EPA/530-SW-88-031Q
                    FINAL
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)

           BACKGROUND DOCUMENT FOR

                     K022

              (Non CBI Version)
            James  R.  Berlow,  Chief
         Treatment Technology Section
                 Jose  Labiosa
               Project Manager
     U.S.  Environmental  Protection  Agency
            Office of Solid Waste
              401  M  Street,  S.W.
           Washington, D.C.  20460
                 August 1988

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                             TABLE OF  CONTENTS


Section                                                              Page

EXECUTIVE SUMMARY 	    vi i

1.   INTRODUCTION 	    1-1

1.1    Legal Background	    1-1
       1.1.1    Requirements Under HSWA	    1-1
       1.1.2    Schedule for Developing Restrictions	    1-4
1.2    Summary of Promulgated BOAT Methodology	    1-5
       1.2.1    Waste Treatability Group. ..•	    1-7
       1.2.2    Demonstrated and Available Treatment
                Technologies	    1-7
       1.2.3    Collection, of Performance Data	   1-11
       1.2.4    Hazardous Constituents Considered and
                Sel ected for Regul at i on	   1-17
       1.2.5    Compliance with Performance Standards	   1-30
       1.2.6    Identification of BOAT	   1-32
       1.2.7    BOAT Treatment Standards for "Derived-from"
                and "Mixed" Wastes	   1-36
       1.2.8    Transfer of Treatment Standards	   1-40
1.3    Variance from the BOAT Treatment Standard	   1-41

2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 	    2-1

2.1    Industry Affected and Process Description 	    2-1
2.2    Waste Characterization 	    2-5

3.   APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES  	    3-1

3.1    Applicable Treatment Technologies 	    3-1
3.2    Demonstrated Treatment Technologies 	    3-1
       3.2.1    Fuel Substitution 	    3-3
       3.2.2    Incineration 	   3-19
       3.2.3    Stabilization 	   3-38

4.   PERFORMANCE DATA BASE  	    4:1

4.1    Nonwastewater 	    4-1
       4.1.1    BOAT List Organics  	    4-1
       4.1.2    BOAT List Metals 	    4-3
4.2    Wastewater  	    4-4
                                     11

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                      TABLE OF CONTENTS  (Continued)


Section                                                              Page

5.  IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
    (BOAT) 	    5-1
5.1    Nonwastewater 	    5-1
       5.1.1    BOAT List Organics 	    5-1
       5.1.2    BOAT List Metals	    5-2
5.2    Wastewater 	    5-3

6.  SELECTION OF REGULATED CONSTITUENTS	    6-1

6.1    Identification of BOAT List Constituents in the
       Untreated Waste 	    6-1
6.2    Constituent Selection 	    6-3

7.  CALCULATION OF BOAT TREATMENT STANDARDS 	    7-1

7.1    Nonwastewater 	    7-1
7.2    Wastewater 	    7-2

8.  ACKNOWLEDGMENTS 	    8-1

9.  REFERENCES  	    9-1

APPENDIX A  STATISTICAL METHODS 	    A-l

APPENDIX B  ANALYTICAL QA/QC 	    B-l

APPENDIX C  DETECTION LIMITS FOR TESTED WASTES	    C-l

APPENDIX D  METHOD OF MEASUREMENT FOR THERMAL CONDUCTIVITY 	    D-l
                                    111

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                              LIST OF TABLES


Table                                                               'Page

1-1          BOAT Constituent List 	,	   1-18

2-1          Facilities That Produce Phenol and Acetone from
             Cumene--by State and EPA Region 	    2-2

2-2          Constituent Analysis of Untreated K022 Waste 	    2-6

2-3          BOAT Constituent Concentrations and Other Data 	    2-7

4-1          Design Data for Use of K022 as Fuel in an
             Industrial Boiler at Plants 1 and 2 	    4-5

4-2          Concentration Data for Untreated K022 Waste from
             Plant 1 	    4-6

4-3          Concentration Data for Treated Residual (Ash for
             K022) at Plant 1 	    4-7

4-4          Concentration Data for Untreated and Treated
             Residual K022 Waste at Plant 2 	    4-8

4-5          Performance Data for Stabilization of F006 Waste  	    4-9

5-1          TCLP Performance Data for Stabilization of F006 Waste
             After Screening and Accuracy Correction of Treated
             Values  	    5-4

6-1          Status of BOAT List Constituent Presence in Untreated
             K022 Waste 	    6-5

6-2          Regulated Constituents for K022 Waste  	    6-12

7-1          Calculation of Nonwastewater Treatment Standards
             for the Regulated Constituents Treated by Fuel
             Substitution  	    7-3

7-2          Calculation of Nonwastewater Treatment Standards  for
             the Regulated Constituents Treated by Stabilization  .    7-4
                                     IV

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                        LIST OF TABLES (Continued)


Table                                                                Page

A-l          95th Percentile Values for the F Distribution  	    A-2

B-l          Matrix Spike Recovery Data for Kiln Ash Residuals
             from PI ant 1 	    B-3

B-2          Matrix Spike Recovery Data for Kiln Ash Residuals
             from PI ant 2 	    B-4

B-3          Matrix Spike Recovery Data for the TCLP Extracts
             from Stabilization of F006 Waste 	    B-5

B-4          Accuracy-Corrected Performance Data for
             Stabilization of F006 Waste  	    B-6

B-5          Analytical Methods for Regulated Constituents
             Analysis  	    B-8

B-6          Method Modifications Used to Analyze K022 Untreated
             and Treated Samples  	    B-9

C-l          Detection Limits of  BOAT List Constituents in  K022
             Untreated Waste for  PI ant 1  	    C-2

C-2          Detection Limits of  BOAT List Constituents in  Kiln
             Ash for Plant 1 	    C-9

C-3          Detection Limits of  BOAT List Constituents Analyzed
             in K022 Waste from Plant 2 	   C-16

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                              LIST OF FIGURES

Figure                                                               Page
2-1          Schematic Diagram for Production of Phenol and
             Acetone from Cumene	    2-3
3-1          Liquid Injection Incinerator 	   3-23
3-2          Rotary Kiln Incinerator 	   3-24
3-3          Fluidized Bed Incinerator 	   3-26
3-4          Fixed Hearth.Incinerator 	   3-27
D-l          Schematic Diagram of the Comparative Method  	    D-2
                                     VI

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                             EXECUTIVE SUMMARY

                     BOAT Treatment Standards for K022

    Pursuant to the Hazardous and Solid Waste Amendments (HSWA) enacted
on November 8, 1984, the Environmental Protection Agency (EPA) is
establishing best demonstrated available technology (BOAT) treatment
standards for the listed waste identified in 40 CFR 261.32 as K022.
Compliance with these BOAT treatment standards is a prerequisite for
placement of the waste in units designated as land disposal units
according to 40 CFR Part 268.  The effective date of the nonwastewater
standards is August 8, 1988.  The applicability of the restrictions for
K022 wastewater and the effective date are discussed in the preamble to
the final rule for First Thirds wastes.
    This background document provides the Agency's rationale and
technical support for selecting the constituents to be regulated in
nonwastewater forms of K022 waste and for developing treatment standards
for those regulated constituents.  The document also provides waste
characterization information that serves as a basis for determining
whether treatment variances may be warranted.  EPA may grant a treatment
variance in cases where the Agency determines that the waste in question
is more difficult to treat than the waste upon which the treatment
standards have been established.
    The introductory section, which appears verbatim in all the First
Third background documents, summarizes the Agency's legal authority and
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promulgated methodology for establishing treatment standards and
discusses the petition process necessary for requesting a variance from
the treatment standards.  The remainder of the document presents
waste-specific information — the number and locations of facilities
affected by the land disposal restrictions for K022 waste, the
waste-generating process, waste characterization data, the technologies
used to treat the waste (or similar wastes), and available performance
data, including data on which the treatment standards are based.  The
document also explains EPA's determination of BOAT, selection of
constituents to be regulated, and calculation of treatment standards.
    K022 waste is listed as "distillation bottom tars from the production
of phenol/acetone from cumene."  The Agency estimates that eight
facilities produce phenol and acetone from cumene and thus generate K022
waste.  These facilities fall under Standard Industrial Classification
(SIC) Code 2869.
    EPA is regulating five organic and two metal constituents in
nonwastewater forms of K022 waste.  (For the purpose of determining the
applicability of the treatment standards, wastewaters are defined as
wastes containing less than 1 percent (weight basis) total suspended
solids* and less than 1 percent (weight basis) total organic carbon
* 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.
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(TOC).  Waste not meeting this definition must comply with the treatment
standards for nonwastewaters.)  The nonwastewater treatment standards for
the organic constituents are based on performance data from fuel
substitution of K022 waste.  The nonwastewater treatment standards for
metals are based on performance data from stabilization.
    -Wastewater treatment standards for K022 are to be proposed and
promulgated prior to May 8, 1990.  Until this date, these wastes will be
restricted from land disposal  according to the provisions described in
the preamble to the final rule for First Third wastes.
    The following table lists the BOAT treatment standards for K022
nonwastewater.  For BOAT list organics, the nonwastewater treatment
standards reflect total constituent concentration; the units are mg/kg
(parts per million on a weight-by-weight basis).  For BOAT list metals in
nonwastewater, treatment standards reflect leachate concentration from
the toxicity characteristic leaching procedure (TCLP).  The units are
mg/1  (parts per million on a weight-by-volume basis).  Note that if the
concentrations of the regulated constituents in the waste, as generated,
are lower than or equal to the treatment standards, then treatment is not
required prior to land disposal.
    Testing procedures for all sample analyses performed for the
regulated constituents are specifically identified in Appendix B of this
background document.
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    EPA wishes to point out that because of facility claims of
confidentiality, this document does not contain all of the data that EPA
usually discloses in the documents supporting its decision-making
process.  In this document, the data restricted from public scrutiny
pertain to data used for selecting constituents to regulate, data used
for determining substantial treatment, and data used for developing BOAT
treatment standards.  Under 40 CFR Part 2, Subpart B, facilities may
claim any or all of the data that are submitted to EPA as confidential
business information (CBI).  These confidentiality rules outline
procedures that EPA must follow when using these data for rulemaking.
Since EPA has not yet made a determination regarding the validity of the
data being claimed as CBI, the data will be treated as CBI until a
determination is made.  The Agency would like to emphasize, however, that
all the data have been evaluated according to the methodology presented
in Section 1 of this document.  All deletions of CBI are noted in the
appropriate places.

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                     BOAT Treatment Standards for K022
                                    Maximum for any single grab sample
Constituent
                                     Nonwastewater
    Total      TCLP leachate
concentration  concentration
   (ing/kg)        (mg/1)
              Wastewater
                 Total
             concentration
                 (mg/1)
Volatile Orqanics
Toluene

Semivolatile Orqanics
Acetophenone
Sum of Diphenylamine
    0.034
   19
NA
NA
and Diphenylnitrosamine
Phenol
Metals
Chromium (total)
Nickel
13
12

NA
NA
NA
NA

5.2
0.32
NA = Not applicable.

aEPA intends to propose and promulgate K022 wastewater treatment
 standards prior to May 8, 1990.
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                              1.   INTRODUCTION
    This section of the background document presents a summary of the
legal authority pursuant to which the best demonstrated available
technology (BOAT) treatment standards were developed, a summary of EPA's
promulgated methodology for developing the BOAT treatment standards, and,
finally, a discussion of the petition process that should be followed to
request a variance from the BOAT treatment standards.
1.1      Legal Background
1.1.1    Requirements Under HSWA
    The Hazardous and Solid Waste Amendments of 1984 (HSWA), which were
enacted on November 8, 1984, and which amended the Resource Conservation
and Recovery Act of 1976 (RCRA), impose substantial new responsibilities
on those who handle hazardous waste.  In particular, the amendments
require the Agency to promulgate regulations that restrict the land
disposal of untreated hazardous wastes.  In its enactment of HSWA,
Congress stated explicitly that "reliance on land disposal should be
minimized or eliminated, and land disposal, particularly landfill and
surface impoundment, should be the least favored method for managing
hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C. 6901(b)(7)).
    One part of the amendments specifies dates on which particular groups
of untreated hazardous wastes will be prohibited from land disposal
unless "it has been demonstrated to the Administrator, to a reasonable
degree of certainty, that there will be no migration of hazardous
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constituents from the disposal unit or injection zone for as long as the
wastes remain hazardous" (RCRA section 3004(d)(l), (e)(l), (g)(5),
42 U.S.C. 6924 (d)(l), (e)(l), (g)(5)).
    For the purpose of the restrictions, HSWA defines land disposal "to
include, but not be limited to, any placement of ... hazardous waste in
a landfill, surface impoundment, waste pile, injection well, land
treatment facility, salt dome formation, salt bed formation, or
underground mine or cave" (RCRA section 3004(k), 42 U.S.C. 6924(k)).
Although HSWA defines land disposal to include injection wells, such
disposal of solvents, dioxins, and certain other wastes, known as the
California List wastes, is covered on a separate schedule (RCRA section
3004(f)(2), 42 U.S.C. 6924 (f)(2)).  This schedule requires that EPA
develop land disposal restrictions for deep well injection by
August 8, 1988.
    The amendments also require the Agency to set "levels or methods of
treatment, if any, which substantially diminish the toxicity of the waste
or substantially reduce the likelihood of migration of hazardous
constituents from the waste so that short-term and long-term threats to
human health and the environment are minimized" (RCRA section 3004(m)(l),
42 U.S.C. 6924 (m)(l)).  Wastes that satisfy such levels or methods of
treatment established by EPA, i.e., treatment standards, are not
prohibited from being land disposed.
    In setting treatment standards for listed or characteristic wastes,
EPA may establish different standards for particular wastes within a
single waste code with differing treatability characteristics.  One such

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characteristic is the physical form of the waste.  This frequently leads
to different standards for wastewaters and nonwastewaters.
Alternatively, EPA can establish a treatment standard that is applicable
to more than one waste code when, in EPA's judgment, a particular
constituent present in the wastes can be treated to the same
concentration in all the wastes.
    In those instances where a generator can demonstrate that the
standard promulgated for the generator's waste cannot be achieved, the
amendments allow the Agency to grant a variance from a treatment standard
by revising the treatment standard for that particular waste through
rulemaking procedures.  (A further discussion of treatment variances is
provided in Section 1.3.)
    The land disposal restrictions are effective when promulgated unless
the Administrator grants a national variance and establishes a different
date (not to exceed 2 years beyond the statutory deadline) based on "the
earliest date on which adequate alternative treatment, recovery, or
disposal capacity which protects human health and the environment will be
available" (RCRA section 3004(h)(2), 42 U.S.C. 6924 (h)(2)).
    If EPA fails to set treatment standards by the statutory deadline for
any hazardous waste in the First Third or Second Third waste groups (see
Section 1.1.2), the waste may not be disposed in a landfill or surface
impoundment unless the facility is in compliance with the minimum
technological requirements specified in section 3004(o) of RCRA.  In
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addition, prior to disposal, the generator must certify to the
Administrator that the availability of treatment capacity has been
investigated, and it has been determined that disposal in a landfill or
surface impoundment is the only practical alternative to treatment
currently available to the generator.  This restriction on the use of
landfills and surface impoundments applies until EPA sets treatment
standards for the waste or until May 8, 1990, whichever is sooner.  If
the Agency fails to set treatment standards for any ranked hazardous
waste by May 8, 1990, the waste is automatically prohibited from land
disposal unless the waste is placed in a land disposal unit that is the
subject of a successful "no migration" demonstration (RCRA section
3004(g), 42 U.S.C. 6924(g)).  "No migration" demonstrations are based on
case-specific petitions that show there will be no migration of hazardous
constituents from the unit for as long as the waste remains hazardous.
1.1.2    Schedule for Developing Restrictions
    Under section 3004(g) of RCRA, EPA was required to establish a
schedule for developing treatment standards for all wastes that the
Agency had listed as hazardous by November 8, 1984.  Section 3004(g)
required that this schedule consider the intrinsic hazards and volumes
associated with each of these wastes.  The statute required EPA to set
treatment standards according to the following schedule:
    1.   Solvent and dioxin wastes by November 8, 1986;
    2.   The "California List" wastes by July 8, 1987;
    3.   At least one-third of all listed hazardous wastes by
         August 8, 1988 (First Third);
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    4.   At least two-thirds of all listed hazardous wastes by
         June 8, 1989 (Second Third); and
    5.   All remaining listed hazardous wastes and all hazardous wastes
         identified as of November 8, 1984, by one or more of the
         characteristics defined in 40 CFR Part 261 by May 8, 1990 (Third
         Third).
    The statute specifically identified the solvent wastes as those
covered under waste codes F001, F002, F003, F004, and F005; it identified
the dioxin-containing hazardous wastes as those covered under waste codes
F020, F021, F022, and F023.
    Wastes collectively known as the California List wastes, defined
under section 3004(d) of HSWA, are liquid hazardous wastes containing
metals, free cyanides, PCBs, corrosives (i.e., a pH less than or equal to
2.0), and any liquid or nonliquid hazardous waste containing halogenated
organic compounds (HOCs) above 0.1 percent by weight.  Rules for the
California List were proposed on December 11, 1986, and final rules for
PCBs, corrosives, and HOC-containing wastes were established
August 12, 1987.  In that rule, EPA elected not to establish treatment
standards for metals.  Therefore, the statutory limits became effective.
    On May 28,  1986, EPA published a final rule (51 FR 19300) that
delineated the  specific waste codes that would be addressed by the First
Third, Second Third, and Third Third land disposal restriction rules.
This  schedule is incorporated into 40 CFR 268.10, 268.11, and 268.12.
1.2    Summary  of Promulgated BOAT Methodology
     In a November 7, 1986, rulemaking, EPA promulgated a technology-based
approach to establishing treatment standards under section 3004(m).
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Congress indicated in the legislative history accompanying the HSWA that
"[t]he requisite levels of [sic] methods of treatment established by the
Agency should be the best that has been demonstrated to be achievable,"
noting that the intent is "to require utilization of available
technology" and not a "process which contemplates technology-forcing
standards"  (Vol.  130 Cong.  Rec. S9178 (daily ed., July 25, 1984)).  EPA
has interpreted this legislative history as suggesting that Congress
considered the requirement under section 3004(m) to be met by application
of the best demonstrated and achievable (i.e., available) technology
prior to land disposal of wastes or treatment residuals.  Accordingly,
EPA's treatment standards are generally based on the performance of the
best demonstrated available technology (BOAT) identified for treatment of
the hazardous constituents.   This approach involves the identification of
potential treatment systems, the determination of whether they are
demonstrated and available,  and the collection of treatment data from
well-designed and well-operated systems.
    The treatment standards, according to the statute, can represent
levels or methods of treatment, if any, that substantially diminish the
toxicity of the waste or substantially reduce the likelihood of migration
of hazardous constituents.  Wherever possible, the Agency prefers to
establish BOAT treatment standards as "levels" of treatment
(i.e., performance standards), rather than to require the use of specific
treatment "methods."  EPA believes that concentration-based treatment
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levels offer the regulated community greater flexibility to develop and
implement compliance strategies, as well as an incentive to develop
innovative technologies.
1.2.1    Waste Treatability Group
    In developing the treatment standards, EPA first characterizes the
waste(s).  As necessary, EPA may establish treatability groups for wastes
having similar physical and chemical properties.  That is, if EPA
believes that hazardous constituents in wastes represented by different
waste codes could be treated to similar concentrations using identical
technologies, the Agency combines the wastes into one treatability
group.  EPA generally considers wastes to be similar when they are both
generated from the same industry and from similar processing stages.  In
addition, EPA may combine two or more separate wastes into the same
treatability group when data are available showing that the waste
characteristics affecting performance are similar or that one of the
wastes in the group, the waste from which treatment standards are to be
developed, is expected to be most difficult to treat.
    Once the treatability groups have been established, EPA collects and
analyzes data on identified technologies used to treat the wastes in each
treatability group.  The technologies evaluated must be demonstrated on
the waste or a similar waste and must be available for use.
1.2.2    Demonstrated and Available Treatment Technologies
    Consistent with legislative history, EPA considers demonstrated
technologies to be those that are currently used on a full-scale basis to
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treat the waste of interest or a waste judged to be similar (see 51 FR
40588, November 7, 1986).  EPA also will consider as demonstrated
treatment those technologies used to separate or otherwise process
chemicals and other materials on a full-scale basis.  Some of these
technologies clearly are applicable to waste treatment, since the wastes
are similar to raw materials processed in industrial applications.
    For most of the waste treatability groups for which EPA will
promulgate treatment standards, EPA will identify demonstrated
technologies either through review of literature related to current waste
treatment practices or on the basis of information provided by specific
facilities currently treating the waste or similar wastes.
    In cases where the Agency does not identify any facilities treating
wastes represented by a particular waste treatability group, EPA may
transfer a finding of demonstrated treatment.  To do this, EPA will
compare the parameters affecting treatment selection for the waste
treatability group of interest to other wastes for which demonstrated
technologies already have been determined.  (The parameters affecting
treatment selection and their use for this waste are described in
Section 3.2 of this document.)  If the parameters affecting treatment
selection are similar, then the Agency will consider the treatment
technology also to be demonstrated for the waste of interest.  For
example, EPA considers rotary kiln incineration to be a demonstrated
technology for many waste codes containing hazardous organic
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constituents, high total organic content, and high filterable solids
content, regardless of whether any facility is currently treating these
wastes.  The basis for this determination is data found in literature and
data generated by EPA confirming the use of rotary kiln incineration on
wastes having the above characteristics.
    If no full-scale treatment or recovery operations 'are identified for
a waste or wastes with similar physical or chemical characteristics that
affect treatment selection, the Agency will be unable to identify any
demonstrated treatment technologies for the waste, and, accordingly, the
waste will be prohibited from land disposal (unless handled in accordance
with the exemption and variance provisions of the rule).  The Agency is,
however, committed to establishing treatment standards as soon as new or
improved treatment processes are demonstrated (and available).
    Operations only available at research facilities, pilot- and bench-
scale operations, will not be considered in identifying demonstrated
treatment technologies for a waste.  Nevertheless, EPA may use data
generated at research facilities in assessing the performance of
demonstrated technologies.
    As discussed earlier, Congress intended that technologies used to
establish treatment standards under section 3004(m) be not only
"demonstrated," but also "available."  To decide whether demonstrated
technologies may be considered "available," the Agency determines whether
they (1) are commercially available and (2) substantially diminish the
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toxicity of the waste or substantially reduce the likelihood of migration

of hazardous constituents from the waste.  These criteria are discussed

below.

    1.   Commercially available treatment.  If the demonstrated treatment
         technology is a proprietary or patented process that is not
         generally available, EPA will not consider the technology in its
         determination of the treatment standards.  EPA will consider
         proprietary or patented processes available if it determines
         that the treatment method can be purchased or licensed from the
         proprietor or is a commercially available treatment.  The
         services of the commercial facility offering this technology
         often can be purchased even if the technology itself cannot be
         purchased.

    2.   Substantial treatment.  To be considered "available," a
         demonstrated treatment technology must "substantially diminish
         the toxicity" of the waste or "substantially reduce the
         likelihood of migration of hazardous constituents" from the
         waste in accordance with section 3004(m).  By requiring that
         substantial treatment be achieved in order to set a treatment
         standard, the statute ensures that all wastes are adequately
         treated before being placed in or on the land and ensures that
         the Agency does not require a treatment method that provides
         little or no environmental benefit.  Treatment will always be
         deemed substantial if it results in nondetectable levels of the
         hazardous constituents of concern (provided the nondetectable
         levels are low relative to the concentrations in the untreated
         waste).  If nondetectable levels are not achieved, then a
         determination of substantial  treatment will be made on a
         case-by-case basis.  This approach is necessary because of the
         difficulty of establishing a meaningful guideline that can be
         applied broadly to the many wastes and technologies to be
         considered.  EPA will consider the following factors in an
         effort to evaluate whether a technology provides substantial
         treatment on a case-by-case basis:

         • Number and types of constituents treated;

         • Performance (concentration of the constituents in the
           treatment residuals); and

         • Percent of constituents removed.
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    EPA will only set treatment standards based on a technology that
meets both availability criteria.  Thus, the decision to classify a
technology as "unavailable" will have a direct impact on the treatment
standard.  If the best demonstrated technology is unavailable, the
treatment standards will be based on the next best demonstrated treatment
technology determined to be available.  To the extent that the resulting
treatment standards are less stringent, greater concentrations of
hazardous constituents in the treatment residuals could be placed in land
disposal units.
    There also may be circumstances in which EPA concludes that for a
given waste none of the demonstrated treatment technologies are
"available" for purposes of establishing the 3004(m) treatment
performance standards.  Subsequently, these wastes will be prohibited
from continued placement in or on the land unless managed in accordance
with applicable exemptions and variance provisions.  The Agency is,
however, committed to establishing new treatment standards as soon as new
or improved treatment processes become available.
1.2.3    Collection of Performance Data
    Performance data on the demonstrated available technologies are
evaluated by the Agency to determine whether the data are representative
of well-designed and well-operated treatment systems.  Only data from
well-designed and well-operated systems are considered in determining
BOAT.  The data evaluation includes data already collected directly by
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EPA and/or data provided by industry.  In those instances where
additional data are needed to supplement existing information, EPA
collects additional data through a sampling and analysis program.  The
principal elements of this data collection program are:  (1) the
identification of facilities for site visits, (2) the engineering site
visit, (3) the sampling and analysis plan, (4) the sampling visit, and
(5) the onsite engineering report.
    (1)  Identification of facilities for site visits.  To identify
facilities that generate and/or treat the waste of concern, EPA uses a
number of information sources.  These include Stanford Research
Institute's Directory of Chemical Producers;  EPA's Hazardous Waste Data
Management System (HWDMS); the 1986 Treatment, Storage, Disposal Facility
(TSDF) National Screening Survey; and EPA's Industry Studies Data Base.
In addition, EPA contacts trade associations to inform them that the
Agency is considering visits to facilities in their industry and to
solicit their assistance in identifying facilities for EPA to consider in
its treatment sampling program.
    After identifying facilities that treat the waste, EPA uses this
hierarchy to select sites for engineering visits: (1) generators treating
single wastes on site; (2) generators treating multiple wastes together
on site;  (3) commercial treatment, storage, and di
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standards from data produced by treatment facilities handling only a
single waste, and (2) facilities that routinely treat a specific waste
have had the best opportunity to optimize design parameters.  Although
excellent treatment can occur at many facilities that are not high in
this hierarchy, EPA has adopted this approach to avoid, when possible,
ambiguities related to the mixing of wastes before and during treatment.
    When possible, the Agency will evaluate treatment technologies using
full-scale treatment systems.  If performance data from properly designed
and operated full-scale systems treating a particular waste or a waste
judged to be similar are not available, EPA may use data from research
facility operations.  Whenever research facility data are used, EPA will
explain in the preamble and background document why such data were used
and will request comments on the use of such data.
    Although EPA's data bases provide information on treatment for
individual wastes, the data bases rarely provide data that support the
selection of one facility for sampling over another.  In cases where
several treatment sites appear to fall into the same level of the
hierarchy, EPA selects sites for visits strictly on the basis of which
facility could most expeditiously be visited and later sampled if
justified by the engineering visit.
    (2)  Engineering site visit.  Once a treatment facility has been
selected, an engineering site visit is made to confirm that a candidate
for sampling meets EPA's criteria for a well-designed facility and to
                                    1-13

-------
ensure that the necessary sampling points can be accessed to determine
operating parameters and treatment effectiveness.  During the visit, EPA
also confirms that the facility appears to be well operated, although the
actual operation of the treatment system during sampling is the basis for
EPA's decisions regarding proper operation of the treatment unit.   In
general, the Agency considers a well-designed facility to be one that
contains the unit operations necessary to treat the various hazardous
constituents of the waste, as well as to control other nonhazardous
materials in the waste that may affect treatment performance.
    In addition to ensuring that a system is reasonably well designed,
the engineering visit examines whether the facility has a way to measure
the operating parameters that affect performance of the treatment system
during the waste treatment period.  For example, EPA may choose not to
sample a treatment system that operates in a continuous mode, for which
an important operating parameter cannot be continuously recorded.   In
such systems, instrumentation is important in determining whether the
treatment system is operating at design values during the waste treatment
period.
    (3)  Sampling and analysis plan.  If after the engineering site visit
the Agency decides to sample a particular plant, the Agency will then
develop a site-specific sampling and analysis plan (SAP) according  to the
Generic Quality Assurance Pro.iect Plan for the Land Disposal Restrictions
Program ("BOAT"). EPA/530-SW-87-011.  In brief, the SAP discusses where
the Agency plans to sample, how the samples will be taken, the frequency
                                    1-14

-------
of sampling, the constituents to be analyzed and the method of analysis,
operational parameters to be obtained, and specific laboratory quality
control checks on the analytical results.
    The Agency will generally produce a draft of the site-specific SAP
within 2 to 3 weeks of the engineering visit.  The draft of the SAP is
then sent to the plant for review and comment.  With few exceptions, the
draft SAP should be a confirmation of data collection activities
discussed with the plant personnel during the engineering site visit.
EPA encourages plant personnel to recommend any modifications to the SAP
that they believe will improve the quality of the data.
    It is important to note that sampling of a plant by EPA does not mean
that the data will be used in the development of BOAT treatment
standards.  EPA's final decision on whether to use data from a sampled
plant depends on the actual analysis of the waste being treated and on
the operating conditions at the time of sampling.  Although EPA would not
plan to sample a facility that was not ostensibly well designed and well
operated, there is no way to ensure that at the time of the sampling the
facility will not experience operating problems.  Additionally, EPA
statistically compares its test data to suitable industry-provided data,
where available, in its determination of what data to use in developing
treatment standards.  The methodology for comparing data is presented
later in this section.
                                    1-15

-------
    (Note: Facilities wishing to submit data for consideration in the
development of BOAT standards should, to the extent possible, provide
sampling information similar to that acquired by EPA.  Such facilities
should review the Generic Quality Assurance Pro.iect Plan for the Land
Disposal Restrictions Program ("BOAT"), which delineates all of the
quality controT and quality assurance measures associated with sampling
and analysis.  Quality assurance and quality control procedures are
summarized in Section 1.2.6 of this document.)
    (4)  Sampling visit.  The purpose of the sampling visit is to collect
samples that characterize the performance of the treatment system and to
document the operating conditions that existed during the waste treatment
period.  At a minimum, the Agency attempts to collect sufficient samples
of the untreated waste and solid and liquid treatment residuals so that
variability in the treatment process can be accounted for in the
development of the treatment standards.  To the extent practicable, and
within safety constraints, EPA or its contractors collect all samples and
ensure that chain-of-custody procedures are conducted so that the
integrity of the data is maintained.
    In general, the samples collected during the sampling visit will have
already been specified in the SAP.  In some instances, however, EPA will
not be able to collect all planned samples because of changes in the
facility operation or plant upsets; EPA will explain any such deviations
from the SAP in its follow-up onsite engineering report.
                                    1-16

-------
    (5)  Onsite engineering report.  EPA summarizes all its data
collection activities and associated analytical results for testing at a
facility in a report referred to as the onsite engineering report (OER).
This report characterizes the waste(s) treated, the treated residual
concentrations, the design and operating data, and all analytical results
including methods used and accuracy results.  This report also describes
any deviations from EPA's suggested analytical methods for hazardous
wastes that appear in Test Methods for Evaluating Solid Waste. SW-846,
Third Edition, November 1986.
    After the OER is completed, the report is submitted to the waste
generator and/or treater for review.  This review provides a final
opportunity for claiming any inrirmation contained in the report as
confidential.  Following the review and incorporation of comments, as
appropriate, the report is made available to the public with the
exception of any material claimed as confidential.
1.2.4    Hazardous Constituents Considered and Selected for Regulation
    (1)  Development of BOAT list.  The list of hazardous constituents
within the waste codes that are targeted for treatment is referred to by
the Agency as the BOAT constituent list.  This list, provided as
Table 1-1, is derived from the constituents presented in 40 CFR Part 261,
Appendices VII and VIII, as well as several ignitable constituents used
as the basis of listing wastes as F003 and F005.  These sources provide a
                                    1-17

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lS21g
                    Table 1-1   BOAT Constituent List
BOAT
reference
no.

