EPA/530-SW-88-031F
FINAL
BEST DEMONSTRATED AVAILABLE TECHNDLOGY (BOAT)
BACKGROUND DOCUMENT FOR
K071
James R. Berlow, Chief
Treatment Technology Section
John Keenan
Project Manager
U.S. Environmental Protection Agency
Office of Solid Waste
401 M Street, S.W.
Washington, D.C. 2046(1
August 1988
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TABLE OF CONTENTS
Section Page
EXECUTIVE SUMMARY vi i i
1. INTRODUCTION 1-1
1.1 Legal Background 1-1
1.1.1 Requirements Under HSWA 1-1
1.1.2 Schedule for Developing Restrictions 1-4
1.2 Summary of Promulgated BOAT Methodology 1-5
1.2.1 Waste Treatability Group 1-7
1.2.2 Demonstrated and Available Treatment Technologies .. 1-7
1.2.3 Collection of Performance Data 1-11
1.2.4 Hazardous Constituents Considered and 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 Standarc 1-41
2. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION 2-1
2.1 Industries Affected and Process Description 2-1
2.2 Waste Characterization 2-5
3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES 3-1
3.1 Applicable Treatment Technologies 3-1
3.2 Demonstrated Treatment Technologies 3-1
3.2.1 Acid Leaching 3-4
3.2.2 Sludge Filtration 3-10
3.2.3 Chemical Precipitation 3-14
3.2.4 Chemical Oxidation 3-26
4. PERFORMANCE DATA BASE 4-1
4.1 Nonwastewater 4-1
4.2 Wastewater : 4-2
5. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY
(BOAT) 5-1
5.1 Nonwastewater 5-1
5.2 Wastewater 5-5
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TABLE OF CONTENTS (Continued)
Section Page
6. SELECTION OF REGULATED CONSTITUENTS 6-1
6.1 Identification of BOAT List Constituents in K071 Waste 6-1
6.2 Constituent Selection 6-2
7. CALCULATION OF BOAT TREATMENT STANDARDS 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 COMPARISON OF TCLP AND EP RESULTS FCR MERCURY IN K071 C-l
n
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LIST OF TABLES
Table Page
1-1 BOAT Constituent List 1-18
2-1 Number of Producers of Chlorine Using the Mercury
Cell Process Listed by State 2-3
2-2 Number of Producers of Chlorine Using the Mercury
Cell Process Listed by EPA Region 2-4
2-3 Major Constituent Analysis of Untreated K071 Waste 2-6
2-4 BOAT List Constituent Concentrations in Untreated K071
Waste 2-7
4-1 Acid Leaching, Chemical Oxidation, and Sludge
Dewatering/Acid Washing Data Collected by EPA at
Plant A (Plant A.I Data) 4-3
4-2 Acid Leaching (Percolation) Data.Collected by EPA at
Plant A (Plant A.I Data) 4-10
4-3 Acid Leaching, Chemical Oxidation, and Sludge
Dewatering/Acid Washing Data Submitted by Plant A
(Plant A.2 Data) 4-11
4-4 Acid Leaching, Chemical Oxidation, and Sludge
Dewatering/Acid Washing Data Submitted by Plant B 4-21
4-5 Sludge Dewatering/Water Washing Data Submitted by
Plant C 4-22
4-6 Sludge Dewatering/Water Washing Data Submitted by
PI ant D 4-24
4-7 Sludge Dewatering/Water Washing Data Submitted by
Plant E 4-28
4-8 Chemical Precipitation and Filtration Data Collected
by EPA at Plant A 4-34
IV
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LIST OF TABLES (Continued)
Table Page
5-1 Accuracy-Corrected Mercury Data for Acid Leaching,
Chemical Oxidation, and Sludge Dewatering/Acid Washing. 5-6
5-2 Accuracy-Corrected Mercury Data for Sludge
Dewatering/Water Washing 5-17
5-3 Results of ANDVA Test for Demonstrated Technologies
for K071 Nonwastewater 5-24
5-4 Accuracy-Corrected Mercury Data for Chemical
Precipitation and Filtration 5-25
6-1 Status of BOAT List Constituent Presence in Untreated
K071 Waste 6-4
7-1 Calculation of Nonwastewater Treatment Standard
for Mercury in K071 Waste Using Performance Data from
Acid Leaching Followed by Chemical Oxidation and Then
Sludge Dewatering/Acid Washing 7-3
7-2 Calculation of Wastewater Treatment Standard
for Mercury in K071 Waste Using Performance Data from
Chemical Precipitation and Filtration 7-14
A-l 95th Percentile Values for the F Distribution A-2
B-l Analytical Methods for Regulated Constituents B-3
B-2 Specific Procedures or Equipment Used in Mercury
Analysis When Alternatives of Equivalents Are Allowed
in the SW-846 Methods B-4
B-3 Matrix Spike Recoveries for Solid Waste Matrix -
Plant A.I B-5
B-4 Matrix Spike Recoveries for Treated TCLP Leachate
Nonwastewater and Wastewater - Plant A.I B-6
B-5 Matrix Spike Recoveries for Treated Residual -
Plant C B-7
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LIST OF TABLES (Continued)
Table Page
B-6 Matrix Spike Recoveries for Treated Nonwastewater TCLP
and EP Leachates - PI ant C B-8
B-7 Matrix Spike Recoveries for Treated Residual - Plant D B-10
B-8 Matrix Spike Recoveries for Treated Nonwastewater
EP Leachate - Plant D B-ll
VI
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LIST OF FIGURES
Figure Page
3-1 Schematic of K071 Waste Treatment Process 3-3
3-2 Continuous Extractor 3-7
3-3 Continuous Chemical Precipitation 3-17
3-4 Circular Clarifiers 3-20
3-5 Inclined Plate Settler 3-21
Vll
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EXECUTIVE SUMMARY
BOAT Treatment Standards for K071
Pursuant to section 3004(m) of the Hazardous and Solid Waste
Amendments (HSWA) enacted on November 8, 1984, the Environmental
Protection Agency (EPA) is establishing best demonstrated available
technology (BOAT) treatment standards for the listed waste identified in
40 CFR 261.32 as K071. 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, 1990, which reflects a two-year
nationwide capacity variance.
This background document provides the Agency's rationale and technical
support for selecting the constituent to be regulated in K071 waste and
for developing treatment standards for that regulated constituent. The
document also provides waste characterization and treatment information
that serves as a basis for determining whether treatment variances may be
warranted. EPA may grant a treatment variance in cases where the Agency
has determined that the waste in question is more difficult to treat than
the waste upon which the treatment standards have been established.
The introductory section, which appears verbatim in all the First
Third background documents, summarizes the Agency's legal authority and
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promulgated methodology for establishing treatment standards and
discusses the petition process necessary for requesting a variance from
the treatment standards. The remainder of the document presents
waste-specific information the number and locations of facilities
affected by the land disposal restrictions for K071 waste, the
waste-generating process, waste characterization data, the technologies
used to treat the waste (or similar wastes), and available performance
data, including data on which the treatment standards are based. The
document also explains EPA's determination of BOAT, selection of
constituents to be regulated, and calculation of treatment standards.
K071 waste is listed as "brine purification muds from the mercury cell
process in chlorine production, where separately prepurified brine is not
used." The Agency estimates that 14 of 20 facilities using the mercury
cell process do not use prepurified brine and therefore may generate K071
waste. Chlorine producers fall under Standard Industrial Classification
(SIC) Code 2812.
The Agency is regulating mercury in both nonwastewater and wastewater
forms of K071 waste. (For the purpose of determining the applicability
of the treatment standards, wastewaters are defined as wastes containing
less than 1 percent (weight basis) total suspended solids* and less than
*The term "total suspended solids" (TSS) clarifies EPA's previously used
terminology of "total solids" and "filterable solids." Specifically,
total suspended solids is measured by method 209C (Total Suspended Solids
Dried at 103-105°C) in Standard Methods for the Examination of Water
and Wastewater, Sixteenth Edition.
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1 percent (weight basis) total organic carbon (TOC). Waste not meeting
this definition must comply with the treatment standards for
nonwastewaters.) For K071 nonwastewater, the BOAT treatment standard is
based on performance data from acid leaching followed by chemical
»
oxidation and then sludge dewatering/acid washing. For K071 wastewater,
the treatment standard is based on performance data from chemical
precipitation and filtration.
The following table presents the BOAT treatment standards for K071
waste. The treatment standard for nonwastewater reflects the
concentration of mercury in the leachate from the Toxicity Characteristic
Leaching Procedure (TCLP). For wastewater, the treatment standard
reflects total mercury concentration. The units for both total
concentration and TCLP leachate concentration are mg/1 (parts per million
on a weight-by-volume basis). Note that if the concentrations of the
regulated constituents in K071 waste, as generated, are lower than or
equal to the proposed BOAT treatment standards, then treatment is not
required prior to land disposal.
Testing procedures are specifically identified in Appendix B of this
background document.
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BOAT Treatment Standards for K071
Maximum for any single grab sample
Nonwastewater Wastewater
Total TCLP leachate Total waste
Constituent concentration concentration concentration
(mg/kg) (mg/1) (mg/1)
Mercury NA 0.025 0.030
NA = Not applicable.
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1. INTRODUCTION
This section of the background document presents a summary of the
legal authority pursuant to which the best demonstrated available
technology (BOAT) treatment standards were developed, a summary of EPA's
promulgated methodology for developing the BOAT treatment standards, and,
finally, a discussion of the petition process that should be followed to
request a variance from the BOAT treatment standards.
1.1 Legal Background
1.1.1 Requirements Under HSWA
The Hazardous and Solid Waste Amendments of 1984 (HSWA), which were
enacted on November 8, 1984, and which amended the Resource Conservation
and Recovery Act of 1976 (RCRA), impose substantial new responsibilities
on those who handle hazardous waste. In particular, the amendments
require the Agency to promulgate regulations that restrict the land
disposal of untreated hazardous wastes. In its enactment of HSWA,
Congress stated explicitly that "reliance on land disposal should be
minimized or eliminated, and land disposal, particularly landfill and
surface impoundment, should be the least favored method for managing
hazardous wastes" (RCRA section 1002(b)(7), 42 U.S.C. 6901(b)(7)).
One part of the amendments specifies dates on which particular groups
of untreated hazardous wastes will be prohibited from land disposal
unless "it has been demonstrated to the Administrator, to a reasonable
degree of certainty, that there will be no migration of hazardous
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constituents from the disposal unit or injection zone for as long as the
wastes remain hazardous" (RCRA section 3004(d)(l), (e)(l), (g)(5),
42 U.S.C. 6924 (d)(l), (e)(l), (g)(5)).
For the purpose of the restrictions, HSWA defines land disposal "to
include, but not be limited to, any placement of ... hazardous waste in
a landfill, surface impoundment, waste pile, injection well, land
treatment facility, salt dome formation, salt bed formation, or
underground mine or cave" (RCRA section 3004(k), 42 U.S.C. 6924(k)).
Although HSWA defines land disposal to include injection wells, such
disposal of solvents, dioxins, and certain other wastes, known as the
California List wastes, is covered on a separate schedule (RCRA section
3004(f)(2), 42 U.S.C. 6924 (f)(2)). This schedule requires that EPA
develop land disposal restrictions for deep well injection by
August 8, 1988.
The amendments also require the Agency to set "levels or methods of
treatment, if any, which substantially diminish the toxicity of the waste
or substantially reduce the likelihood of migration of hazardous
constituents from the waste so that short-term and long-term threats to
human health and the environment are minimized" (RCRA section 3004(m)(l),
42 U.S.C. 6924 (m)(l)). Wastes that satisfy such levels or methods of
treatment established by EPA, i.e., treatment standards, are not
prohibited from being land disposed.
In setting treatment standards for listed or characteristic wastes,
EPA may establish different standards for particular wastes within a
single waste code with differing treatability characteristics. One such
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characteristic is the physical form of the waste. This frequently leads
to different standards for wastewaters and nonwastewaters.
Alternatively, EPA can establish a treatment standard that is applicable
to more than one waste code when, in EPA's judgment, a particular
constituent present in the wastes can be treated to the same
concentration in all the wastes.
In those instances where a generator can demonstrate that the
standard promulgated for the generator's waste cannot be achieved, the
amendments allow the Agency to grant a variance from a treatment standard
by revising the treatment standard for that particular waste through
rulemaking procedures. (A further discussion of treatment variances is
provided in Section 1.3.)
The land disposal restrictions are effective when promulgated unless
the Administrator grants a national variance and establishes a different
date (not to exceed 2 years beyond the statutory deadline) based on "the
earliest date on which adequate alternative treatment, recovery, or
disposal capacity which protects human health and the environment will be
available" (RCRA section 3004(h)(2), 42 U.S.C. 6924 (h)(2)).
If EPA fails to set treatment standards by the statutory deadline for
any hazardous waste in the First Third or Second Third waste groups (see
Section 1.1.2), the waste may not be disposed in a landfill or surface
impoundment unless the facility is in compliance with the minimum
technological requirements specified in section 3004(o) of RCRA. In
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addition, prior to disposal, the generator must certify to the
Administrator that the availability of treatment capacity has been
investigated, and it has been determined that disposal in a landfill or
surface impoundment is the only practical alternative to treatment
currently available to the generator. This restriction on the use of
landfills and surface impoundments applies until EPA sets treatment
standards for the waste or until May 8, 1990, whichever is sooner. If
the Agency fails to set treatment standards for any ranked hazardous
waste by May 8, 1990, the waste is automatically prohibited from land
disposal unless the waste is placed in a land disposal unit that is the
subject of a successful "no migration" demonstration (RCRA section
3004(g), 42 U.S.C. 6924(g)). "No migration" demonstrations are based on
case-specific petitions that show there will be no migration of hazardous
constituents from the unit for as long as the waste remains hazardous.
1.1.2 Schedule for Developing Restrictions
Under section 3004(g) of RCRA, EPA was required to establish a
schedule for developing treatment standards for all wastes that the
Agency had listed as hazardous by November 8, 1984. Section 3004(g)
required that this schedule consider the intrinsic hazards and volumes
associated with each of these wastes. The statute required EPA to set
treatment standards according to the following schedule:
1. Solvent and dioxin wastes by November 8, 1986;
2. The "California List" wastes by July 8, 1987;
3. At least one-third of all listed hazardous wastes by
August 8, 1988 (First Third);
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4. At least two-thirds of all listed hazardous wastes by
June 8, 1989 (Second Third); and
5. All remaining listed hazardous wastes and all hazardous wastes
identified as of November 8, 1984, by one or more of the
characteristics defined in 40 CFR Part 261 by May 8, 1990 (Third
Third).
The statute specifically identified the solvent wastes as those
covered under waste codes F001, F002, F003, F004, and F005; it identified
the dioxin-containing hazardous wastes as those covered under waste codes
F020, F021, F022, and F023.
Wastes collectively known as the California List wastes, defined
under section 3004(d) of HSWA, are liquid hazardous wastes containing
metals, free cyanides, PCBs, corrosives (i.e., a pH less than or equal to
2.0), and any liquid or nonliquid hazardous waste containing halogenated
organic compounds (HOCs) above 0.1 percent by weight. Rules for the
California List were proposed on December 11, 1986, and final rules for
PCBs, corrosives, and HOC-containing wastes were established
August 12, 1987. In that rule, EPA elected not to establish treatment
standards for metals. Therefore, the statutory limits became effective.
On May 28, 1986, EPA published a final rule (51 FR 19300) that
delineated the specific waste codes that would be addressed by the First
Third, Second Third, and Third Third land disposal restriction rules.
This schedule is incorporated into 40 CFR 268.10, 268.11, and 268.12.
1.2 Summary of Promulgated BOAT Methodology
In a November 7, 1986, rulemaking, EPA promulgated a technology-based
approach to establishing treatment standards under section 3004(m).
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Congress indicated in the legislative history accompanying the HSWA that
"[t]he requisite levels of [sic] methods of treatment established by the
Agency should be the best that has been demonstrated to be achievable,"
noting that the intent is "to require utilization of available
technology" and not a "process which contemplates technology-forcing
standards" (Vol. 130 Cong. Rec. S9178 (daily ed., July 25, 1984)). EPA
has interpreted this legislative history as suggesting that Congress
considered the requirement under section 3004(m) to be met by application
of the best demonstrated and achievable (i.e., available) technology
prior to land disposal of wastes or treatment residuals. Accordingly,
EPA's treatment standards are generally based on the performance of the
best demonstrated available technology (BOAT) identified for treatment of
the hazardous constituents. This approach involves the identification of
potential treatment systems, the determination of whether they are
demonstrated and available, and the collection of treatment data from
well-designed and well-operated systems.
The treatment standards, according to the statute, can represent
levels or methods of treatment, if any, that substantially diminish the
toxicity of the waste or substantially reduce the likelihood of migration
of hazardous constituents. Wherever possible, the Agency prefers to
establish BOAT treatment standards as "levels" of treatment
(i.e., performance standards), rather than to require the use of specific
treatment "methods." EPA believes that concentration-based treatment
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levels offer the regulated community greater flexibility to develop and
implement compliance strategies, as well as an incentive to develop
innovative technologies.
1.2.1 Waste Treatability Group
In developing the treatment standards, EPA first characterizes the
waste(s). As necessary, EPA may establish treatability groups for wastes
having similar physical and chemical properties. That is, if EPA
believes that hazardous constituents in wastes represented by different
waste codes could be treated to similar concentrations using identical
technologies, the Agency combines the wastes into one treatability
group. EPA generally considers wastes to be similar when they are both
generated from the same industry and from similar processing stages. In
addition, EPA may combine two or more separate wastes into the same
treatability group when data are available showing that the waste
characteristics affecting performance are similar or that one of the
wastes in the group, the waste from which treatment standards are to be
developed, is expected to be most difficult to treat.
Once the treatability groups have been established, EPA collects and
analyzes data on identified technologies used to treat the wastes in each
treatability group. The technologies evaluated must be demonstrated on
the waste or a similar waste and must be available for use.
1.2.2 Demonstrated and Available Treatment Technologies
Consistent with legislative history, EPA considers demonstrated
technologies to be those that are currently used on a full-scale basis to
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treat the waste of interest or a waste judged to be similar (see 51 FR
40588, November 7, 1986). EPA also will consider as demonstrated
treatment those technologies used to separate or otherwise process
chemicals and other materials on a full-scale basis. Some of these
technologies clearly are applicable to waste treatment, since the wastes
are similar to raw materials processed in industrial applications.
For most of the waste treatability groups for which EPA will
promulgate treatment standards, EPA will identify demonstrated
technologies either through review of literature related to current waste
treatment practices or on the basis of information provided by specific
facilities currently treating the waste or similar wastes.
In cases where the Agency does not identify any facilities treating
wastes represented by a particular waste treatability group, EPA may
transfer a finding of demonstrated treatment. To do this, EPA will
compare the parameters affecting treatment selection for the waste
treatability group of interest to other wastes for which demonstrated
technologies already have been determined. (The parameters affecting
treatment selection and their use for this waste are described in
Section 3.2 of this document.) If the parameters affecting treatment
selection are similar, then the Agency will consider the treatment
technology also to be demonstrated for the waste of interest. For
example, EPA considers rotary kiln incineration to be a demonstrated
technology for many waste codes containing hazardous organic
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constituents, high total organic content, and high filterable solids
content, regardless of whether any facility is currently treating these
wastes. The basis for this determination is data found in literature and
data generated by EPA confirming the use of rotary kiln incineration on
wastes having the above characteristics.
If no full-scale treatment or recovery operations are identified for
a waste or wastes with similar physical or chemical characteristics that
affect treatment selection, the Agency will be unable to identify any
demonstrated treatment technologies for the waste, and, accordingly, the
waste will be prohibited from land disposal (unless handled in accordance
with the exemption and variance provisions of the rule). The Agency is,
however, committed to establishing treatment standards as soon as new or
improved treatment processes are demonstrated (and available).
Operations only available at research facilities, pilot- and bench-
scale operations, will not be considered in identifying demonstrated
treatment technologies for a waste. Nevertheless, EPA may use data
generated at research facilities in assessing the performance of
demonstrated technologies.
As discussed earlier, Congress intended that technologies used to
establish treatment standards under section 3004(m) be not only
"demonstrated," but also "available." To decide whether demonstrated
technologies may be considered "available," the Agency determines whether
they (1) are commercially available and (2) substantially diminish the
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toxicity of the waste or substantially reduce the likelihood of migration
of hazardous constituents from the waste. These criteria are discussed
below.
1. Commercially available treatment. If the demonstrated treatment
technology is a proprietary or patented process that is not
generally available, EPA will not consider the technology in its
determination of the treatment standards. EPA will consider
proprietary or patented processes available if it determines
that the treatment method can be purchased or licensed from the
proprietor or is a commercially available treatment. The
services of the commercial facility offering this technology
often can be purchased even if the technology itself cannot be
purchased.
2. Substantial treatment. To be considered "available," a
demonstrated treatment technology must "substantially diminish
the toxicity" of the waste or "substantially reduce the
likelihood of migration of hazardous constituents" from the
waste in accordance with section 3004(m). By requiring that
substantial treatment be achieved in order to set a treatment
standard, the statute ensures that all wastes are adequately
treated before being placed in or on the land and ensures that
the Agency does not require a treatment method that provides
little or no environmental benefit. Treatment will always be
deemed substantial if it results in nondetectable levels of the
hazardous constituents of concern (provided the nondetectable
levels are low relative to the concentrations in the untreated
waste). If nondetectable levels are not achieved, then a
determination of substantial treatment will be made on a
case-by-case basis. This approach is necessary because of the
difficulty of establishing a meaningful guideline that can be
applied broadly to the many wastes and technologies to be
considered. EPA will consider the following factors in an
effort to evaluate whether a technology provides substantial
treatment on a case-by-case basis:
Number and types of constituents treated;
Performance (concentration of the constituents in the
treatment residuals); and
Percent of constituents removed.
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EPA will only set treatment standards based on a technology that
meets both availability criteria. Thus, the decision to classify a
technology as "unavailable" will have a direct impact on the treatment
standard. If the best demonstrated technology is unavailable, the
treatment standards will be based on the next best demonstrated treatment
technology determined to be available. To the extent that the resulting
treatment standards are less stringent, greater concentrations of
hazardous constituents in the treatment residuals could be placed in land
disposal units.
There also may be circumstances in which EPA concludes that for a
given waste none of the demonstrated treatment technologies are
"available" for purposes of establishing the 3004(m) treatment
performance standards. Subsequently, these wastes will be prohibited
from continued placement in or on the land unless managed in accordance
with applicable exemptions and variance provisions. The Agency is,
however, committed to establishing new treatment standards as soon as new
or improved treatment processes become available.
1.2.3 Collection of Performance Data
Performance data on the demonstrated available technologies are
evaluated by the Agency to determine whether the data are representative
of well-designed and well-operated treatment systems. Only data from
well-designed and well-operated systems are considered in determining
BOAT. The data evaluation includes data already collected directly by
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EPA and/or data provided by industry. In those instances where
additional data are needed to supplement existing information, EPA
collects additional data through a sampling and analysis program. The
principal elements of this data collection program are: (1) the
identification of facilities for site visits, (2) the engineering site
visit, (3) the sampling and analysis plan, (4) the sampling visit, and
(5) the onsite engineering report.
(1) Identification of facilities for site visits. To identify
facilities that generate and/or treat the waste of concern, EPA uses a
number of information sources. These include Stanford Research
Institute's Directory of Chemical Producers; EPA's Hazardous Waste Data
Management System (HWDMS); the 1986 Treatment, Storage, Disposal Facility
(TSDF) National Screening Survey; and EPA's Industry Studies Data Base.
In addition, EPA contacts trade associations to inform them that the
Agency is considering visits to facilities in their industry and to
solicit their assistance in identifying facilities for EPA to consider in
its treatment sampling program.
After identifying facilities that treat the waste, EPA uses this
hierarchy to select sites for engineering visits: (1) generators treating
single wastes on site; (2) generators treating multiple wastes together
on site; (3) commercial treatment, storage, and 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 isits 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 Pro.iect Plan for the Land Disposal Restrictions
Program ("BOAT"). EPA/530-SW-87-011. In brief, the SAP discusses where
the Agency plans to sample, how the samples will be taken, the frequency
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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.
1-15
-------
(Note: Facilities wishing to submit data for consideration in the
development of BOAT standards should, to the extent possible, provide
sampling information similar to that acquired by EPA. Such facilities
should review the Generic Quality Assurance Pro.iect Plan for the Land
Disposal Restrictions Program ("BOAT"), which delineates all of the
quality 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.
1-16
-------
(5) Onsite engineering report. EPA summarizes all its data
collection activities and associated analytical results for testing at a
facility in a report referred to as the onsite engineering report (OER).
This report characterizes the waste(s) treated, the treated residual
concentrations, the design and operating data, and all analytical results
including methods used and accuracy results. This report also describes
any deviations from EPA's suggested analytical methods for hazardous
wastes that appear in Test Methods for Evaluating Solid Waste. SW-846,
Third Edition, November 1986.
After the OER is completed, the report is submitted to the waste
generator and/or treater for review. This review provides a final
opportunity for claiming any 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.
/.
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
2/.
28.
29.
224.
225.
226.
30.
227.
31.
214.
32.
33.
228.
34.
