FINAL
BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
BACKGROUND DOCUMENT ADDENDUM FOR
K015
Larry Rosengrant, Chief
Treatment Technology Section
Elaine Eby
Project Manager
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.V.
Washington. DC 20460
May 1990
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ACKNOWLEDGMENTS
This document was prepared by the U.S. Environmental Protection
Agency, Office of Solid Waste, by Versar Inc. under Contract No.
69-WO-0068. Mr. Larry Rosengrant, Chief, Treatment Technology Section,
Waste Treatment Branch, served as the EPA Program Manager for the BDAT
program. Ms. Elaine Eby served as the Project Manager for K015
nonwastewater regulatory program. Mr. Steven Silverman served as legal
advisor.
The following personnel from Versar Inc. were involved in preparing
this document: Mr. Jerome Strauss, Program Manager; Mr. Stephen
Schwartz, Assistant Program Manager; Ms. Roberta Eelman, Staff Engineer;
Ms. Sally Gravely, Program Secretary; and Ms. Martha Martin, Technical
Editor.
11
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TABLE OF CONTENTS
Section Page No,
1. INTRODUCTION AND SUMMARY 1-1
2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION 2-1
3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
4. PERFORMANCE DATA 4-1
4.1 BOAT List Organics Treatment Data 4-1
4.2 BOAT List Metals Treatment Data 4-2
5. DETERMINATION OF BEST DEMONSTRATED AVAILABLE
TECHNOLOGY (BOAT) 5-1
5.1 BOAT for Treatment of Organics 5-1
5.2 BOAT for Treatment of Metals 5-2
6. SELECTION OF REGULATED CONSTITUENTS 6-1
6.1 Identification of BOAT List Constituents in K015 6-1
6.2 Constituents Selected for Regulation 6-2
7. CALCULATION OF BOAT TREATMENT STANDARDS 7-1
8. REFERENCES 8-1
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LIST OF TABLES
Page No.
Table 1-1 BOAT Treatment Standards for K015 1-3
Table 2-1 K015 Untreated Waste Concentration 2-2
Table 4-1 Treatment Performance Data Collected by EPA
for K019 (Sample Set #1) .- 4-3
Table 4-2 Treatment Performance Data Collected by EPA
for K019 (Sample Set #2) 4-4
Table 4-3 Treatment Performance Data Collected by EPA
for K019 (Sample Set #3) 4-5
Table 4-4 Treatment Performance Data Collected by EPA
for K019 (Sample Set #4) 4-6
Table 4-5 Treatment Performance Data Collected by EPA
for K019 (Sample Set #5) 4-7
Table 4-6 Treatment Performance Data Collected by EPA
for K019 (Sample Set #6) 4-8
Table 4-7 Analytical Results for K087 Untreated Waste Collected
Prior to Treatment by Rotary Kiln Incinerator 4-9
Table 4-8 Analytical Results for Kiln Ash Generated by Rotary Kiln
Incineration of K087 Waste 4-10
Table 4-9 Treatment Performance Data Collected by EPA for
K048 and K051 4-11
Table 7-1 Organic Standards for K015 Nonwastewaters 7-5
Table 7-2 Metal Standards for K015 Nonwastewaters 7-5
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1. INTRODUCTION
This document provides the Agency's rationale and technical support
for selecting the constituents to be regulated in K015 nonwastewaters and
for developing best demonstrated available technology (BOAT) treatment
standards for those regulated constituents. Treatment'standards for K015
wastewaters were originally promulgated as a part of the First Third
rulemaking (53 FR 31154). This document is an addendum to the supporting
BOAT background document for K015 dated August 1988. Most of the
information regarding untreated K015 waste and K015 wastewater standards
is available in the original background document and its references.
This addendum reflects only revisions pertaining to K015 nonwastewater
standards development.
According to 40 CFR 261.32, waste code K015 is generated by the
organic chemicals industry and is listed as "still bottoms from the
distillation of benzyl chloride." Because of the high organic
concentrations in K015 (88 percent benzal chloride), the Agency has
determined that the BOAT for K015 waste is incineration. The treatment
standard for K015 nonwastewaters (wastes with total organic carbon (TOC)
or total suspended solids (TSS) greater than 1 percent) was promulgated
in the First Third rulemaking as "No land disposal based on no generation
of ash," because EPA believed that incineration of K015 waste was
unlikely to generate ash. After promulgation of the final First Third
rule, EPA learned from a K015 generator that incineration of K015
generates an ash residue. Additionally, treatment of wastewater
residuals such as incineration scrubber water and landfill leachate might
form nonwastewater residuals. Therefore, EPA is revising the no land
disposal standard by developing numerical standards for K015
nonwastewaters to reflect these new issues.