222.
1.
2.
3.
4.
5.
6.
223.
/.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
?3.
24.
25.
26.
27.
28.
29.
224.
225.
226.
30.
227.
31.
214.
32.
33.
228.
34.
Constituent
Volatile organ ics
Acetone
Acetonitri le
Acrolein
Acrylonitri le
Benzene
Bromod ich loromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-1.3-butadiene
Ch lorod ibromome thane
Chloroethane
2 Chloroethyl vinyl ether
Chloroform
Ch loromethane
3 -Ch loropropcne
1.2-Dibromo-3-chloropropane
1.2-Dibromoe thane
Dibromome thane
trans-1.4-Dichloro-2-butene
0 ich lorod if luoromethane
1,1-Oichloroethane
1,2-0 ich loroethane
1 . 1 -Dich loroethy lene
trans-1 ,2-Dichloroethene
1.2-Dichloropropane
trans-1 , 3-Oichloropropene
cis-l,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacry late
Ethylene oxide
lodomethane
Isobutyl alcohol
Methanol
Methyl ethyl ketone
CAS no.

67-64-1
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110-75-8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-9b-3
110-57-6
75-71-8
75-34-3
107-06-2
75-35-4
156-60-5
78-87-5
10061-02-6
10061-01-5
123-91-1
110-80-5
141-/8-6
100-41-4
107-12-0
60-29-7
97-63-2
75-21-8
74-88-4
78-83-1
67-56-1
78-93-3
                                   1-18

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

229.
35.
37.
38.
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
231.

50.
215.
216.
217.

51.
52.
53.
54.
55.
56.
57.
58.
59.
218.
60.
61.
62.
63.
64.
65.
66.
Constituent
Volatile organ ics (continued)
Methyl isobutyl ketone
Methyl met hacry late
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyridine
1.1.1. 2- Tetrach loroethane
1.1.2 . 2- Tetrach loroethane
Tetrach loroethene
Toluene
Tribromome thane
1 . 1 . 1- Tr ich loroethane
1 , 1 ,2-Trich loroethane
Tr ich loroethene
Tr ich loromonof luoromethane
1.2.3-Trichloropropdne
l.l,2-Trichloro-1.2,2-trif luoro-
ethane
Vinyl chloride
1.2-Xylene
1 ,3-Xylene
1 .4 Xylene
Semi volatile organ ics
Acenaphthalene
Acenaphthene
Acetophenone
2-Acety laminof luorene
4-Aminobiphenyl
Ani line
Anthracene
Aram He
Benz (a ) anthracene
Benzal chloride
Uenzenethiol
Deleted
Benzo(a)pyrene
Benzo( b ) f luoranthene
Benzo(gh i )pery lene
Benzo(k)f luoranthene
p-Benzoquinone
CAS no.

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

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

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

50-32-8
205-99-2
191-24-2
207-08-9
106-51-4
                                   1-19

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1521g
                         Table 1-1  (Continued)
BOAI
reference
no.

67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
II.
78.
79.
BO.
81.
8?.
232.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
219.
Constituent
Semi volatile organ ics (continued)
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
B i s ( 2-ch loro i sopropy 1 ) ether
Bis(2-ethylhexyl)phthalate
4 Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dimtrophenol
p-Chloroani 1 ine
Chlorobenzi late
p-Ch loro-m-creso 1
2-Ch loronaphtha lene
2-Chlorophenol
3-Chloropropionitrile
Chrysene
ortho-Cresol
para-Cresol
Cyc lohexanone
0 ibenzl a. h) anthracene
D i benzol a. e)pyrene
Dibenzo(a, ijpyrene
m Dichlorobenzene
o-O ich lorobenzene
p- 0 i ch lorobenzene
3,3' -Dich lorobenz idine
2.4-Dichlorophenol
2.6-Dichlorophenol
Diethyl phthalate
3.3' -Dime thoxyberu ulinc
p Oimethylaminoazobenzene
3.3' -Dimethylbenzidine
2.4-Dimethylphenol
Dimethyl phthdlate
Di-n-butyl phthalate
1.4-Dinitrobenzene
4 . 6-0 in t tro-o-creso 1
2.4-Oinitrophenol
2.4-Oinitrotoluene
2.6-Oinitrotoluene
Di-n-octyl phthaldte
0 i -n-propy In i trosam ine
Oiphenylamine
Diphenylnitrosamine
CAS no.

111-91-1
111-44-4
39638-32-9
11/-81-7
101-55-3
85-68-7
88-8b-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
542-76-7
218-01-9
95-48-7
106-44-5
108-94 I
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
106-46-7
91-94-1
120-83-2
87-65-0
84-66-2
119-90-4
60-11-7
119-93-7
105-67-9
131-11-3
84-74-2
100-25-4
534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
621-64-7
122-39-4
86-30-6
                                  1-20

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I521g
                         Table 1-1  (Continued)
BOA I
reference
no.

107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.

36.
121.
122.
123.
124.
125.
126.
127.
128.
129.
130.
131.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
220.
143.
144.
145.
146.
Constituent
Semivolat i le organ Ics (continued)
1.2-Oiphenylhydrazine .
Fluoranthene
F luorene
Hexach lorobenzene
Hexach lorobutad iene
Hexach lorocyc lopentadiene
Hexach loroe thane
Hexach lorophene
Hexach loropropene
lndeno(1.2.3-cd)pyrene
Isosafrole
Methapyri Iene
3-Methylcholanthrene
4,4' -Methylenebis
(2-chloroani 1 ine)
Methyl methanesulfonate
Naphthalene
1 ,4-Naphthoqu inone
1 -Naphthy lamme
2-Naphthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-N \trosodi-n-buty lam me
N-Nitrosodiethylamine
N-N i trosod i me thy lam ine
N-N i trosomethy lethy lam ine
N - N i t rosomorpho 1 i ne
N-Nitrosopiperidine
N-Nitrosopyrrol idine .
5-Nitro-o-toluidine
Pentach lorobenzene
Pentach loroethane
Pentach loron i t robenzene
Pentach loropheno 1
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcinol
CAS no.

122-66-7
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
70-30-4
1888-71-7
193-39-5
120-58-1
91-80-5
56-49-5

101-14-4
66-27-3
91-20-3
130-15-4
134-32-/
91-59-8
100-01 6
98-95-3
100-02-7
924-16-3
55-18-5
62-75-9
10595-95-6
59-89-2
100-75-4
930-55-2
99-65-8
608 93 5
76-01-7
82-68-8
87-86-5
62-44-2
85-01-8
108-95-2
85-44-9
109-06-8
23950-58-5
129-00-0
108-46-3
                                  1-21

-------
1521q
                        Table l-l  (Continued)
BOAT
reference
no.

147.
148.
149.
150.
151.
152.
153.


154.
155.
156.
157.
158.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.

169.
170.
1/1.

172.
173.
174.
175.
Constituent
Semivolat i 1e organ ics (continued)
Safrole
1.2.4.5- let rach lorobenzene
2.3.4.6- Tet rach loropheno 1
1.2. 4- Trich lorobenzene
2 , 4 . 5-Tr ich loropneno 1
2 , 4 , 6- Tr ich loropneno 1
Tris(2.3-dibromopropy 1)
phosphate
Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexava lent)
Copper
Lead
Hercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Inorganics other than metals
Cyanide
fluoride
Sulfide
Orqanochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
CAS no.

94-59-7
95-94-3
58-90-2
120-82-1
95-95-4
88-06-2

126-72-7

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

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

309-00-2
319-84-6
319-85-7
319-86-8
                                  1-22

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

176.
177.
178.
179.
180.
181.
182.
183.
184.
185.
186.
187.
188.
189.
190.
191.

192.
193.
194.

195.
196.
197.
198.
199.

200.
201.
202.
203.
204.
205.
206.
Constituent
Orqanochlorine pesticides (continued)
ganma-BHC
Chlordane
ODD
ODE
DOT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Hethoxyclor
Foxaphene
Phenoxyacet ic acid herbicides
2.4-Oichlorophenoxyacet ic acid
S i Ivex
2.4.5-T
Orqanophosphorous insecticides
Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
CAS no.

58-89-9
57-74-9
72-54-8
72-55-9
50-29-3
60-57-1
939-98-8
33213-6-5
72-20-8
7421-93-4
76-44-8
1024-57-3
465-73-6
143-50-0
72-43-5
8001-35-2

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

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

12674-U-2
11104 28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
                                   1-23

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15?lg
                          Table  1-1  (Continued)
BOAT
reference      Constituent                               CAS  no.
no.

               Dioxins and furans

207.           Hexachlorodibenzo-p-dioxins
208.           Hexachlorodibenzofurans
209.           Pentacnlorodibenzo-p-dioxins
210.           Pentachlorodibeniofurans
211.           Tetrachlorodibenzo-p-dioxins
212.           Tetrachlorodi'benzofurans
213.           2.3,7.8-retrachlorodibenzo-p-dioxin      1746-01-6
                                     1-24

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comprehensive list of hazardous constituents specifically regulated under
RCRA.  The BOAT list consists of those constituents that can be analyzed
using methods published in SW-846, Third Edition.
    The initial BOAT constituent list was published in EPA's Generic
Quality Assurance Project Plan for Land Disposal Restrictions Program
("BOAT") in March 1987.  Additional constituents are added to the BOAT
constituent list as more key constituents are identified for specific
waste codes or as new analytical methods are developed for hazardous
constituents.  For example, since the list was published in March 1987,
18 additional constituents (hexavalent chromium, xylenes (all three
isomers), benzal chloride, phthalic anhydride, ethylene oxide,  acetone,
n-butyl alcohol, 2-ethoxyethanol, ethyl acetate, ethyl benzene, ethyl
ether, methanol, methyl isobutyl ketone, 2-nitropropane,
1,l,2-trichloro-l,2,2-trifluoroethane, and cyclohexanone) have been added
to the list.
    Chemicals are listed in Appendix VIII if they are shown in scientific
studies to have toxic, carcinogenic, mutagenic, or teratogenic effects on
humans or other life-forms, and they include such substances as those
identified by the Agency's Carcinogen Assessment Group as being
carcinogenic.  A waste can be listed as a toxic waste on the basis that
it contains a constituent in Appendix VIII.
    Although Appendix VII, Appendix VIII, and the F003 and F005
ignitables provide a comprehensive list of RCRA-regulated hazardous
constituents, not all of the constituents can be analyzed in a complex
                                    1-25

-------
waste matrix.  Therefore, constituents that could not be readily analyzed

in an unknown waste matrix were not included on the initial BOAT

constituent list.  As mentioned above, however, the BOAT constituent list

is a continuously growing list that does not preclude the addition of new

constituents when analytical methods are developed.

    There are five major reasons that constituents were not included on

the BOAT constituent list:

    1.   Constituents are unstable.  Based on their chemical structure,
         some constituents will either decompose in water or will
         ionize.  For example, maleic anhydride will form maleic acid
         when it comes in contact with water, and copper cyanide will
         ionize to form copper and cyanide ions.  However, EPA may choose
         to regulate the decomposition or ionization products.

    2.   EPA-approved or verified analytical methods are not available.
         Many constituents, such as 1,3,5-trinitrobenzene, are not
         measured adequately or even detected using any of EPA's
         analytical methods published in SW-846 Third Edition.

    3.   The constituent is a member of a chemical group designated in
         Appendix VIII as not otherwise specified (N.O.S.).  Constituents
         listed as N.O.S., such as chlorinated phenols, are a generic
         group of some types of chemicals for which a single analytical
         procedure is not available.  The individual members of each such
         group need to be listed to determine whether the constituents
         can be analyzed.  For each N.O.S. group, all those constituents
         that can be readily analyzed are included in the BOAT
         constituent list.

    4.   Available analytical procedures are not appropriate for a
         complex waste matrix.  Some compounds, such as auramine, can be
         analyzed as a pure constituent.  However, in the presence of
         other constituents, the recommended analytical method does not
         positively identify the constituent.  The use of high
         performance liquid chromatography (HPLC) presupposes a high
         expectation of finding the specific constituents of interest.
         In using this procedure to screen samples, protocols would have
         to be developed on a case-specific basis to verify the identity
         of constituents present in the samples.  Therefore, HPLC is
         usually not an appropriate analytical procedure for complex
         samples containing unknown constituents.
                                    1-26

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    5.   Standards for analytical instrument calibration are not
         commercially available.  For several constituents, such as
         benz(c)acridine, commercially available standards of a
         "reasonably" pure grade are not available.  The unavailability
         of a standard was determined by a review of catalogs from
         specialty chemical manufacturers.

    Two constituents (fluoride and sulfide) are not specifically included

in Appendices VII and VIII; however, these compounds are included on the

BOAT list as indicator constituents for compounds from Appendices VII and

VIII such as hydrogen fluoride and hydrogen sulfide, which ionize in

water.

    The BOAT constituent list presented in Table 1-1 is divided into the

following nine groups:

         Volatile organics;
         Semivolatile organics;
         Metals;
         Other inorganics;
         Organochlorine pesticides;
         Phenoxyacetic acid herbicides;
         Organophosphorous insecticides;
         PCBs; and
         Dioxins and furans.

The constituents were placed in these categories based on their chemical

properties.  The constituents in each group are expected to behave

similarly during treatment and are also analyzed, with the exception of

the metals and the other inorganics, by using the same analytical methods,

    (2)  Constituent selection analysis.  The constituents that the

Agency selects for regulation in each waste are, in general, those found

in the untreated wastes at treatable concentrations.  For certain waste
                                    1-27

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codes, the target list for the untreated waste may have been shortened
(relative to analyses performed to test treatment technologies) because
of the extreme unlikelihood that the constituent will  be present.
    In selecting constituents for regulation, the first step is to
develop of list of potentially regulated constituents  by summarizing all
the constituents that are present or are likely to be  present in the
untreated waste at treatable concentrations.  A constituent is considered
present in a waste if the constituent (1) is detected  in the untreated
waste above the detection limit, (2) is detected in any of the treated
residuals above the detection limit, or (3) is likely  to be present based
on the Agency's analyses of the waste-generating process.   In case (2),
the presence of other constituents in the untreated waste may interfere
with the quantification of the constituent of concern,  making the
detection limit relatively high and resulting in a finding of "not
detected" when, in fact, the constituent is present in  the waste.   Thus,
the Agency reserves the right to regulate such constituents.
    After developing a list of potential constituents  for regulation.
EPA reviews this list to determine if any of these constituents can be
excluded from regulation because they would be controlled by regulation
of other constituents on the list.  This indicator analysis is done for
two reasons: (1) it reduces the analytical cost burdens on the treater
and (2) it facilitates implementation of the compliance and enforcement
program.  EPA's rationale for selection of regulated constituents  for
this waste code is presented in Section 6 of this background document.
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    (3)  Calculation of standards.  The final step in the calculation of
the BOAT treatment standard is the multiplication of the average
accuracy-corrected treatment value by a factor referred to by the Agency
as the variability factor.  This calculation takes into account that even
well-designed and well-operated treatment systems will  experience some
fluctuations in performance.  EPA expects that fluctuations will result
from inherent mechanical limitations in treatment control systems,
collection of treated samples, and analysis of these samples.  All of the
above fluctuations can be expected to occur at well-designed and
well-operated treatment facilities.  Therefore, setting treatment
standards utilizing a variability factor should be viewed not as a
relaxing of section 3004(m) requirements, but rather as a function of the
normal variability of the treatment processes.  A treatment facility will
have to be designed to meet the mean achievable treatment performance
level to ensure that the performance levels remain within the limits of
the treatment standard.
    The Agency calculates a variability factor for each constituent of
concern within a waste treatability group using the statistical
calculation presented in Appendix A.  The equation for calculating the
variability factor is the same as that used by EPA for the development of
numerous regulations in the Effluent Guidelines Program under the Clean
Water Act.  The variability factor establishes the instantaneous maximum
based on the 99th percentile value.
                                    1-29

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    There is an additional step in the calculation of the treatment
standards in those instances where the ANOVA analysis shows that more
than one technology achieves a level of performance that represents
BOAT.  In such instances, the BOAT treatment standard for each
constituent of concern is calculated by first averaging the mean
performance value for each technology and then multiplying that value by
the highest variability factor among the technologies considered.  This
procedure ensures that all the technologies used as the basis for the
BOAT treatment standards will achieve full compliance.
1.2.5    Compliance with Performance Standards
    Usually the treatment standards reflect performance achieved by the
best demonstrated available technology (BOAT).  As such, compliance with
these numerical standards requires only that the treatment level be
achieved prior to land disposal.  It does not require the use of any
particular treatment technology.  While dilution of the waste as a means
to comply with the standards is prohibited, wastes that are generated in
such a way as to naturally meet the standards can be land disposed
without treatment.  With the exception of treatment standards that
prohibit land disposal or that specify use of certain treatment methods,
all established treatment standards are expressed as concentration levels,
    EPA is using both the total constituent concentration and the
concentration of the constituent in the TCLP extract of the treated waste
as a measure of technology performance.
                                    1-30

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    For all organic constituents, EPA is basing the treatment standards
on the total constituent concentration found in the treated waste.  EPA
is using this measurement because most technologies for treatment of
organics destroy or remove organics compounds.  Accordingly, the best
measure of performance would be the total amount of constituent remaining
after treatment.  (NOTE:  EPA's land disposal restrictions for solvent
waste codes F001-F005 (51 FR 40572) use the TCLP extract value as a
measure of performance.  At the time that EPA promulgated the treatment
standards for F001-F005, useful data were not available on total
constituent concentrations in treated residuals, and, as a result, the
TCLP data were considered to be the best measure of performance.)
    For all metal constituents, EPA is using both total constituent
concentration and/or the TCLP extract concentration as the basis for
treatment standards.  The total constituent concentration is being used
when the technology basis includes a metal recovery operation.  The
underlying principle of metal recovery is that it reduces the amount of
metal in a waste by separating the metal for recovery; total constituent
concentration in the treated residual, therefore, is an important measure
of performance for this technology.  Additionally, EPA also .be!ieves that
it is important that any remaining metal in a treated residual waste not
be in a state that is easily Teachable; accordingly, EPA is also using
the TCLP extract concentration as a measure of performance.  It is
important to note that for wastes for which treatment standards are based
                                    1-31

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on a metal recovery process, the facility has to comply with both the
total and the TCLP extract constituent concentrations prior to land
disposing the waste.
   «
    In cases where treatment standards for metals are not based on
recovery techniques but rather on stabilization, EPA is using only the
TCLP value as a measure of performance.  The Agency's rationale is that
stabilization is not meant to reduce the concentration of metal in a
waste but only to chemically minimize the ability of the metal to leach.
1.2.6    Identification of BOAT
    BOAT for a waste must be the "best" of the demonstrated available
technologies.  EPA determines which technology constitutes "best" after
screening the available data from each demonstrated technology, adjusting
these data for accuracy, and comparing the performance of each
demonstrated technology to that of the others.  If only one technology is
identified as demonstrated, it is considered "best"; if it is available,
the technology is BOAT.
    (1)  Screening of treatment data.    The first activity in
determining which of the treatment technologies represent treatment by
BOAT is to screen the treatment performance data from each of the
demonstrated and available technologies according to the following
criteria:
    1.   Design and operating data associated with the treatment data
         must reflect a well-designed, well-operated system for each
         treatment data point.  (The specific design and operating
         parameters for each demonstrated technology for the waste
         code(s) of interest are discussed in Section 3.2 of this
         document.)
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    2.   Sufficient QA/QC data must be available to determine the true
         values of the data from the treated waste.  This screening
         criterion involves adjustment of treated data to take into
         account that the true value may be different from the measured
         value.  This discrepancy generally is caused by other
         constituents in the waste that can mask results or otherwise
         interfere with the analysis of the constituent of concern.
    3.   The measure of performance must be consistent with EPA's
         approach to evaluating treatment by type of constituents (e.g.,
         total concentration data for organics, and total concentration
         and TCLP extract concentration for metals from the residual).
    In the absence of data needed to perform the screening analysis, EPA
will make decisions on a case-by-case basis as to whether to use the data
as a basis for the treatment standards.  The factors included in this
case-by-case analysis will be the actual treatment levels achieved, the
availability of the treatment data and their completeness (with respect
to the above criteria), and EPA's assessment of whether the untreated
waste represents the waste code of concern.
    (2)  Comparison of treatment data.  In cases in which EPA has
treatment data from more than one demonstrated available technology
following the screening activity, EPA uses the statistical method known
as analysis of variance (ANOVA) to determine if one technology performs
significantly better than the others.  This statistical method
(summarized in Appendix A) provides a measure of the differences between
two data sets.  Specifically, EPA uses the analysis of variance to
determine whether BOAT represents a level of performance achieved by only
one technology or represents a level of performance achieved by more than
one (or all) of the technologies.  If EPA finds that one technology
performs significantly better (i.e., is "best"), BOAT treatment standards
                                    1-33

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are the level  of performance achieved by that best technology multiplied
by the corresponding variability factor for each regulated constituent.
If the Agency finds that the levels of performance for one or more
technologies are not statistically different, EPA averages the
performance values achieved by each technology and then multiplies this
value by the largest variability factor associated with any of the
technologies.
    (3) . Quality assurance/quality control.  This section presents the
principal quality assurance/quality control (QA/QC) procedures employed
in screening and adjusting the data to be used in the calculation of
treatment standards.  Additional QA/QC procedures used in collecting and
screening data for the BOAT program are presented in EPA's Generic
Quality Assurance Pro.iect Plan for Land Disposal Restrictions Program
("BOAT"). EPA/530-SW-87-011.
    To calculate the treatment standards for the land disposal restriction
rules, it is first necessary to determine the recovery value for each
constituent (the amount of constituent recovered after spiking—which is
the addition of a known amount of the constituent—minus the initial
concentration in the samples, all divided by the spike amount added) for
each spiked sample of the treated residual.  Once the recovery values are
determined, the following procedures are used to select the appropriate
percent recovery value to adjust the analytical  data:
                                    1-34

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    1.    If duplicate spike recovery values are available for the
         constituent of interest,  the data are adjusted by the lowest
         available percent recovery value (i.e.,  the value that will
         yield the most conservative estimate of treatment achieved).
         However,  if a spike recovery value of less than 20 percent is
         reported  for a specific constituent, the data are not used to
         set treatment standards because the Agency does not have
         sufficient confidence in  the reported value to set a national
         standard.

    2.    If data are not available for a specific constituent but are
         available for an isomer,  then the spike recovery data are
         transferred from the isomer and the data are adjusted using  the
         percent recovery selected according to the procedure described
         in (1) above.

    3.    If data are not available for a specific constituent but are
         available for a similar class of constituents (e.g., volatile
         organics, acid-extractable semivolatiles), then spike recovery
         data available for this class of constituents are transferred.
         All spike recovery values greater than or equal to 20 percent
         for a spike sample are averaged and the constituent
         concentration is adjusted by the average recovery value.  If
         spiked recovery data are  available for more than one sample, the
         average is calculated for each sample and the data are adjusted
         by using  the lowest average value.

    4.    If matrix spike recovery  data are not available for a set of
         data to be used to calculate treatment standards, then matrix
         spike recovery data are transferred from a waste that the Agency
         believes  is similar (e.g., if the data represent an ash from
         incineration, then data from other incinerator ashes could be
         used).  While EPA recognizes that transfer of matrix spike
         recovery  data from a similar waste is not an exact analysis,
         this is considered the best approach for adjusting the data  to
         account for the fact that most analyses do not result in
         extraction of 100 percent of the constituent.  In assessing  the
         recovery  data to be transferred, the procedures outlined in  (1),
         (2), and  (3) above are followed.

    The analytical procedures employed to generate the data used to

calculate the treatment standards  are listed in Appendix B of this

document.  In cases where alternatives or equivalent procedures and/or

equipment are allowed in EPA's SW-846, Third Edition methods, the
                                    1-35

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specific procedures and equipment used are documented.  In addition, any
deviations from the SW-846, Third Edition methods used to analyze the
specific waste matrices are documented.  It is important to note that the
Agency will use the methods and procedures delineated in Appendix B to
enforce the treatment standards presented in Section 7 of this document.
Accordingly, facilities should use these procedures in assessing the
performance of their treatment systems.
1.2.7  BOAT Treatment Standards for "Derived-From" and "Mixed" Wastes
    (!)  Wastes from treatment trains generating multiple residues.  In a
number of instances, the proposed BOAT consists of a series of
operations, each of which generates a waste residue.  For example, the
proposed BOAT for a certain waste code is based on solvent extraction,
steam stripping, and activated carbon adsorption.  Each of these
treatment steps generates a waste requiring treatment--a
solvent-containing stream from solvent extraction, a stripper overhead,
and spent activated carbon.  Treatment of these wastes may generate
further residues; for instance, spent activated carbon (if not
regenerated) could be incinerated, generating an ash and possibly a
scrubber water waste.  Ultimately, additional wastes are generated that
may require land disposal.  With respect to these wastes, the Agency
wishes to emphasize the following points:
    1.   All of the residues from treating the original listed wastes are
         likewise considered to be the listed waste by virtue of the
         derived-from rule contained in 40 CFR 261.3(c)(2).   (This point
         is discussed more fully in (2) below.)  Consequently, all of the
         wastes generated in the course of treatment would be prohibited
         from land disposal unless they satisfy the treatment standard or
         meet one of the exceptions to the prohibition.

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    2.   The Agency's proposed treatment standards generally contain a
         concentration level for wastewaters and a concentration level
         for nonwastewaters.  The treatment standards apply to all of the
         wastes generated in treating the original prohibited waste.
         Thus, all derived-from wastes meeting the Agency definition of
         wastewater (less than 1 percent total organic carbon (TOC) and
         less than 1 percent total suspended solids) would have to meet
         the treatment standard for wastewaters.  All residuals not
         meeting this definition would have to meet the treatment
         standard for nonwastewaters.  EPA wishes to make clear that this
         approach is not meant to allow partial treatment in order to
         comply with the applicable standard.

    3.   The Agency has not performed tests, in all cases, on every waste
         that can result from every part of the treatment train.
         However, the Agency's treatment standards are based on treatment
         of the most concentrated form of the  waste.  Consequently, the
         Agency believes that the less concentrated wastes generated in
         the course of treatment will also be  able to be treated to meet
         this value.

    (2)  Mixtures and other derived-from residues.  There is a further

question as to the applicability of the BOAT treatment standards to

residues generated not from treating the waste (as discussed above), but

from other types of management.  Examples are  contaminated soil or

leachate that is derived from managing the waste.  In these cases, the

mixture is still deemed to be the listed waste, either because of the

derived-from rule (40 CFR 261.3(c)(2)(i)) or the mixture rule (40 CFR

261.3(a)(2)(iii) and (iv)) or because the listed waste is contained in

the matrix (see, for example, 40 CFR 261.33(d)).  The prohibition for the

particular listed waste consequently applies to this type of waste.