Constituent
Volat i le organ ics
Acetone
Acetonitri le
Aero le in
Acrylonitri le
Benzene
Brocnod ich loromethdnc
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulf ide
Chlorobenzene
2-Chloro-1.3-butadiene
Ch lorod ibromomethane
Chloroethane
2-Chloroethyl vinyl ether
Chloroform
Chloromethane
3-Ch loropropene
1 ,2-Oibromo-3-chloropropane
1 . 2 - 0 1 bromoethane
U ibromome thane
trans -1 ,4-Dichloro-2-butene
Dichlorodif luorome thane
1. 1-Dichloroethane
1.2-D ich loroethane
1 , 1 -Oich loroethy lene
trans- 1.2-D ich loroethene
1,2-Dichloropropane
trans-1 ,3-D ich loropropene
cis- 1, 3-D ich loropropene
1,4-Oioxane
2-Cthoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methdcry late
E thy lene oxide
lodomethane
Isobutyl alcohol
Hethano 1
Methyl ethyl kctone
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
74-9S-3
110-57-6
75-71-8
75-34-3
107-06-2
75-35-4
156-60-5
78-87-5
10061-02-6
10061-01-5
123-91-1
110-80-5
141-/8-6
100-41-4
107-12-0
60-29-7
97-63-2
75-21-8
74-88 4
78-83-1
67-56-1
78-93-3
1-18
-------
1521g
Idble 1-1 (Continued)
BOAT
reference
no.
229.
35.
37.
38.
230.
39.
40.
41.
42.
43.
44.
45.
46.
47.
48.
49.
231.
50.
215.
?16.
217.
51.
52.
53.
54.
55.
56.
57.
58.
59.
218.
60.
61.
62.
63.
64.
65.
66.
Constituent
Volatile organ ics (continued)
Methyl isobutyl ketone
Methyl methacrylate
Methacry lonitri le
Methylene chloride
2-Nitropropane
Pyridine
1,1, 1 ,2-Ietrachloroethane
1 , 1 ,2,2-Tetrach I o roe thane
Tetrach loroethenc
Toluene
Tribrononethane
1 . 1 . 1 - F r ich loroethane
1 , 1 ,2-Trichloroethane
Trichloroethene
Trichloromonof luoromethane
1 . 2.3- f rich loropropane
1,1.2-Trichloro 1.2.2- trifluoro-
e thane
Vinyl chloride
1.2-Xylene
1.3-Xylene
1.4 Xylene
Semivo lat i le organ ics
Acenaphtha lene
Acenaphthene
Acetophenone
2-Acetylaminof luorene
4-Aminobipheny 1
Aniline
Anthracene
Aram He
Benz ( a ) anthracene
Benzal chloride
bunienethio 1
DC Icted
Benzol a Ipyrene
Benzo(b)f luoranthene
Benzo(ghi Jpery 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
-------
lS21g
Table 1-1 (Continued)
UOAI
reference
no.
B7.
68.
69.
70.
71.
72.
73.
74.
75.
76.
11.
78.
79.
80.
81.
8?.
?32.
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.
Const ituent
Semivoldt i le organ ics (continued)
Bis(2-chloroethoxy)methane
8is(2-chloroethyl)ether
8 is(2-ch loro isopropy 1 ) ether
Bis(2-ethylhoxyl)phthaldte
4 Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Buty 1-4,6-din itrophenol
p-Chloroani 1 ine
Chlorobenzi late
p-Chloro-m-cresol
2-Ch loronaphtha lene
2-Ch loropheno 1
3-Ch loropropionitn le
Chrysene
ortho-Cresol
para-Crcsol
Cyc lohexanone
D i benz( a. h) anthracene
Dibenzo(a.e)pyrene
l)ibenio(a, ijpyrenu
m Oichlorobenzene
o-Oichlorobenzene
p-U ich lorobenzene
3,3' -Dichlorobon/ id ine
2.4 0 ich loropheno 1
2 . 6-0 ich loropheno 1
Diethyl phthalate
3,3' -Dime thoxybcn/ id ine
p Dimethylaminoazobenicne
3.3' -Oimethylbenzidme
2.4-Oimethylphenol
Dimethyl phthalate
Di-n-butyl phthalate
1.4-Dinitrobenzene
4 . 6-0 m i tro-o-creso 1
2,4-Dinitropheno 1
2.4-Oinitrotoluene
2.6-Din itrotoluene
Oi-n-octyl phthalate
D i -n-propy In i trosam ine
Dipheny lam me
Oipheny Ini trosamme
CAS no.
111-91-1
111-44-4
39638-32-9
11/-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-S5-9
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
11/-84-0
621-64-7
122-39-4
86-30-6
1-20
-------
I521g
Table l-l (Continued)
UOAI
reference
no.
107.
ioa.
109.
110.
111.
112.
113.
114.
115.
116.
ll/.
118.
119.
120.
36.
121.
122.
123.
124.
125.
126.
127.
1?8.
129.
130.
131.
132.
133.
134.
135.
136.
137.
138.
139.
140.
141.
142.
220.
143.
144.
145.
Mb.
Const ituent
Semivo lat i le orqdnics (continued)
1 . 2 -Oipheny Ihydraz me
F luoranthene
F luorene
Hexach loroben/ene
Hexachlorobutadiene
Hexach lorocyc 1 open tad lene
Hexdch loroethane
Hexach lorophene
Hexach loropropene
1 ndeno( 1 . 2 , 3 -cd ) py rene
Isosafrole
Methapyr i lene
3 Hethylcholanthrene
4.4'-Methylenebis
(2-chloroani 1 ine)
Methyl methanesu 1 fondle
Naphthalene
1 ,4-Naphthoqu inone
1-Naphthy lamine
2-Naphthy lamine
p-Nitroani line
Nitrobenzene
4-Nitrophenol
N-Nitrosodi-n-buty lamine
N-Nitrosodiethy lamine
N-N i t rosod imethy lam i ne
N-N i trosomethy lethy lamine
N-N i trosomorpho 1 ine
N-Nitrosopiperidine
N-Nitrosopyrrol idine
5-Nitro-o-toluidine
Pcntach lorobonzcne
Pentach loroethane
Pentach loron i t robenzene
Pentdch loropheno 1
Phenacet in
Phenanthrene
Phenol
Phlha 1 ic anhydr ide
2-Picol ine
Pronamide
Pyrene
Kesorcinol
CAS no.
122-66-7
206-44-0
B6-73-/
118-74-1
87-68-3
77-4/-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
-------
I521q
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.
171.
172.
1/3.
174.
175.
Constituent
Semivolatile organics (continued)
Safrole
1,2,4.5- let rach lorobenmne
2.3.4,6-Tetrachlorophcnol
1 , 2 , 4 - T r ich lorobenzene
2.4,5-Trich loropheno 1
2,4, 6- Tr ich loropheno 1
Tris(2.3-dibromopropy 1)
phosphate
Metals
Antimony
Arsenic
Barium
Beryl! ium
Cadmium
Chromium (total)
Chromium (huxavalent)
Copper
Lead
Mercury
Nickel
Selenium
Silver
Thallium
Vanadium
Zinc
Inorganics other than metals
Cyan idc
fluoride
Sulf ide
Orqanoch lor inc pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
CAS no.
94-59-7
95-94-3
58-90-2
120-82-1
95-95-4
88-06-2
126-72-7
7440-36-0
7440-38-2
7440-39-3
7440-41-7
7440-43-9
7440-47-3
-
7440-50-8
7439-92-1
7439-97-6
7440-02-0
7782-49-2
7440-22 4
7440-28-0
7440-62-2
7440-66-6
57-12-5
16964-48 8
8496-25-8
309-00-2
319-84-6
319-85-7
319-86-8
1-22
-------
1521g
Table 1-1 (Continued)
BOAT
reference
no.
1/6.
177.
178.
179.
iao.
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
Orqanochlonne pesticides (continued)
gamma -BHC
Ch lordane
DOO
DDE
DDf
Oieldrin
Endosulfan I
Endosulfan II
Endrin
Endrin aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Hethoxyc lor
Toxaphene
Phenoxyacet ic acid herbicides
2.4-Oichlorophenoxyacet ic acid
Si Ivex
2.4.5-T
Orqanophosohorous insecticides
Oisulfoton
Famphur
Methyl parathion
Para th ion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroc lor 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
-------
ISZlg
Table 1-1 (Continued)
BOAT
reference Constituent CAS no.
no.
Dioxins and furans
207. Hexachlorodibenzo-p-dioxins
208. Hexachlorodibenzofurans
209. Pentachlorodibenzo-p-dioxins
210. Pentachlorodiben/ofurans
211. Tetrachlorodibenzo-p-dioxins
212. Tetrachlorodibenzofurans
213. 2.3.7.8-retrachlorodibenzo-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 .mplex
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 the development of
numerous regulations in the Effluent Guidelines Program under the Clean
Water Act. The variability factor establishes the instantaneous maximum
based on the 99th percentile value.
1-29
-------
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
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on a metal recovery process, the facility has to comply with both the
total and the TCLP extract constituent concentrations prior to land
disposing the waste.
In cases where treatment standards for metals are not based on
recovery techniques but rather on stabilization, EPA is using only the
TCLP value as a measure of performance. The Agency's rationale is that
stabilization is not meant to reduce the concentration of metal in a
waste but only to chemically minimize the ability of the metal to leach.
1.2.6 Identification of BOAT
BOAT for a waste must be the "best" of the demonstrated available
technologies. EPA determines which technology constitutes "best" after
screening the available data from each demonstrated technology, adjusting
these data for accuracy, and comparing the performance of each
demonstrated technology to that of the others. If only one technology is
identified as demonstrated, it is considered "best"; if it is available,
the technology is BOAT.
(1) Screening of treatment data. The first activity in
determining which of the treatment technologies represent treatment by
BOAT is to screen the treatment performance data from each of the
demonstrated and available technologies according to the following
criteria:
1. Design and operating data associated with the treatment data
must reflect a well-designed, well-operated system for each
treatment data point. (The specific design and operating
parameters for each demonstrated technology for the waste
code(s) of interest are discussed in Section 3.2 of this
document.)
1-32
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2. Sufficient QA/QC data must be available to determine the true
values of the data from the treated waste. This screening
criterion involves adjustment of treated data to take into
account that the true value may be different from the measured
value. This discrepancy generally is caused by other
constituents in the waste that can mask results or otherwise
interfere with the analysis of the constituent of concern.
3. The measure of performance must be consistent with EPA's
approach to evaluating treatment by type of constituents (e.g.,
total concentration data for organics, and total concentration
and TCLP extract concentration for metals from the residual).
In the absence of data needed to perform the screening analysis, EPA
will make decisions on a case-by-case basis as to whether to use the data
as a basis for the treatment standards. The factors included in this
case-by-case analysis will be the actual treatment levels achieved, the
availability of the treatment data and their completeness (with respect
to the above criteria), and EPA's assessment of whether the untreated
waste represents the waste code of concern.
(2) Comparison of treatment data. In cases in which EPA has
treatment data from more than one demonstrated available technology
following the screening activity, EPA uses the statistical method known
as analysis of variance (ANOVA) to determine if one technology performs
significantly better than the others. This statistical method
(summarized in Appendix A) provides a measure of the differences between
two data sets. Specifically, EPA uses the analysis of variance to
determine whether BOAT represents a level of performance achieved by only
one technology or represents a level of performance achieved by more than
one (or all) of the technologies. If EPA finds that one technology
performs significantly better (i.e., is "best"), BOAT treatment standards
1-33
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are the level of performance achieved by that best technology multiplied
by the corresponding variability factor for each regulated constituent.
If the Agency finds that the levels of performance for one or more
technologies are not statistically different, EPA averages the
performance values achieved by each technology and then multiplies this
value by the largest variability factor associated with any of the
technologies.
(3) Quality assurance/quality control. This section presents the
principal quality assurance/quality control (QA/QC) procedures employed
in screening and adjusting the data to be used in the calculation of
treatment standards. Additional QA/QC procedures used in collecting and
screening data for the BOAT program are presented in EPA's Generic
Quality Assurance Pro.lect 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 constituentminus the initial
concentration in the samples, all divided by the spike amount added) for
each spiked sample of the treated residual. Once the recovery values are
determined, the following procedures are used to select the appropriate
percent recovery value to adjust the analytical data:
1-34
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1. If duplicate spike recovery values are available for the
constituent of interest, the data are adjusted by the lowest
available percent recovery value (i.e., the value that will
yield the most conservative estimate of treatment achieved).
However, if a spike recovery value of less than 20 percent is
reported for a specific constituent, the data are not used to
set treatment standards because the Agency does not have
sufficient confidence in the reported value to set a national
standard.
2. If data are not available for a specific constituent but are
available for an isomer, then the spike recovery data are
transferred from the isomer and the data are adjusted using the
percent recovery selected according to the procedure described
in (1) above.
3. If data are not available for a specific constituent but are
available for a similar class of constituents (e.g., volatile
organics, acid-extractable semivolatiles), then spike recovery
data available for this class of constituents are transferred.
All spike recovery values greater than or equal to 20 percent.
for a spike sample are averaged and the constituent
concentration is adjusted by the average recovery value. If
spiked recovery data are available for more than one sample, the
average is calculated for each sample and the data are adjusted
by using the lowest average value.
4. If matrix spike recovery data are not available for a set of
data to be used to calculate treatment standards, then matrix
spike recovery data are transferred from a waste that the Agency
believes is similar (e.g., if the data represent an ash from
incineration, then data from other incinerator ashes could be
used). While EPA recognizes that transfer of matrix spike
recovery data from a similar waste is not an exact analysis,
this is considered the best approach for adjusting the data to
account for the fact that most analyses do not result in
extraction of 100 percent of the constituent. In assessing the
recovery data to be transferred, the procedures outlined in (1),
(2), and (3) above are followed.
The analytical procedures employed to generate the data used to
calculate the treatment standards are listed in Appendix B of this
document. In cases where alternatives or equivalent procedures and/or
equipment are allowed in EPA's SW-846, Third Edition methods, the
1-35
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specific procedures and equipment used are documented. In addition, any
deviations from the SW-846, Third Edition methods used to analyze the
specific waste matrices are documented. It is important to note that the
Agency will use the methods and procedures delineated in Appendix B to
enforce the treatment standards presented in Section 7 of this document.
Accordingly, facilities should use these procedures in assessing the
performance of their treatment systems.
1.2.7 BOAT Treatment Standards for "Derived-From" and "Mixed" Wastes
(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.
1-36
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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
1-37
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separate treatability subcategorization). For the most part, these
residues will be less concentrated than the original listed waste. The
Agency's treatment standards also make a generous allowance for process
variability by assuming that all treatability values used to establish
the standard are lognormally distributed. The waste also might be
amenable to a relatively nonvariable form of treatment technology such as
incineration. Finally, and perhaps most important, the rules contain a
treatability variance that allows a petitioner to demonstrate that its
waste cannot be treated to the level specified in the rule (40 CFR Part
268.44(a)). This provision provides a safety valve that allows persons
with unusual waste matrices to demonstrate the appropriateness of a
different standard. The Agency, to date, has not received any petitions
under this provision (for example, for residues contaminated with a
prohibited solvent waste), indicating, in the Agency's view, that the
existing standards are generally achievable.
(3) Residues from managing listed wastes or that contain listed
wastes. The Agency has been asked if and when residues from managing
hazardous wastes, such as leachate and contaminated ground water, become
subject to the land disposal prohibitions. Although the Agency believes
this question to be settled by existing rules and interpretative
statements, to avoid any possible confusion the Agency will address the
question again.
1-38
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Residues from managing First Third wastes, listed California List
wastes, and spent solvent and dioxin wastes are all considered to be
subject to the prohibitions for the listed hazardous waste as originally
generated. Residues from managing California List wastes likewise are
subject to the California List prohibitions when the residues themselves
exhibit a characteristic of hazardous waste. This determination stems
directly from the derived-from rule in 40 CFR 261.3(c)(2) or, in some
cases, from the fact that the waste is mixed with or otherwise contains
the listed waste. The underlying principle stated in all of these
provisions is that listed wastes remain listed until delisted.
The Agency's historic practice in processing delisting petitions that
address mixing residuals has been to consider them to be the listed waste
and to require that delisting petitioners address all constituents for
which the derived-from waste (or other mixed waste) was listed. The
language in 40 CFR 260.22(b) states that mixtures or derived-from
residues can be delisted provided a delisting petitioner makes a
demonstration identical to that which a delisting petitioner would make
for the original listed waste. Consequently, these residues are treated
as the original listed waste for delisting purposes. The statute
likewise takes this position, indicating that soil and debris that are
contaminated with listed spent solvents or dioxin wastes are subject to
the prohibition for these wastes even though these wastes are not the
originally generated waste, but rather are a residual from management
(RCRA section 3004(e)(3)). It is EPA's view that all such residues are
1-39
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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
1-40
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expected to affect treatment selection. EPA has identified some of the
most important constituents and other parameters needed to select the
treatment technology appropriate for the given waste(s) in Section 3.
Second, when analysis suggests that an untested waste can be treated
with the same technology as a waste for which treatment performance data
are already available, EPA analyzes a more detailed list of
characteristics that the Agency believes will affect the performance of
the technology. By examining and comparing these characteristics, the
Agency determines whether the untested wastes will achieve the same level
of treatment as the tested waste. Where the Agency determines that the
untested waste can be treated as well or better than the tested waste,
the treatment standards can be transferred.
1.3 Variance from the BOAT Treatment Standard
The Agency recognizes that there may exist unique wastes that cannot
be treated to the level specified as the treatment standard. In such a
case, a generator or owner/operator may submit a petition to the
Administrator requesting a variance from the treatment standard. A
particular waste may be significantly different from the wastes on which
the treatment standards are based because the subject waste contains a
more complex matrix that makes it more difficult to treat. For example,
complex mixtures may be formed when a restricted waste is mixed with
other waste streams by spills or other forms of inadvertent mixing. As a
result, the treatability of the restricted waste may be altered such that
it cannot meet the applicable treatment standard.
1-41
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Variance petitions must demonstrate that the treatment standard
established for a given waste cannot be met. This demonstration can be
made by showing that attempts to treat the waste by available
technologies were not successful or by performing appropriate analyses of
the waste, including waste characteristics affecting performance, which
demonstrate that the waste cannot be treated to the specified levels.
Variances will not be granted based solely on a showing that adequate
BOAT treatment capacity is unavailable. (Such demonstrations can be made
according to the provisions in Part 268.5 of RCRA for case-by-case
extensions of the effective date.) The Agency will consider granting
generic petitions provided that representative data are submitted to
support a variance for each facility covered by the petition.
Petitioners should submit at least one copy to:
The Administrator
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
An additional copy marked "Treatability Variance" should be submitted
to:
Chief, Waste Treatment Branch
Office of Solid Waste (WH-565)
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, DC 20460
Petitions containing confidential information should be sent with
only the inner envelope marked "Treatability Variance" and "Confidential
Business Information" and with the contents marked in accordance with the
1-42
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requirements of 40 CFR Part 2 (41 FR 36902, September 1, 1976, amended by
43 FR 4000).
The petition should contain the following information:
1. The petitioner's name and address.
2. A statement of the petitioner's interest in the proposed action.
3. The name, address, and EPA identification number of the facility
generating the waste, and the name and telephone number of the
plant contact.
4. The process(es) and feed materials generating the waste and an
assessment of whether such process(es) or feed materials may
produce a waste that is not covered by the demonstration.
5. A description of the waste sufficient for comparison with the
waste considered by the Agency in developing BOAT, and an
estimate of the average and maximum monthly and annual
quantities of waste covered by the demonstration. (Note: The
petitioner should consult the appropriate BOAT background
document for determining the characteristics of the wastes
considered in developing treatment standards.)
6. If the waste has been treated, a description of the system used
for treating the waste, including the process design and
operating conditions. The petition should include the reasons
the treatment standards are not achievable and/or why the
petitioner believes the standards are based on inappropriate
technology for treating the waste. (Note: The petitioner should
refer to the BOAT background document as guidance for
determining the design and operating parameters that the Agency
used in developing treatment standards.)
7. A description of the alternative treatment systems examined by
the petitioner (if any); a description of the treatment system
deemed appropriate by the petitioner for the waste in question;
and, as appropriate, the concentrations in the treatment
residual or extract of the treatment residual (i.e., using the
TCLP, where appropriate, for stabilized metals) that can be
achieved by applying such treatment to the waste.
8. A description of those parameters affecting treatment selection
and waste characteristics that affect performance, including
results of all analyses. (See Section 3 for a discussion of
1-43
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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
1-44
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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. INDUSTRIES AFFECTED AND WASTE CHARACTERIZATION
According to 40 CFR 261.32, the following chlorine industry wastes
are subject to the land disposal restriction provisions of HSWA:
K071: Brine purification muds from the mercury cell process in
chlorine production, where separately prepurified brine is not
used.
K073: Chlorinated hydrocarbon waste from the purification step of
the diaphragm cell process using graphite anodes in chlorine
production.
K106: Wastewater treatment sludge from the mercury cell process in
chlorine production.
K071 waste is the subject of this background document.
This section discusses the industry affected by the land disposal
restrictions for K071 waste, describes the process generating the waste,
and presents a summary of available waste characterization data for the
waste.
2.1 Industries Affected and Process Description
Chlorine is produced primarily from the electrolytic decomposition of
either sodium chloride or potassium chloride, from which the coproducts
are sodium hydroxide (caustic soda) or potassium hydroxide. All of the
caustic soda and potassium hydroxide and over 90 percent of the chlorine
produced in the U.S. are made by the electrolytic decomposition of sodium
chloride or potassium chloride. Chlorine is also produced from the
nonelectrolytic oxidation of hydrochloric acid (HC1), from the production
of sodium metal, and from the electrolytic production of magnesium metal
from molten magnesium chloride.
2-1
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Three types of electrolytic cells are in commercial use for the
production of alkalies and chlorine: the mercury cell, the diaphragm
cell, and the membrane cell. The listed waste K071 is generated in
chlorine production by the mercury cell process. The Agency estimates
that there are 20 facilities producing chlorine by the mercury cell
process and that 14 of these facilities do not use prepurified brine and
therefore may generate K071 waste. The number and locations of these
facilities are provided in Table 2-1, listed by State, and in Table 2-2,
listed by EPA Region. Chlorine producers fall under Standard Industrial
Classification (SIC) Code 2812.
In chlorine production by the mercury cell process, a saturated salt
brine solution is prepared in a brine saturator tank by dissolving sodium
chloride, usually in the form of rock salt, into depleted brine solution
recycled from the mercury cells. The saturated solution then undergoes
brine purification, which removes impurities that were present in the raw
salt. In brine purification, hydroxides, carbonates, and/or sulfates are
added to remove calcium, magnesium, and iron impurities by
precipitation. After precipitation, the saturated solution is sent
through clarification and filtration, where the precipitated solids are
removed. The purified saturated brine is then fed to the mercury cells,
where electrolytic decomposition into sodium and chlorine occurs.
The K071 waste is generated from two sources in the brine
purification process: (1) the insoluble materials from the salt that
settle to the bottom of the brine saturator tank (these muds are commonly
2-2
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0341g
Table 2-1 Number of Producers of Chlorine Using the
Mercury Cell Process Listed by State
Number of
State producers3
Alabama (IVj
Delaware (II!)
Georgia (IV)
Kentucky (IV)
Louisiana (VI)
Maine (I)
New York (II)
North Carolina (IV)
Ohio (V)
Tennessee (IV)
Texas (VI)
Washington (X)
West Virginia (III)
Wisconsin (V)
Total
3
1
1 (1)
1
1 (1)
1
1 (1)
1
1
1
O.(l)
1
0 (2)
1
14(6)
^Numbers in parentheses are numbers of additional facilities that use
prepurified salt in the process and therefore do not currently generate
K071 waste.
Reference: SRI 1987.
2-3
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034 Ig
Table 2-2 Number of Producers of Chlorine Using
the Mercury Cell Process Listed by EPA Region
Number of
EPA Region producers3
I
II
111
IV
V
VI
X
1
1 (1)
1 (2)
7 (1)
2
1 (2)
1
Total 14 (6)
aNumbers in parentheses are numbers of additional facilities
that use prepurified salt in the process and therefore do not
currently generate K071 waste.
Reference: SRI 1987.
2-4
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referred to as saturator insolubles) and (2) the solids removed by
clarification and filtration.
2.2 Waste Characterization
This section includes all waste characterization data available to
the Agency for K071 waste. The major constituents and their approximate
concentrations are presented in Table 2-3. The ranges of concentrations
for the BOAT list constituents detected in the waste are presented in
Table 2-4.
2-5
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0341g
Table 2-3 Major Constituent Analysis of Untreated K071 Waste
Concentration (wt. %)
Major constituent
Calcium
Calcium carbonate
Calcium sulfate
Calcium chloride
Chloride
Graphite
Iron and aluminum hydroxides
Magnesium carbonate
Magnesium hydroxide
Sodium chloride
Sodium hydroxide
Sodium sulfate
Sulfate
Other solids
Water
BOAT metals
(1)
7.4
9.5
-
-
<0.1
0.3
<0.1
19.0
0.1
0.2
-
-
63.4
<0.1
(1) (2)
17
8.0
1.8
2.0
9.4
-
-
1.2
-
67.1
-
-
3.2
17.8
2.1 41
<0.1
(2) (2)
19.2-24.8 20
-
-
-
1.1-5.5
1.1-3.3 0.3
11-16.5
3.0
5.5-11
-
-
-
30
45 46.7
(3)a
30-40
50-60
-
-
-
-
-
-
5-15
-
-
-
-
-
Reported on a dry basis.