.1-1
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The Agency will regulate the same five organic and two metal
constituents in K015 nonwastewaters as are regulated in the wastewater
forms. Treatment standards for the BOAT list organic constituents in
nonwastewater forms are based on a transfer of treatment performance data
from incineration of similar wastes (i.e., K019 and K087). Toluene and
benzal chloride standards are based on transfer of treatment data from
K019. (Benzal chloride is not present in K019, nor is it present in any
other regulated waste. The Agency has decided that p-dichlorobenzene, a
constituent present in treatable levels in K019, is sufficiently similar
to benzal chloride. Therefore, the treatment data from p-dichlorobenzene
in K019 will be used to propose treatment standards for benzal chloride
in K015.) Benzo(b/k)fluoranthene, phenanthrene, and anthracene standards
are based on transfer of treatment performance data from K087. For BDAT
list metal constituents (nickel and chromium), the treatment standards
for nonwastewaters are based on transfer of treatment performance data
from stabilization of incinerator ash generated from combustion of a
waste (K048-K052) containing similar concentrations of metals.
Table 1-1 presents the treatment standards for K015 nonwastewaters
and the existing standards for K015 wastewaters.
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Table 1-1 BOAT Treatment Standards for K015
Maximum for any single grab sample
Nonwastewater Wastewater
Total TCLP leachate Total
concentration concentration concentration
Constituent (mg/kg) (mg/1) (mg/1)
Volatile Organics
Toluene 6.0 NA 0.2
Semivolatile Organics
Anthracene 3.4 NA 1.0
Benzal chloride 6.2 NA 0.3
Benzo(b/k)fluoranthene 3.4 NA 0.3
Phenanthrene 3.4 NA 0.3
Metals
Chromium NA 1.7 0.3
Nickel NA 0.2 0.4
NA - Not applicable.
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2. INDUSTRY AFFECTED AND WASTE CHARACTERIZATION
The Agency estimates that K015 waste is generated by two facilities
in the United States, one in New Jersey and the other in Tennessee. The
process description outlined in the K015 background document has not been
altered; therefore, it is not repeated in this document. When the
original background document was published, EPA believed that the
untreated K015 waste had an average ash content of 0.09 percent, which
EPA considered to be negligible. However, data submitted by industry
since publication of that document shows that the ash content can range
from 0.2 to 1.8 percent and averages approximately 0.7 percent.
Additionally, the Agency has received characterization data for metals in
untreated K015 since the original publication of the K015 background
document and the K015 proposed addendum. These data are presented in
Table 2-1, which incorporates characterization data for untreated K015
waste appearing in the First Thirds K015 Background Document with
information received after the publication of that document.
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Table 2-1 K015 Untreated Waste Concentration
Parameter
Untreated waste concentration (mg/kg)
BOAT Volatile Organics (me/kg)
Toluene
BOAT Semivolatile Organics (me/kg)
Anthracene
Benzal chloride
Benzo(b and/or k)fluoranthene
Phenanthrene
BOAT METALS (mg/kg)a
Nickel
Chromium
Other Parameters
Ash content (%)b
Heating value (Btu/lb)
Carbon content (%)
Dry loss (%)
Sulfur content (%)
Water content (%)
<5,000
880,000
<5,000
<5,000
1.0
<0.5
11.0
20.0
0.2 - 1.8 (0.7 average)
10,000
51.0 - 51.3 (51.1 average)
96.0 - 99.0 (97.2 average)
0.03 - 0.32 (0.22 average)
Source: USEPA 1987a, p. 6-3
aMonsanto 1990.
bMonsanto 1989.
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3. APPLICABLE AND DEMONSTRATED TREATMENT TECHNOLOGIES
The applicable and demonstrated treatment technologies for K015
nonwastewaters remain as stated in the original background document. The
technologies must be those that destroy or reduce the organic constituent
concentration in the waste. These technologies, which include
incineration and fuel substitution, are described in detail in the
original background document.
Because the Agency has information indicating that nonwastewater
residuals can be generated as a result of incineration of K015 wastes
(i.e., ash), an additional technology for treatment of BOAT list metals
in K015 nonwastewater forms must be considered. The applicable
technology that EPA has identified for metals treatment in K015
nonwastewaters is stabilization. The purpose of stabilization is to
immobilize the metal constituents of concern, thereby reducing their
leaching potential.
EPA has identified incineration and fuel substitution as the
demonstrated treatment technologies for K015 waste as generated, chromium
reduction and chemical precipitation for removal of metals from any
residual wastewaters (i.e., incineration scrubber water), and
stabilization for metals in residual nonwastewaters (i.e., incinerator
ash).