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

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

possible exception of contaminated soil and debris for which the Agency

is currently investigating whether it is appropriate to establish a
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separate treatability subcategorization).   For the most part, these
residues will be less concentrated than the original listed waste.  The
Agency's treatment standards also make a generous allowance for process
variability by assuming that all treatability values used to establish
the standard are lognormally distributed.   The waste also might be
amenable to a relatively nonvariable form of treatment technology such as
incineration.  Finally, and perhaps most important, the rules contain a
treatability variance that allows a petitioner to demonstrate that its
waste cannot be treated to the level specified in the rule (40 CFR Part
268.44(a)).  This provision provides a safety valve that allows persons
with unusual waste matrices to demonstrate the appropriateness of a
different standard.  The Agency, to date,  has not received any petitions
under this provision (for example, for residues contaminated with a
prohibited solvent waste), indicating, in the Agency's view, that the
existing standards are generally achievable.
    (3)  Residues from managing listed wastes or that contain listed
wastes.  The Agency has been asked if and when residues from managing
hazardous wastes, such as leachate and contaminated ground water, become
subject to the land disposal prohibitions.  Although the Agency believes
this question to be settled by existing rules and interpretative
statements, to avoid any possible confusion the Agency will address the
question again.
                                    1-38

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    Residues from managing First Third wastes, listed California List
wastes, and spent solvent and dioxin wastes are all considered to be
subject to the prohibitions for the listed hazardous waste as originally
generated.  Residues from managing California List wastes likewise are
subject to the California List prohibitions when the residues themselves
exhibit a characteristic of hazardous waste.  This determination stems
directly from the derived-from rule in 40 CFR 261.3(c)(2) or, in some
cases, from the fact that the waste is mixed with or otherwise contains
the listed waste.  The underlying principle stated in all of these
provisions is that listed wastes remain listed until delisted.
    The Agency's historic practice in processing delisting petitions that
address mixing residuals has been to consider them to be the listed waste
and to require that delisting petitioners address all constituents for
which the derived-from waste (or other mixed waste) was listed.   The
language in 40 CFR 260.22(b) states that mixtures or derived-from
residues can be delisted provided a delisting petitioner makes a
demonstration identical to that which a delisting petitioner would make
for the original listed waste.  Consequently, these residues are treated
as the original listed waste for delisting purposes.  The statute
likewise takes this position, indicating that soil and debris that are
contaminated with listed spent solvents or dioxin wastes are subject to
the prohibition for these wastes even though these wastes are not the
originally generated waste, but rather are a residual from management
(RCRA section 3004(e)(3)).  It is EPA's view that all such residues are
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covered by the existing prohibitions and treatment standards for the
listed hazardous waste that these residues contain or from which they are
derived.
1.2.8    Transfer of Treatment Standards
    EPA is proposing some treatment standards that are not based on
testing of the treatment technology on the specific waste subject to the
treatment standard.  The Agency has determined that the constituents
present in the untested waste can be treated to the same performance
levels as those observed in other wastes for which EPA has previously
developed treatment data.  EPA believes that transferring treatment
performance data for use in establishing treatment standards for untested
wastes is technically valid in cases where the untested wastes are
generated from similar industries or processing steps, or have similar
waste characteristics affecting performance and treatment selection.
Transfer of treatment standards to similar wastes or wastes from similar
processing steps requires little formal analysis.  However, in a case
where only the industry is similar, EPA more closely examines the waste
characteristics prior to deciding whether the untested waste constituents
can be treated to levels associated with tested wastes.
    EPA undertakes a two-step analysis when determining whether
constituents in the untested wastes can be treated to the same level of
performance as in the tested waste.  First, EPA reviews the available
waste characterization data to identify those parameters that are
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expected to affect treatment selection.  EPA has identified some of the
most important constituents and other parameters needed to select the
treatment technology appropriate for the given waste(s) in Section 3.
    Second, when analysis suggests that an untested waste can be treated
with the same technology as a waste for which treatment performance data
are already available, EPA analyzes a more detailed list of
characteristics that the Agency believes will affect the performance of
the technology.  By examining and comparing these characteristics, the
Agency determines whether the untested wastes will achieve the same level
of treatment as the tested waste.  Where the Agency determines that the
untested waste can be treated as well or better than the tested waste,
the treatment standards can be transferred.
1.3    Variance from the BOAT Treatment Standard
    The Agency recognizes that there may exist unique wastes that cannot
be treated to the level specified as the treatment standard.  In such a
case, a generator or owner/operator may submit a petition to the
Administrator requesting a variance from the treatment standard.  A
particular waste may be significantly different from the wastes on which
the treatment standards are based because the subject waste contains a
more complex matrix that makes it more difficult to treat.  For example,
complex mixtures may be formed when a restricted waste is mixed with
other waste streams by spills or other forms of inadvertent mixing.  As  a
result, the treatability of the restricted waste may be altered such that
it cannot meet the applicable treatment standard.
                                    1-41

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    Variance petitions must demonstrate that the treatment standard

established for a given waste cannot be met.  This demonstration can be

made by showing that attempts to treat the waste by available

technologies were not successful or by performing appropriate analyses of

the waste, including waste characteristics affecting performance, which

demonstrate that the waste cannot be treated to the specified levels.

Variances will not be granted based solely on a showing that adequate

BOAT treatment capacity is unavailable.  (Such demonstrations can be made

according to the provisions in Part 268.5 of RCRA for case-by-case

extensions of the effective date.)  The Agency will consider granting

generic petitions provided that representative data are submitted to

support a variance for each facility covered by the petition.

    Petitioners should submit at least one copy to:

       The Administrator
       U.S. Environmental Protection Agency
       401 M Street, S.W.
       Washington, DC  20460

    An additional copy marked "Treatability Variance" should be submitted

to:

       Chief, Waste Treatment Branch
       Office of Solid Waste (WH-565)
       U.S. Environmental Protection Agency
       401 M Street, S.W.
       Washington, DC  20460

    Petitions containing confidential  information should be sent with

only the  inner envelope marked "Treatability Variance" and "Confidential

Business  Information" and with the contents marked in accordance with the
                                    1-42

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requirements of 40 CFR Part 2 (41 FR 36902, September 1, 1976, amended by

43 FR 4000).

    The petition should contain the following information:

    1.   The petitioner's name and address.

    2.   A statement of the petitioner's interest in the proposed action.

    3.   The name, address, and EPA identification number of the facility
         generating the waste, and the name and telephone number of the
         plant contact.

    4.   The process(es) and feed materials generating the waste and an
         assessment of whether such process(es) or feed materials may
         produce a waste that is not covered by the demonstration.

    5.   A description of the waste sufficient for comparison with the
         waste considered by the Agency in developing BOAT, and an
         estimate of the average and maximum monthly and annual
         quantities of waste covered by the demonstration. (Note:  The
         petitioner should consult the appropriate BOAT background
         document for determining the characteristics of the wastes
         considered in developing treatment standards.)

    6.   If the waste has been treated, a description of the system used
         for treating the waste, including the process design and
         operating conditions.  The petition should include the reasons
         the treatment standards are not achievable and/or why the
         petitioner believes the standards are based on inappropriate
         technology for treating the waste. (Note:  The petitioner should
         refer to the BOAT background document as guidance for
         determining the design and operating parameters that the Agency
         used in developing treatment standards.)

    7.   A description of the alternative treatment systems examined by
         the petitioner (if any); a description of the treatment system
         deemed appropriate by the petitioner for the waste in question;
         and, as appropriate, the concentrations  in the treatment
         residual or extract of the treatment residual (i.e., using the
         TCLP, where appropriate, for stabilized metals) that can be
         achieved by applying such treatment to the waste.

    8.   A description of those parameters affecting treatment selection
         and waste characteristics that affect performance, including
         results of all analyses.  (See Section 3 for a discussion of
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         waste characteristics affecting performance that the Agency has
         identified for the technology representing BOAT.)
    9.    The dates of the sampling and testing.
   10.    A description of the methodologies and equipment used to obtain
         representative samples.
   11.    A description of the sample handling and preparation techniques,
         including techniques used for extraction,  containerization, and
         preservation of the samples.
   12.    A description of analytical procedures used, including QA/QC
         methods.
    After receiving a petition for a variance, the Administrator may
request any additional information or waste samples that may be required
to evaluate and process the petition.  Additionally, all petitioners must
certify that the information provided to the Agency is accurate under
40 CFR 268.4(b).
   .In determining whether a variance will be granted, the Agency will
first look at the design and operation of the treatment system being
used.  If EPA determines that the technology and operation are consistent
with BOAT, the Agency will evaluate the waste to determine if the waste
matrix and/or physical parameters are such that the BOAT treatment
standards reflect treatment of this waste.  Essentially, this latter
analysis will concern the parameters affecting treatment selection and
waste characteristics affecting performance parameters.
    In cases where BOAT is based on more than one technology, the
petitioner will need to demonstrate that the treatment standard cannot be
met using any of the technologies, or that none of the technologies are
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appropriate for treatment of the waste.  After the Agency has made a
determination on the petition, the Agency's findings will be published in
the Federal Register, followed by a 30-day period for public comment.
After review of the public comments, EPA will publish its final
determination in the Federal Register as an amendment to the treatment
standards in 40 CFR Part 268, Subpart D.
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              2.   INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
    According to 40 CFR 261.32, the waste identified as K022 is listed as
follows:
    K022 - Distillation bottom tars from the production of phenol/acetone
           from cumene.
    This section discusses the industry affected by the land disposal
restrictions for K022 waste, describes the process generating the waste,
and presents a summary of available waste characterization data.
2.1      Industry Affected and Process Description
    The Agency estimates that eight facilities in the United States
produce phenol and acetone from cumene and thus generate K022 waste.  The
facilities are located in the eastern, central, and southern States.
Table 2-1 lists these facilities and their locations.
    The cumene process consists of the following basic steps:
(1) oxidation of cumene to a concentrated cumene hydroperoxide;
(2) cleavage of the cumene hydroperoxide to phenol and acetone along with
a variety of other products (e.g., cumylphenols, acetophenone, dimethyl
phenyl carbinol, and alpha methyl styrene); (3) neutralization of the
cleaved products with sodium hydroxide or other suitable base or with
ion-exchange resins; and (4) separation of the phenol and acetone using a
series of distillation columns.  A flow diagram for the cumene production
process is presented in Figure 2-1.
                                    2-1

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1836g
           Table 2-1  Facilities  That  Produce  Phenol  and  Acetone
                     from Cumene--by State  and EPA  Region
State
EPA Region
Facility name and location
111 inois
                     BTL Specialty Resins  Corp.
                     Blue Island,  Illinois
Indiana
                     General  Electric  Company
                     Plastics Business Operations
                     Mount Vernon,  Indiana
Kansas
                   VII
                     Texaco,  inc.
                     Texaco Chemical  Company,  subsidiary
                     El Dorado,  Kansas
Louisiana
                   VI
                     Georgia Gulf Corporation
                     Plaquemine,  Louisiana
Ohio
                     Aristech Chemical  Corporation
                     Haverhill,  Ohio
Pennsylvania
                     Al1ied Signal,  Inc.
                     Allied Corp.,  Chemical  Sector
                     Frankford,  Pennsylvania
Texas
Texas
                   VI
                   VI
                     Oow Chemical U.S.A.
                     Oyster Creek,  Texas

                     Shell Oi1  Company
                     Shell Chemical Company,  division
                     Deer Park, Texas
Reference:  SRI 1987.
                                  2-2

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       CUUENE
                                                                                                      HECOVCHfO
                                                                                                       CUMENE
                                                                       UOHT ENDS
                                                                       TO ACETONE
                                                                       PURIFICATION
                                                                                                                                              ACETOPHENONE
ro
 i
CO
      SOOIUU
      STEARATE
             HVDROPEROXIOATION
                 REACTOR
                                                                        ACETONE
                                                                                          WATER
                                     CUUENE
                                   DISTILLATION
     DILUTE
     NtOH
 CLEAVAGE
 REACTOR/
 SEPARATOR/
NEUTRALIZED
 SEPARATOH
                                                                       ACETONE
                                                                      DISTILLATION
 WATER
  WASH
 TOWER
   OR
DEIONIZER
                                                      CUUENE
                                                     DISTILLATION
  PHENOL
DISTILLATION/
PURIFICATION
ACETOPHENOL
  COLUMN
                                                                                                                                                         Koaa
                                                                                                                                                        WASTE
                                                                                     WASTE-
                                                                                     WATER
                                                                                                                           PHENOL
                        FIGURE  2-1   SCHEMATIC DIAGRAM  FOR  PRODUCTION  OF PHENOL AND ACETONE FROM CUMENE

-------
    Cumene hydroperoxide is the first reaction product when cumene is
oxidized with air at 130°C in an aqueous sodium carbonate medium.
The reaction mix is circulated to a vacuum column where untreated cumene
is separated from the mix.  The cumene is recycled to the reactor and any
alpha methyl styrene contained in the recovered cumene is separated by
distillation.  The recovered alpha methyl styrene can undergo further
processing, be sold, or be incinerated.  The cumene hydroperoxide mixture
from the bottoms products of the vacuum column is reacted with 10 to
25 percent sulfuric acid at about 60°C and co-mixed with an inert
solvent (such as benzene) to extract organic material from the aqueous
acid.  .After settling, the acid phase is separated out and recycled to
the process.  The organic phase is neutralized with sodium hydroxide (or
another suitable base) or with ion-exchange resins.  The resultant
aqueous waste stream, which contains sodium sulfate, sodium phenate,
phenol, acetone, and sodium stearate, is separated and sent to wastewater
treatment.  The crude, neutralized organic layer is sent to a series of
distillation columns where acetone, cumene, phenol, acetophenone, and the
solvent are recovered.  The first column separates a crude acetone
product overhead that is further purified by distillation.  The bottoms.
from the acetone distillation column are passed through a water scrubber
to remove  residual acetone and inorganic salts.  The bottoms are then
passed through a series of columns where the lower boiling hydrocarbons,
solvents,  cumene, and alpha methyl styrene are removed and subsequently
recovered, recycled, or disposed of.  The crude phenol is refined in
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the next distillation column.  The purified phenol is removed overhead
and the bottoms may be further distilled to recover acetophenone.  The
still bottoms remaining at the completion of distillation are the waste
stream K022.
2.2      Waste Characterization
    This section includes all waste characterization data available to
the Agency for K022 waste.  The approximate percent concentrations of the
major constituents composing K022 waste are listed in Table 2-2.   The
percent concentration in the waste was determined from engineering
judgment based on analytical results and literature data.  The ranges of
BOAT constituents present in the waste and all other available parameters
affecting treatment selection data are presented in Table 2-3.  The data
show a waste with high concentrations of organic constituents
(approximately 82 to 93 percent as indicated by total organic carbon
levels), low concentrations of moisture, and low ash content.  Individual
BOAT constituent concentrations include approximately 0.1 to 50 percent
acetophenone, 0.1 to 10 percent phenol, and less than 0.1 percent other
BOAT list constituents.
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1836g

          Table  't-'i.    Constituent Analysis of  Untreated K.022 Waste
                                         Range of concentration
Constituent                                   data (wt "/,)
Acetophenone                                        0.1-50
Phenol                                              0.1-10
Other BOAT constituents                            <0.1
Tarsa                                             1-50
Total organic carbon                              52-93
dTars may include acetophenone and phenol, as well as other polyaromat1C
 ring structures.
'Total organic carbon includes the carbon from the acetophenone,
 phenol, tars, alpha methyl styrene. cumylphenol, etc.

Reference:  Environ 1985.
                                     2-6

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1837g
                Table 2-3  BOAT Constituent Concentrations and Other Data
BOAT                                                       Untreated  waste
ref.                                                      concentration  (mg/kg)
no.             BOAT list constituent                Plant 1                 Plant  2
                This  table contains RCRA Confidential Business Information.
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            3.  APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
    This section describes the applicable and demonstrated treatment
technologies for K022 waste.  The identification of these treatment
technologies is based on data obtained from field testing, data submitted
by industry, and current literature sources.  Detailed discussions are
provided for the demonstrated technologies.
3.1      Applicable Treatment Technologies
    The Agency has identified fuel substitution and incineration as being
applicable for BOAT list organics in K022 waste.  Fuel substitution and
incineration technologies are designed to destroy the toxic organics
present in the waste fuel.  Use of these technologies results in a
residual ash that may contain BOAT list metals, the applicable technology
for which is stabilization.  Stabilization is designed to reduce the
Teachability of metals in the treated residual.  Note that both fuel
substitution and incineration may result in a residual scrubber water
that requires further treatment for metals.  The applicable technologies
for such a residual are chemical precipitation, chromium reduction, and
other wastewater treatment  technologies.
3.2      Demonstrated Treatment Technologies
    The technologies demonstrated for the BOAT list organics in this
waste or in wastes with similar parameters affecting treatment selection
(i.e., high organic content, low water content, and low ash content) are
fuel substitution and incineration, including liquid injection
incineration, rotary kiln incineration, and fluidized bed incineration.
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    EPA believes fuel substitution is a demonstrated treatment technology
for untreated K022 waste because fuel substitution is being used on a
full-scale basis to treat this and similar waste.  The Agency knows of
six generators using fuel substitution for treatment of K022 waste
specifically.  Performance data collected by EPA for fuel substitution of
K022 waste in an industrial boiler are discussed in Section 4.  A
discussion of fuel substitution is presented in Section 3.2.1.
    EPA is not aware of any generators or TSD facilities currently using
incineration for treatment of K022 waste.  While performance data are not
available for incineration, this technology has been demonstrated on
wastes with similar waste characteristics affecting performance.  A
discussion of incineration treatment technologies is presented in
Section 3.2.2.
    EPA also is not aware of any generator or treatment, storage, and
disposal (TSD) facility currently using stabilization for treatment of
the residuals obtained from treatment of K022 wastes.  However,
stabilization has been demonstrated for BOAT list metals in kiln ash
residues and other nonwastewater wastes, e.g., F006 waste.   The
parameters affecting treatment selection in such wastes are similar to
those of K022 ash residues.  Thus, the Agency believes that stabilization
is, for the purposes of the BOAT program, demonstrated for K022 inorganic
nonwastewaters.  A discussion of stabilization is presented in
Section 3.2.3.
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    EPA knows of at least one facility that generates K022 wastewater as
a scrubber water.  Other potential sources of K022. wastewater include
CERCLA site wastes, RCRA facility corrective action wastes, and landfill
leachates.  The Agency is not aware of any generator or TSD facility that
currently treats such wastewaters.  Because characterization data are not
available for K022 wastewater specifically, the Agency cannot identify
similar wastes or technologies that are demonstrated for the similar
wastes and therefore for K022 wastewaters.
    The Agency intends to collect data on K022 wastewater, identify
demonstrated technologies, and develop BOAT treatment standards by
May 8, 1990.
3.2.1    Fuel Substitution
    Fuel substitution involves using hazardous waste as a fuel in
industrial furnaces or in boilers for generation of steam.  The hazardous
waste may be blended with other nonhazardous wastes (e.g., municipal
sludge) and/or fossil fuels.
    (1)  Applicability and use of fuel substitution.  Fuel substitution
has been used with industrial waste solvents, refinery wastes, synthetic
fibers/petrochemical wastes, and waste oils.  It can also be used when
combusting other waste types produced during the manufacturing of
Pharmaceuticals, pulp and paper, and pesticides.  These wastes can be
handled in a solid, liquid, or gaseous form.
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    The most common types of units in which waste fuels are burned are
industrial furnaces and industrial boilers.  Industrial furnaces include
a diverse variety of industrial processes that produce heat and/or
products by burning fuels.  They include blast furnaces, smelters, and
coke ovens.  Industrial boilers are units wherein fuel is used to produce
steam for process and plant use.  Industrial boilers typically use coal,
oil, or gas as the primary fuel source.
    A number of parameters affect the selection of fuel substitution.
These parameters are:
    •  Halogen content of the waste;
    •  Inorganic solids content (ash content) of the waste,
       particularly heavy metals;
    •  Hea-ting value of the waste;
    •  Viscosity of the waste  (for liquids);
    •  Filterable solids concentration (for liquids); and
    •  Sulfur content.
    If halogenated organics are burned, halogenated acids and free
halogen are among the products of combustion.  These released corrosive
gases may require subsequent treatment prior to venting to the
atmosphere.  Also, halogens and halogenated acids formed during
combustion are likely to severely corrode boiler tubes and other process
equipment.  To minimize such problems, halogenated wastes are blended
into fuels only at very low concentrations.  High chlorine content can
also lead to the incidental production (at very low concentrations) of
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other hazardous compounds such as polychlorinated biphenyls (PCBs),
chlorinated dibenzo-p-dioxins (PCDDs), chlorinated dibenzofurans (PCDFs),
and chlorinated phenols.
    High inorganic solids content (i.e., ash content) of wastes may cause
two problems:  (1) scaling in the boiler and (2) particulate air
emissions.  Scaling results from deposition of inorganic solids on the
walls of the boiler.  Particulate emissions are produced by
noncombustible inorganic constituents that flow out of the boiler with
the gaseous combustion products.  Because of these problems, wastes with
significant concentrations of inorganic materials are usually not handled
in boilers unless they have an air pollution control.system.
    Industrial furnaces vary in their tolerance to inorganic
constituents.  Heavy metal concentrations, found in both halogenated and
nonhalogenated wastes used as fuel, can cause environmental concern
because they may be emitted in the gaseous emissions from the combustion
process, in the ash residues, or in any produced solids.  The
partitioning of the heavy metals to these residual streams primarily
depends on the volatility of the metal, the waste matrix, and the furnace
design.
    The heating value of the waste must be sufficiently high (either
alone or in combination with other fuels) to maintain combustion
temperatures consistent with efficient waste destruction and operation of
the boiler or furnace.  For many applications, only supplemental fuels
having minimum heating values of 4,400 to 5,600 kcal/kg (8,000 to
10,000 Btu/lb) are considered to be feasible.  Below this value, the
unblended fuel would not be likely to maintain a stable flame, and its
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combustion would release insufficient energy to provide the needed steam
generation potential in the boiler or the necessary heat for an
industrial furnace.  Some wastes with heating values of less than
4,400 kcal/kg (8,000 Btu/lb) can be used if sufficient auxiliary fuel is
employed to support combustion or if special designs are incorporated
into the combustion device.  Occasionally, for wastes with heating values
higher than virgin fuels, blending with auxiliary fuel may be required to
prevent overheating or overcharging the combustion device.
    In combustion devices designed to burn liquid fuels, the viscosity of
the liquid waste must be low enough that it can be atomized in the
combustion chamber.  If viscosity is too high, heating of storage tanks
may be required prior to combustion.  For atomization of liquids, a
viscosity of 165 centistokes (750 Saybolt Seconds Universal (SSU)) or
less is typically required.
    If filterable material suspended in the liquid fuel prevents or
hinders pumping or atomization, it will be unacceptable.
    Sulfur content in the waste may prevent burning of the waste because
of the potential for atmospheric emissions of sulfur oxides.  For
instance, Federal sulfur oxide emission regulations have been proposed
for certain new source industrial boilers (51 FR 22385).  Air pollution
control devices are available to remove sulfur oxides from the stack
gases.
    (2)  Underlying principles of operation.  For a boiler and most
industrial furnaces there are two distinct principles of operation.
Initially, energy in the form of heat is transferred to the waste to

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achieve volatilization of the various waste constituents.  For liquids,
volatilization energy may also be supplied by using pressurized
atomization.  The energy used to pressurize the liquid waste allows the
atomized waste to break into smaller particles, thus enhancing its rate
of volatilization.  The volatilized constituents then require additional
energy to destabilize the chemical bonds and allow the constituents to
react with oxygen to form carbon dioxide and water vapor.  The energy
needed to destabilize the chemical bonds is referred to as the energy of
activation.
    (3)  Description of the fuel substitution process.  As stated
previously, a number of industrial applications can use fuel
substitution; therefore, no one process description will fit all of these
applications.  However, the following section provides a general
description of industrial kilns (one form of industrial furnace) and
industrial boilers.
         (a)  Kilns.  Combustible wastes have the potential to be used as
fuel in kilns and, for waste liquids, are often used with oil to co-fire
kilns.  Coal-fired kilns are capable of handling some solid wastes.  In
the case of cement kilns, there are usually no residuals requiring land
disposal, since any ash formed becomes part of the product or is removed
by particulate collection systems and recycled back to the kiln.  The
only residuals may be low levels of unburned gases that escape with the
combustion products.  If this is the case, air pollution control devices
may be required.
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    Three types of kilns are particularly applicable:  cement kilns,  lime
kilns, and lightweight aggregate kilns.
         (i)  Cement kilns.  The cement kiln is a rotary furnace that is
a refractory-lined steel shell used to calcine a mixture of calcium,
silicon, aluminum, iron, and magnesium-containing minerals.  The kiln is
normally fired by coal or oil.  Liquid and solid combustible wastes  may
then serve as auxiliary fuel.  Temperatures within the kiln are typically
between 1,380 and 1,540°C (2,500 to 2,800°F).  To date,  only
liquid hazardous wastes have been burned in cement kilns.
    Most cement kilns have a dry particulate collection  device (i.e.,
either an electrostatic precipitator or a baghouse) with the collected
fly ash recycled back to the kiln.  Buildup of metals or other
noncombustibles is prevented through their incorporation in the product
cement.  Many types of cement require a source of chloride so that most
halogenated liquid hazardous wastes currently can be burned in cement
kilns.  Available information shows that scrubbers are not used.
         (ii)  Lime kilns.  Quick-lime (CaO) is manufactured in a
calcination process using limestone (CaCO ) or dolomite (CaCO  and
MgCO  ).  These raw materials are also heated in a refractory-lined
rotary kiln, typically to temperatures of 980 to 1,260°C (1,800 to
2,300°F).  Lime kilns are less likely to burn hazardous wastes than
are cement kilns because product lime is often added to potable water
systems.  Only one lime kiln currently burns hazardous waste in the  U.S.
That  particular facility sells its product lime for use as flux or as
refractory in blast furnaces.

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    As with cement kilns, any collected fly ash is recycled back to the
lime kiln, resulting in no residual streams from the kiln.  Available
information shows that scrubbers are not used.
       (iii)  Lightweight aggregate kilns.  Lightweight aggregate kilns
heat clay to produce an expanded lightweight inorganic material used in
Portland cement formulations and other applications.  The kiln has a
normal temperature range of 1,100 to 1,150°C (2,000 to 2,100°F).
Lightweight aggregate kilns are less amenable to combustion of hazardous
wastes as fuels than are the other kilns described above because these
kilns lack material to adsorb halogens.  As a result, burning of
halogenated organics in such kilns would likely require afterburners to
ensure complete destruction of the halogenated organics and scrubbers to
control acid gas production.  Such controls would produce a wastewater
residual stream subject to treatment standards.
         (b)  Industrial boilers.  A boiler is a closed vessel in which
water is transformed into steam by the application of heat.  Normally,
heat  is supplied by the combustion of pulverized coal, fuel oil, or gas.
These fuels are fired into a combustion chamber with nozzles and burners
that  provide mixing with air.  Liquid wastes, and granulated solid wastes
in the case of grate-fired boilers, can be burned as auxiliary fuel in a
boiler.  Few grate-fired boilers burn hazardous wastes, however.  For
liquid-fired boilers, residuals requiring land disposal are only
generated when the boiler is shut down and cleaned.  This is generally
done  once or twice per year.  Other residuals from liquid-fired boilers
would be the gas emission stream, which would consist of any products of

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incomplete combustion, along with the normal combustion products.  For
example, chlorinated wastes would produce acid gases.  If this is the
case, air pollution control devices may be required.  For solid-fired
boilers, an ash normally is generated.  This ash may contain residual
amounts of organics from the blended waste/fuels as well as
noncombustible materials.  Land disposal of this ash would require
compliance with applicable BOAT treatment standards.
     (4)  Waste characteristics affecting performance.  For cement kilns,
lime kilns, and lightweight aggregate kilns burning nonhalogenated wastes
(i.e., no scrubber is needed to control acid gases), no residual waste
streams would be produced.  Any noncombustible material in the waste
would leave the kiln  in the product stream.  As a result, in transferring
standards EPA would not examine waste characteristics affecting
performance, but rather would determine the applicability of fuel
substitution.  That is, EPA would investigate the parameters affecting
treatment selection.  For  kilns these parameters (as mentioned
previously) are Btu content, percent  filterable solids, halogenated
organics content, viscosity, and sulfur content.
     Lightweight aggregate  kilns burning halogenated organics and boilers
burning wastes containing  any noncombustibles will produce residual
streams subject to treatment standards.  In determining whether  fuel
substitution is likely to  achieve the same  level of performance  on an
untreated waste as on a previously treated waste, EPA will examine:
(1)  relative volatility of the waste  constituents,  (2) the heat  transfer
characteristics (for  solids), and (3) the activation energy for
combustion.
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         (a)  Relative volatility.  The term relative volatility (a)
refers to the ease with which a substance present in a solid or a liquid
waste will  vaporize from that waste upon application of heat from an
external source.  Hence, it bears a relationship to the equilibrium vapor
pressure of the substance.
    EPA recognizes that the relative volatilities cannot be measured or
calculated directly for the types of wastes generally treated in an
industrial  boiler or furnace.  The Agency believes that the best measure
of relative volatility is the boiling point of the various hazardous
constituents, and therefore will use this parameter in assessing
volatility of the organic constituents.
         (b)  Heat transfer characteristics.  Consistent with the
underlying principles of combustion in aggregate kilns or boilers, a
major factor with regard to whether a particular constituent will
volatilize is the transfer of heat through the waste.  In the case of
industrial  boilers burning solid fuels, heat is transferred through the
waste by three mechanisms:  radiation, convection, and conduction.  For a
given boiler it can be assumed that the type of waste will have a minimal
impact on the heat transferred from radiation.  With regard to
convection, EPA believes that the range of wastes treated would exhibit
similar properties with regard to the amount of heat transferred by
convection.  Therefore, EPA will not evaluate radiation convection heat
transfer properties of wastes in determining similar treatability.  For
solids, the third heat transfer mechanism, conductivity, is the one
principally operative or most likely to change between wastes.

