<'.
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TABLE OF CONTENTS (Continued)
- -. '*..- . ; Page
6.4 Identification of Best Demonstrated Available *'
Technology (BDAT) 6-12
6.4.1 Nonwastewaters .... ... 6-12
6.4.2 Wastewaters . .-;...' .... 6-13
6.5 Selection of Regulated Constituents 6-14
6.6 Calculation of BDAT Treatment Standards .6-15
6.6.1 Nonwastewaters 6-16
6.6.2 Wastewaters ; 6-18
7.0 2-ETHOXYETHANOL WASTE (U359) . . !...;....... 7-1
' 7.1 industry Affected and Waste Characterization 7-1
7.1.1 Industry Affected and Process Description .; 7-1
7.1.2 Waste Characterization . .....;:.... 7-2
7.2 Applicable and Demonstrated Treatment Technologies ...... 7-2
7.2.1 Applicable Treatment Technologies 1.. 7-3
. 7.2.2 Demonstrated Treatment Technologies 7-4
7.3 Identification of Best Demonstrated Available .
Technology (BDAT) ...-._ .. ... 7-11
7.3.1 Nonwastewaters ............ 7-11
, 7.3.2 Wastewaters .' 7-13
8.0 ACKNOWLEDGEMENTS 8-1
9.0 REFERENCES ....; 9-1 '
APPENDIX A: TREATMENT TECHNOLOGY DISCUSSIONS
APPENDIX B: ACCURACY CORRECTION OF DATA
APPENDIX C: VARIABILITY FACTOR CALCULATIONS
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LIST OF TABLES
. Page
1-1 BDAT Treatment Standards for UDMH Production Wastes:
K107, K108, K109, and K110 Nonwastewaters and
Wastewaters ... ......' v 1-7
1-2 BDAT Treatment Standards for DNT and TDA Production
Wastes and Related U Wastes: Kill, K112, U328, and U353
Nonwastewaters and Wastewaters ..-." '.'..; 1-8
1-3 BDAT Treatment Standards for EDB Production Wastes
K117, K118, and K136 Nonwastewaters and Wastewaters 1-9
***.
1-4 , BDAT Treatment Standards for EBDC Wastes: K123, K124,
K125, and K126 Nonwastewaters and Wastewaters 1-10
1-5 BDAT Treatment Standards for Methyl Bromide Production
Wastes: K131 and K132 Nonwastewaters and Wastewaters 1-11
1-6 BDAT Treatment Standards for U359 Nonwastewaters and
Wastewaters ............ '. 1-12
2-1 Summary of Available Characterization Data for K107, K108,
K109, and K110 2-15
3-1 Facilities that May Generate Kill and K112, by State and
EPA Region/Facilities that May Generate U328 and U353,
by State and EPA Region ; 3-26
3-2 Summary of Available Characterization Data for Kill, K112,
U328, and U353 3-27
3-3 Treatment Performance Data Collected by EPA from
Incineration of 2,4-Dinitrotoluene and 2,6-Dinitrotoluene 3-28
3-4 Wastes Tested by Incineration .. 3-29
3-5 , Wastewater Treatment Performance Data for
2,4-Dinitrotoluene ...',. 3-30
3-6 . Wastewater Treatment Performance Data for
2,6-Dinitrotoluene .......;...-. '.-...' 3-31
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LIST OF TABLES (Continued)
\ ' ' - ,
.,'-... '' . Page
3-7 Calculation of Nonwastewater and Wastewater Treatment
Standards for Kill ., ..... 3-32
4-1 Summary'of Available Characterization Data for K117, K118, V
K136 4-23
4-2 Treatment Performance Data Collected by EPA from '
Incineration of Ethylene Dibromide (EDB) at Rollins . .
Environmental Services, Inc. (Texas) - Incineration 4-24
4-3 Design Parameters for the Incineration System at Rollins
. Environmental Services, Inc. (Texas) . ; 4-25
4-4 Wastes Tested by Incineration 4-26
4-5 Summary of Detection Limits for Chloroform in Ash Samples
from the Fourteen EPA Incineration Tests ....;.. .......... 4-27
I " ' ' . N
4-6. Wastewater Treatment Performance Data for Ethylene
Dibromide ..: '. ... 4-28
4-7 Wastewater Treatment Performance Data for Bromomethane ...... 4-29
4-8 Wastewater Treatment Performance Data for Chloroform ......... 4-30
_' - \
4-9 Calculation of Nonwastewater Treatment Standards for K117,
K118, and K136 .................;.......... 4-34
4-10 Calculation of Wastewater Treatment Standards for Kl 17,
K118,*nd K136 ....'. 4-35
5-1 Summary of Available Characterization Data for K123, K124,
K125, and K126 ....... .^. 5-17
' '
6-1 Summary of Available Characterization Data for K131 and .
K132 ,... ..6-20
6-2 : Treatment Performance Data Collected by EPA from ' .
Incineration of Ethylene Dibromide (EDB) at RoUins
Environmental Services, Inc. (Texas)-.Incineration -...6-21
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LIST OF TABLES (Continued)
6-3 Design Parameters for the Incinerator System at Rollins
Environmental Services, Inc. (Texas) .......... '. ........ ; . ____ 6-22
6-4 Wastewater Treatment Performance Data for Methyl
Bromide .:...- ........... - . ; ..... . ____ * ____ . ..... ; . ...... 6-23
6-5 Calculation of Nonwastewater and Wastewater Treatment
Standards for K131 and K132 . . : ......... . ..... ... ...... ... 6-24
7-1 Facilities that May Generate U359, by State and EPA Region ...... 7-16
7-2 Summary of Available Characterization Data for U359 ____ ....... 7-17
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LIST OF FIGURES
Page
2-1 UDMH Production Process .'. ...;. .-..... 2-16
3-1 DNT and TDA Production Process .....'.'. ..".'.': 3-33
4-1 EDB Production Process ................ .......... 4-36
5-1 EBDC Production Process .......... 5^18
6-1 Methyl Bromide Production Process :. 6-25
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LIST OF ABBREVIATIONS AND ACRONYMS
yS.;; :;^-.-.- '"Abbi^ation/Aawi^
AC
ACF
AFF
AirS
AL
AnFF
APCD
API
ART
AS
BDAT
BGAC
BT
CAC ;
CFR
ChOx
Chred
CWA
DAF
DNT
BAD
EBDC
EDB
EPA
\
FIL
. Activated Carbon . ,
Accuracy Correction Factor
Aerobic Fixed Film :
Air Stripping
Aerobic Lagoons
Anaerobic Fixed Film
Air Pollution, Control Devices
American Petroleum Institute
Articles not part of WERL database
Activated Sludge Biological Treatment
Best Demonstrated Available Technology
Biological Granular Activated Carbon
Biological Treatment
Chemically Assisted Clarification
Code of Federal 'Regulations
Chemical Oxidation
Chemical Reduction
Clean Water Act
-Dissolved Air Flotation
Dinitrotoluene
Engineering and Analysis Division
Ethylene Bisdithiocarbamic Acid ,
Ethylene Dibromide
Environmental Protection Agency
(United States)
Filtration
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LIST OF ABBREVIATIONS AND ACRONYMS (Continued)
/
Abbreviation/Acronym
FR
FWPCA _'.','
GAC
HSWA
rro . ' '
LDR
Leachate
LL ' . ' ' . ' ' '
NPDES
OCPSF . ,
OER
OSW
PACT ,
RBC
RCRA
RO
SCOx
SExt
SS
TCLP
TDA
TF , '
TOC
Definition
Federal Register
Federal Water Pollution Control Act
Activated Carbon (Granular)
Hazardous and Solid Waste Amendments
Industrial Technology Division
s
Land Disposal Restrictions
Industry Submitted Leachate Data
Liquid-Liquid Extraction .
National Pollutant Discharge Elimination
System V-
Organic Chemicals, Plastics, and '
Synthetic Fibers
On-site Engineering Report
Office of Solid Waste
Powdered Activated Carbon Addition to
Activated Sludge ;
Rotating Biological Contactor
Resource Conservation and Recovery Act
Reverse Osmosis
Super Critical Oxidation
l . ซ,
Solvent Extraction
Steam Stripping
Toxicity Characteristic Leaching
Procedure -
Toluenediamine ,
Trickling Fijter
Total Organic Carbon
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IX
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LIST OF ABBREVIATIONS AND ACRONYMS (Continued)
**
Abbreviatkm/Acruitym .
TSS
UDMH
UF
uv
VF ' '" '
WAO
WERL
WOx
Definition
Total Suspended Solids
Unsymmetrical Dimethylhydrazine (1,1-
Dimethylhydrazine)
Ultrafiltration
.Ultraviolet Radiation
Variability Factor
Wet Air Oxidation
Water Engineering Research Laboratory
Wet Air Oxidation
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1.0 , INTRODUCTION
> '
The U.S. Environmental Protection Agency (the Agency or EPA) is
establishing best demonstrated available technology (BDAT) treatment standards for the
following listed hazardous wastes identified in Title 40, Code of Federal Regulations.
Sections 261.32 and 261.33(f) (40 CFR 26132 and 261.33(ฃ)>: ,
1,1-Dimethylhydrazine (UDMH) Production Wastes: K107, K108,
; K109, and K110;
Dinitrotoluene (DNT) and Toluenediamine (TDA) Production
Wastes: Kill, K112, U328, and U353;
. ' ' "
! Ethylene Dibromide (EDB) Production Wastes: K117, K118, and
K136; , . \
Ethylenebisdithiocarbamic Acid (EBDC) Production Wastes: K123,
K124, K125, and K126;
h
Methyl Bromide Production Wastes: K131 and K132; and
2-Ethoxyethanol Waste: U359.
" *
* r ' - "
These BDAT treatment standards are promulgated in accordance with the amendments
to the Resource Conservation and Recovery Act (RCRA) of 1976, enacted-by the
' > - " ,
Hazardous and Solid Waste Amendments (HSWA) of November 8, 1984. The Agency's
legal authority and promulgated methodology for establishing treatment standards and.
the petition process necessary for requesting a variance from the treatment standards are
summarized in EPA's Methodology for Developing BDAT Treatment Standards .;
(Reference i).
1 ' ' * , . "*
"This background document provides the Agency's rationale and technical
support for developing the BDAT treatment standards for these wastes. These standards
include both methods of treatment and concentration-based treatment standards. This
. ' "' sซ % *
background document also presents the following waste-specific information: the
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number and locations of facilities that may be affected by the land disposal restrictions
for these wastes; the processes generating these wastes; waste characterization data; the
technologies used to treat these wastes (or similar wastes, if any); and the treatment
performance data on which the treatment standards are based. This document also
explains how EPA determines BDAT, selects constituents for regulation, and calculates
treatment standards. '-' '
. Under 40 CFR 261.32 and 40 CFR 261.33(f), the wastes identified above
are listed as follows:
1.1-Dimethvlhvdrazine fUDMH) Production Wastes
K107 - Column bottoms from product separation from the
production of 1,1-dimethylhydrazine (UDMH) from
carboxylic acid hydrazides.
K108 - Condensed column overheads from product separation and
condensed reactor vent gases from the production of
, 1,1-dimethylhydrazine (UDMH) from carboxylic acid
hydrazides. . .
' K109 - Spent filter cartridges from product purification from the
production of 1,1-dimethylhydrazine (UDMH) from
, ' carboxylic acid hydrazides.
K110 - Condensed column overheads from intermediate separation
from the production of 1,1-dimethylhydrazine (UDMH) from
'. ' carboxylic acid hydrazides.
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Dinitrotoluene (DNT) and ToluenediamineJTDA) Production Wastes and
Related U Wastes .
Kill - Product washwaters from the production of dinitrotoluene via
, ' nitration of toluene.
K112 - Reaction by-product water from the drying column in the
.production of toluenediamine via hydrogenation of
dinitrotoluene. , - . .
.i i '
U328 - o-Toluidinei
U353 - p-Toluidine.
Ethvlene Dibromide (EDB^ Production Wastes (
K117 - Wastewater from the reactor vent gas scrubber in the
production of ethylene dibromide via bromination of ethene.
K118 - Spent adsorbent solids from purification of ethylene
dibromide in the production of ethylene dibromide via
bromination of ethene.
t
K136 - Still bottoms from the purification of ethylene dibromide in
the production of ethylene. dibromide via bromination of
ethene. -
.- ^ 1
* * '
Ethylenebisdithiocarbamic Acid (EBDC) Production Wastes
' \ .''. '
K123 - Process wastewater (including supernates, filtrates, and
. washwaters) from the production of
ethylenebisdithiocarbamic acid and its salts.
K124 - Reactor vent scrubber water from the production of
ethylenebisdithiocarbamic acid and its salts. ~
, K125 -' Purification solids .(including filtration, evaporation and
\ centrifugation soh'ds) from the production of
ethylenebisdithiocarbamic acid and its salts.
K126 - Baghouse dust and floor sweepings in milling and packaging
operations from the production or formulation of
- - , ethylenebisdithiocarbamic acid and its salts.
*
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Methyl Bromide Production Wastes
K131 - Wastewater from the reactor and spent sulfuric acid from the
acid dryer from the production of methyl bromide.
K132 - Spent absorbent and wastewater separator solids from the
f production of methyl bromide.
2-Ethoxvethanol Wastes
U359 - 2-Ethoxy-ethanol.
' >*.
s .
Treatment standards for all of the waste streams covered in this
background document were developed by transferring performance data used to calculate
First, Second, and Third Third BDAT treatment standards.
The Agency is establishing either concentration-based BDAT treatment
standards or BDAT treatment standards expressed as .a method of treatment for
wastewater and nonwastewater forms of each of these wastes. Wastewaters are defined
as containing less than 1% (weight basis) total suspended solids1 (TSS) and less than 1%
(weight basis) total organic carbon (TOC). Wastes not meeting this criteria are defined
as being "nonwastewater" and must comply with the nonwastewater treatment standards.
The Agency is establishing BDAT treatment standards expressed as a
method of treatment for wastewater and nonwastewater forms of UDMH production
wastes (K107, K108, K109, and K110), as shown in Table 1-1. The BDAT treatment
standards established for U098 ("off-specification, out-dated, or discarded UDMH") in
the Final Rule for Third Third wastes (55 FR 22688; June 1, 1990) are the basis of these
standards. The Agency believes that methods of treatment are the most appropriate
standards for UDMH wastes because the regulated organic constituents of K107-K110
The term "total suspended solids" (TSS) clarifies EPA's previously used terminology of 'total solids* and 'filterable solids.' Specifically,
total suspended solids is measured by Method 209C (total suspended solids dried at 103-105 *C) in Standard Methods for the Examination
of Water and Wastewater. Sixteenth Edition (Reference 2V * t
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are relatively unstable and consequently are difficult to quantify in treatment residuals.
These wastes are discussed in Section 2.0.
. ' '. s
The Agency is establishing concentration-based BDAT treatment standards
for wastewater and nonwastewater forms of Kill and treatment standards expressed as
methods of treatment for wastewater and nonwastewater forms of K112, U328, and
U353, as shown in Table 1-2. The promulgated treatment standards for Kill are
numerically identical to the BDAT treatment standards for 2,4-dinitrotoluene and 2,6-
dinitrotoluene in F039; this decision reflects a modification to the treatment standards
proposed for Kill. The Agency believes that specified methods of treatment are the
most appropriate standards for K112, U328, and U353 because the regulated organic
constituents of K112, U328, and U353 are relatively unstable and consequently are
i '
difficult to quantify in treatment residuals. These wastes are discussed in Section 3.0.
\ (
^ * > t <
The Agency is establishing concentration-based BDAT treatment standards
for wastewater and nonwastewater forms of EDB production wastes (K117, K118, and
K136), as shown in Table 1*3. The promulgated treatment standards are equivalent to
the F039 BDAT treatment standards for organobromine wastes (U029, UQ30, UQ66,
U067, U068, and U225), and are derived from data used to calculate BDAT treatment
for chloroform wastes in the Final Rule for Third Third wastes. These wastes are
discussed in Section 4.0.
\ ' ' :.'"'
i . '
The Agency is establishing BDAT treatment standards expressed as
methods of treatment for wastewater and nonwastewater forms of EBDC production
wastes (K123, K124, K125, and K126), as shown in Table 1-4. The BDAT treatment
standards established for U114 (EBDC) and U116 (ethylene thiourea) in the Final Rule
for Third Third wastes are the basis for these standards. The Agency believes that
methods of treatment are the most appropriate standards for EBDC production wastes
because the organic constituents of concern in K123-K126 are relatively unstable and
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consequently are difficult to quantify in treatment residuals. These wastes are discussed
in Section 5.0. '
i '
The Agency is establishing concentration-based BOAT treatment standards
for wastewater and nonwastewater forms of methyl bromide production wastes (K131
and K132), as shown in Table 1-5. These treatment standards are based on the BDAT
treatment standards established for U029 (methyl bromide) in the Final Rule for Third
Third wastes. These wastes are discussed.in Section 6.0. , -
The .Agency is establishing BDAT treatment standards expressed as
methods of treatment for wastewater and nonwastewater. forms of 2-ethoxyethanol wastes
(U359), as shown in Table 1-6. The BDAT treatment standards established for U154
(methanol) in the Final Rule for Third Third wastes are the basis of these treatment
standards.. The Agency believes that methods of treatment are the most appropriate
standards for 2-ethoxyeithanol production waste because the constituent of concern is
relatively unstable and consequently is difficult to quantify in treatment residuals. .This
waste is discussed in Section 7,0. V
The numerical treatment standards for the organic constituents regulated in
wastewater and nonwastewater forms of Kill, K117, K118, K131, K132, and K136 are
based on the total concentrations of each constituent in the1 waste. The units used for
total constituent concentrations of organic constituents in nonwastewaters are mg/kg.
(parts per million on a weight-by-weight basis). The units used for total constituent
/ , " j ' , .
concentrations of organic constituents in wastewaters are mg/1 (parts per million on a
weight-by-yolume basis). If the concentrations of the regulated constituents in
wastewater and nonwastewater forms of Kill, K117, K118, K131, K132, and K136, as
generated, are less than or equal to these promulgated BDAT treatment standards, then
treatment of the waste would not be required prior to land disposal.
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-t Table 1-1
BDAT Treatment Standards for UDMH Production Wastes:
K107, K108, K109, and K110
, Nonwastewaters and Wastewaters
Nonwastewaters
Method of Treatment: Incineration
Wastewaters
Methods of Treatment:
Incineration; or
Chemical Oxidation followed by Carbon, Adsorption; or
Biodegradation followed by Carbon Adsorption
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Table 1-2
BDAT Treatment Standards for
DNT and TO A Production Wastes and Related U Wastes:
Kill, K112, U328, and U353
Nonwastewaters and Wastewaters
Kill Nonwastewaters
Maximum for Any Single Grab Sample \
' / ' Total Concentration
; '''.'.' in Nonwastewaters
BDAT List Constituent (mg/kg)
2,4-Dinitrotoluene 140
2,6-Dinitrotoluene 28
/
' Kill Wastewaters
^ Maximum for Any 24-Hour Composite . '.
! Total Concentration
- in Wastewaters
BDAT List Constituent (mg/1)
2,4-Dinitrotoluene 032
2,6-Dinitrotoluene 0.55
Kl 12, U328, and U353 Nonwastewaters
Method of Treatment: incineration
. K112, U328, and U353 Wastewaters
Methods of Treatment: Incineration; or
Chemical Oxidation followed by Carbon Adsorption; or
Biodegradation followed by Carbon Adsorption
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Table 1-3
BDAT Treatment Standards for EDB Production Wastes:
K117, K118, and K136
. Nonwastewaters and Wastewaters
Kl 17, Kl 18, and K136 Nonwastewaters
Maximum for Any Single Grab Sample , .
Total Concentration
- in Nonwastewaters
BDAT List Constituent (mg/kg)
Ethylene dibromide . 15
Bromomethane ,. .15
Chloroform , 5.6
. ? .''.'''
_ ". , Kll?; Kl 18, and K136 Wastewaters
Maximum for any 24-Hour Composite Sample
Total Concentration
%
.in Wastewaters
BDAT List Constituent (mg/1)
Ethylene dibromide- 0.028
Bromomethane . .0.11
Chloroform 0.046
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Table 1-4
BOAT Treatment Standards for EBDC Production Wastes:
K123, K124, K125, and K126
Nonwastewaters and Wastewaters
K123, K124, K125, and K126 Nonwastewaters
Method of Treatment: Incineration
K123, K124, K125, and K126 Wastewaters
Methods of Treatment: Incineration; or
Chemical Oxidation followed by either
Biological Treatment or Carbon Adsorption
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Table 1-5
" f
BDAT Treatment Standards for Methyl Bromide Production
Wastes: K131 and K132
Nonwastewaters and Wastewaters
N Nonwastewaters .
Maximum for Any Single Grab Sample ' .
Total Concentration
\ in Nonwastewaters
BDAT List Constituent ' * : (mg/kg) .
Bromomethane (methyl bromide) .15
Wastewaters
Maximum for any 24-Hour Composite Sample
Total Concentration
, < in Wastewaters
BDAT list Constituent (mg/1)
Bromomethane (methyl bromide) 0.11
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Table 1-6
BOAT Treatment Standards for U359
Nonwastewaters and Wastewaters
U359 Nonwastewaters
Methods of Treatment: Incineration or Fuel Substitution
U359 Wastewaters
Methods of Treatment:
Incineration; or , ,
Chemical Oxidation followed by either Biological Treatment
or Carbon Adsorption; or ,
Biodegradation followed by Carbon Adsorption
MLM/Q27
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2.0 UDMH PRODUCTION WASTES (K107, K108, K109, K110)
" " ' . ' ' '
This section describes the Agency's approach in establishing BDAT
treatment standards for K107, K108, K109, and K110. This includes a description of the
industry affected by the land disposal restrictions for UDMH production wastes, a
presentation, of available waste characterization data, and a discussion of the Agency's
rationale in determining BDAT treatment standards for these wastes.
' - ' ' / . ' v '
- v-
In 40 CFR 261.32 (hazardous wastes from specific sources), waste
identified as K107 is listed as column bottoms from product separation from the
production of 1,1-dimethyIhydrazine (UDMH) from carboxylic acid hydrazides; K108 is
listed as condensed column overheads from product separation and condensed reactor
vent gases from the production of UDMH from carboxyl acid hydrazides; K109 is listed
as spent filter cartridges from product purification from the production of UDMH from
carboxylic acid hydrazides; and K110 is listed'as condensed column overheads from
intermediate separation from the production of UDMH from carboxylic acid hydrazides.
1 ./
2.1 Industry Affected and Waste Characterization
2.1.1 Industry Affected and Process Description ,
< '
To the Agency's knowledge, one domestic facility produces and purifies
. /, , '
UDMH and may potentially generate K107, K108, K109, and K110. This facility is Olin
Chemicals, located in Lake Charles, LA, of Region VI. This facility was identified using
the 1990 SRI Directory of Chemical Producers (3) and data collected during EPA's
listing efforts for K107, K108, K109, and K110 (4).
' -i ' '
, i - - .
1,1-Dimethylhydrazine, commonly known as unsymmetrical dimethyl-
hydrazine (UDMH), is used as a rocket fuel, as an adsorbent for acid gases in the
manufacture of various photographic chemicals, and as a stabilizer .for organic peroxide
MLM/027
1031-Ol.mlm 2-1
-------
fuel additives. It is also used as an analytical reagent for aldehyde and ketone analysis.
A simplified flow diagram illustrating the manufacturing process generating UDMH and
its related wastewater is presented in Figure 2-1. .-"-.
UDMH is made by the reductive catalytic alleviation of a carboxylic acid
hydrazide with formaldehyde and hydrogen, followed by basic hydrolysis of carboxylic
' - . ! i
acid dimethylhydrazide to remove the carboxyl group, as shown in the following
equation: . .
CH20/H2 base
RCONHNHj > RCONHN (CH3)2 ---- -> (CH3)2NNH2
The primary waste generated consists of the column bottoms from the final
purification step in the production of commercial UDMH (K107, shown in Figure 2-1
and characterized in Table 2-1). The second listed waste generated consists of the
condensed overheads from a combination of reactor vent gases and final product
separation vent gases which are co-condensed as a liquid waste (K108, shown in Figure
2-1 and characterized in Table 2-1). The third listed waste generated consists of spent
filter cartridges from product purification (K109, shown in Figure 2-1 and characterized
in Table 2-1). Finally, the fourth listed waste generated consists of condensed overheads
from intermediate separation columns used before the final step in UDMH synthesis
(K110, shown in Figure 2-1 and characterized in Table 2-1).
2.12 . Waste Characterization
Table 2-1 presents a summary of the available characterization data for
K107, K108, K109, and K110. None of the BDAT List constituents are expected to be
present in these wastes; data are presented for 1,2-dimethylhydrazine, which is believed
to be present or has been detected in K107, K108, K109, and K110.
MLM/027
1031-01 .mim ' - 2-2
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22 Applicable and Demonstrated Treatment Technologies
This section identifies the technologies that are applicable for the.
treatment of nonwastewater and wastewater forms of K107, K108, K109, and K110 and
determines which of the applicable technologies can be considered demonstrated for the
purpose of establishing BOAT.