References:
(1) USEPA 1988a. Section 1.2.
(2) USEPA 1986a.
(3) Bennett 1986.
2-6
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1533g
Table 2-4 BOAT List Constituent Concentrations in Untreated K071 Waste
Constituents
Volatile Organic Compounds:
Bromodichloromethane
Bromoform ( tr ibromomethane)
Chlorodibromomethane
Chloroform
Metals:
Ant imony
Arsenic
Barium
Beryl 1 ium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Selenium
5 i Iver
Thai 1 ium
Vanadium
Zinc
- = Not analyzed.
ND = Not detected.
References:
(1) USEPA 1988a. Tables
(2) USEPA 1986a.
(3) Olin Chemicals 1988
(4) Bennett 1966.
ug/1
ug/1
ug/1
ug/1
mg/1
mg/1
mg/ 1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/1
mg/ 1
5-2 through 5-8,
(LDR7-00055).
(1)
62
550
170
200
ND
NO
0.57-1.
ND
ND
ND
ND
ND
17.0-22.
3.15-<6
ND
ND
Concentration
data source
(1) (2) (3) (4) (4)
<25 ....
<25 ....
<25 -
<25 ....
ND 10.0
ND ....
1 1.4 -
ND ....
ND 3.8
ND 5.9 -
1.19-<4.0 184.7
ND 47.8 -
1 1.12 73.8 4.4-172.8 14 2.2
.5 7.9 90.3
ND ....
ND ....
7.74-<43 ND ....
ND
2.29-3.
5-12. and
ND ....
18 2.5 128.0
5-14.
2-7
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3. APPLICABLE/DEMONSTRATED TREATMENT TECHNOLOGIES
This section identifies the applicable and demonstrated treatment
technologies for treatment of K071 waste. Detailed discussions are
provided for those technologies that are demonstrated. Information on
the applicable and demonstrated treatment technologies comes from
literature sources, engineering site visits, and industry submittals.
3.1 Applicable Treatment Technologies
The technologies that are considered to be applicable for treatment
of K071 waste are those that treat toxic metals (especially mercury, the
constituent for which the waste was listed) by reducing the metal
concentration and/or Teachability in the waste. For K071 nonwastewater,
the Agency has identified the following treatment technologies, either
alone or in combination, as being applicable: acid leaching, chemical
oxidation, sludge dewatering combined with either acid or water washing,
stabilization, and retorting. For K071 wastewater produced during
treatment or handling of K071 waste (e.g., wastewaters generated from
sludge dewatering), the Agency has identified chemical precipitation and
filtration as being applicable.
3.2 Demonstrated Treatment Technologies
The demonstrated technologies for K071 nonwastewater are acid
leaching, chemical oxidation, and sludge dewatering combined with either
acid or water washing. The Agency has identified two facilities that use
a treatment system consisting of acid leaching followed by chemical
oxidation and then sludge dewatering/acid washing; one facility that uses
acid leaching (percolation) alone; and three facilities that use sludge
3-1
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dewatering/water washing.
Stabilization is not currently being used to treat K071 waste or
wastes that are similar with regard to parameters that affect the
applicability of the technology. Retorting, the only remaining
applicable technology for the nonwastewater, is not currently being used
to treat K071 waste or similar wastes. Accordingly, EPA does not believe
that either of these technologies is demonstrated for K071.
For K071 wastewater, chemical precipitation followed by filtration is
demonstrated; several facilities treat K071 wastewater using this
technology.
Sludge dewatering/water washing, used alone to treat K071 at three
facilities identified by EPA, removes mercury present in the waste by
washing and separating liquids from the solid portion. The solid portion
is the treated K071 nonwastewater. The liquids removed are K071
wastewater.
The acid leaching, chemical oxidation, and sludge dewatering/acid
washing treatment system, used for treatment of K071 nonwastewaters at
two of the facilities identified by EPA, removes mercury from the waste
as soluble mercuric chloride, generating a nonwastewater residual with
reduced concentrations of hazardous metal constituents and a wastewater
containing the acid-leached metals. This wastewater requires further
treatment. A schematic diagram of this treatment system is provided in
Figure 3-1. In the acidification step, sulfuric acid is added to the
waste to reduce the pH. In a simultaneous reaction, the calcium in the
waste is precipitated as calcium sulfate (CaSO ). In the next process
3-2
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ANIONIC
FLOCCULANT
SULFURIC
ACID
SODIUM
HYPOCHLORITE
1
K071 WASTE
ACID
LEACHING
CHEMICAL
OXIDATION
\
i
*-
SLUDGE
DEWATERING
AND WASHING
K071
FILTRATE
HYDROCHLORIC ACID
AND
WATER WASH SPRAYS
J
TREATED
K071
NONWASTEWATER
CO
I
00
SODIUM
SULFIDE
K071
TREATED
WASTEWATER
PRESSURE
FILTRATION
\
\
OTHER
PROCESS
WASTEWATERS
SULFIDE
PRECIPITATION
FILTER CAKE:
K106
FIGURE 3-1 SCHEMATIC OF K071 WASTE TREATMENT PROCESS
-------
step, chemical oxidation, any elemental mercury present in the waste is
solubilized by reaction with sodium hypochlorite (NaOCl) to form mercuric
chloride (HgCl ). After chemical oxidation, the waste is fed to a
filter equipped with hydrochloric acid and water wash sprays, where the
solids are washed and dewatered.
The K071 wastewater, which contains dissolved mercury as HgCl , is
treated by sulfide precipitation and filtration. Mercury is removed as
the sulfide, HgS, in a wastewater treatment sludge listed as K106.
Overall, treatment of K071 waste results in the formation of a
treated solid residual from the sludge dewatering step and both a treated
wastewater and a solid residual from the sulfide precipitation/filtration
step. The treated residual from the sludge dewatering step is analyzed
to determine the performance of treatment for nonwastewater. The treated
wastewater from sulfide precipitation and filtration is analyzed to
determine the performance treatment for wastewater.
The following demonstrated technologies or treatment steps are
discussed in detail below: acid leaching, sludge filtration (sludge
dewatering), and chemical precipitation.
3.2.1 Acid Leaching
Acid leaching is a process that removes a soluble constituent or
constituents from a relatively insoluble solid phase by contacting the
solids with an acidic solution. The spent acid will concentrate the
leached constituent or constituents, and will then be subject to further
treatment. A treatment system for acid leaching usually consists of some
3-4
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type of solid/liquid contacting system followed by equipment for
solid/liquid separation.
(1) Applicability and use of acid leaching. Acid leaching can be
applied to treatment of wastes in solid or slurry form when the hazardous
constituents of the waste are soluble in a strong acid solution or can be
converted by reaction with a strong acid to a soluble form. It
frequently is used to remove metals from sludges.
(2) Underlying principles of operation. The underlying principle of
operation for acid leaching is that by lowering the pH of the waste,
metals can be concentrated in a solution passing through the waste
because of the higher solubility associated with acidic pH values.
In order to assure effective removal of metals, strong acids, such as
sulfuric (H SO ), hydrochloric (HC1), nitric (HNO ), and
hydrofluoric (HF), frequently are used. Separation of the liquids from
the treated solids can be accomplished either by designing solid/liquid
contacting equipment used in the leaching step to retain solids and
release liquids, or by additional separation steps such as filtration.
(3) Description of the acid leaching process. Acid leaching
processes can be categorized into two major types: (a) treatment by
percolation of the acid through the solids, and (b) treatment by
dispersion of the solids in the acid and then subsequent separation of
the solids from the liquid.
3-5
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(a) Percolation processes. Percolation is carried out in batch
tanks and in several designs of continuous percolation equipment. Batch
percolators are large tanks. The solids are placed in the tank and the
acid is fed onto the solids. The acid percolates through the solids and
drains out through screens or porous media in the tank bottom. The acid
may flow countercurrently through a series of tanks, with fresh acid
being added to the tank containing the most nearly exhausted solids.
Following treatment, the solids are removed.
Continuous percolation is carried out in moving-bed equipment, where
the acid normally flows countercurrently to the solids (see Figure 3-2).
The acid drains from each solids bed to the solids bed beneath.
(b) Dispersed-solids processes. Leaching by dispersion of fine
solids into the acid is performed in batch tanks or in a variety of
continuous devices. In the batch and continuous systems, the untreated
waste and the acid are mixed in the reaction tank. Following mixing, the
treated solids are separated from the acid; separation can be
accomplished either by settling or filtration, depending on the type and
concentration of solids involved. In both systems, sufficient acid must
be supplied to keep the pH at a level necessary to effectively leach the
metals from the waste.
(4) Waste characteristics affecting performance. In determining
whether an untested waste can be treated to the same level of performance
as a previously tested waste, the waste characteristics EPA will examine
for the acid leaching process are: (a) the solid particle size, (b) the
neutralizing capacity (or alkalinity) of the solids being treated, and
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SOLIDS
FEED
SPENT ACID
TO
TREATMENT
TREATED
SOLIDS
FIGURE 3-2
CONTINUOUS EXTRACTOR
3-7
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(c) the type and chemical form of the hazardous metal constituent(s) in
the waste.
(a) Particle size. The reaction rate of the acid with the
hazardous constituent(s) of the waste, and the rate of transport of acid
to and from the site of the hazardous constituent, are both affected by
the size of the solid particles. The smaller the particles, the more
rapidly they will leach because of the increased surface area that is
exposed to acid.
(b) Neutralizing capacity. The neutralizing capacity, or
alkalinity, of the solid affects the amount of acid that must be added to
the waste in order to achieve and/or maintain the desired reactor pH. In
addition to dissolving the waste contaminants, the acid also will
dissolve some of the alkali bulk solids. Therefore, highly alkaline
wastes require more acid or a stronger acid in order to maintain the pH
during treatment.
(c) Type and chemical form of hazardous metal constituent(s).
The type of metal(s) present will affect the degree to which acid
leaching will be effective. Different metals will have different
solubilities and thus impact the removal that can be achieved.
The chemical form of each of the hazardous metal constituents is also
important in determining the reactivity and/or solubility of the
constituent. For example, mercury may exist in waste as mercuric oxide
(HgO) or metallic mercury (Hg). Reaction with a strong acid and a source
of chloride will transform the less soluble HgO into the more soluble
mercuric chloride form (HgO + 2HC1 - HgCl + HO). This will
3-8
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allow removal of mercury present as HgO. Conversely, metallic mercury
(Hg) will not react with acid to form HgCl and will not leach.
(5) Design and operating parameters. The design and operating
parameters of an acid leaching system that affect performance are:
(a) contact time between the solid and the acid, (b) choice of acid used,
(c) pH, and (d) type of contactor used.
(a) Contact time. In continuous percolation systems, contact
time is usually specified by the design volume of the equipment or the
speed of the moving bed. For a given contact time, the performance of
either a continuous or a batch percolation system can be increased by
using a countercurrent flow of acid. In all acid leaching systems, the
extent of reaction and dissolution of the contaminant are directly
related to the contact time.
(b) Choice and concentration of acid used. If the hazardous
constituents to be removed in the acid leaching system are already
present in the waste in a soluble form, or are solubilized by pH
reduction, then any acid that will reduce the pH to the desired value may
be used. However, if chemical reaction is necessary to form the soluble
species, then the appropriate acid must be used at the proper
concentration. If selection of the acid will have an effect on the
nonhazardous constituents of the waste (i.e., the acid may precipitate an
alkali metal salt such as calcium sulfate), then an acid that produces a
waste that can be more effectively separated by a solid/liquid separation
device (such as a filter or a centrifuge) should be used.
3-9
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(c) pH. For dispersed-solids systems, the feed of acid to the
treatment reactor should be based on pH monitoring and control, since the
reaction rate is likely to be highly pH dependent. Because reaction rate
in acid leaching depends on pH, a pH should be selected, based on the
contact time and amount of the hazardous constituent(s) in the waste as
determined by laboratory testing, that provides for complete reaction in
the contact time provided. Also, the effect that the pH may have on the
composition or characteristics of the nonhazardous constituents of the
waste should be considered. For example, if maintenance of a certain pH
value leads to formation of solids that will allow the most efficient
solid/liquid separation after leaching is completed, then pH should be
maintained at this value.
For percolation systems, pH monitoring of the acid percolating
through the tank bottom should ensure that enough acid is being added.
If the pH is not low enough, additional acid may be added.
(d) Type of contactor used. The performance of an acid
leaching system depends on the type of contacting system used.
Additionally, acid leaching processes are affected by the number of
contacting stages and the type of flow pattern of the acid
(countercurrent or cocurrent).
3.2.2 Sludge Filtration
(1) Applicability and use of sludge filtration. Sludge filtration,
also known as sludge dewatering or cake-formation filtration, is a
technology used on wastes that contain high concentrations of suspended
solids, generally higher than 1 percent. The remainder of the waste is
3-10
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essentially water. Sludge filtration is applied to sludges, typically
those that have settled to the bottom of clarifiers, for dewatering.
After filtration, these sludges can be dewatered to 20 to 50 percent
solids.
(2) Underlying principles of operation. The basic principle of
filtration is the separation of particles from a mixture of fluids and
particles by a medium that permits the flow of the fluid but retains the
particles. As would be expected, larger particles are easier to separate
from the fluid than smaller particles. Extremely small particles, in the
colloidal range, may not be filtered effectively and may appear in the
treated waste. To mitigate this problem, the wastewater should be
treated prior to filtration to modify the particle size distribution in
favor of the larger particles, by the use of appropriate precipitants,
coagulants, flocculants, and filter aids. The selection of the
appropriate precipitant or coagulant is important because it affects the
particles formed. For example, lime neutralization usually produces
larger, less gelatinous particles than does caustic soda precipitation.
For larger particles that become too small to filter effectively because
of poor resistance to shearing, shear resistance can be improved by the
use of coagulants and flocculants. Also, if pumps are used to feed the
filter, shear can be minimized by designing for a lower pump speed or by
use of a low shear type of pump.
(3) Description of the sludge filtration process. For sludge
filtration, settled sludge is either pumped through a cloth-type filter
media (such as in a plate and frame filter that allows solid "cake" to
3-11
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build up on the media) or the sludge is drawn by vacuum through the cloth
media (such as on a drum or vacuum filter, which also allows the solids
to build). In both cases, the solids themselves act as a filter for
subsequent solids removal. For a plate and frame type filter, removal of
the solids is accomplished by taking the unit off line, opening the
filter, and scraping the solids off. For the vacuum type filter, cake is
removed continuously. For a specific sludge, the plate and frame type
filter will usually produce a drier cake than a vacuum filter. Other
types of sludge filters, such as belt filters, are also used for
effective sludge dewatering.
(4) Waste characteristics affecting performance. The following
characteristics of the waste will affect performance of a sludge
filtration unit: (a) size of particles and (b) type of particles.
(a) Size of particles. The smaller the particle size, the more
the particles tend to go through the filter media. This is especially
true for a vacuum filter. For a pressure filter (like a plate and
frame), smaller particles may require higher pressures for equivalent
throughput, since the smaller pore spaces between particles create
resistance to flow.
(b) Type of particles. Some solids formed during metal
precipitation are gelatinous in nature and cannot be dewatered well by
cake-formation filtration. In fact, for vacuum filtration a cake may not
form at all. In most cases, solids can be made less gelatinous by use of
the appropriate coagulants and coagulant dosage prior to clarification,
or after clarification but prior to filtration. In addition, the use of
3-12
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lime instead of caustic soda in metal precipitation will reduce the
formation of gelatinous solids. Also, the addition of filter aids, such
as lime or diatomaceous earth, to a gelatinous sludge will help
significantly. Finally, precoating the filter with diatomaceous earth
prior to sludge filtration will assist in dewatering gelatinous sludges.
(5) Design and operating parameters. For sludge filtration, the
following design and operating variables affect performance: (a) type of
filter selected, (b) size of filter selected, (c) feed pressure, and
(d) use of coagulants or filter aids.
(a) Type of filter. Typically, pressure type filters (such as
a plate and frame) will yield a drier cake than a vacuum type filter and
will also be more tolerant of variations in influent sludge
characteristics. Pressure type filters, however, are batch operations,
so that when cake is built up to the maximum depth physically possible
(constrained by filter geometry), or to the maximum design pressure, the
filter is turned off while the cake is removed. A vacuum filter is a
continuous device (i.e., cake discharges continuously), but will usually
be much larger than a pressure filter with the same capacity. A hybrid
device is a belt filter, which mechanically squeezes sludge between two
continuous fabric belts.
(b) Size of filter. As with in-depth filters, the larger the
filter, the greater its hydraulic capacity and the longer the filter runs
between cake discharge.
(c) Feed pressure. This parameter impacts both the design pore
size of the filter and the design flow rate. In treating waste, it is
3-13
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important that the design feed pressure not be exceeded; otherwise,
particles may be forced through the filter medium, resulting in
ineffective treatment.
(d) Use of coagulants. Coagulants and filter aids may be mixed
with filter feed prior to filtration. Their effect is particularly
significant for vacuum filtration since in a vacuum filter their use may
make the difference between no cake and a relatively dry cake. In a
pressure filter, coagulants and filter aids will also significantly
improve hydraulic capacity and cake dryness. Filter aids, such as
diatomaceous earth, can be precoated on filters (vacuum or pressure) for
sludges that are particularly difficult to filter. The precoat layer
acts somewhat like an in-depth filter in that sludge solids are trapped
in the precoat pore spaces. Use of precoats and most coagulants or
filter aids significantly increases the amount of sludge solids to be
disposed of. However, polyelectrolyte coagulant usage usually does not
increase sludge volume significantly because the dosage is low.
3.2.3 Chemical Precipitation
(1) Applicability and use of chemical precipitation. Chemical
precipitation is used when dissolved metals are to be removed from
solution. This technology can be applied to a wide range of wastewaters
containing dissolved BOAT list metals and other metals as well. This
treatment process has been practiced widely by industrial facilities
since the 1940s.
(2) Underlying principles of operation. The underlying principle of
chemical precipitation is that metals in wastewater are removed by the
3-14
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addition of a treatment chemical that converts the dissolved metal to a
metal precipitate. This precipitate is less soluble than the original
metal compound and therefore settles out of solution, leaving a lower
concentration of the metal present in the solution. The principal
chemicals used to convert soluble metal compounds to the less soluble
forms include lime (Ca(OH) ), caustic (NaOH), sodium sulfide (Na S),
and, to a lesser extent, soda ash (Na CO ), phosphate, and ferrous
sulfide (FeS).
The solubility of a particular compound will depend on the extent to
which the electrostatic forces holding the ions of the compound together
can be overcome. The solubility will change significantly with
temperature; most metal compounds are more soluble as the temperature
increases. Additionally, the solubility will be affected by the other
constituents present in a waste. As a general rule, nitrates, chlorides,
and sulfates are more soluble than hydroxides, sulfides, carbonates, and
phosphates.
An important concept related to treatment of the soluble metal
compounds is pH. This term provides a measure of the extent to which a
solution contains either an excess of hydrogen or hydroxide ions. The pH
scale ranges from 0 to 14, with 0 being the most acidic, 14 representing
the highest alkalinity or hydroxide ion (OH ) content, and 7.0 being
neutral.
When hydroxide is used, as is often the case, to precipitate the
soluble metal compounds, the pH is frequently monitored to ensure that
sufficient treatment chemicals are added. It is important to point out
3-15
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that pH is not a good measure of treatment chemical addition for
compounds other than hydroxides; when sulfide is used, for example,
facilities might use an oxidation-reduction potential meter (ORP)
correlation to ensure that sufficient treatment chemical is used.
Following conversion of the relatively soluble metal compounds to
metal precipitates, the effectiveness of chemical precipitation is a
function of the physical removal, which usually relies on a settling
process. A particle of a specific size, shape, and composition will
settle at a specific velocity, as described by Stokes' Law. For a batch
system, Stokes' Law is a good predictor of settling time because the
pertinent particle parameters remain essentially constant. Nevertheless,
in practice, settling time for a batch system is normally determined by
empirical testing. For a continuous system, the theory of settling is
complicated by factors such as turbulence, short-circuiting, and velocity
gradients, increasing the importance of the empirical tests.
(3) Description of the chemical precipitation process. The
equipment and instrumentation required for chemical precipitation varies
depending on whether the system is batch or continuous. Both operations
are discussed below; a schematic of the continuous system is shown in
Figure 3-3.
For a batch system, chemical precipitation requires only a feed
system for the treatment chemicals and a second tank where the waste can
be treated and allowed to settle. When lime is used, it is generally
added to the reaction tank in a slurry form. In a batch system, the
supernate is usually analyzed before discharge, thus minimizing the need
for instrumentation.
3-16
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WASTEWATER
FEED
CO
I
EQUALIZATION
TANK
1
f.
Q
X
9
j
7
^>
TREATMENT
CHEMICAL
FEED
SYSTEM
1 ,.
1 H
pH
MONITOR
PUMP
ATMENT
EMICAL
CEEO
rSTEM
COAGULANT OH
FLOCCULANT FEED SYSTEM
ELECTRICAL CONTROLS
WASTEWATER FLOW
MIXER
EFFLUENT TO
DISCHARGE OH
SUBSEQUENT
TREATMENT
^ SLUOQE TO
OEWATERINQ
FIGURE 3-3 CONTINUOUS CHEMICAL PRECIPITATION
-------
In a continuous system, additional tanks are necessary, along with
the instrumentation to ensure that the system is operating properly. In
this system, the first tank that the wastewater enters is referred to as
an equalization tank. This is where the waste can be mixed in order to
provide more uniformity, minimizing wide swings in the type and
concentration of constituents being sent to the reaction tank. It is
important to reduce the variability of the waste sent to the reaction
tank because control systems inherently are limited with regard to the
maximum fluctuations that can be managed.
Following equalization, the waste is pumped to a reaction tank where
treatment chemicals are added; this is done automatically by using
instrumentation that senses the pH of the system and then pneumatically
adjusts the position of the treatment chemical feed valve so that the
design pH value is achieved. Both the complexity and the effectiveness
of the automatic control system will vary depending on the variation in
the waste and the pH range that is needed to properly treat the waste.
It is important that the reaction tank be designed to assure that the
waste and treatment chemicals are dispersed throughout the tank; this
ensures commingling of the reactant and the treatment chemicals. In
addition, effective dispersion of the treatment chemicals throughout the
tank is necessary to properly monitor and thereby control the amount of
treatment chemicals added.
After the waste is reacted with the treatment chemical, it flows to a
quiescent tank where the precipitate is allowed to settle and
subsequently be removed. Settling can be chemically assisted through the
3-18
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use of flocculating compounds. Flocculants increase the particle size
and density of the precipitated solids, both of which increase the rate
of settling. The particular flocculating agent that will best improve
settling characteristics will vary depending on the particular waste;
selection of the flocculating agent is generally accomplished by
performing laboratory bench tests. Settling can be conducted in a large
tank by relying solely on gravity or can be mechanically assisted through
the use of a circular clarifier or an inclined separator. Schematics of
the two separators are shown in Figures 3-4 and 3-5.
Filtration can be used for further removal of precipitated residuals
both in cases where the settling system is underdesigned and in cases
where the particles are difficult to settle. Polishing filtration is
discussed in a separate technology section.
(4) Waste characteristics affecting performance. In determining
whether chemical precipitation is likely to achieve the same level of
performance on an untested waste as on a previously tested waste, the
following waste characteristics will be examined: (a) the concentration
and type of the metal(s) in the waste, (b) the concentration of total
suspended solids (TSS), (c) the concentration of total dissolved solids
(IDS), (d) whether the metal exists in the wastewater as a complex, and
(e) the oil and grease content. These parameters affect the chemical
reaction of the metal compound, the solubility of the metal precipitate,
or the ability of the precipitated compound to settle.
3-19
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EFFLUENT
SLUDGE
INFLUENT
CENTER FEED CLARIFIER WITH SCRAPER SLUDGE REMOVAL SYSTEM
SLUDGE
RIM FEED - CENTER TAKEOFF CLARIFIER WITH
HYDRAULIC SUCTION SLUDGE REMOVAL SYSTEM
SLUDGE
RIM FEED - RIM TAKEOFF CLARIFIER
EFFLUENT
INFLUENT
EFFLUENT
FIGURE 3-4 CIRCULAR CLARIFIERS
3-20
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INFLUENT
EFFLUENT
FIGURE 3-5
INCLINED PLATE SETTLER
3-21
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(a) Concentration and type of metals. For most metals, there is
a specific pH at which the metal hydroxide is least soluble. As a
result, when a waste contains a mixture of many metals, it is not
possible to operate a treatment system at a single pH that is optimal for
the removal of all metals. The extent to which this affects treatment
depends on the particular metals to be removed and their concentrations.
An alternative can be to operate multiple precipitations, with
intermediate settling, when the optimum pH occurs at markedly different
levels for the metals present. The individual metals and their
concentrations can be measured using EPA Method 6010.
(b) Concentration and type of total suspended solids (TSS).