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    Using thermal conductivity measurements as part of a treatability
comparison for -two different wastes through a given boiler or furnace is
most meaningful when applied to wastes that are homogeneous.  As wastes
exhibit greater degrees of nonhomogeneity, thermal conductivity becomes
less accurate in predicting treatability, because the measurement
essentially reflects heat flow through regions having the greatest
conductivity (i.e., the path of least resistance and not heat flow
through all parts of the waste).  Nevertheless, EPA has not identified a
better alternative to thermal conductivity, even for wastes that are
nonhomogeneous.
    Other parameters considered for predicting heat transfer
characteristics were Btu value, specific heat, and ash content.  These
parameters can neither better account for nonhomogeneity nor better
predict heat transferability through the waste.
          (c)  Activation energy.  Given an excess of oxygen, an organic
waste in  an industrial furnace or boiler would be expected to convert to
carbon monoxide  and water provided that the activation energy is
achieved.  Activation energy is the quantity of heat (energy) needed to
destabilize molecular bonds and create reactive intermediates so that the
oxidation  (combustion) reaction will proceed to completion.  As a measure
of activation energy, EPA is using bond dissociation energies.  In
theory, the bond dissociation energy would be equal to the activation
energy;   in practice, however, this  is not always the case.
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    In some instances, bond energies will not be available and will have
to be estimated, or other energy effects (e.g., vibrational) and other
reactions will have a significant influence on activation energy.
Because of the shortcomings of bond energies in estimating activation
energy, therefore, EPA analyzed other waste characteristic parameters to
determine if these parameters would provide a better basis for
transferring treatment standards from an untested waste to a tested
waste.  These parameters included heat of combustion, heat of formation,
use of available kinetic data to predict activation energies, and general
structural class.  All of these parameters were rejected for the reasons
provided below.
    The heat of combustion measures only the difference in energy of the
products and reactants; it does not provide information on the transition
state  (i.e., the energy input needed to  initiate the reaction).  Heat of
formation is used as a predictive tool to determine whether reactions are
likely to proceed; however, data are not available for a significant
number of hazardous constituents.  Use of available kinetic data was
rejected because while these data could  be used to calculate some free
energy values  (AG), they could not be used for the wide range of
hazardous constituents.  Finally, EPA decided not to use structural
classes because the Agency believes that evaluation of bond dissociation
energies allows for a more direct comparison.
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    (5)  Design and operating parameters.
         (a)  Design parameters.  Cement kilns and lime kilns, along with
aggregate kilns burning nonhalogenated wastes, produce no residual
streams.  Their design and operation is such that any wastes that are
incompletely destroyed will be contained in the product.  As a result,
the Agency will not look at design and operating values for such devices,
since treatment, per se, cannot be measured through detection of
constituents in residual streams.  In this instance, it is important
merely to ensure that the waste is appropriate for combustion in the
kilns and that the kiln is operated in a manner that will produce a
usable product.
    Specifically, cement, lime, and aggregate kilns are only demonstrated
for liquid hazardous wastes.  Such wastes must be sufficiently free of
filterable solids to avoid plugging the burners at the hot end of the
kiln.  Viscosity also must be low enough to inject the waste into the
kiln through the burners.  The sulfur content is not a concern unless the
concentration  in the waste is sufficiently high as to exceed Federal,
State, or local air pollution standards promulgated for industrial
boilers.
    The design parameters that normally affect the operation of an
industrial boiler (and aggregate kilns with residual streams) with
respect to hazardous waste treatment are (1) the design temperature,
(2) the design retention time of the waste in the combustion chamber, and
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(3) turbulence in the combustion chamber.  Evaluation of these parameters
would be important in determining if an industrial boiler or industrial
furnace is adequately designed for effective treatment of hazardous
wastes.  The rationale for selection of these three parameters is given
below.
         (i)  Design temperature.  Industrial boilers are generally
designed based on their steam generation potential (Btu output).  This
factor is related to the design combustion temperature, which in turn
depends on the amount of fuel burned and its Btu value.  The fuel feed
rates and combustion temperatures of industrial boilers are generally
fixed based on the Btu values of fuels normally handled (e.g., No. 2
versus No. 6 fuel oils).  When wastes are to be blended with fossil fuels
for combustion, the blending, based on Btu values, must be such that the
resulting Btu value of the mixture is close to that of the fuel value
used  in the design of the boiler.  Industrial furnaces also are designed
to operate at specific ranges of temperature in order to produce the
desired product (e.g., lightweight aggregate).  The blended waste/fuel
mixture should be capable of maintaining the design temperature range.
         (ii)  Retention time.  A sufficient retention time of combustion
products is normally necessary to ensure that the hazardous substances
being combusted (or formed during combustion) are completely oxidized.
Retention times on the order of a few seconds are generally needed at
normal operating conditions.  For industrial furnaces as well as boilers,
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the retention time is a function of the size of the furnace and the fuel
feed rates.  For most boilers and furnaces the retention time usually
exceeds a few seconds.
         (iii)  Turbulence.  Boilers are designed so that fuel and air
are intimately mixed.  This helps ensure that complete combustion takes
place.  The shape of the boiler and the method of fuel and air feed
influence the turbulence required for good mixing.  Industrial furnaces
also are designed for turbulent mixing where fuel and air are mixed.
         (b)  Operating parameters.  The operating parameters that
normally affect the performance of an industrial boiler and many
industrial furnaces with respect to treatment of hazardous wastes are
(1) air feed rate, (2) fuel feed rate, (3) steam pressure or rate of
production, and (4) temperature.  EPA believes that these four parameters
will be used to determine whether an industrial boiler burning blended
fuels that contain hazardous waste constituents is operated properly.
The rationale for selecting these four parameters is given below.  Most
industrial furnaces will monitor similar parameters, but some exceptions
are noted.
         (i)  Air feed rate.  An important operating parameter in boilers
and many industrial furnaces is the oxygen content in the flue gas, which
is a function of the air feed rate.  Stable combustion of a fuel
generally occurs within a specific range of air-to-fuel ratios.  An
oxygen analyzer in the combustion gases can be used to control the feed
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ratio of air to fuel to assure complete thermal destruction of the waste
and efficient operation of the boiler.  When necessary, the air feed rate
can be increased or decreased to maintain proper fuel-to-oxygen ratios.
Some industrial furnaces do not completely combust fuels (e.g., coke
ovens and blast furnaces); hence, oxygen concentration in the flue gas is
a meaningless variable.
         (ii)  Fuel feed rate.  The rate at which fuel is injected into
the boiler or industrial furnace will determine the thermal output of the
system per unit of time (Btu/hr).  If steam is produced, steam pressure
monitoring will indirectly determine  if the fuel feed rate is adequate.
However, various velocity and mass measurement devices can be used to
monitor fuel flow directly.
         (iii)  Steam pressure or rate of production.  Steam pressure in
boilers provides a direct measure of  the thermal output of the system and
is directly monitored by use of in-system pressure gauges.  Increases or
decreases in steam pressure can be effected by increasing or decreasing
the fuel and air feed rates within certain operating design limits.  Most
industrial furnaces do not produce steam; instead, they produce a product
(e.g., cement, aggregate) and monitor the rate of production.
         (iv)  Temperature.  Temperatures are monitored and controlled in
industrial boilers to assure the quality and flow rate of steam.
Therefore, complex monitoring systems are frequently installed in the
combustion unit to provide a direct reading of temperature.  The
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efficiency of combustion in industrial boilers is dependent on combustion
temperatures.  Temperature may be adjusted to design settings by
increasing or decreasing the air and fuel feed rates.
    Wastes should not be added to primary fuels until the boiler
temperature reaches the minimum needed for destruction of the wastes.
Temperature instrumentation and control should be designed to stop the
addition of waste in the event of process upsets.
    Monitoring and control of temperature in industrial furnaces are also
critical to the product quality, e.g., lime, cement, or aggregate kilns
that require minimum operating temperatures.  Kilns have very high
thermal inertia in the refractory and  in-process product, high residence
times, and high air feed rates, so that even if the fuel flow to the kiln
should stop momentarily, organic constituents would still continue to be
destroyed.  The main operational control required for wastes burned  in
kilns is to stop waste flow in the event of low kiln temperature, loss of
electrical power to the combustion air fan, and loss of primary fuel flow.
         (v)  Other operating parameters.   In addition to the four
operating parameters discussed above,  EPA considered and then discarded
one additional parameter--fuel-to-waste blending ratios.  However, while
blending is done to yield a uniform Btu content fuel, blending ratios
will vary greatly depending on the Btu content of the wastes and the
fuels being used.
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3.2.2    Incineration
    This section addresses the commonly used incineration technologies:
liquid injection, rotary kiln, fluidized bed, and fixed hearth.  A
discussion is provided regarding the applicability of these technologies,
their underlying principles of operation, a technology description, waste
characteristics that affect performance, and, finally, important design
and operating parameters.  As appropriate, the subsections are divided by
type of incineration unit.
    (1)  Applicability and use of incineration.
         (a)  Liquid injection.  Liquid injection is applicable to wastes
that have viscosity values low enough that the waste can be atomized in
the combustion chamber.  A range of literature maximum viscosities are
reported, with the low being 100 SSU and the high being 10,000 SSL).  It
is important to note that viscosity is temperature dependent so that
while liquid injection may not be applicable to a waste at ambient
conditions, it may be applicable when the waste is heated.  Other factors
that affect the use of liquid injection are particle size and the
presence of suspended solids.  Both of these waste parameters can cause
plugging of the burner nozzle.
         (b)  Rotary kiln/fluidized bed/fixed hearth.  These incineration
technologies are applicable to a wide range of hazardous wastes.  They
can be used on wastes that contain high or low total organic content,
high or low filterable solids, various viscosity ranges, and a number of
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other waste parameters.  EPA has not found these technologies to be
demonstrated on wastes that are composed essentially of metals with low
organic concentrations.  In addition, the Agency expects that some of the
high metal content wastes may not be compatible with existing and future
air emission limits without emission controls far more extensive than
those currently practiced.
    (2)  Underlying principles of operation.
         (a)  Liquid injection.  The basic operating principle of this
incineration technology is that incoming liquid wastes are first
volatilized and then additional heat is supplied to the waste to
destabilize the chemical bonds.  Once the chemical bonds are broken,
these constituents react with oxygen to form carbon dioxide and water
vapor.  The energy needed to destabilize the bonds is referred to as the
energy of activation.
         (b)  Rotary kiln and fixed hearth.  There are two distinct
principles of operation for these incineration technologies, one for each
of the chambers involved.  In the primary chamber, energy, in the form of
heat, is transferred to the waste to achieve volatilization of the
various organic waste  constituents.  During this volatilization process
some of the organic constituents will oxidize to carbon dioxide and water
vapor.  In the secondary chamber, additional heat is supplied to overcome
the energy requirements needed to destabilize the chemical bonds and
allow the constituents to react with excess oxygen to form carbon dioxide
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and water vapor.  The principle of operation for the secondary chamber is
similar to that of liquid injection.
         (c)  Fluidized bed.  The principle of operation for this
incineration technology differs somewhat from that for rotary kiln and
fixed hearth incineration relative to the functions of the primary and
secondary chambers.  In fluidized bed incineration, the purpose of the
primary chamber is not only to volatilize the wastes but also to
essentially combust the waste.  Destruction of the waste organics can be
better accomplished in the primary chamber of this technology than in
rotary kiln and fixed hearth incineration because of (1) improved heat
transfer from fluidization of the waste using forced air and (2) the fact
that the fluidization process provides sufficient oxygen and turbulence
to convert the organics to carbon dioxide and water vapor.  The secondary
chamber (referred to as the freeboard) generally does not have an
afterburner;  however, additional time is provided for conversion of the
organic constituents to carbon dioxide, water vapor, and hydrochloric
acid if chlorine is present in the waste.
     (3)  Description of the incineration process.
         (a)  Liquid injection.  The liquid injection system is capable
of incinerating a wide range of gases and liquids.  The combustion system
has  a simple design with virtually no moving parts.  A burner or nozzle
atomizes the liquid waste and injects it into the combustion chamber
where it burns  in the presence of air or oxygen.  A forced draft system
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supplies the combustion chamber with air to provide oxygen for combustion
and turbulence for mixing.  The combustion chamber is usually a cylinder
lined with refractory (i.e., heat resistant) brick and can be fired
horizontally, vertically upward, or vertically downward.  Figure 3-1
illustrates a liquid injection incineration system.
         (b)  Rotary kiln.  A rotary kiln is a slowly rotating,
refractory-lined cylinder that is mounted at a slight incline from the
horizontal (see Figure 3-2).  Solid wastes enter at the high end of the
kiln, and liquid or gaseous wastes enter through atomizing nozzles in the
kiln or afterburner section.  Rotation of the kiln exposes the solids to
the heat, vaporizes them, and allows them to combust by mixing with air.
The rotation also causes the ash to move to the lower end of the kiln
where it can be removed.  Rotary kiln systems usually have a secondary
combustion chamber or afterburner following the kiln for further
combustion of the volatilized components of solid wastes.
         (c)  Fluidized bed.  A fluidized bed incinerator consists of a
column containing inert particles such as sand, which is referred to as
the bed.  Air, driven by a blower, enters the bottom of the bed to
fluidize the sand.  Air passage through the. bed promotes rapid and
uniform mixing of the injected waste material within the fluidized bed.
The fluidized bed has an extremely high heat capacity (approximately
three times that of flue gas at the same temperature), thereby providing
a large heat reservoir.  The injected waste reaches the ignition
                                    3-22

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                                                                    WATER
      AUXILIARY FUEL
-H BURNER
                        AIR-
OJ
I
tv>
00 LIQUID OR  GASEOUS.
    WASTE INJECTION
-»>| BURNER
               PRIMARY
             COMBUSTION
               CHAMBER
AFTERBURNER
 (SECONDARY
 COMBUSTION
  CHAMBER)
 SPRAY
CHAMBER
                                                                                   GAS TO AIR
                                                                                   POLLUTION
                                                                                   CONTROL
                            HORIZONTALLY  FIRED
                            LIQUID INJECTION
                            INCINERATOR
                                                       ASH
                                              WATER
                                             FIGURE 3-1
                               LIQUID  INJECTION  INCINERATOR

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                                                                GAS TO
                                                             AIR POLLUTION
                                                                CONTROL
                       AUXILIARY
                           FUEL
                                               AFTERBURNER
   SOLID
  WASTE
INFLUENT
   FEED
MECHANISM
                                                                    COMBUSTION
                                                                    GASES
                             LIQUID OR
                             GASEOUS
                              WASTE
                             INJECTION
                                                                  ASH
                                     FIGURE 3-2
                            ROTARY KILN  INCINERATOR
                                      3-24

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temperature quickly and transfers the heat of combustion back to the
bed.  Continued bed agitation by the fluidizing air allows larger
particles to remain suspended in the combustion zone (see Figure 3-3).
         (d)  Fixed hearth incineration.  Fixed hearth incinerators, also
called controlled air or starved air incinerators, are another major
technology used for hazardous waste incineration.  Fixed hearth
incineration is a two-stage combustion process (see Figure 3-4).  Waste
is ram-fed into the first stage, or primary chamber, and burned at less
than stoichiometric conditions.  The resultant smoke and pyrolysis
products, consisting primarily of volatile hydrocarbons and carbon
monoxide, along with the normal products of combustion, pass to the
secondary chamber.  Here, additional air is injected to complete the
combustion.  This two-stage process generally yields low stack
particulate and carbon monoxide (CO) emissions.  The primary chamber
combustion reactions and combustion gas are maintained at low levels by
the starved air conditions so that particulate entrainment and carryover
are minimized.
         (e)  Air pollution controls.  Following incineration of
hazardous wastes, combustion gases are generally further treated in an
air pollution control system.  The presence of chlorine or other halogens
in the waste requires a scrubbing or absorption step to remove hydrogen
chlorioe and other halo-acids from the combustion gases.  Ash in the
waste is not destroyed in the combustion process.  Depending on its
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  WASTE
INJECTION
BURNER
                              FREEBOARD
                              SAND BED
                                                          GAS TO
                                                          AIR POLLUTION
                                                          CONTROL
                                                         MAKE-UP
                                                         SAND
                                                          AIR
                                 ASH
                             FIGURE 3-3
                    FLUIDIZED  BED INCINERATOR
                                   3-26

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                 AIR
         WASTE
       INJECTION
BURNER
ro
                                                        AIR
                                                        GAS TO AIR
                                                        POLLUTION
                                                        CONTROL
  PRIMARY
COMBUSTION
 CHAMBER

   GRATE
                                                        SECONDARY
                                                        COMBUSTION
                                                         CHAMBER
                                    1
                                                        AUXILIARY
                                                        FUEL
                 2-STAGE  FIXED HEARTH
                     INCINERATOR
                                   ASH
                                         FIGURE 3-4
                              FIXED  HEARTH  INCINERATOR

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composition, ash will either exit as bottom ash, at the discharge end of
a kiln or hearth for example, or as participate matter (fly ash)
suspended in the combustion gas stream.  Particulate emissions from most
hazardous waste combustion systems generally have particle diameters of
less than 1 micron and require high efficiency collection devices to
minimize air emissions.  In addition, scrubber systems provide an
additional buffer against accidental releases of incompletely destroyed
waste products resulting from poor combustion efficiency or combustion
upsets, such as flameouts.
    (4)  Waste characteristics affecting performance.
         (a)  Liquid injection.  In determining whether liquid injection
is likely to achieve the same level of performance on an untested waste
as on a previously tested waste, the Agency will compare the dissociation
bond energies of the constituents in the untested and tested wastes.
This parameter is being used as a surrogate indicator of activation
energy, which, as discussed previously, destabilizes molecular bonds.  In
theory, the bond dissociation energy would be equal to the activation
energy; in practice, however, this is not always the case.  Other energy
effects (e.g., vibrational, the formation of intermediates, and
interactions between different molecular bonds) may have a significant
influence on activation energy.
    Because of the shortcomings of bond energies in estimating activation
energy, EPA analyzed other waste characteristic parameters to determine
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whether these parameters would provide a better basis for transferring
treatment standards from an untested waste to a tested waste.  These
parameters include heat of combustion, heat of formation, use of
available kinetic data to predict activation energies, and general
structural class.  All of these parameters were rejected for the reasons
provided below.
    The heat of combustion measures only the difference in energy of the
products and reactants; it does not provide information on the transition
state.  Heat of formation is used as a predictive tool to determine
whether reactions are likely to proceed; however, data are not available
for a significant number of hazardous constituents.  Use of kinetic data
was rejected because these data are limited and could not be used to
calculate free energy values (AG) for the wide range of hazardous
constituents to be addressed by this rule.  Finally, EPA decided not to
use structural classes because the Agency believes that evaluation of
bond dissociation energies allows for a more direct determination of
whether a constituent will be destabilized.
          (b)  Rotary kiln/fluidized bed/fixed hearth.  Unlike liquid
injection, these incineration technologies also generate a residual ash.
Accordingly, in determining whether these technologies are likely to
achieve the same level of performance on an untested waste as on a
previously tested waste, EPA would need to examine the waste
characteristics that affect volatilization of organics from the waste, as
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well as destruction of the organics once volatilized.  Relative to
volatilization, EPA will examine thermal conductivity of the entire waste
and the boiling point of the various constituents.  As with liquid
injection, EPA will examine bond energies in determining whether
treatment standards for scrubber water residuals can be transferred from
a tested waste to an untested waste.  Below is a discussion of how EPA
arrived at thermal conductivity and boiling point as the best method to
assess volatilization of organics from the waste; the discussion relative
to bond energies  is the same for these technologies as for liquid
injection and will not be repeated here.
          (i)  Thermal conductivity.  Consistent with the underlying
principles of incineration, a major factor with regard to whether a
particular constituent will volatilize is the transfer of heat through
the waste.   In the case of rotary kiln, fluidized bed, and fixed hearth
incineration, heat is transferred through the waste by three mechanisms:
radiation, convection, and conduction.  For a given incinerator, heat
transferred  through various wastes by radiation is more a function of the
design and type of incinerator than the waste being treated.
Accordingly, the  type of waste treated will have a minimal impact on the
amount of heat transferred by radiation.  With regard to convection, EPA
also believes that the type of heat transfer will generally be more a
function  of  the type and design of the incinerator than the waste
itself.   However,  EPA is examining particle size as a waste
characteristic that may significantly impact the amount of heat
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transferred to a waste by convection and thus impact the volatilization
of the various organic compounds.  The final type of heat transfer,
conduction, is the one that EPA believes will have the greatest impact on
volatilization of organic constituents.  To measure this characteristic,
EPA will use thermal conductivity; an explanation of this parameter, as
well as how it can be measured, is provided below.
    Heat flow by conduction is proportional to the temperature gradient
across the material.  The proportionality constant is a property of the
material and is referred to as the thermal conductivity.  (Note:  The
analytical method that EPA has identified for measurement of thermal
conductivity is named "Guarded, Comparative, Longitudinal Heat Flow
Technique"; it is described in Appendix D.)  In theory, thermal
conductivity would always provide a good indication of whether a
constituent in an untested waste would be treated to the same extent in
the primary incinerator chamber as the same constituent in a previously
tested waste.
    In practice, thermal conductivity has some limitations in assessing
the transferability of treatment standards; however, EPA has not
identified a parameter that can provide a better  indication of the heat
                                                    ^-
transfer characteristics of a waste.  Below is a discussion of both the
limitations associated with thermal conductivity  and the other parameters
considered.
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    Thermal conductivity measurements, as part of a treatability
comparison for two different wastes through a single incinerator, are
most meaningful when applied to wastes that are homogeneous (i.e., major
constituents are essentially the same).  As wastes exhibit greater
degrees of nonhomogeneity (e.g., a significant concentration of metals in
soil), then thermal conductivity becomes less accurate in predicting
treatability, because the measurement essentially reflects heat flow
through regions having the greatest conductivity (i.e., the path of least
resistance) and not heat flow through all parts of the waste.
    Btu value, specific heat, and ash content were also considered for
predicting heat transfer characteristics.  These parameters can no better
account for nonhomogeneity than can thermal conductivity; additionally,
they are not directly related to heat transfer characteristics.
Therefore, these parameters do not provide a better indication of heat
transfer that will occur in any specific waste.
         (ii)  Boiling point.  Once heat is transferred to a constituent
within a waste, removal of this constituent from the waste will depend on
its volatility.  EPA is using the boiling point as a surrogate of
volatility of the constituent.  Compounds with lower boiling points have
higher vapor pressures and therefore would be more likely to vaporize.
The Agency recognizes that this parameter does not take into
consideration the impact of other compounds in the waste on the boiling
point of a constituent in a mixture; however, the Agency is not aware of
a better measure of volatility that can easily be determined.
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    (5)  Design and operating parameters.
         (a)  Liquid injection.  For a liquid injection unit,  EPA's
analysis of whether the unit is well designed will  focus on (1)  the
likelihood that sufficient energy is provided to the waste to  overcome
the activation level for breaking molecular bonds,  and (2) whether
sufficient oxygen is present to convert the waste constituents to carbon
dioxide and water vapor.  The specific design parameters that  the Agency
will evaluate to assess whether these conditions are met are temperature,
excess oxygen, carbon monoxide level, and waste feed rate.  Below is a
discussion of why EPA believes these parameters to be important, as well
as a discussion of how these parameters will be monitored during
operation.
    It is important to point out that, relative to the development of
land disposal restriction standards, EPA is only concerned with these
design parameters when a quench water or scrubber water residual is
generated from treatment of a particular waste.  If treatment  of a
particular waste in a liquid injection unit would not generate a
wastewater stream, then the Agency, for purposes of land disposal
treatment standards, would be concerned solely with the waste
characteristics that affect selection of the unit, not with the
above-mentioned design parameters.
         (i)  Temperature.  Temperature is  important in that it provides
an indirect measure of the energy available (i.e., Btu/hr) to  overcome
the activation energy of waste constituents.  As the design temperature
increases, it is more likely that the molecular bonds will be
destabilized and the reaction completed.
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    The temperature is normally controlled through the use of
instrumentation that senses the temperature and automatically adjusts the
amount of fuel and/or waste being fed.  The temperature signal
transmitted to the controller can be transmitted simultaneously to a
recording device, referred to as a strip chart, and thereby continuously
recorded.  To fully assess the operation of the unit,  it is important to
know not only the exact location in the incinerator where the temperature
is being monitored but also the location of the design temperature.
         (ii)  Excess oxygen.  The incinerator must contain oxygen in
excess of the stoichiometric amount needed to convert  the organic
compounds to carbon dioxide and water vapor.  If insufficient oxygen is
present, then destabilized waste constituents could recombine to the same
or other BOAT list organic compounds and could potentially cause the
scrubber water to contain higher concentrations of BOAT list constituents
than would be the case for a well-operated unit.
    In practice, the amount of oxygen fed to the incinerator is
controlled by continuous sampling and analysis of the  stack gas.  If the
amount of oxygen drops below the design value, then the analyzer
transmits a signal to the valve controlling the air supply and the flow
of oxygen to the afterburner is increased.  The analyzer simultaneously
transmits a signal to a recording device so that the amount of excess
oxygen can be continuously recorded.  Again, as with temperature, it is
important to know the location from which the combustion gas is being
sampled.
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         (iii)  Carbon monoxide.  Carbon monoxide is an important
operating parameter because it provides an indication of the extent to
which the waste organic constituents are being converted to carbon
dioxide and water vapor.  An increase in the carbon monoxide level
indicates that greater amounts of organic waste constituents are
unreacted or partially reacted.  Increased carbon monoxide levels can
result from insufficient excess oxygen, insufficient turbulence in the
combustion zone, or insufficient residence .time.
         (iv)  Waste feed rate.  The waste feed rate is important to
monitor because it is correlated to the residence time.  The residence
time is associated with a specific Btu energy value of the feed and a
specific volume of combustion gas generated.  Prior to incineration, the
Btu value of the waste is determined through the use of a laboratory
device known as a bomb calorimeter.  The volume of combustion gas
generated from the waste to be  incinerated is determined from an analysis
referred to as an ultimate analysis.  This analysis determines the amount
of elemental constituents present, including carbon, hydrogen, sulfur,
oxygen, nitrogen, and halogens.  Using this analysis plus the total
amount of air added, one can calculate the volume of combustion gas.
Having determined both the Btu  content and the expected combustion gas
volume, the feed rate can be fixed at the desired residence time.
Continuous monitoring of the feed rate will determine whether the unit
was operated at a rate corresponding to the designed residence time.
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         (b)  Rotary kiln.  For this incineration technology, EPA will
examine both the primary and secondary chamber in evaluating the design
of a particular incinerator.  Relative to the primary chamber, EPA's
assessment of design will focus on whether sufficient energy is likely to
be provided to the waste to volatilize the waste constituents.  For the
secondary chamber, analogous to the sole liquid injection incineration
chamber, EPA will examine the same parameters discussed previously under
liquid injection incineration.  These parameters will not be discussed
again here.
    The particular design parameters to be evaluated for the primary
chamber are kiln temperature, residence time, and revolutions per
minute.  Below is a discussion of why EPA believes these parameters to be
important, as well as a discussion of how these parameters will be
monitored during operation.
         (i)  Temperature.  The primary chamber temperature provides an
indirect measure of the energy input (i.e., Btu/hr) that is available for
heating the waste.  The higher the temperature is designed to be in a
given kiln, the more likely it is that the constituents will volatilize.
As discussed earlier under  "Liquid injection," temperature should be
continuously monitored and  recorded.  In addition, it is important to
know the location of the temperature sensing device in the kiln.
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         (ii)  Residence time.  This parameter affects whether sufficient
heat is transferred to a particular constituent to enable volatilization
to occur.  As the time that the waste is in the kiln is increased,  more
heat is transferred to the hazardous waste constituents.   The residence
time will be a function of the specific configuration of the rotary kiln,
including the length and diameter of the kiln, the waste feed rate, and
the rate of rotation.
         (iii)  Revolutions per minute (RPM).  This parameter provides an
indication of the turbulence that occurs in the primary chamber of a
rotary kiln.  As the turbulence increases, the quantity of heat
transferred to the waste would also be expected to increase.  As the RPM
value increases, however, the residence time decreases, resulting in a
reduction of the quantity of heat transferred to the waste.  This
parameter needs to be carefully evaluated because it provides a balance
between turbulence and residence time.
         (c)  Fluidized bed.  As discussed previously in the section on
"Underlying principles of operation," the primary chamber accounts for
almost all of the conversion of organic wastes to carbon dioxide, water
vapor, and acid gas  if halogens are present.  The secondary chamber will
generally provide additional residence time for thermal oxidation of the
waste constituents.  Relative to the primary chamber, the parameters that
the Agency will examine in assessing the effectiveness of the design are
temperature, residence time, and bed pressure differential.  The first
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two were discussed under rotary kiln incineration and will not be
discussed here.  The last, bed pressure differential, is important in
that it provides an indication of the amount of turbulence and therefore
indirectly the amount of heat supplied to the waste.  In general, as the
pressure drop increases, both the turbulence and the heat supplied
increase.  The pressure drop through the bed should be monitored and
recorded continuously to ensure that the designed value is achieved,
         (d)  Fixed hearth.  The design considerations for this
incineration unit are similar to those for a rotary kiln except that the
rate of rotation (i.e., RPM) is not an applicable design parameter.  For
the primary chamber of this unit, the parameters that the Agency will
examine in assessing how well the unit is designed are the same as those
discussed under "Rotary kiln"; for the secondary chamber (i.e.,
afterburner), the design and operating parameters of concern are the same
as those discussed under "Liquid injection."
3.2.3    Stabilization
    Stabilization refers to a broad class of treatment processes that
chemically reduce the mobility of hazardous constituents in a waste.
Solidification and fixation are other terms that are sometimes used
synonymously for stabilization or to describe specific variations within
the broader class of stabilization.  Related technologies are
encapsulation and thermoplastic binding; however, EPA considers these
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technologies to be distinct from stabilization in that the operational
principles are significantly different.
    (1)  Applicability and use of stabilization.  Stabilization is used
when a waste contains metals that will leach from the waste when it is
contacted by water.  In general, this technology is applicable to wastes
containing BOAT list metals having a high filterable solids content, a
low TOC content, and a low oil and grease content.  This technology is
commonly used to treat residuals generated from treatment of
electroplating wastewaters.  For some wastes, an alternative to
stabilization is metal recovery.
    (2)  Underlying principles of operation.  The basic principle
underlying this technology is that stabilizing agents and other chemicals
are added to a waste to minimize the amount of metal that leaches.  The
reduced Teachability is accomplished by the formation of a lattice
structure and/or chemical bonds that bind the metals to the solid matrix
and thereby limit the amount of metal constituents that can be leached
when water or a mild acid solution comes into contact with the waste
material.
    Two principal stabilization processes are used -- cement-based and
lime-based processes.  A brief discussion of each is provided below.  In
both cement-based and lime/pozzolan-based techniques, the stabilizing
process can be modified through the use of additives, such as silicates,
that control curing rates or enhance the properties of the solid material
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         (a)  Portland cement-based process.  Portland cement is a
mixture of powdered oxides of calcium, silica, aluminum, and iron,
produced by kiln burning of materials rich in calcium and silica at high
temperatures (i.e., 1,400 to 1,500°C).  When the anhydrous cement
powder is mixed with water, hydration occurs and the cement begins to
set.  The chemistry involved is complex because many different reactions
occur depending on the composition of the cement mixture.
    As the cement begins to set, a colloidal gel of indefinite
composition and structure is formed.  Over a period of time, the gel
swells and forms a matrix composed of interlacing, thin, densely-packed
silicate fibrils.  Constituents present in the waste slurry (e.g.,
hydroxides and carbonates of various heavy metals) are incorporated into
the interstices of the cement matrix.  The high pH of the cement mixture
tends to keep metals in the form of insoluble hydroxide and carbonate
salts.  It has been hypothesized that metal ions may also be incorporated
into the crystal structure of the cement matrix, but this hypothesis has
not been verified.
         (b)  Lime/pozzolan-based process.  Pozzolan, which contains
finely divided, noncrystalline  silica (e.g., fly ash or components of
cement kiln dust), is a material that is not cementitious in itself, but
becomes so upon the addition of lime.  Metals in the waste are converted
to silicates or hydroxides, which inhibit leaching.  Additives, again,
can be used to reduce permeability and thereby further decrease leaching
potential.
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    (3)  Description of the stabilization process.  In most stabilization
processes, the waste, stabilizing agent, and other additives, if used,
are mixed and then pumped to a curing vessel or area and allowed to
cure.   The actual operation (equipment requirements and process
sequencing) will depend on several factors such as the nature of the
waste, the quantity of the waste, the location of the waste in relation
to the disposal site, the particular stabilization formulation to be
used,  and the curing rate.  After curing, the solid formed is recovered
from the processing equipment and shipped for final disposal.
    In instances where waste contained in a lagoon is to be treated, the
material should be first transferred to mixing vessels where stabilizing
agents are added.  The mixed material is then fed to a curing pad or
vessel.  After curing, the solid  formed is removed for disposal.
Equipment commonly used also includes facilities to store waste and
chemical additives.  Pumps can be used to transfer liquid or light sludge
wastes to the mixing pits and pumpable uncured wastes to the curing
site.   Stabilized wastes are then removed to a final disposal site.
    Commercial concrete mixing and handling equipment generally can be
used with wastes.  Weighing conveyors, metering cement hoppers, and
mixers similar to concrete batching plants have been adapted in some
operations.  Where extremely dangerous materials are being treated,
remote control and in-drum mixing equipment, such as that used with
nuclear waste, can be employed.
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    (4)  Haste characteristics affecting performance.  In determining
whether stabilization is likely to achieve the same level of performance
on an untested waste as on a previously tested waste, the Agency will
focus on the characteristics that inhibit the formation of either the
chemical bonds or the lattice structure.  The four characteristics EPA
has identified as affecting treatment performance are the presence of
(1) fine particulates, (2) oil and grease, (3) organic compounds, and
(4) certain inorganic compounds.
         (a)  Fine particulates.  For both cement-based and
lime/pozzolan-based processes, the literature states that very fine solid
materials (i.e., those that pass through a No. 200 mesh sieve, 74 urn
particle size) can weaken the bonding between waste particles and cement
by coating the particles.  This coating can inhibit chemical bond
formation and decreases the resistance of the material to leaching.
         (b)  Oil and grease.  The presence of oil and grease in both
cement-based and lime/pozzolan-based systems results in the coating of
waste particles and the weakening of the bonding between the particle and
the stabilizing agent.  This coating can inhibit chemical bond formation
and thereby decrease the resistance of the material to leaching.
         (c)  Organic compounds.  The presence of organic compounds in
the waste interferes with the chemical reactions and bond formations that
inhibit curing of the stabilized material.  This results in a stabilized
waste having decreased resistance to leaching.
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         (d)  Sulfate and chlorides.  The presence of certain inorganic
compounds will interfere with the chemical reactions, weakening bond
strength and prolonging setting and curing time.  Sulfate and chloride
compounds may reduce the dimensional stability of the cured matrix,
thereby increasing Teachability potential.
    Accordingly, EPA will examine these constituents when making
decisions regarding transfer of treatment standards based on
stabilization.
    (5)  Design and operating parameters.  In designing a stabilization
system, the principal parameters that are important to optimize so that
the amount of Teachable metal constituents is minimized are (1) selection
of stabilizing agents and other additives, (2) ratio of waste to
stabilizing agents and other additives, (3) degree of mixing, and
(4) curing conditions.
         (a)  Selection of stabilizing agents and other additives.  The
stabilizing agent and additives used will determine the chemistry and
structure of the stabilized material and therefore will affect the
Teachability of the solid material.  Stabilizing agents and additives
must be carefully selected based on the chemical and physical
characteristics of the waste to be  stabilized.  For example, the amount
of sulfates in a waste must be considered when a choice is being made
between a 1ime/pozzolan and a portland cement-based system.
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    In order to select the type of stabilizing agents and additives, the
waste should be tested in the laboratory with a variety of materials to
determine the best combination.
         (b)  Amount of stabilizing agents and additives.  The amount of
stabilizing agents and additives is a critical parameter since sufficient
stabilizing materials are necessary in the mixture to properly bind the
waste constituents of concern, making them less susceptible to leaching.
The appropriate weight ratios of waste to stabilizing agent and other
additives are established empirically by setting up a series of
laboratory tests that allow separate leachate testing of different mix
ratios.  The ratio of water to stabilizing agent (including water in
waste) will also impact the strength and leaching characteristics of the
stabilized material.  Too much water will cause low strength; too little
will make mixing difficult and, more important, may not allow the
chemical reactions that bind the hazardous constituents to be fully
completed.
         (c)  Mixing.  The conditions of mixing include the type and
duration of mixing.  Mixing is necessary to ensure homogeneous
distribution of the waste and the stabilizing agents.  Both undermixing
and overmixing are undesirable.  The first condition results in a
nonhomogeneous mixture; therefore, areas will exist within the waste
where waste particles are neither chemically bonded to the stabilizing
agent nor physically held within the lattice structure.  Overmixing, on
                                    3-44

