EPA/530-SW-88-031I
FINAL
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
BACKGROUND DOCUMENT FOR
K037
James R. Berlow, Chief
Treatment Technology Section
Lisa Jones
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
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 Selected for
Regulation 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 2-4
3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
3.1 Applicable Treatment Technologies 3-1
3.2 Demonstrated Treatment Technologies 3-2
3.2.1 Incineration 3-3
4. PERFORMANCE DATA BASE 4-1
5. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
FOR K037 5-1
5.1 Nonwastewaters 5-1
5.2 Wastewaters 5-3
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TABLE OF CONTENTS (Continued)
Page
6. SELECTION OF REGULATED CONSTITUENTS 6-1
6.1 Identification of Constituents in the Untreated Waste 6-1
6.2 Comparison of Untreated and Treated Waste Data for the
Major Constituents 6-9
6.3 Selection of Regulated Constituents 6-11
7. CALCULATION OF BOAT TREATMENT STANDARD 7-1
8. ACKNOWLEDGMENTS 8-1
9. REFERENCES 9-1
APPENDIX A STATISTICAL METHODS A-1
APPENDIX B ANALYTICAL QA/QC B-l
APPENDIX C DETECTION LIMITS FOR K037 UNTREATED AND TREATED
SAMPLES C-l
APPENDIX D METHOD OF MEASUREMENT FOR THERMAL CONDUCTIVITY D-l
m
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LIST OF TABLES
Table
1-1
2-1
2-2
4-1
4-2
4-3
4-4
4-5
4-6
6-1
6-2
7-1
A-l
B-l
B-2
B-3
C-l
BOAT Constituent List
Constituent Analysis of Untreated K037 Waste
BOAT List Constituent Concentration and Other Data
Rotary Kiln Incineration/EPA Collected Data:
Sample Set #1
Rotary Kiln Incineration/EPA Collected Data:
Sampl e Set #2
Rotary Kiln Incineration/EPA Collected Data:
Sampl e Set #3
Rotary Kiln Incineration/EPA Collected Data:
Sampl e Set #4
Rotary Kiln Incineration/EPA Collected Data:
Sampl e Set #5
Rotary Kiln Incineration/EPA Collected Data:
Sampl e Set #6
Status of BOAT List Constituent Presence in Untreated
K037 Waste
BOAT List Constituents and Their Concentrations in
Untreated Waste and Treatment Residues
Regulated Constituents and Calculated Treatment Standards
for K037
95th Percentile Values for the F Distribution
Analytical Methods for Regulated Constituents
Matrix Spike Recoveries for K037 Treated Solids-
EPA-Collected Data
Matrix Spike Recoveries for K037 Scrubber Waste
Sample--EPA-Collected Data
Detection Limits for K037 Waste and Treatment Residuals .
Page
1-18
2-5
2-6
4-2
4-3
4-4
4-5
4-6
4-7
6-2
6-10
7-2
A-2
B-2
B-3
B-4
C-2
IV
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LIST OF FIGURES
Figure Page
2-1 Production and Waste Schematic for Disulfoton 2-2
3-1 Liquid Injection Incinerator 3-7
3-2 Rotary Kiln Incinerator 3-8
3-3 Fluidized Bed Incinerator 3-10
3-4 Fixed Hearth Incinerator 3-11
D-l Schematic Diagram of the Comparative Method D-2
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EXECUTIVE SUMMARY
BOAT Treatment Standards for K037
Pursuant to section 3004(m) of the Resource Conservation and Recovery Act
as enacted by the Hazardous and Solid Waste Amendments 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 K037. 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 these treatment standards is August 8, 1988.
This background document provides the Agency's rationale and
technical support for selecting the constituents to be regulated in K037
waste and for developing treatment standards for those regulated
constituents. The document also provides waste characterization and
treatment information that serves as a basis for determining whether
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 wastes upon which the BOAT treatment standards are
based.
The introductory section of this document (Section 1), which appears
verbatim in all the First Third background documents, summarizes the
Agency's legal authority and promulgated methodology for establishing
treatment standards and discusses the petition process necessary for
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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 K037 waste,
the waste-generating process, 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.
Waste code K037 is listed as "wastewater treatment sludge from the
production of disulfoton." The Agency is aware of only one facility that
generates waste identified as K037.
The Agency is regulating two organic constituents in the wastewater
and nonwastewater forms of K037. (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
(TOC). Waste not meeting this definition must comply with the treatment
standards for nonwastewaters.) The treatment standards for the organic
constituents in both wastewater and nonwastewater forms of K037 are based
on performance data from rotary kiln incineration.
* 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 Editon.
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The following table presents the specific BOAT treatment standards
for K037 wastewater and nonwastewater. The treatment standards for both
wastewater and nonwastewater reflect the total constituent
concentration. The units for the total constituent concentration are
mg/kg (parts per million on a weight-by-weight basis) for the
nonwastewater and mg/1 (parts per million on a weight-by-volume basis)
for wastewater. If the concentrations of the regulated constituents in
K037, as generated, are lower than or equal to the BOAT treatment
standards, then treatment is not necessary as a prerequisite 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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BOAT Treatment Standards for K037
Maximum for any single grab sample
Nonwastewater Wastewater
Constituent Total TCLP leachate Total
concentration concentration concentration
(mg/kg) (mg/1) (mg/1)
Volatile Organics
Toluene 28 NA 0.028
Organophosphorous Insecticides
Disulfoton 0.1 NA 0.003
NA = Not applicable.
IX
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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 tech logy 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 disposal facilities
(TSDFs); and (4) EPA in-house treatment. This hierarchy is based on two
concepts: (1) to the extent possible, EPA should develop treatment
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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
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ensure that the necessary sampling points can be accessed to determine
operating parameters and treatment effectiveness. During the visit, EPA
also confirms that the facility appears to be well operated, although the
actual operation of the treatment system during sampling is the basis for
EPA's decisions regarding proper operation of the treatment unit. In
general, the Agency considers a well-designed facility to be one that
contains the unit operations necessary to treat the various hazardous
constituents of the waste, as well as to control other nonhazardous
materials in the waste that may affect treatment performance.
In addition to ensuring that a system is reasonably well designed,
the engineering visit examines whether the facility has a way to measure
the operating parameters that affect performance of the treatment system
during the waste treatment period. For example, EPA may choose not to
sample a treatment system that operates in a continuous mode, for which
an important operating parameter cannot be continuously recorded. In
such systems, instrumentation is important in determining whether the
treatment system is operating at design values during the waste treatment
period.
(3) Sampling and analysis plan. If after the engineering site visit
the Agency decides to sample a particular plant, the Agency will then
develop a site-specific sampling and analysis plan (SAP) according to the
Generic Quality Assurance Project Plan for the Land Disposal 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
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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.
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(Note: Facilities wishing to submit data for consideration in the
development of BOAT standards should, to the extent possible, provide
sampling information similar to that acquired by EPA. Such facilities
should review the Generic Quality Assurance Project Plan for the Land
Disposal Restrictions Program ("BOAT"), which delineates all of the
quality control and quality assurance measures associated with sampling
and analysis. Quality assurance and quality control procedures are
summarized in Section 1.2.6 of this document.)
(4) Sampling visit. The purpose of the sampling visit is to collect
samples that characterize the performance of the treatment system and to
document the operating conditions that existed during the waste treatment
period. At a minimum, the Agency attempts to collect sufficient samples
of the untreated waste and solid and liquid treatment residuals so that
variability in the treatment process can be accounted for in the
development of the treatment standards. To the extent practicable, and
within safety constraints, EPA or its contractors collect all samples and
ensure that chain-of-custody procedures are conducted so that the
integrity of the data is maintained.
In general, the samples collected during the sampling visit will have
already been specified in the SAP. In some instances, however, EPA will
not be able to collect all planned samples because of changes in the
facility operation or plant upsets; EPA will explain any such deviations
from the SAP in its follow-up onsite engineering report.
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(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 information contained in the report as
confidential. Following the review and incorporation of comments, as
appropriate, the report is made available to the public with the
exception of any material claimed as confidential.
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
-------
1521g
Table 1-1 BOAT Constituent List
BOAT
reference
no.
222.
1.
2.
3.
4.
5.
6.
223.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224.
225.
226.
30.
227.
31.
214.
32.
33.
228.
34.
Constituent
Volatile orqanics
Acetone
Acetonitri le
Aero le in
Aery Ion itrile
Benzene
Branodich loromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachlor ide
Carbon disulfide
Chlorobenzene
2-Chloro-1.3-butadiene
Chlorod ibromome thane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Ch loromethane
3-Ch loropropene
1.2-Oibrcmo-3-chloropropane
1.2-Dibromoethane
Oibrononethane
trans-l,4-Dichloro-2-butene
Dichlorodif luorocnethane
1. 1-Oichloroethane
1.2-Dichloroethane
1 , 1 -D ich loroethy lene
trans-1.2-Dichloroethene
1,2-Dichloropropane
trans-1 ,3-Dichloropropene
c is- 1, 3-D ich loropropene
1.4-Oioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
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
74-95-3
110-57-6
75-71-8
75-34-3
107-06-2
75-35-4
156-60-5
78-87-5
10061-02-6
10061-01-5
123-91-1
110-80-5
141-78-6
100-41-4
107-12-0
60-29-7
97-63-2
75-21-8
74-88-4
78-83-1
67-56-1
78-93-3
1-18
-------
Ib21g
Table 1-1 (Continued)
BOAT
reference
no.
229.
35.
37.
3tt.
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)
Hethyl isobutyl ketone
Methyl methacrylate
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyridine
1.1. 1 ,2-Tetrachloroethane
1.1.2,2-Tetrachloroethane
Tetrach loroethene
Toluene
Tnbromomethane
1 , 1,1-Trichloroethane
1 , 1 ,2-Trichloroethane
Trich loroethene
Trichloromonof luoromethane
1 ,2.3-Fr ichloropropane
l.l,2-Trich(oro-1.2.2-trif luoro-
ethane
Vinyl chloride
1.2-Xylene
1.3-Xylene
1.4 Xylene
Semivolat i le organ ics
Acenaphtha lene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Aniline
Anthracene
Aramite
Benz ( a ) anthracene
Benzal chloride
Benienethiol
Deleted
Benzo(a)pyrene
Benzo( b ) f 1 uoranthene
Benzo( gh i )pery lene
Benzo(k ) f luoranthcne
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
-------
1521g
Table l-l (Continued)
BOA!
reference
no.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
11.
78.
79.
80.
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
Semivolatile organ ics (continued)
Bis(2-chloroethoxy)methane
Bis(2-chloroethy1)ether
Bis(2-chloroisopropy IJether
Bis(2-ethylhexyl)phthalate
4 Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroani 1 ine
Chlorobenzilate
p-Chloro-m-cresol
2-Chloronaphtha lene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortho-Cresol
para-Creso)
Cyc lohexanone
0 i benz ( a. h) anthracene
0 i benzo( a , e ) py rene
Dibenzo(a, Opyrene
m-Oichlorobenzene
o-Oichlorobenzene
p-0 ich lorobenzene
3.3' -Dichlorobcn/ id ine
2,4-Oichlorophenol
2,6-Oichlorophenol
Oiethyl phthalate
3,3'-Dimethoxybeni idine
p Dime thy lam inoazobenzene
3.3'-Oimethy)benz idine
2,4-Oimethylphenol
Dimethyl phthalate
Oi-n-butyl phthalate
1 ,4-Dinitrobenzene
4.6-Oinitro-o-cresol
2.4-Oinitrophenol
2,4-Dinitrotoluene
2.6-Dinitrotoluene
Oi-n-octyl phthalate
Di-n-propy In itrosamine
Oiphenylamine
Oipheny In itrosamine
CAS no.