For K015 nonwastewaters containing treatable concentrations of BDAT
list metals resulting from incineration, the Agency has not identified
any facilities using stabilization on nonwastewater residuals. However,
the Agency believes that stabilization is demonstrated for K015
nonwastewater residues because stabilization is demonstrated on other
nonwastewater incineration residues containing BDAT list metals. A
detailed description of stabilization appears in the Treatment Technology
Background Document (USEPA 1989b).
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4. PERFORMANCE DATA
This section presents the data available on the performance of
incineration and stabilization in treating K015 nonwastewaters.
4.1 BOAT List Organics Treatment Data
EPA does not have performance data for treating the nonwastewater ash
generated during rotary kiln incineration of K015 waste; therefore, the
Agency will transfer data from the treatment of other listed wastes. Six
sample sets.from the treatment of K019 and five sample sets from the
treatment of K087 were collected for rotary kiln incineration. Transfer
from more than one waste code is necessary since all constituents to be
regulated in K015 cannot be found in one single waste code. Toluene and
benzal chloride standards are based on "transfer of treatment data from
K019. (Benzal chloride is not present in K019, nor is it present in any
other regulated waste. The Agency has decided that p-dichlorobenzene, a
constituent present in treatable levels in K019, is sufficiently similar
to benzal chloride. Therefore, the treatment data from p-dichlorobenzene
in K019 will be used to promulgate treatment standards for benzal
chloride in K015.) Benzo(b/k)fluoranthene, phenanthrene, and anthracene
standards are based on transfer of treatment performance data from K087.
The technology on which treatment performance is based in both the
K019 and K087 wastes is incineration, which is the BOAT technology for
K015 waste as generated. The Agency believes that the data from K019 and
K087 wastes represent a level of treatment performance that can be
achieved for K015 by using incineration because the waste constituents
are similar to K015 wastes and are present at higher concentrations than
in K015. The data from K019 and K087 wastes are presented in Tables 4-1
through 4-8 at the end of this section.
4-1
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For more detailed information on the K019 and K087 performance data,
see the background documents for these waste codes (USEPA 1988b, 1988c).
4.2 BOAT List Metals Treatment Data
No performance data are available for treatment of metals (nickel and
chromium) in K015 nonwastewaters (i.e., incinerator ash or scrubber water
treatment residuals). However, data sets are available for stabilization
of metals in the incinerator ash from treatment of K048-K052 (petroleum
refining wastes). Treatment performance data before stabilization in
K048-K052 waste show chromium and nickel present at a level at least as
high as that expected to be found in K015 nonwastewater residuals.
Therefore, the Agency believes that the K048-K052 data sets represent a
level of treatment performance that can be achieved for K015
nonwastewater residuals using stabilization. The performance data for
ash stabilization from K048-K052 appear in Table 4-9.
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Table 4-1 Treatment Performance Data Collected by EPA for K019a
Plant A - Rotary Kiln Incinerator
Sample Set tl
Untreated waste
Detected BOAT list
organic constituents
K019
concentration
mg/kg
(ppm)
RCRA blend"
concentration
mg/kg
(ppm)
Treated waste
Kiln ash
concentration
mg/kg
(ppm)
Kiln ash
TCLP
mg/L
(ppm)
Volatiles
43. Toluene
Semivo la tiles
<200
2,300
<2
57. Anthracene
65. Benzo(k)f luoranthene
88. p-Dichlorobenzene
141. Phenanthrene
<10
<10
81
21
110
67
32
240
<2
<2
<2
<2
Metals
159. Chromium
163. Nickel
4.0
3.0
40
8.8
44
66
0.200
0.680
Design and Operating Parameters
\
Parameter
Kiln temperature (*F)+
Kiln solids residence time (min)
Waste feed rate (MMBtu/hr)+
Design
Kiln rotational speed (rpm)
Operating value
1825-1900
120
K019: 13.1
RCRA blend.
Waste burner tl: 3.9-5.5
RCRA blend,
Waste burner K: 4.4-9.7
0.19-0.21
aThis table appears in its entirety in the K019 background document (USEPA 1988b). Only an abridged
version is necessary for this document.
Only one sample of RCRA blend waste was taken. The results are repeated in each sample set.
cThis information has been claimed as RCRA Confidential Business Information.