-------
the other hand, may inhibit gel formation and ion adsorption in some
stabilization systems.  As with the relative amounts of waste,
stabilizing agent, and additives within the system, optimal mixing
conditions generally are determined through laboratory tests.  During
treatment it is important to monitor the degree (i.e., type and duration)
of mixing to ensure that it reflects design conditions.
         (d)  Curing conditions.  The curing conditions include the
duration of curing and the ambient curing conditions (temperature and
humidity).  The duration of curing ensures that the waste particles have
had sufficient time in which to form stable chemical bonds and/or lattice
structures.  The time necessary for complete stabilization depends upon
the waste type and the stabilization used.  The performance of the
stabilized waste (i.e., the levels of constituents in the leachate) will
be highly dependent upon whether complete stabilization has occurred.
Higher temperatures and lower humidity increase the rate of curing by
increasing the rate of evaporation of water from the solidification
mixtures.  If temperatures are too high, however, the evaporation rate
can be excessive, resulting in too little water being available for
completion of the stabilization reaction.  The duration of the curing
process should also be determined during the design stage and typically
will be between 7 and 28 days.
                                    3-45

-------
                         4.  PERFORMANCE DATA BASE
    This section discusses the available performance data associated with
the demonstrated technologies for K022 waste.  Performance data include
the constituent concentrations in untreated and treated waste samples,
the operating data collected during treatment of the sampled waste,
design values for the treatment technology, and data on waste
characteristics that affect performance.  In this document, EPA has
presented all performance data, to the extent that they are available, in
tables found at the end of this section.
    EPA's use of these data in determining the technology that represents
BOAT, and for developing treatment standards, is described in Sections 5
and 7, respectively.
4.1      Nonwastewater
4.1.1    BOAT List Organics
    The Agency collected six sets of untreated and treated waste samples
from Plant 1 to characterize treatment of K022 using fuel substitution in
an industrial boiler.  Treatment of K022 resulted in one residual-- the
ash, a nonwastewater.  The ash, generated during the 24-month period in
which the boiler was in service, was collected from the boiler when it
was taken out of service for cleaning and maintenance.  The Agency
believes that the ash is representative of the residual obtained from
burning the K022 wastes and other substances that were used as fuels
based on information obtained from Plant 1 personnel.  Table 4-1 presents
the available design data.  Table 4-2 contains data for the untreated
                                    4-1

-------
K022 waste, while Table 4-3 provides the data for the ash.  Since BOAT
list organics were not detected in the residual ash, EPA believes that
the system was well designed and well operated relative to treatment of
this waste.  Sufficient QA/QC information is available to adjust the
analytical results for the volatile and semivolatile organic constituents
in the treated residual data.  These data are presented in Appendix B.
    From Plant 2, the Agency collected one sample of the untreated waste
and six samples of residual ash, also from fuel substitution in an
industrial boiler.  The sample for the untreated waste is assumed to be
representative of the waste burned during the 18-month operation of the
boiler.  The ash was generated during this period and resulted solely
from the combustion of K022 waste.  The ash was collected from the boiler
when the unit was shut down for cleaning and maintenance.  Design data
are presented in Table 4-1.  Operating data are not available for the
industrial boiler used at this facility.  Based on the analytical data
available for the residual ash, the boiler appeared to have been well
operated, since the organic constituents present in the raw waste were
reduced to nondetectable levels.  Table 4-3 presents the data available
for the untreated waste and the residual ash.  QA/QC data associated with
the treated waste data are limited.  The available QA/QC data are
presented in Appendix B.
    From an industrial boiler at Plant 3, the Agency collected one sample
of boiler feed containing a mixture of K022 and other wastes and one
sample of the residual ash.  (A separate sample of the K022 waste was not
                                    4-2

-------
collected.)  The data obtained for this facility indicated that
nondetectable levels for the BOAT organic constituents were achieved.
The data, however, are not used to assess the treatment of K022 for three
reasons.  First, a sample of the K022 waste itself was not obtained;
therefore, it is not possible to identify which constituents present in
the boiler feed were contributed by the K022 waste and which were
contributed by the other wastes also burned in the boiler at the same
time.  Second, poor recovery values were obtained for the acid fractions
of the matrix spike and matrix spike duplicate samples; for example, the
recovery value for phenol (a major constituent of K022 waste) in the ash
was zero.  Therefore, the analytical results could not be adjusted to
reflect recoveries.  Third, design and operating data for the boiler were
not available.  As a result, the Agency decided to withdraw these data
from further consideration.
4.1.2    BOAT List Metals
    EPA does not have performance data showing treatment of BOAT list
metals in K022 nonwastewater, i.e., ash.  Industry, however, submitted
performance data showing treatment of F006 waste (an electroplating
sludge) by stabilization, the demonstrated technology for metals in K022
ash.  These F006 data, presented in Table 4-5, reflect total and TCLP
leachate concentrations for BOAT list metals in the untreated waste and
TCLP leachate concentrations for metals in the treated waste.  The data
represent F006 wastes from various electroplating industries, including
auto parts manufacturing, aircraft overhauling, zinc plating, small
engine manufacturing, and circuit board manufacturing.
                                    4-3

-------
    The Agency believes the F006 data can be used to represent the

performance of stabilization on the K022 ash.  Furthermore, EPA expects

that the ash is easier to stabilize because such ash residuals contain

metals in the form of oxides, which have been shown to leach at lower

concentrations than the typical F006 hydroxides.

    Other stabilization data were available to EPA and can be found in

the Administrative Record.  They were eliminated from further

consideration as sources for transferring data to develop treatment

standards because of one or a combination of the reasons provided below:

    1.   The waste treated was less similar to the K022 ash or expected
         precipitated residuals than the waste for which performance data
         are presented;

    2.   The performance data do not show substantial treatment for the
         constituents to be regulated (selected in Section 6);

    3.   Design and operating data, or the lack of such data, do not
         enable the Agency to ascertain whether the treatment system was
         well designed and well operated; or

    4.   The measure of performance is not consistent with EPA's approach
         in evaluating treatment of metals by stabilization; e.g., EP
         levels rather than TCLP leachate levels are given.

4.2      Wastewater

    Data are not available for treatment of K022 wastewater or a waste

determined to be similar.
                                    4-4

-------
1837g
             Table 4-1   Design Data for Use of K022 As Fuel in
                       an  Industrial Boiler at Plants 1 and 2
Parameter                   Design value             Operating value
        This table contains RCRA Confidential Business Information.
                                  4-5

-------
1836g

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

-------
1837g
                      Table 4-3  Concentration Data for Treated Residual  (Ash for K022) at Plant 1
BOAT
ref.
no.
43
53
142
106/219

171
174
161
163
155
156
157
15B
159
160
161
163
166
167
166
212









NA = Not
aSample 4
Arsenic
Barium
Cadmium
BOAT
list
constituent
Toluene
Acetophenone
Phenol
Diphenylamine/
Diphenylnitrosamine
Sulfide
•B-BHC
Dieldrin
B-Endosulfan
Arsenic
Barium
Beryll lum
Cadmium
Chromium
Copper
Lead
Nickel
Thai 1 ium
Vanadium
Zinc
Tetrachlorodibenzofuran
TCLP Extract
Barium
Cadmium
Chromium
Copper
Lead
Nickel
Si Iver
Zinc
analyzed.
TCLP extract was reanalyzed.
Waste concentration
Sample 1
(mg/kg)
<0.012
<3.8
<1.9
<2.65

200
<0.4
<0.4
<0.4
<15
15
0.1
<2.5
60
38
21
47
<15
<5
25
0.00035
(ma/1)
0.08
<0.025
0.2
NA
<0.15
NA
<0.025
NA

Sample 2
(mg/kg)
<0.012
<7.6
<3.8
<5.3

NA
NA
NA
NA
138
95
0.2
4.1
289
2110
1840
223
1930
<5
1740
NA
(mq/1)
0.066
<0.025
1.3
NA
<0.15
NA
<0.025
NA

Sample 3
(mg/kg)
<0.012
<3.8
<1.9
<2.63

NA
NA
NA
NA
<15
28
<0.1
<2.5
21
<5
<15
98
<15
13
<2.5
NA
(mq/1)
0.27
<0.025
<0.1
NA
2.9
NA
<0.025
NA

Sample 4
(mg/kg)
<0.012
<3.8
<1.9
<2.63

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

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

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

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

NA
NA
NA
NA
45
27
0.1
2.5
344
215
105
266
181
<5
209
NA
(mq./l)
0.076
<0.025
<0.1
NA
<0.15
NA
<0.025
NA

The results are as follows:
<0.15 mg/1 Chromium - 1.7
0.66 mg/1 Lead
<0.025 mg/1 Silver
- <0.15
- <0.025
mg/1
mg/1
mg/1












Reference:  USEPA 1988a.
                                                             4-7

-------
1836g
                       Table 4-4  Concentration Data for Untreated and Treated Residual  K022
                                                  .Waste at Plant 2
Concentrat ion
BOAT
ref.
no.
43
38
53
142
156
159
160
163
167
168
186
171



BOAT
list
constituent
Total Composition
Toluene
Methylene chloride
Acetophenone
Phenol
Ba r i urn
Chromium
Copper
Nickel
Vanadium
Zinc
Heptachlor
Sulf ide
TCLP Results3
Arsenic
Barium
Chromium
Untreated
waste Sample
(mg/kg) 1
<0.012
<0.008
<1.254
<0.627
18
639
46
276
<5.0
78
<0.4
320
<0.15
0.09
43
Treated waste (mq/kq)
Sample
2
<0.06
<0.04
NA
NA
21
813
52
279
'5.0
70
NA
NA
<0.15
0.03
45
Sample
3
<0.012
<0.008
NA
NA
33
1460
50
309
<5.0
56
NA
NA
<0.15
0.1
66
Sample
4
<0.012
<0.008
NA
NA
24
753
42
284
8.7
22
NA
NA
<0.15
0.08
43
Sample
5
<0.012
<0.008
NA
NA
23
1050
52
392
<5.0
42
NA
NA
<0.15
0.08
49
Sample
6
<0.012
0.021
NA
NA
17
1540
55
776
<5.0
77
NA
NA
<0.1S
0.14
47
NA = Not ana lyzed.
 TCLP results are not available for copper,  nickel,  zinc,  and vanadium.
 Untreated waste is RCRA Confidential Business Information.
Reference:  USEPA 1988b.
                                                          4-8

-------
                                                     Table 4-5  Performance Data for Stabilization of F006 Waste
-p>
I
Concentration (ppm)
Sample Set f
Constituent
Arsenic


Barium


Cadmium


Chromium


Copper


Lead


Stream
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
1

<0.01
<0.01
36.4
0.08
0.12
1.3
0.01
0.01
1270
0.34
0.51
40.2
0.15
0.20
35.5
0.26
0.30
2

<0.01
<0.01
<0.01
21.6
0.32
0.50
0.42
31.3
2.21
0.50
0.01
755
0.76
0.40
0.39
7030
368
5.4
0.25
409
10.7
0.40
0.36
3

<0.01
<0.01
<0.01
85.5
1.41
0.33
0.31
67.3
1.13
0.06
0.02
716
0.43
0.08
0.20
693
1.33
1.64
1.84
25.7
0.26
0.30
0.41
4

-
<0.01
<0.01
17.2
0.84
0.20
0.23
1.30
0.22
0.01
0.01
110
0.18
0.23
0.30
1510
4.6
0.30
0.27
88.5
0.45
0.30
0.34
5

<0.01
<0.01
<0.01
14.3
0.38
0.31
0.19
720
23.6
3.23
0.01
12200
25.3
0.25
0.38
160
1.14
0.20
0.29
52
0.45
0.24
0.36
6

<0.01
<0.01
<0.01
24.5
0.07
0.30
0.33
7.28
0.3
0.02
0.01
3100
38.7
0.21
0.76
1220
31.7
0.21
0.20
113
3.37
0.30
0.36
7

<0.01
<0.01
<0.01
12.6
0.04
0.04
0.14
5.39
0.06
0.01
0.01
42900
360
3.0
1.21
10600
8.69
0.40
0.42
156
1.0
0.30
0.38
8

<0.01
<0.01
<0.01
15.3
0.53
0.32
0.27
5.81
0.18
0.01
0.01
47.9
0.04
0.10
0.2
17600
483
0.50
0.32
169
4.22
0.31
0.37
9

0.88
<0.02
<0.02
19.2
0.28
0.19
0.08
5.04
0.01
<0.01
<0.01
644
0.01
0.03
0.21
27400
16.9
3.18
0.46
24500
50.2
2.39
0.27

-------
                                                                    Table 4-5  (Continued)
Concentration (ppm)
Sample Set I
Constituent Stream
Mercury Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Nickel Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Selenium Untreated total
Untreated TCLP
•^ Treated TCLP3
£ Treated TCLPb
Silver Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Zinc Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
1
.
<0.001
<0.001
-
435
0.71
0.04
-
-
<0.01
0.06
-
2.3
0.01
0.03
-
1560
0.16
0.03
"
2
.
<0.001
<0.001
<0.001
989
22.7
1.5
0.03
-
<0.01
0.06
0.11
6.62
0.14
0.03
0.05
4020
219
36.9
0.01
3
.
<0.001
<0.001
<0.001
259
1.1
0:23
0.15
-
<0.01
0.07
0.11
39
0.02
0.20
0.05
631
5.41
0.05
0.03
4

<0.001
<0.001
<0.001
37
0.52
0.10
0.02
-
-
0.08
0.14
9.05
0.16
0.03
0.04
90200
2030
32
0.04
5

<0.001
<0.001
<0.001
701
9.78
0.53
0.04
-
<0.01
0.04
0.09
5.28
0.08
0.04
0.06
35900
867
3.4
0.03
6
.
0.003
<0.001
<0.001
19400
730
16.5
0.05
-
<0.01
0.05
0.11
4.08
0.12
0.03
0.05
27800
1200
36.3
0.04
7

<0.001
<0.001
<0.001
13000
152
0.40
0.10
_
<0.0\
0.04
0.07
12.5
0.05
0.03
0.05
120
0.62
0.02
0.02
8
„
<0.001
<0.001
<0.001
23700
644
15.7
0.04
-
<0.01
0.07
0.07
8.11
0.31
0.03
0.05
15700
650
4.54
0.02
9
.
<0.001
<0.001
<0.001
5730
16.1
1.09
0.02
-
<0.45
<0.01
<0.01
19.1
<0.01
<0.01
<0.01
322
1.29
0.07
<0.01
Binding agent:  cement kiln dust.
3Mix ratio is 0.2.  The mix ratio is the ratio of the reagent weight to waste weight.
bMix ratio is 0.5.
Note:  Waste samples are from the following industries:   set /I.  unknown;  set 12,  auto part manufacturing;  set 13.  aircraft  overhauling;  set  14.  zinc
       plating; set 15, unknown;  set Id. small engine manufacturing; set 17,  circuit  board manufacturing; set IB, unknown; and  set  /9.  unknown.

Reference:  CWM Technical Note 87-117.  Table 1.  (CWM 1987).

-------
    5.  IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
    This section explains EPA's determination of the best demonstrated
available technology (BOAT) for K022 waste.  As discussed in Section 1,
the BOAT for a waste must be the "best" of the "demonstrated"
technologies; the BOAT must also be "available."  In general, the
technology that constitutes "best" is determined after screening the
available data from each demonstrated technology, adjusting these data
for accuracy, and comparing the performance of each technology to that of
the others.  If only one technology is identified as demonstrated,  this
technology is considered "best."  To be "available," a technology
(1) must be commercially available and (2) must provide substantial
treatment.
5.1      Nonwastewater
5.1.1    BOAT List Organics
    While both fuel substitution and incineration are identified as being
demonstrated on K022 nonwastewater for treatment of organics, the Agency
has performance data for fuel substitution only.  Accordingly, it is not
possible to perform the statistical comparison test (ANOVA) between these
technologies as discussed in Section 1 of this document.  While
performance data are not available for incineration of K022 waste,  EPA
would not expect this technology to improve the destruction of BOAT list
organic constituents achieved by fuel substitution because the
concentrations of the BOAT list organics in the treated waste from fuel
substitution are already at nondetectable concentration levels.
    Demonstrated technologies are considered "available" if they (1) are
commercially available and (2) substantially diminish the toxicity of the
                                    5-1

-------
waste or substantially reduce the likelihood that hazardous constituents
will migrate from the waste.  In addition to meeting the criterion of
being "commercially available," fuel substitution provides "substantial"
treatment by significantly reducing the concentrations of the hazardous
organic constituents of concern to nondetectable levels.  (See the
accuracy-corrected treated waste concentrations in Appendix B.)
    Because EPA believes that fuel substitution is "demonstrated,"
"available," and achieves the "best" performance, the technology is
determined to be BOAT for organics in K022 waste.
5.1.2    BOAT List Metals
    For metals in K022 nonwastewater, the only identified demonstrated
technology is stabilization.  Performance data are available for
stabilization of F006 waste using cement kiln dust as the binding agent
as discussed in Section 4.  The Agency does not expect that use of other
binders would improve the level of performance.  Thus, stabilization
using cement kiln dust as the binding agent is "best."
    EPA considers stabilization to be "available" as it is commercially
available and provides substantial treatment.  EPA's determination of
substantial treatment is discussed below.
    In screening the performance data, the Agency had to determine
whether any data points should be deleted because they did not represent
a well-designed and well-operated system; thus, EPA deleted data points
from the less effective mix ratio used in treating the sample sets.
Specifically, EPA determined that a mix ratio of 0.5 was most effective
                                    5-2

-------
for wastes in sample sets 2, 4, 5, 6, 7, 8, and 9, and that a mix ratio
of 0.2 was effective for wastes in sample sets 1 and 3.
    The Agency also deleted other data points for individual metal
constituents for one of the following reasons:  (1) the treated
concentration was higher than the untreated concentration; (2) sufficient
information was not available on the untreated concentration to determine
treatment effectiveness; (3) the untreated leachate concentration was
already at a low level where meaningful treatment could not be
determined; and (4) after correcting the results for accuracy, the
treated level of performance could be attributed solely to dilution from
the binding reagent.  (Table B-3 shows accuracy-corrected values for all
treated waste data points; this table also indicates the specific reasons
for data point deletion.)
    Table 5-1 shows the remaining data.  EPA's determination of
substantial treatment is based on observations of the following
reductions in the TCLP leachate concentrations of metals in the F006
waste:  up to 23 mg/1 for cadmium, 358 mg/1 for chromium, 49 mg/1 for
lead, 729 mg/1 for nickel, and 0.25 mg/1 for silver.
    As stabilization using cement kiln dust as a binder is demonstrated,
best, and available for BOAT list metals in K022 nonwastewater,
stabilization represents BOAT.
5.2    Wastewater
    Data and information on treatment of K022 wastewater are not
currently available for identifying BOAT.
                                    5-3

-------
                  Table 5-1  TCLP Performance Data for Stabilization of F006 Waste After Screening and Accuracy Correction of Treated Values
Constituent
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Zinc
Stream
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP
Untreated TCLP
Treated TCLP

,a 2b
__
.-
2.21
0.01
0.76
0.45
368
0.27
10.7
0.39
--
0.71 22.7
0.05 0.03
..
0.14
0.06
0.16 219
0.03 0.01
Concentration (ppm)
Sample Set *
3a 4b 5b 6b
	 	 	 	
1.41 0.84 0.38
0.34 0.25 0.21
1.13 0.22 23.6 0.3
0.06 0.01 0.01 0.01
0.43 -- 25.3 38.7
0.09 -- 0.44 0.89
4.6 1.14 31.7
0.29 0.31 0.22
3.37
0.39
--
1.1 0.52 9.78 730
0.27 0.02 0.04 0.06
.-
0.16 -- 0.12
0.05 - 0.06
5.41 2.030 867 1.200
.03 0.04 0.03 0.04

?b 8b
	 	
0.53
0.29
0.06 0.18
0.01 0.01
360
1.41
8.69 483
0.45 0.35
1.0 4.22
0.41 0.40
--
152 644
0.11 0.04
--
0.31 '
0.06
0.62 650
0.02 0.02

9b
--
0.28
0.09
• --
--
16.9
0.50
50.2
0.29
--
16.1
0.02
--
--
1.29
0.01
Binding agent:   cement kiln dust.
aMix ratio is 0.2.   The mix ratio is the ratio of the reagent  weight  to waste weight.
bHix ratio is 0.5.
Reference:  CWH Technical Note 87-117.  Table 1.

-------
    Since stabilization using cement kiln dust as a binder is best,
commercially available, and substantially reduces the likelihood that
hazardous metals would leach from the waste, stabilization is determined
to be BOAT for the BOAT list metals in K022 nonwastewater.
                                    5-5

-------
                  6.  SELECTION OF REGULATED CONSTITUENTS
    As discussed in Section 1, the Agency has developed a list of
hazardous constituents (see Table 1-1) from which the constituents to be
regulated are selected.  EPA may revise the list as additional data and
information become available.  The list is divided into the following
categories:  volatile organics, semivolatile organics, metals,
inorganics, organochlorine pesticides, phenoxyacetic acid herbicides,
organophosphorous pesticides, PCBs, and dioxins and furans.  The
constituents in each category have similar chemical properties and are
expected to behave similarly during treatment, with the exception of the
inorganics.
    This section describes the process used to select the constituents to
be regulated.  The process involves developing a list of potential
regulated constituents and then eliminating those that would not be
treated by the chosen BOAT or that would be controlled by regulation of
the remaining constituents.
6.1      Identification of BDAT List Constituents in the Untreated Waste
    As discussed in Sections 2 and 4, the Agency has characterization
data (see Table 2-3) as well as performance data from treatment of K022
waste by fuel substitution (see Tables 4-2, 4-3, and 4-4).  These data,
along with information on the waste generating process, have been used to
determine which BDAT list constituents may be present in the waste and
thus which are potential candidates for regulation in the nonwastewater
and wastewater.
                                    6-1

-------
    Table 6-1 indicates, for the untreated waste, which constituents were
analyzed, which constituents were detected, and which constituents the
Agency believes could be present but not detected.  For those
constituents detected, concentrations are indicated.
    Under the column "Believed to be present," constituents other than
those detected in the untreated waste are marked with X or Y if EPA
believes they are likely to be present in the untreated waste.   For those
constituents marked with X, an engineering analysis of the waste
generating process indicated that they are likely to be present (e.g.,
the engineering analysis shows that a particular constituent is present
in the raw material).  Those constituents marked with Y have been
detected in the treated residual(s), and thus EPA believes they are
present  in the untreated waste.  Constituents may not have been detected
in the untreated waste for one of several reasons:  (1) none of the
untreated waste samples were analyzed for those constituents, (2) masking
or interference by other constituents prevented detection, or (3) the
constituent indeed was not present.  It  is important to note that some
wastes are defined as being generated from a process that may utilize
variable raw materials composed of different constituents.  Therefore,
all potentially regulated constituents would not necessarily be present
in any given sample.
    As shown on Table 6-1, K022 samples  were analyzed for 214 of the 231
BOAT list constituents.  Because there is no in-process source for the
remaining 17 constituents, EPA believes  they are unlikely to be present.
                                    6-2

-------
Of the 214 constituents analyzed, 14 were detected in untreated waste
samples.  These include four volatile organics, four semivolatile
organics, chromium, sulfide, and four organochlorine pesticides.  Ten
additional metals and one polychlorinated furan were found in the treated
residuals and therefore are believed to be present in the waste.  These
25 constituents are potential candidates for regulation.
6.2      Constituent Selection
    EPA has chosen to regulate one volatile organic, all four
semivolatile organics, and two metals.  These constituents are presented
in Table 6-2.  Two of the semivolatile organics--diphenylamine and
diphenylnitrosamine--are regulated as the sum of these constituents
because these two compounds cannot be distinguished using EPA's standard
analytical testing procedures.
    Of the three volatiles detected in the untreated waste (toluene,
ethyl benzene, and methylene chloride), the Agency selected toluene.
Methylene chloride is present in the untreated waste at lower
concentrations according to the data, and the compound is expected to be
easier to treat based on its boiling point (40 to 42°C for methylene
chloride versus 111°C for toluene).  Ethyl benzene is not being
regulated because treatment data for this constituent are not available.
(The treated residual ash was not analyzed for this constituent and other
data are not available for transferring.)
    Of the metals, chromium and nickel are present in the ash at the
highest concentrations for most of the ash samples relative to the other
                                    6-3

-------
metals detected.  The Agency believes that stabilization of chromium and
nickel is necessary to reduce the Teachability of these two constituents
in the ash.  Also, the Agency believes that stabilization of these two
BOAT list metals will reduce the Teachability of the remaining BOAT list
metals present  in the ash residual.
    The four pesticides, B-BHC, dieldrin, B-endosulfan, and heptachlor,
were not selected for regulation because (1) they are present at
concentrations  significantly lower than the volatiles and semivolatile
organics, and (2) it is believed that they will be treated along with the
regulated constituent based on their relatively low initial
concentrations.
    Sulfide is  not being regulated at this time as the Agency currently
has not completed its evaluation of its waste characterization and
treatment information.  Tetrachlorodibenzofurans are not being regulated
at this time because the accuracy of the quantification for the
constituent cannot be determined.  EPA has concluded that additional
analysis, with  the proper QA/QC, would be required before EPA can
consider developing treatment standards for the constituent.
                                    6-4

-------
219b9
              Table C-l  Status of BOAT  List  Constituent  Presence
                            in Untreated K022 Waste
BOAT
reference
no.