111-91-1
111-44-4
39638-32-9
117-81-7
101-55-3
85-68-7
88-85-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
542-76-7
218-01-9
95-48-7
106-44-5
108-94 1
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
106-46-7
91-94-1
120-83-2
87-65-0
84-66-2
119-90-4
60-11-7
119-93-7
105-67-9
131-11-3
84-74-2
100-25-4
534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
621-64-7
122-39-4
86-30-6
1-20
-------
1521g
Table 1-1 (Continued)
BOAT
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
Semi volatile organ ics (continued)
1 . 2 - 0 i pheny Ihydraz i ne
F luoranthene
F luorene
Hexach lorobenzene
Hexachlorobutadiene
Hexac h 1 o roc yc 1 open t ad i ene
Hexach loroethane
Hexach lorophene
Hexach loropropene
Indeno( 1 , 2 , 3-cd ) pyrene
Isosafrole
Hethapyri lene
3-Methylcholanthrene
4,4'-Hethylenebis
(2-chloroani 1 ine)
Methyl methanesulfonate
Naphthalene
1 . 4-Naphthoqu i none
1-Naphthylamine
2-Naphthylamine
p-Nitroani 1 me
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-N i trosomethy lethy lam i ne
N-Nitrosomorpholine
N-Nitrosopiperidine
N-Nitrosopyrrolidine
5-Nitro-o-toluidine
Pentach lorobenzene
Pentach loroethane
Pentach loron i t robenzene
Pentach loropheno 1
Phenacetin
Phenanthrene
Phenol
Phlhalic 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
134-32-7
91-59-8
100-01-6
98-95-3
100-02-7
924-16-3
55-18-5
62-75-9
10595-95-6
59-89-2
100-75-4
930-55-2
99-65-8
608-93-5
76-01-7
82-68-8
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
-------
1521g
Table 1-1 (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 le organ ics (continued)
Safrole
1,2.4,5- Tet rach lorobenzene
2 . 3 , 4 , 6- Tet rach loropheno 1
1 , 2 . 4-Tr ich lorobenzene
2. 4, 5-Trich loropheno 1
2 . 4 , 6-Tr ich loropheno 1
Tris(2,3-dibromopropyl)
phosphate
Metals
Antimony
Arsenic
Barium
Beryl 1 ium
Cadmium
Chromium (total)
Chromium (hexavalenl)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thai lium
Vanadium
Zinc
Inorganics other than metals
Cyan ide
fluoride
Sulfide
Orqanochlorine pesticides
Aldrin
a Ipha-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
-------
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)
gamna-BHC
Ch lordane
ODD
DOE
DOT
Oieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxyacetic acid
Silvex
2.4.5-T
OrqanoDhosDhorous 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
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
1-23
-------
1521g
Table 1-1 (Continued)
BOAT
reference Constituent CAS no.
no.
Dioxins and furans
207. Hexachlorodibenzo-p-dioxins
208. Hexachlorodibenzofurans
209. Pentachlorodibenzo-p-dioxins
210. Pentachlorodibenzofurans
211. Tetrachlorodibenzo-p-dioxins
212. Tetrachlorodibenzofurans
213. 2.3.7.8-Tetrachlorodibenzo-p-dioxin 1746-01-6
1-24
-------
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 Pro.iect 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
-------
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
-------
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.
1-28
-------
(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 tne 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
-------
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
-------
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 believes that
it is important that any remaining metal in a treated residual waste not
be in a state that is easily Teachable; accordingly, EPA is also using
the TCLP extract concentration as a measure of performance. It is
important to note that for wastes for which treatment standards are based
1-31
-------
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 "echnology 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
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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:
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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
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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
(1) Wastes from treatment trains generating multiple residues. In a
number of instances, the proposed BOAT consists of a series of
operations, each of which generates a waste residue. For example, the
proposed BOAT for a certain waste code is based on solvent extraction,
steam stripping, and activated carbon adsorption. Each of these
treatment steps generates a waste requiring treatment — a
solvent-containing stream from solvent extraction, a stripper overhead,
and spent activated carbon. Treatment of these wastes may generate
further residues; for instance, spent activated carbon (if not
regenerated) could be incinerated, generating an ash and possibly a
scrubber water waste. Ultimately, additional wastes are generated that
may require land disposal. With respect to these wastes, the Agency
wishes to emphasize the following points:
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.
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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.
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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
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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
The purpose of this section is to provide~a complete characterization
of the K037 listed waste by describing the industry that generates the
waste, the process that generates the waste, and the data that
characterize the waste. According to 40 CFR Part 261.32 (hazardous
wastes from specific sources), the waste identified as K037 is
specifically generated by the manufacturers of disulfoton and is listed
as follows:
K037 - Wastewater treatment sludge from the production of disulfoton.
2.1 Industry Affected and Process Description
Only one facility in the United States is known to produce
disulfoton. It is located in EPA Region VII, in the State of Missouri.
The disulfoton production process consists of three basic steps:
(1) the formation of diethyl salt (DES), (2) the formation of chlorothio
alcohol (CTA), and (3) the reaction of DES and CTA to form disulfoton. A
flow diagram for the disulfoton production process is presented in
Figure 2-1.
In the first step of the process, diethyl phosphorodithioic acid is
formed in the DES unit from the reaction of PS and ethanol in
toluene. The major side product of this reaction is the
0,0,0-triethylester of the phosphorodithioic acid. The diethyl
phosphorodithioic acid is next reacted in the same vessel with caustic
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RECOVERED TOLUENE
MAKEUP
TOLUENE
SOLVENT
ETHANOL
PoS,
DES
UNIT
CRUDE
DES
TOLUENE
RECOVERY
UNIT
NaOH
ro
ro
PCI
E
THIO ALCOHOL
CTA
UNIT
CTA
DES
DISYSTON
UNIT
WASTEWATER
PROCESS
WATER
DISYSTON
SOLVENT
RECOVERY
UNIT
WASTE-
WATER
TREATMENT
DISULFOTON
- PRODUCT
WASTEWATER
WASTEWATER
TREATMENT SLUDGE—K037
Figure 2-1 Production and Waste Schematic for Disulfoton
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soda to form DES. The overall reaction for both subreactions is as
follows:
Toluene
P2S5 + 4C2H5OH + ZNaOH ----> 2(C2H50)2P(S)SNa + H2$ + 2H20.
Ethanol DES
The DES is then separated from the reaction mix, which is sent to a
toluene recovery unit. The recovered toluene is recycled back to the DES
unit.
The second step of the disulfoton production process takes place in
the CTA unit, where PCI and thio-alcohol are reacted to form CTA as
follows:
PC13 + 3HOC2H4-S-C2H5 ---> 3C1C2H4-S-C2H5 + H3P03.
In the final step of the process, DES and CTA are reacted in the
disyston unit to form disulfoton and sodium chloride:
(C2H50)2P(S)SNa + C1C2H4-S-C2H5 ---> (C2H50)2P(S)-S-C2H4-S-C2H5 + NaCl
Process water from the disyston unit is sent, along with wastewater
from the toluene recovery unit, to the disyston solvent recovery unit,
where disulfoton is recovered and recycled to the disyston unit.
Wastewater from the disyston solvent recovery unit is circulated to
wastewater treatment. The sludges generated from wastewater treatment
are the waste stream K037.
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2.2 Waste Characterization
This section includes all waste characterization data available to
the Agency for K037 waste. The approximate percent concentrations of the
major constituents composing K037 waste are listed in Table 2-1. The
percent concentration in the waste was determined from engineering
judgment based on analytical data and plant information. The ranges of
BOAT list constituents present in the waste and all other available
parameters affecting treatment selection data are presented in Table 2-2.
The data show a waste with high concentrations of solids (75 percent),
low concentrations of water (less than 5 percent), approximately
20 percent disulfoton, 0.2 percent toluene, and less than 0.1 percent
other BOAT list constituents. According to the data, no BOAT list
inorganics other than metals, BOAT list organochlorine pesticides, BOAT
list phenoxyacetic acid herbicides, PCBs, or dioxins and furans should be
present in K037 wastes.
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1485g/p.l3
Table 2-1 Constituent Analysis of Untreated K037 Waste •
Constituent Concentration (wt. %)
Oisulfoton
Toluene
Water
Solids (filter paper and diatomaceous earth filter aid)
Other BOAT list constituents
Total 100 I-.
References:
1. USEPA 1987a. Onsite Engineering Report for K037.
2. Personal communication with J. J. Lonsinger, Environmental Control
Manager, Mobay Corporation. Agricultural Chemicals Division,
February 9, 1987.
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1485g/p.2
Table 2-2 BOAT List Constituent Concentration and Other Data
BOAT
reference
no.
BOAT list constituent
Untreated K037 waste concentration (mg/kg)
(11 (21
Volati1e Orqanics
43 Toluene
Semivolatile Orqanics
70 bis(2-ethylhexyl) phthalate
Metals
155
156
158
159
160
161
163
167
168
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Nickel
Vanadium
Zinc
Orqanophosphorous Insecticides
195 Disulfoton
Other Parameters
Solids (filter paper and
diatomaceous earth
filter aid)
Water
201-2.000
<250-500
<2.0-3.1
18-39
3.3-10
43-93
7.0-24
5.6-28
46-130
7-10
89-190
104,000-246,000
<25,000
0-100,000
<750,000
125,000-225,000
References:
1. USEPA 1987a. Onsite Engineering Report for K037.
2. Personal communication with J.J. Lonsinger, Environmental Control Manager, Mobay
Corporation, Agricultural Chemicals Division, February 9, 1987.
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3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
This section describes the applicable treatment technologies,
demonstrated treatment technologies, and performance data for the
treatment of K037. Since the waste characterization data in Section 2
reveal untreated K037 wastes containing high BOAT list organic
concentrations and high filterable solids, the technologies considered to
be applicable are those that destroy or remove the various organic
compounds in wastes with high filterable solids.
3.1 Applicable Treatment Technologies
The Agency has identified the following treatment technologies as
being applicable for K037: batch distillation, incineration, and solvent
extraction. Batch distillation can be used to separate components having
widely different boiling points. Incineration technologies destroy the
organic components in the waste feed. Solvent extraction removes organic
constituents from a waste by exploiting the relatively high solubilities
of the waste constituents in a particular solvent.
As stated previously, the Agency has identified these treatment
technologies as applicable for treatment of'K037 because the technologies
are designed to destroy or remove the toxic organics present in untreated
wastes with high filterable solids. The selection of the treatment
technologies applicable for treating BOAT list organics in K037 waste is
based on data submitted by industry, current literature sources, and
field testing.
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3.2 Demonstrated Treatment Technologies
The technologies demonstrated on this waste or on waste with similar
parameters affecting treatment selection (i.e., high organic content, low
water content, and high filterable solids content) are batch distillation
and incineration including rotary kiln incineration and fluidized bed
incineration. The Agency believes that solvent extraction is potentially
applicable to the treatment of K037 waste; however, EPA does not have
data on the characteristics of K037 waste that would allow the Agency to
conclude that solvent extraction is "demonstrated" on similar wastes.
The Agency does not believe that other technologies are applicable
because various physical and chemical characteristics of this waste would
not allow treatment.
EPA believes batch distillation and fluidized bed incineration to be
demonstrated treatment technologies for K037 because both have been used
to treat wastes with similar characteristics. The Agency knows of at
least one facility using batch distillation and one facility using
fluidized bed incineration for treatment of wastes similar to K037.
However, EPA is not aware of any generator or TSD facility currently
using either technology for treatment of wastes containing a large
percentage of K037; nor are there performance data that demonstrate
their effectiveness in treating the BOAT list constituents in K037 waste.