4-3
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Table 4-2 Treatment Performance Data Collected by EPA for K019a
Plant A - Rotary Kiln Incinerator
Sample Set *2
Untreated waste
Detected BOAT list
organic constituents
K019
concentration
mg/kg
(ppm)
RCRA blend"
concentration
mg/kg
(ppm)
Treated waste
Kiln ash
concentration
mg/kg
(ppm)
Kiln ash
TCLP
mg/L
(ppm)
Volatiles
43. Toluene
Semivolatiles
57. Anthracene
65. Benzo(k)fluoranthene
88. p-Oichlorobenzene
141. Pnenanthrene
<2.000
74
15
2.300
110
67
32
240
<2
<2
<2
<2
<2
Metals
159. Chromium
163. Nickel
3.4
3.6
40
8.8
60
89
0.130
0.560
Design and Operating Parameters
V
Parameter
Kiln temperature (*F)+
Kiln solids residence time (min)
Waste feed rate (MMBtu/hr)+
Design
Kiln rotational speed (rpm)
Operating value
1800-1880
120
K019: 12.2
RCRA blend.
Waste burner i\: 5.2-5.5
RCRA blend.
Waste burner 12: 4.4-9.7
0.19-0.21
aThis table appears in its entirety in the K019 background document (USEPA 1988b). Only an abridged
version is necessary for this document.
Only one sample of RCRA blend waste was taken. The results are repeated in each sample set.
GThis information has been claimed as RCRA Confidential Business Information.
4-4
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Table 4-3 Treatment Performance Data Collected by EPA for K019a
Plant A - Rotary Kiln Incinerator
Sample Set #3
Untreated waste
Detected BOAT list
organic constituents
K019
concentration
mg/kg
(ppm)
RCRA blend"
concentration
mg/kg
(ppm)
Treated waste
Kiln ash
concentration
(ppm)
Kiln ash
TCLP
mg/L
(ppm)
Volatiles
43. Toluene
Semivolatlies
<2,000
2.300
<2
57. Anthracene
65. Benzo(k)fluoranthene
88. p-Dichlorobenzene
141. Phenanthrene
80
11
110
67
32
240
<2
<2
<2
159. Chromiun
163. Nickel
3.5
2.3
40
8.8
202
169
0.260
0.960
Design and Operating Parameters
Parameter
Kiln temperature ("F)+
Kiln solids residence time (min)
Waste feed rate (HMBtu/hr)+
Design
Kiln rotational speed (rpm)
Operating value
1850-1900
120
K019: 12.4
RCRA blend.
Waste burner II: 5.2-5.8
RCRA blend.
Waste burner 12: 4.4-8.4
0.19-0.21
aThis table appears in its entirety in the K019 background document (USEPA 1988b). Only an abridged
version is necessary for this document.
Only one sample of RCRA blend waste was taken. The results are repeated in each sample set.
°This information has been claimed as RCRA Confidential Business Information.
4-5
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Table 4-4 Treatment Performance Data Collected by EPA for K019a
Plant A - Rotary Kiln Incinerator
Sample Set *4
Untreated waste Treated waste
K019RCRA blend" Kiln ash Kiln ash
concentration concentration concentration TCLP
Detected BOAT list mg/kg mg/kg mg/kg mg/L
organic constituents (ppm) (ppm) . (ppm) (ppm)
Volatiles
43. Toluene <2,000 2,300 <2
Semivolatlies
57. Anthracene <10 110 <2
65. Benzo(k)fluoranthene <10 67 <2
88. p-Dichlorobenzene 84 32 <2
141. Phenanthrene 19 240 <2
Metals
159. Chromium 1.8 40 28 0.110
163. Nickel 2.2 8.8 69 0.870
Design and Operating Parameters
Parameter Design Operating value
Kiln temperature CF)+ -c 1775-1900
Kiln solids residence time (min) -c 120
Waste feed rate (MMBtu/hr)+ -c K019: 12.7
RCRA blend,
Waste burner /I: 5.2-5.8
RCRA blend.
Waste burner #2: 4.4-7.3
Kiln rotational speed (rpm) -c 0.19-0.21
a
This table appears in its entirety in the K019 background document (USEPA 1988b). Only an abridged
version is necessary for this document.
Only one sample of RCRA blend waste was taken. The results are repeated in each sample set.
cThis information has been claimed as RCRA Confidential Business Information.