To be considered applicable, a technology must theoretically be usable to
treat the waste in question or to treat a waste that is similar, in terms of parameters that
affect treatment selection. (Detailed descriptions of technologies that are applicable to
listed hazardous wastes are provided in EPA's Treatment Technology Background
Document (5).) To be considered demonstrated, a technology must be employed in full-
scale operation for treatment of the waste in question or of a similar waste.
Technologies available only at pilot-scale or bench-scale,operations are not considered in
identifying demonstrated technologies. .
i" . ' ' ' ' .
2.2.1 Applicable Treatment Technologies
' ! -
Nonwastewaters . ,
, . * ' .
.'"',.. I
' ' <. . ' '
Since nonwastewater forms of K107, K108, K109, and Kl 10 generally
contain hazardous organic constituents at treatable concentrations, applicable treatment
technologies include those that destroy or reduce the total amount of various organic
compounds in the waste. The Agency has identified the following treatment technologies
as applicable for these wastes:
Chemical oxidation; ,
Critical fluid extraction followed by. incineration of the contaminated
solvents; . ..
" '''-'.
> Distillation; , ,
MLM/027 i ''"' .
1031-Ol.mlm . 2-3
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Incineration (fluidized-bed, rotary kiln, and liquid injection);
t ' " -
Solvent extraction followed by incineration or recycle of the extract;
and
Wet air oxidation. ~
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A.
Wastewaters
Since wastewater forms of K107, K108, K109, and K110 may contain
hazardous organic constituents at treatable concentrations, applicable treatment
technologies include those that destroy or reduce the total amount of various organic
compounds in the waste. Therefore, the Agency has identified the following treatment
technologies as potentially applicable for treatment of these wastes:
Biological treatment; *
Carbon adsorption;
Chemical oxidation;
Distillation; .
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
* '
Steam stripping; and
Wet air oxidation.
S ' . '
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in .more detail in Appendix A. . .
MLM/027
1031-01.mlm 2-4
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The concentrations and type(s) of constituents present in the waste
generally determine which technology is most applicable. Carbon adsorption, for
example, is often used as a polishing step following primary treatment by biological
treatment, solvent extraction, or wet air oxidation. Typically, carbon adsorption is
applicable for treatment of wastewaters containing total organic constituent
concentrations of less than 0.1%. Wet air oxidation, biological treatment, and solvent
extraction (followed by incineration or recycle or the extract) are applicable for
treatment of wastewaters containing organic constituents at concentrations of up to 1%.
\
222 Demonstrated Treatment Technologies
- This section identifies those applicable treatment technologies that EPA
considers to be demonstrated for the purpose of establishing BDAT for K107, K1Q8,
K109, and K110.
Nonwastewaters . ,
The Agency believes that incineration is a demonstrated technology for the
treatment of nonwastewater forms of K107, K108, K109, and K110. For the land
disposal restrictions program, the Agency has tested rotary kiln incineration on a full-
scale operational basis for many organic waste constituents including: ,
Aromatic and other Hydrocarbon Wastes '
Toluene . . .
Polymiclear Aromatic Wastes . "
s - . . . '
Benzo(a)pyrene .
Chrysene
Indeno(l,2,3-cd)pyrene , .
Benz(a)anthracene .
, . Fluoranthene
Naphthalene . . \. . - ''
MLM/027 . . . ' ' . . " ' .
103t-01.mtm . 2-5 .' . '
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The Agency believes that because incineration is demonstrated for the
treatment of many organic waste constituents, including those which are structurally
similar to dimethylhydrazine, it is also demonstrated for these wastes. The Agency is not
aware of any facilities that treat K107, K108, K109, and K110 by fuel substitution and
the Agency believes that fuel substitution is inappropriate for wastes such as K107, K108,
K109, and K110 that contain many constituents with molecular components other than
carbon, hydrogen, and oxygen. Therefore, the Agency believes that fuel substitution is
not a demonstrated technology for these wastes.
i
From review of the 1986 TSDR Survey (6) and the USEPA's Water
Engineering Research Laboratory (WERL) database (7), the Agency has determined
that some facilities also treat nonwastewater forms of aromatic and polynuclear aromatic
wastes or wastes judged to be similar to K107, K108, K109, and K110 using wet air
oxidation, chemical oxidation, and distillation on a full-scale operational basis.
Therefore, EPA considers these technologies to be demonstrated for aromatic and
polynuclear aromatic wastes such as K107, K108, K109, and K110.
: The Agency is not aware of any facilities that treat nonwastewater forms of
these wastes or wastes judged to be similar on a full-scale operational basis using solvent
extraction (followed by incineration or recycle of the extract) or critical fluid extraction
(followed by incineration of the contaminated solvents); therefore, EPA believes that
these technologies are not currently demonstrated for these wastes.
Wastewaters
The following technologies have been identified as demonstrated for
treatment of the following types of organic wastes (organized by. chemical structure):
MLM/OS7
1031-01.mlm 2-6
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Aromatic and Other Hydrocarbon Wastes
Incineration
Biological Treatment ,
Carbon Adsorption
Wet Air Oxidation
Chemical Oxidation
Steam Stripping
Brominated Organic Wastes
Biological Treatment '
Halogenated Aliphatic Wastes
t '.
Incineration <
Wet Air Oxidation .
Chemical Oxidation
Biological Treatment ,
Carbon Adsorption .
Solvent Extraction
Distillation .
Steam Stripping
Halogenated Pesticide and Chlorobenzene Wastes
Biological Treatment
Wet Air Oxidation
Steam Stripping
Carbon Adsorption
j
Oxygenated Hydrocarbon and Heterocvclic Wastes'
Biological Treatment
Carbon Adsorption
Steam Stripping ' .
Wet Air Oxidation
Wastes of a Pharmaceutical Nature
Wet Air Oxidation
MLM/027
1031-Ol.fflto 2-7
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Phenolic Wastes , ' . ' "
Wet Air Oxidation
Carbon Adsorption * . ,
Biological Treatment -,'"
Chemical Oxidation
Solvent Extraction
Steam Stripping ; .
Polynuclear Aromatic Wastes
Incineration
Biological Treatment
.Carbon Adsorption .
Wet Air Oxidation
Chemical Oxidation
Steam Stripping
Organo-Nitrogen Compound Wastes ..
Biological Treatment ,
Carbon Adsorption
Steam Stripping .
Wet Air Oxidation
Solvent Extraction ' .
Miscellaneous Halopenated Organic Wastes
Biological Treatment
Steam Stripping
Carbon Adsorption
Solvent Extraction followed by Steam Stripping followed by Carbon
Adsorption -
Chemical Oxidation
Wet Air Oxidation
For some of the waste groups, the Agency is not aware of any facilities that
incinerate wastewater forms of these organic wastes. However, commenters responding
to the Second Third .proposed rule indicated that they were incinerating many
wastewaters and that they did not want to be precluded from doing so. In addition, the
Agency has conducted incineration tests which -demonstrate that incineration is an
MIM/027 -
1031-Ol.mta . . . 2-8
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effective treatment technology for a wide variety of organic compounds, including
halogenated and nonhalogenated organic compounds and pesticides. EPA's evidence
that incineration constitutes significant treatment for these compounds is that these
compounds were quantified at or near their detection limits in the ash and scrubber
water residues from these tests. The chemical structures and physical properties of these
compounds are similar.to those of the compounds in K107, K108, K109, and K110.
Since incineration is demonstrated for treatment of organic waste constituents in
nonwastewater forms of K107, K108, K109, and K110 as discussed above, the Agency
believes incineration is also demonstrated for; these waste constituents in wastewater
forms of these wastes. Therefore, the Agency also identifies incineration as a demon-
strated technology for wastewater forms of K107, K1Q8, K109, and K11Q.
' ' . ' '
Based on engineering judgment, the Agency considers the following
technologies to be demonstrated for wastewater forms of K107, K108, K109, and K110:
'* * f
' Biological treatment;
Carbon adsorption;
Chemical oxidation; , ;
. Distillation;
' ' '
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
* ' ;
Steam stripping; and v ,
Wet air oxidation.
MLM/027
1031-01.mini 2-9
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23 Identification of Best Demonstrated Available Technology (BDATt
. . i
This section presents the Agency's rationale for determining, the best
demonstrated available technology (BDAT) for nonwastewater and wastewater forms of
K107, K108, K109, and K110. The best demonstrated available technology is determined
based on a thorough review of all the treatment performance data available on the waste
of concern or wastes judged to be similar. .
\
For a treatment technology to be identified as "best," the treatment
performance data are screened to determine: -
Whether the data represent operation of a well-designed and well-
operated treatment system; ' ,
Whether sufficient analytical quality assurance/quality control
measures were employed to ensure the accuracy of the data; and
Whether the appropriate measure of performance was used to assess
the performance of the particular treatment technology.
Following the identification of "best," the Agency determines whether the
technology is "available." An available treatment technology is one that (1) is not a
proprietary or patented process that cannot be purchased or licensed from the proprietor
(i.e., it must be commercially available), and (2) substantially diminishes the toxicity of
the waste or substantially reduces the likelihood of migration of hazardous constituents
from the waste. . .
2.3;! Nonwastewaters
^ * ซ i -
As discussed previously, incineration is a demonstrated treatment
technology for nonwastewater forms of K107, K108, K109; and K110.
MLM/027 .
1031-01.mlm 2-10
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The Agency obtained incinerator ash analytical data from the 14 BOAT
treatment tests conducted at what EPA considers to be well-designed and well-operated
hazardous waste incinerators. Strict quality assurance/quality control measures were
employed to ensure the accuracy of the data, and since EPA was collecting these data to
identify and characterize BOAT treatment technologies, appropriate performance
variables, namely U and P waste constituent concentrations in treated and untreated
waste, were measured. The Agency has determined that due to the high temperatures,
efficient mixing, and consistent residence times used at commercial hazardous waste
incinerators, incineration processes are relatively indiscriminate in the destruction of
organics. Therefore, based on the treatment performance data available, the Agency.
considers incineration to be the "best" technology for the treatment of nonwastewater
forms of K107, K108, K109, and K110.
, . Incineration is a commercially available technology. Additionally,
treatment performance data from the 14 BOAT incineration treatment tests indicated
substantial treatment by incineration for the waste constituents of concern and other
similar constituents in nonwastewater forms of unquantifiable U wastes. Therefore,
incineration is considered an "available" treatment technology for K107, K108, K109, and
Kl 10 for the purpose of establishing BDAT. . : .
\
Incineration has been determined to be BDAT for all of the non-
wastewater organic constituents that cannot be quantified in hazardous waste matrices
using current analytical methods, based on similarities in chemical and physical
properties including those contained in nonwastewater forms of K107, K108, K109, and
K110. .
) * , , /
2.3.2 Wastewaters .
' - ; . i
' ' v
As discussed previously, incineration, wet air oxidation, biological
treatment, carbon adsorption, solvent extraction followed by incineration or recycle of
t -
MLM/027
I031-01.mlm . 2-11
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the extract, chemical oxidation, distillation, and steam stripping are all demonstrated
technologies for the treatment of wastewater forms of K107, K108, K109, and K110.
The Agency believes that the best technologies for treating wastewater
forms of K107, K108, K109, and K110 are those technologies that destroy the constit-
uents found in these wastes. Steam stripping, solvent extraction followed by incineration
or recycle of the extract, and distillation are technologies that remove the constituents
from the wastewater stream; however, the waste constituents are not destroyed but are
processed into a more concentrated waste,stream, i.e., the condensate, extract, or bottom
stream (or still bottoms). These waste streams typically require further treatment before *
disposal. As a result, the Agency does not consider steam stripping, solvent extraction,
or distillation to be the best technologies for treating wastewater forms of the wastes
covered in this subsection.
Because a technology removes waste constituents from the waste stream to
be land disposed, but does not destroy them, does not necessarily preclude it from being
considered "best." As discussed below, carbon adsorption is being established as part .of
the chemical oxidation and biodegradation treatment trains. The purpose of the carbon
" f
adsorption step as part of these treatment trains is to remove organic by-products
resulting from the oxidation of waste constituents or biologically degraded by-products.
Carbon adsorption was selected as the removal step over steam stripping, solvent
extraction, and distillation because the Agency believes that carbon adsorption is the
most appropriate removal technology for the widest range of organic compounds likely to
be present in the oxidation and biological treatment effluent streams.
Chemical oxidation provides treatment by oxidizing the organic constituents
found in these wastes. However, to ensure effective treatment of these wastes, chemical
oxidation treatment should include a final carbon adsorption step. Since the constituent
of concern (1,1-dimethylhydrazine) is not quantifiable, it is not possible to accurately .
judge the effectiveness of the chemical oxidation step. Therefore, the Agency believes
MLM/027
1031-Ol.mlm
2-12
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that it is sound engineering judgment to include a final step of carbon adsorption
f , *
following oxidation. Carbon adsorption will ensure that the oxidation by-products are
* - p \
removed from the wastewater matrix. The Agency believes that chemical oxidation
followed by carbon adsorption should be considered a "best" technology train for the
treatment of 1,1-dimethylhydrazine in wastewater forms of K107, K108, K109, and K110.
(It should be noted that spent carbon from the treatment of these wastewaters would
become a nonwastewater form of this waste (54 Federal Register 26630-1, June 23,1989)
and thus would be required to be incinerated to meet the applicable treatment standard.)
The Agency is also including biodegradation followed by carbon adsorption
as a "best" technology train for the treatment of 1,1-dimethylhydrazine' in wastewater
forms of K107, K108, K109, and K11.0. This determination is based on hydrolysis data
indicating that hydrazines break down rapidly in water to simple amines and ammonia,
which are known to be amenable to biological treatment. ~~
The definition of biodegradation as a technology-based standard for listed
wastewaters calls for operating the unit such that "a surrogate compound or indicator
parameter has been substantially reduced in concentration in the residuals". EPA
believes that this provision will provide permitting and compliance authorities with
sufficient control over the biodegradation unit that biodegradation can be designated as
BOAT for these wastes.
' i ' .
The Agency believes it is sound engineering judgement to include a final
step of carbon adsorption following biodegradation to ensure effective treatment of these
wastes. Carbon adsorption will ensure, that the biological break-down products are
removed from the wastewater matrix. (It should be noted that spent carbon from the
treatment of these wastewaters becomes a nonwastewater form of this waste and thus .
would be required to be incinerated to meet the applicable treatment standard.)
MLM/027
1031-01 .mlm 2-13
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In cases where the Agency has treatment performance data for both
wastewater treatment processes and incineration (as measured by total constituent .
concentration in scrubber water), the Agency prefers to establish treatment standards
based on the wastewater treatment processes. However, the Agency has determined that
wastewaters are also treated by incineration and does not intend to preclude industry
from continuing this practice. Therefore, EPA is also identifying incineration as a best
i, ' j
demonstrated technology for the wastewater forms of K107, K108, K109, and K110.
1 ' - ^
Treatment performance data included in Volume A of the Background
Document for Organic U and P Wastes and Multi-Source Leachate (F039) (8) indicated
substantial treatment of organic constituents by carbon adsorption, chemical oxidation,
and biological treatment. In addition, these technologies are commercially available.
Therefore, these technologies are considered to be "available" treatment technologies for
the purpose of establishing BOAT. As discussed in Section 2.2.1, incineration is also an
"available" treatment technology for treatment of these wastes.
Based on the above discussion, EPA is promulgating the following methods
of treatment as treatment standards for organic constituents that are not quantifiable in
wastewater forms of K107, K108, K109, and K110: (1) incineration, (2) chemical
oxidation followed by carbon adsorption, and (3) biodegradation followed by carbon '
adsorption. The Agency believes that these standards will ensure effective treatment
(removal and destruction) of the constituents of concern.
MLM/027
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Table2-l
Summary of Available Characterization Data
for K107, K108, K109, and K110
BOAT List Constituents
None
1,1-Dimethylhydrazihe
0.01
1-10
40-50
trace-0.01
MLMAKZ7
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2-16
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3.0 DNT AND TDA PRODUCTION WASTES (Kill, K112) AND U328 AND
This section describes the Agency's approach in establishing BDAT
treatment standards for Kill, K112, U328, and U353. This includes a description of the
industry that would be affected by land disposal restrictions for dinitrotoluene (DNT)
and toluenediamine (TDA) production wastes, a presentation of available waste
characterization data, and a discussion of the Agency's rationale in determining BDAT
treatment standards for these wastes.
/
Under 40 CFR 261.32 (hazardous wastes from specific sources), waste
identified as Kill is listed as product washwaters from the production of DNT via
nitration of toluene, and K112 is listed as reaction by-product water from the drying
column in the production of TDA via hydrogenation of DNT. U328 and U353 are listed
in 40 CFR 261.33(f) as o-toluidine and p-toluidine, respectively.
!
3.1 Industry Affected and Waste Characterization
1 - ^ '
3;1.1 ., Industry Affected and Process Description
i
To the Agency'^ knowledge, six domestic facilities produce and purify DNT
and TDA and may potentially generate Kill, K112, U328, and U353. Nonwastewaters
generated during the production of TDA and toluene diisocyanate have been addressed
in the Second Third final rule (i.e., K113, K114, K115, K116, and K027). Table 3-1 lists
these facilities by state and EPA region. These facilities were identified using the 1990
SRI Directory of Chemical Producers (3) and data collected during EPA's.listmg efforts
for Kill and K112 (5).
' - ' (
! ' '.*-*'
DNT and TDA are generally produced for use in toluene diisocyanate
manufacturing. TDA may also be produced for use in the manufacture of dyes or other
MLM/027 . - -
1031-Ol.mlm , . " . 3-1
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chemical products. Toluene diisocyanate is used to manufacture polyurethanes, including
polyurethane foam products, coatings, elastomers, and adhesives. A simplified flow
diagram illustrating the manufacturing process generating toluene diisocyanate is
presented in Figure 3-1.
The dinitration of toluene is represented by the overall reaction:
CH,
H2S04
Toluene
+2HN03
Nitric
Acid
-------
then sent to a pressurized reactor where hydrogen is introduced. The TDA product from
the hydrogenation reaction is sent to a catalyst recovery unit. The crude product is then
distilled through a series of columns. Solvent is removed from the solvent recovery
column and is completely recycled. By-product water resulting from the hydrogenation
of dinitrotoluene is removed in the TDA drying column. The by-product water forms the
listed waste K112.
Following distillation, the purified TDA is dissolved in a solvent, typically
chlorobenzene or o-dichlorobenzene. The resulting mixture is then sent to a series of
reactors to form TDI. Phosgene liquid is fed into the bottom of these reactors, which
are referred to as phosgenators. The crude TDI product from the phosgenation reaction
is then distilled through a series of columns. Phosgene is recovered in the phosgene
recovery column and recycled to the phosgenators. Solvent is removed from the solvent
recovery column and sent to a separation column. Bottoms from the solvent recovery
column are sent to the residue separation column, where TDI residue is separated from
the overhead TDI product. '"...-.
U328 and U353 consist of commercial chemical products or manufacturing
intermediates from non-specific sources containing o-toluidine and p-toluidine,
respectively, as the sole active ingredients. Commercial chemical products or
manufacturing intermediates include all commercially pure grades of the listed chemical,
all technical grades, and all formulated products in which the listed chemical is the sole
active ingredient. Off-specification products containing either o-toluidine or p-toluidine
as the sole active ingredient are also included. Finally, any residue of o-toluidine or p-
toluidine that remains in a container or in an inner liner removed from a container and
will not be recycled, reclaimed, or reused, and any residue or contaminated soil, water,
or debris from a spill of o-toluidine or p-toluidine are included.
MLM/027
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U328 and U353 do not include manufacturing process wastes. A product
becomes a waste when it is:
Discarded or intended to be discarded;
Mixed with another material and applied to the land for dust
suppression or road treatment;
Applied to land in lieu of its original intended use; or
Distributed or burned as a fuel or fuel additive.
3.1.2 Waste Characterization
Table 3-2 presents a summary of the available characterization data for
Kill, K112, U328, and U353. Data are presented for BDAT List constituents and other
compounds that are believed to be present or were quantified in Kill, K112, U328, and
U353. ' .' . . '',.
/
3.2 . Applicable and Demonstrated Treatment Technologies
This section identifies the technologies that are applicable for the
treatment of nonwastewater and wastewater forms of Kill, K112, U328, and U353 and
determines which of the applicable technologies can be considered demonstrated for the
purpose of establishing BDAT.
To be applicable, a technology must theoretically be usable to treat the
waste in question or to treat a waste that is similar in terms of parameters that affect
treatment selection. (Detailed descriptions of technologies that are applicable to listed
hazardous wastes are.provided in EPA's Treatment Technology Background Document
(5).) To be demonstrated, a technology must be employed in full-scale operation for
treatment of the waste in question or of a similar waste. Technologies available at only
MLM/Q27
1031-01.mlm 3-4
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pilot-scale or bench-scale operations are not considered in identifying demonstrated
technologies. .
3.2.1 Applicable Treatment Technologies - ' ,
x ' - *
Nonwastewaters
t .... ^
Since nonwastewater forms of Kill, K112, U328, and U353 generally
contain hazardous organic constituents at treatable concentrations, applicable treatment
technologies include those that destroy or reduce the total amount of various organic
compounds in the waste. The Agency has identified the following treatment technologies
' ' '
as applicable for these wastes:
' Chemical oxidation;
Critical fluid extraction followed by incineration of the contaminated
solvents; . x ,
Distillation; .'. - .
/
* Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
and . . . " v .
Wet air oxidation. .
t '-
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A.
Wastewaters
j
s
Since wastewater forms of Kill, Kli2, U328, and U353 may contain
hazardous organic constituents at treatable concentrations, applicable treatment
MLM/027
1031-01.mlm 3-5 .
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technologies include those that destroy or reduce the total amount of various organic
compounds in the waste. Therefore, the Agency has identified the following treatment
technologies as potentially applicable for treatment of these wastes:
Biological treatment; . .
Carbon adsorption;
Chemical oxidation;
\
Distillation;
Incineration (fluidized-bed, rotary kiln, and liquid injection);
PACTฎ treatment (including powdered activated carbon addition to
, activated sludge and biological granular carbon technologies);
Solvent extraction followed by incineration or recycle of the extract;
Steam stripping; and
*
Wet air oxidation.
' . " '
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and have been described in more detail in Appendix A. ,
ป
The concentrations and type(s) of constituents present in the waste
generally determine which technology is most applicable. Carbon adsorption, for
example, is often used as a polishing step following primary .treatment by biological
treatment, solvent extraction, or oxidation. Typically, carbon adsorption is applicable for
treatment of wastewaters containing total organic constituent concentrations less than
0.1%. Wet air oxidation, biological treatment, and solvent extraction (followed by
incineration or recycle of the extract) are applicable for treatment of wastewaters
containing organic constituents at concentrations of up to 1%.
MLM/027 .
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322 Demonstrated Treatment Technologies
This section identifies those applicable treatment technologies that EPA
considers to be demonstrated for the purpose of establishing BOAT for Kill, K112,
U328, and U353.
Nonwastewaters
The Agency believes that incineration is a demonstrated technology for the
5
treatment of nonwastewater forms of Kill, K112, U328, and U353. For the land
disposal restrictions program, the Agency has tested rotary kiln incineration on a full-
scale operational basis for many organic waste constituents including:
*'
Aromatic and Other Hydrocarbon Wastes
Toluene ,
Phenolic Wastes
2-5eciButyl-4,6-dinitrophenol (Dinoseb)
o-Cresol
p-Oresol
Phenol . :
Polynuclear Aromatic Wastes
Benzo(a)pyrene
Chrysene , >
Indeno(l,2,3-cd)pyrene
Benz(a)anthracene
Fluoranthene , ,
! ' ; Naphthalene. ^
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Organo-Nitrogen Compound Wastes
Acetonitrile
Acrylonitrile
Aniline
Nitrobenzene
Pyridine
The Agency believes that because incineration is demonstrated for the
treatment of many organic waste constituents, including those which are structurally
similar to those constituents found in Kill, K112, U328, and U353, incineration is also
demonstrated for these wastes. The Agency is not aware of any facilities that treat these
wastes by fuel substitution and the Agency believes that fuel substitution is inappropriate
for wastes such as Kill, K112, U328, and U353 that contain many constituents with
molecular components other than carbon, hydrogen, and oxygen. Hence, the Agency
believes that fuel substitution is not a demonstrated technology for Kill, K112, U328,
andU353.
From review of the 1986 TSDR Survey (6) and EPA's WERL database (7),
the Agency has determined that some facilities also treat nonwastewater forms of
aromatic and polymiclear aromatic wastes or wastes judged to be similar to Kill, K112,
U328, and U353 using wet air oxidation, chemical oxidation, and distillation on a full-
scale operational basis; therefore, EPA considers these technologies to be demonstrated
for aromatic and polynuclear aromatic wastes such as Kill, K112, U328, and U3S3.
The Agency is not aware of any facilities that treat nonwastewater forms of
these wastes or wastes judged to be similar on a full-scale operational basis using solvent
extraction (followed by incineration or recycle of the extract) or critical fluid extraction
(followed by incineration of the contaminated solvents); therefore, EPA believes that
these technologies are not currently demonstrated for these wastes.
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Wastewaters , .
The following technologies have been identified as demonstrated for
treatment of the following.types of organic wastes (organized by chemical structure):
Kill, K112, U328, and U353.
Aromatic and Other Hydrocarbon Wastes
Incineration ,. . - .
Biological Treatment .'.