The Agency believes rotary kiln incineration is demonstrated to treat
K037 since it is being used to treat wastes similar to K037 in parameters
affecting treatment selection, including low water content, high organic
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content, and high solids concentration. To help develop treatment
standards, EPA tested rotary kiln incineration to demonstrate the actual
performance achievability. Since the Agency is not aware of any
generator or TSD facilities currently using rotary kiln incineration for
treatment of wastes containing a large percentage of K037, the K037 was
incinerated in EPA's own in-house rotary kiln. Performance data
collected by EPA for incineration of K037 using a rotary kiln incinerator
are shown in Tables 4-1 through 4-6. A detailed discussion of
incineration is presented in Section 3.2.1.
3.2.1. 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,
the 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 this technology.
(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 viscosity values
are reported, with the low being 100 SSU and the high being 10,000 SSU.
It is important to note that viscosity is temperature dependent so that
while liquid injection may not be applicable to a waste at ambient
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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 suspended solids, various viscosity ranges, and-a range of
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
currently practiced.
(2) Underlying principles of operation.
(a) Liquid injection. The basic operating principle of this
incineration technology is that incoming liquid wastes are 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
3-4
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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
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 is somewhat different from that for rotary kiln
and fixed hearth incineration, in that the fluidized bed incinerator
contains fluidizing sand and a freeboard section above the sand. The
purpose of the fluidized bed is to both volatilize the waste and combust
the waste. Destruction of the waste organics can be accomplished to a
better degree in the primary chamber of a fluidized bed incinerator than
in that of a rotary kiln or fixed hearth incinerator 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 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.
3-5
-------
(3) Description of incineration technologies.
(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
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
3-6
-------
WATER
AUXILIARY FUEL
BURNER
LIQUID OR GASEOUS.
WASTE INJECTION
-^BURNER
nri
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
-------
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
3-8
-------
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 ignition 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. 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 HC1 and
3-9
-------
WASTE
INJECTION
ASH
FIGURE 3-3
FLUIDIZED BED INCINERATOR
GAS TO
AIR POLLUTION
CONTROL
MAKE-UP
SAND
AIR
3-10
-------
AIR
GAS TO AIR
POLLUTION
CONTROL
AIR
CO
I
WASTE
INJECTION
BURNER
1
PRIMARY
COMBUSTION
CHAMBER
GRATE
SECONDARY
COMBUSTION
CHAMBER
AUXILIARY
FUEL
2-STAGE FIXED HEARTH
INCINERATOR
ASH
FIGURE 3-4
FIXED HEARTH INCINERATOR
-------
other halo-acids from the combustion gases. Ash in the waste is not
destroyed in the combustion process. Depending on its composition, ash
will either exit as bottom ash, at the discharge end of a kiln or hearth
for example, or as particulate matter (fly ash) suspended in the
combustion gas stream. Particulate emissions from most hazardous waste
combustion systems generally have particle diameters less than one micron
and require high efficiency collection devices to minimize air
emissions. In addition, scrubber systems provide additional buffer
against accidental releases of incompletely destroyed waste products due
to poor combustion efficiency or combustion upsets, such as flame outs.
(4) Waste characteristics affecting performance (WCAP).
(a) Liquid injection. In determining whether liquid injection is
likely to achieve the same level of performance on an untested waste as a
previously tested waste, the Agency will compare 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;
however, in practice this is not always the case. Other energy effects
(e.g., vibrational effects, the formation of intermediates, and
interactions between different molecular bonds) may have a significant
influence on activation energy.
3-12
-------
Because of the shortcomings of bond energies in estimating activation
energy, EPA analyzed other waste characteristic parameters to determine
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 were rejected for 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 tool to predict whether reactions are likely to
proceed; however, there are a significant number of hazardous
constituents for which these data are not available. Use of kinetic data
were rejected because these data are limited and could not be used to
calculate free energy values (&G) 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
3-13
-------
characteristics that affect volatilization of organics from the waste, as
well as destruction of the organics, once volatilized. Relative to
volatilization, EPA will examine thermal conductivity of the entire waste
and 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 of the waste being treated.
Accordingly, the type of waste treated will have a minimal impact on the
amount of heat transferred by radiation. With regard to convection, EPA
also believes that the type of heat transfer will generally be more a
function of the type and design of incinerator than of the waste itself.
However, EPA is examining particle size as a waste characteristic that
3-14
-------
may significantly impact the amount of heat transferred to a waste by
convection and thus impact 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 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 Appendix D). In theory, thermal conductivity
would always provide a good indication of whether a constituent in an
untested waste would be treated to the same extent in the primary
incinerator chamber as the same constituent in a previously tested waste.
In practice, thermal conductivity has some limitations in assessing
the transferability of treatment standards; however, EPA has not
identified a parameter that can provide a better indication of heat
transfer characteristics of a waste. Below is a discussion of both the
limitations associated with thermal conductivity and other parameters
considered.
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
3-15
-------
constituents are essentially the same). As wastes exhibit greater
degrees of nonhomogeneity (e.g., significant concentration of metals in
soil), then thermal conductivity becomes less accurate in predicting
treatability because the measurement essentially reflects heat flow
through regions having the greatest conductivity (i.e., the path of least
resistance) and not heat flow through all parts of the waste.
Btu value, specific heat, and ash content were also considered for
predicting heat transfer characteristics. These parameters can no better
account for nonhomogeneity than 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 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.
(5) Incineration 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
3-16
-------
activation level for breaking molecular bonds and (2) whether sufficient
oxygen is present to convert the waste constituents to carbon dioxide and
water vapor. The specific design parameters that the Agency will
evaluate to assess whether these conditions are met are temperature,
excess oxygen, and residence time. Below is a discussion of why EPA
believes these parameters to be important, as well as a discussion of how
these parameters will be monitored during operation.
»
It is important to point out that, relative to the development of
land disposal restriction standards, EPA is concerned with these design
parameters only 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 only with the waste
characteristics that affect selection of the unit, not the
above-mentioned design parameters.
(i) Temperature. Temperature is important in that it provides an
indirect measure of the energy available (i.e., 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.
The temperature is normally controlled automatically through the use
of instrumentation which senses the temperature and automatically adjusts
the amount of fuel and/or waste being fed. The temperature signal
3-17
-------
transmitted to the controller can be simultaneously transmitted to a
recording device, referred to as a strip chart, and thereby continuously
recorded. To fully assess the operation of the unit, it is important to
know not only the exact location in the incinerator that the temperature
is being monitored but also the location of the design temperature.
(ii) Excess oxygen. It is important that the incinerator contain
oxygen in excess of the stiochiometric amount necessary to convert the
organic compounds to carbon dioxide and water vapor. If insufficient
oxygen is present, then destabilized waste constituents could recombine
to the same or other BOAT list organic compounds and potentially cause
the scrubber water to contain higher concentrations of BOAT list
constituents than would be the case for a well-operated unit.
In practice, the amount of oxygen fed to the incinerator is
controlled by continuous sampling and analysis of the stack gas. If the
amount of oxygen drops below the design value, then the analyzer
transmits a signal to the valve controlling the air supply and thereby
increases the flow of oxygen to the afterburner. The analyzer
simultaneously transmits a signal to a recording device so that the
amount of excess oxygen can be continuously recorded. Again, as with
temperature, it is important to know the location from which the
combustion gas is being sampled.
(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
3-18
-------
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, which include 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. After both the
Btu content and the expected combustion gas volume have been determined,
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.
(b) Rotary kiln. For this incineration, EPA will examine both the
primary and secondary chamber in evaluating the design of a particular
incinerator. Relative to the primary chamber, EPA's assessment of design
will focus on whether sufficient energy is likely to be provided to the
3-19
-------
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 is important, in
that it 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.
Additionally, it is important to know the location of the temperature
sensing device in the kiln.
(ii) Residence time. This parameter is important in that it
affects whether sufficient heat is transferred to a particular
constituent in order for volatilization to occur. As the time that the
waste is in the kiln is increased, a greater quantity of heat is
transferred to the hazardous waste constituents. The residence time will
be a function of the specific configuration of the rotary kiln including
the length and diameter of the kiln, the waste feed rate, and the rate of
rotation.
3-20
-------
(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. However, as
the RPM value increases, 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
two were discussed under rotary kiln and will not be discussed here. The
last, bed pressure differential, is important in that it provides an
indication of the amount of turbulence and therefore indirectly the
amount of heat supplied to the waste. In general, as the pressure drop
increases, both the turbulence and heat supplied increase. The pressure
drop through the bed should be continuously monitored and recorded to
ensure that the design value is achieved.
3-21
-------
(d) Fixed hearth. The design considerations for this incineration
unit are similar to those for a rotary kiln except that rate of rotation
(i.e., RPMs) is not an applicable design parameter. For the primary
chamber of this unit, the parameters that the Agency will examine in
assessing how well the unit is designed are the same as those discussed
under rotary kiln; for the secondary chamber (i.e., afterburner), the
design and operating parameters of concern are the same as those
previously discussed under "Liquid injection."
3-22
-------
4. PERFORMANCE DATA BASE
The Agency collected the six data sets for untreated and treated
wastes to characterize treatment of K037 using a rotary kiln treatment
system. Treatment of K037 resulted in two treatment residuals: ash and
scrubber water. Tables 4-1 through 4-6 present the six data sets of
total waste concentration analyses for K037 waste samples, and the design
and operating data for the treatment system. As shown by the operating
data taken during collection of the samples, all six data sets reflect
treatment by a well-operated system. Furthermore, all the data sets show
treatment of the organic BOAT list constituents detected in the untreated
wastes to nondetected levels in the treatment residuals.
4-1
-------
1485g/p.5
Table 4-1 Rotary Kiln Incineration
EPA Collected Data
Sample Set #1
ANALYTICAL DATA:
BOAT
Reference BOAT list
No. constituent
43 Toluene
70 Bis(2-ethylhexyl)phthalate
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
1559 Chromium
160 Copper
161 Lead
163 Nickel
166 Thallium
167 Vanadium
168 Zinc
195 Disulfoton
Untreated
waste
(mg/kg)
640
<250
3.1
26
<0.5
3.9
70
24
28
130
<2.5
8
190
171,000
Treated
Treated waste Scrubber
waste TCLP water
(mg/kg) (mg/1) (,,g/l)
<10 NA <10
<2.0 NA <50
10 <0.01 0.10
150 <0.045 0.91
0.54 <0.005 <0.005
2.1 <0.015 0.059
80 0.079 0.15
610 3.3 4.7
54 0.029 6.6
110 0.20 0.10
<2.5 <0.015 <0.015
82 0.93 <0.1
290 0.64 16
<0.0335 NA <1.00
DESIGN AND OPERATING DATA:
Ki In Design va lue
Temperature 1832'F
Revolutions per minute 0.2 rpm
Afterburner
Temperature 2200"F
Excess oxygen 6-8%
Carbon monoxide <1000 ppm
Operating value
1778-1816"F
0.2 rpm
2043-2063"F
8%
<1 ppm
NA - Not Applicable.
Reference: USEPA 1987. Onsite Engineering Report for K037.
4-2
-------
1485g/p.6
Table 4-2 Rotary Kiln Incineration
EPA Collected Data
Sample Set #2
ANALYTICAL DATA:
BOAT
Reference BOAT list
No. constituent
43 Toluene
70 Bis(2-ethylhexyl)phthalate
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
163 Nickel
166 Thallium
167 Vanadium
168 Zinc
195 Oisulfoton
Untreated
waste
(mg/kg)
530
<250
2.4
39
<0.5
3.9
73
12
12
90
<2.5
7
89
104.000
Treated
waste
(mg/kg)
<10
<2.0
5.0
140
0.51
<2.0
93
940
66
110
<2.S
80
330
Treated
waste
TCLP
(mg/1)
NA
NA
<0.01
<0.045
<0.005
<0.015
0.22
10
0.013
0.58
<0.015
1.3
0.45
'0.0335 NA
Scrubber
water
(Mg/1)
<10
<50
0.26
0.19
<0.005
0.062
0.21
4.7
11
<0.1
<0.015
-=0.1
4.2
<1.00
DESIGN AND OPERATING DATA:
Kiln Design value
Temperature 1832"F
Revolutions per minute 0.2 rpm
Afterburner
Temperature 2200T
Excess oxygen 6-8%
Carbon monoxide <1000 ppm
Operating
1778-1818
0.2 rpm
2043-2063
8'X
<1 ppm
value
"F
"F
NA - Not Applicable.