4-6
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Table 4-5 Treatment Performance Data Collected by EPA for K019a
Plant A - Rotary Kiln Incinerator
Sample Set 15
Untreated waste Treated waste
K019RCRA blend5 Kiln ash Kiln ash
concentration concentration concentration TCLP
Detected BOAT list rag/kg rag/kg rag/kg mg/L
organic constituents (ppn) (ppm) (ppm) (ppm)
Volatiles
43. Toluene <2.000 2.300
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Table 4-6 Treatment Performance Data Collected by EPA for K019a
Plant A - Rotary Kiln Incinerator
Sample Set *6
Untreated waste Treated waste
K019RCRA blend" Kiln ash Kiln ash
concentration concentration concentration TCLP
Detected BOAT list mg/kg rag/kg mg/kg mg/L
organic constituents (ppm) (ppm) (ppm) (ppm)
Volatiles
43. Toluene <2,000 2.300 <2
Semivolatiles
57. Anthracene <10 110 <2
65. Benzo(k)fluoranthene <10 67 <2
88. p-Dichlorobenzene 90 32 <2
141. Phenanthrene 17 240 <2
Metals
159. Chromium 5.3 40 141 0.092
163. Nickel 6.0 8.8 288 0.690
Design and Operating Parameters
Parameter Design Operating value
Kiln temperature (*F)+ -c 1775-1850
Kiln solids residence time (min) -c 120
Waste feed rate (MMBtu/nr)+ -c K019: 11.5
RCRA blend.
Waste burner #1: 5.2-5.8
RCRA blend.
Waste burner «: 5.2-9.7
Kiln rotational speed (rpm) -c 0.19-0.21
aThis table appears in its entirety in the K019 background document (USEPA 1988b). Only an abridged
version is necessary for this document.
Only one sample of RCRA blend waste was taken. The results are repeated in each sample set.
cThis information has been claimed as RCRA Confidential Business Information.
4-8
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Table 4-7 Analytical Results for K087 Untreated Waste Collected
Prior to Treatment by Rotary Kiln Incinerator3
Concentration
Constituent/parameter (units)
Sample set t
1234
5
BOAT Semivolatile Organics (mg/kg)
Anthracene
Benzo (b)fluorant hene
Benzo(k ) f luoranthene
Phenanthrene
7.500
3.200
3.100
34.000
8.100
<1,010
7.500
34.000
7.100
3.100
3.100
15.000
8.100
<982
9.300
41,000
6.700
5,300
<1.026
15.000
This table appears in its entirety in the £087 background document.
necessary for this document.
Only these selected data are
Note: This table shoos concentrations or maximum potential concentrations in the untreated waste for all
constituents detected in the untreated waste or detected in the residuals generated by treatment of
the waste.
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Table 4-8 Analytical Results for Kiln Ash Generated by
Rotary Kiln Incineration of K087 Waste9
Concentration
Sample set t
Constituent/parameter (units)
BOAT Sanivolatile Organics (mg/kg)
Anthracene
Benzo(b)fluoranthene
Benzo(k)fluoranthene
Phenanthrene
<1.000
<1.000
<1.000
<1.000
<1.000
<1,000
<1.000
<1.000
<1.000
<1.000
<1,000
<1.000
<1.000
<1.000
<1,000
<1.000
<1,000
<1.000
<1,000
<1,000
aThis table appears in its entirety in the K087 background document. Only these selected data are
necessary for this document.
Note: This table shows concentrations or maximum potential concentrations in the untreated waste for all
constituents detected in the untreated waste or detected in the residuals generated by treatment of
the waste.
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Table 4-9 Treatment Performance Data Collected by EPA for K048 and K051
Plant 1 - Stabilization of Incinerator Ash
Treated waste
TCLP extracts of stabilized fluidized bed incinerator ash
Detected Untreated waste Cement binder
BOAT list TCLP extracts Run 1 Run 2 Run 3
metal of K048 and K051 mg/L mg/L mg/L
constituents incinerator ash (ppm) (ppn) (ppm)
159. Chromium (total) 2.1-2.6 2.11 2.12 2.16
163. Nickel 0.02-0.03 <0.018 <0.018 <0.018
aThis table appears in its entirety in the K048-K052 background document. Only
Desiqn and Cement
operating parameters Run 1 Run 2 Run 3
Binder-to-ash ratio 0.2 0.2 0.2
Lime-to-ash ratio NA NA NA
Fly ash-to-ash ratio NA NA NA
Uater-to-ash ratio 0.5 0.5 0.5
Ambient temperature CO 23 23 23
Mixture pH 11.6 11.5 11.5
Cure time (days) 28 28 28
Unconfined compress ive strength 943.5 921.6 1.270
2
(Ib/in )
Kiln dust binder
Run 1 Run 2
mg/L rog/L
(ppm) (ppm)
1.78 1.92
<0.018 <0.018
these selected data are
Stabilization
Kiln dust
Run 1 Run 2
0.2 0.2
NA NA
NA NA
0.5 0.5
19 19.5
12.1 12.1
28 28
222.8 267.7
Run 3
mg/L
(ppm)
1.87
<0.018
necessary for
process
Run 3
0.2
NA
NA
0.5
20
12.1
28
241.0
Lime and fly ash binder
Run 1
mg/L
(ppm)
1.13
<0.018
this document
Lime
Run 1
NA
0.2
0.2
0.5
19
12.0
28
565.8
Run 2
mg/L
(ppm)
1.21
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5. DETERMINATION OF BEST DEMONSTRATED
AVAILABLE TECHNOLOGY (BOAT)
This section presents the rationale for the determination of best
demonstrated available technology (BDAT) for K015 nonwastewater organics
and metals treatment. As discussed in Section of the original background
document on K015, the Agency examined all the available data for the
demonstrated technologies to determine whether one of the technologies
performed significantly better than the others. Next, the "best"
performing treatment technology was evaluated to determine whether the
resulting treatment was available. To be "available," a technology
(1) must provide substantial treatment and (2) must be commercially
available to the affected industry. If the "best" demonstrated
technology is "available," then the technology represents BDAT.
