United State*
Environmental Protection
Agency
Solid Waste and
Emergency Response
(630BW)
EPA530-fl-97-038
    77 497
  1991
Background Document
for First Third Wastes
to Support 40 CFR Part
268 Land Disposal
Restrictions (Final Rule);
Addendum: Capacity Analysis
for K061 Wastes
      Printed on paper that contains at lest 20 percent postconsumer fiber

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  Addendum To The Background Document
                   For
  First Third Wastes To Support 40 CFR Part
       268 Land Disposal Restrictions

                Final Rule

     Capacity. Analysis For K061 Wastes
United States Environmental Protection Agency
           Office of Solid Waste
            401 M Street, N.W.
          Washington, D.C. 20460
               August 1991
                                                 005420
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       This document is an mfdcndum lo the background document for the First Third wastes 10
support the 40 CFR Pan 268 Land Disposal Restrictions. This document updates the capacity
analysis for K061 wastes based on the new treatment standards established for high zinc K061 and
c:i more recent information received by EPA on high zinc K061 generation, management, and
treatment. The purpose.of this document is to provide information' to support EPA's
determination that adequate  treatment capacity exists for high zinc K061 wastes. EPA notes'that
the analysis is in some ways academic, given that the time for granting national capacity variances
for K061 ended in August  1991. (See RCRA section 3(XM(h)(2).]  Nevertheless, the information
on capacity should be useful  to the regulated community.

       This rule establishes new treatment standards under the land disposal restrictions for high
zinc K061 wastes.  EPA has determined that sufficient treatment capacity exists to treat these
wastes. Although EPA has established numeric ircaimcr; standards for high zinc K061 based on
the performance of high temperature metals recwcry (HTMR), the Agency does not preclude
the use of other treatment technologies that can meet the numeric standards established for this
waste. In conducting this capacity analysis for high zinc K061 wastes, the Agency has confirmed
the earlier estimates for generation volumes of high zinc K061 and again determined that there is
sufficient available treatment capacity for these wastes.

Background

       K061 is emission control dust/sludge from the primary production of steel in electric arc
furnaces.  Treatment standards for nonwawwatcr  forms of KQ61 were promulgated  as part of the
First Third final rule on August 8,1988. Two subcaicgories of nonwasiewater forms of K061
were defined: the low zinc  subcatcgory (less than 15 percent zinc)  and the high zinc subcategory
(greater than 15 percent).  The treatment standard lor the low zinc subcategory was based on
stabilization.1  For the high zinc si bcategory, the final standard was "No Land Disposal Based on
High Temperature Metals Recovery as a Method of Treatment" {53 FR 31221). Due to a
shortage in HTMR capacity,  the effective date was delayed until August, 1990. An interim
numerical standard based en  the performance of stabilization technology was in effect until that
time. The Third Third proposed :iile requested comments on the  possible extension of the
interim standard for high zinc K061 for one additional year (54 FR 4S457). Responses from
industry indicated that HTMR processes were being built but would not be available by August,
1990. Therefore, EPA extended the interim treatment standard for an additional year until
August. 1991. At that point, the standard of "No Land Disposal Based on HTMR". would go into
effect.

       In the Third Thud proposed rule, EPA also proposed to amend the existing treatment
standard for high zinc K0<51 waste* to he resmdu'nj-in 3 HTMR furnace.  Hwrupr,  since 'he-
existing standard was  under review by the District of Columbia Court of Appeals, EPA decided
not to amend the standard  in the Third Third rule. The  Natural Resources Defense Council,
                  'Low zinc K061 wastes arc net addressed in this rule and arc therefore not included in this
               background document.

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                                                                         005422
 Chemical Waste Management. Inc., and the Hazardous Waste Treatment Council claimed EPA
 unlawfully exempted the slag residues thai result from the "treatment" of K061 in zinc smelters
 f-om ihc Land Disposal Restrictions.  EPA had determined in the First Third rule that it lacked
 Vie authority to establish any treatment slan-Jardi for ihc slag residues that rauli from ihi!y. However, the Court held thst tl'A had incorrectly -interpreted its statutory authority
 nnd remanded the issue for further consideration.

        This rulemaking is in response to the Court's remand. EPA has determined that K061
 slag is subject to RCRA regulations. In addition, the Agency has established new treatment
 standards for high zinc K061 wastes based on the performance of HTMR.