Certain suspended solid compounds are difficult to settle because of
either their particle size or shape. Accordingly, EPA will evaluate this
characteristic in assessing transfer of treatment performance. Total
suspended solids can be measured by EPA Wastewater Test Method 160.2.
(c) Concentration of total dissolved solids (TDS). Available
information shows that total dissolved solids can inhibit settling. The
literature states that poor flocculation is a consequence of high TDS and
shows that higher concentrations of total suspended solids are found in
treated residuals. Poor flocculation can adversely affect the degree to
which precipitated particles are removed. Total dissolved solids can be
measured by EPA Wastewater Test Method 160.1.
(d) Complexed metals. Metal complexes consist of a metal ion
surrounded by a group of other inorganic or organic ions or molecules
(often called ligands). In the complexed form, the metals have a greater
3-22
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solubility and, therefore, may not be as effectively removed from
solution by chemical precipitation. EPA does not have an analytical
method to determine the amount of complexed metals in the waste. The
Agency believes that the best measure of complexed metals is to analyze
for some common complexing compounds (or complexing agents) generally
found in wastewater for which analytical methods are available. These
complexing agents include ammonia, cyanide, and EDTA. The analytical
method for cyanide is EPA Method 9010. The method for EDTA is ASTM
Method D3113. Ammonia can be analyzed using EPA Wastewater Test
Method 350.
(e) Oil and grease content. The oil and grease content of a
particular waste directly inhibits the settling of the precipitate.
Suspended oil droplets float in water and tend to suspend particles such
as chemical precipitates that would otherwise settle out of the
solution. Even with the use of coagulants or flocculants, the separation
of the precipitate is less effective. Oil and grease content can be
measured by EPA Method 9071.
(5) Design and operating parameters. The parameters that EPA will
evaluate when determining whether a chemical precipitation system is well
designed are: (a) design value for treated metal concentrations, as well
as other characteristics of the waste used for design purposes (e.g.,
total suspended solids), (b) pH, (c) residence time, (d) choice of
treatment chemical, and (e) choice of coagulant/flocculant. Below is an
explanation of why EPA believes these parameters are important to a
3-23
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design analysis; in addition, EPA explains why other design criteria are
not included in EPA's analysis.
(a) Treated and untreated design concentrations. EPA pays
close attention to the treated concentration the system is designed to
achieve when determining whether to sample a particular facility. Since
the system will seldom out-perform its design, EPA must evaluate whether
the design is consistent with best demonstrated practice.
The untreated concentrations that the system is designed to treat are
important in evaluating any treatment system. Operation of a chemical
precipitation treatment system with untreated waste concentrations in
excess of design values can easily result in poor performance.
(b) pH. The pH is important because it can indicate that
sufficient treatment chemical (e.g., lime) is added to convert the metal
constituents in the untreated waste to forms that will precipitate. The
pH also affects the solubility of metal hydroxides and sulfides, and
therefore directly impacts the effectiveness of removal. In practice,
the design pH is determined by empirical bench testing, often referred to
as "jar" testing. The temperature at which the "jar" testing is
conducted is important in that it also affects the solubility of the
metal precipitates. Operation of a treatment system at temperatures
above the design temperature can result in poor performance. In
assessing the operation of a chemical precipitation system, EPA prefers
continuous data on the pH and periodic temperature conditions throughout
the treatment period.
3-24
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(c) Residence time. The residence time is important because it
impacts the completeness of the chemical reaction to form the metal
precipitate and, to a greater extent, the amount of precipitate that
settles out of solution. In practice, it is determined by "jar"
testing. For continuous systems, EPA will monitor the feed rate to
ensure that the system is operated at design conditions. For batch
systems, EPA will want information on the design parameter used to
determine sufficient settling time (e.g., total suspended solids).
(d) Choice of treatment chemical. A choice must be made as to
what type of precipitating agent (i.e., treatment chemical) will be
used. The factor that most affects this choice is the type of metal
constituents to be treated. Other design parameters, such as pH,
residence time, and choice of coagulant/flocculant agents, are based on
the selection of the treatment chemical.
(e) Choice of coagulant/flocculant. This is important because
these compounds improve the settling rate of the precipitated metals and
allow for smaller systems (i.e., lower retention time) to achieve the
same degree of settling as a much larger system. In practice, the choice
of the best agent and the required amount is determined by "jar" testing.
(f) Mixing. The degree of mixing is a complex assessment that
includes, among other things, the energy supplied, the time the material
is mixed, and the related turbulence effects of the specific size and
shape of the tank. EPA will, however, consider whether mixing is
provided and whether the type of mixing device is one that could be
3-25
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expected to achieve uniform mixing. For example, EPA may not use data
from a chemical precipitation treatment system where an air hose was
placed in a large tank to achieve mixing.
3.2.4 Chemical Oxidation
(1) Applicability and use of chemical oxidation. Chemical oxidation
processes are used to oxidize a number of BOAT list organic compounds
including phenol and some substituted phenols. In addition, this process
is used to treat sulfide wastes by converting the sulfide to the
essentially insoluble sulfate form. The parameters that affect selection
of this technology include water content, filterable solids, and total
organic carbon content. The term chemical oxidation, as used in this
report, refers to the technology that is applicable only when treatment
can be conducted at ambient or near ambient pressure and temperature
conditions. When chemical oxidation is conducted at higher temperatures
and pressures, the process is referred to as wet air oxidation. This
latter technology is discussed separately. The processes described in
this section also do not include the oxidation of cyanides by similar
chemicals, which is also discussed separately.
(2) Underlying principles of operation. Some dissolved organic
compounds or sulfides can be chemically oxidized to yield carbon dioxide,
water, salts, or acids, and, in the case of sulfides, sulfates. The
principal oxidants are hypochlorate or free chlorine, hydrogen peroxide,
and chlorine dioxide. The reaction chemistry for each of these oxidants
is discussed below.
3-26
-------
(a) Oxidation with hypochlorite or free chlorine. This type of
oxidation is carried out using either sodium hypochlorite or free
chlorine. The reaction is normally conducted under slightly alkaline
conditions. Example reactions for the oxidation of phenol and sulfide
are shown below.
C6H5OH + 14NaOCl - 6C02 + 3H20 + 14NaCl
S= + 4NaOCl - S04= + 4NaCl.
(b) Peroxide oxidation. Peroxide also oxidizes the same
constituents (intermediate) under similar conditions. The relevant
reactions are:
S= + 4H202 - S04= + 4H20
C6H5OH + 14H202 - 6C02 + 17H20.
(c) Chlorine dioxide oxidation. Chlorine dioxide also oxidizes
the same pollutants under identical conditions. Chlorine dioxide first
hydrolyzes to form a mixture of chlorous (HC10 ) and chloric acids
(HC10 ). These acids act as the oxidants, as shown in the equations
below.
2C102 + H20 - HC102 + HC103
C6H5OH + 7HC102 - 6C02 + 3H20 + 7HC1
3C6H5OH + 14HC103 - 8C02 + 9H20 + 14HC1
3-27
-------
(3) Description of the chemical oxidation process. Chemical
oxidation can be accomplished by either a batch or a continuous process.
For batch treatment, the wastewater is transferred to a reaction tank
where the pH is adjusted and the oxidizing agent is added. In some
cases, the tank may be heated to increase the reaction rate. For most
operations, a slightly alkaline pH is used. It is important that the
wastewater in the tank be well mixed for effective treatment to occur.
After treatment, the wastewater is either directly discharged or
transferred to another process for further treatment.
In the continuous process, automatic instrumentation may be used to
control pH levels, reagent oxidation, and temperature. In both types of
processes, typical retention times are in the 60- to 120-minute range.
(4) Waste characteristics affecting performance. In determining
whether performance standards can be transferred from a previously tested
waste to an untested waste, EPA will examine the following waste
characteristics: (1) the concentration of other oxidizable contaminants
and (2) the presence of metal salts.
(a) Concentration of organic oxidizable compounds. The presence
of other oxidizable compounds in addition to the BOAT constituents of
concern will increase the demand for oxidizing agents and hence will
potentially reduce the effectiveness of the treatment process. As a
surrogate for the amount of oxidizable organics present, EPA will analyze
for total organic carbon (TOC).
3-28
-------
(b) Concentrations of metal salts (oxidizable compounds). Metal
salts, especially lead and silver salts, will react with the oxidizing
agent(s) to form metal peroxides, chlorides, hypochlorites, and/or
chlorates. Formation of these compounds can cause excessive consumption
of oxidizing agents and potentially interfere with the effectiveness of
treatment. Lead and silver salts can be analyzed by EPA Method 3050.
(5) Design and operating parameters. In assessing the effectiveness
of the design and operation of a chemical oxidation system, the
parameters that the Agency will examine are:
1. Retention time;
2. Type of oxidizing agent;
3. Mixing;
4. pH; and
5. Temperature.
(a) Retention time. The system must be designed to provide
enough retention time to ensure complete oxidation. For a batch system,
adequate retention time is provided by holding the treated batch until
the reaction nears completion prior to discharge. The reaction typically
requires from 1 to 2 hours to approach completion. The rate may be
increased somewhat by increasing the temperature if the reaction tank is
equipped with heating units. The tank size is determined by the amount
of waste treated per batch and the amount of oxidizing agent added. For
continuous systems, retention time is determined by the size of the tank
and the process flow rates of the waste treated. To ensure that the
system is operated at the design retention time, EPA will monitor the
waste feed rate.
3-29
-------
(b) Type of oxidizing agent. Several factors govern the choice
of oxidizing agents. The amount of oxidizing agent required to treat a
given amount of reducing compound will vary with the agent chosen.
Enough oxidant must be added to ensure complete oxidation; the specific
amount will depend on the type and chemistry of the reducing compounds in
the waste. Theoretically, the amount of oxidizing agent to be added can
be computed from process stoichiometry; in practice, a small excess of
oxidant should be used. In assessing the effectiveness of any chemical
oxidation system, EPA would want to know how a facility determines the
amount of oxidant to be added, as well as how the facility ensures that
\
the particular addition rate is maintained.
(c) Mixing. Process tanks must be equipped with mixers to ensure
that there is maximum contact between the reducing solution and the
oxidizing agent. Proper mixing also limits the production of any solid
precipitates from side reactions that may resist oxidation. In addition,
mixing provides an even distribution of the tank contents and a
homogeneous pH throughout the waste, thereby improving oxidation of
wastewater constituents. The quantifiable degree of mixing is a complex
assessment that includes the energy supplied, the time the material is
mixed, and the related turbulence effects of the specific size and shape
of the tank. EPA will, however, evaluate the degree of mixing
qualitatively by considering whether mixing is provided and whether the
type of mixing device is one that could be expected to achieve uniform
mixing.
3-30
-------
(d) pH. Operation at the optimal pH will maximize the chemical
oxidation by keeping the ions in solution and limiting the formation of
undesirable precipitates. The pH in batch processes should be monitored
at regular intervals during the reaction. The pH is controlled by the
addition of caustic, lime, or acid to the solution. In most cases, a
slightly alkaline pH is used. In a few cases involving the use of free
chlorine, slightly acidic pH values may be selected. In order to ensure
that the proper pH is maintained during treatment, EPA will continuously
monitor the pH.
(e) Temperature. Temperature is important because it affects the
rate of reaction and the solubility of the oxidizing agent. As the
temperature is increased, the required reaction time is reduced and the
solubility of the oxidizing agent will, in most instances, be increased.
EPA will monitor temperature during the treatment period to ensure that
the design value is achieved.
3-31
-------
4. PERFORMANCE DATA BASE
This section discusses the available performance data associated with
the demonstrated technologies for K071 waste. Performance data include
the constituent concentrations in untreated and treated waste samples,
the operating data collected during treatment of the sampled waste,
design values for the treatment technology, and data on waste
characteristics that affect performance. EPA has presented all such data
to the extent that they are available, in tables found at the end of this
section.
EPA's use of these data in determining the technology that represents
BOAT, and for developing treatment standards, is described in Sections 5
and 7, respectively.
4.1 Nonwastewater
At Plant A, the Agency collected seven sets of untreated K071 waste
and treated nonwastewater samples from a treatment system that consisted
of acid leaching, chemical oxidation, and sludge dewatering/acid washing
(as described in Section 3.2.1). The Agency also collected one set of
samples from treatment by a one-step acid leaching (percolation)
treatment process (see Section 3.2.1(3)). These data (designated as
Plant A.I data) are presented in Tables 4-1 and 4-2. These data show,
along with design and operating information, the total and TCLP leachate
concentrations of metals in both the untreated and treated matrices.
Note that the untreated concentration of mercury in the waste undergoing
treatment by one-step acid leaching was sufficiently low that EPA does
4-1
-------
not believe a performance evaluation would be meaningful. The untreated
TCLP leachate concentration for mercury was 0.0006 mg/1.
Industry provided the Agency with two additional groups of data for
treatment of the K071 waste using the first treatment system described
above. One group of data is also from Plant A (designated as Plant A.2
data) and consists of 379 data points for EP leachate concentrations of
mercury in the treated waste. The other group of data (designated as
Plant B data) consists of EP leachate results for mercury from 19 samples
of treated waste; the total concentration of mercury was measured in four
of the samples. These two groups of data are presented in Tables 4-3 and
4-4.
Additional data were submitted by industry for treatment of K071
nonwastewater by sludge dewatering/water washing. Table 4-5 presents
12 data sets submitted by Plant C, showing total and EP leachate
concentrations of metals (2 of the data sets indicate TCLP leachate
concentrations) in the treated residuals. Table 4-6 presents 24 data
sets of total and EP leachate concentrations of metals in the treated
residuals from Plant D. Another 232 data points showing EP leachate
concentrations of mercury in the treated waste were submitted by Plant
E. These data are shown in Table 4-7.
4.2 Wastewater
The Agency collected three samples each of untreated and treated
waste from treatment of K071 wastewater in a sulfide precipitation and
filtration treatment system at Plant A. The data from these samples are
presented in Table 4-8.
4-2
-------
0341g
Table 4-1 Acid Leaching, Chemical Oxidation, and Sludge Dewatering/Acid Washing Data
Collected by EPA at Plant A (Plant A.I Data)
Sample Set II
Concentration
Constituent
Barium
Cadmium
Copper
Lead
Mercury
Nickel
Thallium
Zinc
Untreated
Total
(mg/1)
0.57
<0.3
<0.8
<6.6
17.0
4.87
12.2
2.29
waste
TCLP
(mg/l)
0.31
<0.06
<0.16
<1.3
0.44
0.54
<1.7
0.11
Treated
Total
(mg/kg)
3.3
<1.5
<4.0
<33
2.7
24
62
5.4
waste
TCLP
(mg/1)
0.12
0.006
0.06
2.0
0.0003
0.08
0.25
0.21
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Acidification reactor pH 2.5 - 3.0
Hypochlorite reactor pH 6.5
Hypochlorite reactor residence time > 0.05 hr
Filter vacuum > 5.0 in Hg
2.94
6.4
0.25 hr
5.0 in Hg
Reference: USEPA 1988a. Tables 3-1 and 5-2.
4-3
-------
0341g
Table 4-1 (Continued)
Sample Set #2
Concentration
Untreated waste
Constituent
Barium
Cadmium
Copper
Lead
Mercury
Nickel
Thai! ium
Zinc
Note: Design
Parameter
Acidification
Hypochlorite
Hypochlorite
Fi Iter vacuum
Total
(mg/D
0.57
<0.3
<0.8
<6.6
17.0
4.87
12.2
2.29
and operating parameters
reactor pH
reactor pH
reactor residence time
TCLP
(mg/1)
0.31
<0.06
<0.16
<1.32
0.44
0.54
<1.7
0.11
are as follows:
Design value
2.5 - 3.0
6.5
> 0.05 hr
> 5.0 in Hg
Treated waste
Total TCLP
(mg/kg) (mg/1)
3.2 0.13
<1.5 0.04
<4.0 <0.08
<33 0.84
4.8 <0.0002
23 <0.13
51 <0.86
4.7 0.18
Operating value
2.95
6.4
0.25 hr
5.0 in Hg
Reference: USEPA 1988a. Tables 3-1 and 5-3.
4-4
-------
0341g
Table 4-1 (Continued)
Sample Set #3
Concentration
Constituent
Barium
Cadmium
Copper
Lead
Mercury
Nickel
Thall ium
Zinc
Untreated
Total
(mg/1)
0.814
<0.15
1.19
<3.3
22.1
3.15
7.74
3.18
waste
TCLP
(mg/1)
0.22
<0.3
<0.8
<6.6
20
<1.3
<8.6
0.92
Treated
Total
(mg/kg)
2.7
<1.5
<4.0
<33
1.8
21
51
3.9
waste
TCLP
(mg/1)
0.18
0.13
<0.16
<1.3
2.0
<0.26
<1.7
0.25
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Acidification
Hypochlorite
Hypochlorite
Fi Her vacuum
reactor
reactor
reactor
pH
PH
residence time
2.
6.
>
>
5 - 3.0
5
0.05 hr
5.0 in Hg
2.
6.
0.
7.
93
4
38
.0
hr
in Hg
Reference: USEPA 1988a. Tables 3-1 and 5-4.
4-5
-------
0341g
Table 4-1 (Continued)
Sample Set #4
Concentration
Constituent
Barium
Cadmium
Copper
Lead
Mercury
Nickel
Thall ium
Zinc
Untreated
Total
(mg/1)
0.814
<0.15
1.19
<3.3
22.1
3.15
7.74
3.18
waste
TCLP
(mg/1)
0.22
<0.3
<0.8
<6.6
20
<1.3
<8.6
0.92
Treated
Total
(mg/kg)
2.7
<3.0
<4.0
<33
1.7
20
<43
3.1
waste
TCLP
(mg/1)
0.16
<0.01
0.05
0.33
0.0002
0.13
<0.43
0.28
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Acidification reactor pH
Hypochlorite reaactor pH
Hypochlorite reactor residence time
Fi Her vacuum
2.5 - 3.0
6.5
> 0.05 hr
> 5.0 in Hg
2.93
6.4
0.36
7.0
hr
in Hg
Reference: USEPA 1988a. Tables 3-1 and 5-5.
4-6
-------
0341g
Table 4-1 (Continued)
Sample Set #5
Concentration
Constituent
Barium
Cadmium
Copper
Lead
Mercury
Nickel
Thall ium
Zinc
Untreated
Total
(mg/1)
0.814
<0.15
1.19
<3.3
22.1
3.15
7.74
3.18
waste
TCLP
(mg/1)
0.22
<0.3
<0.8
<6.6
20
<1.3
<8.6
0.92
Treated
Total
(mg/kg)
2.4
<1.5
<4.0
<33
1.2
21
43
5.0
waste
TCLP
(mg/1)
0.16
0.003
0.05
0.16
0.0005
0.07
0.26
0.23
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Acidification reactor pH
Hypochlorite reactor pH
Hypochlorite reactor residence time
Fi Iter vacuum
2.5 - 3.0
6.5
> 0.05 hr
> 5.0 in Hg
2.94
6.4
0.46
7.0
hr
in Hg
Reference: USEPA 1988a. Tables 3-1 and 5-6.
4-7
-------
0341g
Table 4-1 (Continued)
Sample Set #6
Concentration
Constituent
Ba r i urn
Cadmium
Copper
Lead
Mercury
Nickel
Thallium
Zinc
Untreated
Total
(mg/1)
1.1
<1.5
<4.0
<33
20.6
<6.5
<43
3.05
waste
TCLP
(mg/1)
0.34
<0.06
<0.16
<1.3
2.1
0.31
<1.7
0.37
Treated
Total
(mg/kg)
2.4
<1.5
<4.0
<33
1.8
22
<43
5.3
waste
TCLP
(mg/1)
0.14
<0.01
0.05
<0.33
0.0016
0.11
<0.43
0.41
Note: Design and operating parameters are as follows:
Parameter Design value Operating value
Acidification reactor pH 2.5 - 3.0 2.92
Hypochlorite reactor pH 6.5 6.4
Hypochlorite reactor residence time > 0.05 hr 0.30 hr
Filter vacuum > 5.0 in Hg 11 in Hg
Reference: USEPA 1988a. Tables 3-1 and 5-7.
4-8
-------
0341g
Table 4-1 (Continued)
Sample Set #7
Concentration
Constituent
Barium
Cadmium
Copper
Lead
Mercury
Nickel
Tha 1 1 i urn
Zinc
Untreated
Total
(mg/1)
1.1
<1.5
<4.0
<33
20.6
<6.5
<43
3.05
waste
TCLP
(mg/1)
0.34
<0.06
<0.16
<1.3
2.1
0.31
<1.7
0.37
Treated
Total
(mg/kg)
3.1
<1.5
<4.0
<33
1.7
24
<43
5.3
waste
TCLP
(mg/1)
0.16
<0.003
0.05
0.07
<0.0002
0.09
0.18
0.34
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Acidification reactor pH
Hypochlorite reactor pH
Hypochloride reactor residence time
Filter vacuum
2.5 - 3.0
6.5
> 0.05 hr
> 5.0 in Hg
2.91
6.4
0.31 hr
11 in Hg
Reference: USEPA 1988a. Tables 3-1 and 5-8.
4-9
-------
0341g
Table 4-2 Acid Leaching (Percolation) Data Collected by EPA
at Plant A (Plant A.I Data)
Sample Set #1
Concentrat ion
Untreated waste
Constituent
Barium
Cadmium
Copper
Lead
Mercury
Nickel
Si Iver
Thai 1 ium
Zinc
Note: Design
Parameter
Acidification
Retention time
Total
(mg/1)
1.4
<1.5
<4.0
<33
1.1
7.9
<2.5
<43
2.5
and operating parameters
pH 3
for acid leaching >3
TCLP
(mg/1)
0.2
0.09
<0.16
<1.3
0.0006
<0.26
0.45
<1.7
0.42
are as follows:
Design value
.0
.0 hrs
Treated waste
Total TCLP
(mg/kg) (mg/1)
2.2 0.18
<1.5 <0.06
<4.0 0.16
<33 1.3
1.6 0.0006
<6.5 0.46
<2.5 <0.25
<43 <1.7
1.8 0.18
Operating value
3.0
1.0 hr
Reference: USEPA 1988a. Tables 3-3 and 5-12.
4-10
-------
2145g
Table 4-3 Acid Leaching, Chemical Oxidation, and Sludge Oewatering/Acid Washing Data
Submitted by Plant A (Plant A.2 Data)
Sample
no.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
16
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
Treated mercury
concentration
EP (mg/1)
0.018
0.056
0.008
0.025
<0.002
<0.002
0.007
0.002
<0.002
0.012
0.003
0.004
0.002
<0.002
<0.002
<0.002
0.001
0.003
<0.001
<0.002
<0.002
<0.002
'0.002
<0.002
<0.001
<0.001
-0.002
<0.002
<0.002
<0.001
0.002
<0.001
<0.001
<0.001
-0.001
0.001
Disposition
code3
3
3
1
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Date sampled
11/18/86
11/21/66
11/23/86
11/24/86
11/25/86
11/25/66
11/26/86
11/27/86
11/28/86
11/29/66
11/30/86
11/30/86
12/01/86
12/04/86
12/05/66
12/06/86
12/09/86
12/09/86
12/10/86
12/11/86
12/12/86
12/13/86
12/14/86
12/15/86
12/17/86
12/17/66
12/18/66
12/21/86
12/21/86
12/23/66
12/25/86
12/25/86
12/26/86
12/27/66
12/28/86
12/29/86
Operating
Acidif icat ion
reactor pH
2.9-3.9
2.9
2.9
3.0-4.4
2.0
3.0-3.1
3.0
3.0
3.0-3.1
3.0
3.2
3.3
3.4
3.1-3.2
2.7-3.0
3.1
3.0-3.1
3.1
3.0
3.1
3.5-3.8
3.2-3.3
3.8
2.8-3.4
3.2
3.2
3.0-3.3
3.3
3.3
3.3
3.1-3.2
2.8-3.2
3.2
2.6-3.3
3.1-3.3
3.1-3.2
information
Hypochlorite
reactor pH
6.4
6.6
6.7
6.4-6.9
6.2
6.4-6.5
6.6
6.4
6.4-6.6
6.4
6.6
6.4
6.4-6.6
6.5-6.6
6.4
6.4
6.4
6.4
6.4
6.2-6.4
6.4-6.6
6.5-6.6
6.4
6.6
6.6
6.6
6.6
6.6
6.6
5.5
6.5-6.6
6.2-6.5
6.5-6.6
6.5
6.4-6.5
5.8-6.5
Filter
vacuum
(in Hg)
11
6
12
16-19
10-14
9-10
5
7
7-11
8
5
10
3
11-14
8-9
15-17
9-10
10-12
8
5-6
5-7
6-6
8
6-9
8-12
10
8-10
10
11
6-7
8-10
9-12
S-10
6-10
a-9
10-14
Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(2) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4)
transported to
licensed hazardous waste landfill for disposal.
The design values associated with these operating data are presented in Table 4-1.
4-11
-------
2145g
Table 4-3 (Continued)
Sample
no.