Reference: USEPA 1987. Onsite Engineering Report for K037.
4-3
-------
1485g/p.7
Table 4-3 Rotary Kiln Incineration
EPA Collected Data
Sample Set #3
ANALYTICAL DATA:
Treated
BOAT
Reference BOAT list
No. constituent
43 Toluene
70 Bis(2-ethylhexyl)phthalate
155 Arsenic
156 Barium
157 Beryllium
156 Cadmium
159 Chromium
160 Copper
161 Lead
163 Nickel
166 Thallium
167 Vanadium
168 Zinc
195 Disulfoton
Untreated
waste
(mg/kg)
1,300
<250
<2.0
18
<0.5
3.8
43
7.0
5.6
46
<2.5
7
110
246,000
Treated
waste
(mg/kg)
<10
<2.0
25
130
<0.5
<2.0
100
630
25
180
<2.5
61
840
<0.0335
waste Scrubber
TCLP water
(mg/1) Ug/1)
NA <10
NA «50
0.022 0.22
0.049 0.22
<0.005 <0.005
<0.015 0.073
0.13 0.19
1.1 3.9
<0.01 9.6
0.19 '0.1
<0.015 <0.015
0.97 <0.1
0.75 2.7
NA <1.00
DESIGN AND OPERATING DATA:
Ki In Desiqn value
Temperature 1832"F
Revolutions per minute 0.2 rpm
Afterburner
Temperature 2200'F
Excess oxygen 6-8%
Carbon monoxide <1000 ppm
Operating value
1778-1818-F
0.2 rpm
2043-2063T
B-X
<1 ppm
NA - Not Applicable.
Reference: IJSEPA 1987. Onsite Engineering Report for K037.
4-4
-------
1485g/p.8
Table 4-4 Rotary Kiln Incineration
EPA Collected Data
Sample Set #4
ANALYTICAL DATA:
Treated
BOAT
Reference BOAT list
No. constituent
43 Toluene
70 Bis(2-ethylhexyl)phthalate
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
163 Nickel
166 Thallium
167 Vanadium
168 Zinc
195 Oisulfoton
Untreated
waste
(mg/kg)
630
<250
<2.0
28
<0.5
5.3
85
21
22
120
<2.5
9
180
186.000
Treated
waste
(mg/kg)
<10
<2.0
15
150
<0.5
<2.0
110
460
15
160
<2.5
78
620
<0.0335
waste
TCLP
(mg/1)
NA
NA
<0.01
0.075
<0.005
<0.015
0.074
3.0
0.017
0.24
<0.015
1.1
2.7
NA
Scrubber
water
Ug/i)
<10
<50
0.23
0.18
'-0.005
0.063
0.090
4.0
4.0
<0.1
'0.015
<0.1
0.97
<1.00
DESIGN AND OPERATING DATA:
Ki In Desiqn value
Temperature 1832"F
Revolutions per minute 0.2 rpm
Afterburner
Temperature 2200"F
Excess oxygen 6-8%
Carbon monoxide <1000 ppm
Operating value
1830-1897"F
0.2 rpm
2043-2063-F
8%
<1 ppm
NA - Not Applicable.
Reference: USEPA 1987. Onsite Engineering Report for K037.
4-5
-------
1485g/p.9
Table 4:5 Rotary Kiln Incineration
EPA Collected Data
Sample Set #5
ANALYTICAL DATA:
Treated
BOAT
Reference BOAT list
No. constituent
43 Toluene
70 Bis(2-ethylhexyl)phthalate
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
163 Nickel
166 Thallium
167 Vanadium
168 Zinc
195 Disulfoton
Untreated
waste
(mg/kg)
201
<250
<2.0
22
<0.5
3.3
50
15
12
61
<2.5
10
110
181.000
Treated
waste
(mg/kg)
<10
<2.0
5.0
140
<0.5
<2.0
88
380
15
110
<2.5
77
450
<0.0335
waste
TCLP
(mg/ 1 )
NA
NA
<0.01
1.1
<0.005
<0.015
0.26
4.3
0.021
0.41
<0.015
1.3
4.8
NA
Scrubber
water
Ug/D
<10
<50
0.29
0.30
<0.005
0.11
0.13
6.2
6.8
<0.1
0.02
<0.1
1.7
'1.00
DESIGN AND OPERATING DATA:
Ki In Desiqn value
Temperature 1832"F
Revolutions per minute 0.2 rpm
Afterburner
Temperature 2200*F
Excess oxygen 6-8%
Carbon monoxide <1000 ppm
Operating value
1830-1897-F
0.2 rpm
2043-2063"F
8%
<1 ppm
NA - Not Applicable.
Reference: USEPA 1987. Onsite Engineering Report for K037.
4-6
-------
1485g/p.lO
Table 4-6 Rotary Kiln Incineration
EPA Collected Data
Sample Set #6
ANALYTICAL DATA:
Treated
BOAT
Reference BOAT list
No. constituent
43 Toluene
70 Bis(2-ethylhexyl)phthalate
155 Arsenic
156 Barium
157 Beryllium
158 Cadmium
159 Chromium
160 Copper
161 Lead
163 Nickel
166 Thallium
167 Vanadium
168 Zinc
195 Oisulfoton
Untreated
waste
(mg/kg)
2000
500
<2.0
33
<0.5
10
93
16
8.2
120
<2.5
8
120
192,000
Treated
waste '
(mg/kg)
<10
<2.0
20
170
0.71
<2.0
87
240
20
110
<2.5
88
330
<0.0335
waste
TCLP
(mg/1)
NA
NA
'-0.01
0.1
<0.005
<0.015
<0.045
0.15
<0.01
0.59
<0.015
0.25
0.16
NA
Scrubber
water
Ug/l)
<10
<50
0.45
0.39
<0.005
0.16
0.17
6.3
11
0.11
0.02
<0.1
2.3
<1.00
DESIGN AND OPERATING DATA:
Ki In Desiqn value
Temperature 1832'F
Revolutions per minute 0.2 rpm
Afterburner
Temperature 2200*F
Excess oxygen 6-8%
Carbon monoxide <1000 ppm
Operating value
1830-1897-F
0.2 rpm
2043-2063'F
8*
<1 ppm
NA - Not Applicable.
Reference: USEPA 1987. Onsite Engineering Report for K037.
4-7
-------
5. IDENTIFICATION OF BEST DEMONSTRATED
AVAILABLE TECHNOLOGY FOR K037
This section presents the rationale for the determination of best
demonstrated available technology (BOAT) for K037 nonwastewaters and
wastewaters. As discussed in Section 1, the Agency examines all
available data for the technologies that have been demonstrated for a
particular waste to determine whether one of the demonstrated
'technologies performs significantly better than another. Next, the
"best" performing of these technologies is evaluated to determine whether
it is "available," i.e., whether it is' (1) commercially available and
(2) provides "substantial" treatment of the waste.
K037 waste is an organic nonwastewater for the purpose of determining
the applicability of the BOAT treatment standards, since wastewaters are
defined as wastes containing less than 1 percent (weight basis)
filterable solids and less than 1 percent (weight basis) total organic
carbon. However, demonstrated technologies for K037 nonwastewaters
produce both nonwastewater and wastewater residuals. BOAT must therefore
be identified for both types of waste streams.
5.1 Nonwastewaters
The demonstrated technologies for K037 nonwastewaters are batch
distillation and incineration. The only treatment performance data
available to the Agency are for treatment of K037 using rotary kiln
incineration. It is therefore not possible to directly compare
performance achieved by these two demonstrated technologies, or compare
5-1
-------
rotary kiln incineration to other forms of incineration, such as
fluidized bed.
All performance data for K037 incineration were reviewed and assessed
in relation to the design and operating parameters of the facility at the
time of the test; the Agency concluded that the data were developed from
a well-designed and well-operated facility. The quality assurance/
quality control analyses conducted on the data and the analytical tests
used to assess treatment performance were also reviewed and found to be
satisfactory. All available data were therefore used to evaluate BOAT
for this waste stream.
Nevertheless, the Agency has determined that rotary kiln incineration
achieves better treatment of organics in K037 than does batch
distillation. This is because incineration destroys the hazardous
organic components of this waste, whereas batch distillation only
concentrates them into a lower volume residual, which itself may require
incineration. The Agency also concludes that fluidized bed units would
not produce better treatment than rotary kilns because fluidized bed
operating temperatures are lower than rotary kiln temperatures. Rotary
kiln incineration is therefore the best demonstrated treatment technology
for K037 organic nonwastewaters.
Rotary kiln incineration is also a widely available commercial
technology. It achieves substantial treatment, as demonstrated by the
accuracy-adjusted performance data presented in Section 4.
Concentrations of organics (disulfoton) in the untreated waste were
5-2
-------
186,000 mg/kg; concentrations in the treated residual (incinerator ash, a
nonwastewater) were below detection limits. EPA concludes that rotary
kiln incineration is available for K037 organic nonwastewaters and is
therefore the best demonstrated available treatment for K037.
Incineration of K037 does, however, produce incinerator ash, a
nonwastewater residual for which BOAT must also be established. Although
performance data from the test conducted on incineration of K037 in a
rotary kiln indicated the presence of some metals, this waste is listed
as an organics waste only. Performance data for this waste indicate that
organics residuals in the treated waste are below detection limits. The
Agency concludes that no additional treatment of nonwastewater residuals
from incineration of K037 is needed and that incineration is therefore
BOAT for all nonwastewaters associated with the treatment of K037 waste.
5.2 Wastewaters
Treatment of K037 wastes in a rotary kiln incinerator produces one
wastewater treatment stream—scrubber water from the air pollution
control equipment of the incinerator.
Performance tests indicate that concentrations of disulfoton in
scrubber water from K037 incineration are below detection limits. Since
the input waste contains 186,000 mg/kg organics (disulfoton), this
represents substantial treatment for organics in scrubber water. Because
the Agency concludes that no additional treatment of scrubber water would
significantly improve on this performance, rotary kiln incineration is
also BOAT for wastewater residuals from treatment of K037 nonwastewater.
5-3
-------
6. SELECTION OF REGULATED CONSTITUENTS
As discussed in Section 1, the Agency has developed a BOAT list of
hazardous constituents (Table 1-1) from which the constituents to be
regulated are selected. The list is an expanding list that does not
preclude the addition of new constituents as additional key parameters
are identified. The list is divided into the following categories:
volatile organics, semivolatile organics, metals, inorganics other than
metals, pesticides, PCBs, and dioxins and furans.
This section describes the step-by-step process used to select the
pollutants to be regulated. The selected constituents must be present in
the untreated waste and must be treatable by the chosen BOAT, rotary kiln
incineration, as discussed in Section 5. Moreover, the regulated
constituents are those compounds that are significantly reduced, and such
reduction ensures that the recommended BOAT is the most effective
treatment for the K037 waste. Using this definition and the major BOAT
list constituents identified in Section 2, two constituents, toluene and
disulfoton, are selected as the regulated constituents for K037 for which
treatment standards are developed in Section 7 of this report.
6.1 Identification of Constituents in the Untreated Waste
Table 6-1 presents the BOAT list constituents as discussed in
Section 1. The table indicates (1) which of the BOAT list constituents
were analyzed for in the untreated waste and the treated waste and (2) of
those analyzed for, which were detected. Of the 231 BOAT list
constituents, 213 were analyzed for and the only constituents that were
6-1
-------
2169g
Table 6-1 Status of BOAT List Constituent Presence
in Untreated K037 Waste
BOAT
reference
no.