 Response to Comments

        In the proposed rule, EPA recognized that generation and management of K06! wastes
 and the amount of available treatment may have changed since the capacity analysis for K061  was
 conducted for the First Third rule.  Therefore, the Agency requested additional information on
 tie generation and management of high zinc K06I wastes and the capacity of processes that can
 treat these wastes. Six commented focused on  HTMR capacity issues: Armco Advanced
 Materials Company, the Steel Manufacturers Association, the Specialty Steel Industry of the
 United States. Waste Management Inc., the American Iron and Steel Institute, and International
 Mill Service Inc..  Four commenters noted that  there are other treatment processes besides
 HTMR that can meet the numeric treatment standards: Encycle. Michigan Disposal, Conversion
 Systems Inc., and Zinox.  The information received was used to update the analyses presented
 below.                                                     /

 Waste Generation

        For the First Third rule, data from EPA's National Survey of Hazardous Waste
 Treatment, Storage, Disposal, and Recycling Facilities (TSDR Survey) was used to estimate that
 83.1 million  gallons (345,000 tons) per year of K061  (both-high and low zinc) would require
 alternative treatment capacity (53 FR 31193). Data initially received from commenters on the
 first Third proposed rule indicated  that approximately 75 percent of K061 waste contained  15
 percent or more total zinc.  Therefore, according to TSDR data 62 million gallons (260,000 tons)
.per year of high zinc K061 would require treatment capacity. However, this figure may be ah
 underestimate of high zinc K061 generation.

       Two other sources have provided the Agency with data on the generation of high zinc
 K061. The Horsehead Resource  Development Company (HRD), the primary commercial facility
 currently recovering zinc from K061 wastes using HTMR, estimates that approximately 415,000
 tons of high zinc K061 will be generated in 1991.

       The American Iron and Steel Institute (AISI), which represents most  of the generators of
 KG61, estimates that approximately 20' pounds of K061 are generated per ton of steci that is
 produced {i.e., a waste-to-product ratio of 1 percent.)  According to AISI, steel production in
 1989 was approximately 98 million tons. Approximately 35 million tons (36 percent) of all steel is
 produced is electric arc furnaces.  Therefore, using the estimated waste-to-product ratio of 1
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               percent, approximately 350.000 tuns of KOfil w.-ir. pcncratcu in  1989.  High zinc K061  is generated
               during carbon steel production. Since carbon MIT) accounts for SI percent of the steel produced
               in electric arc furnaces, the volume? of high zinc K'Cil produced in 1W!9 was approximately
                                                                                                               8--B
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                      Since there is .3 {ftsfwpnncy in'irK' c%iii*;;ii(". .-if hii;h /inc Kflfil  veneration, for the
               purposes of this capacity analysis, the highest ligurc. 4I5.(KK) tons, was used to estimate ihc
               volume of high zinc K06J requiring treatment.

               Current Management Practices       ,                            .

                      AISI estimates that most high zi'nc K06! th;it is treated (about  9u percent) currently goes
               through HTMR..  Tne volume of high zinc K061 being stabilized anci zabsequentty land disposed is
               therefore low.  The Agency believes that this mjy bt due to the existing incentives to recycle high
               zinc K061.  Stabilization and landfilling costs are tisph, and sonic states have provided lax
               incentives not to land dispose hazardous wastci. Thus, the generators  of high zinc K061 that are
               treating their waste are doing so primarily by rveyclinj; their wastes through HTMR.

                        HTMR Caaacitv
       The currently available HTMR capacity is estimated to be 533,000 tons per year.  In
addition. 40,000 tons of HTMR capacity is expected to become available by August. 1991. The
following facilities account for the available capacity:

       •      Three Horsehead Resource Development plants are currently operating with a
              lota! annual capacity of 455,000 tons.  HRD confirmed that capacity at their
              Palmerton. Pennsylvania plant is 265.000  tons per year, capacity at their Calumet.
              Illinois plant is 90,000 tons per year, and  indicated that their new Rockwood
              Tennessee plant is now operational with a capacity of 100.000 tons rather than the
             . expected capacity of 80,000 ;cr,r, reported in the proposed rule.