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
Treated mercury
concentration
EP (mg/1)
0.001
0.002
0.001
0.002
0.001
0.009
<0.001
0.012
0.001
<0.001
0.015
0.016
0.027
0.028
0.026
<0.001
-0.001
<0.001
0.001
<0.001
-o.ooi
<0.001
<0.001
<0.001
-0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
--o.ooi
0.001
0.004
<0.001
0.001
Disposition
codea
1
1
1
1
1
1
1
1
1
1
2
2
3
2
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Date sampled
12/31/86
01/01/87
01/01/87
01/04/87
01/04/87
01/06/87
01/07/87
01/08/87
01/09/87
01/11/87
01/12/87
01/12/87
01/12/S7
01/15/87
01/15/87
01/16/87
01/17/87
01/18/87
01/19/87
01/20/87
01/22/87
01/25/87
01/25/87
01/27/87
01/28/87
02/01/87
02/01/87
01/29/87
02/03/a7
02/05/87
02/08/87
02/06/87
02/09/87
02/10/87
02/12/87
02/15/87
02/15/87
02/16/87
02/18/87
02/18/87
02/22/87
Operating
Acidif icat ion
reactor pH
3.2
3.9
3.3
3.4
3.3
3.4-3.6
3.2-3.3
4.6
3.2
3.1-3.2
3.2
-
-
3.2-3.3
-
3.3
3.2-3.4
3.3-3.8
3.1-3.2
3.0-3.2
(Operating data
the remaining
informal ion
Hypochlorite
reactor pH
6.4
-
6.4
6.5
6.4
6.4-6.5
6.5
-
6.4-6.5
6.4-5.5
6.5
-
-
6.4-6.5
-
6.4
6.4
6.5
6.5
6.4
Filter
vacuum
(in Hg)
9-11
6
9
6
10
8
8
6
8
6-14
16-17
-
-
8-11
-
8-10
7-8
5-10
8-9
6-7
were not submitted for
treated data points. )
Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(2) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4)
transported to
licensed hazardous waste landfill for disposal.
The design values associated with these operating data are presented in Table 4-1.
4-12
-------
2145g
Table 4-3 (Continued)
Sample
no.
78
79
80
81
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
105
107
108
109
110
111
112
113
114
115
116
117
118
119
Treated mercury
concentrat ion
EP (mg/1)
0.001
0.004
<0.001
<0.001
<0.001
0.018
0.018
0.008
<0.001
0.001
0.001
0.007
0.017
<0.001
0.006
0.005
0.009
0.001
0.002
<0.001
0.002
0.002
0.004
0.002
0.002
0.001
0.001
0.001
0.005
0.005
0.003
0.003
0.002
<0.001
=0.001
<0.001
<0.001
0.001
-o.ooi
0.001
<0.001
<0.001
Disposition
code3
1
1
1
1
1
2
3
1
1
1
1
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Operating information
Fi Iter
Acidification Hypochlorite vacuum
Date sampled reactor pH reactor pH (in Hg)
02/22/87
02/24/87
02/25/87
03/01/87
02/28/87
03/02/87
03/02/87
03/03/87
03/04/87
03/05/87
03/07/87
03/08/87
03/08/87
03/08/87
03/10/87
03/11/87
03/14/87
03/15/87
03/13/87
03/17/87
03/18/87
03/19/87
03/22/87
03/22/87
03/24/87
03/26/87
03/29/87
03/30/87
04/01/87
04/03/87
04/05/87
04/05/87
04/07/87
04/08/87
04/10/87
04/11/87
04/12/87
04/13/87
04/18/87
04/17/87
' 04/16/87
04/16/87
Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(2) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4) transported to
licensed hazardous waste landfill for disposal.
JThe design values associated with these operating data are presented in Table 4-1.
/i. 1 o
-------
2145g
Table 4-3 (Continued)
Sample
no.
120
121
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
156
Treated mercury
concentration
EP (mg/1)
0.001
0.017
<0.001
0.003
0.006
<0.001
0.002
<0.001
<0.001
0.002
<0.001
<0.001
<0.001
0.001
<0.001
0.001
^0.001
<0.001
<0.001
<0.001
0.003
0.003
0.001
0.006
0.003
<0.001
0.001
--0.001
0.012
<0.001
<0.002
0.003
0.018
0.060
0.031
0.002
^0.001
<0.001
<0.001
Disposit ion
code3
1
2
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
2
3
3
1
1
1
1
Operating information
Filter
Acidification Hypochlorite vacuum
Date sampled reactor pH reactor pH (in Hg)
04/20/87
04/22/87
04/22/87
04/23/87
04/24/87
04/25/87
04/28/87
04/30/87
05/02/87
05/03/87
05/05/87
05/06/87
05/07/87
05/08/87
05/12/87
05/13/87
05/14/87
05/16/87
05/18/87
05/20/87
05/21/87
05/23/87
05/25/87
05/26/87
05/27/87
05/29/87
05/30/87
06/01/87
06/02/87
06/04/87
06/06/87
06/08/87
06/09/87
06/09/87
06/10/87
06/14/87
06/16/87
06/17/87
06/19/87
"'Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(2) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4) transported to
licensed hazardous waste landfill for disposal.
The design values associated with these operating data are presented in Table 4-1.
4-14
-------
14Sg
Table 4-3 (Continued)
Sample
no.
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
167
188
189
190
191
192
193
194
195
196
197
Treated mercury
concentration
EP (mg/1)
=0.001
0.001
0.060
0.031
0.021
0.011
<0.001
<0.001
0.016
0.008
0.007
<0.001
<0.001
0.013
0.032
0.017
0.006
0.007
0.001
<0.001
0.021
0.004
0.008
0.005
0.003
0.001
0.005
0.007
0.002
0.040
0.010
0.001
0.008
0.005
0.012
0.002
0.002
0.028
0.040
Disposition
code3
1
1
2
3
3
1
1
1
2
1
1
1
1
2
3
2
1
1
1
1
2
1
1
1
1
1
1
1
1
2
1
1
1
1
1
1
1
2
4
Operating information
Filter
Acidification Hypochlorite vacuum
Date sampled reactor pH reactor pH (in Hg)
06/21/87
06/23/87
06/24/87
06/24/87
06/25/87
06/26/87
06/28/87
06/29/87
07/01/87
06/30/87
07/04/87
07/05/87
07/05/87
07/06/87
07/07/87
07/08/87
07/08/87
07/08/87
07/09/87
07/12/87
07/11/87
07/11/87
07/13/87
07/14/87
07/19/87
07/21/87
07/22/87
07/24/87
07/25/87
07/26/87
07/26/87
07/28/87
08/01/87
08/02/87
08/04/87
08/05/87
08/07/87
08/09/87
08/09/87
Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(i?) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4) transported to
licensed hazardous waste landfill for disposal.
Tne design values associated with these operating data are presented in Table 4-1.
4-15
-------
El45g
Table 4-3 (Continued)
Sample
no.
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
233
234
235
236
Treated mercury
concentration
EP (mg/1)
0.022
0.011
0.240
0.032
0.031
0.014
0.003
0.003
0.012
0.008
0.002
0.007
0.005
0.003
0.012
0.004
0.004
<0.001
0.010
<0.001
0.002
0.150
0.010
0.010
0.005
0.002
0.002
0.002
0:005
0.014
0.001
0.003
0.068
0.003
<0.001
0.009
0.009
0.005
0.005
Disposition
code3
2
1
4
4
4
4
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
4
1
1
1
1
1
1
1
2
1
1
4
1
1
1
1
1
1
Operating information
Filter
Acidification Hypochlorite vacuum
Date sampled reactor pH reactor pH (in Hg)
08/12/87
08/12/87
08/14/87
08/17/87
08/23/87
08/23/87
08/24/87
08/25/87
08/24/87
08/17/87
08/27/87
08/27/87
09/06/87
09/07/87
09/05/87
09/09/87
09/09/87
09/10/87
09/11/87
09/12/87
09/13/87
09/14/87
09/15/87
09/14/87
09/17/87
09/18/87
09/19/87
09/20/87
09/20/87
09/20/87
09/20/87
09/21/87
09/21/87
09/22/87
09/23/87
09/25/87
09/28/87
10/01/87
10/03/87
Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(2) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4) transported to
licensed hazardous waste landfill for disposal.
The design values associated with these operating data are presented in Table 4-1.
4-16
-------
Table 4-3 (Continued)
Sample
no.
237
238
239
240
241
242
243
244
245
T46
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
272
273
274
275
Treated mercury
concentration
EP (mg/1)
0.003
0.002
0.008
0.002
0.008
0.032
0.012
0.011
0.003
0.006
0.028
0.003
0.001
0.006
-------
45g
Table 4-3 (Continued)
Sample
no.
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
312
313
314
Treated mercury
concentrat ion
EP (mg/1)
0.008
0.002
0.001
<0.001
<0.001
<0.001
0.001
0.006
0.004
0.010
0.002
0.003
0.004
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.008
<0.001
0.001
0.008
0.001
0.001
0.003
<0.001
0.002
<0.001
<0.001
<0.001
<0.001
0.002
0.008
Operating information
Fi Iter
Disposition Acidification Hypochlorite vacuum
code3 Date sampled reactor pH reactor pH (in Hg)
1 11/14/87
1 11/16/87
1 11/17/87
1 11/14/87
1 11/18/87
1 11/19/87
1 11/20/87
1 11/21/87
1 11/22/87
1 11/23/87
1 11/24/87
1 11/26/87
1 11/26/87
1 11/29/87
1 11/29/87
1 11/30/87
1 11/30/87
1 12/01/87
1 12/03/87
1 12/04/87
1 12/06/87
1 12/07/87
1 12/08/87
1 12/09/87
1 12/10/87
1 12/11/87
1 12/12/87
1 12/13/87
1 12/14/87
1 12/15/87
1 12/15/87
1 12/16/87
1 12/17/87
1 12/20/87
1 12/19/87
1 12/21/87
1 12/22/87
1 12/27/87
1 12/25/87
Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(2) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4) transported to
licensed hazardous waste landfill for disposal.
The design values associated with these operating data are presented in Table 4-1.
4-18
-------
>145g
Table 4-3 (Continued)
Sample
no.
315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
Treated mercury
concentration
EP (mg/1)
0.003
0.005
=0.001
<0.001
<0.001
<0.001
0.004
0.001
0.002
0.001
<0.001
=0.001
0.001
0.002
<0.001
0.002
<0.001
0.004
0.004
<0.001
0.500
0.001
0.001
=0.001
<0.001
<0.001
<0.001
--0.001
0.001
0.001
0.001
0.001
<0.001
0.001
0.001
<0.001
0.003
<0.001
<0.001
Oisposit ion
codea
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Operating information
Filter
Acidification Hypochlorite vacuum
Date sampled reactor pH reactor pH (in Hg)
12/26/87
12/28/87
12/30/87
12/30/87
01/02/88
01/04/88
01/05/88
01/07/88
01/10/88
01/11/88
01/12/88
01/13/88
01/16/88
01/15/88
01/18/88
01/20/88
01/21/88
01/22/88
01/24/88
01/25/88
01/26/88
01/28/88
01/30/88
01/28/88
02/01/88
02/02/88
02/03/88
02/05/88
02/07/88
02/07/88
02/08/88
02/10/88
02/11/88
02/12/88
02/13/88
02/15/88
02/16/88
02/17/88
02/18/88
^Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(2) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4) transported to
licensed hazardous waste landfill for disposal.
The design values associated with these operating data are presented in Table 4-1.
4-19
-------
Table 4-3 (Continued)
Sample
no.
354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
Treated mercury
concentration
EP (mg/1)
0.004
0.008
0.001
0.001
<0.001
0.008
=0.001
<0.001
0.004
0.002
0.001
<0.001
-0.001
<0.001
0.001
<0.001
<0.001
<0.001
--0.001
0.001
<0.001
<0.001
0.001
0.003
0.011
0.002
Disposition
code3
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Operating information
Filter
Acidification Hypochlorite vacuum
Date sampled reactor pH reactor pH (in Hg)
02/21/88
02/20/88
02/19/88
02/23/88
02/24/88
02/25/88
02/28/88
02/26/88
03/01/88
03/02/88
03/05/88
03/05/88
03/04/88
03/07/88
03/06/88
03/08/88
03/10/88
03/13/88
03/12/88
03/16/88
03/17/88
03/20/88
03/18/88
03/22/88
03/23/88
03/24/88
Disposition codes as defined by the facility are as follows: (1) transported to sanitary landfill for disposal;
(L) reanalyzed because of suspected contamination; (3) returned to treatment system for reprocessing; and (4) transported to
licensed hazardous waste landfill for disposal.
''The design values associated with these operating data are presented in Table 4-1.
4-20
-------
Table 4-4 Acid Leaching. Chemical Oxidation, and Sludge Dewatenng/Acid Washing Data Submitted by Plant B
i
ro
Treated
mercury concentration (ppm)
Sample
no. Total
1
2
3
4 7.38
5 8.68
6 27.54
7 13.45
8
9
10
11
12
13
14
15
16
17
18
19
EP
0.0047
0.0206
0.0054
0.0030
0.0096
0.0092
0.0085
0.0175
0.0164
0.0098
0.0140
0.0113
0.0131
0.0710
0.0480
0.0090
0.0220
0.0661
0.0067
Operat >ng information3
Date sampled
1/13/88
1/13/88
1/15/88
1/19/68
1/20/88
1/20/68
1/21/68
1/21/86
2/05/66
2/11/88
2/18/88
4/15/68
4/15/88
4/21/68
4/21/88
4/22/88
4/22/88
5/02/86
5/03/88
Acidif icat ion
reactor pH
3.6
3.8
2.8
-
2.2
2.3
2.2
2.1
2.6
2.8
3.0
2.1
-
2.0
2.0
2.0
-
2.5
2.9
Hypochlor ite
reactor pH
6.6
6.8
6.4
-
7.8
7.4
7.6
7.4
7.6
7.4
6.0
6.9
-
6.8
6.9
7.2
6.8
7.1
7.2
Hypochlor ite
reactor residence
time (min)
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
20-40
Filter
vacuum
(in Hg)
9-12
9-12
9-12
9-12
9-12
9-12
9-12
9-12
9-12
7-9
7-9
7-9
7-9
7-9
7-9
7-9
7-9
7-9
7-9
The design values associated with these data are assumed to be similar to the design values presented in Table 4-1.
Reference: B.F. Goodrich 1968 (LORU-L0011).
-------
Table 4-5 Sludge Dewatering/Water Washing Data Submitted by Plant Ca
Treated waste concentration (nonwastewater)
Sample set
Constituent Measurement
Arsenic Total (mg/kg)
EP (mg/1)
Barium Total (mg/kg)
EP (mg/1)
Cadmium Total (mg/kg)
EP (mg/1)
Chromium Total (mg/kg)
EP (mg/1)
ro Lead Total (mg/kg)
"^ EP (mg/1)
Mercury Total (mg/kg)
EP (mg/1)
Nickel Total (mg/kg)
EP (mg/1)
Selenium Total (mg/kg)
EP (mg/1)
Silver Total (mg/kg)
EP (mg/1)
#1
3.7
<0.005 (<0.005)
34
0.4 (<0.005)
1.4
0.016 (0.01)
13
<0.005 (<0.005)
42
0.08 (0.09)
150
0.013 (0.014)
11
0.06
<0.5
<0.005 (<0.005)
0.51
<0.005 (<0.005)
#2
4.3
<0.005
37
0.33
1.3
0.009
16
<0.005
48
0.06
120
0.014
12
0.05
<0.5
<0.005
0.58
<0.005
*3
0.82
<0.005
6.3
<0.30
1.1
0.008
3.9
<0.005
10
0.06
78
0.018
2.0
0.06
<0.5
<0.005
0.89
<0.005
#4
0.49
<0.005
3.9
0.30
3.4
0.009
4.3
<0.005
4.9
<0.03
60
0.013
2.0
0.02
<0.5
<0.005
<0.5
<0.005
15
1.1
<0.005
16
<0.30
3.0
0.009
15
<0.005
25
0.31
82
0.024
8.4
0.08
<0.5
<0.005
<0.5
<0.005
16
1.4
<0.005
15
<0.30
2.0
<0.006
26
0.11
32
0.07
95
0.021
12
0.06
<0.5
<0.005
<0.5
<0.005
aDesign and operating data are not available.
-------
Table 4-5 (Continued)
Treated waste concentration (nonwastewater)
Sample set
Constituent
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Nickel
Selenium
Si Iver
Measurement
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
7
<0
200
0
5
0
700
0
38
0
240
0
<0.
«0.
4.
<0.
100
0.
17
.7
.005
.52
.2
.012
.010
.09
on
5
005
7
005
40
7
<0
67
<0
3
0
430
0
42
0
92
0
<0
<0
0
<0
44
0
#8
.5
.005
.30
.5
.012
.019
.08
.003
.5
.005
.80
.005
.12
n
25
<0.005
71
<0.30
3.9
0.009
390
<0.005
62
0.11
78
<0.0005
<0.5
<0.005
<0.5
<0.005
56
1.2
6
<0
110
<0
1
<0
760
0
110
0
72
0.
<0.
<0.
<0.
<0.
260
0.
110
.8
.005
.30
.3
.006
.018
.08
.0082
5
005
5
005
44
111
53
<0.005
57
<0.30
<0.50
<0.006
540
0.011
41
0.10
53
0.0007
<0.5
<0.005
<0.5
<0.005
50
0.10
5
<0
120
<0
0
0
820
<0
30
0
150
<0
<0
<0
<0
<0.
48
0
#12
.0
.005 (<0.005)
.30 (0.40)
.53
.014 (0.017)
.005 (<0.005)
.10 (0.06)
.0005 (<0.0005)
.5
.005
.5
.005 (<0.005)
.23 (0.80)
Design and operating data are not available.
Note: Numbers in parentheses under sample sets #1 and #6 are TCLP leachate concentrations.
Reference: Occidental Chemical Corporation 1987a.
-------
Table 4-6 Sludge Oewatering/Water Washing Data Submitted by Plant Oa
Treated waste concentration (nonwastewater )
Sample set
Constituent
Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Nickel
Selenium
Si Iver
Measurement
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
Total (mg/kg)
EP (mg/1)
11
0.46
<0.005
35
on
0.02
<0.008
7.5
<0.005
82
0.10
5.7
<0.002
<0.46
<0.005
<0.46
<0.005
14
0.10
*2
0.73
<0.005
45
0.19
<0.73
<0.008
6.7
<0.005
86
0.11
6.2
<0.002
<0.52
<0.005
<0.52
<0.005
11
0.12
#3
<0.52
<0.005
86
0.24
<0.73
<0.008
6.6
<0.005
97
0.12
6.5
<0.005
<0.52
<0.005
<0.52
<0.005
13
0.15
#4
0.70
<0.005
81
<0.20
0.71
<0.008
6.3
«0.006
69
0.14
5.9
<0.005
<0.50
<0.005
<0.50
<0.005
12
0.13
15
0.63
<0.005
15
0.05
<0.63
<0.008
7.0
<0.005
41
0.12
3.9
<0.005
<0.45
<0.005
<0.45
<0.005
4.4
<0.07
#6
0.54
<0.005
97
0.02
<0.76
<0.008
6.8
<0.005
86
0.10
3.3
<0.005
<0.54
<0.005
<0.54
<0.005
11
0.12
Design and operating data are not available.
-------
Table 4-6 (Continued)
Treated waste concentration (nonwastewater)
Sample set
Constituent Measurement
Arsenic Total (mg/kg)
EP (mg/1)
Barium Total (mg/kg)
EP (mg/1)
Cadmium Total (mg/kg)
EP (mg/1)
Chromium Total (mg/kg)
EP (mg/1)
ro Lead Total (mg/kg)
01 EP (mg/1)
Mercury Total (mg/kg)
EP (mg/1)
Nickel Total (mg/kg)
EP (mg/1)
Selenium Total (mg/kg)
EP (mg/1)
Silver Total (mg/kg)
EP (mg/1)
"
<0.58
<0.005
180
0.30
<0.81
<0.008
7.6
0.006
110
0.10
4.2
<0.005
<0.58
<0.005
<0.58
<0.005
13
0.17
#8
0.61
<0.005
82
0.43
<0.71
<0.008
6.8
<0.005
72
0.10
4.9
<0.005
<0.51
<0.005
<0.51
<0.005
7.1
0.09
19
<0.40
<0.005
33
<0.02
0.78
<0.008
6.5
<0.005
96
0.06
4.2
<0.005
<0.40
<0.005
<0.40
<0.005
19
0.19
110
0.96
<0.005
39
<0.02
0.74
<0.008
6.6
<0.005
110
0.10
3.6
<0.005
<0.48
<0.005
<0.48
<0.005
21
0.28
111
0.89
<0.005
29
<0.02
1.3
<0.008
6.7
<0.005
85
0.11
4.0
<0.005
<0.80
<0.005
<0.80
<0.005
15
0.12
#12
1.1
<0.005
22
0.11
0.84
<0.008
6.6
<0.005
94
0.09
2.9
<0.005
0.54
<0.005
0.54
<0.005
16
0.19
-------
Table 4-6 (Continued)
Treated waste concentration (nonwastewater)
Sample set
Constituent Measurement
Arsenic Total (mg/kg)
EP (mg/1)
Barium Total (mg/kg)
EP (mg/1)
Cadmium Total (mg/kg)
EP (mg/1)
Chromium Total (mg/kg)
EP (mg/1)
-p.
ro Lead Total (mg/kg)
^ EP (mg/1)
Mercury Total (mg/kg)
EP (mg/1)
Nickel Total (mg/kg)
EP (mg/1)
Selenium Total (mg/kg)
EP (mg/1)
Silver Total (mg/kg)
EP (mg/1)
#13
6.0
<0.005
70
0.05
<0.63
<0.008
17
<0.005
330
0.35
3.5
0.0080
<0.47
<0.005
<0.47
<0.005
92
0.66
#14
7.7
<0.005
56
0.11
<0.71
<0.008
16
<0.005
340
0.77
3.7
0.0063
<0.51
<0.005
<0.51
<0.005
76
0.63
#15
15
<0.005
60
0.27
<0.78
<0.008
17
<0.005
340
0.40
4.8
<0.032
<0.56
<0.005
<0.56
<0.005
81
0.79
#16
<0.51
<0.005
24
0.21
<0.71
<0.008
11
<0.005
170
0.08
2.3
0 . 0080
<0.51
<0.005
<1.6
<0.005
69
0.22
#17
2.5
<0.005
7.9
0.11
<0.69
<0.008
5.7
<0.005
100
0.11
6.9
<0.002
<0.49
<0.005
<0.49
<0.005
30
0.14
#18
7.3
<0.005
42
<0.04
<0.77
<0.008
16
<0.005
200
0.10
11
0.0093
<0.95
<0.005
<0.95
<0.005
95
0.16
-------
Table 4-6 (Continued)
Treated waste concentration (nonwastewater)
Sample set
Constituent Measurement
Arsenic Total (mg/kg)
EP (mg/1)
Barium Total (mg/kg)
EP (mg/1)
Cadmium Total (mg/kg)
EP (mg/1)
Chromium Total (mg/kg)
EP (mg/1)
i
r\i Lead Total (mg/kg)
^ EP (mg/1)
Mercury Total (mg/kg)
EP (mg/1)
Nickel Total (mg/kg)
EP (mg/1)
Selenium Total (mg/kg)
EP (mg/1)
Silver Total (mg/kg)
EP (mg/1)
119
6.1
<0.005
98
<0.02
<0.70
<0.008
19
<0.005
310
0.36
2.0
0.013
<0.50
<0.005
<0.50
<0.005
77
0.46
#20
7.9
<0.005
79
0.38
<0.70
<0.008
20
<0.005
430
0.33
9.6
0.014
<0.52
<0.005
<0.52
<0.005
220
1.22
121
<0.6
<0.005
<3.0
<0.03
0.73
<0.005
0.10
0.007
79
0.15
5.5
0.0008
<3
<0.03
<0.6
<0.005
1.3
<0.005
122
<0.6
<0.005
<3.0
<0.03
<0.70
0.005
0.78
<0.005
42
0.17
1.8
«0.0005
<3
<0.04
<0.6
<0.005
<0.6
<0.005
123
<0.6
<0.005
<3.0
<0.03
0.73
<0.005
0.62
0.007
34
0.11
3.0
<0.0005
6.2
0.03
<0.6
<0.005
0.83
<0.005
124
<0.6
<0.005
50
0.06
0.50
<0.005
0.10
0.006
42
0.12
3.4
<0.0005
3.0
<0.03
<0.6
<0.005
<0.6
<0.005
Design and operating data are not available.
Reference: Occidental Chemical Corporation 1987b.
-------
1558g
Table 4-7 Sludge Dewatering/Water Washing Data Submitted by Plant Ea
Sample no.
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
Treated
mercury concentration
EP (mg/1)
0.013
0.005
0.017
0.020
0.048
0.070
0.002
0.008
0.013
0.010
0.009
0.004
<0.002
0.008
0.004
0.003
0.012
0.007
0.011
0.006
0.001
0.009
0.002
0.001
0.003
0.004
<0.001
0.009
0.003
0.015
0.006
0.009
0.008
0.005
0.011
0.014
0.010
0.002
0.005
0.012
0.002
Sampling
quarter
3rd '87
2nd '87
a
'Design and operating data are not available.
4-28
-------
1558g
Table 4-7 (Continued)
Sample no.
42
43
44
45
46
47
46
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
Treated
mercury concentration Sampling
EP (mg/1) quarter
0.010
<0.001
0.010
<0.001
0.001
<0.001
0.002
0.004
0.003
0.022
0.006
0.005
0.015 1st '87
0.030
0.013
0.018
0.024
0.010
<0.001
0.012
0.017
0.009
0.006
0.001
0.001
0.011
0.012
0.007
0.006
0.016
0.040
0.010
0.016
0.024
0.021
0.010
0.013
<0.001
0.014
0.012
4-29
-------
1558g
Table 4-7 (Continued)
Sample no.