222.
1.
2.
3 .
4.
5.
6.
223.
7.
6.
9.
10.
11.
12.
13.
14.
15.
16.
17.
Id.
19.
20.
21.
22.
23.
24.
25.
26.
27.
26.
29.
224.
225.
226.
30.
227.
31.
214.
32.
33.
228.
34.
Const ituent
Volat i 1e orqanics
Acetone
Acetonitrile
Acrolein
Aery lonitr i le
Benzene
Bromodichlorome thane
Bromomethane
n-Butyl alcohol
Carbon tetrachloricie
Carbon bisulfide
Chlorobenzene
2-Chloro-l ,3-butadiene
Ch lorod i bromomet hane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 . 2-Dibromo-3-chloropropane
1 ,2-Dibromoethane
Di bromomet hone
trans -1 , 4-Dichloro-2-butene
D ich lorod if luoromethane
1 , 1-Dichloroethane
1 , 2-Dichloroethane
1 , 1-Dichloroethylene
trans-1.2-0ichloroethene
1 . 2-Dichloropropdiie
trans -1 ,3-Dichloropropene
cis-1 ,3-Dichloropropene
1.4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Detection believed to
status" be present

D (CBI)
ND
NO
ND
ND
ND
ND
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
NA
D (CBI)
ND
NA
ND
NA
ND
ND
NA
ND
                                    6-5

-------
lable  G-l  (Continued)
BDA1
reference
no.

225.
35.
37.
36.
230.
3y.
40.
41.
42.
43.
44.
45.
46.
47.
46.
49.
231.

50.
215.
216.
217.

51.
52.
53.
54.
55.
56.
57.
58.
59.
218.
60.
61.
62.
63.
64.
65.
66.
Const ituent
Volatile orqnnic^ (continued)
Methyl isobutyl ketone
Methyl methacry late
Methdcry lonitri le
Methylene chloride
2-Nitropropane
Pyridme
1,1,1 ,2-letrachloroethdne
1 , 1 , 2,2- Tetrochloroe thane
Tetrachloroethene
Toluene
Tribromomethane
1,1, 1-Trichlo roe thane
1. 1.2-Trichloroethane
Trichloroethene
Trichloromonofluoroinethdne
1 ,2,3-Trichloropropane
l,1.2-Trichloro-1.2.2-
trif luoroethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1,4-Xylene
Semivolatile orn.inic?,
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Ammobiphenyl
Ani 1 me
Anthracene
Aramite
Benz ( a ) anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene
Benzo(b)f luoranthene
Benzofghi )pery lene
Benzol k)f luoranthene
p-Benzoqumone
Detection believed to
status3 be present

NA
ND
ND
D (CBI)
NA
ND
ND
ND
ND
D (CBI)
ND
ND
ND
ND
ND
ND

NA
ND
NA
NA
NA

ND
ND
D (CBI)
ND
ND
ND
ND
ND
ND
NA
ND

ND
ND
ND
ND
ND
       6-6

-------
2198q
                              l.ible 6-1   (Cont uiuerl)
BOAT
reference
no.

C7.
66.
69.
70.
71.
72.
73.
7-).
75.
76.
77.
78.
79.
80.
61.
62.
232.
63.
84.
65.
aC.
87.
88.
69.
90.
91.
92.
93.
94.
95.
96.
97.
96.
99.
100.
101.
102.
103.
104.
105.
106. /219.

Const ituent
Sfimivolflt i If? orcii'inicr. (continued)
6is(2-chloroethoxy)methane
Bis(2-chlorobthyl)ether
Ris(2-chloroisopropyl ) ether
& i s ( 2 - e t hy 1 nex y 1 ) pht ha 1 a t e
4-Bromopheny 1 phenyl ether
Butyl benzyl phthaldte
2-sec-Buty 1-4. 6- din i trophenol
p-Chloroani 1 me
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphtha lene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
Dibenz(d.h) anthracene
D i benzol a , e ) pyrene
Dibenzo(a, i )pyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Oichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2 , 6-0 ich lorouheno 1
Diethyl phthoKne
3.3'-Dimethoxybenzidine
p- Dimethyl am moazobenzene
3. 3 '-Dime thy Ibenz id me
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalote
1 ,4-Din itrobenzene
4,R-Dinitro-o-cresol
2.4-Dinitrophenol
2,4-Dinitrotoluene
2,6-Dmitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine
D i pheny 1 n i t rosam i ne
Detection Believed to
status3 be present

ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
NA
ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

D (CBI)
                                      6-7

-------
219Bg
                             Table 6-1   (Corn inueci)
BOAT
reference
no.

107.
IDS.
109.
110.
111.
112.
113.
114.
lib.
116.
117.
11H.
119.
120.

3C.
121.
122.
123.
124.
125.
126.
127.
126.
129.
130.
1.31.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
220.
143.
144.
145.
146.
Const ituent
Semivolat ile orqanics (continued)
1 . 2-Dipheny Ihydraz me
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyc lopentadiene
Hexachloroethane
Hexachlorophene
Hexach loropropene
lndeno( 1 ,2,3-cd)pyrene
Isosafrole
Methapyri lene
3-Methy Icho lanthrene
4,4'-Methylenebis
(2-chloroani 1 ine)
Methyl methanesulfonate
Naphthalene
1 ,4-Naphthoquinone
1-Naphthylamine
2-Naphthylarrnne
p-Nitroani 1 me
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamme
N-N itrosodiethy Idraine
N-Nitrosodimethy lamine
N-Nitrosomethylethylamine
N-Nitrosomorphol me
N-N itrosopi per idine
n-Nitrosopyrrol id ine
5-Nitro-o-toluidine
Pentachlorobenzene
Pen tachloroe thane
Pentachloron itrobenzene
Pentachlorophenol
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcinol
Detect ion Believed to
status3 be present

ND
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
D (CBI)
NA
ND
ND
ND
ND
                                     6-8

-------
Table  G-l  (Continued)
BOAT
reference
no.

147.
148.
149.
150.
151.
152.
153.


154.
155.
156.
157.
156.
159.
221.
ICO.
161.
16?.
163.
104.
165.
166.
167.
1C6.

1G9.
170.
171.

172.
173.
174.
175.
Const Huent
Semivolatile organics (continued)
Saf role
1.2.4 .5-Tetrachlorobenzene
2,3,4,6-Tetrachlorophenol
1 ,2,4-Tr ichlorobenzene
2,4, 5-Trichlorophenol
2,4,6-Trichlorophenol
Tris(2,3-dibromopropyl)
phosphate
Metals
Ant imony
Arsenic
Barium
Beryl 1 lum
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
S i Iver
Thai 1 ium
Vanadium
Zinc
Inorqanics other thrin metfll-i
Cyanide
F luor ide
Sulf ide
Orqanochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
Detection believed to
stdtui0 be present

ND
NO
ND
ND
ND
ND

ND

ND
ND Y
ND Y
ND Y
ND Y
D (CBI)
NA
ND Y
ND Y
ND
ND Y
ND
ND
ND Y
ND Y
ND Y

ND
0 (CBI)
D (CBI)

ND
ND
D (CBI)
ND
       6-9

-------
laljle  6-1   (Cont \nued)
BDA1
reference
no.

176.
177.
176.
179.
130.
161.
182.
18?,.
184.
165.
166.
187.
188.
lay.
190.
191.
.^
192.
193.
194.

195.
196.
197.
198.
199.

200.
201.
202.
203.
204.
205.
206.
Constituent
Oruonochlor ine ue:'.t IL ules (cent
gamma -BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan 1
Enclosulfan 11
Endrin
Endrin aldehyde
Heptochlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyc lor
Toxaphene
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxyacet ic acid
ii Ivex
2.4.5-7
Orqflnonhosnhorour; insect icirler.
Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCRs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1246
Aroclor 1254
Aroclor 1260
Detection Believed to
statui8 be present
inued)
ND
ND
ND
ND
ND
D (CBI)
ND
D (CBI)
ND
ND
D (Cbl)
ND
ND
ND
ND
ND

ND
ND
ND

ND
ND
ND
ND
ND

ND
ND
ND
ND
ND
NO
ND
        6-10

-------
21 Sec)
                             Tjhlc f.-l  (C.ont inuecl)
BOAT
reference
no.	
Const ituent
Detect ion
 status3
Bel levecl to
be present
               Pi ox ins and furans
207.
20b.
209.
210.
211.
212.
213.
Hexachlorodibenzo-p-dioxins        NO
Hexachlorodibenzofurdns            ND
Pentachlororiibenzo-p-diox ins       ND
Pentachlorodibenzofurans           ND
Tetrachlorodibenzo-p-dioxins       ND
Tetrachlorodiben.rofuran:,           D (CB1)
2,3.7,8-Tetrachlorodibenzo-
  p-dioxin                         NO
D   = Detected.
Cbl = Confidential business  information.
ND  = Not detected.
NA  = Not analyzed.
X   = Believed to be present based on engineering analysis of waste generating
      process.
Y   = Believed to be present based on detection  in treated residuals.

alf detected, concentration  is shown, units are mg/kg.
                                     6-11

-------
1836g

             Table 6-2  Regulated Constituents for K022 Waste



                         BOAT  Volatile  Orqanics

                         Toluene


                         BOAT  Semivolatile  Orqanics

                         Acetophenone
                         Phenol
                         Sum of  Diphenylamine  and
                           Dipheny1nttrosamine


                         BOAT  Metals

                         Chromium
                         Nickel
aThe standard for diphenylamine and diphenyInitrosamine  will  be
 calculated as the sum of these two constituents because the  two
 constituents cannot be distinguished using EPA's standard  analytical
 testing procedure.
                                     6-12

-------
                7.  CALCULATION OF BOAT TREATMENT STANDARDS
    This section details the calculation of treatment standards for the
regulated constituents selected in Section 6.  EPA is setting
nonwastewater treatment standards based on performance data from (1) fuel
substitution and  (2) stabilization, using a cement kiln dust binder of a
nonwastewater similar to the ash residual generated from use of K022 as a
fuel substitute.
7.1      Nonwastewater
    For treatment of BOAT list organics in K022 nonwastewater by fuel
substitution, all six data sets from Plant 1 have been used to calculate
the treatment standards.  The treatment data from this plant are believed
to represent a well-designed and well-operated treatment system, since
the organic constituents present in the untreated wastes were reduced to
nondetectable levels in the treatment residual.  Furthermore, they are
accompanied by sufficient QA/QC data to develop treatment standards.
Thus, the data points meet the requirements for setting treatment
standards.  The data from Plant 2 have not been used because sufficient
QA/QC data are not available to adjust the data for accuracy.
    Five of the data points from stabilization of F006 waste show
treatment of chromium;  nine data points show treatment of nickel.  These
data points were  used to calculate the metal treatment standards for K022
waste.  The performance data from stabilization of the F006 waste using a
cement kiln dust  binder reflect treatment in a well-designed,
                                    7-1

-------
well-operated system;  the data also are accompanied by sufficient QA/QC
information.  Thus, the data meet the requirements for setting treatment
standards.
    As discussed in Section 1, the calculation of a treatment standard
for a constituent to be regulated involves (1) adjusting the data points
for accuracy, (2) determining the mean (arithmetic average) and
variability factor (see Appendix A) for the data points, and
(3) multiplying the mean and the variability factor together to determine
the treatment standard.
    The procedure for adjusting the data points is discussed in detail in
Section 1.  The data from each of the demonstrated technologies are
adjusted in Appendix B.  The unadjusted and accuracy-corrected values for
the regulated constituents are presented again in Tables 7-1 and 7-2,
along with the accuracy-correction factors, means of the accuracy-
corrected values, and treatment standards.
7.2      Wastewater
    As discussed in Section 3, the Agency is aware that K022 wastewater
is generated from treatment of K022 waste.  Since neither
characterization data nor treatment data are available for such
wastewater, the Agency has not identified technologies that would be
demonstrated for the waste or developed treatment standards for the
waste.  EPA intends to propose and promulgate treatment standards for
K022 wastewater prior to May 8, 1990.
                                    7-2

-------
1836g

                   Table 7-1  Calculation of Nonwastewater Treatment Standards for the Regulated Constituents  Treated  by  Fuel  Substitution



                                                                      Correc-
                              Unadjusted  concentration  (mg/kg)         tion        Accuracy-corrected concentration (mq/kg)     Mean    Variability  Treatment
                       	Sample  Set  *	 factor  	Sample Set f	  (mg/kg)    factor     standard
                          123456                 123456                           (mg/kg)


BOAT Volatile Organics

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

BOAT Semivolatile Qrganics

Acetophenone           <3.8    <7.6    <3.8     <3.8     <3.7     <3.8    1/0.65   <5.8   '11.69   <5.8    <5.8    <5.7    <5.8      6.77      2.8         19

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

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

-------
1962g
                       Table  7-2  Calculation of Nonwastewater Treatment  Standards
                         for  the Regulated Constituents Treated by Stabilization





TCLP
concentrat ion

Sample Set 01
Sample Set v2
Sample Set *3
Sample Set 04
Sample Set »5
Sample Set f6
Sample Set f7
Sample Set #8
Sample Set #9
Average (mg/1)
Sample no.
Variability factor
Treatment standard
(mg/1)
.
0.39
O.Ob
-
0.36
0.76
1.21
-
-



(mg/1)
Chromium
Accuracy-
corrected
Correction value
factor (mg/1)
.
.1/0.658 0.454
1/0. B66 0.092
-
1/0.858 0.443
- 1/0.856 0.866
1/0.856 1.41
-
-
0.657
5
7.94
5.2


TCLP
concentration
(mg/1)
0.04
0.03
0.23
0.02
0.04
0.05
0.10
0.04
0.02




Nickel


Correct ion
factor
1/0.866
1/0.903
1/0.866
1/0.903
1/0.903
1/0.903
1/0.903
1/0.903
1/0.903





Accuracy-
corrected
value
(mg/1)
0.046
0.033
0.266
0.022
0.044
0.055
0.111
0.044
0.022
0.072
9
4.47
0.32
                                                 7-4

-------
                            8.  ACKNOWLEDGMENTS
    This document was prepared for the U.S. Environmental Protection
Agency, Office of Solid Waste, by Versar Inc. under Contract
No. 68-01-7053.  Mr. James Berlow, Chief, Treatment Technology Section,
Waste Treatment Branch, served as the EPA Program Manager during the
preparation of this document and the development of treatment standards
for K022 waste.  The technical project officer for the waste was Mr. Jose
Labiosa.  Mr. Steven Silverman served as legal advisor.
    Versar personnel involved in the preparation of this document
included Mr. Jerome Strauss, Program Manager; Ms. Justine Alchowiak,
Quality Assurance Officer; Mr. David Pepson, Senior Technical Reviewer;
Ms. Olenna Truskett, Technical Reviewer; Ms. Juliet Crumrine and
Ms. Barbara Malczak, Technical Editors; and the Versar secretarial staff,
Ms. Linda Gardiner and Ms. Mary Burton.
    Sampling and analysis of K022 waste was performed by PEI Associates,
Inc., under Contract No. 68-03-3389 for the Office of Research and
Development (ORD).  Mr. Benjamin Blaney, Chief, Treatment Technology
Staff, served as the ORD Program Manager.  The ORD technical project
officer was Mr. Brian Westfall.  Mr. Michael Melia, PEI, served as lead
engineer.
    We greatly appreciated the cooperation of the individual companies
that permitted their plants to be sampled and that submitted detailed
information to the U.S. EPA.
                                    8-1

-------
                               9.   REFERENCES
Ackerman, D.G., McGaughey, J.F., and Wagoner, D.E.  1983.  At sea
  incineration of PCB-containinq wastes on board the M/T Vulcanus.
  600/7-83-024.  Washington, D.C.:  U.S. Environmental Protection Agency.

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

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

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

Bonner, T.A., et al.  1981.  Engineering handbook for hazardous waste
  incineration.  SW-889.  Prepared by Monsanto Research Corporation for
  U.S. Environmental Protection Agency NTIS PB 81-248163. June 1981.

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

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

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

CWM.  1987.  Chemical Waste Management.  Technical note 87-117,
  Stabilization treatment of selected metals containing wastes.
  September 22, 1987.  Chemical Waste Management, 150 West 137th Street,
  Riverdale, 111.

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

Environ.  1985.  Characterization of waste streams listed in 40 CFR
  Section 261 waste profiles.  Vol. 1.  Prepared  for Characterization and
  Assessment Division, U.S. Environmental Protection Agency.
                                    9-1

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

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

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

Novak, R.G., Troxler, W.L., and Dehnke, T.H.  1984.  Recovering energy
  from hazardous waste incineration.  Chemical Engineering Progress
  91:146.

Oppelt, E.T.  1987.  Incineration of hazardous waste.  JAPCA 37(5),
  May 1987.

Pojasek, R.B. 1979. Solid-waste disposal:  solidification.  Chemical
  Engineering 86(17): 141-145.

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

SRI.  1987."  Stanford Research Institute, International.  1987 Directory
  of chemical producers - United States.  Menlo Park, Calif.:  SRI
  International.

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

USEPA.  1986a.  U.S. Environmental Protection Agency, Office of Solid
  Waste and Emergency Response.  Test methods for evaluating solid
  waste.  SW-846.  3rd ed.  Washington, D.C.:  U.S. Environmental
  Protection Agency.

USEPA.  1986b.  U.S. Environmental Protection Agency, Office of Solid
  Waste.   Hazardous waste management systems, land disposal
  restrictions, final rule, Appendix  I to Part 268 - Toxicity
  Characteristic Leaching Procedure (TCLP).  51 FR 40643-40654.
  November 7, 1986.
                                    9-2

-------
USEPA.  1986c.  U.S. Environmental Protection Agency.  Best demonstrated
  available technology (BOAT) background document for F001-F005 spent
  solvents.  Vol. 1, EPA/530-SW-86-056.

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

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

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

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

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

Vogel, G. et al.  1986.   Incineration  and cement kiln capacity for
  hazardous waste treatment.  In Proceedings of the  12th Annual Research
  Symposium. Incineration and Treatment of Hazardous Wastes. Cincinnati,
  Ohio.
                                    9-3

-------
                                 APPENDIX A
                            STATISTICAL METHODS

A.1  F Value Determination for ANOVA Test
    As noted in Section 1.2, EPA is using the statistical  method known as
analysis of variance (ANOVA) to determine the level  of performance that
represents "best" treatment where more than one technology is
demonstrated.  This method provides a measure of the differences between
data sets.
    If the Agency found that the levels of performance for one or more
technologies are not statistically different (i.e.,  the data sets are
homogeneous), EPA would average the long-term performance values achieved
by each technology and then multiply this value by the largest
variability factor associated with any of the acceptable technologies.
If EPA found that one technology performs significantly better (i.e., the
data sets are not homogeneous), the "best" technology would be the
technology that achieves the best level of performance, i.e., the
technology with the lowest mean value.
    To determine whether any or all of the treatment performance data
sets are homogeneous using the analysis of variance method, it is
necessary to compare a calculated "F value" to what is known as a
"critical value."  (See Table A-l.)  These critical  values are available
in most statistics texts (see, for example, Statistical Concepts and
Methods by Bhattacharyya and Johnson, 1977, John Wiley Publications,
New York).

                                    A-l

-------
                Table A-l
95th PERCENTILE VALUES FOR
    THE F DISTRIBUTION
 degrees of freedom for numerator
 degrees of freedom for denominator
      (shaded are* = JSS)
^
1
2
3
4
5
C
1
8
9
10
11
12
13
14
15
16
17
18
19
20
00
24
26
28
30
40
50
60
70
80
100
150
200
400
m
i
161.4
18.51
10.13
7.71
6.61
5.99
5.59
5.32
5.12
4.9C
4.84
4.75
4.67
4.60
4.54
4.49
4.45
4.41
4.38
4.35
4.30
4.26
4.23
4.20
4.17
4.08
4.03
4.00
3.98
3.96
3.94
3.91
3.89
3.86
3.84
2
199.5
19.00
9.55
6.94
5.79
5.14
4.74
4.46
4JJC
4.10
3.98
3.89
3.S1
3.74
3.68
3.63
3.59
3.55
3.52
3.49
3.44
3.40
3.37
3.34
3.32
3.23
3.18
3.15
3.13
3.11
3.09
3.06
3.04
3.02
2.99
3
215.7
19.16
9.28
6.59
5.41
4.76
4.35
4.07
3.86
3.71
3.59
3.49
3.41
3.34
2.29
3.24
3.20
3.16
3.13
3.10
3.05
3.01
2.98
2.95
2.92
2.84
2.79
2.76
2.74
2.72
2.70
2.67
2.65
2.62
2.60
4
224.6
19.25
9.12
6.39
5.19
4.53
4.12
3.84
3.C3
3.48
3.36
3.26
3.18
3.11
3.06
3.01
2.96
2.93
2.90
2.87
2.82
2.78
2.74
2.71
2.69
2.61
2.56
2.53
2.50
2.48
2.46
2.43
2.41
2.39
2.37
6
230.2
19.30
9.01
6.26
5.05
4.39
3.97
3.69
3.48
3.33
3.20
3.11
3.03
2.96
2.90
2.85
2.81
2.77
2.74
2.71
2.66
2.62
2.59
2.56
2.53
2.45
2.40
2.37
2.35
2.33
2.30
2JJ7
2.26
2~23
JL21
6
234.0
19.33
8.94
6.16
4.95
4.28
3.87
3.58
3.37
3.22
3.09
3.00
2.92
2.85
2.79
2.74
2.70
2.66
2.63
2.60
2.55
2.51
2.47
2.45
2.42
2.34
2JZ9
2.25
2^3
2.21
2.19
2.16
2.14
2J.2
2.09
8
23S.9
19.37
8.85
6.04
4.82
4.15
3.73
3.44
3.23
3.07
2.95
2.85
2.77
2.70
2.64
2.59
2.55
2.51
2.48
2.45
2.40
2J6
2.32
229
2M
2.18
2.13
2.10
2.07
2.05
2.03
2.00
1.98
1.96
1.94
12
243.9
19.41
8.74
5.91
4.68
4.00
3.57
3.28
3.07
2.91
2.79
2.69
2.60
2.53
2.48
2.42
2.38
2.34
2.31
2.28
2.23
2.18
2.15
2.12
2.09
2.00
1.95
1.92
1.89
1.88
1.85
1.82
1.80
1.78
1.76
16
24C.3
19.43
8.69
5.84
4.60
3.92
3.49
3.20
2.98
2.82
2.70
2.60
2.51
2.44
2.39
2.33
2JZ9
2JI5
2.21
2.18
2.13
2.09
2.05
2.02
1.99
1.90
1.85
1.81
1.79
1.77
1.75
1.71
1.69
1.67
1.64
20
248.0
19.45
8.66
5.80
4.56
3.87
3.44
3.15
2.93
2.77
2.65
2.54
2.46
2.39
2.33
2J3S
2.23
2.19
2.15
2.12
2.07
2.03
1.99
1.96
1.93
1.84
1.78
1.75
1.72
1.70
1.68
1.64
1.62
1.60
1.67
30
250.1
19.46
6.62
5.75
4.50
3.81
138
3.08
2.86
2.70
2.57
2.46
2.38
2.31
2^5
2.20
2.15
2.11
2.07
2.04
1.98
1.94
1.90
1.87
1.84
1.74
1.69
1.65
1.62
1.60
1.57
1.54
1.52
1.49
1.46
40
251.1
19.46
8.CO
5.71
4.46
3.77
3.34
3.05
2.82
2.67
2.53
2.42
2.34
*> 07
o «n
2.16
2.11
2.07
2.02
1.99
1.93
1.89
1.85
1.81
1.79
1.69
1.63
1.59
1.56
1.54
1.51
1.47
1.46
1.42
1.40
50
252.2
19.47
8.58
5.70
4.44
3.75
3.32
3.03
2.80
2.64
2.50
2.40
2.32
2^4
2.18
2.13
2.08
2.04
2.00
1.96
1.91
1.86
1.82
1.78
1.76
1.66
1.60
1.56
1.53
1.51
1.48
1.44
1.42
1.38
1.32
100
253.0
19.49
8.56
5.6C
4.40
3.71
3.28
2.98
2.76
2.59
2.45
2.35
2.26
2.19
2.12
2.07
2.02
1.98
1.94
1.90
1.84
1.80
1.76
1.72
1.69
1.59
1.52
1.48
1.45
1.42
1.39
1.34
1.32
1.28
1.24
-
25i.3
19.50
6.53
5.63
4.3C
3.67
3.23
2.93
2.71
2.54
2.40
2.30
2^1
2.13
2.07
2.01
1.96
1.92
1.88
1.84
1.78
1.73
1.69
1.65
1.62
1.51
1.44
1.39
1.35
1.32
1.28
1.22
1.19
1.13
1.00
                   A-2

-------
    Where the F value is less than the critical value, all treatment data

sets are homogeneous.  If the F value exceeds the critical value, it is

necessary to perform a "pair wise F" test to determine if any of the sets

are homogeneous.  The "pair wise F" test must be done for all of the

various combinations of data sets using the same method and equation as

the general F test.

    The F value is calculated as follows:

    (i)  All data are natural logtransformed.

    (ii)  The sum of the data points for each data set is computed (T.).

    (iii)  The statistical parameter known as the sum of the squares

between data sets (SSB) is computed:
   SSB

where:

k
p •    s
N



(iv)





where:


xi,j =
         = number of treatment technologies
         = number of data points for technology i
         = number of data points for all technologies
         = sum of natural logtransformed data points for each technology.

          The sum of the squares within data sets (SSW) is computed:

                                        r.2
 k   ni   ,
 I   I  *'
 Lf   L*
i-1 j=l
                                   k
                                 - I
           the natural logtransformed observations (j) for treatment
           technology (i).
                                    A-3

-------
    (v)  The degrees of freedom corresponding to SSB and SSV/ are
calculated.  For SSB, the degree of freedom is given by k-1.  For SSW,
the degree of freedom is given by N-k.
    (vi)  Using the above parameters, the F value is calculated as
follows:
                                  MSB
                              F = MSW
    where:
    MSB = SSB/(k-1) and
    MSW = SSW/(N-k).
    A computational table summarizing the above parameters is shown below.

                    Computational Table for the F Value
Source
Between
Within
Degrees of
freedom
k-1
N-k
Sum of
squares
SSB
SSW
Mean square
MSB = SSB/k-1
MSW = SSW/N-k
F value
MSB/MSW
    Below are three examples of the ANOVA calculation.  The first two
represent treatment by different technologies that achieve statistically
similar treatment; the last example represents a case in which one
technology achieves significantly better treatment than the other
technology.
                                    A-4

-------
1790g
                                                            Example 1
                                                       Methylene Chloride
           Steam stripping                                              Biological treatment
Influent       tffluent      ln(effluent)    [ln(effluent)]2    Influent      tffluent      ln(effluent)
 Ug/l)         (ng/1)                                         Ug/l)        (MO/I)
Sum:
                                                                                           [ln(ef fluent)]'
1550.00
1290.00
1640.00
5100.00
1450.00
4600.00
1760.00
2400.00
4800.00
12100.00
10.00
10.00
10.00
12.00
10.00
10.00
10.00
10.00
10.00
10.00
2.30
2.30
2.30
2.48
2.30
2.30
2.30
2.30
2.30
2.30
5.29
5.29
5.29
6.15
5.29
5.29
5.29
5.29
5.29
5.29
1960.00
2568.00
1817.00
1640.00
3907.00





10.00
10.00
10.00
26.00
10.00





2.30
2.30
2.30
3.26
2.30





5.29
5.29
5.29
10.63
5.29





                                 23.18
                                 53.76
                                                           12.46
                                                   31.79
Sample S i/c:
    10           10
                10
Mean:
  3669
10.2
2.32
2378
                                                              13.2
2.49
Standard Deviation:
  3328.67          .63
Variability factor:
                  1.15
                  .06
                                              923.04
                                              7.15
                                                                                2.48
                                 .43
ANOVA
SSB =
SSW =
Calcul
i=l
r *
z,
at ions:
2 \
' 1
n. J
.2) *2i.
-
(
A <• r i
N J
* [Tl?l
MSB = SSB/(k-l)

HSU = SSW/(N-k)
                                                           A-5

-------
1790g
                                     Example 1  (Continued)

F   = MSB/MSW

where :
k   = number of treatment technologies

n   = number of data points for technology i
 i

N   - number of natural logtransformed data points for all  technologies

T.  = sum of logtransformed data points for each technology

X   - the nat.  log transformed observations (j) for treatment technology  (i)
 ij
n  = 10. n  = 5. N = 15. k = 2. T  = 23.18.  T  = 12.46.  T = 35.64.  T  =  1270.21
   = 537.31  T  = 155.25
bib =
       537.31   155.25
        10
                            1270.21
                              15
                                           -  0.10
SSU - (53.76 + 31.79) -


MSB = 0.10/1 = 0.10

MSW - 0.77/13 = 0.06

F  =	  = 1.67
      0.06
                           10
                                                   - 0.77
                                    ANOVA Table

Source
Between(B)
Within(W)
Degrees of
freedom
1
13

SS MS F value
0.10 0.10 1.67
0.77 0.06
      The critical value of the F test at the 0.05 significance level  is 4.67.   Since
      the F value is  less than the critical value, the means are not significantly
      different (i.e.. they are homogeneous).