       •      Internationa! Mill Services is currently operating two thermal dust trsaimcnt plants
              with a combined yearly capacity of 18.000 tons.

       »      Zia Technology has a zinc recovery facility Capable of processing 60.000 tons per
              year of high zinc K061.  Zia has ihe potential io process up to 90,000 tons of KOfil
              per year (they are currently permiuc.-! for 60.000 tons). Their process can handle
              both low and high zinc, but there  is a penalty for low zinc.

       •      Laclede Steel Company has contracted with Elkem to construct a HTMR furnace
              wilh an annual capacity of 40.000  tons per year. This furnace should be operable
              in  August, 1991.
               August, 1991.
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Available Mubilijuiinii Capacity
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       Thecurrcm'y available stnbiiizaiicn cap;id!y reported irs iha Third Third llfjiii rust is
approximately 1.3 million tons per year (55 FR 22635). However, greater capacity for treating
K061 may now be present. For example, Michigan Disposal. Inc. claims that chemical fixation
and stabilization techniques can meet thp K0<5! treatment standards.  Mkhi»b« Disposal's current
SiarrlSizaJirm capacity for high zinc KOftl  is apnrnvimately-100,000 tons per year.  Ariciiiionallv.
Cheni Waste Mjsnagemenl and Peoria Conversion Systems may also have stabili/.iition capacity,  •

Kxtractiyc Metallurgy Capacity

       In addition to HTMR and stabilization, other effective techniques may be present to treat
high zinc K061 waste. For example, Encycle indicates their metal recovery process can treat K051
wasie. Their .current treatment capacity is approximately 30,000 tons  per year, and this capacity is
expected to increase to 60,000 tons within a year.  Encycle typically recovers zinc and either
stabilizes the iron residue or sends it off site as feed. Trier,  nay be additional facilities that can
treat high zinc K061 with extractive metallurgy processes.

Capacity implications

       Based on the data  presented above, sufficient HTMR capacity exists to handle the 1991
demand £r>r zinc recovery from K061 wastes. There is also available stabilization and extractive
metallurgy capacity  thai can meet the treatment standards. Therefore, the Arency has
determined that there is sufficient capacity to handle the volumes of high zinc K061 requiring
treatment under the Land Disposal Restriction.                                •
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Conlacfc      Thomas J;wieek, Director of Government and Regulatory Affaire       UUO1«C*>

Company:     Horsehcnd Resource Development (HRD) and
              Zinc Corporation of America (ZCA)

Phone:       412-77-1-1020

Date:         12/06/90

Caller:        James Hsu

General Facility Information

       Horsehead Resource Development (HRD) and Zinc Corporation of America (ZCA)
operate pyrolitic metal recovery facilities in Palmcrtori, Pennsylvania, and Calumet, Illinois. These
processes are used primarily to recover zinc from K061 waste.  A ?.inc recovery facility in
Rock-wood, Tennessee, is cvpcctcd to cor.ic on line in 1991.

Metals Recovered

       HRD recovers zinc from K061. Mr. Jancck indicated that their process can efficiently
recover zinc from KG61 having a zinc conccmraiion higher man 10 percent.

Process Information

       HRD's zinc recovery process docs not cxtrnci nickel and chromium.  Therefore, HRD
blends high/nickel/high chromium K061 (generated from stainless and specialty steel
manufacturing) with low nickel/low chromium K061 (from carbon steel manufacturing) so that the
resultant slag passes the TCLP for nickel and chromium.  Mr. Janeck indicated that INMETCO
processes most of the high nickel/high chromium K0614>ccausc they extract the  nickel and
chromium.  INMETCO's process concentrates zinc in the baghouse dust which is then sent to
HRD for zinc recovery.

       Mr. Janeck also indicated that  the stag from the HRD process meets the stabilization
standard set for low zinc K061.