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
115
116
117
118
119
120
121
122
Treated
mercury concentration
EP (mg/1)
0.027
0.020
0.010
0.023
0.046
0.005
0.025
0.036
0.024
0.009
0.012
0.030
0.039
0.036
0.033
0.049
0.035
0.037
0.030
0.009
0.006
0.009
0.006
0.016
0.009
0.014
0.010
0.008
0.007
0.006
0.006
<0.001
0.003
0.009
0.021
0.006
0.027
0.035
0.028
0.029
0.034
Sampling
quarter
4th '86
3rd '86
4-30
-------
1558g
Table 4-7 (Continued)
Sample no.
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
Treated
mercury concentration Sampling
EP (mg/1) quarter
<0.001
0.013
0.007
0.014
0.056
0.037
0.026
0.016
0.023
0.037
0.037
0.039
0.001
0.039
0.002
0.041
0.072
0.005
0.107
0.036
0.008
0.039
0.014 2nd '86
0.005
0.034
0.004
0.002
0.004
0.008
0.066
0.001
0.004
<0.001
0.002
0.007
0.005
0.018
0.022
0.031
0.014
0.091
4-31
-------
1558g
Table 4-7 (Continued)
Sample no.
164
165
166
167
168
169
170
171
172
173
174
175
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
Treated
mercury concentration
EP (mg/1)
0.037
0.164
0.005
0.008
0.004
0.005
0.091
0.011
0.038
0.090
0.065
0.007
0.012
0.020
0.016
0.030
0.114
0.169
0.051
0.012
0.045
0.037
0.027
0.029
0.055
0.115
0.041
0.030
0.033
0.025
0.022
0.040
0.001
0.038
0.016
0.020
0.021
0.038
0.039
0.027
0.023
Sampling
quarter
1st '86
4th '85
4-32
-------
1558g
Table 4-7 (Continued)
Sample no.
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
Treated
mercury concentration Sampling
EP (mg/1) quarter
0.015
0.026
0.023
0.029
0.010
0.023
0.023
0.027
0.032
0.028
0.035
0.027
0.031
0.064
0.031
0.022
0.025
0.035
0.050
0.031
0.026
0.042
0.063
0.044
0.043
0.053
0.022
0.017
aDesign and operating data are not available.
Reference: Bennett 1986.
4-33
-------
1412g
Table 4-8 Chemical Precipitation and Filtration Data Collected
by EPA at Plant A
Sample Set #1
Constituent
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Silver
Vanadium
Zinc
Untreated
wastewater
(mg/D
<0.2
0.248
<0.03
<0.06
0.097
<0.66
23.7
0.157
0.148
<0.04
0.615
Filter cake
Total
(nig/kg)
1.1
74
2.3
6.3
133
50
25.900
14
131
0.46
443
(K106)a
TCLP
(mg/1)
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Treated
wastewater
(mg/1)
<0.2
0.103
<0.06
0.553
<0.16
<1.32
0.028
0.275
<0.1
<0.08
0.047
Note: Design and operating parameters are as follows:
Parameter Design value
Operating value
Excess sulfide
>40 mg/1
85 mg/1
aOnly one sample was collected of the filter cake (K106).
Reference: USEPA 1988a. Tables 3-2 and 5-9.
4-34
-------
1412g
Table 4-8 (Continued)
Sample Set #2
Constituent
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Si Iver
Vanadium
Zinc
Note: Design and operating
Parameter
Excess sulfide
Untreated
wastewater
(mg/1)
<0.1
0.226
<0.06
0.189
<0.16
<1.32
9.25
<0.26
0.1
<0.08
0.88
parameters are as
Design
>40 mg/1
Fi Iter cake
Total
(mg/kg)
1.1
74
2.3
6.3
133
50
25.900
14
131
0.46
443
follows:
value
(K106)a
TCLP
(mg/1)
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Operating value
101 mg/1
Treated
wastewater
(mg/1)
<0.1
0.158
<0.06
<0.12
<0.16
<1.32
0.027
<0.26
<0.1
<0.08
<0.04
aOnly one sample was collected of the filter cake (K106).
Reference: USEPA 1988a. Tables 3-2 and 5-10.
4-35
-------
1412g
Table 4-8 (Continued^
Sample Set #3
Constituent
Arsenic
Barium
Cadmium
Chromium
Copper
Lead
Mercury
Nickel
Si Iver
Vanadium
Zinc
Note: Design and
Parameter
Excess sulfide
Untreated
wastewater
(mg/1)
<0.1
0.293
<0.06
<0.12
<0.16
<1.32
77.2
<0.26
0.12
<0.08
0.535
operating parameters are as
Design
>40 mg/ 1
Ft Iter cake
Total
(mg/kg)
1.1
74
2.3
6.3
133
50
25.900
14
131
0.46
443
follows:
value
(K106)a
TCLP
(mg/1)
<0.01
0.74
0.02
<0.01
<0.02
0.13
0.01
0.15
<0.02
<0.01
1.7
Operating
96 mg/
Treated
wastewater
(mg/1)
<0.1
0.144
<0.06
<0.12
<0.16
<1.32
0.028
<0.26
<0.1
<0.08
0.064
value
1
aOnly one sample was collected of the filter cake (K.106).
Reference: USEPA 1988a. Tables 3-2 and 5-11.
4-36
-------
5. IDENTIFICATION OF BEST DEMONSTRATED AVAILABLE TECHNOLOGY (BOAT)
This section explains EPA's determination of the best demonstrated
available technology (BOAT) for K071 waste. As discussed in Section 1,
the BOAT for a waste must be the "best" of the "demonstrated"
technologies; the BOAT must also be "available." In general, the
technology that constitutes "best" is determined after screening the
available performance data from each technology, adjusting these data for
accuracy, and comparing the performance of each technology to that of the
others. If only one technology is identified as demonstrated, this
technology is considered "best." To be "available," a technology
(1) must be commercially available and (2) must provide substantial
treatment.
5.1 Nonwastewater
The Agency has performance data showing treatment of K071
nonwastewater from two technologies: (1) acid leaching followed by
chemical oxidation and then sludge dewatering/acid washing, and
(2) sludge dewatering/water washing.
Data from the first technology include the EPA-collected data at
Plant A, Plant A.I data (see Table 4-1); the data submitted by Plant A,
Plant A.2 data (see Table 4-3); and the data submitted by Plant B (see
Table 4-4). For the second technology, data are available from Plants C
(see Table 4-5), D (see Table 4-6), and E (see Table 4-7).
5-1
-------
In screening these data, EPA examined the associated design and
operating data, quality assurance/quality control (QA/QC) information,
and the measure of performance (e.g., total constituent concentration or
TCLP leachate concentration).
Design and operating information that accompanies the Plant A.I,
Plant B, and 56 of the 379 data points from the Plant A.2 data show that
these data reflect well-designed and well-operated systems. Design and
operating data are not available for the remainder of the Plant A.2 data
or for data from Plants C, D, and E.
The concentrations of mercury in analyzed samples from Plants A.2, B,
and E data are assumed to have been adjusted prior to being submitted to
the Agency. As discussed later in Section 6, mercury is the only
selected regulated constituent in K071 waste. Recoveries for mercury in
the QA/QC information, used for adjusting the mercury data for accuracy,
are available for Plants A, C, and D. This information is presented in
Appendix B.
The measure of performance for mercury in K071 nonwastewater is its
concentration in the leachate from the TCLP. TCLP data are available
only for the data collected by EPA at Plant A and for data submitted by
Plant C (2 of 12 mercury results are reported as TCLP leachate
concentrations from the latter plant). The remaining data are reported
as total or EP leachate concentrations. Normally, the EP leachate data
would not be considered in the development of a treatment standard to be
regulated as a TCLP concentration. However, industry-submitted data
5-2
-------
indicate that for mercury in K071 nonwastewater there is no statistical
difference between the values obtained from the two types of measurement
(see Appendix C).
During the screening of all 673 TCLP and EP nonwastewater data points
for mercury, the Agency eliminated 34--1 from Table 4-1 and 33 from
Table 4-3. The Table 4-1 data point from Plant A (Sample Set #3) was
discarded because the leachate concentration was higher than the
corresponding total waste concentration, an indication of error in either
sampling or analysis. Of the 33 discarded data points from Table 4-3,
the 31 data points marked with disposition codes 2 and 3 were not
considered further because of suspected sample contamination or because
the waste was returned to the treatment system for reprocessing, an
indication of poor operation. The other two data points from Table 4-3
were discarded because the Agency determined they were representative of
poor operation. (Operating information was not actually available for
the last two eliminated data points. EPA's determination of poor
operation was based on the fact that the concentrations of mercury in the
EP leachates were greater than the highest mercury concentration observed
(0.070 mg/1) in the acid leaching, oxidation, sludge dewatering/acid
washing data that meet the well-designed and well-operated criteria.)
In cases where data showing treatment are available for more than one
technology, the Agency performs an analysis of variance (ANOVA) test (see
Appendix A) to determine which technology performs significantly better
than the others. The usable performance data must be corrected for
accuracy before performing the ANOVA test. Basically, the adjustment
5-3
-------
involves multiplying the treatment value by an accuracy-correction
factor, the reciprocal of the percent recovery. The procedure for
selecting the appropriate percent recovery is discussed in detail in
Section 1.2. Tables 5-1 and 5-2 present the accuracy-corrected mercury
data. Percent recoveries are presented in Appendix B.
For K071 waste, an ANOVA test was performed on the treated TCLP and
EP mercury data from treatment by acid leaching followed by chemical
oxidation and then dewatering/acid washing (6 data points from the Plant
A.I data, 346 from the Plant A.2 data, and 19 from the Plant B data) and
from treatment by dewatering/water washing (12 data points from Plant C,
24 from Plant D, and 232 from Plant E). Results of the ANOVA test are
presented in Table 5-3. Results indicate that the "best" demonstrated
technology is acid leaching followed by chemical oxidation and sludge
dewatering/acid washing.
Treatment by acid leaching followed by chemical oxidation and then
sludge dewatering/acid washing is considered "available" because (1) all
three processes in the system are commercially available and (2) the
treatment substantially diminishes the toxicity of the waste and
substantially reduces the likelihood that hazardous constituents will
migrate from the waste. For example, as shown by the Plant A.I data, the
TCLP leachate mercury concentrations ranging from 0.44 to 20 ppm fell to
less than 0.0017 ppm (corrected for accuracy). (For the Plant A.2 and B
data, untreated waste concentrations were not available.)
5-4
-------
Having shown the technology to be "best," "demonstrated," and
"available" for K071 nonwastewater, EPA considers acid leaching followed
by chemical oxidation and then sludge dewatering/acid washing to be BOAT.
5.2 Vlastewater
For metals in K071 wastewater, the demonstrated treatment technology
is chemical precipitation followed by filtration. Performance data are
available for chemical precipitation, using sulfide as the treatment
chemical, and filtration, as discussed in Sections 3 and 4. The
performance data meet the screening criteria outlined in Section 1.2.
The Agency does not expect that the use of other treatment chemicals
would improve the level of performance. Thus, chemical precipitation,
using sulfide, followed by filtration is "best."
Chemical precipitation, using sulfide, followed by filtration is
"available" because such treatment is commercially available and provides
substantial treatment for K071 wastewater. EPA's determination of
substantial treatment is based on the fact that the concentrations of
mercury were reduced to less than 0.030 mg/1 (corrected for accuracy)
from 9.25 to 77.2 mg/1 in the untreated wastewater. The
accuracy-corrected data are presented in Table 5-4.
As chemical precipitation followed by filtration is "best,"
"demonstrated," and "available" for K071 wastewater, the treatment is
BOAT.
5-5
-------
1412g
Table 5-1 Accuracy-Corrected Mercury Data for Acid Leaching, Chemical Oxidation,
and Sludge Oewatering/Acid Washing
Data source
Plant A.I
Sample
no.
1
2
3a
4
5
6
7
Treated TCLP or
EP concentration
(ntg/1)
0.0003
<0.0002
2.0
0.0002
0.0005
0.0016
<0.0002
Accuracy-correct ion
factor
1/0.95
1/0.95
-
1/0.95
1/0.95
1/0.95
1/0.95
Accuracy-corrected
data (mg/1)
0.0003
<0.0002
-
0.0002
0.0005
0.0017
<0.0002
Plant A.2C
lc
2C
3
4C
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
0.018
0.056
0.008
0.025
<0.002
<0.002
0.007
0.002
<0.002
0.012
0.003
0.004
0.002
<0.002
<0.002
<0.002
0.001
0.003
<0.001
<0.002
<0.002
<0.002
<0.002
<0.002
<0.001
<0.001
<0.002
<0.002
<0.002
<0.001
0.002
Data point was eliminated because of suspected sampling or analytical error.
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
C0ata points were eliminated under disposition code 2 or 3 (see text).
5-6
-------
141Zg
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47C
48C
49C
50C
51C
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/1)
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
0.002
0.001
0.002
0.001
0.009
<0.001
0.012
0.001
<0.001
0.015
0.016
0.027
0.028
0.026
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<'0.001
<0.001
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy. t
C0ata points were eliminated under disposition code 2 or 3 (see text).
5-7
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 72
73
74
75
76
77
78
79
80
81
82
83C
84C
85
86
87
88
89
90C
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/1)
<0.001
<0.001
0.001
0.004
<0.001
0.001
0.001
0.004
<0.001
<0.001
<0.001
0.018
0.018
0.008
<0.001
0.001
0.001
0.007
0.017
<0.001
0.006
0.005
0.009
0.001
0.002
<0.001
0.002
0.002
0.004
0.002
0.002
0.001
0.001
0.001
0.005
0.005
0.003
0.003
0.002
<0.001
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
C0ata points were eliminated under disposition code 2 or 3 (see text).
5-8
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 112
113
114
115
116
117
118
119
120
121C
122
123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/1)
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.001
0.017
<0.001
0.003
0.006
<0.001
0.002
<0.001
<0.001
0.002
<0.001
<0.001
<0.001
0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.003
0.003
0.001
0.006
0.003
<0.001
0.001
<0.001
0.012
<0.001
<0.002
0.003
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
Data points were eliminated under disposition code 2 or 3 (see text).
5-9
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 152C
153C
154C
155
156
157
158
159
160
161C
162C
163C
164
165
166
167C
168
169
170
171
172C
173C
174C
175
176
177
178
179C
180
181
182
183
184
185
186
187
188C
189
190
191
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/1)
0.018
0.060
0.031
0.002
<0.001
<0.001
<0.001
<0.001
0.001
0.060
0.031
0.021
0.011
<0.001
<0.001
0.016
0.008
0.007
<0.001
<0.001
0.013
0.032
0.017
0.006
0.007
0.001
<0.001
0.021
0.004
0.008
0.005
0.003
0.001
0.005
0.007
0.002
0.040
0.010
0.001
0.008
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
C0ata points were eliminated under disposition code 2 or 3 (see text).
5-10
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 192
193
194
195
196C
197
198C
199
200d
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219d
220
221
222
223
224
225
226
227C
228
229
230
231
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (ntg/1)
(mg/D
0.005
0.012
0.002
0.002
0.028
0.040
0.022
0.011
0.240
0.032
0.031
0.014
0.003
0.003
0.012
0.008
0.002
0.007
0.005
0.003
0.012
0.004
0.004
<0.001
0.010
<0.001
0.002
0.150
0.010
0.010
0.005
0.002
0.002
0.002
0.005
0.014
0.001
0.003
0.068
0.003
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
C0ata points were eliminated under disposition code 2 or 3 (see text).
Data points were eliminated because of poor operation determination (see text).
5-11
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266C
267
268
269
270
271C
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/1)
<0.001
0.009
0.009
0.005
0.005
0.003
0.002
0.008
0.002
0.008
0.032
0.012
0.011
0.003
0.006
0.028
0.003
0.001
0.006
<0.001
--0.001
<0.001
0.001
0.003
0.006
0.002
0.001
0.010
0.006
0.005
0.011
0.007
0.011
0.002
0.012
0.004
0.021
0.005
0.003
0.026
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
C0ata points were eliminated under disposition code 2 or 3 (see text).
5-12
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 272
273
274
275C
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
313
314
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/D
0.009
0.004
0.004
0.016
0.008
0.002
0.001
<0.001
<0.001
<0.001
0.001
0.006
0.004
0.010
0.002
0.003
0.004
<0.001
<0.00l
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.008
<0.001
0.001
0.008
0.001
0.001
0.003
<0.001
0.002
<0.001
<0.001
<0.001
0.002
0.008
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
"Data points were eliminated under disposition code 2 or 3 (see text).
5-13
-------
U12g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 315
316
317
318
319
320
321
322
323
324
325
326
327
328
329
330
331
332
333
334
335C
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(rag/D
0.003
0.005
<0.001
<0.001
<0.001
<0.001
0.004
0.001
0.002
0.001
<0.001
<0.001
0.001
0.002
=0.001
0.002
<0.001
0.004
0.004
<0.001
0.500
0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
0.001
0.001
0.001
<0.001
0.001
0.001
<0.001
0.003
<0.001
<0.001
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
C0ata points were eliminated under disposition code 2 or 3 (see text).
5-14
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant A.2b 354
355
356
357
358
359
360
361
362
363
364
365
366
367
366
369
370
371
372
373
374
375
376
377
378
379
Plant Bb 1
2
3
4
5
6
7
8
9
10
11
12
13
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/D
0.
0.
0.
0.
<0.
0.
004
008
001
001
001
008
<0.001
<0.
0.
0.
0.
<0.
<0.
<0.
0.
<0.
<0.
<0.
<0.
0.
<0.
<0.
0.
0.
0.
0.
0.
0.
0.
0.
0.
0
o.
0
0
0
0
0
0
001
004
002
001
001
001
001
001
001
001
001
001
001
001
.001
001
.003
Oil
,002
,0047
,0208
.0054
0030
.0096
.0092
.0085
.0175
.0164
.0098
.0140
.0113
.0131
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
5-15
-------
1412g
Table 5-1 (Continued)
Data source Sample
no.
Plant Bb 14
15
16
17
16
19
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor data (mg/1)
(mg/D
0.0710
0.0480
0 . 0090
0.0220
0.0661
0.0087
aData point eliminated because of suspected sampling or analytical error.
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
C0ata points were eliminated under disposition code 2 or 3 (see text).
Data points were eliminated because of poor operation determination (see text).
5-16
-------
1412g
Table 5-2 Accuracy-Corrected Mercury Data for Sludge Dewatering/Water Washing
Data source Sample
no.
Plant C 1
2
3
4
5
6
7
8
9
10
11
12
Plant D 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
Treated TCLP or
EP concentration
(mg/D
0.013
0.014
0.018
0.013
0.024
0.021
0.011
0.003
<0.0005
0.0082
<0.0007
<0.0005
<0.002
<0.002
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.008
0.0063
0.032
0.0080
<0.002
0.0093
0.013
0.014
0.0008
<0.0005
«0.0005
<0.0005
Accuracy-correct ion
factor
1/1.12
1/1.17
1/1.04
1/1.12
1/0.81
1/0.79
1/0.76
1/1.05
1/1.19
1/0.80
1/0.98
1/0.99
1/0.93
1/0.93
1/0.96
1/0.98
1/1.04
1/1.01
1/1.03
1/1.01
1/1.02
1/1.03
1/1.01
1/1.02
1/0.93
1/0.94
1/0.82
1/0.87
1/0.92
1/0.82
1/0.80
1/0.83
1/1.07
1/1.02
1/1.02
1/1.04
Accuracy-corrected
data (mg/1)
0.012
0.020
0.017
0.012
0.030
0.027
0.014
0.003
<0.0004
0.0103
<0.0007
<0.0005
<0.002
<0.002
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
<0.005
0.009
0.007
0.039
0.009
<0.002
0.011
0.016
0.017
=0.0007
<0.0005
<0.0005
<0.0005
5-17
-------
1412g
Table 5-2 (Continued)
Data source Sample
no.
Plant Ed 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor values (mg/1)
(mg/1)
0.013
0.005
0.017
0.020
0.048
0.070
0.002
0.008
0.013
0.010
0.009
0.004
<0.002
0.008
0.004
0.003
0.012
0.007
0.011
0.006
0.001
0.009
0.002
0.001
0.003
0.004
<0.001
0.009
0.003
0.015
0.006
0.009
0.008
0.005
0.011
0.014
0.010
0.002
0.005
0.012
0.002
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
5-18
-------
1412g
Table 5-2 (Continued)
Data source Sample
no.
Plant Ea 42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
72
73
74
75
76
77
78
79
80
81
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor values (mg/1)
(mg/1)
0.010
<0.001
0.010
<0.001
0.001
<0.001
0.002
0.004
0.003
0.022
0.006
0.005
0.015
0.030
0.013
0.018
0.024
0.010
<0.001
0.012
0.017
0.009
0.006
0.001
0.001
0.011
0.012
0.007
0.006
0.016
0.040
0.010
0.016
0.024
0.021
0.010
0.013
<0.001
0.014
0.012
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
5-19
-------
UlZg
Table 5-2 (Continued)
Data source Sample
no.
Plant Ea 82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
111
112
113
114
. 115
116
117
118
119
120
121
122
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor values (mg/1)
(mg/1)
0.027
0.020
0.010
0.023
0.046
0.005
0.025
0.036
0.024
0 . 009
0.012
0.030
0.039
0.036
0.033
0.049
0.035
0.037
0.030
0.009
0.006
0.009
0.006
0.016
0.009
0.014
0.010
0.008
0.007
0.006
0.006
<0.001
0.003
0.009
0.021
0.006
0.027
0.035
0.028
0.029
0.034
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
5-20
-------
1412g
Table 5-2 (Continued)
Data source Sample
no.
Plant Ed 123
124
125
126
127
128
129
130
131
132
133
134
135
136
137
138
139
140
141
142
143
144
145
146
147
148
149
150
151
152
153
154
155
156
157
158
159
160
161
162
163
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor values (mg/1)
(mg/D
<0.001
0.013
0.007
0.014
0.056
0.037
0.026
0.016
0.023
0.037
0.037
0.039
0.001
0.039
0.002
0.041
0.072
0.005
0.107
0.036
0.008
0.039
0.014
0.005
0.034
0.004
0.002
0.004
0.008
0.066
0.001
0.004
<0.001
0.002
0.007
. 0.005
0.018
0.022
0.031
0.014
0.091
aData were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
5-21
-------
1412g
Table 5-2 (Continued)
Data source Sample
no.
Plant Ea 164
165
166
167
166
169
170
171
172
173
174
175
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
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor values (mg/1)
(mg/D
0.037
0.164
0.005
0.008
0.004
0.005
0.091
0.011
0.038
0.090
0.065
0.007
0.012
0.020
0.016
0.030
0.114
0.169
0.051
0.012
0.045
0.037
0.027
0.029
0.055
0.115
0.041
0.030
0.033
0.025
0.022
0.040
0.001
0.038
0.016
0.020
0.021
0.038
0.039
0.027
0.023
aOata were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
5-22
-------
1412g
Table 5-2 (Continued)
Data source Sample
no.
Plant Ea 205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
232
Treated TCLP or Accuracy-correction Accuracy-corrected
EP concentration factor values (mg/1)
(mg/1)
0.015
0.026
0.023
0.029
0.010
0.023
0.023
0.027
0.032
0.028
0.035
0.027
0.031
0.064
0.031
0.022
0.025
0.035
0.050
0.031
0.026
0.042
0.063
0.044
0.043
0.053
0.022
0.017
Data were not accompanied by recovery information for mercury; data are assumed to be
corrected for accuracy.
5-23
-------
1412g
Table 5-3 Results of ANOVA Test for Demonstrated Technologies for
K.071 Nonwastewater
Summary statistics:
Technology
ld
2b
Standard
Data count Mean deviation
371 0.0043 0.0079
268 0.0206 0.235
Minimum Maximum
0.0002 0.0710
0.0004 0.1690
Analysis of variance results:
Source
Between groups
Within groups
Total
Degree of
freedom
1
638
639
Sum of Mean of
squares squares
414.6216 414.6216
792.3055 1.2418
1204.7222
Critical
F ratio value
332.0964 3.84
''Technology 1 is acid leaching followed by chemical oxidation and then sludge dewatering/acid
washing.
Technology 2 is sludge dewatering/water washing.
Note: Since the F ratio exceeds the critical value, the means of the two groups of data are
significantly different. Technology 1 is considered best because its mean is lower.
5-24
-------
1412g
Table 5-4 Accuracy-Corrected Mercury Data for Chemical
Precipitation and Filtration
Sample
Data source no.
Treated total
concentration
(mg/1)
Accuracy-correct ion
factor
Accuracy-correct ion
value (mg/1)
Plant A.I
0.028
0.027
0.028
1/0.95
1/0.95
1/0.95
0.0295
0.0284
0.0295
5-25
-------
6. SELECTION OF REGULATED CONSTITUENTS
As discussed in Section 1, the Agency has developed a list of
hazardous constituents (see Table 1-1) from which the constituents to be
regulated are selected. EPA may revise 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 for K071. The process involves developing a list of
potential regulated constituents and then eliminating those constituents
that would not be treated by the chosen BOAT or that would be controlled
by regulation of the remaining constituents.