222.
1.
2.
3.
4.
5.
6.
223.
7.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224.
225.
226.
30.
227.
31.
214.
32.
33.
228.
34.
Constituent
Volatile orqanics
Acetone
Acetonitrile
Acrolein
Acrylonitri le
Benzene
Bromodichloromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-l ,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 ,2-Dibromo-3-chloropropane
1 ,2-Dibromoethane
Dibromomethane
trans-l,4-Dichloro-2-butene
Oichlorodif luoromethane
1 , 1-Dichloroethane
1 ,2-Oichloroethane
1, 1-Dichloroethylene
trans-1 ,2-Oichloroethene
1 ,2-Oichloropropane
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
status3 be present
NA
NO
ND
NO
ND
ND
NO
NA
NA
ND
NO
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
NO
NO
ND
ND
NO
NO
ND
ND
NO
ND
NO
ND
ND
NA
NO
NA
ND
ND
NA
ND
6-2
-------
2169g
Table 6-1 (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 orqanics (continued)
Methyl isobutyl ketone
Methyl methacrylate
Methacrylonitri le
Methylene chloride
2-Nitropropane
Pyridine
1,1.1, 2-Tatrachloroethane
1,1,2, 2-Tetrachloroethane
Tetrachloroethene
Toluene
Tr ibromomethane
1.1. 1-Trichloroethane
1.1,2-Trichloroethane
Trichloroethene
Trichloromonof luoromethane
1,2,3-Trichloropropane
1.1.2-Trichloro-l,2,2-
trif luoroethane
Vinyl chloride
1.2-Xylene
1,3-Xylene
1,4-Xylene
Semivolat i le orqanics
Acenaphthalene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobiphenyl
Ani 1 ine
Anthracene
Aramite
6enz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo( a )pyrene
Benzo(b)f luoranthene
Benzo(ghi )perylene
Benzo(k)f luoranthene
p-Benzoquinone
Detection Believed to
status3 be present
NA
ND
ND
NO
ND
ND
ND
ND
201-2,000
NO
ND
ND
ND
NO
ND
NA
NA
NA
NA
NA
ND
ND
ND
ND
ND
ND
ND
ND
ND
NA
ND
ND
ND
NO
ND
ND
6-3
-------
2169g
Table 6-1 (Continued)
BOAT
reference
no.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
76.
79.
80.
81.
82.
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
Semivolati 1e orqanics (continued)
8is(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl)ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroaniline
Chlorobenzilate
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortho-Cresol
para-Cresol
Cyc lohexanone
D ibenz( a, h) anthracene
Oibenzo(a,e)pyrene
Dibenzofa. i)pyrene
m-Dichlorobenzene
o-Dichlorobenzene
p-Dichlorobenzene
3,3'-Oichlorobenzidine
2,4-Oichlorophenol
2,6-Dichlorophenol
Diethyl phthalate
3,3'-Dimethoxybenzidine
p-0 imethy lam i noazobenzene
3,3'-Oimethy Ibenz idine
2, 4-0 imethy 1 phenol
Dimethyl phthalate
Di-n-butyl phthalate
1 ,4-Oinitrobenzene
4,6-Dinitro-o-cresol
2,4-Oinitrophenol
2,4-Dinitrotoluene
2,6-Oinitrotoluene
Di-n-octyl phthalate
Di-n-propylnitrosamine
Dipheny lamine
Dipheny Initrosamine
Detection Bel ieved to
status3 be present
NO
NO
ND
<250-500
ND
NO
ND
ND
ND
ND
ND
ND
NO
ND
NO
ND
NA
ND
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
ND
NO
ND
ND
ND
ND
ND
6-4
-------
2169g
Table 6-1 (Continued)
BOAT
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
Semivolatile orqanics (continued)
1,2-Oiphenylhydrazine
Fluoranthene
Fluorene
Hexach lorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexach loroethane
Hexachlorophene
Hexach loropropene
Indeno(1.2,3-cd)pyrene
Isosafrole
Methapyrilene
3-Methy Icho lanthrene
4,4'-Methylenebis
(2-chloroani line)
Methyl methanesulfonate
Naphthalene
1,4-Naphthoquinone
1-Naphthylamine
2-Naphthylamine
p-Nitroani 1 ine
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-Nitrosomethylethylamine
N-Nitrosomorpholine
N-Nitrosopiperidine
n-Nitrosopyrrol idine
5-Nitro-o-toluidine
Pentach lorobenzene
Pentach loroethane
Pentach loron i t robenzene
Pentachlorophenol
Phenacetin
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
Pronamide
Pyrene
Resorcinol
Detection Believed to
status3 be present
NO
NO
NO
NO
NO
NO
NO
NO
NA
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NO
NA
NO
NO
NO
NO
6-5
-------
2169g
Table 6-1 (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.
171.
172.
173.
174.
175.
Constituent
Semivolatile orqanics (continued)
Safrole
1,2,4. 5-Tetrachlorobenzene
2,3.4, 6-Tetrach lorophenol
1,2,4-Trichlorobenzene
2, 4,: 5-Trich lorophenol
2, 4, 6-Trich lorophenol
Tris(2,3-dibromopropyl)
phosphate
Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Tha 1 1 ium
Vanadium
Zinc
Inorqanics other than metals
Cyanide
Fluoride
Sulfide
Orqanochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
Detection Believed to
status3 be present
ND
NO
ND
NO
ND
NO
ND
ND
<2-3.1
18-39
ND
3.3-10
43-93
NA
7-24
56-28
ND
46-130
ND
ND
ND
7-10
89-130
.
-
-
NO
ND
ND
ND
6-6
-------
2169g
Table 6-1 (Continued)
BOAT
reference
no.
Constituent
Detection Believed to
status3 be present
Orqanochlorine pesticides (continued)
176.
177.
178.
179.
180.
181.
182.
183.
184.
185.
186.
187.
188.
163.
190.
191.
192.
193.
194.
195.
196.
197,
198.
199.
200.
201.
202.
203.
204.
205.
206.
ganma-BHC
Chlordane
DDD
DDE
DDT
Dieldrin
Endosulfan 1
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
Phenoxvacetic acid herbicides
2,4-Dichlorophenoxyacetic acid
Silvex
2,4,5-T
Orqanoohor.Dhorous insecticides
Disulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
ND
ND
ND
NO
NO
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
ND
NO
ND
104.000-246.000
ND
NO
ND
NO
ND
ND
ND
ND
ND
NO
ND
6-7
-------
2169g
Table 6-1 (Continued)
BOAT
reference
no.
Constituent
Detection
status3
Believed to
be present
207.
208.
209.
210.
211.
212.
213.
Dioxins and furans
Hexachlorodibenzo-p-dioxins NO
Hexachlorodibenzofurans NO
Pentachlorodibenzo-p-dioxins NO
Pentachlorodibenzofurans NO
Tetrachlorodibenzo-p-dioxins NO
Tetrachlorodibenzofurans NO
2.3,7,8-Tetrachlorodibenzo-
p-dioxin NO
NO = 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.
a,
'Where concentrations are shown, units are ing/kg.
6-8
-------
detected were toluene and bis(2-ethylhexyl)phthalate; certain metals such
as arsenic, barium, cadmium, chromium, copper, lead, nickel, vanadium,
and zinc; and the organophosphorous insecticide disulfoton. Eighteen
constituents were not analyzed for because at the time the analysis was
performed, those constituents were not on the BOAT constituent list. For
those constituents identified as not detected (ND), it was assumed that
they were present at or below detection limits or that some constituents
were present in the untreated waste but masking or interference prevented
their detection. Detection limits for K037 constituents in treated and
untreated wastes are provided in Appendix C. A summary of the detected
constituents and their concentrations is given in Table 6-2.
6.2 Comparison of Untreated and Treated Waste Data for the Ma.ior
Constituents
Table 6-2 also presents the concentrations of major constituents in
the treated waste residues, namely ash and scrubber water. The treated
waste data demonstrate that the three detected organics -- toluene,
disulfoton, and bis(2-ethylhexyl)phthalate -- were reduced
significantly. This further indicates that the BOAT identified is
effective in reducing the major organic constituents to nontreatable
levels, and that the treatment residues do not need any additional
organic treatment.
Because the concentrations of toluene, bis(2-ethylhexyl)phthalate,
and disulfoton were reduced substantially, these compounds were regarded
as potential regulated constituents. The Agency requires further
analysis of constituents for which substantial reduction was not achieved
6-9
-------
1485g/p.l3
Table 6-2 BOAT List Constituents and Their Concentrations
in Untreated Waste and Treatment Residues
BOAT
reference
no.
43.
70.
155.
156.
157.
158.
159.
160.
161.
163.
166.
167.
168.
195.
BOAT list
constituent
Toluene
Bis(2-ethylhexyl)-
phthalate
Arsenic
Barium
Beryll ium
Cadmium
Chromium
Copper
Lead
Nickel
Thai 1 ium
Vanadium
Zinc
Disulfoton
Untreated waste
(mg/kg)
201-2.000
<250-500
<2-3.1
18-39
<0.5
3.3-10
43-93
7-24
5.6-28
46-130
<2.5
7-10
89-190
104.000-246,000
Treated waste residue
Ash
(mg/kg)
<10
<2.0
5.25
130-170
<0.5-0.54
<2. 0-2.1
80-110
380-940
15-66
110-180
<2.5
61-88
290-840
<0.0335
Ash TLCP
(mg/1)
NA
NA
<0. 01-0. 022
<0. 045-1.1
<0.005
<2.0
<0. 045-0. 26
0.15-10
<0. 01-0. 029
0.19-0.59
0.015
0.25-1.8
0.45-4.8
NA
Scrubber water
(ug/1)
<10
<50
0.1-0.45
0.18-0.91
<0.005
0.059-0.16
0.09-0.21
3.9-6.3
4-11
<0.1-0.11
<0.015
<0.1
0.97-16
<1.0
NA = Not appl icable.
Reference: USEPA 1987. Onsite Engineering Report for K037.
6-10
-------
to determine whether the reduction is significant. Statistical analysis
would be required for this determination. As seen in Table 6-2, this
step was not necessary.
Untreatable concentrations of metals were detected in the scrubber
water and ash residuals. The amounts are too low to warrant metals
treatment. Furthermore, since none of the detected BOAT list metals were
treated by rotary kiln incineration, none were regarded as potential
regulated constituents.
6.3 Selection of Regulated Constituents
Toluene and disulfoton are the only two BOAT list constituents
selected as regulated constituents for K037. Using the analytical data
for these constituents, the Agency developed BOAT treatment standards,
which are discussed in the following section. The Agency did not select
bis(2-ethylhexyl)phthalate as a regulated constituent because regulation
of toluene and disulfoton will, the Agency believes, control other
organics present in the untreated waste.
6-11
-------
7. CALCULATION OF BOAT TREATMENT STANDARDS
The purpose of this section is to calculate the actual treatment
standards for the regulated constituents identified in Section 6. EPA
has six sets of influent and effluent data from one facility for
treatment of K037 using rotary kiln incineration. As discussed in the
introduction, the following steps were taken to derive the BOAT treatment
standards for K037.
1. The Agency evaluated the data collected from the rotary kiln
treatment system to determine whether any of the data represented
poor design or operation of the treatment system. The available
data show that none of the six data sets represents poor design
or operation. All six data sets for rotary kiln incineration are
used for regulation of the K037 waste.
2. Accuracy-corrected constituent concentrations were calculated for
all BDAT-list constituents. An arithmetic average concentration
level and a variability factor were determined for each BOAT list
constituent regulated in this waste, as shown in Table 7-1. The
calculation of the variability factor is presented in Appendix A.