       Since fluxes and rcductahls are added to the process, there is no significant K061 volume
reduction as a result of zinc recovery.                                        ,

K061 Generation and Recovery Capacity

       HRD marketing studies suggest mat the generation of KCoi  wiii increase by approximately
six percent from 1990 to 2000.  KQ61 generation is projected to be approximately 500,000 tons in
1991 (this quantity does not include the low zinc, high nickel/high chromium K061, which is
estimated to be 10 to 20 percent of the high zinc, low nickel/tow chromium quantity).
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                                  Phone Log (continued)
       KRD'S cslimalc of available I1TMR capacity in 1991 is:
              HRD (Palmerton, PA)
              HRD (Calumet, 1L)
              HRD (Rock-wood. TN)
              Zinc Nationale (Mexico)
              Zia Tcchnoloey (Texas)
              Elkcm
265,000 tons/year
 90,000 tonsftear
 80,000 ions/year
 50,000 tons/year
 40,000 tons/year
 40,000 tons/year
                                                                          00542G
              Total 1991 Capacity
565,000 tons^ear
Waste Management
Ijecause:
       Mr. Janeck indicated that there is a strong incentive Jo recycle the high zinc K061
       (1}    Stabilization and landfilling costs arc high;

       (2)    Generators prefer recycling because it eliminates their long-term
             liability: and

       (3)    Some states (e.g., California) have provided tax incentives not Jo
             land dispose.
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 Contact:      John Onuska, Director of Marketing

 Company:     INMETCO

 Phone:       412-758-2210                                                UUo4
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Contact:       Bob Kiitun, VT of Snier. ;in
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             Subject:
I'coriii Disposal Company. Peoria. II.
309-68S-0760
l/25/')l
James IIsu
                                                    005430
                   Mr. Gene Mnllhcws indicated that Pccria Di.^xiMil Company processes only low zinc.
             KOS1.  He estimales thai Pcoria processed approximately 27.000 ions of low zinc K061 in 1990.
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                                                      I'hiinc Log
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Chcm Waste Management
70S-218-1500
\nsrn                 '       .
James Hsu
Stabilization of K061 and Status of Proposed HTMR Facility
00543.1
                      Mr. Herbst indicated that Chem Waste Management (CWM) stabilizes predominantly tow
               zinc K061. He does not have information of how much high zinc K061 CWM processes, hut be
               acknowledged that CWM processes very little high zinc K061.  CWM has stabilization capacity at
               their Indiana and Alabama facilities to process K061.

                      In the KQ61 background document, CWM submitted a letter to EPA indicating their
               interest in building a high temperature metals recovery (HTMR) facility in the Jackson,
               Mississippi area that could manage up to 100.000 tons of K061 per year.  Mr. Herbst  indicated
               that the HTMR project has been put on held, but declined to provide the reason for putting the
               project on hold.
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              Contact:      Robin Faihi-nihal
              Coinpr.nv     HcriuKC Envirc-nmcniai Sc:vic^, 1;.^..  iijJi.snapo!ix IN
              Phone:       317-243-OSIT
              Date:         1/25/91
              Caller        James Hsu
              Subject:       Stabilization of KOoi
005432
                     Ms. Fathcnthal indicated that Heritage manages very little K061. She estimates that in
               1990, Heritage stabilized approximately 5.-400 tons of K061.  Ms. Fathcnthal does not know
               whether this quantity is high zinc or low zinc K061.
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          Coniaci:       Brian Corrcn
          Company:     U.S. Pollution Cor.irol Inc.. OK
          Phone: "      405-697-3236
          Dale:         1/24/91
          Caller:        James Hsu
          5 ubject:       Stabilization of K061
00543-3
                 Mr. Correa was not authorized to answer qucMions on K061 stabilization. Ke asked thai
          ve provide the questions in writing to:

                       Mr. Randy Miller (USPCI)
                       515 West Greens Rd.
                       Suite 500
                       Houston, IX 71067.

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Conuics:
Compaity:
Phone:
Dale:
Caiicr:
Subject:
                                                      J'hunc 1

                            Bah Desco. M;m.igcr of Opcr;iiions
                            Deroco. Inc.
                            216-5<>6-019()
                            .VlS/Vl
                            James Hsu
                            Management of K061
0 Of)
                     Dereco Inc. collects and recycles J&L Specialty Products Corporation's stainless steel
              baghousc dust (typically low zinc dusts). Dcreco periodically recei\'es bleed-off baghouse dust
              from JiL. and recovers the zinc and lead from the dust using a high-temperature kiln.  The
              recovered product usually contains 65 peicent zinc oxide and 3 percent lead oxide, and is sold to
              zinc smelters.  Rcsidu?.] from the high-temperature kiln is recycled back to the J&L smeller.