6.1 Identification of BOAT List Constituents in K071 Waste
As discussed in Sections 2 and 4, the Agency has characterization
data as well as performance data from treatment of K071 waste. All these
data, along with information on the waste generating process, have been
used to determine which BOAT list constituents may be present in the
waste and thus which are potential candidates for regulation in K071
nonwastewater and wastewater.
Table 6-1 indicates, for the untreated waste, which constituents were
analyzed, which constituents were detected, and which constituents the
Agency believes are likely to be present though not detected.
Concentrations are shown for constituents that were detected.
6-1
-------
Under the column "Believed to be present," constituents other than
those detected in the untreated waste are marked with X or Y if EPA
believes they are likely to be present in the untreated waste. For those
constituents marked with X, an engineering analysis of the waste
generating process indicates that they are likely to be present
(e.g., the engineering analysis shows that a particular constituent is a
major raw material). Those constituents marked with Y have been detected
in the treated residual(s) and thus EPA believes that they are present in
the untreated waste. Constituents may not have been detected in the
untreated waste for one of several reasons: (1) none of the untreated
waste samples were analyzed for these constituents, (2) masking or
interference by other constituents prevented detection, or (3) the
constituent indeed was not present. (With regard to Reason (3), it is
important to note that some wastes are defined as being generated from a
process. The process may utilize variable starting materials composed
of different constituents; therefore, all potentially regulated
constituents would not be present in any given sample.)
As shown in Table 6-1, four volatile organics and ten metals were
detected in untreated samples. Three additional metals were found in the
treated residuals and therefore are believed to be present in the waste.
These 17 constituents are the potential candidates for regulation in K071
waste.
6.2 Constituent Selection
Of the 17 candidates for regulation, EPA is regulating mercury. The
performance data for nonwastewater indicate that the regulation of
6-2
-------
mercury will ensure that barium and nickel concentrations are reduced in
the TCLP leachate. EPA believes that the other ten metals may be present
in treatable concentrations, but at the respective total or TCLP/EP
concentrations, only copper and zinc would be treated by any of the
demonstrated technologies for K071 nonwastewater or K071 wastewater. The
Agency is not regulating copper and zinc in K071 waste. (These metals are
regulated only when they serve as indicators of performance, as explained
in the preamble to the final rule for First Thirds wastes.) The four
organics were found in one sample at concentrations ranging from 0.062 to
0.550 mg/kg. These constituents are not being regulated because the EPA
has no data on K071 waste or any similar waste from which the Agency
believes performance data can be transferred.
Note that 136 of the 231 BOAT list constituents were not analyzed.
These include 90 volatile and semivolatile organics, hexavalent chromium,
cyanide fluoride, sulfide, and the remaining classes of organics
(organochlorine pesticides, phenoxyacetic acid herbicides,
organophosphorous insecticides, PCBs, and dioxins and furans). EPA does
not expect any of these constituents to be present in treatable
quantities.
6-3
-------
2195g
Table 6-1 Status of BOAI List Constituent Presence
in Untreated K071 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
Aero le in
Aery Ion itri le
Benzene
Bromod ich loromet hane
Bromomethane
n-Butyl alcohol
Carbon tetrachloride
Carbon disulfide
Chlorobenzene
2-Ch loro- 1 . 3-butad iene
Ch lorod i bromomet hane
Chloroe thane
2-Chloroethyl vinyl ether
Chloroform
Chloromc thane
3 Chloropropene
l,2-Dibromo-3-chloropropane
1.2-Dibronnethane
Oibrononethane
trans- 1,4-Dich loro- 2 -butene
D i ch lorod i f luoromet hane
1, 1-Oichloroethane
1,2-Dichlorocthane
1.1-Oichloroethylene
trans-1.2-0ichloroethene
1 . 2-0 ich loropropdne
trans- 1 . 3-0 ich loropropene
cis-l,3-Dichloropropene
1,4-Dioxane
2-Ethoxyethanol
Ethyl acetate
Ethyl benzene
Ethyl cyanide
Ethyl ether
Ethyl methacrylate
Ethylene oxide
lodomethane
Isobutyl alcohol
Hethanol
Methyl ethyl ketone
Detection Believed to
status3 be present
NA
NA
NA
NA
ND
0.062
ND
NA
ND
ND
ND
NA
0.170
ND
ND
0.200
ND
NA
NA
NA
NA
NA
NA
ND
NO
ND
NO
ND
ND
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
6-4
-------
2195g
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.
Const ituent
Volatile orqanics (continued)
Methyl isobutyl ketone
Methyl met hacry late
Methacrylonitrile
Methylene chloride
2-Nitropropane
Pyridine
1,1,1. 2-Tetrach loroethane
1,1,2,2-Ietrachloroethane
Tetrachloroethcne
Toluene
Tribrocnomethane
1,1, 1-Tr ich loroethane
1 . 1 , 2-Tr ich loroethane
Trichloroethene
Trichloromonof luoromethane
1 ,2,3-Trich loropropane
1.1.2-Trichloro-1.2.2-
trif luoroethane
Vinyl chloride
1.2-Xylene
1.3-XyIene
1.4-Xylene
Semi void I i le orqanics
Acenaphthalene
Acenaphthene
Acetophenone
2 - Acety lam i nof luorene
4-Aminobiphenyl
Ani line
Anthracene
Aramite
Benz(a)anthracene
Benzal chloride
Benzenethiol
Deleted
Benzo(a)pyrene
Benzo(b) f luoranthene
Benzo(gh i )pery lene
Benzo(k)f luoranthene
p-Benzoquinone
Detection Believed to
status be present
NA
NA
NA
NO
NA
NA
NA
NO
NO
ND
0.550
ND
ND
ND
NA
NA
NA
ND
ND
ND
ND
ND
ND
NA
NA
NA
NA
ND
NA
ND
NA
NA
NO
ND
NO
ND
NA
6-5
-------
Z195g
Table 6-1 (Continued)
BOAT
reference
no.
67.
68.
69.
70.
71.
72.
73.
74.
75.
76.
77.
78.
79.
80.
ai.
82.
232.
83.
84.
85.
86.
U7.
88.
89.
90.
91.
92.
93.
94.
95.
96.
97.
98.
99.
100.
101.
102.
103.
104.
105.
106.
219.
Constituent
Semivolatile orqanics (continued)
Bis(2-chloroethoxy)methane
Bis(2-chloroethyl)ether
B is(2-ch loro isopropy 1 ) ether
Bis(2-ethylhcxyl)phthalate
4-Bromophenyl phenyl ether
Butyl benzyl phthalate
2-sec-Buty 1-4 . 6-d in i tropheno 1
p-Chloroani line
Chlorobenzi late
p-Chloro-m-cresol
2-Ch loronaphtha lene
2-Chlorophenol
3-Chloropropionitrile
Chrysene
ortho-Cresol
para-Cresol
Cyc lohexanone
Dibenz( a, h (anthracene
Dibenzo(a,e)pyrene
Dibenzofa, i)pyrene
m-Oichlorobenzene
o-Oichlorobenzene
p-Oichlorobenzene
3,3'-Dichlorobenzidine
2 , 4 -0 ich loropheno 1
2.6-Dichlorophenol
Diethyl phthd late
3 , 3 ' -D imethoxybenz id ine
p-Oimethylaminoazobenzene
3,3' -Dimethylbenz idine
2.4-Oimethy 1 phenol
Dimethyl phthalate
Di-n-butyl phthalate
1.4-Oinitrobenzene
4,6-Dinitro-o-cresol
2.4-Oinitrophenol
2.4-Dinitrotoluene
2.6-Dinitrotoluene
Di-n-octyl phthalate
Oi-n-propylnitrosamine
Di phenyl am ine
0 i pheny 1 n i t rosam i ne
Detection Believed to
status3 be present
ND
NO
ND
ND
ND
ND
NA
ND
NA
NA
ND
ND
NA
ND
NA
NA
NA
ND
NA
NA
NO
ND
ND
ND
ND
NA
ND
NA
NA
NA
ND
ND
ND
NA
NA
ND
ND
ND
ND
NA
NA
NA
6-6
-------
219bg
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
Semivolati le ornanics (continued)
1.2-Oiphenylhydrazine
F luoranthene
Fluorcne
Hexach lorobenzene
llexach lorobu tad i ene
Hexachlorocyc lopentadiene
Hexach loroethano
Hexach lorophene
Hexach loropropene
lndeno(l,2,3-cd)pyrene
Isosafrole
Methapyri lene
3-Methylcholanthrene
4,4' -Methy leneb is
(2-chloroani 1 ine)
Methyl methanesulfonate
Naphthalene
1 . 4-Naphthoqu inone
1-Naphthylamine
2-Naphthylamine
p-Nitroaniline
Nitrobenzene
4-N itrophenol
N-Nitrosodi-n-butylamine
N-Nitrosodiethylamine
N-Nitrosodimethylamine
N-N i trosomethy lethy lam i tie
N - N i t rosomorpho 1 i ne
N-Nitrosopiperidine
n-N i trosopyrro 1 id ine
5-Nitro-o-toluidine
Pentach lorobenzene
Pentachloroethane
Pentach loron i t robenzene
Pentach loropheno 1
Phenacet in
Phenanthrene
Phenol
Phtha 1 ic anhydr ide
2-Picoline
Pronamide
Pyrene
Resorcinol
Detection Believed to
status3 be present
NA
NO
NO
NO
NO
NO
NO
NA
NA
NO
NA
NA
NA
NA
NA
ND
NA
NA
NA
ND
NO
ND
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
ND
NA
ND
ND
NA
NA
NA
ND
NA
6-7
-------
2195g
Table 6-1 (Continued)
BOAT
reference
no.
147.
148.
149.
150.
151.
152.
153.
154.
155.
156.
15/.
158.
159.
221.
160.
161.
162.
163.
164.
165.
166.
167.
168.
169.
170.
171.
172.
173.
174.
175.
Constituent
Semivolatile organ ics (continued)
Safrole
1.2,4. 5-Tetrach lorobenzene
2.3.4. 6-Tetrach loropheno 1
1, 2. 4-Trich lorobenzene
2,4,5-Trichloropheno)
2, 4. 6-Trich loropheno 1
Tris(2.3-dibromopropyl)
phosphate
Metals
Ant imony
Arsenic
Barium
Beryl Hum
Cadmium
Chromium (total)
Chromium (hexavalent)
Copper
Lead
Mercury
Nickel
Selenium
S i Ivcr
Thallium
Vanadium
Zinc
Inorqanics other than mntals
Cyan ide
Fluoride
Sulfide
Orqanochlor ine pesticides
Aldrin
alpha-BHC
beta-BHC
delta-BHC
Detection Believed to
statusa be present
NA
NA
NA
ND
NO
NO
NA
10
NO Y
0.57-1.4
NO
3.8
5.9
NA
184.7
47.8
1.12-172.8
3.15-90.3
ND Y
ND Y
7.74-<43
ND
2.29-128.0
NA
NA
NA
NA
NA
NA
NA
6-8
-------
2195g
lable 6-1 (Continued)
BOAT
reference
no.
Detection Believed to
Constituent status3 be present
Organochlorine nest icicles (continued)
176.
17/.
178.
179.
180.
181.
182.
183.
184.
lUb.
186.
187.
188.
189.
190.
191.
192.
193.
194.
195.
196.
197.
198.
199.
200.
201.
202.
203.
204.
205.
206.
ganma-BIIC
Chlordane
ODD
ODE
DDT
Dieldrin
Endosulfan I
Endosulfan II
Endrin
tndnn aldehyde
Heptachlor
Heptachlor epoxide
Isodrin
Kepone
Methoxyc lor
Toxaphene
Phenoxyacet ic acid herbicides
2,4-Dichlorophenoxyacetic acid
Silvex
2.4.5-T
Orqnnophosphorous insecticides
Disulfoton
Fampnur
Methyl parathion
Parathion
Phorate
PCBs
Aroclor 1016
Aroclor 1221
Aroclor 1232
Aroclor 1242
Aroclor 1248
Aroclor 1254
Aroclor 1260
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
6-9
-------
2195g
Table 6-1 (Continued)
BOAT
reference Constituent
no.
Detection
status3
Believed to
be present
207.
208.
209.
210.
211.
212.
213.
Dioxins and furans
Hexachlorodibenzo-p-dioxins
Hexach lorod iberuof urans
Pentachlorodibenzo-p-dioxins
Pentachlorodibenzofurans
letrachlorodibenzo-p-dioxins
Tetrachlorodibenzofurans
2.3.7.8-Tetrachlorodibenzo-
p-dioxin
NA
NA
NA
NA
NA
NA
NA
NO = Not detected.
NA - Not analyzed.
X = Believed to be present based on engineering analysis of the
waste generating process.
Y = Believed to be present based on detection in treated residuals.
If detected, concentrations arc shown; units are mg/kg.
6-10
-------
7. CALCULATION OF BOAT TREATMENT STANDARDS
This section details the calculation of treatment standards for the
regulated constituent, mercury, selected in Section 6.
For nonwastewater, EPA is setting a treatment standard based on
performance data from treatment by acid leaching followed by chemical
oxidation and then sludge dewatering/acid washing. As discussed in
Section 5, the Agency has 371 data points from this BOAT that the Agency
believes reflect treatment in well-designed and well-operated systems.
As these data are also accompanied by sufficient QA/QC information, they
meet the requirements for setting treatment standards.
For wastewater, the treatment standard is based on performance data
from chemical precipitation, using sulfide as the treatment chemical, and
filtration. The Agency has three data points from chemical precipitation
and filtration that reflect a well-designed and well-operated system, are
accompanied by sufficient QA/QC information, and thus meet the
requirements for setting treatment standards.
As discussed in Section 1, the calculation of a treatment standard
involves (1) adjusting the data points for accuracy, (2) determining the
arithmetic average and variability factor for the data points, and
(3) multiplying the average and variability factor together to determine
the treatment standard.
The data from both the nonwastewater and wastewater BDATs were
adjusted in Section 5 prior to determining BOAT (see Tables 5-1 and
5-4). The accuracy-corrected data, as well as the averages of the
7-1
-------
values, variability factors, and treatment standards, are presented in
Tables 7-1 and 7-2.
7-2
-------
1412g
Table 7-1 Calculation of Nonwastewater Treatment Standard for Mercury in K071 Waste
Using Performance Data from Acid Leaching Followed by Chemical.
Oxidation and Then Sludge Dewatering/Ac id Washing
Sample
Data source no.
Plant A.I 1
2
3
4
5
6
7
Plant A. 2 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
Accuracy-corrected TCLP Treatment
or EP concentration Variability standard3
(mg/1) Average factor (mg/1)
0.0003 0.0043 5.47 0.025
<0.0002
-
0.0002
0.0005
0.0017
<0.0002
-
-
0.008
-
<0.002
-0.002
0.007
0.002
<0.002
0.012
0.003
0.004
0.002
-0.002
'-0.002
<0.002
0.001
0.003
<0.001
<0.002
<0.002
'0.002
<0.002
<0.002
<0.001
<0.001
<0.002
<0.002
<0.002
<0.001
Note that the treatment standard will be enforced using the TCLP. The value for the treatment
standard was rounded to two significant figures at the end of the calculation.
7-3
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 31
32
33
34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
Accuracy-corrected TCLP
or EP concentration
(mg/1)
0.002
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
0.002
0.001
0.002
0.001
0.009
<0.001
0.012
0.001
<0.001
-
-
-
-
-
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
=0.001
<0.001
7-4
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 71
72
73
74
75
76
77
78
79
80
61
82
83
84
85
86
87
88
89
90
91
92
93
94
95
96
97
98
99
100
101
102
103
104
105
106
107
108
109
110
Accuracy-corrected TCLP
or EP concentration
(mg/1)
<0.001
<0.001
<0.001
0.001
0.004
<0.001
0.001
0.001
0.004
<0.001
<0.001
<0.001
-
-
0.008
<0.001
0.001
0.001
0.007
-
<0.001
0.006
0.005
0.009
0.001
0.002
<0.001
0.002
0.002
0.004
0.002
0.002
0.001
0.001
0.001
0.005
0.005
0.003
0.003
0.002
7-5
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 111
112
113
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
143
144
145
146
147
149
150
151
Accuracy-corrected TCLP
or EP concentration
(mg/1)
<0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.001
-
<0.001
0.003
0.006
<0.001
0.002
<0.001
<0.001
0.002
<0.001
<0.001
<0.001
0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.003
0.003
0.001
0.006
0.003
<0.001
0.001
<0.001
<0.001
<0.002
0.003
7-6
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 152
153
154
155
156
157
158
159
160
161
162
163
164
165
166
167
168
169
170
171
172
173
174
175
176
177
178
179
180
181
182
183
184
185
186
187
188
189
190
191
Accuracy-corrected TCLP
or EP concentration
(mg/1)
-
-
0.002
<0.001
<0.001
<0.001
<0.001
0.001
-
-
-
0.011
<0.001
<0.001
-
0.008
0.007
<0.001
<0.001
-
-
-
0.006
0.007
0.001
<0.001
-
0.004
0.008
0.005
0.003
0.001
0.005
0.007
0.002
-
0.010
0.001
0.008
7-7
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 192
193
194
195
196
197
198
199
200
201
202
203
204
205
206
207
208
209
210
211
212
213
214
215
216
217
218
219
220
221
222
223
224
225
226
227
228
229
230
231
Accuracy-corrected TCLP
or EP concentration
(mg/1)
0.005
0.012
0.002
0.002
-
0.040
-
0.011
-
0.032
0.031
0.014
0.003
0.003
0.012
0.008
0.002
0.007
0.005
0.003
0.012
0.004
0.004
<0.001
0.010
<0.001
0.002
-
0.010
0.010
0.005
0.002
0.002
0.002
0.005
-
0.001
0.003
0.068
0.003
7-8
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 232
233
234
235
236
237
238
239
240
241
242
243
244
245
246
247
248
249
250
251
252
253
254
255
256
257
258
259
260
261
262
263
264
265
266
267
268
269
270
271
Accuracy-corrected TCLP
or EP concentration
(mg/1)
<0.001
0.009
0.009
0.005
0.005
0.003
0.002
0.008
0.002
0.008
0.032
0.012
0.011
0.003
0.006
0.028
0.003
0.001
0.006
<0.001
<0.001
<0.001
0.001
0.003
0.006
0.002
0.001
0.010
0.006
0.005
0.011
0.007
0.011
0.002
-
0.004
0.021
0.005
0.003
-
7-9
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 272
273
274
275
276
277
278
279
280
281
282
283
284
285
286
287
288
289
290
291
292
293
294
295
296
297
298
299
300
301
302
303
304
305
306
307
308
309
310
311
Accuracy-corrected TCLP
or EP concentration
(mg/1)
0.009
0.004
0.004
-
0.008
0.002
0.001
<0.001
<0.001
<0.001
0.001
0.006
0.004
0.010
0.002
0.003
0.004
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
<0.001
0.008
<0.001
0.001
0.008
0.001
0.001
0.003
<0.001
0.002
<0.001
<0.001
<0.001
7-10
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 312
313
314
315
316
317
318
319
320
321
'322
323
324
325
326
327
328
329
330
331
332
333
334
335
336
337
338
339
340
341
342
343
344
345
346
347
348
349
350
351
352
353
Accuracy-corrected TCLP
or EP concentration
(mg/1)
<0.001
0.002
0.008
0.003
0.005
<0.001
<0.001
<0.001
<0.001
0.004
0.001
0.002
0.001
<0.001
<0.001
0.001
0.002
<0.001
0.002
<0.001
0.004
0.004
<0.001
-
0.001
0.001
=0.001
<0.001
<0.001
<0.001
<0.001
0.001
0.001
0.001
0.001
<0.001
0.001
0.001
<0.001
0.003
<0.001
<0.001
7-11
-------
1412g
Table 7-1 (Continued)
Sample
Data source no.
Plant A. 2 354
355
356
357
358
359
360
361
362
363
364
365
366
367
368
369
370
371
372
373
374
375
376
377
378
379
Plant B 1
2
3
4
5
6
7
8
9
10
11
12
13
Accuracy-corrected TCLP
or EP concentration
(mg/D
0.004
0.008
0.001
0.001
<0.001
0.008
<0.001
<0.001
0.004
0.002
0.001
-0.001
<0.001
<0.001
0.001
<0.001
<0.001
<0.001
<0.001
0.001
<0.001
<0.001
0.001
0.003
0.011
0.002
0.0047
0.0208
0.0054
0.0030
0.0096
0.0092
0.0085
0.0175
0.0164
0.0098
0.0140
0.0113
0.0131
7-12
-------
1412g
Table 7-1 (Continued)
Data source
Plant B
Sample
no.
14
15
16
17
18
19
Accuracy-corrected TCLP
or EP concentration
(mg/1)
0.0710
0.0480
0.0090
0.0020
0.0661
0.0087
aNote that the treatment standard will be enforced using the TCLP. The value for the treatment
standard was rounded to two significant figures at the end of the calculation.
7-13
-------
1412g
Table 7-2 Calculation of Wastewater Treatment Standard for Mercury
in K071 Waste Using Performance Data from
Chemical Precipitation and Filtration
Data source
Plant A.I
Sample
no.
1
2
3
Accuracy-corrected
total concentration
(mg/1) Average
0.0295 0.0291
0.0284
0.0295
Treatment
Variability standard3
factor (mg/1)
1.05 0.030
The value for the treatment standard was rounded to two significant figures at the end of the
calculation.
7-14
-------
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 K071 waste. The technical project officer for the waste was
Mr. John Keenan. Mr. Steven Silverman served as legal advisor.
Versar personnel involved in the preparation of this document
included Mr. Jerome Strauss, Program Manager; Mr. Mark Donnelly,
Engineering Team Leader; Ms. Justine Alchowiak, Quality Assurance
Officer; Mr. David Pepson, Senior Technical Reviewer; Ms. Olenna
Truskett, Technical Reviewer; Mr. Fouad Mohamed, Statistician;
Ms. Barbara Malczak, Technical Editor; and the Versar secretarial staff,
Ms. Linda Gardiner and Ms. Mary Burton.
Field sampling for data collected by EPA at Plant A was conducted
under the leadership of Mr. William Shaughnessy of Versar; laboratory
coordination was provided by Mr. Jay Bernarding, also of Versar.
We greatly appreciated the cooperation of the Chlorine Institute Inc.
and the individual companies that permitted their plants to be sampled
and that submitted detailed information to the U.S. EPA.
8-1
-------
9. REFERENCES
Ajax Floor Products Corp. n.d. Product literature: technical data
sheets, hazardous waste disposal system. P.O. Box 161, Great Meadows,
N.J. 07838.
Austin, G.T. 1984. Shreve's chemical process industries, 5th ed.
New York: McGraw-Hill.
Bennett, B.L. 1986. Memorandum from B.L. Bennett, Plant Manager,
Stauffer Chemical Company, St. Gabriel, La., to Jim Berlow, USEPA,
Office of Solid Waste. Mercury analysis values for treatment of K071
waste by a dewatering/water washing treatment system, November 12, 1986.
B.F. Goodrich. 1988. Comments on land disposal restrictions for First
Third of scheduled wastes, proposed rule. Submitted to EPA RCRA Docket
F-88-LDR7-FFFFF. Comment No. LDRU-L0011. Washington, D.C.: U.S.
Environmental Protection Agency.
Bishop, P.L., Ransom, S.B., and Grass, D.L. 1983. Fixation mechanisms
in solidification/stabilization of inorganic hazardous wastes. In
Proceedings of the 38th Industrial Waste Conference. 10-12 May 1983. at
Purdue University, West Lafayette, Indiana.
Cherry, K.F. 1982. Plating waste treatment, pp. 45-67. Ann Arbor,
Mich.: Ann Arbor Science, Inc.
Conner, J.R. 1986. Fixation and solidification of wastes. Chemical
Engineering Nov. 10, 1986.
Cullinane, M.J., Jr., Jones, L.W., and Malone, P.G. 1986. Handbook for
stabilization/solidification of hazardous waste. U.S. Army Engineer
Waterways Experiment Station. EPA Report no. 540/2-86/001. Cincinnati,
Ohio: U.S. Environmental Protection Agency.
Cushnie, G.C., Jr. 1985. Electroplating wastewater pollution control
technology, pp. 48-62, 84-90. Park Ridge, N.J.: Noyes Publications.
1984. Removal of metals from wastewater: neutralization and
precipitation, pp. 55-97. Park Ridge, N.J.: Noyes Publications.
Electric Power Research Institute. 1980. FGD sludge disposal manual,
2nd ed. Prepared by Michael Baker Jr., Inc. EPRI CS-1515 Project
1685-1. Palo Alto, Calif.: Electric Power Research Institute.
Kirk-Othmer. 1980. Encyclopedia of chemical technology. 3rd ed.,
Vol. 10. New York: John Wiley and Sons.
9-1
-------
Mishuck, E., Taylor, D.R., Telles, R., and Lubowitz, H. 1984.
Encapsulation/fixation (E/F) mechanisms. Report No. DRXTH-TE-CR-84298.
Prepared by S-Cubed under Contract No. DAAK11-81-C-0164.