Carbon Adsorption
Wet Air Oxidation '
Chemical Oxidation
Steam Stripping
Phenolic Wastes
Wet Air Oxidation
./ Carbon Adsorption
Biological Treatment
Chemical Oxidation
Solvent Extraction
Steam Stripping .
PQlynuclear Aromatic Wastes .
i . ' -
Incineration
Biological Treatment
Carbon Adsorption .
Wet Air Oxidation -
Chemical Oxidation
Steam Stripping
i ,
' Organo-Nitrogen Compound Wastes
Biological Treatment
Carbon Adsorption
Steam Stripping
Wet Air Oxidation
Solvent Extraction
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The Agency is not aware of any facilities that incinerate wastewater forms
of some of the waste groups. However, commenters responding to the Second Third
proposed rule indicated that they were incinerating many wastewaters and that they did
not want to be precluded from doing so. In addition, the Agency has conducted
incineration tests which demonstrated that incineration is an effective treatment
technology for a wide variety of organic compounds, including halogenated and
nonbalogenated organic compounds and pesticides. EPA's evidence that incineration
constitutes significant treatment for these compounds is based on these compounds being
quantified at or near their detection limits in the ash and scrubber water residues from
these tests. The chemical structures and physical properties of these compounds are
similar to those of the compounds in Kill, K112, U328, and U353. Since incineration is
demonstrated for treatment of organic waste constituents in nonwastewater forms of
Kill, K112, U328, and U353 as discussed above, the Agency believes incineration is also
demonstrated for these waste constituents in wastewater forms of these wastes. ,
Therefore, the Agency is also identifying incineration as a demonstrated technology for
wastewater forms of Kill, K112, U328, and U353.
_^ *
Based on engineering judgment, the Agency considers the following ,
technologies to be demonstrated for wastewater forms of Kill, K112, U328, and U353:
Biological treatment;
' Carbon adsorption;
Chemical oxidation;
Distillation; .
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
Steam stripping; and
. . Wet air oxidation. .
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3.3 Treatment Performance Data
i
The Agency does not have treatment performance data for treatment of
nonwastewater and wastewater forms of Kill. However, during the comment period,
one commenter submitted information indicating that the concentrations of .
2,4-dinitrotoluene and 2,6-dinitrotoluene in nonwastewater and wastewater forms of Kill
are sufficiently high that if Kill was treated to meet existing F039 treatment standards
for dinitrotoluenes, then the other constituents in Kill would be treated to acceptably
low concentrations. Therefore, treatment performance data were transferred from other
previously tested wastes to develop concentration-based treatment standards for Kill.
EPA's methodology for transfer of treatment performance data is provided
in EPA's Methodology for Developing BDAT Treatment Standards (1). Transfer of
treatment performance data is technically valid in cases where the untested waste is
generated from a similar industry or similar processing step, or has similar waste
characteristics affecting treatment performance and treatment selection as the tested
wastes. Sources of treatment performance data for potential transfer to nonwastewater
forms of Kill include wastes previously tested by rotary kiln, fluidized-bed, or liquid
injection incineration and are identified in EPA's Final Best Demonstrated Available
Technology (BDAT) Background Document for U and P Wastes and Multi-Source
Leachate (F039). Volume C: Nonwastewater Forms o^Qrganic U and P Wastes and
Multi-Source Leachate (F039) for-Which There Are Concentration-Based Treatment
. Standards (10) (referred to hereafter as Volume C of the F039 Background Document).
Sources of treatment performance data for potential transfer to wastewater forms of
Kill include those wastes and technologies identified in EPA's Final Best Demonstrated
Available Technology (BDAT) Background Document For U and P Wastes and Multi-
Source Leachate (F039). Volume A: Wastewater Forms of Organic U and P Wastes and
Multi-Source Leachate (F0391) For Which There Are Concentration-Based Treatment
Standards (8) (referred to hereafter as Volume A of the F039 Background Document).
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3.3.1
Treatment of Organic. Constituents in Kill Nonwastewaters
Wastes previously tested by the Agency by rotary kiln, fluidized-bed, or
liquid injection incineration include: D014, D016, F024, K001, K011, K013, K014, K015,
K019, K024, K037, K048, K051, K087, K101, K102, P020, P059, U028, U080, U122,
U127, U141, U161, U166, U188, U192, U220, U226, and U239.
Treatment performance data from these previously tested wastes which
were used to develop treatment standards for nonwastewater forms of F039 were also
used to develop treatment standards for 2,4-dinitrotoIuene and 2,6-dinitrotoluene in
Kill. Treatment performance data for the two BDAT List constituents of concern in
Kill from these 14 incineration tests are presented in Table 3-3. A key to the test
numbers identified in Table 3-3 is given in Table 3-4. ,
332
Treatment of Organic Constituents in Kill Wastewaters
Treatment standards for organic BDAT List Constituents in Kill
wastewaters were developed from treatment performance data transferred from EPA's
Volume A of the FQ39 Background Document (8). These .data were used for transfer to
wastewater forms of Kill because the Agency prefers, whenever possible, to use
.appropriate treatment performance data from well-designed and well-operated
wastewater treatment units, rather than scrubber water concentration data, in setting
BDAT treatment standards. These data represent treatment using a specific wastewater
treatment technology as opposed to scrubber water from incineration.
Tables 3-5 and 3-6 present all of the available wastewater treatment
performance data for 2,4-dinitrotoluene and 2,6-dinitrotoluene, respectively. The data
used to determine the BDAT treatment standards are shown with an asterisk. Presented
below are short descriptions of the data sources for wastewater treatment performance
MLM/027
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data on 2,4-dinitrotoluene and 2,6-dinitrotoluene and the Agency's rationale for
determining which data sets were used in the development of each treatment standard.
Sources of Treatment Performance Data
* ' ' " l
This section, describes each of the sources of wastewater treatment
performance data used to compile data for the determination of treatment standards.
/"'. '" ' '
WAO/PACT* Data. For specific Third Third U and P waste codes, a
wastewater treatment performance test .was conducted using Wet Air Oxidation (WAO)
and PACTฎ treatment technologies. The treatment performance data from this test
were incorporated into the tables of this section.
v -; '
. WERL Database. U.S. EPA's Risk Reduction Engineering Laboratory,
which now includes the former Water Engineering Research Laboratory (WERL), has
developed and is continuing to expand a database on the treatability of chemicals in
various types of waters and wastewaters. This WERL database has been compiled from
wastewater treatment performance data available in literature. The treatment
performance data for BOAT List constituents in this database have been included in the
tables of this section. V
Treatment Performance Data \
- . *
2,4-Dinitrotoluene. The data available for 2,4-dinitrotoluene were
compiled from the WERL database and literature WAO data and are presented in
Table 3-5. Technologies for which data are available include AS, PACTฎ, and WOX.
The treatment performance data represent bench-scale and full-scale studies. The
resulting effluent concentrations ranged from 58 ppb to 26,000 ppb.
MLM/027
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The Agency is establishing PACTฎ as BDAT for 2,4-dinitrotoluene.
PACTฎ was selected as BDAT because it represents full-scale data with a high influent
concentration and the lowest effluent concentration of the technologies represented in
Table 3-5. The BDAT treatment standard for 2,4-dinitrotoluene was calculated using the
effluent concentration of 58 ppb and the appropriate variability factor. The calculation
of the resulting BDAT treatment standard for 2,4-dinitrotoluene (0.32 ppm) is described
in Section 3.6 and is shown in Table 3-7. '
2,6-Dinitrotoluene. The data available for 2,6-dinitrotoluene were
compiled from the WERL database and are presented in Table 3-6. Technologies for
which data are available include AL, AS, and PACTฎ. The treatment performance data
represent bench-scale, pilot-scale, and full-scale studies. The resulting effluent .
concentrations ranged from 18 ppb to 260 ppb. . . ' '
The Agency is establishing PACTฎ as BDAT for 2,6-dinitrotoluene.
PACT* was selected as BDAT because it represents full-scale data with a high influent
concentration and the lowest average effluent concentration of those full-scale data
which show substantial treatment. The BDAT treatment standard for 2,6-dinitrotoluene
was calculated using the effluent concentration of 100 ppb and the appropriate variability
factor. The calculation of the resulting BDAT treatment standard for 2,6-dinitrotoluene
(0.55 ppm) is described in Section 3.6 and is shown in Table 3-7.
3.4 Identification of Best Demonstrated Available Technology (BDAT>
This section presents the Agency's rationale for determining the best
demonstrated available technology (BDAT) for nonwastewater and wastewater forms of
Kill, K112, U328, and U353.
EPA determines the best demonstrated available technology based on a
thorough review of all of the treatment performance data available for the waste of
1031-01.mlm 3-14
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concern or wastes judged to be similar. Following the identification of "best," the Agency
determines whether the technology is "available." An available treatment technology is
one that (1) is not a proprietary or patented process that cannot be purchased or
licensed from the proprietor (i.e., it must be commercially available), and
(2) substantially diminishes the toxicity of the waste or substantially reduces the
likelihood of migration of hazardous constituents from the waste.
3.4.1 Nonwastewaters
The determination of BDAT for nonwastewater forms of Kill, K112,
U328, and U353 is discussed below.
Kill
The treatment performance data that were evaluated to determine BDAT
' . ' t
treatment standards for nonwastewater forms of Kill are presented in Section 3.3.
The treatment performance data were screened to determine: '
Whether the data represent operation of a well-designed and well*
operated treatment system; , ' '
Whether sufficient analytical quality assurance/quality control
measures were employed to ensure the accuracy of the data; and ,
Whether the appropriate measure of performance was used to assess
the performance of the particular treatment technology.
EPA has identified incineration as demonstrated for the treatment of
organic constituents in nonwastewater forms of Kill. EPA has treatment performance
data from the incineration of 2,4-dinitrotoluene and 2,6-dim'trotoluene in wastes
considered to be similar to Kill.
MLM/027
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All of the incineration data included in Section 3.3 represent BDAT for
wastes included in previous rulemakings and therefore have already met the above
conditions. Thus, incineration is the "best" technology for treating organic nonwastewater
forms of Kill.
K112, U328, and U3S3
As discussed previously, incineration is also a demonstrated treatment
technology for nonwastewater forms of K112, U328, and U353.
The Agency obtained incinerator ash analytical data from the 14 BDAT
treatment tests conducted at what EPA considers to be well-designed and well-operated
hazardous waste incinerators. Strict quality assurance/quality control measures were
employed to ensure the accuracy of the data, and since EPA was collecting these data to
identify and characterize BDAT treatment technologies, appropriate performance
variables, namely waste constituent concentrations in treated and untreated waste, were
measured. The Agency has determined that due to the high temperatures, efficient
mixing, and consistent residence times used at commercial hazardous waste incinerators,
incineration processes are relatively indiscriminate in the destruction of organics.
Therefore, based on the treatment performance data available, the Agency considers
incineration to be the "best" technology for the treatment of nonwastewater forms of
K112, U328, and U353.
i
Incineration is a commercially available technology. Additionally,
treatment performance data from the 14 BDAT incineration treatment tests show
substantial treatment by incineration for the waste constituents of concern and other
similar constituents in nonwastewater forms of unquantifiable U wastes. Therefore,
incineration is an "available" treatment technology for Kill, K112, U328, and U3S3 for
the purpose of establishing BDAT.
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3.4.2 Wastewaters
The determination of BOAT for wastewater forms of Kill, K112, U328,
K
and U353 is discussed below.
Kill
The treatment performance data that were evaluated to determine BOAT
treatment standards for wastewater forms of Kill are presented in Section 3.3. As
discussed in Section 3.3, the Agency believes that the data from PACTฎ treatment of
2,4-dinitrotoluene and 2,6-dmitrotoluene represent the best treatment performance for
these constituents. -
K112, U328, and U353
j
As discussed previously, incineration, wet air oxidation, biological
treatment, carbon adsorption, solvent extraction followed by incineration or recycle of
the extract, chemical oxidation, distillation, and steam stripping are all demonstrated ,
technologies for the treatment of wastewater forms of K112, U328, and U353.
1
The Agency believes that the best technologies for treating K112, U328,
and U3S3 are those technologies that destroy the constituents found in these wastes.
Steam stripping, solvent extraction followed by incineration or recycle of the extract, and.
y,
distillation are technologies that remove the constituents from the wastewater stream;
however, the waste constituents are not destroyed but are processed into a more concen-
trated waste stream, i.e., the condensate, extract, or bottom stream (or still bottoms).
These waste streams typically require further treatment before disposal. As a result, the
Agency does not consider steam stripping, solvent extraction, or distillation to be the best
technologies for treating wastewater forms of the wastes covered in this subsection.
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Because a technology removes waste constituents from the waste stream to
be land disposed, but does not destroy them, does not necessarily preclude it from being
considered "best." As discussed below, carbon adsorption is being established as part of
j .
the chemical oxidation and biodegradation treatment trains. The'purpose of the carbon
adsorption step as part of these treatment trains is to remove organic by-products
resulting from the oxidation of waste constituents or biologically degradated by-products.
Carbon adsorption was selected as the removal step over steam stripping, solvent
extraction, and distillation because the Agency believes that carbon adsorption is the
most appropriate removal technology for the widest range of organic compounds likely to
be present in the oxidation and biological treatment effluent streams.
Chemical oxidation provides treatment by oxidizing the BOAT List
constituents found in these wastes. However, to ensure effective treatment of these
wastes, chemical oxidation treatment should include a final carbon adsorption step.
Carbon adsorption will ensure that the oxidation by-products are removed from the
wastewater matrix. The Agency believes that chemical oxidation followed by carbon
adsorption should be considered a "best" technology train for the treatment of organic
constituents in wastewater forms of K112, U328, and U353. (It should be noted that
spent carbon from the treatment of these wastewaters would become a nonwastewater
form of the waste (54 Federal Register 26630-1, June 23, 1989) and thus would be
required to be incinerated to meet the applicable treatment standard.)
The Agency is also including biodegradation followed by carbon adsorption
as a "best" technology train for the treatment of organic constituents in wastewater forms
of K112, U328, and U353. Recently submitted data indicated that biological treatment
can achieve significant reductions in the concentrations of 2,4-dinitrotoluene and
2,6-dinitrotoluene in wastewater forms of K112. Based on these data, EPA is
establishing biodegradation as a method of treatment for wastewater forms of K112.
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The Agency also believes that o-toluidine and p-toluidine, the listed
components of U328 and U353, are chemically similar to DNT, and that the treatment
standards for wastewater forms of K112 should apply to wastewater forms of these
wastes as well. Therefore, EPA is establishing biodegradation as a method of treatment
for wastewater forms of U328 and U353.
The definition of biodegradation as a treatment standard for wastewaters
calls for operating the unit such that, "a surrogate compound or indicator parameter,has
been substantially reduced in concentration in the residuals." The Agency believes that
this provision will provide permitting and compliance authorities with sufficient control
over the biodegradation unit that it can be designated as BDAT for wastewater forms of
K112, U328, and U359.
The Agency believes it is sound engineering judgement to include a final
step of carbon adsorption following biodegradation to ensure effective treatment of these
wastes. This step will ensure that the biological break-down products are removed from
the wastewater matrix. (It should be noted that spent carbon from the treatment of
these wastewaters becomes a nonwastewater form of the waste and thus would be
required to be incinerated to meet the applicable treatment standard.)
. "v
.In cases where the Agency has treatment performance data for both
wastewater treatment processes and incineration (as measured by total constituent
concentration in scrubber water), the Agency prefers to establish treatment standards
based on the wastewater treatment processes. However, the Agency has determined that
, ' / '
wastewaters are also treated by incineration and does not intend to preclude industry
from continuing this practice. Therefore, EPA is also identifying incineration as a best
demonstrated technology for these wastewater forms of K112, U328, and U353.
. Treatment performance data included in Volume A of the F039
* .
Background Document (8) indicated substantial treatment of organic constituents by '
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PACTฎ, carbon adsorption, chemical oxidation, and biological treatment In addition,
these technologies are commercially available. Therefore, these technologies are
considered to be "available" treatment technologies for the purpose of establishing
BDAT. As discussed in Section 3.2.1, incineration is also an "available" treatment
technology for treatment of K112, U328, and U353.
Based on the above discussion, EPA is promulgating the following methods
of treatment as treatment standards for organic constituents that are not quantifiable in
wastewater forms of K112, U328, and U353: (1) incineration, (2) chemical oxidation
followed by carbon adsorption, and (3) biodegradation followed by carbon adsorption.
The Agency believes that each standard will ensure effective treatment (removal and
destruction) of the constituents of concern.
3.5 Selection of Regulated Constituents in Kill
The Agency has developed a list of hazardous constituents (the BDAT
Constituent List, presented in EPA's Methodology for Developing BDAT Treatment
Standards (1)) from which, constituents are selected for regulation. EPA may revise this
list as additional data and information become available. The list is divided into the
following categories: volatile organics, semivolatile organics, metals, inorganics other
than metals, organochlorine pesticides, phenoxyacetic acid herbicides, organophosphorus
insecticides, polychlorinated biphenyls (PCBs), and dioxins and furans. This section
presents EPA's methodology and rationale for selection of constituents for regulation in
nonwastewaier and wastewater forms of Kill.
Generally, constituents selected for regulation must satisfy the following
criteria:
1. The constituent must be on the BDAT List of constituents.
Presence on the BDAT List means that EPA-approved methods
exist for analysis of the constituent in treated waste matrices.
MLM/027 -
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The constituent must be present in. or be suspected of being present
in. the untreated waste. For example, analytical difficulties may
prevent a constituent from being identified in the untreated waste,
but its identification in a treatment residual may lead the Agency to
conclude that it is present in the untreated waste.
From a group of constituents that may be selected for regulation because
1 ' /
they meet the above criteria, EPA may select a subset of constituents that represents the
broader group. For example, from a group of constituents that react similarly to
treatment, the Agency may select for regulation those constituents that (1) are the most
difficult to treat, based on waste characteristics affecting treatment performance; (2) are
V \ . '
representative of other constituents in the waste, based on structural similarities; or (3)
are present in the untreated waste in the highest concentrations. Selecting a subset of
constituents for regulation is done to facilitate implementation of industry compliance
and of EPA's enforcement program.
The Agency initially considered all constituents on the BDAT list for
regulation in Kill. Table 3-2 summarizes available waste characterization data for
constituents in Kill and presents ranges of concentrations for constituents detected in
the waste. Constituents for which analyses were not performed are identified by "NA"
(not analyzed).
\ Two BDAT List constituents have been identified in Kill,
2,4-dinitrotoluene and 2,6-dinitrotoluene. The Agency has selected both BDAT List
constituents for regulation in nonwastewater and wastewater forms of Kill.
3.6 . Calculation of BDAT Treatment Standards for Kill
The Agency bases concentration-based treatment standards on the
performance of well-designed and well-operated treatment systems. These standards
account for analytical limitations in available treatment performance data and for
MLM7027
103141 .aim 3*21
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variabilities related to treatment, sampling, and analytical techniques and procedures.
This section presents the calculation of treatment standards for the constituents selected
for regulation in Section 3.5 using the available treatment performance data discussed in
Section 3.3.
3.6.1 Nonwastewaters ,
Treatment standards for regulated constituents in nonwastewater forms of
Kill were calculated based on data compiled from the BDAT incineration database for
incinerator ash. Treatment performance data from eleven (11) incinerator tests were
used to calculate the BDAT treatment standards for 2,4-dinitrotoluene and
2,6-dinitrotoluene in nonwastewater forms of Kill.
'
The Agency considered the detection limits from each of these tests and
determined which were the most representative for each waste constituent. The Agency
selected the highest detection Emit for each regulated constituent from the incineration
tests to account for the anticipated variability in untreated wastes.
' . y
Concentration-based treatment standards for regulated waste constituents
were calculated by multiplying the constituent detection limit in ash by an accuracy
correction factor and a variability factor. The following subsections discuss these three
components of the treatment standard calculation. The calculation of treatment
standards for regulated constituents in nonwastewater forms of Kill are summarized in
Table 3-7.
Detection Limits
: The detection limits for 2,4-dinitrotoluene and 2,6-dinitrotoluene in ash
were used to. calculate the treatment standards for nonwastewater forms of Kill. The
MLMAK7
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highest detection limit for each of these constituents from the 11 incineration tests was
used.
Accuracy Correction Factors
The detection limits used to calculate treatment standards were corrected
using matrix spike recovery data from the same test from which the detection limits were
taken to account for analytical interferences associated with the chemical matrices of the
samples. Detection limits were corrected.for accuracy as follows:
A matrix spike recovery was determined for each regulated constitu-
ent. In cases where a matrix spike was not performed for a
regulated constituent in the treatment test from which the detection
limit was taken, the matrix spike recovery from a similar constituent
from that treatment test was transferred to the constituent.
An accuracy correction factor was determined for each of the above
constituents by dividing 100 by the matrix spike recovery (expressed
as a percentage), for that constituent.
Detection limits for each of the regulated constituents were
corrected by multiplying the detection limit for each constituent by
1 its corresponding accuracy correction factor. The detection limit
and accuracy correction factor for each constituent are shown on
Table 3-7. .
Matrix spike recoveries used to adjust detection limits for the regulated
constituents in nonwastewater forms of Kill are included in Appendix B. Duplicate
matrix spikes were performed for some waste constituents. If a duplicate matrix spike
was performed for a constituent, the matrix spike recovery used for that constituent was
the lower of the two values between the first matrix spike and the duplicate spike.
Matrix spike recoveries of less than 20% are not acceptable and were not used to correct
detection limits. Matrix spike recoveries greater than 100% were considered to be 100%
for the purpose of this calculation so that the data were not adjusted to concentrations
MLM/027 . .
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below the detection limits. In cases where the detection limit came from more than one
* * i
test, the lowest matrix spike recovery among the tests was used.
Variability Factors '- ''
The variability factor accounts for the variability inherent in treatment
system performance, treatment residual collection, and analysis of the treated waste
samples. Variability factors could not'be calculated for regulated constituents that were
not detected in the incinerator ash residuals. Therefore, a variability factor of 2.8 was
used to account for this inherent variability, as discussed in the Methodology for
Developing BDAT Treatment Standards (1).
3.6.2
Wastewaters
Treatment standards for wastewater forms of Kill were calculated based
on data compiled from EPA's wastewater treatment performance database. Specifically,
treatment performance data from PACTฎ treatment were used.
Concentration-based treatment standards for regulated waste constituents
were calculated by multiplying the constituent effluent concentration (as presented in
Section 33) by an accuracy correction factor and a variability factor. The following
subsections discuss these three components of the treatment standard calculation. The
calculation of treatment standards for regulated constituents in wastewater forms of Kill
are summarized in Table 3-7.
Constituent Effluent Concentration
The effluent concentration obtained using the BDAT for each regulated
constituent in Kill was determined as discussed in Section 3.3.2. The treatment .
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performance data for each regulated constituent are presented in Tables 3-5 and 3-6 at
the end of this section. ,
Accuracy Correction Factors
/ f
Accuracy correction factors account for analytical interferences associated
with the chemical matrices of the samples. BAD variability factors were used or
transferred for use in the calculations of treatment standards for regulated constituents in
wastewater forms of Kill. Based on the fact that HAD variability factors were originally
calculated to represent performance, analytical, and matrix variations, an additional
accuracy correction factor was not used. ,
Variability Factors
A variability factor (VF) accounts for the variability inherent in the
treatment system performance, treatment residual collection, and analysis of the treated
waste samples. Variability factors are generally calculated as described in EPA's
Methodology for Developing BOAT Treatment Standards (1). However, original
. effluent data points were not1 available for the regulated constituents1 in Kill since
WERL effluent data were used to determine treatment standards and those data were
presented as averages in the WERL database. Therefore, it was not possible to calculate
an individual variability factor for these constituents; instead, an average variability
factor was used. The average variability, factors were generated from the BAD
variability factors and are specific to the type of constituent under consideration (i.e.,
volatile organic, acid extractable semivolatile organic, etc.). The calculation of average
variability factors is discussed in Appendix C.
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Table 3-1
Facilities that May Generate Kill and K112,
by State and EPA Region
WiงW:^ฅ^^&syjl^
Air Products and Chemicals
BASF Corporation
Mobay Corporation
Mobay Corporation
Olin Chemicals
Rubicon
,':V: ':: '$/'< ''&< ฃ::'::*:.- ' ฃ $.&'' '' i'i?'?.: '$' ' ':'' 'ฃ:***?x~ฃ$y''ฃ'-
^^^^JpBCaTOปm^sf^i
Pasadena, TX
Geismar, LA
Baytown,TX
New Martinsville, WV
Lake Charles, LA
Geismar, LA
' VI
,Vl
VI
m
VI
VI
Facilities that May Generate U328 and U353,
by State and EPA Region
Facility
Archem Company
DuPont
First Chemical Company
Olin Chemicals
G. Frederick Smith
Chemicals Company
, Location
Houston, TX
Deepwater, NJ
Pascagoula, MS
Lake Charles, LA
Columbus, OH
EPA Region
VI
n
IV
VI
v
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Table 3-2
Summary of Available Characterization Data
for Kill, K112, U328, and U353
WK^jffm^ySMSI
':':': -"' ' -'- ': ' ":' -.:-"--',;>..-._":-. --';'..;'.:,:;',-,','.'."-,:;'''r::-;>-1:-
2,4-Dinitrotoluene
2,6-Dinitrotohiene
Other Constituents
Sulfuric Acid
Nitric acid
2,6rDinitro-p-cresol
Mononitrotoluenes
Mononitrophenols
Dinitrophenols '
Nitrobenzoic acids
Mononitrocresols
2,4-Toluenediamine
2,6-Toluenediamine
3,4-ToIuenediamine
o-Toluidine
p-Toluidine
Wj^M^j^Coi^a
0.08
0.02
-
1-4
1-4
0.06
0.005
. 0.007*
0.007*
0.007*
0.007*
NA
NA
NA - ,
NA -
NA
i^fi^*^$ff:
liBill
NA
NA
,-
NA ,
NA
NA
NA
NA .