Note:  All calculations Mere rounded to two decimal places.   Results may differ
       depending upon the number of decimal places used in each step of the calculations.
                                          A-6

-------
1790g
                                                            Example 2
                                                        Inchloroethylene
Steam stripping
Influent
Ug/D
1650.00
S200.00
5000.00
1720.00
1560.00
10300.00
210.00
1600.00
204.00
160.00
Lf fluent
(M9/D
10.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
8S.OO
10.00
ln(eff luent)

2.30
2.30
2.30
2.30
2.30
2.30
2.30
3.30
4.44
2.30
[ln(ef fluent)]2

5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5.29
Influent
(M9/D
200.00
224.00
134.00
150.00
484 . 00
163.00
182.00



Biological treatment
tf fluent
Ug/1)
10.00
10.00
10.00
10.00
16.25
10.00
10.00



Infeff luent)

2.30
2.30
2.30
2.30
2.79
2.30
2.30



[In(effluent)]2

5.29
5.29
5.29
5.29
7.78
5.29
5.29



Sum:
Sample Size:
     10          10
Mean:
   2760
19.2
Standard Deviation:
   3209.6        23.7

Varidbi I ity Fddor:
                  3.70
                                 26.14
                10
2.61
                  .71
                                72.92
                                              220
                              120.5
                                                              10.89
2.36
                                                               1.53
                                                            16.59
               2.37
.19
                                 39.52
ANOVA Calculations:
SSB =

k

SSU = f Z,
1^1
n I
, n . i
-

lA-ri
N J


£' ,z- -1 z f Ti2l
,Z, X£'.J -.?, 7T-
MSB = SSB/(k-l)

MSV - SSW/(N-k)
                                                           A-7

-------
1790g •


                                     Example 2  (Continued)

F   - MSB/MSV

where:
k   = number of treatment technologies

n   - number of data points for technology i
 i

N   = number of data points for all technologies

T   - sum of natural logtransformed data points for each technology
 i
X   - the natural logtransformed observations (j) for treatment technology (i)
 ij

N  = 10. N  - 7. N - 17. k - 2. T  - 26.14.  T  - 16.59.  T -  42.73.  |2=  1825.85.  T?  =  683.30.


T2 = 275.23

      683.30      275.23  1   1825. B5
       10
SSU = (72.92 + 39.52) -


MSB - 0.25/1 - 0.25
MSW = 4.79/15 = 0.32


    0.32
                     7    J      17

                          683.30   2/5.23
                            10
                                              =  0.25
                                                = 4.79
                                    ANOVA Table
Degrees of
Source freedom
Between ( B) 1
Within(W) 15

SS MS F value
0.25 0.25 0.78
4.79 0.32
      The critical value of the F test at the 0.05 significance level is 4.54.   Since
      the F value  is  less than the critical value, the means are not significantly
      different (i.e., they are homogeneous).
Note:  All calculations were rounded to two decimal places.   Results may differ
       depending upon the number of decimal places used in each step of the calculations.
                                           A-8

-------
1790g
                                                           Examp Ic 3
                                                          Chlorobenzene
Activated sludge followed by  carbon adsorption              Biological treatment
Influent       Effluent       In(effluent)    [ln(effluent)]2   Influent      Effluent
 (Mg/l)         Ug/D                                         Ug/l)         Ug/D
                                                                        In(effluent)
                                                                          ln[(effluent)]<
7200.00
6500.00
607b.OO
3040.00



80.00
70.00
35.00
10.00



4.36
4.25
3.56
2.30



19.18
18.06
12.67
5.29



9206.00
16646.00
49775.00
14731.00
3159.00
6756.00
3040.00
1083.00
709 . 50
460.00
142.00
603.00
153.00
17.00
6.99
6.56
6.13
4.96
6.40
5.03
2.83
48.86
43.03
37.58
24.60
40.96
25.30
8.01
Sum:
                                 14.49
                                  55.20
                                                            38.90
                                                     228.34
Sample Size:
      4
Mean:
   5703
49
3.62
14759
                                                             452.5
5.56
Standard Deviation:
   1835.4        32.24
                  .95
                           16311.86
                 379.04
1.42
Variabi I ity Factor:
                  7.00
                                                              15.79
ANOVA
SSB -
SSW =
MSB =
HSU =
F =
Calculations:
4,1^1 - I
1=11 n 1
V H • 9 ^^
F k nj x2. 1 k
SSb/(k-l)
SSW/(N k)
MSB/MSW

1, " )2
N



                                                          A-9

-------
1790g
where.
                                      Example 3   (Continued)
k   = number of treatment technologies
n   - number of data points for technology i
 i
N   = number of data points for all technologies
T.  = sum of natural logtransformed data points for each technology

X   - the natural logtransformed observations (j) for treatment technology (i)
 ij

N  = 4. N = 7. N = 11.  k = 2. T  = 14.49. T  = 38.90. T = 53.39.  T*= 2850.49.  T? = 209.96
     1513.21
      209.96     1513.21
SSB_
SSW = (55.20 + 228.34)
                                              -  9.52
             = 14.88
MSB = 9.52/1 = 9.52

MSU * 14.88/9 = 1.65
K = 9.52/1.65 - 5.77
                                    ANOVA Table
                   Degrees of
          Source    freedom
SS
MS
F value
Bctwccn( B)
Within(W)
1
9
9.53
14.89
9.53
1.65
5.77
      The critical value of the F test at the 0.05 significance level is 5.12.   Since
      the F value  is  larger than the critical value, the means are significantly
      different (i.e.. they are heterogeneous).  Activated sludge followed by carbon
      adsorption is "best"  in this example because the mean of the long-term performance
      value,  i.e., the effluent concentration,  is lower.
Note:  All calculations were rounded to two decimal places.  Results may differ depending
       upon the number of decimal places used  in each step of the calculations.
                                          A-10

-------
A.2  Variability Factor
                                     c99
                              VF =  Mean
    where:
     VF     =  estimate of daily maximum variability factor determined
               from a sample population of daily data;
    Cgg     =  estimate of performance values for which 99 percent of the
               daily observations will be below.  Cgg is calculated
               using the following equation:  Cgg = hxp(y + 2.33 Sy)
               where y and Sy are the mean and standard deviation,
               respectively, of the logtransformed data; and
    Mean    =  average of the individual performance values.
    EPA is establishing this figure as an instantaneous maximum because
the Agency believes that on a day-to-day basis the waste should meet the
applicable treatment standards.  In addition, establishing this
requirement makes it easier to check compliance on a single day.  The
99th percentile is appropriate because it accounts for  Almost all process
variability.
    In several cases, all the results from analysis of the residuals from
BOAT treatment are found at concentrations less than the detection
limit.  In such cases, all the actual concentration values are considered
unknown and, hence, cannot be used to estimate the variability factor of
the analytical results.  Below is a description of EPA's approach for
calculating the variability factor for such  cases with  all concentrations
below the detection limit.
    It has been postulated as a general rule that a lognormal
distribution adequately describes the variation among concentrations.
Agency data show that the treatment residual concentrations are
                                    A-ll

-------
distributed approximately lognormally.  Therefore, the lognormal model
has been used routinely in the EPA development of numerous regulations in
the Effluent Guidelines program and is being used in the BOAT program.
The variability factor (VF) was defined as the ratio of the 99th
percentile (C  ) of the lognormal distribution to its arithmetic mean
(Mean), as follows:
           VF =     C99.                                   ^
                   Mean
    The relationship between the parameters of the lognormal  distribution
and the parameters of the normal distribution created by taking the
natural logarithms of the lognormally distributed concentrations can be
found in most mathematical statistics texts (see, for example,
Distribution in Statistics-Volume 1 by Johnson and Kotz, 1970).  The mean
of the lognormal distribution can be expressed in terms of the
mean (M) and standard deviation (a) of the normal distribution as
follows:
         C99    =  Exp (M +  2.33a)                        (2)
         Mean   =  Exp (M +  0.502).                       (3)
    By substituting (2) and (3) in  (1), the variability factor can then
be expressed in terms of a as follows:
         VF = Exp  (2.33 a - 0.5a2).                       (4)
    For residuals with concentrations that are not all below the
detection limit, the 99th percentile and the mean can be estimated from
the actual analytical data and, accordingly, the variability factor (VF)
can be estimated using equation (1).  For residuals with concentrations
                                    A-12

-------
that are below the detection limit, the above equations can be used in

conjunction with the following assumptions to develop a variability

factor.

    •  Assumption 1:  The actual concentrations follow a lognormal
       distribution.  The upper limit (UL) is equal to the detection
       limit.  The lower limit (LL) is assumed to be equal to one-tenth
       of the detection limit.  This assumption is based on the fact that
       data from well-designed and well-operated treatment systems
       generally fall within one order of magnitude.

    •  Assumption 2:  The natural logarithms of the concentrations have
       a normal distribution with an upper limit equal to In (UL) and a
       lower limit equal to In (LL).

    •  Assumption 3:  The standard deviation (o) of the normal
       distribution is approximated by:

       o = [ln(UL) - ln(LL)] / [(2)(2.33)]
         = [ln(UL/LL)] / 4.66.                             (5)

       (Note that when LL = (0.1)(UL) as in Assumption 1, then
       o = (InlO) / 4.66 = 0.494.)

    Substitution of the a value from equation (5) into equation (4)

yields the variability factor, VF, as shown:

       VF = 2.8.                                           (6)
                                    A-13

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                                APPENDIX  B
                             ANALYTICAL QA/QC

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

-------
The appropriate recovery values are selected according to the procedures
specified in Section 1.2.6(3).
    Tables B-l and B-2 present matrix spike recovery data for K022
waste.  Using these analytical recovery values, the data points were
corrected for accuracy.  Table B-3 presents recovery data for F006 waste
from which the standards for metals in K022 waste were transferred.
Table B-4 shows accuracy-corrected concentrations for the F006 treated
TCLP data.  This table also indicates why data points were deleted from
the data base.
B.2      Methods and Procedures Employed to Generate the Data Used in
         Calculating Treatment Standards
    Table B-5 lists the methods used for analyzing the constituents to be
regulated in K022 waste.  Most of these methods are specified in SW-846
(USEPA 1986a).  For some analyses, the SW-846 methods were modified;
these modifications are presented in Table B-6.  The Agency plans to use
these methods and procedures to enforce the treatment standards for K022
waste.
                                    B-2

-------
1636g
               Table B-l   Matrix Spike Recovery Data  for  Kiln  Ash Residuals
                                       from Plant  1
                                                   Sample               Duplicate
Constituent                                   percent  recovery      percent  recovery
Volat i 1e Orqanics

1,1-Dichloroethane                                  77                      77
Trichloroethene                                     89                      87
Chlorobenzene                                      101                     100
Toluene                                            106                     110
Benzene                                            102                     104
(Average of volatiles)                             (95)                    (95.6)

Semivolatile Orqanics (acid extractable)

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

Semivoldti1e Orqanics (base/neutral extractable)
1 ,2, 4 -Tri chlorobenzene
Acenaphthene
2,4-Dinitrotoluene
Pyrene
N-Nitroso-di-n-propylamine
1 ,4-Dichlorobenzene
(Average of base/neutral extractables)
74
40
60
14 a
74
76
' (64.8)
71
43
63
18 a
73
76
(65.2)
aThese data are not acceptable for use in developing treatment  standards because  the
 percent recovery  is less than 20 percent.

Reference:  USEPA  1988a.
                                            B-3

-------
163Gg
                    Table B-2   Matrix  Spike  Recovery  Data  for Kiln Ash
                                  Residuals  from  Plant  2
                                                   Sample              Duplicate
Constituent                                   percent  recovery     percent recovery
Volat i1e Orqanics

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

Semivolatile Oroanics (acid extractable)

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

Semivolatile Orqanics (base/neutral extractable)

1,2.4-Trichlorobenzene                              NA                     NA
Acenaphthene   •                                     NA                     NA
2,4-Dimtrotoluene                                  NA                     NA
Pyrene                                              NA                     NA
N-Nitroso-di-n-propylamine                          NA                     NA
1,4-Dichlorobenzene                                 NA                     NA
(Average of base/neutral extractables)             (NA)                    (NA)
NA = Not available.

Reference:  USEPA  1988b.
                                            B-4

-------
1982g
              Table B-3  Matrix Spike Recovery Data for the TCLP  Extracts  from  Stabilization of F006 Waste
Constituent
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium0
Silver0
Zinc
Original
amount
found
Ippm)
0.101a
0.01b
0.3737a
0.2765b
0.00758
2.9034b
0.3494a
0.2213b
0.2247a
0.1526b
0.3226a
0.2142b
0.001a
0.001b
0.028a
0.4742b
0.1013
0.043b
0.0437a
0.0344b
0.01333
27.202b
Duplicate
(ppm)
0.01
0.01
0.3326
0.222
0.0069
0.7555
0.4226
0.2653
0.2211
0.1462
0.3091
0.2287
0.001
0.001
0.0264
0.0859
0.12
0.053
0.0399
0.0411
0.0238
3.65
X Error
0.0
0.0
5.82
10.9
4.17
58.7
9.48
9.0
0.81
2.14
2.14
3.27
0.0
0.0
6.87
69.3
8.6
10.4
4.55
8.87
28.3
76.3
Actual
spike
0.086
0.068
4.9474
5.1462
4.9010
6.5448
4.6780
4.5709
4.8494
4.9981
4.9619
4.6930
0.0034
0.0045
4.5400
4.6093
0.175
0.095
4.2837
0.081
5.0910
19.818
X Recovery
94.5
104
91.9
97.9
97.9
94.3
85.8
86.6
92.5
97.0
92.9
89.4
92
110
90.3
86.6
86
66d
84.8
0.87d
101.4
87.8
Accuracy-
correct ion
factor
1.06
0.96
1.09
1.02
1.02
1.06
1.17
1.15
1.08
1.03
1.08
1.12
1.09
0.91
1.11
1.15
1.16
0.96
1.18
114.9
0.99
1.14
aAt a mix ratio of 0.5.
bAt a mix ratio of 0.2.
cFor a mix ratio of 0.2. correction factors of 1.16 and 1.18 were used when correcting for selenium and silver
 concentrations, respectively.
 This value is not considered in the calculation for the accuracy-correction factor.

Reference:  Memo to R. Turner, U.S. EPA/HWERL. from Jesse R. Conner.  Chemical Waste Management,  dated January 20.  1988.
                                                          B-5

-------
Table B-4  Accuracy-Corrected Performance Data for Stabilization of F006 Waste
Concentration (ppm)
Sample Set f
.Constituent Stream
Arsenic Untreated total
Untreated TCLP
Treated TCLPa
Treated TCLPb
Barium Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Cadmium Untreated total
Untreated TCLP
Treated TCLP3
f Treated TCLPb
Ol
Chromium Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Copper Untreated total
Untreated TCLP
Treated TCLPa
Treated TCLPb
Lead Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
1
<0.01
<0.01d
-
36.4
0.08
0.12f
-
1.3
0.01
0.01e
-

1270
0.34
0.59f
-
40.2
0.15
0.20f
-
35.5
0.26
0.33f
-
2
<0.01
<0.01c'd
<0.01d
21.6
0.32
0.51C
0.46f
31.3
2.21
0.53C
0.01

755
0.76
0.46C
0.45
7030
368
5.57C
0.27
409
10.7
0.45C
0.39
3
<0.01
<0.01c'd
<0.01d
85.5
1.41
0.34
0.34C
67.3
1.13
0.06
0.02C

716
0.43
0.09
0.23C
693
1.33
1.69f
1.99C
25.7
0.26
0.34f
0.44C
4
-
<0.01c'd
<0.01d
17.2
0.84
0;20C
0.25
1.30
0.22
0.01C
0.01

110
0.18
0.27C
0.35f
1510
4.6
0.31C
0.29
88.5
0.45
0.34C
0.379
5
<0.01
<0.01c'd
<0.01d
14.3
0.38
0.32°
0.21
720
23.6
3.43C
0.01

12200
25.3
0.29C
0.44
160
1.14
0.21C
0.31
52
0.45
0.27C
0.399
6
<0.01
<0.01c'd
<0.01d
24.5
0.07
0.31C
0.36f
7.28
0.3
0.02C
0.01

3100
38.7
0.24C
0.88
1220
31.7
0.22C
0.22
113
3.37
0.34C
0.39
7
<0.01
<0.01C
<0.01d
12.6
0.04
0.04C
0.15f
5.39
0.06
0.01C
0.01

42900
360
3.5C
1.41
10600
8.69
0.41C
0.45
156
1.0
0.34C
0.41
8
<0.01
•d 
-------
                                                                    Table B-4  (Continued)
Concentration (ppm)
Sample Set #
Constituent
Mercury



Nickel



Selenium



Si Iver



.Zinc



Stream
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP3
Treated TCLPb
Untreated total
Untreated TCLP
Treated TCLP9
Treated TCLPb
1
.
<0.001
<0.001d
-
435
0.71
0.05
-
.
<0.01
0.07d
-
2.3
0.01
0.04e
-
1560
0.16
0.03

2

<0.001
<0.001Cld
<0.001d
989
22.7
1.73C
0.03
_
<0.01
0.07c'd
0.13d
6.62
0.14
0.04C
0.06
4020
219
42. Oc
0.01
3

<0.001
<0.001d
<0.001c>d
259
1.1
0.26
0.17C
.
<0.01
0.08d
0.13c'd
39
0.02
0.24f
0.06C
631
5.41
0.06
0.03C
4

<0.001
d
<0.001d
701
9.78
0.61C
0.04
.
<0.01
0.05c'd
0.10d
5.28
0.08
0.05C
0.07^
35900
867
3.87C
0.03
6
.
0.003
<0.001c>d
<0.001d
19400
730
19. lc
0.06
_
<0.01
0.06c>d
0.13d
4.08
0.12
0.04C
0.06
27800
1200
42. Oc
0.04
7
.
<0.001
<0.001c>d
<0.001d
13000
152
0.46C
0.11
_
<0.01
0.05c'd
0.08d
12.5
0.05
0.04C
0.06f
120
0.62
0.02C
0.02
8
.
<0.001
<0.001c>d
<0.001d
23700
644
18. lc
0.04
.
<0.01
. 0.08c'd
0.08d
8.11
0.31
0.04C
0.06
15700
650
5.17C
0.02
9
.
d
<0.001d
5730
16.1
1.25C
0.02
.
<0.45
<0.01c'd
<0.01d
19.1
<0.01
<0.01C
<0.01e
322
1.29
0.08C
<0.01
aMix ratio is 0.2.   The mix ratio is the ratio of  the reagent  weight  to waste  weight.
bMix ratio is 0.5.
Note:  Data points were deleted for the reasons given in  the following  footnotes:
cLess effective design and operation.
 No untreated total concentration or TCLP.
Untreated TCLP value low.
 Treated values greater than untreated value.
^Reduction attributed to dilution with reagent.

-------
       table B-5  Analytical Methods tor Reyulated Constituents Analysis
               Analysis/Methods
   Method
Reference
Semivolatile Organics:

    Continuous 1 iquici-1 iquid extraction                35?0
    Soxhlet  extraction                                  3540
    Gas chromatography/mass spectrometry for
      semivolatlie organics:  Capillary Column
      Technique                                        8?70

Volatile Organics:

    Purge and trap                                     5030
    Gas chromatography/mass spectrometry for
      volatile organics                                 B240

Metals:
    Digestion
      All solids
    3050
    Inductively coupled plasma atomic emission
      spectroscopy (chromium and nickel)

    Sulfide
TCLP
    6010

    9030

51 FR 40C43
References:

1.  USFPA.  1986a.  U.S. Environmental Protection Agency,  Office of Solid
    Waste and Emergency Response.  Test methods for evaluating solid waste.
    SW-B46, 3rd ed.  November 19BG.

2.  USEPA.  1986b.  U.S. Environmental Protection Agency,  Office of Solid
    Waste.  Hazardous waste management systems; land disposal restrictions;
    final rule; Appendix I to Part 2C6 - Toxicity Characteristic Leaching
    Procedure (TCLP).  51 FR 40643-40654.  November 7, 1986.
                                    B-8

-------
              Table B-6  Method Mod itication:, Used to Analyze K02?
                         Untreated and Treated Samples
                              Method modifications
Vn1.it i 1e Orqanics

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

Semivolatile Orqanics

    Because of the high hydrocarbon nature of the matrix,  some modifications
were necessary in the semivolatile preparation procedure.   The samples were
originally extracted (pitch) or diluted (oil and raw waste) from approximately
1 gram to 5 mi Hi liters  in an attempt to achieve as low a  detection limit as
possible.  However, further dilution was found to be necessary before
quantitative work was possible: the sample extract was dark and highly
concentrated.  The modification made was that additional surrogates and matrix
spikes were added prior to the further dilution in order that they might be
measurable in the final aliquot.  Accounting was made for  any spikes already
present.  In general, 2S-fold and greater dilutions were required in the
semivolatiles analyses.
                                     B-9

-------
                                APPENDIX C
                     DETECTION  LIMITS  FOR TESTED WASTES

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

-------
         Table C-l   Detection Limits  of BOAT List  Constituents  in  K022 Untreated  Waste for  Plant  1
BOAT
reference Constituent
no.
Untreated waste3
R-l
(mg/kg)
R-2
(mg/kg)
R-3
(mg/kg)
R-4
(mg/kg)
R-5
(mg/kg)
R-6
(mg/kg)
               Volatile Oroanics                  aDetection limits for the untreated waste  are  RCRA Confidential
                                                  Business Information (CBI).
222.           Acetone
1.             Acetonitrile
2.             Acrolein
3.             Acrylonitrile
4.             Benzene
5.             Bromodichloromethane
6.             Bromomethane
223.           n-Butyl alcohol
7.             Carbon tetrachloride '
8.             Carbon disulfide
9.             Chlorobenzene
10.             2-Chloro-1.3-butadiene
11.             Chlorodibromomethane
12.             Chloroethane
13.             2-Chloroethyl vinyl ether
14.             Chloroform
15.             Chloromethane
16.             3-Chloropropene
17.             l,2-Dibromo-3-chloropropane
18.             1,2-Oibromoethane
19.             Dibromomethane
20.             trans-l,4-Dichloro-2-butene
21.             Oichlorodifluoromethane
22.             1,1-Dichloroethane
23.             1.2-Dichloroethane
24.             1,1-Dichloroethylene
25.             trans-1,2-Dichloroethene
26.             1,2-Dichloropropane
27.            ' trans-1,3-Dichloropropene
28.             cis-1,3-Dichloropropene
29.             1.4-Dioxane
224.           2-Ethoxyethanol
225.           Ethyl acetate
226.           Ethyl benzene
30.             Ethyl cyanide
227.           Ethyl ether
31.             Ethyl methacrylate
214.           Ethylene oxide
32.             lodomethane
                                                          C-2

-------
                                                Table C-l   (Continued)
BOAT
reference Constituent
no.
Untreated waste3
R-l R-2
(mg/kg) (mg/kg)
R-3 R-4 R-5
(mg/kg) (mg/kg) (mg/kg)
R-6
(mg/kg)
              Volati 1e Orqonics (continued)       Detection  limits  for  the untreated waste are RCRA Confidential
                                                   Business  Information  (CBI).

33.            Isobutyl alcohol
228.           Methanol
34.            Methyl ethyl ketone
229.           Methyl isobutyl ketone
35.            Methyl methacrylate
37.            Methacrylonitrile
38.            Methylene chloride
230.           2-Nitropropane
39.            Pyridine
40.            1,1.1,2-Tetrachloroethane       '
41.            1,1,2,2-Tetrachloroethane
42.            Tetrachloroethene
• .3.            Toluene
44.            Tribromomethane
45.            1.1,1-Trichloroethane
46.            1.1,2-Trichloroethane
47.            Trichloroethene
48.            Trichloromonofluoromethane
49.            1.2,3-Trichloropropane
231.           l.l'.2-Trichloro-1.2,2-
                 trifluoroethane
50.            Vinyl chloride
215.           1,2-Xylene
216.           1,3-Xylene
217.           1.4-Xylene

               Semivolatiles

51.            Acenaphthalene
52.            Acenaphthene
53.            Acetophenone
54.            2-Acetylaminofluorene
55.            4-Aminobiphenyl
56.            Aniline
57.            Anthracene
58.            Aramite
59.            Benz(a)anthracene
218.           Benzal chloride
60.            Benzenethiol
61.            Deleted
62.            Benzofa)pyrene
                                                            C-3

-------
                                                Table C-l   (Continued)
BOAT
reference Constituent
no.
Untreated waste3
R-l
(mg/kg)
R-2
(mg/kg)
R-3
(mg/kg)
R-4
(mg/kg)
R-5
(mg/kg)
R-6
(mg/kg)
             Semivolati1e Orqanics (continued)      Detection  limits  for  the untreated waste are RCRA Confidential
                                                   Business  Information  (CBI).
63.            Benzo(b)fluoranthene
64.            Benzo(ghi)perylene
65.            Benzo(k)fluoranthene
66.            p-Benzoquinone
67.            Bis(2-chloroethoxy)methane
68.            Bis(2-chloroethyl)ether
69.            Bis(2-chloroisopropyl)ether
70.            Bis(2-ethylhexyl)phthalate
71.            4-Bromophenyl phenyl ether
72.            Butyl benzyl phthalate
73.            2-sec-Butyl-4,6-dinitrophenol
74.            p-Chloroaniline
75.            Chlorobenzilate
76.            p-Chloro-m-cresol
77.            2-Chloronaphthalene
78.            2-Chlorophenol
79.            3-Chloropropionitrile
80.            Chrysene
81.            ortho-Cresol
82.            para-Cresol
232.           Cyclohexanone
83.            Dibenz(a,h)anthracene
84.            Dibenzo(a.e)pyrene
85.            Dibenzo(a,i)pyrene
86.            m-Dichlorobenzene
87.            o-Dichlorobenzene
88.            p-Dichlorobenzene
89.            3,3'-Oichlorobenzidine
90.            2,4-Dichlorophenol
91.            2.6-Oichlorophenol
92.            Diethyl phthalate
93.            3,3'-Dimethoxybenzidine
94.            p-Dimethylaminoazobenzene
95.            3,3'-Dimethylbenzidine
96.            2.4-Dimethylphenol
97.            Dimethyl phthalate
98.            Di-n-butyl  phthalate
99.            1,4-Dinitrobenzene
100.           4,6-Dinitro-o-cresol
101.           2,4-Dinitrophenol
                                                             C-4

-------
                                                Table  C-l   (Continued)
BOAT
reference Constituent
no.
a
Untreated waste
R-l
(mg/kg)
R-2
(mg/kg)
R-3
(mg/kg)
R-4
(mg/kg)
R-5
(mg/kg)
R-6
(mg/kg)
            Semivolatile Orqanics (continued)     aDetect ion  limits  for  the untreated waste are RCRA Confidential
                                                   Business  Information  (CB1).

102.            2.4-Dinitrotoluene
103.            2,6-Dinitrotoluene
104.            Di-n-octyl phthalate
105.            Di-n-propylnitrosamine
106.            Diphenylamine
219.            Diphenylnitrosa-,ine
107.            1,2-Diphenylhydrazine
108.            Fluoranthene
109.            Fluorene
110.            Hexachlorobenzene
111.            Hexachlorobutadiene
112.            Hexachlorocyclopentadiene
113.            Hexachloroethane
114.            Hexachlorophene
115.            Hexachloropropene
116.            lndeno(1.2.3-cd)pyrene
117.            Isosafrole
118.            Methapyrilene
119.            3-Methylcholanthrene
120.            4,4'-Methy1enebis
                 (2-chloroaniline)
36.            Methyl methanesulfonate
121.            Naphthalene
122.            1,4-Naphthoquinone
123.            1-Naphthylamine
124.            2-Naphthylamine
125.            p-Nitroaniline
126.            Nitrobenzene
127.            4-Nitrophenol
128.            N-Nitrosodi-n-butylamine
129.            N-Nitrosodiethylamine
130.            N-Nitrosodimethylamine
131.            N-Nitrosomethylethylamine
132.            N-Nitrosomorpholine
133.            N-Nitrosopiperidine
134.            n-Nitrosopyrrolidine
135.            5-Nitro-o-toluidine
136.            Pentachlorobenzene
137.            Pentachloroethane
138.            Pentachloronitrobenzene
                                                           C-5

-------
                                                Table C-l  (Continued)
BOAT
reference Constituent
no.