                     Mr. Desco indicated that Dereco recycles  14,000 tons of J&L's baghoase dust per year. This
              arrangement eliminates ihc need for J&L to ship K061 off site for management.  Dcreco is currently
              negotiating with LTV Sice!  lo set up a Minihir recycling arranucmeni.
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                 Phone:

                 Date:

                 Caller:

                 Waetz Kiln
                                       I'honc Log


              John Cigan

              Horsehead Resource Dcvt-lopmcRi (HRD)

              215-826*719

              5/21/91

              James Hsu
005435
       Mr. Cigan staled that data used for the BOAT was only one trial using high zinc K061.
Waelz kilns are large units used to hand!e'K061 from generators in the region. The variability in
K061 allows HRD to blend the feed to meet the TCLP standards.  However, HRD may have
problems achieving the vanadium and thallium (and other trace metals) standards because the
BOAT standard was set using an atypical process input. Mr. Cigan indicated that low zinc K061
is mixed with high zinc K061 to achieve the optimal feed, which has to be 20 percent zinc by
weight  Me also reported that the Rockwood plant will be operational by August 1991.

Flame Reactor

       This process targets a different K()61 market than the Waelz kiln. Flame reactors are
designed to be constructed on-site at arc furnaces to process the K061 dust The flame reactor is
restricted to handle one to three sources of dust. Because the process is different (i.e., slag is
different) than the Waelz kiln and the design arrangement does not allow blending of K061; the '
Ocir.c reactor may not achieve the TCLP standards.

K06I Generation

       Mr. Cigan revised Thoma* Jdncck'i csUmaic of the generation of high zinc K061 wastes
from 550,000 tons per year to 415,000 Ions per year.
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                             John Cig<*n



                             Horschcad Resource Development (HRD)



                             215-826-8719



                             5/22/91



                             Mario Kcrby
00543G
       The capacity at the Rockwood, IL facility is 100,000 ions per year. HRD confirmed the

available capacity at other HRD facilities. In 1990. 77 percent of the K061 processed was high

zinc and 23 percent was low zinc.
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              Contact:       Gasi George

              Company:     Wayne Dwjwwal, Michigan

              Date:         5/23/91

              Caller:        Mario Kcrby
00543'
                     Wayne Disposal was handling large volumes of K061 before the rule.  After the rule, they
              lost half of their K061 business.  Wayne believes that EPA should go with the delisting numbers.
              The wastes they currently stabilize include F006. TTwir stabilization capacity is 5 million gallons a
              month (200,000 yd-). Forty percent of their total capacity could be dedicated to K061. They are
              currently treating 1,500-2,000 yd3/inonth (conversion factor of 4,000 Ibsftd3).
                     They will gladly submit data upon  a written request.
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               Contact:

               Company:

               Phone:

               Date:

               Caller:
              Norm Kotraba

              Zia Technology

              409-567-7777

              5/21/91

              James Hsu
                                                                                                                      i   3 ^.
005438
       Mr. Kotraba stated that the TCLP should not affect 'Zia Technology because they don't
landplace any residuals. Their process effluents arc: prime Western grade zinc; Rennelt lead
bullion: and direct reduced iron pellet {sent to arc furnaces as raw materials).

       They are in semi-production mode and arc expected to begin coramercia! production by
July 1991. Their process can handle low and high zinc K061, but there is a penalty for Jow zinc
They currently find it difficult to get a steady stream of KQ61  to keep their process in operation.
If they can get a sufficient flow of K061, the Zia process «n  potentially process 85,000 to 90,000
tons of KOSlftear (they are permitted 60,000 tons/yr).  Much  of this information was presented at
a recent EPASMA meeting.
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               Contact:

               Company:

               Date:

               Caller:
                            Rotiert Qdie

                            Encyclc

                            5/22,91

                            Mario Kerby
                                                                                             005439
                                                                                                                            till
                      Mr. Odie indicated thai available capacity for K061 depends on what they choose to
               process.  The firm has the capacity to process solids of up to 5,000 tons per month. They
               currently recover zinc. The process they use produces pyrrhic hydroxide as an end product which
               can be used as a reducUsril and can be used as a feed.  In general, the Firm uses higher zinc
               content materials. At present, most of their capacity is taken up by other wastes. They are
               planning  to take iron liydrOxkJv wasie and make it into some other compound since for these
               wastes the BOAT was not clear.  There is no residue generated from the hydrometallorgical
               process.  The other option is to recover zinc and stabilize the iron residue. The firm would like
               the regulations written in such it way ths« they can help.
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                                        APPENDIX A