NA
NA
. NA
0.05-0.3
0.05-0.3
0.05-0.3
0-0.06
0-0.04
f^CiiX-^fM-^Af:^;^
liii&ili
NA
NA
-
NA
.NA
NA
NA
NA
NA
NA
. NA
NA
.NA
NA
NA '
NA
111 111 1 ;
Ililiisl 1 :
NA
NA
-
NA
NA
NA
NA
NA
NA
NA
.. ,NA
. NA
. NA
NA
NA
NA *
NA - Not analyzed.
*Total combined concentration.
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3-28
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Table 3-4
Wastes Tested by Incineration
:;|lreip:|;
IfNumilr^
1
2
3
4
5
6
7
8
9
, 10 .
11
12
13
14
f m^ฉ p(KSii S| '
KOOl-Pentachlorophenol
KOOl-Creosote
K011, K013, K014
K019
K024
K037
K048.K051
K087
K101
K102
F024
K015
D014, D016, P0591,
U127', U192'
U141ป, U028', P020',
U122', U226m, U2391,
U080ซ, U2201, U166a,
U161', U188'
: ': :''->.:>!: iov'.. -<'.': >:''" >-. !- :'.:< f '.: '.'
::p: .; | ": ::i-.,-;.,- ':; ;:.; ;:;;: :-'::':v." :- ;V:: p: " ;;;.:
^ V^'v:--^'-:-'-^- '::! '':-'-:>v ป';>''" ': :'":'.:
y- '^YX'lv^'i-i'l'ftvSv:1!-: ::" "'i'l'I'X:'! ;': !-?:-.
:;;-:-:".: :':-.-! :-:>::-: l-.-:-::i i'lOx-iv; .':':-&r-:-:':-.'-:> -"
filiiSpio&ll
lil^^diii
Rotary Kiln
Rotary Kiln
Rotary Kiln
Rotary Kiln
Rotary Kiln
Rotary Kiln
Fluidized Bed
Rotary Kiln
Rotary Kiln
Rotary Kiln'
Rotary Kiln
Liquid
Injection
Rotary Kiln
;
Rotary Kiln
jBackgroiind
ppcumeiit
^Jt^n^o^vi
If^JDpmfiml^
. 18
, 18
17
19
20
21
22
- 23
24
25,,
,26
27
NA '-,'
NA
1 JlPpUe III
i^j^eeririg s
|g
^HReBSrencc^-.
28
29
30
31
32 .
33
34,35
36
37.
38
39
40
41
4^
NA - Not applicable. '
Commercial chemical products were used in these incineration tests as surrogates for
these wastes.
MLM/027
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I
i
>
c
8*
ป-t
Sf
I
1
3-30
-------
so
I
1
oo
T""l
s
s
8
^^
i
OB
VO
i
N
is
3-31
-------
Table 3-7
Calculation of Nonwastewater and Wastewater
Treatment Standards for Kill
Detection^
Kill NoDwastewaten
2,4-Dinitrotoluene
2,6-Dinitrotoluene
50 mg/kg
10 mg/kg
1.
1.0
2.8
140 mg/kg
28 mg/kg
Kill Wastewaters
2,4-Dinitrotoluene
2,6-Dinitrotoluene
0.058 rog/L
, 0.10 mg/L
032 mg/L
0.55 mg/L
'An accuracy correction factor was not used since an HAD variability factor was used.
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il
3-33
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4.0 EDB PRODUCTION WASTES (K117, K118, K136)
This section describes the Agency's approach in establishing BDAT
treatment standards for Kill, K118, and K136. This includes a description of the
industry that would be affected by the land disposal restrictions for ethylene dibromide
ป i * '
(EDB) production wastes, a presentation of available waste characterization data, and a
discussion of the Agency's rationale in determining BDAT treatment standards for these
wastes.
Under 40 CFR 261.32 (hazardous wastes from specific sources), waste
identified as K117 is listed as wastewater from the reactor vent gas scrubber in the
.' i .
production of EDB via bromination of ethene; K118 is listed as spent adsorbent solids
from purification of EDB via bromination of ethene, and K136 is listed as still bottoms
from the purification of EDB in .the production of EDB via bromination of ethene.
4.1 Industry Affected and Waste Characterization
^ . <
4.1.1 Industry Affected and Process Description
. To the Agency's knowledge, two domestic facilities produce EDB from the
bromination of ethene and may potentially generate K117, K118, and K136. The
4 "
facilities are Ethyl Corporation located in Magnolia, AR, and Great Lakes Chemical
located in El Dorado, AR. Both facilities are located in EPA Region VI. These
facilities were identified using the 1990 SRI Directory of Chemical Producers (3) and
data collected during EPA's listing efforts for K117, K118, and K136 (11).
Ethylene dibromide is used as a component of tetra-alkyl lead anti-knock
gasoline additives. It is also used as an intermediate in chemical synthesis (e.g., vinyl
bromide) and as a nonflammable solvent for resins, gums, and waxes. EDB has also
been used as a soil fumigant for the agricultural industry, but was banned by EPA for
MLM/027 v . ..
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this use, A simplified flow diagram illustrating the manufacturing process generating
ethylene dibromide is presented in Figure 4-1.
Ethylene dibromide is produced by the following reaction sequence:
QH* + Br2 > BrCH2CHjBr
The reaction of bromine with ethylene is highly exothermic; thus, various
methods are used to bring these two feedstocks together so as to dissipate the heat of
reaction and minimize the formation of by-products (12). These various methods are not
expected to affect the generation and composition of the waste streams.
A gaseous vent stream leaves the reactor and is passed through a
condenser to condense unreacted ethene, bromine, and EDB which are recycled to the
reactor. The noncondensable gases, which consist of low boiling paraffinic hydrocarbons
and unreacted ethene and bromine, are then scrubbed with water to remove traces of
EDB and organics prior to being vented to the atmosphere. The scrubber produces an
aqueous effluent (K117, as shown in Figure 4-1).
Purification of crude liquid can involve either filtration or drying over an
activated adsorbent packing or similar solid, to remove inorganic solids or reduce color.
This purification process produces spent adsorbent solids (Kl 18, as shown in Figure 4-1).
The wastes are solids containing adsorbed EDB. The purified product meets die
commercial specification of 99.5% minimum EDB.
The product can also be purified by distillation. Distillation produces an
organic still bottom that combines EDB and any high-boiling materials produced by side
reactions (K136, as shown in Figure 4-1).
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4.1.2 Waste Characterization . . -
i *
/
Table 4-1 presents a summary of the available characterization data for
K117, K118, and K136. Data are presented for BDAT List constituents and other
compounds that are believed to be present in or were quantified in K117, K118, and
K136.
4.2 . Applicable and Demonstrated Treatment Technologies
This section identifies the technologies that are applicable for the
treatment of nonwastewater and wastewater forms of K117, K118, and K136 and
discusses which of the applicable technologies can be considered demonstrated for the
purpose of establishing BDAT. . .
' *
To be applicable, a technology must theoretically be usable to treat the
waste in question or to treat a waste that is similar in terms of parameters that affect -
treatment selection. (Detailed descriptions of technologies that are applicable to listed
hazardous wastes are provided in EPA's Treatment Technology Background Document
(5).) To be .demonstrated, a technology must be employed in full-scale operation for
treatment of the waste in question or of, a similar waste. Technologies available only at
pilot-scale or bench-scale operations are not considered in identifying demonstrated
technologies. , '
4.2.1 Applicable Treatment Technologies
i
Nonwastewaters .
Since nonwastewater forms of K117, K118, and K136 generally contain
hazardous organic constituents at treatable concentrations, applicable treatment
technologies include those that destroy or reduce the total amount of various organic
MLM/027
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compounds in the waste. The Agency has identified the following treatment technologies
as applicable for these wastes:
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
and
Critical fluid extraction followed by incineration of the contaminated
solvents.
" t
These treatment technologies were identified based on current waste treatment practices.
and engineering judgment and are described in more detail in Appendix A.
' *
Wastewaters
Since wastewater forms of K117, K118, and K136 may contain hazardous
organic constituents at treatable concentrations, applicable technologies include those
that destroy or reduce the total amount of various organic compounds in the waste.
Therefore, the Agency has identified the following treatment technologies as potentially
applicable for treatment of these wastes:
Biological treatment;
Carbon adsorption;
Chemical oxidation;
Chemically assisted clarification;
1 . x
PACTฎ treatment (including powdered activated carbon addition to
activated sludge and biological granular activated carbon ',
technologies);
Reverse osmosis;
Solvent extraction; , '..."-'
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Stripping treatment (including steam stripping and air stripping
technologies); and
Wet air oxidation.
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A.
The concentrations and type(s) of constituents present in the waste
generally determine which technology is most applicable. Carbon adsorption, for ,
example, is often used as a polishing step following primary treatment by biological
treatment, solvent extraction, or oxidation. Typically, carbon adsorption is applicable for
treatment of wastewaters containing total organic constituent concentrations less than .
0.1%. Wet air oxidation, PACTฎ treatment, biological treatment, and solvent extraction
are applicable for treatment of wastewaters containing organic constituents at
concentrations of up to 1%.
422 Demonstrated Treatment Technologies , c-
This section identifies those applicable treatment technologies that EPA
considers to be demonstrated for the purpose of establishing BDAT for Kill, K112,
U328, and U353. .
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Nonwastewaters
The Agency believes that incineration is a demonstrated technology for the
treatment of nonwastewater forms of K117, K118, and K136. For the land disposal
restrictions program, the Agency conducted an ethylene dibromide incineration test on a
full-scale operational basis. The Agency believes that since incineration is demonstrated
for treatment of EDB, treatment is therefore demonstrated for similar brominated
organic waste constituents. Analytical data and complete discussions of the test methods
used are available in the.corresponding on-site engineering report (OER) for the EDB
incineration test (13). . : ,
The Agency is not aware of any facilities that treat the nonwastewater
forms of brominated organic wastes, or wastes judged to be similar, by fuel substitution
and the Agency believes that fuel substitution is inappropriate for wastes such as,K117,
K118, and K136 that contain many constituents with molecular components other than
carbon, hydrogen, and oxygen. Therefore, the Agency believes that fuel substitution is
not currently demonstrated for these wastes. In addition, the Agency is not aware of any
facilities that treat nonwastewater forms of the brominated organic wastes, or wastes
judged to be similar, using solvent extraction or critical fluid extraction on a full-scale
operational basis; therefore, EPA believes that these technologies are not currently
demonstrated for these wastes.
Wastewaters
The Agency has identified biological treatment, air/steam stripping, reverse
osmosis, chemically assisted clarification, and carbon adsorption as demonstrated
technologies for the treatment of organic constituents in wastewater forms of K117,
K118, and K136. These technologies have been identified as providing .treatment on a
full-scale operational basis for the BDAT List constituents in K117, K118, and K136,
including ethylene dibromide, bromomethane, and chloroform.
MLM/027
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Analytical data and additional discussions of the constituents expected to
be found in K117, K118, and K136 are presented in Section 4.3.
The Agency is not aware of any faculties that treat wastewater forms of
brominated organic wastes by PACTฎ, solvent extraction, chemical oxidation, or wet air
oxidation; therefore, the Agency believes that these technologies are not currently
.demonstrated for these wastes. (
i
4.3 Treatment Performance Data
/ t . . '
The Agency does not have treatment performance data for treatment of
, nonwastewater and wastewater forms of K117, K118, and K136. Therefore, treatment
performance data were transferred from other previously tested wastes to develop
concentration-based treatment standards for these wastes.
EPA's methodology for transfer of treatment performance data is provided
in EPA's Methodology for Developing BOAT Treatment Standards (1), Transfer of
treatment performance data is technically valid in cases where the untested waste is
generated from a similar industry or similar processing step, or has similar waste
characteristics affecting treatment performance and treatment selection as the tested
wastes. Sources of treatment performance data for potential transfer to nonwastewater
forms of K117, K118, and K136 include wastes previously tested by rotary kirn, fluidized-
bed, or liquid injection incineration and identified in EPA's Volume C of the F039
Background Document (10). Sources of treatment performance data for potential
transfer to wastewater forms of K117, K118, and K136 include those wastes and
technologies identified in EPA's Volume A of the F039 Background Document (8).
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4.3.1 Treatment of Organic Constituents in Nonwastewaters
Wastes previously tested by the Agency by rotary kiln, fluidized-bed, or
liquid injection incineration include: D014, D016, F024, K001, K011, K013, K014, K015,
K019, K024, K037, K048, K051, K087, KlOl, K102, P020, P059, U028, U080, U122,
U127, U141, U161, U166, U188,11192, U220, U226, and U239. .
In addition, the Agency is aware of several facilities that currently
incinerate-bromine-containing wastes. At Rollins Environmental Services, Deer Park,
Texas, the Agency has previously incinerated ethylene dibromide wastes that were
cancelled pesticides under FIFRA provisions. Excess oxygen conditions were carefully
controlled to reduce the amount of bromine gas and to increase the amount of hydrogen
bromine gas generated by incineration. Hydrogen bromide is readily absorbed by the air
pollution control devices (APCDs), while bromide is difficult to remove by APCDs. The
Agency believes that control of the undesirable conversion of the bromine-containing
waste to bromine gas significantly affects the design and operation of the incineration
systems. For these reasons, the Agency does not believe that transfer of treatment
performance data from incineration of the non-brominated wastes listed in previous
sections of this document is technically valid for the purpose of developing
, concentration-based treatment standards for brominated constituents in organic wastes.
Therefore, treatment performance data from the EDB incineration test
were used to develop treatment standards for EDB and bromomethane in K117, K118,
and K136. EDB treatment performance data from the EDB incineration ,test for the
untreated waste feed and the incinerator ash treatment residual are included in
ft ,i
Table 4-2. Design data for the treatment systems used for the EDB incineration test are
included in Table 4-3.
Since the waste characterization data presented in Section 4.1.2 also
identify chloroform as a constituent in K117, incineration treatment performance data on
v ' '
MLM/027 ' ,
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chloroform were transferred to Kl 17, Kl 18, and K136. Specifically, the Agency
/' -
considered treatment performance data from the 14 EPA-conducted incineration tests
listed in Table 4-4. Chloroform was detected in the untreated or treated wastes from
treatment tests 3 and 4; accordingly, data from these two tests were used in the
development of treatment standards for chloroform. Table 4-5 presents the highest
detection limits available for chloroform in the incinerator ash in all 14 incineration ;
tests.
432 Treatment of Organic Constituents in Wastewaters
Treatment standards for organic BDAT List Constituents in these
wastewaters were developed from treatment performance data transferred from EPA's
Volume A of the F039 Background Document (8). These data were used for transfer to
wastewater forms of K117, K118, and K136 because the Agency prefers, whenever
\
possible, to use appropriate treatment performance data from well-designed and well-
operated wastewater treatment units, rather than scrubber water concentration data, in
setting BDAT treatment standards. These data represent treatment, using a specific
wastewater treatment technology as opposed to scrubber water.
Tables 4-6, 4-7, and 4-8 at the end of this section present the available
treatment performance data for ethylene dibromide, bromomethane, and chloroform.
The data used to determine the BDAT treatment standards are shown with an asterisk.
v ' - ,
Presented below are short descriptions of the data sources for wastewater
treatment performance data on ethylene dibromide, bromomethane and .chloroform and
the Agency's rationale for determining which data sets were used in the development of
each treatment standard.
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Sources of Treatment Performance Data
This section describes each of the sources of wastewater treatment
performance data sources to compile data for determination of treatment standards.
WAO/PACT* Data. For specific Third Third U and P waste codes, a
wastewater treatment performance test was conducted using Wet Air Oxidation (WAO)
and PACTฎ treatment technologies. The treatment performance data from this test
were incorporated into the tables of this section.
ITD Database-Effluent Guidelines. In response to the Federal Water
Pollution Control Act (FWPCA) of 1972 and the Clean Water Act (CWA) of 1977, EPA
promulgated regulations to reduce the level of pollutants in wastewater discharged from
industrial point sources using the "Best Available Technology Economically Achievable."
The program of developing and promulgating effluent guidelines was assigned to the
Industrial Technology Division (ITD) (now titled Engineering and Analysis Division
(BAD)) within EPA's Office of Water Regulations and Standards. To date, BAD has
promulgated effluent guidelines for 27 industrial categories.
The treatment performance data used for EAD's promulgation efforts have
been summarized by category in specific effluent limitations guidelines and standards
development documents. The treatment performance data from the Development
Document for Effluent Limitations Guidelines. New Source Performance Standards, and
Pretreatment Standards for the Organic Chemicals and the Plastics and Synthetic Fibers
Point Source Category (14) for BDAT List organic constituents for which EAD effluent
limitations exist were incorporated into the tables of this section.
NPDES Database. Under the Dean Water Act, the discharge of pollutants
into the waters of the United States is prohibited unless a permit is issued by EPA or a
state under the National'Pollutant Discharge Elimination System (NPDES). An NPDES
\
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permit provides effluent limitations for specific pollutants that a facility can discharge.
The permit also provides for monitoring and reporting requirements by a facility to .
check whether the effluent limitations are;being met. The monitoring data submitted by
facilities to EPA or the state as part of the NPDES permit program is summarized in a
database. .
j .
The NPDES database was searched for 90 BDAT List constituents to
identify facilities that have monitoring data for any of those constituents. Constituent
data from this search, representing concentrations of constituents in wastewater effluents,
have been incorporated into the tables of this section. EPA was unable to evaluate
whether substantial treatment occurred since corresponding influent concentrations of
the constituents were unavailable. The treatment technologies or treatment trains
represented by the NPDES data were identified in some,, but not all cases. Where
available, the treatment technology has been specified in the tables of this section.
' WERL Database. U.S. EPA's Risk Reduction Engineering Laboratory,
which now includes the former Water Engineering Research Laboratory (WERL), has
developed and is continuing to expand a database on the treatability of chemicals in
various types of waters and wastewaters. This WERL database has been compiled from
wastewater treatment performance data available in literature. The treatment
performance data for BDAT List constituents in this database have been included in the
tables of this section.
Treatment Performance Data , ,
. ' Ethvlene Dibromide (1,2-dibromoethane). The data available for ethylene
dibromide were compiled from the WERL database and are presented in Table 4-6.
Technologies for which data are available include AirS and RO. The treatment
performance data represent pilot-scale studies only. The resulting effluent
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t
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concentrations ranged from 0.06 ppb to 7.0 ppb with a detection limit for ethylene
dibromide established at 4.8 ppb. :'','.
The Agency is establishing air stripping (AirS) as BDAT for EDB. Air
stripping was selected as BDAT because of its high removal efficiency and ability to treat
wastewater to a level below the detection limit* The BDAT treatment standard for EDB
was calculated using a detection limit of 4.8 ppb and the appropriate variability factor.
The calculation of the resulting BDAT treatment standard for EDB (0.028 ppm) is
described in Section 4.6 and is shown in Table 4-10.
Bromomethane. The data for bromomethane were compiled from the
WERL and NPDES databases and are presented in Table 4-7. Technologies for which
data are available include AS and BT. The treatment performance data represent full-
scale technologies and show an effluent concentration range of 1 ppb to 20 ppb.
The Agency is establishing activated sludge biological treatment as BDAT
for bromomethane. Activated sludge was selected as BDAT because the available data
show high influent concentrations and a high removal efficiency. The BDAT treatment
standard for bromomethane was calculated using the effluent concentration of 20 ppb
r
and the appropriate variability factor. The calculation of the resulting BDAT treatment
standard for bromomethane (0.11 ppm) is described in Section 4.6 and is shown in Table
4-10.
Chloroform. Several sources of wastewater treatment performance data
were available for chloroform including data from the EAD, WERLป and WAO
databases. These data are presented in Table 4-8. Technologies for which data are
available include AL, AS, AS+Fil, AirS, CAC, CAC+AirS, chemical oxidation (ChQx),
GAG, PACTฎ, RO, SCOx, SS, TF, and WOX. The treatment performance data
represent bench-scale, pilot-scale, and full-scale data. The resulting effluent
concentrations ranged from 0.13 ppb to 16,000 ppb.
MtM/027 .
1031-01.mlm 4-12
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The treatment performance data available from the HAD database were
used in determining the BDAT treatment standard for this constituent for the following
reasons:
(1) The EAD data represent treatment performance data from the
OCPSF sampling episodes. The data collected by EAD include
long-term sampling of several industries. These data are therefore a
good reflection of the total organic chemical industry and
adequately represent a wastewater containing chloroform. . < .
(2) The EAD data were carefully screened prior to inclusion in the
OCPSF database. These data were used in determining a
promulgated EAD effluent limitation.
(3) A promulgated EAD limitation represents data that have undergone
both EPA and industry review and acceptance.
The Agency is establishing steam stripping (SS) as BDAT for chloroform.
The BDAT treatment standard was calculated using the EAD median long-term average
of 12.2 ppb and the EAD Option 1 variability factor. The calculation of the resulting
BDAT treatment standard for chloroform (0.046 ppm) is described in Section 4.6 and is
shown in Table 4-10. .
4.4 Identification of Best Demonstrated Available Technology (BDAT)
This section presents the Agency's rationale for determining the best
demonstrated available technology (BDAT) for nonwastewater and wastewater forms of
K117, K118, and K136. . .
EPA determines the best demonstrated available technology based on a
thorough review of all of the treatment performance data available for the waste of
concern or wastes judged to be similar. Following the identification of "best," the Agency
determines whether the technology is "available." An available treatment technology is
one that (1) is not a proprietary or patented process that cannot be purchased or
MLM/027 ' . '
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licensed from the proprietor (i.e., it must be commercially available), and (2)
substantially diminishes the toxicify of the waste or substantially reduces the likelihood of
migration of hazardous constituents from the waste.
4.4.1 Nonwastewaters '' .
The treatment performance data that were evaluated to determine BDAT
treatment standards for the nonwastewater forms of K117, K118, and K136 are presented
in Section 43. The treatment performance data were screened to determine:
-' ' - ' .
Whether the data represent operation of a well-designed and well-
operated treatment system; \
Whether sufficient analytical quality assurance/quality control mea-
sures, were employed to ensure the accuracy of the data; and
Whether the appropriate measure of performance was used to assess
the performance of the particular treatment technology.
EPA has identified incineration as demonstrated for the treatment of
organic constituents in nonwastewater forms of K117, K118, and K136. EPA has
treatment performance data from the incineration of constituents included in each of
these wastes.
All of the incineration data included in Section 4.3 represent BDAT for
wastes included in previous rulemakings and therefore have already met the above
conditions. Thus, incineration is the "best" technology for treating organic nonwastewater
forms of these wastes in each group of wastes.
Incineration, identified as the "best" technology for these organic wastes, is
commercially available. Treatment performance data included in Section 4.3 show
substantial treatment by incineration for waste -constituents of concern and other similar
MLM/027
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constituents. Because incineration is applicable, demonstrated, and "available," it is :
therefore being established as BDAT for treatment of .the organic constituents in
nonwastewater forms of K117, K118, and K136.
x '
4.4.2 Wastewaters .
The treatment performance data that were evaluated to determine BDAT
treatment standards for wastewater forms of K117, K118, and K136 are presented in
Section 4.3. The Agency believes that data from the EAD and BDAT programs should
be used preferentially over data from other sources whenever possible. The EAD
database represents a comprehensive source of wastewater treatment performance data
and usually represents longer term sampling with a greater number of sample sets than
data in other wastewater treatment performance databases. Data generated as part of
the BDAT program represent controlled tests and follow EPA protocols for sampling
and analysis procedures. . ,
The following is an outline of the hierarchy used to determine the best
demonstrated technology, for wastewater constituents included in this document. All data
used in determining BDAT for a constituent came from the highest level in the hierarchy
in which they were available for a particular constituent.
(1) EAD treatment performance data that were used to promulgate an
EAD effluent limitation standard. The data representing EAD
Option I were used in all cases (43).
(2) Agency-sponsored BDAT wastewater treatment test data.
(3) Industry-submitted multi-source leachate treatment performance
data, where the data showed substantial treatment.
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(4) Other available treatment performance data. Evaluation of these
data was based on:
(a) The treatment technology for which data were available;
(b) Whether the data represented full-, pilot-, or bench-scale
treatment;
(c) The concentration of the constituent of interest in the ,
influent to treatment;
(d) The average concentration of the constituent of interest in
the effluent from treatment; and
(e) The removal efficiency of the treatment technology.
Full-scale treatment performance data with an influent
concentration range greater than 100 ppb were preferred over pilot-,
bencn-scale, or data with a low (i.e., 0-100 ppb) influent
concentration range. If several sets of data met these criteria (i.e.,
full-scale available technologies with high influent concentrations),
they were compared by examination of their average effluent values
and percent removals to determine the data set(s) with the lowest
effluent values and the technology with the highest percent removal.