3. The BOAT treatment standard for each constituent regulated in
this rulemaking was determined by multiplying the average
accuracy-corrected total composition by the appropriate
variability factor.
Table 7-1 summarizes the calculation of the treatment standards for
K037 nonwastewaters and wastewaters. EPA believes the treated
constituent concentrations substantially diminish the toxicity of K037.
7-1
-------
Table 7-1 Regulated Constituents and Calculated Treatment Standards for K037
Accuracy-corrected concentration
Constituent
Matrix (units)
Nonwastewaters Disulfoton (mg/kg)
7"1 Toluene (mg/kg)
ro
Wastewaters Disulfoton (mg/1)
Toluene (mg/1)
Sample
set #1
0.04
10
0.0011
0.01
Sample
set f<2
0.04
10
0.0011
0.01
Sample
set #3
0.04
10
0.0011
0.01
Sample
set #4
0.04
10
0.0011
0.01
Sample
set #5
0.04
10
0.0011
0.01
Sample
set #6
0.04
10
0.0011
0.01
Average
treated
waste
concentration
0.04
10
0.0011
0.01
Variability
factor
(VF)
2.8
2.8
2.8 •
2.8
Treatment
standard
(average
x VF)
0.10
28
0.003
0.028
-------
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 the K037 waste. The technical project officer for the waste was
Ms. Lisa Jones. Mr. Steven Silverman served as legal advisor.
Versar personnel involved with preparing this document included
Mr. Jerome Strauss, Program Manager; Ms. Laura Fargo, Engineering Team
Leader; Ms. Justine Alchowiak, Quality Assurance Officer; Mr. David
Pepson, Senior Technical Reviewer; Mr. James Morgan, Technical Reviewer;
Ms. Juliet Crumrine, Technical Editor; and the Versar secretarial staff,
Ms. Linda Gardiner and Ms. Mary Burton.
Mr. Benjamin Blaney, Chief, Treatment Technology Staff, served as the
ORD Program Manager for collection of treatment data for K037 waste. The
ORD technical project officer was Mr. Ronald Turner. The K037 treatment
test was conducted at the U.S. EPA Combustion Research Facility by Acurex
Corporation, contractor to the Office of Research and Development. Field
sampling for the test was conducted under the leadership of PEI
Associates. Laboratory coordination and analysis were provided by Radian
Corporation.
We greatly appreciate the cooperation of the company whose plant was
sampled and who submitted detailed information to the U.S. EPA.
8-1
-------
9. REFERENCES
Ackerman, D.G., McGaughey, J.F., Wagoner, D.E. 1983. At sea incineration
of PCB-containing wastes on board the M/T Vulcanus. EPA/600/7-83-024.
Washington, D.C.: U.S. Environmental Protection Agency.
Bonner, T.A., et al. 1981. Engineering handbook for hazardous waste
incineration. Prepared by Monsanto Research Corporation for U.S. EPA.
NTIS PB 81-248163.
Novak R.G., Troxler, W.L., 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).
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. 1986. Stanford Research Institute. Directory of chemical
producers - United States of America. Menlo Park, California:
Stanford Research Institute International.
USEPA. 1980. U.S. Environmental Protection Agency. RCRA listing
background document, waste code K036/K037.
USEPA. 1986a. 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. 1986b. U.S. Environmental Protection Agency, Office of Solid
Waste and Emergency Response. Test methods for evaluating solid
waste. SW-846 Third Edition. Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1987a. U.S. Environmental Protection Agency. Onsite engineering
report of treatment technology performance and operation for
incineration of K037 waste at the Combustion Research Facility. Draft
report. Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1987b. U.S. Environmental Protection Agency. Onsite engineering
report of treatment technology performance and operation for
Safety-Kleen Corporation, Hebron, Ohio. CBI Report. Washington, D.C.:
U.S. Environmental Protection Agency.
9-1
-------
USEPA 1987c. U.S. Environmental Protection Agency. Onsite engineering
report of treatment technology performance and operation for Amoco Oil
Company, Whiting, Indiana. Draft report. Washington, D.C.: U.S.
Environmental Protection Agency.
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.
9-2
-------
APPENDIX A
STATISTICAL METHODS
A.I 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
rti = degrees of freedom for numerator
n» = degrees of freedom for denominator
(shaded area = .95)
^
I
i
«
•i
«
c
1
8
9
10
11
12
13
14
15
16
17
18
19
20
22
24
26
28
30
40
50
60
70
80
100
150
200
400
•0
1
^
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
4.2C
4.10
3.98
3.89
3.31
3.74
3.68
3.63
3.59
3.55
3.52
3.49
3.44
3.40
3.37
3.34
3.32
3.23
3.18
3.15
3.13
3.11
3.09
3.06
3.04
3.02
2.99
3
215.7
19.16
9.28
6.59
5.41
4.76
4.35
4.07
3.86
3.71
3.59
3.49
3.41
3.34
3.29
3.24
3.20
3.16
3.13
3.10
3.05
3.01
2.98
2.95
2.92
2.84
2.79
2.76
2.74
2.72
2.70
2.67
2.G5
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.S7
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
2J9
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
2JZ7
2.26
2J2Z
2-21
6
234.0
19.33
8,94
6.16
4.95
4.28
3.87
3.58
3.37
3.22
3.09
3.00
2.92
2.85
2.79
2.74
2.70
2.66
2.63
2.60
2.55
2.51
2.47
2.45
2.42
2.34
2JJ9
2.25
2J!3
2.21
2.19
2.16
2.14
2.12
2.09
8
238.9
19.37
8.85
6.04
4.82
4.15
3.73
3.44
3.23
3.07
2.95
2.85
2.77
2.70
2.64
2.59
2.55
2.51
2.48
2.45
2.40
2.36
2.32
2JJ9
2^
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
2J!9
225
2.21
2.18
2J3
2.09
2.05
2.02
1.99
1.90
1.85
1.81
1.79
1.77
1.75
1.71
1.69
1.67
1.64
20
248.0
19.45
8.66
5.80
4.56
3.87
3.44
3.15
2.93
2.77
2.65
2.54
2.46
2.39
2.33
2.28
2^3
2.19
2.15
2.12
2.07
2.03
1.99
1.96
1.93
1.84
1.78
1.75
1.72
1.70
1.68
1.64
1.62
1.60
1.57
30
250.1
19.46
8.62
5.75
4.50
3.81
3.38
3.08
2.86
2.70
2.57
2.46
2.38
2.31
2J25
2.20
2.15
2.11
2.07
2.04
1.98
1.94
1.90
1.S7
1.84
1.74
1.69
1.65
1.62
1.60
1.57
1.54
1.52
1.49
1.46
40
251.1
19.46
8.CO
5.71
4.46
3.77
3.34
3.05
2.82
2.67
2.53
2.42
2.34
2.27
2 °1
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
252J!
19.47
8.58
5.70
4.44
3.75
3.32
3.03
2.80
2.64
2.50
2.40
2.32
2J24
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
2JJ5
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
-
254.3
19.50
S.53
5.63
4.35
3.67
3.23
2.93
2.71
2.5-:
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:
SS8 = .|
where:
k = number of treatment technologies
n^ = number of data points for technology i
N = number of data points for all technologies
T^ = sum of natural logtransformed data points for each technology.
(iv) The sum of the squares within data sets (SSW) is computed:
SSW =
where:
" k ni 2
k
- I
1 = 1
V '
ni -
^ j = the natural logtransformed observations (j) for treatment
technology (i).
A-3
-------
(v) The degrees of freedom corresponding to SSB and SSW are
calculated. For SSB, the degree of freedom is given by k-1. For SSW,
the degree of freedom is given by N-k.
(vi) Using the above parameters, the F value is calculated as
follows:
MSB
F = MSW
where:
MSB = SSB/(k-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
Influent Effluent
(M9/D
1550.00
1290.00
1640.00
5100.00
1450.00
4600.00
1760.00
2400.00
4800.00
12100.00
(«/D
10.00
10.00
10.00
12.00
10.00
10.00
10.00
10.00
10.00
10.00
Biological treatment
In(effluent) [ln(ef f luent)]2 Influent Effluent In(effluent)
2.30
2.30
2.30
2.48
2.30
2.30
2.30
2.30
2.30
2.30
Ug/i) (M9/U
5.29 1960.00 10.00 2.30
5.29 2568.00 10.00 2.30
5.29 1817.00 10.00 2.30
6.15 1640.00 26.00 3.26
5.29 3907.00 10.00 2.30
5.29
5.29
5.29
5.29
5.29
[In(effluent)]2
5.29
5.29
5.29
10.63
5.29
Sum:
23.18
53.76
12.46
31.79
Sample Si/c:
10 10
Mean:
3669
10.2
Standard Deviation:
3328.67 .63
Variabi1ity factor:
1.15
10
2.32
.06
2378
923.04
13.2
7.15
2.48
2.49
.43
ANOVA Calculations:
. 2
SSB =
n.
SSW= f 1 .Sj
[ i=l j=l
MSB = SSB/(k-l)
MSW = SSW/(N-k)
k f Tj2 }
"i=i (irr)
A-5
-------
1790g
Example 1 (Continued)
F = MSB/MSU
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. logtransformed 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
fc.
SSB
537.31 155.25
10
1270.21
15
= 0.10
SSI- (53.76. 31.79)- | "7.31^155.25
10 5
= 0.77
HSB = 0.10/1 = 0.10
MSW = 0.77/13 = 0.06
F = °'10 =1.67
0.06
ANOVA Table
Degrees of
Source freedom
BetMeen(B) 1
Within(W) 13
SS HS 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 were 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
Frichloroethylene
S_team striooinq
Influent
Ug/l)
1650.00
5200.00
5000.00
1720.00
1560.00
10300.00
210.00
1600.00
204.00
160.00
Sum:
Sample Size:
10
Mean:
2760
Effluent
(«/D
10.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
85.00
10.00
.
10
19.2
In(effluent)
2.30
2.30
2.30
2.30
2.30
2.30
2.30
3.30
4.44
2.30
26.14
10
2.61
[In(effluent)]2
5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5.29
72.92
-
-
Influent
(iV)
200.00
224.00
134.00
150.00
484.00
163.00
182.00
_
7
220
Biological treatment
Effluent
Ug/i)
10.00
10.00
10.00
10.00
16.25
10.00
10.00
-
7
10.89
ln(ef fluent)
2.30
2.30
2.30
2.30
2.79
2.30
2.30
16.59
7
2.37
[In(effluent)]2
5.29
5.29
5.29
5.29
7.78
5.29
5.29
39.52
-
-
Standard Deviation:
3209.6 23.7
VariabiIity Factor:
3.70
.71
120.5
2.36
1.53
.19
ANOVA Calculations:
SSB =
"" • [ J, K ""•'
MSB = SSB/(k-l)
MSW - SSW/(N-k)
N
Tj2
-s fTj2l
i-1 [rTTj
A-7
-------
1790g
Example 2 (Continued)
F = MSB/MSW
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
2 2
N = 10. N = 7. N = 17. k - 2. T - 26.14. T - 16.59, T - 42.73, f = 1825.85. T = 683.30.
275.23
SSB
683-30
10
SSW = (72.92 + 39.52) -
MSB = 0.25/1 = 0.25
MSW = 4.79/15 = 0.32
. 0.25
1825.85
17
683.30 275.23
10 7
= 0.25
= 4.79
0.78
0.32
ANOVA Table
Degrees of
Source freedom
Between(B) 1
Uithin(W) 15
SS
0.25
4.79
MS
0.25
0.32
f value
0.78
The critical value of the F test at the 0.05 significance level is 4.54. Since
the F value is less than the critical value, the means are not significantly
different (i.e.. they are homogeneous).
Note: All calculations were rounded to two decimal places. Results may differ
depending upon the number of decimal places used in each step of the calculations.