As discussed in Section 5 of the original background document for
K015, the BDAT treatment for organics is incineration; this technology
remains applicable for K015 as generated nonwastewaters,
5.1 BDAT for Treatment of Organics
For treatment of organics in K015 nonwastewaters, the Agency has data
only from incineration. The data sets were collected during tests in
which wastes similar to the K015 waste (i.e., K019, K087) were
incinerated. Because data from the other demonstrated technologies such
as fuel substitution are not available, the Agency cannot compare
performance to determine which technology is "best." EPA believes that
well-designed and well-operated fuel substitution systems could not
achieve better treatment than incineration since both technologies
operate at approximately the same temperatures and turbulent conditions.
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EPA's determination that substantial treatment occurs is based on the
reduction of the concentration of all BOAT list organic constituents to
nondetectable levels. In addition to the substantial reduction,
incineration is commercially available and therefore meets the second
criterion of "availability." As "best," "demonstrated," and "available,"
the technology represents BOAT for the organics present in K015.
5.2 BOAT for Treatment of Metals
Incineration of K015 generates wastewater and nonwastewater residuals
both requiring treatment for BOAT list metals. The BDAT for treatment of
metals in the wastewater residual is discussed in the original background
document for K015. For BDAT treatment of metals in the nonwastewater
residual from incineration of K015 waste, no treatment data are
available. EPA does, however, have treatment data for metal-containing
nonwastewater incinerator ash residuals (K048-K052) believed to be
similar to K015 ash. Stabilization is the demonstrated, technology for
which the Agency has data in treating BDAT list metals in the K048-K052
ash. The Agency determined that the treatment performance data for the
K048-K052 BDAT list metals represent a well-designed and well-operated
treatment system.
The ash stabilization data for K048-K052 show TCLP chromium reduction
from a range of 2.1 to 2.6 mg/1 in the untreated waste down to a level of
1.0 to 2.1 mg/1 in the stabilized waste. Nickel is reduced from an
untreated TCLP level of 0.02 to 0.03 mg/1 to a level of <0.018 mg/1 in
the stabilized waste.
The Agency has no reason to believe that the use of other processes
could improve the level of performance achieved by stabilization.
Therefore, stabilization is "best." This treatment system is "available"
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because the components of the treatment system are commercially available
and provide substantial treatment. Therefore, stabilization represents
BOAT for BDAT list metals in K015 ash residues and also in the
nonwastewater residuals from treatment of incinerator scrubber waters.
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6. SELECTION OF REGULATED CONSTITUENTS
As discussed in Section 1 of the original background document on
K015,* the Agency has developed a list of BDAT hazardous constituents
(Table 1-1 of original background document) from which the constituents
to be regulated are selected. EPA may revise this list as additional
data and information become available. The list is divided into the
following categories: volatile organics, semivolatile organics, metals,
inorganics other than metals, organochlorine pesticides, phenoxyacetic
acid herbicides, organophosphorous insecticides, PCBs, and dioxins and
furans.
This section describes the process used to select the constituents to
be regulated in K015 nonwastewaters. The process involves developing a
list of potential regulated constituents and then eliminating those
constituents that would not be treated by the chosen BDAT or that would
be controlled by regulation of other constituents in the waste.
6.1 Identification of BDAT List Constituents In K015
As discussed in Sections 2 and 4, the Agency has characterization
data for untreated K015 nonwastewaters, but no data characterizing
treated K015 nonwastewaters. The characterization data and the
performance data from K015 wastewaters from the original background
document on K015 have been used to determine which BDAT list constituents
may be present in the waste and thus which ones are potential candidates
for regulation in the nonwastewater forms of K015.