The demonstrated technologies identified in Section 4.2.2 and determined
to be best for each constituent as identified in Section 4.3 are all commercially available.
In addition, treatment performance data included in Section 4.3 show substantial
treatment of the constituent for which the technology was selected as BDAT. Therefore,
the technologies selected as best and demonstrated for each constituent are also
/
considered to be available and are being promulgated as BDAT.
4.5
Selection of Regulated Constituents
The Agency has developed a list of hazardous constituents (the BDAT
Constituent List, presented in EPA's Methodology for Developing BDAT Treatment
Standards (1)) from which constituents are selected for regulation. EPA may revise this
list as additional data and information become available. The list is divided into the
following categories: volatile organics, semivolatile organics, metals, inorganics other
than metals, organochlorine pesticides, phenoxyacetic acid herbicides, organophosphorus
MLM/027
1031-01 .mim
4-16
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insecticides, polycblorinated biphenyls (PCBs), and dioxins and furans. This section
presents EPA's methodology and rationale for selection of constituents for regulation in
nonwastewater and wastewater forms of K117, K118, and K136.
Generally, constituents selected for regulation must satisfy the following
criteria:
1. The constituent must be on the BDAT List of constituents.
Presence on the BDAT List means that EPA-approved methods
exist for analysis of the constituent in treated waste matrices.
2. The constituent must be present in. or be suspected of being present
in. ttie untreated waste. For example, analytical difficulties may
prevent a constituent from being identified in the untreated, waste,
but its identification in a treatment residual may lead the Agency to
conclude that it is present in the untreated waste.
From a group of constituents that may be selected for regulation because
they meet the above criteria, EPA may select a subset of constituents that represents the
broader group. For example, from a group of constituents that react similarly to
treatment, the Agency may select for regulation those constituents that (1) are the most
difficult to treat, based on waste characteristics affecting treatment performance; (2) are
representative of other constituents in the waste, based on structural similarities; or (3)
are present in the untreated waste in the highest concentrations. Selecting a subset of
constituents for regulation facilitates implementation of industry compliance and of
EPA's enforcement program.
The Agency initially considered all constituents on the BDAT list for
regulation in K117, K118, and K136. Table 4-1 summarizes available waste
characterization data for constituents in K117, K118, and K136 and presents ranges of
concentrations for constituents detected in the waste. Constituents for which analyses '
were not performed are identified by "NA" (not analyzed). ,
MLM/027
HBl-Ol-mlm , 4-17
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Three BDAT List constituents have been identified in K117, K118, and
K136; namely, ethylene dibromide, bromomethane, and chloroform. The Agency has
selected these three BDAT List constituents for regulation in nonwastewater and
wastewater forms of K117, K118,~ and K136.
4.6
Calculation of BDAT Treatment Standards
The Agency bases concentration-based treatment standards on the
performance of well-designed and well-operated treatment systems. These standards
account for analytical limitations in available treatment performance data and for,.
variabilities related to treatment, sampling, and analytical techniques and procedures.
This section presents the treatment standards calculated for the constituents selected for
regulation in Section 4.5 using the available treatment performance data discussed in.
Section 4.3.
4.6.1
Nonwastewaters
Treatment standards for regulated constituents in nonwastewater forms of
K117, K118, and K136 were calculated based on data compiled from the BDAT
incineration database for incinerator ash. Specifically, treatment performance data from
the Agency's ethylene dibromide incineration test were used to calculate BDAT
treatment standards for ethylene dibromide and bromomethane in nonwastewater forms
, s ' ,
of K117, K118, and K136. The treatment standard for bromomethane was based on a
transfer of treatment performance data from ethylene dibromide. Treatment
performance data from two incinerator tests were used to calculate the BDAT treatment
standard for chloroform in nonwastewater forms of K117, K118, and K136.
The Agency considered the detection limits from each of these tests and
determined which were the most representative for each waste constituent. The Agency
MLM/027
1031-01.rate
4-18
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selected the highest detection'limit for each regulated constituent from the incineration
tests to account for the anticipated variability in untreated wastes.
Concentration-based treatment standards for regulated waste constituents
were calculated by multiplying the constituent detection limit in ash by an accuracy
correction factor and a variability factor. The following subsections discuss these three
components of the treatment standard calculation. The calculations of treatment
standards for regulated constituents in nonwastewater forms of K117, K118, and K136
are summarized in Table 4-9. ,
Detection Limits
The detection limits for ethylene dibromide, bromomethane, and
chloroform in ash were used to calculate the treatment standards for nonwastewater
forms of K117, K118, and K136. The highest detection limit for each of these
constituents from the 11 incineration tests was used.
, i , .
Accuracy Correction Factors
The detection limits used to calculate treatment standards were corrected
using matrix spike recovery data from the same test from which the detection limits were
taken to account for analytical interferences associated with the chemical matrices of the
samples. Detection limits were corrected for accuracy as follows:
A matrix spike recovery was determined for each regulated constitu-
ent. In cases where a matrix spike was not performed for a
regulated constituent in the treatment test from which the detection
limit was taken, the matrix spike recovery from a similar constituent
from that treatment test was transferred to the constituent.
An accuracy correction factor was determined for each of the above
constituents by dividing 100 by the matrix spike recovery (expressed
as a percentage) for that constituent. . ;
MLMrtC? .','-.
1031-01.mlm 4-19
-------
Detection limits for each of the regulated constituents were
corrected by multiplying the detection limit for each constituent by
its corresponding accuracy correction factor. The accuracy corrected
detection limit for each regulated constituent is shown on Table 4-9.
Matrix spike recoveries used to adjust detection limits for the regulated
constituents in nonwastewater forms of Kl 17, K118, and K136 are included in Appendix
B. Duplicate matrix spikes were performed for some waste constituents. If a duplicate
matrix spike was performed for a constituent, the matrix spike recovery used for that
constituent was the lower of the two values between the first matrix spike and the
duplicate spike. Matrix spike recoveries of less than 20% are not acceptable and were
not used to correct detection limits. Matrix spike recoveries greater than 100% were
considered to be 100% for the purpose of this calculation so that the data were not
adjusted to concentrations below the detection limits. In cases where the detection limit
came from more than one test, the lowest matrix spike .recovery among the tests was
used.
Variability Factors -
The variability factor accounts for the variability inherent in treatment
system performance, treatment residual collection, and analysis of the treated waste
samples. Variability factors could not be calculated for regulated constituents that were
not detected in the incinerator ash residuals. Therefore, a variability factor of 2.8 was
used to account for this inherent variability, as discussed in the Methodology for
Developing BOAT Treatment Standards (1).
4.62
Wastewaters
Treatment standards for wastewater forms of K117, K118 and K136 were
calculated based on data compiled from EPA's wastewater treatment performance
MLM/027
1031-01.rolm
4-20
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database. Specifically, treatment performance data from air and steam stripping and
biological treatment were used. .
Concentration-based treatment standards regulated for waste constituents
were, calculated by multiplying the constituent effluent concentration (as presented in
Section 4.3) by an accuracy correction factor and a variability factor. The following
subsections discuss these three components of the treatment standard calculation. The
calculation of treatment standards for regulated constituents in wastewater forms of :
K117, K118, and K136 are summarized in Table 4-10.
Constituent Effluent Concentration
The effluent concentration obtained using the BDAT for each regulated
constituent was determined as discussed in Section 4.3.2. The treatment performance
data for each regulated constituent are presented in Tables 4-6, 4-7, and 4-8 at the end
* ' ' i
of this section.
Accuracy Correction Factors
Accuracy correction factors account for analytical interferences associated
with the chemical matrices of the samples. EAD variability factors were used (or
transferred for use) in the calculations of treatment standards for regulated constituents
in wastewater forms of K117, K118, and K136. Based on the fact that EAD variability
factors were originally calculated to represent performance, analytical, and matrix
variations, accuracy correction factors were not used.
- . i '
Variability Factors .
',"
A variability factor (VF) accounts for the variability inherent in the
treatment system performance, treatment residual collection, and analysis of the treated
' '
MLM/027 . '
1031-01 .mlm 4-21
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waste samples. Variability factors are calculated as described in EPA's Methodology for
Developing BOAT Treatment Standards (1). However, original effluent data points
were not available for ethylene dibromide and bromomethane in K117, K118, and K136
since WERL effluent data were used to determine treatment standards and these data
were used to determine treatment standards and these data were presented as averages
in me WERL database. Therefore, it was not possible to calculate an individual
variability factor for these constituents; instead, an average variability factor was used.
The average variability factors were generated from the EAD variability factors and are
specific to the type of constituent under consideration (i.e., volatile organic, acid
extractable semivolatile organic, etc.). The calculation of average variability factors is
. discussed in Appendix C.
MLM/027
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Table 4-1
i
Summary of Available Characterization Data
for K117, K118, K136
vi^rBD^
Ethylene dibromide
Chloroform
Bromomethane
Other Constituents
1, 1,2-Tribromomethane
Bromoethane
Bromochloroethane
i .
Bis(2-bromo)ethyl ether
^^^^yiax^iL:faj^1^xi&^^^^^,
0.01-0.22
0-0.0001
NA '
,
NA
0-0.007
0.002-0.0002
NA
lljiKllsfill
1-75
NA
0-0.0004
Q-0.02
. NA
0-0.01
0-0.06
CBI
CBI
CBI
CBI
CBI
CBI
CBI
CBI - Confidential Business Information.
NA = Not analyzed.
MLM/027
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4-23
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Table 4-2
Treatment Performance Data Collected by EPA
from Incineration of Ethylene Dibromide (EDB)
at Rollins Environmental Services, Inc. (Texas) - Incineration
; BDAT List Constituent
Sample
^SeiNoV:
Untreated Waste
Detection
Concentration
Incineration Ash:
Detection
Concentration
1,2-Dibromoethane
(Ethylene dibromide)
25,000
119,000
25,000
92,000
25,000
102,000
<5
<5
<5
Source: EDB Test Bum Progress Emissions Test Results (13).
MLM/027
1031-01. into
4-24
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Table 4-3
Design Parameters for the Incineration System at Rollins
Environmental Services, Inc. (Texas)
Physical Design Parameter
Value or Description
ROTARY KILN:
Manufacturer . '
Height
Inside diameter
Length
Volume
Width
Materials of construction:
Outer shell
Front wall
LODDBY FURNACE:
Manufacturer
Height
Inside diameter
Length
Volume .
Width
AFTERBURNER:
Manufacturer .
Height
Inside diameter
Length
Volume
Width
Materials of construction:
Outer shell
Ceiling
NR
9.5 feet
32.8 feet
2^24 cubic feet
NR
1.18-inch steel plate with 9-inch refractory lining.
0.59-inch steel plate with castable refractory and refractory
brick lining.
NR'
6.25 feet
14 feet
429 cubic feet
NR
135 feet
NR
49 feet
8,300 cubic feet
125 feet
13-inch refractory bricks supported by stainless steel clips
attached to steel beams.
6-inch bricks ,
NR - Not Reported. , . . '
*This equipment was designed for RES(TX), Inc., and therefore does not carry a model number.
Source: EDB Test Burn Progress Emissions Test Results (13)
MLM/027
1031-01.mini
4-25
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Table 4-4
Wastes Tested by Incineration
;::Yg:||;->V;^:y:-'lf
..Jfral^C;
iv^nibcTy;
1
. 2
3
4
5
6
7
8
9
10
11
12
13
14
g^^t^^xlfe^eijl
KOOl-Pentachlorophenol
KOOl-Creosote
K011, K013, K014
K019
K024
K037
K048, K051
K087
K101
K102
F024
K015
D014, D016, P059V
U127*, U1921
U141ป, U028', P020',
U122*. U226\ U239V
0080*, U220*, U166*,
U161', U188*
-' -''-''','.;.{" . -. ,- '',', ' "':.'"".".:' - "-,"!-,"
!.'-:-;-'.""" p" ;' ',- ' : .''-'-'-: -'- .::'''-.
v^Te^roiogj^
-I^'"'tftfe4i-H:l
:.;,;-;;!'. y :, -:_ ;-.. ..,.. . ;. - ''
Rotary Kiln
Rotary Kiln
Rotary Kiln
Rotary Kiln
Rotary Kiln,
Rotary Kiln
Fluidized-Bed
Rotary Kiln
Rotary Kiln
Rotary Kiln
Rotary Kiln
Liquid
Injection
Rotary Kiln
Rotary Kiln
Background
l^tttMittenit^U:
^R^Breni^^:
^^vjaSijSas^
18
18
17
19
20
21
22
23
24
25
26
27
NA
NA
W^M]sMiil
ifc^itoeenng.; \
g||;l^rtS| 1
SIR^rciic6^ ^
?!->^S^ฃ *.' jS'S'ii : f '*'J~: : ' ''-.
:?-i:s|j>iunipers;tfwvi!-
28
29
30
31
32
33
x 34, 35
36
'37
38
39
40
41 ,
42
NA Not applicable.
Commercial chemical products were used in these incineration tests as surrogates for
these wastes. .
MLMAK27
1031-01.mlm
4-26
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Table 4-5
Summary of Detection Limits for Chloroform
in Ash Samples from the Fourteen EPA Incineration Tests*
S:-:3^0j^i^iNSi^SSifrWSSt
1
.". * . " 2 . - , .
' ' ' ' 3
4
5
6
7
8
9
10
,11
13
14 ,
2 '
10
2'
2b
2
2 ,
'. 2 . ' ,
0.025
0.005
1.5
0.005
0.01
0.01
Chloroform detected in scrubber water.
^Chloroform detected in untreated waste.
'Incinerator ash samples were not collected for Test 12.
."Corresponding waste codes are indicated in Table 4-4.
MLM/02?
1031-01 .mlm
4-27
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5.0 EBDC PRODUCTION WASTES (K123, K124, K125, K126)
This section describes the Agency's approach in establishing BOAT
treatment standards for K123, K124, K125, and K126.. This includes a description of the
industry 'that would be affected by the land disposal restrictions for
ethylenebisdithiocarbamic acid (EBDC) production wastes, a presentation of available
waste characterization data, and a discussion of the Agency's rationale in determining
BOAT treatment standards for these wastes.
Under 40 CFR 261.32 (hazardous wastes from specific sources), waste
identified as K123 is listed as process wastewater (including supernates, filtrates, and
washwaters) from the production of EBDC and its salts; K124 is listed as reactor vent
scrubber water from the production of EBDC and its salts; K125 is listed as purification
solids (including filtration, evaporation, and centrifugation solids) from the production of
EBDC and its salts; and K126 is listed as baghouse dust and floor sweepings in milling
and packaging operations from the production of EBDC and its salts.
5.1 Industry Affected and Waste Characterization
5.1.1 Industry Affected and Process Description
To the Agency's knowledge, two domestic facilities produce and purify
EBDC and its salts and may potentially generate K123, K124, K125, and K126. These
facilities are Alco Chemicals in Chattanooga, TN, and Vinings Industries in Marietta,
GA. Both faculties are located in EPA Region IV. These facilities were identified using
the 1990 SRI Directory of Chemical Producers (3) and data collected during EPA's
listing efforts for K123, K124, K125, and K126 (15).
EBDC is used mainly as a fungicide. Nabam, the sodium salt of EBDC, is
primarily used as an algicide in rice; it is also used as an intermediate in the synthesis of
other products. Zineb, the zinc salt of EBDC, is used against downy mildews, rusts, and
MLM/027 -
1031-01.mlra .5-1
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scabs; it is one of the most widely used fungicides of this group. Maneb, the manganese
salt of EBDC, is widely used as a foliar fungicide for control of downy mildews on hops
and vine, against downy mildews, rust, and scabs on fruit, vegetables, maize, rice, cereals,
tobacco, and as a seed dressing and soil treatment. Mancozeb, a combination of maneb
and zineb, is used as a foliar .fungicide with additional acaricidal action and as a seed
treatment. Polyram (a zineb-ammonia adduct) has the additional property of having a
relatively long residue effect. A simplified flow diagram illustrating the manufacturing
process generating EBDC is presented in Figure 5-1.
Nabam is typically produced by reacting ethylenediamine with carbon
disulfide in the presence of sodium hydroxide. Nabam is soluble in water and may be
sold as an aqueous solution or used as an intermediate in the production of other
products.
Maneb is produced by adding the chloride or sulfate salt of manganese to a
solution of nabam or to a solution of the ammonium salt of EBDC (formed by the
addition of ammonium hydroxide to ethylene diamine and carbon disulfide). Likewise,
zineb is produced by reacting the chloride or sulfate salt of zinc with nabam or with the
ammonium salt of EBDC.
The reaction for these processes is as follows:
NaOH
MLM/027
1031-01.mlm
T!
Chloride or Sutfate
Salt of Manganese
N-CS-NB+
N-C-S-Na*
H S
Nabam
Chloride or Sulfate
Salt of Zinc
5-2
f
N-C-S-Mn+
N-C-S-MH+
H S
Zineb
H
N-C-S-Zn*
N-C-S-ZQ+
II
H S
Maneb
-------
s
Both maneb and zineb are insoluble and may be recovered from the aqueous solution by
. filtration or centrifugation. An insoluble metal precipitate may also be formed by using
hydrogen peroxide as an oxidant to produce insoluble thiuramsulfides from the soluble
sodium or ammonium EBDC salts. Polyram, for example, is produced by blending zineb
with ethylene thiuramonosulfide. These solid precipitates (e.g., maneb, polyram) are
typically dried and formulated with clay and/or surfactants to produce the final product.
The production of EBDC generates both aqueous and solid wastes. K123
includes a collection of aqueous wastes which are formed from any of the following
operations: (1) separation of the aqueous supernatant generated after precipitation of
the insoluble EBDC product (formed as either a transition metal salt and/or
tbiuramsulfide); (2) concentration of this aqueous supernatant in the evaporator,
resulting in the formation of an aqueous waste; and (3) washing of the product, also
producing process wastewater. K124 is formed from the passage of reactor vent gases
through a scrubber, typically generating a caustic aqueous waste. K125 consists of the
purification solids formed from the evaporation of water from the mother liquor or from
the filtration and centrifugation of the EBDC salt during wastewater treatment. K126
consists of dust and floor sweepings from milling and packaging operations.
'. . / '
5.12 Waste Characterization
'.' ' . (
Table 5-1 presents a summary of the available characterization data for
(. t
K123, K124, K125, and K126. Data are presented for BDAT List' constituents and other
compounds that are believed to be present or have been detected in K123, K124, K125,
and K126.
i '-.*'*
5.2 Applicable and Demonstrated Treatment Technologies
This section identifies the technologies that are applicable for the
treatment of nohwastewater and wastewater forms of K123, K124, K125, and K126 and
MLM/027 . .
1031-01. mlm 5-3
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determines which of the applicable technologies can be considered demonstrated for the
purpose of establishing BOAT.
To be applicable, a technology must theoretically be usable to treat the
waste in question or to treat a waste that is similar, in terms of parameters that affect
treatment selection. (Detailed descriptions of technologies that are applicable to listed
hazardous wastes are provided in EPA's Treatment Technology Background Document
(5).) To be demonstrated, a technology must be employed in full-scale operation for
treatment of the waste in question or of .a similar waste. Technologies available only at
pilot-scale or bench-scale operations are not considered in identifying demonstrated
technologies.
52.1 Applicable Treatment Technologies
Nonwastewaters
Since nonwastewater forms of K123, K124, K125, and K126 generally
contain hazardous organic constituents at treatable concentrations, applicable treatment
technologies include those that destroy or reduce the total amount of various organic
compounds in the waste. The Agency has identified the following treatment technologies
as applicable for these wastes:
Chemical oxidation;
Critical fluid extraction followed by incineration of the contaminated
solvents;
Distillation;
Incineration (fluidized-bed, rotary kiln, and liquid injection);
MLM/027
1031-01 .into
5-4
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Solvent extraction followed by incineration or recycle of the extract;
and . . - .
Wet air oxidation.
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A.
Wastewaters '
; . (
Since wastewater forms of K123, K124, K125, and K126 may contain
hazardous organic constituents at treatable concentrations, applicable treatment
technologies include those that destroy or reduce the total amount of various organic
compounds in the waste. Therefore, the Agency has identified the following treatment
technologies as potentially applicable for treatment of these wastes:
"V
" * . . - '
Biological treatment; ,
* Carbon adsorption;
Chemical oxidation;
Distillation;
Incineration (fluidized-bed, rotary kiln, and liquid injection);
\
Solvent extraction followed by incineration or recycle of the extract;
Steam stripping; and
Wet air oxidation.
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and have been described in more detail in Appendix A.
MlM/027
1031-01.mlm 5-5
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The concentrations and type(s) of constituents present in the waste
generally determine which technology is most applicable. Carbon adsorption, for
example, is often used as a polishing step following primary treatment by biological
treatment, solvent extraction, or wet air oxidation. Typically, carbon adsorption is
applicable for treatment of wastewaters containing total organic constituent
concentrations of less than 0.1%. Wet air oxidation, biological treatment, and solvent
extraction (followed by incineration or recycle of the extract) are applicable for
treatment of wastewaters containing organic constituents at concentrations of up to 1%.
522
Demonstrated Treatment Technologies
This section identifies those applicable treatment technologies that EPA
considers to be demonstrated for the purpose of establishing BOAT for K123, K124,.
K125, and K126.
\
Nonwastewaters
The Agency believes that incineration is a demonstrated technology for the
treatment of nonwastewater forms of K123, K124, K125, and K126. For the land
disposal restrictions program, the Agency has tested rotary kiln incineration on a full-
scale operational basis for many organic waste constituents including:
MLM/027
1031-01.mlm
Aromatic and other Hydrocarbon Wastes
Toluene
Brominated Organic JVastes
1,2-Dibromoethane (ethylene dibromide)
Halogenated Aliphatic Wastes
i ป
Bis(2-cbloroethyl)ether
1,1-Dichloroethane
5-6
-------
1,1,1-Trichloroethane
1,2,4-Trichlorobenzene
Halogenated Pesticide and Chlorobenzene Wastes
Hexachlorocyclopentadiene
Chlordane
Heptachlor
Chlorobenzene . .
1,2-Dichlorobenzene . . .
1,4-Dichlorobenzene
Hexachlorobenzene
Pentachlorobenzene
Pentachloronitrobenzene
1,2,4,5-Tetrachlorobenzene
2,4-Dichlorophenoxyacetic acid
Methoxychlor
Hexachlorobutadiene
Oxygenated Hydrocarbon and Heterocyclic U and P Wastes
Acetone
Ethyl acetate
Methyl ethyl ketone. ,
Methyl isobutyl ketone
1,4-Naphthoquinone
Wastes of a Phannaceutical Nature ' .
Isosafrole .
Phenoh'c Wastes \
2-sec-Butyl-4,6-dinitrophenol (Dinoseb)
o-Cresol
p-Cresol ,
Phenol / ,
Polynuclear Aromatic Wastes ,
Benzo(a)pyrene
Chiysene
Indeno(l,2,3-cd)pyrene ซ ' '
Benz(a)anthracene
MLM/027 . ป
1031-Ol.mlm 5-7
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Fluoranthene
Naphthalene
Organo-Nitrogen Compoi
Acetonitrile
Acrylonitrile
Aniline
Nitrobenzene
Pyridine ^ ,
Miscellaneous Halogenated Organic Wastes
Chloromethane
Dichlorodifluoromethane
Vinyl chloride
Bis(2-chloroethyl)ether
3,3'-Dichlorobenzidine
Pronamide
The Agency believes that because incineration is demonstrated for the
treatment of many organic waste constituents, including those which are structurally
similar to the constituents found in K123, K124, K125, and K126, it is also demonstrated
for these wastes. The Agency is not aware of any facilities that treat these wastes by fuel
substitution and the Agency believes that fuel substitution is in appropriate for wastes
such as K123, K124, K125, and K126 that contain many constituents with molecular
components other than carbon, hydrogen, and oxygen. Thus, the Agency believes that
fuel substitution is not a demonstrated technology for these wastes.
From review of the 1986 TSDR Survey (6) and the USEPA's Water
Engineering Research Laboratory (WERL) database (7), the Agency has determined
that some facilities also treat nonwastewater forms of aromatic and polynuclear aromatic
wastes or wastes judged to be similar to K123, K124, K125, and K126 using wet air
oxidation, chemical oxidation, and distillation on a full-scale operational basis. .
Therefore, EPA considers these technologies to be demonstrated for aromatic and
polynuclear aromatic wastes such as K123, K124, K125, and K126.
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The Agency is not aware of any facilities that treat nonwastewater forms of
these wastes or wastes judged to be similar on a full-scale operational basis using solvent
i, '
extraction (followed by incineration or recycle of the extract) or critical fluid extraction.
(followed by incineration of the contaminated solvents); therefore, EPA believes that
these technologies are not currently demonstrated for these wastes.
. .-.. ' ' i ^
Wastewaters , ,
~>
The following technologies have been identified as demonstrated for
treatment of the following types of organic wastes (organized by chemical structure):
Aromatic and Other Hydrocarbon Wastes
Incineration -
Biological Treatment
Carbon Adsorption
i Wet Air Oxidation
Chemical Oxidation
Steam Stripping .
i
Brpminated OrganicJWastes '
Biological Treatment
Halogenated Aliphatic Wastes '
s *
Incineration
Wet Air Oxidation
Chemical Oxidation
Biological Treatment .