A-8
-------
I790g
Example 3
Chlorobenzene
Activated sludge followed by carbon adsorption
Biological treatment
Influent
Effluent
In(effluent) [ln(eff luent)]
Influent
Ug/D
Effluent
Ug/D
In(effluent)
ln[(eff luent)]
7200.00
6500.00
6075.00
3040.00
80.00
70.00
35.00
10.00
4.38
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:
Sample Size:
4
Mean:
5703
49
Standard Deviation:
1835.4 32.24
Variabi I ity Factor:
14.49
3.62
.95
55.20
14759
16311.86
7.00
452.5
379.04
15.79
38.90
5.56
1.42
228.34
ANOVA Calculations:
SSB
SSW = I .E .£'
I 1=1 J=l
MSB = SSB/(k-l)
HSU = SSW(N-k)
F = MS8/MSU
>.J
N
Tj2
-s (Ti 1
i=l I — ]
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
i
X = the natural logtransformed observations (j) for treatment technology (i)
ij
2 2
N = 4, N = 7. N = 11, k = 2, T = 14.49. T = 38.90, T = 53.39. T = 2850.49, T = 209.96
T = 1513.21
2
209.96 + 1513.21
4 7
SSV = (55.20 + 228.34)
9.52
14.88
MSB = 9.52/1 = 9.52
MSW - 14.88/9 = 1.65
F - 9.52/1.65 = 5.77
ANOVA Table
Degrees of
Source freedom
SS
MS
F value
Bctween(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 va'lue 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.
Hole: 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. Cgq is calculated
using the following equation: Cgq = txp(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 lognormaTly. 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. (1)
Mean
The relationship between the parameters of the lognormal distribution
and the parameters of the normal distribution created by taking the
natural logarithms of the lognormally distributed concentrations can be
found in most mathematical statistics texts (see, for example,
Distribution in Statistics-Volume 1 by Johnson and Kotz, 1970). The mean
of the lognormal distribution can be expressed in terms of the
mean (M) and standard deviation (a) of the normal distribution as
follows:
C99 = Exp (M + 2.33-r) (2)
Mean = Exp (M + 0.5u"). (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 - 0.5<72). (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 (a) of the normal
distribution is approximated by:
a = [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
a = (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
-------
APPENDIX B
ANALYTICAL QA/QC
The analytical methods used for analysis of the regulated
constituents identified in Section 5 are listed in Table B-l. SW-846
methods (EPA's Test Methods for Evaluation Solid of Waste;
Physical/Chemical Methods. SW-846, Third Edition, November 1986) are used
in most cases for determining total constituent concentrations.
The accuracy determination for a constituent is based on the matrix
spike recovery values. Tables B-2 and B-3 present the matrix spike
recoveries for disulfoton and toluene total composition analyses for K037
residuals for the EPA-collected data.
The accuracy correction factors for disulfoton and toluene for each
treatment residual are summarized in Tables B-2 and B-3. The accuracy
correction factors were determined in accordance with the general
methodology presented in the Introduction. For example, for disulfoton
actual spike recovery data were obtained for analysis of both solid and
liquid matrices, and the lowest percent recovery value was used to
calculate the accuracy correction factor. An example of the calculation
of a corrected constituent concentration value is shown below.
Analytical Correction Corrected
Value % Recovery Factor Value
0.0335 ppm 91 100 =1 10 1.10 x 0.0335 = 0.04 ppm
91
B-l
-------
1485g/p.3
Table B-l Analytical Methods for Regulated Constituents
Regulated constituent
Extraction method
Analytical
method Reference
Oisulfoton
Toluene
Specified in analytical method
Specified in analytical method
8140 USEPA 1986b
5030. 8240 USEPA 1986b
B-2
-------
ISboc
Table B-2 Matrix Spike Recoveries for K.037 Treated Solids - EPA-Collected Data
BOAT
constituent
Disulfoton
Toluene
Original amount Spike added
found (ug/1) (ug/1)
<0.007 0.173
NC 25
Sample Set #5
Spike result Percent
(ug/1) recovery*
0.157 91
NC 166
Sample Set #5 Duplicate
Spike added
(ug/1)
0.173
25
Spike result
(ug/1)
0.164
NC
Accuracy
Percent correction
recovery3 factor
95 1.10
165 1.00
NC = Not calculable because the only values available were the spike amount and the percent recovery.
aPercent recovery = [(spike result - original amount)/spike added].
Accuracy correction factor = 100/percent recovery (using the lowest percent recovery value).
Reference: USEPA 1987. Onsite Engineering Report for K037.
CD
-------
Table B-3 Matrix Spike Recoveries for K037 Scrubber Water Sample - EPA-Collected Data
Sample Set #5 Sample Set #5 Duplicate Accuracy
BOAT
const ituent
Disulfoton
Toluene
Original amount Spike added
found (ug/1) (ug/1)
<0.2 5.18
NC 25
Spike result Percent Spike added
(ug/1) recovery* (ug/1)
4.88 94 5.18
NC 109 25
Spike result
(ug/1)
5.28
NC
Percent correction
recovery3 factor
102 1.06
116 1.00
NC = Not calculable because the only values available were the spike amount and the percent recovery.
Percent recovery = [(spike result - original amount )/spike added].
Accuracy Correction Factor = 100/Percent Recovery (using the lowest percent recovery value).
Reference: USEPA 1987. Onsite Engineering Report for K037.
-------
APPENDIX C
DETECTION LIMITS FOR K037 WASTE AND TREATMENT RESIDUALS
Table C-l shows analytical detection limits for the BOAT list
constituents analyzed for K037 waste.
C-l
-------
1553g
Table C-l Detection Limits for K037 Untreated and Treated Samples
BOAT
ref.
no.
222.
1.
2.
3.
4.
5.
6.
223.
?:
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
29.
224.
Parameter
Volatlles
Acetone
Acetonitri le
Acrolein
Acrylonitri le
Benzene
Bromodichloromethane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Chloro-l ,3-butadiene
Chlorodibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Chloropropene
1 ,2-Dibromo-3-chloropropane
1 ,2-Dibromoethane
Oibromomethane
trans -1.4-D1chloro-2-butene
Oichlorodif luoromethane
1 ,1-Dichloroethane
1,2-Oichloroethane
1 . 1-Oichloroethylene
trans -1 ,2-Dichloroethene
1 ,2-Dichloropropane
trans-1 ,3-Dichloropropene
cis-l,3-0ichloropropene
1 ,4-Dioxane
2-Ethoxyethanol
CAS no.
67-64-1
75-05-8
107-02-8
107-13-1
71-43-2
75-27-4
74-83-9
71-36-3
56-23-5
75-15-0
108-90-7
126-99-8
124-48-1
75-00-3
110-75-8
67-66-3
74-87-3
107-05-1
96-12-8
106-93-4
74-95-3
110-57-6
75-34-3
107-06-2
75-35-4
156-60-5
78-87-5
10061-02-6
10061-01-5
123-91-1
107-12-0
110-80-5
Untreated
waste
(mg/kg)
NL
10.000
25,000
500
100
100
500
NL
100
500
100
2500
100
500
10.000
100
500
100
100
100
100
2500
100
100
100
100
100
250
250
250
NA
NL
Treated
waste
(mg/kg)
NL
1000
2500
50
10
10
50
NL
10
50
10
250
10
50
1000
10
50
10
10
10
10
250
10
10
10
10
10
25
25
25
NA
NL
Treated
waste
TCLP
(mg/1)
NL
1000
2500
50
10
10
50
NL
10
50
10
250
10
50
1000
10
50
10
10
10
10
250
10
10
10
10
10
25
25
25
NA
NL
Scrubber
water
Ug/D
NL
1000
2500
50
10
10
50
NL
10
50
10
250
10
50
1000
10
' 50
10
10
10
10
250
10
10
10
10
10
25
25
25
NA
NL
C-2
-------
1553g
Table C-l (Continued)
BOAT
ref.
no.
225.
226.
30.
227.
31.
214.
32.
33.
228.
34.
229.
35.
36.
37.
38.
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
46.
49.
231.
50.
215.
216.
217.
Parameter
Volatiles (continued)
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
Isobutyl alcohol
Methanol
Methyl ethyl ketone
Methyl isobutyl ketone
Methyl methacrylate
Methyl methanesulfonate
Methacrylonitri le
Methylene chloride
z-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 loromonof luoromethane
1,2,3-Trichloropropane
l,l,2-Trichloro-l,2.2-
trif luoroethane
Vinyl chloride
1,2-Xylene
1,3-Xylene
1,4-Xylene
CAS no.
141-78-6
100-41-4
97-63-2
60-29-7
75-21-8
75-21-8
74-88-4
78-83-1
67-56-1
78-93-3
108-10-1
80-62-6
66-27-3
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
Untreated
waste
(rug/kg)
NL
NL
NA
NL
500
NL
100
NA
NL
2500
NL
500
NA
NA
2500
NL
-
100
100
100
100
100
100
100
100
100
2500
NL
500
NL
NL
NL
Treated
waste
(mg/kg)
NL
NL
NA
NL
50
NL
10
NA
NL
250
NL
50
NA
NA
250
NL
-
10
10
10
10
10
10
10
10
10
250
NL
50
NL
NL
NL
Treated
waste
TCLP
(mg/1)
Nl
NL
NA
NL
50
NL
10
NA
NL
250
NL
50
NA
NA
250
NL
-
10
10
10
10
10
10
" 10
10
10
'250
NL
50
NL
NL
NL
Scrubber
water
(M9/D
NL
NL
NA
NL
50
NL
10
NA
NL
250
NL
50
NA
HA
250
NL
-
10
10
10
10
10
10
10
10
10
250
NL
50
NL
NL
NL
C-3
-------
1553g
Table C-l (Continued)
BOAT
ref.
no.
51.
52.
53.
54.
55.
56.
57.
56.
59.
218.
60.
61.
62.
63.
64.
65.
66.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
81.
82.
Parameter
Semivolati les
Acenaphthalene
Acenaphthene
Acetophenone •
2-Acetylaminof luorene
4-Aminobiphenyl
An i line
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzal chloride
Benzenethiol
Benzo(a)pyrene
Benzo(b)f luoranthene
Benzo(ghi )perylene
Benzo(k)f luoranthene
p-Benzoquinone
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
Bis(2-chloroisopropyl) ether
Bis(2-ethylhexyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Butyl-4,6-dinitrophenol
p-Chloroani line
Chlorobenz i late
p-Chloro-m-cresol
2-Chloronaphthalene
2-Chlorophenol
3-Chloropropionitri le
Chrysene
ortho-Cresol
para-Cresol
CAS no.
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
98-87-3
108-96-5
50-32-8
205-99-2
191-24-2
207-08-9
106-51-4
111-91-1
111-44-4
39638-32-9
117-81-7
101-55-3
85-68-7
88-85-7
106-47-8
510-15-6
59-50-7
91-58-7
95-57-8
542-76-7
218-01-9
95-48-7
106-44-5
Untreated
waste
(mg/kg)
250
250
250
25,000
5,000
500
250
NA
250
NL
NA
25,000
250
250
250
250
25,000
250
250
250
250
250
250
NA
2,500
NA
250
250
250
NA
250
250
250
Treated
waste
(mg/kg)
2.0
2.0
2.0
200.0
35.0
3.5
2.0
NA
2.0
NL
NA
200.0
2.0
2.0
2.0
2.0
200.0
2.0
2.0
2.0
2.0
2.0
2.0
NA
2.0
NA
2.0
2.0
2.0
NA
2.0
2.0
2.0
Treated
waste
TCLP
(mg/1)
50
50
50
5,000
1.000
100
50
NA
50
NL
NA
5.000
50
50
50
50
5.000
50
50
50
50
50
50
NA
500
NA
50
50
50
NA
50
50
50
Scrubber
water
Ug/1)
50
50
50
5,000
1.000
100
50
NA
50
NL
NA
5.000
50
50
50
50
5.000
50
50
50
50
50
50
NA
500
NA
50
50
50
NA
50
50
50
C-4
-------
1553g
Table C-l (Continued)
BOAT
ref.
no.