*Section 1 of the original background document describes BDAT methodology.
This methodology has since been updated in a separate document,
Methodology for Developing BDAT Treatment Standards (USEPA 1989a).
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Information presented in the original background document for K015
waste describes, for the untreated waste, which constituents were
detected and which constituents the Agency believes could be present
though not detected. These constituents are toluene, anthracene, benzal
chloride, benzo(b/k)fluoranthene, phenanthrene, chromium, and nickel.
6.2 Constituents Selected for Regulation
The Agency has no information to suggest that different constituents
will be present in the nonwastewater forms of K015 than were present in
the wastewater forms; therefore, the same five organic and two metal
constituents will be regulated in the nonwastewater form of K015 were
regulated as in the wastewater form. These constituents are toluene,
anthracene, benzal chloride, benzo(b/k)fluoranthene, phenanthracene,
chromium, and nickel.
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7. CALCULATION OF BOAT TREATMENT STANDARDS
This section presents the calculation of the actual treatment
standards for the regulated constituents determined in Section 6. EPA
has five sets of treated data for K087 and six sets of treated data from
K019 using rotary kiln incineration. EPA also has three data sets for
treatment of metal-bearing ash residues by stabilization from K048-K052.
As discussed in Section 1 of the original background document for K015,
the following steps were taken to derive the BDAT treatment standards for
K015 nonwastewaters.
The Agency evaluated the 11 data sets collected from the rotary kiln
incineration of K019 and K087 to determine whether any of the data
represent poor design or poor operation of the treatment system. The
available data show that none of the data sets represent poor design or
poor operation. Hence, all data sets for rotary kiln incineration of
K019 and K087 are used for establishing treatment standards for
regulation of the BDAT list organic constituents in K015 nonwastewaters.
Treatment standards for the BDAT list organic constituents (toluene,
anthracene, benzal chloride, benzo (b/k) fluoranthene, and phenanthrene)
in nonwastewater forms are based on transfer from incineration of similar
wastes. For BDAT list metal constituents (nickel and chromium), the
treatment standards for nonwastewaters are based on transferred
performance data from stabilization of incinerator ash from combustion of
a waste containing similar concentrations of metals.
Because benzal chloride was not a constituent in any other tested
waste, no treatment performance data were available. However, it was
regulated in the wastewater form of K015 in the First Third rulemaking.
EPA believes that benzal chloride can be treated in nonwastewater
residuals because it is similar to several constituents in wastes that
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have been tested. Specifically, its structure and boiling point are
similar to those of p-dichlorobenzene. P-dichlorobenzene was treated
sucessfully in K019. Hence, EPA believes that benzal chloride can be
treated as well as p-dichlorobenzene.
Toluene is being regulated based on the fact that it is present in
similar wastes that were treated by incineration (K019) at higher levels
than in untreated K015 waste. Therefore, treatment of K015 by incinera-
tion should result in at least as low a level of toluene in K015
nonwastewater as in K019.
Benzo(b/k)fluoranthene is being regulated based on the fact that it
is present in similar wastes that were treated by incineration (e.g.,
K019, K087). Both the b and k forms are found in K087, whereas only the
k form is present in K019. Additionally, the untreated benzo(b/k)fluor-
anthene is present at higher concentrations in K087 than in K019.
Therefore, the Agency believes that the benzo(b/k)fluoranthene in K087
should be more difficult to treat than in K019 and, hence, should be a
better source of incineration treatment data for benzo (b/k) fluoranthene.
Anthracene and phenanthrene are being regulated based on the fact
that they are present in similar wastes that were treated by incineration
(K019, K087). However, the concentrations of these constituents in K019
are not as high as in untreated K015. Anthracene and phenanthrene are
present at higher concentrations in K087 than in K015. Therefore,
treatment by incineration should result in a level of these constituents
in K015 that is at least as low as in K087.
There were no data for metals in untreated K015 incinerator ash, but
nickel and chromium were found in the incinerator scrubber water. Hence,
the Agency believes nickel and chromium can be waste constituents in the
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ash. Therefore, they are being chosen for regulation in the nonwaste-
water form of K015.
For the selected BOAT list metal constituents chromium and nickel,
treatment data were transferred from K048-K052. Characterization data
for untreated K015 show nickel- ranging from 1-11 ppm and chromium ranging
from <0.5 to 20 ppm. For untreated K048-K052, nickel levels range from
0.025 - 390 ppm, and chromium values range from 0.04 to 3400 ppm. Data
are not available for stabilization of metals in incinerator ash of K015;
however, data are available for stabilization of metals in the
incinerator ash of K048-K052. Based on the similarity and amount of the
constituents expected to be found in the untreated K015 ash compared to
K048-K052 ash, it is believed that K015 incinerator ash would be
sufficiently similar to the ash generated by the destruction of
K048-K052. The design and operating data for K048-K052 stabilization
were examined and they indicated that the system was well designed and
well operated. EPA, therefore, believes that K048-K052 treatment data
for metals can be transferred to K015.