- ' Carbon Adsorption
Solvent Extraction
Distillation ,
Steam Stripping
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Halogenated Pesticide and Chlorobenzene Wastes
Biological Treatment
Wet Air Oxidation
Steam Stripping
Carbon Adsorption
Oxygenated Hydrocarbon and Heterocyclic Wastes
Biological Treatment
Carbon Adsorption
Steam Stripping
Wet Air Oxidation
Wastes of a Pharmaceutical Nature
Wet Air Oxidation
Phenolic Wastes
Wet Air Oxidation
Carbon Adsorption
Biological Treatment
Chemical Oxidation
Solvent Extraction
Steam Stripping
Polynuclear Aromatic Wastes
Incineration
Biological Treatment
Carbon Adsorption
Wet Air Oxidation
Chemical Oxidation
Steam Stripping
Organo-Nitrogen Compound Wastes
Biological Treatment
Carbon Adsorption
Steam Stripping
Wet Air Oxidation
Solvent Extraction
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Miscellaneous Halogenated Organic Wastes , ,
Biological Treatment
Steam Stripping
Carbon Adsorption
Solvent Extraction followed by Steam Stripping followed by Carbon
Adsorption
Chemical Oxidation .
Wet Air Oxidation '
The Agency is not aware of any facilities that incinerate wastewater forms
of some of the waste groups. However, commenters responding to the Second Third
proposed rule indicated that they were incinerating many wastewaters and that they did
not want to be precluded from doing so. In addition, the Agency has conducted
incineration tests which demonstrate that incineration is an effective treatment
technology for a wide variety of organic compounds, including halogenated and
nonhalogenated organic compounds and pesticides. EPA's evidence that incineration
constitutes significant treatment for these compounds is based on these compounds being
quantified at or near their detection limits in the ash and scrubber water from these
tests. The chemical structures and physical properties of these compounds are similar to
those of the compounds in K123, K124, K12S, and K126. Since incineration is
demonstrated for treatment of organic waste constituents in nonwastewater forms of
K123, K124, K125, and K126 as discussed above, the Agency believes incineration is also
demonstrated for these waste constituents in wastewater forms of these wastes.
' *
Therefore, the Agency also identifies incineration as a demonstrated technology for
wastewater forms of K123, K124, K125, and K126.
-' > . : ., ' . " - . '
Based on engineering judgment, the Agency considers the following
technologies to be demonstrated for wastewater forms of K123, K124, K125, and K126:
Biological treatment; >
Carbon adsorption;
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Chemical oxidation;
Distillation; -...
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
Steam stripping; and
i
Wet air oxidation. .
Identification of Best Demonstrated Available Technology (BOAT)
. This section presents the Agency's rationale for determining the best
demonstrated available technology (BDAT) for nonwastewater and wastewater forms of
K123, K124, K125, and K126. The best demonstrated available technology is determined
based on a thorough review of all the treatment data available on the waste of concern
or wastes judged to be similar.
For a treatment technology to be identified as "best," the treatment
performance data are screened to determine:
Whether the data represent operation of a well-designed and well-
operated treatment system;
Whether sufficient analytical quality assurance/quality control mea-
sures were employed to ensure the accuracy of the data; and
Whether the appropriate measure of performance was used to assess
the performance of the particular treatment technology.
Following the identification of "best," the Agency determines whether the
technology is "available." An available treatment technology is one that (1) is not a
, j '
proprietary or patented process that cannot be purchased or licensed from the proprietor
(i.e., it must be commercially available), and (2) substantially diminishes the toxicity of
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the waste or substantially reduces the likelihood of migration of hazardous constituents
from the waste.
53.1 Nonwastewaters
As discussed previously, incineration is a demonstrated treatment
technology for nonwastewater forms of K123, K124, K125, and K126.
The Agency obtained incinerator ash analytical data from the 14 BOAT
treatment tests conducted at what EPA considers to be well-designed and well-operated
hazardous waste incinerators. Strict quality assurance/quality control measures were
employed to ensure the accuracy of the data, and since EPA was collecting these data to
identify and characterize BOAT treatment technologies, appropriate performance
x
variables, namely, U and P waste constituent concentrations in treated and untreated
waste, were measured. The Agency has determined that due to the high temperatures,
efficient mixing, and consistent residence times used at commercial hazardous waste
incinerators, incineration processes are relatively indiscriminate in the destruction of
organics. Therefore, .based on the treatment performance data available, the Agency
considers incineration to be the "best" technology for the treatment of nonwastewater
forms of K123, K124, K125, and K126.
i
Incineration is a commercially available technology. Additionally,
x '
treatment performance data from the 14 BDAT incineration treatment tests show
substantial treatment by incineration for organic waste constituents in nonwastewater
forms of unquantifiable U wastes; therefore, incineration is considered an "available"
treatment technology for K123, K124, K125, and K126 for the purpose of establishing
BDAT. .
Incineration has been determined to be BDAT for all of the
nonwastewater organic constituents that cannot be quantified in hazardous waste
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matrices using current analytical methods, including those contained in nonwastewater
forms of K123, K124, K125, and K126, based on similarities in chemical and physical
properties.
532
Wastewaters
As discussed previously, incineration, wet air oxidation, biological
treatment, carbon adsorption, solvent extraction followed by incineration or recycle of
the extract, chemical oxidation, distillation, and steam stripping are all demonstrated
technologies for the treatment of wastewater forms of K123, K124, K125, and K126.
/ - -
tile Agency believes that the best technologies for treating wastewater
forms of K123, K124, K125, and K126 are those technologies that destroy the
constituents found in these wastes. Steam stripping, solvent extraction followed by
incineration or recycle of the extract, and distillation are technologies that remove the
constituents from the wastewater stream; however, the waste constituents are not
destroyed but are processed into a more concentrated waste stream, i.e., the condensate,
extract, or bottom stream (or still bottoms). These waste streams typically require
further treatment before disposal. As a result, the Agency does not consider steam
stripping, solvent extraction, or distillation to be the best technologies for treating
wastewater forms of the wastes covered in this subsection. The Agency realizes that
biodegradation may provide effective treatment for these wastes. Nevertheless, since
EPA has negligible data for the performance of biological treatment with similar wastes,
EPA is not designating biological treatment as an acceptable treatment method for these
wastes. .
Because a technology removes waste constituents from the waste stream to
be land disposed, but does not destroy them, does not necessarily preclude it from being
considered "best". As discussed below, carbon adsorption is being established as part of
the. chemical oxidation treatment train. The purpose of the carbon adsorption step as
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A..-
part of this treatment train is to remove organic by-products resulting from the oxidation
of waste constituents. Carbon adsorption was selected for this removal step over steam
/ * ' ' .
stripping, solvent extraction, and distillation because the Agency believes that carbon
. adsorption is the most appropriate removal technology for the widest range of organic
compounds likely to be present in the oxidation effluent stream.
Chemical oxidation provides treatment by oxidizing the organic constituents
found in these wastes. However, to ensure effective treatment of these wastes, chemical
oxidation treatment should include a final carbon adsorption or biological treatment step.
Since these constituents are not quantifiable, it is not possible to accurately judge the
effectiveness of the chemical oxidation step. Therefore, the Agency believes that it is
sound engineering judgement to include a final step of carbon adsorption or biological
treatment following oxidation. This step will ensure that these organic constituents and
the oxidation by-products are removed from the wastewater matrix. (It should be noted
that spent carbon from the treatment of these wastewaters would become a
nonwastewater form of this waste (54 Federal Register 26630-1. June 23, 1989) and thus
would be required to be incinerated to meet the applicable treatment standard.)
In cases where the Agency has treatment performance data for both
wastewater treatment processes and incineration (as measured by total constituent
concentration in scrubber water), the Agency prefers to establish treatment standards
based on the wastewater treatment processes. However, the Agency has determined that
wastewaters are also treated by incineration and does not intend to preclude industry
from continuing this practice. Therefore, EPA is also identifying incineration as a best
demonstrated technology for wastewater forms of these wastes.
Treatment performance data included in Volume A of the F039
Background Document (16) indicated substantial treatment of organic constituents by
chemical oxidation, carbon adsorption, and biological treatment. In addition, these
technologies are commercially available. Therefore, these technologies are considered to
". /
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be "available" treatment technologies for the purpose of establishing BDAT. As
discussed in Section 5.3.1, incineration is also an "available" treatment technology for
treatment of these wastes. ,
Based on the above discussion, EPA is promulgating the following methods
of treatment as treatment standards for organic constituents that are not quantifiable in
wastewater forms of K123, K124, K125, and K126: (1) incineration, (2) chemical
oxidation followed by carbon adsorption, and (3) chemical oxidation followed by
biological treatment. The Agency believes that these standards will ensure effective .
treatment (removal and destruction) of the constituents of concern.
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Table 5-1
Summary of Available Characterization Data
for K123, K124, KI25, and K126
BDAT List Constituents
Zinc
:.S:b^|;c^itip^l|f
ithylene tbiourea
Ethylenebisisothiocyanate
Sodium hydroxide
ithylenebisdithiocarbamate
;f;|iflp||^^
:-%;ja2$'^
NA
:::;S;kuS:ง0
NA
V;li;งi2l;fl-:;
CBI
mfftm:-
. NA
:^:'r^oH^;:%M^^^^
.^:y::v;^^
CBI
CBI
NA . -
NA
CBI
NA
<50
NA'
CBI
NA
NA
CBI
CBI
CBI
NA
NA
CBI - Confidential Business Information
NA - Not analyzed
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a
a
e
I
.> ฃ
If
11
a
* ID
CM fg
ซ
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6.0 METHYL BROMIDE PRODUCTION WASTES (K131, K132)
r' ' i
This section describes the Agency's approach in establishing BDAT
treatment standards for K131 and K132. This includes a description of the industry
affected by the land disposal restrictions for methyl bromide production wastes, a
presentation of available waste characterization data, and a discussion of the Agency's
rationale in determining BDAT treatment standards for these wastes. .
i \
/ ป
Under 40 CFR 261.32 (hazardous wastes from specific sources), wastes
identified as K131 are listed as wastewater from the reactor and spent sulfuric acid from
the acid dryer from the production of methyl bromide. K132 wastes are listed as spent
absorbent and wastewater separator solids from the production of methyl bromide.
6.1 Industry Affected and Waste Characterization
\ 1 . '
This section describes the industry affected by the land disposal restrictions
for K131 and K132 and presents available characterization.data for these wastes.
. ' ' \
6.1.1 Industry Affected and Process Description
To the Agency's knowledge, two domestic facilities produce and purify
methyl bromide and may potentially generate K131 and K132. The facilities are Ethyl
Corporation, located in Magnolia, AR, and Great Lakes Chemical, located in El Dorado,
AR. Both faculties are located in EPA Region VI. These facilities were identified using
the 1990 SRI Directory of Chemical Producers (3) and data collected during EPA's
listing efforts for K131 and K132 (16). .
. > . . - _.<''
Methyl bromide is used mainly as a soil and space fumigant Other uses
for methyl bromide are as a methylating agent in organic synthesis, as a fire extinguisher
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for airplane engines, in ionization chambers, as a wool degreaser, and for extracting oils
from nuts, seeds, and flowers. ,
Methyl bromide (CH3Br) can be produced by two reaction sequences. In
the first sequence, bisphenol-A (BPA) is dissolved in methanol (CH3OH) and bromine
(Br2) is added to the solution. Stoichiometry requires that'four moles of bromine be
used per each mole of bisphenol-A reacted. A slight excess of bromine, is generally used
to ensure complete bromination. The reaction results hi the production of
tetrabromobisphenol-A (TBBPA) and hydrobromic acid. Hydrobromic acid then is
methylated to produce methyl bromide. Methyl bromide is volatile, distills but of the
reactor, and is then purified as discussed below. The reactions are as follows:
Reaction 1:
CH3
HO-(ง)-C-(fi
v/ I V
^
Bisphenol-A
l-OH+4Br2
Bromine
Reaction 2:
HO-
^ I \
r2 CH3 ^2
bisphenol-A
4HBt
HCH3OH
Methanol
Acid
4CH3Br
Methyl
Bromide1
4H2O
Water
4HBr
Hydrobromic'
Add
A typical process flow diagram for production of methyl bromide by this
process is shown in Figure 6-1. The feedstocks, bisphenol-A, methanol, and bromine are
added to the reactor. Water is added to the reactor to precipitate TBBPA, which is
removed by centrifugation. The gaseous methyl bromide product is vented from the
reactor and may be condensed or scrubbed with an alkali solution, such as sodium
hydroxide (NaOH) or sodium carbonate (NajCOj) to neutralize residual hydrobromic
acid. The unreacted methanol and brine, which contains bromine, are recycled to the
reactor.
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The crude product is then washed with sulfuric acid to dry the methyl
bromide and then may be condensed (12). The acid dryer generates a corrosive spent
sulfuric. acid effluent (K131). To further purify the product, the methyl bromide may be
passed .over an absorbent solid to remove impurities. A spent solid absorbent is .
generated (K132) if this additional purification process is used.
The second methyl bromide production sequence utilized industrially
produces only methyl bromide. As in the first sequence, methyl bromide is produced by
reacting liquid methanol with liquid hydrobromic acid. Hydrobromic acid is commonly
produced in-situ by reacting either sulfur (S) or sulfur dioxide (SO2). with bromine and
water (H2O) (12). Sulfuric acid (H,SO4) is produced as a by-product of these reactions
as follows:
)
... ^ r > -
S + 3Br2 + 4H2O --- > 6HBr + H2SO4
SO2 + Br2 4- 2H2p -i-T> 2HBr +
Hydrobromic acid then reacts with methanol to form methyl bromide and water:
CHjOH f HBr - > CH3Br + H2O
The overall reactions are:
S + 3Br2 + 6CH3OH -~ > 6CH3Br
SO2 + Br2 + 2CH3OH ->
The yield of methyl bromide by this sequence is approximately 90-95%
In both the reactor and the acid dryer, sulfuric acid can react with
- \ _ * .
methanol in two side reactions to produce methyl hydrogen sulfate (CH3SO4H) and
dimethyl sulfate (CH3SO4CH3), as follows:
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CHjOH
CH3OH
H2SO4 -
CH3SO4H
CH3SO4H + H2O
CH3SO4CH3 * H2O
/
If the sulfur is used as a feedstock and the co-product TBBPA is not
produced, the wastewater from the reactor is K131 and is discharged. The crude product
is then contacted with sulfuric acid to dry the methyl bromide by absorbing water. The,
* ป
acid dryer will also generate a corrosive spent sulfuric acid effluent identified as K131.
6.12
Waste Characterization
Table 6-1 presents a summary of the available characterization data for
K131 and K132. Data are presented for BOAT list constituents and other compounds
that are believed to be present in or-were quantified in K131 and K132.
63,
Applicable and Demonstrated Treatment Technologies
This section identifies the technologies that are applicable for the
treatment of nonwastewater and wastewater forms of K131 and K132 and determines
1 x.
which of the applicable technologies can be considered demonstrated for the purpose of
establishing BOAT.
To be applicable, a technology must theoretically be usable to treat the
waste in question or to treat a waste that is similar in terms of parameters that affect
treatment selection. (Detailed descriptions of technologies that are applicable to listed
hazardous wastes are provided in EPA's Treatment Technology Background Document
(5).) To be demonstrated,1 a technology must be employed in full-scale operation for
treatment of the waste in question or of a similar waste. Technologies available only at
pilot-scale or bench-scale operations are not considered in identifying demonstrated
technologies.
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62.1 Applicable Treatment Technologies
Nonwastewaters . '
Since nonwastewater forms "of K131 and K132 may contain hazardous
organic constituents at treatable concentrations, applicable'treatment technologies
include those that destroy or reduce the total amount of various organic compounds in
the waste. The Agency has identified the following treatment technologies as applicable
for these wastes:
* Critical fluid extraction followed by incineration of the contaminated
solvents;
ป Incineration (fluidized-bed, rotary Jain, and liquid injection); and
* Solvent extraction followed by incineration or recycle of the extract.
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A.
S " * t
Wastewaters,
Since wastewater forms of K131 and K132 may contain hazardous organic
constituents at treatable concentrations, applicable technologies include those that
destroy or reduce the total amount of various organic compounds in the wastewater.
Therefore, the Agency has identified the following treatment technologies as potentially
applicable for treatment of these wastes:
Biological treatment;
. Carbon adsorption; ,
* . Chemical oxidation;
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Chemically assisted clarification;
PACTฎ treatment (including powdered activated carbon addition to
activated sludge and biological granular activated carbon
technologies);
Reverse osmosis;
Solvent extraction;
Stripping treatment (including steam stripping and air stripping
technologies); and ,
Wet air oxidation.
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A
The concentrations and type(s) of constituents present in the waste
generally determine which technology is most applicable. Carbon adsorption, for
example, is often used as a polishing step following primary treatment by biological
treatment, solvent extraction, or oxidation. Typically, carbon adsorption is applicable for
treatment of wastewaters containing total organic constituent concentrations less than
0.1%. Wet air oxidation, PACT* treatment, biological treatment, and solvent extraction
are applicable for treatment of wastewaters containing organic constituents at
concentrations of up to
622
Demonstrated Treatment Technologies
This section identifies those applicable treatment technologies that EPA
considers to be demonstrated for the purpose of establishing BOAT for K131 and K132.
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Nonwastewaters
'
. * "
The Agency believes that incineration is a demonstrated technology for the
treatment of nonwastewater forms of K13i and K132. This is based on the belief that
nonwastewater and wastewater forms of K131 and K132 are chemically similar to
i
ethylene dibromide (EDB). For the land disposal restrictions program, the Agency
conducted an EDB incineration test on a full-scale operational basis. The Agency
believes that since incineration is demonstrated for treatment of EDB, treatment is
therefore demonstrated for similar brominated organic waste constituents. Analytical
data and complete discussions of the test methods used are available in the
corresponding on-site engineering report (OER) for the EDB incineration test (13).
The Agency is not aware of any facilities that treat the nonwastewater
forms of brominated organic wastes or wastes judged to be similar by fuel substitution;
therefore, the Agency believes that fuel substitution is not currently demonstrated for
these wastes. The Agency is also not aware of any facilities that treat nonwastewater
forms of the brominated organic wastes or wastes judged to be similar using solvent
extraction or critical fluid extraction-on a full-scale operational basis; therefore, EPA
believes that these technologies are not currently demonstrated for these wastes.
Wastewaters
The Agency has identified biological treatment, air/steam stripping, reverse
osmosis, chemically assisted clarification and carbon adsorption as demonstrated
technologies for .the treatment of organic constituents in wastewater forms of K131 and
K132. These technologies have been identified as providing treatment on a full-scale
operational basis for methyl bromide and other brominated compounds.
Analytical data and additional discussions of the constituents expected to
be found in K131 and K132 are presented in Section 6.3.
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The Agency is not aware of any facilities that treat wastewater forms of
brpminated organic wastes by PACTฎ, solvent extraction, chemical oxidation, or wet air
oxidation; therefore, the Agency believes that these technologies are not currently
demonstrated for these wastes. . ,
6.3
treatment Performance Data
The Agency does not have treatment performance data for treatment of
nonwastewater and wastewater forms of K131 and K132. Therefore, treatment
performance data were transferred from other previously tested wastes to develop
concentration-based treatment standards for these wastes.
EPA's methodology for transfer of treatment performance data is provided
in EPA's Methodology for Developing BDAT Treatment Standards (IV Transfer of
treatment performance data is technically valid in cases where the untested waste is
generated from a similar industry or similar processing step, or has similar waste
characteristics affecting treatment performance and treatment selection as the tested
wastes. Sources of treatment performance data for potential transfer to nonwastewater
forms of K131 and K132 include wastes previously tested by rotary kiln, fluidized-bed, or
liquid injection incineration and identified in EPA's Volume C of the F039 Background
Document (10). Sources of treatment performance data for potential transfer to
wastewater forms of K131 and K132 include those wastes and technologies.identified in '
EPA's Volume A of the F039 Background Document (8).
63.1
Treatment of Organic Constituents in Nonwastewaters
Wastes previously tested by the Agency by rotary kiln, fluidized-bed, or
liquid injection incineration include: 0014, D016, K001, K011, K013, K014, K015, K019,
K024, K037, K048, K051, K087, K101, K102, P020, P059, U028, U080, U122, U127,
U141, U161, U166, U188, U192, U220, U226, and U239.
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In addition, the Agency is aware of several facilities that currently
incinerate bromine-containing wastes. At Rollins Environmental Services, Deer Park,
Texas, the Agency has previously incinerated ethylene dibromide wastes that were
cancelled pesticides under FIFRA provisions. Excess oxygen conditions were carefully
controlled to reduce the amount of bromide gas and to increase the amount of hydrogen
bromine gas generated by incineration. Hydrogen bromine is readily absorbed by the air
pollution control devices (APCDs), while bromine is difficult to remove by APGDs. ~ The
Agency believes that control of the undesirable conversion of the bromine-containing
waste to bromine gas significantly affects the design and operation of the incineration
systems. For these reasons, the Agency does not believe that transfer of treatment
i '
performance data from incineration of the non-brominated wastes listed in previous
sections of this document is technically valid for the purpose of developing
concentration-based treatment standards for brominated constituents in organic wastes.
. Therefore, treatment performance data from the EDB incineration test
were used to develop treatment standards for methyl bromide in K131 and K132.
Treatment performance data from the EDB incineration test for the untreated waste
feed and incinerator ash treatment residual are included in Table 6-2. Design data for
the treatment systems used for the ethylene dibromide incineration test are included hi
Table 6-3. :
6.3.2 Treatment of Organic Constituents in Wastewaters
*
Treatment standards for organic BDAT List constituents in these
wastewaters were developed from treatment performance data transferred from EPA's
Volume A of the F039 Background Document (8). These data were used for transfer to
wastewater forms of K131 and K132 because the Agency prefers, whenever possible, to
use appropriate treatment performance data from well-designed and well-operated
wastewater treatment units, rather than scrubber water concentration data, in setting
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BOAT treatment standards. These data represent treatment using a specific wastewater
treatment technology as opposed to scrubber water.
Table 6-4 presents the available treatment performance data for methyl
bromide. The data used to determine the BDAT treatment standard are shown with an
asterisk.
Presented below are short descriptions of the data sources for wastewater.
treatment performance data on methyl bromide and the Agency's rationale for
determining which data set was used in the development of the treatment standard.
Sources of Treatment Performance Data
This section describes each of the sources of wastewater treatment
performance data used to compile data for the determination of treatment standards.
NPDES Database. Under the Clean Water Act, the discharge of pollutants
into the waters of the United States' is prohibited unless a permit is issued by EPA or a
state under the National Pollutant Discharge Elimination System (NPDES). An NPDES
permit provides effluent limitations for specific pollutants that a faculty can discharge.
The permit also provides for monitoring and reporting requirements by a facility to
check whether the effluent limitations are being met. The monitoring data submitted by
facilities to EPA or the state as part of the NPDES permit program is summarized in a
database. ' " ' ' .
'' i '
The NPDES database was searched for 90 BDAT List constituents to
identify facilities that have monitoring data for any of those constituents. Constituent
data from this search, representing concentrations of constituents in wastewater effluents,
have been incorporated into the tables of this section. EPA was unable to evaluate
whether substantial treatment occurred since corresponding influent concentrations of
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the constituents were unavailable; The treatment technologies or treatment trains
represented by the NPDES data were identified in some, but not all cases. Where
available, the treatment technology has been specified in the tables of this section.
' '
X
WERL Database. U.S. EPA's Risk Reduction Engineering Laboratory,
which now includes the former Water Engineering Research Laboratory (WERL), has
developed and is continuing to expand a database on the treatability of chemicals in
various types of waters and wastewaters. This WERL database has been compiled from
wastewater treatment performance data available in literature. The treatment
performance data for BDAT List constituents in this database have been included in the
tables of this section.
Treatment Performance Data " "
. Methyl Bromide. The data for methyl bromide were compiled from the
WERL and NPDES databases and are presented in Table 6-4. Technologies for which
data are available include AS and BT. The treatment performance data represent full-
scale technologies and result in an effluent concentration range of 1 ppb to 20 ppb.
The Agency is establishing activated sludge biological treatment (AS) as
BDAT for methyl bromide. Activated sludge was selected as BDAT because the
available data show high influent concentrations and a high removal efficiency. The
BDAT treatment standard for methyl bromide was calculated using the effluent
concentration of 20 ppb and the appropriate variability factor. The calculation of the
resulting BDAT treatment standard for methyl bromide (0.11 ppm) is described in
Section 6.6 and is shown in Table 6-5.
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6,4 . Identification of Best Demonstrated Available Technology (BDAT)
This section presents the Agency's rationale for determining the best
demonstrated available technology (BDAT) for nonwastewater and wastewater forms of
K131andK132.
EPA determines the best demonstrated available technology based on a
thorough review of all of the treatment performance data available for the waste of
concern or wastes judged to be similar. Following the identification of "best," the Agency
determines whether the technology is "available." An available treatment technology is
one that (1) is not a proprietary or patented process that cannot be purchased or
licensed from the proprietor (i.e., it must be commercially available), and (2)
substantially diminishes the toxicity of the waste or substantially reduces the likelihood of
migration of hazardous constituents from the waste.