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.
107.
108.
109.
110.
111.
112.
113.
Parameter
Semlvolati les (continued)
Cyclohexanone
D i benz ( a . h ) anthracene
Dibenzo(a,e)pyrene
Dibenzo(a, ijpyrene
m-Dlchlorobenzene
o-Dichlorobenzene
p-Oichlorobenzene
3,3'-Oichlorobenzidine
2,4-Dichlorophenol
2.6-Dichlorophenol
Diethyl phthalate
3,3'-Dimethoxybenzidine
p-Dimethylaminoazobenzene
3,3'-Oimethylbenzidine
2,4-Oimethylphenol
Dimethyl phthalate
Oi-n-butyl phthalate
1.4-Oinitrobenzene
4,6-Dinitro-o-cresol
2,4-Dinitrophenol
2,4-Oinitrotoluene
2,6-Dinitrotoluene
Oi-n-octyl phthalate
Di-n-propylnitrosamine
Diphenylamine
Diphenylnitrosamine
1 ,2-Oiphenylhydrazine
Fluoranthene
Fluorene
Hexachlorobenzene
Hexachlorobutadiene
Hexachlorocyclopentadiene
Hexachloroe thane
CAS no.
108-94-1
53-70-3
192-65-4
189-55-9
541-73-1
95-50-1
106-46-7
91-94-1
120-83-2
87-65-0
84-66-2
119-90-4
60-11-7
119-93-7
105-67-9
131-11-3
84-74-2
100-25-4
534-52-1
51-28-5
121-14-2
606-20-2
117-84-0
621-64-7
122-39-4
86-30-6
122-66-7
206-44-0
86-73-7
118-74-1
87-68-3
77-47-4
67-72-1
Untreated
waste
(mg/kg)
NL
250
250
250
250
250
250
500
250
250
250
250.000
5,000
250.000
250
250
250
2.500
1,250
1,250
250
250
250
-
250
250
250
250
250
250
250
250
250
Treated
waste
(mg/kg)
NL
2.0
2.0
2.0
2.0
2.0
2.0
3.5
2.0
2.0
2.0
2000.0
35.0
2000.0
2.0
2.0
2.0
20.0
10.0
10.0
2.0
2.0
2.0
-
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
2.0
Treated
waste
TCLP
(mg/1)
NL
50
50
50
50
50
50
100
50
50
50
50,000
1.000
50.000
50
50
50
500
250
250
50
50
50
-
50
50
50
50
50
50
50
50
50
Scrubber
water
(/
-------
1553g
Table C-l (Continued)
BOAT
ref.
no.
114.
115.
116.
117.
118.
119.
120.
121.
122.
123.'-
124.
125.
126:
127.
128.
129.
130..
131.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
220.
143.
Parameter
Semivolatlles (continued)
Hexachlorophene
Hexach loropropene
lndeno(1.2.3-cd)pyrene
Isosafrole
Methapyrilene
3-Methylcholanthrene
4.4'-Methylenebis
(2-chloroani line)
Naphthalene
1,4-Naphthoquinone
1-Naphthylamine
2-Naphthy lamine
p-Nitroani line
Nitrobenzene
4-Nitrophenol
M-Nitrosodi-n-buty lamine
N-Nitrosodiethy lamine
•N-Nitrosodimethy lamine
N-Nitrosomethylethylamine ,
N-N itrosomorphol ine
N - N i t rosop i pe r i d i ne
n-Nitrosopyrrol idine
5-Nitro-o-toluidine
Pentachlorobenzene
Pentachloroethane
Pentachloronitrobenzene
Pentachlorophenol
Phenacet in
Phenanthrene
Phenol
Phthalic anhydride
2-Picoline
CAS no.
70-30-4
1888-71-7
193-39-5
120-58-1
91-80-5
56-49-5
101-14-4
91-20-3
130-15-4 '
134-32-7
91-59-8
100-01-6
98-95-3
100-02-7
924-16-3
' 55-18-5
62-75-9
10595-95-6
59-89-2
100-75-4
930-55-2
99-65-8
608-93-5
76-01-7
82-68-8
87-86-5
62-44-2
85-01-8
108-95-2
85-44-9
109-06-8
Untreated
waste
(mg/kg)
NA
250
250
2.500
NA
2500
5,000
250
2.500
2,500
2,500
1 , 250
250
1,250
2,500
2,500
2,500
2,500
5,000
5,000 .
5.000
5,000
250
250
2.500
1,250
2,500
250
250
NL
2.500
Treated
waste
(mg/kg)
NA
2.0
2.0
20.0
NA
20.0
35.0
2.0
20.0
20.0
20.0
10.0
2.0
10.0
20.0
20 '.0
20.0
20.0
35.0
35.0
35.0
35.0
2.0
2.0
20.0
10.0
20.0
2.0
2.0
NL
20.0
Treated
waste
TCLP
(mg/l)
NA
50
50
500
NA
500
1,000
50
500
500
500
250
50
250
500
500
500
500
1,000
1.000
1,000
1.000
50
50
500
250
500
50
50
NL
500
Scrubber
water
Ug/i)
NA
50
50
500
NA
500
1,000
50
500
500
500
250
50
250
500
500
500
500
1,000
1,000
1,000
1.000
50
50
500
250
500
50
50
NL
500
C-6
-------
1553g
Table C-l (Continued)
BOAT
ref.
no.
144.
145.
146.
147.
148.
149.
150.
151.
152.
153.
154.
155.
156.
157.
156.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.
Parameter
Semivolati les (cont.)
Pronamide
Pyrene
Resorcinol
Safrole
1,2,4, 5-Tet rach lorobenzene
2,3,4, 6-Tet rach lorophenol
1,2, 4 -Trich lorobenzene
2, 4, 5-T rich lorophenol
2, 4, 6-Trich lorophenol
Tr i s ( 2 , 3 -d i bromopropy 1 )
phosphate
Metals
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
Si Iver
Thai 1 ium
Vanadium
Zinc
CAS no.
23950-58-5
129-00-0
108-46-3
94-59-7
95-94-3
58-90-2
120-82-1
95-95-4
88-06-2
126-72-7
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-32
7440-50-8
7439-92-1
7439-97-6
7440-02-0
7782-49-2
7440-22-4
7440-28-0
7440-62-2
7440-66-6
Untreated
waste
(ing/kg)
2,500
250
25,000
2.500
2,500
2,500
250
1.250
250
NA
17.0
2.0
1.0
0.5
2.0
3.5
NL
3.0
1.0
1.25
7.5
2.0
3.5
2.5
4.0
1.0
Treated
waste
(mg/kg)
20.0
2.0
2000.0
20.0
2.0
20.0
2.0
10.0
2.0
NA
17.0
2.0
1.0
0.5
2.0
3.5
NL
3.0
1.0
1.25
7.5
2.0
3.5
2.5
4.0
1.0
Treated
waste
TCLP
(mg/1)
500
50
5,000
500
50
500
50
250
50
NA
0.3
0.01
0.045
0.005
0.015
0.045
NL
0.05
0.01
0.001
0.1
0.015
0.045
0.015
0.1
0.03
Scrubber
water
Ug/1)
500
50
5.000
500
50
500
50
250
50
NA
0.3
0.01
0.045
0.005
0.015
0.045
NL
0.05
0.01
0.001
0.1
0.015
0.045
0.015
0.1
0.03
C-7
-------
1553g
Table C-l (Continued)
BOAT
ref.
no.
169.
170.
171.
172.
173.
174.
175.
176.
177.
17S.
179.
180.
181.
182.
183.
184.
185.
186.
187.
188.
189.
190.
191.
192.
193.
194.
Parameter
Inorganics
Cyanide
Fluoride
Sulfide
Orqanochlorine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
gamma -BHC
Chlordane
ODD
DDE
DDT
Dieldrin
Endosulfan 1
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyclor
Toxaphene
Phenoxvacetic acid herbicides
2,4-Dichlorophenoxyacet ic acid
Si Ivex
2.4.5-T
CAS no.
57-12-5
16964-48-8
8496-25-8
309-00-2
319-84-6
319-85-7
319-86-8
58-89-9
57-74-9
72-54-8
72-55-9
50-29-3
60-57-1
939-98-8
33213-6-5
72-20-8
7421-93-4
t
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
Untreated
waste
(mg/kg)
-
-
-
7.5
4.0
7.5
7.5
5.0
100
15.0
7.5
15.0
7.5
7.5
7.5
7.5
15.0
5.0
7.5
7.5
40.0
25.0
1,000
0.385
0.385
0.385
Treated
Treated waste
waste TCLP
(mg/kg) (mg/1)
-
-
-
5.0
2.5
5.0
5.0
5.0
75
10.0
5.0
10.0
5.0
5.0
5.0
5.0
10.0
5.0
5.0
5.0
30.0
15.0
500
0.10
0.10
0.10
Scrubber
water
Ug/D
0.05
0.05
5
0.15
0.10
0.15
0.15
0.10
1.00
0.30
0.15
0.30
0.15
0.15
0.15
0.15
0.30
0.10
0.15
0.15
0.60
0.50
10.0
2.5
2.5
2.5
C-8
-------
1553g
Table C-l (Continued)
BOAT
ref.
no.
195.
196.
197.
198.
199.
200.
201.
202.
203.
204.
205.
206.
207.
208.
209.
210.
211.
212.
213.
Parameter
Orqanophosphorous insecticides
Oisulfoton
Famphur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
Oioxins and furans
Hexachlorodibenzo-p-dioxins
Hexach lorod i benzof uran
Pentachlorodibenzo-p-dioxins
Pen tachlorodi benzof uran
Tetrach lorod ibenzo-p-diox ins
Tetrach lorod i benzof uran
CAS no.
298-04-4
52-85-7
298-00-0
56-38-2
298-02-2
12674-11-2
11104-28-2
11141-16-5
53469-21-9
12672-29-6
11097-69-1
11096-82-5
Untreated
waste
(mg/kg)
5,000
12,500
5,000
3.750
2,500
1.000
1,000
1.000
1.000
1,000
300
400
NA
NA
NA
NA
0.53a
NA
Treated
Treated waste
waste TCLP
(mg/kg) (mg/1)
0.0335
0.085
0.0335
0.0250
0.0165
500
500
500
500
500
250
250
0.15a
0.87a
0.51a
0.35a
0.39a
0.22a
Scrubber
water
Ug/D
1.00
2.50
1.00
0.75
0.50
10.0
10.0
10.0
10.0
10.0
3.00
4.00
5.6b
3.7b
2.4b
2.1b
2.6b
1.6b
2,3,7,8-Tetrachlorodibenzo-p-dioxin -
NL = not on list at the time analysis was performed.
NA = Not detected; however, surrogates not recovered and detection limits cannot be calculated.
- = No analysis performed.
aUnits are ng/g.
hUnits are ng/1.
Reference: USEPA 1987. Onsite Engineering Report.
C-9
-------
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 into 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
-------
UPPER
GUARD
HEATER
THERMOCOUPLE
UPPER STACK
HEATER
TOP
REFERENCE
SAMPLE
HEAT FLOW
DIRECTION
BOTTOM
REFERENCE
SAMPLE
LOWER STACK
HEATER
LIQUID COOLED
HEAT SINK
GUARD
GRADIENTS
STACK
GRADIENT
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
"in ' WdT/dx)top
and the heat out of the sample is given by
Qout = Abottom(dT/dx)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 A are in reasonable
out in out
agreement, the average heat flow is calculated from
« • "in + /2'
The sample thermal conductivity is then found from
Sample = Q/(dT/dx)sample.
D-3
------- |