As described in the original background document, analytical
accuracy-corrected constituent concentrations were calculated for all
regulated BOAT list constituents. An arithmetic average of concentration
levels for each constituent and a variability factor for each wastewater
constituent were then determined. The variability factor represents the
variability inherent in the treatment process and the sampling and
analytical methods. Variability factors are calculated based on the
treatment data for each of the regulated constituents. The general
methodology for calculating variability factors is presented in
Appendix A of the original background document for K015.
The BOAT treatment standard for each constituent to be regulated in
this rulemaking was determined by multiplying the average
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accuracy-corrected total composition by the appropriate variability
factor. The calculation of treatment standards for the organic
constituents is shown in Table 7-1. The calculation of the treatment
standards for chromium and nickel is presented in Table 7-2.
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Table 7-1 Organic Standards for K01S Horaraatewatera
Untreated Average of Average of Treatment
waste "treatment corrected8 treatment Variability standard
(Big/kg) values (og/kg) values (mg/kg) factor (mg/kg)
Benzal chloride (K015) 880,000 <2.0
(not present in any
other tested waste)
Toluene (K015) <10
Toluene (K019) 2,000 <2.0
<2.2 2.8 6.2
<2.1 2.8 6.0
Benzo(b/k)fluoranthene <5,000
(10)15)
Benzo(b/k)fluoranthene 982-10,345
(K087)
2.8
3.4
Anthracene (K015)
Anthracene (K087)
<5,000
6,700-14,200 <1.0
2.8
3.4
Fhenanthrene (K01S)
Hum an throne (K087)
<5,000
15,000-43,200 <1.0
2.8
3.4
corrected treatment value is average treatment value multiplied by the reciprocal of the fractional
recovery.
Performance data from treatments of p-dichlorobenzene were used to calculate treatment levels
for benzal chloride.
Table 7-2 Metal Standards for K015 Honwastewaters
Average of
Unstabilized corrected9 treatment Variability Treatment
ash (TCLF) values (TCLP) factor standard
(mg/1) (mg/1)
Chromium (total) 2.64 -3.26 1.48
Hickel 0.07 0.07
(mg/1)
1.14 1.7
2.86 0.2
Corrected treatment value is average treatment value multiplied by the reciprocal
of the fractional recovery.
Unstabilized and treated ash data are from treatment tests of K048-K052 wastes.
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8. REFERENCES
Monsanto. 1989. Monsanto Chemical Company. Treatability variance
package on K015 nonwastewaters. Bridgeport, N.J.: Monsanto Chemical
Company.
Monsanto. 1990. Monsanto Chemical Company. Public comment submitted
in response to EPA proposed land disposal restrictions for Third Third
scheduled wastes, January 5, 1990. EPA RCRA Docket No. LD12-00116.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1987. U.S. Environmental Protection Agency. Onsite engineering
report of treatment technology performance and operation for
incineration of K015 waste at the John Zink Company test facility.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1988a. U.S. Environmental Protection Agency, Office of Solid
Waste. Best demonstrated available technology (BDAT) background
document for K015. Washington, B.C.: U.S. Environmental Protection
Agency.
USEPA. 1988b. U.S. Environmental Protection Agency, Office of Solid
Waste. Best demonstrated available technology (BDAT) background
document for K019. Washington, D.C.: U.S. Environmental Protection
Agency.
USEPA. 1988c. U.S. Environmental Protection Agency, Office of Solid
Waste. Best demonstrated available technology (BDAT) background
document for K087. Washington, D.C.: U.S. Environmental Protection
Agency.
USEPA. 1988d. U.S. Environmental Protection Agency, Office of Solid
Waste. Best demonstrated available technology (BDAT) background
document for K048 and K052. Washington, D.C.: U.S. Environmental
Protection Agency.
USEPA. 1989a. U.S. Environmental Protection Agency, Office of Solid
Waste. Methodology for developing BDAT treatment standards.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1989b. U.S. Environmental Protection Agency, Office of Solid
Waste. Treatment technology background document. Washington, D.C.:
U.S. Environmental Protection Agency.
USEPA. 1990. U.S. Environmental Protection Agency, Office of Solid
Waste. Background document for nonwastewater BDAT list constituents.
Washington, D.C.: U.S. Environmental Protection Agency.
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