6.4.1 Nonwastewaters
The treatment performance data that were evaluated to detennine BDAT
treatment standards for the nonwastewater forms of K131 and K132 are presented in
Section 6.3 The treatment performance data were screened to determine:
Whether the data represent operation of a well-designed and well-
operated treatment system;
Whether sufficient analytical quality assurance/quality control
measures were employed to ensure the accuracy of the data; and
Whether the appropriate measure of performance was used to assess
the performance of the particular treatment technology.
MLM/027
1031-01 .mint 6-12
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EPA has identified incineration as demonstrated for the treatment of
organic constituents in nonwastewater forms of K131 and K132. EPA has treatment
performance data from the incineration of constituents included in each group of wastes.
t ซ
All of the incineration data included in Section 4.3 represent BOAT for
wastes included in previous rulemakings and therefore have already met the above
conditions. Thus, incineration is the "best" technology for treating organic nonwastewater
forms of these wastes in each group of wastes. .
Incineration, identified as the "best" technology for these organic wastes, is
commercially available. Treatment performance data included in Section 6.3 show
substantial treatment by incineration for waste constituents of concern and other similar
constituents. Because incineration is applicable, demonstrated, and "available," it is
therefore being established as BDAT for treatment of the organic constituents in
nonwastewater forms of K131 and K132.
6.4.2 Wastewaters
The treatment performance data that were evaluated to determine BDAT
treatment standards for wastewater forms of K131 and K132 were presented in Section
6.3. The methodology used in determining the "best" technology for treatment of
wastewater constituents that are included in K131 and K132 was that for any constituent.
without EAD data, BDAT wastewater treatment test data, or industry-submitted leachate
treatment performance data showing substantial treatment, and other available treatment
performance dak were evaluated to determine BDAT and were used to calculate the
BDAT concentration-based treatment standard. Considered in this evaluation were the
treatment technology for which data were available, whether the data represented a full-
scale, pilot-scale, or bench-scale technology, the concentration of the constituent of
concern in the influent to treatment, the average concentration of the constituent of
concern in the effluent from treatment, and the removal efficiency of the treatment
MLM/027 . .
1031-Ol.mim . 6-13
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technology. Full-scale treatment data with an influent concentration range greater than
100 ppb were preferred over pilot-scale or bench-scale data and preferred over data with
a low (i.e., 0-100 ppb) influent concentration range. If several sets of data met these
criteria (i.e., full-scale available technologies with high influent concentrations), they
were compared by examination of their average effluent values and percent removals.
EPA has identified biological treatment as the "best",demonstrated
technology for-wastewater forms of K131 and K132. Biological treatment is
I
commercially available and the treatment performance data included in Section 6.3 show
substantial treatment of methyl bromide by this technology. Therefore, biological
treatment is also1 considered to be available and is being promulgated as BDAT.
6.5 Selection of Regulated Constituents
The Agency has developed a list of hazardous constituents (the BDAT
Constituent list, presented in EPA's Methodology for Developing BDAT Treatment
Standards (1)) from which constituents are selected for regulation. EPA may revise this
list as additional data and information become available. The list is divided into the
following categories: volatile organics, semivolatile organics, metals, inorganics other
than metals, organochlorine pesticides, phenoxyacetic acid herbicides, organophosphorus
insecticides, polychlorinated biphenyls (PCBs), and dioxms and furans. This section
presents EPA's methodology and rationale for selection of constituents for regulation in
nonwastewater and forms of K131 and K132.
Generally, constituents selected for regulation must satisfy the following
' '
criteria: .
1. The constituent must be on the BDAT List of constituents.
Presence on the BDAT List means that EPA-approved methods
exist for analysis of the constituent in treated waste matrices.
MLM/027
1031-01 .mlm 6-14
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2. The constituent must be present in, or be suspected of being present
in. the untreated waste. For example, analytical difficulties may
prevent a constituent from being identified in the untreated waste,
but its identification residual may lead the Agency to conclude that
it is present in the untreated waste.
From a group of constituents that may be selected for regulation because
they meet the above criteria, EPA may select a subset of constituents that represents the
broader group. For example, from a group of constituents that react similarly to
treatment, the Agency may select for regulation those constituents that (1) are the most
difficult to treat, based on waste characteristics affecting treatment performance; (2) are
representative of other constituents in the waste, based on structural similarities; or (3)
are present in the untreated waste in the highest concentrations. Selecting a subset of
constituents for regulation facilitates implementation of industry compliance and of
i
EPA's enforcement program.
The Agency initially considered all constituents on the BOAT List for
regulation in K131 and K132. Table 6-1 summarizes the constituents believed to be
present in these wastes. Two BDAT List constituents have been identified in K131 and
K132, methyl bromide and methanol. The Agency has selected methyl bromide for
regulation in nonwastewater and wastewater forms of K131 and K132. The Agency has
not selected methanol for regulation due to concerns regarding the accurate quantitation
of this constituent. , .
6.6 Calculation of BDAT Treatment Standards /
The Agency bases concentration-based treatment standards on the
performance of well-designed and well-operated treatment systems. These standards
account for analytical limitations in available treatment performance data and for
variabilities related to treatment, sampling, and analytical techniques and procedures.
MLM/027
1031-01.mta 6-15
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This section presents the treatment standards calculated for methyl bromide using the
available treatment performance data discussed in Section 6.3.
6.6.1 Nonwastewaters
' T . '
Treatment standards for regulated constituents in nonwastewater forms of
K131 and K132 were calculated based on data compiled from the 8DAT incineration
database for incinerator ash. Specifically, detection limit data from the Agency's
ethylene dibromide incineration test were transferred for use in calculating the BOAT
treatment standards for methyl bromide in.nonwastewater forms of K131 and K132.
This transfer is justified by the Agency's belief that methyl bromide is structurally similar
toEDB.
The concentration-based treatment standard for methyl bromide was
calculated by multiplying the detection limit for ethylene dibromide in ash by an
accuracy correction factor and a variability factor. The following subsections discuss
these three components of the treatment standard calculation. This calculation is
summarized in Table 6-5. * ,
Detection Limits
The detection limit for ethylene dibromide in ash was transferred to methyl
bromide to calculate the/treatment standard for nonwastewater forms of K131 and K132.
Accuracy Correction Factors
The detection limit used to calculate the treatment standard for methyl
bromide was corrected using matrix spike recovery data from the same test from which
the detection limit was taken to account for analytical interferences associated with the
MLM/027 -
1031-01.mlm 6-16
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chemical matrices of the samples. The detection limit was corrected for accuracy as
follows: ,
A matrix spike recovery was determined for the regulated constitu-
ent. In cases where a matrix spike was not performed for a
regulated constituent in the treatment test from which the detection
limit was taken, the matrix spike recovery from a similar constituent
from that treatment test was transferred to the constituent.
An accuracy correction factor was determined for the constituent by
dividing 100 by the matrix spike recovery (expressed as a
percentage) for that constituent. :
The detection limit was then corrected by multiplying by the
corresponding accuracy correction factor.. The accuracy corrected
detection limit for ethylene dibromide (and transferred to methyl
bromide) is shown on Table 6-5.
The matrix spike recovery used to' adjust the detection limit for methyl
bromide in nonwastewater forms of K131 and K132 is included in Appendix B.
Duplicate matrix spikes were performed for some waste constituents. If a duplicate
matrix spike was performed for a constituent, the matrix spike recovery used for that
constituent was the lower of the two values between the first matrix spike and the
duplicate spike. Matrix spike recoveries of less than 20% are not acceptable and were
not used to correct detection limits. Matrix spike recoveries greater than 100% were
considered to be 100% for the purpose of this calculation so that the data were not
adjusted to concentrations below the detection limits.
Variability Factors
The variability factor accounts for the variability inherent in treatment
system performance, treatment residual collection, and analysis of the treated waste
samples. Variability factors could not be calculated for waste constituents that were not
detected in the incinerator ash residuals. In these cases, a variability factor of 2.8 was
MLM/027
1031-Ol.Mta ,N " 6-17
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used to account for this inherent variability, as discussed in the Methodology for
Developing BOAT Treatment Standards (1).
6.62 Wastewaters ' '
Treatment standards for wastewater forms of K131 and K132 were
calculated based on data compiled from EPA's wastewater treatment performance
database. Specifically, treatment performance data from biological treatment were used
to calculate the BDAT treatment standard for methyl bromide in wastewater forms of
-. . - i
K131 and K132. . '
The concentration-based treatment standard for methyl bromide was
calculated by multiplying the constituent effluent concentration (as presented in Section
p
6.3) by an accuracy correction factor and a variability factor. The following subsections
discuss these three components of the treatment standard calculation. The calculation
for methyl bromide in wastewater forms of K131 and K132 is summarized in Table 6-5.
Constituent Effluent Concentration
The effluent concentration obtained using the BDAT for methyl bromide
in K131 and K132 was determined as discussed in Section 6.3.2. The treatment
performance data for methyl bromide are presented in Table 6-4.
Accuracy Correction Factors ,..'.
Accuracy factors account for analytical interferences associated with the
chemical matrices of the samples. An HAD variability factor was transferred for use in
the calculation of the methyl bromide treatment standard. Based on the fact that HAD
variability factors were originally calculated.to represent performance, analytical, and
matrix variations, an additional accuracy correction factor was not used.
MLM/027
1031-01.mlm 6-18
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Variability Factors
A variability factor (VF) accounts for the variability inherent in the .
* _
treatment system performance, treatment residual collection, and analysis of the treated
waste samples. . Variability factors are calculated as described in EPA's Methodology for
Developing BOAT Treatment Standards (1). However, original effluent data points
were not available for methyl bromide in K131 and K132 since WERL effluent data
were used to determine treatment standards and these data were presented as averages
in the WERL database. Therefore, it was not possible to calculate an individual
variability factor for this constituent; instead, an average variability factor was used. The
average variability factors were generated from the EAD variability factors and are
specific to the type of constituent under consideration (i.e., volatile organic, acid
extractable semivolatile organic, etc.). The calculation of average variability factors is
discussed in Appendix C. .
MLM/027
10314)1.0dm 6-19
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Table 6-1
Summary of Available Characterization Data
for K131 and K132
Constituents Believed to be Present in K131 and K132*
BOAT List Constituents
Vfethanol
Methyl Bromide
Other Constituents
Dimethyl Sulfate
Julfuric Acid
VI ethyl Hydrogen Sulfate
VIethyl Ether
ithanol
iydrobromic Acid
All data for constituents believed to be present in K131 and K132 is classified as
Confidential Business Information. '
MLM/027
i031-bl.mlm
6-20
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Table 6-2
Treatment Performance Data Collected by EPA
from Incineration of Ethylene Dibromide (EDB)
at Rollins Environmental Services, Inc. (Texas)'- Incineration
:*. ':,': "'""''.'''''.''. : " ' ''--"XV-!:!-'!;^-" ฃ "'
'.-.-' ':.::-. : ' .'.:-' ; -.".: : ". -: '. .:: :- . :- ::'-'- :'--"' : ":- :
BOAT Met rimซtitn*nr
1^-Dibromoethane
(Ethylene dibromide)
Sainple
Set No.
1
2 ,-
3
ฃ^^^^
Detection Limit
K^'-fat/x&^.:-
25,000
25,000
25,000
CoikieBtratioa of
EDB(mg/kg)
119,000
92,000
102,000
;;-';!!!^B^^
WpiE^ff^S
D^tectfoa limit
W-V*J&Kฃ.
5
5-
. 5
;:'. :'- ' .Ttninn---'. '' '" -
?c;"W'!.'Pปซป%.xV:..:-
ConceDtratioB In
Solids Difwharg*
Stream (tag/leg)
<5
<5
<5
Source: EDB Test Bum Progress Emissions Test Results (13).
MLM/027
1031-01.mlm
6-21
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Table 6-3
Design Parameters for the Incinerator System at Rollins
Environmental Services, Inc. (Texas)
: t:f:! Physical: Design Parameter
vvv'". . ":: ;'.'.';;; .::.-'. : :.: Value or Description '-( -'.'"^-.C^- ' ::'':".-:>; :*;.:
ROTARY KILN:
Manufacturer
Height
aside diameter . L
^ength
Volume
Width
Materials of construction:
.
Outer shell
?ront wall
* ' ''
NR .
9 .5 feet
32.8 feet
2^24 cubic feet
i
1.18-inch steel plate with 9-inch refractory lining.
3.59-inch steel plate with castable refractory and refractory brick
ining " .-
LODDBY FURNACE:
Manufacturer
Height
nside diameter
^ength
Volume
Width
'
NR
6^5 feet
14 feet
429. cubic feet
pJR . -.
AFTERBURNER:
Manufacturer
Height .
aside diameter
-ength
Volume .
Width
Materials of construction:
Outer shell
Ceiling
* " .
13 JS feet
NR - .. . - ' '. , ' '
49 feet
8^00 cubic feet
12\5feet
13-inch refractory bricks support by stainless steel clips attached to
steel beams.
5-inc bricks.
NR - Not Reported
'This equipment was designed for RES(TX), Inc., and therefore does not cany a model number.
Source: EDB Test Burn Progress Emissions Test Results (13)
MUM/027
1031-01 .mlm
6-22
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s
i
A
3 ฃ
**
.0
E?
s
*
5 "E>
Ifl
I
S
i
s
t
*
t!
?*
9
ง
6-23
-------
Table 6-5
/
Calculation of Nonwastewater and Wastewater
Treatment Standards for K131 and K132
'-' ;- Regulated '
Gonstltoent '
Constituent From
Which Treatment
Performance Data
Were Transfeitied
Detection Limit
'"'^ii %lffiitiit;;%':-'f ."
.; Concentration
Accuracy Corrected
Variability Factor
Treatment Standard
Nonwastewaters '
vf ethyl Bromide JEthylene Dibromide
5.41mg/kg
2&
15 mg/kg
Wastewaters
Methyl Bromide (Methyl Bromide
0.020 mg/L
5.7*
0.11 mg/L
The variability factor represents an HAD VF and, therefore, accounts for both variability and accuracy
correction. ,
MLM/027
1031-01.mlm
6-24
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I
TTT
IN
I
3
ฃ
I .!
! I
s , ซ
5 Z
6-25
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-------
7.0 2-ETHOXYETHANOL WASTE (U359)
This section describes the Agency's approach in establishing BDAT
treatment standards for U359. This includes a description of the industry affected by the
land disposal restrictions for 2-ethoxyethaCnol wastes, a presentation of available waste
characterization data, and a discussion of the Agency's rationale in determining BDAT
treatment standards for this waste.
7.1 Industry Affected and Waste Characterization
/ ' "
t
7.1.1 . Industry Affected and Process Description
To the Agency's knowledge, three domestic,facilities manufacture 2- .,
ethoxyethanol and may potentially generate U359. Table 7-1 lists these facilities by state
and EPA region. These facilities were identified using the 1990 SRI Directory of
Chemical Producers (3) and data collected during EPA's listing efforts for U359 (17).
i .
U3S9 consists of a commercial chemical product or manufacturing
intermediate from a non-specific source containing 2-ethoxyethanol as the sole active
ingredient. Commercial chemical products or manufacturing intermediates include all
commercially pure grades of the listed chemical, all technical grades, and all formulated
products in which the listed chemical is the sole active ingredient. Off-specification
product containing 2-ethoxyethanol as the sole active ingredient is also included. Finally,
, any residue that remains in a container that contained 2-ethoxyethanol or inner liner
removed from a container that contained 2-ethoxyethanol and that will not be recycled,
1 i i
reclaimed, or reused; or any residue or contaminated soil, water, or debris from a spill of
2-ethoxyethanol is also considered U359. U359 does not include manufacturing process
wastes. A process waste occurs when a product is:
- Discarded or intended to be discarded;
MLM/Q27 ,
1031-Ol.mlm ' . 7-1
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* Mixed with another material and applied to the land for dust
suppression or road treatment;
* Applied to land in lieu of its original intended use; or
Distributed or burned as a fuel or fuel additive.
7.1.2 Waste Characterization .
Table 7-2 presents a summary of the available characterization data for
U359. : .
' '
7*2 Applicable and Demonstrated Treatment Technologies
This section identifies the technologies that are applicable for the
treatment of nonwastewater and wastewater forms of U359 and determines which of the
applicable technologies can be considered demonstrated for the purpose of establishing
BDAT.
To be applicable, a technology must theoretically be usable to treat the
waste in question or to treat a waste that is similar, in terms of parameters that affect
treatment selection. (Detailed descriptions of technologies that are applicable to listed
hazardous wastes are provided in EPA's Treatment Technology Background Document
(5).) To be demonstrated, a technology must be employed in full-scale operation for
treatment of the waste in question or of a similar waste. Technologies available only at
pilot-scale or bench-scale operations are not considered in identifying demonstrated
technologies. '
MLM/027
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72.1 Applicable Treatment Technologies
, ^ ^
Nonwastewaters '
Since nonwastewater forms of U359 may contain hazardous organic
constituents at treatable concentrations, applicable treatment technologies include those
that destroy or reduce the total amount of various organic compounds in the waste. The
x, , T
Agency has identified the following treatment technologies as applicable for these
wastes:
Chemical oxidation;
Critical fluid extraction followed by incineration of the contaminated.
solvents; , '
Distillation; ,
Fuel substitution;
1 1
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
and '
i -
, Wet air oxidation. .
\
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A.
v '' . - S
Wastewaters -
... ,. _. ^ | - ^ . ^ .
Since wastewater forms of U359 may contain hazardous organic
constituents at treatable concentrations, applicable technologies include those that
destroy or reduce the total amount of various organic compounds in the waste.
MLM/027
1031-Ol.mto 7-3
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Therefore, the Agency has identified the following treatment technologies as potentially
applicable for treatment of these wastes:
* *
Biological treatment;
Carbon adsorption;
Chemical oxidation; :
Distillation;
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
Steam stripping; and
* Wet air oxidation.
These treatment technologies were identified based on current waste treatment practices
and engineering judgment and are described in more detail in Appendix A.
s
The concentrations and type(s) of constituents present in the waste
generally determine which technology is most applicable. Carbon adsorption, for
example, is often used as a polishing step following primary treatment by biological
treatment, solvent extraction, or oxidation. Typically, carbon adsorption is applicable for
treatment of wastewaters containing organic constituents at concentrations of less than
0.1%. Wet air oxidation, biological treatment, and solvent extraction (followed by
incineration or recycle of the extract) are applicable for treatment of wastewaters
containing organic constituents at concentrations of up to 1%.
*.
722 Demonstrated Treatment Technologies
This section identifies those applicable treatment technologies that EPA
considers to be demonstrated for the purpose of establishing BDAT for U3S9.
J&M/027
1031-OI.mlm ' 7-4
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Noiiwastewaters
V "
The Agency believes that incineration is a demonstrated technology for the
treatment of nonwastewater forms of U359. For the land disposal restrictions program,
the Agency has tested rotary kiln incineration on a full-scale operational basis for many
organic waste constituents including:
Aromatic and other Hydrocarbon Wastes
Toluene .
Broihinated Organic Wastes
Ethylene Dibromide
Halogenated Aliphatic Wastes
Bis(2-chlproethyl)ether .
1,1-Dichloroethane -
1,1,1-Trichloroethane
1,2,4-Trichlorobenzene
(
Halogenated Pesticide'and Chlorobenzene Wastes
Hexachlorocyclopentadiene ;
Chlordane
Heptachlor
Chlorobenzene. , .
1,2-Dichlorobenzene , '
' 1,4-Dichlorobenzene
Hexachlorobenzene
Pentachlorobenzene , ,
Pentachloronitrobenzene '.''.-
1,2,4,5-Tetrachlorobenzene
2,4-Dichlorophenoxyacetic acid.
Methoxychlor
Hexachlorobutadiene
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Oxygenated Hydrocarbon and Heterocyclic U and P Wastes
Acetone
Ethyl acetate
Methyl ethyl ketone
Methyl isobutyl ketone
1,4-Naphthoquinone
Wastes of a Pharmaceutical Nature
Isosafrole
Phenolic Wastes
2-sec-Butyl-4,6-dinitrophenol (Dinoseb)
o-Cresol
p-Cresol
Phenol
Polynuclear Aromatic Wastes
Benzo(a)pyrene
Chiysene
Indeno( l,2,3-cd)pyrene
Benz(a)anthracene
Fluoranthene .
Naphthalene
Organo-Nitrogen Compound Wastes '
Acetonitrile
Acrylonitrile
Aniline
Nitrobenzene
Pyridine
Miscellaneous Halogenated Organic Wastes
> Chloromethane
Dichlorodifluoromethane
Vinyl chloride
Bis(2-chloroethyl)ether
. 3,3'-Dichlorobenzidine
Pronamide
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In addition, current management practices for nonwastewater forms of
U359 include incineration. One generator of U359 indicated that this waste was
incinerated off site and another generator indicated that biological treatment sludges
from the treatment of wastewater forms of U359 are also incinerated.
The Agency believes that because incineration is demonstrated for the
treatment of many organic waste constituents, including those which are structurally
similar to those constituents found in U3S9, that incineration is also demonstrated for
U359. The Agency is not aware of any facilities that treat these wastes by fuel
substitution. However, the Agency believes that fuel substitution is an appropriate
technology for these wastes, particularly considering that 2-ethoxyethanol contains only
carbon hydrogen, and oxygen in its molecular structure.
N
From review of the 1986 TSDR Survey (6) and the USEPA's Water
Engineering Research Laboratory (WERL) database (7), the Agency has determined
that some facilities also treat nonwastewater forms of aromatic and polynuclear aromatic
wastes or wastes judged to be similar to U359 using wet air oxidation, chemical
oxidation, and distillation on a full-scale operational basis. Therefore, EPA considers
these technologies to be demonstrated for aromatic and polynuclear aromatic wastes
suchasU359. .-...,
N '''.'
The Agency is not aware of any. facilities that treat nonwastewater forms of
these wastes or wastes judged to be similar on a full-scale operational basis using solvent
extraction (followed by incineration or recycle of the extract) or critical fluid-extraction
(followed by incineration of the contaminated solvents); therefore, EPA believes that
these technologies are not currently demonstrated for these wastes. .
MLM/027 .
1031-01 .mim . , .7-7
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Wastewaters . ,
The following technologies have been identified as demonstrated for
treatment of the following types of organic wastes (organized by chemical structure):
Aromatic and Other Hydrocarbon Wastes
Incineration .
Biological Treatment
Carbon Adsorption
Wet Air Oxidation
Chemical Oxidation ,
Steam Stripping
Brnminated Organic Wastes
Biological Treatment
Halogenated Aliphatic Wastes '.-'-
' . i ' '
Incineration
Wet Air Oxidation
Chemical Oxidation
Biological Treatment
Carbon Adsorption
Solvent Extraction -
Distillation
Steam Stripping
Halogenated Pesticide and Chloroberreerie Wastes
~ -,- ' _ ;
-Biological Treatment
Wet Air Oxidation
Steam Stripping
Carbon Adsorption
Oxygenated Hydrocarbon and Heterocyclic Wastes
Biological Treatment^
Carbon Adsorption
Steam Stripping
Wet Air Oxidation
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Wastes of a Pharmaceutical Nature
Wet Air Oxidation
- \ w"
Phenolic Wastes -
/ ^^^^^^^...^i^
Wet Air Oxidation
Carbon Adsorption
Biological Treatment \
Chemical Oxidation
Solvent Extraction
Steam Stripping
-Polymiclear Aromatic Wastes
Incineration \ . >
Biological Treatment > _
Carbon Adsorption
Wet Air Oxidation ' -
Chemical Oxidation ,
Steam Stripping
\ - .'.....
Organo-Nitrogen Compound Wastes ,
Biological Treatment
- Carbon Adsorption
. Steam Stripping
Wet Air Oxidation
Solvent Extraction '
Miscellaneous Halogenated Organic Wastes
Biological Treatment
Steam Stripping
Carbon Adsorption
Solvent Extraction followed by Steam Stripping followed by Carbon
Adsorption
Chemical Oxidation
Wet Air Oxidation
The Agency is not aware of any facilities that incinerate wastewater forms
i
of some of the waste groups. However, commenters responding to the Second Third
proposed rule indicated that they were incinerating many wastewaters and that they did
MLM/027 ' ' . .
1031-OI.mto . ,7-9 ' ' . ' .
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not want to be precluded from doing so. In addition, the Agency has conducted
incineration tests which demonstrate that incineration is an effective treatment
technology for a wide variety of organic compounds, including halogenated and
nonhalogenated organic compounds and pesticides. EPA's evidence that incineration
constitutes significant treatment for these compounds is that these compounds were
quantified at or near their detection limits in the ash and scrubber water residues from
these tests. The chemical structures and physical properties of these compounds are
similar to those of 2-ethoxyethanol. Since incineration is demonstrated for treatment of
waste constituents, in nonwastewater forms of U359 as discussed in above, the Agency
believes incineration is also demonstrated for these waste constituents in wastewater
forms of these wastes. Therefore, the Agency also identifies incineration as a demon-
strated technology for wastewater forms of U359.
t
Based on engineering judgment, the Agency considers the following
technologies to be demonstrated for wastewater forms of U359:
* ("
Biological treatment;
Carbon adsorption;
Chemical oxidation;
Distillation;
Incineration (fluidized-bed, rotary kiln, and liquid injection);
Solvent extraction followed by incineration or recycle of the extract;
Steam stripping; and
Wet air oxidation.