                                  K061 Capacity Ann lysis for the

                                     First Third Kitiiit Rule
                                                                                             o

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                                                               005441
    RCRA hazardous  waste K06!  is  descried  as  emission  control
dust/sludge from the primary production  of  steel  in  electric  furnaces.
K061 is listed as a hazardous  waste ui.'i.du&e of tfcs presence of hexavsler.t
chromium, lead, and cadmium.  For K061 containing £1S percent zinc  (high
zinc K061), the Agency has identified the BOAT technology to  be high
temperature metals  recovery.  For K061 containing 5 percent of  the K061  requiring alternative
treatment is high zinc K061.  Table 2-23 shows the volumes of K061  waste
identified by the Agency as requiring alternative treatment.  •
    One waste stream reported in the TSDR Survey  (67,920 gallons) was
reported as a mixed K061 and K062 stream.   After  reviewing the survey
information, it was determined that the  waste  stream had been'received
from an offsite fac'ility and was directly  landfilled.   Because of this
information and the characteristics of the  waste  codes  involved, the
Agency assumed that the waste stream is  an  inorganic solid.   The Agency
believes that these wastes will likely be  segregated upon promulgation of
the land disposal restrictions and, therefore, will  no  longer be
generated as a mixed waste  stream.  To conservatively estimate the
volumes of K061 and K062 that will require  alternative  treatment, the
                                A-l
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                                                                                                          005442
                                                  iable ^-:•   Capacity Unalyiis for kOSl*
                                  Type of alternative
                                  treatment/recovery
1963 volume needing
alternative capacity
{gallons/year)
                                  High tensperature metjIs recovery

                                  Stabilization
                                                                                    E.'.3i?.?26
                                                                           Total     83.142.S6S
                                  £8»elir,e voltes ctita from TSD9 Sur«ey for  1966 [facility  responses  as
                                   cf July IZ.  1?66).  Volume! do not include  underground injection
                                   qgartitiei or  contaminated soils.
                                                                   A-2
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                                                                  00544,;
 entire  volume of this waste  stream was assigned to the BOAT technologies
 for  both K061 and K06Z, with no resulting  impact on capacity variance
 determinations for those wastes (see below).
     The Agency believes that sufficient high-temperature metals recovery
 capacity does not exist for  high zinc K061.  For the proposed rule
 (R~f.4  Aef. 11), EPA analyzed the length  of the required to install a
 BDA". treatment system for K061 waste.  Based on this analysis,  EPA
 estimates that a BOAT treatment system could be constructed within two
 years.  This estimate does not include the time required for preparation
 and  approval of RCRA and/or State permit applications because high
 temperature metal -recovery is considered recycling, zrtd as such,  is
 exempt  from RCRA permitting.
     Therefore, the Agency is granting a 2-year national capacity  variance
 from the ban effective date for KOol wzstes requiring high temperature
 metals  recovery,  however, the Agency 4s sett  .j an interim standard for
 high zinc KOol based on stabilization.
     Several commenters were concerned that commercial facilities  with
 available stabilization capacity were not permitted specifically  for K061
waste.   However, review of the TSDR Survey data indicates that  there is
 approximately 205 million gallons of existing (not planned) available
capacity at facilities that accepted K061 for stabilization in  1986 or
 said they would accept K061 for stabilization.   These facilities  included
GSX  Services of South Carolina, Pcoria Disposal Inc., and several CBI
                                 A-?
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     14
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 •'.*
 :|
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  1
                                                             005444

facilities.  Because  they have accepted K061 for stabilization  in the    "~
piit,  the Agency assumes the faci'hiies were permitted to stabilize K061
wastes.
                                                                   .»
    Based on the information in the  ISDK Survey,  the Agency believes that
adequate stabilization capacity exists for t. gh  zinc and low zinc K051.
Therefore, the Agency is not granting a capacity  variance from the ban
effective date for K061 wastes based on stabilization.
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