R-l
(mg/kg)
Untreated waste3
R-2 R-3 R-4
(mg/kg) (mg/kg) (mg/kg)

R-5
(mg/kg)

R-6
(mg/kg)
             Semivolati1e Organics  (continued)      Detection limits for the untreated waste are RCRA  Confidential
                                                   Business Information (CBI).

 139.            Pentachlorophenol
 140.            Phenacetin
 141.            Phenanthrene
 142.            Phenol
 220.            Phthalic  anhydride
 143.            2-Picoline
.144.            Pronamide
 145.            Pyrene
 146.            Resorcinol
 147.            Safrole
 148.            1.2,4,5-Tetrachlorobenzene
 149.            2.3,4,6-Tetrachlorophenol
 150.            1,2,4-Trichlorobenzene
 151.            2,4,5-Trichlorophenol
 152.            2,4.6-Trichlorophenol
 153.            Tris(2,3-dibromopropyl)
                  phosphate

                Metals

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

                Inorganics

 169.            Cyanide
 170.            Fluoride
 171.            Sulfide


                                                              C-6

-------
                                                 Table C-l  (Continued)
BOAT
reference Constituent
no.
Untreated waste
R-l
(mg/kg)
R-2
(mg/kg)
R-3 R-4
(mg/kg) (mg/kg)
R-5
(mg/kg)
R-6
(mg/kg)
               Qroanochlorine pesticides          aDetect ion  limits for the untreated waste are RCRA Confidential
                                                   Business Information (CB1).

172.            Aldrin
173.            alpha-BHC
174.            beta-BHC
175.            delta-BHC
176.            gamma-BHC
177.            Chlordane
178.            DOD
179.            DDE
180.            DDT
181.            Dieldrin
182.            Endosulfan 1
183.            Endosulfan II
184.            Endrin
185.            Endrin aldehyde
186.            Heptachlor
187.            Heptachlor epoxide
188.            Isodrin
189.            Kepone
190.            Methoxyclor
191.            Toxaphene

               Phenoxyacetic  acid herbicides

192.            2,4-Dichlorophenoxyacetic  acid
193.            Silvex
194.            2.4.5-T

               Orqanophosphorous insecticides

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

               PCBs

ZOO.            Aroclor 1016
201.            Aroclor 1221
202.            Aroclor 1232
                                                             C-7

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

               Dioxins and furans

207.           Hexachlorodibenzo-p-dioxins
208.           Hexachlorodibenzofurans
209.           Pentachlorodibenzo-p-dioxins
210.           Pentachlorodibenzofurans
211.           Tetrachlorodibenzo-p-dioxins
212.           Tetrachlorodibenzofurans
213.           2,3,7 ,'8-Tet rach lorod i benzo-p-
                 dioxin
ND = Not detected.
 D = Detected.
NA = Not analyzed.
                                                           C-8

-------
1954g
                       Table C-2  Detection Limits of BOAT List Constituents in Kiln Ash for Plant  1
BOAT
reference
no.
Constituent
  A-l
(mg/kg)
  A-2
(mg/kg)
  A-3
(mg/kg)
  A-4
(mg/kg)
  A-5
(mg/kg)
  A-6
(mg/kg)
               Volatiles Orqanics
III.
1.
2.
3.
4.
5.
6.
223.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224.
225.
226.
30.
227.
31.
214.
32.
Acetone
Acetonitrile
Acrolein
Acrylonitrile
Benzene
Bromodichloromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-l,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1,2-Dibromo-3-chloropropane
1,2-Dibromoethane
Dibromomethane
trans-1,4-Dichloro-2-butene
D ichlorod ifluoromethane
1,1-Dichloroethane
1,2-Dichloroethane
1,1-Dichloroethylene
trans-1,2-Dichloroethene
1,2-Dichloropropane
trans-1,3-Dichloropropene
cis-1,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
.0.0375
0.014
0.0135
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.909
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.015
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.0150
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
NA
0.420
0.065
0.0375
0.014
0.0125
0.046
NA
0.016
0.006
0.0115
0.006
0.0145
0.0345
0.020
0.0115
0.0375
0.0025
0.025
0.020
0.017
0.090
0.235
0.0155
0.0135
0.011
0.010
0.015
0.0145
0.0135
0.500
NA
NA
NA
1.50
NA
0.500
NA
0.0465
                                                               C-9

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

A-l
Img/kg)

A-2
(mg/kg)

A-3
(mg/kg)

A-4
(mg/kg)

A-S
(mg/kg)

A-6
(mg/kg)
              Volati1e orqanics (continued)
33.
228.
34.
229.
35.
37.
38.
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
231.

50.
215.
216.
217.
51.
52.
53.
54.
55.
56.
57.
58.
59.
218.
60.
61.
62.
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methacrylonitrile
Methylene chloride
2-Nitropropane
Pyridine
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1,1.1-Trichloroethane
1.1,2-Trichloroethane
Trichloroethene
Tr ich loromonofluoromethane
1,2,3-Trichloropropane
l.l,2-Trichloro-1.2.2-
  trif luoroethane
Vinyl chloride
1,2-Xylene
1.3-Xylene
1,4-Xylene

Semivolat iles

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

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


63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
232.
83.
84.
85.
86.
87.
88.
89.
90.
91.
92.
93.
94.
95.'
96.
97.
98.
99.
100.
101.
Constituent
Semivolatile orqanics
(Continued)
Benzol b)f luoranthene
Benzo(ghi)perylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)methane
&is(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroani 1 ine
Chlorobenzi late
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitrile
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
D ibenzo( a, h) anthracene
D i benzo ( a , e ) py rene
0 i benzo ( a , i ) pyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenzidine
2,4-Dichlorophenol
2,6-Dichlorophenol
Diethyl phthalate
3,3'-Dimethoxybenzidine
p-Dimethylaminoazobenzene
3,3'-Dimethylbenzidine
2,4-Dimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1,4-Dinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
A-l
(mg/kg)


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


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


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


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


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


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

-------
1954g
                                                   Table  C-2   (Continued)
BOAT
reference
no.
Const ituent
   A-l
 (mg/kg)
   A-2
 (mg/kg)
  A-3
(mg/kg)
   A-4
 (mg/kg)
   A-5
 (mg/kg)
  A-6
(mg/kg)
              Semivolatile orqanics
                   (Continued)
102
103.
104.
105.
106.
219.
107.
108.
109.
110.
111.
112.
113.
114.
115.
116.
117.
118.
119.
120.

36.
121.
122.
123.
124.
125.
126.
127.
128.
129.
130.
131.
132.
133.
134.
135.
136.
137.
138.
2,4-Dinitrotoluene
2.6-Dinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine
Diphenylnitrosamine
1,2-Diphenylhydrazine
F luoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
Indenofl,2,3-cd)pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4.4'-Methylenebis
   (2-chloroaniline)
Methyl methanesulfonate
Naphthalene
1,4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroaniline
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N-Nitrosomorpholine
N-Nitrosopiperidine
n-Nitrosopyrrolidine
5-Nitro-o-toluidine
Pentachlorobenzene
Pentachloroethane
Pentachloronitrobenzene
 8.39
16.79
 8.31
 8.31
 8.23
8.31
2.79
1.90
2.65
2.65
3.45
3.00
1.55
3.40
1.55
1.45
0.80
7.00
2.95
2.20
11.53
6.50
5.59
3.79
5.30
5.30
6.90
6.00
3.10
6.79
3.10
2.90
1.59
13.99
5.90
4.41
23.05
13.0
2.77
1.88
2.63
2.63
3.41
2.97
1.54
3.36
1.54
1.43
0.79
6.93
2.92
2.18
11.41
6.43
2.77
1.88
2.63
2.63
3.41
2.97
1.54
3.36
1.54
1.43
0.79
6.93
2.92
2.18
11.41
6.43
2.74
1.86
2.6
2.6
3.38
2.94
1.52
3.33
1.52
1.42
0.78
6.86
2.89
2.16
11.3
6.37
2.77
1.88
2.63
2.63
3.41
2.97
1.54
3.36
1.54
1.43
0.79
6.93
2.92
2.18
11.41
6.43
35
70
34.64
34.64
34.3
                                                34.64
0.55
0.5
36
50
4.15
5.50
3.35
6
1
8.50
1.85
0.85
2.00
1.50
4.55
4.7
0.80
4.75
1.10
1
72
100
8.30
11.00
6.69
12
2
17
3.69
1.70
4.00
3.00
9
9.4
1.60
9.51
0.54
0.49
35.65
49.5
4.11
5.44
3.31
5.94
1
8.41
1.3
0.84
1.98
1.48
4.50
4.65
0.79
4.71
0.54
0.49
35.65
49.5
4.11
5.44
3.31
5.94
1
8.41
1.3
0.84
1.98
1.48
4.50
4.65
0.79
4.71
0.539
0.49
35.3
49
4.07
5.39
3.28
5.88
0.98
8.33
1.81
0.833
1.96
1.47
4.46
4.6
0.784
4.66
0.54
0.49
35.65
49.5
4.11
5.44
3.31
5.94
1
8.41
1.3
0.84
1.98
1.48
4.50
4.65
0.79
4.71
                                                               C-12

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


139.
140.
141.
142.
220.
143.
144.
145.
146.
147.
148.
149.
150.
151.
152.
153.


154.
155.
156.
157.
158.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.



Const Huent
Semivolatile orqanics
(Continued)
Pentachlorophenol
Phenacet in
Phenanthrene .
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcinol
Safrole
1 ,2,4,5-Tetrachlorobenzene
2,3,4, 6-Tetrach loropheno 1
1 ,2,4-Trichlorobenzene
2, 4, 5-T rich loropheno 1
2, 4, 6- T rich loropheno 1
Tris(2,3-dibromopropyl)
phosphate
Metals
Ant imony
Arsenic
Ba r i urn
Beryll ium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thall ium
Vanadium
Zinc
Metals TCLPa
Arsenic
Barium
A-l
(mg/kg)


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

4.70

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

0.15
' 0.01
A-2
(mg/kg)


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

9.40

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

0.015
0.01
A-3
(mg/kg)


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

4.70

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

0.015
0.01
A-4
(mg/kg)


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

4.70

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

. 0.015
0.01
A-5
(mg/kg)


1.81
4.6
2.45
1.86
NA
18.1
11.3
2.25
37.7
2.35
3.14
15.2
0.931
1.08
1.62

4.61

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

0.015
0.01
A-6
(mg/kg)


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

4.66

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

0.015
0.01
                                                            C-13

-------
1954g
                                                   Table  C-2   (Continued)
BOAT
reference
no.
Constituent
    A-l
  (mg/kg)
   A-2
 (mg/kg)
  A-3
(mg/kg)
   A-4
 (mg/kg)
   A-5
 (mg/kg)
   A-6
 (mg/kg)
               Metals TCLPa (continued)
               Cadmium
               Chromium
               Lead
               Mercury
               Selenium
               Silver
0.025
0.025
0.15
0.005
0.3
0.025
0.025
0.025
0.15
0.005
0.3
0.025
0.025
0.025
0.15
0.005
0.5
0.025
0.025
0.025
0.15
0.005
0.5
0.025
0.025
0.025
0.15
0.005
0.5
0.025
0.025
0.025
0.15
0.005
0.5
0.025
               Inorganics
169.
170.
171.
Cyanide
Fluoride
Sulfide
  1.25
 10
200
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
               Orqanochlorine pesticides
172.
173.
174.
175.
176.
177.
176.
179.
180.
181.
182.
183.
184.
185.
186.
187.
186.
189.
190.
191.
Aldrin
alpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chlordane
DDD
ODE
DDT
Dieldrin
Endosulfan 1
Endosulfan 11
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
kepone
Methoxyclor
Toxaphene
0.4
0.4
0.4
0.4
0.4
0.8
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.8
0.4
0.4
0.4
0.4
NA
0.4
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
               Phenoxyacetic acid herbicides
192.
193.
194.
2.4-Dichlorophenoxyacetic acid       0.02       NA
Silvex                               0.01       NA
2.4.5-T                              0.01       NA
                         NA
                         NA
                         NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                                                             C-14

-------
1954g
                                                   Table C-2   (Continued)
BOAT
reference
no.
Constituent
  A-l
(mg/kg)
   A-2
 (mg/kg)
  A-3
(mg/kg)
   A-4
 (mg/kg)
   A-5
 (mg/kg)
   A-6
 (mg/kg)
               Orqanophosphorous insecticides
195.
196.
197.
198.
199.
Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
0.05
0.04
0.05
0.05
0.05
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
               PCBs
200.
201.
202.
203.
204.
205.
206.
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
0.8
0.8
0.8
0.8
0.8
0.8
0.8
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
207.
208.
209.
210.
211.
212.
213.
Dioxins and furans

Hexachlorodibenzo-p-dioxins          0.00007    NA
Hexachlorodibenzofurans              -          NA
Pentachlorodibenzo-p-dioxins         0.0002     NA
Pentachlorodibenzofurans             0.000068   NA
Tetrachlorodibenzo-p-dioxins         0.000022   NA
Tetrachlorodibenzofurans             0.000028   NA
2.3.7.8-Tetrachlorodibenzo-p-        0.00036    NA
  dioxin
                       NA
                       NA
                       NA
                       NA
                       NA
                       NA
                       NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
                        NA
- = No detection limit specified.  Detection limit studies have not been completed.

NA = Not analyzed

 Units are mg/1.
                                                          C-15

-------
220bg
               •Table C-3  Detection  Limits of BOAT List Constituents
                           Analyzed  in  K022 Waste from P lout 2
BOAT
reference
no.

222.
1.
2.
3.
4.
5.
F..
?23.
7.
b.
9.
10.
11.
12.
13.
14.
15.
it.
17.
16.
ly.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224.
225.
226.
30.
227.
31.
Const ituent
Vnlat i les
Acetone
Aceton itn le
Acrolein
Acrylonitri le
Benzene
Broinodichloroinethoiit!
Bromome thane
n-Butyl alcohol
Carbon tetrachloride
Carbon chsulficle
Chlorobenzene
2-Chloro-l ,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 ,2-Dibromo-3-chloropropane
1 ,2-Dibromoethane
Dibromomethane
trans -1 , 4 -D \chloro-2-butene
Dichlorodif luorome thane
1. 1-Dichloroethane
1 ,2-Dichloroethane
1 , 1-Dichloroethylene
trans-1 ,2-Dichloroethene
1 ,2-Dichloropropane
trans-1 ,3-Dichloropropene
cis-l,3-Dichloropropene
1 ,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
CAS no.

C7-C4-1
75-05-B
107-02-6
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-46-1
75-00-3
110-75-8
67-66-3
74-67-3
107-05-1
96-12-6
106-93-4
74-95-3
110-57-6
75-71-6
75-34-3
107-06-2
75-35-4
156-60-5
78-67-5
10061-02-6
10061-01-5
123-91-1
110-80-5
141-76-6
100-41-4
107-12-0
60-29-7
97-63-2
Detect ion limit (mci/ku)
Untreated Ash
waste'1 residual'

NA
0.42
0.065
0.0375
0.014
0.0125
0.046
NA
0.01C
0.006
0.0115
0.006
0.0145
0.0345
0.02
0.0115
0.0375
0.0025
0.025
0.02
0.017
0.09
0.235
0.0155
0.0135
0.011
0.01
0.015
0.0145
0.0135
0.5
NA
NA
NA
1.5
NA
0.5
                                    C-16

-------
220M)
                             lab le I- j  (Cont mued)
BDA1
reference
no.

214.
32.
33 .
226.
34.
229.
35.
37.
36. •
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
231.

50.
215.
216.
217.

51.
52.
53.
54.
55.
56.
57.
56.
59.
216.
60.
Const ituent
Volflt i les
Ethylene oxide
loclomethdne
isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl kelone
Methyl met rue ry Kite
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyridine
1,1,1 ,2-Tetrachloroethane
1,1.2,2-Tetrachloroethane
Tetrachloroethene
Toluene
Tribromomethane
1. 1,1-Trichloroethane
1 . 1 ,2-Trichloroethdne
Trichloroethene
Trichloromonof luorome thane
1 ,2,3-Tnchloropropane
l,l,2-Trichloro-l,2.2-
trif luoroethane
Vinyl chloride
1.2-Xylene
1.3-Xylene
1 ,4-Xy lene
Semivolat i les
Acenaphthalene
Acenaphthene
Acetophenone
2-Acety laminof luorene
4-Aminobipheny 1
Aniline
Anthracene
Aram He
Benz(a)anthracene
Benzal chloride
Benzenethiol
CAS no.

75-21-6
74-86-4
78-S3-1
67-56-1
7B-93-3
. 108-10-1
80-62-6
126-96-7
75-09-2
79-46-9
110-86-1
630-20-6
79-34-6
127-18-4
108-88-3
75-25-2
71-55-6
79-00-5
79-01-6
75-69-4
96-16-4
76-13-1

75-01-4
97-47-6
10b-3B-3
106-44-5

208-96-6
83-32-9
96-B6-2
53-96-3
92-67-1
62-53-3
120-12-7
140-57-8
56-55-3
96-87-3
108-96-5
Detection limit (ina/kq)
Untreated Ar,h
waste residual

NA
0.0465
1.0
HA
0.0225
NA
0.5
1.15
0.008
NA
0.5
0.018
0.115
0.017
0.012
0.0135
0.013
0.0115
0.0125
0.0295
0.0365
NA

0.0395
NA
NA
NA

0.99
0.495
1.254
1.396
0.429
1.96
0.363
1.023
0.264
NA
69.3
                                 C-17

-------
Toble C-3  (Continued)
BOAT
reference
no.

61.
62.
63.
ti4.
65.
66.
67.
65.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
BO.
61.
32.
232.
Bo.
84.
85.
66.
67.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
96.
99.
Constituent
iemivolat i les (continued)
Deleted
Benzo(a)pyrene
Benzol b)f luoranthene
Benzo(ghi )pery lene
Benzo(k)f luoranthene
p-Benzoqumone
Bis(2-chloroethoxy) me thane
B is (2-chloroethy 1 (ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthdlate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-8uty 1-4 , 6-d in i tropheno 1
p-Chloroani 1 ine
Chlorobenz \late
p-Chloro-m-cresol
2-Chloronaphtha lene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortho-Cresol
para-Cresol
Cyclohexanone
D i benz( a, h) anthracene
Oibenzo(a,e)pyrene
Dibenzo(a. i Ipyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3,3'-Dichlorobenz id ine
2.4-Dichlorophenol
2,6-Dichlorophenol
Diethyl phthdlate
3,3'-Oimethoxybenzidine
p- Dimethyl am inoazobenzene
3,3'-Dimethy Ibenz id me
2, 4 -Dimethyl phenol
Dimethyl phthalate
Di-n-butyl phthalate
1 ,4-Dmitrobenzene
CAi no.


50-32-8
205-99-2
191-24-2
207-08-9
106-51-4
111-91-1
111-44-4
39636-32-9
117-81-7
101-55-3
85-6B-7
86-65-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
542-76-7
218-01-9
95-48-7
106-44-5
106-94-1
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
106-46-7
91-94-1
120-63-2
87-65-0
84-66-2
119-90-4
60-11-7
119-93-7
105-67-9
131-11-3
64-74-2
100-25-4
Detection limit (mci/kt|)
Untreated Ash
wai.tfr.a residual


1.155
1.271
0.759
0.479
6.105
0.196
0.677
0.625
0.924
0.675
1.056
1.733
0.825
0.957
1.615
0.4S5
0.611
1.650
0.792
0.809
0.609
Nn
1.353
1 . 236
1.485
0.545
0.545
0.545
1.815
0.561
0.743
0.429
29.7
2.475
4.125
0.165
0.677
1.452
0.625
    C-18

-------
2206g
                               Tdlile C-3  (Com inued)
bDAI
reterence
no.

100.
101.
102.
103.
104.
105.
106. /219

107.
lOb.
109.
110.
111.
112.
113.
114.
115.
116.
117.
US.
119.
120.

36.
121.
122.
123.
124.
125.
12o.
127.
126.
129.
130.
131.
132.
133.
134.
135.
Constituent
Semivol.it t )er. (continued)
4.6-Dinitro-o-cresol
2.4-Dinitrophenol
2,4-Dinit rotoluene
2,6-Dmitrotoluene
Di-n-octyl phthalate
Di-n-propy In i trotiOiinne
D ipheny lamine/'
Diphenylnitrosamme
1 ,2-Diphenylhydrazine
F luoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutacliene
Hexachlorocyc lopentadiene
Hexachloroethane
Hexachlorophene
Hexachloropropene
lndeno(l , 2 ,3-cd)pyrene
Isosaf role
Methapyri lene
3-Methylcholanthrene
4 ,4 '-Methy leneLns
(2-chloroani 1 me)
Methyl methanesulfonate
Naphthalene
1 ,4-Ndphthoqu inone
1 -Napht hy lamine
2-Naphthylamine
p-Nitroani 1 me
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-buty lamine
N-Nitrosodiethylamme
N-Nitrosodime thy lamine
N-Nitrosomethy let hy lamine
N -Nitrosomorpholine
N-Nitroso'piperidme
n-Nitrosopyrrol idine
5-Nitro-o-toluidine
CAS no.

534-52-1
51-2B-5
121-14-2
606-20-2
117-S4-0
621-64-7
122-39-4/
86-30-6
122-66-7
206-44-0
ef.-73-7
116-74-1
67-GB-3
77-47-4
67-72-1
70-30-4
1S8B-71-7
193-39-5
120-56-1
91-60-5
56-49-5

101-14-4
66-27-3
91-20-3
130-15-4
134-32-7
91-59-6
100-01-6
9B-95-3
100-02-7
924-16-3
55-16-5
62-75-9
10595-95-6
59-89-2
100-75-4
930-55-2
99-65-8
Deter.t ion 1 unit (mq/kti)
Unt recited Ash
waste0 residual5

0.446
0.512
2.792
-
0.924
0.627

0.875
.1.139
0.990
0.512
1.122
0.512
C.479
0.264
-
2.310
0.974
0.726
3.795
2.145

1 1 . 55
-
0.162
0.165
1 1 . 88
16.5
1.37
O.lb2
1.106
1.98
0.33
2.B05
0.61
0.281
0.06
0.495
1.502
                                    C-19

-------
2206a
                                Talile C-?.  (Tout inuecl)
BOAT
reference
no.

136.
137
136.
139.
140.
141.
142.
220.
143.
144.
145.
14C.
147.
14tt.
149.
ISO.
151.
152.
153.


154.
155.
156.
157.
15S.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.
Const ituent
Semivolat 1 les (continued)
Pentachlorobenzene
Pen tachlo roe thane
Pent ach loron i 1 robenzene
Pentachlorophenol
Phenacet in
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcmol
Safrole
1 ,2,4,5-Tetrachlorobenzene
2.3.4,6-Tetrachlorophenol
1 ,2,4-Tr ichlorobenzene
2,4,5-Trichlorophenol
2,4 , 6-Trichlorophenol
Tris(2.3-dibromopropyl )
phosphate
Metals
Ant imony
Arsenic
Barium
Beryll ium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
ii Iver
Thai 1 ium
Vanadium
Zinc
CAS no.

60B-93-5
76-01-7
62-68-6
87-66-5
62-44-2
85-01-6
108-95-2
65-44-9
109-06-B
23950-58-5
129-00-0
106-46-3
94-59-7
95-94-3
56-90-2
120-62-1
95-95-4
88-06-2

126-72-7

7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-32
-
7440-50-6
7439-92-1
7439-97-6
7440-02-0
7782-49-2
7440-22-4
7440-26-0
7440-62-2
7440-66-6
Detect ion 1 mnt (mq'kcj)
Untreated Ash
waste residual

1.551
0.364
1 . 56s
0.611
1.551
O.S25
0.627
NA
6.105
3.795
0.759
12.705
0.792
1.056
0.512
0.314
0.363
0.545

15.51

15
15
1
0.5
2.5
5
NA
5
15
1
10
30
2.5
15
C
2.5
                                     C-20

-------
2?06a
                             Table C-3  (Cont mued)
BOAT
reference
no.










169.
170.
171.

172.
173.
174.
175.
17C.
177.
173.
175.
ISO.
Ibl.
182.
183.
184.
las.
186.
187.
108.
189.
190.
191.
Constituent
Metals TCIPC
Arsenic
Ba r i urn
Cadmium
Chromium
Lead
Mercury
Selenium
Si Iver
Inorganics
Cyanide
Fluoride
Sulf ide
Orqanochlor \ne nesticirter.
Aldrin
dlpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chlorcldne
ODD
DOE
DDT
Dieldr in
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxychlor
Toxaphene
CAS no.










57-12-5
16964-46-8
b49C-25-6

309-00-2
319-S4-6
319-65-7
319-36-8
56-69-9
57-74-9
72-54-8
72-55-9
50-29-3
60-57-1
939-98-8
33213-6-5
72-20-6
7421-93-4
76-44-8
1024-57-3
465-73-G
143-50-0
72-43-5
8001-35-2
Detection limit (mq/kq)
Untreated Ash
wasted residual '

0.15
0.01
0.025
0.025
0.15
0.005
0.3
0.025

2.5

-

0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.4
0.6
0.4
0.4
0.4
0.4
0.4
0.4
                                 C-21

-------
2206g
                                Table C- :,   (Cont inued)
BOAT
reference
no.

192.
193.
194.

195.
196.
197.
198.
199.

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

207.
20S.
209.
210.
211.
212.
213.

Constituent
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxydcet ic acid
Si Ivex
2,4,5-T
Orqanonhosnhorour, insect icicles
Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1246
Aroclor 1254
Aroclor 1260
Diovins and furans
Hexachlorodibenzo-p-diox ins
Hexachlorodibenzof urans
Pentachlorodibenzo-p-dioxins
Pentachlorodtbenzof urans
Tetrachlorodibenzo-p-diox ins
Tetrachlorodibenzof urans
2.3.7,6-Tetrachlorodibenzo-p-
dioxin
CAS no.

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

298-04-4
52-65-7
296-00-0
56-36-2
296-02-2

12674-11-2
11104-26-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-62-5








1746-01-6
Detection limit (mq/kq)
Untreated Ash
wastea residual13

0.01
0.01
0.01

0.05
0.05
0.5
0.05
0.05

0.4
0.4
0.4
0.4
0.4
0.4
0.4

0.000053
0.000036
0.000052
0.000049
0.000062
0.000062

0.00012
NA = Not analyzed.
  - = No detection  limit specified.
Detection limit studies,  have  not  been  completed.
 Detection  limits for the untreated waste are RCRA Confidential Business
 Information  (CBI).
 Six ash samples were analyzed for volatile organics.  The detection limits
 listed nre applicable for five of the six samples.  For one sample, the detection
 limits are five times higher.
c = Units are mg/1.
                                     C-22

-------
                                APPENDIX D
              METHOD OF MEASUREMENT  FOR THERMAL CONDUCTIVITY

    The comparative method of measuring thermal conductivity has been
proposed as an ASTM test method under the name "Guarded,  Comparative,
Longitudinal Heat Flow Technique."  A thermal heat flow circuit is used
that is the analog of an electrical circuit with resistances in series.
A reference material is chosen to have a thermal conductivity close to
that estimated for the sample.  Reference standards (also known as heat
meters) having the same cross-sectional dimensions as the sample are
placed above and below the sample.  An upper heater, a lower heater, and
a heat sink are added to the "stack" to complete the heat flow circuit.
See Figure D-l.
    The temperature gradients (analogous to potential differences) along
the stack are measured with type K (chromel/alumel) thermocouples placed
at known separations.  The thermocouples are placed into holes or grooves
in the references and also in the sample whenever the sample is thick
enough to accommodate them.
    For molten samples, pastes, greases, and other materials that must be
contained, the material is placed in a cell consisting of a top and
bottom of Pyrex 7740 and a containment ring of marinite.  The sample is
2 inches in diameter and 0.5 inch thick.  Thermocouples are not placed
into the sample; rather, the temperatures measured in the Pyrex are
extrapolated to give the temperature at the top and bottom surfaces of
the sample material.  The Pyrex disks  also serve as the thermal
conductivity reference material.
                                    D-l

-------
  GUARD
GRADIENTX
   STACK
GRADIENT
           THERMOCOUPLE
                                    CLAMP
                        UPPER STACK
                           HEATER
                            TOP
                         REFERENCE
                           SAMPLE
                           BOTTOM
                         REFERENCE
                           SAMPLE
                        LOWER STACK
                           HEATER
                        LIQUID COOLED
                          HEAT SINK
                              l
                                        HEAT FLOW
                                         DIRECTION
                                               •-•L
                                                         UPPER
                                                         GUARD
                                                         HEATER
                                                           LOWER
                                                           GUARD
                                                           HEATER
FIGURE D-l    SCHEMATIC DIAGRAM OF THE COMPARATIVE METHOD
                            D-2

-------
    The stack is clamped with a reproducible load to ensure intimate
contact between the components.  To produce a linear flow of heat down
the stack and reduce the amount of heat that flows radially, a guard tube
is placed around the stack, and the intervening space is filled with
insulating grains or powder.  The temperature gradient in the guard is
matched to that in the stack to further reduce radial heat flow.
    The comparative method is a steady state method of measuring thermal
conductivity.  When equilibrium is reached, the heat flux (analogous to
current flow) down the stack can be determined from the references.  The
heat into the sample is given by
                           Q    = A (dT/dx)
                            in     top     top
and the heat.out of the sample is given by
                           Q    = A    (dT/dx)
                            out    bottom     bottom
where
                          A =  thermal  conductivity
                        dT/dx  = temperature gradient
and top refers to the upper reference while bottom refers to the lower
reference.   If the heat were confined to flow down the stack, then Q
                                                                    in
and Q    would be equal.   If Q.  and Q     are in  reasonable
     out                       in      out
agreement, the average heat flow is calculated from
                           Q    = (Q   + Q   )/2.
                                    in     out
The sample thermal conductivity is then found from
                         A     = Q/(dT/dx)
                           sample         sample.
                                    D-3

-------