Occidental Chemical Corporation. 1987a. Delisting petition for NaCl
brine purification muds (K071). Submitted by Occidental Chemical
Corporation, Delaware City, Delaware. Washington, D.C.: U.S.
Environmental Protection Agency, Office of Solid Waste.
Occidental Chemical Corporation. 1987b. Delisting petition for inorganic
waste stream K071: brine purification muds. Submitted by Occidental
Chemical Corporation, Muscle Shoals plant, Sheffield, Alabama.
Washington, D.C.: U.S. Environmental Protection Agency, Office of
Solid Waste.
01 in Chemicals. 1988. 01 in Corporation comments on the proposed land
disposal restrictions for the First Third of scheduled waste.
Submitted to EPA RCRA Docket F-88-LDR7-FFFFF. Comment No. LDR7-00055.
Washington, D.C.: U.S. Environmental Protection Agency.
Perry, R.H. and Chilton, C.H. 1973. Chemical engineers' handbook.
5th ed. Sec. 19. New York: McGraw Hill Book Co.
Pojasek, R.B. 1979. Sol id-waste disposal: Solidification. Chemical
Engineering 86(17):141-145.
SRI. 1987. Stanford Research Institute. 1987. Directory of chemical
producers - United States of America. Menlo Park, Calif.: Stanford
Research Institute.
USEPA. 1980. U.S. Environmental Protection Agency. U.S. Army Engineer
Waterways Experiment Station. Guide to the disposal of chemically
stabilized and solidified waste. Prepared for MERL/ORD under
Interagency Agreement No. EPA-IAG-D4-0569. PB81-181505.
Cincinnati, Ohio: U.S. Environmental Protection Agency.
USEPA. 1983. Treatabilitv manual. Vol. Ill, Technology for
control/removal of pollutants, pp. 111.3.1.3-2. EPA-600/2-82-001c,
January 1983.
USEPA. 1986a. U.S. Environmental Protection Agency, Office of Solid
Waste. Summary of available waste composition data from review of
literature and data bases for use in treatment technology application
and evaluation for "California list" waste streams. Final report.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1986b. U.S. Environmental Protection Agency, Office of Solid
Waste and Emergency Response. Test methods for evaluating solid
waste. 3rd ed. Washington, D.C.: U.S. Environmental Protection
Agency. November 1986.
9-2
-------
USEPA. 1986c. U.S. Environmental Protection Agency. Hazardous waste
management systems; land disposal restrictions; Final Rule; Appendix
I to Part 268 - Toxicity Characteristic Leaching Procedure (TCLP).
51 FR 40643, November 7, 1986.
USEPA. 1987a. U.S. Environmental Protection Agency, Office of Solid
Waste. Computer printout: Data on management of K071 wastes from
HWDMS data base. Retrieved January 16, 1987. Washington, D.C.:
U.S. Environmental Protection Agency.
USEPA. 1987b. U.S. Environmental Protection Agency, Office of Solid
Waste. Engineering analysis for production of chlorine and sodium or
potassium hydroxide by the mercury cell process. Final report.
Washington, D.C.: U.S. Environmental Protection Agency.
USEPA. 1988a. U.S. Environmental Protection Agency, Office of Solid
Waste. Onsite engineering report of treatment technology performance
and operation for Vulcan Materials Company, Port Edwards, Wisconsin.
Final report. Washington, D.C.: U.S. Environmental Protection
Agency.
USEPA. 1988b. U.S. Environmental Protection Agency, Office of Solid
Waste. Sampling and analysis plan for Vulcan Materials Company, Port
Edwards, Wisconsin. Final report. Washington, D.C.: U.S.
Environmental Protection Agency.
9-3
-------
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
ni = degrees of freedom for numerator
n» = degrees of freedom for denominator
(shaded area = .96)
r.M
^
1
2
3
4
5
6
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
1
<
161.4
18.51
10.13
7.71
6.61
5.99
5.59
5.32
5.12
4.96
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
4.26
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
2.65
2.62
2.60
4
224.6
19.25
9.12
6.39
5.19
4.53
4.12
3.84
3.C3
3.48
3.36
3.26
3.18
3.11
3.06
3.01
2.96
2.93
2.90
2.87
2.82
2.78
2.74
2.71
2.69
2.61
2.56
2.53
2.50
2.48
2.46
2.43
2.41
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
2J27
2.26
2^3
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
2JZ9
2^5
2J23
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
2JI9
2JI7
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
1.75
16
246.3
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
2^9
*t oe
2JJ1
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
2.25
2.20
2.15
2.11
2.07
2.04
1.98
1.94
1.90
1.87
1.84
1.74
1.69
1.65
1.62
1.60
1.57
1.54
1.52
1.49
1.46
40
251.1
19.46
8.60
5.71
4.4C
3.77
3.34
3.05
2.82
2.67
2.53
2.42
2.34
2J!7
n *>j
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
1.45
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
2^4
2.18
2.13
2.08
2.04
2.00
1.96
1.91
1.86
1.82
1.78
1.76
1.66
1.60
1.56
1.53
1.51
1.48
1.44
1.42
1.38
1.32
100
253.0
19.49
8.56
5.66
4.40
3.71
3.28
2.98
2.76
2.59
2.45
2.35
2.26
2.19
2.12
2.07
2.02
1.98
1.94
1.90
1.84
1.80
1.76
1.72
1.69
1.59
1.52
1.48
1.45
1.42
1.39
1.34
1.32
1.28
1.24
m
25-i.S
19.50
8.53
5.63
4.3C
3.67
3.23
2.93
2.71
2.5;
2.40
2.30
2.21
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:
,U^ll-[(*"
11 In.)
SSB =
where:
k = number of treatment technologies
n^ = number of data points for technology i
N = number of data points for all technologies
Ti = sum of natural logtransformed data points for each technology.
(iv) The sum of the squares within data sets (SSW) is computed:
k ni o
SSW= £ _Ii X21tj
where:
k
- I
n
i = 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
Hethylene Chloride
Steam stripping
Influent Effluent
(M9/D
1SSO.OO
1290.00
1640.00
5100.00
1450.00
4600.00
1760.00
2400.00
4800.00
12100.00
(M9/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(eff luent)]2 Influent Effluent ln(ef fluent)
2.30
2.30
2.30
2.48
2.30
2.30
2.30
2.30
2.30
2.30
Ug/D Ug/D
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
Variability factor:
10
2.32
.06
2378
923.04
1.15
13.2
7.15
2.48
2.49
.43
ANOVA Calculations:
SSB =
SSW =
MSB = SSB/(k-l)
MSW = SSW/(H-k)
A-5
-------
1790g
Example 1 (Continued)
F = HSB/NSW
where:
k - number of treatment techno log ies
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
i
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
SSB - *
10 5
1270.21
15
= 0.10
SSM - (53.76 01.79) .
10
= 0.77
MSB = 0.10/1 = 0.10
MSW = 0.77/13 - 0.06
F . °_^_ =1.67
0.06
ANOVA Table
Degrees of
Source freedom
Between(B) 1
Withm(W) 13
SS MS F value
0.10 0.10 1.67
0.77 0.06
The critical value of the F test at the 0.05 significance level is 4.67. Since
the F value is less than the critical value, the means are not significantly
different (i.e.. they are homogeneous).
Note: All calculations 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
Steam stripping Biological treatment
Influent Effluent In(effluent) [ln(effluent)]2 Influent Effluent In(effluent)
Ug/1) Ug/i) (^g/D Ug/1)
Sum:
Sample Size:
10 10
26.14
10
72.92
16.59
[In(effluent)]2
1650.00
5200.00
5000.00
1720.00
1560.00
10300.00
210.00
1600.00
204.00
160.00
10.00
10.00
10.00
10.00
10.00
10.00
10.00
27.00
85.00
10.00
2.30
2.30
2.30
2.30
2.30
2.30
2.30
3.30
4.44
2.30
5.29
5.29
5.29
5.29
5.29
5.29
5.29
10.89
19.71
5.29
200.00
224.00
134.00
150.00
484 . 00
163.00
182.00
10.00
10.00
10.00
10.00
16.25
10.00
10.00
2.30
2.30
2.30
2.30
2.79
2.30
2.30
5.29
5.29
5.29
5.29
7.78
5.29
5.29
39.52
Mean:
2760
19.2
Standard Deviation:
3209.6 23.7
VaridbiIity Factor:
3.70
2.61
.71
220
120.5
10.89
2.36
1.53
2.37
.19
ANOVA Calculations:
SSB - -
ssw=i ,ilj?1*
-------
I790g
Example 2 (Continued)
F ' MSB/MSW
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
X - the natural logtransformed observations (j) for treatment technology (i)
ij
N = 10. N - 7. N - 17. k - 2, I - 26.14, f - 16.59. T ^ 42.73. f - 1825.85. T = 683.30,
T = 275.23
SSB
10
SSW = (72.92 + 39.52) -
MSB - 0.25/1 = 0.25
HSU = 4.79/15 = 0.32
1825.B5
17
683.30 2/5.23
f
^^^M~^__ ^^K-ta«
10 7
. = 0.25
= 4.79
=0.78
0.32
ANOVA Table
Degrees of
Source freedom
Between(B) 1
Uithin(U) 15
SS
0.25
4.79
HS F value
0.25 0.78
0.32
Ihe 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
-------
I790q
Example 3
Chlorobenzene
Activated sludge followed by carbon adsorption
Biological treatment
Influent
Ug/D
Effluent
Ug/1)
In(effluent) [ln(effluent)] Influent
Effluent
Ug/D
In(effluent) ln[(effluent)]2
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 4
Mean:
5703
49
Standard Deviation:
1835.4 32.24
VariabiIily Factor:
7.00
14.49
3.62
.95
55.20
14759
16311.86
452.5
379.04
15.79
38.90
5.56
1.42
228.34
ANOVA Calculations:
SSB -
SSW = [ j?i j=i x '-J
MSB = SSB/(k-l)
MSW = SSW/(N-k)
K = MSB/MSW
4^
J "«-i l~J
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)
U
N = 4, N = 7. N = 11. k = 2. T = 14.49. T = 38.90. T = 53.39, T = 2850.49. T = 209.96
= 1513.21
[209.96 1513.21
2850.49
11
- 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
Bctwccn(B)
Within(U)
1
9
9.53
14.89
9.53
1.65
5.77
The critical value of the F test at the 0.05 significance level is 5.12. Since
the F value is larger than the critical value, the means are significantly
different (i.e., they are heterogeneous). Activated sludge followed by carbon
adsorption is "best" in this example because the mean of the long-term performance
value, i.e.. the effluent concentration, is lower.
Note: All calculations were rounded to two decimal places. Results may differ depending
upon the number of decimal places used in each step of the calculations.
A-10
-------
A.2 Variability Factor
C99
VF = Mean
where:
VF = estimate of daily maximum variability factor determined
from a sample population of daily data;
Cgg = estimate of performance values for which 99 percent of the
daily observations will be below. Cgq is calculated
using the following equation: Cgg = Exp(y + 2.33 Sy)
where y and Sy are the mean and standard deviation,
respectively, of the logtransformed data; and
Mean = average of the individual performance values.
EPA is establishing this figure as an instantaneous maximum because
the Agency believes that on a day-to-day basis the waste should meet the
applicable treatment standards. In addition, establishing this
requirement makes it easier to check compliance on a single day. The
99th percentile is appropriate because it accounts for almost all process
variability.
In several cases, all the results from analysis of the residuals from
BOAT treatment are found at concentrations less than the detection
limit. In such cases, all the actual concentration values are considered
unknown and, hence, cannot be used to estimate the variability factor of
the analytical results. Below is a description of EPA's approach for
calculating the variability factor for such cases with all concentrations
below the detection limit.
It has been postulated as a general rule that a lognormal
distribution adequately describes the variation among concentrations.
Agency data show that the treatment residual concentrations are
A-ll
-------
distributed approximately lognormally. Therefore, the lognormal model
has been used routinely in the EPA development of numerous regulations in
the Effluent Guidelines program and is being used in the BOAT program.
The variability factor (VF) was defined as the ratio of the 99th
percentile (C ) of the lognormal distribution to its arithmetic mean
(Mean), as follows:
VF = C99. (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 (^) and standard deviation (a) of the normal distribution as
follows:
C9g = Exp (M + 2.33a) (2)
Mean = Exp (M + 0.5o2). (3)
By substituting (2) and (3) in (1), the variability factor can then
be expressed in terms of a as follows:
VF = Exp (2.33 a - 0.5a2). (4)
For residuals with concentrations that are not all below the
detection limit, the 99th percentile and the mean can be estimated from
the actual analytical data and, accordingly, the variability factor (VF)
can be estimated using equation (1). For residuals with concentrations
A-12
-------
that are below the detection limit, the above equations can be used in
conjunction with the following assumptions to develop a variability
factor.
Assumption 1: The actual concentrations follow a lognormal
distribution. The upper limit (UL) is equal to the detection
limit. The lower limit (LL) is assumed to be equal to one-tenth
of the detection limit. This assumption is based on the fact that
data from well-designed and well-operated treatment systems
generally fall within one order of magnitude.
Assumption 2: The natural logarithms of the concentrations have
a normal distribution with an upper limit equal to In (UL) and a
lower limit equal to In (LL).
Assumption 3: The standard deviation (o) of the normal
distribution is approximated by:
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 Evaluating Solid Waste; Physical/Chemical
Methods, SW-846. Third Edition, November 1986) are used in most cases for
determining total constituent concentrations. Leachate concentrations
are to be determined using the Toxicity Characteristic Leaching Procedure
(TCLP), published in 51 FR 40643, November 7, 1986.
SW-846 allows for the use of alternative or equivalent procedures or
equipment; these are noted in Table B-2. These alternatives or
equivalents included use of alternative sample preparation methods and/or
use of different extraction techniques to reduce sample matrix
interferences.
The accuracy determination for a constituent is based on the matrix
spike recovery values. Tables B-3 and B-4 present the matrix spike
recoveries for mercury for both total composition and TCLP analyses for
K071 residuals for the EPA-collected data. Matrix spike recoveries for
total composition, TCLP, and EP toxicity analyses for data submitted by
Plants A and B are presented in Tables B-5 through B-8.
The accuracy-correction factors for mercury for each treatment
residual are summarized in Tables B-3 through B-8. The accuracy-
correction factors were determined in accordance with the general
methodology presented in the Introduction. For example, for mercury,
B-l
-------
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
0.0016 mg/1 95 ip_0 _ j 05 1.05 x 0.0016 = 0.0017 mg/1
95
B-2
-------
10341
Table B-l Analytical Methods for Regulated Constituents
Const ituent
Extract ion method
Analytical method
Reference
Mercury, total
concentration
Specified in analytical method
Mercury in Liquid Waste
(Manual Cold-Vapor Technique)
7470
References:
Specified in analytical method
Mercury in Solid or Semisolid 7471
Waste (Manual Cold-Vapor Technique)
Mercury. TCLP
leachate
Toxicity Characteristic Leaching
Procedure (TCLP)
51 FR 40643
CD
I
CO
Specified in analytical method
Mercury in Liquid Waste
(Manual Cold-Vapor Technique)
7470
(1) USEPA 1986b.
(2) USEPA 1986c.
-------
0341g
Table B-2 Specific Procedures or Equipment Used in Mercury Analysis
When Alternatives or Equivalents Are Allowed in the SW-846 Methods
Constituent
Mercury
Ana lysis
Method Equipment
7470 Perk in Elmer SOA
7471
Alternatives or equivalents
allowed by SW-846 method
Operate equipment according to
instructions by instrument manufacturer.
Specific procedures
or equipment used
Equipment was operated using
procedures specified in Perk in
Elmer 50A Instructions Manual.
Use cold vapor apparatus as described Mercury was analyzed by cold-vapor
in SW-846 or an equivalent apparatus. method using the apparatus as
specified in SW-64G, except that there
was no scrubber.
Prepare samples using the water Samples were prepared using the water
bath method or the autoclave method. bath method.
both described in SW-B46.
Reference: USEPA 19a«a. Table 6-7.
B-4
-------
Table 6-3 Matrix Spike Recoveries for Solid Waste Matrix - Plant A.I
CD
i
en
BOAT
const ituent
Mercury
Original amount
found (mg/kg)
1.1
Sample result Duplicate result
Spike added Spike result Percent Spike added Spike result Percent
(mg/kg) (mg/kg) recovery (mg/kg) (mg/kg) recovery
2.0 3.6 125 2.0 3.7 130
Accuracy-
correct ion
factor6
O.OSO
NC = Hot calculable.
a
Percent recovery = [(spike result - original amount)/spike added].
Accuracy-correction factor = 100/percent recovery (using the lowest percent recovery value).
Note: Matrix spike data were obtained from untreated K.071 waste (Sample Set fti).
-------
Table B-4 Matrix Spike Recoveries for Treated 1CLP leachate Nonwastewater and Wastewater - Plant A.I
Sample Set *6 Sample Set <<6 duplicate
BOAT Original amount Spike added Spike result Percent Spike added Spike result Percent
constituent found (ug/1) (ug/1) (ug/1) recovery*3 (ug/1) (ug/1) recovery
Mercury 1.6 4.0 5.4 95 4.0 5.5 98
Accuracy-
correct ion
factor6
1.05
NC = Not calculable.
aPercent recovery = [(spike result - original amount)/spike added].
Accuracy-correction factor = 100/percent recovery (using the lowest percent recovery value).
Reference: USEPA 1968a. Table 6-16.
CD
-------
0341g
Table B-5 Matrix Spike Recoveries for Treated Residual - Plant C
Sample result
BOAT Original amount Spike added Spike result Percent
constituent found (mg/kg) (mg/kg) (mg/kg) recovery3
Sample »3:
Mercury 78 0.4 NR 106
Sample »8:
Mercury 92 0.4 NR 88
Accuracy-
correction
factor5
1.0
1.14
NR = Not reported.
aPercent recovery « [(spike result - original amount)/spike added].
Accuracy-correction factor = 100/percent recovery (using the lowest percent recovery value).
Reference: Occidental Chemical Corporation 1987a.
B-7
-------
Table B-6 Matrix Spike Recoveries for Treated Nonwastewater 1CLP and EP Leachates - Plant C
Sample result Duplicate result
BOAT Original amount Spike added Spike result Percent Spike added Spike result
constituent found (ug/1) (ug/1) (ug/1) recovery3 (ug.'l) (ug/1)
Samole *1 - EP Toxicity:
Mercury 13 0.2 NR 124 0.4 NR
Sample *! - TCIP:
Mercury 14 0.2 I1R 95 0.4 NR
Sample *2 - EP loxicity:
Mercury 14 0.2 NR 117 0.4 NR
Sample *3 - EP Toxicit.y:
Mercury 18 0.2 . NR 104 0.4 NR
Sample *4 - EP Toxicity:
CO Mercury 13 0.2 IIR 120 0.4 NR
oo
Sample *5 - EP Toxicity:
Mercury 24 0.2 NR 81 0.4 NR
Sample *6 - EP Toxicity:
Mercury 21 0.2 NR 94 0.4 NR
Sample *7 - EP Toxicity:
Mercury 11 0.2 NR 76 0.4 NR
Samole *8 - EP Toxicity:
Mercury 3.0 0.2 NR 105 0.4 NR
Sample *9 - EP Toxicity:
Mercury
-------
lahle B-6 (Cont inuecl)
BDA1 Original amount Spike added
constituent found (ug/1) (ug/1)
Sample * 11 - £P Toxicit^ :
Mercury 0.7 0.?
Samjjle fl? - [P Toxic it_^:
Mercury <0.5 0.2
Sample >\2 - TCLP:
Mercury <0.5 0.2
Sample result Duplicate result
Spike result Percent Spike added Spike result
(ug/1) recovery0 (ug/1) (ug/1)
NR 106 0.4 IIR
NR 99 0.4 m
NR 90 0.4 IIR
Accuracy-
Percent correction
recovery f actor '
96 1.02
101 1.01
99 1.11
NR = Not reported.
"Percent recovery = [(spike result - original amount)/spike added].
Accuracy-correction factor = 100/percent recovery (using the lowest percent recovery value).
Reference: Occidental Chemical Corporation 1987a.
-------
0341g
Table 8-7 Matrix Spike Recoveries for Treated Residual - Plant D
BOAT Original amount
constituent found (mg/kg)
Sample #11 :
Mercury 4.0
Sample f!9:
Mercury 2.0
Sample *22:
Mercury 1.8
Sample result
Spike added Spike result Percent
(mg/kg) (mg/kg) recovery3
0.4 NR 83
0.4 NR 99
0.4 NR 99
Accuracy-
correct ion
factor6
1.20
1.01
1.01
NR = Not reported.
aPercent recovery = [(spike result - original amount)/spike added].
Accuracy-correction factor = 100/percent recovery (using the lowest percent recovery value).
Reference: Occidental Chemical Corporation 1987b.
B-10
-------
Table B-8 Matrix Spike Recoveries for Treated Nonwastewater EP Leachate - Plant 0
BOAT
const ituent
Sample Set *1 :
Mercury
Sample iet f2:
Mercury
Sample Set *3:
Mercury
Sample iet *4:
Mercury
Sample Set *5:
DO
I Mercury
i
H-»
Sample iet *6:
Mercury
Sample Set *7:
Mercury
Sample iet *'8:
Mercury
Sample iet *9:
Mercury
Sample iet *10:
Mercury
Sample iet *1 1 :
Me re u r y
Sample result
Original amount Spike added Spike result Percent
found (ug/'l) (ug/1) (ug/1) recovery3
<2.0 0.2 IIR 99
<2.0 0.2 UR 106
<5.0 0.2 NR 96
<5.0 0.2 UR US
<5.0 0.2 NR 112
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Table B-8 (Continued)
Sample result
EDAT Original amount Spike added Spike result Percent
constituent found (ug/1) (ug/1) (ug/1) recovery3
Sample Set f\2:
Mercury <5.0 0.2 HR 108
Sample Set f\;.:
Mercury 8.0 0.2 HR 93
Sample Set #14:
Mercury 6.: 0.2 HR 94
Sample Set *15:
Mercury 32 0.2 NR 92
Sample Set #16:
f Mercury 8.0 0.2 NR 89
i
K>
Sample Set #17:
Mercury <2.0 0.2 HR 92
Sample Set #18:
Mercury 9.2 0.2 NR 94
Sample Set #19:
Mercury 13 0.2 NR 80
Sample Set #20:
Mercury 14 0.2 NR 83
Sample Set #21 :
Mercury O.t, 0.2 HR 107
Sample Set r22:
Mercury 'O.1.. 0.2 HR 102
Duplicate result
Spike added Spike result
(ug/1) (ug/1)
0.4 NR
0.4 NR
0.4 NR
0.4 NR
0.4 NR
0.4 NR
0.4 NR
0.4 NR
0.4 NR
0.4 NR
0.4 NR
Accuracy-
Percent correct ion
recovery3 factor3
102 1.0
94 1.08
97 1.06
82 1.22
87 1.15
97 1.09
82 1.22
81 1.25
83 1 : 20
109 1.0
102 1.0
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Table B-8 (Continued)
Sample result
BOAT Original amount Spike added Spike result Percent
constituent found (uc/1) (ug/1) (ug/1) recovery3
Sample Set »?3:
Mercury <0.5 O.Z NR 102
Sample Set *24:
Mercury <0.5 0.? NR 104
Duplicate result Accuracy-
Spike added Spike result Percent correction
(ug/1) (ug/1) recovery3 factor'
0.4 NR 104 1.0
0.4 NR 108 1.0
NR = Hot reported.
Percent recovery = [(spike result - original amount)/spike added].
Accuracy-correction factor = 100/percent recovery (using the lowest percent recovery value).
Reference: Occidental Chemical Corporation 1987b.
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APPENDIX C
COMPARISON OF TCLP AND EP RESULTS FOR MERCURY IN K071
The Agency compared 24 pairs of K071 data consisting of analytical
results for mercury in the leachate from the Toxicity Characteristic
Leaching Procedure (TCLP) and the Extraction Procedure (EP).
The data pairs are as follows:
TCLP leachate EP leachate
mercury concentration (mg/1) mercury concentration (mq/1)
0.0053 0.053
0.026 0.035
0.017 0.042
0.0004 0.0036
0.0002 0.0002
0.0004 0.0002
0.0032 0.0037
<0.0002 0.0002
<0.0002 <0.0002
<0.0002 0.0006
<0.0002 <0.0002
0.0004 <0.0002
0.0006 <0.0002
0.276 0.823
0.270 0.817
0.270 0.737
0.125 0.100
0.0004 <0.0002
<0.0002 <0.0002
<0.0002 <0.0002
22.0 13.4
0.0016 0.0035
0.0023 0.0192
0.0680 0.0910
A statistical comparison of the TCLP data set with the EP data set using
the analysis of variance test indicates that no statistically significant
difference exists between the means of the two data sets. This
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indifference implies that the TCLP and EP are equivalent in their
measurement of mercury.
Calculations were performed using the logtransformed values of the
data, which assumes that the data follow a lognormal distribution. The
test results are provided below:
Degree of Sum of Mean of F Critical
Source freedom squares squares ratio value
Between sets
Within set
Total
(If the F ratio does not exceed the critical value, the data sets are
considered equivalent.)
The t-test for paired data also confirms the conclusion of the
analysis of variance test.
1
46
47
1.8598
522.3669
524.2267
1.8598
11.3558
0.1638 4.02
C-2
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