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73 Identification of Best Demonstrated Available Technology (BOAT)
This section presents the Agency's rationale for determining the best
demonstrated available technology (BOAT) for nonwastewater and wastewater forms of
U359. The best demonstrated available technology is determined based on a thorough
review of all the treatment data available on the waste of concern or wastes judged to be
similar . . "
/ . "'
For a treatment technology to be identified as "best," the treatment,
performance data are screened to determine: . ' > .
Whether the data represent operation of a well-designed and well-
operated treatment system; -
Whether sufficient analytical quality assurance/quality control mea-
sures were employed to ensure the accuracy of the data; and
Whether the appropriate measure of performance was used to assess
the performance of the particular treatment technology.
Following the identification of "best," the Agency determines whether the
' ' j
technology is "available." An available treatment technology is one that (1) is not a
proprietary or patented process that cannot be purchased or licensed from the proprietor
(i.e., it must be commercially available), and (2) substantially diminishes the toxicity of
the waste or substantially reduces the likelihood of migration of hazardous constituents
from the waste.
73.1 . Nonwastewaters .
'
As discussed previously, incineration is a demonstrated treatment
technology for nonwastewater forms of U359.
MUM/027 .
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The Agency obtained incinerator ash analytical data from the 14 BDAT
treatment tests, conducted at well-designed and well-operated hazardous waste .
incinerators. Strict quality assurance/quality control measures were employed to ensure
the accuracy of the data, and since EPA was collecting these data to identify and
characterize BDAT treatment technologies, appropriate performance variables, namely
U and P waste constituent concentrations in treated and untreated waste, were
i . . ,
measured. The Agency has determined that due to the high temperatures, efficient .
mixing, and consistent residence times used at commercial hazardous waste incinerators,
incineration processes are relatively indiscriminate in the destruction of organics. Based
on the treatment performance data available, the Agency considers incineration to be the
"best" technology for the treatment of nonwastewater forms of U359,
Incineration is a commercially available technology. Additionally,
treatment performance data from the 14 BOAT incineration treatment tests show.
substantial treatment by incineration for the waste constituents in nonwastewater forms
of unquantifiable U wastes. Therefore, incineration is considered an "available"
treatment technology for U3S9 for the purpose of establishing BDAT.
Incineration has been determined to be BDAT for all of the
nonwastewater organic constituents that cannot be quantified in hazardous waste
matrices using current analytical methods, including those contained in nonwastewater
forms of U359, based on their similarities in chemical and physical properties.
The Agency is promulgating fuel substitution as an alternative to
incineration for nonwastewater forms of U359. The basis of this decision is that
2-ethoxyethanol is a readily oxidizable carbon, hydrogen, and oxygen compound that will
not release undesirable products (such as halogenic acids, nitrogen, or sulfur dioxide)
upon combustion.
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132 Wastewaters
As discussed previously, incineration, wet air. oxidation, biological '
treatment, carbon adsorption, solvent extraction followed by incineration or recycle of
the extract, chemical oxidation, distillation, and steam stripping are all demonstrated
technologies for the treatment, of. wastewater forms of U359.
'
The Agency believes that the best technologies for treating wastewater .
forms of U359 are those technologies that destroy the constituents .found in these wastes.
Steam stripping, solvent extraction followed by incineration or recycle of the extract, and
distillation are technologies that remove the constituents from the wastewater stream;
however, the waste constituents are not destroyed but are processed into a more
concentrated waste stream, i.e., the condensate, extract, or bottom stream (or still
bottoms). These waste streams typically require further treatment before disposal. As a
result, the Agency does not consider steam stripping, solvent extraction, or distillation to
be the best technologies for treating wastewater forms of the wastes covered in this
subsection. .
\
Because a technology removes waste constituents from the waste stream to
be land disposed, but does not destroy them, does not necessarily preclude it from being
considered "best". As discussed below, carbon adsorption is being established as part of
the chemical oxidation and biodegradation treatment trains. The purpose of the carbon
adsorption step as part of these treatment trains is to remove organic by-products'
resulting from the oxidation of waste constituents or biologically degraded by-products. .
Carbon adsorption was selected as the removal step over steam stripping, solvent
extraction, and distillation because the Agency believes that carbon adsorption is the
most appropriate removal technology for the widest range of organic compounds likely to
>
be present in the oxidation and biological treatment effluent streams.
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Chemical oxidation provides treatment by oxidizing (or destroying) the
organic constituent in U359. However, to ensure effective treatment of this waste,
chemical oxidation treatment should include a final carbon adsorption or biological
treatment step. Since 2-ethoxyethanol is not quantifiable, it is not possible to accurately
judge the effectiveness of the chemical oxidation step. Therefore, the Agency believes
that it is sound engineering judgement to include a final step of carbon adsorption or
\
biological treatment following oxidation. Carbon adsorption or biological treatment will
ensure that the oxidation by-products are removed from the wastewater matrix. The
Agency believes that chemical oxidation followed by carbon adsorption or biological
treatment should be considered a "best" technology train for the treatment of
2-ethoxyethanol in wastewater forms of U359. (It should be noted that spent carbon
from the treatment of these wastewaters would become a nonwastewater form of this
waste (54 Federal Register. 26630-1, June 23, 1989) and thus would be required to be
incinerated .to meet the applicable treatment standard.)
''
The Agency is also including biodegradation followed by carbon.adsorption
as a "best" technology train for the treatment of 2-ethoxyethanol in wastewater forms of
U359. This is based on the determination that 2-ethoxyethanol is known to hydrolyze
rapidly to ethanol, which is known to be amenable to biological treatment
The definition of biodegradation as a technology-based standard for listed
wastewaters calls for operating the unit such that "a surrogate compound or indicator
parameter has been substantially reduced in concentration in the residuals." EPA
believes that this provision will provide permitting and compliance authorities with
sufficient control over the biodegradation unit that biodegradation can be designated as
BDATforU359.
The Agency believes it is sound engineering judgement to include a final
step of carbon adsorption following biodegradation to ensure effective treatment of
U359. This step will ensure that the biological breakdown products are removed from
N
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\
the wastewater matrix. (It should be noted that spent carbon from the treatment of
these wastewaters becomes a nonwastewater form of this waste (54 Federal Register.
26630-1, June 23, 1989) and thus would be required to be incinerated to meet the
applicable treatment standard.)
In cases where the Agency has treatment performance data for both
wastewater treatment processes and incineration (as measured by total constituent
concentration in scrubber water), the Agency prefers to establish treatment standards
based on the,wastewater treatment processes. However, the Agency has determined that
wastewaters are also treated by incineration and does not intend to preclude industry
from continuing this practice. Therefore, EPA is also identifying incineration as a best
demonstrated technology for these wastes.
N
Treatment performance data included in Volume A of the Background
Document for Organic U and P Wastes and Multi-Source, Leachate (F039) (8) show
i ' . i
substantial treatment of organic constituents by carbon adsorption, chemical oxidation,
and biological treatment In addition, these technologies are commercially available.
Therefore, these technologies are considered to be "available" treatment technologies for
the purpose of establishing BOAT. As discussed in Section 7.3.1, incineration is also an
"available" treatment technology for treatment of these wastes.
Based on the above discussion, EPA is promulgating the following methods
of treatment as treatment standards for organic constituents that are not quantifiable in
wastewater forms of U359: (1) incineration, (2) chemical oxidation followed by .carbon
adsorption, (3) chemical oxidation followed by biological treatment, and (4)
biodegradation followed by carbon adsorption. The Agency believes these standards will
ensure effective treatment (removal and destruction) of the constituent of concern.
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Table 7-1
Facilities that May Generate U359
by State and EPA Region
: .ฃ ^-^^"E^^-'^^^i
Oxy Petrochemicals, Inc.
Texas Eastman Co.
Union Carbide Chemicals and Plastics
''^'Jj&ca&on-'
Bayport, TX
Longview, TX
Seadrift, TX
EPA Region
VI
VI
VI
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Table 7-2
Summary of Available Characterization Data for U359
4" -' :- - '..' Matrix \.. f^-.' ."' ' ., '.-.
Laboratory Liquid Samples*
Unknown1*
U359 Organic Liquid6
U359 Untreated Water*
U359 Contaminated Soil6
:' :-\.>K'vChafacteriiatidii:b^ ..
100% 2-Ethoxyethanol
2-Ethoxyethanol (concentration NA)
Benzene (concentrations NA)
Cellosolve Acetate (concentrations NA)
4% 2-Ethoxyethanol
<0.1% 2-Ethoxyethanol
NA , '
NA - Not available
*Questionnaire response from Oxy Petrochemicals', Inc.
bQuestionnaire response from Union Carbide Chemicals & Plastics.
"Questionnaire response from Texas Eastman Company.
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8.0 ACKNOWLEDGEMENTS
Radian Corporation provided technical support for the development of this
document for the U.S. Environmental Protection Agency, Office of Solid Waste under
Contract No, 68-W9-0072. This document was prepared under the direction of Richard
Kinch, Chief Waste Treatment Branch; Larry Rosengrant, Section Chief, Treatment
Technology Section; and Angela Wilkes, Project Officer for the Radian contract. Lisa
Jones served as the Work Assignment Manager. Steve Silverman served as EPA legal
advisor.
The following personnel from Radian Corporation supported the
development of this document: Tom Ferguson, Program Manager; Mary Willett, Project
Director; and the Radian engineering team, Kurt Rindfusz and Robert Shark.
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9.0 REFERENCES
1. U.S. Environmental Protection Agency, Office of Solid Waste. Methodology for.
Developing BDAT Treatment Standards. U.S. Environmental Protection Agency,
Washington, B.C., June 1989.
2. American Public Health Association, American Water Works Association, and
Water Pollution Control Federation. Standard Methods for the Examination of
Water and Wastewater. Sixteenth Edition. Washington, D.C., 1985.
3. SRI International. 1990 Directory of Chemical Producers - United States of
America. Menlo Park, CA: SRI International, 1990.
4. U.S. Environmental Protection Agency, Office of Solid Waste. Listing
Background Document, 1,1-Piniethylhydr^^'ne (UDMH) Production from
Carboxylic Acid Hydrazides. U.S. Environmental Protection Agency, Washington,
D.C., 1990.
y
5. U.S. Environmental Protection Agency. Office of Solid Waste. Treatment
Technology Background Document. U.S. Environmental .Protection Agency,
Washington, D.C., June 1989. '* ,
6. U.S. Environmental Protection Agency. National Survey of Hazardous Waste
Treatment. Storage. Disposal. Recycling Facilities. U.S. Environmental Protection
Agency, Washington, D.C., 1986. ,
7. 'U.S. Environmental Protection Agency. Water Engineering Research Laboratory
(WERL} Treatabilitv Database. U.S. Environmental Protection Agency,
Cincinnati, Ohio, 1989. -
8. U.S. Environmental Protection Agency, Office of Solid Waste. Final Best
Demonstrated Available Technology (BDAT) Background Document for U and P
Wastes and Multi-Source Leachate (F039). Volume A; Wastewater Forms of
Organic U and P Wastes and Multi-Source Leachate (F0391) for Which There are
Concentration-Based Treatment Standards. U.S. Environmental Protection
Agency, Washington, D.C., 1990.
9. U.S. Environmental Protection Agency, Office of Solid Waste. Listing
Background Document for Dinitrotoluene. Toluenediaminp-, and Toluene
Diisocvanate Production. U.S. Environmental Protection Agency, Washington,
D.C., October 1985.
MLM/027
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10.
11.
12.
13.
14.
15.
16.
17.
U.S. Environmental Protection Agency, Office of Solid Waste. Final Best
Demonstrated Available Technology (BOAT) Background Document for U and P
Wastes and Multi-Source Leachate (F039). Volume C: Nonwastewater Forms of
Organic.U.and P Wastes and Multi-Source Leachate (F039) for Which There are
Concentration-Based Treatment Standards. U.S. Environmental Protection
Agency, Washington, D.C, 1990.
U.S. Environmental Protection Agency, Office of Solid Waste. Revised Listing
Background Document for Ethviene Dibromide Production. U.S. Environmental
Protection Agency, Washington, D.C, February 1986.
Kirk-Othrrier. Kirk-Othmer Encyclopedia of Chemical Technology. 3rd Edition.
Volume 4. John Wilev & Sons. Inc. New York. NY. 1978.
Alliance Technologies Corporation. RES (TXV EDB Test Burn Program-
Emissions Test Results. Volume 1. Bedford, MA, June 1988.
U.S. Environmental Protection Agency, Office of Water Regulations and
Standards. Development Document for EffluentJ .imitations Guidelines. New
Source Performance Standards, and Pretreatment Standards for the Organic
Chemicals and the Plastics and Synthetic Fibers Point Source Category.'
(Volumes I and n) U.S. Environmental Protection Agency, Washington, D.C.,
1987.
U.S. Environmental Protection Agency, Office of Solid Waste. Listing
Background Document for Ethylenebisdithiocarbamate Production and
Formulation. U.S. Environmental Protection Agency, Washington, D.C., October
1986.
U.S. Environmental Protection Agency, Office of Solid Waste. Revised Listing
Background Document for Methyl Bromide Production. U.S. Environmental
Protection Agency, Washington, D.C, October 1986.
U.S. Environmental Protection Agency. Federal Register. (Volume 51). U.S.
Environmental Protection Agency, Washington, D.C., February 25, 1986.
pp. 6537-6542.
MLM/Q27
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, Appendix A
TREATMENT TECHNOLOGY DISCUSSION
; Biological Treatment
Biological treatment (or Biodegradation) is a destruction technology in
which hazardous organic constituents in wastewaters are biodegraded. Types of
biological treatment include aerobic fixed film, aerobic lagoons, activated sludge,
anaerobic fixed film, rotating biological contactors, sequential batch reactors, and
trickling filter technologies. This technology generates two treatment residuals: a
treated effluent and a waste biosludge. Waste biosludge may be land disposed without
further treatment if it meets the applicable BOAT nonwastewater treatment standards
for regulated constituents. ' '
Carbon Adsorption ;
Carbon adsorption is a separation technology in which hazardous organic
constituents in wastewaters are selectively adsorbed onto powdered or granular activated
carbon. This technology generates two treatment residuals: a treated effluent and spent
activated carbon. The spent activated carbon can be reactivated, recycled, or
incinerated.
Chemical Oxidation .
" i -
Chemical oxidation is a treatment technology that may be used to treat
wastes containing organics and, in some cases, to treat sulfide and cyanide wastes. The
V.
basic principle of chemical oxidation is that some dissolved organic compounds, inorganic
cyanides, and sulfides are chemically oxidized to yield carbon dioxide, water, salts, simple
organic acids, and, in the case of sulfides, sulfates. The principal chemical oxidants used
are hypochlorite, chlorine gas, chlorine dioxide, hydrogen peroxide, ozone, and potassium
MLMAJ27 - .
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permanganate. Chemical oxidation generates an aqueous waste stream which is either
discharged! or transferred to another process for further treatment.
Chemically Assisted Clarification <
. . \. . '
Chemically assisted clarification, including chemical precipitation, is a
separation technology.in which the addition of chemicals during treatment results in the
formation of insoluble solid precipitates from the wastewater by settling, clarification,
and/or polishing filtration. This technology generates two treatment residuals: treated
wastewater effluent and separated solid precipitate, the solid precipitate would then
require additional treatment as specified by the nonwastewater BOAT treatment
" ^ "
standards.
Critical Fluid Extraction .
Critical fluid extraction is a solvent extraction technology in which the
solvent is brought to its critical state (liquified gas) to aid in the extraction of hazardous
organic constituents from the wastes. After the extraction step, the solvent is returned to
its normal gaseous state, generating a small volume of extract that is concentrated in
hazardous organic constituents. This technology generates two residuals: a treated waste
residual from which most of the contaminants are removed.and an extract The extract
may be recycled or may be treated by incineration.
Distillation
Distillation is the separation of a liquid mixture into various components by
a process of vaporization and condensation. As a treatment technology, distillation is
applicable to the treatment of wastes containing organics that are volatile enough to be
removed by the application of heat This technology generates an organic stream that
may be reusable, and a bottom stream that is often incinerated.
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Fuel Substitution
Fuel substitution is a destruction technology in which energy, as heat, is
transferred to the waste to destabilize chemical bonds and destroy organic constituents.
Fuel substitution differs from incineration in that the waste is used as a fuel in industrial
furnaces or boilers. Two residuals may be generated by the fuel substitution process:
ash and scrubber water. The Agency limits the use of fuel substitution as a method of
treatment to waste streams whose regulated constituents contain only carbon, hydrogen,
and oxygen in their molecular structure.
Incineration
..Incineration is a destruction technology in which energy, as heat, is
transferred to the waste to destabilize chemical bonds and destroy organic constituents.
There are different types of incinerators designed to accommodate different forms of ,
wastes. In a fluidized-bed incinerator, waste is injected into the fluidized-bed material
(generally sand and/or incinerator ash), where it is heated to its ignition temperature.
Heat energy from the combustion reactions is then transferred back to the fluidized bed.
Ash is removed periodically during operation and during bed change-outs.
. . .' \
In a rotary kiln incinerator, wastes are fed into the elevated end of the
kiln, and the rotation V the kUn mixes the waste with hot gases to heat the waste to its
ignition temperature. Ash is removed from the lower end of the kiln. Combustion gases
from the kiln enter the afterburner for complete destruction of organic waste
constituents. Other wastes may also be injected into the afterburner.
' . v' In a liquid injection incinerator, liquid wastes are atomized and injected
into the incinerator. In general, only wastes with low or negligible ash contents are.
amenable to liquid injection incineration. Therefore, this technology generally does not
generate an ash residual. .
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Combustion gases from the incinerator are then fed to a scrubber system
for cooling and removal of entrained particulates and acid gases, if present. In general,
with the exception of liquid injection incineration, two residuals are generated by
incineration processes: ash and scrubber water.
PACT* Treatment
i
PACTฎ treatment is a combination of carbon adsorption and biological
treatment in which hazardous organic constituents are biodegraded or selectively
adsorbed onto powdered activated carbon. This technology generates two treatment
residuals: a treated effluent and spent carbon/biosludge. The spent carbon may be
regenerated and recycled to the process or may be incinerated.
Reverse Osmosis
Reverse osmosis is a separation technology in which dissolved organics
(usually salts) are removed from a wastewater by filtering the wastewater through a
semipermeable membrane at a pressure greater than the osmotic pressure caused by the
dissolved organics in the wastewater. This technology generates two treatment residuals:
the treated effluent wastewater and the concentrated organic salt materials which do not
pass through the membrane. . , .
\ ' /
Solvent Extraction
Solvent extraction, including liquid-liquid extraction, is a separation
technology in which organics are removed from the waste due to greater constituent
solubility in the solvent phase than in the waste phase. This technology generates two
residuals: a treated waste residual and an extract. The extract may be recycled or may
be treated by incineration.
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Stripping Treatment
Stripping treatment is a separation technology. Steam stripping is a
technology in which wastewaters containing volatile organics have the organics removed
by application of heat using steam as the heat source. Air stripping is a technology in
i
which wastewaters containing volatile organics have the organics removed by
volatilization. This technology generates one treatment residual: treated effluent.
Emissions from stripping treatment may require further treatment.
Wet Air Oxidation
:' - \
Wet air oxidation, including supercritical oxidation, is a destruction
technology in which organic constituents in wastes are oxidized and destroyed under
pressure at elevated temperatures in the presence of dissolved oxygen. This technology
is applicable for wastes comprised primarily of water and up to 10% total organic
constituents. Wet air oxidation generates one treatment residual: treated effluent. The
treated effluent may require further treatment for hazardous organic constituents by
carbon adsorption. Air emissions from wet air oxidation may require further treatment
by incineration.
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Appendix B
ACCURACY CORRECTION OF DATA
1 * ' i
The treatment performance data and detection limit data used to
determine treatment standards were adjusted to account for analytical interferences
associated with the chemical matrices of the samples. Generally, treatment performance
data were corrected for accuracy as follows: (1) a matrix spike recovery was determined
for each BOAT List constituent; (2) an accuracy correction factor was determined for
each of the above constituents by dividing 100 by the matrix spike recovery (percent) for
that constituent; and (3) treatment performance data or detection limit data for each
BOAT List constituent were corrected by multiplying the data for each constituent by its
corresponding accuracy correction factor. The procedure for accuracy correction of the
data is described in further detail below.
Matrix spike recoveries are developed by analyzing a sample of a treated
waste for a constituent and then re-analyzing the sample after the addition of a known
amount of the same constituent (i.e., spike) to the sample. The matrix spike recovery
represents the total amount of constituent recovered after spiking, minus the initial
concentration of the constituent Duplicate matrix spikes were performed for some
BDAT List constituents. If a duplicate matrix spike was performed for a constituent, the
matrix spike recovery used for that constituent was the lower of the two values between ,
the first matrix spike and the duplicate spike.
i * k
In cases where a matrix spike was not performed for a waste constituent in
the treatment test from which the detection limit was taken, the matrix spike recovery
from a similar constituent from the treatment test was transferred to the constituent
Matrix spike data for chloroform was transferred from the matrix spike recoveries for
trichloroethylene in the same incineration test The matrix spike for trichloroethylene
was 100%, resulting in an accuracy correction factor of 1.
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For some constituents, treatment performance data were transferred from
F, D, or K wastes. In these cases, when a matrix spike was not performed for a
particular constituent, the matrix spike recovery for each constituent was derived from
the average matrix spike recoveries of the' appropriate analytical fraction (e.g., volatile or
semivolatile organics) for which recovery data were available. First, the matrix spike
recoveries for all volatile or semivolatile organic constituents from the first matrix spike
were averaged. An average matrix spike recovery was then calculated for the duplicate
matrix spike recoveries. The lower of the two average matrix spike recoveries was used
to calculate the accuracy correction factor for the constituent
An accuracy correction factor was determined for each constituent by
dividing 100 by the matrix spike recovery (percent) for that constituent. An accuracy
correction factor of 1.00 was used when both the matrix spike and duplicate matrix spike
recoveries exceeded 100 % to ensure the data were not adjusted to concentrations below
the detection limits. Matrix spike values of less than 20% are not acceptable and were
not used to correct detection limits, nor included in calculating average matrix spike
recoveries. , .
^ . . .
Table B-l presents the accuracy correction of data from the ethylene
dibfomide (EDB) incineration test Accuracy correction factors used for each waste
code are presented in Sections 4 and 6.
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if
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m
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s
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' : .. . Appendix C
VARIABILITY FACTOR CALCULATIONS
A variability factor (VF) accounts for the variability inherent in the
treatment system performance, treatment residual collection, and analysis of the treated
waste samples. Variability factors are calculated as described in EPA's Methodology for
Developing BOAT Treatment Standards (1).
Original effluent data points were not always available; therefore,
variability factors for some constituents were not calculated as described in Reference 1.
For example, WERL effluent data were presented as averages in the WERL database,
and therefore, it was not possible to calculate an individual variability factor for these
constituents since actual effluent data points were unavailable. For volatile and
semivolatile' organic constituents where a variability factor was unknown or could not be
calculated, an average variability factor was used. The average variability factors were
generated from the BAD variability factors and are specific to the type of constituent
under consideration (i.e., volatile organic, base neutral extractable semivolatile organic,
etc.). The average volatile organic variability factor is an average of the sum of volatile
variability factors from BAD data as shown in Table C-l. The average base neutral
extractable semivolatile organic variability factor is an average'of the sum of base neutral
semivolatile variability factors from BAD data as shown in Table C-l. Determination of
this average variability factor is similar to the procedure used by EPA in the BOAT land
disposal rule in the past to determine average accuracy correction factors. .
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Table C-l
Variability Factor Calculation for Volatile Organics
','.--. ; "*'' Volatile Organics .;;"";:; S^T^S
Acrylonitrile .
Jenzene
Chloroethane
Chloroform
Chlorometharie
.,1-Dichloroethane
,2-Dichloroethane
1,1-Dichloroethene
trans- 1,2-Dichloroethene
Vlethylene chloride -
fetrachloroethylene
fohie&e .
,1,1-Trichloroethane
,1,2-Trichloroethane
rrichloroethylene .
Vinyl chloride
Average
Average VF for Volatile Organic
EAD VariabUity Factor
4.83045
13 .5252
5.34808
3.71334
3.79125
5.88383
8.22387
2.4723
534808
3.86915
534808
7.9506
\
534808
534808
534808
534808
5.7310
5.7
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Table C-2
Variability Factor Calculation for Base Neutral Extractable
Semivolatile Organics
Base Neutral Extractable Semivolatile Organics
Acenaphthalene
Acenaphthene
3enzo(a)anthracene
3enzo(a)pyrene
3enzo(k)fluoranthene
Bis(2-ethylhexyl)phthalate
Chrysene
Diethyl phthalate
Dimethyl phthalate
Di-n-butyl phthalate
Fluoranthene
Fluoranthene
^uorene
Naphthalene
Nitrobenzene
'henanthrene
'yrene
Average
Average VF for Base Neutral Extractable
Semivolatile Organics
BAD; Variability OFactdr
5.89125
5.89125
5.89125
. 5.89125
5.89125
5.89125
5.91768
5.89125
-4.75961
4.63833
3.23768
5.89125
5.89125
5.89125
4.83045
5.89125
5.89125
5.5340
5.5
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